Submissions & Publications
The Australian and International Pilots Association (AIPA), through its Safety and Technical Committee, is committed to protecting and advancing aviation standards and operations. The committee works to position AIPA as a key component of the aviation quality control process: through the development of relationships with Government, regulatory bodies and industry to ensure the views of Australia's professional airline pilots are considered in important safety and technical matters.
AIPA is also a co-founding member of the Australian Airline Pilots’ Association (AusALPA) which represents more than 5,000 professional pilots within Australia on safety and technical matters.
Please click on the links below to view recent submissions and publications from AIPA and AusALPA.
AusALPA Submission to CASA Consultation on GRF
AusALPA has made a submission on the Proposed Policy for the implementation of Global Reporting Format (GRF). The Association has been a advocating for the implementation of GRF, since 2018, as it is an agreed international standard and has been...
Comments on the Class 5 Medical Self-Declaration..
In response to the Discussion Paper (DP) on access to Class C and D controlled airspace for sport and recreation aircraft, AusALPA expresses overall support while emphasising the importance of integrating this topic into the broader Australian...
Comments on the Paper for Access to Class C & D
In response to the Discussion Paper (DP) on access to Class C and D controlled airspace for sport and recreation aircraft, AusALPA expresses overall support while emphasising the importance of integrating this topic into the broader Australian...
AusALPA Submission ASIC Single IB Reform
AusALPA fully supports strengthening the integrity of ASICs/MSICs. Access to security-controlled areas should only be permitted by using a suitably encoded ASIC/MSIC. The card ideally should incorporate biometric data. AusALPA should be included...
Position Paper - Remote Towers *NEW* November 2022
AusALPA cannot support the full implementation of RTS until a safety standard equivalent to or greater than the current standard can be proven, and procedures and implementation agreed to by all stakeholders.
Proposed Lowering of Class E to 6500'
August 2022 AusALPA has been actively involved in stakeholder engagement with Airservices’ airspace proposals, particularly those related to the “J-curve”, for some time. We have been stridently critical of the way in which Airservices (AsA) has...
AusALPA Comments on the Airspace Review of Ballina
AusALPA strongly support the end-state proposal of a combined control zone and approach service for the Ballina airspace. AusALPA is concerned that the proposed piecemeal and stepped-solution timeline for the implementation of the draft...
AusALPA letter to CEO CASA YBBN 7kt Tailwind Case
AusALPA is very concerned with the political processes being undertaken by Airservices (AsA) and Brisbane Airport Corporation (BAC) to appease a small but vocal segment of the local community who, after being lulled into a false environmental...
AusALPA Submission Planning re Golden Plains Wind
Safeguarding Australia’s aviation infrastructure - although it is hard to ignore the parallels with the iconic Australian movie The Castle, our primary concern in relation to the Craigwood aeroplane landing area (ALA) and the Golden Plains Wind Farm...
AusALPA Comments on Draft 2021 SSP and NASP
AusALPA embraces the Australian Government’s State Safety Policy Statement. We also welcome the prospect that our Government agencies will act to a far greater extent in meeting those aspirational goals.
AusALPA Submission Lowering Class E on East Coast
AusALPA welcomes the opportunity to contribute feedback on the proposal to lower the base of Class E airspace to 1,500ft AGL in medium and high density enroute airspace between Cairns and Melbourne in December 2021. In view of the significant...
AusALPA Submission on 2020 TAF Review
AusALPA welcomes the opportunity to comment on the latest TAF Review.
AUSALPA SUBMISSION TO SDLC RE EXEMPTIONS
June 2020 Attached is a submission from the Australian Airline Pilots Association (AusALPA) to the Senate Standing Committee for the Scrutiny of Delegated Legislation Inquiry into the Exemption of Delegated Legislation from Parliamentary...
AusALPA Management of Critical Safety Information
The current NOTAM system poses safety risks by failing to provide effective safety critical information to pilots.
Sub to Senate Comm TSA (Serious Crime Bill) 2019
AusALPA is committed to protecting and advancing Australia’s aviation safety standards and operational security. We are grateful for the opportunity to contribute to the essential work done by the Legal and Constitutional Affairs Legislation...
2019 NASF Implementation Review
AusALPA recognises that the economic decisions surrounding airports, i.e. determining the balance between the economic benefits of developments and the detriments to the accessibility, efficiency and capacity of an airport, rest entirely with the...
