CASA regulatory review updates
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CASA regulatory review updates
AHIA NEWS FLASH – CASA delays roll-out of CASR regulations due to industry’s concerns.
Full report to AHIA members by President on Monday 28 Sep ’15 about the impact of a delayed Part 61 on the training industry. Will this further stall investment and student numbers?
On Fri 25 Sep ’15, Steve Creedy, award winning aviation writer, stated in the Aviation Section of The Australian national newspaper:
Civil Aviation Safety Authority boss Mark Skidmore has flagged that rule changes the federal government wanted finalised this year are likely to be delayed because of industry feedback.
Mr. Skidmore also signaled his determination that staff at the regulator adopt the more consultative approach being advocated by upper management.
Industry groups have welcomed comments by Mr Skidmore that CASA will take on board industry concerns but some have expressed concern the message is not filtering down to some parts of the organisation.
In an email to staff, Mr Skidmore said he was aware some staff may be unclear about the regulator’s current priorities on developing and implementing remaining parts of the Civil Aviation Safety Regulations.
These included suites of rules covering general aviation maintenance, passenger transport operations, aerial work and sport and recreation operations.
Mr Skidmore noted the government’s response to the Aviation Safety Review had called for the drafting of all new regulations to be completed this year but it had also said they should be subject to changes in “regulatory approach and appropriate consultation’’.
It also said CASA needed to ensure an effective communication and education process was put into place before these provisions started.
“As I have made clear previously, in so far as they relate to CASA, I am committed to ensuring we implement the government’s response to the Aviation Safety Regulation Review in an effective and timely manner,’’ he said in the email.
“Many of those recommendations have already been successfully implemented and a range of others are under way. Delivering on the government’s expectations is vital. Consistent with that obligation, however, it is equally important to get the implementation of changes right. If it takes a little more time to implement successful and effective change, then I support such an approach. “This principle applies to the finalisation of both the development and implementation of the new regulations.’’
Mr Skidmore said extensive consultation with the aviation industry had produced comments indicating operators found the volume of changes overwhelming and were struggling to find time to comment on them.
“While it is early days, and no decisions on how the regulatory change program will move forward will be made until the consultation is finished and the results analysed, it is clear CASA’s current approach is causing the aviation community significant difficulty,’’ he said.
“We need to finish this listening and discussion exercise before determining the next steps. If this creates some delay in the regulatory development and implementation process, I believe that would be time well spent to get the right outcomes for Australian aviation.’’
Mr Skidmore revealed earlier this month that he is allocating more resources to addressing issues raised by industry about flight crew licensing rules in Parts 61, 141 and 142.
He noted in his email that it was difficult to bring the aviation community with CASA on regulatory changes while it was still working on issues from previous changes.
“Regulatory development will be completed as quickly as is possible and implementation will be undertaken in an orderly and managed way, with a view to maximising safety benefits while minimising unnecessary burden on the aviation community,’’ he said.
AHIA
Full report to AHIA members by President on Monday 28 Sep ’15 about the impact of a delayed Part 61 on the training industry. Will this further stall investment and student numbers?
On Fri 25 Sep ’15, Steve Creedy, award winning aviation writer, stated in the Aviation Section of The Australian national newspaper:
Civil Aviation Safety Authority boss Mark Skidmore has flagged that rule changes the federal government wanted finalised this year are likely to be delayed because of industry feedback.
Mr. Skidmore also signaled his determination that staff at the regulator adopt the more consultative approach being advocated by upper management.
Industry groups have welcomed comments by Mr Skidmore that CASA will take on board industry concerns but some have expressed concern the message is not filtering down to some parts of the organisation.
In an email to staff, Mr Skidmore said he was aware some staff may be unclear about the regulator’s current priorities on developing and implementing remaining parts of the Civil Aviation Safety Regulations.
These included suites of rules covering general aviation maintenance, passenger transport operations, aerial work and sport and recreation operations.
Mr Skidmore noted the government’s response to the Aviation Safety Review had called for the drafting of all new regulations to be completed this year but it had also said they should be subject to changes in “regulatory approach and appropriate consultation’’.
It also said CASA needed to ensure an effective communication and education process was put into place before these provisions started.
“As I have made clear previously, in so far as they relate to CASA, I am committed to ensuring we implement the government’s response to the Aviation Safety Regulation Review in an effective and timely manner,’’ he said in the email.
“Many of those recommendations have already been successfully implemented and a range of others are under way. Delivering on the government’s expectations is vital. Consistent with that obligation, however, it is equally important to get the implementation of changes right. If it takes a little more time to implement successful and effective change, then I support such an approach. “This principle applies to the finalisation of both the development and implementation of the new regulations.’’
Mr Skidmore said extensive consultation with the aviation industry had produced comments indicating operators found the volume of changes overwhelming and were struggling to find time to comment on them.
“While it is early days, and no decisions on how the regulatory change program will move forward will be made until the consultation is finished and the results analysed, it is clear CASA’s current approach is causing the aviation community significant difficulty,’’ he said.
“We need to finish this listening and discussion exercise before determining the next steps. If this creates some delay in the regulatory development and implementation process, I believe that would be time well spent to get the right outcomes for Australian aviation.’’
Mr Skidmore revealed earlier this month that he is allocating more resources to addressing issues raised by industry about flight crew licensing rules in Parts 61, 141 and 142.
He noted in his email that it was difficult to bring the aviation community with CASA on regulatory changes while it was still working on issues from previous changes.
“Regulatory development will be completed as quickly as is possible and implementation will be undertaken in an orderly and managed way, with a view to maximising safety benefits while minimising unnecessary burden on the aviation community,’’ he said.
AHIA
It's interesting to compare what was proposed in the Flight Crew Licencing Regulatory Impact Statement (RIS) and what we have now. The entire dedacle was all in the interests of ICAO harmonisation to allow Australia to "export" pilot training!
