CASA MANUAL OF STANDARDS (MOS) 139 - A review by the Australian Airports Association with the assistance of Aerodrome Design and the AAA Standards ...
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MOS 139 - A REVIEW BY THE AUSTRALIAN AIRPORTS ASSOCIATION
CASA MANUAL OF
STANDARDS (MOS) 139
A review by the Australian Airports Association with the assistance of Aerodrome Design
and the AAA Standards Working Group.
May 2014
1MOS 139 - A REVIEW BY THE AUSTRALIAN AIRPORTS ASSOCIATION
27 Type C Charts.................................................... 10
TABLE OF CONTENTS 28 Viability............................................................. 10
CHAPTER 8.............................................................10
AUSTRALIAN AIRPORTS ASSOCIATION.................4 29 Markers............................................................. 11
30 Runway Centreline Width................................. 11
EXECUTIVE SUMMARY..........................................4
31 Temporarily Displaced Threshold Markings...... 11
CHAPTER 1.............................................................5
32 Passenger Path Markings.................................. 11
1 Definitions......................................................... 5
33 Wind Indicators................................................. 11
CHAPTER 2.............................................................5
34 Taxiway Edge..................................................... 12
2 Transverse Slope on Runway Strip.................... 5
35 Helicopter Standards......................................... 12
CHAPTER 5.............................................................5 36 Use of Gable Markers........................................ 12
3 Aircraft Classification Number (ACN)................ 5 37 Use of Gable Markers........................................ 12
CHAPTER 6.............................................................5 38 Runway Holding Position Markings................... 13
4 Non-Instrument and Instrument Runways....... 5 39 Equipment Clearance Line................................ 13
5 Runway Slope.................................................... 6 40 Equipment Storage Markings............................ 13
6 Runway Line of Sight......................................... 6 41 Apron Road Crossing Taxiway Marking............. 14
7 Characteristics of Runway Shoulders................ 6 42 Apron Road Adjacent Taxiway Marking............ 14
8 Surface of Graded Area of Runway Strip........... 6 43 Airside Road Marking........................................ 14
9 RESA.................................................................. 7 44 Secondary Lead In Line..................................... 14
10 RESA.................................................................. 7 45 Keyhole Marking............................................... 14
11 Surface of Stopway........................................... 7 46 Stopbar Marking............................................... 15
12 Taxiway Edge Clearance.................................... 7 47 Marshaller Stop Line and Pilot Stop Line.......... 15
13 Surface of Taxiway Shoulders............................ 8 48 Alignment Lines................................................. 15
14 Width of Taxiway Strip...................................... 8 49 Secondary Position Marking............................. 15
15 Taxiway Separation Requirement...................... 8 50 Tow Bar Disconnect Marking............................ 15
16 Aprons............................................................... 8 51 Push Back Limit Marking................................... 16
17 Helicopter Taxilane............................................ 8 52 Runway Designation Signs................................ 16
18 Separation Distances on Aprons....................... 8 53 Tug Parking Position Lines................................. 16
19 Procedures for Aerodrome Operators to deal 54 Primary Source of Electricity Supply................. 16
with Obstacles................................................... 9
CHAPTER 9.............................................................16
20 Objects that could become Obstacles............... 9
55 Portable Lighting............................................... 17
21 Tall Structures................................................... 9
56 Taxiway Lights................................................... 17
22 Additional Obstacle Assessment for an Existing
Non-Instrument Runway to be Upgraded to a 57 Elevated vs Insert Runway Edge Lights............. 17
Non-Precision Instrument Runway................... 9 58 Lighting Colour.................................................. 17
23 Curved Takeoff.................................................. 9 59 Obstacle Lighting............................................... 18
24 PANS OPS.......................................................... 9 60 Visual IWDI Lighting.......................................... 18
CHAPTER 7.............................................................9 61 Approach Lighting............................................. 18
25 Runway Strip Width.......................................... 10 62 Visual Lighting................................................... 18
26 Type B Charts.................................................... 10
2MOS 139 - A REVIEW BY THE AUSTRALIAN AIRPORTS ASSOCIATION
63 General (Visual Approach Slope Indicator 96 Area Marking.................................................... 26
Systems)............................................................ 18
97 Aerobridge Home and Preselect Positions........ 26
64 Low Intensity Lighting....................................... 19
98 Engine Start Designation................................... 26
65 Taxiway Centreline Lighting............................... 19
99 Low Strength Pavement Marking...................... 26
66 Location of Taxiway Centreline Lights............... 19
100 Hold Safe Markings .......................................... 26
67 Location of Taxiway Centreline Lights on Exist
101 MAGS Size and Location.................................... 26
Taxiways............................................................ 19
102 Lighting LEDs..................................................... 27
68 Runway Guard Lights........................................ 20
103 Lighting SMGCS................................................. 27
69 Illustrations of Taxiway Lighting........................ 20
104 Demand for Track Changes in Aerodrome
70 Apron Flood Lighting......................................... 20
Manual.............................................................. 27
71 Vehicle Warning Lights...................................... 20
105 Use of Displaced Threshold............................... 27
72 Lighting In Vicinity of Aerodromes.................... 20
106 Apron Line Marking........................................... 27
73 Chances to Reported Australian NOTAM
107 Side Transitions................................................. 28
Office ................................................................ 21
108 Apron Markings Needing Clarification ............. 28
74 NOTAM Request Form....................................... 21
109 Wind Socks........................................................ 28
75 Nomination of ARO’s to NOF and CASA............ 21
76 Emergency Planning.......................................... 21
77 Emergency Exercise Exemption......................... 21
78 Frequency of Emergency Exercises................... 21
CHAPTER 10...........................................................21
79 Vehicle Lights.................................................... 22
80 Aircraft Parking.................................................. 22
81 Aircraft Parking.................................................. 22
82 Friction Test Standards...................................... 22
83 Navaid Signage and Maintenance..................... 22
84 Light Aircraft Tie-Down Facilities....................... 23
85 Siting of Equipment in Operational Areas......... 23
86 Airservices Australia Navaid Standards............. 23
87 Requirement of NCN......................................... 23
CHAPTER 11...........................................................23
MISCELLANEOUS ITEMS........................................23
88 Definition of Instrument – Non Instrument
Runway............................................................. 24
89 Aircraft Classification Number ......................... 24
90 PANS OPS.......................................................... 24
91 Manual Update RDS.......................................... 24
92 Line Marking..................................................... 24
93 Runway Strip Marking 150 vs 90....................... 25
94 Apron Line Marking........................................... 25
95 Fuel Hydrant Marking....................................... 25
3MOS 139 - A REVIEW BY THE AUSTRALIAN AIRPORTS ASSOCIATION
AUSTRALIAN AIRPORTS
EXECUTIVE SUMMARY
ASSOCIATION
The Australian Airports Association (AAA) is the The primary focus of all involved in the aviation industry
national industry voice for airports in Australia. The across Australia is to deliver aviation safety to the
AAA represents the interests of more than 260 airports Australian public and it is recognised that there are
and aerodromes Australia wide – from local country many elements to ensuring this level of safety. The AAA
community landing strips to major international gateway recognises the wide scope of responsibilities that CASA
airports. The AAA’s members include Adelaide, Brisbane, has in establishing a regulatory framework, securing
Cairns, Canberra, Darwin, Gold Coast, Hobart, Perth, compliance from the regulations, issuing certificates and
Melbourne and Sydney airports. licences and assessing safety-related decisions taken by
industry that impact on aviation safety. The resourcing of
The AAA serves airports across the entire national
the regulator to perform all these responsibilities is a key
aviation infrastructure network. This includes:
aspect of ensuring that Australia remains at the forefront
• Tier 1 Capital City Airports of aviation safety.