AusALPA Submission to Gladstone Airport
AusALPA prefers ILS Instrument Flight Procedures (IFP) and 3D approaches over non-precision approaches and we advocate that they should be provided wherever they can be installed and retained if pre-existing. Our members find that ILS IFPs are an...
Essendon Fields Airport Prelim Draft Master Plan
AusALPA believes the Preliminary Draft Master Plan 2019 is primarily a commercial development plan that sacrifices less-economic aviation activities for buildings and non-aviation use. It does not promote, protect or encourage aviation...
Airspace Modernisation Project Tranche 2 Proposals
AusALPA supports the Tranche Two proposal to lower continental Class E airspace to FL125 if the supporting communications and surveillance services are available in this airspace.
Airspace Modernisation Project Tranche 3 Proposals
AusALPA does not support the Tranche Three proposals of the Airspace Modernisation Project and believes that a significant rethink is required. Class E is an inherently less safe model of airspace classification to that of Class C. Any suggestion...
AusALPA Wake Turbulence at Sydney Airport
The ATSB has released the results of its analysis into wake turbulence events at Sydney Airport between 2012-2016.
Senate Inquiry into Rescue, Firefighting Emergency
AusALPA supports the vital work that is being performed daily by highly trained professionals providing aviation rescue and firefighting services (ARFFS) to ensure the safety of the flying public and the crews, of which many are our members.
AusALPA Submission Airservices Proposal Airspace
AusALPA supports this change to the service provision responsibilities of regional Class D aerodrome airspace management and recognises that standardisation and consistency across the country can assist in efficiency of operations for both pilots...
AusALPA Submission on CASA Parts 121-119
It appears that CASA intends to subvert a multi-partisan safety-related process in order to create a workplace surveillance scheme which will be totally rejected by the pilot community.
AusALPA Submission on CASA Parts 135-119
AusALPA recognises that considerable progress has been made toward finalising Part 135. However, there remain some contentious issues and we are cautious about how much traction the TWG feedback has gained in refining these operational parts.
AusALPA Submission on Space Activity Bill
AusALPA believes that both the current and future space activities framework fall well short of our expectations to “integrate and enhance our existing aviation safety regime”.
AusALPA Submission on Aust Airspace Policy 2018
There is a need to advance plans for future demands and uses of airspace in the civil sector which is presently not addressed.
AusALPA Position Paper - OLS Penetrations
Currently, AusALPA is far from convinced that the approval processes correctly identify the impacts on safety, accessibility, efficiency and capacity attributable to the OLS penetration.
AusALPA Letter to CAPL re CBR A/P Catalina Drive
While we recognise that CAPL has gone beyond the minimum Guideline ‘B’ requirements for the Runway 17 (RW17) analysis and that the geography of 25 Catalina Drive in relation to RW 12 provides a practical limit to the assessment area, we believe more...
AusALPA Comments on Windtech Assessment
AusALPA was certainly gratified to see that a number of our previous concerns have been addressed. We recognise the significant increase in data points examined and applaud the transparency that they bring to both the experimental technique and the...
AusALPA Position Paper Stop Bars Position
AusALPA supports the installation and operational use of stop bars at Australian airports. The runway, at all entry or exit points, should be protected by an associated stop bar to mitigate the risk of a runway incursion. There is an overriding...
AusALPA Submission on Part 91 NPRM CD 1511OS-2
AusALPA member association representatives participated in the Part 91 Technical Working Group (TWG) and have noted positively that many of the items identified for further work have indeed been addressed by CASA.
AusALPA Response to AsA TAS Airspace Proposal
AusALPA recently learnt of the proposal by Airservices Australia (AsA) to trial Class E airspace in Tasmania through our participation at an AsA chaired meeting held after the TAS RAPAC meeting (April 11th). We were previously unaware of any...
AusALPA Position Paper - SBAS
Australia does not have an SBAS service. In the absence of an SBAS service, SBAS based LPV operations cannot be undertaken SBAS would provide a safer and more operational efficiency for a considerable number of aircraft, including smaller RPT and...
AusALPA Submission on CASA Part 139 NPRM 1426AS
AusALPA supports the need to amend the Part 139 and its associated Manual of Standards specifically to align with ICAO Annex 14, except where there is a valid reason (e.g. terrain constraints) not to do so. The submission includes areas in which...
AusALPA Letter to DIRD on NASF Guideline B
As the only stakeholders constantly exposed to these specific environmental risks, AusALPA’s greatest disappointment in the evolution of Guideline B is the apparent inability of the safety message to be heard over the economic development noise...
