[Peetwo]

Submission 60 & 61.

Via RRAT 20/20 submissions: 

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60 Regional Airspace and Procedures Advisory Committee (RAPAC) (PDF 130 KB)

South Australian RAPAC statement to enquiry

Committee Secretariat
Senate Standing Committees on Rural and Regional Affairs and Transport

Email:rrat.sen@aph.gov.au

Dear Sir / Madam:

RE: Senate inquiry into the current state of Australia’s General Aviation industry.

Please accept the South Australian General Aviation industry submission to this Senate Inquiry. We
have canvassed a range of opinions from General Aviation operators across South Australia to
prepare this submission, and trust that the issues raised will be addressed. The experience
represented here is broad, and includes operators at all levels of General Aviation. We note that
General Aviation operators offer charter services, scenic flights, search and rescue operations,
passenger and freight transport, mustering services, photography and survey services. All these
services are ad hoc services, and operate according to bookings. We note that for the purposes of
this submission, General Aviation does not include Regular Public Transport services with published
and fixed routes.

Recommendation 1: That the Federal Government provide the aviation industry with their vision and policy platform for the future.

Recommendation 2: That the Federal Government complete and publish the Future of Aviation paper as soon as possible.

Recommendation 3: That the Federal Government act on all recommendations as stated in the Aviation Safety Regulation Review, as presented to the Federal Government on 3 June 2014 by Warren Truss, the then Minister for Infrastructure and Regional Development.

Recommendation 4: That all locations capable of providing a TAF be returned to providing a TAF around the clock.

Training:

CASR Part 61 governed the introduction of the flight crew licencing regulations to Australia’s aviation
industry, and was introduced on 1 September, 2014. Prior to the introduction of Part 61, the then
Director of Aviation Safety re-assured the industry that “what you can do today, you can do
tomorrow”. Regrettably, this was not the result, and a level of bitterness remains.

Part 61 introduced a number of new flights tests to check pilots’ skills for things that used to be
handled under a flight review, or similar. Since Part 61 has been introduced, only flight examiners
can conduct flight tests. Accessing the individual or organisation with the required qualifications to
examine these skills is proving a costly exercise for the regional and remote operator. Either crew
and aircraft need to be re-located to the location suitable for the examiner. We note that a the
majority of aircraft used in General Aviation are not available at the average training school, hence
the relocation of both crew and aircraft.

Alternatively, the examiner – with all associated costs – must be re-located to the business location.
Unfortunately, some of the items to be checked (3D approaches, or certain classes of airspace)
cannot be re-located, which is why relocating aircraft and crew remains the preferred, albeit more
costly, option.

The added complexity of training regulations has seen a number of flight schools close, or drastically
alter their business model to remain viable. It would be hoped that this exercise would be seen as a
warning for future regulatory amendment, but it appears not to be the case.

Recommendation 5: That General Aviation operators be separated from RPT operators and be
permitted to operate under a fatigue management system as described in CAO 48.1 (published 8
December 2004).

Recommendation 6: That CASA release the finalised Part 135 / Part 138 regulations, in plain English.

Recommendation 7: That CASA ensure that pilot maintenance, as described in Schedule 8,
Paragraph 42ZC (4) (d) in the Civil Aviation Regulations 1988, be retained.

Recommendation 9: That the Government make available as soon as possible a grant scheme for
affected GA businesses (including maintenance organisations) similar to the scope of the Exceptional
Circumstances scheme eligible to agricultural businesses affected by drought.

Recommendation 10: That the Government re-instate Jobkeeper for affected GA businesses who
can prove a decline of 30 per cent or more on 2018 / 19 financial year.

Recommendation 11: That the Government make available a loan scheme of up to $2 million at
minimal interest targeted at aircraft refurbishment / replacement.

