[Peetwo]

RAAA Convention 21-23 October 2015

  I note that the RAAA convention officially kicks off today in the Hunter, is this just another WOFTAM gobfest; or could it be a catalyst for getting the Forsyth (ASRR) report & recommendations back on track, a kind of last chance for the Miniscule?

Looking at the program for tomorrow it would appear that not only is the DPM making an appearance but also the terrible trio - 'the three stooges':

Friday 23 October 2015

Session 8
09:00 - 09:30
The Hon Warren Truss
Deputy Prime Minister
Minister for Infrastructure and Regional Development
(Subject to Final Confirmation)

Regional Aviation: The Sky's the limit..

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..Session 10
10:00 - 10:30
Mark Skidmore
Director of Aviation Safety,
Civil Aviation Safety Authority

CASA's direction - Regional focus...

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..Session 13
12:30 - 13:00
Jason Harfield
A/g Chief Executive Officer
Airservices Australia

Delivering value for Australian aviation

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Session 14
13:00 13:30
Martin Dolan
Chief Commissioner
Australian Transport Safety Bureau

Repeat lessons: What the ATSB is finding?..

  
Now in the course of the day's official business I would like to nominate an IOS/PAIN representative to somehow get the DPM in a headlock & bend his ear. 
IMO that person should be this bloke..

And here is why (reference from RAAA Winter Newsletter 2015):

If you take a look around the world you will see a number of countries that are particularly dependent upon aviation as a core component of their transport and social infrastructure; Australia is clearly one of those countries.

Why is it then that we as a nation suffer so badly from a regulatory regime that is so poorly suited to modern Australia and our industry?

There are many reasons for this of course, mainly historical but also geographical and political that lead us to a system today that is overly complex, anachronistic and damaging, not only to our future investment in hard assets but more importantly, in people.

Many participants I speak to in the aviation industry have recently and deliberately steered their children and grand-children well clear of aviation. I too do not want my children involved in the industry unless we see some strong leadership from Government.

We have to ask a further question. Why is it that many of us who have been in the industry for a long time do not see it as an industry worth considering for the next generation(s)? We will come back to this question shortly.

As has been expertly chronicled in the Aviation Safety Regulation Review (ASRR), chaired by David Forsyth, there is much wrong with the industry and whilst the current government should be congratulated for implementing that review, they have been close to negligent in the speed by which they have dealt with its recommendations.

We have only recently seen the Statement of Expectations (SOE) issued by the Minister to CASA, a full six months after the appointment of the new Director of Aviation Safety, Mark Skidmore. Additionally, we are only now seeing movement on the ASSR recommendations, a full 15 months after its publication.

One of the overriding themes from the ASRR was the breakdown in the relationship between CASA and the industry. This was born of many issues, most of which remain. The debacle that is Part 42 and Part 145 was implemented with undue haste and from my view with potentially dangerous outcomes. Can someone please explain how we have a safer and more efficient industry as a result of those changes? We certainly have far fewer participants in aviation as smaller organisations that could not afford the layers of bureaucracy that those changes brought, exited the industry.

Those organisations employed staff all over Australia and now we have lost an unacceptable volume of skills that sadly are now provided by overseas suppliers.
Separately, can someone also explain the shambles that is Part 61?

I feel for those pilots who have finished their training since August of last year and still cannot get their ATPL’s issued. These candidates are our industry’s future, and thus having expended an enormous amount on their licence, have no way of gaining or advancing their employment. This is scandalous. How would CASA have reacted if an aviation organisation in Australia had botched a major change to their operations to this extent? An immediate “Show Cause” I would think.

Can someone also explain the huge disconnect between Commonwealth and State legislation that now limits engineering apprentice training to only a handful of registered organisations?

Further, it is both outrageous and concerning, that there exists such a dichotomy between the CASA regions, the Certificate Management Teams and individual inspectors. This is evidenced through the inconsistency in interpreting and applying the provisions of the Regulations. Fatigue Risk Management is a classic and topical example of the lack of direction, cohesion, or understanding that exists within the regulator.

The four examples I have given above are real life outcomes of a disjointed framework in which the aviation industry operates throughout this vast country.
Under successive colours of government we have ended up with a regime that is broken.

Whilst we enjoy an enviable safety reputation in this country, this is borne more of the diligence of personnel within our surviving aviation providers than in regulation and regulatory oversight itself.

Senior managements within all organisations I know are well aware of their obligations under the Civil Aviation Act and discharge their duties with diligence and concern. This is why outcomes such as Part 61 cause us all such heartache.