Here's a link to the RIS:
https://www.comlaw.gov.au/Details/F2...9-358947eec395
Here's a quote from the RIS concerning the effect on ATPLs:
"The multi-crew flight test will have a duration of approximately 2 hours and can be performed in a suitable aircraft or flight simulator. Based on 580 pilots undertaking the test per year the annual industry cost will be $0.9m"
I have asked CASA directly how many ATPLs have been issued in the first year of Part 61, but they won't respond. I understand following discussions with one of the few ATPL approved Flight Examiners that there have been 3 ATPLs issued. Also interesting to note the flight test was intended for the multi-crew qualification and not the stand alone 5 hour ATPL flight test extravaganza the industry has been saddled with.
It's also interesting to review ICAO Annex 1 to see what true harmonisation would have allowed the industry to do. eg: Unless you are delivering an integrated PPL/CPL course or multi-crew training a person holding a flight instructor rating can operate independently and does not require a Part 141 certificate. (Like the FAA)
Here's a link to the RIS:
https://www.comlaw.gov.au/Details/F2...9-358947eec395
Here's a quote from the RIS concerning the effect on ATPLs:
"The multi-crew flight test will have a duration of approximately 2 hours and can be performed in a suitable aircraft or flight simulator. Based on 580 pilots undertaking the test per year the annual industry cost will be $0.9m"
I have asked CASA directly how many ATPLs have been issued in the first year of Part 61, but they won't respond. I understand following discussions with one of the few ATPL approved Flight Examiners that there have been 3 ATPLs issued. Also interesting to note the flight test was intended for the multi-crew qualification and not the stand alone 5 hour ATPL flight test extravaganza the industry has been saddled with.
It's also interesting to review ICAO Annex 1 to see what true harmonisation would have allowed the industry to do. eg: Unless you are delivering an integrated PPL/CPL course or multi-crew training a person holding a flight instructor rating can operate independently and does not require a Part 141 certificate. (Like the FAA)
Here's interesting scenario:
A private pilot who has been flying a Cessna 172 for a couple of years and their flight review is about to expire. A grade 1 instructor cannot complete this pilots flight review if there is any "training" involved unless he does so operating under a Part 141 Certificate. CASA recommend all flight reviews include a training component.
Now his mate who learnt to fly at the same time and has been flying the Cessna 172 buys a Harvard. A PPL holding a flight instructor rating with design feature and flight activity training endorsements can train / issue constant speed prop, tailwheel, retractable undercarriage and aerobatic endorsements in the Harvard. The design feature endorsements would satisfy the requirements of a flight review and no 141 certificate or CPL required.
Seems like the people developing the new rules can't let go of the old rules, yet create these sorts of glaring anomalies. BTW, the RIS used the flexibility provided by Part 61 allowing instructors to do flight reviews independently as a selling point.
A private pilot who has been flying a Cessna 172 for a couple of years and their flight review is about to expire. A grade 1 instructor cannot complete this pilots flight review if there is any "training" involved unless he does so operating under a Part 141 Certificate. CASA recommend all flight reviews include a training component.
Now his mate who learnt to fly at the same time and has been flying the Cessna 172 buys a Harvard. A PPL holding a flight instructor rating with design feature and flight activity training endorsements can train / issue constant speed prop, tailwheel, retractable undercarriage and aerobatic endorsements in the Harvard. The design feature endorsements would satisfy the requirements of a flight review and no 141 certificate or CPL required.
Seems like the people developing the new rules can't let go of the old rules, yet create these sorts of glaring anomalies. BTW, the RIS used the flexibility provided by Part 61 allowing instructors to do flight reviews independently as a selling point.
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Is any one seriously arguing that you shouldn't have to do a flight test for the ATPL?
"Also interesting to note the flight test was intended for the multi-crew qualification and not the stand alone 5 hour ATPL flight test extravaganza the industry has been saddled with"
5 hours! Really? Please explain? The ATOs I've talked to on this haven't had to go much past half that. Is that too much? 2 hours better? 1 1/2? 1? 15 minutes?
Then again in my 45 years Ive never had an "Extravaganza" test so what would I know.
"Also interesting to note the flight test was intended for the multi-crew qualification and not the stand alone 5 hour ATPL flight test extravaganza the industry has been saddled with"
5 hours! Really? Please explain? The ATOs I've talked to on this haven't had to go much past half that. Is that too much? 2 hours better? 1 1/2? 1? 15 minutes?
Then again in my 45 years Ive never had an "Extravaganza" test so what would I know.
5 Hours is our average cyclic including briefing. I believe the EASA ATPL flight test is fairly extensive too, ie. in the vicinity of 3-4 hours, so I can believe 5. 1-2 hours is barely a couple of sequences.
Captain Sherm, out of interest, have you noted in your Professional Life or seen any incidents outside of it that have been or could have been attributed to a person with an ATPL that didn't require a Flight Test?
Ie, does the Flight Test actually improve an area of Safety that has identified as being below standard and thusly deserving of more regulation? Or is it a matter of wrapping bubble wrap upon bubble wrap?
Ie, does the Flight Test actually improve an area of Safety that has identified as being below standard and thusly deserving of more regulation? Or is it a matter of wrapping bubble wrap upon bubble wrap?
IXIXLY on the money
Nineninely...! you are asking a pertinent question, one that goes to the heart of much that is so wrong with our aviation systems. I achieved a charter Licence with a twelve page ops manual and my fresh commercial ticket, no charge, no fees. Never heard about 'chief pilot'. After Grade 3 made Grade 2 (or was that Class 2? keep changing stuff for no reason) instructor and made CFI without application or test. Grade 1 no test sometime later and became an approved Licence Testing Officer (might not have been capital letters) with no application or tests. I suppose it was enough that I was working at it and had accumulated experience. Was given an AOC, some paper turned up, probably too busy to read that. I remember clearly some CASA type came to see the movements at my airport '89 moto GP at Phillip Island, he talked about who had an AOC to justify the passenger multiple flights that were happening. Only much later did I have a clue what he was talking about. Just like we've put up with useless aviation medicals, the whole shooting match of non sense. Why? A mixture of apathy, too busy to worry and an ego thing that says we do this because we are so special, and accept government knows best so pull your forelock or doff your lid. Please save us from stupidity, General Aviation in Australia is down the drain. When will we see that freedom is the only way for progress?
