Melb Aero Study
Melb Aero Study
Melb Aero Study
Melbourne
Office of Airspace Regulation
March 2011
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1 Executive Summary
This aeronautical study was commissioned in response to the Government‘s
expectation under the Australian Airspace Policy Statement (AAPS1) for the Civil
Aviation Safety Authority (CASA) to undertake regular and ongoing studies to meet
its obligations under Section 13 of the Airspace Act 2007 (Act). The Office of
Airspace Regulation (OAR) undertakes a risk based approach in determining which
locations are studied.
The purpose of the study is to review the airspace classification within 45 nautical
miles (nm) of Melbourne aerodrome, Victoria. Particular emphasis is placed on the
safety of Passenger Transport2 (PT) operations.
1
A full list of acronyms used within this report can be found at Annex A.
2
For the purposes of this study, PT services can be defined as activities involving Regular Public Transport (RPT) and all non-
freight-only Charter operations.
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1.2 Issues
The key issues raised by airspace users during the generative interviews,
questionnaires and stakeholder forums have been identified as follows:
• Access to the Melbourne CTR by aircraft operating under Visual Flight
Rules (VFR) is restricted.
• The absence of co-ordination between Moorabbin Tower and Melbourne
Terminal Control Unit (TCU) restricts access for VFR flights to the
Melbourne Control Area (CTA).
• The ATS delivered in the Avalon Class D airspace and the Moorabbin
Class D airspace are different. This results in difficulty for flight instructors
to teach students a standard set of procedures when there is no
consistency in the service provided.
• The Moorabbin Flying Training Areas, Danger Areas (D314 and D315),
are no longer sufficient in size for training. Housing development and Fly
Neighbourly Advice (FNA) effectively reduce the useable size. Frequency
management in the training area (D315), south of the Melbourne Radar
boundary, is a concern.
• The Non-Directional Beacon (NDB) and Area Navigation (RNAV)
Instrument Approach Procedures (IAPs) for Moorabbin are not contained
within CTA. These IAPs do not meet the Civil Aviation Safety Regulation
(CASR) Part 173 Manual of Standards (MOS) requirements.
• The buffers for the IAPs for Avalon are not contained within CTA and do
not meet the CASR Part 173 MOS requirements.
• Airspace infringements (formally known as Violations of Controlled
Airspace) occur throughout the Melbourne airspace.
• Limited access to Instrument Landing Systems (ILS) navigation aids make
Instrument Flight Rules (IFR) training difficult.
• Aircraft holding at the IFR waypoint TEMPL, north of Avalon, will be
contained within Class C and Class E airspace and alternate between the
two classes.
• IFR training at the Cowes Navigation Aids (NavAids) is confined due to the
proximity of the Restricted Areas R323A, R323B and R339.
• A review and update of all VFR reporting and approach points should be
carried out. A number of points such as GMH, Academy and Mount
Cottrell are now hard to identify.
• The VFR route that connects Carrum to Laverton gets congested. The
VFR route follows the edge of Port Phillip Bay from Moorabbin to the
Bureau of Meteorology (BOM) Tower near Laverton takes aircraft within
1 nm of the Melbourne 1,500 foot Class C CTA step.
• Three different height CTA steps intersect within a short distance of the
Bacchus Marsh aerodrome.
• Rising terrain to the west (Brisbane Ranges to south-west and hills to the
west and north west) and the base of the adjacent CTA restrict gliding
operations at Bacchus Marsh.
• Radio communication between aircraft on the ground at the Little River
aerodrome and Avalon Approach is not available.
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• Three different height CTA steps intersecting within a short distance of the
Bacchus Marsh aerodrome contribute to the airspace infringements in the
area.
• The proposed introduction of a Class C airspace step, with a Lower
Limit (LL) of 6,500 feet (ft) Above Mean Sea Level (AMSL) to the west of
Bacchus Marsh would assist gliding operations in the area.
• Radio communication difficulties between aircraft on the ground at the
Little River aerodrome and Avalon Approach should be addressed.
• Updating the aeronautical charts will enhance the situational awareness of
pilots.
1.4 Recommendations
It is important to note that the study may make recommendations based on existing
and projected data. The following comment as summarised by Chief Justice Sir
Harry Gibbs of the High Court of Australia has been considered while conducting the
study:
Where it is possible to guard against a foreseeable risk which, though perhaps
not great, nevertheless cannot be called remote or fanciful, by adopting a
means which involves little difficulty or expense, the failure to adopt such
means will in general be negligent.3
CASA applies a precautionary approach when conducting aeronautical studies and
therefore the following recommendations are made:
1. Representatives from the flying schools in the Melbourne area should meet
with Airservices Australia (Airservices) to discuss options for increasing
access to the Melbourne CTA and CTR by student pilots and VFR aircraft.
2. Airservices should investigate opportunities to co-ordinate VFR departures
from Moorabbin with Melbourne TCU for flights within the Melbourne CTA.
3. Airservices’ Continuous Standards Improvement Section should
investigate the belief that the ATS delivered in Avalon Class D airspace is
different from that in Moorabbin Class D airspace.
4. Airservices should review the IAPs for Moorabbin and Avalon to determine
compliance with CASR Part 173 MOS requirements. The review should
include options for airspace redesign.
5. The Moorabbin Flying Training Areas, Danger Areas D314 and D315,
should be dis-established.
6. An ACP should be submitted by the Victorian Chapter of the Australian
Aerobatic Club to establish a Danger Area for aerobatics north of Tooradin.
7. Airservices’ Safety Promotions team and CASA’s Safety Analysis,
Education and Promotions Division should review the airspace
infringements then formulate and deliver an educational awareness
program for flying in the Melbourne basin and surrounding airspace.
8. The gliding community at Bacchus Marsh should submit an ACP to
introduce a Class C step with a LL of 6,500 ft AMSL to the west.
3
Gibbs, Chief Justice Sir Harry. Turner v State of South Australia (1982). High Court of Australia before Gibbs CJ, Murphy,
Brennan, Deane and Dawson JJ.
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9. The users of the Little River aerodrome should meet with Airservices to
discuss options for gaining airways clearances whilst on the ground at
Little River.
10. Airservices should review and update the aeronautical charts for
Melbourne.
Contents
1 EXECUTIVE SUMMARY ............................................................................................3
2 INTRODUCTION ....................................................................................................10
3 AIRSPACE ...........................................................................................................12
4 DETAILS OF MELBOURNE AIRSPACE MANAGED BY AIRSERVICES...............................14
5 DETAILS OF AIRSPACE ARCHITECTURE – RESTRICTED AREAS ..................................31
6 DETAILS OF AIRSPACE ARCHITECTURE – DANGER AREAS ........................................37
7 CONSULTATION ...................................................................................................43
8 SUMMARY OF INCIDENTS AND ACCIDENTS ..............................................................58
9 AIRSPACE REFORM..............................................................................................59
10 AIRSPACE RISK AND OTHER AIRSPACE MATTERS ...................................................66
11 SUMMARY OF ISSUES ...........................................................................................72
12 FINDINGS AND CONCLUSIONS ...............................................................................73
13 CASA RECOMMENDATIONS..................................................................................74
14 REFERENCES ......................................................................................................75
ANNEX A – ACRONYMS AND ABBREVIATIONS .................................................................77
ANNEX B – AUSTRALIAN AIRSPACE STRUCTURE ............................................................79
ANNEX C – DEFINITIONS AND EXPLANATION OF TERMS ..................................................80
ANNEX D – STAKEHOLDERS .........................................................................................81
ANNEX E – MOORABBIN FLY NEIGHBOURLY ADVICE ......................................................84
ANNEX F – STAKEHOLDER CONSULTATION / FEEDBACK REGISTER..................................85
ANNEX G – EMAIL FROM LITTLE RIVER AERODROME OPERATOR ....................................91
ANNEX H – SUBMISSION REGARDING AIRCRAFT NOISE OVER URBAN AREAS ......................92
ANNEX I – SUBMISSION REGARDING SKYDIVING NEAR POINT ORMOND .............................96
List of Figures
Figure 1: Airspace within 45 nm Melbourne.............................................................. 12
Figure 2: Airspace managed by Airservices within 45 nm Melbourne ...................... 15
Figure 3: Melbourne Aerodrome............................................................................... 16
Figure 4: Essendon Aerodrome................................................................................ 17
Figure 5: Melbourne CTR ......................................................................................... 18
Figure 6: Class C LL 1,500 ft AMSL step.................................................................. 19
Figure 7: Broadcast area within the Melbourne Class C LL 1,500 ft AMSL step ...... 20
Figure 8: Class C LL 2,000 ft AMSL step.................................................................. 20
Figure 9: Class C LL 2,500 ft AMSL step.................................................................. 21
Figure 10: Class C LL 3,500 ft AMSL step ............................................................... 22
Figure 11: Class C LL 4,500 ft AMSL step ............................................................... 23
Figure 12: Class C LL 7,500 ft AMSL step ............................................................... 24
Figure 13: Class C LL 8,500 ft AMSL step ............................................................... 25
Figure 14: Moorabbin Aerodrome............................................................................. 26
Figure 15: Moorabbin Class D CTR.......................................................................... 27
Figure 16: Avalon Aerodrome................................................................................... 28
Figure 17: Avalon Class D CTR................................................................................ 29
Figure 18: Avalon Class E ........................................................................................ 30
Figure 19: Puckapunyal aerodrome.......................................................................... 31
Figure 20: Puckapunyal aerodrome and associated Restricted Areas ..................... 32
Figure 21: Restricted Area R374 .............................................................................. 33
Figure 22: Restricted Areas R323A and R323B ....................................................... 33
Figure 23: Restricted Area R332 .............................................................................. 34
Figure 24: Restricted Area R321 .............................................................................. 34
Figure 25: Restricted Area R339 .............................................................................. 35
Figure 26: Point Cook Temporary Restricted Area ................................................... 36
Figure 27: Danger Area D314................................................................................... 37
Figure 28: Danger Area D315................................................................................... 38
Figure 29: Aerobatic Area within Danger Area D315................................................ 38
Figure 30: Proposed location of Moorabbin aerobatic area. ..................................... 39
Figure 31: Danger Area D322A ................................................................................ 40
Figure 32: Danger Area D322B ................................................................................ 40
Figure 33: Danger Area D383................................................................................... 41
Figure 34: Danger Area D389................................................................................... 41
Figure 35: Danger Area D399................................................................................... 42
Figure 36: Avalon airspace and the holding pattern at TEMPL................................. 46
Figure 37: VHF Frequencies used in D315............................................................... 48
Figure 38: Airspace Infringements 01 July 2008 – 30 June 2010 ............................. 49
Figure 39: Suggested change to Class C Step north west of Melbourne ................. 50
Figure 40: IFR waypoint CANTY. ............................................................................. 51
Figure 41: Restricted Areas in the vicinity of the Cowes and Wonthaggi NavAids ... 52
Figure 42: VTC Inset incorrectly showing VFR Route near R321............................. 53
Figure 43: CTA steps in the vicinity of Bacchus Marsh............................................. 54
Figure 44: Proposed CTA step to the west of Bacchus Marsh ................................. 55
Figure 45: Point Ormond and Elwood....................................................................... 56
Figure 46: Little River Aerodrome............................................................................. 57
Figure 47: Control Zone and Control Area Chart – Vancouver ................................ 60
Figure 48: Control Zone and Control Area Chart – Manchester .............................. 62
Figure 49: Control Zone and Control Area Chart – Memphis.................................... 64
Figure 50: Moorabbin Fly Neighbourly Advice .......................................................... 84
2 Introduction
The Office of Airspace Regulation (OAR) within the Civil Aviation Safety Authority
(CASA) has sole carriage of the regulation of Australian-administered airspace, in
accordance with section 11 of the Airspace Act 2007 (Act). Section 12 of the Act
requires CASA to foster both the efficient use of Australian-administered airspace
and equitable access to that airspace for all users. CASA must also take into account
the capacity of Australian-administered airspace to accommodate changes to its use.
