Safety concern regarding the operational hours of Gold Coast tower
A flight crew member has raised a safety concern regarding the current hours of operation of the Gold Coast tower, and its associated airspace. The reporter has stated that the hours of operation of the Gold Coast tower have been reduced from 0600-2300 local pre-covid, to the current hours of 0600-2130. These tower hours leave a window of 90 minutes prior to the airport curfew coming into effect where a number of high capacity RPT aircraft are required to operate into a CTAF environment at night that is often congested with other high capacity aircraft, as well as General Aviation aircraft operating in the circuit area. The reporter is concerned that the reversion to a CTAF at the Gold Coast is inappropriate during this window, given the volume and type of traffic operating during the period prior to curfew. This situation is further exacerbated by frequent delays to airline schedules, with flights that were planned to arrive during the tower hours often arriving after the tower has ceased operating.
In addition to these concerns, the reporter has stated that on a number of occasions they have witnessed the Gold Coast tower cease operations prior to the nominal time of 2130, and on one occasion witnessed this occurring with no prior notice or warning via NOTAM or ATIS. On this occasion the reporter witnessed a high capacity RPT flight having its airways clearance cancelled whilst holding short of the runway for departure, requiring the crew to negotiate and replan for a new airway’s clearance through a different ATC unit and potentially introducing a number of threats and distractions to the flight crew.
On another occasion on the 15th of July 2022, Gold Coast tower ceased operating at approximately 1600 local resulting in approximately 44 high capacity RPT jet and 13 General Aviation aircraft movements in a CTAF environment prior to the 2300 curfew coming into effect.
The reporter has expressed concern that as air traffic movements return to pre-covid levels, the hours of operation of the Gold Coast tower have not been increased in line with this demand and, at present, are insufficient to provide an adequate level of ATC coverage and safety.
The ATSB notes that previous concerns have been raised through the Repcon process regarding the staffing and qualification levels of controllers operating at the Gold Coast Tower in REPCON AR2020-00075 and AR2020-00034. Of note, Airservices Australia had previously advised the ATSB in response to Repcon AR2020-00075 that 'to further mitigate the current challenges faced, additional ATC staff are transferring to Gold Coast in January 2021 to further bolster capability, and ensure an appropriate level of staffing readiness in anticipation of an upturn in traffic is achieved. The current Gold Coast Tower resource and training plan in fact indicates that there will be a level of staffing in excess of the level required by June 2021.'
Airservices appreciates the opportunity to respond to the concerns raised in the REPCON and provide context regrading the current hours of operation and contingency processes.
Airservices acknowledges that it is not currently providing the full hours of service at Gold Coast as documented in the En Route Supplement Australia (ERSA) due to the current resourcing mix, however, Airservices has an approval from the Civil Aviation Safety Authority (CASA) to vary the published hours of operation at Gold Coast to 1955-1130 UTC.
Since late 2020, Airservices has been working to bolster resourcing at Gold Coast and currently has an overall excess level of staff. In order to provide the hours of service documented in ERSA, we require a specific number of staff to be Fully Endorsed Controllers (FEC) which includes performing the Aerodrome Control (ADC) function. Currently, the number of FEC available at Gold Coast is below the requirement but through a more robust recruitment process and increased simulator and on-the-job training, our endorsement success rate has improved.
In providing oversight of Airservices, CASA conducted surveillance at Gold Coast in September 2021 and are currently two open safety findings relating to resource planning and hours of operation at Gold Coast. Airservices continues to work with CASA to address these and expects they will be closed by 31 January 2023 when the resourcing mix will provide the required number of FEC. In relation to the events on 15th July 2022, Airservices experienced late notice unavailability of staff to fulfil a shift at Gold Coast. All reasonable steps were taken to see if the shift could be filled and when this was not possible, contingency measures were put in place which required the early closure of the tower and the aerodrome reverting to Common Traffic Advisory Frequency (CTAF) procedures. This short term variation was communicated to CASA and industry to minimise the impact. Subsequent to this event, Airservices is exploring changes to minimise the exposure to CTAF operations during unplanned contingency periods when the tower is closed. These changes include the provision of approach service down to a lower level from the current 3,500 ft when the CTAF is in operation.
In response to the REPCON, CASA confirms that Gold Coast Tower hours reduced from 0555-2300 (local) to 0555-2130 (local) in 2020.
Over a period of six months starting in late March 2020, CASA received multiple requests to vary the hours of service for the tower.
Apart from one request, which was associated with runway works, all the requests were associated with workforce management impacted by COVID-19.
CASA conducted a surveillance of Gold Coast Tower in June 2020, subsequently a Safety Observation was issued to Airservices regarding staffing.
The Airservices response to the Safety Observation indicated a plan to rectify, however, ongoing variations at Gold Coast triggered a requirement for a priority follow-up surveillance.
This was conducted in September 2021, where two (2) Safety Findings were issued against Airservices for failing to:
- Provide adequate staffing to ensure service continuity as defined by the Regulations, specifically, ERSA hours – 0555-2300 (local), and
- Provide supervision as required by the Regulations.
Both Safety Findings have been managed in accordance with the CASA Surveillance Manual (CSM), and subsequently, due to the extended time taken to resolve, in accordance with CASA’s Coordinated Enforcement Manual (CEM).
Airservices has provided CASA a detailed Action Plan with specific and discreet milestones to return to full-service provision and compliance. The Action Plan has been progressively updated and monitored meticulously by CASA Inspectors, Management, and the Enforcement team.
Rectification was originally set to be 30th June 2022 however, this has now been extended several times with the most recent date of 13 March 2023 having not been met due to unexpected controller competency issues. CASA is awaiting AA plan update for the resumption of services and is expecting a response by 7 April 2023.
CASA is aware of the ongoing variations being reported and is attempting to manage Airservices back to compliance as outlined.