“Safety of Air Navigation as the Most Important Consideration” - Mark Skidmore

[Dick Smith]

I realise this is probably discussed in some other thread, but I can’t find it at the moment.

CASA Director, Mark Skidmore, has made it clear that he is going to follow the Australian Government’s policy of giving primacy to safety as the “first principle” where he states in the recent CASA Briefing (January 2015) that he regards “the safety of air navigation as the most important consideration”.

Many will know that for over twenty years I have objected to this as it’s simply not possible.

The most important consideration over what?

If it means the most important consideration over cost, the only person flying will be James Packer – and he wouldn’t even be able to afford to do so. I have asked a number of Ministers for Transport to change that part of the Act so it says words to the effect, “the most important considerations being safety and participation levels in aviation”. Of course, the bureaucrats have stopped this at every move. You wouldn’t want to actually reflect in the Act what happens in practice, would you?

Remember, the Act states quite clearly the most important consideration is safety - then refers briefly to the environment - thereby allowing the bureaucrats to stop any harmonisation with lower cost, internationally-proven rules.

One thing I have found with my two terms in Canberra was the total lack of ethics and the dishonesty in the system. Yes, the bureaucrats know that if the most important consideration was just safety, no-one would be flying. However, they insist the wording stays so it can be used to stop any real reform that they may object to.

Hitch has made some other similar and sensible comments in The Last Minute Hitch article dated 23rd January 2015 – see here (http://www.australianflying.com.au/news/the-last-minute-hitch-23-january-2015?utm_medium=email&utm_campaign=FLYO+E-Newsletter+23rd+January+2015&utm_content=FLYO+E-Newsletter+23rd+January+2015+CID_6df46f80cd561c962e4d66cc199 19dfd&utm_source=Email%20marketing%20software&utm_term=The%20Last%20Minute%20Hitch)

[hiwaytohell]

Did you also notice the total absence of the word "accountable":

From the Director of Aviation Safety, Mark Skidmore

There are five principles CASA must embrace when making decisions or taking actions that affect the aviation community. The first principle is of course aviation safety. The Civil Aviation Act makes this certain by stating its main object is to "establish a regulatory framework for maintaining, enhancing and promoting the safety of civil aviation, with particular emphasis on preventing aviation accidents and incidents." The Act also requires CASA to "regard the safety of air navigation as the most important consideration" when exercising our powers and performing our functions. So clearly CASA's first principle must be to support the safest aviation environment for all Australians. CASA's activities must pass the test of making a positive impact on maintaining or improving aviation safety. With safety at number one there are four other principles I will use to ensure CASA is an even more effective aviation safety regulator, while building our relationships with the aviation community. These principles are communication, cost, complexity and consistency. I know people in the aviation community have been talking about issues relating to these principles for some time and I thank those who have provided input to my approach.
I have told CASA's people that I will require everyone in the organisation to think about and apply these principles when we make new regulations or amend existing regulations, when we make decisions and take or recommend actions. These principles will guide CASA in all our dealings with the aviation community. CASA has a responsibility to communicate clearly, simply and effectively. If the aviation community does not understand CASA’s safety requirements we will not get the right safety outcomes. When CASA makes changes or takes decisions and actions we must consider the financial impact on both the aviation community and CASA and seek to keep it as low as possible-without of course compromising the achievement of optimal safety outcomes. While we are bound by legal requirements in the way CASA's legislation is developed and presented, we must do our very best to minimise complexity and provide clear explanations of what we require that are free of jargon and confusing language. Finally, CASA must be consistent in its decision making and actions. It is not acceptable for different areas within CASA to present different views on the same issues to the aviation community.
I am personally a great supporter of aviation and want to see as many people flying as possible. In keeping with this vision and our core regulatory functions, CASA's role is to encourage, support and foster higher standards of aviation safety.
Safe flying
Mark Skidmore AM

[ozbiggles]

The good old affordable safety issue
Working wonders in recreational aviation.

[Dick Smith]

Oz. I suppose you believe in "un affordable " safety.

To have any credibility at all on this site you should explain how un affordable safety could work.

[Dick Smith]

You are correct.

Second most powerful lobby group in the USA after the NRA is the U.S. AOPA!

That's the prime reason GA is so much better off their!

[Andy_RR]

Unaffordable safety is less safe than affordable safety because when it's unaffordable it doesn't necessarily stop the activity. "Methods" are found to restore affordability.

[Aussie Bob]

Second most powerful lobby group in the USA after the NRA is the U.S. AOPA

Wish you and Boyd had had more success in taking over the useless CASA fawning Aussie AOPA mob we have here today.

[PLovett]

I don't think it would matter who was at the helm of AOPA Australia, trying to get pilots in Australia to work together is like trying to herd cats. I am forever reminded of this scene in Monty Python's "The Life Of Brian" when it comes to aviation.....from about 3.25 on

www.youtube.com/watch?v=NrDVsprWRCQ

[ozbiggles]

Credibility on an anonymous web site....that's what been missing in my life.

What is your concept of unaffordable safety DS? Then I will tell you if I believe in it. What I don't believe in is pilots who take up the airwaves complaining about their belief the red carpet should be rolled out for them.

And my comments on RA are not my own, they come from a report that DR Rob Lee had a bit to do with.

[Dick Smith]

That's just the point. I don't have a concept of un affordable safety as there is no such thing.

Safety has always been limited by what those paying for it can afford.

It is just a fact of life. Its a pity you and a few others don't appear to understand this.

[dubbleyew eight]

I don't know what ozbiggles does in aviation but he seems to be one of the blue elephant paper brigade.
you meet them everywhere.
they don't show any real engineering sense, couldn't give you an estimation of the flight loads in a component but believe that by following the rules and carrying insurance they can engage in the stupidest of practises with impunity.
you know ....leave little squares of blue paper everywhere and the elephants will stay away.

I think what sticks in the throats of the CAsA bods is that deep down they know that Dick Smith is correct.
If you want actually safe aviation then that can only be achieved with responsible people applying actual engineering understanding to the challenge of flying machines through the air.

Engineering understanding is an enormous black hole in aviation.
If you look at the homebuilding environment just about all the stupidity can be seen to arise from a lack of any fundamental engineering understanding.

"Certification" actually works to prevent competent aviation.
it locks knowledge away from the participants and confines it to selected authorised persons who then find that they can't make a go of the industry and it all dies.

maintaining an environment of "Certification" and the small cadre of "authorised persons" is the empire at the heart of CAsA. what a sad empire it all is. all it ever seems to achieve is a less and less viable industry.

If a person actually applies engineering nouse to flying an aeroplane, but doesn't follow the blue paper route with reams of "auditable documentation" then despite them aviating safely they face threats of years in prison. an absurd situation.

