[Peetwo]

Aviation Green Paper Submissions? -

Via Betsy's website: https://www.infrastructure.gov.au/have-y...reen-paper

Outcome

Submissions on the Aviation Green Paper closed on 30 November 2023. Submissions made on the Aviation Green Paper are published in full below (unless it was indicated at the time of submission that a submission was to remain in-confidence).

The public consultation has been an important opportunity for the Australian community and industry to have their say. The input is important to support government in making decisions on the policies to be included in the Aviation White Paper, which is expected to be released in mid 2024.

Submissions will be released on the department’s website in tranches as they are processed. All submissions must be reviewed to ensure that the privacy of submitters is respected.

The Department is not responsible for the content of these submissions, which remains the responsibility of the original authors and do not represent the views of the Department. To the extent permitted by law, the Commonwealth disclaims liability to any person or organisation in respect of anything else done, or omitted to be done, in reliance upon information contained in any of the submissions.

Not sure if there are more submissions yet to be published. There are currently 355 submissions, a large majority of which are limited comments from disgruntled individuals living under airport approaches at major city airports. Still going through the industry stakeholder submissions, some of which will be worthy of review and further exposure.

Example 1 of a first class factual, evidence based submission, comes from the 'Honourable Company of Air Pilots Australia (HCAPA)': https://www.infrastructure.gov.au/sites/...tralia.pdf

2. Likely Future Directions to 2050

a. The Green Paper does not layout a National Aviation Policy. Without a coherent policy, there will be a piecemeal approach to different issues which will diminish their effectiveness.

b. There is an emphasis on sustainability and environmental issues and, whilst these are admirable objectives, they do not solve the many areas that exist today and will continue to do so without effective action.

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4. Regional and Remote Aviation

a. Regional airports are vital infrastructure for natural disaster relief (fires, floods, cyclones). There needs to be a national plan to maintain and support this vital asset.

b. Many of our regional airports are suffering due to the decline in general aviation. There needs to be a balance between the transformation to net zero and further burdening general aviation.

c. To this end, the Australian Government should consider prioritising regional airports and supporting infrastructure such as roads and runways. These assets are particularly impacted by natural disasters and issues regarding ongoing maintenance funding and planning.

d. In HCAPA’s view, “better, more resilient and more flood-proof infrastructure” starts with regional airports. We have had widespread flooding across Australia that has highlighted the impossibility of flood-proofing all of our roads and railway lines while highlighting the vulnerability of many of our population centres to isolation from flooding. Retaining a connection by air can significantly ease the hardship for those affected, particularly in more remote communities, and may well be the most cost-effective first step.

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6. Airport development planning processes and consultation mechanisms

a. Has “light touch” led to incompatible development around airports? (see Sub para 8.k)

b. It is unfortunate that the focus of this section of the Paper is on noise, instead of protecting the airspace and preventing inappropriate rezoning leading to development that impinges on the safety and efficiency of aviation.

c. Noise is a community issue, but it is not assisted by rezoning and allowing domestic premises to be built close to airports or under known or planned flight paths.

d. Wind disturbance from building and other activities on or off airport continues to be a major safety concern. The  National Airports Safeguarding Framework Guideline (NASFG) “B” is not fit for purpose as it does not follow the Royal Netherlands Aerospace Centre (Royal NLR; Dutch: Koninklijk Nederlands Luchten Ruimtevaartcentrum) research and considers buildings and other things in isolation. The Guideline needs to be amended to rectify these defects and then needs, along with the other NASF Guidelines, to be enacted by each State and Territory, as was the original undertaking made at COAG.

(The whole section on Airport development planning etc well worth a read)

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7. General Aviation:

a. GA is still the backbone of our aviation industry. It is the sector that provides initial flying training in the civil sector. Without it the whole aviation transport industry faces constraints so supporting this sector is vital. This includes support of GA airports, access to training airspace, support for light aircraft maintenance engineers and facilities.

b. At present, the energy density of batteries is insufficient to support a flight of 150nm, which is a basic requirement for the issue of a PPL.  Another way of reducing emissions, at least in the flight training sector, is increased use of high-fidelity simulation, thereby reducing actual flight time.

c. A major issue is the lack of light aircraft maintenance facilities, and this may not be as much a regulatory issue as a societal one. HCAPA would support the concept of the “gumtree” LAME: a maintainer who does not necessarily have their own fixed workshop facility but is allowed to travel and work on the aircraft where the owner/operator is based. (Much like the “we come to you” motor mechanics and windscreen technicians.)

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8. Fit-for-Purpose Regulations

a. With the demise of RAPAC and its morphing into AvSEF there is no longer a regular forum where issues that involve multiple departments can be discussed. Each department now has their own dedicated consultation/ engagement process.

b. CASA stated at the time RAPAC was dissolved that there would still be a multi departmental forum held on a regular basis. There may have been one or two attempts, but HCAPA is not aware of any recently. Moreover, these are not the same as the AvSafety seminars that CASA organises. 

c.  A good example of where multi-departmental involvement is required is the development of Western Sydney International Airports airspace and routes. Now we have information on air routes coming from Infrastructure but ultimately it will be ASA that controls the airspace and CASA who approves it through the OAR. Western Sydney airspace has ramifications for both airlines and GA.

d.  Another example of where multi-departmental involvement would have been appropriate was Airservices’ handling of the Ballina Byron Gateway airport. ASA went through a process of consultation before establishing their Surveillance Flight Information Service, during which they were told it would not really be a satisfactory solution. Ultimately ATSB raised it as a safety issue forcing the OAR to do an airspace review. One of the recommendations was the establishment of CTR at Ballina by 30 Nov 2023!

e. Apparent risk aversion means that Australian regulators fail to take account of ways of regulating aviation using means that are well-tried and tested and in common use by the rest of the world, and hence Australia has ceased to be a leading force in ICAO.

f. This leads into the next issue which is “consultation” which should mean listening to stakeholders rather than going out and trying to find feedback that supports preconceived positions. Recent discussion on the medical TWG relate to this. Departments should approach consultation with a blank sheet of paper, do actual research and analysis before coming to conclusions.

g. The Aviation Safety Advisory Panel receive their information on TWG recommendations from the CASA “support” team rather than from the TWG members themselves. This means that CASA are able to report outcomes of the discussions in a way that suggests the TWG members either support the CASA input to the group, or may be misled into accepting a report that does not fairly represent the views of the industry specialists’ proposals. Furthermore, some key agreed standards have been changed significantly during the legal drafting process...

(The full section under 'Fit-for-purpose regulation' is worth a read)

MTF...P2