[Peetwo]

A Sandy reply to PIP - 

Yesterday I opened up the latest CASA Briefing and it was with a heavy heart that I read the following bureaucratic waffle from PIP...

Director of Aviation Safety, Pip Spence
 

However Sandy lifted my spirits with this 'no prisoners' response...

So there we have it, the first real communication from the CASA CEO, otherwise known by the really silly and excruciating title of ‘Director of Air Safety.’

Two months and nothing.

“…incremental changes..” but not one specific item.

“ And the other good news is that we are building on already solid foundations.” 
Charitably let’s assume Ms. Spence is meaning Aviation Hearse has solid foundations.
For certainly she speaks not of the much beleaguered and shrunken industry of General Aviation (GA) trying desperately to cover ever more CASA fees, and finding the time to handle CASA’s mountainous paperwork and avoid criminal prosecution for some minor misdemeanour. We have ‘crimes’ for some activities that don’t even rate a mention in the USA rules.

Does Ms. Spence expect us to believe there will be improvements? Surely in over two months she might have reviewed the pronouncements of her predecessors? If so she would understand why we don’t believe a word of it. Because belief and hope have been hammered out of us.
Words are not sufficient;  and all the words have been said over and over again but the results for GA have been “incrementally” worse and worse, death by a thousand cuts.

“…mammoth task of introducing the Civil Aviation Safety Regulations is inching towards completion.”

Who created this mammoth task and why? Well, at long last nearly finished;  after thirty three years? before inches gave way to millimetres? Not to mention $millions wasted with 830 employees beavering away. Snails move at lightning speed compared to CASA’s  never ending story.
In fact the CASRs will not be finished until they are replaced by a workable set of rules such as NZ, or better still for the harmonisation of industry, the US FARs.
But wait, Mr. Carmody told us it was all done and dusted. It really is impossible to believe that the feel good intentions of the CASA leadership will be translated into reality. Its just soft soap repeated.

Ms. Spence, with respect,

Please don’t tell us how good it is or how it is going to be improved. If you are to survive your stint with CASA and have your reputation intact, better still enhanced, you must decide to take some reform measures now to the Minister and ask him for his support.

You could start with :-

(1)  A rapprochement with Glen Buckley.
(2) Go to Minister Dutton with the recommendation from the Forsyth report to remove the ASIC requirements for GA pilots.
(3)  Private Pilot medicals same as RAAUS or USA.
(4) Delete Cessna Special Inspections for Private ops., as USA.
(5)  Allow independent instructors, same as USA where 70% of pilots are trained by independent instructors.

The last reform (5) will help to regenerate the whole of GA, a start to rebuild training throughout Australia where, due to over regulation and unnecessary regulation, we have lost some twelve hundred flying schools which is why we’ve been importing airline pilots.

Get some runs on the board and then tackle the other main problems like the wrong split of VH registered aircraft and the RAAUS system because here safety has suffered, quite apart from our loss of freedom to chose, and forcing people into a fleet of extremely low weight. RAAUS, a monopoly entity administering aircraft with an artificial weight limit, which are often not suited to Australian conditions, but are favoured by many because of a more practical regulatory environment, especially the medicals.

Make a stand within Aviation House and GA will stand with you, you will be a hero to thousands, I’m not exaggerating.

Sandy Reith.

Hmm...it may be time for Barnaby to give PIP a nudge in the right direction as it seems that (once again) the newly appointed DAS/CEO is in serious danger of being captured by the CASA Iron Ring 

 "..But the good news is the mammoth task of introducing the Civil Aviation Safety Regulations is inching closer to completion.."



So Carmody and the current CASA Board Chair have both told porky pies! Are you able to retract Queen's Birthday Gong's for misleading both the industry and the Federal parliament? 

But the Chocfrog POTW goes too...  

Spence has “drunk the kool aid”.

For those not familiar with the expression:

“‘ Drinking the Kool-Aid" is an expression used to refer to a person who believes in a possibly doomed or dangerous idea because of perceived potential high rewards. The phrase often carries a negative connotation. It can also be used ironically or humorously to refer to accepting an idea or changing a preference due to popularity, peer pressure, or persuasion. In recent years it has evolved further to mean extreme dedication to a cause or purpose, so extreme that one would "drink the Kool-Aid" and die for the cause.”