The aviation regulations in Australia have at their heart some really stupid concepts.
From where I sit in aviation, and with 42 years between where I am now and when I started, the rules and regulations are getting stupider and stupider because the fundamental errors at the heart of CAsA's world view have never been corrected.

To paraphrase the welshman. 'If I wanted to get to where you wanted to go I wouldn't start from here.'
CAsA, if you want to achieve safe aviation you won't achieve it the way you are going.

Dick Smith is human. undoubtedly he has made mistakes or had things he has said taken out of context, or misunderstood. but Dick Smith is correct in saying that this isn't the way to safely approach or regulate aviation.

you're as thick as two short planks at times Australia.

Air Vice Mashall (retired) Mark Skidmore hasn't impressed me one iota so far.

W8

[Wallsofchina]

Agree with you Dick, Mark Skidmore might just have ruled a line under his skill level.

Why does it even need to be stated by a Safety Authority?
Do they all have to run around with a piece of wool tied round a finger to remember?

This is a parallel to the Corporate world where companies spend a quarter of a million on Vision and Mission Statements, bolt them on to the office wall and forget all about them.

Maybe the problem starts with the name.

If you have a Civil Aviation Safety Authority, where is the Civil Aviation Operating and Development Authority?

[neville_nobody]

If you have a Civil Aviation Safety Authority, where is the Civil Aviation Operating and Development Authority?

Yes that actually is the issue. CASA are trying to control EVERYTHING in aviation rather than administering aviation.

It's utterly ridiculous that an aircraft can get a type certificate from the FAA then CASA wants you to 'prove' everything again, or pay more money to get an approval for this or that. Either it is has been tested and shown to work or it hasn't.

It's no wonder that basically every Biz Jet in Australia is N registered, you just buy the thing, do the training for the crew and you're on your way.
VH register it and you need a host approvals for things that come standard with the aircraft!!:ugh:

[Centaurus]

you just buy the thing, do the training for the crew and you're on your way.
VH register it and you need a host approvals for things that come standard with the aircraft!!

I think it was back in the 1970's when DCA bought a couple of Merlin twin engine turbo-props. I vaguely recall DCA wasn't satisfied with the FAA type certification of the Merlin and decided to undertake some landing trials using two of the DCA Flying Unit pilots. Neither were qualified test pilots. The end result was a Merlin on its guts at Wagga following a very heavy landing. :=

[LeadSled]

I think it was back in the 1970's when DCA bought a couple of Merlin twin engine turbo-props. I vaguely recall DCA wasn't satisfied with the FAA type certification of the Merlin and decided to undertake some landing trials using two of the DCA Flying Unit pilots. Neither were qualified test pilots. The end result was a Merlin on its guts at Wagga following a very heavy landing. :=Folks,
It was not a matter of Australia not being satisfied with FAA (or any other) certification, we had our own certification rules, and every new type had to meet those rules, which often resulted in very expensive modifications, as well as the expense of "test flying" every new type.

The damage to the Merlin was extensive, with the main gear almost driven up through the wings, both engines almost broken out of their severely damaged mounts, plus an instant "droop snoot" nose ( fuselage buckled at the forward windscreen pillars, and buckled/torn/ruptured plating in the nose gear well).

That is why, in 1996, the first Howard Government set out to repeal all the Australian unique certification rules, and adopt the FAA rules for certification, but CASA have managed to subvert that intention, and have virtually re-created "first of type" certification.

One of the most stupid argument, that still comes up amongst some of the "iron ring" is that NOT having our own unique standards is "surrendering sovereignty", or, put another way, we should NOT have the same design standards as other countries, but maintain different standards for the sake of being different (and creating a lot of CASA jobs that the industry has to pay for).

For years, Australia maintained takeoff calculation methods that severely handicapped Australian carriers, mostly Qantas, compared to other carriers. By 1997, there had never been an incident where the "unique Australian rule" would have prevented the incident, and there has not been, since, but the hard core CASA battle tooth and nail to maintain this unique "standard".

Wrecking the Merlin (my memory says Mangalore) was not because the pilots were not "test pilots", it was because the aircraft was being flown to "Australian standards". In this case, the "standard" required a approx. 3 degree approach, stable at Vref, at 50 feet, close the throttles and maintain the attitude - no flare. As any of you who have flown Metro or Merlin (or many other aircraft) will know, a heavy landing is almost guaranteed under those circumstances.

A number of aircraft were wrecked "test flying to Australian standards". To this day a lovely little flying boat, a Riviera if my memory serves me correctly, lies at the bottom of Pittwater, thanks to the same damned fool nonsense as wrecked the Merlin.

Tootle pip!!

[Sunfish]

Skidmore has just proclaimed himself to be a fellow traveller who won't make waves or attempt to change the course of Aviation regulation in Australia. That can only be bad for the entire industry from Qantas all the way downwards for reasons I will explain below. Dick Smith is also right about the "affordable safety" although the use of that term is unfortunate. I will explain that as well.

Lets start with the Senate report; that catalogued the failures of aviation regulation and made the most serious charge possible against a public service anywhere of any kind: - a total lack of trust of the regulator by the industry, in other words a breakdown of any constructive relationship between regulator and regulated. Additional to this is the breakdown of trust with CASA's partners Air Services Australia and the Australian Transport Safety Bureau who are joined by memorandums of understanding to CASA and cooperate in its malfeasance, as evidenced by the disgraceful ATSB report into the ditching of the Pel AIr aircraft.

In addition, thanks to Karen Caseys law suit, we now find that there appears to be a web of corruption involving political donations by Pel AIrs owners to political parties who then lent upon CASA and ATSB. This has all the features of what is termed Crony Capitalism - you scratch my back, I scratch yours.

The characteristic of Crony Capitalism is that rules are bent to suit your mates and the legislative preamble of the Aviation Act: "establish a regulatory framework for maintaining, enhancing and promoting the safety of civil aviation, with particular emphasis on preventing aviation accidents and incidents" is what facilitates this because "safety" is a nominative, it can mean anything you like it to mean. It is this sentence that facilitates the entirety of CASAs bastardisation of Australian Aviation - CASA is always chasing "safety" a willow the whisp which means that what CASA calls unsafe practices for one pilot or operator are perfectly reasonable for another.

The impact of Crony Capitalism is that investment in the industry diminishes since no investor can secure himself against sovereign risk - that the regulator is going to take agin you for some reason and destroy your investment and capital, as CASA has demonstrably done time and again. Lack of investment means lack of jobs and growth in the industry and overall, Australia suffers. Mark Skidmore has, by his own words, refused to redefine "safety" in practical terms and will thus allow the bastardisation and embuggerance of the industry to continue on his watch, no matter what his no doubt good intentions may be.

