Charter Operators applying for RPT

[Mick Stuped]

Interested in comment from anyone about the latest explanation from CASA regarding RPT Exemptions.

INFORMATION SHEET


CHARTER OPERATORS APPLYING FOR RPT AUTHORISATION ON AOC AUGUST 2013

Background

1. By notice dated18 June 2013 (the notice), CASA wrote to charter operators

(a) reminding them of their obligation to comply with all applicable legislative requirements;

(b) providing general guidance on how to apply for anauthorisation to conduct regular public transport (RPT) operations as describedin regulation 206(1)(c) of the Civil AviationRegulations 1988 (CAR); and

(c) in this regard,advising them that CASA may consider exempting an operator from complying with certain otherwise applicable RPT requirements.

RPT AOC required to conduct RPT operations


2. An operator may not lawfully conduct RPT operations without holding an Air Operator’s Certificate (AOC) which expressly authorises RPT operations. Nothing in the notice said anything to the contrary. The holder of an AOC that authorises charter operations may not conduct RPT operations, irrespective of any ‘exemptions’ that may be given to that operator.

3. CASA has no power to issue an exemption against the requirement to hold an RPT authorisation on an AOC, but CASA may issue an exemption against a regulatory requirement that an RPT AOC holder must other wise meet.

4. The phrase “interim RPT authorisations” in the notice did not convey that an operator could hold a form of RPT AOC different to the usual form, only that the operatormay be issued exemptions which could be in force until such time as Part 135 of the Civil AviationSafety Regulations 1998 (CASR) was made.

Exemption process – what information must be provided to CASA


5. CASA’s notice of 18 June 2013 stated:

Charter operators considering applying for an AOC authorising RPT operations in circumstances of the kind mentioned above should carefully consider:

· all relevant requirements under the regulations currently governing RPT operations, from full compliance with which they would need to seek an exemption or from which an approval to deviate would be necessary;

· what they would be required to do in order to meet standards corresponding to those specified in proposed CASR Part135; and

· the benefits, as well as the demands, involved in moving to comply with those standards in advance of their adoption in the legislation, as conditions on an authorisation to conduct RPT operations that might be available in the interim.

6. If your organisation has already applied inresponse to the notice,you should provide the information set out by this information sheet if you have not already done so.

7. If an operator applying for an RPT authorisation on their AOC 1 seeks the issue of an exemption, the operator may also separately apply for an exemption from RPT related regulatory requirements, in accordance with CASR 11.190. Any such application should state or provide:

(a) specifically,what exemptions are sought (that is, what regulation(s) is an exemption sought against),
(b) the reasons for seeking each exemption,
(c) an explanation as to why the operator cannot meet the relevant RPTrequirement;
(d) how the application for the exemption relates, if at all, to proposed draft CASR Part 135 by specific reference to the relevant draft regulation in that Part;2
(e) details of how an acceptable level of safety would be provided if an exemption was to be given: see CASA Advisory Circular AC 11-02(2) August 2011 - EXEMPTIONS AGAINST THE CASR, CAR AND CAO, which explains the exemption application and assessment process3;
(f) any associated operations manual amendments that are specific to the exemption sought and detailing any operational requirements relating to the matters the subject of the exemption.

8. For example,if an exemption is sought against the requirement that an operator have a CAR 217 training and checking organisation, which requires pilots to be subject to two proficiency checks in each calendar year, CASA would not give an unconditional exemption against these requirements. Rather, an applicant for an exemption would have to explain,amongst other things, how it would ensure an acceptable level of safety would be provided.

9. Further,the aviation legislation sometimes sets out what must be provided to CASA to enable CASA to consider the relaxation of an RPT requirement. For example, if an operator wants to operate ow capacity RPT operations to an aerodrome that does not meet the RPT requirements set out in Appendix 3 of CAO 82.3, paragraph5.2.1 of CAO
82.3 enables CASA to approve the use of such an aerodrome, but only if:
(a) the operator provides CASA with details of the surface and dimensions of the aerodrome proposed to be approved, being details of the kind set out in Appendix3 of CAO 82.3; and

(b) CASA is satisfied,after considering those details,that the aerodrome is suitable for the take-off and landingof aeroplanes with MTOW not exceeding 5700 kg.

10. If before the notice was sent to operators, an operator had already applied to CASA for an RPT authorisation and has represented to CASA they can or do meet all RPT requirements, it is not likely that CASA would grant any exemptions against such requirements. In any event, in such a circumstance, CASA’s resources would best be directed to assessing the application for theRPT authorisation.

11. CASA cannot advise before hand what exemptions,if any,will be given in any particular case,as each application will be considered on a case-by-case basis.

12. It is the operator’s responsibility to reviewtheaviationlegislation,especiallyCAO82.3, to understand:

(a) what the current RPT requirements are;

(b) whether the operator can meet those requirements, and if not, why not; and

(c) in seeking an exemption from an otherwise applicable regulatory requirement, how the operator will satisfy CASA that an acceptable level of safety can and will be achieved and maintained.

