[Peetwo]

RAAA Convention 21-23 October 2015



 I note that the RAAA convention officially kicks off today in the Hunter, is this just another WOFTAM gobfest; or could it be a catalyst for getting the Forsyth (ASRR) report & recommendations back on track, a kind of last chance for the Miniscule?

Looking at the program for tomorrow it would appear that not only is the DPM making an appearance but also the terrible trio - 'the three stooges':

Friday 23 October 2015

Session 8
09:00 - 09:30
The Hon Warren Truss
Deputy Prime Minister
Minister for Infrastructure and Regional Development
(Subject to Final Confirmation)

Regional Aviation: The Sky's the limit..

---

..Session 10
10:00 - 10:30
Mark Skidmore
Director of Aviation Safety,
Civil Aviation Safety Authority

CASA's direction - Regional focus...

---

..Session 13
12:30 - 13:00
Jason Harfield
A/g Chief Executive Officer
Airservices Australia

Delivering value for Australian aviation

---

Session 14
13:00 13:30
Martin Dolan
Chief Commissioner
Australian Transport Safety Bureau

Repeat lessons: What the ATSB is finding?..

  
Now in the course of the day's official business I would like to nominate an IOS/PAIN representative to somehow get the DPM in a headlock & bend his ear. 
IMO that person should be this bloke..

And here is why (reference from RAAA Winter Newsletter 2015):

If you take a look around the world you will see a number of countries that are particularly dependent upon aviation as a core component of their transport and social infrastructure; Australia is clearly one of those countries.

Why is it then that we as a nation suffer so badly from a regulatory regime that is so poorly suited to modern Australia and our industry?

There are many reasons for this of course, mainly historical but also geographical and political that lead us to a system today that is overly complex, anachronistic and damaging, not only to our future investment in hard assets but more importantly, in people.

Many participants I speak to in the aviation industry have recently and deliberately steered their children and grand-children well clear of aviation. I too do not want my children involved in the industry unless we see some strong leadership from Government.

We have to ask a further question. Why is it that many of us who have been in the industry for a long time do not see it as an industry worth considering for the next generation(s)? We will come back to this question shortly.

As has been expertly chronicled in the Aviation Safety Regulation Review (ASRR), chaired by David Forsyth, there is much wrong with the industry and whilst the current government should be congratulated for implementing that review, they have been close to negligent in the speed by which they have dealt with its recommendations.

We have only recently seen the Statement of Expectations (SOE) issued by the Minister to CASA, a full six months after the appointment of the new Director of Aviation Safety, Mark Skidmore. Additionally, we are only now seeing movement on the ASSR recommendations, a full 15 months after its publication.

One of the overriding themes from the ASRR was the breakdown in the relationship between CASA and the industry. This was born of many issues, most of which remain. The debacle that is Part 42 and Part 145 was implemented with undue haste and from my view with potentially dangerous outcomes. Can someone please explain how we have a safer and more efficient industry as a result of those changes? We certainly have far fewer participants in aviation as smaller organisations that could not afford the layers of bureaucracy that those changes brought, exited the industry.

Those organisations employed staff all over Australia and now we have lost an unacceptable volume of skills that sadly are now provided by overseas suppliers.
Separately, can someone also explain the shambles that is Part 61?

I feel for those pilots who have finished their training since August of last year and still cannot get their ATPL’s issued. These candidates are our industry’s future, and thus having expended an enormous amount on their licence, have no way of gaining or advancing their employment. This is scandalous. How would CASA have reacted if an aviation organisation in Australia had botched a major change to their operations to this extent? An immediate “Show Cause” I would think.

Can someone also explain the huge disconnect between Commonwealth and State legislation that now limits engineering apprentice training to only a handful of registered organisations?

Further, it is both outrageous and concerning, that there exists such a dichotomy between the CASA regions, the Certificate Management Teams and individual inspectors. This is evidenced through the inconsistency in interpreting and applying the provisions of the Regulations. Fatigue Risk Management is a classic and topical example of the lack of direction, cohesion, or understanding that exists within the regulator.

The four examples I have given above are real life outcomes of a disjointed framework in which the aviation industry operates throughout this vast country.
Under successive colours of government we have ended up with a regime that is broken.

Whilst we enjoy an enviable safety reputation in this country, this is borne more of the diligence of personnel within our surviving aviation providers than in regulation and regulatory oversight itself.

Senior managements within all organisations I know are well aware of their obligations under the Civil Aviation Act and discharge their duties with diligence and concern. This is why outcomes such as Part 61 cause us all such heartache.

By my calculations we are into our 23rd or 24th year of “Regulatory Reform” and all I now see is “Regulatory Reform Fatigue” as the outcome of many failed processes, false starts and confusion.

So in that environment, how are we going to encourage the next generation into the industry? I fear that will become increasingly more difficult.

I have outlined above just a few examples of where the industry, regulators and government are not working together to foster the industry.

It’s easy to bleat I know, and much harder to fix “machinery” that has been covered in temporary fixes for decades. Perhaps what is most frustrating, and the reason for the bleating, is that many of the solutions have already been identified and recommended by the ASSR and supported by industry.

When we ask the question as to why we simply did not adopt the New Zealand regulations we are told that somehow “Australia is different” and then in the next breath we hear about harmonisation with the rest of the world.

Look at all the South Pacific nations that have adopted the New Zealand regulations and the benefits that now flow to New Zealand suppliers as a result.

Why does it take months to modify an aircraft for Australian registration when it takes days in Europe?

The New Zealand experience of Aviation Regulatory Reform is in my opinion a success story. It was achieved through real consultation and collaboration, and a genuine willingness of CAANZ to engage with industry.

The solution obviously rests with Parliament and the relevant Minister(s)

We elect Government, they set the legislative environment, formulate the regulatory framework and then employ the senior personnel to regulate. The industry supports this but DOES NOT support individual personnel within regulators running their own “legislative” agendas.

The industry is encouraged by the appointment of directors from industry to the new CASA Board.

However, Parliament must take a greater interest in aviation and each colour of government should at least have a Junior Minister for Aviation that can dedicate their time to ensuring the regulatory framework and policy settings are appropriate for our modern industry.

Without a bold new coordinated vision for our industry how do we hope to attract the appropriate talent to take this vital industry forward?

Please note these views are personal and do not necessarily reflect the views of my employer.

 
I know..I know it is only rhetoric/words on a page; but you get the feeling there is much passion behind the words - bravo Scott, cyber choc frog for that effort..

The RAAA recently (see above) held their annual convention in the Hunter, apparently discussions on the Forsyth review & the reform of CASA caused much contention amongst certain delegates - Reference: Safeskies thread - The Emperor's new clothes - MKII. However maybe this will end up being the catalyst, the final straw that broke the Camel's back - one can only hope -  .

Link for RAAA webpage & newsletter.



MTF..P2  

[Peetwo]

RAAA Convention 21-23 October 2015

  I note that the RAAA convention officially kicks off today in the Hunter, is this just another WOFTAM gobfest; or could it be a catalyst for getting the Forsyth (ASRR) report & recommendations back on track, a kind of last chance for the Miniscule?

Looking at the program for tomorrow it would appear that not only is the DPM making an appearance but also the terrible trio - 'the three stooges':

Friday 23 October 2015

Session 8
09:00 - 09:30
The Hon Warren Truss
Deputy Prime Minister
Minister for Infrastructure and Regional Development
(Subject to Final Confirmation)

Regional Aviation: The Sky's the limit..

---

..Session 10
10:00 - 10:30
Mark Skidmore
Director of Aviation Safety,
Civil Aviation Safety Authority

CASA's direction - Regional focus...

---

..Session 13
12:30 - 13:00
Jason Harfield
A/g Chief Executive Officer
Airservices Australia

Delivering value for Australian aviation

---

Session 14
13:00 13:30
Martin Dolan
Chief Commissioner
Australian Transport Safety Bureau

Repeat lessons: What the ATSB is finding?..

  
Now in the course of the day's official business I would like to nominate an IOS/PAIN representative to somehow get the DPM in a headlock & bend his ear. 
IMO that person should be this bloke..

And here is why (reference from RAAA Winter Newsletter 2015):

If you take a look around the world you will see a number of countries that are particularly dependent upon aviation as a core component of their transport and social infrastructure; Australia is clearly one of those countries.

Why is it then that we as a nation suffer so badly from a regulatory regime that is so poorly suited to modern Australia and our industry?

There are many reasons for this of course, mainly historical but also geographical and political that lead us to a system today that is overly complex, anachronistic and damaging, not only to our future investment in hard assets but more importantly, in people.

Many participants I speak to in the aviation industry have recently and deliberately steered their children and grand-children well clear of aviation. I too do not want my children involved in the industry unless we see some strong leadership from Government.

We have to ask a further question. Why is it that many of us who have been in the industry for a long time do not see it as an industry worth considering for the next generation(s)? We will come back to this question shortly.

As has been expertly chronicled in the Aviation Safety Regulation Review (ASRR), chaired by David Forsyth, there is much wrong with the industry and whilst the current government should be congratulated for implementing that review, they have been close to negligent in the speed by which they have dealt with its recommendations.

We have only recently seen the Statement of Expectations (SOE) issued by the Minister to CASA, a full six months after the appointment of the new Director of Aviation Safety, Mark Skidmore. Additionally, we are only now seeing movement on the ASSR recommendations, a full 15 months after its publication.

One of the overriding themes from the ASRR was the breakdown in the relationship between CASA and the industry. This was born of many issues, most of which remain. The debacle that is Part 42 and Part 145 was implemented with undue haste and from my view with potentially dangerous outcomes. Can someone please explain how we have a safer and more efficient industry as a result of those changes? We certainly have far fewer participants in aviation as smaller organisations that could not afford the layers of bureaucracy that those changes brought, exited the industry.

Those organisations employed staff all over Australia and now we have lost an unacceptable volume of skills that sadly are now provided by overseas suppliers.
Separately, can someone also explain the shambles that is Part 61?

I feel for those pilots who have finished their training since August of last year and still cannot get their ATPL’s issued. These candidates are our industry’s future, and thus having expended an enormous amount on their licence, have no way of gaining or advancing their employment. This is scandalous. How would CASA have reacted if an aviation organisation in Australia had botched a major change to their operations to this extent? An immediate “Show Cause” I would think.

Can someone also explain the huge disconnect between Commonwealth and State legislation that now limits engineering apprentice training to only a handful of registered organisations?