Dick Smith is right about "affordable safety" but seems to not understand what this means in practical terms, and the spineless jellyfish in ATSB who could have been the enablers in such a process are silent. The practical name for achieving "Safety" is "risk management". This discipline is at least Forty years old, I was taught it on my first job with an oil company. It involves the quantification of risk and the cost of accidents, followed by a determination of what it would cost to mitigate the risk followed by a straightforward cost benefit analysis.

Risk management is not rocket science, it is well understood. It is the basis for rule making by other regulators (notably the FAA). The ATSB can produce most of the statistics for its implementation off the top of its head and the industry has the rest. What it does require is for a Government to decide what an acceptable level of risk is for various classes of Aviation: "One in a Million"? "One in Twenty million"? Again there are international metrics for this stuff to guide us and most of the world, except Australia, benchmarks their aviation sectors against these metrics every year. Just redefine "Safety" in the preamble of the Act and everything else Dick Smith requires will follow.

However it now appears certain that nobody in Government on either side of politics has the guts to become accountable for anything, let alone aviation safety, and this provides a perfect opportunity for the parasites that are CASA, ATSB and AsA and their corrupt business partners to milk what is left of the industry for all they are worth to satisfy their bloated egos, lust for power and of course the money.

Need I add that the final outcome of this situation is to make the industry as a whole much less safe and ultimately lead to a series of catastrophic accidents?

[mack44]

Sunfish "Skidmore has just proclaimed himself to be a fellow traveller who won't make waves or attempt to change the course of Aviation regulation in Australia"

My heart sank when I read CASA's latest news letter. No new broom here!

[tail wheel]

The end result was a Merlin on its guts at Wagga following a very heavy landing.

And if memory serves me correctly, another on it's guts at Mt Hagen, courtesy of the then Director?

From an HS125 to a Cessna 185, I don't think there is much DCA/CAA/CASA haven't pranged over the years. The fact CASA no longer have a Flying Unit, is probably a large plus for Australian air safety.

[Arm out the window]

Seems there is a lot being read into Mark Skidmore's, to me, quite reasonable-sounding words, to somehow twist it into a statement of his intention to do nothing!

There are five principles CASA must embrace when making decisions or taking actions that affect the aviation community. The first principle is of course aviation safety. The Civil Aviation Act makes this certain by stating its main object is to "establish a regulatory framework for maintaining, enhancing and promoting the safety of civil aviation, with particular emphasis on preventing aviation accidents and incidents."

Struth! Imagine having a regulator that aims to prevent accidents.

With safety at number one there are four other principles I will use to ensure CASA is an even more effective aviation safety regulator, while building our relationships with the aviation community. These principles are communication, cost, complexity and consistency.

Presumably increased communication and consistency, reduced cost and complexity, I think it's fair to assume, although some will no doubt say the opposite.


I know people in the aviation community have been talking about issues relating to these principles for some time and I thank those who have provided input to my approach. I have told CASA's people that I will require everyone in the organisation to think about and apply these principles when we make new regulations or amend existing regulations, when we make decisions and take or recommend actions. These principles will guide CASA in all our dealings with the aviation community.

One would almost hazard to suggest he has listened to complaints and wants his organisation to act to address them.

I could go on, but we can all read and interpret his words as we see fit.

Did you also notice the total absence of the word "accountable":


I think saying he will require his staff to apply those guiding principles counts as a statement of intent to make them accountable, which at least is a start. He didn't use the words 'pineapple' or 'wheelbarrow' either, I note, which is quite telling.

Skidmore has just proclaimed himself to be a fellow traveller who won't make waves or attempt to change the course of Aviation regulation in Australia.


How on Earth do you draw that conclusion from his statement? The level of negativity on display in this thread is bordering on unbelievable.

If you don't like what these guys do, fair enough, but there are two serious options available to you:

a) fight them tooth and nail until you bring them down, then replace the whole shooting match with something else (and presumably then whinge about that too), or

b) put prejudice aside and try to work within the system, whilst constructively pushing for change where it's warranted.

[Frank Arouet]

Who can forget this;

A group of young enthusiasts
Met at a local pub
To talk about a common love
The Port Moresby Gliding Club.

Their membership was very low
The running costs were high,
They needed some dramatic act
To catch the public's eye.

"I've got a good idea" said one
"Been planning it all day,
I'll try it out tomorrow
When coming back from Lae."

The flight to Lae was wonderful
The aircraft right on track,
They had no reason to suspect
The drama coming back.

Their business done, they climbed aboard
One had a bulging bilum
The Captain chuckled to himself,
"The last ten miles will thrill 'em".

This trick will have no impact
If I fill her up with fuel,
I'll take enough for top of climb
And glide in from Mount Yule.

They flew along as smooth as silk
With not a single jolt,
But as they got to Galley Reach
Both donks groaned to a halt.

The Captain said "Thank Christ they've stopped
They make a dreadful din,
I'll now complete this exercise
And glide the begger in."

A glider is a lovely thing
You see them everywhere,
Some metal, others wood and glue
But never a KingAir!

With noses flat against the glass
The victims watched in horror,
And none of them had any doubt
They'd all be dead tomorra.

He held her on the centre line
He called the tower and said,
"For Christ's sake make me number one
I'm landing straight ahead."

He put it down right on the keys
and made sure he was clear,
Then smilingly he turned and said,
"I think we need a beer."

The Aero Club looks very nice
Looks like its just been painted,
But there was no-one to answer him
The bloody lot had fainted!

Wes turned and looked him in the eye
He said "Thank Christ that's ended!
It really won't surprise me
If your licence is suspended!

Those passengers we've got on board
Look like they're in a trance,
But now you must excuse me
'Cos I think I've shat my pants!"

When Joe Wal heard it on the 'phone
His hands flew to his head,
His eyes stood out like organ stops
"Damn me" was all he said.

But when heard the details
Of this history making flight,
His eyes lit up with interest
And he thought of it all night.

For Joe has always longed to fly
Although it made him dizzy,
But this bloke here could show him how
On days he wasn't busy.

So Joe signed up on the spot
They headed for the pub,
Now Joe's the latest member
Of the Moresby Gliding Club.

Sir Julius picked up his 'phone and heard
A voice known far and wide,
"This Grumman that arrives next month
- I wonder how that glides?"

