[Kharon]

20/20 Hindsight.

> Or; an even money bet. One could even term it as a 30% less than a 50/50 even chance of getting something done.
 
“The mills of the gods grind slow” is an old saw. The point it struggles to make is that slow but certain divine retribution (from Wiki) is on the way. Well the 2020 Senate inquiry is certainly ‘slow’ – 24 months of grinding the grist in their mills. The ‘divine’ part is yet to be seen and ‘retribution’ is most certainly a vision splendid, far beyond the horizon.
 
Even so: the submissions have begun to trickle in – you can find them – HERE.
 
Aunt Pru will do her best to keep track of the whole thing on this thread; from soup to nuts. We have not seen a schedule or notice of pubic sessions; so patience is required.
 
There is little patience within the BRB /IOS – the question most asked is why don’t we save all the bother and simply enforce the 150 recommendations made between the Forsyth report and the Senate inquiry into Pel-Air. A close second is why not repeal 61/141 and 142 and simply adopt the FAA system. Both valid questions to be asked and fully answered.
 
There are two submissions logged at present – both worth the few moments it takes to read them.
 
A lot MTF I reckon.
 
Toot – toot.

[Peetwo]

20/20 Hindsight.

> Or; an even money bet. One could even term it as a 30% less than a 50/50 even chance of getting something done.
 
“The mills of the gods grind slow” is an old saw. The point it struggles to make is that slow but certain divine retribution (from Wiki) is on the way. Well the 2020 Senate inquiry is certainly ‘slow’ – 24 months of grinding the grist in their mills. The ‘divine’ part is yet to be seen and ‘retribution’ is most certainly a vision splendid, far beyond the horizon.
 
Even so: the submissions have begun to trickle in – you can find them – HERE.

---

1 Mr John HOORE (PDF 185 KB) 

CASA’s Role in General Aviation:

CASA is responsible for aviation safety in Australia - part of which involves administering the General
Aviation industry. It does this by developing regulations, enforcing these regulations and providing
administrative services.

Under the existing legislative structure, CASA
• Develops the Civil Aviation Regulations
• Administers the Regulations
• Investigates those believed to be in breach of the Regulations
• Determines the guilt or otherwise of those involved
• Imposes sanctions on those persons or organisation CASA deems to be guilty

In a democratic society, it is quite unreasonable for one organisation to have such extensive powers – CASA is, effectively the “legislator, the judge, the jury and the executioner.”

This situation does not exist in other industries. For example, the organisations that develop the set the standards for driving a car or truck issue licences, but they do not have the responsibility of policing the rules, determining guilt or issuing penalties...

..RECOMMENDATION 1 The roles and responsibilities presently assigned to CASA should be reassigned to separate organisations to ensure fairness for all participants.

RECOMMENDATION 2 The responsibilities presently assigned to CASA should be reallocated to other organisations so that the decisions on what services must be purchased by participants in the GA industry are not made by the same organisation which profits from the implementation of those decisions.

RECOMMENDATION 3 CASA should be directed not to expend resources developing systems and procedures which are rightly the responsibility of the individual training providers.

RECOMMENDATION 4 CASA should not expend resources developing draft Operations Manuals and should not take on the responsibility of and impose a charge for approving an Organisation’s Operations Manual...

..Conclusion:

I believe that CASA staff are highly skilled, and the individual members have a great deal to offer the General Aviation industry. The problem is that the organisation has been structured in such a way that it must be very difficult for it to clearly understand its role in the General Aviation industry and resolve the often-competing imperatives of promoting safety, generating income and assuming responsibility for certain functions which are clearly the responsibility of the organisations providing General Aviation services.

There is something seriously wrong when, in Australia, we have a climate that is so conducive for training pilots, but yet we are forced to look overseas to recruit pilots and instructors to meet a shortfall in our ability to train men and women to meet the demands of the aviation industry.

2 Mr Sandy Reith (PDF 103 KB) 

Dear Senators,

The last thing we need is yet another inquiry. You have the Forsyth Report from the (time consuming and
expensive) Aviation Safety Regulation Review, the ASRR. You also have the BITRE report on GA. You
have the CASA figures of current medical approvals and if you count out overseas students you will see a
big decline.

In the ASRR you will find hundreds of submissions which go exactly to the problems and decline of GA in
Australia. In the PDF attached you will see part of the problem, over regulation causing huge cost increases which is why we are now so uncompetitive, why we have to import our airline pilots. You might understand that GA activity has declined when our population has almost doubled.

Why we have lost thousands of jobs, businesses and services in GA right across Australia. In the USA an
instructor can go out and teach flying. They are not graded. Not so here, you will have to be graded, vetted and spend many thousands ($50,000? more?) and wait uncertainly over months or years for a flying school permit. Totally unnecessary.

The attached table was produced by Adrianne Fleming, Head of Operations at Tristar Aviation, Moorabbin
Airport regarding the latest rules versus the previous regime.

Tip of iceberg.

What is sorely needed is reform action. Not another inquiry. You could start by requiring CASA to
immediately allow independent instructors as per the USA. Thirty one years ago CASA (it’s predecessor by
another name change) was set by the Minister to rewrite the rules. It still hasn’t finished because the
independent corporate body model of governance cannot work. It is incapable. There must be a transparent
line of Parliamentary oversight and accountability. We are entitled to expect governments to govern, not
hand over virtually unlimited power to unelected bureaucrats.

If you suspect I’m exaggerating, look at the Glen Buckley case, an excellent example of the CASA modus
operandi, how to crush a GA business.

There is a great opportunity to revitalise this ailing industry, there’s just enough left of the GA industry to build upon, please don't do a Nero.

Regards,

Alexander C. (Sandy) Reith

 

---

Aunt Pru will do her best to keep track of the whole thing on this thread; from soup to nuts. We have not seen a schedule or notice of pubic sessions; so patience is required.
 
There is little patience within the BRB /IOS – the question most asked is why don’t we save all the bother and simply enforce the 150 recommendations made between the Forsyth report and the Senate inquiry into Pel-Air. A close second is why not repeal 61/141 and 142 and simply adopt the FAA system. Both valid questions to be asked and fully answered.
 
There are two submissions logged at present – both worth the few moments it takes to read them.
 
A lot MTF I reckon.
 
Toot – toot.

Don't forget to monitor the Additional Documents page - 

MTF...P2

ps Supplementary submission from Sandy in the form of an open email to his local member Dan Tehan...  

Dear Dan,

Regarding the  Aviation Security Identification Card (ASIC). 

Cost to pilots.     $283  (approx)  EVERY Two Years. 

I’ve held a CASA (prev. DCA) flying licence since 1966. Commercial Licence since ‘68. I’ve held Chief Flying Instructor approval and licence testing approvals. I’ve been approved Chief Pilot for Regular Public Transport flying services and still my Government treats me like a potential criminal terrorist and charges me $283 every two years to prove who I am and to look at whether I have a criminal activity record during the past two years. 

Three questions please:- 

1/.
      I request a ten year extension, at no cost, to my existing ASIC by virtue of the following facts. 

     a. Being retired from professional flying the cost is excessive, 

     b. My history as above and being known to you personally,

     c. I am 78 years of age and pose no risk to security at any airport (during my professional flying career I flew into every major airport in Australia without a security incident)

2/.
      Will the Government consider general relief from the ASIC imposition by way of extending the period of validity to ten years? 

Adding years of validity by formula could be an alternative with benefits of longer periods of validity to provide incentive to upgrade from, say, Private Licence to Commercial Pilot Licence. 

3/.
      Can you please provide evidence of the efficacy of the ASIC program? 
It was introduced after 9/11 and therefore history should show if its been effective or necessary. 
The Government owes this explanation to the General Aviation (GA) community and industry because the ASIC is very expensive and a disincentive to flying activity. It is considered valueless by virtually the whole of the GA community. 

The GA industry has been debilitated by extreme over regulation through CASA and the Department of Infrastructure, the latter controlling ASICs. 

A positive step towards halting the GA decline, loss of jobs and services, would be very welcome. 

Please note, no similar security identification requirement is made of GA personnel in the USA, home of 9/11. 

Kind regards,

Sandy

 

[Peetwo]

Friday Arvo Fax.

There are some equally ‘silly’ reports on the RA Oz reporting card, but the one which jumps off the pages is this one:- HERE -. I asked P7 to give it a gentle ( five minute) once over – just to make sure that once the laughter stopped, there were indeed not only several very serious breaches of basic common sense ‘flight safety’ and a certain disregard for the rules which govern both. The whole thing was fraught with peril from before even the engine was started. The manner in which the final approach to landing was conducted is not only reckless, but a danger to any other aircraft operating within the aerodrome precincts and the very airport infrastructure.

There are many parallels to be drawn between this episode and the Angel Flight fatal at Mt. Gambier. The most obvious being deliberately persisting into non VFR conditions, then continuing an approach in less than prescribed minimum visibility conditions. One led to a fatal accident, the other just got lucky.

CASA brought the boom down on AF after Mt. Gambier and yet the RA Oz crew have been allowed to present a ‘signed confession’ of dangerous operational practice and neither St. Commode nor his henchmen have raised an eyebrow, ATSB have simply filed the thing in the ignore bin.

The report provided speaks of some piss poor training – across the spectrum. Glen Buckley gets a severe hammering while the idiot posing as minister sings the praises of SOAR and their wonderful CASA sanctioned training systems.

