I have copied this from Lee's email so if you accidently delete your email or forget where you put it... here it is...

As you may already be aware, a Notice of Proposed Rule Making (NPRM) was issued on 28th September by CASA on the dual topics of:

- mandatory carriage of radios at non-towered aerodromes or in the vicinity

- changes in CAR 166 & 166A governing operations at or near non-controlled aerodromes.

Regulatory amendments are not expected to be effective until early 2010, if the changes go ahead. A brief summary of the proposal and CASA’s view point is given below but we do recommend you read the NPRM yourself for full details. (There is a neat, single page, summary of proposed changes on page 8 of the document.)

This is your opportunity to express your opinions to CASA. So follow the link below to the CASA website, read the NPRM and have your say. CASA will accept comments via email, fax, post or through CASA’s online comment facility – details of these can be found at the bottom of this webpage: http://casa.gov.au/scripts/nc.dll?WCMS:PWA::pc=PC_93417  The deadline for replies to CASA is close of business, 23rd October 2009. Please do not reply to this email as the address is not monitored.

In essence, the proposed changes to radio procedures are:

· For all pilots to make recommended, standard radio calls (as published in CAAPs & the AIP) when at or near non-towered aerodromes. (Key Proposal 1)
 

o Making the appropriate calls is to be a performance based regulatory requirement for pilots flying radio equipped aircraft and qualified to use the radio.
 

o It will be the Pilot in Command’s responsibility to broadcast on the aerodrome frequency whenever necessary to avoid collision or the risk of collision.
 

· For operations at or near certified, registered or other designated aerodromes (as published in ERSA) it will be compulsory to carry a serviceable VHF radio and be qualified to use it. (Key Proposal 2)
 

o Portable VHF transceivers will still count.
 

· New rules covering the arrival and departure of aircraft which have no radio communication – either because they are not radio equipped, the radio is unserviceable or the PIC is not qualified to use the radio. (Key Proposal 3)
 

The NPRM also proposes to withdraw the following paragraphs from the “Civil Aviation Regulations 1988 - Reg 166 - Operating in vicinity of a non-controlled aerodrome”:

· (2) (d) & (4) - It would now be permitted to join on base leg. (Key proposal 4)
 

· (2) (g) - There would no longer be a requirement to have a minimum length for final approach. (Key Proposal 6)
 

· (3) (a) - It would not be required to carry a VHF radio when conducting straight-in approaches (except at certified,
 

registered or other specially designated aerodromes). (Key Proposal 7)
 

· (3) (b) - There would no longer be specific mandatory broadcasts for straight-in approaches (although such broadcasts would still be recommended in other publications). (Key Proposal 8)
 

and proposes to amend these paragraphs:

· (2) (f) - if the aircraft is able (and permitted to by its flight manual) landings & takeoffs may be made on runways which are not into wind. (Key Proposal 5)
 

· (3) (d) - The minimum distance from the threshold for an aircraft to be lined up on final approach would be no less than 3 miles. (Key Proposal 9)
 

In the NPRM there are several different options for how the radio carriage may be implemented, and several options for how the radio use may be implemented. Section 3.4 “Key changes proposed in this NPRM” contains further information on what CASA would like to implement.

CASA’s stand, with respect to radio carriage:

“Option 1 – Mandate radio carriage for operations into registered or certified non- towered aerodromes (as published in ERSA) and other aerodromes designated (and published in ERSA) by CASA on a case-by-case risk basis:
 

· would give greater protection to all aircraft users of registered or certified aerodromes;
 

· would capture all high capacity RPT-serviced aerodromes;
 

· could be applied to capture all passenger transport operations;
 

· would serve to amalgamate CTAF and CTAF(R) aerodromes;
 

· would be a much broader mandate than the current requirement;
 

· would not be harmonised internationally.
 


 

3.3.2.3 This option would be the broadest reasonable requirement for radio carriage and would have the advantage of obviating the need to address operational safety risks at non-towered aerodromes on a case-by-case basis, potentially at significant cost to CASA. The vast majority of aircraft flying into certified or registered aerodromes are already radio-equipped, so a regulatory mandate for radio carriage at these aerodromes could be expected to have very little cost impact on operators.
 


 

3.3.2.4 It should be noted when considering this option that it is intended to make provision for radio unserviceability and non-radio aircraft (see paragraph 3.4.1.1)”
 

And with respect to radio use:

“Option 2 – General regulatory requirements for radio broadcasts, with specific recommended standardised calls published in education and guidance material
 

· Would involve a relatively simple ‘use your radio’ regulation supplemented by the publication of education and guidance material/aeronautical information publications to explain what positional broadcasts are recommended.
 


 

3.3.3.3 A possible argument against this option may be that, whilst the supplementing educational material could be immediate (e.g. booklets, AIP, magazines), its effectiveness would not be easy to determine. There would also be a need for the educational process to be sustained over a period of time, by way of flight reviews for example.”
 

If you wish to submit your own thoughts, or perhaps suggest a preferable alternative listed as one of the other options, then your chance is NOW!

The RA-Aus stand on this:

We do not support mandatory carriage of radios. We do strongly recommend that pilots who use aerodromes with heavy traffic have radios, and obviously CTAF(R) aerodrome users are currently required to have and use radios. However, we also recognise that many of our pilots do not operate in busy or CTAF(R) locations and they shouldn’t be compelled to purchase something they’re unlikely to use.

With respect to the radio use, RA-Aus does not object to the commonsense approach shown in Option 2 above. Standardised calls would be recommended, but left to the individual pilot’s judgement to make depending on the circumstances.
 

As with anything, the more responses which are received by CASA, the more likely it is that you will be heard.

So to make life easy for you, here’s the link which takes you direct to CASA’s online response: http://casa.gov.au/scripts/submit.asp?session=834307192&pc=PC_91112&nprm=NPRM%200908OS

Yours sincerely,

Lee Ungermann

Chief Executive Officer
 

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