[Peetwo]

The EAP CASA's GWEP (Great White Elephant Project)

Two days ago I received correspondence from CASA's Branch Manager of the Communications Branch, in regards to my 26 July FOI disclosure log enquiry, which said:

Enquiry

I note that the CASA FOI Disclosure log has recently been updated (from 6 March entry onwards) and reformatted.

Unfortunately the new format does not include links for the FOI publicly released documents and has omitted the previously released (prior to 26 February entry) PDF weblinks . In case this is an administrative oversight issue, would it be possible for all the new entries to have their released documents PDF web linked (hyperlinked)?

If this is for some reason not possible, could you at least release the documents for the 6 March 2024 entry: " Reports relevant to CASA's restricting of technical staff since 2010; 2021 CASA APS Employee Census Results; 2023 CASA APS Employee Census Results; Psycho-social safety climate survey conducted by University of South Australia in 2019 for CASA; The Internal Audit Report EAP - Enterprise Aviation Processing; and the most recent interim ICAO report on CASA. Exemption(s) applied: Full release..", Thank you in advance P2

This was the Branch Manager Amanda Palmer, of the Comms Branch reply (with attachment):

OFFICIAL 

Hi P2 

Please find attached disclosure records in relation to the 6 March 2024 FOI release.

Regards,

Amanda

Amanda Palmer (she/her)

Branch Manager

Communications Branch

CASA\Stakeholder Engagement Division

Attachment reference: https://auntypru.com/wp-content/uploads/...h-2024.pdf

FWD to page 30 of this document, under the title: 

Enterprise Aviation Processing
(EAP) System

Internal Audit Report
Date: 11 November 2022

FFWD to page 38, where it says:

3.1 What is the Enterprise Aviation Processing System?

The EAP system is a software system created for aviation regulators to manage their regulatory safety and security oversight responsibilities in accordance with the Standards and Recommended Practises issued by the International Civil Aviation Organization (ICAO) in accordance with the Chicago Convention. EAP is a modular, configurable and scalable system that can provide a wide range of functionality, including the management of aviation related licencing, aircraft certification and registration, accident and incident management, and other functions. At the time of this audit, over 30 countries around the world use EAP to manage their aviation regulation requirements, including New Zealand, Thailand, Austria, Switzerland, France and Australia. At the time of this audit, EAP comprised over 40 separate, fully integrated modules covering aviation regulators’ remits, which can be deployed in total, or in part, to meet an individual regulator’s needs. EAP is designed to manage tasks associated with accepting applications, making assessments, issuing approvals, together with subsequent continuing oversight (surveillance).

 
Hmm...(the parts in bold) how's that working out? Well according to this internal audit absolutely abysmally...  

4.1.2 Findings

4.1.2.1 Overall, CASA’s implementation of the EAP Project has not met timescales, costs, quality and scope targets as specified in the original 2011 project plan, and does not appear to be meeting performance targets for the EAP Five Year Strategy

As discussed in Sections 3.3 and 3.4, when CASA purchased EAP initially, it made a number of incorrect assumptions, including that EAP could be used to drive change from a distributed regulatory operating model to a centralised “national” operating model. These incorrect assumptions resulted in EAP implementation being significantly behind schedule, over budget, and not delivering the functionality specified in the 2011 EAP Implementation Project.

Specifically, between EAP’s purchase in 2011 and the forecast end of the EAP Five Year Strategy:

• timescales for EAP implementation have not been achieved. The 2011 EAP Implementation Project identified an implementation timeframe of two years (mid-2011 to mid-2013) to implement 19 EAP modules. Based on the EAP Five Year Strategy, the new implementation timeframe is mid-202535
• EAP costs are significantly higher than intended originally. The original budget was $9.1 million to implement 19 modules.36 As at 30 September 2022, based on CASA’s financial records, CASA had expended $39.5 million on implementing EAP. However, actual EAP implementation costs are likely significantly higher than this figure37
• the quality and functionality of the EAP system has not been delivered as intended originally. Significant required EAP functionality has not been delivered to date, with some elements not being delivered at all. Functionality elements not delivered to date include: surveillance; organisational approvals; medical; and workflow distribution.38 At the time of the audit, Internal Audit was advised a decision on whether to use the EAP Medical Module had not been made, despite CASA having purchased this module in 2011
• CASA’s EAP scope is not up-to-date. CASA has not maintained an up-to-date record of the extent to which it intends implementing the EAP modules (or parts of modules) it has purchased, and what functionality these modules will provide.39 Also, CASA does not have an up-to-date record of which EAP modules it has implemented to date. 40

