08-11-2018, 08:29 AM
LMH 10/08/18: It's all about consultation this week as small transport ops are dropped into the crucible.
Via the Yaffa:
The Last Minute Hitch: 10 August 2018
10 August 2018
In general aviation, pessimism is robust but optimism is fragile. As much as we'd like to reverse that, things keep happening that justify the pessimism. We all applauded Minister McCormack at Wagga Wagga when he announced that CASA would craft a new set of maintenance regulations specifically for GA, but our ovation may have been premature given that we didn't have the full story. With the release of the initial discussion paper this week, we find that the new regs will apply to only a very small segment of what we call "GA", because CASA has deemed to re-define the term so that charter operations and joyflights are no longer part of GA. Although the proposed new regs seem like a great idea, they will benefit only a few small segments of GA: flying academies, ag operators, aeromedical (except patient transfer), SAR and dedicated airwork aircraft. Private flying schools and aero clubs won't benefit because their aircraft are also used in joyflights, which means the aeroplanes will have to be maintained to the passenger-carrying rules, even though their main purpose is training. Flying academies won't have this problem because they don't offer their fleets for joyflights. Once again, the operators who need the most relief from the regulatory burden are being offered none.
I see three options for the flying schools and aero clubs: maintain one aircraft to the higher standards and use only that one for joyflights, maintain the entire fleet to the higher standard or start refusing joyflights. A dedicated aircraft will add complexity and kill flexibility; running the entire fleet to the passenger-carrying regs will add cost. If the new GA regs are really going to provide the cost and burden relief that CASA says they will, flying schools and aero clubs may have to move to the new regs simply to stay alive. As training forms the larger part of their business, sacrificing joyflights may be the only choice they really have, denying GA one of its greatest promotional tools. The old caper of re-branding a joyflight as a Trial Instructional Flight will have limited ability to assuage the problem because TIFs are training and therefore passengers can't be carried; they're good for only one person. From my desk, the only answer I can see is to reclassify joyflights out of passenger-carrying and back into GA. Perhaps submissions from the industry might reflect that.
On the optimistic side, the consultation documents for these new regs do hint at a new attitude. Take, for instance, this statement. Adopting a regulatory structure based on an established and appropriate international standard that is tried, tested and proven to be working effectively, is an efficient approach to delivering tangible improvements to Australia’s GA community. That is an absolutely inarguable position for them to take, afterall, we've been telling CASA that for decades! The amount breath and tears spent trying to get this over to CASA seems to have born fruit, but it must be very frustrating to proponents of the FARs that CASA has come back like it was all their idea. All we need now is for that now-acknowledged philosophy to be applied to Part 61 ... Part 66, Part 141, Part 142, Part 135 and every other appropriate regulation.
Concurrent with the above, CASA has also started the consultation process for Part 135, which is the set of rules that cover small aeroplanes in passenger-carrying ops; in other words, low-capacity RPT, charter and joyflight. This is another conundrum for smaller operators: do they keep their charter AOC or opt out? For some companies, they will have to bite the bullet because their charter income is a larger proportion of their business, and for others it's their reason for existence. The new Part 135 proposals do present a large increase in costs (e.g. you will have to fit TAWS-B if you have more than six seats), and as charter is not a high-margin business, there is unlikely to be room to absorb the extra drag on cash flow. CASA says the new regs are designed to combine the flexibility of charter with the safety benefits it says exist in structured training and checking, but, not being an "economic regulator", they have ignored the extra costs. I also have to ask why, when they admit they were told in 1999 to apply RPT-style regs to charter, it has taken 19 years to get around to it? The answer might lie in the statement that CASA "was told ..." So who told them? I suspect the "telling" was political, meaning that CASA probably didn't even believe there was a safety issue to be addressed and so didn't give it priority. You have to wonder if there really is a safety issue that Part 135 will fix.
Bathurst Regional Council has confirmed they are going to apply commercial-standard rents to leases at the airport. They see this as a reasonable thing to do; why should airport operators get lower lease rates than other industries? Their reasoning falls down because of the monopoly they hold. Commercial leases outside of airports are subject to the natural laws of competition; if lessees don't like the rates they can always go elsewhere. Aviation companies must be on airports, which are owned and controlled by one entity: the council. That makes a monopoly situation, and it should be treated as such. Rates at regional airports should be subject to scrutiny from a regulatory body, in this case the Department of Transport and Infrastructure. It would be the ideal function of the mooted Office of Aviation Industry put forward in the resolutions from the AGAA GA summit held at Wagga Wagga. It is not fair to aviation companies that they are locked into a monopoly situation without protection. The major capital city airports are subject to this type of oversight, so why not the regionals as well?
