[Kharon]

GD – “[but] you have the knowledge and ability to make changes, or do you?”

It’s more a question of willpower and interest; the advice will be dribbling, muted and placatory. What Turnbull needs to see is the benefits a healthy aviation industry provides; jobs, not for pilots, but for coffee shop staff, apprentices, car hire, fuel, maintenance, tradesmen to refurbish business premises, etc.  With just a little imagination, a revitalised, profitable industry could be created.  Tourism, training, the list is long.  BUT until there is meaningful reform – as per the Rev Forsyth – an investment in aviation, or support industry makes no fiscal sense, the time constraints and regulatory compliance burden make it too easy for the ‘money’ to shop elsewhere.

RIP Forsyth report; close but no cigar.  No matter, the three stooges are all ‘match-fit’ and wearing their courage badges as ‘G’ strings at the local gabfests.  

No doubt, the problems will all be solved in a thirty minute Estimates session next week; can’t wait.

[Peetwo]

KC & the AMROBA Band - Latest newsletter

A how to set the Forsyth review report & recommendations in stone...

1. Implementing permanent change

Without doubt, there has been almost unanimous support in the aviation industry for the recommendations of the ASRR report. The government and industry obviously support these recommendations, so when will the Department of Infrastructure & the CASA Board initiate changes to the Civil Aviation Act to implement these recommendations permanently? The Board and Infrastructure must recommend changes to change the regulatory style.


The Act must be amended to implement the government supported ASRR recommendations.

The Act was rushed together to create the CAA back in 1988 and has a series of ad hoc amendments. NZ realises that after 20 years, the Act should be reviewed so when will Australia set up a review of the Act against international treaties and applicability to the current aviation industry.

CASA & aviation continually have review after review with no permanent result – regulatory review has been under way since the formation of the CAA in 1988. The rest of the aviation world are modernising their requirements utilising performance based regulations & standards and utilising a risk based approach. The USA are well ahead of Australia as we implement draconian requirements of the past. Changes must happen.

Many businesses that have spanned a few regimes of CASA and its predecessors, are not confident that permanent change will happen until the government support and direction to the CASA Board & DAS is given legislative support in the Act. We need a DAS reportable to the Board and a Board reportable to the Minister. The Board must be held fully accountable.

Act – Duties (1) The Director is to manage CASA subject to the directions of, and in
accordance with policies determined by, the Board.

Subject to the directions of, and iaw policies determined by the Board.

For the Board to direct and provide policies to implement the government ASRR recommendations, then they need to recommend a review of the Act, especially the following sections of the Act:

Sec 3A - [i]Main object of this Act[/i]

The main object of this Act is to establish a regulatory framework for maintaining, enhancing and promoting the safety of civil aviation, with particular emphasis on preventing aviation accidents and incidents.

Compare with NZ who are also reviewing their Act: While the [NZ] Act is fundamentally sound, the Act is over 20 years old and during this period there have been a number of changes in the aviation industry. The Ministry wants to make sure the Act promotes a responsive regulatory system to support a dynamic aviation sector.

[NZ] Objectives of Minister

The objectives of the Minister under this Act are—

(a) to undertake the Minister's functions in a way that contributes to the aim of achieving an integrated, safe, responsive, and sustainable transport system; and (b) to ensure that New Zealand's obligations under international civil aviation agreements are implemented.

NZ is reviewing their Act after 20 years and we have had no review after 27 years.

Sec 9 CASA’s functions

(1) CASA has the function of conducting the safety regulation of the following, in accordance with this Act and the regulations:

© developing and promulgating appropriate, clear and concise aviation safety standards;

The ASRR clearly identified that this provision should be clarified; consistent with the Convention, compatible with other major NAAs, including NZ.

In AMROBA’s opinion, CASA has never promulgated “clear and concise aviation safety standards ” under this provision of the Act. All current “standards” are issued under the Regulations.

All future “standards” should be made under the Act and undergo full Parliamentary oversight.

Sec 20AB Flying aircraft without licence etc.

Provision in this section is seen as supporting prescriptive regulations – needs to be modernised.

(2) A person must not carry out maintenance on:

(a) an Australian aircraft; or

(b) an aeronautical product in Australian territory; or

© an aeronautical product for an Australian aircraft; if the person is not permitted by or under the regulations to carry out that maintenance.

The word “that” can be interpreted very narrowly.

Sec 98 Regulations etc.

(1) The Governor-General may make regulations, not inconsistent with this Act:

(a) prescribing matters required or permitted by this Act to be prescribed;

(b) prescribing matters necessary or convenient to be prescribed for carrying out or giving effect to this Act;

© for the purpose of carrying out and giving effect to the provisions of the Chicago Convention relating to safety;

(d) in relation to safety of air navigation within a Territory or to or from a Territory;

(e) in relation to safety of air navigation, being regulations with respect to trade and commerce with other countries and among the States; and

(f) in relation to safety of air navigation, being regulations with respect to any other matter with respect to which the Parliament has power to make laws.

Compare with the FAA responsibilities for minimum standards.

USA Title 49. Sec. 44701. General requirements

(a) Promoting Safety. - The Administrator of the Federal Aviation Administration shall promote safe flight of civil aircraft in air commerce by prescribing -

(1) minimum standards required in the interest of safety for appliances and for the design, material, construction, quality of work, and performance of aircraft, aircraft engines, and propellers;

(2) regulations and minimum standards in the interest of safety for -

(A) inspecting, servicing, and overhauling aircraft, aircraft engines, propellers, and appliances;

(B) equipment and facilities for, and the timing and manner of, the inspecting, servicing, and overhauling; and

© a qualified private person, instead of an officer or employee of the Administration, to examine and report on the inspecting, servicing, and overhauling;

(3) regulations required in the interest of safety for the reserve supply of aircraft, aircraft engines, propellers, appliances, and aircraft fuel and oil, including the reserve supply of fuel and oil carried in flight;

(4) regulations in the interest of safety for the maximum hours or periods of service of airmen and other employees of air carriers; and

(5) regulations and minimum standards for other practices, methods, and procedure the Administrator finds necessary for safety in air commerce and national security.

The concept that CASA has to create regulations and standards without stating they should be the minimum regulations and standards is a major reason why regulatory reform is treated as regulatory development by CASA staff.

The above are but a few examples – a complete review is warranted.

MTF...P2

[Gobbledock]

Full marks to De Stoop. The man has integrity, balls, and isn't afraid to show the world the true state of play. One can only wish that sort of strong respected leadership was in play years ago, back when corporate kiss arses as well as weak and arrogant batty boys were running AOPA, ain't that right Lookleft?

I like how De Stoop also isn't afraid to 'out' the reason, or at least one reason, why reform keeps getting scuttled - long term bureacratic survivors who have overstayed their welcome for far too long and ensured that the Iron Ring survives.Nice work Mark, diplomatically worded and succinctly put. Not something the Gobbledock could do!

It's funny how the Forsythe review, a catalyst for change, has been buried and cremated. Yet whenever the Governments authorise other reviews on things such as tax reform, unions, anything they actually want to change, they use a review to start the ball rolling and they make changes pretty quickly! The buried Forsythe review is proof that the Miniscule wants no change whatsoever. Shame on you, you out of touch, prehistoric numbnut.

You want to get shit done boys? Then it has to be Fawcett as Junior Minister for Aviation, Manning empowered at ATsB and Beaker and his lapdogs punted, Boyd empowered at CAsA with Dr Voodoo and Skid'Mark gone and Mike Smith brought in, and ASA's Harfwit, Sir Anus and some additional dipshits punted as well, and then an international candidate brought in. No more spin doctors, egomaniacs or lickers of the Miniscules ring piece.

It's actually a small list, only a handful of changes, but changes that would make a massive difference.

TICK TOCK Malcolm, if you allow this dangerous game and the decline in aviation to continue it will take more than a fat bank account and the ability to make middle aged female voters moist to save your ass if a smoking hole occurs......just sayin.

[Kharon]

Nice one GD – (CF) it’s truly amazing, although not surprising (not anymore) the way SS CASA just keeps rolling along, untroubled by the outside world. No matter who or what tries to alter the course – the wheelhouse door is securely bolted and well protected. Perhaps it’s time the ‘opposition’ combined into an overwhelming force. Aircraft carrier Senate, Destroyer Board, Frigate AOPA and the battleships of AIPA, VIPA, AMROBA, RAAAA, in flotilla to blast the bloody thing out of the water, before it reaches final destination – utter catastrophe.

Toot toot.

[Gobbledock]

Ferryman;

"Perhaps it’s time the ‘opposition’ combined into an overwhelming force. Aircraft carrier Senate, Destroyer Board, Frigate AOPA and the battleships of AIPA, VIPA, AMROBA, RAAAA, in flotilla to blast the bloody thing out of the water, before it reaches final destination – utter catastrophe".

A robust flotilla indeed sir. But no such fleet would be complete without it's humble Houseboat at the flank, Captained by Kharon with the Gobbledock stoking the boiler room.
And I insist that no RAAF or Navy types be involved, and certainly no shitty Collins submarines either (mind you they will all be busted and sitting in dry dock).
The above flotilla could launch multiple marine sorties, and fire off unlimited rounds of pineapples and pooh torpedoes, climaxing in the destruction of an enemy that has been harder to to destroy than the Viet Cong. Actually the Viet Cong used to hide in the US Army's latrine trenches, in all that putrid shit and then bayonet an unsuspecting US soldier as he sat on the crapper and pinched one off. A large blade right through the sphincter! It certainly does remind me how some at CAsA have operated for many decades!

Tick tock

[Peetwo]

KC & the AMROBA Band - Latest newsletter

A how to set the Forsyth review report & recommendations in stone...

