Is CASA Competent to Make an Objective 1:50 Decision?
Any proposal is required to provide an equivalent level of safety for the public.
Following are some questions that CASA has not answered nor provided information to the public to make a more informed decision on the NPRM.
In the absence of such data is it worth gambling on CASA's integrity given its previous performance? How long ago was it necessary to hold the Lockhart River inquiry into CASA's ability to safeguard the public interest?
How has CASA demonstrated it posses the skills to determine an equivalent level of safety? It has not.
What processes does CASA use to determine an equivalent level of safety?
How has CASA determined the processes and proven them to be valid?
Within Australian operators what is the expertise of the individuals who have conducted the risk assessments and developed the safety cases to justify the approvals already granted to reduce the ratio from 1:36 to 1:50?
What is the experience level within management of Australian air operators who are conducting "risk assessments" and formulating the safety case?
The really competent cabin safety people argued successfully to retain the 1:36 in the 2000 Regulatory Review.
Most have since retired and their expertise not replaced.
What is the basis for these safety cases? Is it scientific and/or evidence based or subjective?
On the basis of the increased risk in the air since 9/11 and the need for both the rear doors to be manned in a ditching is the safety case presented really an economic case?
The CASA CEO that signs off on the 1:50 NPRM and the other world lowest standards is setting the Authority down the path of another inquiry.
Perhaps it can be held in conjunction with the inevitable "Norfolk Island" ditching inquiry.