May your gauges always be in the green,
Hitch
Read more at http://www.australianflying.com.au/the-l...Bke1RIi.99
Sandy comment:
MTF..P2
Via the Yaffa:
![[Image: hitch_tbm.jpg]](http://yaffa-cdn.s3.amazonaws.com/yaffadsp/images/dmImage/StandardImage/hitch_tbm.jpg)
The Last Minute Hitch: 10 August 2018
10 August 2018
In general aviation, pessimism is robust but optimism is fragile. As much as we'd like to reverse that, things keep happening that justify the pessimism. We all applauded Minister McCormack at Wagga Wagga when he announced that CASA would craft a new set of maintenance regulations specifically for GA, but our ovation may have been premature given that we didn't have the full story. With the release of the initial discussion paper this week, we find that the new regs will apply to only a very small segment of what we call "GA", because CASA has deemed to re-define the term so that charter operations and joyflights are no longer part of GA. Although the proposed new regs seem like a great idea, they will benefit only a few small segments of GA: flying academies, ag operators, aeromedical (except patient transfer), SAR and dedicated airwork aircraft. Private flying schools and aero clubs won't benefit because their aircraft are also used in joyflights, which means the aeroplanes will have to be maintained to the passenger-carrying rules, even though their main purpose is training. Flying academies won't have this problem because they don't offer their fleets for joyflights. Once again, the operators who need the most relief from the regulatory burden are being offered none.
Quote:"..sacrificing joyflights may be the only choice they really have.."
I see three options for the flying schools and aero clubs: maintain one aircraft to the higher standards and use only that one for joyflights, maintain the entire fleet to the higher standard or start refusing joyflights. A dedicated aircraft will add complexity and kill flexibility; running the entire fleet to the passenger-carrying regs will add cost. If the new GA regs are really going to provide the cost and burden relief that CASA says they will, flying schools and aero clubs may have to move to the new regs simply to stay alive. As training forms the larger part of their business, sacrificing joyflights may be the only choice they really have, denying GA one of its greatest promotional tools. The old caper of re-branding a joyflight as a Trial Instructional Flight will have limited ability to assuage the problem because TIFs are training and therefore passengers can't be carried; they're good for only one person. From my desk, the only answer I can see is to reclassify joyflights out of passenger-carrying and back into GA. Perhaps submissions from the industry might reflect that.
On the optimistic side, the consultation documents for these new regs do hint at a new attitude. Take, for instance, this statement. Adopting a regulatory structure based on an established and appropriate international standard that is tried, tested and proven to be working effectively, is an efficient approach to delivering tangible improvements to Australia’s GA community. That is an absolutely inarguable position for them to take, afterall, we've been telling CASA that for decades! The amount breath and tears spent trying to get this over to CASA seems to have born fruit, but it must be very frustrating to proponents of the FARs that CASA has come back like it was all their idea. All we need now is for that now-acknowledged philosophy to be applied to Part 61 ... Part 66, Part 141, Part 142, Part 135 and every other appropriate regulation.
Concurrent with the above, CASA has also started the consultation process for Part 135, which is the set of rules that cover small aeroplanes in passenger-carrying ops; in other words, low-capacity RPT, charter and joyflight. This is another conundrum for smaller operators: do they keep their charter AOC or opt out? For some companies, they will have to bite the bullet because their charter income is a larger proportion of their business, and for others it's their reason for existence. The new Part 135 proposals do present a large increase in costs (e.g. you will have to fit TAWS-B if you have more than six seats), and as charter is not a high-margin business, there is unlikely to be room to absorb the extra drag on cash flow. CASA says the new regs are designed to combine the flexibility of charter with the safety benefits it says exist in structured training and checking, but, not being an "economic regulator", they have ignored the extra costs. I also have to ask why, when they admit they were told in 1999 to apply RPT-style regs to charter, it has taken 19 years to get around to it? The answer might lie in the statement that CASA "was told ..." So who told them? I suspect the "telling" was political, meaning that CASA probably didn't even believe there was a safety issue to be addressed and so didn't give it priority. You have to wonder if there really is a safety issue that Part 135 will fix.
Bathurst Regional Council has confirmed they are going to apply commercial-standard rents to leases at the airport. They see this as a reasonable thing to do; why should airport operators get lower lease rates than other industries? Their reasoning falls down because of the monopoly they hold. Commercial leases outside of airports are subject to the natural laws of competition; if lessees don't like the rates they can always go elsewhere. Aviation companies must be on airports, which are owned and controlled by one entity: the council. That makes a monopoly situation, and it should be treated as such. Rates at regional airports should be subject to scrutiny from a regulatory body, in this case the Department of Transport and Infrastructure. It would be the ideal function of the mooted Office of Aviation Industry put forward in the resolutions from the AGAA GA summit held at Wagga Wagga. It is not fair to aviation companies that they are locked into a monopoly situation without protection. The major capital city airports are subject to this type of oversight, so why not the regionals as well?
May your gauges always be in the green,
Hitch
Read more at http://www.australianflying.com.au/the-l...Bke1RIi.99
Sandy comment:
Quote:Sandy Reith
Good job Hitch, right on the money regarding the dysfunctional regulatory regime that GA, all of GA, has been saddled with for many years, and getting considerably worse. Remember the ASSR and David Forsyth’s recommendations? Hailed in many quarters as defining the way out of the morass and virtually totally ignored by government after a few platitudes and changing the CEO, the fatuously titled ‘Director of Air Safety.’
Mate, keep up your good work, thousands of jobs have already been lost, opportunities for thousands of young Aussies (especially from the bush) could be realised with sensible policies. Proven international practice, yes, well, bit of a joke? Not obvious for the last 30 years? Give me strength.
MTF..P2