[Sandy Reith]

1, 2, 3, and 4 the order doesn’t matter but just some action that will demonstrate to our beleaguered General Aviation (GA) industry that the Government is serious about rational policies that will grow GA jobs, businesses and services.
5. Minimum starting move for our infamous Aviation Medical branch of CASA would be car driver medical standard for Private Licence holders. Thirty something years proven in our light weight category and the success of the USA model leaves no doubt that this reform is viable.
6. Recommend the removal of the Aviation Security Identification Card, a most useless and multi $million impost on an ailing GA industry.
7. Recommend a halt to the alienation of irreplaceable airport land, noting that GA businesses can only operate from airports just as other businesses operate with roadways. Pip Spence and Mark Binskin can put to government that its not safe or efficient to cover these airports with shops and factories. They might point to the ludicrous situation where adjacent golf courses for the recreational benefit of a few golfers are protected from commercial developments.
8. As in the USA allow independent instructors who could then start to repopulate flying schools in numerous country centres replacing the hundreds that have disappeared by the impossibility of the ever worsening CASASTROPHE of the last thirty three years.
9. Structure all aircraft operating rules and administration together with a stepped approach as in the USA.
We are just getting started.

[Kharon]

So, what's to become of us?

“It was the best of times, it was the worst of times, it was the age of wisdom, it was the age of foolishness, it was the epoch of belief, it was the epoch of incredulity, it was the season of Light, it was the season of Darkness, it was the spring of hope, it was the winter of despair, we had everything before us, we had nothing before us, we were all going direct to Heaven, we were all going direct the other way – in short, the period was so far like the present period, that some of its noisiest authorities insisted on its being received, for good or for evil, in the superlative degree of comparison only.

“It was the best of times,” - and so it is in many ways. There has never been a better time to tear down the mountain of cumbersome, legally dangerous, operationally inutile, internationally embarrassing regulation and associated restrictions. While the wretched virus holds sway, aviation activity is in a holding pattern and running low on fuel. Money always helps to refuel – but, to expect a rapid recovery under the current regulations and regime, is simply wishful thinking. Adoption of 'world class' rules and a change of regulatory attitude would be a perfect stimulus and allow industry to flourish, on its own initiative; as it has for decades despite lousy regulation and administration.

“It was the worst of times”: not only has industry had a pasting through the virus outbreak; it was in dire straits before that. There is a long list of reasons for this – development of airports; increased administrative costs for operations; an almost insane bunch of regulation; manic regulators, an administration system which, at best could only be described as 'unhelpful' and etc. To add to the existing woes, there is the appointment of a new director of aviation. If Ms Spence is fully backed by heavy duty mandarins and serious changes are to come, then 'hope' may be rekindled. If not then doubt and uncertainty will quickly blossom and all hope of recovery will vanish as fast as investors can find the keys to the Range Rover.

“in short, the period was so far like the present period, that some of its noisiest authorities insisted on its being received, for good or for evil, in the superlative degree of comparison only."

The muted response to the announcement of a new director and chair reflects that. For there is no tangible evidence that anything will change. We have had a series of hamstrung ministers who happily take shelter behind 'the authority'. We have an 'authority which has taken full advantage of never being checked or questioned. The most risible rule set on the planet, ever increasing in size, dominating an industry which dare not call bollocks for fear of decimation through the outlandish legal chicanery those rules allow. This not new – there is a thirty year history of 'fact' to support concern that nothing material will change.

“...but everything in our intercourse did give me pain. Whatever her tone with me happened to be, I could put no trust in it, and build no hope on it; and yet I went on against trust and against hope. Why repeat it a thousand times? So it always was.”

Now, we must all, once again, sit and wait to see which way the coin will land. More time wasted waiting to see which way the hammer will fall. This industry desperately needs positive reassurance that 'change' for the better is not some mythical thing for some time in the future. The need is now and it is urgent.

McDonald could get her finger out – there is a mountain of damning evidence before her, why the delay in taking direct positive, reassuring action? Spence has the job; why is her jacket not hanging on the DAS door, sleeves rolled up swinging the metaphorical axe of real change, in real time? All well and good being cocooned within the bubble, safe salary and protection, remote from the real world – but those in aviation have no such luxuries.

Aye well; back in my box I go; but as we know the wheels of the gods are supposed to grind slow; but I wonder if the gods knocked off and shut down the mill; slow ain't even close, moribund perhaps would be a better descriptor of the Canberra output. There, patience exhausted – Click.............

“So new to him," she muttered, "so old to me; so strange to him, so familiar to me; so melancholy to both of us!...”

[Peetwo]

Submission 54 - Name Withheld. 

Via GA Inquiry submissions page, there is a new submission that IMO should be essential reading for all the Committee members, the new DAS and indeed the mandarins from the Department. Inside of 4 pages, this submission cuts to the chase and highlights very clearly all that is wrong inside of the Flight Operations division of the regulator - Well done that girl...  :

---

We are making this submission to the enquiry because we have personal experience with
regards to the failings of the Civil Aviation Safety Authority. We are the family of one of the
pilots killed in the tragic accident at Renmark in 2017 which occurred during a training flight
which should never have taken place. We would like to point out that we are not making this
submission simply from the perspective of bereaved lay-people with no knowledge of the
workings of the aviation industry. We have combined backgrounds which include, among
other things, a CPL(H), a law degree and an engineering degree. The following submission
will focus specifically on the operation and effectiveness of CASA, with particular reference
to CASA’s aviation safety frameworks, in the context of the accident investigation report
issued by the ATSB (AO-2017-057 - 30 April 2020).

1. CASA approval of incorrect procedures

Following their very lengthy investigation, ATSB finally produced a draft report in late
December 2019. This was presented to Directly Involved Parties (DIP’s) for comment and
clarification prior to the final report which was expected 30 days later.

The draft report made reference to the fact that the operator’s procedure for simulating
engine failure after take-off was different to the procedure outlined in the Pilot's Operating
Handbook and the Civil Aviation Advisory Publication (5.23-1(2).

The draft report further states:

ATSB has sought information from CASA regarding the circumstances under which the
incorrect procedure was approved for use by the operator. Analysis of CASA’s response will
be outlined in the final investigation report.

The final accident report published on the 30 April 2020 states the following:

The ATSB sought information from CASA regarding the circumstances under which the
incorrect procedure was approved for use by the operator. Despite this request, no
information was provided by CASA. Consequently, the ATSB was unable to determine
whether the approval of incorrect information was an isolated human error or symptomatic of
a systemic deficiency with the approval process.

Despite there being four months instead of the expected 30 days in between the draft and
final reports, it would appear that CASA did not respond to the request for information from
the ATSB. It would also appear that ATSB did not bother to exercise their rights under
section 32 of the Transport Safety Investigation Act 2003 to compel them to do so.

In recent correspondence in respect of the above the DAS/CEO CASA stated:

CASA provided all information we understood to be required or that was formally requested
by ATSB and we have since confirmed that ATSB is of the same view. We acknowledge that

there was an absence of clarity here and that it should have been resolved prior to the
finalisation of the report.

This statement merely confirms that CASA and ATSB have had communications with each
other, however this information was not in the final report and has never been made
available publicly or to DIP’s. Despite this, ATSB claimed that the information was sought in
a manner that was transparent to all Directly Involved Parties. There is no transparency with
regards to the fact that we still do not know whether this was an isolated human error or
symptomatic of a systemic deficiency with the CASA approval process.

