[Peetwo]

Angel Flight embuggerance update - 12/02/19

References: https://auntypru.com/forum/showthread.ph...79#pid9879 & https://auntypru.com/2019/02/

An evening with TOM.



It was the dogs that knew first; they always do – we were ambling home in that quiet time between beer o’ clock and dinner, a quick, happy bark; and, off they went. Unconcerned and slightly distracted, I followed along at a more sedate pace until I found them at the new park bench, on which, comfortably ensconced was P7_TOM (The Old Man), his feet on a medium sized ‘Esky’. The dogs were already settled so it was safe to assume he had come to talk. Wrong. “Talk to me” says he; perceptive old sod knows me well; I did indeed need a sounding board. He’d brought Guinness and a proper glass, poured one out for me,  we sat in silence and watched the small miracle of the bubbles creating the head; lovely. “Patience, persistence and performance” we drank a silent toast; then, “say it in one word” he muttered. That made it my turn, I knew he’d say no more until I coughed up the lump I was choking on. The one word challenge is no easy puzzle – given the options available. A lot of words ran through my wooden head – disappointed, disgusted, dismayed, disheartened, confused, confounded, furious; etc. It took a moment to decide that no one word could cover my disbelief of what I was actually witnessing; nor my contempt for those committing the acts; and, my stunned amazement that the Australian public not only tolerate it – but pay billions to let it all happen.

The silence lasted through until the second Guinness had settled. The dogs heard the ‘dinner time’ whistle, looked askance, got the nod and headed off to eat. “Disconnection” says I. “That’ll do for a start” say’s TOM,  “now construe, a for instance, in a nutshell”.

---

Ref: 29 November 2014 http://www.reducedmobility.eu/2014112854...lying.html


Ref: https://www.facebook.com/AOPAaustralia/p...__tn__=K-R

---

The Essendon debacle and the Angel Flight thing. The notion of holistic ‘safety’ and the best interests of the public and industry. CASA have spent a good deal of time (and by extension money) on the current Angel Flight How de Do. Ostensibly, related to their great concern for the safety of those folk who need transport to medical treatment. A real safety case which needs not only the minister’s support, but the Chair of the CASA board must be dragged out of whichever cat-house or opium den he was hiding in to support this great quest for public safety. The perpetrators of the great potential for disaster being Australian qualified Private Pilots; who are reimbursed their fuel costs by the charity. This all related to a debateable ’legal’ technicality in the very rules which CASA wrote. CASA have a remarkable number of operational ‘dispensations’ and ‘exemptions’ out there; some as old as industry itself. So, if the ‘technical’ illegality of AF pilots being reimbursed their fuel costs cannot be resolved; then CASA must either sort the rules out (mission impossible) or; issue an exemption until they finally do; or, perhaps find a way to fund the flights, through charter operators. That, or kill off one of the most useful charities in Australia. The espoused ‘public safety’ case is a gross nonsense: as risible, twisted and perverted as the mind which dreamed it up five years ago. There is barely a ‘real safety case’ to be discussed.

---

Ref: ABC News 22 February 2017 https://www.abc.net.au/news/2017-02-22/p...ss/8290906
 

Ref: SMH 16 Jan 2019 https://www.smh.com.au/business/companie...50re4.html

---

Essendon and the DFO is a horse of an entirely different colour. You don’t hear or see the minister or the CASA chairman out there on the hustings beating their chests and denouncing a ducking great big concrete and steel monstrosity built into the operational safety width of an active runway. That DFO could, potentially hold a couple of thousand innocent, unaware people, shopping and working. There is an ever present threat that ‘something’ could go horribly wrong, during a take off; duri.htmlng a missed approach; or, during a landing. World wide there have been many horrific tales of aircraft and buildings meeting, with the inevitable results. Many nations – even the Italians – have taken steps to minimise the risk. Not our CASA though. They simply pull the string attached to the ATSB top dog’s collar and whistle up yet another ‘Pilot error’ charge; done and dusted; game over. Now let’s move on to really important matters like the technical ‘illegality’ of Angel Fight. 



And ‘we’ pay for this? Politicians all run away, the tax paying public meekly accepts the faery tales, industry shut’s up -  as usual, a’feared of the ‘enforcers’ and the ATSB cowers in the gilded cage. What a brave, brilliant future CASA and our elected officials have crafted for Australia aviation safety. The stellar thinking, the impeccable logic, he visionary foresight toward ultimate safety, the breath taking elegance of the rules supporting the mystique of aviation safety.

---

“It has always seemed strange to me... the things we admire in men, kindness and generosity, openness, honesty, understanding and feeling, are the concomitants of failure in our system. And those traits we detest, sharpness, greed, acquisitiveness, meanness, egotism and self-interest, are the traits of success. And while men admire the quality of the first they love the produce of the second. ― John Steinbeck, Cannery Row.

---

I glance up as the twilight deepens, for I’d been addressing my now empty glass; there sits TOM – a quiet smile playing about the eyes. “Feel better now?" expressed by a raise of the eyebrows. “Yes” say’s I reaching into the Esky to liberate some more of the Alfred Guinness fine offering; “yes, indeed I do”. No thanks required, although how he knew to turn up exactly when he did, with exactly the right ‘thinking’ fluid, I’ll never know. Cheers Pop.

---

“If you're in trouble, or hurt or need - go to the poor people. They're the only ones that'll help - the only ones.”

---

Selah.

From the UP, posted by Ex FSO Griffo..

The "Angels Flights Saga' continues...…Note the last sentence, first paragraph...….

Received this morning 0850WST.....0050Z.....


Dear Angel Flight Supporter

You will be aware that the government agency, CASA, has taken steps to restrict our volunteer pilots, and to ban helicopters, to the extent that the viability of the charity may be placed under threat. Despite repeated requests, the agency has declined to give us, or the Australian Aircraft Owners and Pilots Association (AOPS), any safety case, or risk analysis, to support these restrictions. Importantly, CASA has deliberately bypassed its own policies, protocols and ethical standards, by failing to adhere to its regulatory reform criteria. Instead, the CEO of CASA has issued a Direction, simply a ‘law’ which is signed by him. I have repeatedly asked the CEO why he has done this, and the response was, firstly, ‘because I have the authority’, and then when pressed further, ‘because it’s easy’.

I have asked the National Operations and Standards Exec Manager, what the new rules have to do with the two volunteer flight accidents which have occurred in the last 16 years (both involving bad weather), and his answer to me was to effect that they bore no relationship to the accidents. The ATSB (Safety Bureau) has not yet released its report into the last of these accidents, in 2017.

These accidents (two in 46,000 flights) are attracting unprecedented attention from CASA, and in particular, when compared with the high number of fatal accidents which have occurred in commercial operations in Australia during the same period. Initially, CASA was underpinning its rules on the basis that our passengers are ‘uninformed’ (that is, they don’t understand that they are not travelling on an airline or commercial operation, or understand the differences). We have provided CASA with our entire suite of documents which the pilots and passengers (and drivers) must read, sign and acknowledge, and the videos which the passengers must watch prior to flying. We are perplexed as to why CASA thinks that our disadvantaged rural passengers cannot understand what they read, see or sign.

They are also implying that they have no confidence in the training, testing and licensing of their own pilots. You all know that we only accept as volunteers, those pilots holding CASA licences, and flying CASA registered and maintained aircraft for private flight in Australia. Many of our volunteers are airline pilots, commercial pilots, and of course, private pilots. Their new rules do nothing to address CASA’s training or licensing issues – they merely seek to restrict those pilots, after issuing their licences, so that they can fly anyone else in Australia subject to the provisions of their licences, but not rural people coming into the cities with Angel Flight volunteer pilots for scheduled non-emergency medical appointments.

Angel Flight does not know why there has been such a concerted attack on these volunteer pilots and aircraft – given that it is CASA’s responsibility to ensure a proper level of training before issuing the licence – it is not Angel Flight’s job to take responsibility for training under CASA regulations: we rely on them to give licences only to those who have qualified.

After first alleging that they were introducing these rules, with what seemed undue haste just before Xmas, to improve safety (although they don’t relate to the two accidents since 2003), it then moved to relying on the ‘uninformed’ argument, then changed its thrust to ‘ we are doing what the USA is doing’. That is also grossly misleading, as the private flights in the USA are not regulated in this fashion. They only regulate what they regard to be commercial operations and give an exemption if they are flying for a charity. Finally, last Friday, the chair of the CASA board said we are not ‘technically private flights’. How that relates to their restrictive proposals is perplexing- particularly as CASA has never challenged our private status, and the statement bears no relationship to the proposed restrictions.

A very worrying event occurred last week – CASA called a regional TV station, offering them an exclusive statement if they would embargo the story until this Wednesday. That statement was from the chair of the CASA Board, Tony Matthews, who said CASA was going ahead with all but one of the rules. He alleged they were to table it in parliament on Tuesday, but not release that information until Wednesday – thereby limiting the time within which to lodge a Notice of Motion to Disallow the Directions. More worryingly, they did not tell Angel Flight about this – merely advised a TV station. Quite alarming behavior from a government agency, particularly that it issued the statement on 7 February, a mere 5 working days since the close of the brief public ‘consultation’ – there were 230 submissions, many of them being lodged on the last couple of days. It is difficult to see how they could come up with this decision if they were taking these submissions into account (and Angel Flight has privately received many copies of these). The leaked exclusive was then conveyed to The Australian newspaper, and published on 8th February : again, neither the CASA Board, nor CEO, nor anyone else from CASA, had advised Angel Flight of either its decision or its intention to make a statement or table the proposals, : there was no communication from the agency of any kind, nor to AOPA, represents thousands of general aviation pilots, and who had been communicating with CASA over the issue.

Angel Flight takes a proactive position in relation to safety, but does not accept that CASA should bypass proper regulatory reform procedures to rush these changes through, knowing they will have an adverse effect on these valuable services, and that they are unsupported by any safety case or risk analysis. This should be workshopped by industry and the submissions properly evaluated, and a safety risk analysis conducted and released, before reforms are proposed, and these should be done by regulatory amendment – the proposed administrative directive cuts across many regulations, pursuant to which the pilots achieved their licences. CASA appears to be saying that Angel Flight is responsible for CASA’s own licensing standards. This administrative directive both restricts the rights of pilots to fly under their CASA licences, and could jeopardise valuable volunteer work. Even more extraordinary is that CASA has banned helicopters from flying for Angel Flight, although there have been no heli accidents in the volunteer service,: more astounding is that CASA say it is acceptable to get the total aeronautical time required, in a helicopter, but then ban helicopters! This is particularly unfortunate when many of our rural people in flooded communities may need help getting their families to medical treatment when airfields are flooded. They have offered no explanation for this ban.

We urge you all, and your colleagues, to urgently contact both your local Member of the House of Representatives, and all Senators, requesting they lodge a Notice of Motion for Disallowance, so that the issue of safety can be assessed in a measured, educated, and fact-based fashion, adopting the usual protocols and industry input. There is only a brief window of opportunity to do this -the Notice must be lodged this week, possibly Wednesday, Thursday or Friday, on the basis that CASA will deliver it on Tuesday (but again, they have not allowed us this information – we are relying upon what the chair of their Board has said to a television station).

Let’s all pull together to help people in the bush have a better quality of life – contact all federal members of parliament now by email or phone (link to a list attached).

Senators: https://www.aph.gov.au/Senators_and_Memb...gen=0&ps=0
Members: https://www.aph.gov.au/Senators_and_Memb...gen=0&ps=0


Thanks for your support,
Marjorie Pagani CEO
Angel Flight


No Cheers Here....NOPE!! None at all....

[Peetwo]

CASA embuggerance of Angel Flight update - 12/02/19

References: https://auntypru.com/forum/showthread.ph...79#pid9879 & https://auntypru.com/2019/02/

An evening with TOM.



It was the dogs that knew first; they always do – we were ambling home in that quiet time between beer o’ clock and dinner, a quick, happy bark; and, off they went. Unconcerned and slightly distracted, I followed along at a more sedate pace until I found them at the new park bench, on which, comfortably ensconced was P7_TOM (The Old Man), his feet on a medium sized ‘Esky’. The dogs were already settled so it was safe to assume he had come to talk. Wrong. “Talk to me” says he; perceptive old sod knows me well; I did indeed need a sounding board. He’d brought Guinness and a proper glass, poured one out for me,  we sat in silence and watched the small miracle of the bubbles creating the head; lovely. “Patience, persistence and performance” we drank a silent toast; then, “say it in one word” he muttered. That made it my turn, I knew he’d say no more until I coughed up the lump I was choking on. The one word challenge is no easy puzzle – given the options available. A lot of words ran through my wooden head – disappointed, disgusted, dismayed, disheartened, confused, confounded, furious; etc. It took a moment to decide that no one word could cover my disbelief of what I was actually witnessing; nor my contempt for those committing the acts; and, my stunned amazement that the Australian public not only tolerate it – but pay billions to let it all happen.

