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AMROBA written submissions to the Forsyth Review:

1 Aircraft Maintenance Repair and Overhaul Business Association Inc (AMROBA) - PDF: 149 KB


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8 Aircraft Maintenance Repair and Overhaul Business Association Inc (AMROBA) - [url=]PDF: 1411 KB

Executive Summary

Aviation has been in a state of change ever since government created, in 1988, a
separate aviation safety regulator to operate on economic principles and the
creation of an independent air accident bureau. This followed a 1987 Parliamentary
Report on aviation safety regulation and sport aviation safety. Twenty five years on
and there is still no final legislative system meeting global standards?

The international and national allocation of responsibilities for safety of the safety
regulator, air accident bureau and industry, are obviously still not clarified in the
legislative system that is being imposed.

The ‘objectives’ of multiple aviation reviews, post 1988, that the aviation industry
has been subject to, have never achieved clarity of purpose, and never will, until
the Civil Aviation Act is part of what must be reviewed. Bench-marking the
legislative structure against other mature aviation countries, then amending
accordingly to implement an effective aviation system applicable to the
complexities of Australia’s aviation activities and also compliant with the applicable
Articles of the Convention on International Civil Aviation, must be done.

The Act must enable governments to make Parliamentary Regulations directing the
Civil Aviation Safety Authority (CASA) to promulgate [civil] aviation safety standards
(CASS); standards developed by adapting and/or creating global [civil] aviation
safety standards.

The promulgation of CASSs must be the responsibility of CASA but the Act must
also require those CASSs to be adapted from the Annexes to the Convention on
International Civil Aviation, comparable with North America and European Aviation
Regulators’ promulgated safety standards (Regulations/Standards) with minimal
differences with our closest trading countries, New Zealand and Papua New Guinea.

Until the Civil Aviation Act has an objective that will see the development of aviation
safety requirements to support a safe and sustainable aviation industry, there will
not be overall growth in a safe and sustainable air transport system for all. The
current ‘Main Object’ of the Act works against safe growth in some sectors.
Aviation safety is based on continual review of past decisions, recognising which
decisions have had positive effects and which decisions have had negative effects.

The regulatory reform has been continual since 1989 and industry has had to
continually change their business model. The problem is today, the change process
itself introduces risk elements to safety. Many participants in this industry have
only known an industry undergoing regulatory change and this continual change
imposes confusion, a regulatory imposed risk that has to be managed.

Rewriting the Civil Aviation Act and a three-tier system will enable the regulatory
reform process to be completed within 3 years.

Ken Cannane Dated: 1st January 2014
Executive Director
AMROBA
www.amroba.org.au
Safety All Around

AMROBA Comments/Response to Foryth Review Final Report & recommendations:

Aviation Maintenance Repair and Overhaul Business Association Inc (AMROBA) [PDF: 245 KB]

Summary.
AMROBA strongly supports the thrust of these recommendations as above. Considering the number of previous aviation reports and previous recommendations, AMROBA members are of the opinion that these recommendation, if adopted, are not worth the cost of the review unless the Minister amends the Civil Aviation Act to permanently implement these recommendations. See attached Annex.

Though the reports mentions on page 31 that the Department should bear responsibility
to deliver sound and effective policy direction in pursuit of a safe, secure and sustainable aviation industry in Australia, little else addresses the cost/benefit approach to regulatory development. Our assumption is that the Panel assumes cost/benefits are a subset of being a sustainable industry.

The reason why the current dysfunctional system has been created must be sheeted home to the philosophies of the current Board and CASA Executive. The report clearly identifies that it is not an individual sector, association, airline or organisation that has an issue but industry sees it as a systemic problem with the aviation environment.
Australia has a mature aviation industry with a good safety record that was built on a
safety partnership between the Department and industry. Transferring to an enforcement compliance approach, instead of a safety compliance approach has not been successful except for closing down many aviation participants.

Ken Cannane
On behalf of AMROBA Members
Phone: (02) 97592715
Fax: (02) 97592025

Finally the all important Annex to the above:




MTF...P2