Civil Aviation Safety Authority 22 August 2013

[LeadSled]

MIck,
This has come about as a result of CASA winning an appeal against an AAT decision in court.
The line CASA pursued in definitions of closed charter versus RPT was exactly opposite to the written "policy" advice CASA has provided in the past, re CAR 206.
I would think this will now put a lot of small tourist operators out of business.
Tootle pip!!

[185skywagon]

Leady,
That is way it looks to us too. It is a worry.
:(

[601]

how the application for the exemption relates, if at all, to proposed draft CASR Part 135

How would this stand up to a legal challenge when it is only a thought bubble that has not been passed into law?

[Horatio Leafblower]

I raised the Caper decision and told him that he would shut down every scenic operator in the country. McCormack sat in my office and told me to apply for an RPT AOC.

All good and well, but where does one find Part 145 Maintenance these days?

[Mick Stuped]

If a current charter AOC holder decided to go to RPT, using the thought bubble of Part 135 as a guild to upgrade to Air transport LRPT, as that is the standard that will replace charter, how do we anticipate things like check and training requirements as just one example. Then there is the biggy and how do we get small aircraft off schedule 5, and onto a LRPT maintaince standard when the standard hasn't been decided. Put a 206 on a heavy RPT maintiance schedule what a joke!

What a stuff up. Apply for a RPT category that doesn't exist, under exemptions that are trying to be removed, in aircraft with less than 9 passengers that doesnt have a maintaince standard in place.

To get all that approved on a case by case basis, I think part 135 would be in before that, not to mention how much the back and forth would all cost:ugh:

Or is this all a polite warning to all to say now armed with the caper appeal win, that we are just about to shut you down, start looking for another job.

[601]

To get all that approved on a case by case basis
And with it different requirements/policy/whims/etc depending on which desk the application lands on.

[LeadSled]

AaaaaHHH!!

The wonderful world of SOPs, CASA style.

One salient point hardly mentioned, I raised the Caper decision and told him that he would shut down every scenic operator in the country. McCormack sat in my office and told me to apply for an RPT AOC.but CASA just doesn't care how much it all costs, or if major tourist operations, important tourist attractions, cease to exist, or how many people lose their jobs, and not just in the operators, but all those in support roles on the ground, in the surrounding towns etc.,otherwise they would not have reversed long standing interpretations of CAR 206, and spent who knows how much in the AAT (where they lost) and in the Federal court to appeal the loss in the AAT, to enforce the new "policy".

And, of course, no safety issue, just a new "preferred interpretation", and one that was never intended in the original drafting.

One of the reasons CAR 206 has always been such a dog's breakfast, is that this is another "unintended consequence" of the transition, years ago, from ANRs/ANOs to CARs/CAOs, and incomplete "regulatory reform". CAR 206 was produced, but other complimentary legislation, that made it clear that such things as sightseeing trips and tourist charters, and mail runs, all these small operations that operate regularly, were not scheduled airlines, and were not RPT operations.

At the time, (Toller era) that CASA decided, after many years to the contrary, that remote area mail runs were "RPT", the mail runs had been running for about fifteen years, before "somebody" in CASA decided they were all "illegal" and a whole bunch of show cause paper work landed on operator's desks.

Again, all nothing to do with air safety, just more bastard bureaucracy throwing their weight around --- why?? --- because they can.

------ and told me to apply for an RPT AOC
I wouldn't be surprised ( based on some Senate hearings, the AMROBA Brisbane meeting etc.), if Mr. McCormick doesn't have a clue about the costs of such an application, let alone the ongoing costs of meeting the vastly increased overheads.

Tootle pip!!

[Sunfish]

I suspect Two seaplane operators I know will shut up shop.

I have commented on this mess before. It is an open invitation to official corruption.

[Horatio Leafblower]

I am just so glad that so many people are making this a major election issue.

Isn't it great how AMROBA, RAAA and AOPA are joining forces to make this front and center!

I am so excited by the way both the ALP and the LIBNATS are fighting to make Aviation a strong part of the national infrastructure!


NURSE!!! :ugh: :{

[601]

I am just so glad that so many people are making this a major election issue.

The media just think that aviation is a taxpayer funded irritation they have to endure on the way to a taxpayer funded media event.

The media decide what they are going to cover and how it is covered.

Unless it is a smoking hole when they instantly become world experts or someone has posted a comment on Facebreak that can be made into a headline.

[tail wheel]

"...the mail runs had been running for about fifteen years,..."

The rural mail services have their origins in the RASS (Rural Air Services Scheme) services, negotiated between Sir Bob Norman (of Bush Pilots Airways) and Athol Townley, then Minister for Civil Aviation, in 1954. The RASS services carried mail and rural residents and were always air charter operations until deemed otherwise in 1999 under Mick Toller.

