[Peetwo]

Words of wisdom on broken (nearly 30 year) RRP - *via KC & AMROBA

Perhaps the following should be forwarded to not only miniscule Chester and M&M's department but also to every member of Parliament, as a briefing and historical reference on the imposts imposed on industry by a bloated and cumbersome aviation safety bureaucracy for nearly 3 decades:

2. Lessons Learnt - We Need “Regulatory Reform” not continuing “Regulatory Development” (Reduce Regulatory Impost/Red Tape)

In business, if you do not change with the times, then you will not be successful. In aviation, an argument can be made that the organisations that most need to adapt to changing times are government department/agencies. Since they are complex and highly structured, it is difficult for them to respond to change in a timely manner.

The negative impact of failure to respond is not immediately felt within government departments/agencies and the urgency to act quickly is often absent or non-existent. Public sectors are more sheltered and isolated from private industry changing conditions so creates a need for them to be more innovative ways and means to anticipate and respond to change more quickly and more effectively.

Our non-airline aviation sectors identified their preference to internationally align aviation engineering (design, manufacturing and maintenance) with the FAR system as far back as the mid 1990s. The inability of a public service sector to demonstrate any innovation or response to the needs of these sectors clearly shows that, in aviation, unique conservativeness and lack of response continues to prevent industry to expand and create jobs.

The negative impact of failure to respond is often not felt immediately within these organisations. Therefore the urgency to act quickly is often absent or recognised too late. Since public sector groups are more sheltered and isolated from the changing environment, there is a pressing need for them to seek more innovative ways and means to anticipate and respond to change more quickly and more effectively. They need to enhance their capability to learn, unlearn and relearn so as to become more effective learning organisations.

There is also a misconception that the public sectors, because they are the people to action changes and time frames that are expected by the citizens that are affected by the lack of changes. In many cases businesses and jobs are affected by the inaction of the public services. Today’s participation rate in the non-airline sectors is less than what existed when concepts were changed with the introduction of CAA and changes to GA, including aerialwork.

1988 Changes: No lessons have been learnt when government transitioned from Air Navigation Regulations/Air Navigation Orders to Civil Aviation Regulations/Civil Aviation Orders in 1990. This major change applied AOC/Organisational approval to individual approvals in aerialwork that started the decline of general aviation and introduced a pilot shortage in Australia. The loss of instructors reduced pilot training and subsequent AMO closures increased. Loss of jobs all round. Failed policy??????

Individual Flight Instructors exist in the FAA system and train around 70% of all pilots in the USA. The introduction of the CAA also saw the downturn of many small AOCs as large AOC conditions were applied. The “Supplemental” airline system that was operating was also shelved. Less ports are serviced today. Failed policy????

CASA is great at creating regulatory monopolies without competition. The Individual Flight Instructor, without additional overheads, would compete with flight training organisations. As expected, there were many more training organisations in existence when the independent flight instructor existed. They simply attracted more pilots, more flying and more LAMEs/AMOs.

The same applies in maintenance. There is no need for an approved AMO in certain circumstances, such as, but not limited to:

(1) Flight training organisations employing a LAME,
(2) Aerialwork operator (AOC because of environmental reasons) employing LAME,
(3) Private owner employing a LAME.

An AMO is required when it is a business providing maintenance services commercially.

Finally a 'nail in head' statement from part III of the latest AMROBA newsletter:

Fundamentally, CASA still has not changed from a regulatory development organisation bent on creating more regulations and red tape. Both LNP & ALP have/had policies that should result in "regulatory reform".


"Regulatory Reform" should have an outcome that reduces regulatory requirements and red tape. We continue to hope CASA implements reform.

As usual, excellent stuff KC and the obligatory choccy frog voucher is in the mail...


MTF...P2