[thorn bird]

Of course the CAsA sleight of hand in the so called "differences" P2, is where ICAO may advise "A" check, or inspection, or procedure, or standard, CAsA instigates four, then crows "we are just complying with ICAO". When you point out that ICAO only required one, not four, they reply "well Australia's standard is very much higher than the rest of the world". They never consider what cost all their extra's will inflict on industry nor the complexity it adds to our regulations and operations and the difficulty of marrying them with regulations overseas.

I give you an example. forty odd years ago I became involved with a charter company who operated a mixed fleet of piston twins, turbines and a light jet in transport category. All these aircraft were flying around 800 hours a year by around sixteen pilots. Their operations manual was barely a hundred pages and included international operations and RPT.
The company devoted considerable recourses to pilot training and mentoring, by its nature their crews were young and generally inexperienced, their safety record was exemplary.

All the information required to operate an aircraft is contained in the manufacturers pilot operating handbook or flight manual. In those days Australia had its own unique "flight Manual" the "little black book". It had bugger all in it except "P" charts for take off and landing performance. Our regulator at the time refused to accept the manufacturers data based on certification flight testing and insisted on flight tests for first of type to produce these "P" charts, in many cases the performance data produced was less restrictive than the manufacturers certification data. A simple statement in the Ops manual that the company would use the manufacturers operating procedures contained in the Pilot operating handbook was all that was required to comply.

In the modern era of CAsA, operations manuals have expanded to thousands of pages, probably to reflect the thousands of pages of regulation that has been added over the years, it now runs to part A to part H, volumes of what is euphemistically referred to as "Shelfware". These tomes provide CAsA employees a conduit to interfere in the conduct of operations even tinker with manufacturers recommended procedures.
The "Make work" result of this is hundreds of thousands of dollars and years to obtain an AOC, and hundreds of thousands of dollars and months to add a new type to an AOC.
There are many instances where unqualified, inexperienced FOI's have bullied Chief Pilots into promulgating procedures expressly forbidden by the manufacturer. Complaint is futile because your manual must be "accepted",
you have a million dollar machine sitting idle eating dollars, so you accept FOI's instructions, knowing what is being asked is unsafe, that you must accept responsibility for it, the FOI accepts none, because he accepts not approves, you toe the CAsA line or your machine sits idle.

In P2's post 91 Bill Hamilton makes a very relevant statement:

"Indeed, in my view, the lack of relevant knowledge and experience in CASA has reached an appallingly low level, it has long been the "employer of last resort".

The Part B of the modern day CAsA "accepted" operations manual, Aircraft Operating Procedures, runs to hundreds of pages, largely large parts of the flight Manual cut and pasted from the "Flight Manual" with added bits and pieces required by the FOI of the day. Yet the Flight Manual is the "Legal" document, it is mandatory to have a copy on the flight deck, there is no requirement to have Part B on the aircraft. The procedures contained in the flight Manual must legally be complied with, in fact the opening statement in most part B's is "Notwithstanding anything promulgated in this manual, the aircraft Flight Manual takes precedence". One could wonder therefore exactly what is the point of the part B in the first place other than a "Make Work" exercise for FOI's.

All these pieces of "Shelfware" also require continuous revision as the juggernaught of regulatory ineptitude rolls on, thousands of pages added every year for which proof of compliance must be mandated. There is also continuous amendment required where rules already promulgated are found to have unintended consequences and need to be changed. Writing them properly in the first place would save a lot of angst.

CAsA is charged by the government to ensure safety, I don't believe it is any safer today than it was forty years ago, just a hell of a lot more expensive.