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Truss: Aviation Safety Regulation Review

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Old 10th Feb 2014, 21:31
  #381 (permalink)  
 
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Thumbs up Bravo AFAP!

Blue Ruin thank you for that, not being a member of the AFAP I was unable to access what appears to be another significant contribution to the ASRR... {Q/ BR what is the current membership number for the AFAP?}

IMO AFAP members should be (especially given the short time to prepare) suitably happy with the end result, as the submission appears to encompass many of the main membership concerns while providing historical, simple examples and practical solutions/recommendations with strong adherence to the ToRs...so bravo AFAP...

Supplementary to BR quotes (same hymn sheet..):

7. Alternatively, we believe that the Director of Aviation Safety should not be able to operate independent of a Board structure.


8. We consider it imperative that all senior appointments to any agency with a safety related role should have significant prior experience in a relevant field.
Further to CAsA, other than Avmed debacle (my bold):
11. Policy changes aimed at greater industry self-regulation than currently exists should be opposed. In a climate of reduced resources a philosophy of self-regulation may appear to be an attractive short term option. However, self-regulation is a self-fulfilling principle; the more that CASA devolves to industry, the less expertise resides within CASA to identify shortcomings, the less CASA is seen as ‘the Regulator’ and the less it accepts that responsibility.

12. The perception of CASA by our members is one of constant change, characterised by high staff turn-over and low morale from within. Whilst we understand any regulatory authority will continually review its internal policies and administrative operations to improve service delivery and efficiency, there is a need for a clearly articulated long term goal of what the Regulator wants to achieve and how this will be done.
On the ATsB & PelAir report:
16. We support legislative immunity for flight crew who raise safety concerns and measures that allow flight crew to report directly to a better resourced and independent ATSB.


17. We oppose any relaxations which may allow greater access to information obtained by the ATSB during safety investigations.
25. We note that the Minister whilst in opposition supported demands for the immediate implementation of those recommendations and request that this Review revisit the findings of that inquiry and recommend the implementation of those recommendations as a matter of priority.
28. This is contrary to the intent of ICAO Annex 13 which states that "the objective of an investigation of an accident or incident is prevention of future events" and the ICAO Safety Management Manual which states that "information should be collected solely for the purpose of aviation safety and information protection is essential in ensuring the continued availability of that information". It follows that ATSB reports on accident or incident investigations or any information from the mandatory reporting process should never be made available for regulatory enforcement purposes or civil actions.


29. For a safety reporting regime to operate effectively people must be confident that disclosure will not result in punitive action unless the action was deliberate or reckless.
Finally on RRP, I could quote the whole lot....but to summarise:
41. In contrast to Australia’s CASRs 1998, the New Zealand Civil Aviation Rules are clear and comprehensible. While in no way endorsing the content of the New Zealand legislation, we would support clear plain English regulations aimed at and comprehensible to the industry, not just lawyers.


42. We therefore request that the regulatory development process be reviewed in the interests of achieving the goals of clear, concise and unambiguous regulations delivered in a timely manner.
{Comment: Especially liked the 'Aeroplane' definition example from para 35-39..}

I could go on cherry picking but this submission has already got the IOS tick of approval...again bravo AFAP!

Note: AFAP sub quote at the end...

"...As previously stated, the Federation would welcome the opportunity to supplement the above written submission via verbal submissions to the Review Panel..."

Although the time frame is still limited, it would appear that the panel would be willing to accept further supplementary submissions in support of original submissions, see here...

Submissions are now closed
The formal submission period has now closed. However the Panel will endeavour to consider late submissions.
To make a late submission please use the
Aviation Safety Regulation Review Submission Form.

Addendum: Noted this short summary article from Australian Flying on the RA-Aus submission, where it seems the primary membership concern is the imposition of the ASIC: RA-Aus Weighs into ASIC Debate
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Old 10th Feb 2014, 22:24
  #382 (permalink)  
 
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safety, security...whatever

Had a visit to this regional field, no RPT, by some young AFP chappies recently who left a card which states ..."you are the eyes and ears of the airport, and if you see something suspicious call 131 AFP
And on the front See it, hear it Report it.

Quite fascinating that this was the very attitude taken in the USA after 9/11 and they DID NOT institute cards because they said the very words of the above...you are the eyes and ears etc..and those people at the field are part of the solution...seeing what goes on.

