Draft guidance on radiotelephony procedures

This consultation asked for feedback on CASA's proposed guidance on radiotelephony procedures. The guidance would be detailed in a multipart advisory circular (AC), 'Radiotelephony manual'. The consultation has now closed, and a summary of the feedback is provided below.

About this consultation
Clear, concise and accurate radio communications are an important contributor to aviation safety. To facilitate such communications, the proposed AC aimed to provide a comprehensive resource of standardised and best practice radiotelephony procedures. It included sample communication exchanges as well as detailed lists of standard phrases.

When finally published, the AC would replace the radiotelephony guidance currently specified in section GEN 3.4 of the Aeronautical Information Publication (AIP). CASA would update the AC regularly to ensure it remains accurate and fit for purpose.

In total, there were 71 respondents to the discussion paper.

The highest number of responses were from pilots or aircraft owners, but there were also comments from air traffic controllers, air traffic service providers, aerodrome operators and aviation experts or enthusiasts.

Of the respondents, 51 (72%) consented for their submissions to be openly published, while 17 (24%) requested their submissions remain confidential.

Summary of feedback
Layout of the AC
Thirty-eight respondents (53%) agreed that the layout of the AC was appropriate for a radiotelephony manual, while 18 (25%) said the layout was broadly appropriate but required improvement. Three respondents did not agree with the layout. Three respondents said this aspect was not within their area of expertise while nine (13%) did not answer the question.

Twenty-five respondents (35%) provided suggestions and recommendations for improvement, such as adding more phraseology examples for VFR operations at non-controlled aerodromes, use of real-life place names, and inclusion of sport aviation and uncrewed aircraft-specific examples. Several respondents said the document was too long and complicated, thus diminishing its usefulness and relevance.

Balance of phraseology examples and basic phrase elements
Thirty-three respondents (46%) agreed that the AC had an adequate balance, while 20 (28%) broadly agreed with the balance but sought improvement. Seven respondents (10%) did not agree with the balance. Two respondents said this aspect was not within their area of expertise while nine (13%) did not answer the question.

Twenty-eight respondents (39%) provided suggestions and recommendations for improvement, in some instances repeating the responses to the previous question, but also recommending the AC is split into separate parts covering controlled airspace and non-controlled airspace operations, more phraseology examples for vehicle operations, and addition of examples covering lane of entry operations. Again, several respondents said the document was too long and complicated.

ALL CAPITALS, sentence case or other
A small majority of 30 respondents (42%), expressly preferred example phrases being written in ALL CAPITALS, while 24 respondents (34%) expressly favoured sentence case. Two additional respondents preferred sentence case, but also recommended use of punctuation within the example phrases or formatting each element of a phrase as separate lines of text. Six respondents (8%) indicated no position on the matter while nine (13%) did not answer the question.

Those respondents in favour of all capitals commented that this format was consistent with existing phraseology conventions, is easier to read, and ensures equal importance is given to all elements of a particular phrase. On the other hand, proponents of sentence case said this format was easier to read, allowed selective use of all capitals to emphasise a particular matter and avoided the perception that all capitals means shouting.

AC fit for purpose
Twenty-eight respondents (39%) agreed that the AC was fit for purpose as a phraseology resource, while 25 (35%) said the AC was broadly fit for purpose but required improvement. Eight respondents (11%) did not agree that the AC was fit for purpose. One respondent said this aspect was not within their area of expertise while nine (13%) did not answer the question.

Comments from respondents generally aligned with comments to the previous questions, in particular:

• more detail for air and ground operations at non-controlled aerodromes or airspace
• greater use of diagrams or illustrations
• re-emphasis towards students rather than experienced pilots
• more information about communication technique.

There was also comment on editorial or drafting aspects, length and utility of the AC as currently structured or the relevance of the AC considering the existing AIP or VFRG.

Errors in the draft
Thirty-eight respondents (54%) said they had no errors, omissions, corrections or additional phrases to bring to CASA's attention. On the other hand, 22 respondents (31%) identified a variety of matters for CASA's attention including recommendation to reverse the order of the phrase '(location) TRAFFIC', error in the table on transmission of altimeter settings, need for UAS phraseologies (with at least one example offered), need for phrases about wildlife hazards on aerodromes, need for examples using callsigns relevant to recreational aviation.

Any further comments
Forty-four respondents (63%) provided further comment on the proposed AC. While generally reflecting the comments provided against earlier questions, the additional comments included:

• general support for the proposed AC
• commentary or examples of good or poor communication practice or technique
• concern that the AC focuses too much on experienced pilots
• criticism of AC examples being verbose
• recommendations for correction or improvement.

Next steps
We acknowledge the amount and quality of engagement in this consultation. We found every comment to be relevant and appropriate for creating radiotelephony resources suitable for general use in Australia. Accordingly, we reviewed each comment, recommendation and criticism and are using this information in our further work.

Reflecting on the general sentiment that the proposed AC was too long and at the same time lacking important guidance for the UAS, sport aviation and aerodrome ground operator communities, we have decided not to proceed with just a single document on radiotelephony.

Instead, we intend to create several ACs, separately dealing with aircraft communications and vehicle/personnel operations on controlled and non-controlled aerodromes. The resulting ACs may have overlapping guidance but should be more concise and focused for the relevant operating environments.

Concerning the formatting convention of phraseology examples, we intend to proceed with the ALL CAPITALS option, but with punctation and/or paragraph breaks to make longer phrases easier to read.

We will further investigate the advice about reversing the order of the initial words '… (location), TRAFFIC …' in CTAF communications and take action where necessary from that investigation.

We are also mindful about promptly addressing the existing gap in guidance for industry on radiotelephony procedures. Therefore, we may issue the revised ACs after engaging with original responders to the consultation but without further public consultation.

Our expectation is that the phraseology resources will be living documents subject to regular updates.