St. Commode said this:

If; as he claims, all the gods bestowed the right to be responsible for “keeping Australians safe” does this refer to only a select group or to all? Seems to me it is time CASA accepted that responsibility and took a very close look at the incident cited in relation to rules being broken, poor airmanship through training and the possibility of a mid air; or, collision with an aircraft on the duty runway or even a CFIT. Alternatively, have CASA questioned RA Oz in relation to this matter and shown them some of their famous ‘tuff-luv’?  Told ‘em to straighten it out – or else. Did ATSB run some statistics? 31 'incidents' reported by RA Oz since Dec 2019 (6 weeks worth). Time someone paid attention I’d say…..

Nah to all of the above. Why no?. Why has the patron Saint of aviation safety not swooped in, cleaned up the mess, drafted some new onerous, restrictive rules to make RA Oz a compliant citizen of the land where St. Commode rules as the supreme doyen of aviation safety? Because it’s not his responsibility is it. Course its not, that has been ‘delegated’.

It’s not only a farce, an insult and a cop out, it betrays the very standards CASA have set but fail to enforce. Stall and spin training is now being diluted because many of the ‘cost effective’ - ‘bar-code’ aircraft ain’t tested and not certified as fit for task. What a brilliant start to a professional career that makes.

Sooner or later, the RA Oz system needs to be discussed. In principal it is a fine idea for
‘Recreational pilots’.  Personally, I have no quarrel with it, in it’s rightful place. Seems to me to be a really good thing for many folk; those who just love to fly, recreationally potter about, tour the country side: those on the land who use an aircraft in much the same way as a ute. It is a blessing for those who can safely drive a vehicle but just fall short on CASA medical standards. The benefits are many, the ‘risks’ when sensibly addressed acceptable and the restrictions placed not too draconian at all – considering.

But – (there’s always a but) as a pathway to a Commercial pilot licence and higher? In theory there is a cost saving. In reality the savings are marginal, when you do the numbers – for real. Then, there is the ‘quality’ question. I know many of the RA instructors hold a CASA IR; but many do not. No doubt these are well intentioned and properly mentored by the CASA approved senior crew; but I wonder; if there is a ‘gap’?

It is a truism, that one may teach Granny to ‘fly’ a simple aircraft in a very short period of time – up, down, left, right - try not to hit anything. Does this create a sound basis for progression to the jet command most of those (in debt) ‘training’ aspire to? It is a fair question for open, friendly discussion. BRB opinion to follow…I raise the issue because (IMO) the ‘basic’ training a pilot receives is very, very important. Essentially, that period is of very short duration – the time it takes between first lesson and first solo is the only time a pilot is actually ‘taught’ to ‘fly’ an airframe. After that it becomes a matter of further education, the basics the platform on which advanced training, ‘experience’ and operational knowledge is built. If the foundations are flawed, sooner or later the cracks will begin to appear

With the crew involved in the incident cited (above); the cracks seem o have appeared at a very early stage. Is this a good enough platform from which to build an airline career? The minister seems to think so – but then…………..

Anyway, I ramble. The whole thing is going to a full house (IOS and BRB) - - session (no darts). The agenda is far reaching, beginning from the blatant CASA misrepresentation of a 1999 ministerial directive to the current day legislative mess. Should be interesting –

Toot – toot.

Oops! Bristell plastic fantastics back to bite - 

Via the CASA:

---

---

Hmm...I wonder where the Hooded Canary's ATCB back up to that is? - Certainly not HERE as yet??   

Soar - Going...going...going??

Via the Oz:

Soar Aviation still training pilots during review

ROBYN IRONSIDE
Follow @ironsider




The Civil Aviation Safety Authority has issued a warning for Bristell light sport aircraft due to their inability to recover from spins. Picture: ATSB

A decision on Soar Aviation’s future as a registered training organisation is expected within two weeks.

The flight training school had its registration cancelled in mid-December following an audit by the Australian Skills Quality Authority, which is responsible for Vocational Education and Training courses and VET training providers. The audit found Soar was not compliant with the standards for RTOs and had not supported the needs of individual students or met the requirements of the aviation training package.

At the same time, training partner Box Hill Institute was informed its approval to offer Commercial Pilot Licence courses was being revoked.

Both Box Hill and Soar sought reviews of ASQA’s decisions, which meant they could continue to recruit and train students.

An ASQA spokesman confirmed that while the review progressed, Soar could continue to “operate without restriction”.

“Should the cancellation decision be affirmed by the internal review, it would take effect 35 days after Gobel Aviation (trading as Soar) is notified of the decision,” the spokesman said. “In that instance, the provider could also seek an external review of the decision by the Administrative Appeals Tribunal.”

Similarly, the decision to amend Box Hill Institute’s scope of registration would not take effect while the review was ongoing.

Latest statistics from the Department of Employment show 193 students were enrolled in the CPL course at Box Hill in the second half of 2019, for whom $4.3m worth of loans were paid. In that period, no one graduated despite the data suggesting the course had a 93.6 per cent completion rate.

In a further setback, the Civil Aviation Safety Authority this week issued an urgent safety notice in relation to Bristell light sport aircraft.

According to CASA’s aircraft register, Soar owns 12 of the single engine, two-seat aeroplanes.

The CASA notice warned pilots to exercise extreme caution when conducting any manoeuvre in the Bristells that may lead to an intentional or unintentional stall.

“Bristell NG4 and NG5 operated in flying training should not be used for stall training,” said the notice. “Available information shows the aircraft may not comply with relevant international standards relating to the ability to recover from a spin.” The lack of compliance was due to the fact some countries allow light sport aircraft manufacturers to make a self-­declaration that their aircraft met accepted standards.

“This system has been put in place to lower compliance costs, reduce the time to bring new aircraft to market and allow new technology to be introduced more easily,” said CASA’s statement.

Two investigations are under way into crashes involving Soar-operated Bristell aircraft, one of which was observed to enter a spin from which it could not recover.

A spokeswoman for Soar Aviation confirmed the training school was continuing to fly students “who are reaching their goals of achieving licences”.

---

Comments:

Jock
1 HOUR AGO
I would suggest that this article is well due. Caveat Emptor

David
3 HOURS AGO
Fasten your seat belts.

Turbulence ahead.

If it is not already the Soar saga definitely needs to be on the good Senators radar...

MTF....P2 

[Peetwo]

Two GOLD STAR  choccy frog submissions -   

4 Mr Jonathan Kelly (PDF 60 KB) 

Current Situation:

The result of this 27 year process to reform the old regulations into a clear, concise and
understandable set of regulations that avoid over regulation results in the following:
we know have the following sets of documents setting out the regulations we must abide by:

- the CASRs (regulations)
- the CAAPs
- the Manual of Standards (MOS)
- the remaining CARs (containing regulations not yet transferred to CASR)
- the remaining CAOs (containing regulations still not transferred to CASR or CAAP or MOS)
(see https://www.casa.gov.au/rules-and-regula...rent-rules)

The original 2 thick folders (CAR/CAO) have multiplied to be a whole shelf of folders. The CASR
alone now consist of 5 volumes and is approx 1800 pages.

The MOS consists (currently) of 20 parts covering required standards in many areas including
aircraft maintenance engineer licensing, airworthiness, flight operations, air traffic control training
etc. Part 61 alone of the MOS, (which covers flight crew licensing and training - areas I need to be
conversant with as an instructor) consists of 4 volumes and around 700 pages.

There also are currently hundreds of exemptions to the flight crew licensing regulations that we
may (or may not) need to be aware of. These exemptions are typically made as a result of
deficiencies discovered in the CASRs – eg oversights, inconsistencies or conflicting regulations,
unintended consequences of the regulations etc. (see https://www.casa.gov.au/rules-andregulations/
standard-page/flight-crew-licensing-legislative-instruments).

The 27 year process of reforming the regulations has been a huge burden on the industry and has
not achieved the intended aims. We do not have a regulatory framework that is clear, concise and
understandable, it does not avoid over regulation. Having such a complicated framework does not
enhance safety. I do not believe the situation meets the original (and very desirable) intentions of
reforming our regulations set out in the 1998 bill. The original regulations that we had prior to the
reform, appear in hindsight, to have been far easier to understand and comply with.

5 Mr Clinton McKenzie (PDF 4764 KB)  Attachment 1 (PDF 6794 KB) 

MTF...P2 

[Sandy Reith]

Clinton McKenzie has drawn together many of the deleterious results of a failed government policy. One can only speculate on the tremendous economic losses occasioned by this extraordinary aberration, a blot on our civic life, and upon Australia’s reputation. Clinton refers to his knowledge of the personal costs to individuals, none more sad, and devastating to families, than the instance of a suicide. Such costs are incalculable but certainly will deplete respect for law, and confidence in our democratic institutions.

There is one element of Clinton’s submission that calls for a critique, with great respect. That is in the closing statement regarding “exercise the privileges of that licence.”

It may be characterised as a privilege to be alive and enjoy the fruits of modern life and the technological advances that enable the dream like ability to fly like a bird. Its easy to argue that a privilege of such an extraordinary feat is bestowed by a greater power. At times there are glorious feelings that infuse the soul of pilots, we are ‘privileged’’ to experience the sensations and freedoms of flight.

Not least to navigate amongst the extraordinary features of our ever changing atmosphere.

All of these arguments do not allow that government bestows these privileges of flight. Quite the contrary, the efforts of private individuals are, and were, the progenitors of virtually all aerial activity.

Thus to fly is the right and prerogative of a free people who may decide generally accepted rules regarding aerial traffic outside the parameters of personal space, say up to 500ft across one’s property.

In the legal sense we should vehemently declare our right to fly is not a privilege granted by government.

Whilst maintaining our right to fly we allow some agreed ‘road rules’ and nothing more.

