[Peetwo]

St Carmode the guru of bureaucratic obfuscation of aviation safety??

AP relevant thread posts:

Non-compliance with ICAO Annex 14 - Part III.

Moving right along with the NCN list for ICAO Annex 14; I go now to volume 2 of Annex 14 which of course deals with helicopter landing sites or heliports - see HERE. Referring to the ASA GEN 1.7 list for the notified differences for Annex 14 volume II, there is currently 87 pages: http://www.airservicesaustralia.com/aip/..._Vol_2.pdf

Being a smaller SARP, plus given the smaller aviation safety niche, I naively assumed that volume II would have less non-compliances than volume I. Therefore I was extremely dismayed to discover that Annex 14 Vol II outstripped Vol I by approximately 100 notified differences...  

What is worse is there is not one ND that didn't exceed (improve) on the difference level of...

"..Less protective or partially implemented not implemented.."  

And the reason for that is because apparently anything that is outside of a Federally leased; or CASA certified ALOP airport perimeter fence is not within their remit; or the concern/responsiblity of CASA - UFB!   

This bizarre situation where the aviation safety regulator's oversight responsibilities apparently stop at the airport fence and airspace boundaries is perfectly highlighted in the recently publicly released consultation company AviPro's review of the proposed HLS for the new Tweed Heads hospital: ref - https://majorprojects.accelo.com/public/...iation.pdf
 

Civil Aviation Safety Authority (CASA)

Engagement with CASA is not a normal part of an application for a development. CASA is normally only informed by AirServices Australia if there is deemed to be a risk to safety for a development.

HLS Compliance and Standards

Currently within Australia, there are no set rules or regulations applicable to the design, construction or placement of HLS’. The appropriate legislation at present for the use of HLS’ is Civil Aviation Regulation (CAR) 92 which places the onus on the helicopter pilot to determine the suitability of a landing site.

CASA, as the regulator of aviation in Australia, divested itself of direct responsibility in the early 1990s and currently provides only basic operating guidelines via Civil Aviation Advisory Publication (CAAP) 92-2 (2) Guidelines for the Establishment and Operation of Onshore Helicopter Landing Sites.

CASA does not provide design, structural information or advice beyond that provided in the CAAP.

CASA, as a component of a Regulatory Reform Program, does propose to prepare rules for helicopter landing sites and currently has a panel established for this purpose. The new rules will form Civil Aviation Safety Regulation (CASR) Part 139R, however it is not expected that they will be completed any time soon.   If and when they are introduced, there will be an implementation phase and “grandfather” clauses...

    
Hmm..new rules will form Civil Aviation Safety Regulation (CASR) Part 139R...yet again Part 139 features?? One gets the impression that once totally completed Part 139 will be the ultimate behemoth of CASA regulations.

But why does the Part 139 reference ring a bell? 

PING!   From the Senate Estimates archive records: ref - Supp Estimates October 2012 https://www.aph.gov.au/~/media/Estimates...ent_a.ashx

Man Made Obstacles Located Away From Aerodromes - Risk review

Developed for CASA by AeroSafe Risk Management.

November 2009

Recommendations

Using the findings listed above and the treatment strategies outlined in the Risk Assessment Table the following recommendations have been developed. There are a total of 10 recommendations. The complex nature of the issues outlined in this report and the potential solutions are such that the recommendations have been represented in the following format:

• Legislative Framework
• Regulatory Structure
• Advisory Material
• Administration

Legislative Framework

R - 1 Authority to make Regulations: That the Civil Aviation Act is reviewed in the context of ensuring that CASA has the power to make regulations specifically concerning buildings, structures and objects that are located away from the vicinity of a certified or registered aerodrome.

R - 2 Removal of Compensation Requirements: That the Civil Aviation Act 1988 is reviewed in the context of removing the requirement to provide compensation for the installation of marking and/or lighting on buildings, structures and objects that have been determined to be a hazard to aviation.

Regulatory Structure

R - 3 Option 1 – Creation of Part 77 Objects that Affect Navigable Airspace

This option is designed to group all obstacle related regulation within one CASR Part. It is proposed that this CASR Part is designated CASR Part 77. This brings the regulation of obstacles in Australia in line with the regulatory structure applied in the United States and New Zealand.

For this option it is recommended that:

• CASA to start the process of developing new a CASR Part 77 that satisfies the recommendations outlined in ICAO Annex 14 Chapter 4
• the scope of the new CASR Part 77 includes all obstacles whether within the vicinity of an aerodrome or outside the vicinity of an aerodrome and the obstacle requirements and marking and lighting standards set out in CASR Part 139 be transferred to the new CASR Part 77
• the new CASR Part 77 include the standards for the notification of structures, buildings and objects that are in line with FAR Part 77
• the new CASR Part 77 include the following elements...

R- 3 Option 2 – Expansion of Part 139 to include Obstacles that are located away from the
vicinity of aerodromes

This option is designed to ensure that the current CAR Part 139 – Aerodromes sufficiently satisfies the ICAO requirements both for obstacles within the vicinity of aerodromes and for obstacles located away from the vicinity of aerodromes.
For this option it is recommended that:

• That CASA to start the process of updating CASR Part 139 to ensure it satisfies the recommendations outlined in ICAO Annex 14 Chapter 4
• That the scope of CASR Part 139 is expanded to include all obstacles whether within the vicinity of an aerodrome or outside the vicinity of an aerodrome.
• That CASR Part 139 Subpart E is expanded to include the standards for the notification of structures, buildings and objects that are in line with FAR Part 77
• That CASR Part 139 Subpart E is expanded to include the following elements...
 