AusALPA Letter to DIRD on Public Safety Zones
More than any other stakeholders, our members sample the positives and negatives of our approach to airport safeguarding every day. Consequently, AusALPA is committed to the NASF and the Guidelines as well as the long-term strategy of a single...
AusALPA Submission to Discussion Paper 1708OS-3
AusALPA has responded to CASA’s discussion paper which forms one part of the review of aviation safety regulation for remotely piloted Aircraft (RPA). It is expected that the outcomes of this review will serve to inform the RRAT Inquiry process.
AusALPA letter to CAPL on CBR Safety Case
Our involvement in the development process for 9 Molonglo Drive has identified a number of concerns for us about the effectiveness of the current arrangements for consultation with relevant stakeholders.
AusALPA Letter to BOM re TTF Review
AusALPA supports the proposed change to replace the Trend Forecast (TTF) with a 3-hour dynamic Terminal Area Forecast (TAF).
AusALPA Letter to ARPANSA Re Guide for Radiation
AusALPA is particularly disappointed that ARPANSA chose not to engage with any pilot representative bodies in developing the Draft Guide for Radiation Protection in Existing Exposure Situations (RPS G-2), especially given that many people within...
AusALPA Comments on the draft guide for Radiation Protection in Existing Exposure Situations
AusALPA strongly believes that a uniform regulatory imposition is required to achieve a single consistent cosmic radiation protection scheme for Australian aircrew and encouraged ARPANSA, as the lead agency, to influence the State radiation...
AusALPA Letter to CSA re VASG
It is AusALPA’s view that any requirement for a VASG should be separate from the type of propulsion system the operating aircraft uses.
AusALPA Media Release on CAO 48.1
AusALPA has expressed deep concern over CASA's announcement that it will delay the introduction of CAO 48.1 for another 12 months and its intent to conduct an 'independent' review of the CAO 48.1 proposal. The implementation date was delayed by 12...
Post Implementation Review of “Two in the Cockpit”
AusALPA recognises that the swift political action of the Minister to invoke the “cooperative” introduction of the “Two in the Cockpit (2ITC)” rule undoubtedly achieved its intended purpose – restoring public faith in air transport in Australia.
AusALPA Letter to CASA on SCC Paper
Given the wider publication of the Working Group advice, AusALPA believes that it is important to correct some key factual errors and selective research, as well as to note the unjustified but apparently philosophical bias against workforce...
Runway 16L High Intensity Approach Lighting System
It is our recommendation and preference that the planned maintenance of the HIALS be undertaken in incremental steps during curfew hours in order to sustain operation of the HIAL system during normal operational periods.
AusALPA Letter to CASA on 9 Molonglo Drive CBR
AusALPA is concerned that the current standard that underpins the assessment of airport developments for building-induced turbulence is inadequate.
AusALPA Submission to DOIRD re Baronav Policy
The Association agrees strongly with the need to meet the International Civil Aviation Organisation (ICAO) Resolution A36-23 (as superseded by A37-11) in order to reduce the risk of Controlled Flight into Terrain (CFIT) accidents.
AusALPA Ltr to CASA re WestConnex Plume Project
Further to the meeting chaired by the Department on effects of the plumes efflux from the ventilation stacks (in the vicinity of Sydney Airport) resulting from the proposed WestConnex road upgrades held at the Hinkler Room at Sydney Airport on 15...
AusALPA Submission re Western Sydney Airport
In relation to the proposed Western Sydney Airport (WSA), AusALPA has reviewed the Environmental Impact Statement (EIS) together with the Draft Airport Plan and would like to make the following comments...
AusALPA Submission re Part 121
The Association has two main areas of concern on which it will make comment. These are in the matter of offences of strict liability, and the matter of fuel requirements.
AusALPA Position on Airborne Image Recorders
The Association’s position is that the human and financial costs of installing AIRs far exceed any technical investigative benefit and that any suggestion of changing international standards to implement mandatory fitment is extremely premature.
AusALPA Comments on the Review of Aerodrome (TAF) Services for Aviation
In general, the proposals seem reasonable and align Australia with the ICAO Annex 3 SARPS, as modified by the ICAO Basic Air Navigation Plan (ICAO Doc 9673). There are, however, some areas of discussion and/or concern. It is imperative that proper...
AusALPA Position on Rozelle Village Development
The Sydney Morning Herald has reported that Airservices Australia has advised that the proposed residential towers to be erected on top of Balmain Leagues Club would infringe the airspace, as specified in the International Civil Aviation...