Mount Non-compliance & upcoming ICAO/FAA audit?

Mount Non-compliance & upcoming ICAO/FAA audit? - Printable Version

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RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Peetwo - 07-31-2017

Nepal makes honest progress to improving aviation safety record - Wink

Via Kathmandu Post:

Quote:Nepal offloads Icao safety concern tag
Flies out of global civil aviation watchdog’s bad books after four years

- SANGAM PRASAIN, Kathmandu

Jul 22, 2017-

The International Civil Aviation Organisation (Icao) has removed the “significant safety concerns” (SSC) tag it had put on Nepal four years ago.

The Civil Aviation Authority of Nepal (Caan) on Friday made an official announcement that Nepal “is no longer” in the global civil aviation watchdog’s bad books.

“We have passed the safety audit conducted by Icao’s Coordinated Validation Mission (ICVM),” said Caan Director General Sanjiv Gautam at a press meet in Kathmandu on Friday. “Our safety standard has improved better than expected,” he said. “But this is not the end. We have many challenges ahead. We all need to be careful about safety as its indicators keep on fluctuating all the time.”

The UN supervisory body had put the SSC tag on Nepal’s aviation sector in its audit report in 2013—a follow up of 2009 audit-after assessing that Nepal’s safety standard had not improved on par with the global standards.

Nepal’s largest helicopter Shree Airlines was the first casualty of the SSC. Its international chartered services with the United Nations World Food Programme were immediately withdrawn.

As fallout of the SCC, Nepal Airlines Corporation (NAC) was prevented from obtaining an operating authorisation in China. It has also affected the private carrier Himalaya Airlines’ plan to expand its wings to Hong Kong, Saudi Arabia and some other countries.

NAC’s worry had grown of late with the Icao SSC tag, for it has plans afoot to connect London and Australia after acquiring Airbus A330 jets. International airlines and travellers hesitate to travel to a country whose air safety is questioned by Icao.

The 2013 audit report had pointed that Nepal’s score of 55.01 percent in effective implementation (EI) of critical elements of safety oversight system was way below the global average of 60 percent. But the latest audit has given Nepal a score of 66 percent for effective implementation of safety standards—way above the benchmark of global standard of 60 percent.

Icao monitors Nepal’s aviation safety oversight capabilities through the ICVM. The mission is generally invited by a state when it is fully confident that it has fully complied with the international safety standards. The mission led by Icao operations expert Captain Eugene Voudri and airworthiness expert Edmund Bohland carried out an on-site audit on July 4-11.

Among eight critical elements of aviation safety—primary legislation, organisation and safety oversight functions, personnel licensing, aircraft operations, airworthiness of aircraft, aerodromes, air navigation system, and accident and incident investigation, the Icao experts had audited legislation, organisation, operations and airworthiness.

In July 2013, an Icao mission visited Nepal to validate the corrective measures taken by the country to address the deficiencies pointed out by the global aviation watchdog in 2009. But it found several lapses during the on-site audit held on July 10-16, 2013.

Icao had raised the red flag on “operations”, among the eight critical elements of safety oversight, due to a sharp rise in the number of air accidents and incidents between 2009 and 2012.

Based on the SSC, the European Commission (EC) had blacklisted all Nepali carriers in December 2013 for the worst record of air safety oversight. Nepali carriers had to pass SSC for the EC to remove them from its blacklist. “We now have a strong base to request the EC to remove Nepali airlines from its air safety list,” said Gautam. “Nepal’s agenda will be included on the EC’s air safety committee meeting scheduled to be held in Brussels, Belgium in November.”

Published: 22-07-2017 07:54

MTF...P2

Ps Thorny asked: "..Is this proposal the beginning of subtly devolving oversight to a third party? .."

Yes I think so and from an organisation renowned for jealously protecting it's trough fund, it is actually very clever by Carmody, as the operational cost savings would far out weigh the quid pro quo arrangements with IATA. Remembering of course that IATA will be ultimately looking for commercial benefits for it's members in the APAC region.

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Peetwo - 08-01-2017

Is Australia on it's last GASP with ICAO??

Reading up on the latest version of the ICAO GASP and being hot on the inconsistencies of Australian reporting to the ICAO ADREP/iSTARS system (more on my discoveries very soon); I cannot help but think we are close to the long drop of international ridicule when it comes to walking the talk on aviation safety risk mitigation... Blush

Following on from the 'Singers' theme on the Search 4 IP post #191 I would like to further highlight the strange and disturbing dichotomy between 'us' and 'them' on the world stage of belief (not weasel words) in the ICAO principles of effective implementation of an SSP (Annex 19) and compliance with the ICAO SARPS.

Via UnitingAviation.com:

Quote:Deepening our understanding of safety risks to better support States

- Mar 30, 2017
[/url]

Encouraging trends are putting ICAO’s aspirational safety goal of zero fatalities in reach, ICAO’s Deputy Director of Aviation Safety Catalin Radu told delegates at the [url=https://flightsafety.org/summit-seminar/sass2017/]Singapore Aviation Safety Seminar (SASS 2017), but the challenge of managing safety is becoming greater in the dynamic and complex environment caused by the predicted doubling in air traffic volumes over the coming years. His keynote address at the event outlined the measures ICAO is undertaking with its stakeholders to address this.

The SASS 2017 event which is currently taking place and jointly organized by the Flight Safety Foundation and the Singapore Aviation Academy (SAA), is an annual safety seminar designed to provide a platform for aviation professionals to share the latest safety challenges, issues, developments and initiatives to raise the safety standards in the Asia Pacific region. The theme for SASS 2017 is “Stepping up Safety: A Systematic Approach”.

Although the number of fatal accidents has been decreasing steadily since 2011, and it would be logical to deduce that the aviation sector is on its way to achieving its safety goal, Radu warned that “the path however, is not that obvious.” He identified three main issues: the effective implementation of ICAO’s Standards and Recommended Practices (SARPs), ICAO’s Safety priorities (operational risks) and current and emerging issues. “These issues can also be interpreted as opportunities”, he said, since they have encouraged the development of a vast array of systemic initiatives.

To carry out the effective implementation of SARPs, ICAO has put into place what it calls iMPLEMENT, an initiative designed to facilitate data-driven decision making at the top management levels. It has also established, inter alia, the GASP 2017-2019 roadmap to ensure that safety initiatives deliver the intended benefits associated with the Global Aviation Safety Plan (GASP) objectives and initiatives while ensuring the efficient and effective coordination of complementary safety activities between all stakeholders. Not to mention the Regional Aviation Safety Groups (RASGs) that have been created to identify activities to support the GASP implementation in the regions and the Regional Safety Oversight Organizations (RSOO), which secure a more effective fulfillment of a State’s oversight obligations and an efficient way to pool resources.

This work had previously been based on the Effective Implementation score, a flat model that measures States’ implementation of SARPs . “Moving from the Effective Implementation score to a more comprehensive model was essential” Radu continued. “For that reason, we have introduced the Safety Margins, a risk-based prioritization model based on a State’s Traffic and the level of Effective Implementation (EI) in the related technical areas at risk, namely operations, air navigation and support functions”.

In addition, at the forum on RSOOs for Global Aviation Safety, held in Ezulwini, Swaziland from 22 to 24 March 2017, a global strategy and an action plan were endorsed to implement the Global Aviation Safety Oversight System, with the purpose of empowering and strengthening regional mechanisms (RSOOs for example), and with ICAO maintaining an inventory of competent safety oversight providers and the tasks and functions that they provide.

RSOOs (and other safety oversight providers) would have to demonstrate competence in the tasks and functions that they provide and qualify as an ICAO recognised safety oversight provider. “ICAO would act as a library of such providers that States would peruse for their State Oversight Audit Results”, Radu said.

Radu also outlined the development and importance of the RASGs. Initially leading regional definition of global targets to be reflected in ICAO’s future Global Aviation Safety Plan (GASP), RASGs later evolved to assist States in defining their own specific targets based on an acceptable safety margin score. Today, RASGs constitute the perfect platform to harmonise and avoid overlaps between States, but also among RASGs.

Enhancing information is also key to the achievement of ICAO’s Safety priorities, specifically operational risks, Radu declared. “To reduce other accident priorities, a big framework for sharing information has been developed, one that covers much of the industry.”. This has been realized through the development of Core Safety Performance Indicators (SPIs), which constitute an essential element of State Safety Plans (SSPs). International organizations (ACI, CANSO, IATA, ICCAIA and IBAC) representing service providers (airports, ANSPs, Airlines, Manufacturers among others) also participated in this endeavour, with the development of proposed sets of SMS KPIs. Through its iMPLEMENT initiative and the tools it has developed to manage hazards, many of which can be accessed through ICAO’s web-based iSTARs system, ICAO is collecting safety and efficiency datasets provided by the industry to produce safety, efficiency and risk analyses, thus helping States prioritize implementation.

Finally, Radu outlined the challenges and progress being achieved in current issues in aviation safety, such as conflict zones, global aircraft tracking, drones (RPAS), space transportation, and cyber safety, which will be the focus of ICAO’s Cyber Summit and Exhibition, taking place from 4 to 6 April 2017. He also highlighted the need to identify new emerging issues, like mental health, GPS interruption, cargo safety and supersonic aircraft, all of which require establishment of programs where States, the Industry and other stakeholders will contribute.

In summary, Radu believes the aviation community has developed a wide range of programmes, products, databases and tools to enhance and support safety performance. “By combining State audits with State and Industry operational data through SMS and SSP, and by guaranteeing the protection of information or operational data through Amendment 1 to Annex 19, ICAO lies at the heart of its safety Agenda and acts as a major player in moving closer to its zero fatalities aspirational goal,” Radu concluded.

The sincerity and belief (not weasel words) from ICAO’s Deputy Director of Aviation Safety Catalin Radu, is IMO very much at odds with the Australian 'head in the sand' obfuscation to our aviation safety obligations to the ICAO GASP... Sad

MTF...P2

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Peetwo - 09-07-2017

Fawcett on drones, SMS & closing safety loops.

Quote from the foreword of ICAO Annex 19:

Quote:The Standards and Recommended Practices (SARPs) in this Annex are intended to assist States in managing aviation safety risks. Given the increasing complexity of the global air transportation system and its interrelated aviation activities required to assure the safe operation of aircraft, this Annex supports the continued evolution of a proactive strategy to improve safety performance. The foundation of this proactive safety strategy is based on the implementation of a State safety programme (SSP) that systematically addresses safety risks.

Now a quote from M&M's SSP Chapter 2 on safety risk management:

Quote:..However, a modern approach to aviation safety management necessitates a systems approach to managing safety risks, encompassing organisational structures, policies and procedures—the SMS approach.

Safety risk management of the Australian aviation industry is a shared responsibility between industry and government aviation agencies. It is important that the aviation industry and the aviation safety agencies work collaboratively to produce the best safety outcomes.

The SSP recognises the need for a transition to a systems-based approach to safety oversight along with risk-based surveillance. This shift places more responsibility on regulated organisations and changes how regulators undertake oversight and monitoring roles.

The identification and management of aviation safety risk is undertaken through a multi-layered process which permits the aggregation of system and risk information into higher order categories, culminating in an assessment of the level of risk across the aviation industry.

And from M&M's SSP Appendix E:

...Aviation safety risk management in CASA

Consistent with the increased international emphasis on a state safety risk management programme, and as highlighted in ICAO Annex 19 (Safety Management) and ICAO Doc 9859 (Safety Management Manual), CASA adheres to the AS/NZS ISO 31000:2009 Risk Management principles and guidelines to effectively identify, evaluate, control (where CASA has risk ownership) and monitor aviation safety risks.

As outlined in Chapter 2—State Safety Risk Management, management of Australian aviation safety risk is undertaken through a multi-layered process that has the capacity to identify and manage risks at various levels of the aviation industry...

There is at least one person in Australian politics that fully understands the principles and advantages of an effective aviation safety management system in proactively addressing identified safety risk issues, that person is Senator David Fawcett... Wink

Last week we were witness to Senator Fawcett's deeper understanding of an SMS and the important role the Government's aviation safety agencies are proactively supposed to play to ensure the integrity and effectiveness of the Australian version of the ICAO Annex 19 SSP.

Unfortunately it would appear that these agencies still lack the insight to understand the holistic, all inconclusive approach required to turn the SSP into a document of more than just words... Dodgy

In the following Hansard excerpts/Youtube vid, Senator Fawcett proves that these agencies a seemingly content to stand back and watch the drone related accident occur, instead of collectively working together to proactively work on solutions, as much as possible, to mitigate the risk:

Quote:Senator FAWCETT: My last question goes to the issue of risk. You've talked about risk assessments. As you do your risk assessments are you relying on CASA's evaluation, which essentially supports their two-kilogram threshold? Or are you aware of more recent studies, for example from the UK and their Military Aviation Authority, that indicate, certainly for GA aircraft and for rotor craft, that much smaller drones present still catastrophic risk?

Dr Weaver : I'm aware of and have read that study from the UK. Our approach is to take all data sources on board. In some respects once somebody has entered controlled airspace we look at how we manage the risk, no matter what the size of the aircraft or the drone is. So, our risk assessment is focusing on what we can do. Obviously it will also focus on what we can encourage other parts of government and industry to do as well. But we're targeting it down to our role, our controls and our mitigations that we can put in place.

Senator FAWCETT: Lastly, if we were to go to a model where we have a whole-of-government approach where the importation and sale is limited to the kinds of systems that DJI are putting out with that off-the-shelf, very limited operating envelope, and then we have a qualification regime where people can expand that a little bit to what our current requirements are—no closer than three kilometres, no more than 400 feet et cetera—and then another one to a commercial standard, from Airservices' perspective, who do you see should actually be conducting that training and licensing? Is that something that you see should be done by CASA, as it is for air crew at the moment? Could that be done by a commercial provider? Who do you think should be doing that?

Dr Weaver : When I look globally, I see a range of alternative approaches that occur. You see commercial providers of drone training internationally, and then you see some where it's more regulatory based. I guess, as the air traffic service provider, I'm agnostic as to how that's implemented. I'm interested in the outcome of preventing access to controlled airspace.