The notion, which is still well entrenched in government circles, that government doles out ‘privileges’ to it’s ‘subjects’ is an anachronistic feature derived from the medieval practice whereby the Monarch held all privileges and had the only power to dispense same.

[Peetwo]

First ANON submission - 

6 Name Withheld (PDF 292 KB) 

3. The immediate and long-term social and economic impacts of CASA decisions on small

businesses, agricultural operations and individuals across regional, rural and remote Australia

The following comment apply only to the impacts on individuals; there are no comments on the
impacts on small businesses and agricultural operations.

Legislative Instrument CASA 09/19 — Civil Aviation (Community Service Flights — Conditions on Flight
Crew Licences) Instrument 2019 has directly increased the maintenance costs, convenience and
satisfaction of volunteering to assist community service flight organisations.

In my own case, my aircraft maintenance costs of have increased by about 30 % annually. Because
my aircraft is used occasionally for community service flights and typically logs 120 – 150 hours per
year, it is now required to have a periodic inspection after 100 hours rather than 12 months. The 
aircraft did not suffer from any maintenance related safety defects during the man years it was
maintained under its previous, CASA approved, system of maintenance and there is no evidence that
the aircraft will be safer under the new inspection regime. 

The same Instrument imposes very inconvenient restrictions on a pilot’s ability to determine who can
travel as a passenger on a community service flight. For example, a pilot is now prohibited from
taking a spouse, another family member or a friend as a passenger unless that person is a member
of the flight crew. As with the maintenance regulation, CASA is unable to demonstrate any safety
benefit from this restriction and it is more likely that an additional passenger, even a non-pilot, will
enhance safety.

It is universally recognised that community services flights are vital for Australians living in regional,
rural and remote locations so anything that reduces the availability of these services without a
demonstrated safety benefit creates a significant disadvantage for those rural residents who rely on
the services.

What can be done – Legislative Instrument CASA 09/2019 should be withdrawn and CASA should be
directed to collaborate with organisations providing community service flights to develop mutually
acceptable voluntary codes of practice...

MTF...P2

[Peetwo]

2nd & 3rd ANON submission - 

From GA Inquiry webpage, via APH website: https://www.aph.gov.au/Parliamentary_Bus...ubmissions

---

7 Name Withheld (PDF 66 KB) 

Recommendations:
1. All flight/theory schools are required to become Registered Training Organisations under ASQA
and deliver the syllabus consistent the relevant qualification.
2. PPL and CPL theory be examined by the flight school not by CASA.
3. The lock out period for exams be abolished.

CASA have set rules that all examinations, for the CPL subjects, must be completed within two (2)
years. Additional rules exist that should an exam be failed more than three (3) times, a lockout period
of three (3) months applies. In 2016 I passed four (4) of the seven (7) exams and two (2) failures, one
which was locked out for the three (3) month period. In 2018 during email correspondence below, it
was confirmed that my passes would expire but failures would remain;

(see submission)


Lockout periods are contrary to the principles of education and a practice not undertaken by any other
vocational or tertiary institution. How is this fair and encourage or promote learning?

It is accepted that decisions made by CASA are “reviewable” through an internal appeals process and
then through the Administrative Appeals Process. This is costly and may takes a significant time. For
the internal review, CASA charge a fee. Where I intended to appeal several questions in an exam,
which were not relevant to helicopter operations, I was advised the appeal would cost $1,120.00 with
no expectations of success leaving the AAT the next step.

In its current form, one person in charge of the exams is the judge, the jury and the sentencing authority.
The theory syllabus required and exams at both Private and Commercial level for both fixed and rotary
wing are grossly out if date and there seems no interest by CASA to make any improvements when
they are fully aware of the issues. I have spoken to the CASA CEO on two (2) occasions where he
acknowledged ‘an issue’ with no discernible outcome.

How are the CASA examination officers required to demonstrate currency in the subjects they’re setting
examinations for? I would suggest they haven’t been in the general aviation world for many years if at
all.

The permitted materials for the examinations are also not conducive to learning. CASA restrict the
number of tags that can be placed into textbooks, dividers and the what type of materials are allowed.
For example, students may self-print the regulations but not the ERSA or AIP and must purchase from
Air Services.

The costs of the theory element are rising with no common-sense reasoning. It is not surprising why
people undertake their commercial licence in USA and return to just complete the two (2) conversion
exams and a flight test.

4. CASAs power to overrule to require additional non-essential medical tests be removed.
5. The CASA part 5 project be advanced with defined timeframes set and delivered.

8 Name Withheld (PDF 133 KB) 

SUBMISSION ON CASA’S IMPACT ON AUSTRALIA’S GENERAL AVIATION INDUSTRY

This submission relates to the implementation and application of the Civil Aviation Safety Regulations
(CASR) Part 61 and the direct impact on myself as a helicopter pilot and the observations of how it has
impacted my peers.

The implementation of CASR Part 61 has had a significant financial and detrimental career impact to
me. To understand the extent of the impact allow me provide a summary of my aviation experience
to date. I am a commercial helicopter pilot, completing my training in 2010, I hold a CPL(H) and frozen
ATPL(H) with approximately 1,500 hours total time. I hold the following ratings and endorsements:

• Instructor rating (Grade 2 TE, Design Feature TE)
• Low level rating (sling endorsement)
• NVFR(H) rating

I have completed 300+ hours low level, 40+ hours sling, 200+ hours instructing and 400 hours gas
turbine engine.

I completed my instructor rating post CASR Part 61 implementation, which means that for every
endorsement or rating that I wish to instruct I now need to complete a syllabus of training with an
appropriately endorsed instructor, followed by a flight test with a flight examiner who holds instructor
examiner privileges. Under the “old” Civil Aviation Regulation (CAR) Part 5 licencing, I would be
approved to instruct any rating or endorsement that I myself held, without the need for these
additional training costs. What does this mean for me? Quite simply, a substantially increased and
crippling financial burden.

To understand the magnitude of this new financial burden, below I have provided a summary and
breakdown of the costs that I am now faced with that were not previously applicable:

I recently undertook an upgrade of my instructor rating to progress from Grade 3 instructor to Grade
2 instructor. I was required to complete a 3 hour course of training followed by a flight test. At the
same time, I also completed a Design Feature (DF) training endorsement to allow me to teach Gas
Turbine Engines (GTE). Fortunately, I was able to use the DF test sequence to also count as my Grade
2 upgrade test. A summary of these incurred costs are detailed below:

(see submission)


I am now also enrolled to complete further training to allow me to conduct training for additional
ratings and endorsements as follows:

(see submission)

As you can see, I am now required to invest an additional $14,220 to be able to instruct sequences
that under the former CAR 5 licencing system I would have been authorised to instruct without any
additional financial strain.

When we undertake our instructor rating, a large component of course is learning how to teach,
regardless of the flight sequence. Therefore, I suggest that we are appropriately trained already to
teach any sequence that we ourselves hold a rating or endorsement for.

I accept that change is part of life and I encourage making the aviation industry safer. However, my
question is, where is the safety case to support the implementation of these new industry and
individual crippling training requirements? Where are the accident statistics that support the need for
additional training to be able to instruct for each individual rating or endorsement?

What I have found is that the public is often under the false perception that as pilots we are attractively
remunerated and can/should bear the additional training cost. I can assure you that it is not the case.

The award rate for a helicopter pilot at present is approximately $55,000 plus superannuation. There
is no provision for any additional salary loading for holding an instructor rating as a helicopter pilot.
This is an extremely low wage when you consider the investment of circa $100,000 I have made to get
to this level of training.

As a Grade 2 instructor, I am paid a full time equivalent salary of $62,500 plus superannuation. From
this before tax salary, I am now required to find an additional $14,220 after tax to be able to instruct
additional ratings and endorsements, while also paying the bills to support a family.

I have anecdotal evidence to suggest that helicopter pilots are less likely to pursue a career instructing
as the cost to be able to conduct fundamental training is beyond their means. This is likely to have
long term negative consequences on the future of the helicopter industry with a likely shortage of
appropriately qualified instructors to train the next generation of pilots.

Please note this submission is based on my experience and observations of the helicopter industry
only and I make no assertions or assumptions on the impacts to the fixed wind sector.

---

MTF...P2 

[Sandy Reith]

Part 61 has generated huge costs for fixed wing training, the table attached was tabulated by Adrienne Flemming of TriStar Aviation at Moorabbin. CASA have never shown that these impositions have improved training, safety or in any way contributed to the well being of General Aviation (GA). In fact the reverse is true, and the demise of hundreds of flying schools and charter operators all over Australia are testament to a disastrous policy of some thirty years in the making.
The independent government agency, CASA, knows no bounds in it’s relentless attack on our rights to fly. It is pursuing a policy to regulate every element of GA training and general operations in a counterproductive attempt to perfect the whole process in a manner that can only be described as impossible and inhuman.

[Peetwo]

Submission 9 ANON, 10 AMROBA:  

---

9 Name Withheld (PDF 368 KB) 

Problem: CASA fails to set clear and concise aviation safety standards.

I suspect that the Committee will be aware of CASA’s Aviation Regulation Reform Program.
This program has taken greater than 30 years and is still unfinished(!). The time and public
money that this program has consumed, frankly, disgusts me. I understand that regulatory
change may take substantial time and expenditure, and could possibly even accept that if
the desired outcomes are achieved (greater net safety benefits to general aviation and the
public). However, this ongoing regulatory reform has resulted in little or no aviation safety
benefits. The public not only expects more than this from public entities, but is entitled to
more. (As an example of a proactive safety initiative, some of the cost of this reform
program would have been better spent on subsidising the cost to owners of fitting ADS-B
equipment to all VFR aircraft, reducing risk of collision in uncontrolled airspace. I have
further simple suggestions that would increase general aviation safety in a tangible manner,
however it is not my role to introduce aviation safety standards).