• Tier 2 Non-Capital International Gateway Airports The Manual of Standards (MOS) Part 139 - Aerodromes
• Tier 3 Major Regional Airports with direct interstate is the set of regulations established and maintained
services by CASA which covers all aspects of the operation of
aerodromes. Such an important document, dealing with
• Tier 4 Major Regional RPT airports without direct highly technical and complex issues, requires regular and
interstate services (with more than 20,000 dynamic review.
passengers)
A major concern for industry is the amount of time
• Tier 5 Regional Airports without direct interstate
it is taking for CASA to undertake a review and
services (with less than 20,000 passengers)
make the required amendments to the MOS Part
• Tier 6 Regional Airports without Regular Passenger 139 – Aerodromes. Some chapters of the MOS 139 –
Transport services (general aviation operations only) Aerodromes have been in the process of being reviewed
for over five years.
• Tier 7 Remote Community Aerodromes (exist for
community service aviation: medical, emergency MOS Part 139 - Aerodromes contains many conflicting
flights) rules and definitions. Even at the most basic level,
differing definitions of what an “aircraft” is exist. As can
There are a further 100 corporate members who provide
be expected, legacy issues have been accruing over the
goods and services to airports. The Charter of the AAA is
years, such as new rules that are in stark conflict with
to facilitate co-operation among all member airports and
existing rules.
their many and varied partners in Australian aviation,
whilst maintaining an air transport system that is safe, Industry believes a lack of clarity in the MOS Part 139
secure, environmentally responsible and efficient for the - Aerodromes has the potential to cause safety risks at
benefit of all Australians. aerodromes and as such, these amendments must be
considered as a priority. The AAA understands a review
If you have any questions regarding this document please
was started on certain chapters some years ago, but
contact the AAA National Office.
no further information has been received from CASA
Australian Airports Association regarding the outcomes of these reviews.
9/23 Brindabella Circuit The AAA has established a Standards Working Group
Brindabella Park ACT 2609 which brings together the highest skilled, most
knowledgeable individuals in the industry around the
T: 02 6230 1110 matter of regulation of aerodromes. The purpose of
F: 02 6230 1367 this Working Group is to review existing standards and,
E: info@airports.asn.au where appropriate, recommend the development of new
aerodrome standards. This Working Group’s focus is on
the regulations prescribed by CASA.
A priority exercise for this Working Group and the AAA
has been the establishment of the following Issues
Register.
4MOS 139 - A REVIEW BY THE AUSTRALIAN AIRPORTS ASSOCIATION
This exercise provided members of the AAA with a
mechanism to raise issues they have noted with the MOS
Part 139 – Aerodromes, with a view to informing future CHAPTER 5
discussions between the AAA and CASA regarding the
review and amendment of the standards.
This document outlines all the issues to date that have 3 Aircraft Classification Number (ACN)
been raised with the AAA from across our membership
(both aerodrome operators and consultants to the Aerodrome Operator
industry). Where possible, detailed comments and
recommendations for amendments have been provided Section 5.1.3.9 (Table 5.1-1) – Aircraft ACNs.
by our members for consideration by CASA.
Comment
AAA’s goal is that this document can be used to assist
CASA in a broad review of MOS 139 and serve as a Not all the current aircraft ACN’s are detailed in this table
starting point for further discussions with industry. It is e.g. Embraer EMB 175, EMB 190.
vital that this cornerstone document be updated and
amended to maintain pace with the evolving aviation Recommendation
industry to ensure aerodromes continue to operate in a That the table be updated to include current operating
safe and efficient manner.
aircraft ACN’s.
CHAPTER 1 CHAPTER 6
1 Definitions 4 Non-Instrument and Instrument
Runways
Aerodrome Operator
Section 1.2: Definitions. Aerodrome Operator
A NCN was issued at an aerodrome in relation to excess
Recommendation transverse slope on the runway strip, adjacent to a
That Taxiway and Taxilane are to be defined separately, runway that does not have shoulders.
as the separation distances differ (see section 6.5.2). Section 6.2.22.2 - The transverse slope of the graded
runway strip adjacent to the runway shoulder, for the
first 3m outwards, must be negative and may be as great
as 5%.
CHAPTER 2 MOS 139 does not cover the case where no shoulder is
provided. In this case, the maximum transverse slope
permitted for Code 3 or 4 runways is 2.5%.
