Recommendation R19990139

Recommendation issued to: Civil Aviation Safety Authority

Recommendation details
Output No: R19990139
Date issued: 23 November 1999
Safety action status:

See report `Systemic Investigation into the Class G Airspace Demonstration'

Output text

The Bureau of Air Safety Investigation recommends that the Civil Aviation Safety Authority (CASA) review regulations, policies, practices and procedures with a view to ensuring that prior to the implementation of any change to the aviation system, including any initiatives undertaken by CASA, an appropriate safety analysis process consistent with the degree of change is undertaken.

Initial response
Date issued: 17 March 2000
Response from: Civil Aviation Safety Authority
Action status: Closed - Accepted
Response text:

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 R19990139 have been addressed.

Last update 01 April 2011