Many regional flying schools (mine included) are encountering difficulties transitioning to
CASA’s Part 141 and 142 flight training requirements. The time, money and efforts required
to comply with the staggering amount of new regulations is significant (and does not result
in improved safety). Due to the difficulties of the transition, my flying school cannot
currently deliver any training; all 5 instructors have had to move on. A once flourishing
regional aviation business has unfortunately been disbanded.

Section 9(1)© of the Civil Aviation Act 1988 requires that CASA develop “appropriate, clear
and concise aviation safety standards”. They are anything but. The standards are so unclear,
so unconcise, so conflicting and so ambiguous in nature that it could be (easily) argued that
CASA has not delivered its function under S.9 of the Act. (I note that CASA is currently
drafting a plain English guide to some legislation - is this not an admission of not meeting its
function under S.9?).

Aside from being neither clear nor concise, the sheer number of pages of legislative
requirements is overwhelming (I have seen estimates of the entire size at 1600 pages, I
don’t believe any person can know the exact number). Aviation in Australia is not uniquely
different to that of other developed nations. For clarity, I suggest the Committee compares
the physical size of Australian general aviation legislation with that of New Zealand or the
United States of America. I believe at this late stage in this very considerable legislative
mess, it would still be more cost effective to simply discard all Australian aviation legislation
right now and adopt the much clearer New Zealand equivalent.

CASA’s approach to constructing legislation is at odds with Government mandates to reduce
red tape and administrative burden on regulated entities. I note also that the legislation
does not take a contemporary, risk-based approach to achieving its objectives, and instead
is reliant on outdated prescriptive prose.

Solution: Organisational change is required to account for this legislative disgrace; the
agency is clearly incompetent, from the top down. Sack the Chairman, Board and executive
staff (note: I am not suggesting a ‘restructure’ of the agency). Prior to the drafting of any
new legislation, CASA should consider implementing that already operating efficiently in
other jurisdictions (or consider adopting it in full).

Problem: CASA’s structure fails to promote fairness and transparency.

One could argue that CASA’s failure to set clear and concise aviation safety legislation would
not be such a concern, if the ramifications of legislative breaches were not so serious. Many
breaches of the legislation are offences of strict liability, potentially resulting in criminal
convictions. This penalty system does not encourage compliance, particularly regarding
raising potential compliance issues with aircraft owners, aircraft maintainers or the
regulator.

In my dealings with CASA staff I have often encountered conflicting legislative
interpretations (no surprise given the unclear standards). Well-intentioned pilots receiving
incorrect regulatory information are put in a most difficult position, and can potentially be
severely penalised for following this information. Persons who believe they have been
unfairly treated by CASA can approach the CASA Industry Complaints Commissioner (ICC).
CASA states that the ICC “does not sit within CASA’s organisational structure to ensure
independence and impartiality”; the ICC reports to the CASA Board - this arrangement is
akin to being the judge and the jury.

There is no need for the ICC. When the public feels aggrieved at government officials’
decisions, they have a right of review in the Administrative Appeals Tribunal (AAT). The AAT
currently requests that complainants firstly try to decide matters with the CASA ICC. In my
opinion, complainants are discouraged from approaching the ICC due to its relationship
within CASA. If CASA is serious about the impartial nature of the ICC, the ICC should be
required to publish all cases and decisions publically. I suspect these are not published as it
may show that the ICC is ineffective. It should be a simple matter to determine the
effectiveness of the ICC: for those complainants that proceed from the ICC to lodge their
grievance with the AAT, determine the rate of ICC decisions that are overturned by the AAT.

In my short time involved with general aviation I have heard of corrupt and unlawful
behaviour of CASA personnel. CASA previously had an internal Ethics and Conduct
Committee, who investigated fraud and illegal activity with the agency (Picture 1). This was
disbanded in 2016. To gain insight into the internal culture and behaviours of CASA, it may
be beneficial for the Committee to investigate the matters that the Ethics and Conduct
Committee were dealing with (along with the outcomes of any internal workplace surveys).

Solution: Remove strict liability offences from all but the most serious breaches of
legislation. Determine the effectiveness of the CASA Industry Complaints Commissioner – if
found to be effective, make publically available all complaints and decisions; if found to be
ineffective, abolish the function.

10 Aviation Maintenance Repair Overhaul Business Association Inc (AMROBA) (PDF 1277 KB) 

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MTF...P2 

[Peetwo]

Sen McDonald back to work Monday - 

Via FB:

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Senator Susan McDonald
2 hrs ·
*CONDITION UPDATE*

Thank you again to those who have been in touch, delivered a meal and looked after my children. Your support during this time has been so appreciated.

I can report that I am feeling well and my follow-up tests for coronavirus have come back negative.
As a result, I have received advice from Queensland Health that I am no longer required to self-isolate and will be back working on Monday.

While the team at the Townsville University Hospital are well prepared for any future Covid-19 cases, we can all do our bit for our city and across the region.

Over the next few weeks, it’s important we check in on our neighbours and loved ones - a phone call, a meal or an offer to help in some small way makes the world of difference.

Remember to buy local and support the businesses that support us here in the North.

There’s nothing stronger than the North Queensland spirit - we will get through this, like we did the floods, and again we’ll do it together.

For more information on COVID-19, please visit www.health.gov.au or call 1800 020 080.

---

Just goes to show you can't keep a good Senator down...

MTF...P2 

[Peetwo]

Submission 11 - Rotorheads  

Looks like the RRAT committee is back to work -

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11 Australian Helicopter Industry Association (AHIA) (PDF 57 KB)

The AUSTRALIAN HELICOPTER INDUSTRY ASSOCIATION (AHIA) SUBMISSION TO THE SENATE INQUIRY INTO GENERAL AVIATION and CASA

Preamble:

The AHIA has approximately 90 members and represents the interests of a large percentage of the commercial helicopter industry.

AHIA members are heavily involved in firefighting operations, emergency and rescue services, agriculture, aviation training, off shore transfer, tourism, charter, policing and security, infrastructure inspection, parks and wildlife, to name just a few.

Helicopter operations often fall into the category of essential services for many urban and regional communities.

The AHIA and the helicopter industry in general is reliant on efficient and timely services from CASA.

ISSUES:

The Civil Aviation Act 1988 provides the legal framework for the establishment of CASA.

The Civil Aviation Act 1988 requires CASA:
• to develop and promulgate appropriate, clear and concise aviation standards
• develop effective enforcement strategies to secure compliance with the standards

In developing and promulgating aviation safety standards CASA must:
• consider economic and cost impact on individuals, business and community standards
• take into account differing risks associated with different industry sectors

The Board of CASA is required to:
• Ensure that CASA performs its functions in a proper, efficient and effective manner

It is clear that not all the above criteria are being met:
• CASA has not been operating by the requirements of the Act.
• The current regulatory framework that underpins aviation safety has taken too long to finalise.
For example, CASA has been working on changes to Part 135 for well over 15 years and the maintenance regulations are still not finalised.
• Regulations are not sector based. CASA has undertaken sector risk profiles but lower risk operations are not reflected in regulatory simplification.
• Overly complex regulations without improving safety. The new Part 61 severely restricted helicopter operations. A rapid response by helicopter industry leaders ameliorated some of the difficulties.
However, after years of expensive work by CASA officers, such emergency and time consuming responses from industry leaders should not have been required.
• Regulations are difficult to interpret and apply. For example Part 61 is over 700 pages in length.
This is clearly ridiculous. Did CASA compare its work with similar Parts existing in other countries that have mature aviation industries eg, USA, Canada and New Zealand?
• Regulations are costly to implement for business and individuals. CASA is a
monopoly provider of regulatory services. Its hourly charges are arbitrary and some
officers adopt a take it or leave it approach. Many industry participants feel the hourly
rate approach leads to inflated costs due to CASA work quotes only advising
approximate total project times. The aviation industry becomes a price taker with
little recourse to usual market factors.

CASA functions are not applied/exercised uniformly across all regional offices.

• Individual officers can affect decision making through differing policy application,
standards and outcomes.
• There has not been strong oversight of Regional Offices or resident poor performing
CASA staff
• There appears to be insufficient will to take action against or re-educate staff who do
not adhere to the CASA Philosophy document
• CASA Flight Operations Inspectors (FOI) who are not suitably qualified or
experienced to oversee complex company flight operations. This is an ongoing
problem for the helicopter industry. There have been many examples where the FOI
is considerably less qualified than the aircrew being tested.
• Review practice of FOI undertaking aircraft Type ratings. This activity is expensive
and in some cases the FOI has resigned from CASA to take up an external flying
position. This could be an abuse of the process and costly to all involved.

Public consultation processes have not being fully utilised. For example, CASA sponsored
Sector Risk Assessment workshops have been conducted but there is little evidence that the
findings have been incorporated in legislation. This undermines industry confidence in CASA
in that industry participants give up their valuable time to provide detailed information that is
barely used.

CASA’s legal division has for many years been a major choke point in CASA’s operations.
The need for quality legal advice is understood but extended and convoluted legal argument
within CASA has caused unnecessary distress and cost for many industry participants. A
review of the performance of the legal division wold be timely.

While there have been some recent improvements in the services provided by the medical
division, there is still considerable scope for further progress. One clear example is that
advice to CASA from DAMEs or appropriately medical specialists should not be second
guessed by CASA staff.