Although CASA recognised the need to develop a national regulatory operating model41 it continues to manage EAP implementation as a series of annual projects rather than an ongoing change program. This is despite a significant amount of work remaining to consolidate distributed regulatory systems and processes into a national operating model. 42 As a result, CASA’s approach to assessing the effectiveness of EAP implementation:

• has not provided CASA’s Executive and Board with a meaningful analysis of EAP implementation performance (time, cost and quality) against the original 2011 EAP Implementation Project Plan
• does not provide CASA’s Executive and Board with meaningful analysis of CASA’s ongoing performance (time, cost and quality) against the EAP Five Year Strategy.

While formal analysis of CASA’s performance against the EAP Five Year Strategy has not been completed to date, based on interviews and document reviews, it is highly likely that EAP implementation is behind schedule, and will not be completed by 2025 (as specified in the EAP Five Year Strategy).

4.1.2.2 Although EAP benefits have been identified since 2018, these benefits are inconsistent between documents and are not mapped to outputs and outcomes as specified by better practice

Under better practice, benefits management refers to the management actions and reviews that are put in place to ensure that the project’s outputs and outcomes are achieved and that the project’s expected benefits are realised. Previous reviews of the management of EAP Projects (see Section 3.6, Table 3.1) identified that EAP benefits management required significant improvement.

To be managed effectively, project benefits must be mapped to project outputs and outcomes, as well as to the entity’s strategic objectives. Undertaking benefits mapping is essential to provide meaning and context to benefits statements, as mapping links each project’s deliverables against the overall benefits of EAP implementation. This is shown in Figure 4.1 below.

 
Over a decade past the original planned implementation timeline with a cost blowout of over 600% and what have we got to show for it? - zero, zip, zilch, nada!

Addendum: Where's the ICAO Audit report?

This was the original 6 March 2024 FOI request:

Reports relevant to CASA's restricting of technical staff since 2010; 2021 CASA APS Employee Census Results; 2023 CASA APS Employee Census Results; Psycho-social safety climate survey conducted by University of South Australia in 2019 for CASA; The Internal Audit Report EAP - Enterprise Aviation Processing; and the most recent interim ICAO report on CASA. Exemption(s) applied: Full release

It says that there was 'Exemptions' but with a 'Full release' of documents, so how come there is no copy of (in bold) 'the most recent interim ICAO report on CASA'??

This is especially intriguing given that the Dept of Infrastructure etc..etc stated back in February:

In February 2024 ICAO completed its final report following a focussed aviation safety audit held in September 2023. The report reaffirmed that Australia has an effective aviation safety oversight system. The report highlighted areas where Australia could more fully realise the benefits of closer alignment with ICAO’s standards and practices and these areas will be responded to through corrective action plans agreed with ICAO and updates to our State Safety Program (SSP) and National Aviation Safety Plan (NASP) this year. ICAO also undertook a State Safety Programme Implementation Assessment in September 2023. ICAO assessed Australia as having a mature aviation safety system overall that proactively identifies, manages and mitigates safety risks.

Given CASA is listed as a participant and signatory to the multi-agency MoU that apparently occasionally convenes with the 'Purpose' of...

2 PURPOSE

2.1 This MOU records arrangements between Australia’s agencies involved in civil and defence aviation
and their management of international and domestic issues.
2.2 This MOU also records arrangements for managing engagement with the International Civil Aviation
Organization (ICAO), including matters involving correspondence, representation, whole of
government policy positions, the sharing of information, and the filing of differences against ICAO
Standards and Recommended Practices (SARPs).
2.3 This MOU does not create, maintain or govern legally binding obligations between the agencies or
between the agencies and any third party. It will be implemented subject to and in accordance with
Australian laws, policies and international legal obligations.
2.4 While this MOU is not legally binding, agencies will endeavour to perform their respective functions in
a manner consistent with the values and principles it embraces.
2.5 This MOU should be read with the Tripartite MOU, which records arrangements between the Tripartite
member agencies (Infrastructure, CASA and Airservices).

