The risk management equation for planning: Annual potential cost to Community = Assessed maximum cost of individual accident X Probability of that accident.
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What CASA has been using for planning : Annualised potential loss to Community = Cost of individual accident.
By ignoring probability, CASA is giving itself permission to be lazy and focus on the easy stuff that lawyers with limited technical experience can understand instead of focussing on the real dangers to the community which requires deep technical knowledge and honesty.
Example: Which issue has the potential to cost the community more?
(a) Constructing buildings that infringe on established runway clearances.
(b) A private pilot making a mistake in writing up her logbook.
‘Guess which issue attracts detailed prescriptive regulations and a strict liability criminal penalty?