2 Transverse Slope on Runway Strip Comment
Aerodrome Operator The 5% allowance is to facilitate drainage away from the
pavement. Over a small width of 3m the 5% slope would
Section 2.1.8 and 2.1.9 – lack of definitions. have no impact on aircraft safety, regardless of whether
it was from the shoulder or runway. MOS 139 6.2.23.1
Comment allows a step down from the edge of the runway or
Whilst the information is available on what constitutes a shoulder of 25mm.
non-instrument or instrument, it is across a number or
sections e.g. definitions 1-8, 2.1.8, 2.1.9 etc. Recommendation
That Section 6.2.22.2 be reworded to read: “The
Recommendation transverse slope of the graded runway strip adjacent to
That definitions be included in 2.1.8/2.1.9. the runway shoulder (or runway edge in the case where
5MOS 139 - A REVIEW BY THE AUSTRALIAN AIRPORTS ASSOCIATION
there is no shoulder), for the first 3m outwards, must be Applying the requirement for the stricter line of sight
negative and may be as great as 5%”. criteria to a large runway construction may impose
prohibitive costs particularly in the case where the
Consideration should also be given to including
runway will be rarely used by light aircraft. Conversely,
a statement similar to “the determination of
the pilot of a small aircraft will not see a significant part
transverse slopes results from balancing two opposing
of the runway designed specifically for large aircraft use.
requirements. On one hand there is an advantage in
providing relatively steep runway cross slopes for runway
pavement drainage”. Such a statement would assist Recommendation
an aerodrome subject to seasonal periods of heavy Consideration be given to amendments that allow for
precipitation. runway designers to take into account the line of sight
requirements (including where there are intersecting
runways) of all aircraft expected to use the facility.
5 Runway Slope
Consideration may also be given to the following extract
Consultant form ICAO Annex 14: “Consideration will have to be
given to providing an unobstructed line of sight over
Section 6.2.6.2 – refers to “large Jet Aircraft” (lack of
the entire length of a single runway where a full-length
definition).
parallel taxiway is not available. Where an aerodrome
Uniform slope – unclear whether this is to be measured has intersecting runways, additional criteria on the
from the start of the runway or any displaced threshold line of sight of the intersection area would need to be
location. considered for operational safety”.
Comment
7 Characteristics of Runway Shoulders
9.1.16.1.1 states “For the purpose of this Section,
aeroplanes bigger than code 3C are treated as larger Aerodrome Operator
aeroplanes. Code 3C aeroplanes and aeroplanes smaller
Section 6.2.12 - Characteristics of Runway Shoulders
are treated as smaller aeroplanes”
It appears that the MOS is not clear on a definition of Comment
large jet aircraft, nor where the prescribed distance of
runway with a uniform slope commences i.e. end of 6.2.12.1 (d) states “… be constructed so as to be capable
runway, threshold, or the start of the runway. of supporting an aeroplane, running off the runway,
without causing structural damage to the aeroplane;
and…”
Recommendation
That clarification/definition for ‘large jet aircraft’ be Recommendation
provided, as well as clarification on where it is intended
the uniform slope required distance be measured from. That clarification be provided to the extent of the
structural pavement required (i.e. 75m wide structural
pavement would have significant implications).
6 Runway Line of Sight
Consultant 8 Surface of Graded Area of Runway
Table 6.2-3 - if a Code C, E or F runway is used by Code A
Strip
or B aircraft, smaller aircraft are likely to be more critical
Consultant
with lower eye height (1.5m versus 3m).
Section 6.2.23.1 – Any step down to the abutting surface
Comment of a runway strip from a runway, runway shoulder or
stopway must not be more than 25 mm.
A runway suitable for Code C, D, E or F aircraft can be
unsuitable, in some instances, for small Code A or B in
Comment
terms of line of sight. The problem is twofold - a large
aircraft has a much higher pilot eye height, so the pilot The allowable step down from the runway edge or
can see for a far greater distance than the pilot of a light shoulder to the grassed graded section only refers for a
aircraft. A light aircraft only requires in the order of 1000 downward step tolerance and not an upward step. The
to 1500m of runway, whereas a pilot of a large aircraft problem is when grass, silt, etc. builds up on the edge of
typically requires 3000m. a runway it creates an earthed step upwards.
6MOS 139 - A REVIEW BY THE AUSTRALIAN AIRPORTS ASSOCIATION
Without a tolerance, most airports would likely have the end of the runway. The part abutting the runway
no conforming steps on the runway edges. It could cannot be RESA by CASA’s definition. It could be called
also be construed that every tough of grass is a non- undershoot which is often constructed and sealed
conformance. pavement.
Recommendation Recommendation
That the clause be amended to read: “Any step to the That the RESA section and associated clauses be
abutting surface of a runway strip from a runway edge, amended so that when referring to areas abutting the
runway shoulder or stopway must not be more than 25 runway, those areas are clearly identified as undershoot
mm downwards or XXmm (TBD) upwards”. or something other than RESA.
9 RESA 11 Surface of Stopway
Consultant Aerodrome Operator
Section 6.2.26 Dimension of RESA – Ambiguity in the Section 6.2.37- Surface of Stopway
wording
Comment
Comment Consideration needs to be given to the wording of this
Section 6.2.25.2 states: “Where it is not practicable to section, as it is difficult to friction test stopways due
provide the full length of RESA, the provision may include to the length and required speed to undertake friction
an engineering solution to achieve the objective of RESA, testing.
which is to enhance aeroplane deceleration. In the latter
case, aerodrome operators will need to liaise with the
relevant CASA office”. Therefore this section does not 12 Taxiway Edge Clearance
allow a reduction in length, but rather requires measures
in place that would need to provide an equivalent degree
Aerodrome Operator
of protection as provided by the full length. Section 6.3.2 - Taxiway Edge Clearance
There is no issue with specifying a minimum length
of 90m for Code 3 or 4 air transport jet, however Comment
consideration should be given to the issues in specifying Section 6.3.2.1 states: “Subject to paragraph 6.3.2.1A,
240m for Code 3 or 4 international airports. Given the width of any section of a taxiway must be such that,
the RESA standard was changed some time ago, a lot with the nose wheel of the aircraft remaining on the
of airports would have a problem reaching the 240m taxiway, the clearance between the outer main gear
requirement. If it became mandatory, those non- wheels and the edge of the taxiway, at any point, must
compliant airports would need to seek an exemption. not be less than the distance determined using Table
6.3-2”.
Recommendation There may be issues with application of this section to
That amendments be considered allowing for new old/original sections of taxiway versus new/extended
runway developments to include the full RESA taxiways. Consideration may be given to creating an
dimensions in the design. allowance for older existing Code E taxiways to be used
for Code F without an exemption requirement – this
would be consistent with clause 6.3.1.1B
10 RESA
Recommendation
Consultant
That consideration be given for making allowance for
Section 6.2.29 – Bearing strength of RESA
new Taxiway construction (Code F Taxiway) to tie into
existing Taxiway (Code E), with the fillet not meeting the
Consultant 4.5m Taxiway edge clearance.
