DO or DI?
While we are discussing CAO 48, disallowable instruments, motions and the like, I wonder if the WLR panel will have the nouse to look at other Disallowable Instruments (DI) which are or, have been 'rubber stamped' and passed through the system, unscathed.
There are 120 DI on the list at the moment; ranging from 'means of providing surface wind' to the 'number of cabin attendants', all manner of issues presented to the rubber stamp factory. Couple of troubling things;
That there is a need for so many exemptions must be one of the clearest signposts to a regulatory suite which has not kept pace with, or is incapable of supporting 'modern' operations. Prescriptive, complex and ruthlessly micro managed rule sets create the need for operational 'exemption'. Heaven only knows what the 'real' cost of this system is. A company wishing to stay 'legally safe' but operationally efficient needs to draft a proposal, this in all probability will involve operational and legal advice, time and money. Then the 'thing' has to go to the administrator and be processed through reception, recording, evaluation, drafting, legal and a final approval system, all fully documented. Then the 'thing' is off to parliament, through yet another expensive process, before the rubber stamp is used and the operator eventually receives a piece of very expensive paper granting an exemption against the 'rules', as writ.
No doubt the system is above board and the exemptions 'made' legal; but I wonder, when was the last external, independent audit of not only the system but some of the decisions. Some of the 'justification' for approval is mind bending, convoluted and abstruse, to say the least.
I've no objection to 'operations' having exemptions, or instruments, but would question the need for so many. Perhaps a WLR panel member could question why there is a need for so many and the real costs. When you start to add up the costs involved to produce a request for 'instrument', the cost of submission, the cost of process to get the 'thing' to parliament, the cost of parliamentary rubber stamping, all paid for by the travelling public (one way the other); you end up with some very scary numbers. Add this annual cost to the cost of regulatory reform, whichever way you look at it; the numbers are truly concerning especially when weighed against the progress made thus far.
Perhaps the WLR panel cost added to the cost of all previous parliamentary costs for inquiry should be tacked on at the end of a long column of figures which could then be used to define the absolute and abject failure of the great Australian regulatory reform program.
FAR or NZ CAR; pick one and lets be done with it. We could save a packet and send the visiting firemen home; for a rest, after their strenuous labour down-under, in the land of the long week end.
Selah -and/or Tick tock
Last edited by Kharon; 6th Jan 2014 at 20:19.