CAR 206 has it's origins in ANR 197 to ANR 203, which related to exemptions to conduct scheduled services over protected airline routes.

[Creampuff]

But then they started to carry tourists as well …. and the government subsidy was removed.

Fixed routes ... fixed schedules ... open to persons generally ... and not financially viable absent the subsidy.

[tail wheel]

Compounded by the fact these remote area rural services operated into air strips which did not comply with the CAO requirement for RPT services.

A lot of disruption and uncertainty for rural dwellers and operators, for little demonstrated and probably no actual increase in safety......

[pcx]

And potentially a significant decrease in safety if they are forced to drive when they could have flown.

[Mick Stuped]

Ahh the good old safety issue. Don't they just love the thought of increased safety.

Don't know about you but safety in aircraft less than 9 seats for our company is pretty important too. We don't want to loose our pilots/passenger's and business either.
I don't know how I would cope knowing that something we did/neglected caused the loss of lives/workmates/friends, isn't that what keeps everyone in this industry sharp.

Working in remote aviation all our Op's have an increased level of safety just because of the remoteness and changeability of the environment.
This means we have company imposed requirements far above the category of flight. This is part of due diligence for all of the above reasons.

The regulator looks at safety through the eyes of a policeman and usually it is black and white and perceived. That's were the problems start.

I have worked in a few different industries and at the moment moral in this industry is at it's lowest, that I have ever felt in any industry. I feel this is when safety will start to become an issue,because moral starts to drop people start not to care as much.
Trying to keep everyone upbeat and positive, is very hard at the moment in Aviation. The problem starts at the top and filters down right to the bottom infecting all with a don't give a s**t mentality. That's really not very good for safety.

Sorry slight drift, perceived safety is just that. The travelling public don't really care if we are RPT or Charter all they care is that we are licenced. In all our years in this industry, we have never had a client ask if we were RPT or Charter doing the flight IFR or VFR that is all industry perceptions. All they care about is, are we licenced and insured.
If we are licenced and our pilot looks older than 15, then they are happy as that in itself is enough to make them feel that we are not dragging some bloke out the pub that may or may not be sober to fly them, some where in a plane, that may have been airworthy in the past few years at some time.

There has to be a line in the sand that gives trust to the travelling public that they can board an aircraft and arrive safely at their destination. The public understand the bigger the aircraft the higher the skill level required to operate.

I also believe every industry needs a policeman. We however also need a regulator/policeman with direction and common sense that understands the industry, that has the industry's best needs at heart as well.

The comment to HL of go to RPT shows how much the top end of the regulator just doesn't understand the industry they lead.

The last two letters to operators one saying go RPT and get exemptions and then the tactical withdrawal saying to all operators we weren't trying to say that with that letter, really we meant to say go apply for RPT and if your safety isn't up to that standard because we haven't worked out what the standard really is, we may or may not give you an exemption.
Seems to me one hand doesn't know what the other is doing.

Part 135 scares me a bit. I don't know how remote and regional GA will survive with the extra cost of implementation and continued compliance. Only a certain amount of blood you can get out of a stone. We are already experiencing resistance, to price increases for the rapidly rising fuel costs. We cannot keep rising the hourly rate as soon as we do we see the monthly hours decline and our business with it. The attitude of just pass the cost on doesn't always work.

The other Question Part 135 and air transport rises, is a line pilot asked me the other day, will they increase the eligibility hours for newbies? It will be RPT so under the current rules he wouldn't even get a start with us. Where will newbies get a start in this industry. Will all operators have to start their own sudo cadet ships and spend more time ICUS with a newbie at another huge expense or will all training orgs have to extend the training time to cover the so called higher level of skills required for us to take a per seat charge?

[LeadSled]

The rural mail services have their origins in the RASS (Rural Air Services Scheme) services, negotiated between Sir Bob Norman (of Bush Pilots Airways) and Athol Townley, then Minister for Civil Aviation, in 1954. The RASS services carried mail and rural residents and were always air charter operations until deemed otherwise in 1999 under Mick Toller.

Exactly, and what you would expect from someone like Townley, with his aviation background, Minister for Air (https://en.wikipedia.org/wiki/Minister_for_Defence_%28Australia%29) and Minister for Civil Aviation (https://en.wikipedia.org/wiki/Minister_for_Infrastructure,_Transport,_Regional_Development _and_Local_Government_%28Australia%29).

And, the "beginning of the end" for such common sense was the formation of the original CAA, compounded with the split of CAA, when CASA came into being. The reference to "15 years" was in relation to the period of time from when CAR 206 come into being, but other complimentary legislation to ensure that the status quo remained for mail runs and similar activities was never completed.

It took the guardians of air safety about 15 years to realise the missing legislation had "technically" created "illegal RPT".

Another case of the Lane Report's "inadvertent criminals"

Creamie,
As I remember well, when we had a place on the Cape (and were shareholders in Bushies) the mail run aircraft always carried "passengers", often tourists, and freight. It was our source of fresh milk and bread.

shows how much the top end of the regulator just doesn't understand the industry they lead.