RESA commences at the end of the runway strip, yet it is
called a runway end safety area. More confusing is the
note under Section 6.2.29.1 that provides instruction
on constructing the RESA to half pavement strength at
7MOS 139 - A REVIEW BY THE AUSTRALIAN AIRPORTS ASSOCIATION
13 Surface of Taxiway Shoulders 16 Aprons
Aerodrome Operator Consultant
Section 6.3.10 - Surface of Taxiway Shoulders Section 6.5 - Aprons (it may be useful to cross reference
requirements with CAO 20.9)
Comment
Clarification be provided that the ‘sealed’ section does
Comment
not mean structural pavement capable of supporting an CAO 20.9 provides clearance requirements during aircraft
aircraft. refuelling from buildings, other aircraft exposed public
areas etc.
14 Width of Taxiway Strip Recommendation
Aerodrome Operator Consideration be given to amending Section 6.5 to
include a cross reference to CAO 20.9
Section 6.3.12 - Width of Taxiway Strip
Comment 17 Helicopter Taxilane
Clarification be provided that the Taxiway strip is to be
determined by critical aircraft not the code of aircraft e.g.
Aerodrome Operator
B744 = 47.5m or A333 = 45.2m. Example - A taxi lane between the lit Helicopter
Landing Site (HLS) and a set of hangers was observed
by CASA to have an uneven surface that may permit
15 Taxiway Separation Requirement the accumulation of water, an NCN was issued. This
particular taxi lane is only utilised via air taxi and thus
Consultant the accumulation of water would not pose a threat
For Code 3C and 4C, non-precision runway centreline to helicopter safety. It should be recommended that
distances for both codes is shown at 93m. If a 300m taxiways provided for helicopter operations and available
runway strip is required for an airport with a 45m wide only via air taxi be exempt be from para 6.3.5.1 of MOS
runway, 93m would fall within 150m of the runway part 139 (Aerodromes).
centreline
This standard also applies to aircraft taxiways only with
no mention of helicopter requirements. ICAO Annex
Comment 14 Heliport standards should be applied to helicopter
Table 6.3-5 allows parallel taxiway serving NPA Code taxiway strips. The new draft CAAP 92-2(2) for Helicopter
4C to be clear of the 150m runway strip but within the landing Sites does not give any guidance on helicopter
flyover area of a 300m runway strip. Table 6.2.18.2 taxiway clearances and surface standards.
requires a 300m runway strip for Code 3 and 4 aircraft
where the runway width is 45m or more. Comment
The allowance in 6.5-2 appears to be a legacy issue It is unclear why, in this particular instance, CASA applied
from when Code 4C aircraft could operate from a 30m a fixed wing taxiway standard to a facility solely for air
runway under instrument 235A, which has now changed. taxi. There is a general lack of information in MOS 139 on
Changing the table to require a separation clear of 300m helicopters.
and would place a number of airports in a position where
they would need to apply for an exemption. This may Recommendation
also imply an expectation of compliance at some future
That MOS 139 be amended to adopt the standards for
time, where compliance may not be possible.
helicopters contained in ICAO Annex 14 Volume 2.
Additionally, Annex 14 does not list a separation for Code
4C in Table 3.1.
18 Separation Distances on Aprons
Aerodrome Operator
Section 6.5.2 - Separation Distances on Aprons
8MOS 139 - A REVIEW BY THE AUSTRALIAN AIRPORTS ASSOCIATION
Recommendation 21 Tall Structures
6.5.2.1 – Amend this clause so that the taxilane strip is
Consultant
to be determined by critical aircraft, not code of aircraft.
Clarification is also required regarding delineation Section 7.1.8.3 – Tall Structures Data base is not easily
between taxiway and taxilane. accessible.
6.5.2.2 - Amend this clause to include the standard for
aerobridge clearance IATA 1.5m Comment
6.5.2.3 – Amend this clause to define reduced separation The Tall Structure Data Bank, under the custodianship
distance. of the RAAF, should be made available to airports and
consultants.
22 Additional Obstacle Assessment for
CHAPTER 7 an Existing Non-Instrument Runway
to be Upgraded to a Non-Precision
Instrument Runway
19 Procedures for Aerodrome Operators Airport Operator
to deal with Obstacles
Section 7.1.8.5.
Airport Operator
Recommendation
Section 7.1.4.1 - The aerodrome operator must monitor
the OLS applicable to the aerodrome and report to CASA That this section be amended to include a statement
any infringement or potential infringement of the OLS. that no object is to be allowed to penetrate the Pans Ops
surface (refer to Airspace Regulations).
Recommendation
That this section be amended to remove the requirement 23 Curved Takeoff
of potential infringements, as aerodrome operators are
governed by protection of airspace regulations. Consultant
Section 7.1.9.1 - Curved approach, Section 7.3.2.5 (g)
20 Objects that could become Obstacles Curved take off, and Section 7.3.2.11 – it is not clear how
these are defined, nor how to survey and draw.
Airport Operator
Comment
Section 7.1.6.4 - Temporary and transient obstacles.
Temporary obstacles and transient (mobile) obstacles, It is likely that these assessments need to be performed
such as road vehicles, rail carriages or ships, in close on a case by case basis as the requirement is rare.
proximity to the aerodrome and which penetrate the
OLS for a short duration, must be referred to CASA to
determine whether they will be a hazard to aircraft
24 PANS OPS
operations. Consultant
Recommendation Chapter 7 concentrates on OLS but is short on
information for the more important protection of PANS
That this section be reviewed, particularly in relation to OPS surfaces. There may be benefit in considering cross
re-defining non-aerodrome road vehicles, such as grass references to MOS 173.
mowers or airfield operations vehicles. Such vehicles
driving outside the 300m runway strip are currently Comment
classified as transient obstacles and the requirement to
refer to CASA is very onerous. This is a very significant item. All aerodromes with an
RPT service plus many others have published instrument
procedures. Very few, other than capital city airports
have PANS OPS plans. Nearly all have OLS plans.
9MOS 139 - A REVIEW BY THE AUSTRALIAN AIRPORTS ASSOCIATION
Also MOS 173 6.1.5.1 states: “Prior to the effective Recommendation
publication date of a procedure, the certified designer
That this section be amended so that the width
must forward to the aerodrome operator for which a
standards for runway, runway strip, and approach takeoff
procedure has been designed, diagrams and obstacle
inner edge are related to the aircraft type rather than
data sufficient to enable the aerodrome operator to fulfil
runway width, where it is appropriate to do so.
obligations to report and monitor obstacles in the vicinity
of an aerodrome as required under CASR Part 139”.