In exercising its powers and performing its functions, CASA must regard the safety of
air navigation as the most important consideration.4
Section 3 of the Act states that ‘the object of this Act is to ensure that
Australian-administered airspace is administered and used safely, taking into account
the following matters:
a. protection of the environment;
b. efficient use of that airspace;
c. equitable access to that airspace for all users of that airspace; and
d. national security.’
2.2 Purpose
The purpose of this aeronautical study was to conduct a risk assessment of the
airspace within 45 nautical miles (nm) of Melbourne aerodrome, Victoria.
The study forms part of the OAR program of work to review Australia’s airspace as
required by the Act.
The outcome of the study is to demonstrate that all sensible and practicable
precautions are in place to reduce the risk to acceptable levels. For the purpose of
this study, a multifaceted approach was used including quantitative and qualitative
analysis consisting of:
Stakeholder interviews;
Industry forums;
Questionnaires;
Risk Assessment; and
Site visits.
4
Civil Aviation Act 1988, Section 9A – Performance of Functions
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2.3 Scope
The scope of the study includes identification and consultation with stakeholders to
gather necessary data and information related to airspace issues within 45 nm of
Melbourne aerodrome. As a minimum, this includes consultation with Regular Public
Transport (RPT) operators, Charter operators, Flying Training Schools, Department
of Defence (Defence), Emergency Services operators and the Aerodrome Operators.
The study’s scope must also consider CASA’s responsibilities in adopting a proactive
approach to assess the Australian airspace system and its operations, and to identify
and pursue airspace reform opportunities. The AAPS offers clear guidance to CASA
on the Government’s airspace strategy and policy as well as processes to be
followed when changing the classification or designation of particular volumes of
Australian administered airspace.
The scope of this study is not intended to examine aerodrome facilities and
infrastructure issues unless any weakness or failings in these areas have a
significant impact on the safety of airspace operations.
2.4 Objective
The objective of this study is to examine the airspace within 45 nm of Melbourne
Aerodrome to determine the appropriateness of the current airspace classification.
This was accomplished by:
a. Investigating through stakeholder consultation, the appropriateness of the
current airspace classification, access issues, instrument approach design5
issues, expected changes to the current traffic levels and mix of aircraft
operations within the existing airspace;
b. Assessing the opportunity to adopt proven international best practice
airspace systems adapted to benefit Australia’s aviation environment as
required by the AAPS6;
c. Analysis of current traffic levels and mix of aircraft operations within the
existing airspace in relation to the level of services provided;
d. Identifying any threats to the operations, focussing as a priority on the
safety and protection of Passenger Transport (PT) services;
e. Carrying out a qualitative and quantitative risk assessment of the current
airspace environment and the expected impact of any changes;
f. Identifying appropriate and acceptable risk mitigators to the known threats;
g. Reviewing extant Aeronautical Information Publication (AIP) entries for
applicability;
h. Ensuring that the issues are passed onto the relative stakeholder group for
their consideration; and
i. Providing assurance to the Executive Manager Airspace and Aerodromes
Division of the levels of airspace risk associated within 45 nm of Melbourne
Aerodrome.
The OAR issues a review of its Permanent Legislative Instruments on a bi-annual
basis. Any changes to airspace determined by this study with respect to airspace
classifications, air routes, prohibited, restricted or danger areas will be reflected in
these Instruments.
5
Refer to Civil Aviation Safety Regulations (CASR) Manual of Standards (MOS) Part 173.
6
To view the AAPS (2010) visit http://casa.gov.au/scripts/nc.dll?WCMS:STANDARD::pc=PC_90462
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3 Airspace
3.1 Airspace Structure
The airspace within 45 nm of Melbourne is a mix of controlled airspace (Class C,
Class D and Class E) and uncontrolled Class G. Refer to Figure 1 for an extract from
the Melbourne Visual Navigation Chart (VNC).
Air Traffic Control (ATC) Towers operate at Melbourne, Avalon, Essendon and
Moorabbin aerodromes. The airspace volumes are discussed in detail in Section 4.
The airspace contains a number of Restricted and Danger Areas. An explanation of
terminology can be found in Annex C. Restricted Areas are discussed in detail in
Section 5. Danger Areas are discussed in detail in Section 6.
3.3 Surveillance
Melbourne airspace is covered by two radar sites, one located at Gellibrand Hill
(Melbourne Approach) and one located at Mount Macedon (Melbourne Regional).
Gellibrand Hill has both Primary Surveillance Radar (PSR) and Secondary
Surveillance Radar (SSR) units. The PSR has a range of 50 nm whilst the SSR has a
range of 255 nm. Mount Macedon has a SSR unit with a range of 255 nm.
Radar coverage is reliable above 2,000 ft AMSL throughout the study airspace.
Radar coverage is available to the surface, within the Melbourne CTR and to the
south of Melbourne aerodrome.
7
During daylight saving time the hours are changed to: Monday, Thursday and Friday 0800–2100 (Local), Tuesday and
Wednesday 0800–2200 (Local), 0800–1900 (Local) on weekends.
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Figure 7: Broadcast area within the Melbourne Class C LL 1,500 ft AMSL step. (Depicted by the
green dashed line). Melbourne VTC - chart effective date 18 November 2010.
Arthurs Creek
Figure 20: Puckapunyal aerodrome and associated Restricted Areas. (Outlined in red).
Melbourne VNC - chart effective date 18 November 2010.
R321
R339
Point Cook
Temporary
Restricted Area
An area designated for aerobatic flight is contained within the lateral boundaries of
D315. Refer to Figure 29 below. The area has vertical limits from 1,500 ft AMSL to
the base of controlled airspace at 8,500 ft AMSL. The upper limit of the aerobatic
area extends 1,000 ft above the surrounding Danger Area and therefore the vertical
limits are shown on the VTC.
Figure 29: Aerobatic Area within Danger Area D315. (Outlined in red).
Melbourne VTC - chart effective date 18 November 2010.
In June 2008, the Victorian RAPAC agreed to relocate the aerobatic area due to
urban growth. A suitable area approximately 5 nm east of the current location was
identified. The proposed area is 3 nm in diameter centred on S38 09’ 38”
E145 35’ 24”. The vertical limits of the proposed aerobatic area are to be from
1,500 ft AMSL to the base of the Class C airspace LL of 8,500 ft AMSL. Refer to
Figure 30 below.
Proposed
new
aerobatic
area.
RAAF Museum
aerobatic area for
practice and displays.
Aerobatic area
used by RMIT and
Military aircraft
The Point Cook Danger Area contains two aerobatic areas. Refer to Figure 33
above. The first area has been promulgated as a Temporary Restricted Area and is
covered in Section 5.11.
The second aerobatic area lies in the south west corner of the Danger Area and is
used by Royal Melbourne Institute of Technology (RMIT) and Military aircraft. The
area is used from 500 ft AMSL up to the base of CTA (4,500 ft AMSL). RMIT mainly
use the aerobatic area between 3,000-4,500 ft AMSL, the area is also used by the
Military to conduct low level aerobatics.
7 Consultation
OAR representatives sought input from a number of operators and stakeholders who
operate in and around Melbourne. Stakeholder interviews were conducted during
October and November 2010. Stakeholders invited to provide input for the study are
listed in Annex D.
7.1 CASA
CASA employs Aviation Safety Advisors (ASAs) throughout Australia as an integral
mechanism for providing safety promotion, training and educational material to the
various industry segments. ASAs liaise with local operators, and discuss airspace
issues. Consultation was also conducted with CASA Flying Operations Inspectors
(FOI) who oversee local operations. Feedback from the ASAs and FOIs has been
considered during compilation of this study.
7.2.1 Avalon: Aircraft holding at the IFR waypoint TEMPL will be contained
within Class C and Class E airspace and alternate between the two classes
whilst holding. This causes issues for the Controllers as they will provide a full
separation service to the pilot whilst in Class C airspace, and then provide a
reduced service whilst in Class E. In practice, ATC provide a full separation
service to aircraft holding at TEMPL, therefore the safety of the aircraft is not
compromised.