Further, it is both outrageous and concerning, that there exists such a dichotomy between the CASA regions, the Certificate Management Teams and individual inspectors. This is evidenced through the inconsistency in interpreting and applying the provisions of the Regulations. Fatigue Risk Management is a classic and topical example of the lack of direction, cohesion, or understanding that exists within the regulator.

The four examples I have given above are real life outcomes of a disjointed framework in which the aviation industry operates throughout this vast country.
Under successive colours of government we have ended up with a regime that is broken.

Whilst we enjoy an enviable safety reputation in this country, this is borne more of the diligence of personnel within our surviving aviation providers than in regulation and regulatory oversight itself.

Senior managements within all organisations I know are well aware of their obligations under the Civil Aviation Act and discharge their duties with diligence and concern. This is why outcomes such as Part 61 cause us all such heartache.

By my calculations we are into our 23rd or 24th year of “Regulatory Reform” and all I now see is “Regulatory Reform Fatigue” as the outcome of many failed processes, false starts and confusion.

So in that environment, how are we going to encourage the next generation into the industry? I fear that will become increasingly more difficult.

I have outlined above just a few examples of where the industry, regulators and government are not working together to foster the industry.

It’s easy to bleat I know, and much harder to fix “machinery” that has been covered in temporary fixes for decades. Perhaps what is most frustrating, and the reason for the bleating, is that many of the solutions have already been identified and recommended by the ASSR and supported by industry.

When we ask the question as to why we simply did not adopt the New Zealand regulations we are told that somehow “Australia is different” and then in the next breath we hear about harmonisation with the rest of the world.

Look at all the South Pacific nations that have adopted the New Zealand regulations and the benefits that now flow to New Zealand suppliers as a result.

Why does it take months to modify an aircraft for Australian registration when it takes days in Europe?

The New Zealand experience of Aviation Regulatory Reform is in my opinion a success story. It was achieved through real consultation and collaboration, and a genuine willingness of CAANZ to engage with industry.

The solution obviously rests with Parliament and the relevant Minister(s)

We elect Government, they set the legislative environment, formulate the regulatory framework and then employ the senior personnel to regulate. The industry supports this but DOES NOT support individual personnel within regulators running their own “legislative” agendas.

The industry is encouraged by the appointment of directors from industry to the new CASA Board.

However, Parliament must take a greater interest in aviation and each colour of government should at least have a Junior Minister for Aviation that can dedicate their time to ensuring the regulatory framework and policy settings are appropriate for our modern industry.

Without a bold new coordinated vision for our industry how do we hope to attract the appropriate talent to take this vital industry forward?

Please note these views are personal and do not necessarily reflect the views of my employer.

 
I know..I know it is only rhetoric/words on a page; but you get the feeling there is much passion behind the words - bravo Scott, cyber choc frog for that effort..

The RAAA recently (see above) held their annual convention in the Hunter, apparently discussions on the Forsyth review & the reform of CASA caused much contention amongst certain delegates - Reference: Safeskies thread - The Emperor's new clothes - MKII. However maybe this will end up being the catalyst, the final straw that broke the Camel's back - one can only hope -  .

Link for RAAA webpage & newsletter.

To add to the above, here is the RAAA written contribution to the Forsyth (ASRR) review.. :

246 Regional Aviation Association of Australia (RAAA) - PDF: 5469 KB 


II. EXECUTIVE SUMMARY

The RAAA believes the bulk of its concerns stem from a poor culture in CASA which itself results from poor senior management and governance over several decades. If the Government of the day is not to take a more active role in the formulation of aviation policy generally and, through the relevant Department, a more active role in the management of the aviation bureaucracy, it must be prepared to create a more substantial and active Board to oversight CASA’s management.

Successful operators are responsible operators who understand that safety management is integral to the management of their businesses. A safety culture cannot be imposed, it must be fostered. A regulator can police sensible accepted standards, but it cannot foster the safety culture with a rule book and a heavy handed application of penalties.

A genuine safety culture comes from the regulated and the regulator sharing essentially the same values and the same objectives. They will not always agree on the means to achieve these, but without this common basis the safety culture will be undermined. Sound safety culture and practice can really only be achieved by way of a partnership being forged between the regulator and industry.

Today in Australia the regulator, CASA, is held in such low regard there is no common ground, but more of a “them” and “us” attitude. Additionally, industry participants are wary of talking publicly about CASA due to a fear of retribution. This fear is reflected by some RAAA Members’ apprehension in providing examples for our submission to this Inquiry, regardless of whether our submission is classified confidential or not.

&...RAAA response to Forsyth final report:

Regional Aviation Association of Australia - PDF: 396 KB


II. EXECUTIVE SUMMARY


The RAAA welcomes the release of the ASRR Report and commends Deputy Prime Minister Truss for delivering on his pre-election promise to put Australia’s aviation regulatory system under the microscope.

In general, the RAAA endorses the key aspects of the report and looks forward to seeing them implemented.

In addition the RAAA recommends that the philosophy of just culture be incorporated into legislation through the Civil Aviation Act, CASRs and the Transport Safety Investigation Act, rather than through a CASA formulated policy document.

The RAAA proposes that the ATSB transfer information from Mandatory Occurrence Reports to CASA without redaction or de-identification only when just culture principles have been legislated for in Australia.

MTF...P2

[Kharon]

Visit Jabiru Aircraft - HERE - the rest of the quoted report is HERE.   Find five minutes.

June 17, 2015 Operational Limitations on Jabiru Powered Aircraft CASA 292/12.

7 months of Limitations of Jabiru powered aircraft has had a devastating effect on the Jabiru Aircraft company and its associates throughout the world. The viability of Jabiru Aircraft Pty Ltd has been severely threatened and may not be recoverable if the current limitations are continued. The damage inflicted by the CASA publicity of the Limitations and the “Acknowledgement and Acceptance of Risk -Potential Engine Malfunction during Flight Time” waiver will be near impossible to be reversed. Publicity of any incident since, involving a Jabiru aircraft has referenced the CASA imposed Limitations and reinforced the CASA message. The harm that is being done is immeasurable and we call for it to be brought to an end now. Statistics and data attached to this letter support this call.

Over the past 7 months Jabiru has given CASA an insight into the depth of engineering knowledge and research and development that goes on behind the scenes on a day to day basis at Jabiru. Jabiru has also provided all the engineering documents that were used for the last certifications of modifications through the CASA authorised person Alan Kerr; engine reports for ASTM compliance; reports for engines achieving 1000 hours and numerous tear down reports of engines from reported incidents.

Jabiru has complied with the standards of certification approved by CASA and continues to monitor airworthiness issues for Jabiru aircraft and engines and issue the appropriate service notifications. Already this year there has been a significant decrease in Jabiru engine incidents. It would appear the incident rate is now equal to or less than the Rotax incidents by which we were judged last year and were given as the justification of the operational limitations.

Jabiru recognises that education on operational and maintenance issues is very important and has directed significantly more resources to workshops each month focusing on maintenance and operation. Assistance by CASA and RAA would be appreciated in this area as well as in recovering more evidence from incidences to allow complete investigation.

Jabiru calls for all restrictions to Jabiru powered aircraft be lifted for aircraft that have complied with all the Jabiru service bulletins and letters, operate the aircraft in accordance with the manuals, have performed the maintenance in accordance with the manuals and use trained technicians and where the aircraft do not have unapproved modifications.

Only for those owners and operators of Jabiru powered aircraft that do not wish to comply with the Jabiru requirements, do we support the limitations remaining in place until compliance occurs with all Jabiru service bulletins, letters, manuals and conditions of operation. We object to the present form of ‘waiver’ in any event as we regard it as blatantly misleading of the public.

For Jabiru powered aircraft in the Experimental categories of RAA and SAAA, those organisations are able to assess the risk of owner modifications and apply limitations if required.  Jabiru may be able to assist if technical information is required.

Jabiru Aircraft acknowledges CASA’s primary safety related obligations however the overwhelming body of evidence shows Jabiru Aircraft to be one of the safest aircraft in this category of aircraft on the Australian register based on statistics. Student pilots, passengers and persons on the ground are at no greater risk of injury from a Jabiru Aircraft than any other aircraft. It could be argued from the statistics that in fact there is less chance of risk to these persons in a Jabiru Aircraft

Takes a hungry man to enjoy eating betrayal for main course and wanton destruction for dessert.

Such is life on the slippery pole.

[Peetwo]

IOS bullshit detector test

2015 RAAA National Convention: ‘The Sky's the Limit’

Speech
WTS026/2015
23 October 2015

Crowne Plaza, Hunter Valley


Thank you Paul [Tyrell, CEO, RAAA].

Good morning everyone.

I would first like to particularly thank Jim Davis, the Chair of the RAAA, and his fellow Board members for their contributions to regional aviation, and for the invitation to speak with you today.

I would also like to thank Paul Tyrell for his great contributions as CEO of the Association for many years—well done Paul, and all the best for the future.

The Coalition Government is deeply committed to regional Australia—and we recognise how much its progress depends increasingly on a healthy regional aviation sector.

Their interdependence has been constant since aviation began in Australia.

In the 20th century the emerging regional aviation industry was a leap forward in communication like the broadband network is today.

Regional aviation pushed literally above and beyond the limits of surface transport and created a quantum leap in networking regional Australia into the national economy.

And aviation provided regional Australians with access to essential health and other services through innovations, like the Flying Doctor service, which remain vital today.

It is interesting to reflect that the metropolitan air links between Brisbane and Sydney actually grew out of the regional links between Lismore and Brisbane, and later Lismore and Sydney, that New England Airways established in the 1930s.

Qantas, also, as we all know, started as a small regional airline flying Winton to Longreach in Central West Queensland. Qantas deserves great credit for the way it preserves its heritage, particularly with its support of the founders museum in Longreach.
These cases offer two lessons that remain relevant today.

Firstly, regional efforts can create pay-offs which ultimately benefit all Australians.

And secondly—even in a digital economy where much can be done remotely—regional aviation provides, and will continue to provide, many of the major arteries connecting Australia's regions into the broader national life.

For our part, the Government is committed to maintain the right environment for sustaining the health of these arteries.

Trends in regional aviation
As you know very well, the progress of any industry sector cannot be assured and from time to time all will face challenges. Most regional airlines do not go on to be a Qantas and drift off into history.

It is a tough business.

Regional aviation is facing its challenges again especially around a fall in demand in some sectors.

In the 12 months to July this year there was an overall decline of 2.9 per cent in passenger movements through Australia's regional airports—itself part of a decline of 0.6 per cent in Australia's total domestic passenger flows.

These contractions are always unwelcome.

However, they emphasise the importance of all aviation players—including governments and industry—being on top of their game and doing what is necessary to expedite a rebound.

