[Peetwo]

Submission 12 - Phil Hurst and the AAAAs



Ref: https://auntypru.com/wp-content/uploads/...AAAA-1.pdf

1. Introduction

AAAA has made many relevant submissions over two decades on improving the
management of aviation policy in Australia – with a focus on general aviation and
aerial application in particular.

AAAA put forward positive suggestions for improvements based on improvements to
risk profiles and has developed and implemented programs that deliver superior
safety outcomes and which would benefit from recognition by the regulator.
Despite some minor improvements, however, little has changed in terms of negative
overall outcomes for general aviation.

While there have been some advances in CASA’s approach to the regulation of GA,
these advances are not systemic, not significant in the larger scheme of regulation,
not particularly impactful – and are only given up grudgingly as a last resort.
There are good people in CASA working towards a better aviation regulator.

However, they are regularly thwarted by an apparent indifference to good practice,
standard business operating systems and a more cooperative regulatory posture.

CASA continues to lack innovation, expertise and trust. It appears frequently unable
to work positively with industry and particularly GA for win-win scenarios which are
readily available. It struggles to implement better approaches to GA safety and
regulation.

Industry desperately wants an effective and efficient regulator that is open to better
ways of doing things, bases its regulatory approach on supporting and guiding
effective risk management, and levels its regulation, surveillance and education at
the different GA sectors in the best way.

However, the ongoing train-wreck of regulatory change that continues to impose a
heavy burden of red tape and cost on industry for no safety benefit lays bare the true
state of CASA, its culture and its leadership.

CASR Parts 61 (pilot licencing), 141 (training organisations), 66 (maintenance
licencing) and others have created overly complex regulatory overreach that has
decimated industry training and is now belatedly under review because of this
impact.

The CASR Part 138 Manual of Standards has now been forced out for consultation
during the COVID 19 pandemic – as if industry didn’t have enough challenges –
despite many on the Technical Working Group telling CASA it was not fit for purpose
because of overreach, complexity and length. Industry now has to respond to reject
another Part that will cause damage because CASA decided to ignore its own
consultation process. This is the same trajectory as CASR Parts 61,141 and 66.

As an initial submission to the RRAT inquiry, AAAA believes it is worthwhile
providing a summary of previous work, key issues and potential remedies.


2. Executive Summary

The core problem that has had a major negative impact on general aviation over
decades remains CASA.

CASA remains an organisation that seems incapable of positive change, that
continually engages in regulatory overreach and which generates thousands of
regulations that are overly complex, prescriptive, costly and not related to minimum
safety standards, efficiency or recognition of other risk managing regulations.
Despite occasional green shoots of rationality - often initiatives driven by industry -
these are all too frequently torched by the CASA attitude of ‘we know better’ –
despite all evidence to the contrary.

While there remains positive policy consistency from the Civil Aviation Act, the
Minister’s Statement of Expectations and the CASA Board, there is an irreconcilable
difference and tangibly different outcomes from that point on to the implementation of
aviation regulation in Australia.

It is clear that the ASRR has not had the positive effect intended on CASA.

CASA remains in desperate need of reform at many levels to change its trajectory
from being a negative, destructive, inefficient, inward-looking bureaucracy towards
being an effective, innovative aviation regulator that contributes to the nation.

Reference pages 3-9 for recommendations.

Well worth the 2 coffee read - 



MTF...P2 

#reformcasa