The reporter has raised a safety concern in relation to a flight training organisation conducting unsafe circuit entry procedures at [Location] airport.
The reporter states, 'I have serious safety concerns about the practices at [Location] airport by [Operator]'. The reporter advises that there have been numerous occurrences whereby [Operator] aircraft enter a holding pattern on downwind in the circuit. The reporter has often witnessed up to three aircraft in a vertical holding stack from circuit height upwards on the downwind leg. The aircraft subsequently descend in turn, to join the circuit on the downwind leg. [Operator] aircraft have also been known to conduct an orbit (at circuit height) again on the downwind leg, in order to provide separation for other [Operator] aircraft vacating the runway after landing or to backtrack for a departure. The reporter acknowledges [Operator] have a single taxiway for use to access their apron.
The reporter advised this is not a published procedure in the En Route Supplement Australia (ERSA) for other pilots to see and expect. The reporter further advised they have been informed by three [Operator] students that this is a procedure that is internally taught by [Operator] instructors. The student pilots appear to expect other pilots to be aware of this procedure that leads to loss of situational awareness and sudden high workloads to non-[Operator] pilots who are confronted with this odd flying behaviour. The reporter believes this procedure is conducted in order for more training aircraft to be accommodated in the circuit.
The reporter finally states, 'On multiple occasions I have witnessed [Operator] aircraft cut off and key radio transmissions to get in front of other aircraft conducting standard circuit operations. This holding pattern on downwind, especially the vertical stack, does not allow for safe overfly height or crosswind joins and general circuit operations'.
Supplied to the ATSB and CASA, is a review and investigation conducted for ATSB REPCON RA2025-00084. Extract supplied below;
Observations
- The complainant fails to mention any specific dates or times.
- The complainant does not provide sufficient details.
- The complainant sought feedback from [Operator] students.
Findings
- ERSA - No mention is made in the ERSA for any special procedure on the non-active side of [runway A/B].
- Advisory Circular (AC) 91-10 v1.3 Operations in the vicinity of non-controlled aerodromes will apply to common traffic advisory frequency (CTAF) operations.
- [Runway A] is a right-hand circuit pattern.
- [Runway B] is a left-hand circuit pattern.
- Non-active side will therefore always be on the eastern side of the airfield [Location].
- [Operator] arrival procedure coincides and complies with laid down procedure in AC 91-10 v1.3 Operations in the vicinity of non-controlled aerodromes (file reference) D24/454652.
- 7.4 Arrival procedures
- The practice of 'stacking' aircraft on the non-active side is a standard procedure within a CTAF. Inbound traffic should coordinate to maintain a safe altitude when joining on the non-active side, ensuring that the highest aircraft in the 'hold' is at 500 ft for separation purposes. When crossing to the active side during a mid-crosswind, the aircraft at the lowest circuit height will have priority. Pilots should not descend into the active side of the traffic circuit from above because of the difficulty of seeing and being seen by aircraft directly below the aircraft’s flight path.
[Safety reports] data on receipt of REPCON Request RA2025-00084 on Monday April 7 2025
- No evidence has been identified that indicates an instance of [Operator] crew establishing and maintaining:
- a vertical hold stack on the active side of [runway A/B] [Location]
- a holding pattern on the active side of [runway A/B] [Location]
- No evidence has been found to suggest that [Operator] crew performed descending turns from the non-active side to the active side of [runway A/B] at [Location].
- The [Operators]'s internal published procedure states that to maintain separation between aircraft, a pilot in command (PIC) may need to exit the active circuit and, once sufficiently clear, rejoin on the non-active side. The performance of a 360-degree turn or orbit while on downwind or at any point in the circuit is discouraged. I can’t recall orbits being executed by the crew at [Location] recently, [in the past] 12 months.
Actions
- Request for clarification.
- The ATSB and/or the complainant to clarify the following statement - The reporter finally states, 'on multiple occasions I have witnessed [Operator] aircraft cut off and key radio transmissions to get in front of other aircraft conducting standard circuit operations'.
CASA has no comment further to the Operator’s response.
Following a review of the report concerning [Location] airspace, which included an examination of recent incident reports, aircraft movement data (including aircraft types), very high frequency (VHF) arrangements, and the current airspace structure, the Civil Aviation Safety Authority (CASA) has determined that there is no current requirement to alter the airspace classification at [Location].
CASA takes this opportunity to remind all pilots of the importance of thorough flight planning and maintaining awareness of known or expected aviation activities near aerodromes.
This includes flight training and other operations publicised through the aeronautical information system.
Pilots are reminded to actively monitor, and broadcast as necessary, on the appropriate VHF frequencies to ensure safe separation from other air traffic.
CASA maintains regular dialogue with public transport and flight training operators and continually reviews the airspace arrangements at [Location] in line with its legislative responsibilities.
Regarding the suggestion to establish a separate common traffic advisory frequency (CTAF) within the broadcast area, CASA does not support this action at this time but will raise the issues highlighted in the report for broader discussion.
The operator has requested clarification of the reporter's comment - 'On multiple occasions I have witnessed [Operator] aircraft cut off and key radio transmissions to get in front of other aircraft conducting standard circuit operations'.
The ATSB contacted the reporter who supplied the following clarification:
The reporter has observed pilots in [Operator] aircraft appearing to dominate the CTAF frequency by transmitting in advance of their actual position in order to gain priority in the circuit.