AMROBA. - Printable Version

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AMROBA. - P7_TOM - 11-09-2015

AMROBA – from the same hymnbook.  Essentially the same message as the erstwhile De Stoop.  

Common sense and expert opinion - HERE - all ignored of course.  

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RE: AMROBA. - Peetwo - 11-10-2015

From off the Rev Forsyth's thread  :

(09-03-2015, 09:39 AM)Peetwo Wrote:  [b]

AMROBA - Who cares??[/b]

Saw the following from off the AMROBA site, thought it needed some exposure and where better to put it than on the Reverend Forsyth's thread - Why? Well IMHO he is one of a minority who truly does care...   

Quote:

Also in a much easy on the eye format AMROBA's latest newsletter is IMO very much required reading  

Quote:Volume 12 Issue 8 August — 2015

Table of Contents

1. Resurrecting General Aviation — Deregulating GA

2. Is a Modified USA FBO system the Answer?

3. AME Training

4. The Role of the LAME

Well done KC & the AMROBA band..

However - except for bogus weasel-worded corporate plans, that say lots but mean nothing - the deathly silence from the Miniscule's office, his department & Murky's yes-men stooges (Skidmore, Harfy & Beaker) is deafening - could someone check if the Miniscule has a pulse??
   

&..

Quote:KC & the AMROBA Band - Latest newsletter


A how to set the Forsyth review report & recommendations in stone...

Quote: Wrote:1. Implementing permanent change

Without doubt, there has been almost unanimous support in the aviation industry for the recommendations of the ASRR report. The government and industry obviously support these recommendations, so when will the Department of Infrastructure & the CASA Board initiate changes to the Civil Aviation Act to implement these recommendations permanently? The Board and Infrastructure must recommend changes to change the regulatory style.


The Act must be amended to implement the government supported ASRR recommendations.

The Act was rushed together to create the CAA back in 1988 and has a series of ad hoc amendments. NZ realises that after 20 years, the Act should be reviewed so when will Australia set up a review of the Act against international treaties and applicability to the current aviation industry.

CASA & aviation continually have review after review with no permanent result – regulatory review has been under way since the formation of the CAA in 1988. The rest of the aviation world are modernising their requirements utilising performance based regulations & standards and utilising a risk based approach. The USA are well ahead of Australia as we implement draconian requirements of the past. Changes must happen.

Many businesses that have spanned a few regimes of CASA and its predecessors, are not confident that permanent change will happen until the government support and direction to the CASA Board & DAS is given legislative support in the Act. We need a DAS reportable to the Board and a Board reportable to the Minister. The Board must be held fully accountable.

Act – Duties (1) The Director is to manage CASA subject to the directions of, and in
accordance with policies determined by, the Board.

Subject to the directions of, and iaw policies determined by the Board.

For the Board to direct and provide policies to implement the government ASRR recommendations, then they need to recommend a review of the Act, especially the following sections of the Act:

Sec 3A - [i]Main object of this Act[/i]

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

Compare with NZ who are also reviewing their Act: While the [NZ] Act is fundamentally sound, the Act is over 20 years old and during this period there have been a number of changes in the aviation industry. The Ministry wants to make sure the Act promotes a responsive regulatory system to support a dynamic aviation sector.

[NZ] Objectives of Minister

The objectives of the Minister under this Act are—

(a) to undertake the Minister's functions in a way that contributes to the aim of achieving an integrated, safe, responsive, and sustainable transport system; and (b) to ensure that New Zealand's obligations under international civil aviation agreements are implemented.

NZ is reviewing their Act after 20 years and we have had no review after 27 years.

Sec 9 CASA’s functions

(1) CASA has the function of conducting the safety regulation of the following, in accordance with this Act and the regulations:

© developing and promulgating appropriate, clear and concise aviation safety standards;

The ASRR clearly identified that this provision should be clarified; consistent with the Convention, compatible with other major NAAs, including NZ.

In AMROBA’s opinion, CASA has never promulgated “clear and concise aviation safety standards ” under this provision of the Act. All current “standards” are issued under the Regulations.

All future “standards” should be made under the Act and undergo full Parliamentary oversight.

Sec 20AB Flying aircraft without licence etc.

Provision in this section is seen as supporting prescriptive regulations – needs to be modernised.

(2) A person must not carry out maintenance on:

(a) an Australian aircraft; or

(b) an aeronautical product in Australian territory; or

© an aeronautical product for an Australian aircraft; if the person is not permitted by or under the regulations to carry out that maintenance.

The word “that” can be interpreted very narrowly.

Sec 98 Regulations etc.

(1) The Governor-General may make regulations, not inconsistent with this Act:

(a) prescribing matters required or permitted by this Act to be prescribed;

(b) prescribing matters necessary or convenient to be prescribed for carrying out or giving effect to this Act;

© for the purpose of carrying out and giving effect to the provisions of the Chicago Convention relating to safety;

(d) in relation to safety of air navigation within a Territory or to or from a Territory;

(e) in relation to safety of air navigation, being regulations with respect to trade and commerce with other countries and among the States; and

(f) in relation to safety of air navigation, being regulations with respect to any other matter with respect to which the Parliament has power to make laws.

Compare with the FAA responsibilities for minimum standards.

USA Title 49. Sec. 44701. General requirements

(a) Promoting Safety. - The Administrator of the Federal Aviation Administration shall promote safe flight of civil aircraft in air commerce by prescribing -

(1) minimum standards required in the interest of safety for appliances and for the design, material, construction, quality of work, and performance of aircraft, aircraft engines, and propellers;

(2) regulations and minimum standards in the interest of safety for -

(A) inspecting, servicing, and overhauling aircraft, aircraft engines, propellers, and appliances;

(B) equipment and facilities for, and the timing and manner of, the inspecting, servicing, and overhauling; and

© a qualified private person, instead of an officer or employee of the Administration, to examine and report on the inspecting, servicing, and overhauling;

(3) regulations required in the interest of safety for the reserve supply of aircraft, aircraft engines, propellers, appliances, and aircraft fuel and oil, including the reserve supply of fuel and oil carried in flight;

(4) regulations in the interest of safety for the maximum hours or periods of service of airmen and other employees of air carriers; and

(5) regulations and minimum standards for other practices, methods, and procedure the Administrator finds necessary for safety in air commerce and national security.

The concept that CASA has to create regulations and standards without stating they should be the minimum regulations and standards is a major reason why regulatory reform is treated as regulatory development by CASA staff.

The above are but a few examples – a complete review is warranted.

Cheers & MTF..P2

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RE: AMROBA. - Peetwo - 11-13-2015

AMROBA written submissions to the Forsyth Review:

Quote:1 Aircraft Maintenance Repair and Overhaul Business Association Inc (AMROBA) - PDF: 149 KB


&..

8 Aircraft Maintenance Repair and Overhaul Business Association Inc (AMROBA) - [url=]PDF: 1411 KB

Quote:Executive Summary

Aviation has been in a state of change ever since government created, in 1988, a
separate aviation safety regulator to operate on economic principles and the
creation of an independent air accident bureau. This followed a 1987 Parliamentary
Report on aviation safety regulation and sport aviation safety. Twenty five years on
and there is still no final legislative system meeting global standards?

The international and national allocation of responsibilities for safety of the safety
regulator, air accident bureau and industry, are obviously still not clarified in the
legislative system that is being imposed.

The ‘objectives’ of multiple aviation reviews, post 1988, that the aviation industry
has been subject to, have never achieved clarity of purpose, and never will, until
the Civil Aviation Act is part of what must be reviewed. Bench-marking the
legislative structure against other mature aviation countries, then amending
accordingly to implement an effective aviation system applicable to the
complexities of Australia’s aviation activities and also compliant with the applicable
Articles of the Convention on International Civil Aviation, must be done.

The Act must enable governments to make Parliamentary Regulations directing the
Civil Aviation Safety Authority (CASA) to promulgate [civil] aviation safety standards
(CASS); standards developed by adapting and/or creating global [civil] aviation
safety standards.

The promulgation of CASSs must be the responsibility of CASA but the Act must
also require those CASSs to be adapted from the Annexes to the Convention on
International Civil Aviation, comparable with North America and European Aviation
Regulators’ promulgated safety standards (Regulations/Standards) with minimal
differences with our closest trading countries, New Zealand and Papua New Guinea.

Until the Civil Aviation Act has an objective that will see the development of aviation
safety requirements to support a safe and sustainable aviation industry, there will
not be overall growth in a safe and sustainable air transport system for all. The
current ‘Main Object’ of the Act works against safe growth in some sectors.
Aviation safety is based on continual review of past decisions, recognising which
decisions have had positive effects and which decisions have had negative effects.