This includes being responsive to shifts in demand around regional Australia—and several areas are showing impressive growth.

Then decline is heavily focused on FIFO services where cutbacks in mine staffing and new developments have slashed travel requirements. On the other side the lower value of the Australian dollar has been a huge help to the Australian tourist industry with more overseas visitors finding Australian more affordable and locals realizing it is cheaper to holiday at home.

In July 2015, passenger traffic on the Sunshine Coast—Sydney route was 11.7 per cent greater than in July 2014; the Darwin—Perth route was up by 9.7 per cent; and the Broome to Perth route was up by 8.5 per cent.

The strongest growth of all was at Proserpine Airport in the Whitsundays, where passenger movements were up 27.8 per cent over July 2014. Cairns and Ayres Rock are enjoying a resurgence. Following strong and sustained growth in outbound Australian tourism for a decade, the fall in the value of the Australian dollar is creating real opportunities to reinvigorate the growth in domestic tourism.

The bottom-line here is that there are good grounds for an realistic optimism about regional aviation's prospects.

Regional aviation
The Australian Government is investing both dollars and effort in these prospects.
We are targeting our investments to where they are most needed, and they cover several of regional aviation's immediate and longer-term concerns.

The Government's support for regional air services is among our significant efforts. Our En-Route Charges Payment Scheme is providing an additional $4 million up to June 2019 to support regional carriers in providing passenger services to many smaller communities.  
The Scheme assists carriers to service over 30 economically vulnerable regional passenger routes.

These include new routes such as Mudgee to Sydney, Taree to Newcastle and Perth to Onslow.

In parallel, we have directed $4 million up to June 2019 to continue supporting vital aeromedical regional services, such as the Royal Flying Doctor Service. 

And of course, built infrastructure is as vital to regional aviation as to any other industry.

We significantly increased funding for the Regional Aviation Access Programme in the May budget with an extra $33.8 million up to 2018–19 for upgrades to remote airstrips, with more announcements soon.

These infrastructure capital works complement the $56 million up to 2018–19 that the Government is directing to air operators to provide remote and isolated regions with a regular air transport service. Some 260 communities are serviced under this programme.

These generally weekly services carry passengers and freight including fresh food, educational materials, medicines and other necessities.

These vital services to isolated areas underline the great value of regional aviation to regional Australia—and the Government is pleased to do our part in supporting them.

Northern Australia
Our release of the White Paper on Developing Northern Australia earlier this year was a significant development for regional Australia's future—and for regional aviation.

The White Paper included a commitment to create a Business Stakeholder Group dedicated to improving aviation and maritime connections in the north.

I will be announcing the establishment of the Group soon. It will represent a broad cross-section of skills across the aviation and maritime industries and the wider business community.

The Group will work closely with regional aviation stakeholders to identify impediments to aviation services and develop practical solutions for further growth in the North.

Regional access to Sydney Airport
I mentioned earlier the pioneering efforts of New England Airways in the 1930s—and an important function of regional aviation clearly remains connecting metropolitan and regional areas.

A Western Sydney Airport will be operational by the mid-2020s and a new greenfields capital city airport is one of the most exciting aviation projects imaginable.

It is estimated that by 2060, a Western Sydney Airport will increase in Australia's GDP by $24 billion—and this growth will provide significant opportunities for regional airlines.
On Monday I released the draft Airport Plan and draft EIS for public comment over 60 day or 45 business days).

First stage construction of a single 3,700 meter runway and terminal building will cater for 10 million passengers, car parking and our $3.6 billion Western Sydney roadworks package is well underway. Our plan provides for a second parallel runway around 2050 to cater for 80 million passengers.

However, Sydney's Kingsford Smith Airport remains an essential transport hub for regional New South Wales. 

And the Government is committed to retain the existing protections for regional airline access to Kingsford Smith Airport.

The new Western Sydney Airport will provide scope for growth, not a substitute for existing arrangements.

Aviation Safety Regulation

I am well aware of the RAAA's concerns about the extent and nature of Australia's aviation safety regulation.

 

The Government's Aviation Safety Regulation Review acknowledged Australia's excellent aviation safety record—but identified scope for improvements to maintain this record.



The Government agreed to most of the Report's 37 recommendations and action is well under way to implement the Government's response to the Report.



I have already issued new Statements of Expectations to Australia's three key aviation safety agencies—CASA, Airservices Australia, and the Australian Transport Safety Bureau.



These publicly outline the Government's expectations of these agencies over the next two years—including the timely implementation of our response to the Report.



The Government has appointed a new CASA Board, including members who bring relevant technical, operational, governance and managerial aviation experience to the Board. That includes new CASA Chair, Mr Jeff Boyd whom I'm sure you all know very well given his regional aviation background.



The Government also welcomes CASA's release of its new regulatory philosophy—which emphasises the importance of collaboration and communication between CASA and Industry.



CASA is engaging with the aviation industry on several deregulation initiatives to reduce the regulatory burden on industry. This includes looking at specific regulations, rules and procedures that impact on regional airlines.



CASA has also invited the industry to submit specific deregulation proposals.



I encourage the RAAA to continue its work through its own proposals with CASA staff and the Director of Aviation Safety, Mark Skidmore, who is speaking at this conference.

{Okay ran the BS meter over this part of the miniscule's RAAA speech and I am afraid the results were not good -



}

Aviation skills
It is clearly essential that the aviation industry's workforce has the skills and qualifications needed to meet future growth and demand without compromising safety.

The Transport and Logistics Industry Skills Council has identified a range of aviation specific workforce development needs and challenges.

Globally, the International Civil Aviation Organisation, predicts that in the next 20 years airlines will need an additional 25,000 new aircraft to meet demand—it may be a good time to consider buying shares in aircraft manufacturers!

As a result, by 2026 the entire international industry will need 350,000 new pilots and 480,000 new technicians to maintain the aircraft.

There is already a particularly high demand for pilots—and, almost inevitably, poaching—stemming from strong growth in Asia and the Middle East.

These pressures are impacting on Australia and, although I note the good work Rex is doing through their Pilate Cadet Programme—there are significant difficulties in attracting people to work in regional or remote locations.

These pressures create the need to better understand the current challenges and future workforce needs of Australia's aviation industry.

This is why I am establishing an Aviation Workforce Skills Study.

The Study will help Government and industry better understand the future needs of the Australia's aviation workforce, so that we can work to meet them.

The Aviation Industry Consultative Council has advised on the parameters of the study and my Department has engaged the Transport and Logistics Industry Skills Council to lead this work—with a close engagement with industry.

I expect the study to be completed in early 2016.

The Government is also finalising a new and contestable model for developing vocational education and training products.

Australian industry will take the lead in this process, because it is best-placed to know its current and future skills needs.

The move to a contestable model ensures arrangements respond to industry needs.
Skills Service Organisations will be selected through a competitive grants process. They will assist Industry Reference Committees to develop and review suitable training products—and we will shortly announce the successful Skills Service Organisations which will support the Committees.

I expect that the new arrangements will be fully operational from January 2016.

Announcement of the Regional Aviation Security Awareness training package
Finally, the safety and security of Australian aviation is the fundamental priority for the Government, and everyone engaged with the industry.

While there is no evidence of a specific threat to regional aviation in Australia, it is likely to remain a potential terrorist target for the foreseeable future.

The nature of this threat will continue to evolve—so it is essential for Government and industry to continue their efforts to deal with it.

In this context the Government has decided to fund the development and delivery of a new Regional Aviation Security Awareness Training Package.

The Package will commence in 2016 and be available to the 158 security controlled airports in small, lower-risk categories—including 49 airports which host screened air services, such as the Bundaberg, Devonport, Geraldton and Tamworth Airports.

The Package will support many regional and remote airports in accessing important training.

It will provide them with a comprehensive understanding of the current risk environment, assist them in planning responses to future threats, and improve general security awareness.

My Department will shortly begin consultations with regional and remote airport and airline representatives to develop the content and learning delivery model for the Package.

The current Regional Passenger Screening Programme will now be directed to raising security awareness at regional and remote airports.

Regional and remote airports are vital to Australia's prosperity and well-being—and the new training initiative will support their efforts to provide a secure aviation environment.

Conclusion
I have touched on a wide range of issues over the past few minutes—but, as you know, the breadth of issues involved in aviation is very much the nature of this industry.

The initiatives I have announced today will make an important contribution to regional aviation.

But beyond the specifics of both our new and existing measures, I can assure you that the Australian Government is thoroughly committed to the progress of regional aviation.
And we share your goal of ensuring it continues to maximise its longstanding—and outstanding—contribution to the Nation.

Thank you very much, and I am happy to take your questions.

MTF..P2

[Gobbledock]

What an absolute crock of shit. Hey Truss you stupid old goat, you can stick that load of manure on the garden as that is all your speech is good for - garden fertiliser or toilet paper!

And the Miniscules parting speech comment;

Thank you very much, and I am happy to take your questions.

Yes, Gobbbledock has a question sir; When are you going to f#ck off and retire and give us somebody who actually isn't full of piss and wind and actually knows about aviation, like David Fawcett?

Kind regards
Gobbles

[Peetwo]

Changing the guard -

Couple of aviation media outlets reported on the new CEO appointment at the RAAA. This (presumably from Denise) courtesy AvBiz off the Yaffa:

Mike Higgins, new CEO of RAAA


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:

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.

Hmm...some dots just started appearing on the horizon...

MTF...P2

[Peetwo]

 From Senate Estimates thread post - Senate Inquiry: Airport & aviation security

Senate Inquiry: Airport & aviation security - What's the delay?

From Jamie Freed AFR article - Australian government should put domestic airport security in its sights:

In December 2014, a Senate inquiry into airport and aviation security was started to help determine if further measures were needed to enhance airport security and the safety of the travelling public, after a report by Seven Network found there had been 282 security breaches at Australian airports between January 2012 and April 2014. However, the initial reporting date for the inquiry of April 2015 has been postponed several times and is scheduled now for May 19, more than a year after submissions and testimony were given.

In the fast-moving world of aviation security, much of the information presented to the inquiry is now dated. But, notably, an Australian Federal Police submission did raise concerns that although it is an offence to use a false identity on a domestic flight, police have no authority to demand identification until after the event or unless another offence is being committed...

...If Australia wants to close gaps in its domestic airport security it is important the report by the inquiry examining such issues does not continue to be postponed.

I must admit to switching off somewhat with this inquiry, because it seemed to be missing the point that the whole aviation security system needed to be audited from the top down. It is a basket case and achieves very little in effective aviation security while placing significant impost on industry where it can least afford it and where it is quite obviously overkill.