Melbourne TCU considers that the airspace design is overly complex and the
consideration required in respect of service levels adds unnecessarily to
workload.
7.2.2 Ultralight aircraft: Ultralight aircraft such as the Jabiru and other
composite constructed planes are not displayed on the Primary Radar screen
very well. Transponder equipped aircraft display quite well, but most of the
small aircraft are difficult to identify.
VFR aircraft not fitted with an engine driven electrical system capable of
continuously powering a transponder are operating in the Class G and E
airspace in the Melbourne Basin. Transponders are required for all aircraft in
Class E airspace except for VFR aircraft not fitted with an engine driven
electrical system (Ref: CASA Instrument 316/98).8
7.2.4 Radar Advisory Service boundary: The south eastern boundary of the
Radar Advisory Service (40 nm Melbourne) does not cover the bottom corner of
the Moorabbin training area (D315). Extending the boundary to 45 nm
8
CASA Instrument 316/98 can be found on the CASA website:
http://www.casa.gov.au/scripts/nc.dll?WCMS:STANDARD::pc=PC_91058
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Melbourne is not possible with the current equipment as it is too far for the
current display to identify aircraft.
7.3 Defence
Defence has no issues with Melbourne airspace.
Essendon is sometimes not available. Aircraft are sent to either Station Pier or
to the West Gate Bridge. The change in route does not seem to be runway
specific.
A VFR route overhead Melbourne aerodrome to Sunbury would assist flights to
the north west. Aircraft could track overhead Melbourne Airport and cross the
runway intersection. This would keep aircraft away from the runway centrelines
and open up access to the CTR.
The “Three Tanks” VFR Route (Sunbury Water Tanks – Melbourne – Essendon)
is no longer promulgated. Recently the route has been used by helicopters but
is not available to fixed wing aircraft.
[CASA Comment: During discussions with Melbourne TCU staff, it was learnt
that a helicopter VFR corridor – called “The Sunbury Corridor” has been
instigated. The Corridor was promulgated via NOTAM and appeared in the 18
November 2010 edition of ERSA under the Flight Procedures section for
Melbourne. The corridor has been made available to helicopters only, as the
helicopters have the ability to stop an approach and hover if required to permit
an aircraft to land at Melbourne.]
There is no co-ordination for VFR flights between Moorabbin Tower and
Melbourne TCU. Aircraft requiring a clearance into Melbourne CTA must go
outside of controlled airspace, then contact Melbourne TCU to request a
clearance. If the aircraft has not submitted a flight plan, it makes co-ordination
difficult for Melbourne TCU as they have no prior knowledge of the flight. In
addition, by the time the aircraft requesting clearance has contacted the TCU, it
is often too late for the aircraft to be able to climb to get above the Melbourne
and Essendon traffic.
7.4.3 Radar Information Service: The service is available the majority of the
time, upon request. Pilots are given a full Radar Information Service (RIS) or a
snapshot of the traffic prior to the service being terminated due to controller
workload. Stakeholders commented that controller workload is noticeable when
the controller is monitoring two frequencies.
7.4.4 Avalon: The Class E airspace causes confusion. The perception among
pilots is that Avalon controllers are controlling the area as Class C airspace and
not Class E. An example is VFR traffic is being issued with clearances and told
to squawk transponder codes. It makes it difficult to instruct students in Class E
procedures.
The Avalon Class D airspace and the Moorabbin Class D airspace are being
controlled differently. There is no consistency between the two pieces of
airspace. It is difficult to teach students a standard set of procedures when there
is no consistency.
[CASA Comment: The operations at Moorabbin and Avalon are quite different.
Avalon is a mixture of Class D and Class E airspace with a surveillance service
provided by a remote TMA. The service at Moorabbin is provided by the Tower
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TEMPL
9
A copy of the Fly Neighbourly Advice can be found in Annex E.
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The base of the CTA to the north of Melbourne is an area of concern for
airspace infringements due to the high terrain, low level of the steps and the
proximity of traffic arriving and departing Melbourne.
[CASA Comment: Airservices and CASA have developed a Safety Bulletin to
inform pilots of the hazards when using the area around Sunbury. The Safety
Bulletin can be downloaded from the Airservices website:
http://www.airservicesaustralia.com/flying/safety/bulletins/docs/20100916_Sunb
ury-Bolinda_Area_Airspace_Infringments.pdf The educational material and
Safety Seminars should assist in reducing the number of incidents.]
Kilmore
Whittlesea
Bacchus Marsh
Sugarloaf
Reservoir
The airspace infringements to the east of the CTR are the result of traffic
climbing too early when tracking north west or descending too late when
tracking south east along the VFR route. The VFR route from Kilmore –
Whittlesea – Sugarloaf Reservoir leads to airspace infringements. The chart has
a recommendation that aircraft “Fly at VFR cruising altitudes cloud permitting”.
Whilst flying south, aircraft may be at 3,500 ft AMSL and enter the Class C
2,500 ft AMSL step prior to reaching Sugarloaf Reservoir. Adding a comment on
the chart to draw pilot’s attention to the Class C 2,500 ft AMSL step may prevent
infringements.
Infringements occur to the east of the Melbourne CTR, near She Oak Hill. The
infringements are due to aircraft climbing too early when departing Essendon
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and enter the 1,500 ft AMSL Class C Step or aircraft travelling to Essendon are
descending too late from the 3,500 ft AMSL Class C Step and enter the 1,500 ft
AMSL Class C Step.
During the consultation process, a proposal was received with three
suggestions to reduce the controlled airspace to the north west of Melbourne
which could reduce the airspace infringements and provide improved access to
the local aerodromes. Refer to Figure 39.
New 1,500 ft
AMSL boundary
IFR
IFR waypoint
waypoint ARBEY
CANTY
7.4.9 IFR Training: Restricted access to ILS aids make IFR training difficult.
Access to the Essendon ILS is available via a booking system where pilots
contact the Melbourne Traffic Manager to book a time slot. When the Essendon
ILS is not available, the Avalon ILS is the only option available to pilots in the
Melbourne area. As the Avalon ILS is privately owned it is more expensive for
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pilots to use than the Essendon ILS. Bank-run aircraft flying into Essendon
prevent access to the ILS between 1700 and 1900 weekdays. Training
organisations have made contact with the Melbourne Traffic Manager (as per
ERSA entry) to investigate whether the Melbourne Runway 27 ILS could be
used outside of peak periods. The flying schools were told that it is not possible.
7.4.10 IFR Training at Cowes: The Restricted Areas (R323A, R323B and
R339) restrict the use of the Navigation Aids (NavAids) at Cowes for IFR
training. Refer to Figure 41 below. Reducing the size or raising the lower limit of
R323A would increase the area available for instrument flying training around
the Cowes NavAids. A block release of the restricted airspace would allow
additional IFR Training at Cowes and also increase the accessibility of the
airspace.
[CASA Comment: The OAR has discussed the issue with Defence. The
Restricted Areas have been promulgated to protect aircraft from live firing
exercises at West Head. In 2009, Defence conducted a comprehensive audit of
all Restricted Airspace in Australia. Due to the level of activity at West Head,
there is no scope to raise the lower limit of R323A or to reduce the lateral
boundaries of the Restricted Areas. Defence have indicated that activity at the
facility will increase and the Restricted Areas will be activated more often than
they are currently being activated.
The NavAids at Wonthaggi are nearby and could be used instead of the Cowes
NavAids].
Figure 41: Restricted Areas in the vicinity of the Cowes and Wonthaggi NavAids.
Melbourne VNC - chart effective date 18 November 2010.
7.4.11 Port Philip Bay VFR route: The VFR route along the northern edge of
Port Philip Bay from Moorabbin to the Bureau of Meteorology (BOM) Tower gets
congested.
The route takes aircraft within 1 nm of the Melbourne 1,500 ft Class C CTA step.
Refer to Figure 42 below. Eastbound aircraft are flying at 1,500 ft AMSL and
westbound aircraft are flying at 2,500 ft AMSL.
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AIP Enroute 1.1 Section 18.12 states the VFR tolerances which must be
applied for VFR powered flights within Class G in the vicinity of controlled
airspace:
⇒ 0–2,000 ft Above Ground level (AGL) + 1 nm (+ 2 nm by night)
⇒ 2,001–5,000 ft AGL + 2 nm (+ 3 nm by night)
⇒ 5,001–10,000 ft AGL + 4 nm (+ 5 nm by night)
Furthermore, there is an error on the Melbourne VTC Inset. The inset incorrectly
shows the VFR route in the vicinity of the Laverton BOM Tower. Refer to
Figure 42 below. The VFR route is depicted as going half way between the
BOM Tower and the Restricted Area R321. The route is correctly depicted on
the main VTC going over the Laverton BOM Tower.
Figure 42: VTC Inset incorrectly showing VFR Route near R321.
Melbourne VTC - chart effective date 18 November 2010.
7.4.12 AIP Errors: A review of the AIP charts reveals a number of omissions
and errors in addition to the VFR route near the Laverton BOM Tower:
• The two information boxes relating to the VFR route in the Melbourne
VTC Inset incorrectly spell the word “procedures”.
• The vertical limits of the Restricted and Danger Areas are not depicted
on the VTC Inset.
• The Sunbury East aerodrome is not depicted on the Melbourne VNC.
• The Lethbridge aerodrome is not depicted on the Melbourne WAC.
• Typographical errors on the VTC Inset.
7.4.13 VFR approach and reporting points: A review and update of all VFR
reporting and approach points should be carried out. A number of points such
as GMH, Academy and Mount Cottrell are now hard to identify.
The Moorabbin VFR approach point “GMH” is hard to identify due to the
surrounding development. A more easily identifiable approach point would be
beneficial.
Mount Cottrell should be deleted as a tracking point as it is hard to identify.
Aircraft are often instructed to “track via Mount Cottrell”. Students and low-time
pilots often misidentify the point.
The VFR approach point Brighton is often misidentified as Sandringham. Visual
markers would assist pilots in correctly identifying the VFR approach points.
