Originally Posted by
Vag277
Everyone seems to be missing the point that this thread staretd with a link to a set of CONSULTATION DOCUMENTS
You seem to be missing some of the context of the “consultation”, Vag.
This is not the first time a “consultation” on this issue has occurred. This time around we get the addition of yet another bright idea: Time-based engine TBOs, despite what the data show.
The CEO of Angel Flight should not have to say this:
To take away rights or impose restrictions on licence holders, with the stroke of the CEO’s pen, is dictatorial and an abuse of process. Our licences and maintenance requirements are governed by the Regs: any amendment should be by proper Regulatory change . By ambushing us all on the eve of long holidays , and by proposing an administrative direction, ensures no ‘interference’ by our elected representatives in parliament. Parliamentary members can disallow Regs - they cannot disallow a direction, and nor does it have to be presented to either House. The implications of this high-handed and undemocratic action, if allowed to proceed, sets a dangerous precedent which could see all or any of our aviation rights cancelled at the whim of CASA, and not the legislature.
This is not evidence-based or risk-based regulation. This is not “safety through simplicity”.
The process itself is a manifestation of how busted the regulatory paradigm is. An accident or incident occurs and the regulator is “responsible” for responding to it. And what’s the only thing the regulator is ‘good’ at? Regulating. So the regulator trots out a bunch of proposals that will impose more costs, restrictions and complexity and asks: Whaddayareckon? But if the regulator actually cared and listened to what we reckon, the regulator would have listened and heeded the feedback that’s been provided for decades and wouldn’t have come up with the bunch of proposals in the first place, unsupported by any valid cost/benefit/risk data. But that doesn’t matter, because the most important and relevant data that
should be essential considerations in standards setting are irrelevant externalities to the regulator.