[Peetwo]

RAAA response to Murky's SSP DRAFT

Industry v Insanity - P2 supplemental

Every time; and, I do mean every time there is an opportunity for industry to participate in in setting a course away from disaster or on the road to recovery it, weighs in.  Willingly, unstintingly and at little or no cost to the government the industry provides expert, considered opinion, provides cost effective solutions and indicates a willingness to assist with effective, sensible reform programs.  Gratis, no charge advice on which a minister could rely and fund, not only saving the Commonwealth millions, but earning even more revenue, not to mention jobs and investment opportunities.

Look at some of the standout submissions, from Pel-Air through Forsyth and on to the latest Productivity Commission; there are some first class, top drawer submissions made which provide empirical evidence of industry ‘expertise’.  The latest from AAAA is an exemplar: sane, balanced, practical, fully supported by membership, totally achievable and capable of ensuring safety and increased productivity – in short; the right solution.

Over the past decade many such documents have been provided by industry; over the past decade almost none of those documents has been put on a table, discussed with the ‘authority’ and implemented.

Over the past decade the government appointed ‘experts’ have gone to extraordinary lengths to avoid embracing the expert advice of industry specialists, independent reports, analysis and solution.  Even ministerial directives get short shift.  AMROBA, AOPA, AAAA, Forsyth etc. all get the same treatment, a lot of lip service, enough action to provide credible evidence for the minister to state that ‘something’ is being done; then, after a suitable time period in limbo, good ideas are taken out the back, their throats quietly slit, the carcass buried in the departmental graveyard.  RIP.

We spend millions on the care and feeding of things like CASA who could not, on their best day produce a submission to match the AAAA effort, which was gifted to the nation.  We need to ask why we are squandering a fortune employing non expert dead beats who’s sole purpose in life seems to be playing at policemen, ‘prosecution’ and decimating industry initiative.  This occurs throughout the agencies, ASA, ATSB and CASA; incompetent, non experts running multi million dollar enterprises which ignore expert advice on the very thing which necessitates their existence; i.e. the well being of industry and those who manage it, very well, despite dragging the lead weight of departmental arrogance and ignorance behind it, then having to fund that incubus. But don’t just take my word for it; compare the AAAA submission (which we have for free) to the Chambers report; or, the Pel-Air report (both of which we paid dearly for) on a benefit to industry basis and decide for yourself.

It is insane.

For want of a nail the shoe was lost.
For want of a shoe the horse was lost.
For want of a horse the rider was lost.
For want of a rider the message was lost.
For want of a message the battle was lost.
For want of a battle the kingdom was lost.
And all for the want of a horseshoe nail.

Selah.

PS.  Nicely done Phil, well done indeed.

To reinforce the P9 post one only needs look at the following post extract to see that the Department, CASA, ASA & the ATSB have a normalised deficient culture of notifying a difference to ICAO: http://auntypru.com/forum/-Shame-or-fame...12#pid3912

Been a bit quiet on the RAAA front, maybe they've been busy contributing to the excellent just released TAAAF Policy ???

However trolling through the RAAA website (as you do ) I did note that, much like Phil Hurst & the AAAAs (see post link above), the RAAA did comment on Murky's SSP DRAFT... :

II. RAAA Response to the Draft State Safety Programme

The Regional Aviation Association of Australia (RAAA) finds no significant issues with the Policy Statement as it is written. However we have serious concerns about the delta between the proposed situation and reality. The RAAA can cite numerous examples, but recognise most should be addressed in a separate forum to this submission. Therefore this submission will only identify high level concerns.

Policy statement paragraphs 3 and 9 claim that sound assessment of risks and service provider’s safety performance indicators are used to guide the regulatory development approach.

Just one example of where this policy is not applied is in the philosophical design approach to Civil Aviation Order 48.1. The current version is out of step with sound assessment of the actual risk faced by many mature Australian operators, and not based on empirical evidence in the Australian context.

Policy statement paragraph 6 claims that recognition of Australia’s safety regulatory system will ensure that Australia has a competitive aviation industry.

An increased focus is required in this area. Particular emphasis should be given to Bilateral Agreements with international service providers, particularly in the aviation maintenance sphere. The industry has agreed with the international harmonisation route on the basis that our regulations would be recognised and Australian operators could enjoy the associated obvious benefits. However the efforts and results from CASA in this regard are disappointing to date, despite numerous and costly investments in international face to face meetings.

Policy statement paragraph 10 claims that the appropriate personnel will be appointed to discharge their responsibilities competently.

Whilst sufficient financial and human resources have been allocated within areas of CASA, certain staff do not have the proper technical, people management, financial skills or appropriate industry experience to discharge their safety oversight and management responsibilities competently.

One final issue of significance that must be documented at this time is the disappointing lack of progress on the implementation of the Aviation Safety Regulation Review (ASRR). Page 8 of the draft State Safety Programme refers to the ‘Aviation Policy Group (APG) monitoring the progress of the delivery of the SSP and the SSP gives effect to the Aviation Safety Regulatory Review (ASRR) recommendations’. The RAAA has serious concerns on the lack of progress and the lack of visibility and surety that the policy intent of the recommendations has been correctly understood by CASA. A Post Implementation Review by mid-year to ensure the correct application is required.


III. CONCLUSION

The RAAA is grateful for the opportunity to provide our views for the Department of Infrastructure and Regional Development’s Draft State Safety Programme. If you would like further information about the items contained in this submission, or clarification on any of the points we make, the RAAA would be more than happy to assist.

 
Short, sharp & very much to the point - good job Higgins & Co

With those sort of comments (AAAA & RAAA) coming in, maybe I banged the nail on the head, when I said that the Carmody appointment might be to help Murky sort it all out??

Especially when you consider the latest rumours doing the rounds, via "K" off the Alphabets thread:

Rumours eh?


Couple or three juicy morsels floating about in the lead up to the Great Tamworth Bunfight. It depends on exactly how high your cynic tolerance level is set what you make of them, or even if you believe them.

1) Seems (according to the whispers) we are to have a ‘task force’, not a ‘tiger team’ but the real deal, with instructions to ‘sort it’.  Whispers have it that the ‘TF’ will be led by he who was sent from Sleepy Hollow to Murky’s play room; which may or may not be of value.  We can only hope the task lands on the infrastructure desk and Ms. Fiona Nash, working with Pete-the-Pot plant is in charge.  IF that happens, then there is real hope.  The best man for the job in this case is, most definitely a women; finger crossing and small offerings to pagan gods may assist.

2) Seems the Bae facility at Tamworth is to be resurrected and Barnaby will announce this as part of his Tamworth sojourn. The ‘who’ ‘what-for’ and ‘why’ are still the subject of speculation; there is a short priced favourite, MTF as P2 would say.

3) AOPA president Marc De Stoop has taken a tumble and bust a couple of bones.  He is a first class fellah and well worth a short ‘get well’ message, don’t expect a long response, he has a wing root out of commission.

Rumour mill – over and out....

 
Makes sense to me...MTF P2