2. Issues surrounding auditing

It would be hoped that such a fundamental, yet very serious error made by CASA in
approving the incorrect operations manual would be detected and rectified during a routine
CASA formal audit. The following extract from the ATSB report explains why this did not
occur:

In the 5 years leading up to the accident, the Civil Aviation Safety Authority had not
conducted a systemic or detailed audit during that period, and its focus on a largely informal
and often undocumented approach to oversight increased the risk that organisational or
systemic issues associated with the operator would not be effectively identified and
addressed.

In their investigation report ATSB published a flight operations surveillance table which
showed the recommended frequency for audits at Rossair as one per year. Unbelievably, the
last recorded audit was undertaken in 2012, and even this audit was performed on Air South
prior to their merger with Rossair.

ATSB go on further to state:

Rossair personnel reported that the lack of formal oversight placed them in a position where
they did not always have the required support for safety related initiatives and, as a result,
addressing commercial matters became a higher priority (emphasis added). The risks of
informal surveillance have been shown in previous accident investigations.

The 2009 Pelair Westwind ditching highlighted CASA’s process for obtaining information with
regard to the nature and extent of an operator’s procedures as limited and informal, yet
incredibly the same mistakes were still being made in 2017 and are likely to be continuing to
be made today.

Despite CASA personnel advising that the recommended frequency of surveillance was not
achievable with their current resources, the DAS/CEO CASA has attempted to justify CASA’s
failure to adhere to their own surveillance schedule in the following statement:


CASA’s approach to the safety oversight of air service providers is risk-based, having regard
to a range of relevant factors. This does not always translate into a fixed schedule or
mandatory frequency of audit and surveillance uniformly applicable to all operators, or even
all operators within the same sector.


This statement was made despite the knowledge by CASA, albeit informally, that a formal
audit was urgently required in order to address serious concerns raised with regards to high
levels of work-related stress and financial pressures placed upon staff. Had such an audit
occurred, it would have identified the serious cultural flaws and apparent lack of resources
affecting the company.

3. Lack of simple risk assessment

On the accident flight was a pilot undergoing a check flight for induction into the company.

The Chief Pilot was performing this check, however he was also undergoing a check by the
CASA flying operations inspector (FOI) to assess his competence for this role. With both the
flying pilots undergoing supervision, the FOI was the most experienced Cessna 441 pilot on
board and a valuable available resource. Despite this, the only avenue of communication
between the FOI and the pilots was a tap on the shoulder, yet still the flight was authorised
to proceed.

In 2015 CASA produced an advisory publication (CAAP 5.23-1(2)) in which they state that
the use of simulators has reduced the perils of simulating engine failures after take-off,
however where simulators are not available, instructors should not simulate engine failures
below 400ft AGL to provide a reasonable safety margin.

In June 2017 CASA issued a Temporary Management Instruction, part of which mandated
that simulated engine failures not be attempted below 1000ft AGL, however this has now
expired and there is no evidence to suggest that this will become part of the regulations. Is it
unreasonable to assume that older aircraft are less likely to have simulators available and
are more likely to sustain maintenance issues due to their age? Is it also unreasonable to
assume that extra altitude during highly risky training manoeuvres allows more time for
issues to be rectified?

According to DAS/CEO CASA there have been subsequent improvements to internal
procedures and guidance for staff conducting in-flight aircraft activities as a means of further
supporting future activities, however this is of little consequence to the three pilots who lost
their lives due to lack of a simple risk assessment.

4. CASA regulations re on-board recording devices

Under current regulations there is no requirement for any on-board recording devices in
aircraft of this weight, however in 2008 ATSB made a recommendation (R2006004)
regarding the fitment of lightweight recorders:


The Australian Transport Safety Bureau (ATSB) recommends that the Civil Aviation Safety
Authority (CASA) review the requirements for the carriage of on-board devices in Australian
registered aircraft as a consequence of technical developments.


It is now 13 years since that recommendation, and technology is even further advanced yet
still the Safety Authority is procrastinating over the use of this basic simplistic device. If
CASA had made a conscious safety decision, in respect of ATSB’s recommendation, in all
probability we would know the cause of this accident rather than being guided by some
outlandish hypothesis proposed by an investigation report which took three years to produce
at huge expense to the tax-paying public.

The point has been made in many other submissions to this inquiry that the production of
reams of new regulations has taken almost thirty years and enormous amounts of money
and man hours. Surely it would make more sense for a safety regulator to move away from
such onerous, prescriptive rules and focus their attention on monitoring to ensure aviation
companies are financially stable and running safe and competent operations. Accidents are
generally extremely detrimental to the viability of most aviation operations and therefore it
would be presumed that safety would be paramount to ensuring business continuity.

Regular, thorough and competent safety audits would identify and rectify those operators
who are not running their business in such an ethical manner. The travelling public surely
has a right to expect that this is how their tax-payer funded money is being spent?

In 2018 and 2019, during presentations to a number of aviation bodies, the DAS/CEO of the
CASA made references to the apparent dark days in safety standards prior to the formation
of CASA in 1995. He went on to emphasise just how good CASA currently is in exercising its
responsibility in respect of aviation safety.

In one of his speeches from 25 May 2018 he states "Aviation Safety and the safety of the
travelling public is CASA’s number one priority. We are the Safety Regulator and our
principle mandate is aviation safety. Our operations are based on the Civil Aviation Act 1988.
One of the most formative amendments of the Act was in 1995 when we became the Civil
Aviation Safety Authority, and a conscious decision was made that our focus would be first
and foremost of Safety".

It would appear the principle mandate of CASA failed abysmally on 30 May 2017.

---

Hmm...wouldn't this submission be a worthy contribution to the ANAO Audit?? 

MTF...P2 

[Kharon]

Submission #54.

Is indeed a good submission. Once again the highlighting the end result of what is a seriously flawed system.

However, whilst we can see 'result'; the path taken, which allowed that result is IMO not clearly defined, nor does it illuminate the radical elements which allow the great liberties taken in 'operational management' of a flying operation.

A simple, yet clearly defined administrative interference with an operational control safety system may be found in any company library – the 'Operations Manual'.

When the administration seeks to control every aspect of an operation, rather than defining the 'sector risk' matrix and allowing the industry experts to manage those risk elements, the administration involves itself in the minutiae – down to insisting spelling errors be corrected before any form of approval is granted. The purpose of the humble operations manual is to define how compliance and risk management is to be achieved. It is not a document writ specifically for the benefit of the prosecution, And yet it often is turned into such – the dictates of the administrator must be satisfied before approval or acceptance is granted.

There are countless examples where the administration has actively interfered with or influenced company operational tenets; which would be acceptable – provided that should there be a breach or accident, all those, including the administrator were held to account; and, corrections were put put in place to prevent recurrence. A better, safer result is much more desirable than fines, loss of operational approval, or even goal for the operator. Micro management, without responsibility and the endless cycle of 'satisfying' the demands of the administration provide nothing of value to anything other than the safe conviction of those alleged to have committed an offence.