However there is no excuse for this inquiry (with one public hearing February 2015) to have its reporting date deferred for over a year, the original reporting was supposed to be 26 April 2015...

Airport and aviation security


On 4 December 2014, the Senate moved that the following matters be referred to the Rural and Regional Affairs and Transport References Committee for inquiry and report by 26 April 2015.

Airport and aviation security.

Submissions should be received by 16 January 2015. The reporting date is 26 April 2015. On 26 March 2015, the Senate granted an extension of time for reporting until 21 May 2015. On 14 May 2015, the Senate granted an extension of time for reporting until 12 August 2015. On 12 August 2015, the Senate granted an extension of time for reporting until 9 September 2015. On 9 September 2015, the Senate granted an extension of time for reporting until 2 December 2015. On 12 November 2015, the Senate granted an extension of time for reporting until 19 May 2016.

---

Committee Secretariat contact:
Committee Secretary
Senate Standing Committees on Rural and Regional Affairs and Transport
PO Box 6100
Parliament House
Canberra ACT 2600

Phone: +61 2 6277 3511
Fax: +61 2 6277 5811
rrat.sen@aph.gov.au

I would suggest that this inquiry for whatever reason has placed the Department, the Minister & the Committee in somewhat of a dilemma - I wonder why?

While in this inquiry I confess to having missed some excellent evidence given at the one and only public hearing from the RAAA, so in an effort to redeem myself (& maybe provide a clue to where the dilemma may lie), here is most of the Hansard from the RAAA session:

EAVES, Mr Stuart, General Manager Safety, Security and Quality Assurance, Regional Aviation Association of Australia TYRRELL, Mr Paul, Chief Executive Officer, Regional Aviation Association of Australia

[11:19]

...CHAIR: I invite you to make a brief opening statement.

Mr Tyrrell : Thank you. It will be brief. The RAAA and it members support a robust risk based, cost-efficient security environment. We do not have any problems on that front. We would like to see—and the committee has discussed this—benchmarking with other countries just to make sure that we are not out on a limb. As you are probably aware, regional aviation, while it has a high turnover, has fairly slim profit margins. We are somewhat 'customers' of the security environment and so we try to keep things as cost efficient as possible while, at the same time, keeping our passengers safe. The last comment is more an economic one. In the last two years, we have lost four longstanding regional airlines. I am not blaming security but I am just pointing out the environment we live in.

CHAIR: You are have financial pressures. That is what we are talking about?

Mr Tyrrell : Yes. That is correct.

CHAIR: It is not as though they have won Lotto and just taken off for the Whitsundays.

Mr Tyrrell : Not at all, Senator.

CHAIR: In your opening statement you said that you would like to see Australia benchmarking with other countries.

Mr Tyrrell : Yes.

CHAIR: As a bit of a preamble, I have had the pleasure of visiting New Guinea, where I was not allowed on a domestic flight from Mount Hagen to Port Moresby because my suitcase was a little bit big, but I was allowed to take the stone axe that I was given and the arrows that I had bought to support the local economy. But in America they make you take off your thongs. I like to travel with thongs because I don't know what I might smuggle in in a half-inch piece of rubber! Anyway, that is fine. We have heard about New York and how tight security is there. I am not going to belittle the argument, but I really dread flying domestic around America because they are really, really stringent. What countries do you reckon we should benchmark against and in what areas?

Mr Tyrrell : It is more a general point. I take the personal things you have experienced, Senator. You mentioned the USA and the UK. These are large complex industry environments, with complex security arrangements. My argument is that we should not try and exceed these areas. If we can learn from them, great. If we can benchmark against them, that is terrific, as long as we do not come up with peculiar or particular arrangements, unless they are necessary. There may be Australian situations that call for it. I am saying: in general, are we benchmarking and do our arrangements have consistency with the rest of the world? Maybe it is a question for OTS rather than this committee.

CHAIR: Sure. That is fine. I now take what you are saying. It was said earlier that security can be a show. It can be put out there where it looks like a lot of things are being done and maybe the perception could be a little different. You just mentioned that four regional airlines have gone belly up. I should not use that terminology, should I? Unfortunately, they have shut their doors because of cost imposts. So it is not just a case of a reaction of: 'Crikey, let's tighten it all and let's follow what America does.' That is where you are coming from.

Mr Tyrrell : That is true. I have written about this a little bit. Perceptions are sometimes reality in security. From our side of the fence, we feel that maybe in the past security has gone up with alacrity; it is very quick to go up. People get very busy. As customers of those security guidelines, we have to respond. But if the security environment changes, like it diminishes, our perception is that maybe it is glacial in bringing some of the arrangements down. It is more perception rather than science. I just share that with you.

CHAIR: I will put you in the spotlight. If you cannot or do not want to answer, I fully understand. Where do you think the excesses in the security regime are in our regional airports?

Mr Tyrrell : 'Excess' is an interesting word. Maybe where we would have a debate—

CHAIR: I am talking about costs. If sense—God help us using that word between government departments!—were to prevail and it were not just a case of rushing out there and saying, 'Let's do this because it looks good'. If we were actually consulting with stakeholders and benchmarking and bringing in the experts, and not those that can see a quick quid if they get called in to write a new program, could you give us some examples of where, lately, it has just been financial overkill?

Mr Tyrrell : I will probably get my colleague to help here, too. There are two I would probably mention. One is at the minor end, where you have commercial operations and private operations on an airfield—say at Wagga. You all have to have an ASIC card if you are commercial or private. Also, some of the smaller GA people have to have an ASIC.
This is a cost to them. They live in a different part of the airfield and they have to pay for an ASIC. They have to have certain arrangements in place. Maybe in those instances we could allow the bigger commercial operations to have the full security environment and the smaller operators—the private and commercial—a lesser security environment. I am sure OTS have some ideas on the details of that. That is an opening point.

The second has been going for years. Checked-bag screening and passenger screening, some years ago, was lowered from a maximum takeoff weight of 30,000 kilo aircraft to 20,000 kilo aircraft. It was brought in fairly quickly and was based, apparently, on scientific research. We pressed and pressed to try to get an explanation of what this science was, because they are quite different aircraft—as you would appreciate—from 30,000 kilos to 20,000 kilos. So, by lowering the maximum takeoff weight you captured smaller aircraft. There was a hike—economies of scale—and the costs went up. All we were simply asking was: what were the major threats that caused the policy change? That was never explained to us.

CHAIR: I know you said that you wanted to go to Mr Eaves to help out too, but just on this: who made that decision?

Mr Tyrrell : I believe it was OTS at the time—the people running OTS some years ago.

CHAIR: Sure. I thought that could be the answer, but I just wanted to test it. Did the industry—you guys and other stakeholders—actually have the opportunity to comment? I know you said that you asked but you did not receive. Do they ever come to you and say, 'Look guys, what do you reckon? You're the ones that do it. This is what we've got; here's the scientific research.' Or is it just typical: 'Bang! This is what you cop'?

Mr Tyrrell : We had four meetings on this. What was explained to us was that this was research done, I believe, by RMIT. I might be corrected there. We asked to see the research. Some of it was classified; we understand that. We were given a summary in a briefing. There were holes in the argument and they just basically said, 'There's the research, there's the change. Live with it.' That was, kind of, where it went.

CHAIR: That is a common trend, no matter what area of expertise we all work in. Mr Eaves, did you want to add something?

Mr Eaves : As Paul just discussed, as an airline, we are the end user of the security product. Obviously, the intelligence and OTS mandate the requirements and provide the intelligence that the airports—as was discussed earlier—are doing the security screening for. Ultimately, the airline is the last line of defence. So we really are relying on OTS.

CHAIR: Okay; sure. This is the cracker question—here we go! If these imposts of security are placed on you as the end user, do you have the ability to flow that on to the airlines so that it is the travelling public that pays? Is it that simple?

Mr Tyrrell : That is correct. It is that simple. I am not saying that they pass on every cent. As you know, we are very sensitive to price. The airline might have to wear a little bit. For regionals it just hurts them a bit more.

CHAIR: You said there were four regional airlines. Could any regional airports that you know of seriously get to the stage where they ask whether it is worth opening if any more of these imposts come upon you, without the opportunity to have the input and to check the scientific research?

Mr Tyrrell : It sounds a simple question but it is actually quite complex. We are particularly worried about barriers to entry. You asked a question about current airlines. Regionals, as always, are the canary in the cage in terms of the economics. We are really concerned. We want new players to come into the environment.

CHAIR: Sure.

Mr Tyrrell : I have to say it would probably be quite frightening for someone to have a crack now, with the current security environment. I am not saying that they would not—

CHAIR: You mean an airline?

Mr Tyrrell : Yes, that is what I am talking about...

..Senator BACK: Sure. I also support that, and I want to come to that question. Obviously we are always measuring risk against opportunity and risk against benefit. Am I being unduly optimistic when I think about airports like Mt Gambier in South Australia, our own Esperance, Albany, Geraldton and Kalgoorlie even? Is there a risk commensurate with the cost now? Everyone knows each other. The likelihood of somebody wanting to create a maleficence is not high and the number of people on these aircraft is so small when we think about the risk if something did happen out of Geraldton or out of Esperance or Albany. I can accept in major metropolitan airports all of the risks. I can accept even the notion that a suitcase might start out at Wagga and end up in Sydney on its way to Los Angeles. But this does create regional employment. You go through a scanning in Esperance airport and you count eight, 10 or 12 people where previously there were not eight, 10 or 12 people carrying out this role. Are we over the top? Indeed, if it is driving regional airlines out of existence or from servicing these small regional airports, where is the benefit to the community? Is there a more pessimistic and realistic view I am not seeing?

Mr Tyrrell : Are you referring to your concern about security being raised at certain airports?

Senator BACK: Yes, I am. I am concerned that we have gone over the top.

Mr Tyrrell : I would just reflect again on that change from 30,000 to 20,000—which, as you say, creates employment, because we have to check the bags and we have to check the passengers. That is a significant cost. The Regional Aviation Association has not been able to determine from government sources what the level of risk was and what benefit we have gained. Unfortunately, I am answering you question with a question, because I do not have the answer.

Senator BACK: Before I go to Mr Eaves: the reality is that at a city airport, as we know, you have flights coming in all the time, so the percentage of time that these people are actually surveying passengers or luggage is high. At the Esperance airport, where Skywest or Virgin fly in twice a day at the maximum and the airport is 25 or 30 kilometres out of town, the time and cost taken for those people to turn up to oversight those passengers and then go back seems to me to be an absolute overkill.