Its only taken 13 years then ?

So...is your "security " card ASIC soon to be changed to an ASAW, Airport Security Amateur Watchdog with a cheque for $200 to encourage you to keep a look out.
Dont think so somehow.
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Old 11th Feb 2014, 02:35
  #383 (permalink)  
 
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Another FF stuff-up

From todays e-mail stream from FF.

FF loses it again - How on earth can there be a "by close of business" reply to a draft AC???:

CASA wishes to advise that Draft AC 21-42 v2.0 – Light sport aircraft manufacturers’ requirements has been published on the CASA website for comment and review.
Comments are to be forwarded to the Project Leader, Ben Challender by close of business
and the link does not work [just the same as the FF regulators!!]
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Old 11th Feb 2014, 09:36
  #384 (permalink)  
 
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ICAO and Singapore can do it.

Latest ICAO release;
ICAO and Singapore Forge New Agreement on Leadership and Management Training

Cherry picked out of the press release (my bold);
SINGAPORE, 10 February 2014 – The International Civil Aviation Organization (ICAO) and the Government of the Republic of Singapore signed a new Memorandum of Understanding (MOU)
“Singapore is a strong advocate of developing aviation leadership and human capital, which are key to addressing the challenges facing global aviation.

Director General of the Civil Aviation Authority of Singapore. “Singapore’s partnership with ICAO in leadership and management training affirms our commitment to contribute in a meaningful way to advancing international civil aviation.”

ICAO-Singapore collaboration under the new MOU will be focused around the development and delivery of leadership and management training and professional programmes, joint conferences, seminars and courses, the sharing of speakers, moderators and instructors and the exchange of information in areas of mutual interest in the field of civil aviation.
Wouldn't it be nice if the Stasi CASA could even remotely consider such a non punitive approach? Instead we have a legacy of incompetence and disgraceful abuse of unlimited power.
Dear Mr Truss and your Wet Lettuce Review team, please go talk Messrs Quadrio, Butson, Fernandes, James and Davy to name a handful. Then look at how most involved in causing these operators so much pain then got promoted to where they are today.
Sorry, at this point in time the review is a complete crock of ****.

Last edited by Paragraph377; 11th Feb 2014 at 09:52.
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Old 11th Feb 2014, 16:45
  #385 (permalink)  
 
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...and Qantas thinks it has something to teach Asia?
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Old 11th Feb 2014, 22:12
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Talking AAAA receives IOS golden Freddo award!

The headline on Australian Flying's article that summarises the AAAA’s WLR submission,is spot on…
Aerial Ag Gives CASA a Spray

The Ag crew do not hold back, the submission is akin to dumping water on Fort Fumble with a DC-10 fire bomber..
AAAA WLR Submission

Standby for some overspray quotes…
“Dear Miniscule, …noxious weeds are out of control”
CASA is now performing so poorly as to demand significant change of its internal management and its relationship with industry so as to implement practical systems that will lead to commonly accepted benchmarks of practice and outcomes. CASA is dysfunctional at nearly every level, its relationship with industry has been junked, and it is suffering from such a pathological culture that major surgery will be required to realign the organisation with the common hallmarks of a sound safety regulator. CASA must walk the talk.
There has been a complete breakdown in the relationship with industry at the highest levels, an example which has now cascaded throughout almost the entire organisation.

There are many good people working in CASA who are simply unable to make headway against the prevailing culture. They are increasingly isolated and powerless.

There are also some who delight in the culture of ‘gotcha’ that exists and is encouraged at various levels, where the ‘zero-sum game’ against industry is strongest. The lack of systems and confidence to allow the free flow of information both up and down the chain of command within CASA sustains the negative aspects of the CASA culture, and reinforces and encourages behaviour that in a healthy, open and just culture, with a clear focus on cooperation with industry and positive safety outcomes, would simply not be tolerated.

As with all cultures, the problem starts and is sustained at the top.
CASA demonstrates no strategic engagement, with industry withdrawing from meetings and discussions that involve senior management due to fatigue from being lectured to.

There appears to be a complete disconnect between words spoken by senior CASA management and what happens on the ground – with no consistency of policy or interpretation being a long-standing concern. CASA encourages industry to adopt sound management principles and systems such as SMS, ‘just’ cultures and strong executive control of aviation companies, but is hypocritical in not applying these same principles and practices to its own operations.

