This is one of the key points I made in my submission to the Aviation Safety Regulatory Review:
The regulatory reform program has failed and, in its current structure, is beyond repair
In the unlikely event that the ‘new’ package of aviation safety rules is implemented (not merely “completed”) sometime, the package will still be a complicated, convoluted mish-mash which fails to achieve the aims of the reforms.
Despite 155 pages of regulations growing to 2,827 pages (so far) there is almost no practical consequence for the way aircraft are operated and maintained today compared with when the regulatory reform program commenced.
The volume and complexity of the rules, combined with the symbiotic nature of the regulatory regime, results in unnecessarily high risks of inconsistent interpretations of the rules as between individual staff of the regulator, and unnecessarily disruptive (and, in some cases, destructive) consequences for industry participants.
This is one of the comments I made in my submission to the ‘Discussion Paper’ on AVMED:
I gave up reading the ever-growing pile of civil aviation laws in about the year 2000, when it became obvious to me that almost none of it made any practical operational difference compared with the rule set in force when I attained my pilot licence. I have subsequently successfully completed seven Flight Reviews, therefore demonstrating either that my judgment of the safety-relevance of the current regulatory mish-mash was correct or that the various Approved Testing Officers who conducted the reviews are as ‘dangerous’ as I am.
On any objective analysis, the answer is an emphatic ‘no’.