1. Implementing permanent change

Without doubt, there has been almost unanimous support in the aviation industry for the recommendations of the ASRR report. The government and industry obviously support these recommendations, so when will the Department of Infrastructure & the CASA Board initiate changes to the Civil Aviation Act to implement these recommendations permanently? The Board and Infrastructure must recommend changes to change the regulatory style.


The Act must be amended to implement the government supported ASRR recommendations.

The Act was rushed together to create the CAA back in 1988 and has a series of ad hoc amendments. NZ realises that after 20 years, the Act should be reviewed so when will Australia set up a review of the Act against international treaties and applicability to the current aviation industry.

CASA & aviation continually have review after review with no permanent result – regulatory review has been under way since the formation of the CAA in 1988. The rest of the aviation world are modernising their requirements utilising performance based regulations & standards and utilising a risk based approach. The USA are well ahead of Australia as we implement draconian requirements of the past. Changes must happen.

Many businesses that have spanned a few regimes of CASA and its predecessors, are not confident that permanent change will happen until the government support and direction to the CASA Board & DAS is given legislative support in the Act. We need a DAS reportable to the Board and a Board reportable to the Minister. The Board must be held fully accountable.

Act – Duties (1) The Director is to manage CASA subject to the directions of, and in
accordance with policies determined by, the Board.

Subject to the directions of, and iaw policies determined by the Board.

For the Board to direct and provide policies to implement the government ASRR recommendations, then they need to recommend a review of the Act, especially the following sections of the Act:

Sec 3A - [i]Main object of this Act[/i]

The main object of this Act is to establish a regulatory framework for maintaining, enhancing and promoting the safety of civil aviation, with particular emphasis on preventing aviation accidents and incidents.

Compare with NZ who are also reviewing their Act: While the [NZ] Act is fundamentally sound, the Act is over 20 years old and during this period there have been a number of changes in the aviation industry. The Ministry wants to make sure the Act promotes a responsive regulatory system to support a dynamic aviation sector.

[NZ] Objectives of Minister

The objectives of the Minister under this Act are—

(a) to undertake the Minister's functions in a way that contributes to the aim of achieving an integrated, safe, responsive, and sustainable transport system; and (b) to ensure that New Zealand's obligations under international civil aviation agreements are implemented.

NZ is reviewing their Act after 20 years and we have had no review after 27 years.

Sec 9 CASA’s functions

(1) CASA has the function of conducting the safety regulation of the following, in accordance with this Act and the regulations:

© developing and promulgating appropriate, clear and concise aviation safety standards;

The ASRR clearly identified that this provision should be clarified; consistent with the Convention, compatible with other major NAAs, including NZ.

In AMROBA’s opinion, CASA has never promulgated “clear and concise aviation safety standards ” under this provision of the Act. All current “standards” are issued under the Regulations.

All future “standards” should be made under the Act and undergo full Parliamentary oversight.

Sec 20AB Flying aircraft without licence etc.

Provision in this section is seen as supporting prescriptive regulations – needs to be modernised.

(2) A person must not carry out maintenance on:

(a) an Australian aircraft; or

(b) an aeronautical product in Australian territory; or

© an aeronautical product for an Australian aircraft; if the person is not permitted by or under the regulations to carry out that maintenance.

The word “that” can be interpreted very narrowly.

Sec 98 Regulations etc.

(1) The Governor-General may make regulations, not inconsistent with this Act:

(a) prescribing matters required or permitted by this Act to be prescribed;

(b) prescribing matters necessary or convenient to be prescribed for carrying out or giving effect to this Act;

© for the purpose of carrying out and giving effect to the provisions of the Chicago Convention relating to safety;

(d) in relation to safety of air navigation within a Territory or to or from a Territory;

(e) in relation to safety of air navigation, being regulations with respect to trade and commerce with other countries and among the States; and

(f) in relation to safety of air navigation, being regulations with respect to any other matter with respect to which the Parliament has power to make laws.

Compare with the FAA responsibilities for minimum standards.

USA Title 49. Sec. 44701. General requirements

(a) Promoting Safety. - The Administrator of the Federal Aviation Administration shall promote safe flight of civil aircraft in air commerce by prescribing -

(1) minimum standards required in the interest of safety for appliances and for the design, material, construction, quality of work, and performance of aircraft, aircraft engines, and propellers;

(2) regulations and minimum standards in the interest of safety for -

(A) inspecting, servicing, and overhauling aircraft, aircraft engines, propellers, and appliances;

(B) equipment and facilities for, and the timing and manner of, the inspecting, servicing, and overhauling; and

© a qualified private person, instead of an officer or employee of the Administration, to examine and report on the inspecting, servicing, and overhauling;

(3) regulations required in the interest of safety for the reserve supply of aircraft, aircraft engines, propellers, appliances, and aircraft fuel and oil, including the reserve supply of fuel and oil carried in flight;

(4) regulations in the interest of safety for the maximum hours or periods of service of airmen and other employees of air carriers; and

(5) regulations and minimum standards for other practices, methods, and procedure the Administrator finds necessary for safety in air commerce and national security.

The concept that CASA has to create regulations and standards without stating they should be the minimum regulations and standards is a major reason why regulatory reform is treated as regulatory development by CASA staff.

The above are but a few examples – a complete review is warranted.

Sky Wars - The Force awakens - GA uprising?? Bring it on! 

 {Hint 4 Boyd: This bloke/roadblock needs to be escorted from the building ASAP}

From off the Oz this AM it would appear the troops are mobilising finally

CASA reforms: Rex says Order 48.1 wll force routes to close  

by: STEVE CREEDY
From: The Australian
November 06, 2015 12:00AM




Rex chief operating officer Neville Howell says CAO 48.1 if implemented would cost Rex more than $4m a year. Source: Supplied

Regional Express has warned that new rules about flight time limitations will cost it more than $4 ­million annually and could make some routes unviable as angst about regulatory reforms continues to spill out into the public arena.  

In a strongly worded letter sent to Civil Aviation Safety Authority boss Mark Skidmore earlier this year, Australia’s biggest independent regional carrier warned that Civil Aviation Order 48.1 was seriously flawed and was introduced with no real representation from regional aviation.

It also argued the new rules did not meet a directive issued by Mr Skidmore calling for regulatory changes must be shown to be necessary as well as justified on the basis of safety, do not impose unnecessary costs of hinder participation in aviation and its capacity for growth.

“The new prescriptive rule sets of CAO 48.1 if implemented would cost Rex over $4 million annually,’’ the letter from Rex chief operating officer Neville Howell said. “The impact on the 5 Queensland regulated routes that Rex services would represent an additional cost in excess of $2.25 million annually for transporting only some 30,000 passengers a year. This impost would need to be passed to the passenger and would effectively render the service untenable, and would close the services to these remote and isolated communities who depend heavily on the access they receive for medical, legal, government and social activities.”

The letter emerged after aviation groups last week called for an industry task force to deal with the continuing damage caused by regulatory and urged CASA to withdraw CAO 48.1.

Umbrella group The Australian Aviation Associations Forum expressed concern at the slow pace of reform and the ongoing cost of new impositions from new regulations.

The forum warned that recently introduced CASA regulations were threatening the viability of the industry, particularly general aviation, with millions of dollars needed to be invested with no particular safety gains.

It singled out CAO 48.1 and parts 61 (pilot licensing), 141 (recreational, private and commercial pilot training) and 142 (integrated and multi-crew pilot training and checking) as areas which needed urgently addressing.

Industry players gearing up their campaigns for the next federal election subsequently cautioned CASA not to ignore the TAAAF call.

Regional Aviation Association of Australia chief executive Paul Tyrrell said regional airlines had urged Mark Skidmore to ­accelerate the authority’s reorganisation.

“We were trying to inject a sense of urgency I guess into the CASA hierarchy about what we see as some of the low-hanging fruit from the Forsyth Review,’’ he said.

Aerial Application of Association of Australia head Phil Hurst said the communique was a plea for help.

“It is a genuine heartfelt concern for the welfare of an industry that has been damaged directly by CASA regulations,’’ he said.

“The problems currently experienced with firefighting training are a direct result of poor planning and appalling implementation of regulations.

“The best way forward is to get fresh eyes from industry to identify practical exemptions and amendments to address the very real ­issues.’’

The Australian Helicopter Industry Association is advising its members to withdraw their applications to protest “the administrative burden, financial penalties and lack of progress with applications for parts 141, 142 & 145 (maintenance) certificates’’.

The AHIA is particularly concerned about the high cost — sometimes more than $100,000 — its members are paying for documentation and what it says is confusion among CASA personnel about parts 141 and 142.

“It is like trying to find a road across a desert in a dust storm; like the shifting sands, the constantly shifting guidelines make the way forward impossible,’’ AHIA vice-president Ray Cronin said.

“As a result, the AHIA is recommending its members and others in the helicopter community bunker down and withdraw their parts 141, 142 & 145 applications until such time as CASA is able to provide completed templates for the industry to use in the application process.’’

Aviation Maintenance Repair and Overhaul Business Association executive director Ken Cannane said the proposals should be dropped in favour of a system based on the US Federal Aviation Administration regulations.

Mr Cannane said general aviation design, manufacture and maintenance had all suffered from the inability of CASA to maintain pace with the modernisation of the FAR system that once underpinned general aviation in Australia.

He said general aviation supported the FAR system and AMROBA believed the current system was unworkable. The CASA board needed to urgently move towards a FAR-based system for the sector.

“Since the commencement of the CAA in 1988, the industry has promised reforms to reduce red tape and regulatory requirements to enable improved safety and productivity,’’ Mr Cannane said.

“However, like all other associations, all we have seen is the opposite happen as regulatory reform has been changed to ­regulatory development resulting in increased red tape and ­requirements.