Stand alone 'Sector Risk' analysis removes many of the administrative 'traps'. Allowing the 'experts' in any sector to 'manage' their own risks, without administrative interference would mop up many of the grey areas surrounding operational control and risk assessment. In short, the administration should set the boundaries and leave operational matters to those who know and understand the risk factors. As it stands – CASA have total control of operations but accept no responsibility for their part in demanding a 'preferred method of compliance' – their procedure or process incorporated into a manual which then is cited as part of an accident or incident event. See Ross Air or Pel-Air for ready reference.


“He can switch from one view to another with frightening ease. I think it is a sign of being accustomed to such power that the truth does not matter because you cannot be contradicted.”

Toot – toot.

[thorn bird]

opinions...opinions...opinions,

I agree wholeheartedly with what you are trying to get at K but the devil is in the making.

How many times in the regulations does the statement "CASA must be satisfied" appear. The question is just who in CASA does the satisfying? what is their level of competence, experience and background? CASA is not a singular entity. It is a conglomerate of opinions and egos, all based on personal perceived experiences and notions of how or what something should be accomplished or carried out, or achieved. Unfortunately the level of experience and competence is so often lacking within the regulator, for sure there are some very fine people within it, but they alone cannot "Be satisfied" for every interaction CASA has with industry.
There are many within industry who believe based on bitter experience that CASA regulates and enforces based on their desire to above all else avoid liability, rather than an objective aim of improving safety.The Glen Buckley imbroglio is a classic example IMO, where well meaning people "got" what Glen was about, saw the safety benefits, and encouraged him to pursue his business plan. Others higher up the food chain perceived a threat, not to safety, but to liability, so poor Glen had to go. Its so hypocritical because within the regulations there is oft repeated "Acceptable means of compliance" recognising perhaps, that there are different ways of doing things to achieve what CASA continually throws in the industries face "Safety" that word that nobody seems able to definitively define, which CASA use as a blunt instrument to bludgeon industry participant's into complying with their opinions and egos and directions, where liability is born by the participant's for any flaws that may subsequently become apparent.

Because of the varying opinions residing within the regulator in Australia there can be multiple operators of the same aircraft all operating with different procedures, something you don't see with larger transport category aircraft, other than minor differences in call outs and workflow, operational protocols are remarkably similar throughout the world.

As much as CASA is violently risk averse when it comes to liability so are aircraft manufacturers, especially in the GA arena. A very large portion of an aircraft's cost is for product liability insurance. GA manufacturers therefore produce operating instructions and procedures which endeavour to cover every eventuality, with the cloud of litigation hanging over their heads for aircraft that have long passed their life cycle but continue in service, nobody could blame them, but that provokes another problem. With large RPT aircraft is can be assumed they will be operated by well trained and experienced professional pilots therefore procedures are developed to cater for practical commercial operations.
Most GA aircraft are produced for the "private" operator, approximately 80% of light jets produced by Cessna are flown by private operators. I'm not attempting to cast dispersion on private pilots, many if not most are highly competent safe operators.
The operational material manufacturers provide attempts to cover the lowest common denominator and therefore is sometimes impractical when used in a commercial sense. Technically, modern GA aircraft are now matching and sometimes surpassing large RPT aircraft in terms of technical sophistication making them a much safer vehicle than in the past. In some cases the Flight Manual operating procedures have caught up with modern thinking, but still impose impediments from a commercial sense and can be safely streamlined for commercial operation with practical solutions which reduce workload and still achieve desired safety standards.
The unfortunate problem in Australia endeavouring to do this ends up a buggers muddle of competing egos within the regulator which is why complication rather than simplicity rules the day, sometimes to the detriment of safety.

[thorn bird]

One thing high performance aircraft drivers are wary about.

Being low, being slow, being dirty (configured).

Reported by a high performance aircraft driver out of BK a week or so ago. Just airborne with a strong south easter blowing, encountered very strong mechanical turbulence, the sheer was such that it was very difficult not to bust flap limit speeds and keep the shiny side up.....Hmmm, asked if it was reported, response no, being already up to the neck in alligators the last thing wanted was to poke them.

I wonder what caused that? firstly the turbulence secondly the reluctance to report? Hmmmm.

[P7_TOM]

A safety hat trick.

Good catch Thorny – a hat trick.

Catch 1 – 'strong mechanical turbulence'. When you consider that Bankstown has been operational since WW2 and the landscape has changed very little (apart from 'modernised' flood plains) you must wonder why – suddenly 'turbulence' has become so aggressive that it can kick seven bells out of a 'performance' air craft. Could the minister provide the 'vortex' and wind shear' analysis portion of the 'safety analysis for Bankstown – the one that was part of the 'master plan'? Just so can be sure all possible 'risks' to air safety from this very real and present danger was taken into account before runways were closed and large buildings close to the operational surfaces appeared and that data was properly assessed. If HP Jet traffic is being belted around what chance the mutt in the Tupperware?

Catch 2 – No doubt the crew obtained and studied the BoM forecast before departure. There may have even been a one line warning – turbulence below XXX feet – fair warning – but BoM rely heavily on 'models'. Now it takes time and data to construct a 'model' – so have the BoM been feeding the effect of additional construction data into their model as fast as they can? Have they set reference points and monitoring equipment to measure the effect of 'new' topography? I feel sure the minister has this information at his finger tips; perhaps the McDonald inquiry could ask him to provide it, fare for us all to contemplate.

Catch 3 – Alligators, wolves and crocodiles aside – I believe there exists – in law – a requirement to report such speed excursions and 'keeping the shiny side up'. Not filing a report is a double crime (IMO) : but such is the fear of CASA taking the thing to some extreme length for 'safety' reasons that both industry and BoM are deprived of valuable data which may, just in time, help avoid another 'shear' induced accident.

There are good reasons for the almost universal adoption of the 'California Code' – insurance being just one of the many. There is also some pretty solid reasoning in the ICAO 'advice' pertaining to safety zones not only on take-off and landing paths, but on the alongside a runway clearances. Our minister, his department and those responsible for 'safety' seem to have found ways around what is, essentially, common sense, to dance to a developers tune – its the same one snake charmers use by the way.

Hellish din - and, until now, I thought bagpipes were 'beyond' -

[thorn bird]

Thomas, mate, the snakes have their fangs pulled, not so the development sharks.

One of the most dangerous things you can do is stand between a development shark and a dollar.

If they cannot get it by Hook they will get it by Crook.

There is a reason why they are prevented from political donations in NSW, doesn't apply federally,

Ever wonder why?

[Peetwo]

Speaking of the Feds??

Slight thread drift here but while on the subject of the AFAP, remember this from almost a year ago...

O&O report: AI-2018-010 - The approval processes for the Bulla Road Precinct Retail Outlet Centre 

Via the Oz:

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Essendon Airport report delays slammed

ROBYN IRONSIDE
Follow @ironsider



The aftermath of the DFO crash on February 21, 2017. Picture: Jason Edwards

• 12:00AM FEBRUARY 7, 2020
  
  
• NO COMMENTS
  

An investigation into the building approvals process for land at Essendon Airport is taking almost twice as long as the plane crash investigation that triggered it.

The Australian Transport Safety Bureau began its examination of the approvals process for the Bulla Road Precinct Retail Outlet Centre almost three years ago, after the crash of a King Air B200 into the DFO building on February 21, 2017.

