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Mistress Mary, quite contrary… (Part 135 & the RAOz Missing Linke) – AP Forum version

Background references:

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Charter Industry harbours Grave Fears over New Rules
26 October 2018

Operators of small aeroplane charter companies have begun expressing concerns for their future as the industry comes to grips with new regulations that will see airline-like safety standards imposed on their businesses.

Charter companies fly ad-hoc operations tailored to specific customers and don’t offer the regular public transport (RPT) services that are currently subject to increased levels of safety regulation.


CASRs Part 119 (Air Operator’s Certificate – Commercial Air Transport) and 135 (Australian Air Transport Operations – Smaller Aeroplanes) are giving the charter industry the most concern, and several operators believe if the proposal are implemented as they are now, the industry is unlikely to be sustainable.


Some estimate that of the approximately 800 charter operators affected, as low as 100 would still be viable businesses if the regulations were adopted as they are.


Chief among the concerns is that the new rules will not improve safety, but will impose significant increases in costs and divert company resources away from the day-to-day operations of the company.


There is also a strong belief that imposing regulations designed for airlines and aircraft such as an Airbus A380 on smaller aircraft will remove the flexibility that defines the market charter companies service.


According to some operators, Parts 119 and 135 have eroded trust between the industry and the regulator, with many believing that CASA intends to impose the regulations regardless of industry input. Other charter advocates said that the proposals reveal a lack of technical competence in CASA.


“This is complete madness, confounded by absolute stupidity, locked up in a bureaucratic nightmare,” one operator stated. “[It’s] so very sad to see such a simple process locked up with the irresponsible and incompetent regulator.”


Charter companies are also up in arms over CASA’s reclassification of charter out of the definition of general aviation and into the passenger-carrying category. The effect has been to exclude small aeroplane charter operations from reformed regulation such as the new GA-specific maintenance regulations that will be based on the US FARs.


“The reason we have GA is [so] the same C172 can be a private aircraft and a charter aircraft and a survey aircraft and a mustering aircraft,” another operator said. “For this versatility of use we need to have a consistent, uniform set of rules for registration, maintenance, and operation. We could refer to this as ‘lateral consistency’.


“The same pilots and engineers use the same tools, qualifications and skills to fly everything from a Foxbat to U206 to a Chieftain to a B1900D. Our pilots and engineers need a consistent, uniform set of rules from the bottom of GA to the top – ‘longditudinal consistency’.


“The term GA may not be useful to CASA, but it is who we are and what we do. In a heavily regulated sector, words do matter and if they re-define the words they will re-define us out of existence.”


CASA closed consultation on both Part 119 and 135 on 2 September, and is targetting December this year for construction of the new rules.



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Kharon Wrote:  I’m often quite as ‘confused’ by the results of the 30 year quest for regulatory reform as those at CASA who dream up these pointless ‘reforms’. The changes made seem quite contrary and often contradictory. 

For example – take this RAoz outfit – what, of itself is it? What use is it to the national well being? What practical purpose does it serve? There is not too much confusion surrounding an outfit like War-birds or the Glider Federation, both of whom are ‘self administering’. It makes perfectly good sense that a ‘highly specialised’ small  (non commercial) group, should be able to look after themselves – they have done so; successfully, for a long while now and never given the CASA cause to regret cutting them loose from the departmental apron strings. A success story, Bravo. But what is this RAoz thing? It is a to a high degree a quasi commercial association (flight training and aircraft hire), where those who want to potter about in aircraft <600 Kg, in good weather and take the Missus along with on the one hour tour of the local landmarks. All well and good if that is the limit of their aspirations – but the safety case is on very shaky ground.  

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The International Civil Aviation Organization classifies general aviation as covering a range of operations that are not commercial air transport services. This includes aerial work (such as agriculture, photography, surveying, search and rescue), instructional flying and pleasure flying.Aug 8, 2018

General Aviation

The term ‘General Aviation’ (GA) is a misnomer: there are some pretty classy operations lumped into the classification; from long haul, top deck business jets to sophisticated turbine aircraft; from Agricultural applications to the RFDS; from aerial mustering to rescue helicopters. It is a diverse field, providing services and employment, which contributes much to society – and the GDP. 


RAoz does non of these things. Compared to ‘commercial’ GA, their training standards well below GA, their airworthiness certification is below the GA bench mark, the maintenance standards are well below GA norm. In short, the average RAoz aircraft and pilot are much more likely to come to grief (on a risk analysis) than a commercial GA aircraft; or even an Australian registered aircraft, privately maintained and operated by a ‘private’ pilot under the current CASA  rules. And yet, CASA in it’s infernal wisdom is granting more and more latitude to a bunch of amateur Tupperware thrill seekers, while increasing the regulatory burden, exponentially on ‘commercial operations’ which already work under a regulatory impost. Don’t make any sense to me; penalise the ‘real’ operators and pamper the amateur crowd? This passes for ‘reform’? Bollocks it does. 


I don’t have a quarrel with ‘home built’ or experimental aircraft; or those as build ‘em. In fact I’d encourage it. BUT, with the two megalomaniacs running the RAoz outfit trying to make it into something other than the original, as intended system, aided and abetted by a purblind CASA – it is time to call halt and bring in some realism. The illych system of divide and conquer, modified by Jonathan (where are my marbles) Aleck is a canker on the industry rump; part 135 is the slow poison seeping from that malefic. 


Commercial, professional, top end GA driven into spectre of the past – while the Tupperware crowd revel in their unfettered freedom. Lunacy and arse about face logic. Only in Australia. CASA’s current thinking is giving me a serious dose of the screaming Heebeegeebees – truly, loose marble scary……..


Done with it – the only hope is for this industry to collectively scream their bloody heads off; get Part 135 and those as wrote it sent back to Hell; where they all rightfully belong. 


Aye, I know, more a mini rant than a Gazette: but sometimes it’s better to get things off one’s chest than stew on it. Time the commercial operators joined hands and spoke the one word, with one voice – unacceptable!



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P7_TOM Wrote Been a’ pondering, have I.

My firstborn has, as usual, skipped through the obvious steps and landed on a conclusion. Furry Muff for those who actually ‘get-it’ and there are plenty who do; but what of the rest of us – we plodders?


Well, loath as I be to but into the Sunday speakeasy; I thought some time would be well spent by looking at ‘essentials’ and they way the Part 135 eliminates those things which are of value and replaces them with ‘desk-top’ audit ease and even easier conviction. We are discussing serious criminal penalties here; without appeal, under strict liability. The devil is in the detail and the translation, only by qualified ‘legal; opinion. 


But why don’t we put that aside – just for a nonce and look at ‘practical’ safety enhancement? That is, when all said and done, what CASA are shooting for (despite rumours to the contrary). They believe (firmly) that increased ‘safety-management’ and a lot more office staff will make the commercial, non airline sector ‘safer’. Whatever that may mean.


The CASR Part 135 places a tremendous financial burden on the non airline operators. A sector of industry which has, traditionally, always had a battle with balancing the books. The additional impost of even more compliance cost will send many to the wall. For no – zero – safety gain. The 135 logic is flawed, deeply and cataclysmically. 


Funds which could be made available for a ‘better’ rather than bare bones overhaul of an engine are now to be used for the care and feeding of some esoteric ‘safety’ notion person CASA believes will ‘improve’ the ever more nebulous demand for ‘safety’. Look deeply and closely into commercial operations, the solutions are crystal clear. The ‘cash’ surplus is being eaten alive by the ‘compliance daemon. Charter operators spend more time, money and effort ensuring ‘compliance’ than they do almost anything else – and go to sleep at night worrying about things which have sweet duck all to do with ‘safe’ operations the next day.


Why does CASA not take it’s big boot of the ‘strict liability’ pedal and ensure that ‘surplus’ funds are directed into the ‘luxury items’?


About now, there is a collective growl from the IOS meeting. ‘Wait” say’s I, “all will explained”. And, verbatim I do quote it:-


How about being able to afford the luxury of sending the Chief Pilot or even a training pilot along on a charter – call it LOFT, call it a ride along, call it a route check – call it whatever floats your boat. A new start, new to the aircraft, new to the company, new to the territory, new to the ‘job’ – needs every single ounce of ‘non punitive’ additional training the company can provide. This costs real money; money now being spent chasing the dragon of ‘compliance’. Senior pilots stuck in the bloody office – ensuring paper compliance, redrafting operations manual – while young ‘Wannabe’ is out there, on his own, with nary a clue of how to ‘get a job done’ – properly (compliantly).


Affordable luxury – the aging, venerable PA 31 is up for overhaul. Three lists –  ‘nice to have list’ a ‘must do list’ and a bloody long ‘wish-list’. All of this cost money, which is in short supply because it is feeding the compliance daemon. 


Affordable luxury – new GPS, radio or even instruments – all cost money.


The simple fact is that there is only so much Do-Ray-Me to go around after funding the existing, horrendous ‘compliance’ costs. This precludes any training above the absolute minimum required for ‘compliance’; or, spare time for ‘senior pilot’ supervision above and beyond the ‘compliance’ minimum; or, upgrade and repair/rectification/re-fit is gobbled up by the ever demanding ‘compliance’ daemon leads only to one place – shut down or go tit’s up. But therein, lies real safety. Up to date aircraft operated by carefully nurtured pilot – who know what they are about; courtesy of their employer.


CASA ain’t enhancing ‘real’ safety – they are seriously ‘anal retentive’ in ensuring that ‘safety’ is firmly in the hands of the legal profession, safe conviction and that the reality of ‘operational safety’ is removed from the ambit of the operator. Yes, granted, there are some who will take very penny and not re-invest it their own operation – but they are few and far between.


What say you IOS?   A new GPS or another ‘clerk’ in the office – taking care of administrative safety or another experienced ‘chap’ (or Chapess) taking care of ‘real’ airborne safety? 


Where would you spend your safety dollars – operationally; or, on ‘compliance’? Unanimous vote here. 


Yes; I’ll shut up now; yes I need a refill and yes – I will walk home with ‘the lad’; it will be my pleasure.


Now, bugger off and let an old man have a quiet Ale (or two?)


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Gobbledock Wrote:  A journey down Compliance Avenue, just around the corner from Pooh Lane and near Bollocks Street

P7 said;


“when all said and done, what CASA are shooting for (despite rumours to the contrary). They believe (firmly) that increased ‘safety-management’ and a lot more office staff will make the commercial, non airline sector ‘safer’. Whatever that may mean”.


Pretty much sums it up perfectly. More compliance under CAsR Part 135 for nil increased safety benefit. Additional burden of hiring a safety manager to meet compliance needs. Ridiculous crap. Later this year –  aerodromes MOS Part 139; changes that will increase airport compliance. More risk assessments, more safety cases, more cost impost on the little airports with a single ARO, a gardener and one RPT flight per week. Bollocks I call, bollocks!!!


Meanwhile, the ever so safety conscious Big R Regulator allows shopping centres to be built within 150m of a runway centreline without so much as a risk assessment because CAsA are too busy and it’s too much work. FFS. 


Why do you think the Frogs are firing up in France? The yellow vests are sick of Government mismanagement of taxpayer funds, the over regulation of everything from tax laws, civil laws and legislation, police powers, bankster politicans, speed cameras, CCTV cameras, rules rules rules and more effing rules. The yellow vests, do you know the reason for the vests? No, not Greg Hood. It’s becuase of the fuckwit French Government who has made it law that you carry a yellow vest in every vehicles boot incase the car breaks down. You have to put your vest on. FFS, they made that in to a law!!!!


Enough is enough

Meanwhile in the totally unaccountable, totally deluded world of the aviation safety, trough feeding Mandarins and their minions… Dodgy  

Via Twitter today: 

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In a concerted effort to maintain Australia’s world-leading safety record, Australia’s three government aviation agencies are hosting the inaugural FlySafe 2019 Aviation Safety Forum at 
@Avalon_2019 next month:  #flysafe2019@AirservicesNews @CASABriefing

FlySafe 2019 forum set to improve aviation safety


In a concerted effort to maintain Australia’s world-leading safety record, Australia’s three government aviation agencies are hosting the inaugural FlySafe 2019 Aviation Safety Forum at the Australian International Airshow next month.

Airservices Australia, the Australian Transport Safety Bureau (ATSB), and the Civil Aviation Safety Authority (CASA) will together discuss and explore a range of aviation safety issues with the aim of enhancing aviation safety during a full day forum at the airshow, to be held at Avalon Airport in Victoria on Thursday 28 February.


FlySafe 2019 is open and free to trade visitors, exhibitors and conference delegates. The forum will include keynote sessions by Airservices Chief Executive Officer Jason Harfield; ATSB Chief Commissioner Greg Hood; and CASA Chief Executive Officer and Director of Aviation Safety, Shane Carmody.


Safety experts from the three agencies will be discussing the benefits of enabling a positive safety reporting culture and will also talk through a hypothetical accident at a busy airport to describe the important roles each agency plays during an aviation accident.


With the ATSB’s latest annual statistics showing an increase in the number of fatalities from aviation accidents in Australia during 2017, Chief Commissioner Hood said the ATSB regularly investigates aviation accidents involving poor decision making and risk management.


“We regularly see accidents repeated – fatal accidents which could have quite easily been avoided – it is incredibly tragic and very frustrating,” said Mr Hood. “There are valuable safety lessons to be learned for the whole of industry from our investigations, and I look forward to discussing a range of safety matters with the attendees at FlySafe 2019.”


FlySafe 2019 will also hear from the Director of the Defence Flight Safety Bureau, Group Captain Nigel Ward, and from New Zealand’s Transport Accident Investigation Commission, Chief Commissioner, Jane Meares.


“Australia’s aviation safety scorecard is the envy of the world, and we continue to innovate and improve in order to maintain this proud legacy,” said Mr Harfield, who will be providing an update on current developments in air traffic management safety, including the OneSKY program. “It is crucial we do this, so the industry grows safely and efficiently in the years to come.”


Mr Carmody said FlySafe 2019 represents a unique opportunity for the aviation industry.


“CASA is committed to maintaining Australia’s strong aviation safety record through improvements to regulations, effective consultation with industry and working together with other aviation agencies,” Mr Carmody said. “At FlySafe 2019 the aviation industry will have the opportunity to address and confront safety issues, and hear how the three agencies will continue to work together to improve aviation safety in Australia.”


Registration is free for airshow trade visitors and limited places are available. To attend FlySafe 2019, delegates should send their name, title and affiliation to: before 15 February 2019.

My response:

“..concerted effort to maintain Australia’s world-leading safety record, Australia’s three government aviation agencies…” Surely you jest and that should read ‘maintain the status quo of covering up our aviation safety deficiencies’ e.g #MH370 and blind-siding a conga line of..

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Govt Ministers @M_McCormackMP @DarrenChesterMP @WarrenETruss @AlboMP with the mystique of aviation safety (#MOAS), while in the meantime suffocating an essential #GAindustry through oppressive regulation and strict liability embuggerance: References –…64#pid9764 

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cont/- RT…pony-pooh/ … &

#PelAircoverup…n=lastpost … + #MH370 coverup #AIOS…88#pid2988 …  & 

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 RT…ouse-them/ … or…58#pid9758 … via … +…4-N5t930fw … #auspol #aupol #Avgeeks #avgeek