[Peetwo]

Off the Yaffa...

In Dougy's insight this week there was an interesting bit related to the CASA Proposed Airworthiness Directive - PAD/PROP/1 Amdt 3.  Dougy not normally known for delving into such matters - of a private pilot/small aircraft owners nature - took up the cause from the Mooney Pilot's Association perspective on the above PAD... - Editor's Insights 11 June 2015

The Mooney Pilots Association is concerned about a CASA ruling on propeller maintenance and the impact it will have on operating costs - and it’s not just Mooneys.

The CASA direction says, in part, that action “is required due to information received through the CASA Service Difficulty Reporting system and other reports indicating that propellers that are presented for repair/overhaul at extended calendar times commonly exhibit defects that compromise the flight safety of aircraft”.

The MPA says that, “Like other recent initiatives from the airworthiness group in CASA, this proposed amendment is justified only by anecdote and unsubstantiated assertions. There is no evidence presented as to the frequency of such deficiencies; whether those faults should have been discovered earlier during operation and/or annual inspection; and whether such faults have been significant factors in the past accident record either in Australia or overseas”.

Apparently, propeller system failures were implicated in only 12 of 1654 accidents in a US fixed-wing piston fleet of 170,000 aircraft, so such failures account for a very small proportion of accidents and there is no reason to believe that the incidence would be any greater in Australia. MPA Says that the total annual cost to owners in Australia would be about $3.5 million. 

P2 observation:

As a sideline, Dougy in last week's insight happened to mention...

"..I was going to look at Dick Smith’s latest engagement with the media about airspace issues on the NSW north coast, but people I have spoken with this week have suggested that there’s a lot more to this than just a headline; so I’m postponing comment until next week while I absorb more perspectives from industry and government. I’m happy to hear what you have to say too.."

However in this week's insight Dougy appears to have gone cold on the idea??

"..Has the Dick Smith-highlighted airspace issue around Ballina more or less gone away? CASA certainly defused the whole thing during the week, though I notice there’s still attention being paid to it in the media.." 
Come on Dougy you know you want to..

For the benefit of Gobbles & crankybastard  there was a comment from last week's Dougy's insight that they might be interested in  :

Brian J Hannan • 7 days ago

Doug, I read the Australian article and smiled. Let's create fear in the travelling public as a political pressure.

Why don't we have wall to wall air traffic control and surveillance? Something in the back of my mind about Australia adopting "user pays" (pay our way, have our say) whereas the USA doesn't have that and so provides ATC as a service.

Then there is surveillance. I'm not aware of Dick being a proponent of ADS-B to extend surveillance, in fact I believe he won't fit it to his Citation.

I'm sure the great unwashed readers might believe someone with a radio on the ground at Lockhart River might have saved the day - I'm uncertain how that would have stopped someone deliberately breaching the LSALT.

Surveillance costs $. Do you see the airlines calling for towers and ATC? From memory Avalon was carrying over a million pax a year, with nearby ESL students flying through the airspace, before the airspace study and tower was forced through.
You speak the truth, there is a lot more to this than just a headline ;-)

 

We then had this article from Hitch on the same issue - Proposed Six-yearly Prop Overhauls rile GA Community - & where SH gathered further feedback from industry, example:

Aeroplane owner and former president of the Aircraft Owners and Pilots Association (AOPA) Australia, Andrew Andersen, says that the proposed six-year overhaul period is not supported by the evidence CASA cites in the PAD.

"CASA has completely failed to make a case for this proposed change to an existing AD," he said. "It claims that its proposal is supported by SDR data, but this not so. It has changed the applicability of the AD and introduced new, arbitrary, CASA-invented requirements, without justification.

"CASA has not properly described the impact of the proposed legislation. It does not include an estimate of the number of affected aircraft, or the estimated cost of its proposals. CASA is imposing further cost on GA without disclosing the economic impact of its proposals.

"It is noteworthy that all FAA proposed airworthiness directives include an estimate of the number of affected aircraft and the cost. CASA rarely does, and then only when required to do so by another government agency. It is very hard to reconcile the government’s response to the ASRR [Forsyth Report] with such arrogant behaviour."

According to Andersen, of the 253 SDRs that apply, only 13 were reported as corroded and 12 as leaking oil.

Hitch finished the article with this...

"..Other submissions to the PAD are believed to be concerned that the lack of reasoning and process behind the conclusions are inconsistent with promises from CASA DAS Mark Skidmore that new regulations must take into account the impact on the industry and show a clear improvement in safety.."

Which brings me to the next Hitchen offering which focusses on a recently released Directive from the new CASA DAS Skidmore - DAS Directive - 01/2015:

Parliament House Canberra. (Department of Defence - LAC Michael Green)

DAS Directive demands Cost-effective Regulation
12 Jun 2015

CASA Director of Aviation Safety Mark Skidmore has issued his staff with a directive demanding new regulations be risk-based and cost-effective.

The directive is dated 29 May and was made public earlier this month.

"Aviation safety regulations must be shown to be necessary. They are to be developed with a view to addressing known or likely safety risks that cannot be addressed effectively by non-regulatory means alone," the directive states.

"Consistent with CASA’s obligations under the Civil Aviation Act and other Commonwealth laws and Government policies, every proposed regulation must be assessed against the contribution it will make to aviation safety, having particular regard to the safety of passengers and other persons affected or likely to be affected by the activity involved.

"If a regulation can be justified on safety-risk grounds, it must be made in a form that provides for the most efficient allocation of industry and CASA resources. Regulations must not impose unnecessary costs or unnecessarily hinder levels of participation in aviation and its capacity for growth."

The directive also demands that CASA staff:

• Align safety regulations with International Civil Aviation Organisation (ICAO) standards
  
• Consult with industry in an open and transparent manner
  
• Strive to ensure regulations are drafted as clearly and concisely as possible
  
  

When it comes to applying the regulations, Skidmore makes it clear that he wants CASA people to take into account all relevant factors including burdens when it comes to exercising discretionary powers, and that CASA will adopt an alternative means of compliance where a person can demonstrate that the same outcome can be achieved in a less onerous way.

Finally in Hitchen's weekly wrap - The Last Minute Hitch: 12 June 2015 - we get Steve's opinion on all of the above, plus his take on the AHIA recent inroads v CASA with their proposed changes to Part 61:

Either the new CASA is experiencing some growing pains or it is simply a re-badged version of the old CASA, sort of like marketing the Toyota Camry as a Holden Apollo. The evidence lies in two stories that would appear to be inconsistent: the proposed AD on propellers and Mark Skidmore's directive to make regs risk-based and cost-effective. If industry analysts are right when they say the new PAD on props appears not be supported by evidence, then it is hard not to hold this up as an example of exactly what the DAS directive says that CASA won't do. Are we supposed to believe the right-hand or the left-hand? To give a bit, the DAS directive did come out after the PAD was released, but you would think the inconsistency would prompt it to be withdrawn.

On the upside, the helicopter people seem to be making headway in their quest to inject some sensibility into CASR Part 61. Clearly, they are prepared to step-up and show CASA how it needs to be done, and I believe their approach is the right way forward for the industry. CASA is lacking expertise in a number of areas at the moment, which is not helping them to draft logical regulations. They only way we can stop some of the non-sensical stuff flowing from Aviation House is to get in there and provide the expertise they lack.

   
MTF...P2