Every one of those action items is so qualified as to be utterly meaningless.
“The aim is to cut through regulatory red tape as much as is possible while not jeopardising appropriate and necessary safety standards. We need change to get the balance right between the regulations that are required to deliver the safety outcomes expected by the Australian public, without imposing unfair burdens on day-to-day operations.”
The rest? Considering, prioritizing, reviewing everything else presumably to make it appropriate, proportionate and impactful on the General Aviation space. Rubbish!
Ms. Spence, I know you mean well but you are building on sand. Until the Act is rewritten you are wasting your time because the lawyers hamstring each and every initiative, leaving you with the impression you have succeeded while delivering nothing of any value.
Here’s a hint; compare the marine and aviation Acts. Notice anything? Look at the duties of the regulators; AMSA (?) and CASA. The Marine Act specifies these as”‘AMSA must issue provided that… ….”. The Aviation Act: “CASA must not issue unless it is satisfied that..”.You must have been taught that the latter form is a direct and open invitation to official corruption.
Look at how the Marine Act spells out the requirements for certificates and ratings in black and white while CASA hides behind “appropriate, sufficient” and of course “acceptable”. Coupled with “must not” this is an impassable road block to common sense.
Look at how the duties of Captains, staff etc. in the Marine Act are spelled out and qualified by the word “reasonable” wherever there is room for interpretation. CASAS DICTIONARY DOES NOT CONTAIN THE WORD “REASONABLE”!
And finally look how the use of “Strict Liability” is limited to only the most serious offences in the Marine Act instead of being sprayed around like graffiti by the Aviation Vandals of CASA that now work for you.
Merry Christmas and good luck for 2022.
“The aim is to cut through regulatory red tape as much as is possible while not jeopardising appropriate and necessary safety standards. We need change to get the balance right between the regulations that are required to deliver the safety outcomes expected by the Australian public, without imposing unfair burdens on day-to-day operations.”
The rest? Considering, prioritizing, reviewing everything else presumably to make it appropriate, proportionate and impactful on the General Aviation space. Rubbish!
Ms. Spence, I know you mean well but you are building on sand. Until the Act is rewritten you are wasting your time because the lawyers hamstring each and every initiative, leaving you with the impression you have succeeded while delivering nothing of any value.
Here’s a hint; compare the marine and aviation Acts. Notice anything? Look at the duties of the regulators; AMSA (?) and CASA. The Marine Act specifies these as”‘AMSA must issue provided that… ….”. The Aviation Act: “CASA must not issue unless it is satisfied that..”.You must have been taught that the latter form is a direct and open invitation to official corruption.
Look at how the Marine Act spells out the requirements for certificates and ratings in black and white while CASA hides behind “appropriate, sufficient” and of course “acceptable”. Coupled with “must not” this is an impassable road block to common sense.
Look at how the duties of Captains, staff etc. in the Marine Act are spelled out and qualified by the word “reasonable” wherever there is room for interpretation. CASAS DICTIONARY DOES NOT CONTAIN THE WORD “REASONABLE”!
And finally look how the use of “Strict Liability” is limited to only the most serious offences in the Marine Act instead of being sprayed around like graffiti by the Aviation Vandals of CASA that now work for you.
Merry Christmas and good luck for 2022.