[Peetwo]

Carmody Capers - Final Episode 

Wasn't going to give any oxygen to the cynical, 'up yours' submission composed by St Commode and the self-serving, evil spin-meister Dr Hoodoo Voodoo Aleck...

However, despite being fairly typical of past divisive (ie 'divide and conquer'), subjective reply submissions from Fort Fumble, there are certain parts that I feel really need to be exposed to highlight the extreme disconnection with reality that still exists within the ranks of the executive management and by default the current CASA board...

Ref RRAT GA inquiry webpages:   

46 Civil Aviation Safety Authority (PDF 408 KB) 

Extracts:

Numerous submissions to this Inquiry made positive comments about CASA’s improvements in its approach to stakeholder engagement, such as the following statement by the Regional Aviation Association of Australia (RAAA):

The efficacy of CASA’s engagement with the aviation sector, including via public consultation, has never been better. Talk about cherry picking/selective bias -   

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The performance of CASA’s stakeholder engagement and communication with industry is tracked through a regular stakeholder relationship health survey – Measuring our Performance. The scores from the most recent survey in 2018 demonstrate a marked improvement in performance when compared to the 2015 survey #1. CASA is currently conducting the 2020 survey #2. 



P2 - #1 for some historical references on the 2018 bollocks survey refer: Carmody hour comes to the Senate & Dear Miniscule 8G McDo'Naught - L&Ks AGAA (the real voice of General Aviation)

#2 refer from post #58 (above) on how that's working out??  

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Inquiry Submissions

CASA acknowledges the considerable effort made by various individuals and groups who have provided submissions to this Inquiry. In considering their submissions we believe it is important to identify and comment on some themes and to address some apparent misconceptions.

The appropriateness of the Act is a theme in many submissions. Some, such as Mr Dick Smith AC, consider the amendment to the Act in 2019 to ensure that amongst other things, CASA considers cost in developing and promulgating certain aviation standards was not sufficient and that further changes are needed. Alternately, the Australian and International Pilots Association opposes the inclusion of economic considerations in the Act as it conflicts with CASA’s mandate to curb unsafe behaviour. Others, such as the Aerial Application Association of Australia (AAAA), push for an independent review of the Act. It is CASA’s view that the Act is generally fit for purpose and amendments are a matter for Government.

Some submissions question the appropriateness of CASA’s regulatory model, stating it is too complex, prescriptive, and burdensome. For example, the AAAA maintains that the CASRs are ‘engorged’ compared to the previous regulations. It outlines regulations around pilot licensing, stating the previous approach in Part 40 of the CAOs was around 208 pages while the new CASR Part 61 (flight crew licensing) is about 700. The AAAA appears to have confused the Regulations (which has 242 pages of regulatory text) with the MOS which is 698 pages. Hmmm...that's gotta smart, wonder if PH will let that comment ride...

The reality is that CASA has simplified the flight crew licensing system -  Perhaps we need a line out of Alice in Wonderland in response to that line out of a faerie tale (hint "K" -  ) , with industry only needing to refer to Part 61 and its supporting MOS, rather than 24 separate pieces of legislation or standalone syllabuses of training. The Recreational Pilot section (sub part 61.G) is only one page. We acknowledge that while the Part 61 MOS is long, it also contains numerous syllabuses of training. The important point is that only the chapters relevant to each pilot licence type and sub-sector need to be reviewed.

After many recent amendments, CASA acknowledges that the implementation of Part 61 has not been well explained or well received. We have learnt from this by setting up a taskforce to review Part 61 operations and making changes in consultation with industry. Building on this experience, CASA is now undertaking detailed preparations for the transition to the flying operations suite to improve the understanding of both CASA staff and industry of how these regulations operate before they come into force.

Another common theme in the submissions is that the economic burden of regulatory compliance is too high. However, as outlined in submission 16 by Anjum Haweed and Kyriakos Kourousis, the ageing fleet in the general aviation sector means that the costs for keeping these aircraft flying are higher than for new aircraft. The cost of maintenance has increased, along with the cost of parts, particularly for older aircraft which require more maintenance more often. As outlined earlier in this submission, the relative cost of adhering to safety regulations is relatively minor at four per cent.

The submission from Professionals Australia suggests CASA is experiencing cultural problems and workforce challenges, particularly in relation to technical roles. CASA acknowledges that technical staffing numbers have fluctuated over the past few years, however it is important to note that CASA is in transition to a new centralised, cross-regional office approach that enables allocation of resources where they are required and is designed to deliver consistent national outcomes. The strong feedback on the 2019 Census results around being proud to work at CASA (77%) and engagement and confidence in their direct managers (78%) does not support the allegation of poor culture.

Many of the submissions, such as that from the RAAA and the AAAA, refer to the positive changes CASA has made to its approach to consultation and stakeholder engagement. CASA is grateful that the industry has noted the significant efforts made to improve this. CASA is committed to further improving engagement with the aviation community to ensure safety solutions are practical, proportionate and effective.

Some submissions, such as from the Sports Aircraft Association of Australia (SAAA), identify perceived inequities for medical standards between recreational pilots and private general aviation pilots. The content of the SAAA’s submission fails to acknowledge that the reasoning behind recreational aviation pilots having lower medical requirements, is because they are limited to fly aircraft under 600kg, are only allowed to carry one passenger, may only fly in non-controlled airspace and are restricted to fewer airports. In contrast, this very difference is supported by the RAAA who understand and appreciate that recreational pilots have less onerous regulation because they may not operate in the commercial world and are generally restricted only to private flying outside of controlled airspace.

CASA is pleased that the RPAS industry recognises the work CASA has undertaken in the RPAS sub-sector and looks forward to working with the Australian Association of Unmanned Systems and other RPAS associations to progress the regulatory framework for this area.

Conclusion

CASA strives to ensure a positive and collaborative safety culture through a fair, effective and efficient aviation safety regulatory system. To achieve this, CASA works diligently to improve the regulatory environment for all aviation sectors. CASA regularly consults in a variety of ways to ensure that all issues are considered in the development of any new or amended regulations or standards. A great deal of effort is exerted to ensure that CASA’s client-facing systems are efficient and effective. While CASA’s systems and processes have improved, there are always further improvements we can make. CASA looks forward to working together with industry to ensure Australia’s aviation environment remains one of the safest in the world. 

Much MTF...P2 

ps For the benefit of the Senators for what should be (IMO) a submission to this inquiry please refer to this archive post plus links for the DJ Llewellyn submission in support of Bruce Rhoades (may he RIP -  ): 

 What’s wrong with CASA (and the Aviation Industry)?