CAUTION: BRAZIL'S AIR SPACE AHEAD

All right, enough of this dawdling. Back to work. The statement below, issued by the International Air Line Pilots Association, indicates that Brazil has not succeeded in sweeping under the carpet the air-traffic-control disgrace that caused the Sept. 29 mid-air collision that killed 154 in the Amazon.

Among other things, this very strong statement warns international pilots of the potential perils caused by "a lack of proper government oversight and control of the ATC system." It also warns of poor radar coverage in some areas, and air traffic controllers who are inexperienced, unsupervised and lack the ability to speak more than a few phrases of English, which is the worldwide language of aviation.
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"ALPA Cautions Pilots on ATC Operations in Brazilian Airspace

On January 29, the Association issued ALPA Safety Alert 2007-01 to caution pilots about certain aspects of operating in Brazilian airspace. The September 2006 midair collision that occurred over Brazil has highlighted several issues associated with operations in that airspace that may have significant implications for the safety of flight.

ALPA believes that all pilots should maintain a high level of situational awareness while operating into or within the Brazilian Flight Identification Regions (FIRs). Of particular concern are both the procedural and technical ATC methods used in Brazilian airspace and its FIR boundary areas, compared to what pilots may be used to in other parts of the world.

ALPA therefore recommends that pilots

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operating in and around Brazilian airspace ensure they are aware of all operational guidance published by their company and review company training materials if any have been provided.
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always strictly adhere to ICAO standard phraseology for all communications and do not assume that the controller is fully aware of any changes that have been made to the flight plan.
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consider using all available exterior aircraft lighting whenever changing altitudes.
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who are familiar with operations in and around Brazil share that knowledge with their MEC Central Air Safety Committee and with ALPA’s Engineering and Air Safety Department so that subsequent follow-up bulletins can be provided to ALPA members.
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operating in this airspace, as is the case in all operations, work closely with their company safety and operations departments to ensure that all flight crews have the most comprehensive information available regarding the potential hazards of operating in this area.

While the ALPA bulletin focuses on issues related to the pilot/controller interface, pilots should note that the underlying deficiencies are caused by lack of proper governmental oversight and control of the ATC system. This is a separate issue that ALPA, in conjunction with IFALPA and other international agencies and entities, is working to correct.

Without commenting on the ongoing accident investigation regarding the recent midair collision, and based solely on reports from pilots who are experienced in operating in this environment, ALPA wishes to ensure that flight crews are aware of the following issues that may present operational challenges in Brazilian airspace:

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Although use of ATC surveillance radar is now widespread in Brazilian airspace, controllers’ experience operating in a full radar environment is still developing. This may lead to subtle changes in procedures that reflect many years of using nonradar procedures.
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Controller experience is not always taken into account in scheduling ATC facility assignments for controllers. This situation could result in inexperienced controllers operating in a challenging environment with little or no supervision.
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Flight plan changes, including inflight changes from original preflight flight plan, are not always properly transmitted through the entire ATC system. This can result in different ATC sectors having parts of two flight plans (original and revised). Therefore, if a change has been made to the original flight plan, the flight crew should make sure that a clearance for “flight planned route” has been clarified and specific routing details confirmed with each sector.
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As in many areas where English is not the controllers’ primary language, controllers may speak limited English. Pilots must also be aware that some controllers may sound proficient in the use of English as a result of these controllers either speaking with a familiar accent or because of their excellent pronunciation of certain words. In this situation, the actual proficiency of the controller’s English skills could be masked, and this could exacerbate confusion generated by any flight plan changes. Therefore, strict adherence to ICAO standard phraseology is highly recommended.
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Pilots accustomed to more-efficient ATC systems in other operating areas may not realize the need to clarify instructions, avoid assumptions, or rely on the communications and situational awareness between pilots and controllers that may otherwise prevent errors. Similarly, a controller may not challenge pilots who inadvertently request an incorrect or inappropriate altitude, routing, etc.
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Brazil has no national or airport standards for engine-out departure procedures in terminal areas; thus each operator may have different procedures. Therefore, controllers may not know what procedure pilots are following in the event of an engine failure. Under these circumstances, high cockpit workload and language proficiency issues can add to the difficulty in effectively communicating the intended flight path to ATC.

One of the consequences of today’s highly accurate navigation systems is that their precision can result in aircraft being on the same route with little or no lateral deviation. While the strategic lateral offset procedure (SLOP) that is in use in other areas of the world does not yet exist in South America, some member associations are actively debating the benefits of this concept and may soon put forth positions encouraging the use of this procedure. In the meantime, if individual flight crews choose to fly any deviations from a published airway, they should advise each ATC sector of their intentions."

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