The silence lasted through until the second Guinness had settled. The dogs heard the ‘dinner time’ whistle, looked askance, got the nod and headed off to eat. “Disconnection” says I. “That’ll do for a start” say’s TOM,  “now construe, a for instance, in a nutshell”.

---

Ref: 29 November 2014 http://www.reducedmobility.eu/2014112854...lying.html


Ref: https://www.facebook.com/AOPAaustralia/p...__tn__=K-R

---

The Essendon debacle and the Angel Flight thing. The notion of holistic ‘safety’ and the best interests of the public and industry. CASA have spent a good deal of time (and by extension money) on the current Angel Flight How de Do. Ostensibly, related to their great concern for the safety of those folk who need transport to medical treatment. A real safety case which needs not only the minister’s support, but the Chair of the CASA board must be dragged out of whichever cat-house or opium den he was hiding in to support this great quest for public safety. The perpetrators of the great potential for disaster being Australian qualified Private Pilots; who are reimbursed their fuel costs by the charity. This all related to a debateable ’legal’ technicality in the very rules which CASA wrote. CASA have a remarkable number of operational ‘dispensations’ and ‘exemptions’ out there; some as old as industry itself. So, if the ‘technical’ illegality of AF pilots being reimbursed their fuel costs cannot be resolved; then CASA must either sort the rules out (mission impossible) or; issue an exemption until they finally do; or, perhaps find a way to fund the flights, through charter operators. That, or kill off one of the most useful charities in Australia. The espoused ‘public safety’ case is a gross nonsense: as risible, twisted and perverted as the mind which dreamed it up five years ago. There is barely a ‘real safety case’ to be discussed.

---

Ref: ABC News 22 February 2017 https://www.abc.net.au/news/2017-02-22/p...ss/8290906
 

Ref: SMH 16 Jan 2019 https://www.smh.com.au/business/companie...50re4.html

---

Essendon and the DFO is a horse of an entirely different colour. You don’t hear or see the minister or the CASA chairman out there on the hustings beating their chests and denouncing a ducking great big concrete and steel monstrosity built into the operational safety width of an active runway. That DFO could, potentially hold a couple of thousand innocent, unaware people, shopping and working. There is an ever present threat that ‘something’ could go horribly wrong, during a take off; duri.htmlng a missed approach; or, during a landing. World wide there have been many horrific tales of aircraft and buildings meeting, with the inevitable results. Many nations – even the Italians – have taken steps to minimise the risk. Not our CASA though. They simply pull the string attached to the ATSB top dog’s collar and whistle up yet another ‘Pilot error’ charge; done and dusted; game over. Now let’s move on to really important matters like the technical ‘illegality’ of Angel Fight. 



And ‘we’ pay for this? Politicians all run away, the tax paying public meekly accepts the faery tales, industry shut’s up -  as usual, a’feared of the ‘enforcers’ and the ATSB cowers in the gilded cage. What a brave, brilliant future CASA and our elected officials have crafted for Australia aviation safety. The stellar thinking, the impeccable logic, he visionary foresight toward ultimate safety, the breath taking elegance of the rules supporting the mystique of aviation safety.

---

“It has always seemed strange to me... the things we admire in men, kindness and generosity, openness, honesty, understanding and feeling, are the concomitants of failure in our system. And those traits we detest, sharpness, greed, acquisitiveness, meanness, egotism and self-interest, are the traits of success. And while men admire the quality of the first they love the produce of the second. ― John Steinbeck, Cannery Row.

---

I glance up as the twilight deepens, for I’d been addressing my now empty glass; there sits TOM – a quiet smile playing about the eyes. “Feel better now?" expressed by a raise of the eyebrows. “Yes” say’s I reaching into the Esky to liberate some more of the Alfred Guinness fine offering; “yes, indeed I do”. No thanks required, although how he knew to turn up exactly when he did, with exactly the right ‘thinking’ fluid, I’ll never know. Cheers Pop.

---

“If you're in trouble, or hurt or need - go to the poor people. They're the only ones that'll help - the only ones.”

---

Selah.

From the UP, posted by Ex FSO Griffo..

The "Angels Flights Saga' continues...…Note the last sentence, first paragraph...….

Received this morning 0850WST.....0050Z.....


Dear Angel Flight Supporter

You will be aware that the government agency, CASA, has taken steps to restrict our volunteer pilots, and to ban helicopters, to the extent that the viability of the charity may be placed under threat. Despite repeated requests, the agency has declined to give us, or the Australian Aircraft Owners and Pilots Association (AOPS), any safety case, or risk analysis, to support these restrictions. Importantly, CASA has deliberately bypassed its own policies, protocols and ethical standards, by failing to adhere to its regulatory reform criteria. Instead, the CEO of CASA has issued a Direction, simply a ‘law’ which is signed by him. I have repeatedly asked the CEO why he has done this, and the response was, firstly, ‘because I have the authority’, and then when pressed further, ‘because it’s easy’.

I have asked the National Operations and Standards Exec Manager, what the new rules have to do with the two volunteer flight accidents which have occurred in the last 16 years (both involving bad weather), and his answer to me was to effect that they bore no relationship to the accidents. The ATSB (Safety Bureau) has not yet released its report into the last of these accidents, in 2017.

These accidents (two in 46,000 flights) are attracting unprecedented attention from CASA, and in particular, when compared with the high number of fatal accidents which have occurred in commercial operations in Australia during the same period. Initially, CASA was underpinning its rules on the basis that our passengers are ‘uninformed’ (that is, they don’t understand that they are not travelling on an airline or commercial operation, or understand the differences). We have provided CASA with our entire suite of documents which the pilots and passengers (and drivers) must read, sign and acknowledge, and the videos which the passengers must watch prior to flying. We are perplexed as to why CASA thinks that our disadvantaged rural passengers cannot understand what they read, see or sign.

They are also implying that they have no confidence in the training, testing and licensing of their own pilots. You all know that we only accept as volunteers, those pilots holding CASA licences, and flying CASA registered and maintained aircraft for private flight in Australia. Many of our volunteers are airline pilots, commercial pilots, and of course, private pilots. Their new rules do nothing to address CASA’s training or licensing issues – they merely seek to restrict those pilots, after issuing their licences, so that they can fly anyone else in Australia subject to the provisions of their licences, but not rural people coming into the cities with Angel Flight volunteer pilots for scheduled non-emergency medical appointments.

Angel Flight does not know why there has been such a concerted attack on these volunteer pilots and aircraft – given that it is CASA’s responsibility to ensure a proper level of training before issuing the licence – it is not Angel Flight’s job to take responsibility for training under CASA regulations: we rely on them to give licences only to those who have qualified.

After first alleging that they were introducing these rules, with what seemed undue haste just before Xmas, to improve safety (although they don’t relate to the two accidents since 2003), it then moved to relying on the ‘uninformed’ argument, then changed its thrust to ‘ we are doing what the USA is doing’. That is also grossly misleading, as the private flights in the USA are not regulated in this fashion. They only regulate what they regard to be commercial operations and give an exemption if they are flying for a charity. Finally, last Friday, the chair of the CASA board said we are not ‘technically private flights’. How that relates to their restrictive proposals is perplexing- particularly as CASA has never challenged our private status, and the statement bears no relationship to the proposed restrictions.

A very worrying event occurred last week – CASA called a regional TV station, offering them an exclusive statement if they would embargo the story until this Wednesday. That statement was from the chair of the CASA Board, Tony Matthews, who said CASA was going ahead with all but one of the rules. He alleged they were to table it in parliament on Tuesday, but not release that information until Wednesday – thereby limiting the time within which to lodge a Notice of Motion to Disallow the Directions. More worryingly, they did not tell Angel Flight about this – merely advised a TV station. Quite alarming behavior from a government agency, particularly that it issued the statement on 7 February, a mere 5 working days since the close of the brief public ‘consultation’ – there were 230 submissions, many of them being lodged on the last couple of days. It is difficult to see how they could come up with this decision if they were taking these submissions into account (and Angel Flight has privately received many copies of these). The leaked exclusive was then conveyed to The Australian newspaper, and published on 8th February : again, neither the CASA Board, nor CEO, nor anyone else from CASA, had advised Angel Flight of either its decision or its intention to make a statement or table the proposals, : there was no communication from the agency of any kind, nor to AOPA, represents thousands of general aviation pilots, and who had been communicating with CASA over the issue.

Angel Flight takes a proactive position in relation to safety, but does not accept that CASA should bypass proper regulatory reform procedures to rush these changes through, knowing they will have an adverse effect on these valuable services, and that they are unsupported by any safety case or risk analysis. This should be workshopped by industry and the submissions properly evaluated, and a safety risk analysis conducted and released, before reforms are proposed, and these should be done by regulatory amendment – the proposed administrative directive cuts across many regulations, pursuant to which the pilots achieved their licences. CASA appears to be saying that Angel Flight is responsible for CASA’s own licensing standards. This administrative directive both restricts the rights of pilots to fly under their CASA licences, and could jeopardise valuable volunteer work. Even more extraordinary is that CASA has banned helicopters from flying for Angel Flight, although there have been no heli accidents in the volunteer service,: more astounding is that CASA say it is acceptable to get the total aeronautical time required, in a helicopter, but then ban helicopters! This is particularly unfortunate when many of our rural people in flooded communities may need help getting their families to medical treatment when airfields are flooded. They have offered no explanation for this ban.

We urge you all, and your colleagues, to urgently contact both your local Member of the House of Representatives, and all Senators, requesting they lodge a Notice of Motion for Disallowance, so that the issue of safety can be assessed in a measured, educated, and fact-based fashion, adopting the usual protocols and industry input. There is only a brief window of opportunity to do this -the Notice must be lodged this week, possibly Wednesday, Thursday or Friday, on the basis that CASA will deliver it on Tuesday (but again, they have not allowed us this information – we are relying upon what the chair of their Board has said to a television station).

Let’s all pull together to help people in the bush have a better quality of life – contact all federal members of parliament now by email or phone (link to a list attached).

Senators: https://www.aph.gov.au/Senators_and_Memb...gen=0&ps=0
Members: https://www.aph.gov.au/Senators_and_Memb...gen=0&ps=0


Thanks for your support,
Marjorie Pagani CEO
Angel Flight


No Cheers Here....NOPE!! None at all....

[Gobbledock]

TIME TO MAKE A STAND

Absolutely astounding. What an incredibly glaring and alarming misuse of power, processes, the Westminster system and the rights of Australians under the Chicago Convention. Not only that, the loss of a safe and efficient service that has saved countless lives in rural Australia is an absolute travesty. What should disturb those watching on is this;

- CAsA are talking to Channel 7 but not Angel Flight - that is amoral.
- DAS Carmody claiming the reason for change is simply because ‘he can’ - that is an outright abuse of power.
- Hundreds of submissions yet CAsA reviewer them all in 5 days? Horse Pooh! This is the same organisation who take months to answer just one QON - lies and deceit.
- Now the CAsA Chair shows off his ineptitude by meekly following suite with the same spin, bollocks and utter crap that the DAS is espousing - all of them guilty as charged your honour.

There needs to be an immediate halt to CAsA’s actions (I mean CAsA’s sanctions and violations) against Angel Flight and a high level inquiry needs to be enacted. It frightens me to say this, and hold no hope, but the Miniscule needs to intervene AND DO IT RIGHT NOW. Either that or all of industry must come together and act as one now.

Tick Tock

[P7_TOM]

Hook, Line and Sinker.

The bait taken; the catch assured. As the wondrous CASA ‘smoke and mirrors’ machine defers and deflects public attention away; far away from the real story. History GD; never, not ever forget it.

GD – “There needs to be an immediate halt to CAsA’s actions (I mean CAsA’s sanctions and violations) against Angel Flight and a high level inquiry needs to be enacted. It frightens me to say this, and hold no hope, but the Miniscule needs to intervene AND DO IT RIGHT NOW. Either that or all of industry must come together and act as one now.”

"Every great magic trick consists of three parts or acts. The first part is called “The Pledge”. The magician shows you something ordinary: a deck of cards, a bird or a man. He shows you this object. Perhaps he asks you to inspect it to see if it is indeed real, unaltered, normal. But of course…it probably isn’t. The second act is called “The Turn”. The magician takes the ordinary something and makes it do something extraordinary. Now you’re looking for the secret… but you won’t find it, because of course you’re not really looking. You don’t really want to know. You want to be fooled. But you wouldn’t clap yet. Because making something disappear isn’t enough; you have to bring it back. That’s why every magic trick has a third act, the hardest part, the part we call “The Prestige”.

