Proposed amendment to Part 172 Manual of Standards - Provision for visual surveillance systems for aerodrome control services (CD 2203AS)

Closed 24 Oct 2022

Opened 26 Sep 2022


Part 172 of the Civil Aviation Safety Regulations 1998 (CASR) and its associated Part 172 Manual of Standards (MOS) regulates the provision of air traffic services (ATS).

We are seeking comments on an amendment to the Part 172 MOS that would:

  • enable electro-optical technology (known as visual surveillance system or VSS) in the provision of aerodrome control services
  • address a gap in the control tower sight line requirements, in situations where a new runway is commissioned or an existing runway is modified at an aerodrome with an existing aerodrome control facility
  • remove standards from Chapter 3 (ATS facilities and equipment) of the Part 172 MOS that replicate standards already specified by the International Civil Aviation Organization (ICAO).

A VSS includes video cameras and optical surveillance systems that either augment or improve human surveillance at existing control towers, or completely replace a traditional control tower facility. It is proven technology – already in use in several countries – that could provide a cost-effective solution for introducing air traffic control services at aerodromes and overcoming sight line deficiencies at existing control towers.

Division 172.C.3 of CASR requires ATS facilities and equipment in Australia to comply with standards set out in the Part 172 MOS and Chapter 6 of Annex 11 to the Convention on International Civil Aviation (Chicago Convention).

Annex 11 to the Chicago Convention and ICAO Doc. 4444 (also known as the Procedures for Air Navigation Services - Air Traffic Management - PANS-ATM) have enabling standards for VSS. CASA considers these standards suitable for use in Australia. However, Division 172.C.3 of CASR does not reference the relevant parts of the ICAO standards. Critically, the standards in Chapter 3 of the Part 172 MOS require direct human observation from control towers.

Proposed changes to the standards

To enable the use of VSS in Australia, we are proposing the following changes to Chapter 3 of the Part 172 MOS:

  • Remove or amend references that exclusively requires direct human observation for the provision of ATS at an aerodrome.
  • Introduce standards enabling the use of VSS for the provision of aerodrome control services at controlled aerodromes.

We have also identified a shortcoming in the Chapter 3 standards regarding the sight lines from control towers over new runways or modified sections of existing runways, and have identified unnecessary duplication between the standards in Chapter 3 and other regulatory references and ICAO standards. To address these matters, we are also proposing to:

  • extend the requirements that apply for control towers first commissioned after 1 July 2000, so they also apply to a runway that is newly commissioned or modified after 1 July 2000.
  • delete standards in Chapter 3 that replicate an equivalent standard specified in Chapter 6 of Annex 11 to the Chicago Convention.
  • delete subsection 3.1.4 of the Part 172 MOS because matters in this subsection are already dealt with by the safety management system (SMS) requirements in regulation 172.145 of CASR and in Chapters 2 (operations manual) and 6 (SMS) of the Part 172 MOS.
  • amend Division 172.C.3 of CASR by extending the scope of relevant ICAO standards to include the facility or equipment standards specified in any chapter of Annex 11 (not just Chapter 6) and all facility and equipment standards mentioned in ICAO Doc. 4444.

Previous consultations

Prior to the release of this consultation draft, CASA has consulted internally and externally via a working group consisting of representatives from CASA, Airservices Australia and Civil Air – the air traffic controllers’ association.

Why your views matter

Consultation with the community and the aviation industry throughout the policy decision-making process ensures that the proposed new rules are clearly articulated and would work in practice and as they are intended.

Documents for review

All documents related to this consultation are attached in the ‘Related’ section at the bottom of the overview page. They are:

  • Summary of proposed change (SPC) on CD 2203AS, which provides background on the proposed standards
  • Consultation Draft – Part 172 (Air Traffic Service Providers) Amendment Manual of Standards 2022
  • MS Word copy of online consultation for ease of distribution and feedback within your organisation.

Please submit your comments through the Consultation Hub using the survey provided. If you are unable to provide feedback this way, please contact us for advice through

What happens next

At the end of the response period for public comment, we will review each comment and submission received. We will make all submissions publicly available on the CASA website, unless you request your submission remain confidential. We will also publish a Summary of Consultation which summarises the feedback received, intended changes and plans for the regulation.


  • CASA Staff
  • Air traffic controller/s
  • Traveling public/passengers
  • Air traffic service providers
  • Certified aerodrome owner/operator
  • Aerodrome industry consultant


  • Airspace and infrastructure