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CASA Aviation Safety Advisors and Flying Operation Inspectors may be able to
facilitate an appropriate resolution to the issue.
7.4.14 VFR track Moorabbin – Sugarloaf Reservoir. Marking a recommended
VFR route to Moorabbin from the Sugarloaf Reservoir may assist itinerant and
low time pilots navigating through the area.
[CASA Comment: During discussions with other stakeholders it was stated that
marking the route on the VTC may cause head to head traffic over the VFR
approach point “Academy”. Some stated that there were sufficient features
along the route and that marking the route on the VTC was not necessary.]
Three Class C Steps with varying bases of 2,500 ft, 3,500 ft and 4,500 ft AMSL
lie within a short distance of Bacchus Marsh. Figure 43 below. This airspace
design may result in airspace infringements.
Rising terrain to the west (Brisbane Ranges to south-west and hills to the west
and north west) restrict gliding operations at Bacchus Marsh. Due to weather
patterns, the gliders are very restricted for height, and therefore cannot utilise
wave lift. The glider pilots often cannot use the maximum thermal height for safe
return to the aerodrome due to the overlaying CTA steps. The introduction of a
Class C step with a base of 6,500 ft AMSL would greatly increase access to the
gliding community. Preliminary advice from Airservices indicates that the step
would not impact instrument approaches to, or departures from Melbourne.
Refer to Figure 44 below. The gliding community at Bacchus Marsh is
encouraged to submit an ACP to introduce a Class C step with a base of
6,500 ft AMSL.
7.4.18 Skydiving adjacent to the VFR light aircraft lane: Concerns were raised
of a skydiving organisation operating close to the VFR light aircraft lane in the
vicinity of Elwood, near Point Ormond. See Figure 45 below. The skydiving is
close to a residential area and the VFR light aircraft lane.
A skydiving trial was run by Melbourne Skydiving Centre between the months of
February and May 2010. The trial was very successful and as such the Port
Moran Reserve,
Elwood
Modifications to the airspace (i.e. modifying the CTR boundary to exclude Little
River and the associated circuit area) are unable to be made due to CASR
Part 173 MOS requirements and the effect on the Avalon IAPs.
Little River
Aerodrome
Number of
Type of Incident
Incidents
Failure to comply with ATS instructions or procedures 391
Runway Incursions 303
Airspace infringements 295
Loss of Separation Assurance / Breakdown of Separation 97
Traffic Alert and Collision Avoidance System (TCAS) Resolution Advisory 37
Go around 7
Table 3: ESIRs within 45 nm Melbourne (01 July 2008 to 30 June 2010)
Number of
Type of Incident
Incidents
Airspace infringements 295
Failure to comply with ATS instructions or procedures 290
Runway Incursions 257
Loss of Separation Assurance 71
Go around 13
TCAS Resolution Advisory 2
Table 4: ASIRs within 45 nm Melbourne (01 July 2008 to 30 June 2010)
9 Airspace Reform
As required by the AAPS, this study takes into account the Government’s
requirement that CASA will continue the reform of Australia’s airspace and move
towards closer alignment with the ICAO system and the adoption of international best
practice. This includes the adopting of proven international airspace systems adapted
to benefit Australia’s aviation environment.
Paragraph 7 of the AAPS states: ‘The administration of Australian-administered
airspace:
• shall be in the best interests of Australia;
• shall consider the current and future needs of the Australian aviation industry;
• shall adopt proven international best practice airspace systems adapted to
benefit Australia’s aviation environment; and
• shall take advantage of advances in technology wherever practicable.’
Whilst no two aerodromes are exactly alike, this study has endeavoured to find
aerodromes with comparable movement figures and environment—a primary
aerodrome with busy satellite aerodromes close by. The study has investigated the
airspace architecture surrounding:
9.1 Vancouver
Airspace classification, airspace architecture, and Air Traffic Management
procedures detailed in the Nav Canada AIP were reviewed in an effort to determine if
the airspace system used in the vicinity of Vancouver aerodrome, BC, would benefit
the aviation environment in the vicinity of Melbourne.
Vancouver aerodrome (hereafter referred to as Vancouver) is located 4.5 nm south-
west of Vancouver city. Within 40 nm of Vancouver there are six major aerodromes
(including three International aerodromes); eight major water aerodromes, 18 smaller
aerodromes and 19 helicopter landing sites.
The majority of traffic at Vancouver consists of domestic and international scheduled
PT and charter flights. Helicopter and seaplane flights attribute to approximately
7.55% of all movements. ATS is available 24 hours a day.
293,877 aircraft movements and 16,779,709 terminal and transit passengers at
Vancouver were recorded for the 2010 calendar year10, compared with 196,228 and
26,128,118 at Melbourne. Vancouver has three runways, designated as 08L/26R;
08R/26L and 12/30.
The Vancouver CTR is Class C from Surface to 2,500 ft AMSL with Class C overlying
the CTR up to FL125. Between FL125 and FL180, Class B airspace is utilised.
Class A airspace exists above FL18011.
Within 40 nm of Vancouver, every ICAO classification of airspace is utilised. The
airspace surrounding Vancouver is depicted in Figure 47.
10
Vancouver International Airport facts and statistics: http://www.yvr.ca/en/about/facts-stats.aspx
11
NavCanada Designated Airspace Handbook:
http://www.navcanada.ca/NavCanada.asp?Language=EN&Content=ContentDefinitionFiles%5CPublications%5CAeronauticalInf
oProducts%5CDAH%5Cdefault.xml
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Surveillance
Primary and Secondary Surveillance Radar is available to ATC at Vancouver.
In Vancouver city, 11 multi-lateration receivers have been installed around the
harbour, supplementing radar coverage for controllers at the Vancouver ATC and the
airport tower. Providing radar coverage of the entire harbour is impractical, as it is
flanked by mountains and tall buildings. The multi-lateration stations are expected to
be in operational use in early May 2011.
Boundary Bay
(Class C CTR)
Abbotsford
Victoria International
International (Class C CTR)
(Class C CTR) Delta Heritage
Air Park
(Class C CTR)
Figure 47: Control Zone and Control Area Chart – Vancouver (June 2010)
Airspace Comparison
There are a number of differences, in terms of airspace, between Melbourne and
Vancouver:
1. The use of Class G airspace at lower levels at Vancouver;
2. The use of Class F airspace at Vancouver;
3. The extensive use of Class E airspace at Vancouver;
4. The use of Class B airspace at Vancouver; and
5. Transponder usage.
Class G
The majority of the airspace surrounding Vancouver is controlled (Class A – E).
Class G airspace exists at lower levels, usually from SFC to 700 ft AGL or from SFC
to 1,200 ft AGL.
The Class G airspace surrounding Melbourne has various upper limits from 1,500 ft
to 8,500 ft AMSL. The amount of Class G airspace allows access to the majority of
the Melbourne basin by VFR and ultralight aircraft.
Class F
In Canada, Class F airspace is described in terms of horizontal and vertical
dimensions, effective for a specified period of time. Class F airspace may be
restricted airspace, advisory airspace12, military operations areas or danger areas,
and can be controlled airspace, uncontrolled airspace or a combination of both13.
ICAO describes Class F as uncontrolled airspace where IFR and VFR flights are
permitted. All IFR flights receive an air traffic advisory service and all flights receive a
flight information service if requested.
Class F airspace is not currently used in Australia, however anecdotal evidence
suggests that the service provided in Australian Class G is similar to ICAO Class F.
Class E
Class E airspace surrounds Vancouver with a base ranging from 700 ft AGL to
2,000 ft AGL. Specific volumes of Class E are designated as Transponder Airspace.
Class B
Class B is utilised as middle layer of CTA between FL125 and FL180. The use of
Class B airspace provides a separation service for all aircraft, including VFR.
Transponder usage
Transponders are required to be carried and used within all Class A, Class B and
Class C airspace surrounding Vancouver. Class D and Class E airspace attributed
to Abbotsford, Vancouver and Vancouver Harbour are designated as transponder
airspace.
9.2 Manchester
Airspace classification, airspace architecture, and Air Traffic Management
procedures detailed in the UK AIP were reviewed in an effort to determine if the
airspace system used in the vicinity of Manchester14 aerodrome, UK, would benefit
the aviation environment in the vicinity of Melbourne.
Manchester aerodrome (hereafter referred to as Manchester) is located 7.5 nm
south-west of Manchester city. The majority of traffic at Manchester consists of
domestic and international scheduled PT and charter flights. ATS is available 24
hours a day.
172,515 aircraft movements and 18,724,889 terminal and transit passengers at
Manchester were recorded for the 2009 calendar year15, compared with 196,228 and
26,128,118 at Melbourne. Manchester has two runways designated as 05L/23R and
05R/23L.
The Manchester CTR is Class D from Surface to 3,500 ft AMSL with Class A
overlying the CTR up to FL195. The Control Zone and Control Area are depicted in
Figure 48.
Laterally, the CTR is a polygon approximately 20 nm long and 20 nm wide. Adjacent
to the north, east and southern CTR boundaries are Class D steps 1,500 ft AMSL,
12
An Advisory Area is airspace of defined dimensions within which a high volume of pilot training or an unusual type of aerial
activity may be carried out. NavCanada Designated Airspace Handbook – Page 5:
http://www.navcanada.ca/NavCanada.asp?Language=EN&Content=ContentDefinitionFiles%5CPublications%5CAeronauticalInf
oProducts%5CDAH%5Cdefault.xml
13
Ibid – Page 5.
14
Stansted aerodrome, UK, has aircraft movements and passenger numbers closer to Melbourne figures (than Manchester),
however, the close proximity of Stansted to Heathrow (which recorded 466,393 movements in 2009) would make a comparison
between Stansted and Melbourne unrealistic.
15
Civil Aviation Authority’s UK Airport Statistics for 2009.
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2,500 ft AMSL, and 2,000 ft AMSL respectively up to 3,500 ft AMSL. To the west is
Liverpool CTR.