It is NOT CASA's job to "lead" the industry, but since the days of DCA, far too many people within "the department", whatever it was called at the time, thought it was, and far too many people in the "industry", (particularly because of the subsidies doled out by DCA, DCA administering the "two airline agreement" etc.,) were happy enough to put their hands out, and effectively let DCA lead.

In my view, this mindset, still around to this day, is a major factor in the shambles of the administration of the CAAct, the shambles of the "regulatory reform", which is many things, but reform is not one of them, and other debilitating aspects of Australian aviation.

To quote Kim Beazley: "----- because Australian aviation is so small, bureaucrats can micromanage it, and because they can, they do", this statement made at a meeting at Bankstown in early 1996.

Tootle pip!!




Tootle pip!!

[Creampuff]

Just a little loose with the facts, as always.The RASS services carried mail and rural residents and were always air charter operations … Indeed, and the regulator agreed. That’s not what the prompted the regulator’s action in 1999. What prompted the regulator’s action in 1999 was the advertisements that invited any member of the public to pay to get on board – you know, people other than the rural residents, and their cargo, for whom the service was being subsidised.

And ‘the industry’ always overlooks the inconvenient and tawdry truth about who usually prods the regulator to take action. (To resort to a Leaddieism: Hint, it usually isn’t the regulator.)

None of this is to justify some of the distinctions drawn in the classification of operations rules that have no safety justification and, demonstrably, produce no comparative safety benefit. Nor is any of this is to justify the abject failure of successive governments to deliver any classification of operations reform.

It’s just to say that if you could get your facts straight and argue with and hold to account the people actually responsible for classification of operations reform, you might have a slight chance of changing things for the better.

[kimwestt]

Some time ago, we were involved in running a "Closed Charter" through a third party on our AOC out of a Northern port (very northern).
Despite having had our local (BK) office run their ruler over the matter, and them giving us the thumbs up, the local office then deemed it an RPT operation. We provided the "locals" with an affidavit from the local boys in blue, stating that entry to the destination port required written authorisation from the owners/occupiers of the destination. Our submission was that it could not then be deemed RPT. The locals declined to accept our explanation. To say that I/we were subjected to an investigation would be putting it mildly. To the extent that there was a CB investigator dispatched to investigate our actions. We then submitted the matter to CASA legal in CB. CASA legal decided in OUR favor. So, maybe the moral of the story is to let the CASA legal eagles formally consider the matter, rather than accept the half arsed legal interpretations/opinions that seem to be prevalent.
And that was the SECOND time that the legal eagles in CB produced a result in our favour in relation to interpretations.. :)..

[LeadSled]

kimwestt,
Creampuff might like to comment, but the result of the CASA appeal in the Caper Air case seems to me to say that we now have two distinct kinds of "closed charter", one being RPT and the other not RPT.
Just to make it simple for everybody.
Tootle pip!!

[Torres]

I didn't want to buy in on a subject which for me is long dead and buried, but remains a monument to CASA incompetence and inconsistency.

What prompted the regulator’s action in 1999 was the advertisements that invited any member of the public to pay to get on board

What is the safety difference between transporting remote, rural families and their mail and supplies and transporting a very limited number of adventurous tourists to subsidise the operation?

Well before your time Creamie, DCA and CASA agreed the Cape York Mail Services could carry limited tourists for a variety of reasons. Then in June 1999 an OLC lawyer issued a document titled "GAOB Policy Position - Classification of Charter/RPT Operations" which interestingly made the statement "The proper interpretation of these provisions continues to be the subject of controversy". That policy document effectively also denied remote community residents access to their essential air services. (That document was one of a number of similar but varying "policy documents" and "interpretations" issued by various CASA lawyers.)

CASA failed to provide their regulatory decision to operators but immediately moved to the administrative Show Cause process, costing dozens of employees their jobs, costing many air operators hundreds of thousands of dollars in lost income, disrupting the sole transport services available to many remote residents for arguably, no safety related gain.

Interestingly, CASA Darwin adopted a rational common sense approach and authorised essential mail services within their jurisdiction.

Correct or not, that June 1999 CASA document would have far reaching impact on air services to remote rural communities. Had CASA confidence in their opinion, they would have cancelled the AOC of an operation I had involvement with. To the contrary, the AOC was restored and after essential operational changes to the CAOs, issued that operator with an RPT AOC.

And here the aviation industry is, 15 years and over $250 million in regulatory reform costs later, still with the same ludicrous and meaningless CAR206...........

That is my perspective, you are entitled to yours. Not interested in again debating the subject, which is long dead and buried.