While this occurs, very few aerodrome operators have 26 Type B Charts
an understanding of the data supplied as it lists obstacles
but does not provide guidance on what is or is not likely Airport Operator
to impact on the procedure design. If details are given of Section 7.2.2.3 - The decision to prepare a Type B chart
existing Object A B C etc. both at different locations and must be made in consultation with CASA.
elevations, it is unclear how this assists the aerodrome
operator to determine what new object height and Recommendation
location would be suitable or unsuitable in terms of PANS
Consideration be given to reviewing the requirement for
OPS.
a Type B Chart.
Recommendation
Consideration be given to amend MOS 139 to provide 27 Type C Charts
reference material on the construction of PANS OPS
surfaces. This could involve procedure designers working Airport Operator
collaboratively with CASA so that the data provided for Section 7.2.3.2 - For aerodromes regularly used by
monitoring is clear and easily understood. aircraft engaged in international aviation, the decision
to prepare a Type C chart must be made in consultation
with the international aircraft operators and CASA.
25 Runway Strip Width
Aerodrome Operator Recommendation
Consideration be given to reviewing the requirement for
Clarification is required in relation to the applicability of
a Type C Chart.
300m wide RWS for Code 4C operations where there is a
45m wide RWY.
Note the interrelationship to Table 7.1-1 OLS
specification for Code 4 Instrument Non-precision CHAPTER 8
approaches, which provides for a 150m inner edge
where the RWY width is 30m. It is unclear whether this
means, for example, B737 ops approved for narrow
runway (i.e. 30m) do/do not require the full 300m inner
edge and associated transitional surface protection.
28 Viability
However, if the aerodrome happens to have a 45m wide
Aerodrome Operator
RWY does it trigger the full 300m inner edge.
Section 8.1.4.1 - Markings must be clearly visible against
Comment the background upon which they are placed. Where
required, on a surface of light colour, a contrasting
CASA have consistently stated that approval to operate black surround must be provided: on a black surface, a
off a narrow runway width does not flow to other contrasting white surround must be provided
standards.
The situation works in reverse in the case of aerodromes Comment
having a 45m runway but only catering for a Code 3C
Consider amending this clause to “may be clearly
aircraft. In this case the aerodrome exceeds the standard
visible”, as red staging/storage areas are in contrast to
and it should not be required to have a 300m runway
black background, however the standards require white
strip to match the runway as stated in NCNs.
surround.
10MOS 139 - A REVIEW BY THE AUSTRALIAN AIRPORTS ASSOCIATION
29 Markers and the use of CASA approved Runway Threshold
Identification Lights (RTILs).
Aerodrome Operator
Figure 8.2-1: Cone markers Comment
There are various areas in the standards where markings
Comment are required for runway works, including to identify
a displaced threshold (V Bars etc.) and to mark the
Consider the use of other marking for Works limited
closed portion (crosses) and in some cases to remove
markers. In certain locations these markings can be the
permanent markings. The standards don’t differentiate in
cause of safety concerns due jet blast.
day or night.
Subject to the duration and type of works, The Limit of
Works markers may comprise or be a combination of: Recommendation
witches hats; yellow lights at night or in poor visibility;
900mm high red/white water barriers; 300mm high red/ That the requirements for markings in this section be
white water barriers; Concrete barriers; and or Flagging reviewed to take into account situations where the works
tape/rope. are only conducted at night.
The proposed Limit of Work marking will be stated in the
Method of Working Plan. 32 Passenger Path Markings
Aerodrome Operator
30 Runway Centreline Width Section 8.5.32.1 - This clause states passenger paths
Aerodrome Operator must be provided in accordance with relevant State
Road Authority marking standards. The traditional zebra
Section 8.3.3.3 states that the required runway crossing markings cannot always be utilised at a gate and
centreline width is 0.45m for Code 3 or 4 NPA runways simpler markings may be more effective.
and Cat 1 precision approach runways, and 0.9m for Cat
II and III precision approach runways. Comment
It is unclear how this clause would apply to a Cat 1 Use of zebra crossing on extended walkways raises
approach with departures in RVR 350 metres. In such a concerns as they are: slippery when wet; an overly
case a risk assessment would show 0.9m is needed. dominant marking on an apron at the expense of aircraft
guidelines; and provide no visual difference if a road
Comment crossing is encountered.
Rather than Section 8.3.3.3 stating the runway centreline Walkways defined by 2 parallel white lines and a
width ‘must be’, a better wording would be the walking man pictogram are simpler and have been used
‘minimum width should be’, giving airports the option of effectively at some airports. Zebra crossing markings
providing an increased width where a risk assessment could be applied at vehicle intersection points to
suggests a width wider than the standard is appropriate. highlight risk
Recommendation Recommendation
That section 8.3.3.3 be amended to read: “the minimum That this section be reviewed and amended to allow for
runway centreline marking width shall be …” with a a simple walkway marking combined with zebra crossings
recommendation of 0.9m width in the case of runways at vehicle intersections points.
allowing departures in RVR of 350m.
33 Wind Indicators
31 Temporarily Displaced Threshold
Markings Aerodrome Operator
Section 8.7.1.2 – NPA approach runways are to have a
Aerodrome Operator wind direction indicator except 8.7.1.2 does not apply
Section 8.3.9.1 - Whenever a permanent threshold if the surface wind information is provided through an
is temporarily displaced, a new system of visual cues AWIS. Section 8.7.2.3 – Wind Sock must be yellow if not
must be provided, which may include provision of new intended to be lit at night. Section 9.6.1.2 – If a wind
markings, obscuring and alteration of existing markings, indicator is provided for straight in approaches at night,
then the wind indicator is to be lit.
11MOS 139 - A REVIEW BY THE AUSTRALIAN AIRPORTS ASSOCIATION
There are examples of airport with an unlit secondary 35 Helicopter Standards
yellow wind indicator and an operational AWIS.
According to Section 8.7.1.3, a secondary sock is not Aerodrome Operator
required as the AWIS is operational. However, 9.6.1.2
With the exception of 8.11 helicopters are covered under
states that if one is provided, then it must be lit and
two CAAPs rather than MOS 139.
white.
Comment
Comment
There is very little useful information on helicopter
This is a case where a secondary sock is provided in
standards available within MOS 139. Designers generally
excess of the minimum CASA standard and serves
refer to ICAO Annex 14 Volume 2 or material from other
to assist safety. In such cases MOS 139 should allow
countries.
provision of facilities in excess of the minimum without
the operator being exposed to a NCN issue.