Approximately 90 aerodromes/landing sites are located within 45 nm of Manchester,
including Liverpool aerodrome.
Surveillance
PSR and SSR sites provide surveillance coverage to the surface at Manchester.
Liverpool
Liverpool aerodrome is located 20 nm to the west of Manchester. The majority of
traffic at the aerodrome consists of domestic scheduled and charter flights, including
International flights. ATS is available 24 hours a day.
79,298 aircraft movements and 4,884,494 terminal and transit passengers at
Manchester were recorded for the 2009 calendar year16.
Liverpool CTR is Class D from surface to 2,500 ft AMSL with Class D overlying the
CTR from 2,500 ft AMSL to 3,500 ft AMSL. Overlying this Class D is Class A, from
3,500 ft to FL195.
Barton
Aerodrome
Liverpool
Aerodrome Manchester
Aerodrome
Woodford
Aerodrome
Hawarden Ashcroft
Aerodrome Aerodrome
Figure 48: Control Zone and Control Area Chart – Manchester (6 May 2010)
Airspace Comparison
There are two significant differences, in terms of airspace, between the Melbourne
and Manchester aerodromes:
1. The Melbourne CTR is Class C whereas the Manchester CTR is Class D; and
2. Class A airspace overlays Melbourne from FL180 whereas Class A airspace
overlays Manchester from 3,500 ft AMSL.
16
Civil Aviation Authority’s UK Airport Statistics for 2009.
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Class A
Only IFR aircraft are permitted in Class A airspace. In Australia, Class A is
established in all airspace above FL180 on the east coast and over capital city
aerodromes and above FL245 elsewhere.
Considering the amount of VFR traffic operating in the wider Melbourne area, and the
lack of VFR traffic operating at Manchester aerodrome, it is reasonable to suggest
the current level of Class A over Melbourne (FL180) is more suitable to the
Melbourne aviation environment than having Class A at 3,500 ft AMSL.
9.3 Memphis
Airspace classification, airspace architecture, and Air Traffic Management
procedures detailed in the Federal Aviation Administration (FAA) Regulations17.
Federal Aviation Regulations (FAR) 71, 73, 77 and 91 were reviewed in an effort to
determine if the airspace system used in the vicinity of Memphis aerodrome would
benefit the aviation environment in the vicinity of Melbourne.
Memphis International Airport (hereafter referred to as Memphis) is located 4.5 nm
south-east of the Memphis Central Business District (CBD). The majority of traffic at
the aerodrome consists of domestic and international scheduled PT and charter
flights. ATS are available 24 hours a day.
158,850 passenger aircraft movements and 5,039,905 terminal and transit
passengers at Memphis were recorded for the 2009 calendar year18, compared with
196,228 and 26,128,118 at Melbourne. Memphis Airport also is an integral element in
the freight network and is serviced by most of the major freight operators and makes
up for an estimated 60,000 additional movements in 2009.
The Memphis CTR is Class B from SFC to 10,000 ft AMSL with Class E overlying the
CTR up to FL180. Class A airspace exists from FL180 and above. The Control Zone
and Control Area are depicted in Figure 49, below.
Memphis has four runways, designated as 18R/36L; 18C/36C; 18L/36R and 09/27.
The airspace is tailored in a keyhole fashion to ensure protection of the instrument
approaches. To the northwest of Memphis there are three general aviation airports
within 20nm of Memphis, however they are in Class G airspace between SFC to
1,800 ft. Memphis aerodrome acts as a transport hub to the domestic and
international aircraft network and as a result is open 24 hours.
17
FAA Regulations: http://www.faa.gov/regulations_policies/faa_regulations/
18
Research and innovative Technology Administration Bureau of transportation Statistics: http://www.bts.gov/
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Transponder carriage
Transponders are required to be carried and used within 30 nm of a Class B
aerodrome such as Memphis. Although it is theoretically possible to operate within
Class B airspace without a transponder, it is almost never done in practice. The
exception would require the concurrence of the controlling agency which would not
normally be forthcoming.
Surveillance
Primary and Secondary Surveillance Radar is available to ATC at Memphis.
General
Dewitt Spain
Fayette
West
Memphis
Olive Branch
Thomas
Tunica Muni
Tunica
Holly Springs
9.4 Conclusion
The current Melbourne airspace architecture works well for the volume and mix of
traffic. Adopting either of the three foreign airspace models (Vancouver, Manchester
or Memphis) could decrease the efficiency and restrict the access to the airspace.
Melbourne is the only aerodrome of the four that were studied that does not have
parallel runways.
19
Aeronautical Information Publication (AIP) Book (GEN 1.5, 6.2.1)
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20
The report can be viewed on the FAA website:
http://www.faa.gov/regulations_policies/policy_guidance/investment_criteria/media/establish_atct.pdf
21
Airspace Risk Model, Acceptable Risk Criteria and the Value of a Statistical Life – CASA – Robert Phillips – June 2006, Page
11.
22
Ibid, Page 14.
23
Ibid. Page 16.
24
Point Cook aerodrome is a military operated aerodrome where prior permission is required to operate (24 hours notice).
Activities at Point Cook are protected by Restricted Areas and Danger Areas.
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CASA is of the opinion that provided all reasonable precautions are in place in
Class G airspace, risks are appropriately mitigated at all of the localities.
10.2.3 Estimated Traffic Mix and Movement Data
The aircraft using the Melbourne airspace range from large and medium
passenger jets (such as the Airbus A380, Boeing 747 and Boeing 737), medium
size turbo-prop aircraft including the De Havilland DHC8, Saab SF340, and the
Beechcraft BE-200 King Air.
A range of light single-engine and twin-engine aircraft operate throughout the
Melbourne airspace including a variety of helicopters. The airspace is also utilised
by gliders, balloons, ultralights and powered parachutes.
A brief summary of the estimated traffic mix and movement numbers utilising
Airservices’ Airspace Research Application (ARA) data, figures from aerodrome
operators and flying organisations are shown in Table 5.
A movement is classified as a take-off or a landing.
The traffic has been broken down into the following categories:
Key:
VFR including gliders, ultralight, microlight and helicopters
IFR includes IFR training flights, private IFR flights and RPT operations
# Figures obtained through Airservices
* Estimate only (provided by aerodrome operator or industry)
Point Cook An Aeronautical Study of the Point Cook aerodrome is currently being conducted.
Table 5: Traffic mix for Melbourne airspace over a 12 month period (Dates varied).
Note: The Geelong aerodrome is scheduled to close in mid 2011. The Fiskville
aerodrome is currently unserviceable and will either be upgraded to a serviceable
standard or it will be closed permanently. A decision on the future of the Fiskville
aerodrome is pending.
For the purpose of this study it is assumed that movement numbers for the
aerodromes Barwon Heads, Nar Nar Goon, Melton, Guildford, Moriac and Riddell are
low. These aerodromes are privately owned and information about the usage is
therefore difficult to obtain. From stakeholder interviews and the site visit to the area,
CASA believes that the movement numbers for these aerodromes are lower than
those assessed in Table 5. Therefore from all available information the risk at these
aerodromes seems to be low, and if all reasonable precautions are in place, the risk
of a VFR conflict with an IFR aircraft is low.
The Lilydale aerodrome is privately owned with a flying school, charter operator and
an aviation maintenance facility. Anecdotal evidence describes the aerodrome as
“busy”, however actual movement figures have not been received from the
aerodrome operator. It is unlikely the movements at Lilydale are greater than the
aerodromes assessed in Table 5.
10.2.4 Data Review
Following a review of stakeholder feedback, ASIRs and ESIRs for Melbourne (see
Section 8) the reports indicate that there are no issues with the current airspace
classification and it is operating safely. As described in Sections 7, 8 and 10.1.2 of
this report, data supporting this conclusion was gathered from the following
sources:
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• Airservices;
• Royal Australian Air Force (RAAF);
• CASA (ASAs and FOIs);
• Melbourne airspace users;
• ATSB;
• Bureau of Infrastructure, Transport and Regional Economics;
• AIP;
• Airline schedules; and
• Aerodrome operators.
10.2.5 Conclusion
The airspace around the above aerodromes is Class G, which is overlaid by
Class C, and in some instances Class E. Due to radar surveillance, third party
intervention and other risk mitigators utilised by ATC (SIDs, STARs, air routes
and transponder carriage), the risk in the controlled airspace (Class C, Class D
and Class E) is considered to be ALARP.
In summary, CASA’s evaluation is that all reasonable precautions are in place, as
has been established during the site visits and stakeholder interviews. CASA
therefore has reason to believe that the risk within the Melbourne area is ALARP.
10.3 Environment
The OAR Environmental Specialist reviewed the Melbourne Basin airspace to
examine if there are current aircraft environmental impacts associated with:
• noise
• gaseous emissions
• interactions with birds and wildlife, and
• Environment Protection & Biodiversity Conservation Act 1999 (EPBC Act)
issues.
Noise
The ERSA and AIP DAP entries note applicable aircraft noise abatement procedures
(NAPs). Where NAPs need to be amended, Airservices or the aerodrome operator
consults the aviation and local communities for advice. NAPs are established for the
following aerodromes:
• Avalon
• Essendon
• Geelong
• Kyneton
• Melbourne
• Moorabbin
• Tyabb
An overview of the management of aircraft noise at Melbourne Airport (overseen by
the Department of Infrastructure and Transport) is entitled ‘Melbourne Airport and
Aircraft Noise and the Facts’ prepared by the Melbourne Airport.25 Details on the
25
A copy of Melbourne Airport and Aircraft Noise and the Facts document can be found at:
http://www.melbourneairport.com.au/Media/docs/MEL_AirCraftNoise2010-1cc99754-9603-4f30-b5a2-791b52e94fa0-1.PDF
11 Summary of Issues
The key issues raised by airspace users during the generative interviews,
questionnaires and stakeholder forums have been identified as follows:
• Access to the Melbourne CTR by aircraft operating under VFR is
restricted.
• The absence of co-ordination between Moorabbin Tower and Melbourne
TCU restricts access for VFR flights to the Melbourne CTA.
