Option 1 is: That the CAA adopts the Massey CFZ proposal for aircraft-to-aircraft communications, and keeps FISCOM for aircraft-to-ground information.
I have difficulty in understanding how the CAA/Airways proposals would work in practice.
I came up with a number of reasons why the CAA/Airways solution would create a negative safety factor. I’d been considering for some time that Masterton aerodrome (to name but one location) would benefit from a CFZ.
On busy weekends, whilst ‘meat bomb’ dropping, I’m having to contend with not only communications with Ohakea Control, which works better on the frequency assigned for the Manawatu Gorge area at altitude, rather than that published for the Wairarapa … Hence, not always hearing the other traffic in the area that originate calls to Control. Not a big problem in controlled airspace, as long as traffic information is relayed from Control etc.
More important is the fact that I can hear most of both Islands’ traffic on 119.1 MHz when at altitude, making it sometimes a little difficult to assess the ‘relevant’ traffic situation around Masterton. This is irrespective of the argument whether these stations should be operating on 119.1 MHz in the first place.
Now consider the situation where aircraft outside of a 10 nm radius, operating on the assigned FISCOM, may or may not switch to 119.1 when overheading the airfield. Which, as I believe was suggested, was that there was no need for them to do so if above 3000 ft AAL (or lower). This potentially occurs a number of times a day, and when parachute dropping, I at least get to know of their presence on 119.1 (or a CFZ) and can advise them to remain clear when a conflict would occur.
1. Therefore, the use of FISCOM whilst en-route could/would increase the possibility of an aircraft/parachute conflict. (I’m not monitoring FISCOM.)
2. Using a dedicated CFZ would cut down on all the extraneous radio traffic currently on 119.1, limiting it to only aircraft within the operational area.
3. The use of FISCOM, then ‘local’ frequencies’ of airfields within 10 nm, may actually increase the workload for the transiting pilot.
4. As with the use (overuse or inappropriate use?) of 119.1 MHz, how would FISCOMs handle the radio traffic and again, the potential of radio ‘overload’ and pertinent information not being heard (by both pilots and FISCOM controllers)?
5. FISCOM handled by remote towers such as Dunedin, Napier, Gisborne etc: Can they handle it? Maybe not, especially when dealing with scheduled aircraft movements in and out of their aerodromes.
6. Use FISCOM for safety and ‘flight following’ where required. Again, a chance to miss vital information if everyone is operating on these frequencies for general position reporting.
7. If CAA/Airways have to define physical geographic areas for FISCOM boundaries, why not just use these boundaries for new dedicated CFZs. Keep it simple!
8. The argument that CFZs are not mandatory is fallacious. It’s good airmanship to use the CFZ frequency… just make it mandatory. Simple again!
9. Your comment concerning coverage is extremely valid and I very much doubt that can be improved without a big increase in radio infrastructure nationally.
10. As to the lack of frequency availability for dedicated CFZs… again, I don’t believe this is a problem; even if CFZs somewhere in Northland, southern Hawke’s Bay and Southland shared a frequency, would this be a problem for most traffic in these areas below 9500 ft? Certainly much better that the current 119.1 MHz.
11. What happens in the event of Christchurch going ‘off-line’ again, as in the last big earthquake? Having been in upper airspace on survey that day, most things came to a halt. Imagine this happening to all airspace if the FISCOM proposal went ahead.
Mike Haines may wish to consider this, which I see as a major potential problem and not unique to the Masterton area.
1. The Massey CFZ proposal for aircraft-to-aircraft, and FISCOM for aircraft-to-ground. Provided CAA were to accept this concept, it would be the quickest and most cost-effective proposal to implement. Implement CFZ boundaries, assign either dedicated or non-adjacent frequencies and leave the FISCOM for emergency and flight-following.
Which is what a lot of pilots understood its purpose was and, I believe, are still being taught.
There will be large areas of NZ where there are no requirements for CFZs, so the use of a FISCOM frequency makes sense, in addition to overlapping CFZ boundaries where established.
2. An enhanced FISCOM service using new Airways frequency technology to separate adjoining, re-drawn FISCOM areas and to eliminate, as much as possible, “out of area transmissions”. This possibility could merge the two proposals together and thus get the best of both. It is, however, unknown at this stage whether it is feasible both technically and operationally.
Option 2 re-invents the wheel to an extent and does not resolve many issues. Plus, new radio equipment may be required to utilise the new radio technology, especially 8.33 KHz channel spacing. Everyone would need to change to new radio equipment, as in Europe.