Recommendation
Similar issues have occurred at airports with no
That consideration be given to adopting ICAO Annex 14
shoulders but runway edge lines. Where these are not to
Volume 2 or similar for inclusion in MOS139.
the prescribed width (i.e. 450mm in the case of a NPA),
a NCN has been issued. The removal of a secondary sock
would meet compliance but it reduces safety for small 36 Use of Gable Markers
aircraft operating by day.
Aerodrome Operator
Recommendation
Section 8.2.2.2 - Runway strip markers must be white,
That this section be amended to allow provision of and may be gable, cone or flush. Gable markers are
facilities in excess of the minimum standard in cases preferred, and flush markers must only be used where
where their use enhances safety and does not cause runway strips overlap.
conflict.
Comment
34 Taxiway Edge There was an example provided where a CASA audit
has required existing flush markers to be replaced with
Consultant gables.
Section 8.4.5.1 - Taxiway edge markings “must be This may be an example of where strictly following the
provided for paved taxiways where the edges of full standard may actually reduce safety, in this instance the
strength pavement are not otherwise visually clear. potential for an increased risk of a glider wing strike. In
Markings must consist of two continuous 0.15 m wide this example the flush markers are clear and have been
yellow lines, spaced 0.15 m apart and located at the used for many years without incident. Pilots landing
taxiway edge, as shown below.” It is not explicitly clear on the sealed runway will concentrate on the painted
which part of the marking constitutes the actual edge runway markings rather than strip markers, regardless of
of the taxiway. One interpretation is that the outer edge type, and as such clear makers should be allowed.
of the outer yellow line is constituting the edge of the
taxiway. Recommendation
That consideration be given to reviewing this section
Comment to allow discretionary application of the clause in
The outer edge of the line defines the edge of the circumstances where rigid compliance results in a
taxiway as formally accepted by CASA standards, demonstrated reduction in safety.
however it has been noted that some CASA inspection
staff have a different interpretation.
37 Use of Gable Markers
Recommendation
Aerodrome Operator
That clarification be provided that the outer edge of the
There was an example provided where a CASA audit
line is the taxiway edge, which is the same interpretation
required existing flush markers to be replaced with
as used for runway side stripe markings in 8.3.6.3.
gables.
12MOS 139 - A REVIEW BY THE AUSTRALIAN AIRPORTS ASSOCIATION
Comment 1 m gaps.
The designation ‘EQUIPMENT CLEARANCE’ must
In this particular example it was recommended that
be painted on the side of the line occupied by the
the Final Approach and Take Off area around HLS be
equipment and readable from that side. The designation
marked with white gable markers. The intention was
must be repeated along the line at intervals of not more
that to enter the area a clearance should be sought from
than 30 m. Letters must be 0.3 m high, 0.15 m from the
ATC, similar to entering a graded runway strip. CASA
line, painted red.
Surveillance subsequently made the observation ‘white
gable markers delineate the Helicopter Landing Site
adjacent to Taxiway Uniform. The Manual of Standards Comment
(MOS) – Part 139 Aerodromes Sub-Section 8.2.2 states This clause is designed to safely facilitate the pre-
that the use of the white gable marker is to mark the positioning of GSE service equipment for an operational
graded portion of the runway strip’. Gable markers on turn-around of an aircraft on an apron manoeuvring
this and another HLS were then changed to blue in area.
colour although this marking is not recognized in MOS
The current wording is not clear and therefore it can’t
139.
be determined whether this area can be used to store
GSE. The equipment limit area, when not in use should
Recommendation be clear with all GSE returned to the Equipment Storage
That this section be amended to include information area.
on markings for Helicopter Final Approach and Take-Off Unattended GSE parked within the Equipment Clearance
Area (FATO). areas after an aircraft departure causes unnecessary
congestion to aprons. As the MOS does not state
38 Runway Holding Position Markings GSE must be removed immediately after an aircraft’s
departure, the MOS interpretation is ambiguous in that
Aerodrome Operator GSE can be left within this area indefinitely.
Figure 8.4-2: Pattern A and Pattern B runway-holding
Recommendation
position markings.
That section 8.5.8.1 be amended to read “Equipment
Comment clearance lines must be used on congested aprons to
assist with the pre-positioning of service vehicles to keep
Clarification is sought on the distance from the runway clear of manoeuvring aircraft. This Equipment Clearance
centreline to the holding point and whether this includes area is not for storage of GSE. This marking must… etc.”
markings. It is unclear where the three yellow holding
point lights need to be in relation to the markings (two
broken, two continuous). MOS 139 simply says ‘located 40 Equipment Storage Markings
not more than 0.3 m before the intermediate holding
position marking’. Aerodrome Operator
For the figure in question, it is unclear whether half the Section 8.5.9.2 - The words ‘EQUIPMENT STORAGE‘ must
runway strip width measurement includes the two solid be painted in red on the side where equipment is stored,
and two broken lines (bottom arrow pointing up) or if it and readable from that side. Letters must be 0.3 m high
stops at the top arrow pointing down. and 0.15 m from the line, as shown below. This marking
must be repeated at intervals not exceeding 50 m along
Recommendation the boundary.
That an amendment be made to the diagram to clearly
Comment
show measurement points.
There is no guidance marking/dividing the equipment
storage area internally.
39 Equipment Clearance Line
Recommendation
Aerodrome Operator
That this section be amended to include provisions
Section 8.5.8.1 - Equipment clearance lines must be used
permitting airports to divide the storage areas
on congested aprons to assist service vehicles to keep
(internally) and identify vehicle types by markings on
clear of manoeuvring aircraft. This marking must consist
the ground, markings should be white and text size not
of red stripes, 1 m long and 0.15 m wide, separated by
greater than the labels marking the storage area.
13MOS 139 - A REVIEW BY THE AUSTRALIAN AIRPORTS ASSOCIATION
41 Apron Road Crossing Taxiway Marking Recommendation
Consideration be given for this section to include
Aerodrome Operator
additional recommended markings for airside
Section 8.5.10.1 - Apron service roads to keep vehicles roads etc. preferably in line with the ACI handbook
clear of aircraft and taxiways. where appropriate, or alternatively, include a new
Manoeuvrability Limit Area Line marking.
