Feedback to CASA's Office of Airspace Regulation has revealed fears for recreational aviation after controlled airspace is introduced around Ballina-Byron Gateway airport.
Consultation on a revised structure presented to the OAR by Airservices Australia closed on 6 June, with the proposal showing Class C airspace above a Class D tower attracting some criticism in the published feedback from recreational and private pilots.
The CTA proposal for Ballina-Byron will also have impacts on three airfields situated underneath the control steps: Tyagarah, Alstonville South and Blueberry Fields. Tyagarah and Alstonville South are homes to vibrant recreational and sport aviators, which may find themselves shut out of the airspace around Ballina if the CTA is established as proposed.
Before departing the organisation earlier this month, Recreational Aviation Australia (RAAus) Head of Flight Operations Jill Bailey told the OAR that the proposal would decrease safety for recreational pilots.
"[RAAus] understands the need for Class D and overlying Class C in the Ballina area, but until RAAus members are permitted to operate in controlled airspace, this proposal will prevent many Ballina local and transiting RAAus pilots from operating safely around this area.
"RAAus VFR pilots without access to Controlled Airspace are forced to fly over terrain which is not conducive to a successful emergency landing along the J-curve of eastern Australia already which presents a serious safety risk.
"Additionally, consideration needs to be given to ensure VFR flights departing Lismore are not constrained under the overlying Class C step as proposed and training flights from this location are able to reach a safe height OCTA to conduct stall training and other maneuvers which require safe minimum heights."
Although CASA is considering granting CTA access to holders of Recreational Pilot Certificates (RPC), the project is believed to be linked to the stalled CASR Part 103 Manual of Standards.
Oliver Mueller runs Byron Bay Gyrocopters out of Tyagarah Airfield, 14 nm north of Ballina-Byron. Mueller told the OAR that the CTA proposal would force a lower standard of safety on his students.
"I believe that these proposed changes would have a strong negative impact for many pilots, in a recreational and commercial sense," he said. "For example, I would definitely feel the impact in my daily work when conducting flight training for gyroplane students in terms of an increased level of risk taking when providing upper air work at lower altitudes.
"Secondary effect of these changes would be a reduced attractiveness for students/customers to come for this reason to Tyagarah Airfield."
Part of Mueller's concern is that Airservices is proposing to drop the lower level of the Class C airspace above Tyagarah from 6500 to 4500 feet over land, which Mueller firmly believes could produce unsafe conditions.
"A lowering of the current CLL steps over Tyagarah area will result in CLL 4500 over land and CLL 2500 over water and could be viewed as an adverse impact to the operational safety of recreational and glider operations and training activities within this area," he points out.
"In short there will exist a high risk of 'insufficient altitude' to recover from an adverse event such as a fully developed spin without fatality.
"Therefore the current Charlie CLL 6500 over land and CLL 4500 over water step heights should remain unchanged, period."
Alstonville South ALA sits only 8 m south west of Ballina-Byron, and is frequented by recreational, general aviation and antique/warbird aircraft. If the CTA proposal goes ahead as is, the runway will be right on the western limit Class D SFC zone.
That would mean operations out of the airfield would require clearances, something that has not pleased the airfield owner and operator, who had requested a shift in the boundary to 7 nm.
"There is every reason to leave YAVS outside D airspace as antique aircraft operating from YAVS will have difficulty contacting the control tower from this location," the operator said in their submission to the OAR.
"It is worth noting that the altitude of the terrain in the vicinity of the 8-nm control boundary is roughly 550 ft above YBNA and RPT aircraft overflying Alstonville appear to remain high due to the terrain issues, i.e., 3000 ft.
"In summary aircraft arriving and departing YAVS will contribute to the overall safety if they do not have to enter the control zone. Aircraft arriving and departing YAVS from the west will be OCTA and below the 1500 ft step.
"Equitable access has not been provided to traffic into and out of YAVS under the current proposal."
CASA has said it will review all comments and publish the final design for Ballina-Byron airspace in the coming months.
The new control tower is scheduled to be in operation no later than 27 November 2025.