CASA does not have ‘aviation issues’ – it has management and cultural issues. A resetting of the CASA/industry relationship is critical to establishing a more mature regulatory safety culture in Australia.
“He’s not the Messiah..”
Many people in aviation believe that the critical component in sound aviation regulation is to have the ‘right’ person in key jobs, such as the CEO of CASA.

Unfortunately, this ‘messiah’ approach is fundamentally flawed if not supported by longer-term strategic approaches, systems and checks and balances, as demonstrated by the history of CASA and its predecessors.
When industry first heard of the shift of CASA to being a ‘Big R’ regulator, industry accepted that clearly that was the right of the regulator and, industry assumed, was being done with the support of the CASA Board and the Minister. What industry did not anticipate was that the move to a ‘Big R’ regulator was code for the introduction of a bullying and intimidatory culture that would lead to a breakdown in relationships between CASA and industry, a significant reduction in the focus on innovative safety programs and increasingly shrill policing activities that are not delivering real safety improvements.

As previously stated, no aviation association has the track record of AAAA of working positively with CASA for the improvement of aviation safety and regulation. But it is not possible to continue to return to the table when it is clear that there is no trust and no respect being shown for industry’s genuine concerns and its innovative suggestions for improvement.
On RRP spray ‘drift’ problems..
The regulatory reform program is certainly not ‘reform’ any longer.

There is no overall goal in play – ‘safety through clarity’ has been abandoned and there is no real reason for regulatory reform other than for its own sake. Key outcomes, goals, timelines (ie strategic planning) must be established.

Key goals for regulatory reform should include increased safety, reduced cost, simplification and harmonisation.

Key regulatory triggers or thresholds must be established – ie if CASA staff have a good idea, that does not mean, ipso facto, it becomes law. It should have to meet the key goals identified as a trigger for reform. Similarly, if it adds considerable cost for little or no safety benefit, it should not become law.

Regulation should be seen as the final option when other approaches have been exhausted – such as education and safety promotion including joint ventures with industry associations – rather than the default setting and starting point for guiding all aviation activity.

This is a fundamental shift in CASA’s worldview. It is the view of best practice regulators the world over. Of course there need to be rules, but there do not need to be rules for every possible eventuality.
I could go on and on (it's that impressive..) but I guess the real message here is… …“Dear Miniscule, noxious weeds eradication program urgently needed!!”
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Old 11th Feb 2014, 22:37
  #387 (permalink)  
 
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ASRR - Submission by Aerial Agriculture

This really hits the nail on the head:

While a more detailed report card on each agency is provided later in this submission, suffice it to say that the stand-out exception is CASA which can most optimistically be described as underperforming, and at its worst is clearly pathological and in need of significant surgery and cultural rejuvenation.
Let's just do it

US-FAR's now, then the industry can become inclusive for the first time.
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Old 11th Feb 2014, 22:51
  #388 (permalink)  
 
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you've got to lance the boil before you can squeeze the puss out.

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Old 11th Feb 2014, 23:22
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Just Frankly!!

Using a tree killing chemical would be best!!

but just hope we don't get "Brush-off" by the WLR and Minister
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Old 11th Feb 2014, 23:25
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Another FF stuff-up

Nice to see casa reads pprune:

CASA wishes to apologise for the previous subscribers notification regarding Draft AC 21-42 v2.0 – Light sport aircraft manufacturers’ requirements. The closing date for comments had accidently been missed.

Comments are to be forwarded to the Project Leader, Ben Challender by close of business 25 February 2014.
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Old 11th Feb 2014, 23:48
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Hats off to the AAAA. Australia would be better off outsourcing aviation safety regulation to them!

Just one more gem in its submission that I can't resist highlighting:
AAAA expressed strong concerns to ATSB management with previous attempts during investigations to attempt to mould evidence to fit a theory, rather than objectively analysing and presenting the evidence available.
Seems to be a pattern of ATSB behaviour!
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Old 12th Feb 2014, 01:07
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so is there any sign of avmed getting its act together?
It appears not...

Also in the AAAA submission:

One area in particular that struggles with continuous improvement is CASA’s aviation medicine branch. Examples are plentiful of questionable rulings on pilot medicals that fly in the face of genuine expert opinion (for example in cardiology) and result in the trashing of careers for no safety purpose.


