bookworm wrote:
The interpretation that an air traffic control service may only be provided within controlled airspace is not pedantry. It is the stated position of the European Commission.
…. and the converse, outside of CAS you can only provide, in the broadest sense, a FIS. I see nothing which says you must have an air traffic control service (ergo CAS) for an IAP. Indeed, Part ATS seems to maintain the status quo: inside CAS, do what you are told; outside CAS, air traffic instructions are advisory.
EASA appear to have adopted almost ALL ICAO definitions in Part ATS. From Annex 11
James_Chan wrote:
I think it’s the harmonisation of ATS procedures in EASA states.
yeeeees. how many people were injured in the past ten years because of, say, lack of harmonisation of airspace classes on approach procedures?
It looks like regulators, governments and parliaments have a constant RPPY (regulation pages per year), and will just continue to produce new regs forever. At the current rate, they will harmonise the thread thickness and colour of the gold in epaulettes in 2022, swiftly moving on to fire standards for shoes permissible in cockpits.
I would argue that SERA already was a bridge to far. For licencing and maintenance, the ability to have paper valid in the entire EASA area was of benefit, although at a a heavy price for private aviation. SERA made international VFR flights marginally easier.
I would advocate a “one in, one out” rule for the regulators, otherwise the total weight of paper will achieve critical mass and collapse into a black hole, ending life on earth.
There’s also this snippet form Opinion 03/2018
Dave_Phillips wrote:
I see nothing which says you must have an air traffic control service (ergo CAS) for an IAP.
ANO 183. In the case of an aerodrome (other than a Government aerodrome) for which there is equipment for providing aid for holding, aid for let-down or aid for an approach to landing by radio or radar, the person in charge of the aerodrome must—
…
(b) during any period and at such times as are notified, cause an approach control service to be provided.
We seem to be going round in circles.
There’s a difference between an approach control service and an air traffic control service. Start at Annex 11.
Dave_Phillips wrote:
There’s a difference between an approach control service and an air traffic control service. Start at Annex 11.
So, what do you envisage working in the light of the new Part ATS rules and the existing Rule 183? (Not to mention the conservatism of the CAA and the likely reaction of the union.)
How many people were injured in the past ten years because of, say, lack of harmonisation of airspace classes on approach procedures?
I’m not sure, but mid-air collisions is one of these things that don’t happen frequently, but when they do make very big news.
Maybe more worthy of note is:
I think the idea is that one controller licensed and experienced in one EASA-state can eventually do their duties at another EASA-state after being approved (validated?) to work at their new sector or unit.
It would probably cost more money and time to teach everyone hired from abroad when there are more state specific rules – such as 4-part ATSOCAS and how to “control” air traffic in uncontrolled airspace.
I very much like the idea of harmonisation personally. But this whole discussion could become moot as the UK leaves the EU.
Dave_Phillips wrote:
…. and the converse, outside of CAS you can only provide, in the broadest sense, a FIS. I see nothing which says you must have an air traffic control service (ergo CAS) for an IAP.
Correct, there is nothing in Part-ATS that requires ATC and/or CAS for an IAP. But there is in the UK ANO.
183. In the case of an aerodrome (other than a Government aerodrome) for which there is equipment for providing aid for holding, aid for let-down or aid for an approach to landing by radio or radar, the person in charge of the aerodrome must—
…
during any period and at such times as are notified, cause an approach control service to be provided.
There’s a difference between an approach control service and an air traffic control service.
I thought that was dealt with in post 40.
Schedule 1 in the ANO says:
“Approach control service” means an air traffic control service for any aircraft which is not receiving an aerodrome control service, which is flying in, or in the vicinity of the aerodrome traffic zone of the aerodrome for which the service is being provided, whether or not the aircraft is flying by visual reference to the surface;
i.e. the approach control service required by Art 183 is an air traffic control service.
Something has to give. It should be Art 183.
But, if Article 183 is sacrificed, presumably that means that the air-traffic service providers at the 30 airfields I nominated become FISOs?
Do we not think that that would cause issues with the unions and with some commercial operators?
But, if Article 183 is sacrificed, presumably that means that the air-traffic service providers at the 30 airfields I nominated become FISOs? Do we not think that that would cause issues with the unions and with some commercial operators?
I suppose there would be both a regulatory and a cost-benefit analysis and decision for each aerodrome concerned:
Full-time ATC
Part-time ATC with part-time AFIS
Full-time AFIS
Part-time AFIS with part-time A/G
etc. etc.
I’d imagine someone’s work morale would already be extremely low if they were told today or several years ago, something along the lines of:
“We don’t really want you here as we’re not making what our shareholders want us to make. But the ANO requires ATC, and that’s the only reason why you’re employed here”.
Because of that, I don’t think it’ll cause any new issues with unions if Article 183 is sacrificed.
