Thanks Jo for the letter template because it will assist some, and it is
interesting.
The current Manual of Standards Part 139 Aerodromes at 9.19 "Other
lights on an Aerodrome" at 9.19.1 "Vehicle Warning Lights" says
"9.19.1.1 Vehicle warning lights, as required by subsection 10.9.2, must
be provided toindicate to pilots and others the presence of vehicles or
mobile plant on themovement area". 10.9.2 is in Chapter 10 which
chapter is entirely directed at "Operating standards for certified
aerodromes". There is nothing in Chapter 12 requiring observance of
9.19 re vehicle warning lights, and this chapter 12 is entirely directed
at "Operating standards for registered aerodromes".
There shouldn't be an issue re section 9.19.1 on a registered aerodrome
unless an over zealous CASA Aerodrome Inspector has insisted on flashing
beacon lights or he/she has convinced the Council owner to apply such,
when the MOS Part 139 Chapter 12 does not specify such for registered
aerodromes.
Certified aerodromes are different as above, and the template letter
provides a work around for gliding. Access to a GA aircraft on a
certified aerodrome would be different, but the letter may be adaptable(?).
The new Part 139 which will be revealed in detail in the Notice of
Proposed Rule Making being released shortly may change some of this. I
believe that in this area it will get simpler not more adverse.
Furthermore the NPRM will be open for public feedback and response for 3
months (4?). This will allow people to provide feedback as individuals,
or through GFA, or through their local aerodrome committee.
Roger Druce
On 12/05/2017 1:57 PM, Jo Pocklington wrote:
Re the issue of mandatory flashing or rotating lights, we have
previously been advised that all a Council has to do is complete a
standard letter to CASA and an exemption will be made automatically.
CASA are aware that these lights can interfere with radio frequencies
and will provide an exemption to yellow flashing lights, with a
request that all vehicles use their hazard lights instead. Here’s the
standard letter, regards Jo
[Date]
Executive Manager
Airspace and Aerodrome Regulation, Civil Aviation Safety Authority
GPO Box 2005, CANBERRA ACT 2601
*By Email: [email protected]*
Dear Sir
**
*MOS 139 AERODROMES - SECTION 9.19: OTHER LIGHTS ON AN AERODROME***
**
The [Aerodrome Operator] has been approached by the local gliding club
to seek an exemption to paragraph 9.19.1 of MOS Part 139 – Aerodromes.
In particular, the gliding club is seeking an alternate method of
compliance with the requirement for gliding related vehicles operating
airside to use roof mounted vehicle warning lights as per MOS Part
139, paragraph 19.1.1 – specifically, subparagraphs:
·/9.19.1.2 A vehicle warning light or lights must be mounted on the
top of the vehicle, so as to provide 360° visibility./
·/9.19.1.3 The lights must be amber/yellow/orange, and be flashing or
rotating of a standard type commercially available as an automobile
accessory./
The [Aerodrome Operator] understands that vehicle control at
aerodromes in accordance with the regulations is necessary and
uncontrolled vehicle access could potentially cause safety concerns
when operated on the manoeuvring and/or movement areas. However, we
question the requirement that mandates roof mounted vehicle warning
lights when alternative methods of compliance are available.
Vehicles towing gliders on manoeuvring/movement areas of aerodromes
are treated as a taxing aircraft, with the driver of the car carrying
a radio, monitoring and making the required radio transmissions on the
CTAF or other appropriate radio frequencies.
The vehicle/glider combination is very easy for a pilot of another
aircraft to see with the risk of collision considered to be no higher
than that of a taxiing aircraft. Large wingspan sailplanes painted
white are highly conspicuous on the ground. The gliding operation is
very risk aware and attuned to avoiding conflicts with fixed and
moving obstacles.
Gliding operations are not conducted at night, only in day VMC, so
there is no requirement for consideration of night operations.
The [Aerodrome Operator] notes that standard road vehicles have hazard
flashing lights that meet a standard, i.e. Vehicle Standard 2005
(/Australian Design Rule 13/00 – Installation of Lighting and Light
Signalling Devices on other than L-Group Vehicles). /Vehicle hazard
flashing lights are highly visible and provide 360^o visibility. This
contrasts with flashing lights available as an “/automobile
accessory/” that do not meet a standard and have proven to have poor
visibility during daylight hours.
The risk of conflict with aircraft landing, taxiing or taking off is
also mitigated by use of radio on the CTAF as an aid to alerted see
and avoid. Radio is used to make taxiing calls as is normal for
powered aircraft, as per CAR 166E. The gliding club has advised that
many ‘automobile accessory” flashing lights generate considerable RF
interference, reducing the effectiveness of radio to reduce the risk
of conflicts.
We contend that vehicle movements off movement and manoeuvring areas
present minimal risk of conflict. Normal practice is for vehicles not
towing gliders to move to safe parking areas, or exit via defined
tracks or shortest routes to those tracks.
Accordingly, [Aerodrome Operator] would appreciate CASA providing an
exemption to MOS Part 139, subparagraphs 9.19.1.2 and 9.19.1.3 insofar
as vehicle hazard lights are an acceptable method of compliance for
vehicles on manoeuvring/movement areas involved in gliding operations
(whether or not the vehicle is towing a glider).
We await your further advices.
Yours faithfully
*From:*Aus-soaring [mailto:[email protected]]
*On Behalf Of *pam
*Sent:* Friday, 12 May 2017 1:35 PM
*To:* 'Discussion of issues relating to Soaring in Australia.'
*Subject:* Re: [Aus-soaring] rotating beacon non-magnetic
It would be a good move to be able to just use car hazard lights on
airfields where gliders operate.
We are stuck with it until that happens, and I prefer to do what the
glider operators ask – one less whinge to have with their councils.
However, Toowoomba City AD is an RPT Certified AD (even though the
passenger traffic has all moved to Wellcamp) and that’s where we keep
the Diamond Star.
I have had some good suggestions about suction mounts and lightweight
beacons – thanks everyone.
Pam
*From:*Aus-soaring [mailto:[email protected]]
*On Behalf Of *Roger.D
*Sent:* Friday, 12 May 2017 10:38 AM
*To:* [email protected]
<mailto:[email protected]>
*Subject:* Re: [Aus-soaring] rotating beacon non-magnetic
Dear Pam
I would not fuss too much at this point. The matter of yellow/orange
rotating beacon being required on CASA registered aerodromes by some
of CASA's Aerodrome Inspectors, and poorly informed Council's
insisting on such, is likely to go away. CASA are about (at long
last - issue in June?) to release the Notice of Proposed Rule Making
for the new updated Part 139 Aerodromes. It is expected that the NPRM
(which is being issued for public comment for a period of 3 or 4
months) will have the precise details on this matter. It is expected
that use of a motor vehicles ordinary hazard flashers will be the go
as all vehicles these days have such as standard fitment.. However
the situation with capital city airports unde rthe airport act is
controlled by the act. The in between situation of serious scale CASA
certified aerodromes I can't speak to, but these are airports one is
not likely to want to launch off anyway.
Regards
Roger Druce
On 12/05/2017 9:30 AM, pam wrote:
Our new car isn’t steel and we can’t stick a rotating beacon on it.
Does anyone know of a supplier of beacons with a suction cup –
preferably a smaller size beacon?
This is a trend for newer cars, so others may have encountered the
problem already…
Pam
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