Leadie. Athol and Rex Townley were wonderful men and family friends. Athol was the principal of Sidwell & Townley, Pharmacists and our family chemist. He had a very distinguished Naval record in World War II, including assisting in sinking a midget submarine on Sydney Harbour and commanding Fairmile motor launches in New Guinea. Rex Townley also entered politics, becoming Leader of the Opposition in Tasmania.

[Creampuff]

What is the safety difference between transporting remote, rural families and their mail and supplies and transporting a very limited number of adventurous tourists to subsidise the operation?None.

That’s one of the many stupidities of the classification of operation rules, and one of the reasons for Commission Staunton’s recommendation in 1996 that “urgent” consideration be given to clearing up 206.

Under the then-and-still-current classification rules, that fact is that as soon as seats were made available to the public generally – you describe it as “a very limited number of adventurous tourists” to avoid the reality – it became RPT. The government did not want to do anything about it by changing the rules or increasing the subsidy.

Don’t blame the people whose job it was to enforce the rules (and whose decisions, by the way, were upheld on external review).

Blame the people who’ve allowed the classification of operations rules to remain a complicated, counter-intuitive dog’s breakfast for decades.

[Torres]

I respect your opinion as I trust you will respect mine.

"....you describe it as “a very limited number of adventurous tourists” to avoid the reality – it became RPT."

It was an opportunity for a very limited number of people to participate in a rather unique Australian rural service. I respect your opinion it was an RPT operation, supported by Commissioner Staunton's decision, as I trust you will respect my opinion that it was not RPT, which is supported by Commissioner Fice and a number of CASA employees at that time, including the DFOM Darwin and a number of FOIs in Canberra and the State offices.

How many millions of dollars of tax payers funds has CASA p!ssed against the wall in barrister and QC retainers, legal costs, consulting fees etc, not including the millions of dollars in costs and lost revenue by air service providers, solely for CASA to attempt to impose it's ever changing, illogical interpretation of an indecipherable and inappropriate regulation - rather than replacing the regulation years ago with a clear, concise regulation suitable for the needs of all Australians?

CAR206 always was an incomprehensible dog's breakfast since it was illogically and inappropriately migrated from the pre 1988 ANRs. It is a monument to CASA's incompetence that it was not replaced during the past 25 years.

All water under the bridge. Long since dead and buried. I wish you all the best Creamie! :)

[Horatio Leafblower]

OK so we all sit on PPRuNe and piss and moan about how CASA's general incompetence is destroying our industry.

Many of these posts are extremely well written.

Have any of you contacted Warren Truss (the next Transport Minister) to express your fear for the industry - a VIABLE industry which is being made UNVIABLE purely through political indifference?

...how many people are employed in the Aviation industry in each state?

...why the hell don't we have a political voice in this country?

...where the hell is RAAA and AOPA on this?

I have written to my local member, to Warren Truss, and to aviation-minded MPs and Senators. (Didn't bother writing to Albo). I have donated $ to Nick Xenophon.

...but I am only one person employing less than 20 voters. What are YOU doing to save YOUR industry?

[Torres]

I'm not sitting here moaning about CASA's incompetence destroying the general aviation industry.

Over a decade ago I made the most logical decision possible, I walked in disgust and commenced another very successful and highly rewarding career. I left behind a thirty year general aviation and regional airline career with a clear conscience and pride in my achievements.

Have any of you contacted Warren Truss (the next Transport Minister) to express your fear for the industry...

Hahahahahaha! :} Surely you jest Shirley? Another cast in the Anderson mould - why do you think he cares? :E I'm a Life Member of the Party and can't influence change.

I only hope Prime Minister Abbott actually appoints someone interested in transport and civil aviation post September 7.

:ok:

[Horatio Leafblower]

Forgive my passion - maybe its because I am still young.

...even if only when compared to cynical old farts like you. :hmm:

[Torres]

Ah yes, the passion that burned within me for thirty years. I think a few miscreants and under achievers at CASA p!ssed on and extinguished the flame. :}

Horatio, I know you have the passion and have been successful in your career. But there are too few votes employed within the aviation industry to cause change. Not until our rural Aussie residents start to make noises about loss of their air services will any politician take notice.

Meanwhile the bashings from CASA will continue until moral improves!

[Mick Stuped]

HL, yep same here, started at the bottom and worked my way to the top with letters, and in person, to all and sundry. I have submitted numerous replies to white papers, NPR's, etc. Have canvassed ombudsmen and commissioners over different issues over the years. Have been a member of AOPA and sought help on a few occasions. Apart from a few minor wins along the way all my efforts doesn't seem to have helped my company.

That's why I have ended up here on PPRune, not that I like it as a complaining bitch fest, but I really do think that if we all can call it like it is, (with the help of some anonymity) so the real truth and facts can come out, in other words a real whistle blowers forum that has a modicum of respect, it maybe heard.

It has been shown in the past not holding back and being a whistle blower in public will bring retribution upon you and your company without a resolution of the problem.

My hope is that just maybe, some one out there may start to listen. Or at least we can warn those new to the industry not to make the same mistakes we have. History is a great teacher. Share your stories they need to be told.

