ICAO notified differences & the 'snowball effect' -
For the benefit of the Minister & the PM, here is an extract from my latest post off the AMROBA thread:
This line..
"..The answer is always the same – impractical regulations and standards that are unique to Australia. Aviation is global – there is no case for unique requirements. ."
'Standards' in a global aviation perspective are set by ICAO (SARPs) and accepted by ICAO signatory States, then legislated, applied & overseen by the State NAA (i.e. CASA).
Now the KC short & blunt statement for the major reason that aviation safety administration in this country is 'such a mess' got me thinking about Australia's notified differences to ICAO...
So I decided to do some basic research to see just how 'unique' Australia is as a fellow signatory State to ICAO. The empirical evidence so far is simply staggering...
To begin note my comment from this post - AMROBA on Harmonisation
For ease of access I've created our own link - HERE - and for an example the following is a link for the ICAO 'Airworthiness Standards' notified differences - i.e. Annex 8
Okay so when collated, as of 10 Dec 2015, there is now a unbelievable 318 pages of 'notified differences'. My final count on the 'NDs' was at 3116, however because I lost count a number of times - - I calculated that there is an average of 9.6 'ND' entries per page, giving a conservative figure of a staggering 3005 'NDs' - absolutely UFB!
The highest count of an individual annex or volume of an annex was in Annex 10 Volume 4 with 591 and the highest page count was from Annex 14 Volume 2 with 88 pages.
The lowest count for an individual annex is for Annex 12 with zero, which is extremely ironical and speaks volumes because it is one of only a couple of SARPs that does not involve CASA, ASA or the ATSB - well done AMSA .
So there you go, empirical proof that our aviation safety regulatory system is a complete and utter basket case when benchmarked against 'global standards'
Wake up PM, Minister & the CASA board, it is not going to sort itself out -
MTF...P2
Quote:Metaphorically, a snowball effect is a process that starts from an initial state of small significance and builds upon itself, becoming larger (graver, more serious), and also perhaps potentially dangerous or disastrous (a vicious circle, a "spiral of decline")...
For the benefit of the Minister & the PM, here is an extract from my latest post off the AMROBA thread:
(03-29-2016, 11:19 AM)Peetwo Wrote:
Latest AMROBA Newsletter - Volume 13 Issue 3 (March 16)
KC spells it out in clear, concise English.. :
Quote:1. The Major Reason why Aviation is in such a Mess.
Ask any person participating in aviation today for a single reason why aviation is in such a mess. The answer is always the same – impractical regulations and standards that are unique to Australia. Aviation is global – there is no case for unique requirements.
NOTHING WILL CHANGE UNTIL CASA CHANGE THEIR DRAFTING INSTRUCTIONS TO OPC ON HOW REGULATIONS ARE TO BE DRAFTED.
WE ARE FURTHER AWAY FROM HARMONISATION TODAY THAN AT ANY TIME DURING REGULATORY REFORM THAT STARTED PRE 1990.
Until CASA change their instructions to OPC (Office of Parliamentary Counsel) who write the regulations, the same style will continue to be produced. OPC has stated that they can write performance based regulations but CASA’s instructions do not allow this to happen.
The failure of government public servants to promulgate minimum global harmonised regulations and standards for aviation services and activities is still continuing under the CASA Board.
Harmonisation has become a total delusion – general aviation only exists in a similar structure in North America, except we don’t have the rural population of rural America.
This 28 year process has cost government and industry millions of wasted dollars and has achieved the worst outcome possible in the history of civil aviation in Australia. Nobody can look at the latest regulations, standards and proposed regulations and standards and state they are clear and concise. Aviation regulatory reform outcomes over nearly 3 decades has seen a decline in the use of private aircraft plus a loss of commercial air services to rural Australia.
Save money – buy NZ regulatory system.
Why is government (CASA) continuing to waste money? The most cost effective method to overcome regulatory reform is to buy the New Zealand system with some minor changes to meet Australian demographics, as it has been done in PNG and many other countries in the Pacific Rim. It will save millions in the future.
It is what the majority of submissions to the ASRR report suggested. The ASRR highlighted the need to have harmonised requirements, especially in this region.
The ASRR recommendations are fast disappearing into the past without implementation like past inquiries and judicial recommendations.
If an aircraft operation or maintenance organisation wrote their documentation in the almost unfathomable manner as regulations, standards & advisory promulgated by CASA, then they would be classified as an unsafe operator or organisation and be shut down.
It is time the hard truth of what has been created be recognised and be declared another failure in regulatory reform.
Regulatory reform is supposed to bring benefits to the community.
Since reform started back in the late 1980s this industry has seen very little benefits from any reform. It is time for a new approach if aviation and rural communities are to see any benefits.
This line..
"..The answer is always the same – impractical regulations and standards that are unique to Australia. Aviation is global – there is no case for unique requirements. ."
'Standards' in a global aviation perspective are set by ICAO (SARPs) and accepted by ICAO signatory States, then legislated, applied & overseen by the State NAA (i.e. CASA).
Quote:Standards And Recommended Practices (SARPs) are technical specifications adopted by the Council of ICAO in accordance with Article 37 of the Convention on International Civil Aviation in order to achieve "the highest practicable degree of uniformity in regulations, standards, procedures and organization in relation to aircraft, personnel, airways and auxiliary services in all matters in which such uniformity will facilitate and improve air navigation".
Now the KC short & blunt statement for the major reason that aviation safety administration in this country is 'such a mess' got me thinking about Australia's notified differences to ICAO...
So I decided to do some basic research to see just how 'unique' Australia is as a fellow signatory State to ICAO. The empirical evidence so far is simply staggering...
To begin note my comment from this post - AMROBA on Harmonisation
Quote:P2 Comment - Here is a link for the latest list of Australian notified differences - https://www.airservicesaustralia.com/aip/current/sup/s15-h104.pdf. Note the AIP SUPP is now four pages of relevant links to individual Annex differences. The reasoning for the change to the SUPP, listed at Para 1.2, is absolute bollocks, this is just another cynical attempt to cover up the embarrassing number (over a 1000) of notified differences to ICAO SARPs
For ease of access I've created our own link - HERE - and for an example the following is a link for the ICAO 'Airworthiness Standards' notified differences - i.e. Annex 8
Okay so when collated, as of 10 Dec 2015, there is now a unbelievable 318 pages of 'notified differences'. My final count on the 'NDs' was at 3116, however because I lost count a number of times - - I calculated that there is an average of 9.6 'ND' entries per page, giving a conservative figure of a staggering 3005 'NDs' - absolutely UFB!
The highest count of an individual annex or volume of an annex was in Annex 10 Volume 4 with 591 and the highest page count was from Annex 14 Volume 2 with 88 pages.
The lowest count for an individual annex is for Annex 12 with zero, which is extremely ironical and speaks volumes because it is one of only a couple of SARPs that does not involve CASA, ASA or the ATSB - well done AMSA .
So there you go, empirical proof that our aviation safety regulatory system is a complete and utter basket case when benchmarked against 'global standards'
Wake up PM, Minister & the CASA board, it is not going to sort itself out -
MTF...P2