Been a’ pondering, have I.
My firstborn has, as usual, skipped through the obvious steps and landed on a conclusion. Furry Muff for those who actually ‘get-it’ and there are plenty who do; but what of the rest of us – we plodders?
Well, loath as I be to but into the Sunday speakeasy; I thought some time would be well spent by looking at ‘essentials’ and they way the Part 135 eliminates those things which are of value and replaces them with ‘desk-top’ audit ease and even easier conviction. We are discussing serious criminal penalties here; without appeal, under strict liability. The devil is in the detail and the translation, only by qualified ‘legal; opinion.
But why don’t we put that aside – just for a nonce and look at ‘practical’ safety enhancement? That is, when all said and done, what CASA are shooting for (despite rumours to the contrary). They believe (firmly) that increased ‘safety-management’ and a lot more office staff will make the commercial, non airline sector ‘safer’. Whatever that may mean.
The CASR Part 135 places a tremendous financial burden on the non airline operators. A sector of industry which has, traditionally, always had a battle with balancing the books. The additional impost of even more compliance cost will send many to the wall. For no – zero – safety gain. The 135 logic is flawed, deeply and cataclysmically.
Funds which could be made available for a ‘better’ rather than bare bones overhaul of an engine are now to be used for the care and feeding of some esoteric ‘safety’ notion person CASA believes will ‘improve’ the ever more nebulous demand for 'safety'. Look deeply and closely into commercial operations, the solutions are crystal clear. The ‘cash’ surplus is being eaten alive by the ‘compliance daemon. Charter operators spend more time, money and effort ensuring ‘compliance’ than they do almost anything else – and go to sleep at night worrying about things which have sweet duck all to do with ‘safe’ operations the next day.
Why does CASA not take it’s big boot of the ‘strict liability’ pedal and ensure that ‘surplus’ funds are directed into the ‘luxury items’?
About now, there is a collective growl from the IOS meeting. ‘Wait” say’s I, “all will explained”. And, verbatim I do quote it:-
How about being able to afford the luxury of sending the Chief Pilot or even a training pilot along on a charter – call it LOFT, call it a ride along, call it a route check – call it whatever floats your boat. A new start, new to the aircraft, new to the company, new to the territory, new to the ‘job’ – needs every single ounce of ‘non punitive’ additional training the company can provide. This costs real money; money now being spent chasing the dragon of ‘compliance’. Senior pilots stuck in the bloody office – ensuring paper compliance, redrafting operations manual – while young ‘Wannabe’ is out there, on his own, with nary a clue of how to ‘get a job done’ - properly (compliantly).
Affordable luxury – the aging, venerable PA 31 is up for overhaul. Three lists - ‘nice to have list’ a ‘must do list’ and a bloody long ‘wish-list’. All of this cost money, which is in short supply because it is feeding the compliance daemon.
Affordable luxury – new GPS, radio or even instruments - all cost money.
The simple fact is that there is only so much Do-Ray-Me to go around after funding the existing, horrendous ‘compliance’ costs. This precludes any training above the absolute minimum required for 'compliance'; or, spare time for ‘senior pilot’ supervision above and beyond the 'compliance' minimum; or, upgrade and repair/rectification/re-fit is gobbled up by the ever demanding ‘compliance’ daemon leads only to one place – shut down or go tit’s up. But therein, lies real safety. Up to date aircraft operated by carefully nurtured pilot - who know what they are about; courtesy of their employer.
CASA ain’t enhancing ‘real’ safety – they are seriously ‘anal retentive’ in ensuring that ‘safety’ is firmly in the hands of the legal profession, safe conviction and that the reality of ‘operational safety’ is removed from the ambit of the operator. Yes, granted, there are some who will take very penny and not re-invest it their own operation – but they are few and far between.
What say you IOS? A new GPS or another ‘clerk’ in the office – taking care of administrative safety or another experienced ‘chap’ (or Chapess) taking care of ‘real’ airborne safety?
Where would you spend your safety dollars – operationally; or, on ‘compliance’? Unanimous vote here.
Yes; I’ll shut up now; yes I need a refill and yes – I will walk home with ‘the lad’; it will be my pleasure.
Now, bugger off and let an old man have a quiet Ale (or two?)
