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The regulations have to reflect reality,
0:09 they have to reflect where the industry is,
0:11 and at the moment they don't do that.
0:13 Because as I've said, they've grown up basically organically.
0:17 When there's been a regulation required, it's been written.
0:19And people have done the right thing as far as they knew,
0:22 interacting with the industry and meeting the requirements.
0:25 Nowadays, we need to get all that internationally aligned.
0:30So we need to follow ICAO.
0:32 Our regulations up to now basically haven't.
0:34 The CASA parts will align us with ICAO,
0:37 will align us with interoperability
0:39 with other countries around the world.
0:41 It puts us into a modern system.
0:43 Whereas our system at the moment,
0:45 we've relied heavily on exemptions and permissions.
0:47 There's in excess of 1,700 of those documents out there.
0:51 And that becomes a case of ruling almost by exemption,
0:55 which is not the best manner.
0:57 Because if you have a regulation, then you exempt somebody,
0:59 and you exempt somebody, and exempt somebody,
1:01 by the time you get out over here somewhere,
1:03 this original rule is a nonsense.
1:05 So updating it to where we are and reflecting the industry,
1:10 putting us in a better position for the 21st century,
1:13 making them simpler because everything is contained in one place.
1:18 In other words, the manuals of standards
1:20 contain all the standards now.
1:21You don't have to look through various publications,
1:23 as it is a little bit the technique required today.
1:26 So that's the important part of it.
1:28 Updating them to the 21st century,
1:30 allowing industry to move forward in the new regime of equipment
1:33 in avionics and things that we have available,
1:35 making sure we're internationally aligned
1:37 as best we can for interoperability,
1:39 and certainly harmonise with ICAO requirements.
1:42 However, the real issue is
1:44 what is the industry's ability to absorb change?
1:47 So the time we take to implement the regulations
1:50 will be driven basically
1:52 by how well we see the industry adapting to the changes.
1:55 Some of the changes are quite minor.
1:57 Some of them radically change the way people approach things.
2:00 But in each case, we're trying to enable industry to move forward
2:04 on a solid basis of knowing what the requirements are.
2:06 And those requirements, we are trying to make them
2:09 no more onerous than any other country that we would consider to be
2:12 someone we would benchmark ourselves against.
2:14 Reg reform is not a two-minute job,
2:17 and those people in the industry who say
2:19 "Oh, yeah, you just write this and away you go,"
2:21 it shows most probably the fact that they don't understand
2:24 the concepts or the principles involved at sufficient depth.
2:27 We're not trying to...
2:29 You know, we're dealing with what will go through parliament,
2:31 and become a CASA part, it will become law.
2:35 We can't just willy-nilly sign something over
2:39 because we think that's good on that day,
2:41 and yet some of our critics would want just that.
2:45 The process has to involve industry and the aviation community at large,
2:49 which of course is the travelling public as well.
2:51 We have the Notice of Proposed Rule Making process
2:53 involving the Standards Consultative Committee.
2:55 Then we have more public feedback.
2:57 Then we have the Notice of Final Rule Making.
3:00 And again there's feedback on that.
3:02 And then they go forward to parliament
3:03 and then to the Governor-General for the assent.
3:06 Industry, anybody, is free to comment at any stage during that process,
3:12 until we get to the Notice of Final Rule Making,
3:14 and we've decided and we've finished the rules,
3:15 then the rules are finished.
3:18 But it's a very lengthy period of time
3:20 available for people to make comments and I would encourage them to do so.
3:24 The ops regulations, as well, are inextricably interwoven
3:27 with the maintenance regulations
3:29 in that the maintenance regulations
3:30 call up for a certain amount of maintenance.
3:32 Now this is just our preferred option.
3:34 Again, it's open for consultation, so we haven't set anything in stone.
3:37 But if we look at what we have out there now
3:40 in the phase one of the maintenance regulations,
3:42 it says if you are this sort of operator,
3:45 if you are a part 121 operator, you'll need this type of maintenance.
3:48 If you're a 135 operator, you'll need this type of maintenance.
3:51 Well, straightaway, we can see that if Regulation 135 doesn't exist,
3:56 how do you know if you're a 135 operator or not?