Sure, the Angel Flight bagatelle is of passing interest; it is despicable etc. However the actors in this little charade are ‘winding the audience up’ to a fever pitch’ Much like a magician needs to distract the careful watcher; so must CASA. Carmodiy’s arrogant statements are designed to be inflammatory; and, boy-oh-boy – ain’t it working.

CASA, the DoIT, Ministers and many other ‘big guns’ are in deep do-do. If the big underwriters ever get close to the flames, those emanating from the government assisted cooling of the  fires lit by the Essendon DFO disaster; heads will roll; lots of ‘em. The ‘serious players in the insurance world and there are very few of ‘em must be farting blue lights.  If the Unions – like the SDA - ever get down to brass tacks and see just how little insurance is available; or, may be legally counted on there will be hell to pay.

You see there is not an underwriter (not a broker) who will acknowledge a legitimate claim against them if it can be demonstrated that the DFO was ‘knowingly’ built within the area designated as a ‘runway’. There is not a Union in this world which would, without full foreknowledge of the associated risk, place it’s members in a high risk situation – not without ‘insurance’, risk pay and an evacuation plan. Not going to happen – right.

And there it is. No one body is responsible for ‘approving’ the DFO grand scheme. The DFO operation is in so much debt as to beggar the imagination. Their building insurance does not cover being hit by an aircraft having a ‘legitimate’ accident within a mandated runway area. The insurance boys will be out of that so fast it would make your head spin. The only folks happy are the legal eagles – years and years of work there – it is a true legal paradise.

It begs the question. Where was our much vaunted CASA safety oversight when the DFO master plan of madness was approved? Hiding behind some legal interpretation of ‘Commonwealth’ land and ‘approvals’ perhaps? They are supposed to be the ‘be all and end all’ of ‘safety’.  Did they realise the risks the DFO crowd were taking? Did they even stop for a moment and think Whoa? No, they bloody well did not, which is bad enough. But did they also, knowingly, turn a blind eye to the aberration?

There is a multi story building, within the mandated confines of an active runway. It is widely known that the building should never have been approved. It is not widely known that the DFO could not, not at any price, buy insurance for an arguably illegal building being in a collision with an aircraft.

Angel Flight is a worthy cause and has my full support – but it ain’t the headline; not anymore. The CASA smoke and mirrors deflection system is at full throttle. Why else resurrect the done and dusted AF drama. To perhaps avoid a Royal Commission asking why CASA appear to be and seem determined to continue taking no responsibility for the Essendon DFO accident at all. If not the much vaunted, all seeing, all powerful, all wise, ‘safety watchdog, then whom? –Now that is a question I should like answered - fat chance, right.

[Gobbledock]

CAsA NON-COMPLIANT WITH THE MINISTERS STATEMENT OF EXPECTATIONS

The CAsA v Angel Flight issue can no longer be swept under the carpet. The CAsA DAS and Board have failed to deliver on the Ministers SOE, a very serious and legal non-compliance.

I have copied this directly from Miniscule Chester, his Statement of Expectations for the Board of the Civil Aviation Safety Authority for the Period 27 March 2017 to 30 June 2019, and I am highlighting these sections;

1. “I also expect the Board to facilitate effective interaction between CASA and the industry”. As Ben Morgan succinctly pointed out - FAIL
2. “CASA consider the economic and cost impact on individuals, businesses and the community in the development and finalisation of new or amended regulatory changes” - FAIL
3. “CASA undertake effective and ongoing engagement with the aviation industry to create a collaborative relationship between CASA and industry based on a foundation of mutual understanding and respect” - FAIL

The CAsA DAS, Board Chair and current Minister for Infrastructure must be removed immediately!!!!!

[Peetwo]

Angel Flight embuggerance update - 13/02/19:

From AOPA's Facebook page..

Take 5 mins from your day today to stand with AOPA Australia, AngelFlight and all volunteer pilots in calling for CASA to;

COMMUNICATE, COLLABORATE & EDUCATE - NOT OVER-REGULATE.

The Hon Michael McCormack MP
Deputy Prime Minister
Minister for Infrastructure,Transport and Regional Development
Leader of the Nationals
Federal Member for the Riverina
Telephone: (02) 6921 4600
Email: michael.mccormack.mp@aph.gov.au

References: https://auntypru.com/forum/showthread.ph...79#pid9879 & https://auntypru.com/2019/02/

An evening with TOM.


Ref: https://www.facebook.com/AOPAaustralia/p...__tn__=K-R

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The Essendon debacle and the Angel Flight thing. The notion of holistic ‘safety’ and the best interests of the public and industry. CASA have spent a good deal of time (and by extension money) on the current Angel Flight How de Do. Ostensibly, related to their great concern for the safety of those folk who need transport to medical treatment. A real safety case which needs not only the minister’s support, but the Chair of the CASA board must be dragged out of whichever cat-house or opium den he was hiding in to support this great quest for public safety. The perpetrators of the great potential for disaster being Australian qualified Private Pilots; who are reimbursed their fuel costs by the charity. This all related to a debateable ’legal’ technicality in the very rules which CASA wrote. CASA have a remarkable number of operational ‘dispensations’ and ‘exemptions’ out there; some as old as industry itself. So, if the ‘technical’ illegality of AF pilots being reimbursed their fuel costs cannot be resolved; then CASA must either sort the rules out (mission impossible) or; issue an exemption until they finally do; or, perhaps find a way to fund the flights, through charter operators. That, or kill off one of the most useful charities in Australia. The espoused ‘public safety’ case is a gross nonsense: as risible, twisted and perverted as the mind which dreamed it up five years ago. There is barely a ‘real safety case’ to be discussed.

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Ref: ABC News 22 February 2017 https://www.abc.net.au/news/2017-02-22/p...ss/8290906

P2 Addendum: Via Ben Morgan CEO AOPA Australia.

 &..

Dear Angel Flight Supporter

You will be aware that the government agency, CASA, has taken steps to restrict our volunteer pilots, and to ban helicopters, to the extent that the viability of the charity may be placed under threat. Despite repeated requests, the agency has declined to give us, or the Australian Aircraft Owners and Pilots Association (AOPS), any safety case, or risk analysis, to support these restrictions. Importantly, CASA has deliberately bypassed its own policies, protocols and ethical standards, by failing to adhere to its regulatory reform criteria. Instead, the CEO of CASA has issued a Direction, simply a ‘law’ which is signed by him. I have repeatedly asked the CEO why he has done this, and the response was, firstly, ‘because I have the authority’, and then when pressed further, ‘because it’s easy’.

I have asked the National Operations and Standards Exec Manager, what the new rules have to do with the two volunteer flight accidents which have occurred in the last 16 years (both involving bad weather), and his answer to me was to effect that they bore no relationship to the accidents. The ATSB (Safety Bureau) has not yet released its report into the last of these accidents, in 2017.

These accidents (two in 46,000 flights) are attracting unprecedented attention from CASA, and in particular, when compared with the high number of fatal accidents which have occurred in commercial operations in Australia during the same period. Initially, CASA was underpinning its rules on the basis that our passengers are ‘uninformed’ (that is, they don’t understand that they are not travelling on an airline or commercial operation, or understand the differences). We have provided CASA with our entire suite of documents which the pilots and passengers (and drivers) must read, sign and acknowledge, and the videos which the passengers must watch prior to flying. We are perplexed as to why CASA thinks that our disadvantaged rural passengers cannot understand what they read, see or sign.

They are also implying that they have no confidence in the training, testing and licensing of their own pilots. You all know that we only accept as volunteers, those pilots holding CASA licences, and flying CASA registered and maintained aircraft for private flight in Australia. Many of our volunteers are airline pilots, commercial pilots, and of course, private pilots. Their new rules do nothing to address CASA’s training or licensing issues – they merely seek to restrict those pilots, after issuing their licences, so that they can fly anyone else in Australia subject to the provisions of their licences, but not rural people coming into the cities with Angel Flight volunteer pilots for scheduled non-emergency medical appointments.

Angel Flight does not know why there has been such a concerted attack on these volunteer pilots and aircraft – given that it is CASA’s responsibility to ensure a proper level of training before issuing the licence – it is not Angel Flight’s job to take responsibility for training under CASA regulations: we rely on them to give licences only to those who have qualified.

After first alleging that they were introducing these rules, with what seemed undue haste just before Xmas, to improve safety (although they don’t relate to the two accidents since 2003), it then moved to relying on the ‘uninformed’ argument, then changed its thrust to ‘ we are doing what the USA is doing’. That is also grossly misleading, as the private flights in the USA are not regulated in this fashion. They only regulate what they regard to be commercial operations and give an exemption if they are flying for a charity. Finally, last Friday, the chair of the CASA board said we are not ‘technically private flights’. How that relates to their restrictive proposals is perplexing- particularly as CASA has never challenged our private status, and the statement bears no relationship to the proposed restrictions.

A very worrying event occurred last week – CASA called a regional TV station, offering them an exclusive statement if they would embargo the story until this Wednesday. That statement was from the chair of the CASA Board, Tony Matthews, who said CASA was going ahead with all but one of the rules. He alleged they were to table it in parliament on Tuesday, but not release that information until Wednesday – thereby limiting the time within which to lodge a Notice of Motion to Disallow the Directions. More worryingly, they did not tell Angel Flight about this – merely advised a TV station. Quite alarming behavior from a government agency, particularly that it issued the statement on 7 February, a mere 5 working days since the close of the brief public ‘consultation’ – there were 230 submissions, many of them being lodged on the last couple of days. It is difficult to see how they could come up with this decision if they were taking these submissions into account (and Angel Flight has privately received many copies of these). The leaked exclusive was then conveyed to The Australian newspaper, and published on 8th February : again, neither the CASA Board, nor CEO, nor anyone else from CASA, had advised Angel Flight of either its decision or its intention to make a statement or table the proposals, : there was no communication from the agency of any kind, nor to AOPA, represents thousands of general aviation pilots, and who had been communicating with CASA over the issue.

Angel Flight takes a proactive position in relation to safety, but does not accept that CASA should bypass proper regulatory reform procedures to rush these changes through, knowing they will have an adverse effect on these valuable services, and that they are unsupported by any safety case or risk analysis. This should be workshopped by industry and the submissions properly evaluated, and a safety risk analysis conducted and released, before reforms are proposed, and these should be done by regulatory amendment – the proposed administrative directive cuts across many regulations, pursuant to which the pilots achieved their licences. CASA appears to be saying that Angel Flight is responsible for CASA’s own licensing standards. This administrative directive both restricts the rights of pilots to fly under their CASA licences, and could jeopardise valuable volunteer work. Even more extraordinary is that CASA has banned helicopters from flying for Angel Flight, although there have been no heli accidents in the volunteer service,: more astounding is that CASA say it is acceptable to get the total aeronautical time required, in a helicopter, but then ban helicopters! This is particularly unfortunate when many of our rural people in flooded communities may need help getting their families to medical treatment when airfields are flooded. They have offered no explanation for this ban.
We urge you all, and your colleagues, to urgently contact both your local Member of the House of Representatives, and all Senators, requesting they lodge a Notice of Motion for Disallowance, so that the issue of safety can be assessed in a measured, educated, and fact-based fashion, adopting the usual protocols and industry input. There is only a brief window of opportunity to do this -the Notice must be lodged this week, possibly Wednesday, Thursday or Friday, on the basis that CASA will deliver it on Tuesday (but again, they have not allowed us this information – we are relying upon what the chair of their Board has said to a television station).

Let’s all pull together to help people in the bush have a better quality of life – contact all federal members of parliament now by email or phone (link to a list attached).

Senators: https://www.aph.gov.au/Senators_and_Memb...gen=0&ps=0
Members: https://www.aph.gov.au/Senators_and_Memb...gen=0&ps=0

Thanks for your support,

Marjorie Pagani CEO
Angel Flight

Unless I missed it? A quick peruse of the HoR Hansard for yesterday's shambolic sitting of parliament, would appear to show amongst the multitude of CASA exemptions, legislative instruments etc..etc, that the Angel Flight EMBUGGERANCE legislative instrument is yet to be tabled? 

See here: 

 

Civil Aviation Act 1988 —

Civil Aviation Regulations 1988—

Number of Cabin Attendants (Alliance Airlines) Direction 2019—CASA 01/19 [F2019L00095].