...and with the responsibilities to,...

3 ICAO AND ANNEX RESPONSIBILITES

3.1 ICAO was established by the Convention on International Civil Aviation made in Chicago on
7 December 1944 (the Chicago Convention). The Convention established certain principles and
arrangements in order that international civil aviation may be developed in a safe and orderly manner
and that international air transport services may be established on the basis of equality of opportunity
and operated soundly and economically.
3.2 On 1 March 1947 Australia ratified the Chicago Convention thereby becoming a member of ICAO.
The Chicago Convention is implemented domestically through a schedule to the Air Navigation Act
1920, which is administered by Infrastructure. While State aircraft are excluded from the Chicago
Convention under Article (3), the Defence Aviation Safety Program (DASP) strongly aligns with the
Chicago Convention and integrates with Australia’s State Safety Program (SSP) to drive
improvements in safety performance across civil and defence aviation sectors.
3.3 Australia maintains a Permanent Mission to ICAO in Montreal, comprising a Permanent
Representative to ICAO (and Representative on the ICAO Council), and an Air Navigation
Commissioner. Australia is a member of the ICAO Council, which is ICAO’s governing body. As a
member of the ICAO Council, Australia has the ability to influence the international civil aviation
agenda, ICAO’s forward program and standards, as well as the governance of ICAO and the
utilisation and allocation of its resources.
3.4 Australia also maintains a nominee to the Air Navigation Commission of ICAO, an independent
technical body, which reviews and considers safety and air navigation-related standards and
recommendations for adoption by the ICAO Council.
3.5 The Minister for Infrastructure, Transport, Regional Development and Local Government has primary
responsibility for Australia's obligations under the Chicago Convention.
3.6 Infrastructure is responsible for administering Australia’s arrangements under the Chicago
Convention. This includes the legal matters involved with the Chicago Convention, administration of
other treaties, and management of international affairs arising from ICAO. In addition to its lead
coordination role, Infrastructure is responsible for:
• Aviation policy, economic regulation of civil aviation (including airline and airport operations), aviation
statistics and the coordination of facilitation-related engagement with ICAO.
• Aviation environmental issues, including aircraft noise management and the coordination of Carbon
Offsetting Reduction Scheme for International Aviation (CORSIA).
• The coordination of issues related to the governance of ICAO.
3.7 CASA is an independent statutory authority established under the Civil Aviation Act 1988. CASA is
responsible for the safety regulation of civil air operations in Australian territory and Australian aircraft
operating overseas. It is also responsible for regulating the administration of Australia's airspace...

...it is IMO simply unbelievable that CASA have not been privy to a full copy of the ICAO 2023 Audit Report??

Hmm...so what is it that the nine members of the 'MOU OF AUSTRALIA'S AGENCIES INVOLVED IN CIVIL AND DEFENCE AVIATION' are hiding in not making public the 2023 ICAO audit report?? -

MTF...P2

[Peetwo]

KC's response to the CASA EAP GWEP

Via the AP emails:

CASA’s Snowy Project 

“EAP costs are significantly higher than the original budget. The original budget was $9.1 million. Based on expenditure as at 30 September 2022, a conservative estimate of actual EAP implementation costs is $39.5 million7

This budgeted amount significantly underestimates the total EAP implementation costs, as: the majority of business costs have not been included; staff overheads (other than those overheads relating to salary costs) have not been included; and the costs of interim systems implemented to provide EAP functionality while EAP is being configured have not been included.” 

This is typical CASA, buy something that does a job (European) and then try and make it do something else.

Won’t work with the fiefdoms within CASA.
 
Regards
 

MTF...P2

[Peetwo]

KC OBS and AMROBA August Newsletter - 

To all members, 

Recently I participated in an on-line meeting re dealing with the public service.

The first point raised at the meeting was “not my responsibility will transfer you” and the second point was finding who is responsible for what.

At the end of the session, my thoughts turned to maintenance training. 