3:59 So we can't, in a lot of ways,
4:00 just put the maintenance regulations out there
4:02 where they refer to operational regulation parts
4:07 without the operational parts also being available.
4:09 I consider that it will take us in excess of three years, possibly four,
4:13 to roll out the maintenance regulations in total.
4:16 That doesn't mean that we are slow or we're slack or anything like that.
4:21 What it means is that's about the rate
4:23 that we will see the industry take it up
4:24 because we don't want people to stop their day-to-day business...
4:29 ..having to suddenly adapt to a new set of regulations,
4:31 we want to transition them.
4:33 Part 141, for instance, on the flying training schools
4:35 is a whole new approach to demystifying
4:38 and decomplicating flying instruction for the simple operation,
4:42 the one-man, one-woman band,
4:44 or the small school that's not doing integrated training.
4:46 That's a whole new way of regulating that sector.
4:49 And we've gotta make sure that people can continue their business
4:52 but still, at the same time,
4:53 go through that transition period and come out the other side
4:56 in whatever reg part is applicable to them.
5:00 So that will take, I think,
5:02 a considerable amount of time in the coming years
5:05 purely because we'll have to drip-feed the industry.
5:08 And we have the fatigue rules around flight crew and cabin crew,
5:12 and then looking to develop
5:13 the fatigue rules for air traffic controllers.
5:16 again, the transition period for those will have to recognise the fact
5:19 that in some cases there may be crewing response changes,
5:24 there may be changes in roster patterns for the airlines, et cetera.
5:28 There may be some who wish to go to a fatigue risk management system.
5:31 There may be some who do not,
5:33 who wish to remain with the prescriptive regulations.
5:35 Hence, that transition period will be most probably three years
5:39 so that we can allow people time
5:41 to change rosters, recruit pilots, recruit cabin crew,
5:45 or reorganise, whatever they have to do to do their business.
5:49 We must make sure that we can facilitate that and allow them time.
5:52 So in reality, if we take three years,
5:55 I think it's a better result than if we pushed it through and said,
5:59 "By this day, you must be compliant."
6:01 We'd get a result. We'd be able to say, "Yep, everybody's compliant.
6:03 "Don't worry about that."
6:05 But it would be hollow.
6:06 I think one of the first goals I gave this organisation was
6:10 that we would have our staff properly trained and deployed.
6:13 Now we have to also train some of the industry.
6:16 There's also an onus on the industry to train themselves.
6:19 We provide the equipment, we provide the information,
6:21 we provide the background, we provide the regulations,
6:24 now it's up to you to assimilate all that into your organisation.
6:27 But training, education, the cornerstones of what we do.
6:32 If we do not educate people,
6:34 it doesn't matter what sort of regulation we write.
6:36 If you have the uneducated person,
6:38 they will do something most probably inadvertently,
6:42 which the regulation is not only there to make it some sort of offence
6:46 or to prohibit some action,
6:48 it is there because there is a safety requirement behind the regulation.
6:52 If people disregard the regulation out of ignorance,
6:56 well, that's something that we should hopefully be able to address
6:59 by helping them, but we can't make people learn.
7:02 We can't make people obey regulations.
7:04 The regulation doesn't make people safe.
7:06 It's their attitudes, their behaviours, their actions,
7:09 that's what makes them safe or unsafe.
7:11 But every publicly listed company that's an airline
7:15 or an air operator of some description in that business
7:17 that returns a profit at some stage in their process during the year,
7:24 they're deciding how much they're going to spend on safety.
7:26 If they spent everything they could on safety -
7:29 like continually renewing equipment, training people endlessly,
7:32 massive numbers of staff over and above what's required,
7:35 then they wouldn't show a profit.
7:39 So if they do show a profit, somebody, somewhere,
7:42 is making the decision of how much they're going to spend.
7:44 Our job is to make sure that the amount that is spent -
7:47 and I'm not interested in the dollar number, I'm interested in the result,
7:50 the result is showing that the safety is keeping
7:53 where the Australian public demands it is.
7:55 And after all, if we are writing the regulations,
7:57 then we answer to the parliament, and we answer to the industry, et cetera,
8:01 but in the end we answer to the Australian people.
8:03And it's the Australian public who demand a safe system.