[Peetwo]

Red tape embuggerance continues unabated at Aviation House -

Continuing on the theme - of red tape and the 30+ year, $500+ million, aviation safety bureaucracy's embuggerance of the regulatory reform program - I note that Sunfish has started an interesting thread on the UP:

Barriers To Prosperity: Red Tape And The Regulatory State In Australia

---

Australia has experienced 26 years of unbroken economic growth. However, this aggregate figure masks stagnant wages growth and a deterioration in the living standards of many in the Australian middle class. The central cause of this deterioration is low and declining levels of business investment, which is approaching historic lows.

Overregulation and red tape are two key causes of weak investment. The regulatory burden on private enterprise has grown unabated for decades at the state and federal level, and under both Labour and Coalition Governments. Red tape reduces economic output by $176 billion each year. This means that if previous attempts to eliminate red tape were successful, the Australian economy would today be 11 per cent larger and the average household would be $19,300 better off each year.

From the report:

....Red tape arises when more regulation is in place than what is needed to achieve a given stated objective. More formally, red tape can be defined as 'rules, regulations and procedures that require compliance but do not meet the organization’s functional objective for the rule.'......

............Red tape imposes a range of costs on individuals, families, communities, and businesses. These costs can be broadly categorised along the following lines:

1.Administrative costs: costs incurred to demonstrate compliance with a given regulatory requirement. This includes the direct costs of compliance such as reporting requirements, paperwork, and keeping and producing records.

2.Substantive costs: costs incurred to meet the regulatory requirements, such as hiring or training new staff, or purchasing new equipment.

3.Opportunity costs: activities forgone or delayed as a result of red tape, such as delayed implementation of a new project.

4.Financial costs: payments of fees by private actors to government, such as through cost recovery

.
Amen brother.

https://ipa.org.au/publications-ipa/...tate-australia

And some recent posts on the theme of overburdened, non-harmonised regulations etc.:

LeadSled:

Quote:

The AIP USED to be very succinct, practical, logical and well organised.

Horatio,

How true. In my "historic collection", I have a complete AIP from the mid-1960s, simple, straightforward, and all the IAPs with coloured terrain contours were really something.

From the same era, the Air Navigation Act 1920, and associated Air Navigation Regulations (now CAR/CASR) was an A5 book (standard size of publishing legislation) about 1.5cm thick, plain language, generally unambiguous.

The ANOs (now CAO/MOS/AC) were A4 and for most of us, one 5cm binder not stuffed full. There was a bit more if you were a maintenance org.

BUT --- It was all PLAIN ENGLISH.

AND --- You could talk to an "Examiner of Airman", or an Airworthiness Surveyor, and ask questions, and get binding answers, without triggering an "aggressive audit".

Tootle pip!!

PS: I also have a copy of the ANRs from mid-30s, it would, in this day and age, make you cry, it is less than 30 pages of standard A5 format.

---

thorn bird:

Anyone counted the total number of pages of Australian Reg's?

Understand the US regs are 1000 pages of A5, NZ about the same.

---

LeadSled:

Thorn Bird,

Somewhere I have a complete but a bit out of date (Jep) copy of FAR1-199, I will have a look for it. It fits in one big (3 inch, not the usual 2 inch) binder.

Tootle pip!!

PS: The total of ALL material of a legislative or associated nature for Part 61 alone is now put at 6000+ pages. Some claim as high as almost 9000.

About six or so lines of regulation for Limited Cat in the CARs became Part 132, hundreds of pages?? I haven't counted them, but the huge expansion addresses NO new or existing risk that was not already covered. An eruption of volcanic proportions of irrelevant excess regulation.

---

Lead Balloon:

Thorn bird: Pages of regulations (1988 + 1998) plus civil aviation orders plus manuals of standards plus determinations, permissions, approvals and exemptions?

My estimate, based on a page count of the more substantial bits of the dog’s breakfast: Around 30,000 pages and growing.

I doubt whether anyone could reasonably be confident of knowing and understanding the entirety of the current Australian civil aviation regulatory regime. I would presume any claimant of that knowledge and understanding to be a psychopath or insane.

"...total of ALL material of a legislative or associated nature for Part 61 alone is now put at 6000+ pages..."

While on Part 61, there is a very strong possibility that the Part 61 page count will be added to yet again...

From the FF twitter guy:

---

We are calling for comments on our proposal to improve the #Part61 flight instructor rating.  To have your say, go to our Consultation Hub: #avsafety https://consultation.casa.gov.au/regulatory-program/part61-flight-instructor-ratings …



&..

Overview

CASA is proposing to improve the Part 61 flight instructor rating.

The improvements have been developed and refined via ongoing consultation between CASA and the aviation community since the introduction of the flight crew licensing regulations in September 2014.

The proposed improvements aim to support flight training operators and trainers to develop and deliver their flight instructor training courses, amend the privileges and limitations of certain training endorsements and enhance the guidance material.

The proposed improvements would:

• enhance and extend flight instructor training guidance material
  
• introduce a new single unit of competency, FIR4 (flight instructor rating – general), amalgamating the three generic practical units of competency  FIR1, FIR2 and FIR3, thus reducing the complexity of course development.
  
• introduce separate units of competency for each training endorsement 
  
• expand the grade 1 training endorsement to include additional training and assessment privileges
  
• add basic instrument flight training (BIFT) as a privilege of the grade 3 (aeroplane) training endorsement
  
• remove the grade 3 (helicopter) training endorsement limitation on conducting simulated engine failures with the activity to be managed by the flight training operator
  
• make BIFT optional for the grade 3 (helicopter) training endorsement.
  

Implementing the proposed improvements will involve amending the flight crew licensing regulations. An interim approach may be considered.

Why We Are Consulting

To continue the collaborative approach with the aviation community, we are seeking feedback on the consequences and benefits of implementing the proposed initiatives.

This consultation is particularly relevant to:

• flight training operators and flight instructors who conduct training for the grant of a flight instructor rating and training endorsements
  
• pilots who undergo training for a flight instructor rating and training endorsements
  
• flight examiners who conduct flight tests for a flight instructor rating and training endorsements
  
• pilots and operators who conduct flight training.
  

If you are using an iPad to complete the survey you will be asked to 'download the relevant PDF'.  Depending on the software you have on your iPad you may need to download the free viewer to review the single document PDF files.  Where a file is a 'multi-file or portfolio PDF you will need to source the Adobe free view  - available from iTunes.  More information on the 'how to' is available below in 'related' section below.

Provide your feedback
Online Survey

---

Hmm...maybe we'll be looking at a 2nd A4 box to contain the Part 61 behemoth...



Which would be funny if it wasn't so bloody depressing...


MTF...P2