Quote:CHAIR: I want Senator Fawcett to have as much time as he needs. But I want to come back to estimates of 23 May—a Tuesday—this year when we had sitting at the table Mr Chris Manning, a former Qantas chief pilot who is now commissioner at ATSB. The words ring in my head. Although, I can't say them verbatim. Commissioner Manning said to us, 'Anything in airspace is a concern.' I get all that. So I want to ask the experts. We haven't had an incident—which is great. That's lucky. We don't want one. But, Mr Nagy, when you hit the pelican is there any way that something like this could do more damage to a fixed-wing aircraft?

I'm not going to won't worry about helicopters because that's Senator Fawcett's area of expertise. Would or could it do more damage than a birdstrike if it hit the engine or something like that?

Mr Hood : If I may, I would like to table this, an ATSB report where a wedge-tailed eagle, weighing about four kilograms, actually went through the cockpit of an Glasair aircraft near Bathurst in 2015. The pilot was temporarily blinded and broadcast a mayday. He had dead bird throughout the cockpit and in his lap, so the bird actually did go through the windscreen—a four-kilogram bird went through the windscreen. If you equate that to a four-kilogram RPA, obviously that is possible in light aircraft. Am I able to table that, please, Chair?

CHAIR: I can appreciate that, because I know a bloke who was minding his own business north of Pardoo one night when a bush turkey came through the bloody windscreen, mate—I've got a tell you, apart from crapping myself, lucky I wasn't at 30,000 feet.

Mr Hood : Apologies to Senator O'Sullivan, I will get a copy of that report sent to you electronically.

Senator O'SULLIVAN: Thank you.

CHAIR: We've heard evidence about lithium batteries and all that. I want you to tell me. Do we just say, 'Oh, if it's a bird or one of those, it doesn't make any difference—it's the same'?

Mr Hood : I think this is where we don't understand enough. This is where we're very interested in the UK report and what the difference is between striking an RPA and striking a bird. We have about 2,000 bird and animal strikes per year in Australia. Most of them bounce off to little effect, but, of course, the one in the report in front of you did enter the cockpit, breaking the canopy.

Senator FAWCETT: I think the UK report is very explicit on that. It highlights that the degree of give in the plastic of a plastic-covered drone has a very different impact to, perhaps, the homemade one where there are exposed metal components. So with the bird analogy, with lots of soft flesh tissue around, it will have an even more absorbent impact than the plastic. The UK report's actually pretty definitive on that point. A drone with exposed metal components, even at 400 grams, will have significant impact on a helicopter when it comes to dynamics components but even on a GA aircraft. That brings me to the issues around likelihood and consequence, which underpin risk. It brings me to issues of compliance and culture and, lastly, capacity. All of that will lead me to question you, as one of the safety experts, as to what work you are doing to contribute to a systems safety approach to this issue, as in a whole-of-government approach.

In terms of likelihood, Mr Holman, you very dutifully gave the answer that a DJI can only fly to 400 feet because that's the rule, and we had evidence here that you can't fly beyond line of sight. Can I tell you, the culture amongst the operators is different. Go and have a look at the DJI Forum online. These are people who fly DJIs for fun. A post earlier this year said, 'The FAA's 400-foot rule is not a rule; it's only a guideline.' Some bush lawyer has gone through and looked at all kinds of regulations going back into dim, dark history and statements in congress et cetera to justify why people can ignore the 400-foot rule. That's the culture. What that says is that, despite CASA's app and despite the piece of paper they put in the packet, the live culture that is dictating how the people among the 49,000 that the chair is concerned about operate these devices is that the likelihood of them being in places where they should not be is high and probably growing. It's also growing because things like the DJI off the shelf are more and more capable with every evolution. Therefore, there are more of those 49,000 who are flying more high-capacity aircraft. Putting that likelihood together with the consequence that we've seen from the British report, which you've very usefully highlighted again for us, what's your assessment of risk now compared to perhaps a year ago?

Mr Godly : The British report definitely provided a lot of information to us. Six months ago, when we were talking at the estimates committee, there wasn't really any of that real research, just mathematical models, basically based on birdstrikes and not much else. So that report really has informed us and what it has informed us is fairly consistent with what the models were suggesting would happen. In particular, for airliner-type aircraft, the risk of a collision—in particular, the windscreen—is probably limited to that cruise speed, because at the approach and descent speeds the bird strike certified windscreens don't seem to be compromised. And when you take into account the likelihood of that—we are seeing that three per cent of our encounters are above 10,000 feet, but the majority are obviously below that. So when you put likelihood and consequence together, for at least the high-capacity aircraft it's probably a fairly low risk.

For general aviation it's probably a different story. They generally don't have bird strike certified windscreens. And as the British report showed, there's a much greater chance of penetration of a windscreen, and also things like damaging the wings and rotors of helicopters. So in my opinion the biggest risk is for general aviation aircraft.

Senator FAWCETT: Well, perhaps I can put to you, because your submission highlights this, that the percentage of incidents for rotor craft as a percentage of hours flown shows that they are actually probably in the zone of having the most likelihood of an interaction. And perhaps I can also put to you that unlike a strike on the wing of a GA aircraft, which may put a dent in it or may even rupture a fuel tank, in worst case, a strike on a tail rotor of a helicopter probably is going to mean the loss of that helicopter. Whilst the military used to train, somewhat hopefully, to teach people to land a helicopter without a tail rotor functioning, and the centre-of-gravity impacts and rotational impacts et cetera, I'd argue that the majority of your pilots would probably struggle to land a helicopter without a tail rotor, which means you've got whole loss and life loss. So, the consequence is incredibly high. The consequence for your RPT aircraft, whilst it may not crash—we've already seen at Gatwick, incidentally, on 2 July, the same day we had the Fokker incident in Brisbane, aircraft having to divert, or hold, which means cost disruption—other than the windscreen, you've got two or maybe four very large intakes to engines. The cost of one of those going through an engine would be very large. So whilst we're not talking about life necessarily, there is a cost and a consequence across the whole range.

Coming to recognising, as you said in your submission, your priorities and your capacity to investigate things, CASA likewise has capacity constraints. Does it not suggest, if we have high risk and capacity constraint within a regulator like CASA and organisations like yours, that we need a whole-of-government safety system approach to this which includes a prohibition on the import of devices that are capable of these kinds of operations unless they are, as one previous witness told us, off the shelf, geofenced to a very small bubble—100 or 200 feet—around the operator, with increases to that operational capability allowed only when they demonstrate that they have complied with a level of training? And I would argue that the first level of training is an independently invigilated exam that shows that they understand the safety implications of the current envelope—three miles or three kilometres around airports, 400 feet et cetera—and that the geofencing is expanded to a hard limit of 400 feet and the other area and then a final level, which is commercial, all the normal commercial considerations that currently exist, would remove those limitations from the device. That kind of whole-of-government, importation, customs-type restriction as well as CASA, as the regulator, surely, given your capacity constraints, is the sort of model we should be looking at. Have you done any work as the premier safety body to look at a systems based safety approach involving the whole of government as opposed to limiting your thinking to the current aviation environment—which is yourselves, Airservices and CASA?

Mr Hood : As I mentioned before, we're informers of policy and we're working very hard on this issue to ensure that we inform those we are required to inform. Certainly under the CASA ATSB MOU we're feeding the stats and our analysis of those stats to the Civil Aviation Safety Authority and the department. We have also added RPAS to our safety watch. We have nine areas of focus—safety watch, that's called—and RPAS is certainly one of those. We certainly are gaining our own experience in relation to the operation of RPAS—for example, the grounding on our very first sortie, if you like, to use the drone for investigation: on the train, heard the helicopter, let's put it on the ground.

So it's kind of a learning experience for us, being an operator ourselves in the RPAS environment. Our view is that we are working very hard to ensure that we also inform the travelling public of the emerging risk. I did take out something from the previous discussion with the Airports Association that maybe we could do a better job of highlighting those maps that we put in our submissions in terms of local councils and airports, to say, 'These are the near encounters in your area.' Potentially that would inform them in relation to the signs. But I know what you're saying—the policy objective: we're informing the policymakers.

Senator FAWCETT: But what I'm asking is: are you looking for broader policy recommendations than perhaps you have traditionally taken? You know as well as the rest of us do that ministers tend to respond to recommendations of departments. If they go beyond recommendations of departments then, as Sir Humphrey says, 'That would be a very brave, Minister'! So, if departments come only with recommendations that are constrained by their current thinking—and from evidence that we've heard in this inquiry to date it seems that nearly every agency is constrained by the current construct of their role—CASA tells us, 'Well, we don't control importation', and you tell us you don't control regulation and Airservices says the same, who is doing that whole-of-government systems-type thinking to bring a recommendation to the minister saying, 'There is a way we can tackle this, but it will involve cross-departmental action and policy that brings in a number of arms of government'? I'm not hearing from any of you that anyone is doing that level. And if you, as the nation's premier safety experts, can't approach this from a broader systems perspective, asking what are all of the levers of government that we can bring to bear to this, then on what basis can we expect the minister to take action?

Mr Hood : I might make a couple of points. Australia does have an aviation policy group. The ATSB is not a member of the policy group, because it may well be that we have to investigate policy decisions. The department, Defence, CASA and Airservices are all members of the aviation policy group in Australia.

The other point I might add is the ATSB is very much the canary in the mine—and let me tell you, we will sing. But we're not going to sing prematurely, and we're not going to sing without the evidence to sing appropriately. You may be aware, from the other committee, of our report on the ATR aircraft. We have formed a strong view in relation to that aircraft. We published two interim reports and we've got a third one coming. So, we're not afraid to exercise that authority and have our say when we think it's appropriate. In this particular case I suppose it still comes down to the fact that we don't think we have enough evidence yet in relation to the consequence.

Senator FAWCETT: Okay. Thanks, Chair.

Senator FAWCETT: Sorry. You've completely derailed my train of thought, Mr Crawford.

CHAIR: I've been trying to do that for the last six years you've been here and I've never succeeded!

Senator FAWCETT: You have. You'll have to take some lessons. CASA has previously expressed some concern about the maturity of technology such as geofencing. I've actually just been going through your submission again, and I thought you'd mentioned something in here that some of those technologies could potentially introduce risks. But we heard a comment before about DJI as an OEM—and I haven't been able to clarify whether this is their intent or whether this is what they are doing now—and that their product off the shelf is limited to a 100-foot bubble around the operator. If that concept is viable and mature enough that an OEM is doing that, why would we not look at a whole-of-government approach where we limited imports and sales to only OEMs that were prepared to take that approach so that we completely avoid the example of the Christmas present with an ill-informed operator who happens to fly it under a helicopter route or near an airport? And if it is true that DJI have put this in place, then it says that it's mature enough that it's commercially viable, therefore it's probably reliable enough that we can actually start limiting the 90 per cent of the unintentional incidents due to lack of knowledge. Why would we not take that as a key approach to the government?

Mr Carmody : Firstly, I'm not sure that it's true. One of my colleagues might know, as we stay as closely as we can to these sorts of developments. If geofencing—and I'll call it 'geofencing' in that context—or limiting a bubble around a drone is technically feasible, does mature and does become that way, that is certainly one of the methods that you could use to control drones and manage some elements of the risk. I'm not certain that it's as mature as advertised as yet. They're a very big marketer of drones—the biggest in the world. They're obviously trying to stay the biggest in the world, or get bigger. I'm not sure how it actually interacts with other technologies as well. So, I think that the jury is out. It sounds logical and sensible, and we will certainly consider it. But in terms of whether it is there yet, I'm not sure.

Senator FAWCETT: Could you undertake to have one of your people contact them, and OEM, and ascertain and come back to the committee with a view on that.

Mr Carmody : Certainly.

Senator FAWCETT: Because, if it's technically feasible and we limit the market to only manufacturers who meet that technical bar, as sure as apples come from trees, other manufacturers will reach that bar if they want to sell into the market. That then gives us a starting point where, over five years, with degrading batteries and all the rest of it, the old fleet will disappear and we'll be in a much better space for those 49,000 recreational users to encourage, through capability, their requirement to increase their level of knowledge before their machine becomes more capable.

Mr Carmody : We certainly will, Senator. We'll certainly take it on notice. We'll ask the question. I was hopeful we might even have the answer, but I assume we don't. We'll ask the question and come back to the committee and let you know what we find. I think, conceptually, in isolation, it sounds like a very positive outcome. I would just like to see how it fits.

Senator FAWCETT: Don't get me wrong. I applaud the range of efforts in issues like the cinema and things like that. It's fantastic in terms of informing people. But I think you were here before, when I talked about the DJI blog site, or the forum. Despite all of the training and licensing that we give to professional pilots, you get the occasional person who thinks it will be fun to beat someone up or push the boundaries et cetera. If you have a large population who have never been through that rigour, nor understand the risks that emanate from their conduct, then that kind of culture that's reflected in the blogs says that trying to regulate and educate through what is essentially a voluntary system is going to be almost unmanageable. That is why I think we need to have a system where we use the technology to limit the exposure to other aviation users, and only allow it to expand as you do at the moment. The commercial RPAS licence regime is very thorough, and it's great for people who want to operate commercially. What's missing is the middle piece between someone who can essentially buy a toy that they can fly to 100 feet around them and someone who wants to operate something with more capability.

This is my final question for you. Let's say we did go down that three-tiered system, where, without constraint, you can buy a toy, but you've got a technical constraint that you can only fly it in a little bubble, and, at the other end, we already have your commercial system, but in the middle there's the technology piece—and we'll explore that—but then there's the education and licensing approach. I've raised before the example of the maritime radio operators' licence, where, dangerous as that device is, every user has to actually pass an independently invigilated exam. Would CASA be the right body to take your current rule set—around three nautical miles, 400 feet et cetera—and create an online course or syllabus that perhaps could be run by the private sector and then an exam that people would sit so that they could then, with a number saying, 'I have demonstrated a degree of knowledge and competence by passing this exam,' go back to the OEM to get that technical unlock to operate in that middle recreational space? Would CASA be the person to do that?