3. Keep FISCOM as it is as present, do away with all CFZs thus eliminating radio “clutter”, which would then encourage pilots to remain more vigilant with their lookouts rather than becoming complacent and relying on a radio call in a CFZ to disclose other traffic.
Option 3 would be a retrograde step all-round, especially from a safety point of view (i.e. my example of parachute dropping and not knowing who is ‘lurking’ over the drop zone… not to mention me meeting them on the descent).
As an afterthought, the ideal emergency ‘service’ for aircraft might resemble the UK’s Distress & Diversion function on 121.5 MHz. As you may know, this relies on reception by at least one ground station (but the more the better as each ground site has direction-finding capabilities). This allows for triangulation of received signals, which also has assistance from the still-extensive primary radar coverage for identification and diversion purposes.
NZ may not be in a position to fund the D&D type system (minus radar, of course); however, what a great safety net for flyers! Leaving just ‘flight-following’ to FISCOM frequencies… This may aid aircraft not fitted with a transponder but that carry EPIRBS/ELT/PLBs etc to be ‘tracked’ on 121.5 (as well as being monitored by a lot of passenger aircraft).
I believe there needs to be more thought on this matter; however, I firmly believe the Massey/CFZ proposal to be by far the best solution.
I am very pro-CFZ; it has worked really well for us here in Hastings. It is simple and robust. Have not got a lot of experience with FISCOM, hardly ever use Chch Information.
The Massey proposal seems reasonable, the CAA appears to be suggesting a similar idea can be enabled using FISCOM frequencies. I think the Massey idea is better – gives local operations a frequency and leaves FISCOM clear for necessary and emergency communications. Most of us use local frequencies in flight, and refer to FISCOM as required (either switching or monitoring on a second radio).
CAA’s ‘key issues’ are a bit of a reach:
1. CFZs not established in legislation: So what? and we have them already (see 2 below), establish them OR just use them as suggested as a ‘suggested frequency in this area’. They are non-compulsory anyway and there can always be Nordo traffic about, but providing a designated frequency for an area makes sense.
2. CFZs are NZ-specific: Again, so what? We’ve already got them, so where’s the problem? And there are different procedures between countries. CAA and Airways trot out this ‘it’s not ICAO’ whenever it suits, but happily operate outside ICAO if they want to (eg, Airways won’t accept an ICAO VFR Flight Plan).
3. Available frequencies: Would use more, have more, but can’t use more because we might need them sometime?
4. A large number of frequencies raise HF problems: And the current ‘guess the frequency’ system doesn’t?
5. Chart clutter: Have they seen a chart from the UK?
6. That’s what our fees pay for.
7. That’s what FISCOM is for, plus many of the frequencies already in use fit this category- City/Hauraki Traffic in Auckland, all the training and low flying areas etc that don’t require monitoring of ATC of FISCOM (North Shore – training area above 2500′ below 3500′ is in TMA but is on local traffic).
Strikes me that the CFZ proposal will be both SIMPLER and CHEAPER , and without the “blind spots” problem of any FISCOM (as exists with CHCH coverage).
Both systems have merit; however, the Massey proposal seems to tick all the boxes. I get around the country from top to bottom VFR and note a hell of a lot of radio chatter on 119.1 that you pick up from areas way distant from where you are.
This has, in my opinion, led to many pilots not listening to all radio transmissions due to the irrelevance of many radio calls. I have many instances where the local traffic does not hear your close position report or intentions with the non-listening aircraft manoeuvring into conflict with your flight path even though you have transmitted intentions. Transiting through Taumarunui two weeks ago at 4000 ft and 2 miles east, a light aircraft climbed directly in front of me into my path. He was either on the wrong frequency or didn’t hear me. This happens all the time.
The CFZ or MBZs in and around Palmerston North work well, with designated areas having their own frequency. You know that any radio transmissions are for your area rather than possibly being miles away. With two comms or a monitoring function, it is very easy to monitor your local traffic and any traffic in the next area you’re flying into.
There are local frequencies used down here such as the Mt Cook, Fiordland, Milford, Timaru areas and the system works well. I don’t use FISCOM at all in my flying nationwide. It is far easier to get WX via your phone via Metflight on the web. The FISCOM channel is often crowded and also has a lot of one-ended transmissions to other areas. This has led to GA pilots using 119.1 everywhere. CAA is out of touch with the issues here and needs to start listening to those of us who are actually flying. I don’t think there are many CAA staff who actually get in an aircraft any more!
