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Old 2nd Oct 2013, 09:41
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The RAAA view on reg reform!

From Proaviation.. A Bridge Too Far:
Jeff Boyd

By kind courtesy of Aviation Trader‘s Tony Shaw and of Jeff Boyd, we’re re-publishing Jeff’s recent Commentary on the regulatory scene, first published in Aviation Trader‘s September issue, for the benefit of those who haven’t yet seen it.

In my 33 years of working in the regional aviation industry I have seen the whole gamut of industry ups and downs.
I came into this industry at the end of the 1980’s boom. I worked through the recession that we had to have. I have seen the Aussie dollar get down to less than half of a US dollar and then rise to above parity, interest rates jump to crippling levels and now sink to record lows, and who would have ever believed we would be paying well over $2 a litre for aviation fuel. We have worked our way through industry skill shortages and along the way provided the major airlines free training for thousands of pilots and engineers.
Jeff Boyd addressing RAAA’s 2012 conference

We have paid for barbed wire fences around country airports, hardened cockpit doors for aircraft so small that they would bounce off the side of a building, and checked bag screening in places a terrorist would be hard pressed to find in an atlas.
We have enjoyed the work a healthy mining industry has bought us and we have worked hard to keep services to regional towns that don’t have the economic benefit of the mining industry.
But with all its highs and lows, overall for those who have worked hard and worked smart, the regional aviation industry has been a great business to be in.
For me it has taught me and taken me to places that as a young fellow growing up in the Western suburbs of Sydney I could have never imagined. It has provided economic security for myself and my family along with the hundreds of people who have come and gone from our employment over the years.
However probably the biggest threat now facing the future of the regional aviation industry is one that should not be a threat at all. It is one that is not controlled by the vagaries of the European economy or the threat of international terrorism. It is in fact a process that should and could provide great opportunities for our industry, – that is the regulatory reform of the Australian Civil Aviation Regulations.
This process has been going on for almost as long as I have worked in the industry. It has gone on for decades and cost millions of dollars. Some people have literally made a career out of drafting and redrafting the same regulation over and over again. It has gone through several incarnations under several different names of the industry regulator and even more Directors of the regulator. It had an American accent for a while before taking on a more European brogue. Now it would seem to be trying to develop an accent all of its own. This is an area where I believe one the biggest threats lies.
All along we have been told that our Australian regulations had to be rewritten because we needed to harmonise with the rest of the world and become ICAO compliant. I don’t believe that has happened as what I am seeing are Australian-specific rules and regulations being drafted. The new part 66 engineer’s licence for example is absolutely an Australian specific licence. Originally we were told, in fact I even saw it in CASA print, that we were going to get an EASA licence. What we actually ended up with is what CASA describe as an EASA style licence. Most engineers I speak to have found it completely confusing and it is not recognised anywhere else in the world.
CASA has just finished implementing the Part 145 and Part 42 maintenance regulations for RPT operations. This has been a massive task for many of our members, – just as massive I am sure for the people in CASA working to bring these regulations on line. These regulations were brought in on a time line that was too short and very difficult to meet. In fact most 145 and 42 approvals were only issued in the last couple of weeks and days before the cut off date. The pressure this line in the sand placed on many of our members was ridiculous. I believe the level of stress that was placed on both industry and CASA staff could have resulted in serious safety implications. It certainly caused a level of stress on individuals that I would consider harmful.
Now that we have these new maintenance regulations we have actually and unnecessarily divided our small Australian aircraft maintenance industry in two. This has had huge repercussions in the Regional Aviation industry where RPT and non RPT operations generally work side by side. We now have the situation where someone with a CAR30 approval cannot work or provide overhauled or repaired parts to a 145 organisation, however someone in another country automatically approved by CASA that does not necessarily have all of the processes and systems in place as required for an Australian Part 145 approval can do so. I feared when these regulations were proposed that some organisations would see the 145 process as too daunting and would walk away from the RPT industry. This has actually happened with many organisations deciding not to go 145 or worse, just closing down their services all together. I have spoken to several Australian RPT organisations who are now sourcing overhauled or repaired components from overseas instead of the Australian workshop they previously used.
There is also much ambiguity in these regulations with as many interpretations as there are CASA field offices. I believe this can be attributed to a lack of real guidance material for both CASA and industry. This guidance material should have preceded the rolling out of the regulations instead of CASA now playing catch up.
I look and see what it has cost and taken our industry to implement the Part 66 licences, Part 145 and Part 42 and I wonder how much more it will cost and take to actually get these three parts to an amended mature set of regulations. I then contemplate what a small section of the overall regulatory reform process these regulations are. How much more time and money will it take to finish writing and then implement the massive suite of flying ops and non-RPT maintenance regulations and what toll will that have on our industry? How many decades of amendments will ittake to iron out all of these new rules and achieve a mature set of regulations? Then at the end of the day we will be sitting inthe middle of the Pacific with a brand new set of Australian specific regulations.
From where I am writing this on the Eastern side of Australia I am actually closer in distance to New Zealand than I am to Perth. So I wonder why we are not doing as almost every other country in the Pacific, and some in South East Asia have done, and adopt the New Zealand regulations. Here are a set of rewritten ICAO compliant regulations, written for and by a country with aviation operations basically the same as us. I would doubt that there would be an area of operation that would not match ours. There is also the huge upside that their “new” regulations were implemented over a decade ago and have now reached a mature state.
For the critics who will say that I am over simplifying things, or that it would not be constitutionally possible to take up my suggestion, I remind them of a set of aviation regulations called EASA designed and implemented by a large and diverse group of countries all operating within the same geographical region.
Imagine the real benefits to our local aviation industry of having our entire region operating on the same set of regulations. Perhaps I am missing something, and if so I look forward to someone smarter than me telling me what that is, but in the meantime, whoever our next Federal Government Minister may be, I implore them to consider and research my Pacific Solution.
Jeff Boyd is current Chairman of The Regional Aviation Association of Australia, and also Managing Director of Kite Aviation. The RAAA is a not-for-profit organisation formed in 1980 to protect, represent and promote the combined interests of its regional airline members and regional aviation throughout Australia. The RAAA has 29 Ordinary Members (AOC holders) and 72 Associate/Affiliate Members. The RAAA’s AOC members directly employ over 2,500 Australians, many in regional areas and on an annual basis jointly turnover more than $1b. Its members also carry well in excess of 2 million passengers and move over 23 million kilograms of freight each year. More information including categories of membership can be found at RAAA: Regional Aviation Association of Australia.
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