Response 564599847

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Richard Ogilvie

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5. Do you have any feedback regarding this draft report of the aeronautical study?

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The report fails to look holistically at why a particular issue has arisen at Mangalore.

Specifically it fails to consider the key reason for aircraft congestion at Mangalore - namely the withdrawal/limitation of access to NAVAIDs in the Melbourne basin. With the closure of NAVAIDs at locations including Wonthaggi, Yarowee and Philip Island and the booking arrangements implemented at Essendon, Moorabbin and Avalon, all IFR training traffic from Moorabbin, Essendon and other Melbourne basin airports has been forced to use Mangalore as the only unrestricted VOR and NDB within reasonable flight time of a typical IFR training aircraft.

Mangalore is unsuited to host this traffic due to
- the proximity of controlled airspace and restricted airspace
- its proximity to the northern end of the Eastern VFR lane and its geographical location being in the middle of the funnel caused by the hills to the east and Puckapunyal to the west
- its designation as a key feed point for approved IFR routes into and out of Melbourne
- the practical removal of VFR and IFR clearances from Moorabbin to/from the north via ML at or above 6000;

A complete aeronautical study should consider the wider demand for training facilities in the Melbourne area and consider if alternative options could be considered including:
1. Provision of a new, dedicated, training VOR (could be provided on the condition that it is not certified for enroute navigation and that training traffic could work within block altitudes above the area LSALT). This VOR could be placed at WON where presumably Airservices still own the land.
2. Review the requirement for Class C/E airspace above Avalon such that a corridor was provided for RPT arrivals from the north but the VOR was available above, say, 3500' as Class G for training aircraft to use independently of the ILS below.

As a wider issue, the requirement for ground based Navaids being required for the initial issue of an instrument rating should be reviewed. Allowing an initial issue based on GNSS approaches only would both suit the needs of the vast majority of pilots seeking IFR training (the vast majority of whom will never fly a ground-based aid approach in their working lives) and remove the congestion at locations such as Mangalore.