“CASA has ignored governments’ regulatory reform best practice guidelines for over a decade.’’

CASA has said it was actively consulting with the aviation community on a range of issues and this would continue. Changes had also been made to rules to address particular issues such as firefighting operations, it said.

From the Prez De Stoop.. :



{Hint 4 Boyd & the Board: This guy needs to be escorted into the building ASAP - https://www.linkedin.com/pub/mike-smith/2/595/785}


Mike Smith

Civil Aviation & Regulatory Program & Operations Auditing



MTF?- Definitely P2

[Kharon]

Good catch P2.



I just love it that Skidmore has gone on holiday; amidst all the misery, expense and aggravation – he buggers off to ‘relax’.  Anymore relaxed he'd be comatose.  He’s left dear old Johnathan in charge of the asylum and the when the cats away, the catamites will play.

Perhaps the short break is a prelude to a much longer break – (another pagans prayer).  Time for the long knives to be drawn – on both sides.  I doubt, without being rude, the various associations could put the problems any plainer – it’s plain enough to all except the denizens of ‘Sleepy Hollow’; the business as usual sign is still hanging.

There’s a gale blowing through the government departments, stripping away red tape and locked doors – does this bother CASA?  not a bit.  No doubt JA has a perfectly logical, legal argument which says that they, CASA, are above the law and not really, except when it suits, (as in pay scales, negotiated by Slydmore no less) public servants.  Ducking idiot penning missives about pay for the casamites, but nary a word about real reform, Forsyth (except to denigrate it), the bastard 61, the inutile 48.1 or any of the other piecemeal clap-trap foisted on industry.

Please Minister – back Boyd and the Board to the hilt.  Then we can we have shut of the CASA top 10 and replace them all with one Mike Smith and a real ‘tiger team’.  

Go on Warren, you know you want to, dontcha.  Barnaby would back it and the PM would love it.  Go on you mug, have a go, for the country.  Just once do something worthwhile, you may even enjoy it.

Toot toot.

[Gobbledock]

Of new blood, old dross, and 1980's mind sets

Some succinct articles posted this morning;
• AMROBA - 4 chocolate frogs
• P2 - 3 chocolate frogs
• Creepy - a half eaten chocolate frog
• Kharon - 1 chocolate frog
• Bonus frog - for the picture of Mike Smith, our saviour.

Love this bit;

"The Act must be amended to implement the government supported ASRR recommendations.
The Act was rushed together to create the CAA back in 1988 and has a series of ad hoc amendments. NZ realises that after 20 years, the Act should be reviewed so when will Australia set up a review of the Act against international treaties and applicability to the current aviation industry".

Ditto. The Act is shite, and will remain shite until it is stripped down and re-engineered.
The road to reform starts right there. That is your money shot - The Act. All this strict liability bullshit that is even printed on CAsA's toilet paper must go. Dr Voodoo lives for this prehistoric mind dumbing punitive draconian revolution inspiring horse pooh.

Let me put on my 'glass half full' specs for a moment. ASA has had a partial enema - Staib gone. CAsA has had a partial enema - Skull, P.Boyd, Pooh-sham, Farkwitson, Ferret'a'day, and some old Board dross has gone. Tick in the box number 1. Then some New blood - Forsythe's rise in respect, the hiring of Manning (ASA) and Boyd (CAsA), and no, not that bald headed Gerbil P.Boyd. Tick in the box number 2.

However the framework is rooted, and more parasites need to go, the ones who have used The Act as well as strict liability to pineapple thousands of aviators. It's time for a real blood-letting. That is where the final enema comes in - MrDak, the Witchdoctor, Beaker, Sir Anus, as well as the Harfwits and the Wodgers.
SHORT TERM PAIN FOR LONG TERM GAIN.

And a letter to Malcolm in the Middle;

Dear Prime Minister,

Your aviation portfolios have reached crisis point. If afforded the opportunity most of industry would put in a resounding vote of 'no confidence' in your Deputy PM, his Secretary, the heads of the three aviation portfolios, the practices of these portfolios and the untenable system we are forced to work within.

Mr Turnbull, you are pushing for red tape reduction yet you are allowing the aviation industry to be bogged down even more. I would suggest you listen to people like REX who have told you point blank that the unworkable palpable regulatory changes will cost them $4 million annually, and they may have to pull out of regional areas of Australia. Do you really want to take that sort of trouble to an election? This is just one example.

Prime Minister, YOU are responsible for aviation, from a safety to a business perspective. I would suggest you take a break from listening to 'dipshits' for once, and instead you should call a 4 hour love-in, in your board room, and invite Forsythe, Dick Smith, Fawcett, and one or two other trustworthy and knowledgeable experts. Let them tell you the real state of play. It's time for you to step outside the circus tent.

Kind regards
P_666

TICK TOCK MALCOLM TICK TOCK

[Sandy Reith]

From Stan an email with the following:-
International Covenant on Economic, Social and Cultural Rights
PART III

Article 6

1. The States Parties to the present Covenant recognize the right to work, which includes the right of everyone to the opportunity to gain his living by work which he freely chooses or accepts, and will take appropriate steps to safeguard this right.

and 2. The steps to be taken by a State Party to the present Covenanti to achieve the full realization of this right shall include technical and vocational guidance and training programmes, policies techniques to achieve steady economic, social and cultural development and full and productive employment under conditions safeguarding fundamental political and economic freedoms to the individual.

Stan adds "An instructor is either qualified or not. No flying school certification will change that."
This also goes to the message that government does not give us the privilege to fly, neither is it a privilege to make a living from it and we must change our conditioned thinking, realise and admit to being brainwashed by past outdated thinking.

Next step is to demand that the Board agree to removing all mention of privileges from the rules. This throws off the notion of an elite government that hands down privileges to the lowly subjects below. We must establish the principle of our right and freedom to fly, simple rules like road rules.

Until and unless the CASA Board decides to create simple rules and stops treating us like a bunch of untrustworthy criminals then trust or respect to anyone in the top echelons of CASA will not be forthcoming.

Until and unless our minimum demands are met no more talking. The waste of time and money must stop. AMROBA is clear and sensible. The collective mindset of us all is focused on how to improve, not just revert to old rules. Its now plain to see what needs to happen, the Board must take control. It must instruct Mr Skidmore to institute some basic reforms immediately. Government must understand that it cannot crush a whole industry through neglect, lack of oversight, poor policies without repercussions.

"Privileges" out. Independent instructors. Independent LAMES. PPL car driver medical. NOW.

[Peetwo]

OBS?- Nurse take that man's OBS  

A bit of commentary on Oliver's Bollocks Survey:

P9 - Embrace the parallel universe – it’s here to stay.

P2 proposal - That said I'm personally not concerned about revealing my IP (if they want it they can more than likely get it anyway), so I propose to regurgitate said survey on here  & we can then respond to it collectively - with additional answers/etc. - take the piss and send in with a link to the 269 ASRR submissions on a PAIN email?- My proposal, other suggestions welcome.

My personal sentiments mirror pretty much those of Thorny & Gobbles..  I would add that is a bit rich for the IOS to assess CASA as per ASRR R8, when Skidmore & co have effectively done nothing but have talkfests etc. ever since Truss called for the implementation of pretty much all of the Rev Forsyth's report recommendations. 

Nope just another cynical attempt to assuage the miniscule direction - FFS!  

Hmmm.. Now that's embarrassing, of the 7 responses in over a month 4 of them are actually from CASA Admin.

Maybe it’s me that’s got this arse about.  Here we have a ‘safety’ regulator, caught with their pants down, paws in the cookie jar and a three decade long rap sheet.  This proven, beyond a reasonable doubt, by the Senate in Parliament, confirmed by an independent panel of experts, the results delivered to a Minister of the Crown.  All insisting on immediate, full scale, no holds barred reform of the REGULATOR - not the bloody regulations.  This reform demanded by the industry which supports the regulator.  Seems to me that in the face of overwhelming odds, the least the regulator could do is embrace the changes and attempt to pacify the paymaster.

It’s not as if it was just a mild suggestion – it was a clear directive for major, sweeping changes to the REGULATOR; - not the blasted regulation - both immediate and urgent.  Do CASA set about making the changes requested and required? – No, they do not.  Instead in typical cynical, underhand style a new coat of wax is added to the rusted mudguard – in just the same way that brought about the directive for reform.  The methodology applied is exactly the same as that which earned CASA the censure of the Senate and industry.  It’s piss-potical, dishonest and states clearly that no matter what – the regulatory leopard will not change it’s spots.

This dreadful survey is, rightfully, being boycotted for what it is – a perceived compliance with the minimum requirement – not a whole hearted attempt at reform.  The 'survey' makes several assumptions, which imply that the regulator is reformed and the new law is acceptable - neither is true.  CASA just don’t seem to get it – they are the problem – not the ducking solution. Everyman and his dog, from the Minister down can see it, the international community can see it, hells bells my giddy Aunt can see it – and yet CASA persist in the fantasy.  

Clean ‘em out Malcolm, before they return to the self righteous complacency which landed them in the crap in the first instance.  Bugger the regulations – REFORM CASA – the regulations will take care of themselves after that.

Aye, no doubt I’ve got the bull by the tits again, but if anyone else, apart from Slymore, believes that puerile, trite, little, one way, loaded survey is going to achieve anything but derision and disgust, let me know, so that I too may see the light and embrace life in a parallel universe.

Selah.

HL - "..I have the smallest shred of regret at starting this thread. Of particular regret is the choice of title.

Would "DAS IV: A new hope" have been more apt?

...but as others have said, hope springs eternal.

Let's all make sure we make a measured but consistent response to the survey they have asked us to complete. I wait for the results with interest.." 

