By way of explanation for previous post.
Background: Pprune readers should note the Australian Civil Aviation Safety Authority (CASA) is replacing the older Civil Aviation Regulations (CAR) with the new Civil Aviation Safety Regulations (CASR). Many of the new regulations are supported by relevant standards are published in a Manual of Standards (MOS) document.
Problem: Specific transitional rules are required to change from the existing rules to the new rules governing flight operations commencing in December 2021. These transitional rules are formally referred to as the consequential, application, transitional and savings or ‘CATS’ regulations.
An industry observer’s comment: CASA have released another consultation, even before Part 138 MOS consultation had closed! We need to look closely at details of this one, as it includes another layer called CATS regulations! Here is why CASA believe we need it:
The effective implementation of the Flight Operations CASR Parts, both from an operational perspective and a legal perspective, requires the making of CATS regulations. In general terms, CATS regulations would address:
- What current CARs need to be repealed, because their provisions are replaced by the new CASRs and MOSs or because they are no longer needed for other reasons.
- What remaining CARs need to be amended, because the terminology and the definitions they rely on, or other regulatory provisions that they cross-refer to, will no longer be current.
- What current CASRs need to be amended, because the terminology and definitions they rely on, or other regulatory provisions they cross-refer to will no longer be current.
- What actions taken and will which authorisations, approvals, exemptions, and other instruments made under the CARs need to be “saved” i.e. continued in effect for a period of time.
- What transitional provisions are required otherwise to enable the orderly and effective transmission of aircraft operators from the flight operation of requirements contained in the CARs and CAOs to the requirements of the new Flight Operations CASR parts.
Hope this clarifies the situation of concern with the Australian Regulatory Reform process, which continues to ask for industry feedback with too short deadlines. Unfortunately, the ongoing and well-meant process is being hampered by the coronavirus restrictions which has effectively shut down many smaller companies many of whom have entered hibernation or worse still ceased trading. That is one of the reasons of concern, apart for the need for so many changes in the interest of safety.
For the above reason, individuals and companies are encouraged to submit feedback by due date to the published CASA website facility; even if your statement would simply say, “unable to comment due to short timeframe and restrictions imposed by COVID-19 restrictions.”
Closing date is 30 June 2020