FWIW, the AFAP submission is located here...
http://www.afap.org.au/files/nrteUpl...3A453A25PM.pdf
OVERVIEW
The Federation's submission to the Aviation Safety Regulation Review (ASRR or Review) is structured in accordance with the Review terms of reference. Our submission supports that:
1. All aviation agencies and responsibilities be brought back under the oversight of a single Aviation Minister or, at a minimum, the Director of Aviation Safety should not be able to operate independent of a Board structure.
2. The Civil Aviation Safety Authority (CASA) should be better resourced. That programs and initiatives aimed at greater self-regulation do not come at the expense of internal expertise within CASA. The Aviation Medicine section of CASA in particular is in need of an overhaul to ensure clearer processes and that specified service standards are delivered.
3. The Australian Transport Safety Bureau (ATSB) remains independent and purely safety focused. In line with this, that legislative immunity is provided for flight crew who raise safety concerns and the material gathered by the ATSB during investigations is protected from any other party.
4. Airservices Australia (AsA) improves its methodology to ensure appropriate service responses to rapid changes in traffic movements. AsA should also conduct a review of radio and operational procedures for all airports in G Airspace that involve regular public transport operations.
5. The operations of the Office of Transport Security (OTS) are an excessive cost burden on the industry and that many security screening processes are illogical or unnecessary.
6. The recommendations of Senate Committee Inquiry into Aviation Accident Investigations be revisited and implemented as a matter of priority.
7. In accordance with the International Civil Aviation Organisation (ICAO) Annex 13, information gathered in safety investigations or mandatorily supplied be protected and not shared between agencies.
8. The Regulations be re-written in plain English, targeted at and comprehensible to the industry.
9. The Notice of Proposed Rule Making (NPRM) process be reviewed such that sensible and defensible timeframes are provided and adhered to.
10. Jurisdictional issues regarding Australian aircraft operating in New Zealand and New Zealand aircraft operating in Australia needs to be clarified.
11. Fatigue management legislation encompasses all safety sensitive personnel.
12. Automatic Dependent Surveillance Broadcast (ADS-B) surveillance is implemented in all Australian airspace above 10,000 feet.
13. The upgrade of Instrument Landing Systems (ILS) to Cat 3 at all Australian capital city airports.
14. Flight data is provided with legislative protection that ensures it may only be used for safety purposes and prohibits the use of this information in civil or criminal actions.
15. The recommendations of the 2000 Senate Inquiry into the incidents of contaminated cabin air are revisited and implemented as a matter of urgency.
16. Land use planning around airports be controlled and coordinated to ensure airport capacity is not restricted or that development does not adversely impact on existing operations.
A few quotes from the submission...
Whilst we do not object to a user pays model to cover the costs incurred in providing aviation services, we believe it is necessary to accurately quantify those costs and identify who the end users are to ensure that they contribute a fair share rather than attempting to recover the full cost of service provision from the industry. This applies to the Civil Aviation Safety Authority (CASA), Airservices Australia (AsA), the Bureau of Meteorology (BOM) and Office of Transport Security (OTS). In this light it is somewhat disturbing that CASA reported a $12M profit over the last year.
The Aviation Medicine section of CASA in particular appears to act without due regard for the impact its decisions have on individual pilots and the industry. There is little or no communication about delays in the medical certificate renewal process or transparency about the reasons for delays occurring. Certificate holders are obliged to follow up with the section to find out why their certificates have not been renewed only to receive requests for additional medical reports and tests. The Federation has received numerous complaints from members as to the apparently arbitrary nature of decisions and the bureaucratic and incompetent processing of renewals. These delays threaten the livelihood of our members, and undermine the productivity of the businesses for whom they work. We have previously surveyed members and written to the former Minister on this issue1. An overhaul of the Aviation Medicine section of CASA should be a priority. This would include additional resources, clearer processes, specified service standards and improved training of staff.
The security screening processes applied to pilots are arbitrary and unnecessary. Continually screening pilots before they go airside so that their tweezers are detected before they take control of a jet aircraft with an axe in the cockpit seat beggars belief. Particularly when other airside workers, such as baggage handlers and catering staff, are not subject to the same screening processes. In addition, pilots are also subject to continual “random selection” for bomb trace detection tests in airports. This practice not only inconveniences aircrew, but also devalues the testing regime by targeting testing away from ordinary passengers. These measures appear driven by political and public relations concerns rather than any safety case.