Mr Carmody : You could do that, in reality. It is achievable. You've gone through quite a number of steps. There's a fair bit of complexity in that, I might say. But yes. We are the regulator. It is fundamentally our responsibility. The question would be—and that's one of the things that we're looking for in our survey—how much education would be enough? How much do you actually need? As you indicated, quite rightly, in the commercial sector there is a significant amount of rigour. How much, verging from nothing to that, do we actually need? And how would you manage such an arrangement? And how would you link it if the government decided to register every drone, for example? How would you make all of these things fit together? As I said, I think there is a fair bit of complexity in this space. But, on its face, it's achievable. But it would cost.

MTF...P2

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Peetwo - 10-12-2017

Obfuscation of ICAO - A how to? Dodgy

I note that in recent days ICAO have lifted their 2015 red flag on Thailand's aviation safety standards - Bravo to Thailand! Wink

The following article (via the Oz) highlights what it means to Thailand in terms of economic stability and growth in their tourism industry:

Quote:Thailand gets aviation safety upgrade
Aukkarapon Niyomyat And Wirat Buranakanokthanasan

Reuters

4:45PM October 9, 2017

The UN International Civil Aviation Organisation has removed a red flag against Thailand over safety concerns, the Civil Aviation Authority of Thailand says, sending shares in Thai airlines sharply higher.

Thailand was downgraded in June 2015 after its regulator missed a deadline to resolve significant safety concerns, meaning that airlines in Thailand were unable to add further international routes, though they could continue to operate routine flights.

The Thai aviation authority said on Monday the ICAO had made the decision after a meeting on Friday.

The Montreal-based UN agency was not immediately available for comment, but the red flag which appeared against Thailand on its website had disappeared.

"Although lifting the red flag is a significant turning point for her aviation industry, Thailand as well as CAAT need to carry on their missions to improve the aviation safety standards," the CAAT said on its website.

CAAT director general Chula Sukmanop told a news conference the removal of the red flag would give Thai airlines a chance to start new flights to China, Japan and South Korea.

Shares in Thai Airways climbed nearly 8 per cent on the news before falling back to trade at over 5 per cent higher.

The biggest beneficiaries of the decision would be smaller carriers, such as Thai AirAsia X, NokScoot and Thai Lion, said Corrine Png, the CEO of Singapore-based transport research firm Crucial Perspective.

"The ICAO downgrade had seriously impeded these new entrants' growth to lucrative markets such as Japan and South Korea," she said.

"These airlines can now grow more aggressively. This would, however, imply increased competition for Thai Airways when they expand."

ICAO's red flag was based on its audit of the regulatory body, rather than individual airlines.

Some major Thai airlines, including Thai Airways, Bangkok Airways, Thai Lion and NokScoot, have passed the International Air Transport Association Operational Safety Audit, a benchmark for global safety management in airlines.

Aviation safety is particularly important for Thailand given that tourism accounts for around 12 per cent of its economy, the second largest in Asia.

The countries which still have red flags against them are Djibouti, Eritrea, Haiti, Kyrgyzstan and Malawi, according to the ICAO list.

Meanwhile in Australia the aviation safety bureaucracy continues to blinker and confound our NFI minister with the mystique of aviation safety... Confused

Extracts from 6D AGAD speech to Safeskies are empty skies gobfest... Undecided

Quote:..Australia continues to have one of the safest aviation industries in the world and this is testament to you, our aviation community and Government...

...Australia's aviation safety system is recognised internationally as one of the best in the world...

While the minister has obviously acquired an acute strain of aviation safety induced AIOS...

Reference: AIOS - & the 21st Century??

Quote:The industry has "acquired institutionalised ostrichitis syndrome" (AIOS).

...it is worth pondering whether our aviation safety system is in fact any better than the Thais; or are our bureaucrats very effective at covering up our deficiencies... Huh

From recent research for a submission to the Australian Mission to ICAO, PAIN is of the opinion that the Department of Infrastructure & Regional Development and it's three aviation safety agencies, are merely paying lip service to the ICAO... Dodgy

Extract from that submission:

Quote:...It is difficult to treat the interrelated elements in isolation or define the categories in order of weight and importance. On balance, as the ICAO ADREP/iSTARS system is of global significance to aviation safety, we propose to restrict opinion to the reporting of fuel related events to the ICAO as example:-

1) Accurate reporting to ICAO of ‘fuel’ and forecast weather related incidents; and the
Classification of operations.
2) The treatment and reporting of a ditching event, which was both fuel and weather
related.

In general, it must be stated that the Australian Civil Aviation Safety Authority (CASA) has an unique approach to ICAO compliance, with record number of ‘notified differences’. Many of the notifications may, at face value, seem insignificant. It is our opinion that the noted differences are structured to support the complex, contradictory, flawed rule set in place. Reform of this rule set has been in train for thirty years, with successive government ministers and directors of civil aviation promising to complete the task ‘within the next three years’. This is an important consideration as it reflects on the operational approach taken to both open reporting of ‘incident’ or event; and, the tangible fear of prosecution. Australia’s Civil Aviation Regulation (CAR) are founded on the ‘criminal code’ and ‘strict liability’; this, standing alone, provides a strong disincentive to openly reporting safety related matters. This attitude is reflected in the government safety bodies approach to ICAO compliance and reporting.

The ‘unique’ Australian approach to ‘Fuel planning’ and alternate aerodrome requirements may be clearly demonstrated through a history of the ‘fuel related’ events which do not appear to have been captured on either ICAO iSTAR or ECAIRS data base; thus denying the accumulation and evaluation of safety critical, fuel/weather related incidents. Concerns that the number of fuel and or weather related incidents are being down played, not critically analysed and supported by Safety Recommendations appears to be denying vital safety information to the international industry and safety analysts; those who rely on accurate data sets to formulate policy...

..The ATSB reporting of this singular, rare event has been the subject of a Senate inquiry resulting in some 30 significant Senate, disregarded recommendations; followed by a ministerial inquiry conducted by an independent, internationally recognised panel which provided more than three dozen significant, disregarded recommendations. The report was subjected to an independent peer review, by the Canadian TSB, under narrow terms of reference which also made a list of recommendations, which remain lambent, but disregarded.

The analysis of the flight is, radically, a simple one; the aircraft ran out of fuel. How this came to pass is not complex, every shortcoming within the entire safety system was involved; from fatigue to systematic failure. Once again, the safety net failures were easily corrected; and, had those failings been honestly admitted and corrected, there would have been little need for the raft of inquiries and subsequent recommendations (deemed to be opinions).

Both government investigations called for public submissions. As a small part of the PAIN
submission the general reporting to ICAO was tracked. During research it became apparent that there seemed to be unexplained anomalies, which were variously described as ‘taxonomy’ problems, data base error, human error etc. We submit that there are too many ‘anomalies’ to be ignored. This is either a failure of system or; could, reasonably, be construed as deliberate manipulation. Accurate statistics are a vital part of safety analysis, flawed or manipulated reporting is not only misleading but could form part of a causal chain...

"...In general, it must be stated that the Australian Civil Aviation Safety Authority (CASA) has an unique approach to ICAO compliance, with record number of ‘notified differences’..."

Further to the embarrassing - Blush

- number of Australian notified differences to the ICAO SARPs it is worth referring again to my previous post and the DoIRD submission to the Parliamentary JSCOT inquiry into the Serbia/Vanuatu Airservices agreements/treaties: Post #8

Quote:Coming back to that 'categories of differences' table:

My hope is that due to Senator Fawcett's questioning and in collating that data for the sup submission, the Department may have suddenly come to the realisation that Australia is far from being anywhere near adhering to the spirit and intent of most of the ICAO SARPs.

It is worth noting that of the listed 10,696 notified differences from the three countries, 4024 were from Australia, this is a disturbing 38% of the total. But what is more disturbing is the figure in the 'Less protective or partially implemented or not implemented' category (in other words the 'up yours' category... ), which was an UDB 2078, compared to 41 Serbia & 9 Vanuatu...

4024 notified differences for Australia?? Recently I had collated from the 2015 AIP GEN 1.7 SUP that notified differences had grown to a total of 3116. However in actual fact between the 2011 SUP the figure had grown to 4024 but due to the loose ICAO arrangement of only listing NDs every 3 years this was missed. So from my approximate estimate from 2011 to 2014 the NDs had grown by 2500.

This means that in actual fact in the period between 10 February 2014 till November 2015 the Department has managed to reduce the notified differences by 908.

Still got a long way to go but perhaps this highlights more than anything else the impact that the Senator Fawcett inquisition had way back on the 10 February 2014...

Couple the alarming statistics of Australian non-compliance to the ICAO SARPs with the failure of system or; (sic)..deliberate manipulation of accident/incident/safety reporting to ICAO; and the disturbing suspicion that our Annex 13 AAI, the ATSB, is seemingly providing non-transparent, politically correct top cover for the Department, it's agencies and the big end of town Airlines and major operators;...

Quote:Example: PelAir MKII: ASA Swiss Cheese slices & bunnies

...and IMO we are heading towards a statistically high probability of an air disaster that could have been avoided if the government, the department and it's aviation safety agencies weren't so busy covering their asses... Dodgy

MTF...P2

Ps Q/ Did PT ever get a complete response from former DPM/Minister Truss to this article?

Quote:
Did Australia mislead ICAO over the Pel-Air crash?

Updated with partial response from Minister Truss. The Pel-Air accident scandal now threatens to undermine Australia’s nomination of the former chief of CASA, John McCo

Ben Sandilands

Updated with partial response from Minister Truss. The Pel-Air accident scandal now threatens to undermine Australia’s nomination of the former chief of CASA, John McCormick, as the next secretary general of ICAO, the International Civil Aviation Organisation.

The core issue is that the Pel-Air ditching in 2009, and the botched accident report produced by the Australian Transport Safety Bureau, the ATSB, don’t appear to have been filed with ICAO.

This means that ICAO could be seen to be officially unaware of the crash, or the subsequent accident report, contrary to its own ICAO Annex 13, specifically Chapter 7 and Attachment B. The conduct of CASA, under Mr McCormick, in relation to the Pel-Air crash would thus not necessarily arise in ICAO’s deliberations in choosing a new secretary general, the other candidate being from China.

Australia failed in its responsibility to ICAO in not meeting these reporting requirements.
This failure is noticeable in this document, a draft of the Asia/Pacific Annual Safety Report for 2002 to 2011. No reference is made to the Pel-Air ditching.

Yet in the quaint post war terminology employed by ICAO as a United Nations agency, Australia is “the champion for the editing and publishing group.”

But has Australia misled ICAO, or just been an incompetent champion?

If ICAO were to be informed of and curious about the Pel-Air crash, and the quality and integrity of the accident report, it would read the deliberations and testimonies associated with the Australian Senate investigation of the ATSB’s Pel-Air report, which discredited the conduct of both Mr McCormick as director of safety at CASA and Martin Dolan as chief commissioner of the ATSB.

It would also, in its diligence, become aware of the somewhat astonishing generosity of REX, the owner of Pel-Air, to the major political parties of Australia in 2012, in the second half of the year in which the ATSB was in a state of turmoil over the direction of the final report.

A deodorant to counter the stench coming off this sorry, sorry epic, involving the performances of the former responsible transport minister Anthony Albanese, and the current somewhat vague minister, Warren Truss, would also be advised.

Amnesia related to Pel-Air was also apparent in this recently recycled ATSB report into fuel exhaustion accidents.

The current state of play in the Pel-Air saga is that the ATSB, having been found wanting in its procedures by a peer review by the Transportation Safety Board of Canada, is now reviewing its original defective report with its own appointee!

This additional layer of farce and maladministration might also be of interest to ICAO, and is understood to be likely to become an early focus of the same Senate committee that exposed the truth about the original CASA cover up of the deficiencies in Pel-Air’s Westwind jet operations at the time of the 2009 ditching near Norfolk Island.
Ministerial spokesperson responds:

Quote:The ATSB advises that it did report the Pel-Air accident off Norfolk Island to ICAO, which is confirmed through a check of the iSTARS database.
The accident did not appear in the Annual Safety Report Asia Pacific Region (2002-2011) because the report is limited to scheduled commercial operations above 5,700kg. The Pel-Air accident off Norfolk Island was not a scheduled commercial operation so it was excluded from the report.

This statement doesn’t address all of the issues in the post.

It specifically ignores the other instance of ATSB amnesia in its ten year review of fiuel management accidents and incidents, which included events involving non scheduled services by aircraft smaller than the Westwind that was ditched off Norfolk Island.

A complete response to the post continues to be sought from the Minister.

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Peetwo - 03-21-2018

Prerequisite for Fort Fumble middle management drone??

The following quoted extract is from a speech delivered to the RPAS in Australian Skies 2018 conference, by Luke Gumley, Branch Manager Remotely Piloted Aircraft Systems:

Quote:...In addition to CASA’s priorities in the RPAS sector, which I will discuss in a moment, CASA’s regulatory reform program remains a focus. The reform program began many years ago, and has been an ongoing process to either finalise new regulations or to review and update them, to make improvements to aviation safety as technology changes, or to reflect better safety practices. CASA has sought to align the regulations as closely as possible with the International Civil Aviation Organization standards and recommended practices, and to harmonise, where appropriate, with the standards of other leading aviation countries.

The Civil Aviation Safety Regulations comprises of 55 Parts, of which 45 have been made – leaving 10 to go. However, most of the last ten are substantial, involving the flying operations suite, along with some sport and recreational aviation Parts. The operations suite has been through many drafting iterations and consultation over the years, but we are doing our utmost to finalise drafting this year. We can then move on to transition, noting that most of the Parts will include some transition period to allow enough time for people and organisations to be prepared to meet the new regulations.

Our recent audit by ICAO, through the Coordinated Validation Mission last year, saw us receive a result in the high 90s, putting Australia in the top 10 in the world for effective implementation of ICAO standards and recommended practices.

One recent new initiative is how we manage our consultation, with the establishment of the Aviation Safety Advisory Panel in July 2017. The new panel is the primary advisory body which CASA can direct its industry engagement through, when seeking input on current and future regulatory and policy approaches. It also serves as an advisory panel to the Director of Aviation Safety, by providing informed, objective and high-level advice from the aviation community on current, emerging or potential issues that may have aviation safety implications...