• The ATS delivered in the Avalon Class D airspace and the Moorabbin
Class D airspace are different. This results in difficulty for flight instructors
to teach students a standard set of procedures when there is no
consistency in the service provided.
• The Moorabbin Flying Training Areas, Danger Areas (D314 and D315),
are no longer sufficient in size for training. Housing development and FNA
effectively reduce the useable size. Frequency management in the training
area (D315), south of the Melbourne Radar boundary, is a concern.
• The NDB and RNAV IAPs for Moorabbin are not contained within CTA.
These IAPs do not meet the CASR Part 173 MOS requirements.
• The buffers for the IAPs for Avalon are not contained within CTA and do
not meet the CASR Part 173 MOS requirements.
• Airspace infringements occur throughout the Melbourne airspace.
• Limited access to ILS navigation aids make IFR training difficult.
• Aircraft holding at the IFR waypoint TEMPL, north of Avalon, will be
contained within Class C and Class E airspace and alternate between the
two classes.
• IFR training at the Cowes NavAids is confined due to the proximity of the
Restricted Areas R323A, R323B and R339.
• A review and update of all VFR reporting and approach points should be
carried out. A number of points such as GMH, Academy and Mount
Cottrell are now hard to identify.
• The VFR route that connects Carrum to Laverton gets congested. The
VFR route follows the edge of Port Phillip Bay from Moorabbin to the BOM
Tower near Laverton takes aircraft within 1 nm of the Melbourne
1,500 foot Class C CTA step.
• Three different height CTA steps intersect within a short distance of the
Bacchus Marsh aerodrome.
• Rising terrain to the west (Brisbane Ranges to south-west and hills to the
west and north west) and the base of the adjacent CTA restrict gliding
operations at Bacchus Marsh.
• Radio communication between aircraft on the ground at the Little River
aerodrome and Avalon Approach is not available.
• AIP errors and omissions:
o The Sunbury East aerodrome is shown on the Melbourne VTC but not
the Melbourne VNC or the Melbourne TAC.
o The Melbourne VTC inset incorrectly shows the western VFR route in
the vicinity of the Laverton BOM Tower.
o The vertical limits of the Restricted and Danger Areas are not depicted
on the VTC Inset.
o The Lethbridge aerodrome is not marked on the Melbourne WAC. It is
marked on the Melbourne VNC and the ERC-L2 Chart.
o Typographical errors on the VTC Inset. The word procedures is
misspelt in the two information boxes.
13 CASA Recommendations
CASA applies a precautionary approach when conducting aeronautical studies and
therefore the following recommendations are made:
1. Representatives from the flying schools in the Melbourne area should meet
with Airservices to discuss options for increasing access to the Melbourne
CTA and CTR by student pilots and VFR aircraft.
2. Airservices should investigate opportunities to co-ordinate VFR departures
from Moorabbin with Melbourne TCU for flights within the Melbourne CTA.
3. Airservices’ Continuous Standards Improvement Section should
investigate the belief that the ATS delivered in Avalon Class D airspace is
different from that in Moorabbin Class D airspace.
4. Airservices should review the IAPs for Moorabbin and Avalon to determine
compliance with CASR Part 173 MOS requirements. The review should
include options for airspace redesign.
5. The Moorabbin Flying Training Areas, Danger Areas D314 and D315,
should be dis-established.
6. An ACP should be submitted by the Victorian Chapter of the Australian
Aerobatic Club to establish a Danger Area for aerobatics north of Tooradin.
7. Airservices’ Safety Promotions team and CASA’s Safety Analysis,
Education and Promotions Division should review the airspace
infringements then formulate and deliver an educational awareness
program for flying in the Melbourne basin and surrounding airspace.
8. The gliding community at Bacchus Marsh should submit an ACP to
introduce a Class C step with a LL of 6,500 ft AMSL to the west.
9. The users of the Little River aerodrome should meet with Airservices to
discuss options for gaining airways clearances whilst on the ground at
Little River.
10. Airservices should review and update the aeronautical charts for
Melbourne.
14 References
The following publications were referred to or used during the compilation of
this report:
• Australian Airspace Policy Statement (2010).
http://www.infrastructure.gov.au/aviation/airspace_reform/files/AAPS_081209.pdf
• Airspace Act, 2007
http://www.comlaw.gov.au/ComLaw/Legislation/Act1.nsf/0/CBB21AA3AFCE9CA7CA2573070008AB2F/$file/0382007.pdf
• Airspace Regulations
http://www.comlaw.gov.au/ComLaw/Legislation/LegislativeInstrument1.nsf/0/303EE4139D03DE87CA2573060008AB0A/$fi
le/0702382A070604EV.pdf
• The Airspace Risk Model (ARM) MBZ/CTAF Analysis by Robert Phillips, updated
February 2002.
• Manual of the Airspace Risk Model (ARM), Acceptable Risk Criteria (ARC) and
Value of Statistical Life by Robert Phillips, Version 1 - June 2006.
• Civil Aviation Safety Regulations Part 173, Manual of Standards:
http://casa.gov.au/wcmswr/_assets/main/rules/1998casr/173/173mfull.pdf
• Establishment and Discontinuance Criteria for Airport Traffic Control Towers, US
Department of Transport, Office of Aviation Policy and Plans, Washington, DC
20591, August 1990.
http://www.faa.gov/regulations_policies/policy_guidance/investment_criteria/media/establish_atct.pdf
• FAA, Aeronautical Information Manual: http://www.faa.gov/air_traffic/publications/ATpubs/AIM/
• FAA, Federal Aviation Regulations: http://www.faa.gov/regulations_policies/faa_regulations/
• Melbourne Airport and Aircraft noise – The Facts
http://www.melbourneairport.com.au/Media/docs/MEL_AirCraftNoise2010-1cc99754-9603-4f30-b5a2-791b52e94fa0-
1.PDF
• Notice of Proposed Change (NPC 172/04) Changes to General Aviation
Aerodrome Procedures (GAAP), Class D procedures, and miscellaneous air
traffic procedures. http://www.casa.gov.au/wcmswr/_assets/main/newrules/parts/172/download/npc172-04.pdf
• Operations at non-towered aerodromes booklet (CASA):
http://casa.gov.au/wcmswr/_assets/main/pilots/download/nta_booklet.pdf
• Safety Bulletin: Airspace Infringements in the Sunbury/Bolinda Area (Airservices)
http://www.airservicesaustralia.com/flying/safety/bulletins/docs/20100916_Sunbury-
Bolinda_Area_Airspace_Infringments.pdf
• Aeronautical Information Publication – effective 18 November 2010
• En Route Supplement Australia – effective 18 November 2010
• En Route Chart Low 2 – effective date 18 November 2010
• Melbourne World Aeronautical Chart – 17th Edition
• Melbourne Visual Navigation Chart – effective date 18 November 2010
• Melbourne Visual Terminal Chart – effective date 18 November 2010
• Terminal Area Chart 3 – effective date 18 November 2010
• Departure and Approach Procedure charts
• Report into CTAF versus CTAF(R) by the Ambidji Group Pty Ltd.
http://casa.gov.au/oar/download/CTAFvCTAF_R.pdf
• National Airspace System Implementation Group, Concept, version 5.0
• National Airspace System (NAS) Australia, 14 December 2001
Annexes:
A. Acronyms and Abbreviations
B. Australian Airspace Structure
C. Definitions and Explanation of Terms
D. Stakeholders
E. Moorabbin Training Area Fly Neighbourly Advice
F. Stakeholder Consultation/ Feedback Register
G. Email from Little River Aerodrome Operator
H. Submission regarding aircraft noise over urban areas
I. Submission regarding skydiving near Point Ormond
Acronym Explanation
MB Moorabbin
ML Melbourne
MOS Manual of Standards
NAPs Noise Abatement Procedures
NAS National Airspace System
NavAid Navigation Aid
nm Nautical Miles
NOTAM Notice to Airmen
NPC Notice of Proposed Change
OAR Office of Airspace Regulation
OCTA Outside of Controlled Airspace
PPR Prior Permission Required
PSR Primary Surveillance Radar
PT Passenger Transport
RAAF Royal Australian Air Force
RAPAC Regional Airspace and Procedures Advisory Committee
RMIT Royal Melbourne Institute of Technology
RNAV Area Navigation
RNP Required Navigation Performance
RPT Regular Public Transport
SDF Step Down Fix
SFC Surface
SIDs Standard Instrument Departures
SIIMS Safety Investigation Information Management System
SIS Surveillance Information Service
SP Special Procedure
SSR Secondary Surveillance Radar
STARs Standard Instrument Arrival
SVFR Special Visual Flight Rules
TAC Terminal Area Chart
Traffic Alert and Collision Avoidance System (a proprietary term, often used
TCAS
in lieu of ACAS)
TCU Terminal Control Unit
TMA Terminal Area
Transponder Exemption against the requirement for carriage of SSR transponder for
exemption aircraft certified without an engine–driven electrical system
TWR Tower
UAV Unmanned Aerial Vehicle
UK United Kingdom
USA United States of America
VFR Visual Flight Rules
VHF Very High Frequency
VIS Visibility
VMC Visual Meteorological Conditions
VNC Visual Navigation Chart
VOR VHF Omni-Directional Radio Range (navigation aid)
VTC Visual Terminal Chart
WAC World Aeronautical Chart
YLRV Little River Aerodrome
YMAV Avalon Aerodrome
YMEN Essendon Aerodrome
YMMB Moorabbin Aerodrome
Danger Area: The declaration of a Danger Area defines airspace within which
activities dangerous to the flight of aircraft may exist at specified times. Approval for
flight through a Danger Area outside controlled airspace is not required. However,
pilots are expected to maintain a high level of vigilance when transiting Danger
Areas. Danger Areas are primarily established to alert aircraft on the following:
Flying training areas where student pilots are learning to fly and / or gather
in large numbers;
Gliding areas where communications with airborne gliders might be
difficult;
Blasting on the ground at mine sites;
Parachute operations;
Gas discharge plumes; and
Small arms fire from rifle ranges.