SUMMARY

CASA must embrace the goal of being the best medium sized aviation regulator in the world,
with a real commitment to constant improvement.

The Australian helicopter industry is mature and only needs a light-handed regulatory
approach. A well designed Classification of Operations system would reduce the
requirement for complex and heavy handed regulatory oversight. The cost savings and
improved service efficiencies would be considerable.

The Australian helicopter industry has the second largest helicopter fleet in the world. CASA
would be well served to treat it as a safety partner rather than a sector to be controlled.

Given that the industry has far more operational experience than anyone in CASA this is not
an unreasonable request.

The AHIA and its members stand ready to assist practically in improving the regulator to
industry outcomes.

It should be not be forgotten that well over 70% of CASA’s income is derived directly from
the aviation industry. The regulated industry is in fact CASA’s largest stakeholder. This
should never be forgotten.

Paul Tyrrell

CEO
Australian Helicopter Industry Association

Same hymn sheet - 

MTF...P2 

[P7_TOM]

Nothing but praise and support for Paul Tyrrell's excellent submission. It not only, very neatly captures almost all of the 'surface' problems industry faces and rings with truth but manages to discreetly shine a small light into the 'darker' areas of the CASA methodology for excessive 'control': where little is needed.

Will this committee be able to piece together enough of the deeper problems to form a picture? Even more important – will they finally get the message and can they do anything about it all?

Not holding my breath – Nope, just going to do it all again and watch as good intentions, facts and plain old ordinary 'common – or garden sense – gets lost in the translation. I'm not quite over the Forsyth insult yet; last in a thirty year on going series of insults. The last committee provided 60 odd 'recommendations' which produced what?

No matter, well done AHIA, Bravo Mr Tyrrell. Gold star and Tim Tam award seconded.

[Peetwo]

#reformcasa

---

Via Phil Hurst on Twitter: https://twitter.com/PhilHurst62/status/1...8500544512

Tony Kern has been to Australia several times including to speak at AAAA’s Convention. What a great initiative it would be to have Tony and Convergent Performance leading the deep, essential reform of CASA.
@M_McCormackMP @SenMcDonald #reformcasa #ausav

ref: https://www.linkedin.com/pulse/cultural-...ublished=t

Cultural Threat Detection: Business Intelligence for the 21st Century

    Published on May 14, 2020

Tony Kern
Tony Kern
CEO at Convergent Performance, LLC
13 articles

> Winning the Culture Battle
>
> Organizations talk about culture quite a bit, and good organizations care deeply about it. But even the best organizations consistently struggle to fully understand it or even more importantly, harness and control it for their use.
>
> A short trip down the information highway courtesy of our friends (or overseers) at Google provides a taste of the current viewpoint on this topic. Type in “culture trumps…” and hit the search key. In the latest example, it took 0.06 seconds for 1,100,000 results to appear. A few of the highlights:
>
> Culture trumps strategy
>
> Culture trumps policy
>
> Culture trumps leadership
>
> Culture trumps training
>
> Culture trumps technology
>
> Culture trumps everything
>
> Seriously? Culture trumps everything. That almost sounds like a Chuck Norris joke. While we don’t believe that culture is the proverbial unstoppable force against which organizational leaders are the opposite of an immovable object, there is little doubt that whatever it is—it’s powerful.
>
> Whatever wars are being waged in your organization between your strategic objectives and your actual outcomes, your culture tips the scales for the winning side.
>
> A McKinsey survey of some 3,000 executives found that two out of three organizational change efforts fail—the majority due to cultural resistance. Recognizing this threat, some organizations seek to first move the culture into alignment with the planned organizational change strategy. These fare somewhat better, but still fail more than 50% of the time. This isn’t because something else trumped culture in these situations. Rather, it’s likely due to the organization being unable to successfully change the culture to align with their new objectives—so they quit trying.
>
> Organizational culture remains one of the most complex and studied issues in modern business and government. There are literally hundreds of studies, journal articles, and books on the subject. It is not our intent to analyze or even review this vast expanse in this short white paper, but one thing is clear. If organizations are able to shape and harness their culture, they will leap miles ahead of their competition to a position where goals that were once thought as BHAG’s—big hairy audacious goals—become achievable.
>
> Dr. Tony Kern and his colleagues at Convergent Performance—a small veteran owned company specializing in human reliability—have worked for over 30 years with private and public organizations, both large and small, to successfully shift and sustain cultural changes. Along the way, they have discovered some new ways to shape this force of nature.
> A Force of (Human) Nature: Wind and Water
>
> To get a full grasp of how culture works inside organizations, we first need to understand the key difference between two terms: organizational climate and organizational culture.
>
> Organizational climates are usually temporary (but if they exist for too long, they can become a part of the permanent culture). I like to use wind as a metaphor for climate. The speed and directions change frequently based on many factors like the mood of the boss, new personnel, or even a special demand from a customer. It’s possible, even likely, that you may have multiple climate wind shifts going on inside various parts of your organization at any point in time.
>
> Culture, on the other hand, runs much deeper and is far more powerful, more like a flowing river whose hydraulics pull everything it touches along with its currents. Viewed in this manner, you can clearly see why it is so vital to both understand its flow patterns as well as how you can influence it to change.
>
> Both climate and culture are forces of nature—human nature. A human nature that includes resistance to change and suspicion over the personal impact of any potential change. Organizational leaders who understand this and account for it are far more effective with nearly everything they seek to achieve.
>
> These wind and water currents blow even the most well intended business strategies and change initiatives off course, but unlike in the physical world where the directions and speeds are obvious, changes in the cultural speed or direction are nearly impossible to detect without the right set of tools and observation techniques. This is what our company specializes in, along with the proven techniques to shift the direction of the currents and harness the power they create. We have documented evidence of the effectiveness of this approach (see attachment) and would be delighted to discuss these with you at your convenience.
>
> Now let’s look at this phenomenon from a slightly different angle and turn to military science to draw some parallels.
> Inside Moves
>
> In his seminal essay Principles of War, Prussian military strategist Carl von Clausewitz speaks of two critical needs for victory in battle. The first is economy of effort, which is simply the “judicious exploitation of manpower, materiel and time in relation to the achievement of objectives.” In today’s economic climate, a lean approach is a part of most smart business strategies. Clausewitz’s second principle of relevance is the concentration of force at a decisive point, meaning the application of resources at the point and time of greatest leverage. Unlike his contemporary Jomini, who espoused an “if-then” prescriptive approach, Clausewitz was adamant about preparing front line leaders to operate within the friction and fog of war, a topic every time-stressed organizational leader can relate to. From his perspective, the fluidity of battle requires that the best decisions are made closest to the action by intelligent and situationally aware leaders on the front lines. The parallels for modern organizational culture are obvious. If you don’t know where or when the decisive points of your culture are, you cannot leverage them to your advantage.
>
> The establishment of cultural change and threat detection (CCTD) leverages both Clausewitizian principles. It represents economy of effort through better business intelligence, as well as concentration of force by allowing focus on areas of greatest leverage as identified from within the organization by those closest to the battle. More on this technique in a moment.
> From Here to Where?
>
> One of the most difficult questions that arise in any culture change initiative is from what to what?
>
> Typically answering the first half of this question requires consultants armed with culture surveys and other instruments to come in and tell you what you probably already have a good feel for. “From what?” is a tough question, but the current state of your organizational culture may be less relevant than you have been led to believe. Truth be told, most culture change efforts are driven by one or more bad events or missed opportunities in your organization’s recent past. Why spend time, energy, and money to study where you no longer want to be? Why expend resources to build data around a past or present you wish to leave behind?
>
> When resources are limited (when aren’t they?), you have a choice between studying your current situation or putting your time and energy into the change initiative. If you’ve already made the call for change and you’ve identified a desired end state, put your resources into the change effort. Employing Clausewitz’s economy of effort principle allows organizational leaders to bypass concerns about the past and present and regain a future orientation.
>
> How you start this journey is where you can make your first critical mistake.
> What’s the First Rule of Fight Club?
>
> Those who have seen the classic Brad Pitt movie from 1999 know the answer to this one is, “Don’t talk about Fight Club.” The same wisdom holds true for any culture change effort. Bobby Kennedy once said that “everyone is for progress, but progress requires change—and change has many enemies.” People naturally resist change. Culture change announcements often result in the old guard grabbing their pitchforks and torches with chants of “kill the outlanders.” So rather than packaging the effort as culture change, which probably mandates overcoming considerable resistance, consider undertaking the change initiative under the flag of continuous improvement or professional development. It’s a subtle but critical difference. So, what’s the first rule of culture change? Don’t talk about culture change.
>
> This branding shift from culture change to development/improvement is possible because, typically, continuous improvement and professional development are standard parts of most organizational structures and budgets already. Senior executives will often have these tasks as a part of their formal job descriptions and are more likely to support a less controversial approach.
>
> Now let’s go back to the concepts of wind and water, but for simplification we will just use wind to speak about the movements of both culture and climate.
> Cultural Winds
>
> Detecting your present culture directions and speeds are vital to any and all improvement efforts. Towards this end, lets describe a few indicators you should be aware of.
>
> Cultural Tailwinds. Culture is aligned with your strategy or change effort. The time is right.
>
> Cultural Headwinds. Culture is resisting your strategy or change effort. There is an immediate need to work the culture prior to any significant change initiatives or negative outcomes occur.
>
> Cultural Crosswinds. Cultural misalignment between levels or functional areas of your organization are inhibiting your strategy. Further investigation is needed on what is inhibiting smooth cross-functional collaboration.
>
> Cultural Wind Shear. Opposing cultures are active in your organization causing negative disruption and impacting performance.
>
> Cultural Microburst. There is a dangerous development within your culture that demands immediate attention.
> How it Works
>
> A combination of data-driven analysis has been developed to allow organizational leaders to identify and utilize cultural direction to their benefit.
> Three Primary Sources of Culture Data
>
> Three sources of data are used to identify changes in the organizational climate and culture. They are woven into an analytical tool that detects significant shifts.
>
>    Numbers – financial data, safety and quality statistics, HR data on engagement, missed work, sick days, retention. There is a need to rack, stack, track, and assign values to these datasets. What represents a significant shift in each?
>    Cultural Archetypes – specifically identified, tasked, and trained to look at cultural changes with granularity. Their observations and insights receive a special weighting factor, dependent upon several variables.
>    Entire workforce on a routine basis – single question responses tied to training or any other mandatory update or requirement. Best done utilizing a mobile app. No one argues with a sample size of 100%.
>
> Archetypes – Windows into the Day-to-Day Culture
>
> Ten separate archetypes common to most organizations and with special insights on culture have been identified. Not every organization will possess all ten, but most will be able to quickly put a face and name to each of the following.
>
>    Mom – caregiver for the organizational masses. Empath.
>    Maven – hub of communication, trusted with information by the line.
>    Skeptic – natural doubter who pays close attention to change initiatives.
>    Leader of the Resistance – potential cynic who tends to resist management actions.
>    Wise Owl – the sage who has been there, done that, and can analyze things through the long lens of organizational history.
>    Maverick – the likeable rule breaker who has the has the right intentions but takes shortcuts ahead of organizational changes and isn’t willing to do the work to get the official rules caught up to his or her way of doing things. Might be an organization’s best innovator, but colors outside the lines. Senses how far he/she can go without getting hammered by management. “Dances on the edge of acceptable.” By watching where they dance, you can sense the organizational tolerance level.
>    Truth Teller – the courageous conscience of the organization.
>    Newb – impressionable baby duckling who will follow cultural trends and indicate where the organizational culture is moving.
>    The “Fixer” or Organizational Troubleshooter – the go-to management person who gets the tough jobs of cleaning up problems. Sees a lot of stuff other execs do not see—and prefer not to see (or in some cases, to even know about).
>    Culture Pros – hold formal culture-related positions, might be in HR, Safety, Quality, etc. These people are consciously looking for cultural indicators as a part of their job description (we will likely have to provide training for this). Their inputs should be tagged and matched to the numerical data sets, i.e., “In your professional opinion, why are quality escapes going up in manufacturing?”
>
> The analysis techniques for combining these Archetype data into specific recommendations are proprietary and the core of our value proposition.
> Summary
>
> Developing a culture of strong and continuously improving professionalism is no longer a vague concept. It is a viable and achievable choice. In our highly-competitive global marketplace, it has never been more critical. The path to higher levels of performance is not an easy one, but it is a predictable, viable, and achievable alternative to the diseases of sloppiness, apathy, and cultural stalemate that has infected many of our organizations. It is available to anyone and everyone with a will to improve with little more than the application of the principles contained here.
>
> In the words of George Eliot, “it is never too late to be what you might have been.”
>
> If you are intrigued by this approach, we look forward to a deeper discussion at a time and place of your convenience.