When you consider my 'Dear Lachie' post on the dots & dashes thread, you begin to wonder if it is a prerequisite of accepting positions within the aviation safety bureaucracy (CASA, ASA, the ATSB & the Dept) that you must undergo either a frontal lobotomy; or a full blown brainwash prior to employment. How any remotely sane person with any sort of expertise or experience, aligned with the administration of aviation safety in Australia, could possibly prattle out such statements like...

"..CASA has sought to align the regulations as closely as possible with the International Civil Aviation Organization standards and recommended practices, and to harmonise, where appropriate, with the standards of other leading aviation countries..."

...with a straight face is simply UDB! Dodgy

MTF...P2

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Peetwo - 04-30-2018

Chasing tales and washing spots - Part II

From the latest word weasel confection from Carmody Capers... Blush

CC said: "...Everyone in aviation can be proud of the new top six safety ranking given to Australia by the International Civil Aviation Organization. The ranking follows the latest International Civil Aviation Organization audit of Australia's aviation safety system, carried out in late 2017. The audit delivered a 95 per cent safety oversight score, which we must now work to maintain. This means Australia currently ranks sixth out of International Civil Aviation Organization member states for effective safety oversight. The International Civil Aviation Organization assesses a nation's safety oversight capabilities by looking at aviation legislation, licensing, operations, civil aviation organisational structures, air navigation and accident investigation. The high ranking demonstrates Australia has a robust aviation safety system supported by public sector agencies with a deep commitment to achieving the best possible safety outcomes. Credit for the ranking also goes to the commitment to safety by the people and organisations who make up Australia's aviation community. It is your day-to-day work, delivering safety during every flight and every aviation activity, that makes Australian skies amongst the safest in the world. Naturally, I am proud of the role the CASA has played in lifting Australia's safety ranking and I thank all staff for their contribution. Tribute also goes to the contributions and efforts of the Department of Infrastructure, Regional Development and Cities, Airservices Australia, the Australian Transport Safety Bureau, the Australia Maritime Safety Authority and the Bureau of Meteorology.

Get more information on the International Civil Aviation Organization's Universal Safety Oversight Audit Programme. ..."

Now this makes sense of the 'out of the blue' bollocks propaganda piece from Creedy: Reference - On chasing tales and washing spots

Quote:...Australia’s aviation system has been judged one of the world’s safest after an International Civil Aviation Organisation (ICAO) audit ranked it sixth among member states for safety oversight.

The UN-Backed organization audited Australia in 2017 on a range of issues including operations, airworthiness, accident investigations and air navigation services. It gave the nation a safety oversight score of 95 percent, according to the Civil Aviation Safety Authority...

...I wonder how much that ICAO rubberstamp 'bollocks' cost us? Not to mention the cost to HVH in wining, dining (plus extra curricular activities), while pulling the wool over the eyes of ICAO (wet lettuce) Thor in the course of his wanderings through the Halls of AAI top-cover experts the ATSB : Mount NCN post #106

Got a feeling my next Aunty task will be to systematically pull apart that complete and utter load of BOLLOCKS -

In the meantime here is a challenge for CC, given our stellar standing in the world of aviation safety administration can we now request that the FAA IASA team come back and doubly reassure the members of the A4ANZ that we are in the stratosphere of Category 1 member States? Come on CC, money where your mouth is mate!!

Depicted in the Creedy puff piece was this graph of the EI 'effective implementation' of ICAO standards by Australia compared to the global average (below):
[Image: icaoresults2.jpg]

This information was extracted from this interactive ICAO webpage: https://www.icao.int/safety/Pages/USOAP-Results.aspx

Next referring to this comment from CC: "...I am proud of the role the CASA has played in lifting Australia's safety ranking..."

Now if we rewind to this 1/11/2016 Mount NCN thread - Q/ Has the Forsyth ASRR panel been deceived? - you will see that I had copied & pasted the Australian EI graph for 2016:

Quote:

The average % total for 2016 was 93.65%. Based on the Creedy copied graph this compares to 93.99% for 2018. If CC believes that a .34 % point lift in Australia's safety ranking is something to be proud of, then I've got a cheap bridge in Sydney Harbour he may be interested in purchasing... Tongue

However to be fair to CC (or not - Shy

) when you read the blurb on the ICAO adopted USOAP CMA it becomes obvious that the EI graph is constantly being updated as an individual State reviews or updates and self-assesses through SAAQs, EFOD, CAPs (ref pg 1) and PQs (pg 2):

The USOAP CMA has four components integral to the
continuous monitoring by ICAO of the safety oversight
capabilities of its Member States.

To wit:

1) Safety information is collected through
Member States and various internal and external
stakeholders.

2) This information is analyzed to determine the
safety risk profile of each State.

3) Based on the risk profile, ICAO selects and
prioritizes the States which will receive
corresponding USOAP CMA activities.

4) The results of the USOAP activities lead to
updates of the Effective Implementation (EI)
value of the States on the USOAP CMA online
framework.

IMO, despite the CC waffle, this in effect means that the current EI scores are irrelevant to the actual ICAO audit results. This also means that the actual audit report, with the associated recommendations/RCAs, are yet to be released for the State SSP to properly assess and then construct a corrective action plan (CAP).

But don't let me get in the way of the telling of the Carmody Capers fairytale... Big Grin

Finally another quote from page 2 of the ICAO USOAP CMA flyer:

2) Verify the status of the States’ implementation of:

a) Safety-related ICAO Standards and
Recommended Practices (SARPs);

This brings me back to this part of my (yet to be replied to - Huh

) Dear Lachie email/post:

Quote:You said:

“…For comments on filing of differences, as per Article 38 of the Convention on International Civil Aviation (the Chicago Convention), of which Australia is a signatory, we file a range of differences with ICAO. Airservices Australia regularly publish these in the Aeronautical Information Publication available on their website. Australia takes a proactive and conservative approach, updating its differences often and reporting any point of difference to allow operators the information they need to conduct safe operations.

Due the subjective nature of filing differences, the comparison of numbers of differences is not regularly used as a measure. State’s safety oversight arrangements at ICAO are benchmarked through an assessment process leading to an effective implementation score. Australia was assessed in October 2017 by ICAO auditors and while the results are yet to be made public it places Australia in the top 10 States for safety oversight compliance…”

Comment: I am fully cognisant of the Airservices AIRAC publication but disagree with some of the premises and assumptions that you make in the above paragraphs.

To begin here is the link for the latest ASA notified differences AIRAC: http://www.airservicesaustralia.com/aip/...7-h136.pdf

I guess it could be argued that the AIP SUP does allow operators the information they need to conduct safe operations ?? However whether that information can be easily disseminated when you consider the many 100s of pages and thousands of notified differences that AIP SUP links to is an entirely different matter.

In comparison please refer to the five pages of GEN 1.7 of the Singaporean CAAS AIP: https://www.caas.gov.sg/docs/default-sou...1feb18.pdf

The following is a quote from the KC_ICAO_1 PDF (see above or attached) which we believe summarises why it is that we have such a huge number of notified differences to ICAO and why we think this is a significant safety issue concern:

“.. In general, it must be stated that the Australian Civil Aviation Safety Authority (CASA) has an unique approach to ICAO compliance, with record number of ‘notified differences’. Many of the notifications may, at face value, seem insignificant. It is our opinion that the noted differences are structured to support the complex, contradictory, flawed rule set in place. Reform of this rule set has been in train for thirty years, with successive government ministers and directors of civil aviation promising to complete the task ‘within the next three years’. This is an important consideration as it reflects on the operational approach taken to both open reporting of ‘incident’ or event; and, the tangible fear of prosecution. Australia’s Civil Aviation Regulation (CAR) are founded on the ‘criminal code’ and ‘strict liability’; this, standing alone, provides a strong disincentive to openly reporting safety related matters. This attitude is reflected in the government safety bodies approach to ICAO compliance and reporting…”

PAIN understands that the department policy is to place very little importance on notified differences being a ‘measure’ on aviation safety standards of ICAO signatory States.

Reference: 1.2 Supplementary to submission 1 (PDF 60 KB)

Did the Department of Infrastructure and Regional Development collate and analyse the differences lodged with the ICAO by Serbia and Vanuatu when their respective Memoranda of Understanding and proposed Air Services Agreements were being negotiated?

No. Air services arrangements provide an economic framework in which airlines can consider serving a market. Differences lodged by States, among other more pertinent kinds of safety-related information, may be taken into account by the Civil Aviation Safety Authority in the assessment of applications for the operation of foreign aircraft into and out of Australia.

Regards
Gilon Smith
Director (a/g), Air Services Negotiations
Department of Infrastructure and Regional Development
gilon.smith@infrastructure.gov.au Ph: 02 6274 6634

However the above departmental answer to the QON would seem to have been contradicted in the other supplemental submission: 1.1 Supplementary to submission 1 (PDF 78 KB)

“..The process of notification of differences provides a structured way for each State to communicate its aviation rules by measuring itself against the neutral framework of the ICAO standards…”

Q/ Given this conflict in interpretation of notified differences as a ‘measuring’ stick of aviation standards and the fact that the department was obviously responsible for creating the Serbia/Vanuatu/Australia 10696 notified differences table, for the benefit of the Senate RRAT committee and industry stakeholders, would it not be possible for the department to collate a similar table for say the top 50 ICAO signatory States?

Q/ For the benefit of the committee would it be possible (in camera if required) for the department to forward the:

a/ 2017 ICAO audit report of the ATSB;
b/ The 2009 FAA IASA audit report of the CASA;
c/ The 7 December 2009 CASA Board minutes;

Finally, considering the positive feedback the department has received from ICAO’s October 2017 audit, would it be possible for the committee to view that report prior to it’s public release? Would it also be possible for the department to suggest that CASA invite the FAA IASA auditors back to audit and compare whether all the 2009 FAA IASA audit findings have been properly and proactively addressed?

Hmm...(CC & Lachie - Wink

) it is passing strange how the ICAO USOAP CMA system would appear to place significant weight on the importance of an individual State's EI and compliance with the ICAO SARPs as a measure of aviation safety standards... Rolleyes

MTF...P2

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Gobbledock - 05-01-2018

Luke Gumjob said;

"..CASA has sought to align the regulations as closely as possible with the International Civil Aviation Organization standards and recommended practices, and to harmonise, where appropriate, with the standards of other leading aviation countries..."

Absolute parroted tautological rubbish. Who can take this bloke seriously anyway, he was Hi-vis Hoody’a admin assistant in Safety Oversight at Fort Fumble, a Neville nobody who ‘rose’ rapidly under Hoody, so to speak, due to their sharing ‘similar interests’. Oh dear, if only the manly Screaming Skull knew what used to happen on Level 3 after the lights when out!!!!

‘Safe bureaucratic horse Pooh for all’

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - thorn bird - 05-01-2018

Antique Tool Still In Use - Do you know what it is?image1.tiff

[Image: tobacco-smoke-enema-kit-by-wellcome-imag...0.jpeg.jpg]

[Image: tobacco-smoke-enema-kit-by-wellcome-imag...0.jpeg.jpg]

Tobacco Smoke Enema Kit (1750s – 1810s).

The tobacco enema was used to infuse tobacco smoke into a patient's rectum for various medical purposes, but primarily the resuscitation of drowning victims.

A rectal tube inserted into the anus was connected to a fumigator and bellows that forced the smoke into the rectum. The warmth of the smoke was thought to promote respiration.

Doubts about the credibility of tobacco enemas led to the popular phrase "blowing smoke up your ass."
As you are most likely aware, this odd tool is still heavily used by CASA.

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Gobbledock - 05-01-2018

Thorny;

”As you are most likely aware, this odd tool is still heavily used by CASA”

And also often seen receiving a robust workout at ICAO Montreal conferences, toga parties at Hoody’s place and CAsA’s end of year Xmas parties....

‘Safe rectal practises for all’

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Kharon - 05-01-2018

Smoking enema’s & the pinning of fart to the wall; 101.

I expect lots and lots of folk are wondering what the upshot of our digging about in the bowels of Australia’s alleged compliance with ICAO is. There is (almost literally) a mile of solid research to wade through; certainly a ream and it would be understandable if it gave you a headache. However, you cannot call Bollocks without evidence; hence the digging about. “Too much here to read in one hit” was the consensus. Clearly defined conclusions are difficult to draw –from cleverly, we believe, deliberately obscured to sooth political concerns. How to encapsulate it all – put in a nutshell – is problematic as the thing is so nebulous, it almost defies this practical application. Not only that, but to keep a short statement ‘accurate’ and on target through the smoke and mirrors is fraught with the perils of relying on malleable facts. However, to begin at the end:- with the now infamous O’Sofullame Freudian slip.

Hansard - “The FAA has done an audit on CASA in Australia. I understand it's going to be interesting reading.”

"Many are wondering why the government is sitting on the last ICAO/FAA audit: indeed to quote O’Sofullame - “I understand it's going to be interesting reading. They're resisting publication of that at the moment. We're trying to muddle our way through getting that out into the open.”

WTD - “resisting releasing it”. Who or what is resisting and why FDS are 'they' allowed. by the Chair, to get away with it? Bollocks.

P2 – “Depicted in the Creedy puff piece was this graph of the EI 'effective implementation' of ICAO standards by Australia compared to the global average (below):”

P2 – “However to be fair to CC (or not - ) when you read the blurb on the ICAO adopted USOAP CMA it becomes obvious that the EI graph is constantly being updated as an individual State reviews or updates and self-assesses through SAAQs, EFOD, CAPs (ref pg 1) and PQs (pg 2):”

“..The process of notification of differences provides a structured way for each State to communicate its aviation rules by measuring itself against the neutral framework of the ICAO standards…

For the benefit of those intellectually challenged – lets all repeat this sentence; once again. When you have committed it to memory – repeat it: often, to everyone you meet who may want to buy a large bridge which my pyramid company has been asked to dispose of.

“by measuring itself against the neutral framework of the ICAO standards”.

Toot & Spin – Toot & Spin – I’m so dizzy – I may even vomit, copiously.

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - thorn bird - 05-05-2018

This little gem could perhaps explain a lot

Parkinson's Law

C. Northcote Parkinson

C. Northcote Parkinson is Raffles Professor of History at the University of
Singapore. This article first appeared in The Economist in November 1955.

