In relation to the ATSB safety recommendation AO-2018-025-SR-012 regarding CASA's Aeroplane Landing Areas (ALA) guidance on runway overrun areas, CASA does not accept the ATSB recommendation.
The guidance on runway landing areas in Civil Aviation Advisory Publication (CAAP) 92-1 is predicated on the pilot in command having sound piloting skills and displaying sound airmanship. The ATSB found that;
"the aircraft touched down at a high speed and at a point on the runway that reduced the available stopping distance and there were no indications of an attempt at a go-around'.
It is clear from your report that the pilot did not have enough runway to stop the aircraft after landing well beyond the planned touchdown point and subsequently overran the runway. The risk of runway overrun was increased significantly due to the decision to land once it was apparent that the landing distance was no longer sufficient.
The ALA owner indicates in the report;
"that 30 to 50 m before the final stopping point of OAJ had been considered clearway area by the operators at Somersby and not used for take-off or landing"
Effectively therefore, there already was a safe runway overrun area at Somersby as proposed by the safety recommendation.
CASA considers that the unnecessary ATSB recommendation dilutes the key safety message being;
"the importance of pilot preparedness to conduct a go-around if the landing criteria are not met or if there are indications of an unstable landing"
CASA offers guidance on 'go arounds' in CAAP 166-01 Operations in the vicinity of non-controlled aerodromes.
CASA has previously noted that the cost and impact may be difficult for ALA owners to add 30-meter runway strip ends or a potential Runway End Safety Area (RESA).
The practical effect of the ATSB's recommendation may simply be that ALA owners will shorten their runways at either end rather than clearing obstacles after the runway, effectively reducing the length of the runway by 60 meters.
Nevertheless, CASA is currently reviewing the Civil Aviation Advisory Publication (CAAP) 92-1(1), titled Guidelines for aeroplane landing areas. This CAAP was written prior to the introduction of Part 139 of the CASR's and associated manual of standards and therefore requires incorporation and alignment with the CASR framework.
CASA plans to:
• Review CAAP 92-1 and republishing as a Part 139 AC with guidance on RESA for certified aerodromes.
• Update AC 91-02 for operators of small aircraft to provide operational guidance for pilots, including pilot operational guidance contained within CAAP 92-1.
The publication of the above planned ACs updates are scheduled for mid-2020.