[Peetwo]

Submission 20 (ANON) & 21 (Mary Brown) - 

Via Parl website:

20 Name Withheld (PDF 69 KB) 

Summary

CASA’s regulatory reform program, based as it is on safety, has not
demonstrated safety deficiencies that required reform in the first place.
Regulatory reforms have not addressed the financial or economic impact of


proposed changes. Post implementation, has not documented the safety
improvements of reforms, nor the safety improvements arising from them.
Despite public statements to the contrary, CASA’s interaction with the
general aviation industry continues an adversarial approach to
implementation and surveillance.

These issues have been identified and have been well documented in
previous reviews. The problems are long standing and reflect a deep seated

culture within CASA seeks at every opportunity transfer risk from itself to

general aviation. CASA’s resistance to change is also well documented.

Until the organisation’s resistant culture can be changed, the viability of
general aviation will continue to decline rather than thrive.

21 Mrs Mary Brown (PDF 227 KB) 

4. Any related matters.

A report from the Australian Transport and Safety Bureau ‘Aviation Occurrence Statistics 2008-2017’
clearly identifies that the number of fatalities in GA and RA during 2017 were consistent with the
previous nine years. This in itself demonstrates that CASA delivered no measurable safety
improvements during this time. In 2008, according to the CASA Annual Report (07/08), CASA employed
653 employees. CASA’s 2016-17 Annual Report stipulates that the Organisation had 830 employees.
Whilst no measurable safety outcomes were delivered, a raft of regulatory changes WERE delivered, as
evidenced by the increase in the Organisation’s staffing levels over the period examined by the ATSB
Statistics report.

In addition to the increase in staffing levels, we have seen CASA move to an electronic platform as its’
preferred means of communicating and consulting with Industry. The Organisation’s apparent
reluctance to directly engage with stakeholders has resulted in a communications breakdown that can
only be remedied with improved access to face-to-face exchanges and personal communications. Many
within the Industry admit to being able to communicate more effectively in person than on-line. It is that
personal interaction that will facilitate a more positive relationship between Industry and CASA, and allow
CASA to glean a full understanding of the sentiments of those operating within the space of GA. Many
of these Operators are highly skilled, exceptionally knowledgeable and expertly practiced in the
practicalities of safe and sustainable aviation in Australia.

With regards to communications with CASA, a worrying scenario exists with the interpretation of Rules,
AD’s, requirements etc. It is often found that interpretation, rather than solid clarification, is offered by
CASA representatives when contacted for assistance from Industry. These interpretations differ from
staff member to staff member. It has become obvious to Industry that if CASA cannot agree to an
interpretation, the clarification that industry needs can never be obtained. In summary, if our regulator
cannot answer Industry’s questions, how can Industry comply?

Australian aviation has the capacity to return to the vigorous and exciting industry it once was, as we are
incredibly well positioned to be a training ground for pilots and engineers to specialise in their fields, and
meet the needs of an ever-evolving and improving industry. We simply need to be equipped with the
tools to do so. Unfortunately under CASA’s current operational structure, scope and delivery style, there
is very little confidence within the industry that this will ever eventuate, unless urgent, industry knowledge
and proactive expertise can be introduced into the organisation.

Yours in Aviation,

MTF...P2