The reporter expressed a safety concern related to the ability of members of the Gliding Federation of Australia (GFA) to submit NOTAMs to Airservices Australia.
Since the advent of CASR Part 175, requests to Airservices Australia to issue a NOTAM must come from a person who has been approved by CASA as an authorised originator. Anyone who is not an authorised originator and who wishes to request a NOTAM needs to contact CASA, who will request one be issued if the criteria for promulgating a NOTAM are met. Requests involving Sport and Recreational Aviation must go through CASA’s Sport Aviation Section, 14 days before the event.
If an impromptu event is planned a few days before the event, CASA cannot guarantee a NOTAM will be processed in time to alert the aviation community officially of the event. This has occurred on a number of occasions in the past and requests of CASA to allow GFA to be an authorised NOTAM issuer have not been entertained.
The futility of this system was highlighted last December/January when the CASA Sports section was closed for the Christmas holiday season and Airservices refused to accept a NOTAM request from a GFA member.
The GFA can ask the aerodrome reporting officer (ARO) to submit the report, but when willing to do so will often remove essential information from the NOTAM such as contact details for the event organiser. This removes the extra safety consideration of allowing operators or affected pilots the ability to ring and arrange a time for their arrival.
The reporter advised that the ability to directly submit NOTAMs would greatly increase safety to the flying community and simplify procedures for both CASA and Airservices Australia.
Operator's response (Operator 1)
Airservices Australia (Airservices) appreciates the opportunity to respond to the reported safety concern related to the ability of members of the Gliding Federation of Australia (GFA) to submit NOTAMs to Airservices Australia.
It should be noted that Airservices does not have the authority to approve organisations as authorised originators for the purposes of requesting NOTAMs and is bound by the regulations under CASR Part 175. As a result, Airservices did not have the authority to issue the NOTAM request from the GFA member during the Christmas holiday season.
Airservices acknowledges the reporter's concern regarding the ability to directly submit NOTAMs and simplifying procedures however we believe resolution of the issue sits with CASA and the GFA.
Regulator's response (Regulator 1)
CASA has reviewed the REPCON and notes that Airservices Australia has responsibility under Civil Aviation Safety Regulations (CASR) Part 175 as the Aeronautical Information Service (AIS) to appoint originators of and also in issuing NOTAMs. If the Gliding Federation of Australia (GFA) want to become a NOTAM originator for the purpose of issuing Flight Information Region (FIR) NOTAMs regarding intense gliding activity:
- CASR 1998 Part 175 permits an organisation, such as the GFA, to be a data originator and appointing NOTAM authorised person(s), provided:
- The name(s) of the NOTAM authorised person(s) are provided to the AIS and kept up to date; and
- The person(s) have knowledge and competence to request the issue, review and cancellation of NOTAMs.
- CASA does not approve persons or organisations to be authorised NOTAM originators under Part 175;
- The process to issue a NOTAM is not intended to be onerous;
- The information regarding ‘Authorised Originators - Individuals or organisations authorised in writing by CASA’ published by Airservices on their NOTAM originator webpage and NOTAM Originator Manual is now incorrect (see http://www.airservicesaustralia.com/flight-briefing/notam-originator/); and
- The AIS is also required to issue a NOTAM when it is necessary in the interests of aviation safety (CASR 175.120 – AIS provider NOTAM Service).
At certified or registered aerodromes it is the responsibility of the aerodrome operator to raise NOTAMs for that aerodrome. The GFA, as operators at the aerodrome, should liaise with the aerodrome operator to issue a NOTAM about aerodrome ground-related gliding issues where appropriate. Normally, NOTAMs are not issued for other landing areas. Should a NOTAM be required to amend local traffic regulations published in En Route Supplement Australia (ERSA) they should contact CASA Sport Assurance.
The allegation that GFA members were unable to apply to CASA’s Sport Assurance team for a NOTAM over the Christmas shut down period is correct. Airservices Australia was, however, available to issue NOTAMS and under Part 175.120 B3 can evoke issuing notices that are necessary in the interest of safety.
CASA’s Sport Assurance team requires no less than one working day in order to process FIR NOTAM applications, however, greater than three working days’ notice from an organisation is preferable due to the variability of completeness of these applications.
As a result of this REPCON, Airservices Australia has contacted the GFA and organised for responsible persons to be authorised to submit NOTAMs.