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Wren and Ixixly,
all so true, how can an industry as fragile as GA survive this.
It cant is the answer.
$250,000 and two years to grant an AOC.
$100,000 to put a new type on an AOC
"In the interest of safety"??
Sustainable??
Where is the "Safety" case???
There is none its all rubbish.
all so true, how can an industry as fragile as GA survive this.
It cant is the answer.
$250,000 and two years to grant an AOC.
$100,000 to put a new type on an AOC
"In the interest of safety"??
Sustainable??
Where is the "Safety" case???
There is none its all rubbish.
Get out of aviation while you can without losing everything. Don't mortgage your house to buy ADSB- you will lose everything as more and more expensive unique regulations are introduced .
Thread Starter
Industry raises concerns with CASA about delayed regulatory reform processes
Industry raises concerns with CASA about delayed regulatory reform processes
A collection of recent media articles for AHIA members and industry key players commences in following posts.
29 Oct ’15. AM hours. Greg Russell, Chair of The Australian Aviation Associations Forum (TAAAF) issued a Media Release during their 28 to 29 October 2015 meeting in Canberra. For media enquiries contact Greg on 0427 707 733 or email: [email protected].
The TAAAF is a collective of aviation bodies working together to present industry views to Canberra under the guidance of chair Greg Russell.
(AHIA is a member).
AVIATION ASSOCIATIONS FORUM MEETING - TAAAF Communiqué
The Australian Aviation Associations Forum has expressed considerable concern at the slow pace of reform of CASA and the ongoing cost impositions from new regulations.
Recently introduced CASA regulations are threatening the viability of industry and especially general aviation operations, with millions of dollars required to be invested for no commensurate safety gains.
The TAAAF fully supports the Director of Aviation Safety’s Directive 01/2015 on the development and application of risk based and cost effective aviation safety regulation and asked that it be applied to recently introduced CASA regulations.
TAAAF felt effective implementation of the directive will require cultural change within CASA and encouraged the CASA Board to persevere with their clear, Government- mandated cultural change agenda.
The TAAAF recommends the CASA redouble efforts to urgently:
• Withdraw CAO 48.1 (flight and duty times) – this regulation is against the objectives of the DAS Directive 01/2015 in that hard evidence has not been provided to justify it, it ignores decades of safe operations under previous rules, and imposes massive unnecessary costs and complexity.
• Establish an industry task force to propose urgent exemptions and amendments to Parts 61, 141, 142 on pilot licencing and training and institute revised transitional arrangements to allow the industry to operate. In particular, urgent action is needed in respect to firefighting training and the issuing of new ATPL licences for GA pilots as both these essential functions have virtually ceased under the new regulations.
• Reform Australian aviation manufacturing regulations to harmonise with the modernised US FAR system
• Undo the damage caused by new maintenance training regulations that resulted in the loss of three TAFE skill providers.
While there is some good work being undertaken by CASA, it is being hindered by the massive problems caused by legacy regulations only now coming into force.
TAAAF believes that now is the time for definitive action before the new regulations cause irreparable long-term damage and the loss of jobs and businesses.
More soon
AHIA
A collection of recent media articles for AHIA members and industry key players commences in following posts.
29 Oct ’15. AM hours. Greg Russell, Chair of The Australian Aviation Associations Forum (TAAAF) issued a Media Release during their 28 to 29 October 2015 meeting in Canberra. For media enquiries contact Greg on 0427 707 733 or email: [email protected].
The TAAAF is a collective of aviation bodies working together to present industry views to Canberra under the guidance of chair Greg Russell.
(AHIA is a member).
AVIATION ASSOCIATIONS FORUM MEETING - TAAAF Communiqué
The Australian Aviation Associations Forum has expressed considerable concern at the slow pace of reform of CASA and the ongoing cost impositions from new regulations.
Recently introduced CASA regulations are threatening the viability of industry and especially general aviation operations, with millions of dollars required to be invested for no commensurate safety gains.
The TAAAF fully supports the Director of Aviation Safety’s Directive 01/2015 on the development and application of risk based and cost effective aviation safety regulation and asked that it be applied to recently introduced CASA regulations.
TAAAF felt effective implementation of the directive will require cultural change within CASA and encouraged the CASA Board to persevere with their clear, Government- mandated cultural change agenda.
The TAAAF recommends the CASA redouble efforts to urgently:
• Withdraw CAO 48.1 (flight and duty times) – this regulation is against the objectives of the DAS Directive 01/2015 in that hard evidence has not been provided to justify it, it ignores decades of safe operations under previous rules, and imposes massive unnecessary costs and complexity.
• Establish an industry task force to propose urgent exemptions and amendments to Parts 61, 141, 142 on pilot licencing and training and institute revised transitional arrangements to allow the industry to operate. In particular, urgent action is needed in respect to firefighting training and the issuing of new ATPL licences for GA pilots as both these essential functions have virtually ceased under the new regulations.
• Reform Australian aviation manufacturing regulations to harmonise with the modernised US FAR system
• Undo the damage caused by new maintenance training regulations that resulted in the loss of three TAFE skill providers.
While there is some good work being undertaken by CASA, it is being hindered by the massive problems caused by legacy regulations only now coming into force.
TAAAF believes that now is the time for definitive action before the new regulations cause irreparable long-term damage and the loss of jobs and businesses.
More soon
AHIA
Thread Starter
Updates continue ......
