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Latest from Comardy (CAsA) v Morgan (AOPAA) wars...

Via BM...Dear Comardy:

Wednesday, 7th December 2016

Mr Shane Carmody
Acting CEO and Director of Aviation Safety
Civil Aviation Safety Authority
GPO BOX 2005
Canberra ACT 2601, Australia.
 
The Hon Darren Chester MP
Minister for Infrastructure and Transport
House of Representatives
Parliament House
Canberra ACT 2600, Australia.


AOPA Australia calls on CASA to give a genuine
commitment to consult and negotiate on ADSB 2020 extension
 
Mr Carmody,
 
Further to your letter (GI16/1017) dated 1st December 2016 in response to the AOPA Australia’s call for CASA to give a genuine commitment to consult and negotiate on the ADS-B 2020 extension.
 
The AOPA Australia stands by its efforts during the initial ADS-B implementation consultation, whereby we supported the ADS-B concept on the basis that a subsidy be provided to aircraft owners ($15,000 to IFR and $10,000 to VFR).  Airservices and CASA subsequently rolled-back support for the subsidy, forcing the general aviation industry to bear the full impost of the $46.3 million ADS-B fitment estimate, that was published by CASA’s in its Regulatory Impact Statement (RIS).
 
The AOPA Australia throughout the initial ADS-B consultation worked hard to ensure that only IFR aircraft would be subjected to the mandatory fitment.  Our involvement prevented thousands of VFR aircraft from being forced to prematurely install, saving the industry tens of millions. 
 
It remains AOPA Australia policy that the Australian general aviation industry is due fair compensation for the forced ADS-B fitment, given that its introduction is focused entirely on benefits its provides to the airline industry and savings it will achieve for Airservices Australia over the coming 5 years.
 
Looking to the United States the Federal Aviation Administration has sought to establish government backed interest free loans for aircraft owners/operators and have sought to encourage ADS-B technology companies to provide further rebates and incentives to help the FAA achieve industry compliance.  And, whilst the Australian government provides a raft of loans and rebates for a myriad of industries, neither Airservices or CASA have produced any platform of assistance to help the struggling general aviation industry achieve ADS-B compliance.
 
The AOPA Australia highlights that since CASA’s initial ADS-B consultation nine years ago, the general aviation industry under CASA’s regulatory management has experienced;
 

• 35% decline in general aviation pilot numbers, over 8,00 pilots exiting the industry
  
• 50% increase in the number of general aviation aircraft not flying, estimated now to be over 4,000
  
• 35% reduction in general aviation fuel sales
  
• Largest number of general aviation business closures in the past 20 years.
  

 
The above results have been acknowledged by the Minister for Infrastructure and Transport, Mr Darren Chester, which has triggered a review into the cause of general aviation decline in Australia.
 
The AOPA Australia considers the impact of forced ADS-B compliance as being contributory to general aviation decline, with the mandate coming into full effect during a time of sincere economic distress for many general aviation businesses.  Now more than ever our general aviation industry and business community requires both regulatory and financial assistance, so as to ease the burden of the ADS-B installation requirement, so as to avoid inducing further business closures.
To further amplify this point, I received advice only today that one of two large aviation insurance companies has made the decision to withdraw from the Australian market, citing a lack of financial viability within the general aviation industry. 
 
Simply, where have all the pilots, aircraft and businesses gone?
 
The AOPA Australia has consistently raised its concern that ADS-B fitment would negatively impact the general aviation economy, yet CASA have refused to debate our position.  Both your predecessor Mr Skidmore and yourself have actively voiced CASA’s firm stance (to both industry and Senate Estimate hearings) that no extension was being considered and have refused to engage on the topic.
 
The inflexible CASA position has demonstrated to both industry and government CASA’s total disregard to the welfare of the people in this industry and has shown the regulator to be unwilling to genuinely consult or negotiate on the issues which are vital to our future.
 
In frustration, the AOPA Australia along with 480+ industry participants held a general aviation rally in Tamworth, May of 2016, calling on the Deputy Prime Minister and Minister for Infrastructure and Transport to use their powers to force CASA to the table.  Only as a result of the industry standing in full protest to the senior members of government and elevating our concerns to the broad media has CASA been compelled to change direction on the ADS-B issue. 
 
However, what CASA has provided our industry in the ADS-B 2020 extension instrument is entirely unusable to the vast majority of those affected, providing no financial relief to those that need it most.  As previously stated, the extension is a sleight of hand by CASA, designed to appear as if the regulator is doing something, when in fact it is doing nothing.
 
The AOPA Australia last week called on you to convene a meeting in Canberra so that we may openly discuss the ADS-B issue, seeking a genuine commitment from CASA to negotiate with industry.  Your response states that you were “…not clear as to what more needed to be discussed…” and I can only assume it is because you have never been subjected to compliance of CASA’s regulatory demands, that you as Acting Director of Aviation Safety are forcing on aircraft owners and general aviation business operators.
 
On behalf of Australia’s aircraft owners, pilots and aviation business operators we are disappointed that rather than opening your doors to seek understanding as to our difficult and stressful position our industry is in - you have played politics.
 
We again call on you to convene a meeting with industry and to give a genuine commitment to negotiate.
 
Yours Sincerely,

BENJAMIN MORGAN
Executive Director - Aircraft Owners and Pilots Association (AOPA) of Australia
 

MTF...P2

Ps Comment to the above courtesy the PAIN email chain :

Folks,


An added comment: At no stage has the whole issue of ADS-B  been the subject of a credible cost/benefit justification. Despite long standing Government policy for such justification.

Indeed, in risk management terms, ADS-B has never been justified, the many claimed benefits are just that - claims, that have not been demonstrated in practice, lest alone cost/benefit justified.

Just chanting the mantra does not alter the facts.

Cheers,
Bill Hamilton