Comment
It is unclear how to address airside service roads that fall 43 Airside Road Marking
within Taxiway/Taxilane strips and whether they should
be zipper patterned or some other new marking. Aerodrome Operator
Where airside roads fall within taxiway / taxilane strips Section 8.5.10.5 - Service road crosses taxiway or apron
due to lack of space at legacy airports MOS 139 must taxilane road edge, marking to be zipper patter.
provide guidance on how those roads should be marked.
Comment
Recommendation Similar to previous comments in differentiating between
taxiway and taxilane from a driver’s perspective. This
That this section be amended to provide clearer
could become complex and the intent of the marking
guidance on markings for apron road crossing taxiway/
is to warn drivers of adjacent taxying, rather than use
taxilane strips.
for control of vehicles. The zipper crossing marking as
developed by the ACI would appear preferable as it
42 Apron Road Adjacent Taxiway Marking would be internationally recognised, rather than a local
marking.
Aerodrome Operator
Section 8.5.10.4 - Service road adjacent taxying aircraft 44 Secondary Lead In Line
side marking must be a continuous double white line.
Consideration should be given to developing a limit line Aerodrome Operator
marking to distinguish/define between apron area and
Section 8.5.12.3 - requires lead in at a secondary
manoeuvring area or a new Manoeuvrability Limit Area
parking position to be marked by yellow circles 150mm
Line marking which is separate to road markings. This
in diameter. It is sometimes unclear to pilots what the
would assistance in vehicle control on taxiway systems,
purpose of this line is for.
ATC radio communication requirements and proposed
future Apron security screening requirements.
Comment
Comment It has been suggested that this marking is impractical as
it is difficult to paint, difficult to see, appears subservient
Lime is a difficult colour to paint and may not contrast
to a lead out line and importantly it is not understood by
well with white. The issue appears to be about vehicle
pilots.
control adjacent taxiways as opposed to adjacent apron
taxilanes.
Recommendation
The ACI handbook shows a double white line to provide
That this section be amended to remove the
clearance from adjacent taxying aircraft, irrespective
requirement for dots on secondary lead in lines, to be
of taxiway taxilane. The simpler ACI version appears
replaced with a continuous solid yellow line.
preferable.
Alternatively - a new Manoeuvrability Limit Area Line
marking that delineates the apron area from the 45 Keyhole Marking
manoeuvrability area which acts as a boundary from
where radio permission is required with the tower if you Aerodrome Operator
wish to cross the line and also delineates where a higher Figure 8.5-14: Keyhole marking.
level of driver authority is required if you wish to cross
the Manoeuvrability Limit Area Line. This allows only Comment
those with the required additional training to cross the
line managing the greater risks of the Manoeuvrability There is no dimensions provided for the alignment line in
Area with higher degrees of training for drivers. this diagram.
14MOS 139 - A REVIEW BY THE AUSTRALIAN AIRPORTS ASSOCIATION
Recommendation Comment
That amendments be made to include dimensions for The principle of the 18 m length of the alignment line
the alignment line in Figure 8.5-14: Keyhole marking. forward of the most forward nose wheel is to aid the
pilot of an aircraft to correctly steer the aircraft onto the
relevant Bay. This appears to be an unnecessary length
46 Stopbar Marking for the alignment line where there is a positive guidance
aid, either marshalled in or under guidance by a Nose in
Aerodrome Operator Guidance System (NIGS). Both of these guide the pilot as
Section 8.15.16.1- Consideration may be given to to their positioning in relation to the alignment lines.
including this stopbar for VGDS visual docking guidance
system (NIG) stopbar or other marking. Recommendation
That this section be amended to either remove the
Comment need for an alignment line forward of the most forward
Stop bars can be installed to compliment NIGs. nose wheel or decrease the required length from 18
Consideration should also be given to including provision m to a maximum of 10 m where marshalling or NIGS
for another marking (in addition to marshaller and pilot are provided. This will provide flexible options (in Table
stop bars) for use at bays with NIGS, particularly fixed 8.5.3) where positive guidance is provided to pilots then
aerobridges. a reduced alignment line length can be allowed.
47 Marshaller Stop Line and Pilot Stop 49 Secondary Position Marking
Line
Aerodrome Operator
Aerodrome Operator Section 8.5.20.1 - Secondary markings for 15m wingspan
Section 8.5.16 and 8.5.17 - Under these clauses there is or greater must be identified by keyhole marking. Where
no provision for a marking for bays equipped with NIGS. multiple aircraft stopbars exist on a secondary lead in
line consider adopting marshaller stopbar marking.
Comment
Comment
It can be assumed that a marshaller stop line should
be used, however with fixed aerobridges this proves The keyhole works well and has been used with a pilot
difficult. Stop positions can be less than 300mm which stop bar at remote areas. Where marshalling is provided
results in overlapping stop bars. The standards should and it is not practical to stop all aircraft on the same
permit an abbreviated stop bar for NIGS bays. position, the idea is perfectly sensible. The idea of a key
hole is to show where the nose wheel must be placed.
There is also no provision for standoff parking positions If there are multiple stop locations then a key hole is no
where the aircraft is towed on and towed off, the full 6m longer appropriate and standard stop bars should be
x 300mm marking is not required. Both situations can installed. Another consideration would be permitting a
be achieved with a 100mm wide line approximately 1m combination of keyhole and pilot stops.
long.
50 Tow Bar Disconnect Marking
48 Alignment Lines
Aerodrome Operator
Aerodrome Operator
Section 8.5.29 and figure 8.2.25 provide details of tow
Section 8.5.18 - The alignment line must extend from bar disconnect markings. In addition to the MOS 139
the location of the nose wheel in the parked position, requirements for Tow Bar Disconnect Points, each point
backwards under the body of the aircraft for a distance on a common Taxiway and/or Taxilane is numbered
of ‘X’ in Table 8.5-3. The line must also extend forward, sequentially and annotated with the words “TOW BAR
commencing at a point 3 m past the most forward nose DISCONNECT”
wheel position and extending for a distance ‘Y’, in the
table. A 1 m long section of the alignment line must be Tow Bar Disconnect Points are marked along straight
placed in the centre of the 3 m gap, as shown in Figure centrelines of a Taxiway, Taxilane or Pushback Line.
8.5-13. The designation marking will be orientated to face the
pushback engineer where practicable.
