A WDB FLT CREW RPTS THAT DEPS IN BRAZILIAN AIRSPACE ARE GIVEN MULTIPLE CLRNC LIMIT FIXES THAT OFTEN REQUIRE HOLDING FOR FURTHER ATC CLRNC. THE CREW ALSO REPORTS THAT COMMUNICATION WITH ATC CAN BE INTERMITTENT; THUS INCREASING THE RISK OF A CONFLICT AT ONE OF THE CLRNC LIMIT/HOLD POINTS.

Narrative

MY LAST THREE TRIPS DEPARTING SAO PAULO (SBRE) BRAZIL HAS RAISED A SAFETY CONCERN. WITH OUR ATC DEP CLRNC WE ARE GIVEN A CLRNC LIMIT FIX USUALLY WITHIN 200 MILES OF THE ARPT. THEN AS WE PROGRESS THRU THE FLT WE ARE GIVEN AS MANY AS 10 MORE CLRNC LIMIT FIXES WITHIN BRAZIL AIRSPACE. ON THE AVERAGE NIGHT; THERE CAN BE NEARLY 10+ DEPS ALL LEAVING ON SIMILAR ROUTING AND ALTS. I HAVE SPOKEN WITH NUMEROUS CREWS FROM DIFFERENT AIRLINES THAT HAVE BEEN UNABLE TO GET THRU TO ATC WHEN APCHING THESE CLRNC LIMIT FIXES. SOME OF THESE CREWS ARE ENTERING A STANDARD HOLDING PATTERN WHEN THIS HAPPENS AND HAVE HELD FROM ONE TURN TO MANY TURNS. MY CONCERN IS; THIS IS GOING TO RESULT IN A NEAR MISS OR POSSIBLY WORSE IF THIS IS NOT RESOLVED. MANY TIMES WE HAVE DEPARTED WITH LESS THAN 10 MIN SPACING AND SAME ALT CLRNCS. COMS IN SOUTH AMERICA CAN BE VERY DIFFICULT FROM ONE MIN TO THE NEXT. THIS PROC OF GIVING CONTINUED CLRNC LIMIT FIXES NOT A SAFE PROC. IMAGINE IF THIS WAS USED IN THE US AIRSPACE AS A STANDARD FOR ALL ACFT. EVEN WITH GOOD COMS IT COULD CREATE AN ACCIDENT. IN THE LEAST; THIS PROC MAKES FOR UNNECESSARY HOLDING; POSSIBLE FUEL SHORTAGES IN FLT; POSSIBLE ACFT CONFLICTS; ETC; ETC. BRAZIL IS OVER-REACTING AND MAKING THE ENTIRE AIRWAY SYSTEM UNSAFE WITH THIS PRACTICE. PLEASE; SOMEBODY DISCUSS THIS WITH THEM.