By my calculations we are into our 23rd or 24th year of “Regulatory Reform” and all I now see is “Regulatory Reform Fatigue” as the outcome of many failed processes, false starts and confusion.

So in that environment, how are we going to encourage the next generation into the industry? I fear that will become increasingly more difficult.

I have outlined above just a few examples of where the industry, regulators and government are not working together to foster the industry.

It’s easy to bleat I know, and much harder to fix “machinery” that has been covered in temporary fixes for decades. Perhaps what is most frustrating, and the reason for the bleating, is that many of the solutions have already been identified and recommended by the ASSR and supported by industry.

When we ask the question as to why we simply did not adopt the New Zealand regulations we are told that somehow “Australia is different” and then in the next breath we hear about harmonisation with the rest of the world.

Look at all the South Pacific nations that have adopted the New Zealand regulations and the benefits that now flow to New Zealand suppliers as a result.

Why does it take months to modify an aircraft for Australian registration when it takes days in Europe?

The New Zealand experience of Aviation Regulatory Reform is in my opinion a success story. It was achieved through real consultation and collaboration, and a genuine willingness of CAANZ to engage with industry.

The solution obviously rests with Parliament and the relevant Minister(s)

We elect Government, they set the legislative environment, formulate the regulatory framework and then employ the senior personnel to regulate. The industry supports this but DOES NOT support individual personnel within regulators running their own “legislative” agendas.

The industry is encouraged by the appointment of directors from industry to the new CASA Board.

However, Parliament must take a greater interest in aviation and each colour of government should at least have a Junior Minister for Aviation that can dedicate their time to ensuring the regulatory framework and policy settings are appropriate for our modern industry.

Without a bold new coordinated vision for our industry how do we hope to attract the appropriate talent to take this vital industry forward?

Please note these views are personal and do not necessarily reflect the views of my employer.

 
I know..I know it is only rhetoric/words on a page; but you get the feeling there is much passion behind the words - bravo Scott, cyber choc frog for that effort..

The RAAA recently (see above) held their annual convention in the Hunter, apparently discussions on the Forsyth review & the reform of CASA caused much contention amongst certain delegates - Reference: Safeskies thread - The Emperor's new clothes - MKII. However maybe this will end up being the catalyst, the final straw that broke the Camel's back - one can only hope -  .

Link for RAAA webpage & newsletter.

To add to the above, here is the RAAA written contribution to the Forsyth (ASRR) review.. :

246 Regional Aviation Association of Australia (RAAA) - PDF: 5469 KB 


II. EXECUTIVE SUMMARY

The RAAA believes the bulk of its concerns stem from a poor culture in CASA which itself results from poor senior management and governance over several decades. If the Government of the day is not to take a more active role in the formulation of aviation policy generally and, through the relevant Department, a more active role in the management of the aviation bureaucracy, it must be prepared to create a more substantial and active Board to oversight CASA’s management.

Successful operators are responsible operators who understand that safety management is integral to the management of their businesses. A safety culture cannot be imposed, it must be fostered. A regulator can police sensible accepted standards, but it cannot foster the safety culture with a rule book and a heavy handed application of penalties.

A genuine safety culture comes from the regulated and the regulator sharing essentially the same values and the same objectives. They will not always agree on the means to achieve these, but without this common basis the safety culture will be undermined. Sound safety culture and practice can really only be achieved by way of a partnership being forged between the regulator and industry.

Today in Australia the regulator, CASA, is held in such low regard there is no common ground, but more of a “them” and “us” attitude. Additionally, industry participants are wary of talking publicly about CASA due to a fear of retribution. This fear is reflected by some RAAA Members’ apprehension in providing examples for our submission to this Inquiry, regardless of whether our submission is classified confidential or not.

&...RAAA response to Forsyth final report:

Regional Aviation Association of Australia - PDF: 396 KB


II. EXECUTIVE SUMMARY


The RAAA welcomes the release of the ASRR Report and commends Deputy Prime Minister Truss for delivering on his pre-election promise to put Australia’s aviation regulatory system under the microscope.

In general, the RAAA endorses the key aspects of the report and looks forward to seeing them implemented.

In addition the RAAA recommends that the philosophy of just culture be incorporated into legislation through the Civil Aviation Act, CASRs and the Transport Safety Investigation Act, rather than through a CASA formulated policy document.

The RAAA proposes that the ATSB transfer information from Mandatory Occurrence Reports to CASA without redaction or de-identification only when just culture principles have been legislated for in Australia.

MTF...P2