MTF...P2 

[Peetwo]

Submission 12 - Phil Hurst and the AAAAs



Ref: https://auntypru.com/wp-content/uploads/...AAAA-1.pdf

1. Introduction

AAAA has made many relevant submissions over two decades on improving the
management of aviation policy in Australia – with a focus on general aviation and
aerial application in particular.

AAAA put forward positive suggestions for improvements based on improvements to
risk profiles and has developed and implemented programs that deliver superior
safety outcomes and which would benefit from recognition by the regulator.
Despite some minor improvements, however, little has changed in terms of negative
overall outcomes for general aviation.

While there have been some advances in CASA’s approach to the regulation of GA,
these advances are not systemic, not significant in the larger scheme of regulation,
not particularly impactful – and are only given up grudgingly as a last resort.
There are good people in CASA working towards a better aviation regulator.

However, they are regularly thwarted by an apparent indifference to good practice,
standard business operating systems and a more cooperative regulatory posture.

CASA continues to lack innovation, expertise and trust. It appears frequently unable
to work positively with industry and particularly GA for win-win scenarios which are
readily available. It struggles to implement better approaches to GA safety and
regulation.

Industry desperately wants an effective and efficient regulator that is open to better
ways of doing things, bases its regulatory approach on supporting and guiding
effective risk management, and levels its regulation, surveillance and education at
the different GA sectors in the best way.

However, the ongoing train-wreck of regulatory change that continues to impose a
heavy burden of red tape and cost on industry for no safety benefit lays bare the true
state of CASA, its culture and its leadership.

CASR Parts 61 (pilot licencing), 141 (training organisations), 66 (maintenance
licencing) and others have created overly complex regulatory overreach that has
decimated industry training and is now belatedly under review because of this
impact.

The CASR Part 138 Manual of Standards has now been forced out for consultation
during the COVID 19 pandemic – as if industry didn’t have enough challenges –
despite many on the Technical Working Group telling CASA it was not fit for purpose
because of overreach, complexity and length. Industry now has to respond to reject
another Part that will cause damage because CASA decided to ignore its own
consultation process. This is the same trajectory as CASR Parts 61,141 and 66.

As an initial submission to the RRAT inquiry, AAAA believes it is worthwhile
providing a summary of previous work, key issues and potential remedies.


2. Executive Summary

The core problem that has had a major negative impact on general aviation over
decades remains CASA.

CASA remains an organisation that seems incapable of positive change, that
continually engages in regulatory overreach and which generates thousands of
regulations that are overly complex, prescriptive, costly and not related to minimum
safety standards, efficiency or recognition of other risk managing regulations.
Despite occasional green shoots of rationality - often initiatives driven by industry -
these are all too frequently torched by the CASA attitude of ‘we know better’ –
despite all evidence to the contrary.

While there remains positive policy consistency from the Civil Aviation Act, the
Minister’s Statement of Expectations and the CASA Board, there is an irreconcilable
difference and tangibly different outcomes from that point on to the implementation of
aviation regulation in Australia.

It is clear that the ASRR has not had the positive effect intended on CASA.

CASA remains in desperate need of reform at many levels to change its trajectory
from being a negative, destructive, inefficient, inward-looking bureaucracy towards
being an effective, innovative aviation regulator that contributes to the nation.

Reference pages 3-9 for recommendations.

Well worth the 2 coffee read - 



MTF...P2 

#reformcasa

[Peetwo]

Submission 13 & 14  

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13 Mrs Maude Telfer (PDF 711 KB) 

14 Mr Reuben Bush (PDF 226 KB) 

"...Part 66 licencing also brought with it a host of other issues of which you are probably aware of
including, exorbitant fees from training organisations, lack of accessibility for people in regional
areas, and an inability to tailor a licencing outcome that is specific to an individual’s circumstances.
For the survival of the General Aviation Industry, I recommend that CAR31 licencing via CASA Basic’s
and SOE be kept in place for the foreseeable future and the recency requirements for a holder of a
Part 66 licence be extended or done away with. I believe the GA has a lot to offer private aviators,
that organisations like RAAus cannot offer; including trained, competent and experienced aircraft
maintenance personnel. If the regulations do not support GA, aviators with move over to a cheaper
form of aviation and safety will suffer..."

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MTF...P2 

#reformcasa

[Kharon]

18 Across: 'A moral obligation; perhaps'.

By law and the rest of the legal clap-trap attached,  ASA, ATSB and CASA may well thumb their collective noses at a Senate Committee report as they done so now for more years than I care to remember.  Its all well and good having 'inquiry' – the latest scheduled for a staggering two years. You can easily see the complete waste of time, money and energy involved - particularly in the dimming light of the ASRR. There's a farce and a classic example if you like. Senators roaring and shouting the odds, the minister demanding a report, the Canadians dragged into a mess; etc. CASA just said OK, shrugged their shoulders and toddled off to do exactly as pleased 'em best.

If we are to demand changes, the first item of business (IMO) is to bring the 'agencies' to heel, make 'em responsible and accountable – under law to the parliament. Until there is an enforceable 'Act' which obliges them to make the changes and address the edicts of a Senate Committee; or, explain why not – then we are simply pissing into the wind - again.

The RRAT committee had a taste of what they face with the Angel Flight shambles. The committee need look no further back than the Pel-Air scandal to see the contempt in which their 'recommendations' were treated and the insult to the good Rev. Forsyth report. Should the committee want to ask questions; perhaps they could start there. Review their own, the Canadian and Forsyth's recommendations and simply ask 'please explain'. Why have none of these been paid anything more than lip service?  The answer is simple enough - “Not obliged to M'lud”.

Dear Senators; please don't bugger about feeding another paper tiger. Change the controlling legislation, make the agencies responsible and; while you're at it; demand proof positive that all (thirty years worth) of inquiry recommendations have been fully implemented to meet the demands of an industry which pays to be ignored and treated with contempt. No where near good enough is it.

Hitch – Oz Flying – HERE. History has shown us that breath spent on demanding formal inquiries into aviation is largely wasted. If the energy and political patronage of the Aviation Safety Regulation Review (ASRR) has failed to bring about any substantial change in the fortunes of the general aviation community, it's not a long bow to suggest that no inquiry will ... and that includes a Royal Commission.