&.. a voice of sanity from Frank - "..Yes it should be measured and consistent with the Forsyth Review.

I'm still waiting for the results to be implemented from that survey. Can't see what re-submitting anything will do except annoy them further. ."

I am of Frank's view i.e. it is all in the Forsyth review. How can we expect to give anywhere near and accurate assessment until that survey is fully implemented and compliant with the Minister of the Crown's FULL direction - FFS   
However if for no other reason but curiosity, let's have a look at the OBS -

Courtesy AHIA off the UP..

Measuring CASA's performance ─ aviation community survey

---

Message forwarded from CASA to AHIA (and others).

CASA is listening to the aviation community and we need your help to find out more.

I encourage you to complete our survey, which can be accessed from the homepage of the CASA website, or by visiting:

www.casa.gov.au/MOP


This activity is a key part of CASA’s response to the Aviation Safety Regulation Review, which recommended CASA conduct industry surveys every two years to measure the health of the relationship.

We are keen to find out what you think about your interactions with us and measure our performance over time. In particular, we want to learn more about your experiences in complying with and understanding the regulations, applying for and renewing licences, as well as being audited.

This information will provide a benchmark, so that we know where we have to focus our efforts to strengthen the relationship.

Please forward this email to your colleagues and friends in the aviation community so that their views can also be considered.

Thank you for sharing your views.

Mark Skidmore AM
Chief Executive Officer and Director of Aviation Safety

TBC..P2

[Peetwo]

OBS?- Nurse take that man's OBS  

A bit of commentary on Oliver's Bollocks Survey:

P9 - Embrace the parallel universe – it’s here to stay.

P2 proposal - That said I'm personally not concerned about revealing my IP (if they want it they can more than likely get it anyway), so I propose to regurgitate said survey on here  & we can then respond to it collectively - with additional answers/etc. - take the piss and send in with a link to the 269 ASRR submissions on a PAIN email?- My proposal, other suggestions welcome.

My personal sentiments mirror pretty much those of Thorny & Gobbles..  I would add that is a bit rich for the IOS to assess CASA as per ASRR R8, when Skidmore & co have effectively done nothing but have talkfests etc. ever since Truss called for the implementation of pretty much all of the Rev Forsyth's report recommendations. 

Nope just another cynical attempt to assuage the miniscule direction - FFS!  

Hmmm.. Now that's embarrassing, of the 7 responses in over a month 4 of them are actually from CASA Admin.

Maybe it’s me that’s got this arse about.  Here we have a ‘safety’ regulator, caught with their pants down, paws in the cookie jar and a three decade long rap sheet.  This proven, beyond a reasonable doubt, by the Senate in Parliament, confirmed by an independent panel of experts, the results delivered to a Minister of the Crown.  All insisting on immediate, full scale, no holds barred reform of the REGULATOR - not the bloody regulations.  This reform demanded by the industry which supports the regulator.  Seems to me that in the face of overwhelming odds, the least the regulator could do is embrace the changes and attempt to pacify the paymaster.

It’s not as if it was just a mild suggestion – it was a clear directive for major, sweeping changes to the REGULATOR; - not the blasted regulation - both immediate and urgent.  Do CASA set about making the changes requested and required? – No, they do not.  Instead in typical cynical, underhand style a new coat of wax is added to the rusted mudguard – in just the same way that brought about the directive for reform.  The methodology applied is exactly the same as that which earned CASA the censure of the Senate and industry.  It’s piss-potical, dishonest and states clearly that no matter what – the regulatory leopard will not change it’s spots.

This dreadful survey is, rightfully, being boycotted for what it is – a perceived compliance with the minimum requirement – not a whole hearted attempt at reform.  The 'survey' makes several assumptions, which imply that the regulator is reformed and the new law is acceptable - neither is true.  CASA just don’t seem to get it – they are the problem – not the ducking solution. Everyman and his dog, from the Minister down can see it, the international community can see it, hells bells my giddy Aunt can see it – and yet CASA persist in the fantasy.  

Clean ‘em out Malcolm, before they return to the self righteous complacency which landed them in the crap in the first instance.  Bugger the regulations – REFORM CASA – the regulations will take care of themselves after that.

Aye, no doubt I’ve got the bull by the tits again, but if anyone else, apart from Slymore, believes that puerile, trite, little, one way, loaded survey is going to achieve anything but derision and disgust, let me know, so that I too may see the light and embrace life in a parallel universe.

Selah.

HL - "..I have the smallest shred of regret at starting this thread. Of particular regret is the choice of title.

Would "DAS IV: A new hope" have been more apt?

...but as others have said, hope springs eternal.

Let's all make sure we make a measured but consistent response to the survey they have asked us to complete. I wait for the results with interest.." 

&.. a voice of sanity from Frank - "..Yes it should be measured and consistent with the Forsyth Review.

I'm still waiting for the results to be implemented from that survey. Can't see what re-submitting anything will do except annoy them further. ."

I am of Frank's view i.e. it is all in the Forsyth review. How can we expect to give anywhere near and accurate assessment until that survey is fully implemented and compliant with the Minister of the Crown's FULL direction - FFS   
However if for no other reason but curiosity, let's have a look at the OBS -

Courtesy AHIA off the UP..

Measuring CASA's performance ─ aviation community survey

---

Message forwarded from CASA to AHIA (and others).

CASA is listening to the aviation community and we need your help to find out more.

I encourage you to complete our survey, which can be accessed from the homepage of the CASA website, or by visiting:

www.casa.gov.au/MOP


This activity is a key part of CASA’s response to the Aviation Safety Regulation Review, which recommended CASA conduct industry surveys every two years to measure the health of the relationship.

We are keen to find out what you think about your interactions with us and measure our performance over time. In particular, we want to learn more about your experiences in complying with and understanding the regulations, applying for and renewing licences, as well as being audited.

This information will provide a benchmark, so that we know where we have to focus our efforts to strengthen the relationship.

Please forward this email to your colleagues and friends in the aviation community so that their views can also be considered.

Thank you for sharing your views.

Mark Skidmore AM
Chief Executive Officer and Director of Aviation Safety

Ok page 3 of the OBS:

Please rate how satisfied you are with the following aspects of CASA's performance on a scale of 0 to 10, where 0 is very dissatisfied and 10 is very satisfied.

1. Operates with safety as its primary focus
2. Is efficient in its dealings with you
3. Actively helps stakeholders comply with regulations
4. Is responsive to your needs
5. Provides timely responses to queries or requests for information
6. Maintains an open and transparent relationship with you
7. Is innovative and open to new ideas
8. Shares information & knowledge willingly
9. Provides competent & capable staff
10. Understands you/your business/organisation
11. Respects your confidentiality
12. Works collaboratively with industry
13. Strives for operational excellence
14. Makes it clear who you need to contact within CASA
15. Builds a relationship of trust with you
16. Is openly accountable for its actions
17. Treats all stakeholders fairly and with respect
18. Strives to minimise administrative costs & charges
19. Takes actions that are appropriate and in proportion to circumstances
20. Balances consistency and flexibility
21. Behaves with strength and courage

On a scale of 0 to 10, where 0 is ‘very difficult' and 10 is ‘very easy', how easy or difficult is it for you to fully comply with all aviation safety regulations relevant to your role or activities?


On a scale of 0 to 10, where 0 is ‘not at all confident' and 10 is ‘very confident', how confident are you in your ability to comply with all aviation safety regulations relevant to your role?

Please indicate your level of agreement with the following statements on a scale of 0 to 10, where 0 is strongly disagree and 10 is strongly agree.

1. Regulations covering my activities are easy to understand
2. CASA explains the regulations and how they affect industry stakeholders in a clear and succinct manner
3. I have a sound understanding of all regulations governing my aviation activities
4. CASA themselves have a sound understanding of the regulations governing my activities
5. I can easily interpret how regulations affect the way I operate
6. CASA inspectors have a consistent understanding of regulations and apply rules consistently
7. Regulations play a key role in ensuring I operate safely

 

On a scale of 0 to 10, where 0 is "never" and 10 is "always", please indicate how much of the time you believe you are demonstrating best practice in your aviation safety activities.

 
FFS enough!- To this point of the OBS the completion scale is at 18% and I am already over it.  

MTF...P2
{Ps I did try "K" but you were right I was at extreme risk of becoming comatose - I do like the box on the end of choices i.e. 'Don't Know' }

[Kharon]

BOLLOCKS -
Never ask a question unless you know the answer.


BOLLOCKS -

[Peetwo]

OBS?- Nurse take that man's OBS  

A bit of commentary on Oliver's Bollocks Survey:

P9 - Embrace the parallel universe – it’s here to stay.

P2 proposal - That said I'm personally not concerned about revealing my IP (if they want it they can more than likely get it anyway), so I propose to regurgitate said survey on here  & we can then respond to it collectively - with additional answers/etc. - take the piss and send in with a link to the 269 ASRR submissions on a PAIN email?- My proposal, other suggestions welcome.

My personal sentiments mirror pretty much those of Thorny & Gobbles..  I would add that is a bit rich for the IOS to assess CASA as per ASRR R8, when Skidmore & co have effectively done nothing but have talkfests etc. ever since Truss called for the implementation of pretty much all of the Rev Forsyth's report recommendations. 

Nope just another cynical attempt to assuage the miniscule direction - FFS!  

Hmmm.. Now that's embarrassing, of the 7 responses in over a month 4 of them are actually from CASA Admin.