All five people aboard the charter flight to King Island — pilot Max Quartermain and four American tourists — were killed in the incident.

The final report on the crash was released in September 2018, but more than a year later the related investigation into the potential hazard posed by buildings around the airport is still going.
Information obtained by the Australian Federation of Air Pilots under freedom of information laws showed the draft report was actually released to “interested parties” in November 2018.

Subsequently the investigator-in-charge contacted the coroner, saying the final report was due to be released in mid-December.

But that date came and went and more than a year later, AFAP is still waiting for the ATSB to release the report. In a letter to ATSB chief commissioner Greg Hood, AFAP safety and technical officer Julian Smibert sought an explanation.

“During these delays in the publication of the report, development at Essendon Airport has continued unabated, including further construction within the OLS (obstacle limitation surface) and the narrowing of the runway in order to facilitate more construction,” Mr Smibert wrote.

“In addition the maximum permitted mass of aircraft using the airport has been increased from 45 to 50 tonnes, despite the reduction in runway width.”

The ATSB’s investigation summary showed the report on the approvals process was now due to be released by the end of next month.

An ATSB spokesman said the report had been delayed by detailed feedback from directly involved parties that prompted more discussion.

“A second draft of the investigation report incorporating and addressing feedback from all parties was provided to them on 30 September 2019,” he said.

The process was made more complex by the fact the approval process was put in place nearly 20 years ago, he added.

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Hmm...maybe this might help explain the delay...


Ref: https://auntypru.com/setting-the-odds-and-playing-em/

The AFAP concerns around Federal government safety risk mitigation policy in regards to commercial development around airports, has been further highlighted several times in their allied submissions with AIPA (ie AusALPA) 

(Refer to submission 14 to Sterlo's current inquiry: 14 Australian & International Pilots Association  (PDF 1543 KB)  (from about page 17))

...To be clear, AusALPA recognises that the economic decisions surrounding airports, i.e. determining the balance between the economic benefits of developments and the detriments to the accessibility, efficiency and capacity of an airport, rest entirely with the relevant jurisdiction within which the airport is situated or which retains legal control. The issues of enforceability and dispute resolution of development approvals would remain consistent with those jurisdictional norms.

However, contrary to current practice, we are proposing that the assessment, mitigation and enforcement of the safety consequences of all relevant developments be ceded by those jurisdictions to CASA as an independent decision-maker.

Consequently, CASA needs to change its model of how airport standards are applied and enforced so as to obviate the gaming of the system so exemplified by the Essendon experience or by the uncontrolled expansion of the thousands of airspace penetrations at Sydney. As a further consequence, DITCRD should seek major amendments to the Airports Act 1996 that change the current subservient and excessively constrained role attributed to CASA and that also clarify the safety considerations that ABCs must undertake in regard to minor developments.

Furthermore, we are proposing that the visibility of developments affecting the safety outcomes at airports is vastly improved in all jurisdictions.

The public interest is best served by accepting that the potential hazard created by a development on or near an airport is not a function of cost but rather the amalgam of the issues set out in the Guidelines. Each jurisdiction should commit to a public register of development proposals that may present a potential hazard to safe airport operations, enhanced by a published list of stakeholders who are alerted to each new relevant development submitted to the jurisdiction for approval...

With that in mind, now check out the latest (typically unannounced) update to the ATSB Essendon DFO approval process investigation, remembering that this was the last Hooded Canary weasel worded committment made: 

Further investigation

In Quarter 4 of 2019, a draft report on the ATSB’s investigation into the Bulla Road Precinct approval was distributed to directly involved parties for comment.

During the review process, the ATSB determined that further evidence was required to consider the effect of the revocation of instrument 153/15. This has necessitated re-engagement with the airport operator, CASA, the Department of Infrastructure, Transport, Regional Development and Communications, and the International Civil Aviation Organization.

Should safety issue/s be identified during the course of this ongoing investigation, relevant parties will be immediately notified so that appropriate safety action can be taken.

An amended draft report is expected to be distributed to directly involved parties in Quarter 4 of 2020.

Latest from the ATSB investigation webpage:

Anticipated completion: 1st Quarter 2021

Last update 15 January 2021
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ATSB investigation/coverup - Update: 23/06/21

General details
General details
Date: 21 February 2017 Investigation status: Active
Investigation level: Systemic - click for an explanation of investigation levels
Location  (show map): Essendon Airport, Bulla Road Precinct Retail Outlet Centre Investigation phase: Final report: Approval
State: Victoria
Release date: 10 September 2020
Report status: Pending
Anticipated completion: 3rd Quarter 2021

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Last update 01 June 2021

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Status: Active 


Phase: Final report: Approval Read more information on this investigation phase

Hmm...NO COMMENT!   

MTF...P2 

[Peetwo]

Back to the future? - QON re-answered please - 

Given the absolute zero activity/progress on the 20/20 inquiry web pages it would appear that Senator MacDolittle has racked the cue on her previous passion for righting all the 30+ year wrongs inflicted on the industry by the Iron Ring led Big R-regulator...  

However there is always two sides to a coin and in this case maybe it would be politically advantageous for Sterlo and Labor to step up to the line and push for the reforms needed to ensure the 'law unto itself' regulator is once again properly oversighted by both the Minister and the Federal Parliament? Which brings me to the following...

 References: A word of advice Minister; Mandarins; and their Minions



And this...  

Update: 29/01/20

Ref: ...I also note that yesterday in the inquiry additional documents webpage there was added some further answers, to Senator Sterle's written QON, from the CASA Iron Ring (Dr Aleck) that perfectly highlights that there will be no compromise/reform from the current regime's  overbearing, complex and archaic regulatory philosophy - 

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Ref: 4  Answers to written questions on notice by CASA taken on 11 January 2021 from Senator Sterle. Received on 27 January 2021.  

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Questions on notice

Questions to be asked to the Civil Aviation Safety Authority (CASA) for the Rural and Regional Affairs
and Transport Committee Inquiry into:

The current state of Australia’s general aviation industry.

Background

In 2014 the Aviation Safety Regulation Review (ASRR) made 37 recommendations for the Australian
Government to consider. Only recommendation 20 was not agreed to by the government.

The following questions on notice are with reference to recommendations 30 and 31, which are:

1. The Civil Aviation Safety Authority changes the current two-tier regulatory framework (act and
regulations) to a three-tier structure (act, regulations and standards), with:
(a) regulations drafted in a high-level, succinct style, containing provisions for enabling
standards and necessary legislative provisions, including offences
(b) the third-tier standards drafted in plain, easy to understand language.
2. The Civil Aviation Safety Authority structures all regulations not yet made with the three-tier
approach, and subsequently reviews all other Civil Aviation Safety Regulation Parts (in
consultation with industry) to determine if they should be remade using the three-tier
structure.

Furthermore, many submissions to this inquiry make reference to the complexity and difficulties with
comprehension of the current regulations, including the recently developed CASRs and their
associated Manual of Standards (MOS).

Questions on notice:

1. Does CASA acknowledge that regulatory complexity and difficulties with comprehension of regulations
and standards relate to ASRR recommendation 30 (b)?

CASA is aware that some aviation stakeholders can be frustrated by the complexity of civil aviation
legislation as a whole or with parts of the three tiers of legislation. However, CASA consults all
proposed legislation with industry providing the opportunity for any feedback to be incorporated in the
final legislation where possible.

