[Peetwo]

It was the best of times, it was the worst of times - Part II

Between ‘Binger’, Hitch and AOPA finally, at long last clear picture emerging of just how desperate is the plight of ‘small aviation business’.  

One of the very good ideas, which IMO should be universally adopted, from now is the use of the term “small aviation businesses”.  The term GA, or general aviation gives a wrong impression and leaves a ‘gap’ in the public mind.  Many of the ‘small’ aviation businesses have millions of dollars invested; are sophisticated operationally, employ many or provide income to service businesses.  People understand ‘small business’; the truckies proved that.  Ben is on a winner and promoting GA as small business will create more traction than the vague, denigrating, misunderstood term GA.  

AOPA has also called on Infrastructure and Transport Minister Darren Chester to take “clear and direct action” to support small aviation businesses.

Even a wooden head like ‘whatsisname’ can understand the concept that ‘small business’ is struggling; whether or not he will actually do something useful is to be seen. We shall allow some time for the completion of boot lace tying class, if he passes that, then it may be worth wasting time and wind.

The CASA response is ‘scary’ and typical.  Morgan called the CASA bluff and won a small pot; but they have deep pockets and more exit strategies than a vicar in a cat house.  For example:-

A CASA spokesman said: “CASA accepts activity in general aviation has reduced over a lengthy period of time, although we have yet to do a comprehensive analysis of the data provided by AOPA.

There, in one statement; CASA do not accept the ‘opinion’ of AOPA.  Which, stand alone is bad enough, but watch the time slip away as a ‘tiger team’ is put on active duty to devolve and dilute the AOPA findings, then use their ‘official’ findings to renege on any promises made and to justify the continuance of ‘the mystique’.  It would be a grave error to believe the war is over; AOPA has won a small skirmish and the big guns have not arrived, nor have the battle lines been drawn.  For it is indeed a battle and if industry ‘big guns’ sidle off into the neutral zone of ‘exemption’ and ‘instruments’ and ‘privileges’ then, alas, things will revert to normal quicker than you can say “duck me”.  

Blah, blah, blah and horse feathers is the best way to describe the rest of the CASA statements.  Skidmore has sat on his ass for almost two years and achieved little tangible; Forsyth remains only an opinion, Senate recommendations long forgotten, ADSB stays, 61 stays, 48.1 stays, CVD is still in limbo, the same useless FOI and managers are still doing exactly as pleases.  I could go on, and on; but that will suffice for now.  There is no intention within CASA to change their stance on anything, no matter how illegal or ludicrous that stance maybe.

Anyone who thinks differently has not been watching the CASA game closely.  They are tough to beat, they hold government support, are the organisation the minister will turn to for advice and, make no mistake, to cover the ministerial arse that advice will be taken. So, game on and no prisoners taken.  

In peace there's nothing so becomes a man
As modest stillness and humility:
But when the blast of war blows in our ears,
Then imitate the action of the tiger;
Stiffen the sinews, summon up the blood,
Disguise fair nature with hard-favour'd rage;
Then lend the eye a terrible aspect;

In subsidium: Anderson with an excellent 'nailed it' reply on the Hitch article...  

Anderson • 6 days ago


It is truly breathtaking how divorced from reality CASA has become.

Clearing the organisation of the former senior management was an essential step in the right direction for GA, but much, much more is required than tinkering with the website - which is essentially the extent to date of "overhauling CASA’s service delivery systems".

The layer upon layer of regulation imposed in the relentlessly punitive manner by CASA has primary culpability for the decline of GA over the past decade.

"CASA does not accept that the reduction in general aviation activity can solely be attributed to safety regulations or actions by CASA" is simply meaningless propaganda. The operative weasel word here is "solely". It may be true that the decline is not solely attributable to CASA regulation. Wings are not "solely" the reason an aircraft can fly either, but try doing it without them.

CASA must take full responsibility for its reprehensible activities over many years - with GA slowly being driven into the ground as each one passed.

The CASA "spokesperson" (PR code for propagandist) as well as the rest while they are "working to develop a service culture" need to accept they have decimated the industry.

The AOPA report is the best evidence yet of the extent of the carnage.

CASA may or may not have lit the fire, but they sure have been standing by with a high pressure hose pumping avgas onto the flames.

Speaking of weasel words, I wonder if anyone has taken the time to read the latest edition of Murky Mandarin's bollocks SSP (see HERE)? You know the one that was released with little to no fanfare on the day of the Tamworth rally and three days before Malcolm called the  ridiculous two month election campaign.

Contradiction examples from the SSP.

Eg.1 This is Murky's policy statement which supposedly, among other things, is meant to address government aviation policy:

Australia's State Safety Policy Statement

Australia's aviation safety system plays a vital role in ensuring that Australia has a safe, efficient and competitive aviation industry. Australia will continue to seek closer alignment with International Civil Aviation Organization (ICAO) Standards and Recommended Practices and adopt international best practices in its aviation safety system.

