Recreational Aviation Australia (RAAus) has called for the government to develop a National Airspace Strategy to ensure all users have equal access to Australian skies.
The call was contained in RAAus' response to Airservices Australia's second proposal to lower the base of Class E on the eastern seaboard, which was submitted last Friday. RAAus has rejected the revised proposal stating that Airservices has still not established a reason for the change.
"The establishment of a National Airspace Strategy would provide a ‘roadmap’ or similar, for government, its agencies and industry, to work towards in assuring that an acceptable level of risk is achieved in relation to airspace design and operational procedures.
"Furthermore, RAAus maintains the firm position that where an airspace risk warrants airspace design changes, that a proven and noncomplex design criterion should be applied wherever possible and that it must–by law–be done in accordance with the Australian Airspace Policy Statement (AAPS) and the Airspace Act 2007."
RAAus said a National Airspace Strategy would determine the equipment required for airspace categories well in advance, to enable airspace users to prepare for change and ensure no-one is disadvantaged by "poor planning or an inadequate safety case by government or its agencies."
RAAus recommended also that their members be allowed access to controlled airspace as part of that strategy and also called for a review of the effectiveness of the Australian Strategic Air Traffic Management Group (ASTRA).
In supporting their rejection of the revised proposal that would see the base of Class E lowered from 8500 to either 6500 or 4500 feet AMSL with a minimum terrain clearance of 1360 feet, RAAus stated that some aircraft don't have the panel space to install a transponder as would be required in Class E, and called for Electronic Conspicuity (EC) devices to be a permitted alternative.
The organisation also criticised Airservices for not supplying a valid safety case and accused it of designing airspace to suit its own needs.
"It is the contention of RAAus that this unique and overly complex airspace design proposal will introduce further risk for all airspace users whilst not meeting the requirement to provide equitable use of airspace, as prescribed under the Australia Airspace Policy Statement 2018.
"This proposal introduces a clumsy and overly complex design without being clear on the issues it is trying to address.
"It is simply an impractical concept to expect aircraft to climb and descend to remain outside of the Class E based upon a design that aligns with existing ATC sector boundaries, communication and surveillance coverage and terrain, rather than mitigating against specific risks.
"In other words, the design meets the objectives of the designer rather than the user."
The consultation period for the proposal closed last Friday 30 April. More information is on the Airservices Australia engagement website.