[Two_dogs]

I was sure I had seen the word accountable somewhere in the CAsA documents. There is of course an 'opt out clause'

From the Flight Examiners Handbook.
Civil Aviation Safety Authority - Flight Examiner Handbook (http://www.casa.gov.au/scripts/nc.dll?WCMS:STANDARD::pc=PC_102160)



Director of Aviation Safety Preface

Foreword
As a Commonwealth government authority, CASA must ensure that its decision-making processes are effective, fair, timely, transparent, consistent, properly documented and otherwise in accordance with the requirements of the law.
Most of the regulatory decisions CASA makes are such that conformity with authoritative policy and established procedures will be conducive to the achievement of these outcomes. From time to time, however, decision-makers will encounter situations in which the strict application of policy, in the making of a decision involving the exercise of discretion, would not be appropriate. Indeed, in some cases, the inflexible application of policy may itself be unlawful.
This preface and the following Introduction, explains the way in which the policy and processes set out in this manual are to be used by all CASA’s personnel when making decisions in the performance of their functions, the exercise of their powers and the discharge of their duties. It also explains the processes to be followed if it appears that a departure from policy is necessary or appropriate.

Mandatory Use of Policy and Procedure Manuals
This manual is one of the set of manuals and other documents which comprise CASA’s authorised document set. The authorised document set contains the policy, processes and procedures with which CASA personnel are expected to comply when performing assigned tasks. All CASA personnel are required to have regard to the policies set out in this manual. Except as described in the Introduction, CASA decision-makers should not depart from these policies, processes and procedures.

Terry Farquharson
Acting Director of Aviation Safety



Introduction
Regulatory Decision Making


Where the legislation provides for one, and only one decision—the “correct” decision—is the only decision open to CASA. However, most of the decisions CASA makes involve the exercise of discretion. In such cases, there may well be more than one acceptable or correct decision. In these cases, the law requires that CASA makes the “preferable” decision, that is, the most appropriate decision, having regard to the overriding interests of safety and the obligation to be fair.
In all such cases, CASA is bound to act in accordance with the applicable rules of administrative law. These rules govern how CASA arrives at the ‘preferable’ decision in any given case. Adherence to these rules is a requirement, not an option. Decisions and actions taken in contravention of these rules are unlawful, unenforceable, and in most cases invalid. CASA is legally accountable for the decisions it makes, and CASA decision-makers are obliged to avoid the appearance, as much as the reality, of unlawful decision-making.
Sound and lawful regulatory decision-making is generally governed by the 10 rules of administrative law summarised below. Adherence to these rules is essential to CASA’s obligations of accountability and good governance.
1. Natural Justice (Procedural Fairness)
• Hearing Rule. Persons affected by CASA’s decisions have a right to be heard. To be meaningful, the hearing rule normally requires that CASA provides persons with notice (usually in advance) that a particular decision is going to be taken, and the reasons for the decision CASA proposes to take. Without notice and a statement of reasons, there may be little point to providing a person with an opportunity to be heard.
• Rule Against Bias. Decision-makers should not have a personal or pecuniary interest in the outcome of their decisions. Neither may decision-makers prejudge (or pre-determine) matters in respect of which they are called upon to make a decision.
2. A decision-maker must not act for improper purposes. Even if the purposes for which a particular decision are lawful, the decision may only be taken for the purposes specifically authorised by the law under which the decision has been taken.
3. A decision-maker must not take any irrelevant considerations into account in coming to a decision.
4. A decision-maker must take all relevant considerations into account in coming to a decision.
Note: Applicable Policy is Always a Relevant Consideration.
5. A decision-maker must act on the basis of evidence, not mere supposition or speculation.
6. A decision-maker must not formulate requirements in vague or uncertain terms.
7. A decision-maker must not inflexibly apply policy (although departures from policy will normally need to be justified).
8. A decision-maker must not act under dictation (although this does not preclude adherence to formal directions, compliance with lawful conditions in relation to the process by which a decision is taken or the obligation to consult in the process of considering a decision).
9. A decision-maker must decide the matter within a reasonable time.
10. A decision maker must not act in a way that is manifestly unreasonable. A decision must not be so unreasonable that no reasonable person would make such a decision.

[Jetjr]

It indicates the four extra principals, cost, communication, complexity and consistancy but doesnt indicate if he wants to reduce or increase them

[Arm out the window]

Yes it does:

These principles will guide CASA in all our dealings with the aviation community. CASA has a responsibility to communicate clearly, simply and effectively. If the aviation community does not understand CASA’s safety requirements we will not get the right safety outcomes. When CASA makes changes or takes decisions and actions we must consider the financial impact on both the aviation community and CASA and seek to keep it as low as possible-without of course compromising the achievement of optimal safety outcomes. While we are bound by legal requirements in the way CASA's legislation is developed and presented, we must do our very best to minimise complexity and provide clear explanations of what we require that are free of jargon and confusing language. Finally, CASA must be consistent in its decision making and actions. It is not acceptable for different areas within CASA to present different views on the same issues to the aviation community.

[LeadSled]

From an HS125 to a Cessna 185, I don't think there is much DCA/CAA/CASA haven't pranged over the years. The fact CASA no longer have a Flying Unit, is probably a large plus for Australian air safety. Ain't that the truth!!
In (I think) 1966, DCA accounted for over 50% of the accidents that year, with credit for about 100% of the major accidents. As well as the DH 125 there was the NSW C-310 on its guts for the second time, a Musketeer wrecked on takeoff at YSBK (very interesting story), an F-27 dead stick'd into Mudgee ( shut down the wrong engine), and at least several more, the details of which do not immediately come to mind.

Remembering ( Wot!! No checklist??) to extend the gear seemed to be a major DCA problem, Dove at Camden, DH 125 Avalon, C-310 Lismore ( in front of an airshow crowd) and ?, G-1000 twice in WA. AC 560E, NT? Most of us from that time will remember Bill Lord flying into a glider cable with the NSW Region Bonanza.

Interestingly, the G-1000 above is still flying in US, the current owner was most interested to learn the "history" of the aircraft.

Tootle pip!!

[LeadSled]

Two Dogs, arm out the window,

As apologists for CASA, maybe you don't want to understand the shortcomings of the Act, well canvasses on pprune, which, without amendment, will means nothing of significance will change.

The shortcomings are well know, up to and including Ministerial level, I discussed them with Laurie Brereton, when he was Minister for Transport. Every responsible Minister since (except Truss) has solemnly promised to amend S3A and S.9 of the Act, none have.

In short, the bureaucrats have had a complete stranglehold, and as Creampuff has pointed out, time and again, the present situation suits the politicians, the damage to Australian aviation runs a very poor last to political survival.

As to hundreds and thousands of pages of CASA "policy", the law (and the attitude of "certain" CASA employees) trumps policy, every time - particularly in court, or any other legal/quasi legal proceedings.

Tootle pip!!

[Arm out the window]

LeadSled, I'm not an apologist for CASA, rather a realist.

I do know and respect Mark Skidmore, though, and to see the long bows being drawn by some in regard to his statement I feel the need to try to redress the balance somewhat.

