The Civil Aviation Authority has issued a virtual thumbs-down to Massey University School of Aviation’s proposal for a national Common Frequency Zone network.
On April 12, the CAA published its consultation document on Radio frequency use in uncontrolled airspace.
The deadline for submissions (before the CAA makes its “final decision”) expires on May 24.
The CAA sticks to its original objections to Massey’s proposal, as revealed earlier on this website. Then it proposes a development of the current FISCOM including uncosted hardware improvements to expand coverage, a probable (also uncosted) increase in Airways staffing to handle the system and a possible but undefined change in operations to permit aircraft-to-aircraft messaging over the FISCOM frequencies.
No costs or timeframes have been provided for the FISCOM development. On April 14, GAA asked Mike Haines, CAA Manager, Aeronautical Services, the following questions:
1. Is it possible, using the existing FISCOM network, to carry out a trial of “blind position reporting” transmissions without them being directed through a FISCOM operator?
2. In the case of the FISCOM service being handled by existing Tower staff such as Dunedin, Nelson, Napier, Gisborne etc, will they be able to cope with monitoring specific calls to them as well as ignoring those “blind transmission” calls between other aircraft in the area without it impacting on their other duties?
3. What is the timeframe for Airways to upgrade aerials, frequency coverage and staff numbers?
4. Within the inevitable blind spots of low-level FISCOM frequency coverage in the mountainous areas (around 500′ to 1000′ AGL), what frequency will you be advocating that pilots use? This is an important safety issue where pilots are transitting through valley systems and mountain passes low level, in bad weather.
“These are relevant questions, however most cannot be answered until we have the information from industry to see what requirements would be needed to amend the current FISCOM.
“Airways have begun upgrading of the FISCOM aerials and when this is complete (expected mid-year) they will be reviewing coverage and any staffing changes. CAA would look at asking them to undertake a trial on coverage areas with the increased coverage anyway as they are required to provide an flight information service
“If the FISCOM proposals proceed it may be that some Tower FISCOM monitoring may be undertaken by the Flight Service from Christchurch. Until we have feedback from industry on both proposals and issues to be addressed it is premature to sort out some of the more detailed issues.
“The FISCOM coverage is going to be improved – if there are low-level areas where an MBZ or CFZ is needed this will be looked at on a case by case basis.”
This puts opponents in an impossible position. They have less than six weeks to argue against a proposal from CAA that the authority admits it cannot explain in detail until long after the deadline for submissions expires and a “final decision” is made.
Unless CAA is able to provide detailed costings, timeframes and outcomes for its alternative proposal, a rejection of Massey’s proposal could amount to an abuse of process and be open to legal challenge. Curiously, one of CAA’s objections to a national CFZ network is the time it could take to implement.
The CAA says: “CFZs were introduced into New Zealand to assist by providing a common radio frequency at locations where several frequency areas overlap. CFZ are not mandatory and are advisory in nature. These areas are not designated airspace under Civil Aviation Rules Part 71; they are common frequencies that have been allocated in order to enhance safety. CFZs signify areas of concentrated aviation activity, generally recreational aviation. [Our emphasis]
“It is not mandatory to use a radio on the specified frequency within a CFZ, but it would be very poor airmanship not to use the advised frequency and to not comply with expected local radio procedures when radio equipped to do so. As a minimum, pilots should broadcast their position and intentions on entry and exit from a CFZ.”
The consultation document then goes on to demolish its own comments supporting existing CFZs that the authority established, and instead suggests further investment in FISCOM for the benefit of General Aviation – which, under the current User-pays philosophy also leaves the door open to eventual charges on the sector for the service.
GAA understands that Massey is discussing how to respond, and we hope to carry their reaction on this website.
In the meantime, please read the consultation document and remember the deadline. We’d also appreciate your feedback, as GAA supporters plan to file a group submission.
We’d make a further prediction: If CAA rejects the CFZ proposal and presses on regardless with FISCOM, it will still be ignored by many pilots who – purely for reasons of personal safety and lacking something more sensible – will defy CAA advice and keep talking to each other on 119.1.