Repeal of CASA 178/10 Instrument 2019—CASA 03/19 [F2019L00066].

Civil Aviation Regulations 1988 and Civil Aviation Safety Regulations 1998—

The 2019 Bright Open Australian Nationals Instrument 2019—CASA EX01/19 [F2019L00011].

The 2019 Corryong Hang Gliding Cup Instrument 2018—CASA EX174/18 [F2018L01847].

The 2019 Corryong Paragliding Open Instrument 2019—CASA EX09/19 [F2019L00047].

Civil Aviation Safety Amendment (Part 91) Regulations 2018 [F2018L01783].

Civil Aviation Safety Amendment (Part 119) Regulations 2018 [F2018L01787].

Civil Aviation Safety Amendment (Part 121) Regulations 2018 [F2018L01784].

Civil Aviation Safety Amendment (Part 133) Regulations 2018 [F2018L01788].

Civil Aviation Safety Amendment (Part 135) Regulations 2018 [F2018L01782].

Civil Aviation Safety Amendment (Part 138) Regulations 2018 [F2018L01789].

Civil Aviation Safety Regulations 1998—

Authorised Flight Examiners Exemption 2018—CASA EX159/18 [F2018L01636]—Replacement explanatory statement.

Authorised Release Certificate (FAA and EASA Approved Components) Exemption 2018—CASA EX168/18 [F2018L01793].

Carriage of cockpit voice recorders and flight data recorders exemption 2019—CASA EX10/19 [F2019L00078].

Elevator Push Tube—Replacement—AD/DW-1/1 [F2019L00097].

Emergency Power Lever Shear Wire—AD/CESSNA 208/18 Amdt 1 [F2019L00082].

English Language Proficiency Assessments Exemption 2018—CASA EX111/18 [F2018L01214]—Replacement explanatory statement.

Horizontal Stabiliser—Centre Hinge Bracket Flange—AD/DHC-6/77 [F2019L00105].

Horizontal Stabilizer—AD/BELL 206/57 Amdt 4 [F2019L00063].

Life jacket standard (Skyplan Australia Pty Ltd) exemption 2019—CASA EX11/19 [F2019L00075].

Part 149 (Approved Self-administering Aviation Organisations) Manual of Standards 2018 [F2018L01800].

Passenger Seats and Passenger Seat Attachment Fittings—AD/DHC-2/26 Amdt 1 [F2019L00019].

Recording of Time-in-service (Class A Aircraft) Exemption 2018—CASA EX167/18 [F2018L01792].

Repeal of Airworthiness Directive AD/DHC-6/71—CASA ADCX 003/19 [F2019L00104].

Repeal of Airworthiness Directive AD/F406/16—CASA ADCX 002/19 [F2019L00101].

Repeal of Airworthiness Directives AD/DHC-6/31 Amdt 4, AD/DHC-6/50, AD/DHC-6/51 Amdt 4 and AD/DHC-6/70—CASA ADCX 001/19 [F2019L00041].

On the AF war front, I note that AOPA Oz last night changed their Facebook Header picture...



  Also from the AOPA Oz FB page a letter to miniscule McDo'Naught from instructor and commercial pilot Nicholas Christie : 

Nicholas Christie · 14:31 Nice work Ben. A call to the Minister. Let me add a letter I just wrote and sent to the Minister:

Dear Mr McCormack

I’m a professional Flight Instructor and Commercial Pilot, member of RAAus, SAAA and AOPA.

The outcome of the recent CASA legislative changes that have removed the rights of rural people to utilise Angel Flight, is highly disappointing to myself and my colleagues.

CASA’s changes (irrespective of the removal of the AD/ENG4 requirements), will force Angel Flight Pilots to stop their services to rural communities. 

Now an Angel Flight pilot requires that the minimum hours logged by the Pilot in Command of that flight are over TWICE the requirements of a Commercial Pilot! This is absolutely unnecessary from a safety perspective.

Moreover, the new proposed changes will NOT bring back the people who died in the recent two (out of approx. 16,000 flights) that have been conducted through Angel Flight. And, as a professional Commercial Pilot with over 1500 flight hours, I am absolutely confident that the proposed changes would NOT have prevented the accidents if they were to have occurred after these proposed legislative changes take place. 

They will not prevent future accidents either.

It is appalling that a National Party leader and Minister for Transport has allowed this policy to affect the rural community that you represent. Sadly, the people of Australia are the losers because of these changes. The families that will lose this vital service because of these changes will not be able to receive treatment, and families will be forced to make more difficult financial and other choices.

As you may know, the AOPA (Aircraft Owners and Pilot’s Association) has been very vocal about this issue and vehamently opposed to the changes. And they have the support of the General Aviation community in Australia. They have the support of the people that you represent. They have the support of the general Australian population, and they have the support of the Rural communities that you ought to be properly representing.

CASA, yet again, has proven itself to be creating further mistrust, and is undermining any remaining confidence in the aviation community and further reducing the ability of the industry to grow and prosper. And Minister, I’m saddened to provide you my honest assessment that you are simply listening to the bureaucrats that are feeding you untruths and recommending policies that are contributing to the decline, rather than making informed decisions about what’s best for Australia.

1. Will you now support AOPA’s call for a turning point (a new era) in General Aviation in Australia and reject the CASA proposed legislative changes? 

2. Will you do the right thing for the people of Australia and reconsider CASA’s proposals and put forward a motion of disallowance in respect of this legislative change? 

3. Will you direct CASA to finally start to stop over-regulating, and instead communicate, collaborate and educate instead?

With the election looming and an Australian population looking to you and your party for leadership, I urge you to take the steps needed to fight for commonsense, and the people that you represent.

Kind regards

Nicholas Christie

 
MTF...P2 

[Peetwo]

Hitch finally mentions Fort Fumble embuggerance of Angel Flight - WTF?

From the supposed fount of all things Oz GA...

CASA to push ahead with Community Service Restrictions
13 February 2019
    
The Civil Aviation Safety Authority (CASA) announced today that it will implement restrictions on pilots that fly for community service organisations such as Angel Flight.

According to the announcement, the new restrictions will make community service flights–defined as those carrying people to non-urgent medical appointments–safer.

“Most community service flights are conducted by a single pilot in a small aircraft, flying long distances from regional and remote towns to the cities, carrying people with serious medical conditions,” CASA CEO Shane Carmody said.

“This puts a lot of responsibility and sometimes considerable pressure on the pilot. Many of these pilots hold only a private pilot licence.
“It is only fair to the patients and carers using community service flights to ensure there are appropriate safety standards that go beyond those required for everyday private flying."

Among the new restrictions to be applied to CSFs are:

• private pilots cannot fly CSFs unless they have 400 hours total time with at least 250 hour in command
  
• multi-engine aircraft cannot be used on CSFs unless the pilot has 25 hours time on type
  
• private pilot's cannot fly CSFs if they hold a CASA Basic Class 2 medical only
  
• VFR pilots cannot fly CSFs unless they have 10 hours on type
  
• IFR pilots cannot fly CSFs unless they have 20 hours time on type
  
• no pilot can fly a CSF unless they have made at least one landing in the type of aircraft in the previous 30 days.
  

CASA has also demanded that pilots on CSFs put in flight plans and mark their logbooks with CSFs.

Submissions to CASA on the new rules were mixed, with several people opposing any restrictions at all.

"The proposed legislation is a serious impost on the ability of community service flights to operate, and none of the new rules have been backed up by evidence suggesting the need for them, nor does CASA follow it’s own or legally required practices in drafting and introducing these rules without proper risk analysis or industry consultation," said wwll-known GA advocate Baz Scheffers.

"To imply that a one-hour flight by a CASA licensed pilot flying a CASA certified aircraft maintained to CASA’s requirements by a CASA licensed engineer is a significantly, if any, greater risk than driving 8 hours each way in a single day on what are Australia’s most dangerous roads, should call into question the entirety of all legislation governing private operations."

Aviator and entreprenuer Simon Hackett thought the new regulations would have no impact on the safety of a CSF flight.

"The regulation would have no material benefit to the operational safety of the flights concerned. The regulation is likely to create a false impression in the community about what would actually be achieved through its implementation.

"A CSF is a private flight (and would remain a private flight). Private flights operate under rules and requirements that are long established, that work well, and that seem reasonably well harmonised with international best practice.

"There is no evidence and no safety case provided that would explain why two very specific instances of two specific precursors (namely how the pilot met the passenger, and why the passenger is traveling), have any causal relationship with increased operational flight risk, as compared to any other private flight conducted for any other purpose involving people who met in any other way."

Conversely, the Australian Federation of Airline Pilots (AFAP) largely supported the proposals, but went on to state that they felt the restrictions didn't go far enough.

"We recognise that there may be resistance to some of these proposed changes but generally believe that they are not in any way draconian or likely to cause undermining of the viability of CSFs or that sick and disadvantaged Australians would then be without essential transport for their medical needs," the AFAP submission said.

"The AFAP generally supports the introduction of some baseline minimum flight crew licensing and experience requirements however we believe this approach, to addressing the shortcomings of a lack of a systems approach to managing the risk, is not entirely suited for meeting the problem which it seeks to address. Lack of Safety Systems

"The real core of the problem isn’t related to the individual minimum limits and conditions for pilots and maintenance procedures (solely). The core of the problem is that there is a total lack of any organisational structure requirements to manage the safety risks as a safety systems problem." P2 - Hmm...and the AFAP's opinion would be considered to be truly independent by whom?  

Angel Flight CEO Majorie Pagani has previously slammed the new proposals, calling into questions CASA's legal ability to control who a qualified PPL can and can't carry in an aircraft based on health and geographic location.

More information on the proposals including the published submissions is on the CASA website.

Read more at http://www.australianflying.com.au/lates...GcuOQ2g.99

Note the way Fort Fumble carefully manipulate the stats to make it appear that industry dissension is from an irrelevant minority...     

C.9 Consultation process

17 (8%) respondents commented on the perception that CASA had failed to follow its
consultation process.

The following are examples of comments from respondents:

Changing regulations without proper regulatory process by the CEO of CASA without
Parliamentary scrutiny thereby curtailing the rights of pilots to exercise the full
privileges of their licenses. (ANON-Z7UJ-QXZT-7)

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The Authority has deliberately bypassed proper processes and in effect, is seeking to
add a new licence category, and a new maintenance category, for private flights and
private/CPL and ATPL pilots. This is occurring without adhering to settled and wellpublished procedures – all of which were designed to ensure proper industry consultation: and all of which CASA has, on many occasions, championed. (ANONZ7UJ-QXE7-N)

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I object to the fact that no proper consultation took place with either the industry and I
see the proposal as an attempt to bypass the NPRM process by seeking to implement
a direction and not amending the relevant regulations AFTER DUE PROCESS. CASA
did in this case not complied with the to the 2015 Statement of Expectations publicised
by the Board of the Civil Aviation Safety Authority, which includes a requirement for
CASA to consider the economic and cost impact on individuals, businesses and the
community in the development and finalisation of new or amended regulatory
changes.(which also includes proposed directives like th e present one) CASA has
also not complied in my view with their obligation to adopt a proper, fair and
transparent process, by publishing proposed Directions immediately upon the rising of
Parliament, with the closing date set prior to the resumption of Parliament. In this case
CASA also failed in my view to adhere to the proper regulatory processes, whereby
long-standing Regulations, which confer fundamental rights on pilots and aircraft
owners (being the rights to exercise the full privileges of their licences and aircraft use)
are sought to be changed by the direction of CASA. This in my view is an attempt not
to make the proposals subjected to Parliamentary scrutiny as would be the case if they
were tabled as proposed Regulations. (ANON-Z7UJ-QXEA-Y)

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Given that CASA has now deemed CSF’s to be a ‘sector’ worthy of specific and unique directions, which impact significantly upon the rights of pilots and owners to fly and operate their machines according to current regulatory requirements, then it is incumbent upon the Authority to heed its own recommendations before publishing a set of directions without industry or ‘sector’ consultation. It is insufficient that it has written the directions without consultation nor proper analytical process, to now stand behind the one month ‘consultation’ feedback process (which has no statutory mandate in terms of changing the directives pursuant to the consultation), or that it may now be embarking on a data analysis or risk analysis subsequent to the issuance of the proposed directions. (ANON-Z7UJ-QXEC-1)

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It is not reasonable for this proposal to be the first action the regulator takes in relation to CSFs, when it hasn’t even bothered measuring the effectiveness of the lessintrusive and less-disruptive alternatives required by Regulatory Philosophy principle 9. (ANON-Z7UJ-QXES-H)

See responses here: https://consultation.casa.gov.au/regulat...descending


MTF...P2 

[Peetwo]

Back to ToRs - 



Also from Horatio Leafblower off the UP: https://www.pprune.org/pacific-general-a...st10390770

 [b]Calling out CASA's Sham "consultation"

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No matter your opinion of AOPA or Angel Flight, you really must agree that the way CASA has treated the General Aviation industry has been nothing if not contemptuous and arrogant.

