The reporter expressed a safety concern regarding the RNAV (GNSS) RWY 21 approach to Coffs Harbour. The reporter is concerned a segment of the approach must be conducted outside controlled airspace. The reporter stated that they do not consider it safe to be required to fly OCTA during a published instrument approach.
Operator's response (Operator 1)
Airservices Australia (Airservices) appreciates the opportunity to respond to the reported safety concerns regarding the RNAV (GNSS) RWY 21 approach to Coffs Harbour required to be conducted outside of controlled airspace. On 23 September 2010, CASA released its Aeronautical Study of Coffs Harbour which reviewed the airspace classification above the Coffs Harbour aerodrome. The study identified that RNAV approaches to RWY 03 and RWY 21 were not fully contained within controlled airspace as required under the design parameters of Civil Aviation Safety Regulations (CASR) Manual of Standards (MOS) Part 173.
Recommendation 3 of the study requested that "Airservices to undertake a design assessment of the airspace at Coffs Harbour to confirm that all instrument procedures are contained within controlled airspace." Airservices completed the assessment which was provided to CASA on 7 February 2011. The assessment confirmed that none of the instrument approach procedures at Coffs Harbour were fully contained within controlled airspace. The containment of the procedures will require an airspace change.
A proposal to revise the airspace was included within the assessment and provided to CASA to ensure the containment of all currently published instrument approach procedures at Coffs Harbour.
At present, Airservices notes that work is being undertaken by CASA to develop a national approach to airspace designations for the containment of instrument approach procedures.
Regulator's response (Regulator 1)
CASA has reviewed the REPCON and agrees with Airservices that the non-containment of instrument approach procedures within controlled airspace (such as at Coffs Harbour) is recognised as an ongoing issue which the Office of Airspace Regulation (OAR) at CASA has been addressing for a number of years. The OAR deems the current situation as relatively low risk given that only Instrument Flight Rules aircraft are operating in Instrument Meteorological Conditions during instrument approach procedures, and robust traffic information requirements are established to accommodate such operations.
The OAR is undertaking a review of the current policy, taking into account international practices and contemporary instrument navigation procedures.
REPCON questioned CASA as to when the review was likely to be completed and received the following response:
Airservices completed an assessment of the instrument approach containment issues that were identified in the Coffs Harbour aeronautical study in 2010. A report was subsequently sent to CASA in February 2011 for information, advising us that the work had been completed. The report contained two proposals for change, both of which highlighted problems with interpretation and application of MOS Part 173 requirements. One proposal resulted in a CTR with a radius of 21NM; the second proposal would result in a smaller CTR however timed procedures would not be available for use inside tower hours. Both proposals represented a large change to the current airspace.
No formal Airspace Change Proposal was lodged and the report provided was only for information. Recognising the issues raised by Airservices with respect to application of Part 173 requirements, CASA commenced work to review other regional aerodromes for instrument containment issues to get a sense of the extent of the problem. This work was put on hold in June 2012 due to competing priorities and the huge amount of time that it took for the manual assessment of each aerodrome location.
CASA is currently reviewing the policy advice pertaining to airspace design contained in AC 2-5-1(0) and the information contained in MOS Part 173. No completion date has yet been set for this work but once finalised (and any associated regulatory changes developed), CASA will be in a position to implement a standardised approach to the containment of instrument procedures in controlled airspace.