Maybe it’s me that’s got this arse about.  Here we have a ‘safety’ regulator, caught with their pants down, paws in the cookie jar and a three decade long rap sheet.  This proven, beyond a reasonable doubt, by the Senate in Parliament, confirmed by an independent panel of experts, the results delivered to a Minister of the Crown.  All insisting on immediate, full scale, no holds barred reform of the REGULATOR - not the bloody regulations.  This reform demanded by the industry which supports the regulator.  Seems to me that in the face of overwhelming odds, the least the regulator could do is embrace the changes and attempt to pacify the paymaster.

It’s not as if it was just a mild suggestion – it was a clear directive for major, sweeping changes to the REGULATOR; - not the blasted regulation - both immediate and urgent.  Do CASA set about making the changes requested and required? – No, they do not.  Instead in typical cynical, underhand style a new coat of wax is added to the rusted mudguard – in just the same way that brought about the directive for reform.  The methodology applied is exactly the same as that which earned CASA the censure of the Senate and industry.  It’s piss-potical, dishonest and states clearly that no matter what – the regulatory leopard will not change it’s spots.

This dreadful survey is, rightfully, being boycotted for what it is – a perceived compliance with the minimum requirement – not a whole hearted attempt at reform.  The 'survey' makes several assumptions, which imply that the regulator is reformed and the new law is acceptable - neither is true.  CASA just don’t seem to get it – they are the problem – not the ducking solution. Everyman and his dog, from the Minister down can see it, the international community can see it, hells bells my giddy Aunt can see it – and yet CASA persist in the fantasy.  

Clean ‘em out Malcolm, before they return to the self righteous complacency which landed them in the crap in the first instance.  Bugger the regulations – REFORM CASA – the regulations will take care of themselves after that.

Aye, no doubt I’ve got the bull by the tits again, but if anyone else, apart from Slymore, believes that puerile, trite, little, one way, loaded survey is going to achieve anything but derision and disgust, let me know, so that I too may see the light and embrace life in a parallel universe.

Selah.

HL - "..I have the smallest shred of regret at starting this thread. Of particular regret is the choice of title.

Would "DAS IV: A new hope" have been more apt?

...but as others have said, hope springs eternal.

Let's all make sure we make a measured but consistent response to the survey they have asked us to complete. I wait for the results with interest.." 

&.. a voice of sanity from Frank - "..Yes it should be measured and consistent with the Forsyth Review.

I'm still waiting for the results to be implemented from that survey. Can't see what re-submitting anything will do except annoy them further. ."

I am of Frank's view i.e. it is all in the Forsyth review. How can we expect to give anywhere near and accurate assessment until that survey is fully implemented and compliant with the Minister of the Crown's FULL direction - FFS   
However if for no other reason but curiosity, let's have a look at the OBS -

There it is again, CEO and DAS. Maybe the pretentious DAS title will in time disappear.
Here is one answer posted to the survey that we are asked to fill, question being what needs changing?

"Criminal provisions for civil offenses, far too many complex, expensive and ever changing rules, extraordinary 'user pays' fees, most for services that are not required. Super expensive AOC requirements for flying training, not necessary in the US where 70% are trained outside the 'AOC' equivalent system. Extremely expensive control by AVMED when there is no safety case for aviation medicals any more than the same regime would be efficacious for car drivers. Furthermore the car driver style medical is proven successful, in the Australian context, in the low weight aircraft category. New Part 61 regs is hundreds of pages and the DAS tells us that he has 26 employees working full time to fix all the problems that they created with unworkable rules that are crushing the last life out of GA. Just four years ago Casa increased employees to around 850 on the back of increased fuel levies. Casa should take on the NZ rules in their entirety then work to ease the crazy burdens imposed on GA in this country. I have watched with dismay the wrecking of a useful General Aviation industry that used to employ many thousands. The regulator is despised universally throughout GA, there is no trust and no respect. Casa has bullied and forced hundreds out of the business of GA, blamed others for its own shortcomings and is a disgrace to the public service. Being an 'independent government business unit' since 1988 has been an experiment of government that can only be described as a disaster. Safety is compromised by loss of experienced personnel, loss of refueling points and loss of flying schools. Casa has so damaged individuals and businesses that safety reporting has reduced to negligible levels. GA is on its knees and desperately needs some immediate reforms like allowing instructors to work without our AOC system. To remove AVMED from private pilot medicals."

Although recommended that CASA make a survey every two years, following the ASSR, this survey is patently a total waste of money for the simple reason that clearly there is no point until and unless the reforms are in place, the real changes made and working to the benefit of the industry. Otherwise of course we are just going over and over the same ground. Love to know what this survey cost and who are the contractors. Any relatives or former CASA employees? Canberra people? You might say cynical but when we see the millions wasted, the mismanagement, now twenty six CASA employees working full time to correct their own regulations disaster, and having to take the time of GA operators away from their businesses, then we will probe and question. CASA and the Minister must be aware that fiddling at the edges is not acceptable. Only some real reforms to allow growth will start the long road towards cooperation and respect from GA to CASA. Independent instructors and LAMES, a moratorium on SIDs, car driver medicals for PPL, remove the 'strict liability' provisions. Reform is urgent, we demand action, attempting to fix the latest mess is not reform.

Excellent stuff Sandy, keep them coming

MTF..P2

[Kharon]

Scurrilous rumour department.

On the wind – waiting confirmation – ‘Jason’ is very cross with naughty people who challenge his spin and official version of just how bloody marvellous the new regulations are.  Writes nasty letters to people and stamps his little foot when challenged.  Freshly recruited from the vast pool of sandbags (dead weight) to ‘sell’ the notion that CASA is all reformed now and of course, the new rules.  The CASA view which is almost diametrically opposed to the Forsyth 'view' is the correct one apparently.

It seems, according to rumour, that Jason says, the Kiwi’s say their rules are crap and have offered sage advice to Australia and counselled that they, the Kiwi’s, will be following the Australians to part 61 heaven, just as soon as the Twist “tiger team” of 28 men can sort out the few wrinkles in the superlative Australian rule set.  

I will, before taking this tale to a fully blown twiddle, wait for confirmation; but, if it holds water we may yet have another candidate for the IOS hall of shame.

We shall wait and we shall see.

Toot toot.

[Peetwo]

From a March 31st post on this thread:

"..Dear miniscule,

Please take note your Murky Mandarin could be leading you up the garden path...Take heed miniscule...Thai takeaway might be the last thing on your mind but the big Q & the big V will not be happy if you have not considered the very real implications of an ICAO downgrade..."

Thailand admits 'urgent' need to improve aviation safety  


Thailand admits 'urgent' need to improve aviation safety

Bangkok (AFP) - Thai authorities Monday said they would use special powers under junta rule to "urgently" improve airline safety as several carriers face bans on new international flights following concerns raised by a UN aviation agency.

The International Civil Aviation Organization (ICAO), a United Nations body, recently reported "significant safety concerns" to Thailand's Department of Civil Aviation (DCA) after an audit earlier in the year.

In response Japan last week blocked new flights from Thailand in a move affecting charter services by budget carriers Thai AirAsia X and NokScoot as well as Asia Atlantic Airlines, the DCA said, adding existing flights would not be impacted.

Flag carrier Thai Airways has also been hit, saying in a statement on its Facebook page Saturday that two charter flights scheduled for Japan next month had been affected.

At a press conference Monday junta chief and premier Prayut Chan-O-Cha told reporters he would use Section 44 of the interim constitution -- imposed after he seized power from an elected government last May and which gives him absolute powers over legislative, executive and judicial decisions -- to expedite safety improvements.

"We have to accept that we are losing revenue from this, I am serious about solving the problem," he said.

In what appears to be a growing fallout of the ICAO decision a transport ministry official, deputy permanent secretary Voradej Harnprasert, told reporters that airlines including Thai Airways and Nok Air may also face a potential ban on new flights from Seoul and Beijing. It was not immediately possible to confirm these bans.

Prayut also said that he had raised the aviation safety issue with the Japanese prime minister and the South Korean president on the sidelines of the funeral of Singapore's founding father Lee Kuan Yew on Sunday.

- Slipped Standards -

The UN body has flagged several safety concerns including Thai aviation department personnel failing to meet international standards and a lack of full aviation regulations, Transport Minister Prajin Juntong told the press conference.

"The audit revealed some concerns relating to air operator certification procedures," ICAO spokesman Anthony Philbin told AFP by email, stressing that ICAO audits review the capability of civil aviation authorities to monitor and manage operational aviation safety.

Thai authorities have set up two new committees to tackle the concerns and will send teams to South Korea, China, Australia and Germany to discuss the issues following a trip to Japan late last week, Prajin added.

Earlier in the day the minister had said Thailand was warned about its aviation management after an earlier ICAO audit in 2005. "(They) asked us to improve our systems. I understand we have to improve urgently."

In its statement released last Thursday the DCA had said it would provide new training for staff and increase airline inspections as part of its overhaul.

Section 44 has been under the spotlight in Thailand in recent days after Prayut Friday said he was considering lifting martial law, imposed two days before May's coup, and replacing it with an order under this controversial portion of the interim charter.

Several local rights groups have urged the junta chief to rethink the plans, issuing a joint statement maintaining their call to lift martial law but saying the impact of invoking the new order would be "much worse".

Under martial law Thailand's generals have banned political gatherings of more than five people, outlawed criticism of the ruling regime and tried civilians in military courts.

Well some hours ago today the FAA issued a press release :

Press Release – FAA Announces Revised Safety Rating for the Kingdom of Thailand

For Immediate Release
December 1, 2015
Contact: Alison Duquette or Les Dorr
Phone: (202) 267-3883

---

WASHINGTON – The U.S. Department of Transportation’s Federal Aviation Administration (FAA) today announced that the Kingdom of Thailand does not comply with International Civil Aviation Organization (ICAO) safety standards and has been assigned a Category 2 ratingbased on a reassessment of the country’s civil aviation authority.