It is a commonplace observation that work expands so as to fill the time available for its completion. Thus, an elderly lady of leisure can spend an entire day in writing and dispatching a postcard to her niece at Bognor Regis. An hour will be spent in finding the postcard, another in hunting for spectacles, half-an-hour in a search for the address, an hour and a quarter in composition, and twenty minutes in deciding whether or not to take an umbrella when going to the pillar-box in the next street. The total effort which would occupy a busy man for three minutes all told may in this fashion leave another person prostrate after a day of doubt, anxiety and toil.

Granted that work (and especially paper work) is thus elastic in its demands on time, it is manifest that there need be little or no relationship between the work to be done and the size of the staff to which it may be assigned. Before the discovery of a new scientific law-herewith presented to the public for the first time, and to be called Parkinson's Law1 - there has, however, been insufficient recognition of the implication of this fact in the field of public administration. Politicians and taxpayers have assumed (with occasional phases of doubt) that a rising total in the number of civil servants must reflect a growing volume of work to be done. Cynics, in questioning this belief, have imagined that the multiplication of officials must have left some of them idle or all of them able to work for shorter hours. But this is a matter in which faith and doubt seem equally misplaced. The fact is that the number of the officials and the quantity of the work to be done are not related to each other at all. The rise in the total of those employed is governed by Parkinson's Law, and would be much the same whether the volume of the work were to increase, diminish or even disappear. The importance of Parkinson's Law lies in the fact that it is a law of growth based upon an analysis of the factors by which the growth is controlled.

The validity of this recently discovered law must rely mainly on statistical proofs, which will follow. Of more interest to the general reader is the explanation of the factors that underlie the general tendency to which this law gives definition. Omitting technicalities (which are numerous) we may distinguish, at the outset, two motive forces. They can be represented for the present purpose by two almost axiomatic statements, thus:
Factor I. An official wants to multiply subordinates, not rivals and Factor II. Officials make work for each other. We must now examine
these motive forces in turn.

THE LAW OF MULTIPLICATION OF SUBORDINATES

To comprehend Factor I, we must picture a civil servant called A who finds himself
overworked. Whether this overwork is real or imaginary is immaterial; but we should observe, in passing, that A's sensation (or illusion) might easily result from his own decreasing energy-a normal symptom of middle age. For this real or imagined overwork there are, broadly speaking, three possible remedies:
(1) He may resign.
-2 -
(2) He may ask to halve the work with a colleague called B.
(3) He may demand the assistance of two subordinates to be called C and D.
There is probably no instance in civil service history of A choosing any but the third alternative. By resignation he would lose his pension rights. By having B appointed, on his own level in the hierarchy, he would merely bring in a rival for promotion to W's vacancy when W (at long last) retires. So A would rather have C and D, junior men, below him. They will add to his consequence; and, by dividing the work into two categories, as between C and D, he will have the merit of being the only man who comprehends them both.

It is essential to realize, at this point, that C and D are, as it were, inseparable. To appoint C alone would have been impossible. Why? Because C, if by himself, would divide the work with A and so assume almost the equal status which has been refused in the first instance to B; a status the more emphasized if C is A's only possible successor. Subordinates must thus number two or more, each being kept in order by fear of the other's promotion. When C complains in turn of being overworked (as he certainly will) A will, with the concurrence of C, advise the appointment only by advising the appointment of two more assistants to help D, whose position is much the same. With this recruitment of E, F, G and H, the promotion of A is now practically certain.

THE LAW OF MULTIPLICATION OF WORK

Seven officials are now doing what one did before. This is where Factor II comes into
operation. For these seven make so much work for each other that all are fully occupied and A is working harder than ever. An incoming document may well come before each of them in turn. Official E decides that it falls within the province of F, who places a draft reply before C, who amends it drastically before consulting D, who asks G to deal with it. But G goes on leave at this point, handing the file over to H, who drafts a minute, which is signed by D and returned to C, who revises his draft accordingly and lays the new version before A.

What does A do? He would have every excuse for signing the thing unread, for he has many other matters on his mind. Knowing now that he is to succeed W next year, he has to decide whether C or D should succeed to his own office. He had to agree to G going on leave, although not yet strictly entitled to it. He is worried whether H should not have gone instead, for reasons of health. He has looked pale recently - partly but not solely because of his domestic troubles. Then there is the business of F's special increment of salary for the period of the conference, and E's application for transfer to the Ministry of Pensions. A has heard that D is in love with a married typist and that G and F are no longer on speaking terms-no one seems to know why. So A might be tempted to sign C's draft and have done with it.

But A is a conscientious man. Beset as he is with problems created by his colleagues for themselves and for him-created by the mere fact of these officials' existence-he is not the man to shirk his duty. He reads through the draft with care, deletes the fussy paragraphs added by C and H and restores the thing back to the form preferred in the first instance by the able (if quarrelsome) F. He corrects the English-none of these young men can write grammatically-and finally produces the same reply he would have written if officials C to H had never been born. Far more people have taken far longer to produce the same result. No one has been idle. All have done their best. And it is late in the evening before A finally quits his office and begins the return journey to Ealing. The last of the office lights are being turned off in the gathering dusk, which marks the end of another day's administrative toil. Among the last to leave, A reflects, with bowed

shall see, the rate of increase was not as regular as that. All we stage, is the percentage rise over a given period.

ADMIRALTY STATISTICS

have to consider, at this
Percentage increase or decrease
-67.74 -31.50 + 9.54 +40.28 +78.45

Capital ships in commission Officers and men in Royal Navy Dockyard workers
Dockyard officials and clerks Admiralty officials
1914 62
146,000 57,000 3,249 2,000
1928 20 100,000 62,439 4,558 3,569

-3 -

shoulders and a wry smile that late hours, like gray hairs, are among the penalties of success.

THE SCIENTIFIC PROOFS

From this description of the factors at work the student of political science will
recognize that administrators are more or less bound to multiply. Nothing has yet been said, however, about the period of time likely to elapse between the date of A's appointment and the date from which we can calculate the pensionable service of H. Vast masses of statistical evidence have been collected and it is from a study of this data that Parkinson's Law has been deduced. Space will not allow of detailed analysis, but research began in the British Navy Estimates. These were chosen because the Admiralty's responsibilities are more easily measurable than those of (say) the Board of Trade.

The accompanying table is derived from Admiralty statistics for 1914 and 1928. The criticism voiced at the time centered on the comparison between the sharp fall in numbers of those available for fighting and the sharp rise in those available only for administration, the creation, it was said, of "a magnificent Navy on land." But that comparison is not to the present purpose. What we have to note is that the 2,000 Admiralty officials of 1914 had become the 3,569 of 1928; and that this growth was unrelated to any possible increase in their work. The Navy during that period had diminished, in point of fact, by a third in men and two-thirds in ships. Nor, from 1922 onwards, was its strength even expected to increase, for its total of ships (unlike its total of officials) was limited by the Washington Naval Agreement of that year. Yet in these circumstances we had a 78.45 percent increase in Admiralty officials over a period of fourteen years; an average increase of 5.6 percent a year on the earlier total. In fact, as we

Can this rise in the total number of civil servants be accounted for except on the assumption that such a total must always rise by a law governing its growth? It might be urged, at this point, that the period under discussion was one of rapid development in naval technique. The use of the flying machine was no longer confined to the eccentric. Submarines were tolerated if not approved. Engineer officers were beginning to be regarded as almost human. In so revolutionary an age we might expect the storekeepers would have more elaborate inventories to compile. We might not wonder to see more draughtsmen on the payroll, more designers, more technicians and scientists. But these, the dockyard officials, increased only by 40 percent in number, while the men of Whitehall increased by nearly 80 percent. For every new foreman or electrical engineer at Portsmouth there had to be two or more clerks at Charing Cross. From this we might be tempted to conclude, provisionally, that the rate of increase in administrative staff is likely to be double that of the technical staff at a time when the actually useful strength (in this case, of seamen) is being reduced by 31.5 percent. It has been proved, however, statistically, that this last percentage is irrelevant. The Officials would have multiplied at the same rate had there been no actual seamen at all.

-4 -
It would be interesting to follow the further progress by which the 8,118 Admiralty staff of 1935 came to number 33,788 by 1954. But the staff of the Colonial Office affords a better field of study during a period of Imperial decline. The relevant statistics are set down below. Before showing what the rate of increase is, we must observe that the extent of this department's responsibilities was far from constant during these twenty years. The colonial territories were not much altered in area or population between1935 and 1939. They were considerably diminished by 1943, certain areas being in enemy hands. They were increased again in 1947, but have since then shrunk steadily from year to year as successive colonies achieve self-government.

COLONIAL OFFICE OFFICIALS
1935 1939 1943 1947 1954
372 450 817 1,139 1,661

It would be rational, prior to the discovery of Parkinson's Law, to suppose that these changes in the scope of Empire would be reflected in the size of its central administration. But a glance at the figures shows that the staff totals represent automatic stages in an inevitable increase. And this increase, while related to that observed in other departments, has nothing to do with the size - or even the existence - of the Empire. What are the percentages of increase? We must ignore, for this purpose, the rapid increase in staff, which accompanied the diminution of responsibility during World War II. We should note rather the peacetime rates of increase over 5.24 percent between 1935 and 1939, and 6.55 percent between 1947 and 1954. This gives an average increase of 5.89 percent each year, a percentage markedly similar to that already found in the Admiralty staff increase between 1914 and 1928.
Further and detailed statistical analysis of departmental staffs would be inappropriate in such an article as this. It is hoped, however, to reach a tentative conclusion regarding the time likely to elapse between a given official's first appointment and the later appointment of his two or more assistants. Dealing with the problem of pure staff accumulation, all the researches so far completed point to an average increase of about 5 4' percent per year. This fact established, it now becomes possible to state

Parkinson's Law in mathematical form, thus:
In any public administrative department not actually at war a staff increase may be expected to follow this formula:

2km +p n
where k is the number of staff seeking promotion through the appointment of subordinates; p represents the difference between the ages of appointment and retirement; m is the number of man hours devoted to answering minutes within the department; and n is the number of effective units being administered. Then x will be the number of new staff required each year.
Mathematicians will, of course, realize that to find the percentage increase they must multiply x by 100 and divide by the total of the previous year, thus:

100(2km + p) %yn

-5 -

where y represents the total original staff. And this figure will invariably prove to be between 5.17 percent and 6.56 percent, irrespective of any variation in the amount of work (if any) to be done.
The discovery of this formula and of the general principles upon which it is based has, of course, no emotive value. No attempt has been made to inquire whether departments ought to grow in size. Those who hold that this growth is essential to gain full employment are fully entitled to their opinion. Those who doubt the stability of an economy based upon reading each other's minutes are equally entitled to theirs. Parkinson's Law is a purely scientific discovery, inapplicable except in theory to the politics of the day. It is not the business of the botanist to eradicate the weeds. Enough for him if he can tell us just how fast they grow.

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Peetwo - 05-24-2018

The ICAO world according to Dr A - UDB! Dodgy

I note from the Budget Estimates tabled documents that finally the Dept has replied and compiled a table comparing the top 20 ICAO compliant States:

Quote:Senator Barry O'Sullivan, Chair, Rural and Regional Affairs and Transport Legislation Committee
Letter from Mr Brendan McRandle regarding ICAO Standards
22 May 2018
PDF 334KB

However, although this bollocks correspondence is apparently scribed by Mr Brendan McRandle, the following paragraphs IMO have a distinctly Dr A word weasel spin to them - Undecided

See what I mean, got Dr A's pugmarks all over it - Rolleyes

Note that these 'make work' aviation safety bureaucrats are still trying to paint the image that our standing as the sixth most ICAO compliant State is only a recent occurrence facilitated by the great work of HVH and CC Wingnut - UDB! Dodgy

MTF? - Definitely...P2 Cool

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Peetwo - 05-25-2018

(05-24-2018, 12:25 PM)Peetwo Wrote: The ICAO world according to Dr A - UDB!

I note from the Budget Estimates tabled documents that finally the Dept has replied and compiled a table comparing the top 20 ICAO compliant States:

Quote:Senator Barry O'Sullivan, Chair, Rural and Regional Affairs and Transport Legislation Committee
Letter from Mr Brendan McRandle regarding ICAO Standards
22 May 2018
PDF 334KB

However, although this bollocks correspondence is apparently scribed by Mr Brendan McRandle, the following paragraphs IMO have a distinctly Dr A word weasel spin to them -

See what I mean, got Dr A's pugmarks all over it -

Note that these 'make work' aviation safety bureaucrats are still trying to paint the image that our standing as the sixth most ICAO compliant State is only a recent occurrence facilitated by the great work of HVH and CC Wingnut - UDB!

A follow up to the above, I note the following from the recently processed Budget Estimates Hansard:

Quote:CHAIR: Welcome to the Australian Transport Safety Bureau. We've received correspondence in response to our request about the notifications of differences to ICAO Standards and Recommended Practices from the department. With the concurrence of my colleagues, we will table it and recommend it be published. There may be colleagues who have some questions for you on it.

Mr Hood, I want to open with a compliment. I recently spent quite a bit of time with all those old-timers with the magnificent old flying machines, the antiques and that. They've got the highest regard for your department, reputation wise.

Mr Kefford : Thanks, Senator.

CHAIR: It wasn't shared by all departments in aviation, but yours was one. I just wanted to give you that feedback. I want to ask about the drones issue, because we're starting to get towards the sharp end of work. Were you involved at all with CASA? Did you guys make any submissions or engage with CASA on the question of their review?

And so the CHAIR once again effectively nullifies any further line of questioning on the middle finger salute that the aviation safety agencies and the dept give to any thought of proactively harmonising and/or complying with the ICAO SARPs - FDS! Dodgy

MTF...P2

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Peetwo - 05-29-2018

Barry O, Mr McFixit and the ICAO snowjob - Rolleyes

BO - "..We've received correspondence in response to our request about the notifications of differences to ICAO Standards and Recommended Practices from the department. With the concurrence of my colleagues, we will table it and recommend it be published. There may be colleagues who have some questions for you on it..."