Jumping up and down about whether safety should be stated as the first, second or last priority for CASA is ineffectual, as is ranting and raving about whether the new rules and DAS are likely to be any good or not - they're here, like it or not, so we have to work with them.

What would you have in place of S3A and S9 that would make any real difference? CASA, under any name or guise, will still be responsible for regulating aviation with the stated aim of keeping it safe, because any government making laws about aviation will have that as a priority.

Mark Skidmore closes his statement by saying he wants to see as many people flying as possible - I believe he actually does, and would also be aiming to fix what's wrong with the organisation he's now responsible for.

[thorn bird]

"Mark Skidmore closes his statement by saying he wants to see as many people flying as possible"

He will, in New Zealand perhaps, in Australia aviation is unaffordable and becoming increasingly so as the regulation factory continues to churn out ever increasing volume of gobbledegook.

Are Australian regulation writers and lawyers so inept, so incredibly incompetent that it takes them thousands of pages of indecipherable hogwash to annunciate a rule set that keeps aviation safe and the industry solvent?

Other countries manage to, and achieve much higher safety standards than us.

If our regulator can't they should be sacked and replaced with someone who can.

Thats the thing I fail to understand.

Why when in comes to anything to do with bureaucracy, Australians are expected to accept, without complaint, mediocrity and incompetence?

Mr Skidmore needs to understand, if things continue as they are, there won't be an industry in Australia to regulate.

But then again perhaps that's the governments aim.

[Dick Smith]

Why then is there no mention of removing every unnecessary cost?
That has been the problem for the last 15 years

[Arm out the window]

The rules are hard to decipher, it's true - they need to fix that. An accepted recommendation of the Forsyth report is that there should be a plainly-written version of the regs, and I hope they get that out quickly.

However, this kind of conspiracy theory talk -

if things continue as they are, there won't be an industry in Australia to regulate.

But then again perhaps that's the governments aim.

are you serious, that any government wants to kill something that contributes greatly to tourism, an extremely important sector of the economy?

Why then is there no mention of removing every unnecessary cost?


You mean this bit?

When CASA makes changes or takes decisions and actions we must consider the financial impact on both the aviation community and CASA and seek to keep it as low as possible-without of course compromising the achievement of optimal safety outcomes.



OK, he doesn't say 'remove existing unnecessary costs' directly, but the intent is there, surely?

[mack44]

"However, this kind of conspiracy theory talk -

Quote:
if things continue as they are, there won't be an industry in Australia to regulate.

But then again perhaps that's the governments aim.
are you serious, that any government wants to kill something that contributes greatly to tourism, an extremely important sector of the economy?"

Arm out the window I have recently had my charter business unlawfully shut down by CASA's Pooshan Navathe for 15 months. Walk a mile in my shoes and you may change your view point about what Governments do. I would be happy if CASA's administrators followed policy and regulations diligently as set out in Two Dog's post.

[Obidiah]

When CASA makes changes or takes decisions and actions we must consider the financial impact on both the aviation community and CASA and seek to keep it as low as possible-without of course compromising the achievement of optimal safety outcomes.


I don't read that as stating anything more than a token gesture to cost control. I do read that the goal of optimal safety will not be compromised though, and that will cost particularly when implemented by a litigation adverse government organisation.


As for killing off GA, an unlikely case, kept on its knees and subjected to regulatory control that stifles future growth no doubt what so ever.

[Two_dogs]

LeadSled, I am also not a CAsA apologist. I was simply pointing out the difference between the official policy and reality. I thought my post read this way and conveyed my disgust. Maybe I should have used some of those smiley things? :ugh::mad::{



I think Arm out the window, mack44 and myself would be happy to operate according to the official doctrine rather than the ambiguity we currently endure.

As far as understanding the shortcomings of the Act. I have enough trouble keeping up with Part 48 (2013), Part 61 (664 pages), and just can't wait for Part 135.

.

[Arm out the window]

Mack44, very sorry to hear of you, or anyone, having their business stuffed around by unlawful interference if that was the case, and I don't doubt your word.

My point has simply been that I don't accept that CASA is totally corrupt and can only be fixed by firing everyone and starting again; it's like when people say all politicians are bastards and throw up their hands in despair, as if things could never change.

[LeadSled]

Part 61 (664 pages)Two_Dogs,
You must have the Readers Digest version, including MOS and CASA policy/ training material, it is over 2200 pages and growing.

The draft Part 91 is a dreadful document, who knows what Part 135 will look like, but we already know that, if the Part 135 draft remains the same, "aerodrome standards for public transport" alone will wipe out most light aircraft "charter" as we have known it.

Part 133 is just as bad, the proposed severe limitations on single engine helicopters is completely unjustified by any risk analysis, much less cost/benefit justification.The impact on SAR/EMS will be substantial, right back to a load of nonsense first aired in about 2003.

What would you have in place of S3A and S9 that would make any real difference?
Arm Out the Window,

A re-written Act, as recommended by the PAP in 1998, to allow compliance with bi-partisan Government policy that all regulation must be justified, and all regulation must be cost/benefit justified. You should really look at how well the NZ or US legislation handles the balancing act.

It was well put in Byron's directive 01/2007 (now expunged, like much else from the CASA web site), which was recommended in the Hawke Report, and claimed by CASA to the Forsyth Review to have been incorporated as a Hawke recommendation within CASA rule making.

I have yet to see a CASA cost/benefit study of any serious nature (and I have been around quite a while), and certainly not one that satisfies the Productivity Commission or the OBPR definitions. In fact, it is clear that many in CASA do not know the difference between cost/benefit and cost effectiveness studies.

Tootle pip!!

[aroa]

GA ...or some of it will continue in Oz... altho at a reduced/and reducing rate.
In spite of CAsA not because of it.

All the statements about principles and protocols and what CAsA staff will do is just plain crap. Its all been said before in various guises for the last 30 years :mad: And where has that got us..apart from deeper in the mire

Because there is no Oversighting Agency with very BIG and powerful teeth, to do something about CAsA methods and its wrongdoers, then they know they are home and hosed...NO accountability. NO liability. No worries, then.

When the JQ affair was in full flight did the Legal office or the DAS see that a grave and disgusting injustice was being done. NO.:mad:

When 3 AWIs swore false testimony, what did the DAS do?.. just went into protection mode to subvert any action against "his staff" and invoke corruption and Cronyism 101:mad:

And time after time, individuals and businesses are damaged, and the smiling assassins/ incompetants just wander off brushing their hands of that debacle or whatever and on to the next one.!! :mad:
And it just keeps on happening BECAUSE THERE IS NO ACCOUNTABILITY:mad:

While Mr Skidmore may be a very nice ex-RAAF chappie, a hide-bound bureaucracy is a very different kettle of fish :yuk: :yuk:to deal with.

