Response 925034782

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Koh

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Skyports Infrastructure

Site selection (Section 2.2)

Question 1. Do you think the content and structure of the guidance provided on site selection is clear and sufficient for this emerging industry?

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Radio button: Unticked Yes
Radio button: Ticked Yes, but with changes (please specify)
Radio button: Unticked No (please explain why)
Radio button: Unticked Not my area of expertise/not applicable
Comments
The line “minimize the interactions between vertiport traffic and other vertiport and aerodrome traffic” seems to suggest that CASA is taking a position of separation between AAM and conventional aviation traffic, or even between AAM traffic.

It is important that authorities take a position of integration and look at how AAM traffic can scale and operate with conventional aviation traffic. This will help lay the right foundations and underlying systems and infrastructure that will eventually realise the benefits of AAM to transportation and mobility.

If an approach of traffic separation is taken, it will be difficult for the industry to provide the intended services of connecting intra-city and inter-city air traffic at the lower to middle airspace.

If it is not CASA’s intention on holding such a position, the sentence could be revised to avoid any misunderstanding.

Question 2. Do you think the information on site selection is fit for the purpose of supporting the development of infrastructure for vertiports?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked Yes, but with changes (please specify)
Radio button: Unticked No (please explain why)
Radio button: Unticked Not my area of expertise/not applicable
Comments
More guidance should be provided on how vertiport operator or developer should apply the site selection considerations and whether or how such considerations will affect CASA’s approach on regulatory oversight or approval, if any, of the vertiports.
On downwash protection, CASA should specify to what extent the guidelines apply outside the boundary of the vertiport to its vicinity or arrival and departure routes connecting the vertiport.

General comments

Comments
NIL

Vertiport physical characteristics (Section 3)

Question 1. Do you think the content and structure of the guidance provided on vertiport physical characteristics is clear and sufficient for this emerging industry?

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Radio button: Unticked Yes
Radio button: Ticked Yes, but with changes (please specify)
Radio button: Unticked No (please explain why)
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Comments
CASA has done good work in this section. It has taken a very practical and sensible approach to vertiport guidance that provides flexibility for implementation. The concept of having essential and optional vertiport components suggests that CASA has thoroughly thought through the use cases and concept of operations of various vertiport designs. The use of dimensions from Annex 14 Volume II and the EASA PTS is also a positive step towards international harmonisation and provides more certainty to industry on acceptable vertiport designs.

The FATO protection area (safety area), however, should be retained under this section instead of under obstacle limitation surfaces (OLS). We understand that CASA has associated the OLS with the FATO protection area, but this protection area is after all a physical characteristic for which the purpose is to serve the safe operation at the FATO rather than a characteristic of the OLS.

Question 2. Do you think the information on vertiport physical characteristics is fit for the purpose of supporting the development of infrastructure for vertiports?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked Yes, but with changes (please specify)
Radio button: Unticked No (please explain why)
Radio button: Unticked Not my area of expertise/not applicable
Comments
Paragraph 3.1.1.4 seems out of place: “Safety devices to mitigate the risk of fall from height at elevated vertiports should not penetrate the OLS or exceed the height of the protection area.” It may not be a relevant guidance as there are already specifications regarding the penetration of these OLS and protection areas.

Geometry based stands should be included in the AC and be considered acceptable. This is especially relevant for VCAs that carry out ground taxi using its own power or by a ground movement equipment. Such ground movements do not need a large area for manoeuvring at the stand.

General comments

Comments
While not covered in this section, the definition where a FATO is a solid area should be revisited as there are many existing infrastructure serving helicopters that have FATO which are not solid, and extending over water bodies such as the Melbourne Helipad. Even though these infrastructure may not currently be under the oversight of CASA, they should remain open to be used or retrofitted as infrastructure for VCA in the future.

This is also relevant for elevated vertiports or FATOs, e.g. on a building where there could be limited floor area.

This approach of allowing non-solid FATOs is consistent with the approach of the EASA PTS and ICAO heliport design standards, which should be similarly applicable and adopted in Australia, unless there are concerns by CASA to not do so.

Obstacle limitation surfaces (Section 4)

Question 1. Do you think the content and structure of the guidance provided on OLS is clear and sufficient for this emerging industry?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked Yes, but with changes (please specify)
Radio button: Unticked No (please explain why)
Radio button: Unticked Not my area of expertise/not applicable
Comments
The guidance for OLS is extremely progressive and thoughtful to cater for the potential operations of VCAs, in particular, in urban environments. The flexibility accorded to design OLS based on the environment and intended VCA operations will enable the industry to have greater options in site selection for building vertiports.

The only proposal we would like to make is to give consideration for the approach/climb-out surface’s outer edge height above vertiport elevation (Table 2) to stop before it reaches 500 feet (152m) should the VCA is capable of carrying out such operation and if the obstacle environment allows for it. The rationale is that the 500 feet above vertiport elevation is an arbitrary construct that does not account for the elevation of the vertiport or its surrounding environment. If the VCA is able to clear obstacles safely before reaching the altitude, especially for operations from vertiports on tall buildings, this will not be necessary. It also avoids the potential of interfering with higher airspace traffic or having the aircraft performing steep manoeuvres between vertiports that could be in close proximity but at different altitudes.

Question 2. Do you think the information on OLS is fit for the purpose of supporting the development of infrastructure for vertiports?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked Yes, but with changes (please specify)
Radio button: Unticked No (please explain why)
Radio button: Unticked Not my area of expertise/not applicable

General comments

Comments
NIL

Visual aids – wind direction indicators, markers and marking (Section 5.1.1 to 5.4.3)

Question 1. Do you think the content and structure of the guidance provided on wind direction indicators, markers and marking, is clear and sufficient for this emerging industry?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked Yes, but with changes (please specify)
Radio button: Unticked No (please explain why)
Radio button: Unticked Not my area of expertise/not applicable
Comments
Guidance for apron safety lines should be included, even though they may not be available at all vertiports.

Question 2. Do you think the information on wind direction indicators, markers and marking, is fit for the purpose of supporting the development of infrastructure for vertiports?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked Yes, but with changes (please specify)
Radio button: Unticked No (please explain why)
Radio button: Unticked Not my area of expertise/not applicable

General comments

Comments
NIL

Visual aids – lighting (Section 5.5)

Question 1. Do you think the content and structure of the guidance provided on vertiport lighting, is clear and sufficient for this emerging industry?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked Yes, but with changes (please specify)
Radio button: Unticked No (please explain why)
Radio button: Unticked Not my area of expertise/not applicable

Question 2. Do you think the information on vertiport lighting is fit for the purpose of supporting the development of infrastructure for vertiports?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked Yes, but with changes (please specify)
Radio button: Unticked No (please explain why)
Radio button: Unticked Not my area of expertise/not applicable
Comments
The introduction of the barrette of 3 lights for indicating unidirectional arrow on a FAPGLS is a welcome move as it would help improve an aircraft orientating at the FATO/TLOF.

General comments

Comments
NIL