Congratulations to Ben Morgan who continues to take the fight up to the regulator and the politicians in a way that I can't remember AOPA doing in my 28 years in the industry.

CASA has, at the stroke of a pen, eliminated Charter effective March 2021 and with their un-consulted Community Service Flight regulations all but eliminated Angel Flight as an important VOLUNTEER community service.

If I was a conspiracy theorist I would suggest that the RAAA, Chaired by Regional Express, and the ASAP, Chaired by the pseudo-charity (heavily govt funded thru charter contracts and donations) RFDS, have the blood of the General Aviation Industry on their hands.

...oh and by the way, CASA has also eliminated "Charter" from their definition of "General Aviation"... because a Baron or a C206 or a Chieftain flown on charter is "Air Transport" just like a B747. 

Watch Ben Morgan's latest here:

That brings me to my nominee for POTW...  

Lead Balloon -  CASA behaving like arseholes? Surely not.


As everyone slowly grows up and realises that aviation regulatory standards in Australia have always been set, and will always be set, primarily on the basis of politics rather than any objective criteria, people need to decide, individually, what to do about that.

What struck me particularly about Mr Morgan’s spray was the statement that: “I’ve always voted for...”. I switched off and remain uninterested in whatever party he’s always voted for. The primary reason Australia is where it is on so many fronts - and in particular aviation - is that most people have “always voted for” one the major parties.

The problem is that a vote for any of the major parties is a vote for CASA to do whatever it wants. It’s a vote for the status quo. The major parties don’t care about aviation because it’s been conveniently abrogated to the regulator. 

If you really want to make a difference, don’t send an email to any politician. Send an email to Dick Smith urging him to urge members of the public to vote for anyone but a member of a major party, until specified changes have been made. Population, aviation, gardening or pencil widths - doesn’t matter a shit about the merits of the changes. Just say what you want, Dick.

If Dick does that, things might change. Members of the major parties will agree to do what Dick wants so as to preserve the status quo - on the grounds of safety or whatever facade needs to be put over it - and you’ll all be able to return to the practice of voting for whichever of the dumb or dumber parties to whom you’re passionately dedicated.

Otherwise, resign yourself to pretty much more of the same until around 2021, when you’ll have another opportunity to demonstrate you’ve learned something.

Which finally, in the lead up to the next Federal Election, brings me back to ToRs with this Dick Smith archived post:

Dick Smith Wagga Aviation Oration.

Extracts from the Dick Smith Wagga Oration...

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Good news with Minister Barnaby Joyce
 
 
Former Deputy Prime Minister
Barnaby Joyce
 
In December 2017 there was some good news.
Barnaby Joyce – clearly a Bob Hawke in many ways –
was appointed the Minister. What a difference.
 
I had a breakfast meeting with Mr Joyce and pointed out that the Civil Aviation
Act didn’t mention that cost had to be considered. He instantly said, “That is
ridiculous, you always have to look at cost.”
 
It was a fantastic breakthrough. He asked me, “Dick, if you were a dictator what
would you do to get the industry going again – especially aviation in the bush.”
I said, “The first thing I would do is fix the Act so costs can be considered, and I
believe we can get the Shadow Minister, Anthony Albanese, to agree with this.”
 
 
Shadow Minister
Anthony Albanese
 
Mr Joyce told me to go ahead and have a go so I used an industry expert to
come up with the new, effective wording, which says:
 
“CASA must seek to achieve the highest level of safety in air
navigation that is consistent with:
 
(a) Maintaining an efficient and sustainable Australian aviation
industry, including a viable general aviation and training sector
(b) The need for more people to benefit from civil aviation.”
 
It was just common sense. Who could possibly be against such wording? Legislation that allows cost to be considered is not a unique idea.
 
Let’s look at the equivalent wording in the British Civil Aviation Act. It says:
“...provide air transport services which satisfy... public demand at the lowest
charges consistent with a high standard of safety... and an economic return to
efficient operators... ” British CAA Act (2012)
 
Yes, totally different to our existing “safety as the most important consideration”
lie. Mr Joyce agreed with the changes and got me to discuss them with the
Shadow Minister. Within days, Mr Albanese sent back a couple of adjustments
and supported the change – fantastic.
 
That was all to change. Within two weeks, Barnaby Joyce had resigned, clearly
because he did not live in Bob Hawke times!
 

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Change not supported by new minister, Mr McCormack
 

Deputy Prime Minister
Michael McCormack
 
Now let’s move to the present time. I was fortunate to be able to arrange a meeting with the new Deputy Prime Minister, Mr Michael McCormack. When I asked him if he would support the change of the Act, he was undecided and said,
 
“I would like more information. I think there should be more discussion and more consultation.”
 
Now why wouldn’t he have said to me,
 
“Dick, this is just common sense - of course I will support the change - cost always has to be considered and I have read so much about the destruction of general aviation, particularly in the bush.”
 
It is very likely that Mr McCormack would have liked to have said that, but with his six years as a politician, I think his “actor” training came in. He knew that any changes to the Act that even hinted that costs should be looked at would be considered by some as reducing safety – and be beaten up accordingly in the media.
 
However, I really hope he will support the change in the future.
 
We laughed at the “Yes, Minister” segments, however, let’s think about it.
That “Yes, Minister” show is an example of how our politicians have become
actors not doers. I was shocked each time I was chair of the safety regulator
in Canberra to see how people – once the emotive word “safety” came up –
were not game to apply the common sense that I had experienced in private
enterprise for over 30 years.
 
You can’t blame individual politicians for this. The vast majority are as honest as
any Australians. It is the system we have evolved to and we have to fix it.
 
Even though I have concentrated on a story about aviation, this is also the
explanation of why so many are disillusioned with our democratic systems. No
wonder Mr Trump was elected to drain the dishonest swamp.
 

• Firstly, we need to change the Act as agreed by Mr Joyce and Mr
Albanese – “stop the lie – change the Act – let aviation thrive!” This
should be our motto.
• Secondly, we have to ensure that CASA concentrates on the regulatory
rewrite to remove every unnecessary cost.
• Thirdly, we should harmonise with the simpler and lower cost FAA
regulations which allow a successful, safe, General Aviation industry.
• Number four, we need to get people with talent and industry experience
in as advisers to the Minister and appointed to the CASA board. For the
last 15 years, the person appointed to advise the Minister on aviation has
never been a person with the skills or the experience, or ever stated any
vision on how to grow aviation.
• Five, we need to second experienced experts from the industry to CASA
for one or two years to get the General Aviation industry thriving again.
• And six. We need to convince governments to treat aviation safety in a
bipartisan way – not the point-scoring that goes on today which clearly
damages our country.

The major parties agree on our alliance with the United States. Why? Because
it is of such national interest. What could be more of a “national interest” than
having a safe and viable aviation industry? We need the major parties to jointly
support aviation reform. The agreement between Mr Joyce and Mr Albanese is
an example of what can be achieved.
 

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Mr McCormack has huge opportunity
 
Tens of millions of dollars of additional export income
 
In closing - the Deputy Prime Minister, Mr Michael McCormack, has a huge opportunity to support these common sense changes to get aviation, especially aviation in the bush, thriving again.
 
We could become the world leaders in flight training and recreational aviation – tens of millions of dollars of additional export income could be earned – promoting massive investment in both infrastructure and services in our country towns and regional centres.
 
The problems I have mentioned do not affect me personally, I’m fortunate. I can afford the high costs. It’s others and my country I am concerned about.
 
Call for action
 
This is my call to action. I ask you to contact the Minister, your Local Member, the media – everyone – and ask for the “Dick Smith Wagga Proposals” to go ahead. They will be on my website. Sir Henry Parkes gave the Tenterfield Oration in 1889, which was a trigger for our Federation. Well, this is the “Dick Smith Wagga Oration” which I am hoping will trigger the revitalisation of General Aviation in Australia.
 
Aviation call for action
 
https://www.dicksmithfairgo.com.au

Oh and if Albo, McDo'Naught, Carmody Capers & co. think we're going to stop banging on about the DFO abberration...

Dear DPM McDo'Naught

RE: CASA 30+ year embuggerance of the aviation industry.

Following on the discussion from the UP, Bill Pike shared his correspondence to the NFI DPM...  

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Angel Flight

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I sent a submission to McCormack and asked that he forward it to CASA. CASA did not publish it as they said that I had not requested publication. 

Mr M McCormack
Deputy Prime Minister, Leader of the national Party

Attempts by CASA to introduce more complications in the operations of Angel Flight

Dear Mr McCormack,

For many many years CASA has in theory been answerable to a National Party Minister but in fact has run its own race over that time. I accused John Anderson of allowing CASA to run amok, uncontrolled, when I was President of AOPA. You are, unfortunately, so far keeping up the tradition.

The Civil Aviation Safety Authority has been rewriting the safety regulations for over twenty five years with miserable progress. There are simple reasons for this. CASA likes the difficult regulations that we have. By proposing ridiculous regulations they can sit back getting paid while the industry beats itself to death opposing them.

There are/always were two ways of stopping this nonsense. The most obvious would have been to use the US FAR's. A large aviation country with a strong aviation industry probably already has invented the wheel. These regulations are not sufficiently proscriptive for our CASA. Twenty years ago the CASA CEO Mick Toller claimed that the US regs were about to be rewritten so shouldn't be copied. Hasn't happened yet.

The other way is to use an independent panel to write the regs, not CASA. One does not allow the police to write the laws of the country, does one? All industry representatives serve on various panels and Boards in their own time, and have been beggared and exhausted doing so. I suggest that all CASA representatives also volunteer to serve on these boards and panels in their own time. Then we would see some progress

I note Shane Carmody has trotted out the old homily that CASA is the police and nobody likes police. Mick Toller used that one too. That is just not so. It would take a book to do it but the contrary evidence is everywhere. Ask Dick Smith for example

Space precludes a comprehensive list of CASA's shortcomings but here are two typical examples.

1. After consultation CASA introduced, many years ago the Biennial Flight Review (BFR). It was all training, it could not be failed, so who could be against that? Subsequently, CASA, without notice or consultation, changed the name (to is it AFR?) and now it can be failed. Completely dishonest. 

2. Also without consultation , CASA stopped engineers flying out to a property to do required maintenance . Such maintenance now has to be done in an approved workshop, at greatly increased costs to the aircraft owners. This was at the behest of the big maintenance shops without any evidence that the fly in guys were not getting the result. No consultation whatsoever. In the States of course no such regulation exists .

My point is that CASA is, in this case, as ever, looking for more control and complexity even when such control is not justified. It has always annoyed the pedants in CASA that organisations like Angel Flight, (which has in fact an amazingly good safety record), are not under CASA's direct control. I well recall, many many years ago an aviation nonentity called Keith Campbell at a public meeting attended by Sir Donald Anderson, was told by Sir Donald that "my officers are only interested in safety . " Keith responded. "Your officers Sir are only interested in their career paths and their superannuation." There was much agreement from those attending. Uproarious acclamation in fact. Little has changed.

The latest attempt to exercise more direct control over Angel Flight and to add complexity to their operations, with no proven safety benefit, is being done in typical CASA underhanded fashion. Not a by a Regulation, which could be "disallowed" and debated in parliament but as I understand , as a "Direction", which does not have Parliamentary oversight. This was put up for comment over the Christmas period with, initially a two week (later extended to four weeks) comment period. How brazen is that!.

I can only quote my good friend Bill Hamilton who said to CASA representatives so many times when we both served on the old "Program Advisory Panel"

"This Regulation is required because of what known problem?"

I ask the same question of you

Yours Faithfully


FW Pike 
122 Howells Rd
Abernethy NSW 2325


CC Shane Carmody
CEO CASA

---

And some of the comments in response so far :

Blueyonda - Put up their response letter Bill. Let’s see the template letter.

---

aroa - Carbody , the Arrogant, if he replies will just spruik the usual motherhood bs we have all become so accustomed to.

And I would posit, it will probably be written by Dr Discrepancy, so expect convoluted legal acrobatic thinking to justify the unjustifiable..

Campbell's comments from way back still apply. What a fabulous gravy train is CAsA !

The stench from (Non) Aviation House gets worse by the day.

Vale GA !