Great plans and policies have been adopted by Ministers and the Board in decades past and they all vanished into CAsA like snowflakes in hell.

A bucket of serious material is on its way. How it is dealt with and his reaction will prove his credentials or otherwise.
Cajones or snowflakes , we shall see.

[Dora-9]

Leady:

The AC560E was a take off accident (premature gear retraction, as I recall) at Wittenoom WA.

The pilot went on to be the WA Regional Director(!).

[halfmanhalfbiscuit]

Dick Smith

Why then is there no mention of removing every unnecessary cost?
That has been the problem for the last 15 years



Have to agree with Dick. Every process needs assessing to validate what supports safety and what is just bureaucracy and unnecessary costs. Trouble is people with that experience are ........ thin on the ground there.

We should get some good general insight from the first senate estimates in February.

[Paul O'Rourke]

I suppose you can add this one at Mangalore

http://www.atsb.gov.au/publications/investigation_reports/1989/aair/aair198901547.aspx

For some reason I feel there was another gear up around this time?

[Sunfish]

Arm Out The Window:

Seems there is a lot being read into Mark Skidmore's, to me, quite reasonable-sounding words, to somehow twist it into a statement of his intention to do nothing!

Quote:
There are five principles CASA must embrace when making decisions or taking actions that affect the aviation community. The first principle is of course aviation safety. The Civil Aviation Act makes this certain by stating its main object is to "establish a regulatory framework for maintaining, enhancing and promoting the safety of civil aviation, with particular emphasis on preventing aviation accidents and incidents."
Struth! Imagine having a regulator that aims to prevent accidents.

I am going to make the assumption that you are a genuine seeker of truth and not some troll and attempt to explain why you are completely wrong in your belief that the words don't matter.

Ultimately all CASA strategy, policy and regulation activities must conform to the intention of Parliament when they made the Act.. The ultimate arbiter of this is the High Court Of Australia; it is they who will construe the meaning of the words:

"establish a regulatory framework for maintaining, enhancing and promoting the safety of civil aviation, with particular emphasis on preventing aviation accidents and incidents."

The High Court makes no judgement on the reasonableness of what these words mean save that they don't conflict with the Constitution or other law. They will examine the literal meaning of what has been written without making any value judgements on what CASA has done with them.

...And what we find when we construe these words is that they give CASA unfettered power to do what it bloody well likes - which is exactly what it has done, capriciously,, corruptly, expensively, unjustly, inequitably and without a shred of procedural fairness and natural justice being afforded to its victims.

Furthermore your appeal to sweet reason and AVM. Skidmores good offices fails on the existing mountain of evidence of CASA's serial misbehaviour - no, they can't be trusted to be reasonable. Precisely because the Act doesn't require them to be reasonable!

This is how CASA gets away with it:

"establish a regulatory framework for maintaining, enhancing and promoting the safety of civil aviation"

Nowhere does it define what Safety actually is. "Safety" is a nominative word that can mean what you want - it is not defined, thus CASA can and does do anything it likes and when challenged, retreats behind the mantra of "safety" without defining the term.

Furthermore, with absolutely no constraint on what CASA can do to achieve safety, they can do anything they like, including shutting down all aviation completely which is what they do regularly to people they don't like and who CASA judges don't have the political influence to complain.

Lest you think I'm joking, that is why the second strange looking phrase is included:

"with particular emphasis on preventing aviation accidents and incidents."

This specifically refers to CASA the power to achieve it's safety imperative by preventing accidents and incidents.

Now a reasonable person would assume that such an objective would be the outcome of a safety system, but instead what the Act does is supply CASA with an effing great big axe in the form of a specific power to prevent aviation at all if it thinks that this might prevent an accident ro incident, and of course this relies on "negative evidence" for if there is no aviation how can one prove that the prohibited operation was actually safe?

To put that another way; the Act has redefined safety as the act or preventing accidents and incidents, not the outcome of a properly operating safety system.

This phrase is the source of the strangely convoluted legal language used by CASA to justify so many of its worst atrocities: - those regulations that state: "CASA must not issue / approve / permit / authorise, unless it is satisfied that.....". In other words CASA can do what it likes to its satisfaction. In a sane and just country these regulations would state that "CASA will issue / approve / permit / authorise on presentation of evidence that ..the person has satisfied the following criteria."

There is no constraint on CASA's activity except the High Court and Constitution. There is nothing in the Act that constrains CASA not to kill aviation stone dead and it kills parts of it every year.

What should have been in the Act are a series of constraints as follows:

- Perfect safety is impossible to achieve. By definition its cost is infinite as it can only be achieved by doing precisely nothing. CASA needs to be constrained to achieving worlds best practice benchmarks.

- CASA needs to be constrained to promote a safe and growing aviation industry, ie: remove its ability to achieve its objective by preventing aviation. This then introduces a requirement that CASA engage in evidence based rule making that includes cost benefit analysis.

Others have written more extensively on all this. Words matter, until the Act is changed, the industry will continue to decline.

[thorn bird]

Sunny, bravo, thank you, I hope our good senators read your post.

[Arm out the window]

Sunfish, I just aim to say it as I see it. Thanks for your reasoned response (apart from the bit suggesting I'm a troll and the kind offer to set me straight in my thinking!), but I can't agree.

If I'm reading it right, you say that the definition (or non-definition) of safety in law and the 'accident prevention' statement are the root causes of the current woes with CASA, with the implication, I assume, being that if they are changed to something more suitable, we'll be on the path to reform.

I don't say CASA are perfect, far from it, but I find it hard to believe any re-definition of those kinds of terms would change anything much. Of course, the wording of laws is important, but it's the culture and people in the organisation doing what they do that have the impact.

As I've alluded to before, if you radically change things, what do you change them to? Whatever wording of the charter and laws, there will be an organisation charged with being the aviation rule setter and policeman. Would you have another group policing the police? Who and how?

The Australian aviation community isn't big enough to have a well-rounded pool of experts champing at the bit to fill regulatory jobs, so as with most organisations we get a mixed bag. You and others seem to suggest they're all hopeless or vindictive or both, I don't agree.

[Grogmonster]

If you are running a business (Minister for Aviation) and you need to fill a position (New Director) are you going to employ someone who is going to completely disagree with everything you have done in the last few years and tear your Procedures and Policies apart? I don't think so. Enter another "YES" man. And so it goes on!!!!!

Groggy

[dubbleyew eight]

Sunfish you are a gem of clear thinking on this. :ok:

for if there is no aviation how can one prove that the prohibited operation was actually safe?

the canadian owner maintainers have set the precedent here.
you carry out the activity illegally.
you carry it out safely.
you refuse to stop carrying it out.
you refuse, in the actual interests of safe operation, to ever do it in the manner they (CAsA) prescribe.
eventually the system carries out a safety case study to try to stamp it out and proves conclusively that it isn't dangerous at all.
then the law gets changed.