The Australian Government has endorsed the following safety principles that underpin the future aviation safety system:

1. Safety is the primary consideration of Australia's aviation agencies and industry in the performance of their functions;
   
2. The highest safety priority should be afforded to passenger transport operations;
   
3. Australia's regulatory approach and responses are based on a sound assessment of the level of risk associated with particular aviation operations;
   
4. Aviation agencies and industry work closely together to identify aviation safety risks and ensure that the most appropriate methods, practices and technologies are adopted to address and reduce these risks;
   
5. A strong 'just culture' approach underpins information sharing between industry and safety agencies as information sharing assists in preventing future safety events and reflects international best practice;
   
6. Recognition that Australia's safety regulatory system plays an important role in ensuring that Australia has a safe, efficient and competitive aviation industry;
   
7. Australia's aviation regulatory procedures, processes and approach to regulation is fair, transparent and promotes nationally consistent operations;
   
8. Active and ongoing engagement by industry and safety agencies will help inform future regulatory priorities and the development of simpler regulations, standards and orders;
   
9. The safety performance of our aviation safety system will be continuously monitored and measured through the Stat's aggregate safety performance indicators as well as service provider's safety performance indicators; and
   
10. Sufficient financial and human resources for safety management and oversight will be allocated; and staff will be equipped with the proper skills and expertise to discharge their safety oversight and management responsibilities competently.
    

Mike Mrdak
Secretary, Department of Infrastructure and Regional Development
6 May 2016

 
In light of the Mildura Fog duck-up; the ongoing investigation of the broken tail VARA ATR (3 years and counting); and the recent release (after 3 years) of a shambolic investigation into a pushback accident between two RPT jets; I would suggest that the Department and it's responsible agencies are already in direct contravention of No.2 :

"...The highest safety priority should be afforded to passenger transport operations..."    

Eg.2

Quote from SSP Introduction:

The SSP is a key means of demonstrating how each ICAO Contracting State intends to achieve an acceptable level of safety performance in civil aviation in its own State. The SSP is in essence the safety management system (SMS) for the State.


The detailed requirements for SSPs are set out in Annex 19 to the Convention on International Civil Aviation (Chicago Convention). Australia's SSP sets out the specific safety activities which we will continue to perform to meet the ICAO State responsibilities concerning the safe and efficient performance of aviation activities in Australia. 

Those paragraphs highlight our obligations as a signatory to ICAO, as outlined under Annex 19, under a State run SMS (SSP). Yet if you refer to my post - The 'despicable' Dazzling Dazza - you can truly get a sense of how much Murky's new SSP is pure unadulterated weasel words and a complete and utter load of bollocks :

Cynically I also wonder if the quiet no frills release of Murky's SSP, has something to do with the fact that M&M does not want to draw attention and be questioned on the 3000+ notified differences & some of my further observations mentioned here:

Of the ICAO SARPs Annex 13 & 19 are integral to the proper implementation and effective administration of a State SSP. However as a further indicator that the Australian aviation safety bureaucracy is merely paying lip-service to the spirit & intent of ICAO, one only needs to review the 'notified differences' for A13 - http://www.airservicesaustralia.com/aip/current/sup/generatedsupplements/Annex_13.pdf -

; & A19 - http://www.airservicesaustralia.com/aip/current/sup/generatedsupplements/Annex_19.pdf .

There is a combined 12 pages and total of 55 NDs for the two Annexes.

However the real cynicism and affront to industry is within the detail. Let me explain, quote from department SSP DRAFT request for industry comment:

On 4 December 2015, the Department released an updated draft SSP for aviation industry and public comments. The comment period has now closed.

 
Note the date. Now refer to AIP SUP H104/15 [url=https://www.airservicesaustralia.com/aip/current/sup/s15-h104.pdf]  The SUP was issued on the 10 Dec 2015 and notified additional differences to at least 2 of the Annexes instrumental to the administration of a State SSP. So are the relevant notified differences, in particular with Annex 19, preempting the DRAFT SSP being implemented without amendment? How can that be possible when industry stakeholders were yet to comment?

The other option is that the NDs for Annex 19 are based on the current and original SSP.

However the current SSP was published in April 2012, how is it then possible to have additional NDs for a supposedly ICAO compliant document that has been in place for more than 4 years? 

Here is hoping that Murky's mob will eventually publish all industry comments on the 4 Dec 2015 DRAFT SSP..

The other thing that may have prompted M&M to discretely release the SSP two days before the caretaker government period, is that the SSP was referenced in the released TAAAF Policy. 

4. State Safety Program

The State Safety Program (SSP) for aviation is the primary structure for the Government to deliver its obligations under international aviation conventions.

The current approach of Government excludes industry from ongoing involvement in the SSP, other than through very broad consultation or through various piecemeal consultative mechanisms, often through different agencies.

There is a critical need to establish a stronger government-industry partnership through a fresh approach that recognises the role of industry in supporting and informing Government aviation policy. 

The Forum believes that Government should review the structures involved in the State Safety Program and provide mechanisms for improved high-level consultation with industry, including industry representative membership of the key committees.

The Forum is deeply concerned with the ongoing practice of Australia lodging differences to ICAO standards without consultation with industry. This practice must be stopped and a new system of industry consultation implemented through the SSP to ensure any difference lodged has the support of industry and is aligned with Government objectives for the efficient functioning of the Australian aviation regulatory system and international harmonisation.

If this policy (or a version of it) was adopted by the Coalition and they get back into government, it is far easier to say the SSP is done & dusted till next time (3yrs), therefore not requiring adherence to government policy...

 So AOPA and the other members of the TAAAF, keep the pressure up but do not for a minute believe the Department and it's agencies have turned over a new leaf. Murky and his minions are far too practiced in the art of obfuscation and self-preservation to ever really allow efficient functioning of the aviation regulation system and/or international harmonisation...
MTF...P2