Aviation safety issues and actions

CASA ALA guidance on runway overrun areas

Issue number: AO-2018-025-SI-01
Who it affects: All owners and users of ALAs
Issue owner: Civil Aviation Safety Authority
Transport function: Aviation: General aviation
Background: Investigation Report AO-2018-025
Issue release date: 22 October 2019
Current issue status: Safety action pending

Safety issue description

The Civil Aviation Advisory Publication for Aeroplane Landing Areas (92-1(1)) did not have guidance for the inclusion of a safe runway overrun area.

Response to safety issue

With the impending regulatory change with Part 91 (General operating and flight rules) of the Civil Aviation Safety Regulations (CASR) 1998 and subsequent regulation, CAAP 92-1(1) will require review. The Civil Aviation Advisory Publication (CAAP) was written prior to the introduction of Part 139 of the CASR 1998 and associated Manual of Standards (MOS). It should be noted the cost and impact of requiring the 30 m runway strip end, and potential runway end safety area (RESA), may be difficult for industry.

ATSB comment in response

The ATSB notes the Civil Aviation Safety Authority's intention of revising the Civil Aviation Advisory Publication. The ATSB will monitor the Civil Aviation Safety Authority's progress and assess the safety issue on completion of amendments made to this publication.

Recommendation

Action number: AO-2018-025-SR-012
Action organisation: Civil Aviation Safety Authority
Date: 22 October 2019
Action status: Released

The ATSB recommends the Civil Aviation Safety Authority include guidance for the inclusion of a safe runway overrun area in their regulatory guidance for Aeroplane Landing Areas.

Additional correspondence

Response date: 23 December 2019
Response from: Civil Aviation Safety Authority (CASA)
Action status: Monitor
Response text:

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.

ATSB comment:

CASA's response indicated that the safety recommendation had been considered and rejected, and that CASA will not include guidance for a runway end safety area (RESA), although you had plans to revise the Civil Aviation Advisory Publication (CAAP) 92-1 and other advisory publications in mid-2020.

CASA's main consideration in rejecting this safety recommendation appears to be linked to the fact that in this accident, the pilot's long touchdown at a faster speed led to the runway the overrun. While education and training efforts may reduce such actions in the future, other pilots will make the same errors. The ATSB considers pilot actions that contributed to the accident do not remove the risk associated with the safety issue identified in the investigation and led to the safety recommendation.

CASA also indicated that the area beyond the accident runway was considered to be a clearway area by the owner. However, the ATSB investigation report identified undulating terrain and a small watercourse immediately at the end of the runway that increased the likelihood and severity of occupant injury in the case of a runway excursion. That is, a clearway is not an obstacle-free flat area consistent with the concepts of a runway strip or runway end safety area.

The ATSB notes that CASA have also indicated that guidance for the inclusion of a safe runway overrun area could potentially lead ALA owners to reduce their runway length by 60 m, which could be costly and impact operations.

The ATSB also acknowledges there will be challenges for some ALA owners to implement a runway end safe area. However, in the interest of reducing the consequences of future runway overrun accidents at ALAs, the ATSB still believes CASA guidance for ALA owners' consideration, similar to the guidance about obstacles lateral to the runway and in the take-off approach area, is warranted.

As CASA is currently reviewing the Civil Aviation Advisory Publication (CAAP) 92-1(1) 'Guidelines for aeroplane landing areas', the ATSB encourages CASA to re-consider this safety recommendation so that current and future ALA owners have guidance and education about the safety benefits of a safe runway overrun areas.

The ATSB will continue to monitor the CASA's progress addressing this safety recommendation.

Last update 29 April 2020