Dick Smith has recently thrown his weight behind pilots who are starting to get loud about an RC into aviation, using four tragic events as the supporting evidence for his call. But, Dick may be preaching to the exasperated; the battle-weary aviation community that has endured inquiry after inquiry to achieve nothing. Although there may be merit is his call to go once more unto the breach, you can't really blame anyone for wondering what would be the point.

Good points raised by both Hitch and Smith – but is the game worth the candle – as it stands, considering the three decade track record? Methinks not.

Toot – toot.

[Peetwo]

Sandy - Supplementary Submission.

Dear Senators,


Please accept this as a supplementary submission to your inquiry into the state of General Aviation (GA) because it is updated due to the CV problem and includes additional information. 

The attached PDF contains one of the 269 submissions to the Government’s Aviation Safety Regulation Review (ASRR) of 2013/2014, Chair, David Forsyth. 

The PDF author, David Grant, is a respected colleague and highly experienced professional pilot, he consents to forwarding his material to your Committee. 

I concur with his submission, adding that the situation for GA has become considerably worse in the interim, due, firstly, to the the extraordinary, unnecessary and costly impositions of the regulatory changes enforced since 2014, in particular Part 61 around licensing and Parts 141/142, flying schools. Virtually all of our aviation regulations have been inappropriately migrated into the criminal code with strict liability for ease of prosecution which is counterproductive to safety reporting. This also has induced a very unhealthy industry relationship with CASA which practically has the powers of police, prosecutor, judge and jury. 

Secondly the restrictions around COVID 19 have caused more losses of flying schools and tourist related flying businesses such as scenic flights, charter and sky diving. 

In conclusion, the GA community will obviously welcome any interest by Parliament but many government inquiries have not interrupted the march of bureaucratic regulatory overkill. 

Therefore there may be little trust or hope for reform remaining within GA, which has shrunk in numbers, and for these reasons its doubtful that this inquiry will elicit submissions, in number (only 14 to 20/6/20) or depth, that the subject deserves. 

Without a few exemplary specific reforms, quickly promulgated, few will hold out any hope from this inquiry. Specific reforms could readily be made in quick time, in line with the PM’s promise of regulatory reform, such as independent instructors (as USA), private pilot medical standards (as USA or car driver, same as low weight category) and relief around the infamous biennial $300 Aviation Security Identity Card (scrap, lower cost or increase term). 

In the longer term GA has no hope of growing the jobs, businesses and services that can and should occur unless and until there is a root and branch reform of Australia’s aviation regulatory regime and airports policy. The responsibility of Parliamentarians and Government. 

Sandy Reith 
(Alexander C. Reith)

MTF...P2 

[Kharon]

Of minds and what matters.

Munro (2004) - “If you were investigating with the intention of finding out what had happened, once you had made a transcript of a recording wouldn’t you send it to ALL those whose voices were on the tape asking them to verify the transcription? But if you were seeking “an ex post facto justification for a conclusion that had already been reached” (to quote Coroner Chivell) then you might well be selective about who got the transcript and who did not.”

Even in the State of Denial (ACT) it must be coming apparent even to the bipartisan house and the Senate RRAT committee that there is a serious credibility problem, which cannot be sketched around much longer. We all must live with glib and the inutile PR ATSB publish  for the media. Its not right – but it has become a normalised deviance; largely ignored by professional aviation. Perhaps bipartisan parliament can live with that. Who knows.

But coroners have both a legal and moral duty; their rulings have effect on many elements which impact on peoples lives. Industry professionals have legal, operational and moral duties; and, face criminal charges for even the perception of failing in that duty. How are these obligations to be met without accurate analysis of accident. Tangible, accurate, honest data to assist in improving 'safety' protocols and procedures is an essential element in any 'safety' case. Less than this makes not only a mockery of the expensive 'safety system', but opens the door to a recurrence.

For example: the Essendon DFO event. Almost 6 ton of machinery, carrying a ton of jet fuel slams into a building which, but for chance, was not filled with shoppers.  What are the percentage chances of this event reoccurring? If there was no building impinging on the safety zone around the runway, then the chances are remote. In the USA this is an acknowledged risk mitigation fact; there is a widely used code which minimises, within practical limits, building near runways. The ATSB dismissed 'the cause', almost on the day of the Melbourne event (in their time frame) as simple pilot error, based on one element. I would suggest this is a flawed explanation; easily dismissed. Yet the one element in the causal chain is all the coroner will have to work with. It begs the question – 'will there be another similar incident?. The answer is yes; if steps are not taken and enforced to discover exactly what happened to the aircraft, the pilot and how the 'safety system' was breached. 

It is all too easy to blame the ATSB  standing alone. The problem is they are the 'visible' part of a very ugly, dangerous situation; the face of safety if you will. In reality, they are but a cats-paw, waved at the whim of their masters. Essentially of little more than a team of cub reporters providing 'copy' to their editors and re-write, spin merchants. Oh, it is all very neatly done and no one is truly responsible for the dribble published – a company effort, on behalf of their masters voice.

Poor old Coroner; blinded by science, baffled with bullshit carefully steered to the 'right' conclusion. ATSB turn up at the inquest – having had a good long time to polish the Cue ball and Teflon coat it; CASA's legal weapon turns up to make sure that any and all 'argument is shut down – pronto like; and, all the coroner can do is meekly voice his 'opinion' and bury the case there and then, conscience salved by a good claret over a long lunch; knowing the minister is as happy as Claggy.

PAIN tried to hi light this in an abridged, edited version of a lengthy study of 'coroner inquiry'. Every 'fatal' accident, for over 12 years has been examined, all coroners reports and comments read and discussed. There is also a long, list of 'investigation' and conclusions drawn on almost every accident during that time. To put it mildly, the only folks not reaching for the vomit bucket are the 'official safety agencies' and of course the minister.

The answers you seek Senators may not be found in the current crop of 'officials'. Look to the coroners, seek out those no longer employed by the agencies, invite interested parties to speak. Do this before the charade begins in earnest, get some facts, get a real life picture and FDS get a grip. Boyd Munro penned the article below in 2004. The PAIN short report is – HERE.

KEEP A LITTLE SALT HANDY THIS WEEK, PLEASE …IN CASE ANOTHER ATSB REPORT COMES OUT.

I urge members of the Press Corps to keep a grain or two of salt handy this week. It may be needed when ATSB publishes its report into the Aviation Incident which occurred near Launceston on Christmas Eve.

The Report will probably be released this week, and it may contain the kind of inaccuracy for which the ATSB is rapidly developing a reputation. Before you go to camera, microphone or print on it, please contact us by phone or e-mail so we can – if necessary - tell you what ATSB may have chosen not to reveal.

The Aviation Incident is being beaten up for industrial reasons. Changes were made to Australia’s management of airspace. These changes take us part of the way out of the “quill pen and green eye-shade” era in which our airspace management has been for the past 50 years. Our airspace is now managed like that of the USA, which has an outstanding safety record – and there is far more flying in the USA than in any other country.

Those changes, sadly, are apparently seen by the leaders of the Air Traffic Controllers’ Union as a threat to their members’ jobs rather than the opportunity for professional development that they are,

The relationship between ATSB and the Air Traffic Controllers is a close one – so close that ATSB appointed a former Air Traffic Controller to investigate this incident.

ATSB has been widely criticised for its conduct of investigations. For example –

Mr. Wayne Chivell - Coroner, South Australia, July 2003.
"Mr. Fearon was made available by the ATSB to answer as many questions as he could arising from Mr. Cavenagh's evidence.

"The difficulty I have with Mr. Fearon's evidence on this topic is that he is happy to seize upon data, such as that produced by Mr. Braly, as supporting his theory, but when contradictory data was put to him he reverted to rather facile positions."......Mr Fearon's evidence became unhelpfully speculative.

"I find the ATSB's theory, namely................., as to be so unlikely as to be almost fanciful."In my opinion, the evidence is overwhelmingly against the ATSB theory...........

"As each of these technical issues were put to (The ATSB's) Mr. Cavenagh and Mr. Fearon their explanations and arguments became more abstruse and less credible. I gained the very distinct impression that this constituted an ex post facto justification for a conclusion that had already been reached rather than a genuinely dispassionate scientific analysis of the factors involved.

Ms Lyn McDade - Deputy Northern Territory Coroner, March 2003.

"ATSB apparently acting on the advice of others determined that they would not attend the accident site because it appeared to be an accident involving pilot error only. The basis for that determination could not be explored... ...because Mr. Heitman the ATSB representative who made that determination was not able to give evidence because he could not be located. This has deprived the family of the opportunity to test Mr. Heitman and ascertain why he formed the view about the accident he clearly did, without attending the scene or conducting any other enquiries other than telephone contacts with, it appears, Senior Sergeant B and nobody else. Mr. Alistair Hope - Coroner, Western Australia, September 2002 "I should stress at the outset that any comments in relation to the performance of the ATSB are made in the context where eight people have unnecessarily lost their lives, such a tragic event in my view requires careful analysis of available evidence and where answers are not forthcoming because of a lack of evidence, an examination should take place as to the way in which evidence has been obtained and possible deficiencies in obtaining evidence identified, which should be corrected in future cases if such tragedies are not to be repeated on a continuing basis."

Mr. Kurt Mackiewicz - Father of deceased pilot, on the ABC in July 2003

"The protracted investigation was attributable to the ATSB's questionable culture and also their arrogant and obstructionist conduct at the inquiry."