Spence evidently knows nothing about safety management theory, risk management and probability theory, still less about anything to do that involves physically interacting with equipment involved in aviation except seat 1A. I am also concerned that there seems to be a lack of understanding of a number of behavioural concepts vital to aviation.

Aviation is an activity like surgery, pouring concrete and arguing in front of a court in that there is no way to pause the process once it starts. Once the aircraft ascends, it is going to have to land. As a result, Surgeons and Barristers (and perhaps concrete contractors) require that their environment is as deterministic as possible in the sense that a + b always must equal c because the aircraft MUST return to earth, the concrete harden and the judge retire to his club at 1.00pm.

Contrast that environment with the regulations, which are the very opposite of deterministic except in one glaring case I will cover later. This is just plain effing wrong. We all know the reason for this too; it is to give CASA maximum room to deny any liability for outcomes, to escape any requirements to provide either internal or external consistency in its behaviour because that implies determinism a + b only sometimes equals c in CASA’S playbook and when it doesn’t,  it always computes in a way that disadvantages pilots and advantages CASA. It is to maximise CASA s power while minimizing its accountability. To minimise the requirement for heavy intellectual travail and the making of difficult decisions and perhaps even for the personal gratification of the odd psychopath in its ranks, although I am not aware of any.

The result, as report after report and case after case has demonstrated is a toxic regulatory environment that is the medical equivalent of a very bad chemotherapy drug - in that the current system tries to keep us ‘safe”, ridding us of accident, without quite killing the industry.

Perhaps Ms. Spence might like to read some of the regulations and try and understand IN DETAIL what they actually mean because she would find that many of them end up in a judgement call as to what is “sufficient”, “appropriate” or “acceptable”. Those are nominative words that mean anything you like, just as the word “safety” itself is a nominative.

Yes Ms. Spence; “safety” compared to what? Compared to a dose of Astra Zeneca? Compared to the risk of being attacked by a kangaroo in one of Canberra’s parks? Compared to what exactly?

We do know what it isn’t compared to; - the ICAO standards for risk, because to apply international standards require we actually compute risk in Australia, compare them to international standards, compare the associated costs and benefits and (deterministically) regulate on the basis of concrete evidence but that wouldn’t be any fun would it?

Of course if you aren’t regulating deterministically or evidence based as it’s sometimes called, you are building on foundations of sand aren’t you?  This is despite the Supreme(?) court upholding sand castle building in the Angel Flight case where his honor ruled that CASA does not need to base regulation on evidence.

Talking of evidence, did you read the Forsyth Review? The cases of Quadrio, Dominic James, Jabiru, Gippsland Aviation, Bristell and now the loathsome thing your organisation has done to Glen Buckley? These are not the hallmarks of an effective organisation working in the best interests of the country. Can you possibly comprehend the opportunity costs inflicted on the Australian economy? Let alone the personal costs to industry participants? The jobs and GDP aviation will never now produce?

Ah yes! You say, “but what about protecting the public”? We can’t have aircraft crashing all the time can we? Of course not. The way to protect the public and to PROVE to the public they are being protected, is to use a risk management/evidence based approach to regulation - which CASA refuses to do. To put that another way, imagine if CASA was in charge of combatting Covid19 - Nurses would be arrested for tying their shoelaces the wrong way, Astra Zeneca would be banned because CASA didn’t like the colour, and groups would be chosen for vaccination based upon hair length, whether their birthday date was divisible by seventeen and the toss of a coin in Canberra each morning.

With the greatest of respect Ms. Spence, you have been led down a well trodden path to irrelevancy. The system doesn’t need fiddling at the edges. It doesn’t need “business transformation”. We don’t require another “process Queen or King” to make us all play nice in the sandpit, we need someone who will tear the place apart and rebuild it from the ground up of honest solid stone, for example the New Zealand interpretation of the FAA regulations and then administer the result in a fair firm and friendly manner for the good of the country.

And the case I mentioned where CASA is deterministic? Why it’s contained in the last clause of each and every regulation: words to the effect that each and every transgression of this regulation is a criminal offence of strict liability. You have to hand that one to CASA you can’t be more deterministic than that, can you?

Sorry to be blunt, but there it is. Better people than me can explain it.

P7 - Choc Frogs and Tim Tams awarded to Wombat and Sandy. Well said gentlemen; Bravo.