2. Regarding regulatory complexity and comprehension issues, including the time lost for the
stakeholder’s activities due to this, does CASA acknowledge the legitimacy of the frustrations from
aviation stakeholders and that these relate directly to a divergence by CASA to ASRR recommendation
30 (b) and to paragraph 1 © of s9 of the Civil Aviation Act (1988)?

Refer response to Question 1. In addition, CASA does not agree it has diverged from paragraph 9(1)©
of the Civil Aviation Act and considers we have acted in accordance with the Government’s in-principle
agreement of ASRR recommendation 30(b) and notes that implementation of this recommendation is
continuing.

3. Does CASA acknowledge that the cost impact expressed by many aviation stakeholders is referenced
to and due this complexity of regulations and standards, and that the time wastage and lost economic
activity resulting is a significant cost impact to their activities?

CASA acknowledges that complexity in regulations and other aviation safety standards will in some
cases have an unavoidable cost impact on stakeholders. However, CASA does not agree that this
impact is generally of a significant nature or that time and economic ‘loss’ is fairly attributable to
compliance with unnecessarily complex regulatory requirements.

4. Does CASA include lost time and lost economic activity in its cost impact considerations and if so, how
does CASA make this assessment and will CASA provide detail as to how it calculates and includes the
cost of lost-time and lost business opportunities into its cost impact considerations and calculations?

CASA prepares a Regulation Impact Statement (RIS) for any new or amendment regulation or standard
that may have a significant cost impact on stakeholders. The RIS outlines the total cost impact of the
new or amended regulation, including the cost of lost time for business to comply with the regulatory
requirements. This involves estimating the time that affected businesses are required to devote to
complying with the new or amended regulation. RIS and the incorporated estimates for cost of lost
time are reviewed and assessed by the Department of Prime Minister and Cabinet.

5. Given that CASA has actually moved to a four-tier model of regulatory structure, with the fourth-tier
including the development and promulgation of plain English language guides, will CASA acknowledge
that this is evidence that the third-tier, Manual of Standards, have not been developed and
promulgated in “plain, easy to understand language”?

CASA has not moved to a ‘four tier’ model of regulatory structure as guidance material including Plain
English Guides (PEGs) are not the law. The PEGS are a CASA initiative to provide a convenient, simple
and consolidated summary of the rules using graphic illustrations and other aids to help facilitate
another means of understanding for the relevant legislative requirements.

6. Can CASA explain and detail what aviation stakeholder consultation they conducted in order to
establish aviation sector support for such a departure from adopting ASRR recommendation 30 (b)?

CASA’s responses to questions 1, 2 and 5 confirm that CASA continues to act in accordance with the
Government’s in-principle agreement of ASRR recommendation 30(b).

---

Follow up to above...

Via Oz Flying yesterday:

Impact of Complex Regulation not Significant: CASA
28 January 2021



The Civil Aviation Safety Authority (CASA) has told the Senate Inquiry into the General Aviation industry that complexity in regulations has not had a significant impact on stakeholders, according to a statement made public yesterday.

The statement comes in a reply to a question on notice asked by Senator Glenn Sterle in the inquiry in November regarding regulation complexity and the burden on operators and pilots.

"Does CASA acknowledge that the cost impact expressed by many aviation stakeholders is referenced to and due this complexity of regulations and standards, and that the time wastage and lost economic activity resulting is a significant cost impact to their activities?", Senator Sterle asked.

"CASA acknowledges that complexity in regulations and other aviation safety standards will in some cases have an unavoidable cost impact on stakeholders," the response said. "However, CASA does not agree that this impact is generally of a significant nature or that time and economic ‘loss’ is fairly attributable to compliance with unnecessarily complex regulatory requirements."

Several submissions to the inquiry complained about the impact of complex regulations in terms of time and cost, including John McDermott of McDermott Aviation, who stated that the industry was operating safely even though in many cases it was unknowingly working outside CASA regulations.

Senator Sterle also queried CASA about how it assessed the cost impact of regulations on operators and how that was considered in the rule-making process.

"CASA prepares a Regulation Impact Statement (RIS) for any new or amendment regulation or standard that may have a significant cost impact on stakeholders," CASA replied. "The RIS outlines the total cost impact of the new or amended regulation, including the cost of lost time for business to comply with the regulatory requirements.

"This involves estimating the time that affected businesses are required to devote to complying with the new or amended regulation. RIS and the incorporated estimates for cost of lost time are reviewed and assessed by the Department of Prime Minister and Cabinet."
The senate inquiry is ongoing and all submissions and replies to questions on notice are on the inquiry webpage.

I also note that in yesterday's 20/20 inquiry public hearing, the AFAP also picked up on the CASA AWQON (above) and made pretty much the same OBS in regards to CASA's opinion that they have implemented and are being compliant with the ASRR (Forsyth report) recommendation 30(a):

30. The Civil Aviation Safety Authority changes the current two-tier regulatory framework (act and regulations) to a three-tier structure (act, regulations and standards), with:
a. regulations drafted in a high-level, succinct style, containing provisions for enabling
standards and necessary legislative provisions, including offences

Which is totally in direct conflict with historical industry evidence/experience in the preceding 6+years since the former Minister Warren Truss presented the Forsyth ASRR report to the Australian Parliament -    

ps Note that CASA's self-serving, self-delusional belief that they have implemented and have been compliant with pretty much all the Rev Forsyth's recommendations dates back to 31 July 2017: https://www.infrastructure.gov.au/aviati...y_2017.pdf
 

Completed – Implementation Ongoing CASA will continue to focus on new regulations and instruments adhering to Commonwealth legal drafting practices and avoiding inconsistencies with other pieces of relevant legislation. Rules will continue to be prepared in accordance with a three-tier regulatory structure and using easy to understand language. CASA is committed to the remaining reform programme regulations drafted for public and industry consultation by the end of 2018. 

Hmm...IMO Sterlo could start by re-submitting his previous incisive QON to the new (above) leadership team...  

"RIS and the incorporated estimates for cost of lost time are reviewed and assessed by the Department of Prime Minister and Cabinet..."


While your at it Sterlo could we please request a tabling of all such 'reviews and assessments' from the PMC? 

MTF...P2 

[thorn bird]

Quote:

"The Civil Aviation Safety Authority (CASA) has told the Senate Inquiry into the General Aviation industry that complexity in regulations has not had a significant impact on stakeholders, according to a statement made public yesterday."

BWAA....HAW.....HAW....HAW.....SOB!

If that's not the most risible statement in the last half century its got to be close.

Of course, if the impact on "Stakeholders" is insignificant and there are plenty of "stakeholders" out there who would vehemently disagree with that, given the number running around with Stake in hand looking for someone to stab with it, what about the taxpayers? Half a billion bucks or so pissed up against the wall to achieve what exactly?

We could have had New Zealand's updated FAA, FAR's, that most of the nations pacific region have adopted, for a very good reasons.

Firstly they would have cost the Australian taxpayer around five million, NOT half a Billion. Secondly they would have provided better safety outcomes, thirdly they would have unshackled general aviation in Australia permitting growth, financial security and jobs instead of the death by a thousand cuts the GA industry is currently experiencing.
The added bonus? The taxpayer would have saved the cost (Still unknown) of CASA producing a plain English explanation of exactly what the current gobbledegook regulations actually mean.

