CFZs and a new KISSASS concept: Keep It Safe, Simple And Sensible, Sir

01 May 2013 / by Brian Mackie / Consultation, Costs, Governance, Safety

In the continuing and lively debate about Common Frequency Zones, comparisons with other countries are – as the saying goes – odious. The CAA would have us believe that when it comes to aviation regulations, New Zealand must strive for international consistency and that no CFZs exist anywhere else.

Both statements are incorrect. International aviation is rich in inconsistency, and ground-based bureaucrats constantly interpret, make and bend the rules to suit their local conditions and whims.

The New Zealand Civil Aviation Authority is no exception. Its Mandatory Broadcasting Zone is unknown elsewhere, apart from Australia.

Canada has introduced what we would call CFZs, but they call them CFAs and they have done this purely based on increased traffic and safety considerations, around Toronto’s Golden Horseshoe.

In Australia, there is a national common frequency that looks a lot like our informal and NZ CAA-disapproved 119.1. It works in Australia because the concentrations of lower-level air activity are well separated in a vast territory, so there are few complaints about radio clutter. It could not work in our much smaller and completely different country. This is another reason why those in our CAA who claim to seek international consistency sometimes apparently ignore what is evident, all around them.

It has been pointed out by one commentator on the GAA website that he flew for four hours in the UK without talking much on the radio, and was almost always in sight of another aircraft. He is hoist with his own petard. UK airspace is busy-busy-busy, and lookout is more highly developed than in lonely, low-level New Zealand. There is also a far greater amount of controlled airspace in the United Kingdom – and a more sophisticated use of the radio by pilots operating in a country where the highest point is Ben Nevis, at 1344 metres.

In the apparently wide open skies of New Zealand – a long, thin country dissected by a great deal of uncompromising rock (the highest piece of which reaches 3754 metres) and subject to dramatic weather variations – there are uncontrolled airspaces where aircraft flying low tend to create corridors where they congregate, and sometimes conflict. This is why it makes no sense to blindly adopt international conventions that might work well in flat France, where it is possible to fly from the English Channel to the Mediterranean with nary a word to anyone. (Not that French FIS personnel are inclined to answer anyone speaking English, as the writer can testify…)

The air is almost the same everywhere on Earth, but the topography and climates are not.

The National CFZ Network argument is not about becoming a world leader – or, as the CAA would have you believe, instead going along with what is allegedly done elsewhere, lest we “confuse visiting pilots”.

The CAA’s FISCOM proposal does not meet international practice, because such practice does not exist. It cannot, because even the NZ CAA cannot explain what it proposes. Those who seek a sensible solution to a local issue do not seek to be global ground-breakers, in any sense of the term, especially when their own guardian authority admits that it cannot specify, cost or indicate the outcomes of its counter-proposal.

The argument is simply about recognising the true nature of how we fly and where we operate – a place that is unique – and further protecting those who fly in Class G airspace.

We can neither afford nor justify an Airways-monitored GA aircraft-to-aircraft service for the small volume of traffic operating low-level in an incomparable geographic and climatic environment. What is required here is simply a set of discrete frequencies in clearly defined areas where pilots flying in naturally confined airspace can contact one another on a local level. In our environment, aircraft-to-aircraft position reporting is valuable. This is particularly relevant in current hotspots. These are well known areas, and it is worrying that the CAA prefers to suggest an untested, unquantified, uncosted and far more complicated alternative, rather than explore a pragmatic, real-world solution to a genuine and present hazard.

The National CFZ proposal is merely an extension of what the CAA has already accepted and implemented for reasons of safety, which makes its counter-proposal even more baffling. A gradual extension of CFZs would spread the cost, deal with the most immediate issues, and would almost certainly be less expensive than the FISCOM Mystery Project.

Outright rejection of Massey’s plan – which according to the Massey timeline has widespread support among aviation organisations, Airways, the military and civilian users – is inexplicable (unless some individuals within the organisation fear that acceptance might indicate the CAA had somehow “lost the initiative” and thereby lost face by accepting an idea Not Made in Asteron).

The further development of CFZs, even if not on a national level, cannot be precluded simply because, as the CAA argues (in opposing the Massey idea), “there is no rule”. This just admits of a need to create a rule for the existing zones and any new ones. Otherwise, logic dictates that the CAA would have to abolish all CFZs.

In the absence of detailed information about its FISCOM proposal, a CAA rejection of the Massey idea would be unwise and premature. To say no now would be irresponsible, and merely perpetuate what everyone recognises as the irritating – if not downright dangerous – unofficial adoption of 119.1 as the common frequency outside controlled airspace.

The CAA has been recruiting for a top Policy Adviser. Among the candidates’ required talents, described in a somewhat dizzy advert, we quote:

♦ “not fearful of acting with a minimum of planning”

♦ “isn’t upset when things are up in the air”

♦ “relates well to all kinds of people – up, down, and sideways”

Let’s hope that the successful applicant introduces an element of lateral thinking.

Compromise might be the key to resolving this issue. If the CAA could engage in further dialogue with its clientele about CFZs, who knows? It might turn out to be a global ground-breaker.