Class E airspace to Lower to 1500 ft
Airservices Australia is currently consulting on a proposal to lower the limit for Class E airspace between Cairns and Melbourne. This prooposal would have direct impact on many gliding clubs in eastern Australia.
Airservices is currently seeking feedback on this proposal until Monday, 15 February 2021. Members of the gliding community can complete a questionnaire by logging in to Airservices (create an account if you don't have one) at Link to Provide Formal Feedback.
GFA Executive Manager, Operations (EMO) Chris Thorpe has provided information and links.
In summary, this proposal is part of a broader Airspace Modernisation Program being developed by Airservices that seeks to lower the base of Class E controlled airspace between Cairns to Melbourne from a lower limit of 8500 FT AMSL to 1500 FT AGL and replace the existing Class G uncontrolled airspace. This encompasses all areas marked Class E 8500LL on the current charts. It affects many Gliding sites and their Operations.
There are some key elements we need to be aware of and then we are inviting you to provide feedback to Airservices via their website. It is important that individuals provide feedback as your club’s circumstances are different. GFA will also be submitting a high-level feedback directly to Airservices.
Australian Class E airspace has the mandated requirement for a serviceable transponder to be fitted to any aircraft operating in the airspace unless the aircraft does not have an engine driven electrical system capable of powering a transponder, and a serviceable VHF radio capable of ‘Continuous two way’ communications. Members are encouraged to refer to CAO 20.18 and AIP ENR 1.4 for specific information. Pure Gliders are exempt, but Tugs and others are not. Those not exempt will require a fully compliant Transponder to go above 1500AGL at these locations. The new VFR ADS-B (e.g. Sky echo) will not comply.
All Gliders are required to monitor the class E frequency via number of means including one glider monitoring for several gliders in the same area. This proposal would compound this issue for many clubs on the east coast and would include nearly all flights because launches are typically above 1500ft AGL. Arrangements will be needed to monitor the class E frequency and relay any traffic to other Gliders.
GFA is unaware of any safety case presented to industry to increase the amount of Class E airspace. We therefore do not understand the safety benefits of this proposal and cannot evaluate its merits. A safety case to AS/NZS ISO 31000 would be appreciated.
GFA is concerned the duration of consultation phase is not sufficient to provide assurance that equitable access to airspace for all users has been considered.
The cost to Gliding both in equipment and the development of procedures will be considerable if this goes ahead. The cost has not been estimated by the GFA at this stage.
There has been no information communicated at this time that there is any awareness of the cost this proposal imposes on industry, nor recognition of the requirement for a Regulatory Impact Statement to be provided by Airservices and/or CASA to justify to Government that this proposal's cost to industry is reasonable. Members are encouraged to refer to the Office of Best Practice Regulation for more information.
GFA does not support this proposal due to the lack of information and our initial analysis of the impacts to Gliding and aviation safety.
Please go to Airservices to provide feedback Website
Some questions and statements that you may wish to cut
and paste appear below
The consultation period ends 15 February 2021, so your urgent attention to this matter is appreciated.
- What are the specific objectives of this proposal so we can comment?
- Is there a safety case for this proposal so we can understand the safety improvements and comment?
- What is the overall cost benefit for all airspace users of this proposal?
- The requirement to monitor class E frequency while in class E airspace detracts from the use of the glider safety frequencies, thus increasing the risk of glider-to-glider collision. Has this been considered?
- The overall risk to all airspace users may well be increased by this proposal; especially those forced into 1500ft AGL and below.
- VFR ADS-B has been approved by CASA for air-to-air surveillance allowing a cost-effective aid for see and avoid. Given this is in place, aircraft owners and RPT operators can utilise this now to improve safety. Do Airservices require this change from Class G to Class E airspace because they disagree with CASA that these devices will improve safety?
- How do Airservices expect pilots to measure the current ground level in order to calculate the 1500ft AGL?
- The risk of aircraft being on the wrong frequency will adversely impact alerted see and avoid. How do pilots manage the transition between airspace at 1500ft AGL and changing radio frequencies?
- The cost of fitting the required equipment for class E airspace is prohibitive in Glider Tugs and Touring Motor Gliders and will therefore prevent them from accessing the amount of airspace that is currently used. This is unfair.
- Tow planes will need to be fitted with transponders to operate in many locations on or near the East coast of Australia. This represents a significant cost, and the short timescale will prevent most Tow planes being fitted before December. This will prevent Tugs flying above 1500ft AGL.
- Aerotow launches are normally to 2000ft or 3000ft AGL, so the requirement to monitor class E frequency will apply to all gliders and towplanes on most of the East coast of Australia. This includes all training flights. Changing frequencies entering class E will make towing difficult. Having 2 radios will be costly and difficult to use.