29 Oct ’15. PM hours. Steve Hitchen, Editor, Australian Flying Magazine, commented online about the TAAAF Medial Release. In addition, he mentioned CASA’s immediate response. For media enquiries contact Steve on 0447 636 450 or email: [email protected],
TAAAF Communique urges Reform Speed from CASA
The Australian Aviation Associations Forum (TAAAF) has expressed concern at what they say is the slow pace of reform at CASA and costs imposed by new regulations.
TAAAF members highlighted their issues in a communique to industry released today. "Recently introduced CASA regulations are threatening the viability of industry and especially general aviation operations, with millions of dollars required to be invested for no commensurate safety gains," the communique stated.
Although supporting CASA Director Mark Skidmore's directive on developing risk-based regulation, TAAAF members said they believed the directive would become effective only after cultural change happened at CASA, and called for immediate actions on legacy regulation now coming into force.
Specifically, TAAAF called for:
• CAO 48.1 on flight and duty times to be withdrawn due to lack of hard supporting evidence
• An industry task force to propose urgent amendments and exemptions from CASRs 61, 141 and 142
• Manufacturing regulations to be brought in line with the US FAR system
• New maintenance training regulations to be reviewed in order to repair the damage to industry caused by the loss of three TAFE training colleges.
"While there is some good work being undertaken by CASA, it is being hindered by the massive problems caused by legacy regulations only now coming into force.
"TAAAF believes that now is the time for definitive action before the new regulations cause irreparable long-term damage and the loss of jobs and businesses."
CASA Responds - CASA later issued the following response to the TAAAF communique.
"As TAAAF members would be aware CASA is currently actively consulting the aviation community on a range of issues including proposed new aerial work regulations, proposed new operating rules, the best ways to implement future regulations and the development of Flight Plan 2030. Extensive consultation with the aviation community on a range of key issues will continue. CASA welcomes feedback from all sectors of the aviation community and will look carefully at all constructive suggestions.
"Earlier this year the Director of Aviation Safety wrote to all pilots asking for feedback on the new licensing suite of regulations, with more than 100 people responding. CASA has been working methodically through the issues raised and has been addressing unintended consequences. Changes have been made to address specific issues such as firefighting operations.
"Because the ATPL flight test is a new requirement, CASA Flight Training Examiners are available to facilitate the conduct of these tests while industry delegates transition to gaining the required privileges and the tests are built in to industry training and checking programs.
"Also, a special CASA forum is being held in November for aviation organisations developing or planning to develop a fatigue risk management system. The aim of the forum is to ensure there is a mutual understanding between CASA and aviation organisations of the requirements and expected outcomes of a fatigue risk management system.
"CASA is committed to listening to the legitimate concerns of the aviation community and we will look carefully at the suggestions being made by the TAAAF."
More to follow ....... AHIA
TAAAF Communique urges Reform Speed from CASA
The Australian Aviation Associations Forum (TAAAF) has expressed concern at what they say is the slow pace of reform at CASA and costs imposed by new regulations.
TAAAF members highlighted their issues in a communique to industry released today. "Recently introduced CASA regulations are threatening the viability of industry and especially general aviation operations, with millions of dollars required to be invested for no commensurate safety gains," the communique stated.
Although supporting CASA Director Mark Skidmore's directive on developing risk-based regulation, TAAAF members said they believed the directive would become effective only after cultural change happened at CASA, and called for immediate actions on legacy regulation now coming into force.
Specifically, TAAAF called for:
• CAO 48.1 on flight and duty times to be withdrawn due to lack of hard supporting evidence
• An industry task force to propose urgent amendments and exemptions from CASRs 61, 141 and 142
• Manufacturing regulations to be brought in line with the US FAR system
• New maintenance training regulations to be reviewed in order to repair the damage to industry caused by the loss of three TAFE training colleges.
"While there is some good work being undertaken by CASA, it is being hindered by the massive problems caused by legacy regulations only now coming into force.
"TAAAF believes that now is the time for definitive action before the new regulations cause irreparable long-term damage and the loss of jobs and businesses."
CASA Responds - CASA later issued the following response to the TAAAF communique.
"As TAAAF members would be aware CASA is currently actively consulting the aviation community on a range of issues including proposed new aerial work regulations, proposed new operating rules, the best ways to implement future regulations and the development of Flight Plan 2030. Extensive consultation with the aviation community on a range of key issues will continue. CASA welcomes feedback from all sectors of the aviation community and will look carefully at all constructive suggestions.
"Earlier this year the Director of Aviation Safety wrote to all pilots asking for feedback on the new licensing suite of regulations, with more than 100 people responding. CASA has been working methodically through the issues raised and has been addressing unintended consequences. Changes have been made to address specific issues such as firefighting operations.
"Because the ATPL flight test is a new requirement, CASA Flight Training Examiners are available to facilitate the conduct of these tests while industry delegates transition to gaining the required privileges and the tests are built in to industry training and checking programs.
"Also, a special CASA forum is being held in November for aviation organisations developing or planning to develop a fatigue risk management system. The aim of the forum is to ensure there is a mutual understanding between CASA and aviation organisations of the requirements and expected outcomes of a fatigue risk management system.
"CASA is committed to listening to the legitimate concerns of the aviation community and we will look carefully at the suggestions being made by the TAAAF."
More to follow ....... AHIA
Thread Starter
Updates continue .....
30 Oct ’15. AM hours. Steve Creedy, Aviation Editor, The Australian, in his regular Friday Column, wrote:
Urgent call for task force on aviation regulations.
The Australian Aviation Associations Forum has expressed concern at the slow pace of reform. Aviation groups have called for an industry task force to deal with the continuing damage caused by regulatory glitches and want the Civil Aviation Safety Authority to withdraw new fatigue management rules.
The Australian Aviation Associations Forum, which represents a wide cross-section of the industry, fired another broadside at the authority yesterday, expressing “considerable concern” at the slow pace of reform and the ongoing cost impositions from new regulations.
The communique comes as aviation organisations gear up their campaigns for the next federal election, and new TAAAF chairman Greg Russell is moving to ensure the umbrella organisation has more political clout.
