Mode Aviation
Reference No. AR201900029
Date reported 07 May 2019
Concern title Obstruction within runway zone
Concern summary

A large sign had been erected approximately 50 metres from the runway 06 threshold and 5 metres from the runway edge.

Industry / Operation affected Aviation: General aviation
Concern subject type Aviation: Airport

Reporter's concern

The reporter advised that a sign, reading 'BROADCAST 126.7 ROLLING ' has been erected approximately 50 metres from the runway 06 threshold and five metres from the runway edge.

The reporter advised that a sign was placed at the 06 threshold because an aircraft about to roll may not be visible to an aircraft at the 24 threshold or taxiway. However, the reporter believes the sign poses a safety risk to aircraft, particularly gliders, which regularly operate using the 06L grass area. The reporter believes the standard phraseology, "entering & backtracking runway 06/24" broadcast should suffice in the unlikely event of no wind determining the runway in use or an aircraft about to roll from the 06 end. The broadcast, "rolling" is a normal procedure; however, a reminder placed at the taxiway should suffice while not compromising safety by obstructing the clear runway zone inside the gable markers.

There is currently no active NOTAM in place alerting crews to the potential hazard. The reporter stated that the intended message of the sign does little to improve aerodrome safety or awareness, as it would not be read by pilots electing to use an intersection departure on 06, and there is no equivalent message on runway 24 end grass.

The reporter stated that the sign, if deemed necessary, should be placed at the (only) taxiway holding point visible to all pilots and, outside the gable markers. The reporter further suggested the signage should read, "HIDDEN THRESHOLD, BROADCAST 126.7 ROLLING RUNWAY 06/24" or, "HIDDEN THRESHOLD, BROADCAST ENTERING RUNWAY ON 126.7" to reinforce and clarify the local traffic regulations documented on the En Route Supplement Australia (ERSA).

The reporter stated that as the sign is lit in red, it may be confusing to pilots conducting night approaches, as red lighting generally marks the far end of a runway.

Operator's response (Operator 1)

During the course of the design and construct project, it was identified that the existing runway longitudinal surface was not consistent with the standards, and a runway sight distance issue existed. A survey of the runway and issue of sight distance was carried out prior to the design being commenced, and information was provided to both Civil Aviation Safety Authority, and the aerodrome operator for input. This information was later given to the successful design team. A copy of the survey report is in APP 2.

The sign is not meant to be visible from the 24 threshold or taxiway, it is only meant to be visible to aircraft positioned at the threshold of runway 06. Review of the current ERSA does not identify a runway 06L, and further more if such a runway existed, then the runway markings for the sealed runway possibly should read 06R. Notwithstanding that, the operating standard section 6.7.2.3 provides dimensions required for this 06L to exist, noting the current runway strip of 90 metres would not allow sufficient space for the required 37.5 metre width (minimum) of this runway 06L as it is displaced 3 metres from the line of runway edge lights which are spaced 17 metres laterally from the runway centreline. This would have the far edge of the runway 06L some 12.5 metres outside of the current runway strip gable markers, and would pose further hazard being the gable markers and other obstacles allowable outside of the graded portion of the strip. Refer APP 3.

Prior to the design being commenced, and in accordance with International Electrotechnical Commission (IEC) standards, a safety in design risk assessment was carried out to consider risks for each component of the intended project. A copy of the IEC charter for Safety Lifecycle objectives, as well as the HSE040 Safety in Design Risk Assessment is provided in APP 4.

An operational risk profile (Design ref 25) was considered, and to reduce the initial risk rating of "Extreme" a potential Control Measure was identified to install Broadcast signs at both the 06 threshold, and the taxiway/runway intersection. I don't believe a NOTAM is required if everything complies with the operating standard, however if a safety issue is warranted, that results from an engineered solution designed to overcome another safety issue or non-compliance, a permanent NOTAM would be beneficial. Operational personnel can assess this in due course.

There are two mandatory signs (red background white writing), installed that are to be followed (definition of mandatory signs), one located at the hold point of the taxiway/runway intersection and the other located at the 06 threshold. The sign installed at the threshold (the reported safety issue), is not intended to be used or sighted by pilots at the taxiway hold point, intending to perform an intersected departure or at any other location other than the threshold 06.