My firstborn has, as usual, skipped through the obvious steps and landed on a conclusion. Furry Muff for those who actually ‘get-it’ and there are plenty who do; but what of the rest of us – we plodders?
Well, loath as I be to but into the Sunday speakeasy; I thought some time would be well spent by looking at ‘essentials’ and they way the Part 135 eliminates those things which are of value and replaces them with ‘desk-top’ audit ease and even easier conviction. We are discussing serious criminal penalties here; without appeal, under strict liability. The devil is in the detail and the translation, only by qualified ‘legal; opinion.
But why don’t we put that aside – just for a nonce and look at ‘practical’ safety enhancement? That is, when all said and done, what CASA are shooting for (despite rumours to the contrary). They believe (firmly) that increased ‘safety-management’ and a lot more office staff will make the commercial, non airline sector ‘safer’. Whatever that may mean.
The CASR Part 135 places a tremendous financial burden on the non airline operators. A sector of industry which has, traditionally, always had a battle with balancing the books. The additional impost of even more compliance cost will send many to the wall. For no – zero – safety gain. The 135 logic is flawed, deeply and cataclysmically.
Funds which could be made available for a ‘better’ rather than bare bones overhaul of an engine are now to be used for the care and feeding of some esoteric ‘safety’ notion person CASA believes will ‘improve’ the ever more nebulous demand for 'safety'. Look deeply and closely into commercial operations, the solutions are crystal clear. The ‘cash’ surplus is being eaten alive by the ‘compliance daemon. Charter operators spend more time, money and effort ensuring ‘compliance’ than they do almost anything else – and go to sleep at night worrying about things which have sweet duck all to do with ‘safe’ operations the next day.
Why does CASA not take it’s big boot of the ‘strict liability’ pedal and ensure that ‘surplus’ funds are directed into the ‘luxury items’?
About now, there is a collective growl from the IOS meeting. ‘Wait” say’s I, “all will explained”. And, verbatim I do quote it:-
How about being able to afford the luxury of sending the Chief Pilot or even a training pilot along on a charter – call it LOFT, call it a ride along, call it a route check – call it whatever floats your boat. A new start, new to the aircraft, new to the company, new to the territory, new to the ‘job’ – needs every single ounce of ‘non punitive’ additional training the company can provide. This costs real money; money now being spent chasing the dragon of ‘compliance’. Senior pilots stuck in the bloody office – ensuring paper compliance, redrafting operations manual – while young ‘Wannabe’ is out there, on his own, with nary a clue of how to ‘get a job done’ - properly (compliantly).
Affordable luxury – the aging, venerable PA 31 is up for overhaul. Three lists - ‘nice to have list’ a ‘must do list’ and a bloody long ‘wish-list’. All of this cost money, which is in short supply because it is feeding the compliance daemon.
Affordable luxury – new GPS, radio or even instruments - all cost money.
The simple fact is that there is only so much Do-Ray-Me to go around after funding the existing, horrendous ‘compliance’ costs. This precludes any training above the absolute minimum required for 'compliance'; or, spare time for ‘senior pilot’ supervision above and beyond the 'compliance' minimum; or, upgrade and repair/rectification/re-fit is gobbled up by the ever demanding ‘compliance’ daemon leads only to one place – shut down or go tit’s up. But therein, lies real safety. Up to date aircraft operated by carefully nurtured pilot - who know what they are about; courtesy of their employer.
CASA ain’t enhancing ‘real’ safety – they are seriously ‘anal retentive’ in ensuring that ‘safety’ is firmly in the hands of the legal profession, safe conviction and that the reality of ‘operational safety’ is removed from the ambit of the operator. Yes, granted, there are some who will take very penny and not re-invest it their own operation – but they are few and far between.
What say you IOS? A new GPS or another ‘clerk’ in the office – taking care of administrative safety or another experienced ‘chap’ (or Chapess) taking care of ‘real’ airborne safety?
Where would you spend your safety dollars – operationally; or, on ‘compliance’? Unanimous vote here.
Yes; I’ll shut up now; yes I need a refill and yes – I will walk home with ‘the lad’; it will be my pleasure.
Now, bugger off and let an old man have a quiet Ale (or two?)