[Peetwo]

AMROBA latest newsletter: Volume-20-Issue-3-March-2023  

Via AP email chains:

> To all members,
 
With government once again concentrating of developing a White Paper, we look at why regulatory reform never finishes.

• Government departments and agencies cannot complete reform within one term of government or one term of the CEO of CASA.
  
• Change of direction of reform is no longer politically directed.
  
• Most FARs are a result of Bills passed by Congress.
  
• Canada has a Cabinet Direction process.
  
• Australia leaves it to CASA to determine the future without Parliamentary direction.
  

 
March 2023 Newsletter  
 
The only way government can make long term changes is by amending Sec. 98 of the civil aviation act.
 

1. We raise this by using an example. Why does S98 state the GG can make regulations to give effect to the provisions of the Convention relating to safety?
   • For the engineering fields to operate both domestically and globally, industry needs regulations that give effect to the Convention and its assign Annexes.
     
   • Get rid of the safety restriction – all aspects of the Annexes are there to ensure a sound safe and efficient regulatory system
     
2. The convention’s global aviation regulatory system – why aren’t we harmonised after 70 plus years membership of ICAO?
   
3. Understanding the Convention’s Annexes Maintenance Release
   • Time Australia harmonised with other major regulatory systems
     
   • Needs to be adopted prior to CASR Part 43 being adopted.
     
4. Understanding where responsibility lies for safety and liability of those responsible
   • Understanding the difference between “bad” and “good” systems.
     
   • To err is human.
     

 
AMROBA has made a submission to the White Paper and will continue to input until the Green Paper is circulated.
 
Lastly, we don’t understand why CASA will not promulgate EASR Part 147 Annex, attached, so federal funding can be made available for training.
4 CASA CEOs have all been lobbied to promulgate with no result.
 
Why does CASA not see how this relates to the  AME/LAME critical shortage?
Basically proper funding to trade and licence train
 
Regards

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MTF...P2