It would appear that the Kelvinator fridge (safe) is well and truly full as the ASRR web page has been updated from this…
“..The formal submission period has now closed. However the Panel will endeavour to consider late submissions.
To make a late submission please use the Aviation Safety Regulation Review Submission Form....”
To this…
“…The formal submission period has closed.
If you would like to provide further information to the Review Panel, please email [email protected]...”
Oh well perhaps the WLRP could get the DoIRD to set up a blog & comments page, certainly save the panel from being distracted from replying to copious IOS emails…
Here’s a thought..
..why not just provide a link to this thread…
Speaking of blogs & submissions, here is hoping that Phearless Phelan was able to get the updated ProAviation submission in on time:
ProAviation’s submission to the ASRR
Wow mammoth effort PP & Stan!
Warning: May require IOS members to update the Kelvinator with a fresh slab before considering reading in full!
Executive Summary
This submission concludes that a pervading “culture” exists within the Civil Aviation Safety Authority that has degraded relations between the regulator and most industry sectors to a point where it is impacting negatively on air safety in ways that we illustrate by reference to examples.
It is submitted that this culture has developed, evolved and progressively expanded and consolidated since CASA was established in July 1995 and first designated as an independent statutory authority. We believe several symptoms of the existence of this culture can be identified in the examples we cite, and that it is manifested by the interaction between CASA departments which our examples illustrate.
It is acknowledged that a number of quality employees remain employed by CASA, although their numbers are reducing and their capability to influence the way the regulator carries out its functions has been so limited that numerous key figures have voluntarily left the organisation.
A majority of the aviation stakeholders we have consulted observe that the embedded anti-reform culture still exists and thrives within the organisation. They point out that it has already survived several high-level enquiries; and that events have proven that no reform can be effective unless those influences are identified and permanently negated.
CASA has operated, and continues to operate under the notion that to be legal is to be safe. Nothing could be further from the truth, particularly when the industry is forced to operate under flawed and ambiguous legislation while separate offices; and at times different officials in the same office, make differing decisions when applied to different operators requesting identical approvals.
We consider the situations we detail demonstrate that solutions cannot be developed and implemented without significant amendment to the Civil Aviation Act and Regulations.
Introductory notes
Our submission is based on current and past research, some of which has been previously published in articles that are now part of this analysis. Those articles, whilst not always identical with the original, have only been reviewed to the extent necessary to bring them up to date, in some cases by adding a “sequel.”
We note the Minister’s advice that:
[The review] will not be reopening previous air safety investigations nor will it be a forum to resolve individual complaints or grievances. It is about the future regulatory challenges and growing our industry.
In that context we respectfully submit that the case studies which we reference clearly typify both past and current regulatory processes, and that this can also aid in identifying changes that will be necessary to regularise the management of similar events into the future. Furthermore, the point must be made that some individuals are more frequently involved than others in both past and contempoary cases, and that a number of these still occupy positions that offer opportunity for continued misconduct.
We emphasise that matters we quote as examples represent only a fraction of the material that is stored in our files. Much of this material comprises matters which we submit would warrant completely independent external investigation.
Some of the regulatory adventures detailed in the case studies are related to the regulation of flight operations by flying operations officers and their supervisors. Some are related to airworthiness and principally involve airworthiness inspectors and their supervisors.
However, they all involve CASA lawyers in varying roles. Additionally reporting to the General Counsel and Executive Manager of the Office of Legal Services, are the office that attends to freedom of information applications, the investigations office which oversees the activities of CASA investigators, and the Senior Advisor, Enforcement Policy and Practice, whose responsibilities are detailed by CASA as “developing enforcement policy, strategies and procedures, coordinating enforcement and monitoring, on a centralised basis, all aspects of CASA’s enforcement related activities.”
We also draw the Panel’s attention to a major “enforcement” event which is still current; and which calls for close attention as to CASA’s decision making and conduct throughout the processes of investigation and subsequent enforcement activity. This is the process by which Barrier Aviation is currently being managed out of existence.
None of this analysis is intended to denigrate individuals or organisations. Instead we recount events and leave the Panel to form its own impressions. Our own opinions when expressed are labelled “Comment:” and represent the opinion of the author and/or the publisher.
Hmm..kind of put’s the Airborne Gentry’s submission in the shade:
RAeS Submission to the Aviation Safety Regulation Review
Comment: IMO, despite a stiff upper lip, the RAES submission is very much in the ilk of the AOPAA (wet lettuce) submission I’m afraid (but that is just my opinion)..
More to follow K2…