The safety benefits of the standard significantly outweigh the requirements being imposed. These actions are consistent with CASA’s regulatory philosophy where air safety is not compromised, and the proposal reflects a proportionate risk-based approach.
Just goes to show, once again, that CASA does not understand how proper standards setting is supposed to work. CASA can’t even get it’s empty rhetoric right.
The empty rhetoric should have been “outweigh the costs of the requirements being imposed”. However, because CASA doesn’t have any cost data and wouldn’t care less about it in any event, a bunch of waffle and cliches is their only option to paper over what is, in fact, a knee jerk reaction.
No precise quantification of the “benefits”. No precise quantification of what “significantly” means. No precise quantification of the costs of compliance including the costs in terms of people who may no longer have access to CSFs. No precise quantification of the risks taken into account in the claimed ‘risk-based’ approach. None of that has been spelt out because it does not exist.