Mr Tyrrell : I will let Stuart speak of course, but in general we feel there has been some overkill on the point that I raised. Again, we are the end users here. We are not open to the intelligence that is given to the government. They get intelligence and they develop their security measures. The trouble is, we are only part of that conversation.

Senator BACK: Sure.

Mr Tyrrell : It is just our observation that in certain instances it has gone too far.

Mr Eaves : All I can add is that if we are talking about decreasing that limit from 20,000 to other aircraft, for the requirement to do mandatory airport screening, using the scenario of the airline that I work for—they operate Metroliner III and 23 aircraft, 19-passenger configuration—if you were to introduce screening for that type of aircraft, you would capture the items that you ideally would not want on an aircraft; however, going that next step, there is not actually a flight deck door on an aircraft of that size. The regulatory requirements in Australia are for a reinforced cockpit door on an aircraft of 30 passenger seats or above. So if someone had sinister intentions and wanted to take over control of an aircraft security screening would not stop that, because someone could quite simply overpower a pilot to achieve that objective.

CHAIR: Senator Xenophon?

Senator XENOPHON: Thank you for your evidence. Essentially, you are saying that the trigger, or the maximum take-off weight, should go back from 20,000 to 30,000—from 20 to 30 tonnes.

Mr Tyrrell : We are asking, 'Why not?'

Senator XENOPHON: We have a situation now that if it is presumably, say, a Saab, that would be under 30,000?

Mr Tyrrell : Yes, it is. It is under 20,000.

Senator XENOPHON: Okay. It might be a Dash8. You will have different aircraft with different security screening requirements.

Mr Tyrrell : Given that you are drilling into this particular issue, the 20,000 actually splits a fuselage grouping. If it does not bore the committee: the Dash300s were just under 20,000, operated by Qantas, and the Fokker50 was just over 20,000, operated by people like Alliance and Skippers. They got divided down the middle. We asked, not so much 'This is unfair commercially'; we just asked, 'Hang on—why don't you make it 19; or, if you are going to do it, put it somewhere that makes sense.' We are still grappling with what the security issue is here.

Senator XENOPHON: In terms of Mr Seymour's stories, have you seen those or read the transcripts of those?

Mr Tyrrell : Not in detail, but I know some of it.

Senator XENOPHON: That was, in my view, the trigger for this inquiry. Can you at least comment in respect of those? I think it largely relates, not to regional airports, but to metropolitan, capital city airports. Are you able to comment? It does seem disturbing that there are things like box cutters, tasers and even a firearm that apparently got onto an aircraft.

Mr Tyrrell : I think any thinking person is a fan of sound security at major airports. Major airports, big aircraft, lots of people—you want a robust system. If something has got through—and I do not want to criticise them—it needs to be looked at. What went wrong?

Senator XENOPHON: Can we just go to the issue of cost. One of the other witnesses said that if the costs are too great in terms of security screening, that could affect the viability of regional carriers. Can you give a ballpark figure of what the additional cost would be per passenger per flight if, for instance, there were security screening applied to all aircraft of 30 passengers or more?

Mr Tyrrell : I would like to take it on notice, if I could?

Senator XENOPHON: If you could. It is just that I was quite alarmed to hear that the issue of viability of regional carriers could be affected by virtue of additional screening.

But, in context, I think that if passengers know that one or two dollars of their fare—three dollars of their fare—per sector might relate to enhanced security measures then I think that people may cop that.

Mr Tyrrell : It is the cup-of-coffee argument. I respect that security will not bring down an airline on its own, but we have many discussions with many—

CHAIR: Red ties being worn by the pilots nearly did!

Senator XENOPHON: Right—

CHAIR: I am having a real dig there at Qantas!

Mr Tyrrell : Yes, I know.

CHAIR: The management, not the staff!

Mr Tyrrell : It is a cumulative effect, Senator, but I will take your question on notice.

Senator XENOPHON: Sure. With incidents, how does the reporting method work? There is a dispute as to whether as a result of the FOI request by the Seven Network, there has now been a lessening of voluntary reporting. The airports say, 'No,' effectively, but that they will look into that. The deputy secretary of the department said that there was a lessening of reporting. How does it actually work, if there is a security concern at one of the regional airports? How does that filter through the system for the department to know about it?

Mr Eaves : Through a safety management system, all staff—from ground handlers through to flight crew—have the opportunity to, and are encouraged to, report any security concerns.

Senator XENOPHON: And where does that go to the department?
Mr Eaves : That would go into the security department of each airline, which would then pass that information on to the OTS.

Senator XENOPHON: Okay. So, any report under the safety management system would find its way back to the department eventually?

Mr Eaves : Correct.

Senator XENOPHON: Right. And would your association know how many safety concerns are listed? They would not just be security concerns—there might be a maintenance issue or whatever.

Mr Eaves : Correct. The safety management system can categorise everything into maintenance, flight operations and security, so we have a separate security category.

Senator XENOPHON: Okay, so there is a separate security category. Are you able to provide us on notice—and you may want to consider whether you want to have it in camera or not—the number of security concerns that have been reported under the safety management systems for regional carriers?

Mr Eaves : I can take that on notice. I could only answer that on behalf of the airline that I work for.

Mr Tyrrell : I could take it on notice on behalf of the association.

Senator XENOPHON: Yes, that is fine. And, again, if there is some sensitivity you may want to ask that it be put in camera.

Mr Tyrrell : I probably will ask that.

Senator XENOPHON: Okay, thank you.

CHAIR: Mr Tyrrell, are there any different levels of security in regional airports where there is mining? What I am trying to allude to is the mining area, where explosives could be used. I know of Kalgoorlie, for example—I will not try to speak about other areas of Australia. Are there different levels, or are they the same system?

Mr Tyrrell : You are not talking about FIFO? You are talking—

CHAIR: FIFO own their own airstrips.

Mr Tyrrell : That is right, they do own the field. You are talking about—

CHAIR: Yes, regional.

Mr Tyrrell : As far as I know—and I am not an airport expert—we at the airlines follow the guidelines that the airport lays out for us. They have their government guidelines, and sometimes they have their own peculiar ones. But, mostly, they stick to the guidelines and we follow those.

CHAIR: Yes, okay. No further questions for Mr Tyrrell and Mr Eaves? No? Thank you very much for your time, gentlemen.

Mr Tyrrell : Thank you very much.

   

Here is the RAAA submission:

9 Regional Aviation Association of Australia (PDF 431 KB)

 
MTF...P2

[P1_aka_P1]

P2 – “Mr Tyrrell : Thank you very much.”

The only possible criticisms of Paul Tyrell which could be raised are that he is not running CASA; or, better yet, leading all the ASG in a concerted effort to truly reform CASA.

It’s never too late, teamed with Boyd, Cannane, Fawcett and Forsyth it would be rout: followed by a party; to end all parties.

[Peetwo]

P2 – “Mr Tyrrell : Thank you very much.”

The only possible criticisms of Paul Tyrell which could be raised are that he is not running CASA; or, better yet, leading all the ASG in a concerted effort to truly reform CASA.

It’s never too late, teamed with Boyd, Cannane, Fawcett and Forsyth it would be rout: followed by a party; to end all parties.

Tyrell last hoorah

I agree P1, Paul Tyrell has it in spades and with that 'other' Higgins in place at RAAA, he must be a free agent?? (timing is interesting ).

Anyway here is part of his last (as CEO) contribution to 'From the RHS' in the 2015 Spring edition of the RAAA newsletter:

Large regulatory challenges remain for the RAAA, with CAO 48.1 (duty times/fatigue) and CASR 61 (Pilot Licencing) with the former needing immediate withdrawal and well thought through exemptions implemented with respect to the latter.

The RAAA has formed a senior Part 61 working party under David Trevelyan’s leadership that will now liaise directly with the newly formed CASA Part 61 Taskforce.

The CASA CEO, Mark Skidmore, has personally invited the RAAA group to take part in the Taskforce. Action speaks louder than words and it is urgently required in the above two areas.

On the positive side the new CASA Board and CEO were active participants at our convention and made themselves very accessible to the members.

This augurs well for the future given the fractured relationship over the past six years. It has been helped considerably by Jeff Boyd and Ian Smith having such a detailed understanding of regional aviation.


A large imperative is that the agreed recommendations of the Forsyth Review be implemented with alacrity.

CASA has been dragging its feet and the industry, possibly even the Minister, are becoming impatient.

The Forsyth Review is a very good flight plan for our regulatory future and needs to be actioned before anything else. This message must be repeated constantly by all industry participants...

Well said that man



MTF...P2

[Sandy Reith]

" possibly even the Minister, are becoming impatient."
You must be joking...gawd almighty...I took a reasoned deputation to him in 2005 and the best he would say was that the ultralight growth balanced the decline in regular GA.
Vale no regrets Minister Truss, you oversaw the destruction of what should have been a productive, efficient and job creating industry.

[Gobbledock]

Sandy said;


"Vale no regrets Minister Truss, you oversaw the destruction of what should have been a productive, efficient and job creating industry".

Indeed he did, 'destruction by obsfucation'. He was a 40 year Government veteran conditioned to "do nothing, was skilled in doing nothing, is leaving Government having done nothing, and leaves behind a legacy consisting of nothing". Just an air stealing trough slurping cardboard cutout. 

Warren, enjoy your luxurious superannuation package, and good luck to you and/or your family members who end up consulting and advising on the Badgerys airport project or consultative processes, of which there will be many, and worth millions, over the coming years! Who knows, perhaps your old mate Sharp will have a tasty Board or Consulting role for you? Oink oink.

Farewell you stupid old goat, enjoy Mary Poppins and don't bang the effing door on the way out.......

Gobbles xx

[Peetwo]

RAAA News - Summer 2015/16

From the RAAA Summer newsletter in the LHS, Jim Davis opens up on the OTT CAO 48.1:

..However one area of great concern is CAO 48.1 which threatens to impose excessive cost and cause crippling disruption to industry without a commensurate safety gain. This legislation does not comply with CASA’s new regulatory philosophy.

CASA have gone to great lengths to publish their case but an analysis of the document ‘A Review of the case for change: Scientific Support for CAO 48.1 Instrument 2013’ shows an absence of hard evidence to justify the new rules. It is full of assumptions and scientific theory, much of it from other jurisdictions, but does not provide any real evidence of a systemic fatigue problem in the Australian context.