“Recently introduced CASA regulations are threatening the viability of industry and especially general aviation operations, with millions of dollars required to be invested for no commensurate safety gains,’’ the statement said.
The association said it fully supported a directive from CASA director of aviation safety Mark Skidmore on development and application regulations that were risk-based and cost-effective.
It called for the directive to be applied to recently introduced CASA regulations, as well as those about to be introduced, but noted this would require cultural change within the authority.
The association urged CASA to withdraw Civil Aviation Order 48.1 (flight and duty times), arguing it was against the objectives of DAS directive 01/2015 “in that hard evidence has not been provided to justify it, it ignores decades of safe operations under previous rules, and imposes massive unnecessary costs and complexity’’.
The issue was among several hot topics discussed by more than 300 industry representatives at last week’s Regional Aviation Association of Australia national convention in the NSW Hunter Valley.
Civil Aviation Order 48.1 has been a lightning rod for controversy, with the Regional Aviation Association of Australia and the Aerial Application Association of Australia among those wanting the rules halted and the Australian Federation of Air Pilots criticising the Civil Aviation Safety Authority for delaying the changes.
CASA has extended the transition period from last April to next May to allow about 25 changes to the new rules to be considered.
The authority says the proposed changes will ease the regulatory burden of the new fatigue rules and potentially reduce costs for air operators and flying training organisations.
TAAAF also wants to establish an industry task force to propose urgent exemptions and amendments to controversial Part 61, 141, 142 regulations covering pilot licensing and training.
It said CASA should introduce revised transitional arrangements to allow the industry to operate, with firefighting training and the issuing of new air transport pilot licences for general aviation pilots the priorities.
“Both these essential functions have virtually ceased under the new regulations,’’ it said.
Also on the agenda was a proposal to reform Australian aviation manufacturing regulations to better harmonise them with the US system and a call to reverse the damage caused by new maintenance training regulations that had seen the loss of three TAFE providers.
“While there is some good work being undertaken by CASA, it is being hindered by the massive problems caused by legacy regulations only now coming into force,’’ the communique said.
“TAAAF believes that now is the time for definitive action before the new regulations cause irreparable long-term damage and the loss of jobs and businesses.’’
Mr Russell said the communique underpinned real concern within the industry about the pace of reform within CASA and the consistency of its actions.
He said regulatory changes already made and those coming into effect were creating major costs and seriously disrupting the industry. “And I’m not sure that message is well understood in government,’’ he said. “Yes, it’s been going on for a while but … I’ve never seen such angst.’’
Mr Russell said the industry understood the expectations of Deputy Prime Minister Warren Truss in the wake of the Forsyth aviation safety regulation review and the commitment of the CASA board and chief executive to that direction. But he said this was not being matched by the actions of some CASA line staff and the industry believed this pointed to major cultural issues within the organisation.
“We’ll be writing to the board chair and the aim is to work closely with the board and management to address is what we think is this serious and ongoing cultural issue, which is effectively creating this regulatory impasse in terms of the relationship between industry and CASA,’’ he said.
Regional Aviation Association of Australia chief executive Paul Tyrell said opposition to the CAO 48.1 had been a major issue at last week’s RAAA convention.
CASA said it was actively consulting with the aviation community on a range of issues including proposed new aerial work regulations, proposed new operating rules, the best ways to implement future regulations and the development of Flight Plan 2030.
It said the consultation would continue and it would look carefully at all constructive suggestions from the industry.
A request for feedback from pilots on the new licensing rules produced more than 100 responses and CASA had been working methodically through the issues raised and addressing unintended consequences.
“Changes have been made to address specific issues such as firefighting operations,’’ a spokesman said. Because the ATPL flight test is a new requirement, CASA flight training examiners are available to facilitate the conduct of these tests while industry delegates transition to gaining the required privileges and the tests are built in to industry training and checking programs.’’
AHIA is a member of TAAAF.
Urgent call for task force on aviation regulations.
The Australian Aviation Associations Forum has expressed concern at the slow pace of reform. Aviation groups have called for an industry task force to deal with the continuing damage caused by regulatory glitches and want the Civil Aviation Safety Authority to withdraw new fatigue management rules.
The Australian Aviation Associations Forum, which represents a wide cross-section of the industry, fired another broadside at the authority yesterday, expressing “considerable concern” at the slow pace of reform and the ongoing cost impositions from new regulations.
The communique comes as aviation organisations gear up their campaigns for the next federal election, and new TAAAF chairman Greg Russell is moving to ensure the umbrella organisation has more political clout.
“Recently introduced CASA regulations are threatening the viability of industry and especially general aviation operations, with millions of dollars required to be invested for no commensurate safety gains,’’ the statement said.
The association said it fully supported a directive from CASA director of aviation safety Mark Skidmore on development and application regulations that were risk-based and cost-effective.
It called for the directive to be applied to recently introduced CASA regulations, as well as those about to be introduced, but noted this would require cultural change within the authority.
The association urged CASA to withdraw Civil Aviation Order 48.1 (flight and duty times), arguing it was against the objectives of DAS directive 01/2015 “in that hard evidence has not been provided to justify it, it ignores decades of safe operations under previous rules, and imposes massive unnecessary costs and complexity’’.
The issue was among several hot topics discussed by more than 300 industry representatives at last week’s Regional Aviation Association of Australia national convention in the NSW Hunter Valley.
Civil Aviation Order 48.1 has been a lightning rod for controversy, with the Regional Aviation Association of Australia and the Aerial Application Association of Australia among those wanting the rules halted and the Australian Federation of Air Pilots criticising the Civil Aviation Safety Authority for delaying the changes.
CASA has extended the transition period from last April to next May to allow about 25 changes to the new rules to be considered.
The authority says the proposed changes will ease the regulatory burden of the new fatigue rules and potentially reduce costs for air operators and flying training organisations.