Australia the "Lucky Country"? certainly the dumb'est.

[Peetwo]

Homework for the RRAT committee.

Should the McDolittle committee ever get off it's beam ends again and actually do something useful; (about now) there is a question (or two) that could be asked, the answers enlightening.

'We' (a few of the BRB) have been running a count of the legislation changes made in Australia and a comparison graph to map out the 'changes' other 'grown up' administrations, such as the UK, USA and NZ have made in the same time frame.

To do this exercise properly, it is important to 'register' - HERE - for the true Australian count. Failure to do so provides a different 'count' and the data received 'on the street' differs somewhat from the 'official' count (curious ain't it). It is a remarkable difference; the overseas administrations tally of change notifications match the official count and those transmitted to industry.

So, the homework questions:-

Since 2017 there have been 232 email notifications of changes to regulation sent to Australian subscribers: a half a dozen of which describe re write of an entire suite. How many of those were obtained by those not 'registered?


How many of the notified changes were fully explained in terms of benefits to industry by way of savings, ease of operational restriction, added 'safety' value' and alignment with ICAO?

I say we have for 33 long, weary, expensive years lived with a regulatory suite in a constant state of flux. The cost to the taxpayer and industry into the Billion dollar realm. The regulations are not ICAO compliant, are cumbersome and onerous. How much more time and money must be expended before the Minister and government realise that the regulatory reform program is a long standing waste which is killing off an industry which, overseas, is flourishing?

Final question - how much easier and cost / operationally effective would it be to simply adopt the world wide gold standard?  The savings; cost benefits and operational increased activity stand alone would affect the national budget and increase revenue for the nations coffers.

What would the savings be if the regulatory reform program were dumped and the ICAO compliant rule set transitioned in, without interference?

There you go - a question or two worth the cost of having a Senate committee ask. Should the McDolittle coven ever reconvene and actually do something that is..

Toot - toot. (and yes, we do have definitive answers). NFP.

To add to Kharon's post above..

The email notifications numbered 232.

The actual changes to various bits and pieces of legislation numbered 299.  296 if you discount the legislation relating to yet another inquiry into CASA..

Of these 296, the Civil Aviation Regulations suite was re-compiled three times, on 16/11/2018, 5/04/2019, and 3/08/2019.

On the other hand, the Civil Aviation Safety Regulations were re-compiled.....wait for it....a staggering 14 times.  Once, in October 2020, only a couple of days apart.
4/03/2017, 5/04/2018, 21/09/2018, 12/04/2019, 7/08/2019, 20/08/2019, 13/11/2019, 17/07/2020, 4/09/2020, 13/10/2020, 15/10/2020, 23/12/2020, 11/02/2021, and 23/03/2021.

Notice the two dates in 2021.....after St Commodius resigned.  Hang on a second...didn't he say it was all done and dusted?  He wouldn't tell a porkie pie now, would he?

Some other stats...

There are 91 exemptions for various things, some appearing more than once.

There are 9 amendment instruments for CAO 48.1.  Which appears to have been re-written 6 times.

Prescription of aircraft and ratings — CASR Part 61 starts with Edition 3, then goes Editions 5, 6, 7 and 8.  What happened to Edition 4?  Did it fall down behind the tea lady's trolley to get trampled to death?

Urgh....this is doing my head in!

P7 -

Well done CW - the troops say thanks - sorry about the headache, Tim Tams on the way to enjoy with "a vanilla latte with two sugars" - Cheers...

Additional homework for the committee...

Dick Smith, via the UP: https://www.pprune.org/pacific-general-a...st11088945

Incredibly fantastic UK GA document

---

Have a look at the this document.

Notice the heading “Our Vision – We want the UK to be seen as the best place in the world for aviation”.

Under Contents it says, “The Government’s vision for the GA sector.”

Another half-page heading says “We want the UK to be seen as the best place in the world for GA”, and mentions “proportionate risk-based and consistent approach to regulation that delivers high quality safety outcomes.”

This is obviously being driven by the UK leaving the European Union. Also the UK CAA has nothing similar to our wording that their regulator “must regard the safety of air navigation as the most important consideration.”

This is wording from the UK CAA Act:

“… provide air transport services which satisfy… public demand at the lowest charges consistent with a high standard of safety… and an economic return to efficient operators…”

I reckon we all have to get together and make sure that Australia is the best place for general aviation – not the UK, the USA, Canada or anywhere else. Do I have any supporters?

MTF...P2 

[thorn bird]

Dunno about supporters P2, are there any survivors left out there?

[Peetwo]

Doc Runacres Submission 56

Via RRAT webpages: 56 SAR Aviation Medicine (PDF 182 KB) 

---

Moorabbin Airport
As discussed above, there has been pressure on Moorabbin Airport Corporation to provide
more aviation space, parking and hangars at the airport. This pressure has been largely
resisted and no investment in aviation space by Moorabbin Airport Corporation has been
undertaken since privatisation has occurred.

That is not to say that no investment has occurred at Moorabbin Airport, as some businesses
have been allowed to develop their own buildings. Further, as outlined in the 2004 Master
Plan, one hangar has been constructed and one has been converted from non-aviation to
aviation use. This is the total extent of aviation hangar construction since privatisation
occurred at Moorabbin Airport.

Concurrently, a tenant of Moorabbin Airport Corporation went into administration and was
liquidated. A sub-leasee was advised that there is no space for them at Moorabbin Airport
and their tenancy was to be terminated in November 2021. With no viable option available,
the tenant vacated Moorabbin Airport permanently.

I have a collection of names of aircraft owners seeking hangarage for their aircraft and the
demand for aviation space, specifically hangar and aircraft parking at Moorabbin Airport is
now at unprecedented levels.

The Airports Act Cwth (1996) (The Act)
On reviewing The Act, I note the first Object of The Act includes Section 3(a): “to promote the
sound development of civil aviation in Australia”.

Since privatisation, until 2029, when this proposed Master Plan is due to expire, Moorabbin
Airport Corporation boasts $800M invested into Moorabbin Airport, but only $25M of this
will be spent directly on aviation.

During the Second Reading of The Airports Bill, by the Honourable John Sharp, Minister for
Transport and Regional Development assured the Australian people that “The government is
thus committed to putting into place an appropriate regulatory framework to protect the
interests of current and future airport users and local communities” and “The government's
aim is to ensure there is no abuse of the potential market power of airport operators”.
As demonstrated Moorabbin Airport Corporation has done nothing to promote the
development of aviation in Australia and the Governments agenda has been thwarted by
Moorabbin Airport Corporation.

Moorabbin Airport Corporation is required under The Act to provide a Master Plan (Section
70(1)). Included as a purpose of the Master Plan is “…to reduce potential conflicts between
uses of the airport site…”.

The Moorabbin Airport Corporation Master Plan
I have read and reviewed the Moorabbin Airport Corporation Master Plans from 1999, 2004,
2010 and 2015 as way of background to this submission on the Draft 2021 Master Plan.