"..The closest it comes to offering any facts is when it references ATSB data. Here CASA make the extraordinary statement that ‘there have been approximately 65 incidents/accidents in the last 10 years in which human fatigue was identified as a factor (note: not a causal factor). A proportion of these occurrences have been in the Regular Public Transport (RPT) sector of the industry.’ This is manifestly absurd and hardly scientific analysis! The RAAA requested a copy of this data from CASA and when it was not forthcoming obtained the information by approaching the ATSB directly. After talking with the ATSB Chief Commissioner and Aviation Commissioner and having the data examined by industry experts no evidence of a systemic fatigue safety issue was found. .."

P2 comment: Hmm..that passage has some very disturbing similarities to the CVD Pilot's issue, especially when it comes to doctoring or ignoring empirical evidence that is contrary to the "Big R" regulator's subjective interest - now TFB (totally ducking believable) under OST    

Furthermore CASA have made no attempt to examine fatigue trends in the myriad amount of information contained in the SMS data bases of Australian passenger carrying air operators. They have disregarded the fact that mature operators in Australia have been successfully managing fatigue for decades.

It must also be asked why the prescriptive rules contained in CAO 48.1 are more restrictive than the equivalent rules in Europe (EASA Subpart FTL) or the US (FAA Part 117) despite the fact that both those jurisdictions exist in a far greater fatigue inducing environment than we have in Australia. There is no justification for this unnecessary hindering of participation in aviation and its capacity for growth.

The cost impact of the prescriptive rules in CAO 48.1 is very real and will cost some RAAA members millions of dollars per annum. It will also render some current operations totally unviable. CASA may claim that a FRMS will possibly negate these totally impractical rules but there is no guarantee and it begs the question of why they have been imposed in the first place. It also does not address the fact that some smaller operators may not be able to handle the costly exercise of introducing and obtaining CASA approval of a FRMS.

While it is encouraging that CASA has responded to the Statement of Expectations from the Minister with its new regulatory philosophy as embodied in Directive 01/2105, it now appears to be faltering at the first hurdle. CAO 48.1 does pre-date the Directive but it is not effective until 1 May 2017. In the interests of transparency and fair play the RAAA strongly feels that Directive 01/2015 should be applied to CAO 48.1.

The RAAA has been pointing out the inconsistencies and significant problems with CAO 48.1 for regional operators for some years but CASA have steadfastly refused to make any meaningful changes. Sadly, at least in the case of CAO 48.1, the ‘Big R regulator’ is still with us.

  
Makes you wonder if Senator Fawcett & other government Senators made a ill considered decision to vote down Nick Xenophon's CAO 48.1 disallowance motion -

Also in the RAAA newsletter we get the first instalment to the RHS segment from new CEO Mike Higgins:

..Early last year the CASA Director published ‘Directive 01/2015’, which essentially directs CASA staff to ensure that regulatory changes are justified on the basis of safety risk and do not impose unnecessary costs or unnecessarily hinder participation in aviation and its capacity for growth. This is an excellent document and I commend it to you for further reading. The Director has also been actively promoting this philosophy to all staff, particularly those involved in regulatory development. Alas there appears to be a degree of inertia within middle management which is frustrating the much needed cultural change required to fully implement this new philosophy. Fortunately the Director is made of sterner stuff and we understand that there is a significant refresh occurring shortly. His challenge will be to identify who to keep and who to let go.


On a more positive note, credit does need to be given to the CASA officers that led the last CASR 21 Design and Production Working Groups and the Small Aircraft Sector – Risk Profile Working Groups. The meetings were professionally run and in accord with the 01/2015 Directive philosophy and were therefore well received by all attendees.

The two items on the top of the current priorities list are CAO48.1 (Flight and Duty times / Fatigue Risk Management) and a Post Implementation Review (PIR) of the Aviation Safety Regulatory Review (ASRR).


CAO 48.1 would have a severe negative fiscal and financial impact on a number of RAAA members. The first step would be for CASA to recognise the empirical data we have gathered and monitored over the years that clearly demonstrate how we have been successfully been managing the risk of fatigue. The RAAA have recently identified two pre-eminent FRMS experts who can assist us in our endeavours.


The industry at large are wondering how the implementation of the ASRR is tracking. CASA have had the Ministers Statement of Expectations for some time now and indeed long enough for a review of how well the review recommendations have been adopted. This will form the basis of both our study of the PIR (when it happens), and inform the development of the TAAAF Policy Document for 2016.


The RAAA is an active member of the Australian Aviation Associations Forum (TAAAF), and we are meeting with the author of the ASRR to gain further clarification around certain issues identified in the report. This document is published and presented to government members in each election year and has met with an agreeable level of acceptance and uptake in the past. The previous Policy Document 2013 is available on our website.


I recently met with CASA to discuss the way ahead on issues including CAO48.1, Professional Indemnity Insurance for CASA industry delegates, 1:50 ratio of Flight Attendantsassengers, CASR 121/135, CASR 61, certification of offshore MROs/CASR 145 organisations and inconsistencies in interpretation and application of policy and regulations between Canberra and Regional Office staff...

Some positive signs there for the future relevance of RAAA as a significant industry advocate..  However they need to maintain the rage otherwise their influence in Can'tberra, much like their membership, will drop off while the industry continues being slowly & inexorably strangled by the big "R" regulator -


MTF...P2

[Peetwo]

RAAA member, Alliance Airlines  - In a Flight Global article published today, Alliance Airlines tells a few home truths about today's Skidmore led CASA

Alliance Airlines considering switch to NZ AOC

03 March, 2016
| BY: Ellis Taylor
| Brisbane


Australia’s Alliance Airlines could switch its aircraft onto a New Zealand air operator’s certificate owing to headaches in dealing with Australia’s air safety regulator.

Speaking to Flightglobal in an interview, managing director Scott McMillan says that the Civil Aviation Safety Authority (CASA) has repeatedly failed to consult with industry when developing new rules and regulations, which has caused Alliance to bear a number of costs.

As an example, he points to a uniquely Australian requirement that forced Alliance to spend €5 million ($5.43 million) to retrofit global navigation satellite navigation systems to its fleet of Fokker jets.

“We’ve been forced to put GNSS in our aircraft and take out a system that we developed here in Australia that was more accurate and more reliable,” he says.

Fellow Fokker operators Virgin Australia Regional Airlines, Skippers Aviation and Qantas’s Network Aviation unit have also been forced to stump up the considerable cost to develop the retrofit.

McMillan says that despite approaches by Alliance and other operators to CASA asking it to take a cost-benefit approach to the unique retrofit, but got no joy.

“[CASA] bureaucrats will say, ‘how good are we!’ But at what cost and what benefit?”

Alliance has also locked horns over CASA’s proposal to introduce fatigue risk management systems (FRMS) for pilots. While the airline is happy to run FRMS, it bound by prescriptive annexes that would not give it the flexibility its business requires.

“Obviously safety is first,” says McMIllan. “If you bring in an FRMS and it tells you certain things, you’ve got to do it, but you’ve also got to win on the upside.”

He points out that New Zealand allows more flexibility with pilot rostering and fatigue management than the proposed Australian rules, making it appealing to switch jurisdictions.

“A pilot with a New Zealand license can fly with much greater flexibility already than an Australian one – and we’re going to make it less flexible,” says McMillan.

“We are seriously considering moving our whole operation to a New Zealand air operator’s certificate. We satisfy almost all the requirements already.”

Australia and New Zealand have a mutual recognition agreement, which allows carriers from both sides of the Tasman to operate within each others' domestic markets. That allows Airwork to operate Boeing 737 freighters for Toll Express within Australia, while Jetstar’s domestic New Zealand services are flown under its Australian AOC.

Ouch, not a good look Skates old son


MTF..P2

[Kharon]

About time; moving to NZ is the only sane road to travel. The only surprise is that it’s taken so long for the little light to come on. Don’t talk about it Scott McMillan, just get it done, best move you’ll ever make.

[thorn bird]

From Flight Global International.

"Australia’s Alliance Airlines could switch its aircraft onto a New Zealand air operator’s certificate owing to headaches in dealing with Australia’s air safety regulator."

Could this be the beginning of the end? or the end of the beginning?

Maybe the RAAA could subcontract this guy from MI5.

photo.JPG Size: 127.55 KB  Downloads: 7

[Gobbledock]

I've had my dealings with McMillan. Quite an opinionated character and likes to whinge about everyone but himself. TBH I think he is a pompous knob. However, he is also an unofficial IOS member as the bloke truly dislikes Fort Fumble, but for good reason - CAsA has most certainly dicked him and his airline around over the years, with a little bullying thrown in for good measure. So yeah, he is pissed.

But he has a very good point - CAsA has cost his airline a lot of money over the years by engaging in regulatory bullying and pinning Alliance down with pony pooh regulations based upon some lawyer inspired wankery. The dipshits writing the unworkable regulations and then using even bigger dipshits to enforce it are red tape creators. They don't understand aviation holistically, they don't understand finances and business methodologies, and they certainly don't understand what it is like to be held to ransom by draconian legislation and regulations which are outdated, unworkable, convoluted and just plain crap.

So I'm quite happy to forward Scotty a dozen choccy frogs for exercising his democratic right and standing up and saying 'CAsA, you're a bunch of wankers and we've had enough, it's time to head to NZ for our AOC'! Three cheers old mate. It's a brave and ballsy concept, but it is doable. And a little short term pain and hard work would certainly be worth it in the long run.

I think McMillan's actions should, in the very least, grab the attention of Mr Chesterfield, because there is some pretty serious shit going down when the CEO of a reasonable size airline wants to run his AUSTRALIAN operation under the framework of ANOTHER country, and rightly so. It goes to show how bad things are getting.

TICK TOCK MINISCULE CHESTER TICK TOCK

[Peetwo]

RAAA response to Murky's SSP DRAFT

Industry v Insanity - P2 supplemental

Every time; and, I do mean every time there is an opportunity for industry to participate in in setting a course away from disaster or on the road to recovery it, weighs in.  Willingly, unstintingly and at little or no cost to the government the industry provides expert, considered opinion, provides cost effective solutions and indicates a willingness to assist with effective, sensible reform programs.  Gratis, no charge advice on which a minister could rely and fund, not only saving the Commonwealth millions, but earning even more revenue, not to mention jobs and investment opportunities.

Look at some of the standout submissions, from Pel-Air through Forsyth and on to the latest Productivity Commission; there are some first class, top drawer submissions made which provide empirical evidence of industry ‘expertise’.  The latest from AAAA is an exemplar: sane, balanced, practical, fully supported by membership, totally achievable and capable of ensuring safety and increased productivity – in short; the right solution.

Over the past decade many such documents have been provided by industry; over the past decade almost none of those documents has been put on a table, discussed with the ‘authority’ and implemented.

