[Kharon]

Hopework for Oliver.

For today's lesson we are firstly going to examine recognising Pony-Pooh when it's presented as fact.  In the example below it is possible to identify several excellent examples of the word weasels art.   

"I fully accept CASA can make improvements in both the way regulations are developed and implemented," Skidmore said."We do start with the intention to make new regulations as clear as possible, using plain language without unnecessary complexities. We most certainly do not set out to write regulatory requirements that are hard to understand.

"But like many good intentions our goal can get lost during the journey and, for a range of reasons, the result can sometimes be regulations that are more complex than desired."

One of the things impacting the complex nature of regulation is the government requirement for legislation to comply with the federal drafting style, which by its nature tends to result in lengthy, more complex regulations. Clearly, Skidmore feels hamstrung by this.

"In short, it is not always easy or even possible to create ‘simple’ regulations. But having said that, it is CASA’s job to strive towards the goal of clarity, coherence and precision using plain and easy to understand language."

Skidmore has also admitted that the way CASA has implemented new regulations in the past could so with some improvement.

"The first is to do more work up front before the regulations are made," he said. "This may involve testing the regulatory proposals in a practical way with the aviation community or running a pilot program to ensure implementation plans are optimal.

I have highlighted some of the more obvious 'bollocks' statements, now, can you find the rest?

Well done, you have correctly identified nearly every part of the deceptive example, but remember, that was an easy one to get you started.  Before we move onto lesson two it is necessary that you gain an idea of 'Non Bollocks'.  This is essential as (a) facts may be gleaned to assist with bollocks decimation; and (b) 'Facts' can be used to confound the forces of stupidity and darkness; let us visit the library – HERE -.

Your reading list, for today – AAAA; AIPA and AMROBA; will give you a working knowledge across a wide spectrum, showing how  'professional' industry associations see the problems and their suggested remedies for dealing with the amateurish clap trap the sheltered workshops produce.  

Now here's your play lunch and some quotes to read on the bus to the library: of you go:-

And do not blame the A-Gs or the Office of Parliamentary Counsel, or alleged Government legislative policy, what we have got is exactly what CASA intended, with the full support of the previous Minister Albo.

What is entirely inexplicable is Minister Truss continuing with Albo's policies, even when they are 180 degrees removed from the policies pursued by Truss when he was last the Minister, including, but not limited to airspace and airports policy, and regulatory development policy as reflected in Policy Doc. 1/20

That rational risk management is not popular in CASA  is an understatement. If the "rules development" rules of the Productivity Commission/Office of Best Practice Regulation/various recommendations of the Australian  Law Reform Commission, Attorney-General's Department etc. were followed, a good proportion of CASA "rules" would never see the light of day.

The CASA attitude to risk management and cost/benefit is best seen the Airspace Act 2007.  The first "Minister's Airspace Policy Statement" is a model of how  airspace and airspace designation should  be• managed.  In contrast, the second such statement is shorn of all rational meaning, "risk management" goes missing, and "safe" becomes  the criteria, in words very similar to S.9(A) of the Civil Aviation Act 1988.

In short, the almost immovable "CASA Culture" rejects rational risk management and the cost/benefit justification  of regulation. Without amendment to the Act that will not change.

Without  amendments to the Act, a number of your recommendations cannot  be enshrined in law, and we cannot afford to continue  with vastly different  interpretations of the Act ( particularly when the "hard core" of CASA prefer the most narrow, extreme and prescriptive interpretations) with each change of CEO/DAS of CASA.

That rational risk management is not popular in CASA is an understatement. If the "rules development" rules of the Productivity Commission/Office of Best Practice Regulation/various recommendations of the Australian Law Reform Commission, Attorney-General's Department etc. were followed, a good proportion of CASA ''rules" would never see the light of day.

If you can manage those lessons for today, tomorrow we can move on to some of the more interesting, devious bollocks and how to counter them; remember, young Oliver, the longest journey starts with the first step forward.  

Toot toot.