While nothing can be changed under these Master Plans, it is important to understand the
track record that the Moorabbin Airport Corporation holds. Under these Master Plans the
following aviation projects have been achieved:

• Runway 04/22 has been shortened
• Aviation hangar numbers have been reduced from 39 to 32
• Aviation leased land has decreased from 225,000m2 to 163,000m2 (though a possible
further 29,000m2 may come on line)
• A noise abatement sign (since gone) was placed near runway 17R
• The only major project funded by the Moorabbin Airport Corporation has been the
refurbishment of the terminal building, that happens to include the Moorabbin
Airport Corporation offices

Moorabbin Airport Corporation will espouse its investment in aviation by discussing runway
lights and runway and taxiway resealing. Please note that this is not investment in the airport.
This is routine repairs and maintenance, as required by any airport to maintain its certification
with the Civil Aviation Safety Authority and compliance with the International Civil Aviation
Organization.

It should be noted that under the 2015 Master Plan, the removal of seven hangars plus
parking apron was presented as a coloured box on a map. No further details were given and
the first real warnings of this occurring was when the airport provided an eviction notice to
the tenants of seven hangars, which sent shockwaves around the airport.

Further, the removal of seven hangars and subsequent construction of new warehouses and
a new road under the 2015 Master Plan warranted a Major Development Plan. The
Department of Infrastructure, and your office has not been able to provide any evidence such
a plan was provided.

On reviewing the 2021 Draft Preliminary Master Plan, a further coloured box on a map is the
only indication in the reduction of aviation precinct, resulting in another approximately seven
hangars being removed. With no replacement outlined for the seven previously removed
hangars, Moorabbin Airport is now looking at the having had fourteen of thirty-nine hangars
removed, with little or no replacement documented in the Master Plan.

Nothing in the 2021 Draft Preliminary Master Plan addresses:

• Expanding “non-flight training” aspects of general aviation
• That almost none of the previous proposed aviation projects have been undertaken
• How safety at the airport is being improved above the minimum
• How displaced aviation tenants will be managed
• How new aviation tenants will be accommodated

It should be noted that very little of the proposed aviation development from the 1999, 2004,
2010 and 2015 Master Plans has actually been conducted. These sections have largely been
regurgitated from Master Plan to Master Plan.

Corporate Responsibility
It is important to consider the broader picture of Moorabbin Airport Corporation, and its
owner, The Goodman Group.

• The Goodman Group is a $51 billion dollar, publicly listed (ASX), international
company. It boasts, in its 2020 annual report, an operating profit of approximately $1
billion.
The Goodman Group is a property developer, and Moorabbin Airport, approximately
20km from the Melbourne CBD, is prime land for redevelopment as anything other
than an airport.

• The Moorabbin Airport Corporation and Goodman Group have made it clear that they
have no interest in keeping Moorabbin Airport as an airport or supporting aviation,
new aviation tenants or appropriately managing existing tenants. As an example, all
aviation leases appear to have a redevelopment clause which outlines that, with six
months notice, tenants can be evicted to make way for new development. This lack of
security makes managing a business, from a long term perspective, unworkable.
• At the northwest aspect of runway 31L, south of Centre Dandenong Road, west of
taxiway Golf and east of the DFO buildings is “Toxic Mountain”, an area of
approximately 14,000m2. This area contains PFAS contaminated soil, moved there
from the airport environs approximately two years ago. The construction of Toxic
Mountain appears to be a permanent structure. It would appear that the
management and containment of this contaminated soil is contrary to the PFAS
National Environment Management Plan. This has been referred to both the
Environment Protection Authority Victoria and the Federal Department of Agriculture,
Water and the Environment requesting an investigation.
• No Major Development Plan has been made public for the recent development on the
western most aspect of the airport, resulting in the removal of hangars and airport
apron.

These are just a handful of transgressions that Moorabbin Airport Corporation and Goodman
Group have made at Moorabbin Airport.

I note rumours abound that Moorabbin Airport Corporation and Goodman Group are seeking
an early renewal of the option on their lease.

Conclusion
It is clear that Moorabbin Airport Corporation has failed and is failing to manage Moorabbin
Airport appropriately and is therefore in breach of its obligations. Further, there has been no
serious effort to assist, promote or develop general aviation. There is no space for existing
aviation tenants to expand or for new tenants to enter the airport. Moorabbin Airport
Corporation, and Goodman Group, have demonstrated that they are not responsible
corporate citizens and have failed Moorabbin Airport and its citizens, by shrinking the aviation
footprint, without due consideration to the Airports Act and by not investing in aviation.

---

Well put that man...

MTF...P2 

[Sandy Reith]

Well put Dr. S. Runacres, a cogent and succinct list and explanation of the current malaise at Moorabbin Airport.

Also a revealing story about the the inexcusable and irresponsible lack of government oversight of the explicit requirements pertaining to these airports and their development. No doubt John Sharp is awake at night thinking how he can influence his National Party mates to put an end to the travesty that goes by the name of ‘Airport’ Master Plan.

I haven’t heard that he is jumping up and down about how his words are mocked and denied, or the resulting impunity of Government carelessness. The more extraordinary when considering that none of the National Party Ministers who’ve followed in John Sharp’s footsteps as Minister in charge have lifted a finger for GA, let alone caused Goodmans to stick to the government’s policy.

[thorn bird]

Geez, being in home detention sets the mind to ponder. Why oh why do the little birds fly?

Just why does Australia require such convoluted, expensive, industry destroying regulation?

CASA maintains it is necessary for the "Safety" of aviation, the only thing their charter says they must consider.

Therefore to protect the Australian public from raining aluminium they must have complex regulation like no other in the developed world.

Which brings to mind, if complex regulation is the only way to protect the Australian public from raining aluminium,

Why are foreign aircraft, who's regulators have less onerous less complex regulation, permitted to fly into and out of Australia. Surely they are a risk to the safety of the Australian public?

Heard a rumour that CASA is attempting to influence ICAO around to their way of thinking.

Good luck with that, other countries actually value their industries.

[Peetwo]

McDolittle promises to do something with 20/20 Inquiry -   

Via EWH on the Yaffa:

---

 

GA Inquiry to go ahead Despite Lockdowns
6 August 2021
Comments 0 Comments

The Senate Standing Committee on Rural and Regional Affairs and Transport (RRAT) inquiry into the state of general aviation in Australia will go ahead despite being frustrated by a string of COVID lockdowns.

A lack of progress in the inquiry, which is bound to issue a final report in December this year, has many in the GA community believing the inquiry will produce nothing of any substance.

Committee chair Senator Susan McDonald from Queensland told Australian Flying this week that she shared the concerns but the inquiry would go ahead.

"I am equally frustrated at the lockdowns, which unfortunately have disrupted so many senate inquiries," she said.

"The aviation inquiry hearings will still go ahead but it’s likely many witnesses will have to give evidence via video conferencing. I realise this is not ideal, but it’s important that we still hear evidence and pursue the aims of this inquiry."

At this stage there are eight proposed hearing dates scheduled, but are subject to the rapidly-changing COVID situation around the country. The hearing program is:

• Wagga Wagga  6 September  
  
  
• Alice Springs    7 September  
  
  
• Darwin              8 September
  
  
• Rockhampton  16 September
  
  
• Toowoomba     17 September
  
  
• Hobart             29 September
  
  
• Sydney            30 September  
  
  
• Brisbane          1 October
  

Senator McDonald also said she was concerned about the low number of submissions from the GA community. At the time of writing, only 54 submissions had been lodged. The Aviation Safety Regulation Review (ASRR) conducted in 2014 attracted 269 submissions.