Hello Earth to Senator Rex this was your first opportunity and again you muffed it.. Dodgy

Of course you had a Chair that was running interference but then you had another perfect opportunity to talk to the Horse's head, i.e the person that supposedly authored that ICAO SARPs notified differences bollocks correspondence:

Looking into the background/CV of one Mr McRandle (i.e McFixit) there are some 'passing strange' dots and dashes that seriously need connecting... Huh

Quote:BRENDAN MCRANDLE

EXECUTIVE DIRECTOR, AVIATION AND AIRPORTS

DEPARTMENT OF INFRASTRUCTURE, REGIONAL DEVELOPMENT AND CITIES

BIO

Brendan is the Executive Director of Aviation and Airports Division within the Department of Infrastructure and Regional Development.

Brendan has worked with the Department since 2006, initially in the Australian Transport Safety Bureau before moving to different areas on the Department as his career progressed. Immediately prior to joining the Aviation and Airports Division, Brendan was the Executive Director of the Western Sydney Unit and responsible for the second Sydney airport project.

Aviation and Airports Business Division contributes to the well-being of all Australians by fostering a competitive, sustainable and safe aviation sector through appropriate regulation, program delivery and policy development.

The primary role of the Aviation and Airports Division is to advise the Government on the policy and regulatory framework for the Australian aviation and airports industries.

The Division manages the continuing relationship between the Government and the Civil Aviation Safety Authority (CASA), Airservices Australia (Airservices) and Australia's airlines. It also manages Australia's participation in the work of the International Civil Aviation Organisation (ICAO) and provides the secretariat for the International Air Services Commission (IASC).

Apparently BM was awarded a PSM (Public service Medal) in this year's Australia Day awards:

Quote:Brendan McRandle, from the Department of Infrastructure, Regional Development and Cities was awarded a PSM for his work on the development and delivery of the Western Sydney Airport project to the construction stage. Brendan was part of the Towards Strategic Leadership program in 2009.

Yet less than a month after receiving that award and some 8 years before the current forecasted completion of the West Sydney Airport project; BM is effectively sidelined to what has to be regarded as a lesser position in the Dept as Executive Director of the Aviation and Airports division - WTD? Rolleyes

Reference: Ms Kim Forbes, A/g General Manager, Department of Infrastructure, Regional Development and Cities - Notable absences and structural changes in the portfolio 19/02/2018
PDF 193KB

Quote:

As a passing strange coincidence (or not) the McFixit appointment occurred at around about the time AP, on behalf of KC, made submissions to Sam the ICAO man in Montreal, which ultimately led to my reply correspondence to Dear Lachie - Shy

Quote: “…For comments on filing of differences, as per Article 38 of the Convention on International Civil Aviation (the Chicago Convention), of which Australia is a signatory, we file a range of differences with ICAO. Airservices Australia regularly publish these in the Aeronautical Information Publication available on their website. Australia takes a proactive and conservative approach, updating its differences often and reporting any point of difference to allow operators the information they need to conduct safe operations.

Due the subjective nature of filing differences, the comparison of numbers of differences is not regularly used as a measure. State’s safety oversight arrangements at ICAO are benchmarked through an assessment process leading to an effective implementation score. Australia was assessed in October 2017 by ICAO auditors and while the results are yet to be made public it places Australia in the top 10 States for safety oversight compliance…”

Comment: I am fully cognisant of the Airservices AIRAC publication but disagree with some of the premises and assumptions that you make in the above paragraphs.

To begin here is the link for the latest ASA notified differences AIRAC: http://www.airservicesaustralia.com/aip/...7-h136.pdf

I guess it could be argued that the AIP SUP does allow operators the information they need to conduct safe operations ?? However whether that information can be easily disseminated when you consider the many 100s of pages and thousands of notified differences that AIP SUP links to is an entirely different matter.

In comparison please refer to the five pages of GEN 1.7 of the Singaporean CAAS AIP: https://www.caas.gov.sg/docs/default-sou...1feb18.pdf

Which brings me full circle back to the 22 May 2018 letter from Mr McFixit 'regarding ICAO Standards' and that misleading table... Dodgy

Still working on sorting the above figures into a usable reference for comparison purposes but for now if you take the one damning figure of 2445 'for partially implemented or not implemented', Australia is by far and away the worst State for compliance with the ICAO SARPs - Dodgy

Standby for MTF...P2 Cool

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Kharon - 05-30-2018

Statistics – done on the devil’s own abacus.

"There are three kinds of lies: lies, damned lies, and statistics." (British Prime Minister Benjamin Disraeli:1878).

Or, as Jean Shepherd said - In God We Trust: All Others Pay Cash.

The table P2 has posted is ‘interesting’ for several reasons – the most glaringly obvious jump off the page of this masterpiece in manipulation; particularly when you consider how the ‘numbers’ were derived; and, by whom…

Australia almost top scores the most ‘registered’ differences list with 4307. Then leads the pack in “Partially implemented or not implemented” with a whopping 2445.

Second in differences filed; top score for not implemented; statistically that places Australia very close to the bottom of the top twenty. It all depends on how you choose to read the numbers and what you want folk to believe.

Toot – believe it if you like – toot.

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Peetwo - 06-02-2018

(05-30-2018, 07:06 AM)kharon Wrote: Statistics – done on the devil’s own abacus.

"There are three kinds of lies: lies, damned lies, and statistics." (British Prime Minister Benjamin Disraeli:1878).

Or, as Jean Shepherd said - In God We Trust: All Others Pay Cash.

The table P2 has posted is ‘interesting’ for several reasons – the most glaringly obvious jump off the page of this masterpiece in manipulation; particularly when you consider how the ‘numbers’ were derived; and, by whom…

Australia almost top scores the most ‘registered’ differences list with 4307. Then leads the pack in “Partially implemented or not implemented” with a whopping 2445.

Second in differences filed; top score for not implemented; statistically that places Australia very close to the bottom of the top twenty. It all depends on how you choose to read the numbers and what you want folk to believe.

Toot – believe it if you like – toot.

I know for the Excel purists the following comparison tables compiled by DJ would appear to be ass about but for the purposes of how the figures can be manipulated it will do... Rolleyes

First the Attach A table unaltered: http://auntypru.com/wp-content/uploads/2018/06/Copy-of-ICAO-compliance-2.xlsx

Now taking the 'net' differences for 'partially implemented or not implemented' showing Australia a distant last out the twenty ICAO signatory States depicted: http://auntypru.com/wp-content/uploads/2018/06/Copy-of-ICAO-compliance-3.xlsx

On my digging for historical references to Australia's NDs to ICAO I came across a very interesting document i.e the 1999 summary report of the ICAO audit of the CASA: http://auntypru.com/wp-content/uploads/2018/06/australia_1999_en.pdf

Besides giving an interesting but disturbing juxtaposition comparison on the 20+ year history of CASA, the following was the CASA response to an ICAO recommendation that the regulator should endeavour to reduce the number of NDs related to the SARPs CASA was responsible for:

Quote:3.2.2.1 With respect to the recommendation on reducing the number of differences with ICAO SARPs, CASA will, as necessary, consult with the industry on whether or not a difference should be notified or rectified. It will also complete the programme of rewriting the CARs and monitor changes in ICAO SARPs to ensure future conformance. CASA already started consideration of those departures from SARPs which should be the subject of a notified difference and the target date for notification was 1 January 2000. CASA further indicates that it will develop programmes for monitoring future changes to SARPs to ensure that Australia remains compliant.

Again that weasel worded confection has got Dr A's pugmarks written all over it... Dodgy

MTF...P2

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Kharon - 06-04-2018

IF you wake at midnight, and hear a horse's feet,

Perhaps it is time Aleck resigned in order to spend more time with his few remaining marbles. This lunacy, not to mention the expense of seeming to be compliant with the ICAO SARPS etc. must come to an end. The minister needs to take a long, serious look at the huge amounts of money pumped into feeding the deception that Australia is a good, compliant aviation citizen; IMO it is not. The breath taking audacity, monumental arrogance and deliberate manipulation of ‘system’ are clearly apparent when examined closely.

[Image: maxresdefault.jpg]

Past and present government ministers have been or are quite willing to accept the myth that Australia is compliant and has a very safe rule set; a world leader. This is simply the happy horseshit spoon fed to people who cannot possibly understand, or are disinclined to look closely at the realities. The industry hardly has time to do the research; the incredible loads, both financial and operational, demand so much manpower and money that it precludes a WTD moment, followed by protest.

Another disincentive is the protection of ‘rice-bowls’; operational peace and compliance quiet, balanced on a razors edge. To get operations running ‘smoothly’ is, at the best of times, a Herculean task without starting to dig around the foundations, the base blocks on which operational status is based. Rocking the boat and asking awkward questions is a black hole that few will venture near.

But they should. An operation like Qantas for example could, in a heart beat, put some clever folk to work and research exactly how much the current system costs as opposed to how much it would cost if Australia was truly a model aviation citizen. In compliance cost alone Alan Joyce could improve his bottom line substantially. This has to be better than just grinning and bearing it; going along to get along.

This blatant deception, foisted on an unsuspecting public costs a serious amount of money; the current on going sick farce of regulatory reform costs as much again; the cost to industry of compliance with the massive overburden of ‘compliance’ under the ‘regulations’ is reducing the margin between viable and moribund to anorexic levels.

Take a long hard look at the real data on ICAO compliance – even on a self assessment basis, Australia is a long way behind the modern aviation world and grievously suffering for it. Yet the lunatics running the asylum want gold stars, more money to continue the pantomime and a bonus; on account o’ being good. Bollocks.

'If You do as you've been told, 'likely there's a chance,
You'll be give a dainty doll, all the way from France,
With a cap of Valenciennes, and a velvet hood -
A present from the Gentlemen, along 'o being good !

Five and twenty ponies,
Trotting through the dark -
Brandy for the Parson, 'Baccy for the Clerk.
Laces for a lady; letters for a spy,
Watch the wall my darling while the Gentlemen go by!

Selah.

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Gobbledock - 06-04-2018

Dr LLLL (Lying Loyola Legal Lickarse)

K;

“Past and present government ministers have been or are quite willing to accept the myth that Australia is compliant and has a very safe rule set; a world leader. This is simply the happy horseshit spoon fed to people who cannot possibly understand, or are disinclined to look closely at the realities.”

It’s a good old deflection that one. Just because we have not yet experienced a QF and VA tail smouldering inside a smoking crater it makes the masses and the politicians feel safe. Bollocks! We have come close, very close, numerous times, and thank God that Professor Reason’s cheesy holes didn’t perfectly align. But tick tock.

More K;

“An operation like Qantas for example could, in a heart beat, put some clever folk to work and research exactly how much the current system costs as opposed to how much it would cost if Australia was truly a model aviation citizen. In compliance cost alone Alan Joyce could improve his bottom line substantially”.

Indeed they could, probably have, and in the very least they would already know how shiteful the Regs are. However, for political reasons they will never rock the boat, speak publicly about CAsA and our pitiful regulatory environment. Wouldn’t want to risk those Government contracts, subsidised routes and tax breaks hey? Just sayin.....

People like Dr LLLL are in place for a reason. For almost 25 years the bearded used car salesman has massaged his speech with pithy words and gently crafted musings pulled from a university handbook on ‘How To Obsfucate And Deceive By Using Wank Words And Other Robust Initiatives’. It hasn’t fooled everyone. Some of us old sea dogs smelled what the Witchdoctor was cooking before he even poured the ingredients into the cauldron. Tsk Tsk Dr LLLL, we’ve got your number. But the Government embraces muppets like Aleck as he does exactly what they want him to do - paint a picture of a joyous, happy, safe and compliant thriving aviation industry that will benefit from even more onerous regulations and an atmosphere of mistrust where all of us are criminals who just haven’t been caught yet.....

TICK TICK

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Peetwo - 06-06-2018

Three decades of Australia taking the piss out of ICAO - Dodgy

Extracts from the 1999 ICAO audit of CASA:

Quote:3.2.1.2 The Act empowers CASA to effectively discharge its duties and responsibilities. It also

provides CASA with an investigative power and the authority to develop aviation safety standards and to issue permissions and air operator certificates (AOCs) . However, CASA does not have direct regulatory powers. The power for making regulations is held by the Governor General (essentially the Executive Government) in accordance with Article 98 of the Act which also requires that regulations be made for “the purpose of carrying out and giving effect to the provisions of the Chicago Convention relating to safety”. The rationale for giving the regulatory power to the Governor General is that regulations are delegated legislation in respect of which there must be ministerial responsibility and parliamentary oversight. CASA is a regulator, not a law-maker, and this is an important distinction in the Australian system of government. The Act (Article 1) also requires that CASA “...performs its functions in a manner consistent with the obligations of Australia under the Chicago Convention”

3.2.1.3 The civil aviation regulations of Australia are in the process of a major review and are grouped in two different sets. The first set — Civil Aviation Regulations 1998 (CARs 1998) — were adopted in 1998 as the first instalment of a major revision of the Australian regulations system which will be organized along the lines of the United States’ Federal Aviation Regulation (FAR) system. It includes Parts 21 to 35 (Airworthiness). The other regulations are contained in the Civil Aviation Regulations 1988 (CARs 1988). A timetable indicates that the progressive transfer to the new system will be completed by 2003...

...3.2.2.1 With respect to the recommendation on reducing the number of differences with ICAO SARPs, CASA will, as necessary, consult with the industry on whether or not a difference should be notified or rectified. It will also complete the programme of rewriting the CARs and monitor changes in ICAO SARPs to ensure future conformance. CASA already started consideration of those departures from SARPs which should be the subject of a notified difference and the target date for notification was 1 January 2000. CASA further indicates that it will develop programmes for monitoring future changes to SARPs to ensure that Australia remains compliant.

5. ICAO SARPs NOT IMPLEMENTED

Several differences existing between ICAO Annexes 1, 6 and 8 and the Australian regulations were identified and remained not implemented by the time this report was prepared. On the basis of Article 17 of the MOU signed between Australia and ICAO, the differences contained in the Attachment to this report will be forwarded to the appropriate Sections of the Air Navigation Bureau for inclusion in the Supplements to the respective Annexes.

