The New Zealand Air Line Pilots’ Association (NZALPA) today released details of its serious safety concerns with the proposal by the State Owned Enterprise Airways to remove air traffic services from seven regions,* and the decision NZALPA believes Airways has made to put costs savings ahead of the safety of the travelling public and its own members.

NZALPA President Captain Andrew Ridling, speaking on behalf of the membership of most of New Zealand’s pilots and every Air Traffic Controller in the country, said the organisation strongly opposed Airways’ CEO Graeme Sumner’s assertion that those airports could operate at a similar level of safety following the removal of Air Traffic Services, including Air Traffic Control and Flight Service professionals.

“There are a worrying number of safety concerns which must be answered by Airways prior to considering the removal of Air Traffic Services from a regional airport, particularly those serviced by large passenger aircraft.

“In the absence of such discussion the proposal by Airways NZ to remove Air Traffic Services from regional airports cannot be considered anything other than unsafe and brings into question the motives of the Executive Leadership.

“NZALPA has conducted a thorough examination of the technical and safety issues that may result from the removal of Air Traffic Services from a regional airport; both in a general sense, and issues specific to each of the seven airports currently under review.

“NZALPA also considered the opinions of industry subject matter experts as well as data, legislation, and position statements made available by aviation industry regulators such as the International Civil Aviation Organisation (ICAO), the International Air Transport Association (IATA), the International Federation of Air Traffic Controllers' Association (IFATCA), the International Federation of Air Line Pilots’ Association (IFALPA) and New Zealand’s own Civil Aviation Authority (CAA).

“It is unfathomable to NZALPA why CEO Sumner would dismiss the safety concerns raised by subject matter experts without providing supporting evidence to validate his assertions,” Captain Ridling said.

Significant safety concerns in the report are summarised below:

1. Air Traffic Services personnel provide the only accurate reports on the weather conditions at an airport. Without this information there is more risk to aircraft and passengers from poor weather and landing conditions, an increased likelihood of a flight being delayed or cancelled, or of an aircraft diverting to another airport due bad weather, and subsequently running low on fuel.

2. At uncontrolled aerodromes the limiting weather conditions aircraft can operate in are much lower. Without Air Traffic Services to provide separation and information pilots are required to visually sight each other in order to avoid collisions, but this will become extremely difficult in poor weather creating an increased risk of collision.

3. In uncontrolled airspace it is possible for a large passenger aircraft to be operating in cloud while another aircraft is operating up to the edge of the cloud without either being aware of the other. Neither aircraft would be able to sight or avoid the other in sufficient time to prevent a collision.

4. The majority of the aerodromes at which Airways is proposing to remove Air Traffic Services have no RADAR coverage. The controllers at these locations are specially trained to provide separations for aircraft arriving and departing the airport without the need for RADAR to verify the position of aircraft (Procedural Approach Control). Without Air Traffic Services at these airports, aircraft will not be able to be monitored to ensure safe separations are present and will be responsible for ensuring their own safety even when they have no visibility of each other. Passenger aircraft need to fly through cloud in order to operate effectively; they will not always be able to use visual ‘see and avoid’ procedures, nor are they required to by the rules under which they operate.

5. Pilots are not specifically trained to provide separation from one another when they have no visual reference. Without Procedural Approach Control (or Radar Control) there will be higher risk of a loss of safe separation, or a need to reduce airline schedules to the point where only one aircraft is operating at a time.

6. The collision avoidance systems carried by modern aircraft (ACAS/TCAS) are useless in uncontrolled airspace. In uncontrolled airspace other aircraft are not required to carry the equipment that these systems rely on like they are in controlled airspace.

7. There will be an increased risk of accidents caused by the considerable areas of dangerous and unstable air produced behind large aircraft (wake turbulence). As this is normally the responsibility of Air Traffic Services to manage, light aircraft pilots may not be familiar with the danger or the responsibility now placed on them to remain clear of the larger aircraft.

8. The removal of ATS removes the ability to monitor the correct use of VHF radio equipment essential for pilots to communicate with one another. Any radio mistakes or failures will go uncorrected, causing misunderstandings and a higher risk of accidents.

9. Air Traffic Services play a role in training and assisting inexperienced pilots to help develop better understanding and safer practices. This function will be lost from those airports.

10. One of the primary functions of Air Traffic Services is to provide information and assistance to aircraft that are in a state of distress or emergency. This function will be lost, extending the response times of emergency and search and rescue agencies and increasing the likelihood of a fatal outcome.

11. The complexity of an airport’s layout and operations has a more significant impact on the collision risk than how busy or not it may be. The need to manage complex airport layouts and integrate complex operations should be the primary determining factor when considering the need for Air Traffic Services, not the number of aircraft movements.

12. Runway incursions by vehicles, people, and wildlife (something or someone being present on a runway without advising other airport or airspace users), were identified by the Civil Aviation Authority to be one of the highest accident risks to large passenger aircraft. The likelihood of these accidents occurring will increase without Air Traffic Services to monitor and manage the runway and ensure it is clear and safe.

13. There are currently no digital or remote digital tower technologies that are capable of matching the safety and performance of a ‘conventional’ tower. The costs involved in research and design, infrastructure development, and exhaustive safety testing to implement these technologies will be significant, yet there are no obvious operating cost reductions that can be realised.

NOTE: the full report “REMOVAL OF AIR TRAFFIC SERVICES - Report on Associated Technical and Safety Issues“ is available on the NZALPA website at https://www.nzalpa.org.nz/Media-Centre/Removal-of-Air-Traffic-Services-NZALPA-Response-to-Airways-proposal

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