The ability of the branch to hide behind the façade of medical qualifications is well known in industry and under current systems, is an almost unassailable position that has drifted far from actual safety issues, or the leading non-CASA advice on medical issues.
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Old 12th Feb 2014, 03:53
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Time to revolt??

Excellent submission by AAAA, perfectly worded, straight to the point, factual and truthful. This is just one example of what group consensus about CASA is. Surely it is not possible for such an overwhelming percentage of the IOS to be categorically wrong? The fact is that the Australian aviation industry has voted, the results are in, and it is a big ‘VOTE OF NO CONFIDENCE’ in CASA and its legacy of Minister puppets. The facts speak for themelves. The industry has had a gutful. And similar feelings are expressed towards the once respectable ATSB. I cannot speak for others but this spiralling mess is getting worse by the week, the Department has lost control (never had any really) of its wayward hybrid abomination.
I think that group submissions, much like what has been submitted to this weak handed Wet Lettuce Review group and previous senate inquiries needs to be submitted directly to:
· ICAO
· United Nations
· Top end Legal firm

The regulatory reform program needs to be halted immediately. It is now officially The Regulatory Deform Program. It has failed. The money is gone, class it in the same category as the pink batts scheme or the BER – It failed, the money is gone, no results are to be gained, end of it. It is time to kick back off where Byron was headed before the Iron Ring castrated him and many likeminded before him. The lunatics in charge of the asylum have also lost all control. They contradict each other, bully industry and in some instances do it with malice, contempt for law and ethics, with impunity and in a way that would indicate some have severe psychological and sociopathic issues.

The countless millions spent on junkets, rorts, legal pursuits of the innocent, the reg reform mess, abuse of power, unjustified salaries, ‘field excursions’, hypothetical discussions and almost everything else they do has to be stopped. As the AAAA has stated, what is good for the goose is good for the gander! Where is CASA’s SMS? Where is CASA’s change management process? Why doesn’t CASA adequately review its own risks? Where is CASA’s accountability? Why do CASA keep stuffing up, redacting, changing and repairing mistakes? Where is CASA’s just culture? Where is CASA’s ‘robust’ SSP, why is it flawed, a mess, created and implemented by an admin Johnny (should be Juliette as it is a ‘she’) who has taken off to VA? Absolute hypocrites. Enough is enough!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
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Old 12th Feb 2014, 04:09
  #394 (permalink)  
 
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That's easy for you to say. Thank God you don't stutter.


I've been advocating public disobedience for years. After all, they started it.

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Old 12th Feb 2014, 04:56
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More solid gold from the AAAA submission:
The most recent incarnation of the pathology of CASA’s relationship with industry was when CASA attempted to blame industry for the deferment of the start date for CASR Part 61 – Pilot Licencing.

In fact, it was clearly CASA that had failed to produce the essential Manual of Standards in time, CASA that had failed to map out a coherent transitional plan for existing pilots, CASA who had no advisory material in place to support implementation, CASA that was unable to provide adequate training to its own staff on the operation of Part 61 so that industry could in turn be educated, and CASA who did not have the approval system in place for the supporting CASR Part 141/142 training organisations.

Unjustifiably trying to scapegoat the ‘regulated’ for the failures of the ‘regulator’ is a novel approach to building good relationships, especially after industry has contributed – at its own cost – thousands of hours of support, experience and advice through the various Standard Consultative Committee and working groups. AAAA alone has been involved in more than eight CASA working groups and committees since 1999 and many of the issues identified back then remain current today because CASA appears to be incapable of positive, progressive outcomes.
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Old 12th Feb 2014, 05:31
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Phil gets my vote for WLR GA adviser!

Maybe if Aerial Ag Phil was to replace the other, Department picked, Phil () as the GA expert adviser to the WLR we may end up with a well-tended lettuce & pineapple crop for ’14 , we could certainly expect Pete the pot plant to get some respect…
Again I question the legitimacy of the other Phil’s mob…especially after reading this disturbing bit of the AAAA submission..:
AAAA was aghast when the CEO of CASA unilaterally cut sponsorship support of a number of Associations and then linked that action to criticism of CASA by those Associations. AAAA has no problem with CASA spending its sponsorship dollar where it thinks it will get the best return – after all, most of the ‘dollars’ come from industry.

