Tuesday, March 18, 2008

RA-Aus Official Response to CTAF (R) Establishment


Mr Peter Cromarty
General Manager
Office of Airspace Regulation
Civil Aviation Safety Authority

Dear Peter,

RE: Establishment of CTAF (R)
In the past RA-Aus has been a firm supporter of the consultative process undertaken by Airservices Australia and the AERU team with regard to changes of airspace and indeed changes to CTAF(R)s.

RA-Aus also supported the formation of the OAR as we believed that the service provider should not be the regulator as well. However recent events with regard to the OAR’s ‘Blanket’ creation of CTAF(R)s at all Passenger Transport Operation(PTO) Aerodromes have directly shaken our confidence in the consultation process demonstrated by the OAR.

RA-Aus believes that this unilateral move by OAR will destroy years of successful industry consultation. RA-Aus and Industry incur substantial costs to attend a variety of consultative forums of which OAR is only one. If OAR is to disregard the inputs provided by industry during the consultative process than RA-Aus would be better served to take the political route in getting our viewpoint across to Government. The current move to create ‘blanket’ CTAF(R)s is in direct opposition to CASA Directive 1/2007 and also the Australian Airspace Policy Statement (AAPS) for which no cost benefit or risk management process has been undertaken.

The process used by AERU successfully in the past have been essentially Option 3 and it is the only option under the present Discussion Paper(DP) that conforms to the AAPS.

We are also keenly aware of the implications of enmasse CTAF(R)s and their direct correlation to the introduction of ADS-B in the future. RA-Aus understands the desire of the airlines to mandate radio at all PTO aerodromes, however we believe that normalising deviation from the ideals of NAS (US) is creating another unique Australian Airspace System problem that NAS was introduced to alleviate.

Phone: (02) 6280 4700 Fax: (02) 6280 4775 E-mail: admin@raa.asn.au


RA-Aus believes that the perceived safety benefit increase of mandating radio at a wide number of PTO aerodromes is unreliable at best and unless OAR is responsible in their duty of care and follow the required government protocols as per the AAPS and address this subject with a risk based/cost benefit analysis method, the impact will severely affect not only current operations but also future confidence in CASA’s ability to consult with industry.

RA-Aus strongly supports Dr. Bob Hall’s letter of the 22nd of February 2008 to you on the introduction of the new CTAF(R) aerodromes and further more RA-Aus will vigorously oppose any such endeavour to mandate restrictions on current freedoms where no safety case is first demonstrated.

RA-Aus remains committed to the consultation process however finds it difficult to justify expending considerable time and money on consultation with government bodies that wish to repeal strategic directions put in place by their predecessors in order to effect outcomes different to those already agreed in principle during the consultation process.

RA-Aus does not believe that OAR is fulfilling it’s obligation as the airspace regulator if it bypasses government protocols such as the AAPS in favour of more powerful vested interests at the expense of equitable airspace access for all users.


Lee Ungermann
CEO Recreational Aviation Australia Inc.

Bruce Byron, CASA
Bob Hall, ASAC
Tim Blatch, AOPA