Frank:
Well, the AOPAA individual submission goes to a 'page not found' page and the president appears to have memory loss WRT membership numbers and exactly who he represents today, (not 60 years ago).
It would appear the AOPAA link is now defunct….
Perhaps it was…
…the COI query that did it..??
…an extreme overload of the url link due to the many thousands of IOS members interest in what ‘the voice of GA’ had to say??
…sudden realisations that maybe the proposed submission may breach the unwritten, politically correct MOU with FF??
…an IT glitch and it was never intended for the submission to be available for general (IOS) consumption??
Shame really..
...it could have been a good promo for future membership.
The draft submission may have only been five pages and somewhat diluted for impact (i.e. as per the UMOU), but the general premise of the submission was on the whole pretty good...
Dilemma: How are the IOS to do a proper, comprehensive & transparent..
..review, of committed industry stakeholders to the WLR, without documented evidence such as the AOPAA draft submission??
Well it just so happens that I downloaded a hardcopy of the AOPAA draft submission, so maybe some cherry picked paragraphs (again unverified for veracity..
) could be of interest to the IOS review panel…
{Note: Please bear in mind that this is ‘draft’ only and 3rd hand, therefore not to be relied on for veracity & true final AOPAA opinion i.e. hearsay only}
Skipping the standard couple of pages with the usual preamble, organisation priorities..etc..etc; and the problems that AOPAA believe face GA, now and into the future; we finally get to the ‘meat & veg’ section (pages 3-5):
Specifically, the aspects of the regulator that we believe requires change are as follows.
1. Industry consultation. Although communication (and subsequent goodwill) between GA and CASA has improved in recent years, it is a fact that new regulations or changes in regulations are frequently presented to GA as an ultimatum.
A consultative approach is required with those contending with and introducing innovations and technical improvements in all aspects of aviation. This calls for legislative reform.
It is apparent that the CASA legal department, whilst efficient and capable in itself, has an influence which leads to preoccupation with legalistic arguments. Legalism is an arid process. Aviation is an industry of practical and constantly changing technology. Legalism should give way to practicality in the development of aviation.
2. CASA enforcement. The industry is rife with stories of individuals who have been “persecuted” by CASA. Sometimes these cases do sound like individual disagreement “payback” fights, and sometimes problems occur through an area FO making his own interpretation of rules in contrast to everyone else. Sometimes these arguments go on for years at high cost to all concerned. Justice should be seen to be done and the processes
altered to enable that to occur.
3. Aviation should be encouraged by CASA as part of its formal charter. Having its charter limited to ‘Aviation Safety’ encourages negativism, which is widely seen in practice. There is no settled standard for ‘air safety’. This leaves CASA with a poorly identified obligation, and
no obligation to act for the benefit of Australian aviation.
4. Australian LAME training standards are lower than those of NZ. Our training schools don’t align curriculums to industry requirements, and those curriculums vary from state to state.
We should support an Australasian / Pacific approach to maintenance. CASA will base future AMR licences on academic achievement, with insufficient emphasis on experience.
5. Inconsistent CASA policies: CASA must be required to act coherently across all of its officers and offices.
6. To the outside observer, sometimes CASA appears to consist of 4 organizations in one, and each part appears to believe it runs the organization in the style of the Satraps. Those 4 parts are upper management, middle management, the field officers, and the legal dept.
This may be an unfair criticism, but again to the outside observer, CASA often appears to fail to adhere to government directives, or to enforce its own regulations. Different interpretation of regulations by middle management, field officers, and by the legal dept can cause the hapless aviator considerable difficulties.
The 4 parts of CASA make consultation with industry very difficult. Many is the time that various GA organizations have thought to have come to an agreement with CASA, only to find that an agreement has been ignored or reversed by another of CASA’s “parts”. A formalized consultative procedure that overcomes this problem would be very desirable.
7. Constant regulatory changes breed confusion, mistrust and doubt. A safety case should be presented and debated prior to any alteration to the Act, Regulations and other dictums.
CASA’s regulatory changes frequently have no perceptible safety outcome, or certainly none relevant to GA.
8. Pilot licencing: This extensive topic will no doubt be dealt with by others. We limit our comment to suggest that proper accord should be given to foreign training qualifications.
We have seen highly qualified and experienced pilots required to sit for exams in Australia, even when their overseas training was from facilities recognized as the best in the world.
This can be inconvenient and costly for Australian pilots, and can make it impossible for overseas pilots who wish to fly and/or holiday in Australia.
9. Medicals. This is probably the single biggest continuous issue that causes acrimony between GA pilots and CASA. Problems with Avmed include delays in dealing with medical assessments, demanding specialist reports that many would consider unnecessary, and frequent rejection of those specialist reports Avmed has demanded. Demands have become ever more complex and expensive; opinions of DAMEs are often ignored, and opinions of appropriate specialists are often ignored. Avmed has unique medical opinions which sometimes do not agree with overseas experience eg; FAA. Communication between CASA, AVMED and pilots has often been poor. It can be argued that CASA should rely more on its own DAMEs for issue of class 2 medicals, and where specialist opinion is required, CASA should at least listen to specialist opinion.
10. Passenger Insurance: AOPA calls for an industry wide insurance scheme in the manner of the Civil Aviation (Carriers’ Liability) Act (Cth) to be made applicable and exclusively so for all passengers in all Australian aircraft, whether paying passengers, students or otherwise.
11. EASA rules. The GA industry appears to be universally against this implementation. These rules are designed for and suit airline aircraft, not private GA. They are too complex for a typical small GA maintenance organization, and thus add more expense. Most GA aircraft are FAA type-certified. It is perverse and inappropriate to adopt European Rules.
Other Pacific nations, including NZ (which has a thriving GA scene), use FAA regulations. In fact we would do well to align ourselves with NZ, in regulation of individuals (not organizations), training and qualifications, and with inspection authorizations.
{Note: The above would appear to be part of an exec summary, as there were numerous references at the end of each numbered paragraph. Presumably there is intended to be a factual addendum that addresses the individual points more comprehensively}
And finally the money shot.. (i.e. Conclusion):
D. Conclusion.
Without a radical revision, it seems that GA will follow so many other
Australian industries into oblivion, taking jobs, opportunities, and skills with it. The prospective GA pilot faces problems with access to airfields, high costs, and a far from appealing ageing aircraft fleet. The aircraft owner faces a frequently hostile airport owner, shortage of licenced maintenance engineers, rising maintenance costs, increased paperwork, and such uncertainty with both CASA and airport owners that it
is difficult to obtain finance to purchase new aircraft.
Addressing the problems with CASA would go a long way towards easing this situation, as has been demonstrated by NZ’s adoption of the FAA GA model about 17 years ago. It is fact that since then, NZ’s GA has outstripped Australia’s.
We have heard it said that where it takes a wheelbarrow to carry a copy of all regs pertaining to GA, New Zealand’s can be carried in one hand. This may be an exaggeration, but it is not an exaggeration to say that adoption of the NZ regulatory system for GA would improve the prospects of GA’s survival.
Hmm…so that'd be another tick for adopting the NZ regs..
..Ok over to you IOS review panel….