While the size of support AAAA received was immaterial ($9,000 per annum to support the National Convention – for which CASA received considerable commercial sponsorship benefits) the principle of trying to intimidate Associations by manipulating funding was simply disgusting.

To draw a direct line between CASA patronage and intimidation of free speech not only flows against public service guidelines or good practice, it is an unethical approach to managing the relationship between CASA and representative industry bodies that have previously worked genuinely with CASA over many years to deliver regulatory change and safety promotion.

The main reason many Associations have purposefully withdrawn from any contact with the senior management of CASA is because it is a completely unfruitful and hostile environment. AAAA certainly feels that the resources of members are more usefully applied in areas other than trying to maintain a clearly failed relationship with the current senior management of CASA
That passage beggars belief , sort of like what you would expect to hear coming out of a dictatorial or socialist bureaucratic regime….FFS!

VOTE 1 for Aerial Ag Phil (not the other Phil..)

Creamy I'll raise your two clapping hands with a thumbs up for the AAAA submission..
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Old 12th Feb 2014, 08:29
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I have to say that even cynical ol’ me is starting to believe the government is going to have little choice but to take real action in response to all this.

There appear to be too many people with too much credibility using too much blunt language. A wet lettuce response is unlikely to be tolerated by lots of people who have to date been prepared to tolerate lots.

My main point of disagreement with the gist of AAAA’s proposal is that I don’t believe the (reinstated) Board makes much of a difference, whether or not it’s stacked with people with ‘industry experience’.

The fundamental constraint that ‘outsiders’ overlook is that the CASA Board can’t make or unmake decisions to e.g. refuse, suspend or revoke an AOC. The CASA Board can’t direct a delegate to make or not make a regulatory decision.

A CASA Board could have prevented some of the output of the regulatory reform Frankenstein that successive governments have allowed CASA to create. But a properly qualified and experienced CEO and executive team could have prevented the same outcome without the benefit of a Board’s guidance.

Whatever the reasons, the regulatory reform Frankenstein exists, and the review panel, at least, can’t ignore the mayhem left in the monster’s wake.

Interesting times.
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Old 12th Feb 2014, 10:03
  #398 (permalink)  
 
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The ticking and tocking is getting louder!!

So we have numerous submissions and some very interesting ones at that. The AAAA and Ag Phil are officially welcomed into the IOS brotherhood, good to have you onboard boys
These industry submissions are serious stuff folks. We are talking about groups of professional aviators, experienced, smart and highly skilled individuals. Their wording and the message they are articulating should make the government sit up and take notice. The industry has had enough, and justifiably so.
The Skulls verbal contempt for AMROBA, and now we have questions as to CAsA funding not being provided to organisations because the organisation hasn't spoken favourably about CAsA?? It is time for Mrdak and The Board to bow out disgracefully and take the DAS trio with them. Truss you are being made to look like a complete idiot, well one questions whether you are anyway.

Please Mr ICAO and Mr FAA come back and play. Time for a review of Australia's declining aviation oversight. Time for a robust audit. Time to cut the head off the fish.

TICK TOCK TICK TOCK
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Old 12th Feb 2014, 14:38
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Folks,

Over the last 15+ years, nobody has worked harder to be reasonable with CASA in dealing with CASA, to the degree that AAAA Phil and several I could name have crossed swords, believing him to have taken too soft an approach ---- AAAA were buggered around for 10 years over Part 137 --- the level of "regulation" of aerial application here, compared to, say, NZ or US, borders on the ridiculous, just look up the page counts for the Part 137 for each of the named countries.

That the AAAA submission is as it is, just shows just how the most reasonable and reasoning person will finally just give up, as the reasonableness is only interpreted by the "CASA Culture" as weakness.

Well done AAAA, a pity the AOPA submission didn't have a bit of backbone, but that would have have imperiled CASA funding of some AOPA activities.

Long gone are the days when a central AOPA policy was "pay your own way, have your own say".

by close of business 25 February 2014.
Hardly serious consultation, is it, it's token consultation. Barely two weeks to comment on something that is core to one of the few areas of light aviation not bordering on comatose.

Tootle pip!!
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Old 12th Feb 2014, 19:11
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According to Stephen Fry Vogans are the most bureaucratic people in the universe.

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