[Peetwo]

Submissions 34 (Professionals Oz) & 35 (Jerry Visick)

Via the APH website - 

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34 Professionals Australia (PDF 684 KB) 

The impact of CASA’s internal problems on the general aviation industry

The general aviation industry presents a greater regulatory challenge than commercial aviation. General aviation operators lack the scale and resources of commercial aviation and therefore need greater regulatory attention and oversight. While commercial operators have the resources to invest in and sustain robust internal operational safety systems, general aviation operates on smaller scales with more limited resources and presents CASA with different challenges.

Flight crews operating in the general aviation industry usually hold less experience than commercial crews and also tend to be operating much older aircraft. These aircraft require more care and attention as they age, yet the supporting Licenced Aircraft Maintenance Engineering workforce is diminishing at an increasing rate due to widespread retirements and a lack of new entrants.

Compounding this situation is the ageing general aviation aircraft fleet. The average age of the general aviation fleet is over 40 years, with the original design service goals being exceeded by the majority of these aircraft many decades ago. While older aircraft are not inherently unsafe (that depends on how each aircraft has been individually operated, stored and maintained over its life), older aircraft definitely require more attention to remain safe. Evidence of this occurring in industry is not readily apparent, nor is increased CASA oversight to validate appropriate regulatory oversight to manage the ageing issue.

CASA is challenged with balancing the responsibility of administering two sections of aviation with vastly different risk profiles. While commercial aviation is the area where the consequences of critical failures are significant, the likelihood of such failures occurring are lower due to the resources of operators to maintain operational safety and the high level of public scrutiny.

In general aviation, the consequences of critical safety failures are lower than with commercial airliners, however the likelihood and frequency of these failures is high, particularly when payment has been received by the operator for the carriage of passengers; for example the following recent Charter accidents:

• Beechcraft King Air VH-ZCR, Essendon Airport VIC, 21 February 2017 (5 fatalities),
• DHC-2 Beaver VH-NOO, Hawkesbury River NSW, 31 December 2017 (6 fatalities), and
• Cessna 404 Titan VH-OZO, Lockhart River QLD, 11 March 2020 (15 fatalities).

The Charter segment rightly deserves higher levels of CASA oversight and resources to more appropriately align with community safety expectations.

General aviation also has a larger operational “footprint” to be overseen, operating in regional areas not serviced by commercial aviation. This presents another challenge for CASA and the shrinking technical workforce. For example, hot air balloons are flown by small operators throughout Australia but CASA has limited capacity to oversee this area of general aviation due to only employing one hot air balloon Flying Operations Inspector.

Additionally, the self- administration system results in CASA having different levels of oversight responsibility in the general aviation space and adds another level of complexity to regulation. As the responsibility can be subcontracted to non-government organisations operating as Approved Self-administering Aviation Organisations, it’s critical that CASA has the skills and resources to oversight these organisations, otherwise blind spots in the regulation of general aviation could emerge.

35 Mr Jerry Visick (PDF 58 KB) 

..I am a CASA 21M delegate and was previously a CAR 35 delegate - for an approximate
total time of about 40 years. I have over 60 years experience in the industry and hold
an honours degree and a Masters degree in Aeronautical engineering. This is the first
time I have done anything like this and don't really know how to proceed but I do
think the situation within sections of CASA has got completely out of control and
something urgently needs to be done about it.

Up until about the period 1994 - 2000 Australia had a Regulatory Authority in the then
CAA of which we could be justifiably be very proud. The CAA punched well above it's
weight on the international scene.

Unfortunately since then the technical and engineering capability of Airworthiness has
descended to unprecedented lows to an extent that I no longer refer to CASA for any
queries or guidance. The ignorance and lack of knowledge is such that at times I feel
like a surgeon who is being lectured to by a junior nurse.

On another front CASA no longer appear to be inspecting aircraft to ensure that all
installations and modifications are carried out in accordance with approved
information. The result of this is that the log book history of Australian aircraft is
disappearing. Maintenance standards, without CASA oversight, will inevitably become
lower with an impact on aviation safety. Throughout the industry CASA is now only
viewed in derogatory terms.

If you can guide me on making a more formal submission I would be willing to do this
but will require some guidance

Best Regards

Jerry Visick
ARN 521606

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MTF...P2