---

Lead Balloon - Bill, it looks like it’s been done by legislative instrument that is, therefore, disallowable by the Parliament. However, the timing of the making of the instrument is such that it can do maximum damage for a long period of time because of the small number of sitting days of the Parliament before the election and the distraction to other matters during those days. It could be many months before 15 sitting days pass, and the likelihood of a motion of disallowing being moved and heard and voted on in the few sitting days before the election is quite remote.


Doesn’t alter the fact that the consultation was a sham and the justification for the change is a nonsense, though.

 
MTF...P2 

[Peetwo]

Latest on CASA embuggerance of Angel Flight - 

From Ben Morgan, via AOPA Oz on YouTube:

I note that today the Rebekha Sharkie 'disallowance motion' notice was tabled in the House of Reps...  

Ref: https://parlinfo.aph.gov.au/parlInfo/sea...%2F0000%22
 

Notice given for Tuesday, 19 February 2019

      *1    MS SHARKIE : To move—That the Civil Aviation (Community Service Flights—Conditions on Flight Crew Licences) Instrument 2019, made under regulation 11.068 of the Civil Aviation Safety Regulations 1998 on 12 February 2019 and presented to the House on 14 February 2019, be disallowed.
              ( Notice given 18 February 2019. Instrument will be taken to have been disallowed unless disposed of within 15 sittings days, including today. )

Finally CASA are to appear at a spillover hearing on Friday:

---

IMO one of the best bit of news for Friday's spillover hearing with CASA is that apparently Barry Obfuscation will be otherwise engaged...

MTF...P2 

[Peetwo]

Miniscule McDo'Naught WOFTAM amendment to the Civil Aviation Act -   

Senate thread reference:

A hopeful Hansard -  

Addendum to last:  Answer to QON addressed to Norton White at 15/02/19 Senate Spring Hill public hearing (see: https://www.aph.gov.au/DocumentStore.ash...d54d50078a )

Judicial decisions requiring urgent legislative attention

In this paper we outline:

• two judicial decisions that have, in the opinion of the aviation industry, had significant and
unintended consequences on air operators and require urgent legislative attention; and
• our recommendation as to how the Commonwealth Government can remedy the issues
created by these decisions.

1. Work Health Authority v Outback Ballooning Pty Ltd [2019] HCA 2

---

This case concerned the prosecution of Outback Ballooning, a hot air balloon operator based in Alice
Springs, under sections 19 and 32 of the Work Health and Safety (National Uniform Legislation) Act (NT)
(the NT WHS Act).

A passenger was unfortunately killed when her scarf was caught in an inflation fan as she was boarding
the balloon. The NT Work Health Authority alleged that Outback Ballooning breached its duty of care
under the NT WHS Act through its failure to eliminate or minimise risks to embarking passengers.
The question before the High Court was whether or not the NT WHS Act was inconsistent with the
Commonwealth Civil Aviation Act 1988 (which imposes its own very specific regulatory regime
conformably with the Chicago Convention for the safety of air navigation) and therefore inapplicable.

The Court, by majority, found that sections 19 and 32 of the NT WHS Act are not inconsistent with the
Commonwealth civil aviation regime. The effect of this decision is that aircraft operators and airlines
are now subject to both:

• Commonwealth laws in relation to aviation safety; and
• State and Territory laws (including occupational health and safety laws).

Aviation safety worldwide depends on uniformity. This is recognised by the Chicago Convention,
which sets out international standards and practices for the safety of civil aviation. Australia is a
signatory to the Chicago Convention. The importance of international uniformity in safety standards
for civil aviation is recognised in the Commonwealth Civil Aviation Act, which by section 11 requires
that CASA perform its functions in a manner consistent with the Chicago Convention. The High Court
majority decision undermines Australia’s obligations pursuant to the Chicago Convention and also
uniformity of safety standards. State and Territory Workplace Safety Regulators, unlike CASA, are not
obliged by legislation to act in a manner consistent with the Chicago Convention.

The risk of subjecting air operators to a multitude of non-uniform laws was addressed by Justice
Edelman in dissent:

“…it would be surprising, confusing, and potentially dangerous if the Civil Aviation Law were
to have the effect that the rules of the air on a flight from Darwin to Melbourne, via Sydney,
could be regulated not merely by the comprehensive and uniform rules policed by the
Commonwealth Civil Aviation Safety Authority ("CASA"), but also, depending upon the
airspace, by separate and different rules policed by the Work Health Authority and its
inspectors in the Northern Territory, or regulators in New South Wales and Victoria.”

Justice Edelman argued that an exclusive civil aviation regime is necessary to achieve a uniform
national safety regime and rules of the air.

The decision is also likely to add to costs for air operators who will be required to comply with up to 9
sets of safety laws (that may not be consistent) and deal with safety regulators in each State and
Territory in addition to CASA. The maximum penalty for a corporation for a breach of workplace health
and safety legislation can be up to $1.8 million in Western Australia and $1.5 million in other States
and Territories.

Recommendation: As this is a decision of the High Court, it can only be rectified if the
Commonwealth Parliament amends the Civil Aviation Act 1988 (Cth) to include an express statement
of legislative intention that the Civil Aviation Act and its Regulations are intended to cover the field in
respect of the safety of civil aviation.

2. Civil Aviation Safety Authority v Caper Pty Ltd (2012) 207 FCR 357

---

In Civil Aviation Safety Authority v Caper Pty Ltd, CASA cancelled Caper’s AOC on the basis that Caper
was providing regular passenger transport (RPT) when its AOC only permitted charter and aerial work
operations. Caper appealed to the Federal Court.

The case turned on the classification of air operations as either charter or RPT under regulation 206 of
the Civil Aviation Regulations 1988 (the Regulations):

• Charter operations are defined in regulation 206(b) as:

(i) the carriage of passengers or cargo for hire or reward to or from any place, other than
carriage in accordance with fixed schedules to and from fixed terminals;
(ii) the carriage, in accordance with fixed schedules to and from fixed terminals, of
passengers or cargo or passengers and cargo in circumstances in which the
accommodation in the aircraft is not available for use by persons generally.

• RPT operations are defined in regulation 206© as: transporting persons generally, or
transporting cargo for persons generally, for hire or reward in accordance with fixed schedules
to and from fixed terminals over specific routes with or without intermediate stopping places
between terminals.

Caper’s AOC authorised charter flights between Darwin and Bathurst Island. Caper had an
arrangement with a tourist operator (AAT Kings) who chartered Caper’s aircraft for AAT’s tours from
Darwin to Bathurst Island. Only people on the AAT tour were permitted to travel on the aircraft. The
flights operated to fixed schedules between fixed terminals and persons seeking transport on the
flights were referred by Caper to AAT. CASA cancelled Caper’s authorisation to conduct the flights on
the ground that the flights were, in reality, RPT flights and not charter flights.

The Federal Court looked at the concept of ‘closed charters’ in Regulation 206(b)(ii) and found that
the words ‘persons generally’ referred to the general public, so the test for a closed charter was
whether or not travel on the flight was offered to the public at large. In other words - if the flight was
available to the general public then it was an RPT operation.

The Court found that the Caper air operation was available to the general public because the
advertised offer of the flight, albeit bundled with the tour, was made to any member of the public who
wished to join the tour.

This decision had significant ramifications for the use of charter flights to access remote locations for
tourism flights as well as essential services such as regular medical appointments. It created confusion
over the classification of operations which had long been operated safely as charter flights. The fact
that these operations now required RPT authorisation meant that many could not meet the stringent
regulations governing RPT operations and had to withdraw flight services.

The distinction between charter and RPT operations will be removed from the Civil Aviation Safety
Regulations 1998 when the new Part 119 (which deals with the issuing of Air Operator’s Certificates
to Australian operators) and the suite of regulations that set the minimum acceptable standards for
large aeroplanes (Part 121) and small aeroplanes (Part 135) come into effect into effect in 2021. These
regulations include a new classification of operations as Air Transport Operations, dispensing with the
distinction between charter and RPT and creating a single standard for carriage of passengers and
cargo for hire or reward.

CASA has stated that the new regulations are intended to provide graduated requirements
proportionate to the risk.

Recommendation: It is critical that CASA consults and works closely with industry on the
development of the Manual of Standards for the new classification to:

• ensure appropriate levels of regulation apply to each type of flight operation; and
• avoid adverse impacts on air access to remote communities.

In light of the above Norton White recommendations it is a 'passing strange' coincidence that today our absolutely useless, NFI, non-identity miniscule McDo'Naught has seemingly rushed through a total wet lettuce amendment to the Act...  

 

5CIVIL AVIATION AMENDMENT BILL 2019

Mr McCormack (Deputy Prime Minister and Minister for Infrastructure, Transport and Regional Development), pursuant to notice, presented a Bill for an Act to amend the law relating to civil aviation, and for related purposes.

Document

Mr McCormack presented an explanatory memorandum to the bill.

Bill read a first time.


- 10:57:49 AM
Mr McCormack moved—That the bill be now read a second time.


- 11:00:36 AM
Debate adjourned (Ms O’Neil), and the resumption of the debate made an order of the day for the next sitting.

  

Reference link: https://parlinfo.aph.gov.au/parlInfo/sea...t:billhome

Overview of the Bill

The main object of the Civil Aviation Act 1988 is to establish a regulatory framework for
maintaining, enhancing and promoting the safety of civil aviation, with particular emphasis on
preventing aviation accidents and incidents.

Section 9A(1) of the Act instructs that in, exercising its powers and performing its functions,
the Civil Aviation Safety Authority (CASA) must regard the safety of air navigation as the
most important consideration. This bill does not affect the primacy of safety.

The Bill incorporates existing regulatory practice and certain guiding principles from
Australian Government’s Statement of Expectation issued to the CASA Board on 21 March
2017 into legislation. Subject to section 9A(1), the Bill proposes that in developing and
promulgating aviation safety standards, CASA must consider the economic and cost impact
on individuals, businesses and the community of such standards; and take into account the
differing risks associated with different industry sectors.

The Bill does not create any requirements on individuals or organisations.

Hmm...while he has the Act out on the table, perhaps the miniscule should be seriously considering the first Norton White recommendation (from above)?  

Recommendation: As this is a decision of the High Court, it can only be rectified if the
Commonwealth Parliament amends the Civil Aviation Act 1988 (Cth) to include an express statement
of legislative intention that the Civil Aviation Act and its Regulations are intended to cover the field in
respect of the safety of civil aviation.

- Just saying...P2  

[Peetwo]

CASA embuggerance of Angel Flight update - 21/02/19.

Katter & Wilkie sign motion to disallow CSF instrument on next HoR sitting date...

Via AOPA Oz FB page: https://www.facebook.com/AOPAaustralia/p...6361605284

KATTER'S AUSTRALIA PARTY ANNOUNCES MOTION OF DISALLOWANCE

Federal Member for Kennedy, The Hon Bob Katter MP, has today signed a Motion of Disallowance, seconded by Member for Denison, Independent the Hon Andrew Wilke MP, calling for CASA's 09/19 Community Service Flight legislation to be disallowed.

Katter's Australia Party now joins Centre Alliance and a growing list of concerned MP's and Senators who view the CASA 09/19 Community Service Flight legislation put forward by the Liberal/Nationals as both unnecessary and an abuse of aviation community/industry rights.

AOPA Australia will continue working hard behind the scenes to build a strong coalition of political support. If you're an aircraft owner or pilot, recreational or general aviation, now is the time to pledge your support - stand with us we fight for your rights. Join today: www.aopa.com.au/membership

On behalf of the entire AOPA Australia membership, we thank Katter's Australia Party for their support.

MTF...P2  

[Sandy Reith]

We all should urge our local MPs, including State Senators, to follow suit and throw out CASA’s ill considered and counterproductive attack on Angel Flight.

[Kharon]

Time, gentlemen, please.

Sandy – “We all should urge our local MPs, including State Senators, to follow suit and throw out CASA’s ill considered and counterproductive attack on Angel Flight.”


"Now is the time for all good men to come to the aid of the party"

Well said that man; but I would like to see the whole disaster taken it a step or two further, by not only industry but the voting, tax paying public – for it is IMO they who are in the high risk category. The Angel Flight rule changes typify the incredible mess our ‘rules’ and regulations have developed into, during this period of no tangible Ministerial responsibility.

We have an ASA which is rapidly descending into a serious quagmire of confused, petty minded, non operational irrelevancies

We have an ATSB which seems more and more like a public relations group and general embarrassment clean up squad than an independent, fearless analysing body responsible for clearly defined reporting of the ‘why and wherefore’ of an accident and producing recommendations to prevent reoccurrence.

We have a CASA which operationally is almost catatonic. So remote from the realities of air operations and the effect of half baked regulation as to be unrecoverable.