Hmm...how did we get from November 2009 with a regulator that was proactively putting forward recommendations to effectively mitigate safety risk and oversight aviation safety issues outside the airport perimeter fence, to the situation today where it is apparently acceptable to have 1000s of innocent public, totally oblivious to the latent safety risk of shopping at a DFO complex next to an active runway handling high capacity jet aircraft each day - UDB...    

Next the St Carmode contribution to the obfuscation of ICAO:

Australian campaign of O&O of ICAO NCNs - 1999-2019?  


Now an extract pic from page nine of the Mount NCN thread:



P2 - Note the 45 days for submission of CAPs

Okay with the above in mind the following is an extract from the latest Fort Fumble weasel worded missive...  

Risk profile for maintenance of charter operations

CASA is developing a safety risk profile for the maintenance of charter operations. To assist in the development of the risk profile a survey of relevant maintenance organisations will be conducted in May 2019 and CASA is encouraging participation. The survey will collect valuable data to accurately inform risk analysis and should only take 20 to 30 minutes to complete. Sector risk profiles are an important tool in understanding the safety challenges and issues for different segments of the aviation community. They present a picture of the current key safety risks facing a sector and assist in developing a deeper understanding of the effects of these risks. The profiles look at how the level of risks can be reduced and managed by the participants in each sector and CASA, as well as evaluating the effectiveness of risk treatments through a set of safety performance indicators. CASA is also reviewing previous safety risk profiles for aerial mustering and aerodromes, with updated reports to be issued later in 2019.

Read sector risk profile reports.

Over the preceding couple of days I have referred the above CASA link - sector risk profile reports - to several IOS/BRB/industry stakeholder members with the simple question of...

Q/ Have you seen/are you aware of this CASA webpage?

...the response was overwhelming (100%) in the negative -  

Ref CASA sector risk page webpage:

Civil Aviation Safety Authority documents

• Sector risk profile for the aerial mustering sector
  
  
• Sector risk profile for the aerial application sector
  
  
• Sector risk profile for the aerodrome sector
  
  
• Sector risk profile for the small aeroplane transport sector
  
  
• Public attitudes to aviation safety
  
  
• AR-2013-213 analysis of fumes and smoke events in Australia 2008-2012
  
  
• Av safe nations version 1.0
  

NOTE: To assist Industry in understanding the risks that are identified within their Sector, CASA now can provide information called the Sector Analysis.

If your organisation is interested in learning more, please contact your CASA oversighting office to discuss the Sector Analysis applicable to you.

Personally this is reassuring to me as I too had never seen this page before, which is bizarre because the information contained within is invaluable in the context of a regulator legislated with the responsibility to - "...regard the safety of air navigation as the most important consideration..."  - and I would argue if this information were to be properly disseminated across industry then maybe industry would be a lot more engaging and trustful that the regulator had the industry stakeholders interests at heart. 

The "NOTE" above would seem to indicate that this 'sector analysis' concept is a recent innovation. However it doesn't take long to realise that this proactive regulator initiated concept has been in play since at least the 28/01/2015 - right click on pdf link HERE then click on properties, note date created. This places the 'sector analysis' concept at the very start of the brief period that Mark Skidmore was the CASA CEO.

Assuming that Skidmore was supportive of this sector safety risk analysis, his moniker on the bottom of the aerodrome sector analysis would seem to support this assumption, brings into play some other interesting parallels. -   

Rewinding to early 2015 it should be remembered that Skidmore was responsible for knocking the last CASA attempted Angel Flight embuggerance on the head (see previous post above):

CASA said on Friday people power had persuaded the regulator to maintain the status quo on how not-for-profit community service flights were regulated, with the present guidelines guidelines sufficient for now.

“We have listened to the feedback to CASA’s preferred option and we accept this is not the way to proceed,” Skidmore said in a statement.

“CASA is not proposing any changes to the existing regulatory requirements for community service flights at this time.”

    
Hmm...Shirley the previous CEO of CASA Mark Skidmore got his research (white hat) and stats crew to back up his decision with a relevant sector risk profile for Community Service Flights? And even if he didn't (due to the timing) Shirley St Carmode got his R&S crew to carry out the sector risk profile for the CSFs? 

P2 comment - The argument, that given St Carmode's 600K+ part time status, that he is not aware of the R&S crew is lame because, even though only in the acting role, he countersigned this sector risk profile - see https://www.casa.gov.au/files/srpsmallaerobookletpdf   

The successful development of a sector risk profile relies on

industry participation in identifying hazards, associated risks
and developing treatments which are not only feasible but
also effective in delivering safe outcomes. It is in this regard
that I would like to thank the principal contributors from the
small aeroplane sector for giving up their valuable time to
attend workshops, provide commentary on documentation and
demonstrating a commendable dedication to building a risk
profile for the sector.

Safe Flying

Shane Carmody

Acting Chief Executive Officer and
Director of Aviation Safety

     
However it would appear (maybe due to lack of MOAS trough funds -   ) that since taking on the fulltime/part time role as CEO of Fort Fumble, St Carmode has sidelined the R&S crew. How else would you explain there not being (after the DFO fatal) an updated sector risk profile for aerodromes; or a sector risk profile struck up for high capacity mid level RPT operators (think VARA ATRs or REX coal loaders); or a sector risk profile for ARFFS providers;...or...or...???   

MTF...P2