Breaking NZ into different CFZs would be a big help. You will know that transmissions heard are for your area.
The FISCOM changes are all well and good, but there will still be a lot of transmissions on air that are not relevant to you and thus you have the same problem over time of pilots tuning out due to too much radio chatter.
Whatever changes are made need to be simple. CAA has a habit of over-complicating things and I think would be better to adopt the Massey proposal.
Around the early 2000s, we at Wellington used the FISCOM frequency in effect as a CFZ in the Southern Wairarapa, prefixing South Wairarapa Traffic to calls (a mouthful). It worked quite well, as I recall.
I agree with Massey University that improvement is long overdue to facilitate better communications between aircraft outside of controlled airspace and the need to separate the frequencies to avoid the over-talk that currently goes on from anywhere in the network.
We have a particularly difficult terrain problem in NZ along with the associated adverse weather that frequently prevails to make VFR difficult. Good communications are essential to safe flight.
I am amazed that it has taken this long for this problem to surface and get discussed. I have been microlighting in the lower levels now for five years in airspace that is frequently Class G. I use controlled airspace when I can as it is definitely safer but I am also aware that many are not taught to use it and are fearful of it. It is just as fearful in Class G when the weather is adverse and I have heard many a surprising tale since I have been involved in microlighting.
Overall, I feel we are still back in the 70s with VFR flying and as we observe ADSB coming prominent in overseas areas we definitely need change and education of our VFR fraternity to increase our safety levels. I am impressed with the activity in VFR flying that goes on and the freedom that we all have. I am also impressed with the aircraft building activity that I see in NZ.
I feel the need to comment on the safety levels in the same breath. I fly a bug smasher but observe many who dream to fly something fast and sleek. All very good in CAVOK weather but deadly when coupled with the extremes of NZ conditions. Too fast, no knowledge of controlled airspace and how to use it so subsequently under the base, low flying in bad weather without the knowledge to reduce speed and configure accordingly and often communicating on incorrect frequencies. Recent accidents prove this to be the case.
I have been an early adopter of iPad use (forced upon me, I might add) but have become an evangelist within the flying community to ensure as many people as possible adopt similar technology to increase their situational awareness in flight and overall safety to themselves and others. Look at AIR NAV PRO and see what we get. This is only one avenue; there are many others that are available for aviation use including EFBNZ which is fantastic within the confines of small aircraft cockpits. A free weather service like the boating marine forecast would also help.
I agree with the points you have made, particularly with regard to low level coverage and unnecessary, uncontrolled, traffic that will not only overload the FISCOM operators, but may even interfere with their normal duty. The FISCOM boundaries will have to be more positively delineated, too, at the moment it doesn’t really matter which one we use, I “suck it and see” sometime, to see which has the best reception in my position, but this is no good if all aircraft in a specific area need to hear each other, which is the whole point of the Massey proposal.
The only advantage I can see from the CAA proposal is that all calls are logged – or recorded ? – so that in the event of an aircraft reported missing at least its last reported position will be known, even if not on a filed flight plan and SARWATCH. The Massey CFZ suggestion doesn’t address this issue.
In brief: I support the proposal of the Massey University School of Aviation that a series of Common Frequency Zones should be created nationwide, with clearly defined boundaries, so that all uncontrolled VFR traffic has the potential to be aware of conflicting traffic in their vicinity, and that the use of 119.1 should be restricted to traffic passing near to unattended aerodromes.
In detail: The CAA comment that all traffic using a FISCOM freq. is logged and could be of use if an aircraft is subsequently reported missing, as a reason to support their FISCOM proposal, has some merit but also some disadvantages:
1) The present FISCOM boundaries are not clearly defined. I can only speak definitively with experience of Northland, but flying South from Kerikeri towards Whangarei, equidistant from either coast, one of two FISCOM frequencies could be selected, 118.5 or 124.9 – see GEN 3.4-2 The boundary of the 124.9 segment is very loosely delineated on the present FISCOM advisory chart, and not at all on the present VNC B1- Northland. As a result two VFR, uncontrolled, opposing aircraft could be transmitting on either one of the FISCOM frequencies shown, and whilst both would be heard by the FISCOM operator they would not hear each other, and being uncontrolled the FISCOM operator would have no mandatory responsibility to advise of each others’ presence.
2) The volume of recreational, uncontrolled, and almost ‘conversational’ local reporting on the FISCOM frequencies would be a distraction for the FISCOM operators, and detract from their ability to properly carry out their core business.
