Safety Advisory Notice SAN19990016

Safety Advisory Notice issued to: Civil Aviation Safety Authority

Recommendation details
Output No: SAN19990016
Date issued: 30 March 1999
Safety action status: Closed



The current requirements for the completion of domestic flight plan forms do not acknowledge whether pilots are approved to fly a particular instrument approach. Consequently, holders of the proposed Australian Private Pilot Instrument Rating (APPIR) who are limited to the use of navigation aids for enroute operations, or those holders of a Command Instrument Rating (CIR) not approved to conduct an instrument approach, may not be afforded the appropriate level of hazard alerting service.


Privileges of instrument ratings

Holders of the proposed Australian Private Pilot Instrument Rating (APPIR) may only be qualified to use navigation aids for enroute operations. However, they may extend their basic qualification in order to be endorsed to conduct any one of a number of instrument approach types.

To hold a CIR, pilots only need to be qualified to conduct an Non Directional Beacon (NDB) instrument approach, although they may be approved to navigate by any one of a number of navigational aids.

In addition, pilots flying in accordance with the privileges of the proposed APPIR or a CIR, may not be entitled to conduct any one of a number of instrument approach types if their recency on that type of instrument approach has expired.

Requirements for the completion of a domestic flight plan form

The Aeronautical Information Publication (AIP) details information that is required to be submitted on a domestic flight plan, including navigational equipment that pilots are qualified to use. While pilots may elect to include additional relevant information in the remarks field, there is currently no defined procedure for an instrument rated pilot to advise Air Traffic Services (ATS) on the flight plan of the instrument approach types that they are approved to use. Anecdotal evidence suggests that if the symbol for a particular navigational aid is circled on the domestic flight plan form, most ATS officers assume that the pilot is qualified to conduct instrument approaches using that aid. The AIP states that pilots must advise ATS if they are issued a clearance which requires the use of navigation aids not available to the aircraft, or which the pilot is not qualified to use. This instruction implies that this advice would not normally be provided until a clearance is provided that cannot be complied with.

Hazard alerting service

ATS provides pilots with vital operational information of an unexpected and critical nature to assist them to avoid hazardous situations. This information is broadcast on the appropriate ATS frequency and is directed to those aircraft "maintaining continuous communications with ATS at the time the hazard is assessed that are within one hour's flight time of the hazardous conditions" (Manual of Air Traffic Services). Among other things, a hazard alerting service informs pilots if weather conditions at destination aerodromes fall below alternate minima. The instrument flight rules (IFR) alternate minima referred to in a hazard alert are usually based on the navigational aid that provides the highest alternate minima for an instrument approach to that aerodrome, usually the NDB approach for the highest category of aircraft that may use that approach. The level of hazard alerting provided to pilots is normally determined by the information provided by the flight notification process and is based upon the completion of a domestic flight plan form.


The present system for flight notification to ATS for IFR flights does not incorporate a defined process by which a pilot's approval to fly a particular instrument approach procedure may be advised. While pilots may elect to include additional information in the remarks field of the domestic flight plan form, such information is not routinely included. Therefore, it may not be possible for ATS to correctly assess whether a particular level of hazard alerting service is required for a flight on the basis of the information presently submitted.

For example, a pilot may be the holder of the proposed APPIR, but may only be qualified for enroute use of navigation aids. Alternatively, the pilot may be endorsed to conduct instrument approaches but may not consider that they are competent to conduct an approach on the basis of lack of approach recency. While the pilot can elect to plan the last route segment of the flight in accordance with IFR, he would be required to fly visually below lowest safe altitude (LSALT) for arrival at the destination. The relevant alternate minima applicable for this flight would be no more cloud cover than 4 octas at a ceiling below 500 ft above LSALT. An appropriate level of hazard alerting for this example would be that the pilot would be advised if weather conditions unexpectedly deteriorated below this alternate minima.

The instructions contained in the AIP would require the pilot to circle any navigational aid on their flight plan that they are qualified to use. Unless the pilot detailed the limitations on their use of navigation aids for approaches in the remarks field of the flight plan, ATS would not know if a pilot was qualified to use the navigation aids only for enroute navigation, or for instrument approaches. Given that many ATS officers assume that pilots are able to conduct instrument approaches whenever the relevant symbol is circled on the flight plan, it is possible that ATS would not provide an appropriate hazard alerting service, as they would not know the alternate minima relevant to that flight. At best, pilots may be advised when weather conditions deteriorate below the NDB alternate minima. However, this alternate minima is considerably lower than the visual alternate minima required by the pilot in this example. Consequently, such advice would not be broadcast to the pilot for some time after conditions had deteriorated below the relevant alternate minima, if at all.

In addition, the in-flight requirement to advise ATS if a pilot does not have a particular navigational aid available to them, or is not qualified to use, does not provide sufficient protection as this information is not likely to be communicated until ATC issues an approach clearance. Such clearances are usually only issued within 10-15 minutes of arrival at the destination. Such a requirement to advise ATC would only apply to destinations within controlled airspace. Pilots planning flights to destinations outside controlled airspace are not likely to communicate such information in the absence of the issue of approach clearances. A more timely hazard alerting service would provide pilots with sufficient time to consider alternates before fuel quantity becomes a critical consideration.

The same limitation of the hazard alerting service as described above would apply to holders of a CIR who, while rated on instrument approaches in accordance with the privileges of the CIR, may not have satisfied the approach recency requirements of the rating and therefore could not legally conduct an approach. Notwithstanding, the majority of command instrument rated pilots maintain currency on those approach types that they are rated to conduct, and hence this deficiency rarely occurs. However, under the proposed APPIR, there is likely to be a significant number of pilots who will not be qualified to conduct instrument approaches using navigational aids for which they are qualified to use for enroute operations.

This situation has the potential to have serious safety consequences when pilots who are not capable of conducting an instrument approach are not made aware of unexpectedly deteriorating conditions ahead. Pilots may subsequently find that they have limited safe options for alternative action on arrival overhead their destination in the absence of an appropriate level of hazard alerting.


Output text

The Civil Aviation Safety Authority should note the safety deficiency identified in this document, and take appropriate action.

Initial response
Date issued: 07 April 1999
Response from: Civil Aviation Safety Authority
Response text:

The Safety Deficiency advised in Safety Advisory Notice 990016 has been noted. CASA has been aware from the outset of the Private Pilot Instrument Rating concept that additional flight notification arrangements would be required.

The current flight notification arrangements accommodate the original enroute instrument rating concept via item 8 on the ATS Flight Notification form, that is, the pilot may indicate that a change of flight rules is planned. Item 15 provides for the pilot to advise the point at which the change is planned. However, as you have pointed out, the Private Pilot Instrument Rating proposal will require additional details to be notified to ATS. Airservices Australia has volunteered, unofficially at this stage, to add another code to flight notification requirements to indicate instrument approach capability. CASA will be negotiating formally with Airservices Australia on the issue.

While writing, I would like to point out that your definition of the safety deficiency is not entirely correct in that holders of command instrument ratings are not permitted to use any navigation aid for enroute operations unless they are also qualified to use that aid to conduct an instrument approach (CAO 40.2.1 para 6.5 refers).

Last update 01 April 2011