15MOS 139 - A REVIEW BY THE AUSTRALIAN AIRPORTS ASSOCIATION
Comment 53 Tug Parking Position Lines
It has been suggested that there is not necessarily a
Aerodrome Operator
need to identify tow bar disconnect points, as all tug
operators are trained and understand the marking. But Section 8.5.28 -The tug parking position line marking
at a complex layout if there is a risk of confusion it may must be provided at aerobridges and other power-in/
be appropriate to give a Bay number associated with a push-out aircraft parking positions, to ensure parked tugs
particular tug released point. The airport should be able are clear of incoming aircraft.
to add additional information as needed.
Comment
Recommendation The standards require tug position markings. There have
That consideration be given to amending this section to been examples where some aircraft positions with a
allow some flexibility in determining risks and the need head of stand road, providing tug parking position that
for additional information in the form of line marking, conflicts with the road. As the tug position is intended
without the risk of potential non-compliance. to allow for tugs to be on the bay when an aircraft taxies
on, the provision of markings should be on a case by case
basis, such as for locations where a building or other
51 Push Back Limit Marking fixed objects make it difficult to position the tug after the
aircraft arrives. With a head of stand road there is easy
Aerodrome Operator access for a tug to get to the nose. Providing tug position
Section 8.5.30.1 - Push-back limit markings must markings permits the operators to park there and in
comprise of two parallel white lines at right angles to and some cases the airport operator may not want to allow
symmetrical about the push back line. The marking must this.
be 1 m long, 0.15 m wide and lines 0.15 m apart.
Where it is necessary to disconnect a tow bar at a
location where a Pushback Limit marking is also required,
a Pushback Limit marking will be provided combined CHAPTER 9
with the sequential number for the Tow Bar Disconnect
Point and annotated with the words “TOW BAR
DISCONNECT
54 Primary Source of Electricity Supply
Comment
Aerodrome Operator
The less line marking the better in terms of avoiding
confusion but where required identification of the push Section 9.1.5.3 - where power cannot be supplied by
back limit marking pertinent to a particular bay may be normal reticulated power, this section allows use of solar
appropriate in some cases. power for use by aircraft with less than 10 passenger
seats. Solar power supplies, coupled with storage, are
arguably becoming increasingly reliable and should
52 Runway Designation Signs be able to be used at aerodromes intended for use by
aircraft with 10 passengers or more, without the need of
Aerodrome Operator a secondary power supply.
Figure 8.6-8: Runway designation signs with taxiway
location sign. Comment
The issue is whether solar power, without a backup
Comment generator, is reliable in all conditions – this could be
There is no example figure provide for a runway considered through a risk-based assessment. Concerns
designation sign placed on the right-hand side of the would occur during extended periods of overcast
taxiway. days. The standard appears to allow solar but requires
a backup generator for air transport aircraft with 10
Recommendation passenger seats or more.
That this section be amended to include an example Recommendation
figure under 8.6-8 of a right-hand side designation sign.
Consideration should be given to allow solar lighting
systems to be used for registered aerodromes regardless
16MOS 139 - A REVIEW BY THE AUSTRALIAN AIRPORTS ASSOCIATION
of number of passengers, providing there is adequate minimum distance offset from the taxiway centreline can
redundancy in place. be specified if needed.
It should also be noted that in the case of cone markers,
55 Portable Lighting these must be 500mm yellow cones (MOS 8.2.1.2) and
must be placed on the edge of the taxiway pavement
Aerodrome Operator MOS 8.2.4.2. There is a clear contradiction here.
Section 9.1.10 - ambiguity exists in the case of solar
Recommendation
portable lights. According to this chapter because of
the variable technology permitted, no light intensity is That section 9.1.12.1 be amended to remove ambiguity
specified. Operators have been instructed to conform and confirm 360mm is the allowable height of elevated
with the lighting standards for unserviceability lights edge lights and lights to be placed clear of propeller of
specifying minimum intensity of 10cd, and minimum aircraft at the minimum taxiway wheel to edge spacing.
taxiway intensity of 5cd, even though the portable solar Section 8.2.4.2 is also to be amended state the cones
lighting according to chapter 9.1.10 does not require to mark the edge of the graded taxiway strip, or at least
these intensities. This has resulted in considerable extra a suitable distance clear of the apron edge top, remain
cost to the airport. clear of aircraft using the taxiway.
Comment
57 Elevated vs Insert Runway Edge Lights
The use of portable lights described in 9.1.10 at RPT
aerodromes is to replace unserviceable lights until Aerodrome Operator
permanent lights are urgently repaired. There is no
Section 9.1.12.2 - Elevated lights, in general, are
reference to their use during airside works, which is
preferable to inset lights, because they provide a larger
where for example portable taxiway and unserviceability
aperture from which light signals can be seen. Elevated
lighting would be needed during airside works. If this was
lights must be used in all cases except: (a) where the use
the case and CASA required the intensities of 10cd and
of inset lights is specified in this Chapter, or (b) where it
5cd, there is a good case for clarification as it is a severe
is not practicable to use elevated lights. Technically this is
demand to insist on normal lighting intensity outputs
incorrect as the outputs of elevated and inset lights are
from temporary portable lights during short-term works,
the same.
and are covered by WSO supervision and NOATM.
Comment
Recommendation
Clause (b) allows use of inset lights where elevated lights
That clarification be provided on what is expected of
are impractical. So in the case of operations by very large
temporary lighting used during temporary works. The
aircraft where there is a risk of jet blast damage, there
expectation that such lighting meets permanent lighting
should be provision for use of inset lights. At locations
outputs is unnecessary and unrealistic given the short-
not served by large jets where there is no risk of damage,
term use and Works Safety Officer surveillance.
elevated lights are probably preferred for the reason
stated in MOS 139.
56 Taxiway Lights
Recommendation
Aerodrome Operator That this section be amended to allow use of inset
Section 9.1.12.1 - Elevated lights must be frangible and runway edge lights at locations where the aircraft,
sufficiently low to preserve clearance for propellers and through either wheel contact or excessive jet blast,
the engine pods of jet aircraft. In general, they should would cause damage to elevated light fittings.
not be more than 360 mm above the ground.
Comment 58 Lighting Colour
There was an example of an operator that installed lights Aerodrome Operator
clear of the taxiway edge that were below 360mm. This
Section 9.2 - The definition of green is different to that
was not accepted by CASA who stated the lights must be
of ICAO. This requires special product development for
low enough to be clear of the critical aircraft propellers.
a small market, and results in higher RandD costs being
It is not possible to purchase edge lights of different passed on to the airport. It has been argued that the
heights. If there is a risk of propeller damage, then a ICAO standard is better for the reason that it allows for
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