The reporter has advised that Airservices has recently replaced Air Traffic Control Line Managers with Operations Line Managers (OLMs) in some locations. The OLMs were initially responsible for oversight and decision making regarding non-operational matters. However, in at least one location, OLMs are now involved in reviewing ATC incidents, delegating operational tasks to controllers and overseeing remedial management processes.
The reporter is concerned that the lack of any ATC experience will result in OLMs assigning operational duties to a controller not best placed to complete the task, due to the OLM not having the understanding of the complexities or procedural requirements of a particular task.
In addition, the reporter queries how OLMs are able to determine the appropriate remedial action for controllers, or ascertain which controller requires the remedial action in case of handover issues, when the OLM has no experience operating as a controller in a complex operational environment.
The Operations Line Manager (OLM) model has been in place for several years. There is a distinction with the ATC Line Manager (ALM) role, where the ALM holds, or has previously held, an ATC Licence.
The OLM manages the delivery of safe, efficient and cost effective air traffic services within a designated operational environment and is accountable for managing the performance of their allocated team and the air traffic services system. An essential requirement of the role is extensive experience in an operational aviation environment.
OLMs do not perform an air traffic control function as described in CASR Part 172, and as such are not required to be authorised to perform the function under CASR Part 65.035, nor hold an ATC Licence. We have had no reported safety occurrences with respect to the performance of an OLM.
Our National ATS Administration Manual describes portfolio responsibilities (such as safety, procedures, administration and training), and each portfolio is assigned to an identified ALM or delegate. With respect to the reporter's comments on tasks undertaken by OLMs, we note the following.
The review of ATS occurrences is conducted within the requirements of our Air Traffic Management Safety Occurrence Management procedure. The accountable line manager must complete the details of the occurrence review, and verify the accuracy and completeness of all data associated with ATS attributed occurrences, which are not subject to investigations or further assurance.
Depending on the level of assurance required for an occurrence, the responsibility for ensuring that each occurrence record is verified for accuracy and completeness is assigned to the CIRRIS Responsible Supervisor, the accountable line manager, Operations Standards & Assurance or Safety Assurance, who may or may not have an ATC background. With respect to the reporter's comments that OLMs are now involved in reviewing ATC incidents, this is consistent with our processes.
Our National ATS Administration Manual requires the portfolio holder to coordinate and facilitate performance management programs for individual staff in conjunction with the Check and Standardisation Supervisor (C&SS), the administration portfolio holder and the staff ALM.
With respect to the reporter's comments how OLM's are able to determine the appropriate remedial action for controllers, or ascertain which controller requires the remedial action in case of handover issues, we consider that this is addressed through our processes where the OLM performs this task in conjunction with C&SS and other staff.
As OLMs do not hold any Shift Manager endorsements or other supervisory qualifications, we are unclear as to the reporter's statement regarding delegating operational tasks to controllers.
Regulator's response (Regulator 1)
CASA is satisfied that the change in management of “operational matters” is not generating any additional safety concerns.
CASA conducts regular risk-based surveillance and auditing of Airservices to ensure compliance with CASR 172. CASA has not identified any compliance issues or safety concerns related to the changes in management structure or manager responsibilities.
CASA notes that an ATS provider must, at all times, maintain an appropriate organisation with a sound and effective management structure to enable it to provide, in accordance with the standards set out in the Manual of Standards and the standards set out or referred to in Annex 11, the air traffic services covered by its approval. This is an area subject to surveillance and auditing by CASA but there have been no findings or indications that recent management changes are impacting the level of ATC service provision, compliance or safety.
CASA notes that an ATS provider must have, at all times, enough suitably qualified and trained personnel who are able to supervise the provision of any air traffic service that it provides. CASA considers safety and compliance for provision of ATC services from a systemic perspective which includes assessment of management capability. CASA has not identified any issues in relation to manager roles.
CASA notes that MOS 126.96.36.199 requires the Airservices Operations Manual to contain a description of the chain of command. OPSMAN172 mentions the position of Operations Line Manager and there is reference to ATC Line Managers. CASA is satisfied that there is no evidence that would justify a safety finding regarding OLMs.
CASA inspectors recently determined that the OLMs they interviewed were highly qualified and experienced in staff management. The OLM was responsible for the training portfolio but was not involved in determining what training a controller may need. The OLM was only responsible for organising the training and keeping adequate records.
CASA notes the need to ensure unqualified and untrained managers are not assigned responsibilities based only on experience or familiarity. These positions should be adequately trained as managers in those areas relevant to their accountabilities.
CASA does not have evidence that supports the issues identified in the REPCON. Whether the use of a manager without an ATC licence is compliant with the regulations is a matter of judgement. The regulations do not rule out such a manager, but they do require them to be suitably qualified and trained.