Maybe if enough smoke comes from forums like this, then just maybe a Journo, public servant or someone with a higher profile may come to our industries aid.(can always dream anyway)

It is very sad to see GA dying, an industry drowning in over regulation and fear, bullied by people that really, have never had to be accountable to a profit margin or ever run their own business telling us how to run ours. Never any thought, ever seems to go into any decision made by CASA on how their decision will financially impact the operators, as show by some of the decisions over the last 20 years or so.

We can only hope that maybe one day we can get a minister that has a interest in Aviation in charge, Preferable an ex Pilot. So to all PPRuners out there, if you are currently running for parliament or have aspirations of running don't forget us when you make it to the top.

Remember GA is the front line, and first step usually in this industry, its the start for new pilots going onto bigger and faster things, and to a certain extent is also the canary in the coal mine.

I am not that naïve that I think its all going to be good, and fixed with a silver bullet, but if we can all start saying enough, it maybe a small start. Write to your MP and your local papers. Go to CASA forums and have your say, submit your ideas on new rules and regs when asked to, no matter if you are a PPL,CPL,ATPL or just a baggage handler or desk jockey be heard its your industry. :ok:

[neville_nobody]

After flying with a union guy who had some experience on rule making committees with CASA I walked away shaking my head. You can submit all you want CASA will just say 'thanks for your input' and then do whatever they were going to do in the first place.

They effectively ignore the industry committees so I don't think community input will change their ideas.

[Aussie Bob]

where the hell is RAAA and AOPA on this?

Regretfully they are in bed with CASA

[Kharon]

HLB #24 "OK so we all sit on PPRuNe and piss and moan about how CASA's general incompetence is destroying our industry." Don't be too hard on Proon, believe it or not, used properly the site is a very effective tool if for no other reason than many items discussed can be investigated, dissected and corroborated. Once an identified issue can be proven, it can be added to the ever increasing catalogue of 'real' complaint. Which only leaves one, unresolved issue:

MSD # 28 –"We can only hope that maybe one day we can get a minister that has a interest in Aviation in charge". I believe this is the only answer, the last Senate inquiry was effective only because the committee actually became bipartisan, rolled up it's collective sleeves and got involved. Why?, well I believe it was because the 'evidence' (for wont of better) was provided in a believable manner which could be understood; and, once the deeper issues were revealed they reacted in the way any reasonable person would – with disgust. Sen. Stearle (WA) was exemplary, from cynical labour line to involved and concerned. Politics forgiven, you had to admire the 'man', if not the Polly.

Remember, Pel Air was a single issue ticket, one way, and look where that got to. Tip of the iceberg?, sure but at least they know now there is one. Should we be lucky enough to have the likes of D. Fawcett esq. pick up sticks, then things will change, but if we get lumbered with a party hack; then, it's time to join Torres and sit in the sun, drinking beer and throwing rocks at the traffic.

So, in short we need a platform (Senate inquiry), someone to listen (Committee) and someone with enough juice, savvy and interest to affect the changes which must be made. It's a big ask kids, huge. It takes time, it will take even longer again to rid the department of the legacy the current mandarins have installed. It's deep, dark and dirty; only from the top down reform can fix it, the evidence is there; it's a question now of getting a fair hearing.

There are more things in heaven and earth, Horatio,
Than are dreamt of in your philosophy.

[Mick Stuped]

Kharon
hear, hear, well said.

Bit more philosophy.

History teaches discontent always starts with the masses. Scream loud enough on mass, someone will hear.

[Stasi Hunter]

Quote:
where the hell is RAAA and AOPA on this?
Regretfully they are in bed with CASA

This is not a fair assessment. Why are they in bed with CAsA? RAAA only operates by the grace of CAsA whereas AOPA is made up of pilots all reliant on CAsA for their permits to fly. Apparently most have never heard of reprisal actions, well wake up it forms the basis of most systemically corrupt systems. Why would CAsA as a bureaucracy be any different. They have the power!

Wake up Australia! We live in a bureaucracy, not unlike the former Eastern European countries. Democratic processes are for show. How many of our elected representatives have actual expertise to debate their respective ministries? Majority are lawyers, what does that say?

At least there are a few who will tell it as it is, the likes of Ben Sandilands and Paul Phelan but we support them anonymously , maybe time to stand up and be counted. There are many no longer in the industry but still supportive via PPrune why not come "out" and support action. Strange how the Anzac spirit only ignites outside our borders. Apathy is alive and well and CAsA love it.

[Aussie Bob]

Stasi, you tell me it is not a fair assesment, then in your post you describe it as a fair assesment. Yes, these organisations by taking a softly softly approach are indeed in bed with CASA. These organisations also seem ignorant of the forthcoming election.

Curently, yes CASA holds the power and these organisations go along with it. The current RAAA web site has nothing on it regarding onerous legislation and AOPA have a tame article five items down the list behind safety seminar publicity. AOPA fail to realise that safety is a non issue compared to the survival of GA.