"I have to say I’m disappointed at the lack of submissions from aviators regarding their concerns," she said. "I understand the reluctance of many to give public evidence but I can assure them they will be doing it in a neutral environment.

"It’s crucial that we get as many points of view as possible to ensure we have a successful and thriving aviation industry now and into the future."

"I encourage anyone with an interest to lodge a submission."

Submissions can be lodged on the RRAT inquiry website.

---

MTF...P2 

[Sandy Reith]

Well fair dinkum Susan McDonald, please excuse a little frustration here. Yes your 54 submissions versus 269 of the 2014 Forsyth review doesn’t look like there’s much enthusiasm for your inquiry.

Sit back and ask yourself why?

Look at it another way, there’s not been any progress away from the ever more stultifying and fee gouging trajectory by the out of control regulator emanating from any of the inquiries since 1988. With much hope and with the firepower of David Forsyth, and his very well qualified fellow members, General Aviation was galvanised into action believing that there would be reforms to relieve GA, stop the rot, and even put us back on a path to growth. Result? nothing but more of the same and worse, ask Glen Buckley, or any of the GA businesses being evicted from their hangars at Moorabbin.

Dear Senator, question; have you read all 269 submissions to the Forsyth inquiry? May I suggest you add those submissions to you 54 and now you have 353 submissions.

You might understand that all this free work contributed by GA business people has to be prepared by them when they are already overworked with mountains of unnecessary CASA paperwork and having to pay for new and unnecessary permits. Then you ask them to do it all again; but what has changed since Forsyth? Fewer people left, regulations worse see Part 61/141/142 (just for starters) and 135 coming to wreck even more GA businesses and reduce the aerial services, especially to your outback residents.

Why did they spend umpteen hours writing all these reports for you and Forsyth?

To help government through what should be the extremely obvious, not forgetting that we employ via our taxes through the government’s own ‘experts,’ CASA, to advise on the efficient means to have a sustainable GA industry. To an industry being crushed by the very government body that should be helping it and you ask why aren’t you getting more submissions?

One could be forgiven for a lapse into cynicism, hopes dashed again and again because there’s not been one government MP stand up for GA and demanding action now.
But we keep on hoping and you gave hope to me, one example, during one of your sessions you understood that there was great difficulty for helicopter pilots to obtain their regular flight checks as required by CASA. In session you, impressively, made to ask CASA to rectify this glaring wrong. Well, what has happened?

And now we read the latest Statement of Expectations (SOE), obviously written by CASA or at least for the CASA brethren, signed off with indecent haste minutes before Barnaby Joyce took over from M. McCormack, with not one concrete requirement. And yes motherhood is a wonderful institution.

Give us some runs on the board immediately, it’s easy if you can persuade Barnaby. He can change the SOE requiring some exemplary reforms within the next two or three weeks. Independent instructors, private pilot medicals in line with the low weight category (car driver), cancel Cessna SIDs for private operations. Then have Barnaby talk to Peter Dutton and implement the Forsyth recommendation and remove the expensive and ineffective ASIC two yearly imposition and call a moratorium on the further alienation of airport land away from aviation uses.

Give us some real hope and be a hero to thousands of dinkum Aussies who will support you to the hilt.

Kind regards, Sandy Reith.

[P7_TOM]

McDolittle and the gilded Lily.

Or, Wanna dance - then face the music.........

"I have to say I’m disappointed at the lack of submissions from aviators regarding their concerns," she said. "I understand the reluctance of many to give public evidence but I can assure them they will be doing it in a neutral environment.

BOLLOCKS~!


"It’s crucial that we get as many points of view as possible to ensure we have a successful and thriving aviation industry now and into the future."

BOLLOCKS~!

The story so far reads something like this - (horse's vocabulary being limited). McDoNought pulled McDolittle aside and said, something like "present as many recommendations as you will - but my CASA will not, nor is it required to accept any one of 'em". "In fact they will not; not on my watch".

McDolittle then scampered back to a position where she was playing for those poor sods in the NT and FNQ; but - Spence got the guernsey - as part of the gracious withdrawal.

Now, BJ is back; and, suddenly, the politician is playing merry hell because no one had any more faith (being politically more attuned than she) and decided not to waste any more time and effort - flogging a dead horse'.

If, and it is a big IF, McDolittle wants now to revitalise her pointless, non productive, two long years of doin' nuthin' then she only has to refer to the Forsyth recommendations and make bloody sure that they are made 'the' corner stone of the reform which MUST happen.

Playing hell because no one has any faith left in our 'politicians' is the ultimate straw - we have tried for three decades; tried hard for justice, rule of law and a reasonable chance of not getting a criminal record for a log book error. The Senator must know by now that CASA is a complete shambles, an expensive wart attached to the industry, endlessly growing, endlessly costing more; endlessly making mock of an industry which should be flourishing. Commit to setting this to rites and industry will back you - otherwise - just another politician - full of piss and wind - signifying NOTHING.

Dear Senator - either piss in the pot or get off it - two choices - no options. It is 'disappointing' (in the extreme) to see that an elected Senator can be 'persuaded' to back off, in self interest against the hopes of an essential industry at breaking point. No matter; hope the continued salary and 'ready acceptance' as being an easily manipulated part of the 'system' helps you sleep at night alongside zero credibility. Too little - too late, too much damage to repair perhaps? Credibility = Zero.

So say the BRB (unanimous)..

[Wombat]

With the greatest respect to the august and venerated members of the BRB, I wish to point out that you have failed to take into account Einstein’s theory of Relativity.

Not Albert Einstein, but Fred Einstein at the Steam Packet Hotel. His immortal theory; “ a moment with your backside on a hot stove seems to last forever while the same time in a session with Flo on the couch seems to last only a few seconds”.

CASA, the Department and politicians do not count time in days and months like mere mortal pilots, nor business owners who reckon in financial years, no, they reckon time in ‘Parliaments”. By that relative clock, it is already too late to reform anything because the next election is due soon.

Members may know that if there is a change of Government at that time, all working papers, briefs and suchlike are hoovered up and put into storage for the statutory thirty years. So your new Minister starts with a completely blank slate apart from published, public documents. All the dirt has been swept under the rug. The new Minister arrives literally knowing nothing about what went before.

So the Minister, CASA and the Department are playing for time. Forsyth is a Parliament ago. Shortly it will be irrelevant ancient history. Same with Glen Buckley, Jabiru, Bristell and goodness knows what else. They are lost in the mists of time. This is especially so if we play fast and loose with the public records act - critical documents, usually incriminating ones that explain who knew what and when, seem to vanish. 

Being cynical, the role of a good public servant can ensure that the Minister doesn’t find the dirty linen until the next election. This is not too hard since the Minister needs at least two years to learn his job and the last year is spent with an eye on elections…

So all CASA and the Department have to do is to deny, obfuscate and delay for about another six months and we all start again from square one. Bristell, Buckley, Jabiru, AMROBA, AOPA, etc.will have to start again to try and educate a deliberately clueless Minister.

……..and next time there is an enquiry or review there will only be 25 submissions.