Yes it is a snow job.
We had a discussion today whether our organisation would make a submission based upon our current view of the in industry. Some of our management team have be in commercial aviation in and out of Australia for over 40 years. The result was we won't, here is why.
In summary, none of us have seen such a distrust of the regulator by the industry...... ever.
The overriding view is that without completely closed sessions between the respondents and the panel, industry will not speak up as to the atrocious performance of the regulator for fear for reprisal by the regulator and its staff.
The reform process has dragged on for so long and overcomplicated so many functions that the actual level of safety has decreased. I have witnessed operations where flight operations staff and compliance managers have spent so much time on a wild goose chase propagated by CASA not knowing how to apply their own regulations.
For a any organisation to put their skin in the game and say it how it is to the panel, that organisation is seriously compromising their own business continuity.
I am all for affordable safety, but compliance with all the wonderful rolled gold policy and procedures, safety systems and mechanisms is simply unsustainable from an economic stand point given the miniscule population base we have to sustain the cost of the operations.
There are no more glaring examples of this than the recent Part 61 kerfuffle which was doomed from the word go and ADS-B compliance, where by the regulator need to make a blanket exemption because the manufacturers of said equipment simply do not have the resources, to equip a very large percentage of the Australian fleet of jets manufactured pre 2007.
The Australianisation of what could be a simple after market fix for many Part 25 certified airframes is nothing more than a WOFTAM, that is costing the very industry that the regulator is meant to support, a fortune for zero increased safety benefit.
Licencing is another issue, in the US I can complete a type rating on a transport category aircraft in the sim. The check airman can issue me a temporary airman certificate I can walk out of the sim centre across the road to the FBO, and jump straight into that aircraft and fly it away on its delivery flight. In Australia, send the paperwork to CLARC and wait 56 days is their current answer....... for what.
The cost to business for that is not sustainable, zero safety benefit.
Unfortunately, in our view the review will end up not fixing anything.
The only real solution is put a broom through the whole place from the board down. Scrap the 25 years of the regulatory reform process and pass a bill in the senate thats says from this date the Australian Civil Aviation Regulations will mirror those of the FAA.
Do they have a higher accident/ incident rate per hour flown? per passenger carried? I would argue not, is it risk based affordable safety..... the answer is yes.