The rest of the world’s aviation sectors – across all disciplines are moving ahead; thriving in some cases. Why is Australia not any longer a leading nation in this field? We are not considered ‘funny’ any longer, most overseas pilots and operators now only shake their heads in disbelief of the antics of Australian aviation oversight bodies; in fact, many of my American friends almost disbelieve the stories until they are confronted with published facts related to ASA, ATSB and the CASA. Then they just shake their heads, say 'Sorry to hear that'.

Angel Flight is but the tip of a large, ugly iceberg; it is time for the government and opposition to weigh in and put the brakes on; before the little that remains descends below third world level.

Selah.

[Peetwo]

Time, gentlemen, please.

Sandy – “We all should urge our local MPs, including State Senators, to follow suit and throw out CASA’s ill considered and counterproductive attack on Angel Flight.”


"Now is the time for all good men to come to the aid of the party"

Well said that man; but I would like to see the whole disaster taken it a step or two further, by not only industry but the voting, tax paying public – for it is IMO they who are in the high risk category. The Angel Flight rule changes typify the incredible mess our ‘rules’ and regulations have developed into, during this period of no tangible Ministerial responsibility.

We have an ASA which is rapidly descending into a serious quagmire of confused, petty minded, non operational irrelevancies

We have an ATSB which seems more and more like a public relations group and general embarrassment clean up squad than an independent, fearless analysing body responsible for clearly defined reporting of the ‘why and wherefore’ of an accident and producing recommendations to prevent reoccurrence.

We have a CASA which operationally is almost catatonic. So remote from the realities of air operations and the effect of half baked regulation as to be unrecoverable.

The rest of the world’s aviation sectors – across all disciplines are moving ahead; thriving in some cases. Why is Australia not any longer a leading nation in this field? We are not considered ‘funny’ any longer, most overseas pilots and operators now only shake their heads in disbelief of the antics of Australian aviation oversight bodies; in fact, many of my American friends almost disbelieve the stories until they are confronted with published facts related to ASA, ATSB and the CASA. Then they just shake their heads, say 'Sorry to hear that'.

Angel Flight is but the tip of a large, ugly iceberg; it is time for the government and opposition to weigh in and put the brakes on; before the little that remains descends below third world level.

Selah.

P2 addition...

LB off the UP...

At estimates on 22 February Mr Carmody said:


"..Our view is that community service flights have an accident/incident rate significantly higher than in private operations..."

Community service flights are private operations.

The circular nonsense that CASA trouts out to justify its decisions messes with my head. It’s beyond Orwellian.

Does CASA really believe that the number of accidents in community services flights in Australia can reasonably be considered statistically significant? Really? Have they spoken to an expert in statistics or an actuary? Ever?

In 100% of cases involving fatalities in community service flights in Australia, the pilot in command was male. It inexorably follows that the regulatory standards for male pilots must be increased and more stringently enforced compared with those for non-male pilots. The statistics speak for themselves.

I don’t know why CASA just doesn’t tell the truth: This is a knee jerk reaction as a consequence of pressure from one quarter, which reaction will be disallowed as a consequences of pressure from another quarter.

This is what happens when you make the police the makers of the road rules and the speed limit.

---

Plus from another learned Gent..


...I watched Senate Estimates yesterday.  I look forward to seeing Carmody's 'evidence' used to back his New Community Flight policy.  His admission about weakness with stats is very serious as you need to understand statistics in order to make good policy...

P2 comment - I really don't want to add much more to LB & LG's OBS of the Estimates hearing yesterday, except to say Carmody Capers was his dicktatorial best and it was quite obvious from the body language of him and Dr A, that they know that there will be no negative consequences coming from their totally CAPTURED miniscule and therefore Government...


MTF...P2 

[Kharon]

"This is a court of law, young man, not a court of justice." ~Oliver Wendell Holmes, Jr.

“In Civil Aviation Safety Authority v Caper Pty Ltd, CASA cancelled Caper’s AOC on the basis that Caper was providing regular passenger transport (RPT) when its AOC only permitted charter and aerial work operations. Caper appealed to the Federal Court.”

“The Court found that the Caper air operation was available to the general public because the advertised offer of the flight, albeit bundled with the tour, was made to any member of the public who wished to join the tour.”

So, Bushtours Inc. ring up one morning wanting to book an aircraft to on carry folks from the bus to an island and return them to the bus. Simple, easy charter – fixed terminals, sure, where else? Fixed time, sure, how else? No problem so far. That one goes off well, everyone’s happy. “Can we do it again next weekend” asks Bushtours; sure we can says the Charter operator, delighted. Bushtours advertise the tour, enter the dragon.

This endless legal wrangle created by Reg. 206 has caused more indigestion and headaches than booze and bad Prawns. In a lawyers hands, in court, black letter law will always trump the notion of ‘justice’. Was Caper operating illegally? The court thought so, fair enough; that’s the law and the ‘rules’ were technically broken. Whether those rules are worth a pinch of chicken pooh or not is not within the narrow scope of the prosecution; not the business of the court: end of………

But it is the end of an Operator, jobs and tourism income. To what end has CASA served the industry, the public or the local community? Closing Caper down has achieved little, arguably they breached a fuzzy, poorly defined, complex part of the law. To me, it seems that unless Caper were advertising and selling individual seats to ‘walk-ins’  - not part of a booked charter then the CASA argument was on the skinny side. Howerver:-

“This decision had significant ramifications for the use of charter flights to access remote locations for tourism flights as well as essential services such as regular medical appointments. It created confusion over the classification of operations which had long been operated safely as charter flights. The fact that these operations now required RPT authorisation meant that many could not meet the stringent regulations governing RPT operations and had to withdraw flight services.”

I wonder why they were not fined, given a stern warning, offered assistance to avoid a repeat and helped to gear up for the ‘new’ rules due in a year or two? Did the punishment fit the crime?  

“The distinction between charter and RPT operations will be removed from the Civil Aviation Safety Regulations 1998 when the new Part 119 (which deals with the issuing of Air Operator’s Certificates to Australian operators) and the suite of regulations that set the minimum acceptable standards for large aeroplanes (Part 121) and small aeroplanes (Part 135) come into effect into effect in 2021.”

‘The law’ as writ may have been satisfied, CASA get to chalk up another notch on their score board; but what have they achieved – in reality – against the overall, total costs?

It is about time CASA stopped ‘prosecuting’ and got on with the business of drafting and publishing a clearly defined set of rules; no one wants to loose a business due to a CASA created, technical breach of an antiquated, now irrelevant rule, designed to protect fledgling airline operations, back in the days of a two airline policy. They’ve had the best part of 30 years and half a billion dollars to sort this one out. Disgraceful minister; shameful and a waste. Good look to go into an election with, ain’t it. Chump.

Toot – toot.

[thorn bird]

The Paradox K is if CAsA is only required to consider Safety.

Why do they allow any aircraft to fly in this country?

If CAsA is only required to be the Safest.

Are they not an abject failure in this regard, Australia is definitely not the safest?

Just exactly what is CASA?? Tinker? Tailor? soldier? Spy?

[Kharon]

If not; why not?

I have just sat through, paying attention, to the CASA Friday special video in the Senate. I have – so help me. I even watched and listened carefully to St. Carmody; by Gad he’s good.  

Mark you, when the minister is carefully managed, spoon fed and watered by St. Carmody’s very own personal aviation specialist, on loan to whichever pathetic specimen of human kind wears the Emperor’s new clothes; an overwhelming sense of confidence must be expected. Hell, with that sort of entrée and backing; you could sell the hanger cat to the public as the next ducking Messiah. So long as the minister is ‘in the loop’ and as dumb as a hammer – you are on a winner. Why would St. Carmody (the self righteous) even break wind, let alone tremble when a couple of stray Senators start asking easy, uniformed questions?

One of the more alarming elements of the whole thing is that St Carmody (ordained preventer of accidents) has either a very slick understanding of ‘statistics’ or has someone on tap who can not only make statistics jump through hoops; but is capable of making those hoops. Remarkable results – to order.  For instance hours:-

Let us examine this ‘safety’ myth that total hours can, in any practical way, relate to the safety of not only CSF operations, but ‘private’ operations in general. I have a good mate who has many thousands of hours in command of a fairly hefty jet transport – which routinely does long haul international flights; top of his game, all flight checks passed and he is bloody good at commanding the aircraft. Would I trust him to fly my family in a single piston engine, propeller driven aircraft, at night to a strange port? No I bloody well would not. Why? Well, he ain’t current for a start and not in the groove for seconds, nor does he have the toys, horsepower and systems support he has learned to rely on in his normal daily work. There is however a young lady of my acquaintance who does very little else except nurse an aging single engine aircraft about the country side, often after sunset, with very limited basic equipment and very few options in so far as power, redundancy or systems backup; yet I would, without a second thought allow my nearest and dearest to travel with her. Why?

One pilot is in current practice with the operational environment the other is not. The young lass could, perhaps get the jet started but that would be the end of it – my mate could probably get the aging beast started; and, relying solely on past experience even manage to fly a circuit or two. But, in an equal race – neither could do the others job. They are simply worlds apart. My mate has not been near an aging single engine aircraft for 30 years; our young lady has never flown a heavy transport. QED?

Yes, an extreme case study – but since when did ‘hours’ signify safety? Angel Flight could (IMO) resolve this silliness quite easily. A pilot data base which would qualify or disqualify a NVFR/IFR or VFR operation on the basis of current in-practice minimums, in compliance with the Regs. A training course which certified that AF pilots have undertaken a course entailing ‘CFIT’/ Weather avoidance analysis, flight planning, fuel management and ‘risk mitigation’ etc. Even had a ride along with a qualified person to ensure that ‘standards’ were met across the operational board. Simple enough to arrange and do. This would provide ‘evidence’ of competency, recent experience and disqualify those who were not ‘currently qualified’ from conducting AF operations until they were. Small expense incurred – occasionally – to provide a venue; lots of experienced folk willing to assist – on a voluntary basis.

No wonder Sen. Patrick say’s “I can’t quite see it” when referring to this cockeyed CASA notion of how ‘safety and statistics’ support their claim that the ‘Little Wings’ version is OK and AF is a setting up an increased level of danger to those who travel. Bollocks.

Even more remote from reality is the CASA take on ‘engine hours’ and aircraft maintenance. Ask any commercial pilot about ‘fit’ aircraft. When do most ‘mechanical’ problems appear – after maintenance. Which aircraft operate and fly the best? Those which ‘fly’ often is the answer. Which is the mechanically and systems malfunction worst aircraft they ever flew – the one which has been in the shed for a twelve month is the answer.

CASA and in particular St. Carmody continue to display their complete disassociation from the realties of working aircraft, pilot fitness for the scheduled operation and sound operational practices.

St. Carmody and his acolytes may be familiar with ‘theory’ but the view from the Ivory tower is limited; the answers are down in the grass roots and basic tenets; not in some academically dreamed up notion of a legally arguable ‘safety’ case. Practical reality; not a sound legal defence against litigation. But Hells Bells, they can’t even get the legal/medico stuff right – as the USA attorney’s are about to point out. The Mt Hotham incident should be the can opener; the Essendon DFO the worms inside that can. Will CASA get a spanking for operational ineptitude? I hope so; for it is well deserved and long overdue. It I were ‘the minister’ I’d be worried more about that and the fall out afterwards than supporting some half arsed waffle stating that sick folk getting a ride to treatment are at more risk than the same folk going shopping – in the DFO – having been given a cost shared ride into town. Pure, unadulterated, political arse covering BOLLOCKS.

Will anything ever change? Yes is the resounding answer – the revised Act, as presented, has, in legal terms imposed a more onerous, retrogressive set of requirements than the one to be replaced. Don’t believe me though – just read it, very carefully – then watch Hansard video 1 and see the smug, satisfied smirk on the wizened face of Jonathon (where’s my marbles) Aleck when it is mentioned. But please, do read the amendment to the Act – ask a legal friend to explain it – and pray to your gods of choice that amendment gets thrown out, into the garbage, where it belongs. A bonus would be the scrawny arse of Aleck following it.

But enough – I’ve only just seen the ‘vision splendid’ once; however, I can assure you, I will watch it all again  MTF? Damn straight there is……..

Toot- Toot.

[Gobbledock]

I don’t know who Carmody looks most like - Chucky the doll out of Child’s Play or a Feret?

[Peetwo]

If not; why not?

I have just sat through, paying attention, to the CASA Friday special video in the Senate. I have – so help me. I even watched and listened carefully to St. Carmody; by Gad he’s good.  