Where is the unity? Where is the militancy? The diversity of pilots makes them their own worse enemy.

I stand by my comment. Until I see these organisations organise demonstrations like say a slow drive through of of capital city airports at peak hour or an enmass fly past nothing will happen. Pilots are a minority but so are Gays, just look at where a bit of militancy has got them.

[Stasi Hunter]

Stasi, you tell me it is not a fair assessment, then in your post you describe it as a fair assessment. Yes, these organisations by taking a softly softly approach are indeed in bed with CASA.

A.B. my apologies, assessment is not the word, the whole association between RAAA /AOPA and CAsA gives the appearance of either staying out of the "argument" or taking sides. But as explained this is of necessity especially in the case of RAAA who rely on "dispensations" (AOCs) to operate in the first place. If AOPA were run in the manner expected of such a representative organisation, its executive and vocal members would soon be removed/dis-empowered by our very own "stasi". These scum have us all by the "short and curlies". The solution for AOPA is to have a non (no longer) flying executive that cannot be touched by CAsA. or to amalgamate with AOPA USA which is not impotent when it comes to taking on the FAA.

These organisations also seem ignorant of the forthcoming election.

CAsA is an established bureaucracy, it is more powerful than any Aviation Minister to date. What difference will an election make. The incumbent DPM has given the middle finger to the Senate Committee why expect anything different.

from the RAAA website: CASA Regulatory Costs
Something clearly has to be done about excessively high regulatory costs. The costs are artificially high because much of what CASA does has no safety benefit, and should therefore be abandoned, but field officers seem unable to let go of functions they once performed, even when it is evident that those functions are valueless, and while high priority tasks are either not performed at all or are delayed typically by six months or more, allegedly because of a “lack of resources”. Yet CASA seems disinterested in becoming more efficient. After all, when it can simply charge industry whatever it costs to run its regulatory services, why should it? It is becoming increasingly clear that only an external review will resolve the unjustifiable costs that CASA imposes on the industry.

initially I took RAAA to be RAAUS which is in a worse position. Too many on this forum have been at the receiving end of CAsA displeasure. A simple stroke of the pen and no more AOC quickly brings you into line. Then there are those like Creampuff that will tell you there is always the legal system. Why bother when CAsA are a law unto themselves. In fact they'll write up a new one to suit (them) whilst you wait.

As to your Pilots are a minority but so are Gays, just look at where a bit of militancy has got them.

Agreed but if we look at how long acceptance (of gays) in Aus has taken compared with Northern Europe we are in for a long ride. Considering that Australia used to be a leader in Freedom to Fly and the practical approach out of necessity we have come a long way in the opposite direction.

if we all came out (in aviation terms) on this site it would be a first step to get acceptance. We have the means on sites like Pro Aviation | Sharp End Aviation News and Features (http://www.proaviation.com.au) and am sure Ben Sandilands would take up more of our causes.

S.H.

[le Pingouin]

Bob, GA affects far too few people directly - the vast unwashed masses would be barely aware and if they are think you're flying VWs with wings on the weekend for fun. You're not going to get any leverage by being militant - how would your militancy affect your average suburban voter? Pissing people off who don't already have a clue who you are just pisses them off.

Why should they care about GA? Until they do, any grand gestures will count for nothing. You need to find a friend in high place willing to push your barrow.

[Sunfish]

Militantcy will simply result in a string of show cause notices regarding "fit and proper person" status, unless you are extremely clever and well organised.

The first thing you could do is agree not to charter to politicians who don't endorse action.

[YPJT]

The first thing you could do is agree not to charter to politicians who don't endorse action.
Sunfish, do you really think for one minute that operators and or pilots would be so united? As soon as one operator refused a charter request, half a dozen would jump in and offer to do the same flight for a fraction of the cost.
It is akin to a CPL standing up to an employer for safety, pay or any other reason. No problem, half a dozen behind you mate ready to do it and keep their mouths shut.

[601]

how would your militancy affect your average suburban voter?

There is one thing that moves by air that affects everybody - mail.
Just don't carry mail.

[le Pingouin]

How is that going to work? I don't think much mail gets carried between capital cities by anything smaller than a Metro.

[tail wheel]

I don't think much mail gets carried between capital cities by anything smaller than a Metro.

Or anything larger than a B Double!

Most ordinary mail in Australia is transported by road.

Road transport of Air Mail was pioneered by Reg Ansett, some may recall!

[Kharon]

@ 40,000 feet, nothing on the clock but the makers name. Consensus – Yup, we have identified a problem, everyone's scared; but we still need a solution.

Reading Pprune and (occasionally) other various sites I get an impression that many 'outfits' are, of necessity, beholden, in one way or another to the CASA; or, captive if you like. This is wrong; provided your operation is 'legal' there should, in a reasonable world, be no need to be continually genuflecting or kissing anyone's arse just to stay 'operational'. Tip toeing around the issues, thinking concessions or permissions etc. will be withdrawn if the voice of dissent is raised – cannot, long term be healthy.