TAAAF also wants to establish an industry task force to propose urgent exemptions and amendments to controversial Part 61, 141, 142 regulations covering pilot licensing and training.
It said CASA should introduce revised transitional arrangements to allow the industry to operate, with firefighting training and the issuing of new air transport pilot licences for general aviation pilots the priorities.
“Both these essential functions have virtually ceased under the new regulations,’’ it said.
Also on the agenda was a proposal to reform Australian aviation manufacturing regulations to better harmonise them with the US system and a call to reverse the damage caused by new maintenance training regulations that had seen the loss of three TAFE providers.
“While there is some good work being undertaken by CASA, it is being hindered by the massive problems caused by legacy regulations only now coming into force,’’ the communique said.
“TAAAF believes that now is the time for definitive action before the new regulations cause irreparable long-term damage and the loss of jobs and businesses.’’
Mr Russell said the communique underpinned real concern within the industry about the pace of reform within CASA and the consistency of its actions.
He said regulatory changes already made and those coming into effect were creating major costs and seriously disrupting the industry. “And I’m not sure that message is well understood in government,’’ he said. “Yes, it’s been going on for a while but … I’ve never seen such angst.’’
Mr Russell said the industry understood the expectations of Deputy Prime Minister Warren Truss in the wake of the Forsyth aviation safety regulation review and the commitment of the CASA board and chief executive to that direction. But he said this was not being matched by the actions of some CASA line staff and the industry believed this pointed to major cultural issues within the organisation.
“We’ll be writing to the board chair and the aim is to work closely with the board and management to address is what we think is this serious and ongoing cultural issue, which is effectively creating this regulatory impasse in terms of the relationship between industry and CASA,’’ he said.
Regional Aviation Association of Australia chief executive Paul Tyrell said opposition to the CAO 48.1 had been a major issue at last week’s RAAA convention.
CASA said it was actively consulting with the aviation community on a range of issues including proposed new aerial work regulations, proposed new operating rules, the best ways to implement future regulations and the development of Flight Plan 2030.
It said the consultation would continue and it would look carefully at all constructive suggestions from the industry.
A request for feedback from pilots on the new licensing rules produced more than 100 responses and CASA had been working methodically through the issues raised and addressing unintended consequences.
“Changes have been made to address specific issues such as firefighting operations,’’ a spokesman said. Because the ATPL flight test is a new requirement, CASA flight training examiners are available to facilitate the conduct of these tests while industry delegates transition to gaining the required privileges and the tests are built in to industry training and checking programs.’’
AHIA is a member of TAAAF.
Thread Starter
Is their a lesson for us all - avoiding over regulation?
In these difficult times, a helpful opinion can give us hope, as we seek resolution of many of the problems associated with regulatory reform. In the Jan to Mar Edition, of Helicopters Australia, an article was published that needs to be shared with others rewriting manuals and new expositions.
The report has been quoted verbatim, with acknowledgment to the journalist.
Maybe we should invite Executive Director, Patrick Ky, EASA, to speak at our Rotortech 2016 Conference on the Sunshine Coast in May 2016!
Why is CASA not using the same sheet of EASA’s music?
Flight International, Edition 3-9 March 2015, page 29 has an interesting report by Regulation Reporter, David Learmonth. David’s article is titled:
‘EASA mends the rules with tighter focus on outcomes’
The executive director at Europe's safety agency has overseen a wholesale shift in mindset. If a regulator dismantles its rule making doctorate it is a sign things are changing, and at EASA and they are!
Executive director Patrick Ky took over the EASA top job in September 2013, and a year later he closed the rulemaking department. "If you have a rulemaking directorate," he explains, "the director is judged by how many rules he makes, or how many existing rules he 'improves'."
The result, he says, is ever-fatter rule books, the content of which nobody could possibly retain, and the complexity of which becomes "impossible to work with".
When he first arrived, Ky says, he gathered his troops and told them to reduce the existing rules down to the absolute essentials, so they could all see what was really necessary.
EASA retains its power to make rules, Ky confirms, but the way the need for rules is assessed, and the way that they are made and framed, is now different. The rulemaking process now starts with a risk assessment to determine whether a rule is needed at all, and if so what it needs to address. Only then is it framed.
Finally, the rate of technological progress is such that prescriptive rules involving equipment can rapidly become outdated, so the future, says Ky, is performance - based rulemaking (PBR), with prescriptive rules only where they are essential. Mostly the latter would define capabilities and responsibilities. PBR means that the required outcome of the rule is specified, and the means by which that outcome is achieved is not the main issue. This method has been foreshadowed for years by the approval of rulings on an "equivalent safety" basis, which allows flexibility in the means by which a safety objective could be achieved.
Rule makers still work at EASA, but within one of the four directorates: strategy and safety management, certification, flight standards, and resources and support.
"Rule makers now only work six months at HQ” Ky explains. "Then they are sent out on inspections so they can see what it's like to have to put EASA rules into practice."
But Ky, a noted simplifier, has actually created a new directorate: strategy and safety management, headed by Luc Tytgat, formerly the director of the pan-European Single Sky Directorate at Eurocontrol. Why?
Ky explains: "If we are to go to PBR, we have to establish what the risk is, and to prioritise our resources and action. Luc's task is to notice what is happening out there, to recognise risk and determine where action might be needed." There are areas crying out for attention, Ky says, and ground handling, where - in simple numbers - there are more safety incidents than in any other phase of an aircraft's operation, is one of them. And in general aviation, it has started down the long path of working with the sector towards replacing regulation that was effectively commercial-aviation-light with industry-specific guidelines.
Long-serving certification director Norbert Lohl was on 1 March replaced by Trevor Woods, who previously worked on flight standards. Lohl says it was tough in the early days, building a relationship with sceptical national aviation authorities. They were essential, because EASA was so under-resourced that it had to contract out a high proportion of new tasks to the national authorities. About 20 of the tasks still are contracted out.