3) The CAA GAP booklet Plane Talking pg. 32 advises that – quote: “The VNCs show the FISCOM freqs… based on VHF coverage at 4000 ft.” In my experience, few recreational pilots on short local flights fly above 3000′, so reception difficulties might also be a consideration.
I am pleased that this discussion is finally getting official “air-time” as the problem has been around a long time. Dave Brown, Chief Pilot/CEO of Christian Aviation made a similar proposal many years ago of essentially similar nature, and I agree with Massey and Dave Brown’s proposals.
New Zealand aviation took a large step forward when the CFZs were first introduced, and I commend CAA for introducing them. They have been very beneficial, in my opinion, especially as I was hearing aircraft operating into Kaitaia Aerodrome while operating around the Coromandel Peninsula.
So in this submission, I wish to contribute on the three issues raised.
1. The Massey University School of Aviation nationwide CFZ proposal.
I propose that CAA accept the proposal, and let the industry as a whole grind out the finer details. The details are best decided by airspace user groups who are experienced in their own particular geographical area. What they decide should be accepted.
2. The CAA proposal to reinforce that FISCOM is to be used in uncontrolled airspace, unless within an MBZ, CFZ or the vicinity of an aerodrome.
I propose that Airways provide a better service by giving pilots access to full meteorological data while airborne, such as TAFs and METARs. Following this, I propose that FISCOM be used for air-to-ground communication and that the proposed CFZs be used for air-to-air communication. With regard to emergency transmissions, I believe that an immediate transmission on the frequency in use, and then changing to an appropriate second (or third) frequency will make best use of the available resources. I have personally responded to two Mayday and two Pan-Pan calls which were on unattended frequencies.
3. Amending AIPNZ ENR 1.1 Section 6.2 for the broadcast area to be below 3000 ft AGL to below 2000 ft AGL.
Agreed, and perhaps 10nm is too far if the aircraft is transiting the area and not going within 3-5nm of the aerodrome. For example, measure the boundaries of the Ardmore MBZ and you’ll find it is much smaller than 10nm.
I would advocate for the CFZ-type system, and if CAA or Airways want to monitor those frequencies, at NO COST to the pilots, then that would most likely work fine.
We operate around Nelson, and I cannot imagine “blind” calls being acceptable on the Tower freq, as it is busy enough at times to make it impossible. In Golden Bay, at low level, on Nelson freq, you already can talk over other aircraft who are low in Tasman Bay, because Nelson is the area’s FISCOM.
What I can see happening with the introduction of charges, just to ask for a transit clearance, (which I am sure will happen sometime in the next year or so) is that people will be doing everything they can to avoid talking with ATC unless absolutely necessary. Therefore, if one is required to operate on a freq that is also used by a local ATC, then folks will not talk.
CFZs, clearly marked on all the charts, and yes, with frequencies well separated, is all we need.
Very disappointed to attend an Avkiwi seminar a year or so back, about radio, to find that the basic message was: “Unless you have 100% skills, and know exactly what to say, you should not be there, and need to spend time with an instructor sorting it out”.
The presenter, an RNZAF pilot (nice guy, but I was in the RNZAF, and the environment is utterly different) was giving us all the impression that you are dangerous and not professional unless you have perfect radio skills!
As a civilian trained pilot and instructor, I was appalled to hear what he was putting across.
“Safety” is what we do. The CAA just talks about it.
Afterwards, I caught up with a couple of local recreational PPLs and reassured them that they would be MUCH better off to say something, even if they are not sure if the phraseology is correct.
We had two CAA staff here a year or so back, talking about national frequency issues, and they said that the mess (now the Manawatu CFZ area) was always going to kill people, and that one of them had even said so, prior to the mid air’s. Being lowly staff, they of course were ignored!
I have had a couple of very near misses in areas with multiple frequencies. One was South of Darfield, when I had left just left the Cant CFZ, and along with visually ensuring I was away from the TMA, and looking for glider traffic from Hororata, and wondering if they would be on 119.1 or 133.55, met a Cherokee heading opposite, probably doing the same things.
The other, operating around an unattended strip, just South of Nelson (that is, inside the zone, but uses 119.1 whilst in the cct) and had a helicopter leaving Nelson almost come through the windscreen. I called, but am pretty sure he/she would have been on Nelson.
I don’t have the answers, but there are places in NZ now (and Manawatu is right up there) that if I can avoid going through, I do, unless I can get Controlled VFR. But even that option will be less attractive once we get charged for making contact.