CASA promulgated individual trade subject standards for maintenance personnel as well as a module for licensing personnel.

• CAO100.66 May 2007.  2011 CASR Part 66, (17 years/13 years)
  
• This is different to the past avionics and mechanical trade pathways plus licencing requirements,
  
• The regulatory standards created variable mechanical trade modules plus a licencing module for small aeroplanes, large aeroplanes and helicopters
  

         - This replaced wider mechanical trade training standards that were based on ICAO standards.
         - 3 separate mechanical trade pathways common level modules.
         - Clashes with the Australian standard trade training system.

ASQA is responsible for providing training to industry employers that meet licencing requirements.

• CASR Part 66, Appendix 1 provides all the subjects to be included.
  
• The Appendix is not separated into the individual pathways for each of the B1 licences.
  

MISA and its predecessors, MERS-ITAB and IBSA have had years to provide these NVET training courses.

• AMROBA has, this year, separated Appendix 1 into the 3 separate mechanical pathways for small aeroplanes, large aeroplanes and helicopters.
  

 
So why aren’t there clear training pathways? To support these licences as the NVET regulations state?

After 17 years or 13 years of government regulatory training standards being produced, the VET system has failed to produce applicable training courses. 

This is exactly what the session I participated in discussed – seems this issue is across more than aviation.

Each course should take no longer than 12 months to be developed (allocate applicable aeroskills competencies) and obtained all States and Federal approvals. 

Newsletter, August 2024 includes:

1. Aviation Jobs – why is there a shortage.

• Industry Skills Australia Aviation Sector produces pilot training courses
  
• Each course is clearly titled with job description
  

          - AVI50319 Diploma of Aviation (Commercial Pilot Licence - Helicopter)

• So why haven’t the course developers labelled maintenance courses in the same way?
  

          - MEA40718 Certificate IV in Aeroskills
          - MEA50219 Diploma of Aeroskills

When searching the education network for jobs and associated training in the VET system, having the job description would provide clarity and maybe attract new starters to the industry. It has been like this for decades and nobody seems to care or are willing to upgrade to current regulatory standards.

AMROBA submitted re-titling AQF qualifications a few years back but has never happened – whose responsibility?

2. AME Training Courses in Each State.

• Differences between each State how courses are presented.
  

3. Global Civil Aviation Market – Participation

• The single thing that prevents global participation in no intergovernmental body is responsible for obtaining BASA type agreements.
  
• Without BASAs, Australian manufactured aircraft/products will not be acceted by other countries/NAAs
  
• Basically, DFAT responsibility, CASA and Department supported.
  

4. ICAO Audit Result in AGA Sample

• Within our ICAO region, Australia is one of 15 nations above 75% Effective Implemented of SARPs in the AGA (aerodromes) sectors.
  
• It is interesting that we are in the middle of his field and the details are on the ICAO website.
  
• I couldn’t find the Operations, Airworthiness or Personnel Licencing results to the 2023/2024 audit.
  

When the Department makes the audit findings public, we will know where we need to work with the Department/CASA to lift our Efective Imlementation of the ICAO SARPs in accordance with Article 37 & 38 of the Convention.

Why there is a delay in making the results public is not clear. 

We have noticed that these 2 Articles have been included in 2024 draft State Safety Plan.

Good for the future 

The industry is mature and can handle whatever the results are. 

Ken Cannane

Executive Director

AMROBA

Phone: (02) 97592715

Mobile: 0408029329

www.amroba.org.au

Safety All Around.

The following is an extract from the just released GWEP MKII:

ICAO audited Australia’s aviation safety systems in 2023

In September 2023, ICAO conducted an audit of Australia’s State Safety Programme Implementation.162
ICAO assessed Australia as having a mature aviation safety system overall that proactively identifies,
manages and mitigates safety risks. The audit also identified some areas where Australia can enhance
its air safety arrangements, including by strengthening some regulations and processes for oversight of
the industry.

The Australian Government welcomes this assessment and will take up ICAO recommendations to
maintain Australia’s internationally respected high safety standards. The Australian Government will
continue to seek closer alignment with ICAO Standards and Recommended Practices.

Same Betsy obfuscation with still no sign of the ICAO audit report itself - WTF??

MTF...P2