61 Outback Helicopter Airwork NT Pty Ltd (PDF 685 KB)

CYLINDER & VALVE WEAR – BAD FUEL

Like other operators from the northern regions around 2016 we started to notice changes in the fuel
supplied by our normal fuel suppliers, mainly a different smell, different colour and different
consistency/feel. Spark plugs were running hotter and wearing out significantly quicker. At times we would only get 100 hours out of a plug instead of approx. 500 – 600 hours. Cylinder and oil temperatures began to run hotter to a point where we started having regular issues with valve wear in the cylinders.

In 2018 we purchased a completely brand-new Robinson R44 Raven I helicopter at a cost of over
$600,000.00 with the expectation of having a full life out of the engine with minimal major maintenance and downtime. However, our first major maintenance was carried out at an astounding 178.2 hours Total Time where three (3) cylinders failed at once. So out of a 2000-hour life item (the engine) where you would typically not need to replace a cylinder (pre low lead 100LL fuel), we only managed 178.2 hours before the cylinders broke down, which equates to only 8.64% of the full life of the component.

These valve wear issues continued at an unprecedented level creating major concerns for the safety of our pilots and aircraft. Concern was consistent throughout industry as many operators especially in the northern regions were experiencing the same problems and frustrated with CASA’s response and lack of action regarding the matter. To help find a cause for why cylinders were suddenly consistently breaking down we took part in the AHIA funded investigation into the durability issues in Lycoming 0-320, 0-360 and 0-540 Engines fitted to Robinson Helicopter R22 & R44 models dated 21/10/2019.

Our normal fuel suppliers whom we purchase fuel in bulk were now suppling low lead fuel 100LL as a
replacement for the older type of leaded fuel 100/130 with no notification of the change. As we felt the
valve damage was caused by excessively high operating temperatures because of using the low lead fuel, we searched for suppliers who could provide leaded fuel so we could stop the problem. At the time there was only one provider who could supply the leaded fuel but only in 44-gallon drums not in bulk amounts.

This mean the cost was much higher in drum form, but we were willing incur the higher charges if it would fix the problem.

We found that by using the 100/130 leaded fuel seemed to lower the oil and cylinder temps and resulted in a reduced number of cylinders required to be repaired or replaced. 100/300 leaded fuel is now available in bulk form however many of our clientele who provide their own bulk fuel opt for the cheaper low lead version which still creates a problem for us. We try to utilize the 100/130 fuel as much as we can, but we cannot dictate what our clients provide.

The current price for 100LL low lead fuel is $2.26 per litre and the 100/130 leaded fuel is $2.55 per litre. A difference of $0.29 per litre. When purchased in bulk amounts a difference of $0.29 adds up. See example below. e.g., 14,000 litre bulk tank @ $0.29 per litre = $4,060.00

Since mid-2017 we have replaced an incredible 49 cylinders on our three (3) R22 and two (2) R44 helicopters some of which only managed less than 100 hours. That is less than 5% of the full life of the cylinder (at 2000hours). Some of these cylinders have been under warranty however a warranty claim does not cover the full cost of the cylinder or the engineering time it takes to remove and re-install. The cost for this unscheduled maintenance, loss of income due to downtime, freight costs, repair costs and admin costs has been an astronomical burden on the business, myself as the owner and my staff.

PART 61 LICENCE CHANGES – additional check and training requirements

Under PART 61 Aerial Application operations which include agricultural spraying and firefighting require an annual proficiency check which is over and above Bi-annual Flight Review pre PART61.

This annual check is also required to be carried out by an approved flight examiner and there being no flight examiners in Darwin with the required credentials, we must source someone from interstate which also includes additional costs for flights, accommodation, travel time, car hire etc.

We recently completed our Application Rating training and Bi-annual flight review in July 2021 with an
independent flight examiner from interstate at a cost more than $5,500.00. Compared to other operators in other states who can provide this service for their pilots at approx. $400.00 per person.

To rub salt into the wound CASA brought out an extension of time for Flight Reviews and checks in August
due to COVID19. CASA EX100/21 – CASA EX92/21 – Extension of COVID-19 Relief Measures – Amendment
Instrument 2021.