Mr. Peter Scollard – Pilot involved at Launceston, in the Hobart Mercury on December 29th. 2003 "I was fully aware of the Virgin Blue plane's presence at all times, I was monitoring it on two radio frequencies and I was maintaining separation. It is quite simple for me to diverge one or two degrees. At no stage was there ever going to be a collision or even a near-collision. Peter has good reason for concern. ATSB has not given him a copy of the transcript of the radio transmissions at the time of the incident, even though he took part in the transmissions. If all ATSB was doing was carrying out a “no blame” investigation, why on earth would they not give him a copy so that he could, for example, point out any transcription errors? To make matters worse it seems that a copy of that transcript, or a tape of the transmissions, has been made available to others!

If you were investigating with the intention of finding out what had happened, once you had made a transcript of a recording wouldn’t you send it to ALL those whose voices were on the tape asking them to verify the transcription? But if you were seeking “an ex post facto justification for a conclusion that had already been reached” (to quote Coroner Chivell) then you might well be selective about who got the transcript and who did not.

So keep that salt handy and be sure to give us a call on 08 8276 4600 if you feel an urge to report on whatever character assassination it is that ATSB has in store for Peter.

Boyd Munro
AIR SAFETY AUSTRALIA

Aye well I mind and; believe it or not - it does matter.

Toot – toot........

[Peetwo]

“Something is rotten in the state of Denmark …"

Educated, independent, responsible individuals with considered opinions on the state of aviation safety in Oz in recent times have been voicing their concerns in various media formats, all of which points to the overwhelming hypothesis that something is rotten in the state of Denmark...    

Examples:

Dr Gates to the SMH Editor:

Dear Ed

With all the cuts to QANTAS announced today because of the big reduction in passenger numbers,  it’s time to review staffing levels and salaries of government departments and agencies involved in aviation, a commensurate cut!

Do we really need all those ‘fat cats’ at the top in CASA and the ATSB (on enormous salaries) to be there, or are they a protected species?  And what about all those air traffic controllers sitting around waiting for a plane?  The only exceptions to the rule are the specialist firefighters who need to be there, regardless.

Sandy to Dan Tehan MP:

Dear Dan,


On February 19th four experienced pilots were killed in a mid air collision near Mangalore. 

This is not the first time that aircraft have had avoidable accidents due to our poorly managed, outdated, inadequate and improperly designed airspace, prerogative of the ‘independent‘ AirServices Australia With the CV induced absence of airline traffic now is the time to make real improvements in our airspace management. 

The whole aviation industry including General Aviation (GA) has been hard hit by the various measures to keep Australians safe from a rampant corona virus. 

Now, more than ever, it is imperative that Government brings in some urgent reforms for GA which it can accomplish with little or no expense. Reforms that are so obvious it should not be difficult to order the agencies to action those measures that can help to regrow GA, apart from making our airspace safer for GA and airline traffic alike.  

Having written and spoken with you on several occasions about the opportunities that exist to grow jobs and businesses in GA, I feel that there’s got to be the understanding that action is required. The Prime Minister talks about reducing red tape. Government could act now to put life back into GA and reverse the over regulated decline of this important industry. 

Car driver medicals for all private pilots, the same successful standard that has been In place now for some thirty years in the Australian low weight aircraft category (and similarly private flyers USA). This is a hugely anomalous area of splitting GA that has induced thousands of private pilots to the low weight category and distorted the whole industry. 

Relief from the Aviation Security Identification Card, a biennial $300 police check which to our knowledge has never been subjected to any cost benefit analysis. This is a measure that was brought about by the ‘911’ attacks but there is no similar ID imposition in the USA. This is an expensive impost that is resented greatly throughout GA because we can see that it has little or no value. Moreover for those of us that have been flying professionally, or privately, for up to fifty years or more it is disgraceful that we are treated like potential terrorists. Pending a proper analysis, Government should immediately increase the validity period in line with a timeline and or licence category. 

Flying training is the backbone of all aviation, we have lost hundreds of flying schools due extreme, unnecessary and hugely expensive CASA requirements. Independent instructors as the successful USA model will allow a resurgence of training especially, important for country centres to re-establish their flying schools. 

Airports, including those made over to local governments, are under threat of closure and inappropriate development in many places. Private airfields like Tyabb and Drouin in Victoria are being hounded by Councils, Central Coast airport in NSW also under attack and they need support 

If there was ever a time for Government to make some necessary changes and assist the aviation community it is right now. Plain commonsense with leadership must prevail if Government is to have credibility with the aviation community. 

Lastly we will not be satisfied to wait on yet another Parliamentary (Senate) inquiry when the last one, Forsyth 2014, has had no appreciable effect, in reality GA is in steeper decline. 

Please make representations on my behalf to Minister Michael McCormack and the Prime Minister. 

Regards,

Sandy

Dr K.I.K academic paper published in MDPI Aerospace open access journal:

Naweed, A.; Kourousis, K.I. Winging it: Key Issues and Perceptions around Regulation and Practice of Aircraft Maintenance in Australian General Aviation. Aerospace 2020, 7, 84.
 Ref: https://auntypru.com/wp-content/uploads/...-00084.pdf or https://www.mdpi.com/2226-4310/7/6/84

..It is of note that CASA approached this matter with a change management mindset, attempting to achieve a consensus from the regulated parties. The management of change, as a systematic
approach/methodology to enable change at an individual and organisation level [9], has also been
promoted by CASA for safety management purposes in the wider aviation industry [10]. Past CASA
attempts to impose regulations or dictate mandatory actions did not have the expected result, as
compliance was found to be problematic. An extensive industry consultation process was employed
for this purpose during 2018−2019 [11]. Tailoring of maintenance regulations (framework, oversight,
and practice) for the GA aircraft was a topic on the industry’s “wish list” from this consultation. This
finding has also confirmed the feedback collected by CASA from their previous interaction with the
GA sector.

Eventually, CASA decided to introduce a new set of maintenance regulations that mirrored the
United States (US) Federal Aviation Administration (FAA) rules for GA aircraft, with these outlined
in CASA’s consultation accompanying documents [11]. The FAA rules’ approach was by far the
preferred industry choice, recording a 78% acceptance rate [11]. The decision to follow the FAA
regulations for GA aircraft is not consistent with the CASA’s overall regulatory structure and
philosophy, as the Australian Civil Aviation Safety Regulations (CASRs) largely follow/mirror the
European Aviation Safety Agency (EASA) rules. This triggers questions on the underlying reasons
that provoke this type of change as well as what challenges may manifest as part of transitional
effects...

And from Dick Smith via the UP: 

Ref: https://auntypru.com/forum/showthread.ph...3#pid11363


Finally from the Commonwealth Ombudsman in reply to Glen Buckley: 

Conclusion of phase 1 of my investigation

On 23 June 2020 this Office sent a concluded view to CASA as follows:

The entry into force of the 1 September 2014 compilation of the Civil Aviation Regulations 1988 (CAR) removed the former CAR 206(1)(a)(vi) related to flying training organisations (FTO) from CAR 206.
CASA’s ruling Franchise AOC Arrangements (the Ruling) issued on 21 February 2006 refers explicitly to its application to commercial operations conducted for CAR 206 purposes. CAR 206(1)(a)(vi) referred to flying training, other than conversion training or training carried out under an experimental certificate.

With CAR 206(1)(a)(vi) removed from the CAR, I note CASA’s view that the policy objectives reflected in the Ruling have remained applicable to the conduct of FTO activities under the post August 2014 regulatory regime, irrespective of the explicit reference to CAR 206.

The Ruling was not amended to reflect that legislative change from 1 September 2014 meaning that the CAR and the Ruling were no longer aligned in material ways.

Conceptually, I accept CASA's view that the Ruling may reflect broader policy considerations.

Nevertheless in my concluded view there was an administrative deficiency due to an absence of a direct relationship between the activity being regulated and the policy said to regulate it. This gave rise to ambiguity and uncertainty with the potential to cause detriment to those relying on the accuracy of the regime or, conversely, prevent detriment from occurring.

In the circumstances, it is my concluded view that CASA should have made a concurrent amendment to its Ruling at the entry into force of the 1 September 2014 compilation of the CAR because of the practical effect of the change to those relying on the regulatory regime.

Thank you for your advice that CASA will amend the Ruling to confirm the intent of the breadth its application.

Please note that this is the Ombudsman’s opinion and CASA may disagree with it, or parts of it.

Ref: https://auntypru.com/wp-content/uploads/...port-1.pdf

MTF...P2

[Peetwo]

Submission 15 -Name Withheld (PDF 278 KB)

In the context of the Dr K paper (above) and the AMROBA submission 2, sub 15 is very relevant and supportive...

As an ex CASA employee, I have observed a progressive de-skilling of the of the inspectorate with each change of Director/CEO. This industry is a fast developing one with significant advances in technology, little opportunity is provided to staff to upskill and/or maintain their tradecraft knowledge base. From a regulatory aspect most CASA based staff training courses are designed to be a tick and flick exercise to meet external audit expectations, these external audits (typically ICAO and the FAA) do not delve sufficiently enough to look at course feedback and interview employees as to the worth/effectiveness or adequacy of the training...

...(pg 2)...This situation has been aggravated by the attrition of dedicated, experienced, highly qualified staff, inadequate training and supervision for new employees added to that the dumbing down of the broader inspectorate by reduction in scope of delegated functions previously held by front line inspectors and withdrawn and assigned only to managers. This situation continues in spite of being identified in a 1998 Plane Safe Report and again in an Australian National Audit Office (ANAO) Audit Report No.19 1999–2000. I do not degrade the quality of ex-military applicants however their experience in not from a civil environment, granted that the Military Airworthiness regulations are modelled on the European regulations it is generally agreed that those applicants fo CASA jobs need some civil experience before joining the inspectorate...

MTF...P2