[Peetwo]

Industry v Insanity - P2 supplemental

Every time; and, I do mean every time there is an opportunity for industry to participate in in setting a course away from disaster or on the road to recovery it, weighs in.  Willingly, unstintingly and at little or no cost to the government the industry provides expert, considered opinion, provides cost effective solutions and indicates a willingness to assist with effective, sensible reform programs.  Gratis, no charge advice on which a minister could rely and fund, not only saving the Commonwealth millions, but earning even more revenue, not to mention jobs and investment opportunities.

Look at some of the standout submissions, from Pel-Air through Forsyth and on to the latest Productivity Commission; there are some first class, top drawer submissions made which provide empirical evidence of industry ‘expertise’.  The latest from AAAA is an exemplar: sane, balanced, practical, fully supported by membership, totally achievable and capable of ensuring safety and increased productivity – in short; the right solution.

Over the past decade many such documents have been provided by industry; over the past decade almost none of those documents has been put on a table, discussed with the ‘authority’ and implemented.

Over the past decade the government appointed ‘experts’ have gone to extraordinary lengths to avoid embracing the expert advice of industry specialists, independent reports, analysis and solution.  Even ministerial directives get short shift.  AMROBA, AOPA, AAAA, Forsyth etc. all get the same treatment, a lot of lip service, enough action to provide credible evidence for the minister to state that ‘something’ is being done; then, after a suitable time period in limbo, good ideas are taken out the back, their throats quietly slit, the carcass buried in the departmental graveyard.  RIP.

We spend millions on the care and feeding of things like CASA who could not, on their best day produce a submission to match the AAAA effort, which was gifted to the nation.  We need to ask why we are squandering a fortune employing non expert dead beats who’s sole purpose in life seems to be playing at policemen, ‘prosecution’ and decimating industry initiative.  This occurs throughout the agencies, ASA, ATSB and CASA; incompetent, non experts running multi million dollar enterprises which ignore expert advice on the very thing which necessitates their existence; i.e. the well being of industry and those who manage it, very well, despite dragging the lead weight of departmental arrogance and ignorance behind it, then having to fund that incubus. But don’t just take my word for it; compare the AAAA submission (which we have for free) to the Chambers report; or, the Pel-Air report (both of which we paid dearly for) on a benefit to industry basis and decide for yourself.

It is insane.

For want of a nail the shoe was lost.
For want of a shoe the horse was lost.
For want of a horse the rider was lost.
For want of a rider the message was lost.
For want of a message the battle was lost.
For want of a battle the kingdom was lost.
And all for the want of a horseshoe nail.

Selah.

PS.  Nicely done Phil, well done indeed.

To reinforce the P9 post one only needs look at the following post extract to see that the Department, CASA, ASA & the ATSB have a normalised deficient culture of notifying a difference to ICAO: http://auntypru.com/forum/-Shame-or-fame...12#pid3912

So I decided to do some basic research to see just how 'unique' Australia is as a fellow signatory State to ICAO. The empirical evidence so far is simply staggering.

To begin note my comment from this post - AMROBA on Harmonisation

P2 Comment - Here is a link for the latest list of Australian notified differences - [/url]https://www.airservicesaustralia.com/aip/current/sup/s15-h104.pdf. Note the AIP SUPP is now four pages of relevant links to individual Annex differences. The reasoning for the change to the SUPP, listed at Para 1.2, is absolute bollocks, this is just another cynical attempt to cover up the embarrassing number (over a 1000) of notified differences to ICAO SARPs

 
 For ease of access I've created our own link - HERE - and for an example the following is a link for the ICAO 'Airworthiness Standards' notified differences - i.e. Annex 8

Okay so when collated, as of 10 Dec 2015, there is now a unbelievable 318 pages of 'notified differences'. My final count on the 'NDs' was at 3116, however because I lost count a number of times.
 
The highest count of an individual annex or volume of an annex was in Annex 10 Volume 4 with 591 and the highest page count was from Annex 14 Volume 2 with 88 pages.

The lowest count for an individual annex is for Annex 12 with zero, which is extremely ironical and speaks volumes because it is one of only a couple of SARPs that does not involve CASA, ASA or the ATSB - well done AMSA

So there you go, empirical proof that our aviation safety regulatory system is a complete and utter basket case when benchmarked against 'global standards'  
Wake up PM, Minister & the CASA board, it is not going to sort itself out.

Of the ICAO SARPs Annex 13 & 19 are integral to the proper implementation and effective administration of a State SSP. However as a further indicator that the Australian aviation safety bureaucracy is merely paying lip-service to the spirit & intent of ICAO, one only needs to review the 'notified differences' for A13 - http://www.airservicesaustralia.com/aip/...nex_13.pdf -

; & A19 - http://www.airservicesaustralia.com/aip/...nex_19.pdf .

There is a combined 12 pages and total of 55 NDs for the two Annexes.

However the real cynicism and affront to industry is within the detail. Let me explain, quote from department SSP DRAFT request for industry comment:
 

On 4 December 2015, the Department released an updated draft SSP for aviation industry and public comments. The comment period has now closed.

 
Note the date. Now refer to AIP SUP H104/15 [url=https://www.airservicesaustralia.com/aip/current/sup/s15-h104.pdf]  The SUP was issued on the 10 Dec 2015 and notified additional differences to at least 2 of the Annexes instrumental to the administration of a State SSP. So are the relevant notified differences, in particular with Annex 19, preempting the DRAFT SSP being implemented without amendment? How can that be possible when industry stakeholders were yet to comment?

The other option is that the NDs for Annex 19 are based on the current and original SSP.

However the current SSP was published in April 2012, how is it then possible to have additional NDs for a supposedly ICAO compliant document that has been in place for more than 4 years? 

Here is hoping that Murky's mob will eventually publish all industry comments on the 4 Dec 2015 DRAFT SSP..


MTF...P2