Extracts from the 2004 ICAO audit of the ATSB:

Quote:5.1.3 Status of implementation and differences to Annex 13

5.1.3.1 In practice, the ATSB is provided amendments to Annex 13 and other relevant ICAO documentation from the Department of Transport and Regional Services (DOTARS).
The Deputy Director Aviation Safety Investigation reviews the amendments and advises the DOTARS if differences to Annex 13 exist. Australia has notified differences to ICAO in respect of Annex 13. However, while section 17 of the TSI Act automatically endorses any amendments to ICAO SARPs and gives them the force of Australian law, the ATSB has not yet formalized its process for reviewing the SARPs and identifying its differences (Appendix 1-1 refers).

5.1.3.2 In respect of the difference filed by Australia against paragraph 5.1, the audit team
recalled that paragraph 5.1 is a fundamental paragraph in Annex 13, placing an obligation on the State of Occurrence to institute an investigation into the circumstances of an accident and to be responsible for the conduct of the investigation, with the objective of the prevention of (future) accidents and incidents (paragraph 3.1 of Annex 13). The accident investigation agencies in some other major aviation States, facing similar workload increases and budgetary decreases as ATSB, have elected to investigate all
accidents in accordance with Annex 13, with the proviso that the investigation is continued to a point that it is evident that no further safety enhancements can be achieved. A decrease in workload is thus achieved by (severely) limiting the scope of the investigation of some (smaller) accidents as well as the size and format of the report.

5.1.3.3 Australia had filed a difference to paragraph 5.4 a) in respect of “gathering, recording and analysing all available information”. The ATSB commented that there were limited resources resulting in a prioritization depending on the likely safety value of the investigation.

5.1.3.4 The difference filed by Australia against paragraph 5.6 concerned the control of the
bodies of the fatally injured flight crew and passengers which rested with the coronial authorities. The ICAO audit team recalled that the intent of paragraph 5.6 was to deal with the access and control by the investigator-in-charge of the wreckage and flight records and documentation. The handling and the autopsies of the bodies was dealt with in paragraph 5.9 which addressed “the State” (not the investigatorin-charge) to reflect the fact that the primary control of the handling of the bodies and the autopsies was the responsibility of other national authorities (usually coronial and police authorities).

5.1.3.5 Regarding paragraph 5.25, Australia had filed a difference reserving the right to remove a participant from an investigation if such a participant contravened the agreed conditions of participation.

The audit team recalled that the spirit of Annex 13 was full cooperation between the States and the participants involved, and full adherence to Annex 13. Hence, Annex 13 did not deal with situations that might result from non-adherence to Annex 13 and it should not be necessary to file differences for such eventualities. The audit team noted that Note 1 to paragraph 5.25 appeared to cover the situation envisaged by Australia. Regarding the envisaged situation, the audit team further noted that subject to a consultation with the State that appointed an accredited representative or an adviser, that State could be
expected to replace or withdraw its appointed representative/adviser. In such a case, the State of Occurrence would not have a need to “remove” a participant from an investigation.

5.1.3.6 The difference filed by Australia against paragraphs 7.1 and 7.5 regarding Preliminary Reports and Data Reports to be sent to the ICAO Accident/Incident Data Reporting (ADREP) system introduced certain limitations to the reporting by Australia. The ICAO audit team reiterated that the ICAO ADREP system had been established by the 1974 ICAO Accident Investigation and Prevention Divisional Meeting. The States participating in the meeting considered it essential that a world accident data system be established and that ICAO be the custodian of the system. The States undertook to report their accidents to the system. The original ADREP system was developed in 1975 by an expert made available to ICAO by Australia. The requirements for States to report to the ADREP system are contained in Chapter 7 of Annex 13. The data in the ADREP system was essential in developing the world accident statistics, determining safety indicators for aviation, analysing causal factors in accidents and in determining and prioritizing safety initiatives.

CORRECTIVE ACTION PROPOSED BY THE ATSB:

Section 17 of the Transport Safety Investigation Act 2003 requires the ATSB to exercise powers in a manner consistent with Annex 13 (identified by Regulation) in the latest form that the Annex is in force. This means that there is no need to take separate action to ensure amendments to Annex 13 are reflected in Australian legislation – it happens automatically.

However, the ATSB has revised the Safety Investigation Policy and Procedures Manual to include a procedure to formally review amendments to SARPs against the TSI Act, regulations, policies, procedures and resource capability of the bureau, and to list and notify any differences to ICAO.

The ATSB has forwarded a notification to ICAO, through the Australian Council Representative, that Australia is removing differences filed against Annex 13 paragraphs 5.6 and 5.25. This action was taken as a result of the ICAO Audit Team noting that the intent of paragraph 5.6 and the spirit of Annex 13 in relation to paragraph
5.25 were being met by Australia.

Extracts from the 2008 ICAO audit of the Civil Aviation System of Australia:

Quote:
AUDIT FINDING LEG/01

Australia has established procedures for the amendment of its regulations and for the identification and notification to ICAO of differences existing between the ICAO SARPs and PANS on one hand and Australia’s regulations in its newly approved Regulatory Development Management Manual on the other hand. However, these procedures do not address adopted regulations and have not fully kept the national regulations in pace with ICAO Annex amendments, in particular in the areas of personnel licensing, airworthiness and aircraft operations. In addition, not all differences to ICAO SARPs have been notified to ICAO. Furthermore, the list of differences to ICAO SARPs as published in the Aeronautical Information Publication (AIP) Australia has not been updated since 9 June 2005.

A new Australian policy and associated procedures for identifying and notifying ICAO of differences to standards and those recommended practices has been developed. The policy includes notification of a difference to those recommended practices which we consider integral to the implementation of a standard.

Once adopted, the new policy will be used to complete a thorough review of Australia’s
differences. All differences to standards and significant recommended practices will then be
notified to ICAO in a single document.

Note: The policy also includes a regular review of differences followed by any required notification to ICAO, to be coordinated by the Department of Infrastructure, Transport, Regional Development and Local Government (Department of Infrastructure).

- Infrastructure By 31 October 2008

Following the notification of all differences to ICAO, Australia will update its AIP to reflect all notified differences and those relating to PANS. - Airservices Australia - By 30 November 2008

Each relevant agency will also develop, document and implement a process for critically assessing proposed amendments to the SARPs to support the differences policy and procedures. These processes will ensure that amendments are adopted as appropriate, or a difference is notified, in a timely manner. - CASA, Airservices Australia, ATSB, BOM, AMSA - By 31 January 2009

Now let's fast forward to the here and now, first of all we had the exchange between the ICAO permanent rep Sam Lucas and Kaz Casey who AP supported with this: ref - Obfuscation of ICAO - A how to?

Quote:"...In general, it must be stated that the Australian Civil Aviation Safety Authority (CASA) has an unique approach to ICAO compliance, with record number of ‘notified differences’..."

Further to the embarrassing - - number of Australian notified differences to the ICAO SARPs it is worth referring again to my previous post and the DoIRD submission to the Parliamentary JSCOT inquiry into the Serbia/Vanuatu Airservices agreements/treaties: Post #8

And again referring to that table for the JSCOT inquiry:

Quote:Coming back to that 'categories of differences' table:

My hope is that due to Senator Fawcett's questioning and in collating that data for the sup submission, the Department may have suddenly come to the realisation that Australia is far from being anywhere near adhering to the spirit and intent of most of the ICAO SARPs.

It is worth noting that of the listed 10,696 notified differences from the three countries, 4024 were from Australia, this is a disturbing 38% of the total. But what is more disturbing is the figure in the 'Less protective or partially implemented or not implemented' category (in other words the 'up yours' category... ), which was an UDB 2078, compared to 41 Serbia & 9 Vanuatu...

4024 notified differences for Australia?? Recently I had collated from the 2015 AIP GEN 1.7 SUP that notified differences had grown to a total of 3116. However in actual fact between the 2011 SUP the figure had grown to 4024 but due to the loose ICAO arrangement of only listing NDs every 3 years this was missed. So from my approximate estimate from 2011 to 2014 the NDs had grown by 2500.

This means that in actual fact in the period between 10 February 2014 till November 2015 the Department has managed to reduce the notified differences by 908.

Still got a long way to go but perhaps this highlights more than anything else the impact that the Senator Fawcett inquisition had way back on the 10 February 2014...

What followed then was Sam Lucas handballed to the Dept minion Lachie which led to my still unreplied - Dear Lachie correspondence?? However since that JSCOT inquiry I was under the (unfortunately false) impression that after 30 years of obfuscating the Dept, Iron Ring and agency minions were endeavouring to reduce the total number of notified differences. However after the tabling at the last Budget Estimates - ref: Barry O, Mr McFixit and the ICAO snowjob - evidence would appear to be the opposite (see attach A table above). - Dodgy

Which finally brings me to this passage of Hansard from the Cloncurry Senate (Air routes) inquiry public hearing - Reference Senate Estimates: Winton/Cloncurry Hansard; & tabled docs.

Quote:ACTING CHAIR: This committee's bailiwick is to do with aviation. We are very alive to the issues around CASA, less so around the ATSB. Let's not flinch: they're not CASA's regulations; they're the government's regulations that are often recommended by CASA. We're aware of the current impacts on general aviation with new CASA regulations, the shortage of pilots and the maintenance issue with licensed aircraft maintenance engineers and the like. We as a committee have called for some figures—and I don't know if Ms Redden is in a position to update us. We want to look at comparisons with international standards. The FAA has done an audit on CASA in Australia. I understand it's going to be interesting reading. They're resisting publication of that at the moment. We're trying to muddle our way through getting that out into the open. So we're very alive, to the point where we have contemplated out loud whether we will hold an inquiry such as this into this regulatory environment—not just the operation of CASA but by extension the impact that that is having on general aviation.

We conducted an audit of the OneSKY program. You might be familiar with that, where we are changing the platform for air traffic control. That absorbed quite an amount of this committee's energy for about 18 months. But I suspect there's nothing new you can tell us about CASA—their popularity or otherwise—and about what people see as arrogance and sometimes an abuse of power. With the ATSB there is not so much. They're in a quite respected cycle of their lives. We are alive to it all. We are contemplating week by week as to whether we'll have an inquiry. If it gets to a point where this evidence that we've called for shows us that it's critical, we'll conduct an inquiry like this and may find ourselves back in Cloncurry—or Mount Isa next time, probably—to hear evidence of its impact, particularly on rural aviation...

So after the evidence of nearly 3 decades (see above) of taking the 'Mickey Bliss' on compliance and relative harmonisation with the ICAO SARPs:
QON - why is the committee whose 'bailiwick is to do with aviation' not holding the aviation safety bureaucracy to account? And how can the Iron Ring resist publication of the ICAO audit report? Finally why isn't a certain independent Senator requesting a copy of that report, either via the FOI or Senate order?

P2 comment: And if people are under the misbleief that under the new CMA USOAP system that an ICAO audit no longer requires a proper summary audit report think again- refer to this ICAO powerpoint presentation link:

From pg 9:

Phase 3 ― Validation and Report Production (Post-audit/ICVM) • ICAO forwards draft audit report to State. • State submits comments and Corrective Action Plans (CAPs). • Comments are incorporated into final audit report. • Final audit report is published on USOAP CMA Online Framework (OLF): www.icao.int/usoap.

And pg 27-28:

IV. Timeline of Validation and Report Production Phase (Post Audit/ICVM)

[Image: USOAP-1.jpg]

And if the Dept et.al are still waiting for the final report, the question will be - what the hell is the delay?? Dodgy

MTF...P2

P7's two bob - Bloody good work P2 - first class. Perhaps we can get the issue raised by Mike Smith at the Wagga pow-wow. Have a choc frog mate...My shout next time around..

Cool

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Peetwo - 06-11-2018

Three decades of Australia taking the piss out of ICAO - Part II

P7 said: "...Perhaps we can get the issue raised by Mike Smith at the Wagga pow-wow. Have a choc frog mate...My shout next time around..."

Bloody good idea Ol'Tom, after all (according to the MS CV) there is no more informed independent Aussie ex-pat that knows the inner workings of FAA's IASA program than Mike Smith... Rolleyes

Quote from AvMassi promo for MS: ref - http://www.avmassi.com/about-us/our-team/mike-smith.html

Quote:...Since leaving the Australian Civil Service, Mike has been engaged as a senior consultant by airlines and aviation regulators around the world, predominantly advising clients in the areas of regulatory reform, ICAO USOAP and FAA IASA compliance and the introduction of Safety Management Systems and risk based oversight principles into their organizations. Recent clients include the World Bank and the civil aviation administrations of Singapore, the UAE, Nigeria and Bahrain. Mike led the World Bank funded program that gained IASA category one status for Nigeria in 2010, allowing that country’s airlines to operate to the USA. Nigeria remains one of only six African nations to hold that status...

I have no doubt that MS will have a passing interest in some of the seriously deluded and disconnected correspondence recently tabled with the Senate RRAT committee in Estimates hearings from the Dept.

For example from the Secretary to the Dept:

And tabled from - the latest - Mr McFixit at Budget Estimates:

So according to Lachie ...

Quote:..Australia was assessed in October 2017 by ICAO auditors and while the results are yet to be made public it places Australia in the top 10 States for safety oversight compliance...

...and the Dept Secretary (see above) the results, which presumably means the report, were due to be published (February 2018) publicly by now. These results/report are important as they will go to the veracity of the Carmody/Dept Secretary/Mr Mc'Fixit/Lachie proclamations of all's good in Dodge City - Undecided

This brings me to an historical reference blog - posthumously from Ben Sandilands Angel

- which is still unfortunately very relevant to our international involvement with ICAO and our regional aviation member states - Confused

: reference Herbert D Ray submission #47 to the Forsyth (ASRR) review.

Quote:US rehabilitates Israeli air safety, a lesson for Australia

Ben Sandilands | Nov 02, 2012 8:05AM | EMAIL | PRINT

The US Federal Aviation Agency’s rehabilitation of Israel as a Level 1 state in relation to air safety ought to be read as the clearest of warnings to Australia to get its act together without delay.

If Australia is busted down to Level 2, which on the evidence, it should be, the consequences include the prohibition under US law of code shares between Australian flag carriers and those of America.