The first sign of incompetence is charisma, is worth remembering here. The charismatic man does not listen and consequently never learns.
until CAsA learns to not be charismatic and starts to learn we will just continue to ignore them and fly illegally.
as discussions in another thread have shown their accident rate was astounding for people who claim to be "experts in aviation".

[hiwaytohell]

Good post Sunny!

Arm out the window;

Your support for Skidmore is admirable, and likewise others have told me that he is a "good bloke".

But this role needs more than just a good bloke.

Skidmore's first missive to industry came up well short of the mark. IMHO it was shallow and naive, and shows he has a long way to go before he fully grasps the gravity of his task.

Yes it is early days, but it is not as though he is coming in cold. There is a great body of evidence regarding the state of CASA including the Forsyth Report to point him in the right direction.

But it is a start!

[LeadSled]

Sunfish, I just aim to say it as I see it.Arm out the window,

All I can say is you must have severely impaired vision.

What Sunfish has to say is spot on.

Aviation is one of the few (if not the only) technical areas of Australian industry, where highly detailed and prescriptive regulations have not been succeeded by risk assessment based performance (outcome) regulations. The modern construction industry could not exist in Australia, at any price we could afford, if performance /outcome based regulation has not superseded the old prescriptivist regulations, and the latter (like aviation) had remained in place.

Sound familiar, we have aviation rules that we cannot afford, are not outcome/performance based, make little contribution to risk reduction (safety, if you insist) but hamstring the industry at all levels, and not just with the costs.

Fact is, if risk assessed performance regulations were applied to maintenance, the regulations/MOS would be about 10-15% of what we have.

How do I make this claim: because within CASA, in about 1999, we carried out a major exercise with the then existing regulations, it was quite amazing what we could dump, needless to say, the "iron ring" has a fit of the vapors and took over, the very idea was all too much for them.

Indeed, to quote a senior CASA legal person of the day:"Neither the Australian aviation nor CASA is sufficiently mature for outcome based regulation".

The sad call, recently, by a number of aviation associations, for yet more (a third level of) prescriptive regulation probably means there was some truth in said legal person's views. The fact is most Australian industry and commerce (and aviation virtually world wise) use two level legislation, and Act, and Regulations made under the Act, and here is the aviation community calling for (and, as a result the Forsyth Report recommending) a third level of regulation. Which, by the way, we already have, in the MOS, so we will probably wind up with four levels of legislation.

CASA will have a field day, I am certain CASA can't believe its luck, with the industry calling for yet more regulation.

Some of you probably think that the current rules for maintenance as EASA based, because CASA keeps saying so, but in fact they are nothing like the equivalent EASA regs, which are a very good effort at outcome based regulation.

Few of you will know that CASA was the last Commonwealth instrumentality to adopt competency based assessment --- but look at what they have done to it, once adopted ---- indeed, I am of the view that a number of the ways competency is to be demonstrated for Part 61 is just plain dangerous, and fly in the face of current knowledge, and manufacturer recommendations.

But, Hey!!!, what would the manufacturers and the rest of the world know, compared to CASA.

Tootle pip!!

[LeadSled]

Paul O'Rourke,
Yep, add that one, it is an impressive total of bent and broken aluminium.
As one poster has already said, perhaps the greatest single contribution to air safety in Australia was the grounding of the "Department's" flying unit, and having contractor do the navaids calibration work.
Tootle pip!!

[Eddie Dean]

LeadSled, EASA and supporting general Aviation with outcome based regulations? Which EASA are you reading?

[Arm out the window]

LeadSled, the third tier of regs being called for, as I understand it, is that the convoluted legal waffle that is Part 61 etc be translated into plain English, so bring it on, I say. Nobody wants more regulation; I just want whatever we have at any given time to be clearly expressed.

We already had that kind of thing with the Act, CAR and CAO, but something more straightforward would be welcome.

Sunfish said something along the lines of 'CASA will issue / approve etc' would be used in a sane country; in fact a fair number of the new regs do read along those lines.

The Part 61 MOS is pretty shabby in places, but they're reviewing and re-issuing it soon apparently, so I'd expect some of the clearly wrong bits to be fixed.

[LeadSled]

Arm out the window,

Clearly, in my opinion, you (and many others) do not understand.

We do not need any third (and fourth) level, no matter what they are called.
In 1996, the then Minister took a decision to move to an aviation legislative format that mirrored the FAA system.

Parts 21 to 35 went into the books in mid-1998, the only reason they have not worked better is CASA buggering around and frustrating the fact and the spirit of the changes.

Perhaps you would like to explain why Australia needs three ( or four, including the MOS) tiers of aviation legislation, when the sane world only needs two.

Explain why Australian aviation needs three (or four) tiers when the rest of Australian industry only needs two --- there is nothing particularly special about aviation. Many other industries have a far greater capacity to cause death and destruction than aviation.

Actually, I know the answer, but another tier of legislation inserted between Regulations and MOS is not the answer to the problems created by CASA style enforcement. You do understand that MOS are legislative, do you.

Tootle pip!!

[Frank Arouet]

Aviation regulation in Australia is casuistry based and adopts some rare but similar protocols to "Ignation Spirituality". Indeed obedience ranks very high in their case based reasoning.

[LeadSled]

----- and adopts some rare but similar protocols to "Ignation Spirituality". Indeed obedience ranks very high in their case based reasoning.

Frank,
Love it!! St. Ignatius would be proud of you.
Tootle pip!!

[Arm out the window]

Clearly, in my opinion, you (and many others) do not understand.


No, I just do not agree, but thanks for the patronising tone, it's very helpful.

LeadSled, I don't care how many tiers there are as long as there's a tier that explains the rules plainly.

The Part 61 MOS is little more than a list of competencies; it doesn't make Part 61 regs any easier to understand, written as they are in legalese with an overabundance of jumping between tables and paragraphs to pin down a simple point, so another manual of some kind telling it like it is would be good.

[Soteria]

You boys are just so negative. What about all the good things that Australian aviation has achieved such as Angus Houston receiving a knighthood, in part due to his work on MH370! And dont forget all the work that Dolan is contributing to that search and investigation. Then you have Jonathan Alecks endless contributions at seminars on topics like Just Culture and other assorted legalese! What about Terry Farq'u'hard'son and the introduction of Sly Sentinel, and of course how could we forget Greg Russell signing off on a billion dollars worth of ASA gizmo gadgetry, all clear and transparent of course :D

So c'mon you guys, let's see some more Positive Mental Attitude (PMA), that glass is half full you know :ok:

[Frank Arouet]

Actually LeadSled, you can add 'poverty' and 'chastity' to the 'obedience' for the full Jesuit mantra because CAsA have sent nearly everyone broke and many don't get any, because of marital and family bust ups in the ensuing emotional dramas.

