20/20 Hindsight.
#1

20/20 Hindsight.

> Or; an even money bet. One could even term it as a 30% less than a 50/50 even chance of getting something done.
 
“The mills of the gods grind slow” is an old saw. The point it struggles to make is that slow but certain divine retribution (from Wiki) is on the way. Well the 2020 Senate inquiry is certainly ‘slow’ – 24 months of grinding the grist in their mills. The ‘divine’ part is yet to be seen and ‘retribution’ is most certainly a vision splendid, far beyond the horizon.
 
Even so: the submissions have begun to trickle in – you can find them – HERE.
 
Aunt Pru will do her best to keep track of the whole thing on this thread; from soup to nuts. We have not seen a schedule or notice of pubic sessions; so patience is required.
 
There is little patience within the BRB /IOS – the question most asked is why don’t we save all the bother and simply enforce the 150 recommendations made between the Forsyth report and the Senate inquiry into Pel-Air. A close second is why not repeal 61/141 and 142 and simply adopt the FAA system. Both valid questions to be asked and fully answered.
 
There are two submissions logged at present – both worth the few moments it takes to read them.
 
A lot MTF I reckon.
 
Toot – toot.
Reply
#2

(02-13-2020, 07:04 AM)Kharon Wrote:  20/20 Hindsight.

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


Mr John HOORE (PDF 185 KB) 


Quote:CASA’s Role in General Aviation:

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

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

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

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

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

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

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

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

..Conclusion:

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

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


Mr Sandy Reith (PDF 103 KB) 


Quote:Dear Senators,

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

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

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

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

Tip of iceberg.

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

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

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

Regards,

Alexander C. (Sandy) Reith
 


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

Don't forget to monitor the Additional Documents page -  Wink

MTF...P2
Tongue

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

Quote:Dear Dan,

Regarding the  Aviation Security Identification Card (ASIC). 

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

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

Three questions please:- 

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

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

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

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

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

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

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

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

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

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

Kind regards,

Sandy
 
Reply
#3

(02-21-2020, 08:24 AM)Peetwo Wrote:  
(02-20-2020, 01:24 PM)Peetwo Wrote:  
(01-17-2020, 07:07 PM)Kharon Wrote:  Friday Arvo Fax.

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

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

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

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

St. Commode said this:



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

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

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

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

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

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

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

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

Toot – toot.

Oops! Bristell plastic fantastics back to bite -  Blush

Via the CASA:



[Image: Bristell-SN.jpg]


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

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

Via the Oz:

Quote:Soar Aviation still training pilots during review

ROBYN IRONSIDE
Follow @ironsider

[Image: d40fd6182d12bc93eb71b2b179138e6e?width=650]


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


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

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

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

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

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

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

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

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

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

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

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

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

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

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

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



Comments:

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

David
3 HOURS AGO
Fasten your seat belts.

Turbulence ahead.

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

MTF....P2  Cool
Reply
#4
Star 

Two GOLD STAR  choccy frog submissions -  Wink  

Mr Jonathan Kelly (PDF 60 KB) 

Quote:Current Situation:

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

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

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

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

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

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

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

Quote:[Image: CM-1-e1582292347872.jpg]
[Image: CM-2-645x1024.jpg]
[Image: CM3-688x1024.jpg]
[Image: CM4-677x1024.jpg]
[Image: CM5-643x1024.jpg]


MTF...P2  Tongue
Reply
#5

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

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

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

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

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

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

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

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

The notion, which is still well entrenched in government circles, that government doles out ‘privileges’ to it’s ‘subjects’ is an anachronistic feature derived from the medieval practice whereby the Monarch held all privileges and had the only power to dispense same.
Reply
#6

First ANON submission -  Rolleyes

Name Withheld (PDF 292 KB) 


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

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

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

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

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

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

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

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

MTF...P2 Tongue
Reply
#7

2nd & 3rd ANON submission -  Rolleyes

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


Name Withheld (PDF 66 KB) 


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

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

(see submission)


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

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

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

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

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

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

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


Name Withheld (PDF 133 KB) 



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

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

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

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

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

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

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

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

(see submission)


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

(see submission)

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

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

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

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

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

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

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

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




MTF...P2  Cool
Reply
#8

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


Attached Files
.pdf Old CAR 5 FIR Vs Part 61 cost Sept 2018.pdf Size: 202.9 KB  Downloads: 6
Reply
#9

Submission 9 ANON, 10 AMROBA:  



Name Withheld (PDF 368 KB) 

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

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

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

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

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

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

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

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

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

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

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

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

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


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


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#10

Sen McDonald back to work Monday -  Wink

Via FB:



[Image: BB11f8e7.img?h=0&w=720&m=6&q=60&u=t&o=f&...1122&y=662]

Senator Susan McDonald
2 hrs ·
*CONDITION UPDATE*

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

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

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

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

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

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

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

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

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