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KC on Scomo's RTR plans??   

Via AOPA Oz:

RED TAPE REDUCTION: WHY IT FAILS IN AVIATION

July 31, 2019 By Benjamin Morgan

AOPA Australia's Aircraft Maintenance & Engineering Contributor KEN CANNANE provide his opinion on why red-tape reduction is failing in aviation.



Recently, we have seen some great news headlines and quotes from Prime Minister Scott Morrison, who has declared he is at war with red-tape, determined to clean out government agencies and departments to make them more efficient and accountable.

For example; “The Morrison government’s plan to cut red tape will boost business investment, increase wages, and remove bureaucratic constraints on Australians reaching their potential.” and “Red tape costs Australian businesses, families, and individuals $176 billion each year, which makes red tape Australia’s biggest industry. This cost represents all of the businesses which are never started, the jobs never created, and the dreams never fulfilled due to red tape.”

However, where industry would like to be in the future can be different to where bureaucracy envisages;



Unless Government sets policy then the direction of government departments and agencies can often be biased and not supportive of business growth to meet Morrison’s red tape reduction policies.

The biggest single hurdle to overcome in aviation is the different impressions for the future between what the bureaucracy wants, what industry wants and what will provide proper growth leading to jobs.

Government must make decisions:

• Are aviation regulations and requirements subject to government policy to create jobs?
  
• Are aviation regulations and requirements subject to government policy to reduce red tape?
  
• What is the change vision and strategy to achieve jobs and red tape reduction?
  
• When will government clarify how the future will be different from the past, and how government and its agencies can make it happen?
  

The majority in industry are uncertain of the future as there is no defined government policy for the future that will provide jobs with reduced red tape.

Industry impression of the future includes many jobs being created post major red tape reduction to aviation requirements as has the USA red tape reduction program achieved. This can be achieved by delegating more responsibility to industry to reduce government costs as the USA aviation system been doing over the last couple of decades.

Industry impression is that CASA will create licencing/certificate & personnel standards for pilots like the Canadians have done and maintenance engineers standards like the Europeans have done. In all cases, remaining compliant with the standards promulgated to the ratified treaty, Convention on International Aviation.

To enable this to happen, government must remove as many barriers as possible so that those that want to make the Morrison’s vision a reality, can do so.

However, past government achievements in the 1990s have already been eroded over time by the bureaucracy. How does the government propose to make changes permanent for participants and the community?
Why isn’t government sorting out these different impressions of the future?

Plus from Shawn Kelly:

FOR BUREAUCRACY’S SAKE: KNOW THINE ENEMY
July 31, 2019 By Benjamin Morgan

AOPA Australia Director Shawn Kelly provides an insight into the strangling of Australian general aviation.



As an experienced seaplane pilot, warbird owner and adventure flight operator in Queensland, I am currently in the process of trying to obtain permits to operate my seaplane on the Pumicestone Passage, located on the Sunshine Coast in Queensland.  What at first appeared to be a relatively simple application process, has evolved into a glaring example of what’s actually killing aviation across Australia.

Currently, I operate from the Maroochy River, which is located in the same Council area as the Pumicestone Passage and is covered by the same office of Maritime Safety Queensland (MSQ).  My thinking was, that since I have safely operated for five years within these jurisdictions without incident, accident or complaint, that it would be relatively easy to obtain permits to operate in an additional area.

But alas, my application was rejected, and again on appeal was rejected again – so why?

The application and rejection process has revealed some interesting insights into the devious Australian bureaucratic mind, and I thought that my experience provides an important lesson that might be helpful in our industry’s larger battle with senseless bureaucracy and over regulation – know thine enemy!

One of the main objections to granting my approval was a concern that the Pumicestone Passage is too crowded, which is an interesting argument, because the waterway is anything but. Take a look at the photo below, which was taken at 13:30 on a Saturday;




With the above photograph in mind, think about how it would compare to say Rose Bay on Sydney Harbour, where there is a strong mixture of ferries, commercial charter boats, private motor and sail boats, along with yacht racing fleets from the CYCA and RSYS – all intermixing with the operations of Sydney Seaplanes.

However, rather than nit-picking whether or not a waterway was actually crowded, I thought it best to demonstrate that seaplanes can safely operate on crowded waterways and that such activities are not in any manner unusual or abnormal.
So with the above in mind, I provided a video of a seaplane landing on Lake Union in Washington State in the the United States of America.  Take a look at the YouTube video below and compare that to the photograph of the Pumicestone Passage;

In my application I explained that there are over 35,000 seaplane operations per year on Lake Union, which equates to about 100 seaplane movements per day, and that seaplanes have been safely operating there for 85 years without a single accident.  More importantly, pilots in Australia are trained to a high standard and everything we do in aviation is undertaken in direct support of safety.

This is the response I received:

52.  I am not satisfied that safety concerns should be deemed unfounded or negligible because of the absence of past accidents and incidents. Indeed, it is only by appropriately managing such safety risks and concerns that the occurrence of accidents and incidents can be prevented;
63.  The Applicant submits that there have been no collisions between seaplanes and vessels that have caused serious injuries or death in Australia in the past 60 years, or on Lake Union in Washington, USA for 85 years.
64.  I am not satisfied that safety records on Lake Union have particular relevance to seaplane operation in the northern area of the Pumicestone Passage. In any event, I am not satisfied that the absence of past accidents and incidents on Lake Union, in itself, is conclusive in demonstrating that all congested waterways are appropriate for seaplane operation.

A stunning response – no doubt – as yet again our aviation industry learns that in the minds of our government bureaucrats our air is so different in Australia as compared to the US (or any other country for that matter) that it demands entirely unique and overly restrictive rules to prevent aviators from harming ourselves or anyone else!

More outrageous is the manner in which the bureaucrats argue that in order to prevent potential accidents or safety issues, the acceptable course of action is to simply to prevent the activity from happening!

The response communicates that the bureaucrats first and only priority is to themselves, with their decisions always seeking to cover their backsides against any perceived liability.

The response from Maritime Safety Queensland raises more questions than it provides answers, such as;  who is the assessing officer and do they hold any formal aviation qualifications?  do they have any relevant aviation experience?  what was the methodology that was used to assess the waterway as congested?  what evidence do they have to suggest that the request was unsafe?  Simply, where are the facts?

It’s absurd that decisions are being made devoid of genuine facts and hard data.  Since when are the opinions of bureaucrats an acceptable form of evidence?

Disappointingly, to challenge this determination will now require that I personally fund an application to the Administrative Appeals Tribunal, footing the bill to ultimately educate Maritime Safety Queensland and its staff on aviation safety matters.
Should I refuse to challenge the decision it will deny my business the opportunity to grow, denies me the opportunity to employ more staff and denies the international tourists that I take flying the opportunity of depositing their hard earned money in Australia – to which we all benefit.

Ultimately, this is just one example that reinforces my view that only through immense public media exposure and political pressure will our industry see any relief in the medium to long term.

If left in the hands of bureaucrats our industry is guaranteed to be grounded and put out of existence.

MTF...P2