Annex D – Stakeholders
The following organisations were invited to provide input to the study.
Position Organisation
Aviation Safety Advisor Safety Analysis & Education Division, CASA
Flying Operations Inspector Operations Division, CASA
Senior Defence Advisor Department of Defence
Regulatory Services Manager,
Airservices Australia
Safety and Environment
Chief Instructor Adventure Airsports
Chief Flying Instructor Aerial Extras
Chief Instructor Aerial Skydives
Chief Flying Instructor Aerochute International
Chief Pilot Aerovision
President Aircraft Owners and Pilots Association
Director Airlines of Tasmania
Chief Flying Instructor Airsports Flying School
Chief Pilot Alliance Airlines
Chief Pilot Australasian Jet
Chief Pilot Australian Air Express
Secretary Australian Airports Association
President Australian and International Pilots Association
Victorian & Tasmanian Delegate Australian Balloon Federation
Manager Australian Federal Police - Melbourne
Technical Consultant Australian Federation of Air Pilots Association
Chief Pilot Australian Helicopters
Aerodrome Operator Australian Pacific Airports (Melbourne) Pty Ltd
Chief Executive Officer Australian Parachute Federation
Chief Instructor Australian Skydive
Aerodrome Operator Avalon Airport
Aerodrome Operator Bacchus Marsh Aerodrome Management Inc.
Chief Flying Instructor Bacchus Marsh School of Aviation
Chief Flying Instructor Ballarat Aero Club
Chief Pilot Baycity Seaplanes
President Beaufort Gliding Club
Chief Pilot Bendigo Aviation
Chief Flying Instructor Bendigo Flying Club
President Bendigo Gliding Club
Chief Flying Instructor Bendigo Recreational Aviation School
Chief Flying Instructor Bini Flight Training
Chief Pilot Choppair Helicopters Pty Ltd
Aerodrome Manager City of Ballarat
Aerodrome Manager City of Greater Bendigo
President Civil Air
Head of Flight Operations Cobham Aviation Services
Chief Instructor Commando Skydivers Incorporated
Manager Country Fire Authority - Victoria
Chief Pilot Crown Melbourne Limited
Chief Pilot De Bruin Air Pty Ltd
Manager Department of Sustainability and Environment - Victoria
Chief Instructor Direct Air / National Aerospace Training
Chief Pilot Elstone
Chief Executive Officer Essendon Airport
Operations Manager Essendon Executive Jet Charter
Chief Pilot Executive Airlines
Chief Pilot / Chief Flying Instructor Geelong Aviation & Flight Training
President Geelong Gliding Club
Chief Pilot Geelong Helicopters
President Geelong Sports Aviators
Victorian Airfields and Airspace Officer Gliding Federation of Australia
Chief Flying Instructor Golden Plains Flying School
Position Organisation
President / Chief Flying Instructor Goulburn Valley Soaring
Aerodrome Manager Greater Shepparton City Council
Manager Hang Gliding Federation of Australia
Chief Pilot Helicopter Resources Pty Ltd
Chief Pilot Helicopters Victoria
Chief Pilot Heli-Serv Pty Ltd
Chief Flying Instructor Inbound Aviation
Chief Pilot Interair Pty ltd
Chief Pilot Jayrow Helicopters Pty Ltd
Chief Pilot Jet City
Chief Pilot Jetstar Airways
Chief Pilot Kefford Aviation
Chief Pilot King Island Airlines
Chief Pilot Kirkhope Aviation Pty Ltd
President Kyneton Aero Club Inc.
Aerodrome Manager Latrobe Regional Airport Board
Chief Flying Instructor Latrobe Valley Gliding Club
Aerodrome Manager Leongatha Aerodrome Users Pty Ltd
Aerodrome Operator Lethbridge Airpark
Chief Pilot Lift Air Pty Ltd
Aerodrome Operator Lighthouse Olive Grove
Chief Flying Instructor Lilydale Airfield Pty Ltd
Aerodrome Operator Little River Aerodrome
Aerodrome Manager Mangalore Airport Pty Ltd
Chief Flying Instructor Melbourne Flight Training
Chief Flying Instructor Melbourne Gliding Adventures
Chief Instructor Melbourne Microlights
Chief Instructor Melbourne Skydive Centre
Chief Pilot Melton Air Services
Manager Metropolitan Fire and Emergency Services Board
Chief Pilot Microflite Helicopter Services
Chief Flying Instructor Mission Aviation Fellowship
Aerodrome Operator Moorabbin Airport Corporation
Chief Pilot / Chief Flying Instructor Moorabbin Aviation Services
Chief Flying Instructor Moorabbin Flight Training Academy
Chief Pilot Moorabbin Flying Services
Chief Flying Instructor Oasis Flight Training
Chief Pilot / Manager Oxford Flying Academy
Chief Pilot Pearson Aviation
Aerodrome Owner Penfield Enterprises Pty Ltd
Chief Flying Instructor Peninsula Aero Club
President Point Cook Aero Club
Chief Pilot Police Air Wing - Victoria
Chief Pilot Professional Helicopter Services
Operations Manager Qantas Airways
Deputy Chief Pilot QantasLink Airways
Chief Pilot R.L. Aviation Pty Ltd
Aerodrome Operator RAAF Air Base Command Post
Operations Officer RAAF Museum
Aerodrome Operator Range Control Officer
Operations Manager Recreational Aviation Association of Australia
Coordinator Regional Airspace and Procedures Advisory Committee
Chief Executive Officer Regional Aviation Association of Australia
Group Safety Manager Regional Express Airlines and Pel-Air Aviation
Aerodrome Operator Riddell Aerodrome
Aerodrome Operator Romsey Aerodrome
Chief Pilot Rotorwing Helicopters
Flight Operations Manager Royal Flying Doctor Service (South Eastern Section)
Chief Flying Instructor Royal Melbourne Institute of Technology
Position Organisation
Chief Flying Instructor Royal Victorian Aero Club - Moorabbin
Chief Flying Instructor Royal Victorian Aero Club - Coldstream
Chief Pilot / Chief Flying Instructor S.T. Aviation Training Academy
Chief Flying Instructor Sarge's Light Sport Aviation
Chief Flying Instructor Secure Air Flight Training
Chief Pilot Sharp Airlines
Chief Pilot Shortstop Aviation
Chief Instructor Skydive Nagambie
Chief Flying Instructor Skyscooters
Director SkyWest
Aerodrome Operator South Barwon Air Services
Chief Flying Instructor South Gippsland Gliding Club
Aerodrome Operator St Leonards Aerodrome
Manager State Emergency Service - Victoria
Aerodrome Operator Sunbury East Aerodrome
Chief Pilot Surf Coast Helicopters
Chief Pilot Tas-Air Pty Ltd
Chief Pilot TasFast Air Freight Pty Ltd
Chief Pilot Tasman Cargo Airlines Pty Ltd
Aerodrome Operator TGS Air Charter
Chief Pilot The Helicopter Service
Chief Pilot Tiger Airways
Chief Flying Instructor Tooradin Flying School
Chief Pilot Torqair
Chief Pilot / Chief Flying Instructor Tristar Aviation
Chief Instructor Upper Yarra Microlights
Chief Pilot Victorian Air Ambulance
President Victorian Hang Gliding and Paragliding Association
Chief Pilot Vintage Tiger Moth Joy Flights
E-Jet Fleet Standards Manager Virgin Blue Airlines Pty Ltd
Chief Pilot Vortex Air / Elite Training Academy
Secretary Wangaratta Aero Club
Chief Flying Instructor Woorayl Air Services
Operations Manager XJET
Aerodrome Operator Yeaburn Aerodrome
Chief Pilot Yungur Aviation Services
Craig Williams Aircraft noise over The volume of aircraft traffic over the
coast and the city of Kingston. Comments Yes.
Aspendale resident urban areas.
4 forwarded to
(Submission attached as Airservices. ED11/143642
ED11/123369 Annex H).
Stakeholder / CASA
No. Reference Comment Action Response
Commentator response
Airservices have
Airservices Australia Yes.
1.2 Issues created a work
5 13 May 2011
Bullet Point 16
Chart errors and omissions.
package to rectify
ED11/130689
the errors identified.
ED11/99460
Airservices Australia
13 May 2011 The Melbourne Visual Pilot Guide
1.3 Findings and Details forwarded to Yes.
would be an ideal platform to create
6 Conclusions
awareness on frequency management
Agreed CASA Safety
ED11/99460 Bullet Point 6 Promotion team. ED11/130689
in the south of the Melbourne Basin.
Stakeholder / CASA
No. Reference Comment Action Response
Commentator response
Further consultation
with industry and
Airservices will need
to take place before
We agree that some Moorabbin entry any changes are
Oxford Aviation
points are difficult to identify. “GMH” made. Yes.
22 June 2011 7.4.13
8 Entry Points
could be changed to “Lysterfield Lake”
and “Academy” to an appropriate point Information ED11/141123
ED11/132007
on the “Eastlink”. forwarded to local
CASA Aviation
Safety Advisors and
Flying Operations
Inspectors.
The concept of skydiving being
encouraged at an extremely busy
Comments have
Oxford Aviation Class D tracking point is dangerous.
7.4.18 been forwarded to Yes.
22 June 2011
9 Skydiving near
The mixing of these activities is not
the Sports Aviation
Point Ormond Section within ED11/141123
ED11/132007 compatible due to the volume of aircraft
CASA.
traffic near Point Ormond. It should not
be allowed.
Flying instructors are encouraged to
ring ML TMA prior to flight planning to
maximise access to ML CTA. Many
VFR aircraft are now utilising a VFR
route from Sugarloaf Reservoir - Comments have
Civil Air Kilmore at low levels within CTA as this been forwarded to
1.4 Yes.
24 June 2011 route is generally able to be the CASA Aviation
10 Recommendations
accommodated. In addition, instructors Safety Advisors to
(1) ED11/141528
ED11/133847 for training Night VFR sorties should discuss with local
ring prior to flight planning to enable the operators.
route selected to have maximum
opportunity for flight within CTA given
ML duty runways and traffic
expectations.