Most folk I have met who are part of an 'outfit' seem to be sane, capable, law abiding, practical, pragmatic sorts with the best interests of the 'outfit' at heart. In combination they could be a positive voice; tribalism and personalities aside. I have no doubt there is talent, leadership, intelligence and a willingness to get involved out there, no doubt at all. But I do wonder why the various 'outfits' can't have an indaba and at least agree to unite, even for a short while to sort things out.

Disclaimer: I only ask as an outsider, looking in: (most definitely not a 'club' member type).

[Neville Nobody]

Have any of you contacted Warren Truss (the next Transport Minister) to express your fear for the industry - a VIABLE industry which is being made UNVIABLE purely through political indifference?

Having 10 years (Under little Johnny) to clean things up and not doing anything what makes you think it will be any different this time round?
No doubt you would have contacted the current minister, what was his reaction?

[LeadSled]

------ Road transport of Air Mail was pioneered by Reg Ansett, some may recall!

Tailwheel,

Funny you should mention that, Reginald Miles pioneered carrying all the east coast freight by road ---- as did TAA.

In the early '60s, when both had a couple of DC-4 freighters, I worked for an overnight express company, Comet.

At least TAA were honourable enough to use overnight express for most of their airfreight. Reginald Miles was to tight for that, he waited until he had a semi load.
At least TAA customers got next day delivery, Ansett customers were often mystified why their "air freight" was no faster than "road freight".

Tootle pip!!

[tail wheel]

And no one knew air mail with Ansett was moving by Ansett Road Express until one of Reg's trucks rolled south of Sydney and air mail carpeted the Pacific Highway. :}

I remember Comet, part of the TNT group up to the mid 1980s. The don't seem to exist anymore.

[dhavillandpilot]

Use to work in management at TNTAIR in the mid 80's, your wrong about road freight in lieu of air freight.

Of course everything went by air they literally FLEW using a 18 wheel Boeing with name tags reading Kenworth.

Those were the days, all the Pelair Westwinds and every small aircraft operator was your friend.

Now it's just toll and they are no fun

[kimwestt]

G'day
If you want to remember back a bit further, RM started his bus service out of Hamilton (Vic). He would get all the pax seated, then collect the fares in order to buy the fuel for the trip to Melbourne!!
:ok:

[tail wheel]

If you want to remember back a bit further, RM started his bus service out of Hamilton (Vic).

I'm not that old!!! :=

On returning to Victoria in December 1931, with his savings he purchased a second-hand Studebaker and began a service car operation between Ballarat and Maryborough carrying passengers and small items of freight. When this proved uneconomic, he switched the Ansett Motors operation to a Ballarat to Hamilton service. The wealthy graziers of Victoria's western district proved to be a much better market. Within a few years he had a small fleet of service cars operating to towns in western Victoria.

Leadie may remember! :}

[LeadSled]

tail wheel,
Steady on, that would make me close to 100 now!!

The next part of the Ansett saga was the Victorian government clampdown on his road passenger services, because he was competing with the railways.

When the Victorian government banned these commercial road services, he made the trip free, but, by George, the mandatory orange and sandwich were the most expensive snacks in Victoria. Retrospective legislation soon sorted that out, so RMA turned to aeroplanes --- and Victoria Air Coach was born.

The ensuing history of High Court (because that is where most of the cases ended up) is the history of inter and intra state aviation in Australia, S.92 and S 51.1 of the Constitution, and the peculiarities of the fact that aviation is "states rights".

Reg was the major driving force in the 'Two Airline" agreement, that did so much to retard aviation in Australia.

Tootle pip!!

[zac21]

(Of course everything went by air they literally FLEW using a 18 wheel Boeing with name tags reading Kenworth.)

And in the sixties it was a fleet of Deutz 10 wheelers!

[LeadSled]

zac21,
In the '60's the overnight parcel services (Comet, IPEC, KwikasAir etc) all used 4 tonners, to avoid the state 6 pence per ton/mile road tax on anything over 4 tons, levied to limit competition with the railways.

Comet mostly used a special model Dodge, 350cui V-8, 5 speed box and 2 speed rear axle --- with a top speed of about 120mph --- no highway speed limits in those day. Ford Australia made a vehicle to a very similar specification.

In those days, the main railway freight depot in NSW was at Darling Harbour. I am certain the workers there were the models for Hollywood's present day zombies, they moved at the rate of the living dead --- and were mostly dead from the neck up.

Work to rule was permanent with the railways, and the rule was no work should be performed during working hours.

Tootle pip!!

[kimwestt]

To quote one A.B.Patterson:
"Their eyes were dull, their heads were flat, they had no brains at all."
Apologies to the man from Ironbark.
:ok: