What is needed is a set of cost and efficiency benchmarks between CASA, and Canada, New Zealand, US FAA, European union and possibly other countries for their air regulator, ATSB and Airservices equivalent.
Sunny,
Why didn't we think of that during the currency of the PAP/CASA Review?? --- Hang on, I remember, we did!!
I still have copies of all the documents somewhere for Part 91, where we did (item by item) a comparison, side by side spreadsheet, of the equivalent sub-regulation from (from memory), as well as AU,NZ, CA,US,UK and ICAO.
Not surprisingly, beside quite a number of Australian regulations, some or all of the other countries' lists were a blank space.
One of the ones that sticks in my mind was the AU regulations/orders about dropping things from aircraft (you know the ones -- they put paid to Sunday morning flour bombing and streamer cutting competitions at the local aero club) AU -- about 9 pages of regulation and orders, most others countries, one or two paragraphs, plus advisory material.
The Review recommendation was a one paragraph regulation, outcome based, with advisory material as to how to comply.
9 pages of regulatory material reduces to about 30 easily understandable words.
Later, long after the PAP had gone, Bruce Byron actually produced a policy directive, binding on CASA staff, as to how all rules were to be justified --
based entirely on the principles used by the PAP/CASA Review --- which in themselves were nothing new, just lifted straight from the recommendations of the Productivity Commission/Office of Best Practice Regulation handbook, the then Australia/NZ Standard for risk management, and other similar sources from Attorney-General, Senate Standing Committee on Regulations and Ordinances, etc.
As I recall (it's no longer on the CASA web site) the first requirement of the Byron directive was to establish that there was an air safety problem that required a regulation (as opposed to less draconian methods of securing compliance). If that was established ( as opposed to something that was for administrative bureaucratic convenience -- a regulatory nono that CASA routinely ignores ) the next step was quantitative cost/benefit analysis (not cost/ effectiveness --- CASA can't tell the difference), including factoring the CASA claimed "benefits" for "proponent bias", which various Canberra based guidelines put at up to 50%, ie; the claimed financial/ societal etc. benefits of a measure are commonly overstated by up to 50%.
Unsurprisingly, by this stage, a large number of regulations were knocked out, to the distress of those in CASA who believe "regulation" is the only answer (as in the new proposals for SAR/EMS operations NPRM --- to be regulated
to the greatest possible extent --- as RPT).
By this stage, draft regulations were starting to look remarkably like NZ or CA or FAA --- but simpler and easier to read.
One "person" in the the CASA Office of Legal Counsel actually put forward the proposition
that "outcome based" rules, that were Government policy, would not work in Australian aviation, because, unlike NZ/CA/US/UK. neither CASA nor the Australia aviation industry were
"mature enough" for anything other than highly detailed and absolutely prescriptive regulation.
As we well know now, all of the above drafts has been dropped --- it is even claimed now that such activities as risk justification and cost/benefit analysis are contrary to the Civil, Aviation Act 1988. Strangely, all the lawyers involved over the years, including several lawyers on the Board, including a Supreme Court Judge as Chairman, apparently missed what has apparently been so blindingly obvious to the present day CASA Board and management.
As for ATC, have a look at the Airspace Act, and particularly the first "airspace directive", signed off by Truss. Now emasculated under the present Government --- and look at the mess Airservices are in!
It is a very sad story, that has cost Australia far more than the $2-300M directly spent by CASA, we have lost a large segment of the industry, either gone offshore or just gone.
And here was Albo, just last week, at the CAPA conference, saying what a great place Australia is, to do aviation business, with all these beaut. country aerodromes where we could be training foreign students.
I wonder why the training industry didn't think of that --- Hang On!! , I remember, they did!!
---- but have been largely put out of business, with excessive costs and regulation, compared to competitor countries. CASA isn't the only offender here, there are plenty of other Australian government entities who have done their bit to help boost pilot training in NZ/US/CA/etc.
Tootle pip!!