[Peetwo]

Two GOLD STAR  choccy frog submissions -   

4 Mr Jonathan Kelly (PDF 60 KB) 

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.

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

MTF...P2