U.S. and Thai aviation officials have a long-standing cooperative relationship and both our countries work continuously to meet the challenge of ensuring aviation safety. A Category 2 International Aviation Safety Assessment (IASA) rating means that the country either lacks laws or regulations necessary to oversee air carriers in accordance with minimum international standards, or its civil aviation authority – a body equivalent to the FAA for aviation safety matters – is deficient in one or more areas, such as technical expertise, trained personnel, record-keeping, or inspection procedures. With a Category 2 rating, Thailand’s carriers can continue existing service to the United States. They will not be allowed to establish new service to the United States.
 
Thailand was assigned an initial Category 2 rating in 1996 and received a Category 1 rating in 1997. Reassessments of Thailand in 2001 and 2008 continued the Category 1 rating. A reassessment in July 2015 found that Thailand did not meet international standards. Today’s announcement follows ongoing discussions with the government of Thailand which concluded on October 28.

As part of the FAA’s IASA program, the agency assesses the civil aviation authorities of all countries with air carriers that have applied to fly to the United States, currently conduct operations to the United States, or participate in code sharing arrangements with U.S. partner airlines, and makes that information available to the public. The assessments determine whether or not foreign civil aviation authorities are meeting ICAO safety standards, not FAA regulations.

A Category 1 rating means the country’s civil aviation authority complies with ICAO standards.  With an IASA Category 1 rating, a country’s air carriers can establish service to the United States and carry the code of U.S. carriers. In order to maintain a Category 1 rating, a country must adhere to the safety standards of ICAO, the United Nations’ technical agency for aviation that establishes international standards and recommended practices for aircraft operations and maintenance. IASA information is posted at www.faa.gov/about/initiatives/iasa/.

Ben Sandilands closely followed the FAA presser with this.. :

Thailand fails critical air safety standards, cops US downgrade

Ben Sandilands | Dec 02, 2015 8:40AM |

Thai 747 at Bangkok’s Suvarnabhumi Airport

All Thai airlines flights that serve Australia are as of today branded as coming under inadequate safety oversights from its national aviation agencies as a result of ICAO and American FAA downgrades.

Whether the consequences of those downgrades are fair or unfair to Thai International, which is Thailand’s major flag carrier, is beside the point. Thailand’s capacity to properly administer air safety compliance by any of its airlines, or for that matter, airports, is now under a very dark cloud.

This is how John Goglia, a former long serving board member on the US National Transportation Safety Board, summarised the situation in Forbes a short time ago.

The Federal Aviation Administration announced this morning that Thailand’s aviation safety rating has been downgraded from Category 1 to Category 2.  This means that the FAA has determined that Thailand does not meet international safety standards set by the International Civil Aviation Organization, referred to as ICAO. As a result of the downgrade, Thai airlines can continue existing service to the US but no new service will be allowed.  In addition, US airlines will not be able to code share with Thai airlines.
According to the FAA’s statement, the category 2 rating means “the country either lacks laws or regulations necessary to oversee air carriers in accordance with minimum international standards, or its civil aviation authority – a body equivalent to the FAA for aviation safety matters – is deficient in one or more areas, such as technical expertise, trained personnel, record-keeping, or inspection procedures.”  In addition, the FAA indicated that Thailand has had a history of ups and downs with its aviation safety ratings.  It was initially assessed a Category 2 in 1996, which was upgraded to Category 1 in 1997. Reassessments in 2001 and 2008 continued the Category 1 rating.  However, an FAA reassessment in July 2015 found that Thailand did not meet international standards.

Plane Talking reported the initial red flagging of Thai air safety by the FAA back in July.

Whatever concerns Qantas might privately have about the competency of Thai air safety administration concerning its air space or airports in the light of ICAO and FAA disapproval, the consequences of such a downgrade being visited on Australia’s aviation regulators ought never be disregarded.

The public administration of aviation in this country is farcical and profoundly incapable of performing its obligations as evidenced in the Pel-Air saga and the notable inability of CASA to oversight that operation or tell the truth about the situation following an internal review.

Australia has talked a great deal about delivering better safety administration outcomes in recent years. Yet it hasn’t delivered on any of the rhetoric. Lots of PR bullshit, sod all material results.

There are in this, some similarities with the inertia exhibited by Thai authorities that ought not be lost on Australia’s flag carriers, who could like Thai International, find themselves seriously penalised by a failure of process in Canberra that isn’t of their own doing.

Well said Ben and IMO that is not just rhetoric when you consider some of the recent findings/observations in regards to the ongoing PelAir cover-up debacle - e.g. Beyond Reason - & the pale??
Tick..tock 'Malcolm in the middle' & Farmer Truss ICAO have ticked off the Thai peninsula and are on their way Downunda..tick tock...
MTF...P2

[Gobbledock]

The bolded bit;

"Thai authorities have set up two new committees to tackle the concerns and will send teams to South Korea, China, Australia and Germany to discuss the issues following a trip to Japan late last week, Prajin added".

Sweet Jesus, why would they want to do that, come to Australia? Go to bloody NZ or Canada, but not Australia. All we have is a CEO/porn star lookalike who wants to hold hands, who wants to talk, giggle and discuss, who wants to dump a poofy named 'tiger team' upon us, a CEO who likes to dismiss the veracity of one of the most important reviews done in decades,  and all this under the watchful eye of a a short freak with a giant pumpkin head and an out of touch Silvertail Miniscule who needs to pack up his skin ointment, his lisp and his colostomy bag and piss off back to Kingaroy.

But then again, CAsA is so fu#ked that maybe CAsA will adopt some of Thailand's worst practise which would be an improvement over CAsA!!!

"Unsafe and downgraded International tigers for all"

[Peetwo]

The bolded bit;

"Thai authorities have set up two new committees to tackle the concerns and will send teams to South Korea, China, Australia and Germany to discuss the issues following a trip to Japan late last week, Prajin added".

Sweet Jesus, why would they want to do that, come to Australia? Go to bloody NZ or Canada, but not Australia. All we have is a CEO/porn star lookalike who wants to hold hands, who wants to talk, giggle and discuss, who wants to dump a poofy named 'tiger team' upon us, a CEO who likes to dismiss the veracity of one of the most important reviews done in decades,  and all this under the watchful eye of a a short freak with a giant pumpkin head and an out of touch Silvertail Miniscule who needs to pack up his skin ointment, his lisp and his colostomy bag and piss off back to Kingaroy.

But then again, CAsA is so fu#ked that maybe CAsA will adopt some of Thailand's worst practise which would be an improvement over CAsA!!!

"Unsafe and downgraded International tigers for all"

Turbulent times for Tiger country -

Gobbles it would seem for some bizarre reason some of our SE Asian neighbours value Aussie aviation safety expertise...

Maybe it is because of programs like the ones that were headed up by true aviation safety experts like Alan Stray.

From Flight Global interview May 2009 -

Alan Stray is director international of the Australian Transport Safety Bureau. He was awarded the Public Service Medal for his work supporting development of the Indonesian National Transportation Safety Committee

What first sparked your interest in aviation?

At a young age I had a deep desire to be a missionary pilot, having often heard about the work of missionary aviation in many countries through my church.

How did you begin your professional aviation career?

In January 1965 I began a five-year aircraft maintenance engineering apprenticeship working on a range of general aviation aircraft from the smallest fabric-covered type to turboprops and the Bristol freighter. In February 1968 I began flying lessons.

Aircraft maintenance engineering and a commercial pilot licence were prerequisites for mission aviation and I spent the 1970s engineering and flying in Papua New Guinea. I returned to Australia in 1980 and flew as a regional airline captain for seven years before joining the then Bureau of Air Safety Investigation in January 1987.

What personal qualities does an investigator need?

In addition to technical skills and a practical background in the aviation industry, an accident investigator requires certain personal attributes. These include integrity and impartiality in the recording of facts, logic and perseverance in pursuing inquiries, often under difficult or trying conditions, an analytical and enquiring mind, and tact in dealing with a wide range of people who have been involved in the traumatic experience of an aircraft accident or serious incident.

What are the best and worst aspects of the job?

Working with those best placed to achieve safety improvements such as regulators, airlines, maintenance organisations, and manufacturers, is important and satisfying. The trauma of an accident site where there has been major airframe disruption and the resultant loss of life can be extremely difficult.

Helping accident victims' families understand the circumstances of an accident and keeping them informed of the progress and subsequent findings of the investigation can be a challenging and unpredictable experience. Some families, although needing answers, are completely accepting of the investigation processes while others, through their grief, are needing answers that the investigator may not be able to provide. This can create tensions.

What has the Indonesia project achieved?

The Indonesian project has achieved a steady rate of capacity building in aviation, marine and rail safety. In May 2007, in co-operation with the Indonesian government, the Australian government, through its Indonesia Transport Safety Assistance Package, committed to three years of transport safety capacity building.

My part of the overall project covers safety investigation with the Australian Transport Safety Bureau directly assisting the Indonesian National Transportation Safety Committee.

To date our projects have developed ICAO-compliant investigation policies and procedures for the NTSC and assisted in the investigation and report writing to ICAO standards of some significant investigations.

A number of training courses for NTSC investigators have been conducted in Indonesia and three investigators are now completing the ATSB's 12-month Diploma of Transport Safety Investigation course in Canberra (a fourth investigator has already completed the programme), and an engineer is undergoing flight recorder replay and analysis training.

 
The fruit of Alan's labour is perhaps best highlighted in the exemplary Final Report on QZ8501, completed within a year of the tragic accident and as yet with little criticism...

