The Broderick letter
It appears that CASA wrote to Tony Broderick, the previous Associate Administrator for Regulation and Certification at the FAA, in relation to the Airservices decision to introduce Class C without radar.
Following is a copy of the letter written by Broderick on 21 October 2004 in reply. CASA decided to take no notice of Broderick and immediately sided with Airservices that Class C airspace without radar is safe (see CASA letter to Minister) because - wait for it - we have operated Class C airspace without radar in the past and we haven't yet had a collision. Readers will no doubt realise that virtually every major airline accident in history took place because the management and pilots of the organisation believed that as the previous procedures had not caused and accident, there wouldn't be one in the future.
Dear Mr. Gemmell
Thank you for your letter of 21 October in regard to the airspace changes proposed to be introduced in Australia on 25 November 2004.
I have, as you recognized, spent considerable time studying the Airservices Australia safety case produced to support these changes. I have also spent considerable time reviewing the excellent report on this matter produced for you by Professor Terry O'Neill.
I can confirm for you my concern that there are fundamental flaws in the safety case provided by Airservices Australia to support the airspace changes. These flaws are very articulately spelled out in Professor O'Neill's report. Based on my review, it is my opinion that it is possible that the changes planned for 25 November could actually have an effect opposite to that intended, and reduce safety instead of improving it. I would hope that these flaws can be corrected before any final decision is made to implement the airspace changes.
With regard to the question asked by the Minister, I am a bit at a loss. It seems to me almost oxymoronic to speak of Class C airspace without radar being used.
The whole idea of Class C airspace is to provide positive separation of aircraft -- IFR from IFR and IFR from VFR. The controllers are able to do this because the radar provides them with specific position information in real time on all aircraft.
I cannot understand how Class C airspace without radar can work safely. How would the controller have an accurate idea of the position of the VFR aircraft? IFR aircraft have the ability to locate themselves and be located on IFR routes, or radials, etc. But that is not the case with VFR traffic, and there is clear communications confusion that arises when trying to explain, as a VFR aircraft, one's location.
I cannot see how Class C airspace can be effective, or safe, if it is structured without radar. So, my answer to the question the Minister asked of you is yes, there is a significant safety differential between Class C airspace with radar and Class C airspace without radar.
I hope this is useful input to your review.
Sincerely
Anthony J. Broderick