Over the past decade the government appointed ‘experts’ have gone to extraordinary lengths to avoid embracing the expert advice of industry specialists, independent reports, analysis and solution.  Even ministerial directives get short shift.  AMROBA, AOPA, AAAA, Forsyth etc. all get the same treatment, a lot of lip service, enough action to provide credible evidence for the minister to state that ‘something’ is being done; then, after a suitable time period in limbo, good ideas are taken out the back, their throats quietly slit, the carcass buried in the departmental graveyard.  RIP.

We spend millions on the care and feeding of things like CASA who could not, on their best day produce a submission to match the AAAA effort, which was gifted to the nation.  We need to ask why we are squandering a fortune employing non expert dead beats who’s sole purpose in life seems to be playing at policemen, ‘prosecution’ and decimating industry initiative.  This occurs throughout the agencies, ASA, ATSB and CASA; incompetent, non experts running multi million dollar enterprises which ignore expert advice on the very thing which necessitates their existence; i.e. the well being of industry and those who manage it, very well, despite dragging the lead weight of departmental arrogance and ignorance behind it, then having to fund that incubus. But don’t just take my word for it; compare the AAAA submission (which we have for free) to the Chambers report; or, the Pel-Air report (both of which we paid dearly for) on a benefit to industry basis and decide for yourself.

It is insane.

For want of a nail the shoe was lost.
For want of a shoe the horse was lost.
For want of a horse the rider was lost.
For want of a rider the message was lost.
For want of a message the battle was lost.
For want of a battle the kingdom was lost.
And all for the want of a horseshoe nail.

Selah.

PS.  Nicely done Phil, well done indeed.

To reinforce the P9 post one only needs look at the following post extract to see that the Department, CASA, ASA & the ATSB have a normalised deficient culture of notifying a difference to ICAO: http://auntypru.com/forum/-Shame-or-fame...12#pid3912

Been a bit quiet on the RAAA front, maybe they've been busy contributing to the excellent just released TAAAF Policy ???

However trolling through the RAAA website (as you do ) I did note that, much like Phil Hurst & the AAAAs (see post link above), the RAAA did comment on Murky's SSP DRAFT... :

II. RAAA Response to the Draft State Safety Programme

The Regional Aviation Association of Australia (RAAA) finds no significant issues with the Policy Statement as it is written. However we have serious concerns about the delta between the proposed situation and reality. The RAAA can cite numerous examples, but recognise most should be addressed in a separate forum to this submission. Therefore this submission will only identify high level concerns.

Policy statement paragraphs 3 and 9 claim that sound assessment of risks and service provider’s safety performance indicators are used to guide the regulatory development approach.

Just one example of where this policy is not applied is in the philosophical design approach to Civil Aviation Order 48.1. The current version is out of step with sound assessment of the actual risk faced by many mature Australian operators, and not based on empirical evidence in the Australian context.

Policy statement paragraph 6 claims that recognition of Australia’s safety regulatory system will ensure that Australia has a competitive aviation industry.

An increased focus is required in this area. Particular emphasis should be given to Bilateral Agreements with international service providers, particularly in the aviation maintenance sphere. The industry has agreed with the international harmonisation route on the basis that our regulations would be recognised and Australian operators could enjoy the associated obvious benefits. However the efforts and results from CASA in this regard are disappointing to date, despite numerous and costly investments in international face to face meetings.

Policy statement paragraph 10 claims that the appropriate personnel will be appointed to discharge their responsibilities competently.

Whilst sufficient financial and human resources have been allocated within areas of CASA, certain staff do not have the proper technical, people management, financial skills or appropriate industry experience to discharge their safety oversight and management responsibilities competently.

One final issue of significance that must be documented at this time is the disappointing lack of progress on the implementation of the Aviation Safety Regulation Review (ASRR). Page 8 of the draft State Safety Programme refers to the ‘Aviation Policy Group (APG) monitoring the progress of the delivery of the SSP and the SSP gives effect to the Aviation Safety Regulatory Review (ASRR) recommendations’. The RAAA has serious concerns on the lack of progress and the lack of visibility and surety that the policy intent of the recommendations has been correctly understood by CASA. A Post Implementation Review by mid-year to ensure the correct application is required.


III. CONCLUSION

The RAAA is grateful for the opportunity to provide our views for the Department of Infrastructure and Regional Development’s Draft State Safety Programme. If you would like further information about the items contained in this submission, or clarification on any of the points we make, the RAAA would be more than happy to assist.

 
Short, sharp & very much to the point - good job Higgins & Co

With those sort of comments (AAAA & RAAA) coming in, maybe I banged the nail on the head, when I said that the Carmody appointment might be to help Murky sort it all out??

Especially when you consider the latest rumours doing the rounds, via "K" off the Alphabets thread:

Rumours eh?


Couple or three juicy morsels floating about in the lead up to the Great Tamworth Bunfight. It depends on exactly how high your cynic tolerance level is set what you make of them, or even if you believe them.

1) Seems (according to the whispers) we are to have a ‘task force’, not a ‘tiger team’ but the real deal, with instructions to ‘sort it’.  Whispers have it that the ‘TF’ will be led by he who was sent from Sleepy Hollow to Murky’s play room; which may or may not be of value.  We can only hope the task lands on the infrastructure desk and Ms. Fiona Nash, working with Pete-the-Pot plant is in charge.  IF that happens, then there is real hope.  The best man for the job in this case is, most definitely a women; finger crossing and small offerings to pagan gods may assist.

2) Seems the Bae facility at Tamworth is to be resurrected and Barnaby will announce this as part of his Tamworth sojourn. The ‘who’ ‘what-for’ and ‘why’ are still the subject of speculation; there is a short priced favourite, MTF as P2 would say.

3) AOPA president Marc De Stoop has taken a tumble and bust a couple of bones.  He is a first class fellah and well worth a short ‘get well’ message, don’t expect a long response, he has a wing root out of commission.

Rumour mill – over and out....

 
Makes sense to me...MTF P2



  

[Peetwo]

RAAA latest newsletter: RAAA News - Autumn 2016

2

IN THE COCKPIT

From The
Righthand Seat - Mike Higgins CEO

Over the last few months I have visited 12 Flying Training Service providers in Victoria and South Australia.

Seven have since decided to join the RAAA as there is no single representative body for this very important sector of our industry.

Some were asking why the RAAA would be interested in offering an advocacy role when most providers were based in non regional areas.

This is because the RAAA recognises the vital importance of the ‘nursery’ of all our future pilots, and also because of the predicted huge increase in trainees from overseas seeking training in Australia.

In order to provide a more effective and efficient operational environment (in the regulatory sense), there is work to be done.

An immediate example is the impending decommissioning of a large number of ground-based navigational aids across the country.

Whilst everyone acknowledges this is inevitable for several reasons, a more rational and risk based approach needs to be applied to the management of this project.

For example, just four RTO’s have reported performing 13,810 approaches over ground based aids in Victoria.

The shutting down of 17 NDBs and 4 VORs will see all these approaches (plus other operators) concentrated over just 4 NDBs and 2 VORs.

Following a recent meeting with several Air Services officers charged with the project, our position is that a moratorium be placed on any further shutdowns until the calendar based decommissioning plan is replaced by an event driven plan.

That is, when CASA can amend its regulations to allow for more training to take place in approved simulators, the less congested the airspace will become.

Once this occurs, then in conjunction with industry, a sensible and safe decommissioning program can be rolled out.

The two items on the top of the current priorities list remain to be CAO48.1 (Flight and Duty times / Fatigue Risk Management) and a Post Implementation Review (PIR) of the Aviation Safety Regulatory Review (ASRR).

The DAS has recognised that we have empirical data that has been gathered and monitored (and audited by CASA) over the years that clearly demonstrate how we have successfully been managing the risk of fatigue. However, this recognition has yet to be driven down to the troops.

The RAAA is an active member of the Australian Aviation Associations Forum (TAAAF) and a TAAAF Policy Document for 2016 has been published and circulated to key Government Ministers and Heads of Departments.

This document is published and presented to Government Members in each election year and has met with an agreeable level of acceptance and uptake in the past, and is available on the RAAA website.

I recommend a read of the Summary Document at least.

The accompanying foundational document has a significant amount of considered detail, for the avid student.

Some recent meetings included:

 CASA to discuss the serviceability issues of a simulator that was causing significant challenges for two of our members.

 Air Services to discuss decommissioning project detailed above.

 BOM to discuss the provision of TAF for one of our airport operator members and lower level GWPT charts.

 Department of Infrastructure to discuss proportionate security measures at regional airports, Airport curfews (see submissions on both issues on our website) and ASIC issues at regional airports and how we might take closer look at a more sensible application of the rules outside the operational periods of RPT services.

If any member would like an update or wish to provide input, please email me at ceo@raaa.com.au.

If any industry member has any questions in relation to the benefits of becoming a member of the RAAA, then I would also welcome your enquiry. I plan to meet as many existing members as I can in coming months, budget allowing.

MTF...P2  

[Peetwo]

Skidmore consultation bollocks -

Previously off the AMROBA thread:

PBR vs Big "R" regulation

 
ARTICLE: Torqued: AC Is Not Good Substitute for Maintenance Fatigue Rule

Fancy that industry sector experts, commentators and relevant stakeholders actively getting involved, without fear nor favour, in public debate on the most appropriate way to proactively address an identified but dormant safety risk issue...  


Meanwhile in Oliver's land of retrograde regulations where all industry participants are criminals until proven otherwise, a couple of comments from LAMEs off Sandy's petition that says it all...

Read this comment and sign the petition. I have been in the aviation industry for the past 49 year... https://www.change.org/p/7202495/c/46057...responsive via @ChangeAUS

..The introduction of the part 145 which CASA admitted in a meeting I was at when they dumped the FAR system for the European system. At that meeting CASA said that the system did not work in europe for GA but they were going to make it work in australia. 30 years this September it still has not been put into place. Companies have literly spent millions of dollars getting the 145 tag for no extra safety gains. It has divided GA and forced a lot of companies to close...

 

Read this comment and sign the petition. Although I am skeptical of clicktivism, this is pertinent... https://www.change.org/p/7202495/c/46083...responsive via @ChangeAUS

...Although I am skeptical of clicktivism, this is pertinent to me. I am a LAME and have seen the decline of aviation in Australia, sadly much of that driven by the red tape forced CASA has been mandated to foist upon the industry. The industry needs simple, effective oversight, with effective and accessable rules, and strong enforcement. The aviation industry is seen as a cash cow by many as there seems to be a perception that aircraft = available money, without much thought to the massive overheads and minuscule margins required to operate.