5 SAFETY RECOMMENDATIONS


While the KNKT acknowledges the safety actions taken by the aircraft operator, there still remain safety issues that need to be considered. The KNKT issues the following Safety Recommendations addressed to:

5.1 Aircraft Operator

1. The KNKT recommends that Indonesia AirAsia to re-emphasize the importance of the Standard Call-Outs in all phases of flight.

2. The KNKT recommends that Indonesia AirAsia to re-emphasize the taking over control procedure in various critical situations of flight.

5.2 Directorate General Civil Aviation


1. The KNKT recommends that the Directorate General Civil Aviation to ensure the implementation of air operators‟ training of flight crew is in accordance with the approved operations manual.

2. The KNKT recommends that the Directorate General Civil Aviation to ensure that air operators under CASR 121 conduct simulator upset recovery training in timely manner.

3. The KNKT recommends that the Directorate General Civil Aviation ensures that air operator maintenance system has the ability to detect and address all repetitive faults appropriately.

4. The KNKT recommends the Directorate General Civil Aviation ensures the Indonesian Civil Aviation Safety Regulations to regulate the duties of the pilot in command as specified by ICAO Annex 6.

5.3 Aircraft Manufacturer

1. The KNKT recommends that Airbus to consider in developing a means for flight crews to effectively manage multiple and repetitive Master Caution alarms to reduce distraction.

2. The KNKT recommends that Airbus to consider and review the FCTM concerning the Standard Call-Outs in all phases of flight.

5.4 United States Federal Aviation Administration and European Aviation Safety Agency

1. The KNKT supports the previous French BEA recommendation (Recommendation FRAN-2015-024) on ensuring that future programs to include initial and recurrent training relating to taking over control of aircraft equipped with non-coupled control stick.

2. The KNKT recommend expediting the implementation of mandatory for upset recovery training earlier than 2019.

While on the Indonesian aviation safety SSP, on another strange parallel irony, 10 days before the NTSC release of the QZ8501 Final Report, I intercepted this informative article from the Jakarta Post -  Policy-making in aviation needs to involve industry players :

Indonesia’s intention of becoming a member of the UN International Civil Aviation Organization (ICAO) council may backfire if the government implements regulations without considering their impacts on flight-industry players. Air Law Community chairman Andre Rahadian said in a discussion on Thursday that several regulations imposed by the government aimed to improve flight safety and security had burdened airlines.

“Regulations should consider the airlines, especially in terms of their businesses continuity,” he said, adding that some regulations had prevented airlines from making achievements while already being affected by the slowing global economy.

Andre highlighted several regulations that weighed in airlines’ costs, such as a minimum paid-up capital requirement and minimum fleet age. He expressed concern that a regulation obligating airlines to deposit paid-up capital of Rp 500 billion (US$36.57 million) in the form of fresh funds and/or capital goods would only increase costs.

He said only two airlines in the country owned such capitalization, leaving others to struggle to meet the requirement in three-years time. The Transportation Ministry introduced earlier this year the minimum capital regulation in response to a major plane accident. The ministry was of the opinion that the accident occurred on account of improper maintenance as a result of the airline’s insufficient capitalization.

Andre said that by involving industry players in the regulation-making process, the government would be able to measure the possible impact of the proposed regulation.

“This can also ensure legal certainty as chances to revise the regulation will be smaller,” he said. The government aims to become a ICAO council member for the 2016-2019 period to introduce Indonesian interests in the organization’s policies. To support the objective, the government must improve flight safety to meet the ICAO requirements.

The move is in line with the ministry’s commitment to focus on transportation safety next year, as it plans to allocate 20 percent of its Rp 48.5 trillion ($3.57 billion) budget in the 2016 state budget to improve safety in air, land, sea and rail transportation.

Coordinating Maritime Affairs Minister Rizal Ramli said on Thursday that the government had asked the Australian government to support Indonesia in its efforts to become a council member. “I assisted in talks with the Australian government to convince Australia and other countries support us,” he said as quoted by kompas.com. The ministry claimed earlier this month that it had implemented corrective recommendations from the ICAO and the US Federal Aviation Administration (FAA) in its efforts to become a council member.

The ministry’s director for air transportation, Muzaffar Ismail, said the corrective actions, which were in line with recommendations from the ICAO, were 96.2 percent complete. The ICAO officials will carry out an evaluation and conduct an inspection this year to follow up and validate the adjustments.

Rizal stated that the large size of Indonesia’s airline business encouraged such an effort.

Data from the ministry said that the country’s airlines had flown around 87 million passengers last year. It aims to fly around 162 million people by 2019. To support the growth, the ministry plans to build 62 new airports by 2030, adding to the existing 237.

  
 Although the findings of the QZ8501 final report could be seen as a set back for the stated Indonesian effort above, it should also be recognised that the NTSC have proven their effectiveness as a properly independent & compliant State AAI (Annex 13). This integrity & independence is fundamental to the implementation of a proper ICAO Annex 19 SSP. Sadly the same cannot be said for our State AAI, the currently much maligned ATSB...


MTF...P2  

   

[Gobbledock]

Mr Alan Stray, where does one start?
He is the epitome of a professional investigator - dedicated, focused, articulate, doesn't bullshit but says it the way he sees it, is respected throughout the investigative fraternity, and as has been mentioned he provided several years worth of assistance to Indonesia on the ITSAP program, and as a result Indonesia now has a department that now pisses over Australia's capability (or lack of). What a lamentable and bizzare tirnaround!

The current ATsB should hang it's head in shame when they look at the talent they used to have (at a senior level) compared to the bearded, bumbling, obsfucating mi mi mi ing laughable gimp they have had for almost 6 years.

TICK TOCK Beaker

[Kharon]

Question time.

I wonder, does the Minister realise the size and seriousness of the opposition to ATSB, ASA and CASA?  Every single aviation related body in the land is set against almost every proposal, disbelieves every statement uttered; and, is categorically fed up to the back teeth with the rhetoric, spin and pony-pooh churned out – to justify the existence of those agencies.   Maria Antoinette thought it was a good idea to ‘let them eat cake’ – turns out that was not one of her better moments.

This industry demands and as the end user and purchaser of that service, has a perfect right to change – for the better.  The industry has a natural right to expect that the government services provided to industry are honest, cost effective and the edicts justify the salaries paid by industry to the supposed ‘experts’ in the field.

Here’s a question – why does it need a 28 man “tiger team” to sort of, sort out the havoc created by just one regulation? –A regulation which was supposed to improve the existing messy situation.  A regulation which is almost five, yes that’s 5 times larger the entire USA FAA regulatory suite, as provided to industry.

{the very full box contains a printed version of Part 61}.

Here’s another – Why can the Indonesian aviation authorities provide a first class report to industry on a serious accident within a twelve month and that after finding and retrieving the lost aircraft?   Australia cannot even acknowledge a potential system error on two separate passenger jets, let alone expect a honest report in less than two years.  

Here’s another – How come the Indonesian regulator has made a positive response to the recent investigation and is seeking ways to improve, while Australia, despite having more resources and a mandate for change is regressing and looking toward draconian law to improve safety?  This, mind you in the face of a world wide trend away from such aberrations.

Has the Minister ever paused to consider why there is almost open revolt within the aviation community?  He should.

Has the PM considered appointing a real ‘Tiger team’ to sort out the incredible mess?  He should.  Appoint David Fawcett a junior minister for Aviation, bring in Cannane, Carmody, Forsyth, Hirst, Smith and a couple of others; give them a legal eagle and turn them loose.  The improvement would be both miraculous and instant.

I just wonder how much longer the industry can support the existing edifice, without crumbling.  So much time. money and effort wasted on achieving SFA, except establishing what everyone already knew – real reform, in real time is, like every safety report, overdue and obfuscated.

Selah.

[Peetwo]

Dear Alphabets

To all concerned I have absolutely zero affiliation with any of the alphabet soup Aviation groups, associations etc...etc just a keen observer. Much like David Forsyth (these days), this places me in a perfect situation to independently assess & review.

Now although I applaud the Marc de Stoop led initiative of Project Eureka, I believe there are already warning signs that this initiative may become derailed through industry politics and by even more bureaucratic obfuscation. It should be remembered that time is on the bureaucrats side and not on the industry's side. I also believe that it is a fundamental mistake not involving as many of the alphabet groups as is humanly possible to present as one cohesive group, eventually through attrition & division the Forsyth CASA reform program will be doomed to fail.

{Note: Here is an example of how in the US 17 industry groups put aside their differences and are now close to pushing through PBOR2 amended legislation: http://auntypru.com/forum/-Alphabet-if%E...35#pid3035 }

You will find attached a email chain talking about tomorrow's - Part 61 Solutions Taskforce - Inaugural Industry Advisory Panel Meeting.

In the course of those emails talk (through Thorny) goes to the incompetence of Roger Weeks, this is acknowledged & accepted. To me (the independent observer) that is the first mistake. The first point of order for that meeting tomorrow should be that industry will not accept Mr Weeks heading up the 'Taskforce', he has obviously a conflict of interest & industry does not believe he has the necessary prerequisites for the job - Full Stop!

Next the industry groups need to insist that CASA put in place an immediate plan of action to repeal (1st sitting of Parliament next year) Part 61 and in the interim replace with original legislation - Full Stop!

From Sandy's post - HERE - off AHIA thread:

..Although recommended that CASA make a survey every two years, following the ASSR, this survey is patently a total waste of money for the simple reason that clearly there is no point until and unless the reforms are in place, the real changes made and working to the benefit of the industry. Otherwise of course we are just going over and over the same ground. Love to know what this survey cost and who are the contractors. Any relatives or former CASA employees? Canberra people? You might say cynical but when we see the millions wasted, the mismanagement, now twenty six CASA employees working full time to correct their own regulations disaster, and having to take the time of GA operators away from their businesses, then we will probe and question. CASA and the Minister must be aware that fiddling at the edges is not acceptable. Only some real reforms to allow growth will start the long road towards cooperation and respect from GA to CASA... 