The two mandatory signs are to be used cohesively to overcome a physical limitation for one particular point of the runway. The eastern end of the runway does not have the same physical limitation, however, to mitigate risk at the same physical point where the runway sight distance issue exists, runway Distance to go signs (Information signs), have been erected for aircraft take offs and landings on runway 24. Refer Design ref 24 of the Risk Assessment.

There is a complying sign located at the taxiway hold point in accordance with the operating standard, and the certified engineered design. We thank the reporter for their recommendations, however this phraseology has been precedent at other aerodromes, in consultation with the aerodrome regulator to overcome similar issues. Runway end lights (described as the far end of the runway) are coloured red, and they do indicate the final limits of the runway surface length, however they have a completely different appearance and role to mandatory MAG signs which are also coloured red in accordance with the standard.

The complainants appear to be very confused by the colour of this mandatory MAG sign, and the sign location. As the substance of the complaint appears to be that the sign location only poses a hazard to glider operations, perhaps the complainants could explain what glider operations are conducted at night.

The complaints enclosed in the report number AR201900029 appear to be from a particular group of aerodrome users, and the points of concern are tabled only around their particular current operations. Whilst there is a reflection for other users concerns being the colour of the sign, and confusion with the far end of the runway (the runway end lights), the standards clearly mandate what is to be provided. As both the sign, and the runway end lights are compliant with the operating standard for colour and location this point of concern should no longer be considered as part of this complaint.

As part of the recent project, Council were committed on considering the overall safety of the aerodrome operations for all users, and in particular considering the physical geographic limitations the runway centreline posed. In order to overcome these limitations, specialist engineers, competent in aviation lighting design, and airfield design were engaged to not only prove the extent of the problem, but to design a solution for it. We welcome any challenge of the Safety in Design Risk Assessment outcomes, and the certified engineered design, that can mitigate risk for all operations, and not just one group.

A simple suggestion from a very accomplished aviation consultant engaged to review this complaint, is to relocate the threshold for glider operations a distance beyond the sign, so the installed sign no longer poses any threat or risk to their particular operation. This suggestion is made only on the basis that the physical dimensions of the glider runway length and width are capable of being achieved, or an exemption for such operations exists. This response is not intended to limit the recreational or professional activities for any aerodrome users, however if this sign is identified as a safety concern, I believe there are evidently more concerns of equal or higher risk that need to be considered for the operational intent.

Operator's response (Operator 2)

In response to this matter CASA wishes to state that in accordance with the reported information the location of the movement area guidance sign (MAGS) is not compliant with the Manual of Standards – Part 139 (MOS), and the use of the colour red may not be appropriate. At five metres from the edge of the sealed runway surface the sign is three metres too close to the runway.

The use of the colour red applies to a mandatory instruction sign. The MOS does not provide direction for the application of a MAGS with mandatory instruction at an aerodrome that does not have air traffic control.

CASA has not provided advice to the aerodrome operator of [Location] aerodrome regarding the installation of a MAGS within a runway strip at a runway threshold. Correspondence has been recorded in relation to an enquiry from a consultant regarding the installation of a MAGS beside a taxiway at the runway holding point at [location] aerodrome. CASA is not aware if the consultant is acting for the operator.

The report does not advise if the glider strip has been marked in accordance with the Manual of Standards – Part 139. The standards do provide scope to mark the width and length of a glider strip. The options would include marking an end for the glider strip that is further down the runway strip.

The provision of a MAGS at the runway threshold does not appear to have been reviewed by CASA. The installed MAGS would be too close to the edge of the runway for powered aircraft, and marking of the glider strip may not be suitable to ensure the installed MAGS is outside of the area intended for glider operations.

The relevant references within the MOS are paragraphs 6.7.2.3, 8.6.1.3, and 8.6.4.1, and section 8.12.

As a result of this information CASA will contact the authorisation holder to liaise in relation to the reported issues.

Last update 15 October 2019