Recommendation

CASA to provide an exemption to the CASR regs to allow a Chief Pilot from a third-party operator be able to conduct Aerial Application and Airwork Operations Proficiency Check & Training in replacement of a flight examiner who can then check & train in house personnel. This would alleviate the need to engage
examiners from interstate and reduce the cost burden on the business.

PART 138

CASA is pushing for the New Part 138 Operators Certificates into the Aviation sector by 02.12.21. to replace the current AOC Airwork Operations. They say it’s going to be easier, simpler and user friendly than the old Air Operator Certificate system. CASA have created another document which will add to the confusion and minefield of regulation and added cost to businesses. There are so many elements to it, pilots will be overloaded by paperwork, it’s just another case of been miro managed from CASA.

 Mustering Operations Certificate has 62 pages
 MOS Manual of Standards (Aerial Work Operations) has 102 pages

WORKER’S COMPENSATION INSURANCE

Northern Territory Worker’s Compensation Insurance is one of our major costs. Since 2009 when the
company started, we have paid over 20.0% workers comp for all staff regardless if they are a pilot, general labourer or office staff. That rate increased to 26.5% over the previous 5 years. Despite seeking quotes from alternative providers this is the best rate we have been able to get despite having had no accidents, no incidents, and no claims. The table below shows alternative quotation rates sourced, 2019.

K Addendum: (sent via carrier pigeon) "K" is apparently out of range of the NBN ( ), so I am posting this on his behalf...

If's and Buts.

"If only" - (fill in the rest) - is a lament oft heard, usually related to some awful result which could (perhaps) have been avoided. Then there is the remarkable, ever present  'but'. Combined, they open up a world of situations which are in the 'past' - almost always retrospective; the tragedy is it is no easy matter to revisit or reset time.

"Things without all remedy
Should be without regard: what's done, is done."

The Buckley saga as a 'one off' event is being treated 'without regard' : and were it an isolated incident then 'what's done, is done' may well be applicable. BUT that's not the case is it?

There exists many decades of evidence to support the argument that many of the 'operations' which have been closed down were victims of some very dubious 'evidence' artfully manipulated and carefully 'hay-stacked' by the 'Authority'. This has been demonstrated through the many 'battles' lost in the AAT and even in a court of law. Yet any careful study of case history reveals some common threads - not in the 'evidence' formally presented but at the radical event level. In isolation many of the 'charges' brought are amplifications, projections, if you will, of 'something - nothing'. A clerical error for example; aircrew, the world over, are notoriously famed for 'bloody awful' paperwork. Fair call too; end of a long, difficult flight the minutiae can be overlooked by crew still recovering from a tough shift. But I digress.

What has been done and what is still being done to Buckley is not an isolated case; nor is the CASA action 'rare or unusual'. The McDolittle 'inquiry' is still valid; currently exposed as a waste of time, effort and money; nevertheless it could (and should) become productive if it took a long, hard, close look at the extensive list of 'shut-down' operations and the methods used to achieve that goal. IMO that will never happen; should that particular genie ever escape the bottle the ramifications would be significant.

It is possible to present an extensive submission providing not only 'fact' but detailed analysis of how many operations were terminated on some very shaky 'say-so' supported by, shall we say 'enhanced' evidence, artfully embellished. If this current Senate 'inquiry' is to have any meaning, or serve any useful purpose, then now would be a good time to stop fiddling about the edges and take the Buckley saga as a corner stone for setting to rights the 'way' in which matters aeronautical are managed by the CASA and return industry to a place were the regulator can be trusted. Back to the rule of law, not of an opinion manipulated to suit 'the law'.

I know; the fool is dreaming - confusing Australian regulatory action with what the rest of the first world expects of their regulator. But; if it pleases, a man may dream. There now 'if's and buts' v stark reality.

Toot - toot.

 
MTF...P2