[Sunfish]

Arm Out the Window:

I don't say CASA are perfect, far from it, but I find it hard to believe any re-definition of those kinds of terms would change anything much. Of course, the wording of laws is important, but it's the culture and people in the organisation doing what they do that have the impact.

As I've alluded to before, if you radically change things, what do you change them to? Whatever wording of the charter and laws, there will be an organisation charged with being the aviation rule setter and policeman. Would you have another group policing the police? Who and how?

The Australian aviation community isn't big enough to have a well-rounded pool of experts champing at the bit to fill regulatory jobs, so as with most organisations we get a mixed bag. You and others seem to suggest they're all hopeless or vindictive or both, I don't agree.

I don't call you a troll and I think you have never had to develop policy or strategic plans or business plans because the words do matter, in fact they are the only thing that matters.

Every action CASA takes or does not take, every plan, every policy must ultimately be shown to be directly related to the achievement of the goal set out in that opening statement: "establish a regulatory framework for maintaining, enhancing and promoting the safety of civil aviation, with particular emphasis on preventing aviation accidents and incidents."

In military terms this is called "the mission" and your activity MUST be directly related to achieving the mission, the corollary is also that you don’t do anything that is not related to achieving the mission.

This is the same principle as is used in strategic business planning, some people sneer at "mission statements" but it is critical that you define very precisely exactly what business you are in and just as importantly what you are NOT in. Many businesses - even mega businesses have foundered because they lost sight of what they were supposed to be doing.

The Act under which CASA operates uses a deliberately flawed and vicious mission statement and as a direct result it produces and delivers a flawed and vicious regulatory product.

Every policy and procedure CASA produces has to be tested against the purpose/mission written into the Act. The way the Act is written, CASA is allowed to achieve its mission by preventing aviation and is not required to take into account the health of the industry at all. This allows them to be total bastards with complete impunity - as they have demonstrated time and again as evidenced by the submissions and findings of the Senate report.

True, merely changing the words aren't going to change things overnight, but until they are changed then no improvement is possible because CASA is today prohibited by the Act from taking account of the impact of its regulations and actions on jobs, growth and investment.

[Creampuff]

Mr Skidmore’s answer to this question will reveal whether he has the necessary mix of experience and integrity to do the job in the public interest:

When will the regulatory reform program be completed?

Mr Skidmore’s predecessor’s predecessor, Mr Byron, gave this answer in February 2005:We have an action item to develop a plan to forward to the minister about when we plan to have them to the minister, and I assume that plan would be done in the next couple of months. I would be hopeful that it would not be long after early 2006 that most of the draft rules are delivered to the minister.That statement was made ten years ago.

Mr Skidmore’s predecessor, Mr McCormick, gave this answer in the "Aviation Safety Yearbook 2013":[O]ur current schedule will see the remaining rules completed by the end of next year. By my calculations, the next year after 2013 was 2014, and 2014 has ended.

The remaining rules have not been completed.

Here’s what I consider to be an objective assessment of the circumstances, by the then Chairman of the Regional Airline Association of Australia, Mr Jeff Boyd, at the Association’s 2013 conference:I look and see what it has cost and taken our industry to implement the Part 66 licences, Part 145 and Part 42 and I wonder how much more it will cost and take to actually get these three parts to an amended mature set of regulations. I then contemplate what a small section of the overall regulatory reform process these regulations are. How much more time and money will it take to finish writing and then implement the massive suite of flying ops and non-RPT maintenance regulations and what toll will that have on our industry? How many decades of amendments will it take to iron out all of these new rules and achieve a mature set of regulations? Then at the end of the day we will be sitting in the middle of the Pacific with a brand new set of Australian specific regulations.

Anyone who says the current trainwreck is anything other than a regulatory equivalent of the Spruce Goose is, in my opinion, either dangerously naïve, delusional or a paid apologist.

Mr Skidmore was at least smart enough not to mention “regulatory reform” in his January 2015 missive. However, he won’t be able to avoid confronting the issue for very long.

[LeadSled]

I don't care how many tiers there are as long as there's a tier that explains the rules plainly. Arm,
Wonderful idea, we could have four, five, six levels of legislation.

Say:
Act,
Regulations,
Manuals of Standards,
Statutory Interpretations of the Act, Regulations and MOS,
Plain Language (according to lawyers) Explanatory Guidance of Statuary Interpretations.

Then,

Temporary Guidance Documents:
to tide us over, while Explanatory Guidance of the Statutory Interpretations of the Act, Regulations and MOS are run through "the system", at each amendment of the Act, Regulations and MOS.

Clarification and explanation of Temporary Guidance Documents.

and so on.

Just think of the additional employment opportunities in CASA and the Office of Parliamentary Counsel.

Or, we could do what the Government intended and commenced in 1996, harmonise with the rest of the world, but particularly US and NZ.

The savings in forests being turned into paper, alone. would be worth it.

EASA and supporting general Aviation with outcome based regulations? Which EASA are you reading? Eddie,
Aviation regulation, it seems to me, is a bit like religion, the basic texts are fairly simple, but after the bureaucracy has got at it, whether it be clerical or "public servants", the outcome bears little or no relation to the best of intentions.

Tootle pip!!

PS1:Arm, sorry, if you find my tone patronising, but in my view you clearly do not understand the root cause of the regulatory problems Australian aviation suffers.
PS2: With apologies to EASA, the above is very roughly based on the JAA/EASA tiers/mountains of paperwork.

[thorn bird]

"The savings in forests being turned into paper, alone. would be worth it".


Maybe CAsA should have to apply for EPA approval before promulgating any new regulations. Given the current requirements for paper work Tasmania's old growth forests are in real danger.


Hopped in an aircraft the other day for a two hour flight.


Wondered why I couldn't get my seat back where it would usually be (Long legs).


Seems like CAsA had decreed that the huge volumes of shelfware, that nobody looks at, must be accessible to the flight crew, not down the back under the luggage, so they were jammed behind my seat.


Spent a very uncomfortable two hours with my knees in my ears, my right leg completely numb, to a point I could hardly walk when we finally landed and the pins and needles were excruciating.


We now apparently required to carry the entire ops manual, thus limiting fuel uplift by a couple of hundred kilo's, and removal of a passenger seat to accommodate it.


If I get deep vein thrombosis out of this can I or my dependents sue CAsA??...Probably not given what has happened to the Pel Air flight nurse.