The regulatory reform has been continual since 1989 and industry has had to
continually change their business model. The problem is today, the change process
itself introduces risk elements to safety. Many participants in this industry have
only known an industry undergoing regulatory change and this continual change
imposes confusion, a regulatory imposed risk that has to be managed.

Rewriting the Civil Aviation Act and a three-tier system will enable the regulatory
reform process to be completed within 3 years.

Ken Cannane Dated: 1st January 2014
Executive Director
AMROBA
www.amroba.org.au
Safety All Around

AMROBA Comments/Response to Foryth Review Final Report & recommendations:

Quote:Aviation Maintenance Repair and Overhaul Business Association Inc (AMROBA) [PDF: 245 KB]

Quote:Summary.
AMROBA strongly supports the thrust of these recommendations as above. Considering the number of previous aviation reports and previous recommendations, AMROBA members are of the opinion that these recommendation, if adopted, are not worth the cost of the review unless the Minister amends the Civil Aviation Act to permanently implement these recommendations. See attached Annex.

Though the reports mentions on page 31 that the Department should bear responsibility
to deliver sound and effective policy direction in pursuit of a safe, secure and sustainable aviation industry in Australia, little else addresses the cost/benefit approach to regulatory development. Our assumption is that the Panel assumes cost/benefits are a subset of being a sustainable industry.

The reason why the current dysfunctional system has been created must be sheeted home to the philosophies of the current Board and CASA Executive. The report clearly identifies that it is not an individual sector, association, airline or organisation that has an issue but industry sees it as a systemic problem with the aviation environment.
Australia has a mature aviation industry with a good safety record that was built on a
safety partnership between the Department and industry. Transferring to an enforcement compliance approach, instead of a safety compliance approach has not been successful except for closing down many aviation participants.

Ken Cannane
On behalf of AMROBA Members
Phone: (02) 97592715
Fax: (02) 97592025

Finally the all important Annex to the above:




MTF...P2

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RE: AMROBA. - Peetwo - 11-17-2015

Latest from AMROBA 17/11:





Cheers KC & AMROBA...

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RE: AMROBA. - Peetwo - 11-26-2015

KC & the AMROBA band today - Courtesy Oz Flying

Quote:
An engineer works on a turbine engine at a maintenance, repair and overhaul (MRO) base. (Steve Hitchen)



AMROBA reinforces Calls for Act Change
26 Nov 2015

Aviation Maintenance, Repair and Overhaul Business Association (AMROBA) Executive Director Ken Cannane has issued a call for the Civil Aviation Act to be changed to enshrine Forsyth reforms permanently.

In a newsletter released earlier this month, Cannane said the hard-won reforms needed to be made permanent once implemented.

"Without doubt, there has been almost unanimous support in the aviation industry for the recommendations of the ASRR(Forsyth) report," Cannane said. "The government and industry obviously support these recommendations, so when will the Department of Infrastructure and the CASA Board initiate changes to the Civil Aviation Act to implement these recommendations permanently?

"The [CASA] Board and [Department of] Infrastructure must recommend changes to change the regulatory style. The Act must be amended to implement the government supported ASRR recommendations.

According to Cannane, the Act badly needs an overhaul if we are to avoid another round of reviews into the function of CASA.

"The Act was rushed together to create the CAA back in 1988 and has a series of ad-hoc amendments. NZ realises that after 20 years, the Act should be reviewed, so when will Australia set up a review of the Act against international treaties and applicability to the current aviation industry?

"CASA and aviation continually have review after review with no permanent result – regulatory review has been under way since the formation of the CAA in 1988. The rest of the aviation world are modernising their requirements utilising performance based regulations and standards and utilising a risk based approach.

"The USA is well ahead of Australia as we implement draconian requirements of the past. Changes must happen. Many businesses that have spanned a few regimes of CASA and its predecessors, are not confident that permanent change will happen until the government support and direction to the CASA Board and DAS is given legislative support in the Act."

AMROBA has been active in trying to mitigate issues arising out of CASR Part 145 (maintenance organisations), which resulted in the Manual of Standards being disallowed in the senate in March this year. According to Senator Nick Xenophon, had the MoS been allowed, it may have made it illegal for engineers to do maintenance they'd been doing safely for years

Hitch it should be remembered that NX was not the only legally qualified person with that view: Walker Special Maintenance Opinion.pdf 
MTF..P2  

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RE: AMROBA. - Peetwo - 11-30-2015

(11-26-2015, 06:45 PM)Peetwo Wrote:  KC & the AMROBA band today - Courtesy Oz Flying

Quote:
An engineer works on a turbine engine at a maintenance, repair and overhaul (MRO) base. (Steve Hitchen)



AMROBA reinforces Calls for Act Change
26 Nov 2015

Aviation Maintenance, Repair and Overhaul Business Association (AMROBA) Executive Director Ken Cannane has issued a call for the Civil Aviation Act to be changed to enshrine Forsyth reforms permanently.

In a newsletter released earlier this month, Cannane said the hard-won reforms needed to be made permanent once implemented.

"Without doubt, there has been almost unanimous support in the aviation industry for the recommendations of the ASRR(Forsyth) report," Cannane said. "The government and industry obviously support these recommendations, so when will the Department of Infrastructure and the CASA Board initiate changes to the Civil Aviation Act to implement these recommendations permanently?

"The [CASA] Board and [Department of] Infrastructure must recommend changes to change the regulatory style. The Act must be amended to implement the government supported ASRR recommendations.

According to Cannane, the Act badly needs an overhaul if we are to avoid another round of reviews into the function of CASA.

"The Act was rushed together to create the CAA back in 1988 and has a series of ad-hoc amendments. NZ realises that after 20 years, the Act should be reviewed, so when will Australia set up a review of the Act against international treaties and applicability to the current aviation industry?

"CASA and aviation continually have review after review with no permanent result – regulatory review has been under way since the formation of the CAA in 1988. The rest of the aviation world are modernising their requirements utilising performance based regulations and standards and utilising a risk based approach.

"The USA is well ahead of Australia as we implement draconian requirements of the past. Changes must happen. Many businesses that have spanned a few regimes of CASA and its predecessors, are not confident that permanent change will happen until the government support and direction to the CASA Board and DAS is given legislative support in the Act."

AMROBA has been active in trying to mitigate issues arising out of CASR Part 145 (maintenance organisations), which resulted in the Manual of Standards being disallowed in the senate in March this year. According to Senator Nick Xenophon, had the MoS been allowed, it may have made it illegal for engineers to do maintenance they'd been doing safely for years

Hitch it should be remembered that NX was not the only legally qualified person with that view: Walker Special Maintenance Opinion.pdf 

From AMROBA latest Newsletter - Volume 12 Issue 11




MTF...P2

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RE: AMROBA. - Gobbledock - 11-30-2015

Well said Ken well said. The Act, or should that be 'the Act of bastardry' needs to change. Strict liability needs to change. Until Dr Voodoo's personal toy is taken away from him,industry, CAsA and the senate will continue this same ludicrous tango that we've been dancing for decades.
And
Many of us have very worn out shoes and are tired of the same Waltz.

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RE: AMROBA. - Peetwo - 11-30-2015

(11-30-2015, 07:20 AM)Peetwo Wrote:  

(11-26-2015, 06:45 PM)Peetwo Wrote:  KC & the AMROBA band today - Courtesy Oz Flying

Quote:
An engineer works on a turbine engine at a maintenance, repair and overhaul (MRO) base. (Steve Hitchen)



AMROBA reinforces Calls for Act Change
26 Nov 2015

Aviation Maintenance, Repair and Overhaul Business Association (AMROBA) Executive Director Ken Cannane has issued a call for the Civil Aviation Act to be changed to enshrine Forsyth reforms permanently.

In a newsletter released earlier this month, Cannane said the hard-won reforms needed to be made permanent once implemented.

"Without doubt, there has been almost unanimous support in the aviation industry for the recommendations of the ASRR(Forsyth) report," Cannane said. "The government and industry obviously support these recommendations, so when will the Department of Infrastructure and the CASA Board initiate changes to the Civil Aviation Act to implement these recommendations permanently?

"The [CASA] Board and [Department of] Infrastructure must recommend changes to change the regulatory style. The Act must be amended to implement the government supported ASRR recommendations.

According to Cannane, the Act badly needs an overhaul if we are to avoid another round of reviews into the function of CASA.

"The Act was rushed together to create the CAA back in 1988 and has a series of ad-hoc amendments. NZ realises that after 20 years, the Act should be reviewed, so when will Australia set up a review of the Act against international treaties and applicability to the current aviation industry?

"CASA and aviation continually have review after review with no permanent result – regulatory review has been under way since the formation of the CAA in 1988. The rest of the aviation world are modernising their requirements utilising performance based regulations and standards and utilising a risk based approach.

"The USA is well ahead of Australia as we implement draconian requirements of the past. Changes must happen. Many businesses that have spanned a few regimes of CASA and its predecessors, are not confident that permanent change will happen until the government support and direction to the CASA Board and DAS is given legislative support in the Act."

AMROBA has been active in trying to mitigate issues arising out of CASR Part 145 (maintenance organisations), which resulted in the Manual of Standards being disallowed in the senate in March this year. According to Senator Nick Xenophon, had the MoS been allowed, it may have made it illegal for engineers to do maintenance they'd been doing safely for years

Hitch it should be remembered that NX was not the only legally qualified person with that view: Walker Special Maintenance Opinion.pdf 

From AMROBA latest Newsletter - Volume 12 Issue 11




MTF...P2

(11-30-2015, 12:50 PM)Gobbledock Wrote:  Well said Ken well said. The Act, or should that be 'the Act of bastardry' needs to change. Strict liability needs to change. Until Dr Voodoo's personal toy is taken away from him,industry, CAsA and the  senate will continue this same ludicrous tango that we've been dancing for decades.
And
Many of us have very worn out shoes and are tired of the same Waltz.

KC & AMROBA Newsletter cont/-




MTF...P2

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RE: AMROBA. - Peetwo - 12-01-2015

(12-01-2015, 08:58 PM)Peetwo Wrote:  Sorry Hitch been busy mate but as always your weekly wrap was far better than the relevant blogpiece...cheers P2 : The Last Minute Hitch: 27 November 2015

Quote:And speaking of reforms, the Aviation Maintenance Repair and Overhaul Business Association (AMROBA) has again called for the Civil Aviation Act to be reviewed and some of the promised culture changes included. This would, theoretically, make them permanent rather than just current policy. Well, it would make them as permanent as the government anyway. If it's easy to make changes to the Act to include, it has to be just as easy for the next government to change the Act to exclude. Still, it would make a statement to the industry that the minister is at least very serious about keeping the reforms going.

But in the eyes of AMROBA, just what are the reforms won for their membership? Whereas we have seen plenty of action on Parts  61, 141 and 142, the maintenance regs, which have the capacity to do some serious mischief to the health of the industry, don't seem to me to be getting similar attention. Either that or the new leadership just doesn't get the point. I would think the MROs issues would also warrant a task-force approach.

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RE: AMROBA. - Peetwo - 12-08-2015

AMROBA disgust -  

In response to this despicable IT story on CASA pushing for metadata access...  

(12-04-2015, 06:28 PM)Peetwo Wrote:  Leopard & spots - UFB!

Here we go.. ..bloody Sociopaths can't help themselves:

Quote:Aviation safety body applies for 'metadata' access


CASA confirms that it wants ongoing access to telecommunications metadata
Rohan Pearce (Computerworld) on 04 December, 2015 13:10




The Civil Aviation Safety Authority has confirmed it has applied for ongoing warrant-less access to telecommunications ‘metadata’ under rules introduced by the data retention legislation.

CASA is in charge of Australian aviation safety regulation.

The latest annual report issued by the Attorney-General’s on the use of the Telecommunications (Interception and Access) Act 1979 revealed that CASA accessed telco metadata 11 times in the last financial year.

“CASA sometimes accesses telecommunications data when it conducts an investigation into whether a person contravened a criminal offence provision in the aviation legislation,” a spokesperson for the organisation said.

CASA was one of the 83 organisations that accessed so-called metadata during the 12 months to 30 June 2015.

In 2014-15, agencies authorised access to telco ‘metadata’ a total of 365,728 times, the report from the Attorney-General’s Department revealed.

The data retention legislation passed earlier this year pared back the number of organisations able to gain warrant-free access to metadata.
The new regime kicked in on 13 October.

The legislation initially restricted access to police and anti-corruption organisations, customs, the Australian Crime Commission, the Australian Commission for Law Enforcement Integrity, the Australian Competition and Consumer Commission, and the Australian Securities and Investments Commission.

There is provision for further organisations to be authorised, however, and the Australian Border Force has been added to the list.

The Victorian government recently revealed that it has sought metadata access for the state’s Racing Integrity Commissioner.

A parliamentary inquiry earlier this year recommended that the Australian Taxation Office be added to the list of authorised organisations.

CASA said it is also seeking access.

“Following the making of the Telecommunications (Interception and Access) Amendment (Data Retention) Act 2015, CASA applied to the Attorney-General’s Department for ongoing direct access to telecommunications data,” the organisation’s spokesperson said.

The government won’t reveal which organisations or the total number to have applied to be authorised to access metadata.


Read more Data breach notification scheme ‘long overdue’
However, an in-progress freedom of information request has revealed that the number is likely to be greater than 40.

  
Definitely Leopard & spots..Skidmore & 'Just Culture' my ass! 
 

The AMROBA response...

Quote:

...Just when you think headway is being made and 2016 may bring about positive outcomes, a simple article in an IT magazine brings back the real truth.

CASA still has a fixation on policing and want permanent access to your metadata.

Worried, you should be, your privacy is being invaded.

Aviation regulatory reform has suffered from a drought of expertise for over 25 years and has actually reduced total participation through the biggest growth period of red tape and requirements that have overlaid criminal provision for the industry to comply with – most are unproductive. 

Over the last decade, the development of aviation safe requirements has changed from implementing international aviation ‘standards and recommended practices’ so aviation participants can, if they so wish, participate in the global aviation markets. We now have regulatory criminal provisions to comply with.

What is really being made is really Civil Aviation [Criminal] Safety Regulations designed so CASA can prosecute non-compliant industry participants. CA[C]Rs are addressing the criminal nature of all participants in the aviation industry. One would think we are participating in criminal activities against society.

We now know why CASA structures the regulatory requirement as criminal provisions. In a recent issue of Computerworld, an article written by Rohan Pearce 4/12/2015, identified CASA as accessing metadata to help prosecutions.

“The latest annual report issued by the Attorney-General’s on the use of the Telecommunications (Interception and Access) Act 1979 revealed that CASA accessed telco metadata 11 times in the last financial year.”

http://www.computerworld.com.au/article/590204/casa-applied-metadata-access/

Though the relevant Act was changed to exclude government departments & agencies such as CASA, this articles states that CASA has applied to have access. This really demonstrates the senior/middle management, including their legal department, attitude to regulatory development and enforcement.

Quote:The initial legislation restricted access to police and anti-corruption organisations, customs, the Australian Crime Commission, the Australian Commission for Law Enforcement Integrity, the Australian Competition and Consumer Commission, and the Australian Securities and Investments Commission. 

Is CASA Australia’s Aviation Regulator or does it have an internal vision of being like one of the above?

Australia has created aviation requirements that are being prosecuted by a Regulator with a fixation on policing breaches of the criminal provisions they have created.

Aviation safety cannot be regulated into people as aviation safety relies on the safety culture of participants.

If CASA need access to metadata for ‘criminal’ offense then the Feds should be handling the offense.

This sought of dampens all the PR from CASA about working with industry.

This is a big brother mentality that does not improve trust or confidence in CASA.

 

Rule-making is still failing

Mar 19 2015

The European Aviation Safety Agency (EASA) has this week published proposals for a modernised rule-making strategy based on slashing regulatory red tape and adopting modern outcome-based risk assessment principles. EASA’s name for this is “performance-based rule-making” (PBR).

As a transnational regulator EASA is the centrepiece of the European Union’s strategy for aviation safety, says it’s Executive Director, Patrick Ky:

“EASA – that means the Agency and its sister national authorities – need to be prepared for the challenges ahead. With these changes, we will be more proportional, flexible and proactive to increase the level of safety in European aviation. I believe that although our proposals are ambitious they are also reasonable. There is nothing wrong with being ambitious about safety.”

Mr Ky was appointed in September 2013, and closed the organisation’s rule-making office a year later.  Ky’s explanation for the new strategy:

“If you have a rule-making directorate,” he explains, the director is judged on how many rules he makes, or how many existing rules he ‘improves’.” The result, he says, is ever-fatter rulebooks, the contents of which nobody could possibly retain, and the complexity of which becomes “impossible to work with”.

“If you have a rule making directorate, the director is judged on how many rules he makes.”

CASA has achieved the 2nd highest in Australia behind Taxation.

Excerpt from Australian Constitution Overview:  “The High Court has also recognised some implied restrictions on legislative power derived from the fundamental system of government established by the Constitution. For example, because of the separation of powers effected by the Constitution, only a court may exercise the judicial power of the Commonwealth. Accordingly, a law of the Commonwealth Parliament cannot provide for criminal conviction by anybody other than a court.”

Many in industry that have been prosecuted by CASA wonder about this.

The current regulatory system is not inductive to GA aviation growth.

Look at any secondary airport in Australia and the decline in aviation activities is obvious. Add many country centres and the decline confirms a serious situation.

Why? Unworkable regulatory requirements.

The CASA Board must bring to a close this unfortunate chapter in Australian aviation.

Aviation is and has been a complete failure in Australia because the original outcome, once supported by the industry, the public and politically, has been totally forgotten.

 

What is the future vision for Australian aviation participants?

 

Regards
 
Ken Cannane
Executive Director
AMROBA
Phone:   (02) 97592715
Fax:       (02) 97592025
Mobile:   0408029329
www.amroba.org.au
Safety All Around.
 

Much like the CVD pilots persecution case (after 25 years+ of incident free aviating), all this on the Skidmore watch -


MTF...P2 

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RE: AMROBA. - Gobbledock - 12-08-2015

Well done CAsA you f#ckheads. You just blew any minor, tiny, teeny, sliver of possible trust formation between you and industry.

Skid'Mark, you should be appalled at LSD's actions on this matter. You need to go. And the Witchdoctor and his apprentice Flyingfiend should be frog-marched out of the building.

CAsA you've done it again.....TICK TOCK says industry TICK TOCK.

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RE: AMROBA. - Kharon - 12-09-2015

Time gentlemen – Please.

It is time for the alphabet groups to speak as one; the subject Metadata for CASA. All together in one loud, long shout of NO.

Ken Cannane, Marc de Stoop, Phil Hurst, along with AIPA, VIPA and every associated union, affiliation or parliamentary ‘friends’ of aviation should be party to a statement to the PM rejecting the notion that CASA is a security or law enforcement agency. It is not. The use criminal code and strict liability rules are a CASA confection designed to ensure that every whim of the inspectorate can be enforced.

If the government will not or cannot curb the rabid attack dogs, the industry, speaking as one must. Start with the pack leader, who either clearly approves or has no control over the department he is allegedly running.

Just say NO, loud, long and often; it’s a simple enough thing to do.

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RE: AMROBA. - Peetwo - 12-12-2015

(12-09-2015, 05:59 AM)kharon Wrote:  Time gentlemen – Please.

It is time for the alphabet groups to speak as one; the subject Metadata for CASA.  All together in one loud, long shout of NO.  

Ken Cannane, Marc de Stoop, Phil Hurst, along with AIPA, VIPA and every associated union, affiliation or parliamentary ‘friends’ of aviation should be party to a statement to the PM rejecting the notion that CASA is a security or law enforcement agency.  It is not.  The use criminal code and strict liability rules are a CASA confection designed to ensure that every whim of the inspectorate can be enforced.

If the government will not or cannot curb the rabid attack dogs, the industry, speaking as one must. Start with the pack leader, who either clearly approves or has no control over the department he is allegedly running.

Just say NO, loud, long and often; it’s a simple enough thing to do.

Joining dots, making dashes & exclamations

Yesterday was reading the weekly wraps off the Yaffa when suddenly the Foggy Hollow MCP started flashing & aural warnings started pealing, then just as suddenly it all stopped - hmm wonder why?

Anyway Hitch followed up his Oz Flying meta-data article - see HERE - with this insightful comment:

Quote:..It seems to me the whole kerfuffle about CASA accessing mobile phone data could have been avoided if some people (CASA and me included) had just done some checking. Whilst some sectors of the aviation community were reaching for their pitchforks and flaming torches, CASA had actually been excluded from access to that information back in April. Somewhere along the line, the system worked and no-one noticed. When you're in the process of building good relationships and trust, it's not a good idea to be accessing people's personal data, even if the content isn't disclosed...

 
Guess that is one of the traps when there is still a major trust deficit between industry & the regulator..

Also very much AMROBA related there was this interesting bit of scuttlebutt, from new AvBiz Editor Denise:

Quote:..Another issue that always provokes comment (and often controversy) is Australia's aviation regulatory environment and how safe it keeps our skies.


The Civil Aviation Safety Authority (CASA) has been under considerable pressure this year to lift its game so that it meets the requirements of the Aviation Safety Regulation Review. There is much work going on but there is also a lot of chatter about how the changes being implemented will be far from the end of it for CASA.

I can’t say much about it yet but there is an explosive report in the pipeline (ding..ding..ding??) that experts have been slogging away on for a couple of years. It highlights just how much more CASA and  the Federal Government need to do to bring our aerospace industry up to scratch on many fronts.

The lack of trained expertise to maintain planes not just in Australia but globally cannot be ignored. The shortfall in qualified aircraft maintenance staff is growing at an alarming rate with the Asia-Pacific region, where aerospace growth is the highest, particularly hard hit.

And we cannot ignore either the deficits in the safety regulation review this report will identify for CASA to be able to meet all  international safety and maintenance training standards.

Australia’s training and licence standards are being changed, but there are still gaps and ambiguity when compared with international standards.

More and more of our Maintenance, Repair and Overhaul (MRO) business is being outsourced overseas where standards can be inconsistent –even spurious. Our safety regulators should be heading overseas frequently to check Australia’s stringent standards are being met, but it seems this is not always the case.

On another front, we have a fragmented aerospace industry and are missing valuable export opportunities because of it.

So watch this space for the report in the New Year. These, and other issues have been simmering, but indications point to them coming to a head in 2016 - and that can only be a good thing. The report advocates a proactive response, not a reactive one and that is the key to a healthy aerospace environment

   
Which got my personal metadata database pinging all the way back to a Senate Inquiry submission that included a copy of an ASRR submission??- Here we go :

Quote:6 Dr Doug Fraser, A/Profs Ian Hampson and Anne Junor and Prof Michael Quinlan (PDF 68 KB)  Attachment 1 (PDF 524 KB)

 Excerpt from the ASRR submission:

Quote:　

Introduction

We are glad to have this opportunity to provide a submission to the Aviation Safety Regulation Review. We represent a team of academic researchers who have been investigating the aviation maintenance industry for the past three years on an ARC Linkage grant entitled The Future of Aircraft Maintenance in Australia: Aviation Safety, Workforce Capability and Industry Development (LP1101100335). Our industry partners (a central feature of the Linkage grant program) are made up of a broad mixture of employee, industry and training sector representatives:

• Australian Aerospace (Defence Contractor)

• Australian Licensed Aircraft Maintenance Engineers Association (ALAEA)

• Australian Maintenance, Repair and Overhaul Business Association (AMROBA)

• Australian Manufacturing Workers or union (AMWU)

• Flight Attendants Association of Australia (FAAA)

• Manufacturing Skills Australia (Skills Council)

• TAFE NSW

• Transport and Logistics Centre (TALC)

• Transport Workers’ Union (TWU)

The purpose and outcomes of the project are described in the project documentation as follows:

This research will analyse sources of skill shortage in Australia’s aircraft maintenance industry, and identify the safety risks of sending maintenance work offshore. It will compare these risks with the costs and benefits of building aircraft maintenance skills and careers and enhancing their contribution to national technological development.

 
Interesting.. For reference the UNSW School of Management final report can be accessed - HERE.
 
So coincidence, err..maybe??

However is this also just a coincidence? From the RAAA thread:  

Quote:Higgins appointed new CEO of RAAA
11 Dec 2015

Mike Higgins has been appointed chief executive of the Regional Aviation Association of Australia (RAAA)replacing long-serving Paul Tyrrell.

RAAA chairman, Jim Davis said today that Higgins brings to the organisation “a tremendous wealth of expertise” with his experience as a licensed aircraft maintenance engineer, a former commercial pilot, maintenance organisation manager and airline general manager, one of the architects of regional aviation security regulations, drug and alcohol management plans and, recently, a senior manager with CASA.

“His breadth of experience will serve RAAA members well in many areas, but it will be particularly valuable as we work with the government and the regulator to solve the huge problems caused by recently introduced legislation and participate in the development of new regulations”, said Davis.

 Paul Tyrrell resigned from the association to pursue a new, as yet undisclosed venture.

“Over the last seven and-a-half-years Paul demonstrated a highly professional and objective approach in his dealings with politicians, various government agencies and the media and was highly regarded, being publicly congratulated by the Deputy Prime Minister at the last RAAA convention,” said Davis

There was also this comment from Hitch in close to his last 'LMH' for the year:

Quote:The Regional Aviation Association of Australia (RAAA) has appointed Mike Higgins as their new CEO, replacing Paul Tyrrell, who resigned some weeks ago. Mike is a LAME, former CPL, MRO manager and has managed an airline. Most curiously, he was a senior manager with CASA, and the man behind the drug and alcohol testing scheme. That means he brings to the RAAA a lot of industry smarts, including how to deal with Canberra and Aviation House in particular. As the RAAA CEO, he'll also be their point man with The Australian Aviation Associations Forum (TAAAF), giving TAAAF some formidable artillery when firing in concert with Greg Russell.

Summer of intrigue...TICK..TOCK miniscule
MTF...P2

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RE: AMROBA. - Peetwo - 12-22-2015

2015 - The Year of 'Great Exasperations'

AMROBA's final newsletter for the year - Volume 12 Issue 12 - should be required reading for those individuals who want to obtain a better appreciation of the largely regulator induced woes & decline of the once flourishing but still essential GA industry...

Quote:1. Year 2016 may provide some benefits for GA!

CASA seems to be denying that aviation participants/aviation activities at secondary airports and many others rural airports are a shadow of the past. Why? The prescriptive regulatory imposts, red tape & documentation that have been generated, especially over the last decade, has created an administrative restricted system. This is preventing aircraft from being used as an alternative form of transport like cars. Once CASA convert recent "words" into "action" then 2016 may show some promise for GA.

2. What are CASA Board’s direction to the DAS?

AMROBA members, like other industry participants, have been waiting and waiting and waiting for change in direction to the regulatory system – e.g. a move from prescriptive based regulatory system to a performance based regulatory system. Sadly, all we see is more prescriptive requirements causing confusion and non-acceptance by industry participants. E.g. Part 61 latest over regulation fiasco.

In addition, ever increasing red tape continues despite the government rhetoric regarding red tape and regulatory burden reduction.

3. CAA/CASA must accept onus for damaging GA


Why can some government departments reduce costs when CAA/CASA cannot? Without doubt, every regulatory change since the formation of the CAA, has reduced the number of participants in this industry. The numbers of jobs in rural aviation and at secondary city airports are a ghost of the past numbers and it all comes down to over-regulation.

Besides the rules of the air, all that should be required in private general aviation is an aircraft with an onus on the operator to maintain it airworthy, a pilot with an applicably rated licence and not much else.

4. Understanding risks – regulator & industry

The latest buzz words is risk based regulation. Sounds good until you realise that public servants are risk adverse and think their role is to protect the public therefore perceiving unsupported risks not based on evidence. Most technical public servants perform their role enthusiastically but when clarity of responsibility is not clear, some may become overawed at their ‘perceived’ responsibility and the public frustrations become obvious. Read submissions to the ASRR.

From KC's review of 2015 & looking forward to 2016 you get a strong sense of exasperation for the year that promised so much but delivered so little...  

Examples:

Quote:..In 2015, once again we have heard a lot of talk from CASA & its DAS, Mark Skidmore. However, industry has heard the same from Cooper, Keith, Toller, Byron & McCormick usually followed by a restructure of the Authority that ends up with more of the same no matter which regime. Skidmore has done the same as his predecessors but, from industry point of view, we are yet to see the benefits. Will Skidmore’s restructure work when previous restructures have not?..

    

Quote:If the CASA Board is to be effective then it has to be transparent so industry can see what directions that they give to DAS Skidmore iaw the Minister’s Statement of Expectations. If all its communications, directions, policies are kept secret between the Board and the DAS, then it will become an ineffective Board serving no benefit for the public or industry participants...

...The aviation regulatory structure and current requirements are probably in a worse condition than at any time in my 55 years’ experience in this industry.

ASRR states we need clear and plain English written standards supported by a regulation like CASR Part 145. We contend that the MoS approach should be standards under 9(1)© of the Act that are written as Standards without the criminal code being applied. We may lose this battle in the short term but hopefully win in the long term.

If we are to have an effective Board, then we need to see what it is doing...

Quote:Why can some government departments reduce costs when CAA/CASA cannot? Without doubt, every regulatory change since the formation of the CAA, has reduced the number of participants in this industry. The numbers of jobs in rural aviation and at secondary city airports are a ghost of past numbers and it all comes down to over-regulation or badly directed regulations.

Besides the rules of the air spelt out in Annex 2 to the Convention, all that is required in private general aviation is aircraft with an onus on the operator to maintain them airworthy; plus a pilot with an applicably rated licence and not much else. Who does the maintenance and the minimum maintenance standards should be promulgated by CASA as standards. Our system has become complicated and therefore no longer encourages the volume of participants needed to expand.

Without doubt, every regulatory change since the formation of the CAA, has reduced the number of participants in this industry...

...The aviation industry has enough challenges from other government departments and agencies ever increasing regulatory imposts, it does not need unnecessary restrictions from its own regulator.


Some of the blame lies with an aviation Act that nobody wants to change because of the political situation in the Senate. Without doubt, CASA’s approach can be partially blamed on an ageing out of date Civil Aviation Act but CASA must also accept blame as it does not comply with the Act. CASA has never promulgated "clear and concise civil aviation safety standards" under the Act because, in their mind, they would have trouble enforcing. So they have created complicated and over regulated standards under the Regulations which have had the criminal code applied to the regulation.

This has nothing to do with safety as aviation safety standards promulgated under the Act are as enforceable as the Act itself.

Every participant in the aviation industry should, whenever they feel disenchanted with any current requirement, or proposed requirement, let the CASA Board know.

The majority of the Board members know by past experience that this industry’s aviation regulatory system is in total disarray. Any other aviation regulator (excluding EASA) that produced such a complicated and frustrating set of requirements would have political consequences...

Quote:..One of the reasons jobs are not being created in aviation, besides the ever changing unworkable regulatory processes (e.g. pilot licencing), is the complexity that has been implemented over time. How many VH registered aircraft sit idle every year? Why are they not being flown more than 100 hours/annum? If aircraft were utilised as they were designed to be used each year, then the industry would be growing.

The only way higher utilisation will occur will be when the regulatory system has been simplified so aircraft can be used as a form of transport as an alternative to road and rail. This means private aviation and small maintenance businesses must operate with virtually zero red tape...

Words of wisdom KC, however is anyone listening?  
MTF...P2

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RE: AMROBA. - Peetwo - 01-11-2016

KC on a mission? -

Although it is still firmly in slumber holiday time in Sleepy Hollow, it would seem some of the Alphabets are already burning the midnight wick in contemplation of 2016 being a year of pro-action & reformation; or go down swinging.

Go - Here - for the first AMROBA newsletter for 2016; & fresh off Ken's keyboard these are fighting words  :

Quote:1. Will the CASA Board be responsible to the public or just another ‘puppet’ Board?

The future of aviation in Australia is now the responsibility of the Board of CASA. The DPM Statement of Expectations clearly places the responsibility on the Board to produce objectives, strategies, policies and directions to the DAS on how the DAS manages CASA.

The Department of Infrastructure is responsible for keeping aviation Acts valid. Accordingly, industry will need to wait till after the next Federal election for the Department to consider recommending changes to hopefully more stable Parliament. Act changes to enable the Forsyth recommendations to be permanently implemented as suggested in the ASRR Report will therefore be post the election.

However, will this CASA Board be accountable to the public? Will this Board promulgate all objectives, strategies, policies and directions determined by the Board that the DAS is obliged to follow when managing CASA?

This Board controls your future, therefore they should be answerable to the public.

Talking to many of our members about what they thought of previous CASA Boards and their expectations of this CASA Board resulted in some interesting answers.

For instance, many never knew of some past Boards and those that did had no confidence that previous Boards have had any influence over the CEO/DAS of CASA. CASA middle management, including their legal sector, have dictated the direction of aviation reform. Irrespective of which CEO/DAS, their policies are still being applied in CASRs & MoS.

When explained that the Act and Minister’s Statement of Expectation empowers the Board to set aviation objectives, strategies, policies and to provide directions to the DASA on how the DAS manages CASA, most believed it will be CASA producing the objectives, strategies, policies and directions for Board endorsement.

Only a Board that promulgates the objectives, strategies, policies & directions publically will gain public trust and confidence.

Though most want this Board and DAS to make a major change to the directions that CASA/CAA have taken over the last decade, they are also realistic and accept that little change in direction is currently happening or will possibly happen.

AMROBA has proposed to the Minister that the Board’s objectives, strategies, policies and directions should be promulgated under the signature of the Board so the public, including industry, can see how their sectors of aviation will be enhanced.

The CAA(UK) Board promulgates such decisions, including Board minutes.

    
Memo to Boyd, the Board and Oliver Skidmore-twist - TICK..TOCK goes the IOS clock!

Oh and KC, the monthly key for the Tim Tam cupboard is in the mail..


MTF...P2   

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RE: AMROBA. - Peetwo - 01-20-2016

OZ Flying catching up -

Courtesy the Yaffa's Oz Flying..

Quote:
AMROBA members are not confident that past CASA boards have had any influence over the DAS. (Steve Hitchen)


CASA Board must drive Reforms: AMROBA
20 Jan 2016

The Aviation Maintenance Repair and Overhaul Business Association (AMROBA) has laid the responsibility for driving reforms at CASA at the feet of the CASA board.

In AMROBA's January 2016 newsletter, Executive Director Ken Cannane says the responsibility of the board to effect changes is enshrined in directions given to them by the Federal Government.

"The future of aviation in Australia is now the responsibility of the board of CASA," Cannane states. "The DPM [Deputy Prime Minister] Statement of Expectations clearly places the responsibility on the board to produce objectives, strategies, policies and directions to the DAS [Director of Aviation Safety] on how the DAS manages CASA.

"However, will this CASA board be accountable to the public? Will this board promulgate all objectives, strategies, policies and directions determined by the board that the DAS is obliged to follow when managing CASA?"

AMROBA expressed concern in November that reforms recommended in the Forsyth Report won't be permanent unless changes are made to the Civil Aviation Act. Cannane believes there is little chance of that happening before the Federal Election that is due in the second half of this year.

"The Department of Infrastructure is responsible for keeping aviation Acts valid. Accordingly, industry will need to wait 'til the next Federal Election for the deparment to consider recommending changes to [a] hopefully more stable parliament."

After surveying several member companies, AMROBA found that many weren't familiar with past CASA boards and those that were had no confidence that previous boards had any influence over the Director of Aviation Safety.

The current CASA board includes a former regional airline operator in Chairman Jeff Boyd; Ian Smith, a former Director of the Regional Aviation Association, former Gliding Federation of Australia president Anita Taylor, ex-RAAF and Qantas pilot Murray Warfield, solicitor Phillpa Stone and current DAS Mark Skidmore, a former RAAF Air Vice Marshal

MTF...P2

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RE: AMROBA. - Peetwo - 02-02-2016

Latest AMROBA Newsletter -

Quote:　
1. The positive aspects of implementing quality systems in manufacturing and maintenance organisations.

Now that CASA has accepted the benefits of implementing quality systems in manufacturing, then it should become a formality that quality systems should also be in maintenance. The industry working group is encouraging CASA to rely on quality systems.

Read more

2. Basic General Aviation Ideas Needed.

Why is North America (USA/Canada) general aviation flourishing and of such size? There are basically two principles applied and that is to provide pilots and maintenance personnel with the appropriate practical skills. In the last newsletter we identified that ICAO GA standards places organisation responsibilities on the pilot and LAME. North America adopts that principle.

Read more

3. Design organisations get a shake-up and will play a greater role in certification.

CASA suggests a more cost effective system for design organisations by proposing to set minimum standards & requirements in outcome based regulations and standards. Comparing how the FAA has devolved functions to enhance safety will bring cost savings to the industry.

Read More

4. AME Licencing is still not internationally compatible.

CASA has promulgated its long awaited changes to the Part 66 MoS to implement the GA "Group" licence ratings but still has to come to terms with changing the LAME role in aviation maintenance. The whole training environment needs a new model.

Read more

Hmm...this sounds familiar

Quote:2. Basic General Aviation Ideas Needed.

Why is North America (USA/Canada) general aviation flourishing and of such size? There are basically two principles applied and that is to provide pilots and maintenance personnel with the appropriate practical skills. In the last newsletter we identified that ICAO GA standards places organisation responsibilities on the pilot and LAME. North America adopts that principle.

General aviation covers private operations to aerialwork, charter and small airline operations and maintenance, manufacturing and training activities. It ranges from small and informally organised individuals and organisations servicing private and other non-passenger commercial businesses through to structurally organised businesses servicing commercial operators.

GA is a very broad area of employment so what works in one sector in many cases does not work in another sector. For example, small aviation businesses in rural locations need to employ from the local community to retain the employee on completion of training – it is an employee retention issue.

Training is the major issue for many local communities as learning to fly or becoming an aircraft tradesperson usually means travelling, at great costs, to a location where specific training is available with additional costs.

Major Issue - Training. There has to be a concerted re-think on the provision of pilot and maintenance training so that training is brought to the local community rather than centralising training at a limited number of locations, mainly near major cities.

In the USA, a person interested in learning to fly can access a website and find the nearest independent flight instructor. Example Website: Independent Flight Instructors or flying school Website: Flying Schools. What the US system does is provide various pathways to obtain a pilot licence.

The same applies in the maintenance fields, e.g. training schools website: Online website. In the US, community schools and FAA Part 147 approved schools share the training almost evenly with very similar A&P practical and knowledge pass marks. There is a small
percentage that self study, gain experience and pass the practical and knowledge tests. It is the flexibility in the FAA regulatory system that was copied by EASA.


EASA provides a similar flexible approach to the FAA but Australia adopted only one of three ways provided by EASA. It has not worked. See item 4 for more detail on AME training flexibility. A system that sees many aircraft not being flown or low utilisation of aircraft has systemic problems with the overall system.

Aviation depends on renewal. New pilots, new aircraft and new support personnel.

Safety improvement relies on the transfer of knowledge and experience from one generation to the next.

Makes sense to me & Sandy will be pleased


MTF...P2

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RE: AMROBA. - Peetwo - 03-17-2016

AMROBA on Harmonisation - In the Breaking News section off the AMROBA website KC & Co have put out a new paper:

Quote:Breaking News 

Harmonisation
March 14, 2016March 14, 2016 Ken Cannane
Harmonisation 0316

PG 1:

Quote:HARMONISATION

Harmonisation once meant adopting the "highest practicable degree of uniformity in regulations, standards and procedures" from the ICAO international aviation standards and recommended practices.

Challenge: The Civil Aviation Act says "consistent with" not "adopt". However, any reasonable person in aviation would assume "consistent with" means "adopting" when Article 37 of an aviation treaty signed by Australia states "adopt".

The government agreed to harmonisation with ICAO international aviation standards initially in 1947 when Australia ratified the International Convention of Civil Aviation and, up until the formation of the CAA, aviation requirements harmonised to a far greater extent than current regulations and standards – so what has gone wrong since 1988?


Economic deregulation (government direction)

In 1993, the Bureau of Transport and Communications Economics produced its fifth report since 1989 into aviation economic regulatory reform. Previous reports concentrated on economic airline deregulation issues. This report recorded the economic reform of Australia’s aviation industry had been an ongoing process with five major reform initiatives undertaken since 1988.

"The overriding aim of the whole micro-economic reform program of which aviation is a key plank has been to pursue regulatory outcomes that will bring the most substantial benefits to the consumers, and encourage greater efficiency."

So how did government economic reform transform into full regulatory reform?

Pre 1988, the Air Navigation Act, Air Navigation Regulations and Air Navigation Orders were more closely harmonised with ICAO international standards and recommended practices than at any time since.

Major reform initiatives have continued but economic reform has been replaced by adoption of expensive and inefficient "world’s best practice" that reverses the benefits of economic reform. After 28 years, the industry is fatigued from reform.

The Australian aviation industry deserves better than being subject to non-harmonised unique regulations and standards. "Harmonisation" has become a permanent career within CASA with no completion date.

How hard is it to adopt plain English international standards without creating unique requirements?

The highest practicable degree of uniformity possible means harmonising as close as possible to the ICAO standards and recommended practice – the US system is very mature and is seen as the world standard that most other governments model their aviation system on. Even Europe is developing rules compatible with the US system except their rules have become unworkable according to the head of EASA.

Aviation reform must return to the government economic reform approach by adopting ICAO international standards and recommended practices without the wording and intent of the international standard being changed.

The most recent government review into CASA’s management of [economic] regulatory reform (ASRR), and red tape reduction policy, actually questions whether CASA has the skills to properly economically reform the aviation system to harmonise with ICAO international standards and recommended practices.

PG 2:

Quote:Aviation Participation Similar to US, not Europe.

Australian aviation industry has a similar participation as both Canada and United States. Up until the last decade, CASA’s predecessors had always used the US aviation regulatory system as the model to use when adopting ICAO international standards. The US system is very mature, empowers and licence industry participants that are similar to Australia. General aviation in Australia is closest to the United States & Canada. NZ worked this out in the early 1990s as did the CAA.

However, in the last decade less experienced regulators in CASA decided the immature complex EASA system, which virtually does not have a general aviation sector like Australia, had more benefits for bureaucracy than industry & consumers. This ill-conceived choice was rejected in many submissions to the ASRR.

Naturally public servants will always support a system that guarantees public servant jobs – it is why there is a need for government to make these determinations on behalf of their constituents.

Which government (CASA Board) will commit to harmonisation with ICAO standards using the US regulatory system as the model?

Today, harmonisation has become a total shambles when compared with mature aviation regulatory systems that cover general aviation as well as air transport, training, maintenance and manufacturing. Aviation regulatory development has not complied with governments’ red tape reduction policies over the last 28 years.

The red tape reduction policy is government’s direction for economic reform.


Commitment to Harmonisation

For a country that originally committed to international harmonisation in 1947, it is an international embarrassment that regulatory development, now a career in the public service, is not complete and has no completion date.

NZ started their recent reform around 1990 and completed it within 5 years.

North America (Canada & USA) and NZ are countries around the Pacific Rim that have similar aviation segments to Australia – from airline to sport aviation and manufacturing. NZ is based on the US system for all segments except major airlines and are more harmonised with international standards than Australia.

Annex 6, Part II to the Convention states: Responsibility. The responsibility that devolves upon the operator in Annex 6, Part I, should, in Part II of the Annex, fall upon the owner and pilot-in-command. Precedent for this course of action exists in Annex 2 to the Convention.

The US system applies these international standards to general aviation.

ICAO international standards are written in plain English; it has been proven in a number of countries that adoption can be completed within 2 years with a five year transition period for industry.

Harmonised standards would mean a reduction in red tape for participants in aviation and a reduction in the size of the government agency, CASA.

Could this be the answer?

Internationally, the "structure" of the Federal Aviation Regulations of the USA has been accepted as the international regulatory "structure" standard.

Variation of an adopted standard or practice should only occur if agreed to by the Australian aviation industry, the public and/or the beneficial communities.

PG 3:

Quote:Comparable jurisdictions

Any benchmarking of Australia's aviation safety related regulations against the US system, that is an industry recognised comparable overseas jurisdiction, would clearly identify the need for major economic reform with improved safety.


After all these years, the level of compliance with international standards should be closer to 100% than it is today. In the Pacific Rim region, the biggest trading country is the United States with the possibility of China being an emerging market.

A government department or agency that spends over 20 years reforming regulations and standards, which only need to be adopted, demonstrates why industry has lost trust and respect for CASA. It is obvious that CASA does not have the expertise and direction to adopt international aviation standards.

The only way to regain that trust and respect is to totally rewrite the Civil Aviation Act so that CASA can only adopt international standards and any proposal to lodge a difference will require consensus from government and the aviation industry.

The government’s Aviation Safety Regulation Review submissions, report and recommendations demonstrate the national support to adopt the US system.

International Treaty almost meaningless!

The need for uniformity throughout the world is higher today because the aviation market is now a true global market demanding harmonisation.

Australia, in 1947, ratified the International Convention of Civil Aviation, also known as the Chicago Convention. Article 37 of the Convention places an obligation on Australia to adopt international standards promulgated by ICAO.

ICAO states in its regulatory oversight manual: 3.3.3.2. "It should be noted, however, that the filing of differences with respect to international standards does not mean that a State (Australia) can then do business as usual. Several articles of the Convention make it clear that if Standards adopted by a State are lower than those required by ICAO, aerodromes, aircraft, service providers or personnel with licences or certificates endorsed by that State cannot participate in international air navigation, except with the permission of the State or States whose territory is entered."

ICAO also states: The term "regulations" is used in a generic sense to include but is limited to what may be variously considered by States as instructions, rules, edicts, directives, sets of law, policies, requirements and orders.

Why be a member State if government/CASA do not adopt these standards?

PG 4:

Quote:Adopting International Standards

ICAO Standard: Any specification for physical characteristics, configuration, material, performance, personnel or procedure, the uniform application of which is recognized as necessary for the safety or regularity of international air navigation and to which Contracting States will conform in accordance with the Convention; in the event of impossibility of compliance, notification to the Council is compulsory under Article 38.

Adopting international standards and procedures should be a simple administrative process. Singapore was able to achieve this quickly over a few years by adopting either the applicable FAR or EASR and updating to meet ICAO standards.

Singapore’s ICAO compliance is one of the best in the world. They adopted standards – this is what CASA should be doing; stop creating and adopt. However, Singapore does not have the demographics of Australia.

The Convention Articles make it quite clear that standards are to be adopted.

Article 37 – Adoption of international standards and procedures

Each contracting State undertakes to collaborate in securing the highest practicable degree of uniformity in regulations, standards, procedures, and organization in relation to aircraft, personnel, airways and auxiliary services in all matters in which such uniformity will facilitate and improve air navigation.

To this end the International Civil Aviation Organization shall adopt and amend from time to time, as may be necessary, international standards and recommended practices and procedures dealing with:

a) Communications systems and air navigation aids, including ground marking;

b) Characteristics of airports and landing areas;

C) Rules of the air and air traffic control practices;

d) Licensing of operating and mechanical personnel;

e) Airworthiness of aircraft;

f) Registration and identification of aircraft;

g) Collection and exchange of meteorological information;

h) Log books;

i) Aeronautical maps and charts;

j) Customs and immigration procedures;

k) Aircraft in distress and investigation of accidents;

and such other matters concerned with the safety, regularity, and efficiency of air navigation as may from time to time appear appropriate.

In addition, Article 42 enabled personnel licences held in 1947 to remain until 1952 when they needed to harmonise with the international standards.

Article 42 - The provisions of this Chapter shall not apply to personnel whose licenses are originally issued prior to a date one year after initial adoption of an international standard of qualification for such personnel; but they shall in any case apply to all personnel whose licenses remain valid five years after the date of adoption of such standard. [The 5 year time passed in 1952.]

 
{P2 Comment - Here is a link for the latest list of Australian notified differences - https://www.airservicesaustralia.com/aip/current/sup/s15-h104.pdf. Note the AIP SUPP is now four pages of relevant links to individual Annex differences. The reasoning for the change to the SUPP, listed at Para 1.2, is absolute bollocks, this is just another cynical attempt to cover up the embarrassing number (over a 1000) of notified differences to ICAO SARPs}   
 
PG 5:

Quote:Application of penalties


What CASA cannot come to terms with is the responsibility to apply penalties for non-compliance.

"The specific status given to regulation when it is applied within the State and the penalty assigned in the event of non-compliance are matters for the judgement of individual States, taking into account their responsibilities under the Convention."

So what is the appropriate penalty for non-compliance of an ICAO adopted standard? In the majority of cases, if the resolution of safety concerns cannot be addressed under a corrective action plan or the licence/certificate holder does not or will not correct the non-compliance, then administrative action must be taken.

However, deliberate actions that can be listed as a criminal action should be included as part of the Federal Criminal Act and Regulations. This is the process used in the United States – CFR Title 49 lists aviation specific criminal actions.

ICAO Regulatory Oversight Manual: 3.3.1.1- "The State laws and regulations should be in conformity with the Annexes to the Convention. The Annex provisions are designed to provide the minimum requirements to be met by all Contracting States, regardless of the size and complexity of their civil aviation activity. The individual States are then responsible for developing equivalent regulations and rules containing sufficient details to ensure that satisfactory compliance will result in the desired level of safety."

The same ICAO manual states:

3.3.2 Adapting or adopting regulations from other States

"To meet their requirements for regulations, Contracting states always have the option of adopting another Contracting state’s regulations. Even though the unilateral adoption of another State’s regulations may have some advantages, such as enhanced exchange of operating crew and aircraft, it should be done only after ensuring that the regulations have been updated to include all ICAO standards. The complexity of the other State’s aviation environment should also be considered. A State with a limited aviation environment should be careful not to place undue burden on its aviation community and its assessment staff by adopting excessively restrictive regulations. A better alternative would be to adapt the regulations to meet the aviation environment while still maintaining harmony with other States."

The responsible aviation government department pre 1988 were more committed to securing the highest practicable degree of uniformity in regulations, standards, and procedures, in relation to aircraft, personnel, airways and auxiliary services that facilitated and improved air navigation.

They also adapted requirements to meet Australian aviation environment while maintaining harmony with other States.

However, since 1988, when the Civil Aviation Authority was formed, the commitment to "harmonisation" has become blurred as public servants create a life time career of regulatory development without commitment to harmonisation.

International harmonisation can be achieved within 2-5 years without major disruption by adopting and adapting the US system to Australia.

Criminal actions should be included in criminal codes, not aviation standards.

Harmonisation means adoption of ICAO standards by adapting the FARs.

Lowest cost option available for our aviation environment.

Hundreds of millions of dollars spent since 1988 and harmonisation still not achieved by CASA. AT WHAT COST TO INDUSTRY.

 
Off the Yaffa - Hitch on the AMROBA paper :

Quote:
Australia's Civil Aviation Safety Regulation review started in 1988, but still has no end in sight.


CASA lacks Expertise to adopt ICAO Standards: AMROBA
17 Mar 2016

The Aviation Maintenance Repair and Overhaul Business Association (AMROBA) has accused CASA of lacking the expertise needed to adopt International Civil Aviation Organisation (ICAO) standards.

AMROBA Executive Director Ken Cannane questioned CASA's skill's base in a paper titled Harmonisation published on the association's website.

Cannane points out that when Australia began the aviation regulatory reform process in 1988, the then CAA elected to re-write regulations rather than adopt existing ICAO standards.

According to Cannane, as a signatory to the Chicago Convention of 1947, Australia is obliged to adopt ICAO standards, which would have seen the reform process completed years ago.

"A government department or agency that spends over 20 year reforming regulations and standards, which only need to be adopted, demonstrates why industry has lost trust and respect for CASA. It is obvious that CASA does not have the expertise and direction to adopt international standards.

"The only way to regain that trust and respect is to totally re-write the Civil Aviation Act so that CASA can only adopt international standards and any proposal to lodge a difference will require consensus from government and the aviation industry."

Cannane states that the CAA used a practice of simply using the US FAA's model of adopting ICAO standards, but now CASA is leaning more toward the European Aviation Safety Agency (EASA) standards.

"In the last decade less experienced regulators in CASA decided the immature, complex EASA system, which virtually does not have a general aviation sector like Australia, had more benefits for bureaucracy than industry and consumers. This ill-conceived choice was rejected in many submissions to the ASRR [Aviation Safety Regulation Review]."

In its December 2014 response to the ASRR, the Department of Infrastructure and Regional Development stated that adopting ICAO standards for general aviation was more difficult than it was for airline transport.

"Australia supports the adoption of International Civil Aviation Organization (ICAO) Standards and Recommended Practices (SARPS) and best practice regulatory approaches used by other leading aviation safety authorities," the response paper stated.

"It is acknowledged that this is easier to achieve with international and domestic aviation passenger and freight operations than it is with other types of operations such as aerial work and general aviation, where there is less consistency in international approaches and less specific international guidance, or where international practice does not meet Australia’s circumstances."

Australia's reform program has been going now for 28 years. By contrast, the NZ CAA completed their reform in only five years

Chocfrogs all round for KC & the AMROBA Band, trouble is the lights appear to be on in the Miniscule's office but at this stage there doesn't appear to be anyone home..

MTF...P2

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RE: AMROBA. - Peetwo - 03-18-2016

(03-17-2016, 10:43 AM)Peetwo Wrote:  AMROBA on Harmonisation - In the Breaking News section off the AMROBA website KC & Co have put out a new paper:

Quote:Breaking News 

Harmonisation
March 14, 2016March 14, 2016 Ken Cannane
Harmonisation 0316
 
{P2 Comment - Here is a link for the latest list of Australian notified differences - https://www.airservicesaustralia.com/aip/current/sup/s15-h104.pdf. Note the AIP SUPP is now four pages of relevant links to individual Annex differences. The reasoning for the change to the SUPP, listed at Para 1.2, is absolute bollocks, this is just another cynical attempt to cover up the embarrassing number (over a 1000) of notified differences to ICAO SARPs}    

Quote:
Australia's Civil Aviation Safety Regulation review started in 1988, but still has no end in sight.


CASA lacks Expertise to adopt ICAO Standards: AMROBA
17 Mar 2016

AMROBA Update - KC on a roll

Binger today via the Oz :

Quote:Call for action on Australia’s aviation maintenance trainees

• Mitchell Bingemann
  
• The Australian
  
• March 18, 2016 12:00AM
  

Reporter
Sydney

 
Ken Cannane, of the Aviation Maintenance Repair and Overhaul Association, says practical skills are not being taught before engineers start work. Picture: Renee Nowytarger

 
A dramatic overhaul of aircraft maintenance traineeships is urgently needed if Australia is to dodge a chronic shortage of aviation engineers, according to researchers and industry groups.

The calls come as statistics from government departments show sharp declines in the number of engineers completing training for aircraft maintenance roles over the past 10 years.

According to figures from the Department of Employment, the number of aviation apprentices and trainees has more than halved from its peak of 779 in 2013 to 370 in 2015.

A recent report from researchers at the University of NSW — titled The Future of Aircraft Maintenance in Australia — also pointed to declines in the training of maintenance staff, finding that a global workforce shortage within the next 10 years would see a 30 per cent shortage of trained aircraft maintenance workers. It said Australia would be hit harder than other nations.

“This means moving quickly to rebuild both aircraft maintenance and maintenance training industries by 2020, to permit Australia to handle a high proportion of its own needs across the civilian airline, general aviation and defence sectors,” the report said.

Ken Cannane, a director for the Aviation Maintenance Repair and Overhaul Association, said the shortage was being exacerbated by a “deskilling” of the workforce because practical skills were no longer being taught before engineers made it into employment.

“This clearly shows that a new approach is needed to provide the practical skills and theoretical knowledge for future aircraft maintenance engineers and technicians,” Mr Cannane told The Australian.

Mr Cannane said that while official figures from the Civil Aviation Safety Authority showed the number of aircraft maintenance engineers on the rise, he said that was only because the organisation had introduced a perpetual licence scheme in 2007.

“This gives the impression that the number of engineers is always growing but because the licences are perpetual we have no idea how many have left and how many are actually still working in the industry,” he said.

“Many training organisations have simply trained far too many people for the industry.

“More importantly, while these training programs have met the documented qualification standards as set out by CASA, they have not, and do not provide the skills needed by industry.”

A spokesman for the CASA disputed the figures and assertions from AMROBA, saying it was “not correct to state that the number of people completing training to become licensed aircraft maintenance engineers is falling”.

“For example in 2011 a total of 211 people completed aircraft mechanical training. In 2012 this rose to 370 and in 2013 this rose again to 410,” the spokesman said.

“It is important all maintenance personnel hold recognised national qualifications that ensure the maintenance and repair industry has a highly skilled workforce.”

The report from UNSW also raised concerns about the level of training that aspiring aircraft engineers went through before becoming fully qualified.

“Australia has allowed its training system to run down, with enrolments in certain categories at their lowest since statistics have been collected, raising concerns that qualifications are not meeting international standards,” the report said.

Mr Cannane said it was imperative that the current training schemes for aircraft maintenance engineers placed a greater emphasis on real-world skills.

“We need a complete review of the apprenticeship traineeships that underpin the licensing system,” he said.

“Our concern is that the Australian qualification framework doesn’t include the practical skills necessary for aviation work. This needs to be addressed, it needs to be fixed and we need to get practical skills back into focus so people can safely work on aircraft.”

The CASA spokesman said while competency-based training remained the basis for all national vocational training standards, it did not mean appropriate practical training and support was being ignored.

“CASA provides guidance to aircraft maintenance organisations about how they can continue to use the CASA Schedules of Experience to confirm that vocational training received in TAFE is further supported in practice in the workplace,” the spokesman said.

“CASA has proposed a new set of standards for the training of engineers who work on small aircraft.

“CASA believes the introduction of these specific licensing requirements for small aircraft predominantly used in general aviation will further allow training to be tailored to support industry needs and promote participation in aircraft maintenance occupations.”

Nah..CASA would never doctor the figures, would they?



MTF..P2

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RE: AMROBA. - Gobbledock - 03-18-2016

CAsA spinning the numbers.......again


KC of the Sunshine Band fraternity said;

"Mr Cannane said that while official figures from the Civil Aviation Safety Authority showed the number of aircraft maintenance engineers on the rise, he said that was only Mr Cannane said that while official figures from the Civil Aviation Safety Authority showed the number of aircraft maintenance engineers on the rise, he said that was only because the organisation had introduced a perpetual licence scheme in 2007.

“This gives the impression that the number of engineers is always growing but because the licences are perpetual we have no idea how many have left and how many are actually still working in the industry,” he said."

Go Ken!!!! 
You know what I like about Ken? The wily old bugger has been around for an eternity and he can see through a bullshit, fudged Government smokescreen before it has even be thought up! Those numbers quoted are bullshit. "Perpetual figures"! Fu#k me sideways, what a beauty? Murky and his minions have done a nice job using that 'hard to quantify formula' for providing accurate figures. Bollocks! 

CAsA you are a bunch of shysters.

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