Woods points out how much is happening on the operations side, especially in human factors and training. EASA is preparing to drive operators towards the application of safety management systems within training departments, and towards the principle of alternative training and qualification programmes, instead of prescriptive syllabus-based recurrent training, plus the application of competency-based training.
Aircraft manufacturers must now provide operational suitability data to prove their cockpit interfaces work. Airlines will be expected to follow the manufacturers' manuals on type rating training more closely. And work is being done to improve the effectiveness of simulators.
EASA is not blind to the fact that pilots frequently seem to be unable to cope with the unexpected, Woods emphasises, and it is looking for ways of dealing with this. (Our thanks to David for use of his excellent report).
AHIA
The report has been quoted verbatim, with acknowledgment to the journalist.
Maybe we should invite Executive Director, Patrick Ky, EASA, to speak at our Rotortech 2016 Conference on the Sunshine Coast in May 2016!
Why is CASA not using the same sheet of EASA’s music?
Flight International, Edition 3-9 March 2015, page 29 has an interesting report by Regulation Reporter, David Learmonth. David’s article is titled:
‘EASA mends the rules with tighter focus on outcomes’
The executive director at Europe's safety agency has overseen a wholesale shift in mindset. If a regulator dismantles its rule making doctorate it is a sign things are changing, and at EASA and they are!
Executive director Patrick Ky took over the EASA top job in September 2013, and a year later he closed the rulemaking department. "If you have a rulemaking directorate," he explains, "the director is judged by how many rules he makes, or how many existing rules he 'improves'."
The result, he says, is ever-fatter rule books, the content of which nobody could possibly retain, and the complexity of which becomes "impossible to work with".
When he first arrived, Ky says, he gathered his troops and told them to reduce the existing rules down to the absolute essentials, so they could all see what was really necessary.
EASA retains its power to make rules, Ky confirms, but the way the need for rules is assessed, and the way that they are made and framed, is now different. The rulemaking process now starts with a risk assessment to determine whether a rule is needed at all, and if so what it needs to address. Only then is it framed.
Finally, the rate of technological progress is such that prescriptive rules involving equipment can rapidly become outdated, so the future, says Ky, is performance - based rulemaking (PBR), with prescriptive rules only where they are essential. Mostly the latter would define capabilities and responsibilities. PBR means that the required outcome of the rule is specified, and the means by which that outcome is achieved is not the main issue. This method has been foreshadowed for years by the approval of rulings on an "equivalent safety" basis, which allows flexibility in the means by which a safety objective could be achieved.
Rule makers still work at EASA, but within one of the four directorates: strategy and safety management, certification, flight standards, and resources and support.
"Rule makers now only work six months at HQ” Ky explains. "Then they are sent out on inspections so they can see what it's like to have to put EASA rules into practice."
But Ky, a noted simplifier, has actually created a new directorate: strategy and safety management, headed by Luc Tytgat, formerly the director of the pan-European Single Sky Directorate at Eurocontrol. Why?
Ky explains: "If we are to go to PBR, we have to establish what the risk is, and to prioritise our resources and action. Luc's task is to notice what is happening out there, to recognise risk and determine where action might be needed." There are areas crying out for attention, Ky says, and ground handling, where - in simple numbers - there are more safety incidents than in any other phase of an aircraft's operation, is one of them. And in general aviation, it has started down the long path of working with the sector towards replacing regulation that was effectively commercial-aviation-light with industry-specific guidelines.
Long-serving certification director Norbert Lohl was on 1 March replaced by Trevor Woods, who previously worked on flight standards. Lohl says it was tough in the early days, building a relationship with sceptical national aviation authorities. They were essential, because EASA was so under-resourced that it had to contract out a high proportion of new tasks to the national authorities. About 20 of the tasks still are contracted out.
Woods points out how much is happening on the operations side, especially in human factors and training. EASA is preparing to drive operators towards the application of safety management systems within training departments, and towards the principle of alternative training and qualification programmes, instead of prescriptive syllabus-based recurrent training, plus the application of competency-based training.
Aircraft manufacturers must now provide operational suitability data to prove their cockpit interfaces work. Airlines will be expected to follow the manufacturers' manuals on type rating training more closely. And work is being done to improve the effectiveness of simulators.
EASA is not blind to the fact that pilots frequently seem to be unable to cope with the unexpected, Woods emphasises, and it is looking for ways of dealing with this. (Our thanks to David for use of his excellent report).
AHIA
Interested in why Industry has its knickers in such a knot about CAO 48.1 yet not a whimper about the lack of a Part 125 to cater for medium aircraft in the 10 to 30 seat range.
When they realise the full implications of Part 121 there will be some operators of Metros, Beech 1900s etc who may find it all too much.
When they realise the full implications of Part 121 there will be some operators of Metros, Beech 1900s etc who may find it all too much.
Thread Starter
Just a reminder that you must log all these concerns on the TLSIC "Aviation Package Review."
You must state your concerns - just check boxes + and add few words - it all helps.
Oh ....... and check out The Australian on Fri 6 Nov '15. Steve Creedy may have some interesting updates on regulatory reform shortcomings.
The waiting game is over as far as industry is concerned!
If needed, we will paste The Australian article (or summary) here. Should be available by Sunday night.
AHIA
You must state your concerns - just check boxes + and add few words - it all helps.
Oh ....... and check out The Australian on Fri 6 Nov '15. Steve Creedy may have some interesting updates on regulatory reform shortcomings.
The waiting game is over as far as industry is concerned!
If needed, we will paste The Australian article (or summary) here. Should be available by Sunday night.
AHIA
Thread Starter
Please note AHIA comments and recent dramatic advice from CASA is now available on Rotorheads forum.
Full accounts have been provided and more later as we get approval to release more of AHIA activities on behalf of their members into the public arena.
Go to "rotorheads" and look at thread titled:
AHIA strongly protests CASA’s mismanaged regulatory reform process!
AHIA
Full accounts have been provided and more later as we get approval to release more of AHIA activities on behalf of their members into the public arena.