The managements of Qantas and Virgin Australia need to carefully consider what losing their respective code share deals with American Airlines and Delta would mean, and ask whether the craven acceptance of the dismal state of affairs in CASA, the ATSB and AirServices Australia is worth the damage such a downgrade would inflict on their shareholders, employees and commercial reputations.

When Israel flouted its responsibilities and was busted for almost four years, it failed to lobby its way out of trouble, which was quite surprising. But as Wikileaks showed earlier this year, when Australia provisionally failed the necessary audits to retain Level 1 status, our lobbying efforts saved the day.

Since then matters if judged by recent events, have gone backwards in CASA, the ATSB and AirServices Australia, and the risk of a safety downgrade and all of its commercial consequences should be treated (as it may already be in high places) as being severe and imminent.

This is the FAA statement concerning Israel, released overnight:

WASHINGTON, D.C. – The U.S. Department of Transportation’s Federal Aviation Administration (FAA) today announced that Israel complies with international safety standards set by the International Civil Aviation Organization (ICAO), based on the results of an October FAA review of Israel’s civil aviation authority.

Israel is now upgraded to Category 1 from the Category 2 safety rating the country received from the FAA in December 2008. Israel’s civil aviation authority worked with the FAA on an action plan so that its safety oversight system fully complies with ICAO’s standards and practices.

A Category 1 rating means the country’s civil aviation authority complies with ICAO standards. A Category 2 rating means a country either lacks laws or regulations necessary to oversee air carriers in accordance with minimum international standards, or that its civil aviation authority – equivalent to the FAA for aviation safety matters – is deficient in one or more areas, such as technical expertise, trained personnel, record keeping or inspection procedures

With the International Aviation Safety Assessment (IASA) Category 1 rating, Israeli air carriers can add flights and service to the United States and carry the code of U.S. carriers. With the Category 2 rating, Israeli air carriers were allowed to maintain existing service to the United States, but could not establish new services

As part of the FAA’s IASA program, the agency assesses the civil aviation authorities of all countries with air carriers that operate or have applied to fly to the United States and makes that information available to the public.

The assessments determine whether or not foreign civil aviation authorities are meeting ICAO safety standards, not FAA regulations

In order to maintain a Category 1 rating, countries with air carriers that fly to the United States must adhere to the safety standards of ICAO, the United Nations’ technical agency for aviation that establishes international standards and recommended practices for aircraft operations and maintenance.

This is the situation in Australia, in terse form:

CASA is accused in multiple places, including under parliamentary privilege before the Senate, of conspiring with the ATSB, to withhold vital safety information contrary to the provisions of the Transport Safety Information Act of 2003 in order to protect the reputation of operator Pel-Air in relation to the ditching of one of Westwind jets off Norfolk Island in 2009, in the final report into the crash published by the ATSB on 30 August.

The ATSB has admitted that the report is not one it can be proud of, through its chief commissioner Martin Dolan, and the general manager, air safety investigations, Ian Sangston, deposed that he didn’t even know what safety questions had been asked of the survivors, but signed off on a report that did not even say whether the safety equipment on the jet worked. (It didn’t.)

AirServices Australia has recently lost at least two airliners in Australian controlled airspace, and in the case of the Virgin Australia 737 that it lost track of for most of the way between Sydney and Brisbane, lied about to the media, and has not addressed evidence that the notification of the incident to the ATSB was so inaccurate in the first instance that it had to be amended after the fact.

There are many more areas of administrative and competency failures, as regular readers of Plane Talking would be aware.

The damage the situation in CASA, the ATSB and AirServices Australia can do to life, property and the economic interests of this country are considerable. They are conveniently ignored in the general media and public life. The inconvenience that will arise without determined and urgent corrective action cannot be understated.

Coming back to the Herbert D Ray submission, although somewhat disjointed it provides an historical insight into the 30+ year disconnection between the metamorphosis of the big 'R' regulator from the real world of aviation safety and international aviation regulation harmonisation.

Extract from HD Ray submission:

Dear Sir,

The purpose of this submission is to respectfully draw the attention of the ‘Senate Standing Committee on Rural and Regional Affairs and Transport (the Committee) to the effects of the ‘Clipping our Wings’ submission questioning the government ‘Where in all the World is our International Civil Aviation law- ?’

This complimentary submission argues a vital consequence of not ‘safety regulating’ compliant with the requirements contained in the Convention on International Civil Aviation which establishes delinquent operational matters and consequences attributed to by the airworthiness matters and consequences as regulated by FAR sterile national law standards and practices not recognized by FAR harmonized international civil aviation law and that laws standards and practices.

Our FAR sterile National Civil Aviation laws do not provide an equivalent ‘internationally acceptable standard of safety’ for persons traveling in VH aircraft transiting in national and international airspace as is afforded those persons traveling in aircraft registered in up to 870+ compliant ICAO Treaty States that are safety regulated compliant with the requirements of the Convention on International Civil Aviation and that Convention’s safety standards and practices.

Our National Civil Aviation regulations have never been audited by an ICAO Universal Safety Oversight Program (USOP) audit team as being classed as other than a ‘Non compliant ICAO Treaty State’

The US should ‘rehabilitate’ CASA’

The attached article “US rehabilitate Israeli air safety, a lesson for Australia” CASA was identified in a “Wikileaks document which showed late last year, that
Australia provisionally failed the necessary audits to retain Level 1 status, our lobbying efforts saved the day.”

Our national civil aviation laws have been consistently audited by the ICAO USOP teams as Australia being a non compliant ICAO Treaty State which by default qualifies our air carriers as FAA category 2 operators.

“A Category 2 rating means a country either lacks laws or regulations necessary to oversee air carriers in accordance with minimum international standards, or that its civil aviation authority – equivalent to the FAA for aviation safety matters – is deficient in one or more areas, such as technical expertise, trained personnel, record keeping or inspection procedures”

Maintaining the ICAO USOP audit findings as a ‘non compliant ICAO Treaty State and an FAA category 2 ‘safety regulator’ means our safety regulation laws are not compliant with the minimum international standards for the certification of aerospace products, which the submission ‘Clipping our Wings’ described, including a lack of technical expertise, trained personnel and inspection procedures, all elements mirrored by the FAA to qualify Israeli air carriers as ‘category 2’ operators.

Our national civil aviation laws are ICAO USOP audited and are in principle found to be not compliant with the requirements of the Convention on International Civil Aviation.
CASA as a ‘safety regulator’ does not provide an equivalent ‘level of safety’ for persons traveling in VH aircraft transiting in national and international airspace as is afforded those persons traveling in aircraft safety regulated compliant with the requirements of the Convention on International Civil Aviation and that Conventions FAR harmonized safety standards and practices.

An FAA category 2 rating on our national air carriers both RPT and GA will have a devastating economic effect on the entire VH aerospace industry, as GA operator’s contract in foreign States and must maintain the diplomatically engineered FAA category 1 level to operate in compliant ICAO Treaty States airspace.

We are operating in foreign airspace as ICAO/FAA category 1 operators, hinged on ‘diplomatic camerade’ and this will surely ‘unhinge’.

The 1999 ICAO USOP audit ‘findings’ noted ‘ that an MOU had been signed between Australia and ICAO to resolve a raft of primary and civil aviation legislation delinquencies and CASA should review the requirements contained in its Regulation and Orders to ensure full conformance with the Standards and Recommended Practices (SARPs) contained in Annexes 1, 6 and 8.

The 1996 USOP audit findings also noted that in June 1996, the Regulatory Framework Program (RFP) office of CASA(as directed by the Program Advisory Panel) commenced a Government endorsed review and revision of the Australian aviation safety requirements currently contained in the Civil Aviation Regulations (CARs) and the Civil Aviation Orders (CAOs). The proposed new legislation is to be called the Civil Aviation Safety Regulations (CASRs).

The ‘findings noted that “the future CASR Parts will ensure, ensure Australian regulations FAR harmonize with international standards and practices?

The ICAO USOP audit teams consistently ‘find’ Australian regulations do not FAR harmonize with international standards and practices and neither does the FAA ‘find’ a VH TC’d aircraft is returned to service compliant with FAA design standard law, and those laws instructions and orders that constitutes ICAO USOP ‘international standards and practices !

In 2004 CEO Bruce Byron’s unauthorized withdrawal of the Program Advisory Panel CASR /FAR sequenced Part 43/66/145 and 147 maintenance, licensing and training rules compliant with our ICAO USOP MOU and our treaty pledge and Article 37 of the Convention rules and those rules replacement with the FAR sterile CAR 1988 Part 1 and CASR Part 42/66/145 and 147 maintenance, licensing and training rules, are not compliant with our ICAO Treaty pledge nor are they Article 37 of the Convention compliant or correlated with international civil aviation laws and that laws standards and recommended practices.

If our civil aviation airworthiness laws are not article 37 compliant with the ICAO treaty States regulated compliant with the requirements of the Convention on International

Civil Aviations simply put we will never be classed as a ‘Compliant ICAO Treaty State’
Subsequent ICAO USOP audits have maintained Australia as a ‘non compliant ICAO Treaty State exacerbated by CASA being established as serially dishonoring promises to regulate to international ICAO USOP ‘Standards and Recommended Practices (SARP’s) and reneged on the 1999 promise ICAO USOP audit promise” “the future CASR Parts will ensure, ensure Australian regulations FAR harmonize with international standards and practices.

The ‘Summary ‘ duplicates the same ‘resolutions’ as ‘Clipping our Wings’ but maybe should include ‘The US should ‘rehabilitate’ CASA’ -to maintain a ICAO/FAA category 1 rating.?
The ICAO USOP audits findings display similar CASA non compliances with USOP SARP’s etc as the level 2’d Israeli air carriers!

Summary

We believe that it is a responsibility of ‘the Committee’ to ensure ‘Constitutional’ matters that vest a power to the parliament to promulgate legislation must be seen to make laws that are appropriate to meet those Constitutional obligations and responsibilities as pledged as an ‘ICAO Treaty State’

The government has entrusted a ‘rulemaking power to CASA who have serially dishonored Treaties, MOU’s, Charters and Pledges, made to the ICAO USOP audit teams to harmonize to airworthiness international standards, by taking the questionable privilege of submitting national airworthiness legislation to our parliament that is in conflict with the terms and conditions of matters our government has contracted to uphold as a Constitutional Section 51 (XXIX) ‘External Affairs’ instrument to be a compliant ICAO Treaty State regulated to FAR harmonized International Civil Aviation law.

The withdrawing of the PAP harmonized CASR/FAR Part 43/66/145/147 universal rules and the ‘putting‘ of national airworthiness legislation that is in conflict with the ICAO Treaty and absolves CASA of its international ‘safety oversight regulator ‘ responsibilities can be argued as being ‘unconstitutional law’.

The options the government should consider in resolving the ‘matter’ of CASA’s airworthiness ‘safety oversight’ management that jeopardizes ‘Safer Skies for All’ includes:

First and foremost

- Separating CASA’s ‘rule making power’ and resume the Program Advisory Panel of Industry experts. CASA can’t be trusted!
- Sack the CASA board and replace it with a ‘non partisan’ board with the ‘best interests’ of the nation at heart! –We don’t want any more ‘sword falling’ invitations for FAR harmonizing CEO’s!
- Revoking 1988 CARS and CAR 42/CASR Part 42 and Part 145 as the CAR 1988 PART 1 (2) dysfunctional behavior creating illegal CASA approved maintenance instructions permeates through CASR Part 42 and Part 145 and cannot positively contribute to ‘safer skies for all’
- Revoking the CASR Part 66 and Part 147 as these rules do not harmonize with the standards and values of either the **FAA or EASA rules.
- Australia should either resurrect the PAP FAR harmonized CASR 43/66/145/147 rules or adopt the NZCAA internationally recognized rules expanding the significant ANZA mutual operational agreement to include the NZCAA maintenance and personnel rules which are seen as the most cost efficient resolution to CASA’s perpetual and costly development of misaligned rules.
- The possibility of presenting the ANZA mutual operational agreement, and expanding the agreement to include maintenance and personnel as the SW Pacific Aviation Safety Agency (SWPASA) would be in line with our joint Trans Tasman Trade agreement principles should be held in view.
- Adapting the NZCAA rules ‘would be more cost effective than harmonizing CASA’s present costly and dysfunctional EASA agenda CAR 1988 and CASR 42/66/145/147 national rules with the EASA system and its guidance material , which favors the ‘big end of town’ at the expense of the ‘little end of town’.
- The transitioning of AME’s who may still hold ICAO Annex 1 license(Diamonds), to the NZCAR 66 AME license is preferable to transitioning to CASR 66 licenses as these are not ICAO Annex 1 rated. (Lemons)
- To overcome CASA’s skill resources dilemma CASA should contract industry IoA holders that specialize in design conformity inspections for C of A issues, and experienced LAME’s (retired) qualified to carry out this RTS function on CASA’s behalf until those LAME/ AWI’s in CASA’s employ receive re currency training. The ADF AW staff will need to obtain AME licenses and civil experience
or
- The government give consideration to extending the MRO industry’s present ‘self regulatory ‘ role to act as a ‘maintenance and AME licensing ‘safety oversight program regulator’ to administer the FAR harmonized ‘maintenance and AME licensing rules on behalf of the government supported by a resurrected ‘Program Advisory Panel’
- As noted adopting the NZCARS is popular with other NAA’s – and is the most cost effective solution to CASA’s skill based AW rules dilemma.
- Having FAR harmonized maintenance and AME personnel rules will see a pleasant change with the ICAO USOP audits finding Australia a ‘compliant ICAO Treaty State’ instead of findings to date of being a ‘non compliant ICAO Treaty State’ and our CAR form 1 ARCs being rated on a par with an **FAA 8130-3 ARC the global airworthiness certification standard

 It will be a pleasant change from being internationally recognized as a ‘lemon’!

Unfortunately for H.D.Ray et.al it would appear that our committee has been lost to the self-interested political survival of a totally disconnected National party... Confused

This was the observed attitude (former Senator Edwards) of the committee then (i.e prior to O'Obfuscation):

Compare that to this recent totally 'soft cock' performance from the Senate RRAT committee headed up by a QLD LNP powerbroker:

&..

No comment required me'thinks... Dodgy

MTF...P2