KC in reply to the above from off a PAIN email chain:

The big difference in Australia is that “modern awards” negotiated by businesses and unions have addressed this issue a couple of decades back.
ATSB also produced a detailed paper in 2001 highlighting this issue:

https://www.atsb.gov.au/media/33957/sir200102_001.pdf

The recommendations in the ATSB paper were adopted back in 2001.
 
AMROBA uses it when advising its members.
 
Regards...

 To which I replied:

..guess that was a somewhat poor example as I was trying to point out the major difference in 'consultation' when it comes to the FAA v CASA.


However that is an excellent ATSB link Ken. That would have been back when the bureau was somewhat relevant and proactive in addressing identified safety issues. I note that the report had 9 very good safety recommendations, fast forward to today's Dolan led ATSB, they would be lucky to have that many SRs in a year. See my report on the decline of the SR under Dolan: http://auntypru.com/wp-content/uploads/2015/03/Popin_2.pdf 
 
As a point of comparison to that ATSB report, refer to yesterday's ATSB VARA ATR interim report  (link at the top of this AP Post: http://auntypru.com/forum/-Overdue-and-Obfuscated?pid=4482#pid4482 ), which IMO should also have generated the need to publish a SR (or two)...

And today another email contributor brings it back to TAWS with the following insightful & historical contribution... :

Folks,
The major points of difference in consultation, FAA v. CASA is:
 
(1)    FAA have a very formal justification criteria for regulation making, that includes risk management and cost/benefit justification ---- the major elements in making sure that every “there should be a rule --------“ doesn’t happen.
(2)    The ARAC groups duties are up to and including drafting the basic “rule” that will eventuate from their activities.
(3)    The ARAC system largely prevents “interested parties” creating “rules” for sectional commercial advantage ----- a major unacknowledged problem here in Australia.
 
As a matter of interest, every time FAA invokes its “emergency authority”, and “proceeds direct to final rule” it turns into to be a shambles, and a very expensive shambles, just like here. The “control cable AD”, which started from the lobbying of one INDUSTRY IDENTITY here, would never get off the ground in the US system.
 
In contrast, here, a genuine risk management approach simply never gets a look in, there is NO genuine and HONEST attempt at cost/benefit analysis, RIS comes after, not before, and we wind up with a huge rule book, where we have LONG SINCE PAST to point of DIMINISHING RETURNS. Ie: Most of CASA’s activities have no beneficial safety benefits, and it can be argued that many have the opposite effect, they actually increase risk.
 
Time and again, CASA’s final rules bear no relationship to what was “consulted” via the Technical Sub-Committees, the “maintenance suite” is the prime example, what we have bears not the slightest relationship to the output of the very expert group put together by Bruce Byron, and bears no relation to the EASA approach, which Byron was looking for.
 
The original draft Part 91 was actually marginally shorter than FAR or NZ CAR 91, the current draft CASR   Part 91 ----- save me.
 
As Assistant Director Bill McIntyre said, many years ago: “ The law requires us to consult, it doesn’t require us to take any notice”.
 
Regards,

In perhaps one of the better examples of the true reality of the Skidmore regime's attitude to industry consultation, I came across a RAAA submission in reply to CAsA's call for comment to proposed changes/improvements to CAO48.1 (RAAA Submission - CD1510OS-2):








Skidmore - Tick, flick & ignore...




MTF...P2

[Peetwo]

Division in the (Aviation) House - Ring the bells!

After reading the following Oz article, by 'that other man Higgins', I wonder if we are seeing the first official battleline being drawn up that may only be sorted by a legislative revisit by NX (& his team) of CAO 48.1...   

First a bit of background can be provided by quoting my recent post off the 'CASA meets the Press' thread:

REX on the 'other' Aunty today - :

Federal air safety watchdog causing 'enormous damage' to regional aviation: Regional Express
ABC Broken Hill
By Sofie Wainwright and Cherie von Hörchner
Updated about an hour agoWed 27 Jul 2016, 6:06pm
 

P2 comment: AFAP - WTF? "..In our view, CASA isn't perfect and there are a number of problems, however we think the moves they're making to replace the outdated, one-size-fits-all fatigue rules are positive and should be supported by airlines.

The new fatigue rules are backed by extensive international scientific evidence on sleep and alertness and replace a system that is well and truly outdated,..."
But hang on a sec wasn't it the AFAP who less than a year ago were being extremely vocal in their criticism of CAO 48.1?? Oh but that's right I seem to recall they had a certain division amongst their ranks: AFAP - Strange dichotomy on CAO48.1??

..Ok from those links there was two that the subject matter was CAO48.1. The 1st was correspondence from Captain Gardiner (above) to CASA (SMS & HF, standards division) and was addressing perceived issues that the EMS/MT sector saw with appendix 3 & 4 (in particular 4B) - Submission on CAO 48.1 Appendix 4B.

...Our submission is based on feedback from members working in the emergency medical services field and the views of the Federation’s Technical Committee, made up of working airline and commercial pilots under the direction of the AFAP’s Technical Director.

As a professional association, the members and staff of the Federation are active in promoting flight safety and improving Australian and global aviation standards. The Federation’s diverse pilot membership base places it in a strong position to comment on the proposed changes to Flight Time Limitations.

Owing to the short timeline, our submission should not be regarded as comprehensive. We would welcome the opportunity to further explain and supplement our submission via discussion with all interested parties...

Hmm (tin foil hat donned ) ..okay so maybe (AFAP) Peter G, just maybe CASA SMS & HF, standards division have taken your advice/suggestion (the part in bold) - along with other industry submissions - on-board and have simply decided to delay the rollout of CAO48.1...   

The other (CAsA) PG: ...“In making these adjustments CASA has taken into account the need to give CASA and the aviation community adequate time to transition to the new rules, while ensuring appropriate safety standards are maintained,’’..

I can thoroughly understand (AFAP) PG's cynicism, because quite frankly we've all seen similar delaying/obfuscation tactics before. However it is perhaps a bit rich (in this case) to expect CAsA to react quite so quickly, when less than a week ago DAS Skidmore would have received this correspondence from the AFAP Prez, Capt Booth:

..I am writing to express our concern about the proposed Medical Transport & Emergency
Service Operations Appendix to CAO 48.1, 2013.

The Federation was not involved in the original working group to develop the proposal & it was only through our members that we were made aware of the draft. Following representation to CASA we were invited to attend the most recent working group. As we made clear at the meeting, we have no concern about operators conducting emergency retrieval services, search & rescue, rig & range safety or the myriad other low rate operations, where Crew Members are on standby for extended periods, under the proposed Appendix 4b. These crew members would be rarely if ever subject to cumulative fatigue however, we are very concerned about the crew members who are involved primarily in patient transfer services...

 
Okay just so we're clear the AFAP said this two days ago to the ABC...

"..The new fatigue rules are backed by extensive international scientific evidence on sleep and alertness and replace a system that is well and truly outdated,..."
 
Now today in the Oz Mike Higgins (the CEO of the RAAA) wrote this piece which also focussed on CAO 48.1... :

Fatigue issues are tied up in CASA red tape

• Mike Higgins
  
• The Australian
  
• 12:00AM July 29, 2016
  

[url=http://www.theaustralian.com.au/business/aviation/fatigue-issues-are-tied-up-in-casa-red-tape/news-story/ad71922faac92efed77149352744a36f#comments][/url]
As part of its program to identify safety issues and assess the level of risk in the aviation industry the Civil Aviation Safety Authority recently held a large aircraft (98 seats plus) sector risk profile workshop, attended by Qantas, Virgin, Tiger, Alliance Airlines and the Regional Aviation Association of Australia.

This was yet another successful workshop based on the excellent and credible approach taken with the previous three workshops, namely the mustering, aerial application and small aircraft sector risk profiles.

Importantly, the key to success was that all the hazards identified were based on objective Australian Transport Safety Bureau data.

This gave all attendees a high level of comfort and subsequent ownership of the exercise. As recently as last year the ATSB indicated it had not identified any unmitigated fatigue issues as the causal factor in any accident or serious incident in regular public transport operations.

CASA so far has failed to produce any concrete evidence that fatigue is a safety hazard that requires the type of drastic regulatory change promulgated in Civil Aviation Order 48.1.

This order mandates a highly complex rostering system that is designed to mitigate against the supposed existing unmanaged risk of pilot fatigue.

This initiative, however, ignores the lack of evidence to support the assertion by CASA that fatigue is not already being managed successfully by the present safety management systems. The RAAA repeatedly has asked that the principles of CASA directive 01/2015 be applied to the new fatigue rules to comply with the new CASA mantra of being a fair, firm and consistent regulator. But to date CASA has steadfastly refused to do this. The proposed CAO 48.1 is the most restrictive aviation work and rest rule regime in the world, stricter than regulations in the US, Europe and New Zealand, with no evidence-based safety justification for it. This CAO means Australia again will be out of step with Australian government policy (and CASA’s own published aim) of international regulatory harmonisation and reducing unnecessary regulation.

"..The RAAA repeatedly has asked that the principles of CASA directive 01/2015 be applied to the new fatigue rules to comply with the new CASA mantra of being a fair, firm and consistent regulator..."  - P2 comment: There's that mantra again - Luv it

Operators engaged in RPT or charter operations are required to have effective safety management systems that identify a range of hazards, including fatigue.

SMS were introduced and mandated by CASA in 2009 for high-capacity RPT and 2011 for low-capacity RPT. SMS are audited by CASA. But CASA has yet to produce any evidence that any identified fatigue issues have not been dealt with by the SMS regime appropriately and to the satisfaction of the operator and the regulator. Therefore, there already exists a successful system of managing fatigue. The operational restrictions and potential cost of the proposed CAO 48.1 are too great for a robust safety case and cost-benefit analysis not to have been established already by CASA.

The CASA requirement for operators to submit a fatigue risk management system by October is problematic for two reasons:

● Industry has still not seen a compelling safety case for CAO 48.1, using objective evidence in the Australian context.
● Even if an objective, data-driven safety case were to be published soon, this would not allow time for affected operators to make the decision on whether to implement an FRMS, then do the tailored work necessary to address the specific identified concerns relevant to their operational environment by the CASA deadline.

The RAAA repeatedly has requested CASA to delay implementation of CAO 48.1 until these concerns can be addressed, but to no avail.

Therefore, one can only fear that FRM is just the first casualty as we ponder what other hazards are likely to be subject to additional culling from SMS treatment and become the subject of more CASA red tape.

Mike Higgins is chief executive of the Regional Aviation Association of Australia.

Hmm...could be an interesting couple of months both in the industry and in the new Parliament -



MTF...P2