The ATSB replied to CASA’s response requesting further detail on the surveillance event. CASA provided the following response: The next surveillance of [Provider] is scheduled for the week starting 29 October 2018. The circumstance regarding [Provider’s] non-delivery / late delivery of their document Revisions will be examined at that forthcoming surveillance event and if appropriate, a safety finding can be made. The lack of a response from [Provider] to the ATSB REPCON will be a discussion point between CASA’s surveillance team and [Provider’s] accountable manager, at the forthcoming…

The reporter provided the following comment upon reviewing the final report: The main concern seems to go unanswered. Both Airservices and CASA address what happens when the service is not available (a NOTAM is issued) but not the process used to get to that point. In other words, when staff providing the service are sick or otherwise not available, why are they not replaced by calling out replacement staff – i.e., what is the process used to determine if the service is provided. If a NOTAM is issued, is it based on any safety work for not replacing the absent controller? Airservices provided…

In response to the report above, the following comments were received from the reporter: We are still getting group text before 1300. For this month, January, we've had 11 group texts.

The reporter provided the following comments: I’m deflated by the response from both the operator and the regulator. Disappointingly, these scenarios have now significantly increased in the past month. We are trying hard to encourage fatigue reporting from our crew who operate these arduous duties in the hope that these duties will be red flagged.