PPRuNe Forums - View Single Post - Merged: The Ambidji Report – CASA should get their money back!
Old 30th Aug 2009, 13:45
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LeadSled
 
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Folkss
Sadly, but hardly unexpectedly, this thread has deteriorated into all the usual suspects slagging off Dick Smith.

A fixture of the aviation scene, and unlikely to change, is the brigade who will never agree with Dick, but let's try to get back to the original subject, the Ambifjii Report and/or it's aftermath.

Flying Schools are going broke at the GAAPs, with planned and realisable utilisation through the floor.
What is going on just to the west of the YSBK zone is scary, most of us think (intuitively, based on years of experience) that YSBK (including the vicinity) is less safe now.

The Ambidjii Report is/was only part of the problem faced by John McCormick, brand new in the Director of Aviation Safety/CEO job. Arguably , what he was presented with, in the ICAO audit, and in particular the matter of airspace management, was overwhelming pressure to at least make a start.

With the double whammy of the ICAO audit and the Ambidjii Report, he was left with little choice as to a starting point.

What he could not have known, in the recommendations with which he was presented, was the serious and longstanding shortcomings of risk analysis, and presentation of such, which has generated so much argument, over airspace management, over so many years.

I would point out that Dick Smith has played no part in what I am referring to. As he has so often pointed out, he prefers the "common sense" test --- also accepted (in effect) by ICAO, as adoption by reference ----- showing a proposed change is essentially (but not exactly) the same as a proven working system.

"Adoption by Reference" leaves the proponent of change (in ICAO terms, and Australian Government risk management policy, AS/NZ 4360 etc.) to deal with the risk assessment of the difference, a far easier task than "whole system" analysis. This was how differences between the FAA NAS and the Australia NAS were handled, many of us spent many long hours grinding through the risk assessment processes, with the differences considered in fine detail, including the inherent risks of the "cultural shift" needed to make AUS/NAS work.

Unfortunately, the methodology long used in aviation regulatory circles ( as CASA has inherited from Airservices) has had long standing and major flaws, not limited to the "garbage in = garbage out" constant.

There are two essentially flawed areas, firstly how the F-N curves of societal risk are derived, and how they are presented on the risk diagram.

The F-N curves,as the process is worked, have a result that is very (unrealistically) conservative, or put another way, greatly overstates risk (fatalities per year) and produces an "acceptable risk" that is, in fact, a trivial ( trivial as a statistical term) risk , orders of magnitude below ALARP --- As Low As Reasonably Practical ----- where we should be at, a level of risk that is acceptable, below which lower risk is not attainable at a cost/benefit justified effort.

There is nothing particularly wrong with the Det Norske Veritas document re. societal risk, referred to in the Ambidjii Report, and Ambidjii has followed what they were given, a seriously flawed process, with which to work.

It is the process that is wrong, to come to the conclusion that YSBK operations, ( or any) GAAP for twenty or so years, presents as an "intolerable risk", it fails the "common sense"test.

For the first ten or so years of GAAP, there were nil/none/nought/zero MAC ---- Intolerable risk??

Anybody who read the O'Neil report into matters NAS, as commissioned by CASA (including the inputs of a number of acknowledged professional risk management persons - as in PhDs, etc., from other branches of the Commonwealth Public Service) gives a far more detailed insight into the shortcomings of the process ---- as still used by CASA and Airservices.

What Professor O'Neil (ANU) had to say is echoed by the three reports arranged here, by Dick Smith, and several more, yet to be published.


The message we have to get across the John McCormick is that he has been the victim of a seriously flawed process.

Fix the process, and we have fixed the GAAP "intolerable risk" problem.


After all, Ambidjii did not recommend the changes put in place. Who, in CASA, recommended the "final solution" (which is what it is for flying training, if we don't do something fast) to the DAS/CEO, I will bet he didn't think it up himself ??

Just go to the ATSB web site, have a look at all the consolidated accident data, and see how good the overall training rate is, compared to other GA sectors, or GA as a whole, then look at Avstats for the places much of the training hours operations occur, then try and convince yourself that the GAAP "intolerable risk", based on MAC only, is the overwhelming risk ---- is reasonable ---- and see how badly it fails the commons sense test -- let alone proper analysis.

The differences between GAAP and FAA D are marginal. For "cultural" reasons I would argue to maintain the current Australian system, but I acknowledge what Dick says about IFR protection, but this is an entirely different proposition to the fundamental flaw that brought about the present GAAP disaster.

As for ICAO D, forget it if you want to preserve any elementary flying training at the GAAPs.

Tootle pip!!

Last edited by LeadSled; 30th Aug 2009 at 14:31.
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