Stakeholder / CASA
No. Reference Comment Action Response
Commentator response
VFR departures from Moorabbin that
plan via overhead ML are generally not
able to be given clearance due to
airspace congestion in the area and no
aircraft may overfly ML below 6,000 ft
AMSL due to congestion. These VFR
aircraft can conflict with a variety of
higher priority aircraft and providing an
Comments have
airways clearance to them can result in
Civil Air been forwarded to
1.4 the short notice cancellation of RPT Yes.
24 June 2011 the CASA Aviation
11 Recommendations SID/STAR clearances. This impacts
Safety Advisors to
(2) upon the systemic separation applied ED11/141528
ED11/133847 discuss with local
within the ML TCU. This issue is not
operators.
related to coordination opportunities
between Moorabbin and ML TCU. As
ML traffic increases the opportunities to
overfly ML will decrease. As an
example, in Sydney TCU aircraft
cannot overfly Sydney below 10,000 ft
AMSL due to traffic and frequency
congestion.
Avalon airspace should be reviewed, in
particular the use of E airspace, as it is
overly complicated and seems poorly
understood by most operators. This
lack of understanding of the airspace
indicates a lack of success in the
Civil Air
1.4 training program when the D/E Operations at Yes.
24 June 2011
12 Recommendations airspace was introduced. Additionally, it Avalon are being
(3) is obvious that D/E radar airspace monitored. ED11/141528
ED11/133847
controlled by an approach unit
providing a radar service would be
run differently to a D tower (formerly
GAAP), which relies more on visual
separation. This is a natural
consequence of the differing separation
Stakeholder / CASA
No. Reference Comment Action Response
Commentator response
tools available to each unit. If
standardisation is important in this area
then control should be returned to
Avalon Tower rather than ML TCU.
As the report writers would be aware
extending CTA to contain Moorabbin
IAPs would significantly extend
Moorabbin airspace and impact on
many currently OCTA VFR routes in
the vicinity of ML. In short VFR access
to the Sugarloaf Reservoir - Kilmore
Civil Air VFR route and the Coastal route to the
1.4 A review of the Yes.
24 June 2011 west would require clearances through
13 Recommendations
CTA. During the process of
containment of IAPs
(4) is underway. ED11/141528
ED11/133847 implementing the D towers this Part
173 MOR requirement was raised and
dismissed. Investigation into the
process for this change may reveal
issues in relation to the timeframe
provided for such a significant change
as opposed to the timeframe required
for map and airspace changes.
This airspace would create another non
standard step in the ML CTA.
Preceding points reflect on the effects
An ACP has been
of complicated and non standard
Civil Air received from the
1.4 airspace boundaries and increases in Yes.
24 June 2011 local gliding
14 Recommendations airspace penetrations as a result. We Disagree
communities. A
(8) question the overall value of ED11/141528
ED11/133847 consultation process
disestablishing this airspace, rather
has commenced.
than NOTAMing the airspace as
required by the gliding community as is
currently done.
Stakeholder / CASA
No. Reference Comment Action Response
Commentator response
We believe this issue was resolved
Situation should be
shortly after ML TCU assumed control
monitored. Little
of the overlying airspace by providing
Civil Air River aerodrome
1.4 the operator with the phone number for Yes.
24 June 2011 users and
15 Recommendations the ML TM. This allows the operator to
Airservices should
(9) be issued with an airways clearance on ED11/141528
ED11/133847 maintain
the ground at Little River (as they
discussions on the
previously did with Avalon Tower when
issue.
they controlled the airspace).
CTA steps for all TCUs no longer
provide constant descent profiles for
RPT aircraft. These steps were
designed prior to economy fuel settings
and on any arrival which has CASA is
Civil Air approximately 35nm or less to the conscious of CTA steps are
Yes.
24 June 2011 runway aircraft will level off multiple the benefits of reviewed as part of
16 CTA Steps
times (depending on aircraft type) prior constant Aeronautical
ED11/141528
ED11/133847 to being cleared for an approach. CTA descent studies.
steps for all major airports should be approaches.
reviewed as a matter of urgency,
with a view to standardisation and
containment of constant descent
profiles.
Avalon CTA does not effectively
contain the IAPs for runway 36 as
Civil Air
aircraft must generally fly OCTA to A review of the Yes.
24 June 2011
17 Avalon CTA steps get to approach commencement containment of IAPs
positions. Avalon airspace needs is underway. ED11/141528
ED11/133847
significant review to be effective and
more standard for RPT operations.
Concern over proposed skydiving Comments have
Paul McLennan
7.4.18 activity near Point Ormond. been forwarded to Yes.
22 June 2011
18 Skydiving near the Sports Aviation
Point Ormond (Submission attached as Section within ED11/141450
ED11/132010
Annex I). CASA.
1. The statement under section 7.4.19 is not entirely correct. It should be clarified that more
often than not pilots are able to contact Avalon Approach by telephone to gain departure
clearances however the following issues are of concern:
* The phone is not always answered when Avalon Approach is contacted by
telephone (03 9235 7337 is the phone number that has been provided to YLRV). On a couple
of occasions it has taken up to three calls to get an answer.
* Once phone contact is established with Avalon Approach the pilot is generally asked
to wait on hold while the person who answers the call gets in touch with the air traffic controller
on the Avalon Approach desk to request a clearance. The clearance is then provided to the
pilot by the messenger and hence the pilot does not hear the express instructions from the
responsible controller. This has not proven to be a problem to date other than the fact that it is
an unnecessarily complex process that could potentially result in misinterpreted instructions.
* Telstra mobile service is available at YLRV however other service providers have
very poor signal strength and often it is impossible to make a call.
* Not all pilots carry mobile phones. Pilots who do carry mobile phones are often
forced to shut down their aircraft when ready for departure to allow them to remove their
headsets and subsequently make a call in an environment without background noise.
* If pilots make a call for a clearance prior to getting into and starting their aircraft, it
can be up to 15 mins later that the departure occurs due to taxi and warm-up time. This is
potentially risky in relation to any change in the airspace that may occur during that time.
2. The best outcome for YLRV, YMAV and Avalon Approach would be the installation of a VHF
radio communications repeater in an appropriate geographical location to ensure that ground
coms are available at YLRV. This would ensure that departure clearances for aircraft at YLRV
can be obtained directly from Avalon Approach by VHF 133.55. The repeater could be located
at YLRV.
3. If a radio repeater is not a viable option, special procedures for departures (without clearance)
from YLRV should be considered on the basis that the airfield is located in close proximity to
the 1500ft step. YLRV is a private Prior Permission Required (PPR) airfield and hence any
aircraft that transits through the airfield would be provided with instructions for departure
procedures. It should be noted that aircraft on the ground at YLRV can hear radio calls from
inbound and outbound airborne aircraft on the Avalon Approach frequency and hence the
aircraft on the ground is likely to be aware of cleared movements by listening to radio calls and
associated read backs from airborne aircraft.
The issues section of the draft report notes “The VFR route that connects Carrum to
Laverton gets congested. The VFR route follows the edge of Port Phillip Bay from
Moorabbin to the Bureau of Meteorology (BOM) Tower near Laverton takes aircraft
within 1 nm of the Melbourne 1,500 foot Class C CTA step”, and it is of concern that
skydiving activities have been approved adjacent to Point Ormond on that route as
noted in Section 7.4.18, and from information provided by Port Phillip Council other
councils including Melbourne and Bayside are also considering inviting skydiving
operations in this route.
1. Point Ormond is a designated tracking point, on the busy Port Philip Bay coastal
route with fixed and rotary wing aircraft operating at various altitudes in both
directions below 2500 FT, the lower limit of Melbourne Centre,
2. it is located just north of Brighton (BTO), a common inbound approach point for
traffic entering the Moorabbin Class D airspace and it is around this point that
many aircraft will be listening to the YMMB ATIS and then changing to YMMB
TWR,
3. it is located just south of Station Pier (SNP), a common inbound approach point
for traffic entering the Essendon Class C airspace and it is around this point that
many aircraft will be listening to the YMEN ATIS and then changing to YMEN
TWR, and
4. it is also location that is frequently used by aircraft transiting from the south east
or east (such as Tyabb, Tooradin, Lilydale and the Latrobe Valley) to the west,
and visa versa, wishing to avoid Melbourne Class C and Moorabbin Class D
airspace.
A common local area flight from Moorabbin has aircraft departing to the north
tracking near Caulfield racecourse then turning west and rejoining the coast just
north of Point Ormond. While I believe most, especially those with two VHF radios
listen to both 135.7 (ML CEN) and 123.0 (MB TWR W), I understand it is not
uncommon for aircraft operate solely on 123.0. Traffic coming from the south, either
departing Moorabbin or tracking costal through the YMMB zone may possibly on the
YMMB TWR frequency at the time of the initial (5 minute) and subsequent (2 minute)
drop announcements as outlined in the attached documents.
In addition to frequent commercial operations, tracks through and via Point Ormond
are commonly used by low time pilots on cross country flights or sharing the
experience of flight with family and friends. I am very concerned about the increased
risk of the proposed operations what is already a busy location, and the potential for
a fatal accident. Also, as the area is outside controlled airspace there is no
requirement for aircraft to have a radio fitted or operating, and while these would be
in the minority they are there. If the Skydive on the Beach operations are to be
conducted at Point Ormond as proposed, I recommend that notification should be
made more broadly including on the YMMB ATIS and also possibly by YMMB TWR
West for departures and transits, and similar notifications from YMEN. Additionally I
would recommend advising all flying schools in and around the Melbourne Basin as
well as seek publicity through aviation organisations and commercial aviation
publications.
I have previously expressed these concerns to the CASA Director of Aviation Safety,
CASA OAR, CASA Southern Region, Air Services Australia National Operations,
Skydive the Beach Melbourne (the operator) and the Australian Parachute
Federation.
Regards
Paul McLennan