What next: Industry groups need to collectively agree to sign off on at least ten bullet points of immediate direct action that will (not shall or should - WILL) be actioned by CASA within the first four weeks of the New Year - not six months, not four months etc. - Full Stop!

Sandy on Reverend Forsyth's thread:

..Until and unless the CASA Board decides to create simple rules and stops treating us like a bunch of untrustworthy criminals then trust or respect to anyone in the top echelons of CASA will not be forthcoming.

Until and unless our minimum demands are met no more talking. The waste of time and money must stop. AMROBA is clear and sensible. The collective mindset of us all is focused on how to improve, not just revert to old rules. Its now plain to see what needs to happen, the Board must take control. It must instruct Mr Skidmore to institute some basic reforms immediately. Government must understand that it cannot crush a whole industry through neglect, lack of oversight, poor policies without repercussions..

I am with Sandy on this there is 'no negotiation', industry needs to send the message that all demands are non-negotiable.

Please don't waste tomorrow's perfect opportunity, the alternative could be that we are talking about this all over again in another six months time..an another 6 months time.. etc..etc

 MTF...P2  

Ps The following is an example of an alphabet group trying to do the best for it's members on the diabolical (death to industry) Part 61.

From AFAP President Captain Booth to Mr Skidmore nearly 5 months ago (DRAFT only):

28 July 2015
Mr Mark Skidmore
Director of Aviation Safety
Civil Aviation Safety Authority
PO Box 2005
CANBERRA ACT 2601

By email: Mark.skidmore@casa.gov.au

Dear Mark,

AFAP concerns regarding the impact of CASR Part 61 on its pilot members
I refer to our recent meeting on 26 May, and discussion around Part 61.
There has already been considerable publicity given to the many concerns raised regarding the financial burdens, deficiencies, confusion and impracticability of the new Part 61. Many of these have been raised more than once in the CASA FCL sub-committee (the minutes of which indicate that many issues raised prior to the drafting of the current legislation are still unresolved).

The AFAP acknowledges the best of intentions of all involved in the development of Part 61, and the difficulty faced by CASA personnel in its implementation both before and after your commencement as Director of Aviation Safety. However, despite those best intentions, and the obvious and intimate understanding of the regulations by those CASA officers involved in their development, to a great many in the aviation industry Part 61 is a verbose, unclear, complicated and ambiguous document which despite copious (sometimes equally confusing) guidance material, is proving extremely difficult and expensive to comply with.

In this we feel that CASA has not lived up to its responsibility under section 9(1)© of the Civil Aviation Act 1988.

In view of this situation the AFAP would ideally like to see a complete review and rewrite of the legislation in a form that is understandable to all industry participants.

In the event this is impractical or, in the interim, I would like to draw your attention to just some of the issues raised by our members with particular emphasis on the cost burden and the confusion imposed by Part 61, in its current form by way of informing the ongoing post implementation review process.

Part 61 has created onerous compliance requirements unique to Australia.

These requirements are causing a reduction in GA participation at all levels.

They are reducing employment opportunities for GA pilots and hindering pilots advancing to airline positions. CASA’s transition study on the procedural, documentary and operational changes of Part 61 was without any appreciable consideration of the cost burden to industry.

Nor was there any demonstrable or quantifiable evidence of improvements in safety standards being achieved as a result of these changes. More complex regulations do not necessarily lower the accident rate. The US FAA regulatory system covers a comparable aviation industry mix to Australia. FAR Part 61 gives much greater flexibility to flight review, proficiency checks and licence attainment, with no demonstrable decrease in safety standards. In fact in 2013 the GA accident rate in the US was 5.85 per 100,000 hrs flown, in Australia it was 8.33 accidents per 100,000 hrs flown (last available ATSB statistics).

An example of increased costs for a representative GA instructor/examiner pilot is out lined in Attachment A.

Australia’s Part 61 is over 300 pages long, and when combined with the MOS, instruments and explanatory statements total approximately 1,000 pages. This legislation compares unfavourably with the length and complexity of Australia’s tax and corporations regulation legislation. As one member put it to us:

“The situation is so confusing that estimates of the flight review / proficiency check requirements for a particular Instructor/ ATO/ check pilot vary from six to fifteen checks every two years with the cost impact, in both cases, being vastly more than was previously experienced. In addition to the direct costs involved, the impost in terms of administration and record keeping is considerable and for all of this there is little or no demonstrated practical improvement in the overall level of safety in the industry. The complexity of the rules and the structure of the legislation make it extremely difficult for industry to achieve compliance with any degree of certainty. Consequently in their current form, and despite the best of intentions, the CASRs could well lead to a reduction in aviation safety and compliance standards in this country.”

Many of the mandatory courses, training and authorisations are not yet in place in Australia, and while they may be available overseas, and may well be available here in time, the cost burden in complying is considerable. For example: the high cost of the ATPL which requires access to a Cat D simulator or equivalent aircraft for the flight test and to satisfy the MCC requirements (in the case of helicopters there is limited, if any, access to suitable simulators).

Few flying training organisations are seeking MCC training approvals. This has created a situation where, we are informed, that to date there has only been one fixed wing ATPL test since Part 61 was enacted and no Helicopter ATPLs.

Many Australian commercial pilots are now unable to qualify to higher ATPL standard which is hindering their ability to progress their careers into positions requiring an ATPL licence.

The ability to conduct an ATPL flight test in a light twin (BE58 etc) would solve this problem by providing a much cheaper solution for self-funded pilots. A workaround solution for the multi-crew component of the flight test should be found.

The AFAP does not deny the fact that checks need to be done, as indeed they were being done prior to Part 61, rather we wish to highlight the impracticality of the Part 61 system under which a number of experienced checkers and trainers are no longer able to perform this important service because they do not comply with the new regulations.

Some examples are:
1. Fixed wing GA instructor/examiner (Attachment A) – biennial cost increase to an individual examiner, Chief Pilot, of over $20,000 AUD and over two working weeks every year lost to additional preparation and testing attendance not previously required by CAO’s; and
2. Helicopter – significant biennial cost increases outlined by the AHIA.

Other ICAO State Regulatory Comparisons

EASA/UK

CASA describe the Part 61 as reflecting world’s best practice and in most instances quotes EASA regulatory comparisons. The European aviation industry has a very different mix of aviation industries from Australia with very little comparable general aviation (GA) segment.

The UK CAA has recognised that the EASA regulations are suppressive to GA and has promulgated two documents, CAP 1123 and CAP 1184, which admit the need for red tape reduction in the move to performance based regulation.

CAP 1123 states that the CAA (UK) will be deregulating GA as much as possible and they will also move to delegation to assist so the CAA (UK) could stop regulatory oversight of GA. GA in Britain is prescribed as aviation not classified as Commercial Air Transport (CAT).

CAP 1184 states that in the near term the CAA(UK) will be changing their legislative requirement to Performance Based Regulation (PBR).

FAA/USA

FAR Part 61.58 allows for a proficiency check in a complex type to cover other types/classes where the Australian Part 61 would require multiple checks.
FAR 61.156 Training requirements: Airplane category—multiengine class rating or airplane type rating concurrently with airline transport pilot certificate.

Allows the airline transport pilot certificate to be issued concurrently with an aircraft type rating. The Australian part 61 does not.

FAR 61.195 Flight instructor limitations and qualifications. Allows a qualified Flight instructor to maintain his approvals based on the number of students trained and passed within the preceding 2 yrs. This is a performance and results driven privilege that does not attract expensive FAA checks and tests of instructors if a certain standard is maintained. The Australian part 61 requires multiple checks and tests to maintain instructor approvals.

ASRR Findings

As the recent Australian Aviation Safety Regulation Review Panel stated:

“Leading regulators across the world are moving to performance-based regulation, using a ‘trust and verify’ approach, collaborating with industry to produce better safety outcomes and ensuring the regulator stays in touch with rapidly advancing technology and safety practices. On occasions, individual operators may push the boundaries and require close regulatory oversight and a firm regulatory response. An effective risk-based regulator will judge when a hard line is necessary.”

The AFAP restates its response to the 2014 Aviation Safety Regulation Review Panel, letter of 8 July 2014:

“We now urge the government to adopt the report and its recommendations with particular regard to recommendations:

14. The Civil Aviation Safety Authority changes its regulatory philosophy and, together with industry, builds an effective collaborative relationship on a foundation of mutual understanding and respect.”

The CASA chaired SCC FCL Subcommittee does recognise some of these problems but appears to be addressing them in proposed minor adjustments/instruments/extensions/transitions to the rule set.

Proposed AFAP Amendments

The AFAP would like amendment proposals to Part 61 that allow:

1. The expansion of class ratings to permit a single flight review/proficiency check on a more  complex aircraft (including helicopters) to cover more simple types. E.g Single engine  aircraft proficiency coverage by the multi-engine class proficiency check.
2. Clarification of the ability to complete more than one test during a single sortie; e.g. IPC and Flight Review or instructor rating on a single sortie, maintaining standards but keeping the cost of checks to viable levels
3. Allow more scope of testing equipment for the ATPL flight test, reducing the currently extreme cost of the ATPL Flight Test, ie explore the possibility of completing the test in a light twin or lower category simulator than currently required. The FARs allows this, with subsequent limitations added to the licence.

The AFAP believe there will be many more examples of unnecessary onerous cost increases and compliance impracticalities as the industry transitions to Parts 61, 141 and 142.

Therefore, engaging with the principal excessive burdens now and scaling back or removing them must be considered a priority.

Yours sincerely,


Captain David Booth
President
Australian Federation of Air Pilots