Aviation safety issues and actions
Interim Recommendation issued to: Civil Aviation Safety Authority
|Date issued:||08 December 1998|
|Safety action status:|
The Bureau of Air Safety Investigation recommends that the Civil Aviation Safety Authority review program management policies and procedures for current and proposed changes to the aviation system, in the light of experience gained from the present Class G Airspace Demonstration.
|Date issued:||03 September 1999|
|Response from:||Civil Aviation Safety Authority|
I refer to your letter of 17 August 1999 regarding finalisation of the Class G Report and outstanding responses to IR980260 and IR980261.
In relation to the both IRs, CASA is still awaiting formal, consolidated advice on the results of the review conducted by the Secretary of DOTRS last December. However, certain aspects are becoming more lucid.
In a letter from the Assistant Secretary Aviation, DOTRS, to CASA, dated 29 June 1999, CASA was advised that the Government's decision is that "the regulatory responsibilities for the design, declaration and management of airspace are to remain with Airservices and not be transferred to CASA". CASA understands that Airservices, in line with this decision, has been given direction by the Government to develop, by December 1999, a program for airspace reform.
In a draft working paper attached to the above mentioned letter, it was stated that before making a decision 'Airservices would provide CASA with formal safety cases justifying any changes, including training and education of users'. CASA can review and, if necessary, veto the change. The paper went on to say that 'This acknowledges possible conflicts of interests which may arise were CASA to be both regulator and the initiator of airspace reforms'.
The paper gave CASA's role as setting minimum standards to be applied to each particular class of airspace'. It did not restrict CASA from initiating an upgrading of a class of airspace, however, it stated that CASA must identify 'a clear safety justification' and 'accompany any such proposal with evidence supporting the safety issue'. An overriding requirement was''When CASA seeks to change the classification of airspace, the DoTRS is to ensure an independent analyst is engaged to consider, and publish comments upon, the safety case made by CASK
CASA is willing to adopt the principles espoused in the above and believes that acceptance of them by the three parties would address the Interim Recommendations.
The following correspondence was forwarded to the Civil Aviation Safety Authority on 4 February 2000:
Further to our discussion, it appears that our respective offices may have mislaid the letter reference the Class 'G' investigation final recommendations. As you are aware, the ATSB report on the investigation into the Class G airspace demonstration was tabled in parliament and subsequently released to the public on Tuesday 23 November 1999. In accordance with paragraph 11.14 of the memorandum of understanding (MoU) between BASI and CASA, I draw your attention to final recommendations R19990139 and R19990140. A response in accordance with paragraph 11.15 of the MoU would be appreciated.
Furthermore, you may have noted from the report that based on information provided by CASA to date, interim recommendations IR19980253 and 19980261 have been classified as 'closed - accepted'; however, IR199980260 is still classified as 'open'. A response to IR19980260, in accordance with paragraph 11.15 of the MoU, would be appreciated at your earliest convenience.
|Date issued:||17 March 2000|
|Response from:||Civil Aviation Safety Authority|
|Response status:||Closed - Accepted|
I refer to your letter of 4 February 2000 regarding recommendations pertaining to the Class G Airspace demonstration. IR19980260 and R19980139 are addressed in this letter. R19980140 will be the subject of separate correspondence.
CASA's policy for safety management of airspace change is in accordance with advice received from DOTRS. This policy was confirmed by Minister Anderson in his 1999 Charter Letters to CASA and Airservices, and restated by him in his address, A Measured Approach to Aviation Safety, in November 1999.
As further explanation, where Airservices, or another party, proposes change, CASA will review the supporting safety case; CASA would only pursue an airspace change where it could be clearly justified on safety grounds and CASA would, of course, prepare a safety case; this safety case would be subject to review by an independent analyst appointed by DOTRS.
As you would be aware, CASA has issued two CAAPs on preparation of safety cases which are available on the website. As regards process for review of safety cases, CASA is documenting a procedure and it is expected that this will be available around mid-2000.
I relation to IR980260, ATSB has previously given advice that 'where appropriate', 'project review processes' 'safety analysis processes', and evaluation processes to assess the effectiveness of safety requirements and mitigators, are required. These are matters that CASA would expect to see addressed at project planning stage and to be incorporated in each safety case.
CASA has distributed to industry a draft paper entitled Risk Management Methodology, and Minimum Criteria for Airspace Classification and Levels of Air Traffic Services (copy also attached). This paper sets out CASA's policy on risk management as it applies to airspace.
The above paper includes reference to airspace risk modelling which takes into account identification and treatment of safety factors brought about by changes in pilot workload, situational awareness and crew coordination. It includes risk acceptability and benefit:cost analysis. It also includes a process for the conduct of an Aeronautical Study (safety case) to support proposals. Feedback to date indicates this paper has been well accepted. When finalised, it will be incorporated into the CASA Manual of Operational Standards.
Regarding regulatory review, as part of the project addressing the Minister's direction to provide the regulatory framework for private and public sector provision of air traffic services, CASA will promulgate CASR Part 71 - Airspace. This will give CASA an appropriate power to set the criteria referred to above.
CASA has also refined its consultative processes. CASA Safety Standards Division now has documented processes in the draft Aviation Safety Standards Division Procedures Manual. These include the Discussion Paper and Notice of Proposed Rule Making processes for new regulations (a copy of the flow charts is attached). These are applicable to all 'rule' changes regardless of whether regulatory change is involved. Other consultation is conducted such as the recent industry day held by CASA on 4 February 2000 regarding the latest airspace proposals from Airservices; this was in addition to, and separate from, Airservices consultation on the matter.
It is CASA's view that IR19980260 and IR19990139 have been addressed.