Go to "rotorheads" and look at thread titled:
AHIA strongly protests CASA’s mismanaged regulatory reform process!
AHIA
New taskforce to implement licensing suite solutions
A special taskforce is being set up within CASA to address outstanding issues with the new licensing suite of regulations.
The 26-person taskforce will work full-time on finding solutions to issues identified with Civil Aviation Safety Regulations Parts 61, 64, 141 and 142.
The taskforce will work closely with a new advisory panel made up of people representing a wide range of sectors across the aviation community.
Key aviation representative organisations have been invited to take up positions on the advisory panel.
These include The Australian Aviation Associations Forum, the Regional Aviation Association of Australia, the Australian Helicopter Industry Association, the Aircraft Owners and Pilots Association, the Australian Business Aviation Association, the Royal Federation of Aero Clubs of Australia and the Aerial Application Association of Australia.
Representatives will also be included from the regular public transport and mustering sectors, along with key people from flying training schools and the tertiary education sector.
CASA’s Director of Aviation Safety, Mark Skidmore, said the Part 61 Solutions Taskforce and the advisory panel will work intensively to address unintended consequences in the licensing suite.
“CASA has already addressed many concerns that have been identified in the new licensing regulations but I understand more needs to be done,” Mr Skidmore said.
“This is a priority and that’s why I need a dedicated team of people within CASA working full-time on the issues.
“Just as importantly we need advice and guidance from the aviation community to prioritise actions and verify that successful solutions have been found.
“The advisory panel will meet formally as required and at other times I expect its members to be in close contact with the CASA taskforce as work progresses.
“I require real solutions to the issues with the licensing suite as quickly as they can be delivered.”
It is expected the taskforce will begin by reviewing transition arrangements and then prioritising issues. The taskforce will begin work immediately.
The taskforce will ensure known or likely safety risks continue to be effectively addressed by the licensing regulations.
At the same time it will make sure unnecessary costs are not imposed by the regulations and that they are not an impediment to participation in aviation or potential future growth.
To date 98 issues with the licensing suite have been raised with CASA through feedback and input from the aviation community. More than half of these have been addressed, with work well advanced on the balance.
Action taken to date includes publishing legislative instruments, extending the 14 day dual check requirement for student pilots to 30 days, R22 and R44 helicopters no longer classified as type-rated aircraft, information sheets have been produced to provide clearer guidance and information, instruments are in place to ensure CAR 217 organisations are properly authorised to conduct flying training activities during the transition period, authorisations are in place for check pilots to conduct operator proficiency checks, changes have been made to English language proficiency requirements and an exemption in relation to low-level rating requirements.
CASA has also announced an extension of the transition period for Parts 141 and 142 of the licensing suite.
Transition for these Parts – which cover flying training – was scheduled to be completed by 31 August 2017. This has now been extended by 12 months to 31 August 2018.
The additional transition time will give CASA more time to arrange a smooth transition by providing additional guidance material and for identified issues to be resolved.
Media contact:
Peter Gibson
Mobile: 0419 296 446
Email
[email protected]
Ref: MR13215
Not blaming industry this time eh??
The 26-person taskforce will work full-time on finding solutions to issues identified with Civil Aviation Safety Regulations Parts 61, 64, 141 and 142.
The taskforce will work closely with a new advisory panel made up of people representing a wide range of sectors across the aviation community.
Key aviation representative organisations have been invited to take up positions on the advisory panel.
These include The Australian Aviation Associations Forum, the Regional Aviation Association of Australia, the Australian Helicopter Industry Association, the Aircraft Owners and Pilots Association, the Australian Business Aviation Association, the Royal Federation of Aero Clubs of Australia and the Aerial Application Association of Australia.
Representatives will also be included from the regular public transport and mustering sectors, along with key people from flying training schools and the tertiary education sector.
CASA’s Director of Aviation Safety, Mark Skidmore, said the Part 61 Solutions Taskforce and the advisory panel will work intensively to address unintended consequences in the licensing suite.
“CASA has already addressed many concerns that have been identified in the new licensing regulations but I understand more needs to be done,” Mr Skidmore said.
“This is a priority and that’s why I need a dedicated team of people within CASA working full-time on the issues.
“Just as importantly we need advice and guidance from the aviation community to prioritise actions and verify that successful solutions have been found.
“The advisory panel will meet formally as required and at other times I expect its members to be in close contact with the CASA taskforce as work progresses.
“I require real solutions to the issues with the licensing suite as quickly as they can be delivered.”
It is expected the taskforce will begin by reviewing transition arrangements and then prioritising issues. The taskforce will begin work immediately.
The taskforce will ensure known or likely safety risks continue to be effectively addressed by the licensing regulations.
At the same time it will make sure unnecessary costs are not imposed by the regulations and that they are not an impediment to participation in aviation or potential future growth.
To date 98 issues with the licensing suite have been raised with CASA through feedback and input from the aviation community. More than half of these have been addressed, with work well advanced on the balance.
Action taken to date includes publishing legislative instruments, extending the 14 day dual check requirement for student pilots to 30 days, R22 and R44 helicopters no longer classified as type-rated aircraft, information sheets have been produced to provide clearer guidance and information, instruments are in place to ensure CAR 217 organisations are properly authorised to conduct flying training activities during the transition period, authorisations are in place for check pilots to conduct operator proficiency checks, changes have been made to English language proficiency requirements and an exemption in relation to low-level rating requirements.
CASA has also announced an extension of the transition period for Parts 141 and 142 of the licensing suite.
Transition for these Parts – which cover flying training – was scheduled to be completed by 31 August 2017. This has now been extended by 12 months to 31 August 2018.
The additional transition time will give CASA more time to arrange a smooth transition by providing additional guidance material and for identified issues to be resolved.
Media contact:
Peter Gibson
Mobile: 0419 296 446
[email protected]Ref: MR13215
Not blaming industry this time eh??