Mark you, when the minister is carefully managed, spoon fed and watered by St. Carmody’s very own personal aviation specialist, on loan to whichever pathetic specimen of human kind wears the Emperor’s new clothes; an overwhelming sense of confidence must be expected. Hell, with that sort of entrée and backing; you could sell the hanger cat to the public as the next ducking Messiah. So long as the minister is ‘in the loop’ and as dumb as a hammer – you are on a winner. Why would St. Carmody (the self righteous) even break wind, let alone tremble when a couple of stray Senators start asking easy, uniformed questions?

One of the more alarming elements of the whole thing is that St Carmody (ordained preventer of accidents) has either a very slick understanding of ‘statistics’ or has someone on tap who can not only make statistics jump through hoops; but is capable of making those hoops. Remarkable results – to order.  For instance hours:-

Let us examine this ‘safety’ myth that total hours can, in any practical way, relate to the safety of not only CSF operations, but ‘private’ operations in general. I have a good mate who has many thousands of hours in command of a fairly hefty jet transport – which routinely does long haul international flights; top of his game, all flight checks passed and he is bloody good at commanding the aircraft. Would I trust him to fly my family in a single piston engine, propeller driven aircraft, at night to a strange port? No I bloody well would not. Why? Well, he ain’t current for a start and not in the groove for seconds, nor does he have the toys, horsepower and systems support he has learned to rely on in his normal daily work. There is however a young lady of my acquaintance who does very little else except nurse an aging single engine aircraft about the country side, often after sunset, with very limited basic equipment and very few options in so far as power, redundancy or systems backup; yet I would, without a second thought allow my nearest and dearest to travel with her. Why?

One pilot is in current practice with the operational environment the other is not. The young lass could, perhaps get the jet started but that would be the end of it – my mate could probably get the aging beast started; and, relying solely on past experience even manage to fly a circuit or two. But, in an equal race – neither could do the others job. They are simply worlds apart. My mate has not been near an aging single engine aircraft for 30 years; our young lady has never flown a heavy transport. QED?

Yes, an extreme case study – but since when did ‘hours’ signify safety? Angel Flight could (IMO) resolve this silliness quite easily. A pilot data base which would qualify or disqualify a NVFR/IFR or VFR operation on the basis of current in-practice minimums, in compliance with the Regs. A training course which certified that AF pilots have undertaken a course entailing ‘CFIT’/ Weather avoidance analysis, flight planning, fuel management and ‘risk mitigation’ etc. Even had a ride along with a qualified person to ensure that ‘standards’ were met across the operational board. Simple enough to arrange and do. This would provide ‘evidence’ of competency, recent experience and disqualify those who were not ‘currently qualified’ from conducting AF operations until they were. Small expense incurred – occasionally – to provide a venue; lots of experienced folk willing to assist – on a voluntary basis.

No wonder Sen. Patrick say’s “I can’t quite see it” when referring to this cockeyed CASA notion of how ‘safety and statistics’ support their claim that the ‘Little Wings’ version is OK and AF is a setting up an increased level of danger to those who travel. Bollocks.

Even more remote from reality is the CASA take on ‘engine hours’ and aircraft maintenance. Ask any commercial pilot about ‘fit’ aircraft. When do most ‘mechanical’ problems appear – after maintenance. Which aircraft operate and fly the best? Those which ‘fly’ often is the answer. Which is the mechanically and systems malfunction worst aircraft they ever flew – the one which has been in the shed for a twelve month is the answer.

CASA and in particular St. Carmody continue to display their complete disassociation from the realties of working aircraft, pilot fitness for the scheduled operation and sound operational practices.

St. Carmody and his acolytes may be familiar with ‘theory’ but the view from the Ivory tower is limited; the answers are down in the grass roots and basic tenets; not in some academically dreamed up notion of a legally arguable ‘safety’ case. Practical reality; not a sound legal defence against litigation. But Hells Bells, they can’t even get the legal/medico stuff right – as the USA attorney’s are about to point out. The Mt Hotham incident should be the can opener; the Essendon DFO the worms inside that can. Will CASA get a spanking for operational ineptitude? I hope so; for it is well deserved and long overdue. It I were ‘the minister’ I’d be worried more about that and the fall out afterwards than supporting some half arsed waffle stating that sick folk getting a ride to treatment are at more risk than the same folk going shopping – in the DFO – having been given a cost shared ride into town. Pure, unadulterated, political arse covering BOLLOCKS.

Will anything ever change? Yes is the resounding answer – the revised Act, as presented, has, in legal terms imposed a more onerous, retrogressive set of requirements than the one to be replaced. Don’t believe me though – just read it, very carefully – then watch Hansard video 1 and see the smug, satisfied smirk on the wizened face of Jonathon (where’s my marbles) Aleck when it is mentioned. But please, do read the amendment to the Act – ask a legal friend to explain it – and pray to your gods of choice that amendment gets thrown out, into the garbage, where it belongs. A bonus would be the scrawny arse of Aleck following it.

But enough – I’ve only just seen the ‘vision splendid’ once; however, I can assure you, I will watch it all again  MTF? Damn straight there is……..

Toot- Toot.

The Dictatorial, deluded world of Carmody Capers - 
Still waiting on the Hansard but after a technical glitch (now rectified by the good crew at ParlAV -   ) I have now completed the Fort Fumble Estimates video segments in five parts.

My first takeaway from watching the recordings is that the total and utter rubbish emanating from both Carmody Capers and Dr Hoodoo Voodoo Aleck is so full of weasel word rhetoric and disconnected, illogical spin'n'bollocks as to be a perfect script for a comeback series of 'Yes Minister' -  

Listening to an obviously much more relaxed Wingnut I kept of thinking of how many times the un-elected career bureaucrat kept saying it was his decision, my decision...I..I..I..etc..etc..(cough..vomit.. ), till in the end the DASictorial Carmody utters the words that we now all come to expect from these power freak aviation safety Mandarins...        

See from 11:20 here: https://youtu.be/6K9s8wIA9cQ

Now why does that sound oh so familiar  - FFWD to 01:38 : 

Now let's spot the disconnect between the autocratic, 'law unto itself',  make work, trough gouging world of the CASA Iron Ring and the reality of trying to make money from a regulatory embuggered industry....  

Ref:

A hopeful Hansard -  

Audio link: https://auntypru.com/wp-content/uploads/...1145-1.mp3

CHAIR: All right. Let's make it easy. Before we go to that, I just want to throw a quick one at you, Mr McMillan and Mr Schofield. We have had a lot of conversation around the alleged pilot shortage, to which we commissioned some work to be done through the Parliamentary Library to inform the committee of what's going on. The information came back saying, 'No, there's no pilot shortage,' but with subsequent conversations with the airline industry, the evidence is absolutely at the other end.

Senator O'SULLIVAN: The result was that the take-up of traditional advertising for vacancies for pilots hadn't changed They didn't pick up any trend in that: 'Last year there were 10 ads and this year there are 20.' There were 10 ads last year and there were 10 ads this year. I think what challenged us was whether that was the only pathway for recruitment.

Mr McMillan : The truth is always somewhere in the middle, Senator.

CHAIR: That's why I'm going to give you the opportunity to tell us.

Mr McMillan : We categorise it not as a pilot shortage but as a pilot training blockage. That might sound like a euphemism, but, at the end of the day, we've got to roll back five years. We've had aviation regulatory reform that's been going on for 23 years and it's not finished. Some of its been okay; some of it's been appalling. In the pilot training area, it's been an absolute disaster. There's a whole heap fewer pilot training centres in Australia than there used to be. Many of them are foreign owned and they're only training pilots for their own operations elsewhere and the number of training establishments has shrunk considerably. Australia's population is growing. You could only think that the same percentage of people want to be pilots. I think what's happening is that the sausage machine has shrunk so small that it's very hard to get a training place. We would say that, from Alliance's perspective, as many people are out there wanting to be pilots. As a company, we are always training ahead. We train eight pilots at a time. We bring them in. We seem to be a good place to work. There are all the different places around Australia to go and live. There is a whole range of different training techniques and things have come in that are far smarter than they were 10 years ago. Some of the regulatory requirements that we have to meet in this country are absurd. That's a separate argument for a separate place. There were no safety issues; there wasn't a number of accidents or anything. But the unintended consequence of what CASA have done with some of their regulations has caused this issue, particularly in Australia.

CHAIR: We are a very long way back.

Senator PATRICK: I presume, because we've also heard evidence in other inquiries, that there used to be a whole bunch of training entities in GA, and GA has also been killed off by those regulations?

Mr McMillan : Correct.

CHAIR: I just wanted to get your view on the record. Thanks very much.

Update - Hansard: 

https://parlinfo.aph.gov.au/parlInfo/sea...nt=Default

Mr Carmody : That's fine. I understand everything you've said. I would make the point, however, that as a director of aviation safety my responsibility is to keep Australians safe. They're the decisions I make, which the government has empowered me to do and wants me to do, based on the evidence that I have. I've made those decisions and it's up to the parliament. If the parliament wishes to disallow, I understand that process completely.

Senator PATRICK: And I'm a senator who wants to make sure that people who rely on these flights to get medical treatment also do so safely, but there's always a balance to be had here and I'm just not sure it's right.

Mr Carmody : There is certainly a balance, and this is—

Senator PATRICK: We can make it completely safe by banning everyone from flying, and there will be no accidents.

Mr Carmody : That's certainly not our intent. That is why, as you know, I listened to what was said with rotary-wing and said it was not my intention to limit the field; my intention was to make sure these activities occur. But we are in the precautionary space. I cannot prevent two accidents that occurred—I cannot do that. What I can do is raise standards to prevent the next accidents occurring. I can't do any more with organisations like Angel Flight than encourage them to raise their standards. I cannot get them to do anything else, because they are not subject to my regulatory oversight. I can only encourage them to raise their standards. I've done that.

Senator PATRICK: You gave every one of their pilots a licence.

Mr Carmody : With respect, they would say they are not their pilots.

Senator PATRICK: Okay. Sure. I'm done, Chair. Thank you very much for your time, Mr Carmody.

Mr Carmody : My pleasure.

ACTING CHAIR: Just to follow up what Senator Patrick said: I think the reason we are both concerned about these regulations is that we've heard from the general aviation sector over a long period that they feel they are being squeezed out of existence by the level of regulation they face. As Senator Patrick said, we could make things a lot safer if everybody stopped flying, but I don't think that's where any of us want to be...

MTF...P2

[Kharon]

Quite the Caper indeed.

Now, I know what the court ruled – a legal breach. I know the operation was shut down. I also know that the ‘rules’ which caused this to happen have been a sore point, particularly when used to the extent of actually closing down an operator. Although Carmody’s ‘new’ regulations may prevent this sort of head banging; not much will change – not in a ‘safety’ sense; but, the operation which was closed down would, under the new rules have been quite legally safe.

It all seems like a lot of time, trouble, jobs, business and money could have been saved by asking Caper to desist for a while – as the rule applied was about to become ‘nugatory’ under the latest changes, (classification of operations) which have not only been coming for a long while, but will change little at operational level.

Reading the FAA and NZCAA versions of Parts 125, 135 and 121 reveals little difference in the way Australian ‘charter’ flying is conducted now– barring a few twiddles and ‘paper-work’. Of course the Australian version is the heavyweight champion – on the scales; pound for pound, it takes much longer in a more complicated way than the mature ‘authorities’ promulgate in their tried and tested Part 135.

CASA are not – and I reiterate – NOT providing rules to ensure and increased ‘operational safety’. They are producing instead reams of pages which prevent their responsibility for anything; and, to avoid itigation. For this we have waited 25 years and spent a half billion; to end up with an indecipherable pile of dribble, like the Roger Weeks wet dream, expounded in Part 61 and the incredible nonsense the MoS produces.

I’ve no idea what the minister or his government think they are buying; but it’s time to stop and think about getting a rope on CASA and restraining the ‘legal’ to focus on the very real operational safety matters which are NOT being addressed. At least not by CASA anyway. We must give thanks to the boys and girls who, despite CASA interface and loopy logic, run operators Safety Management Systems and despite having to ‘deal’ with CASA legal, still manage to keep our skies safe. Quite a trick – in the circumstances.

What heinous breach of basic ‘operational safety’ did Polar, Barrier or Caper commit? I shall leave that up to you to decide – while you consider RAAoz getting a weight increase – gods help us; AF in kit built aircraft, flown on a drivers medical – terrifying.

Perhaps, the minuscule, 'well advised' minister could take ten minutes to read through an articulate, considered, legally grounded opinion or two before he looses all credibility and (hopefully) his seat - Start  - HERE.      (Numb nuts)

Toot toot.