Submission update: While we continue to wait for the miniscule to make his next move..
..there is a couple more submissions that have come to light..
:
Sport Aircraft Association of Australia - Submission to Aviation Safety Regulation Review
The SAAA submission IMO gets the IOS tick of approval..
Coupla quotes...
"...Civil Aviation Safety Authority (CASA), Airservices and the Australian Transport Safety Bureau (ATSB) are supposed to work together to administer aviation in Australia. Is this effective? The answer, in our opinion, is it could be a whole lot better. It is our opinion this may be because of the lack of a functional government mandate for the management of aviation in Australia...
...Other areas of CASA appear to be suffering high staff turnover, or have staff that cannot differentiate between commercial & private operations, and/or have no-one in charge willing to make any decision for fear of repercussions from other departments. CASA is therefore unable to manage outcomes in our sector of aviation (that have been identified by us and the Associate Director of Aviation Safety as desirable safety outcomes) that are well within the capability of the SAAA to deliver...
....then had to start all over again with a new CASA staff member who has not been fully briefed. This leads to delays that are measured in years due to corporate knowledge at CASA being lost in the transition of staff. Meanwhile, CASA demands management stability of our organisation as a condition of a small amount of funding for the hard work that we do for aviation safety, but is not able to offer us the same in return..."
Interesting take on ToR 2) and the Oz SSP :
a) The State Safety Program (SSP)
i) While there is a published SSP document which as of November last year is out of date due to the implementation of Annex 19.
ii) The document reads like a text book about SMS in parts but mostly it reads like a self-reflective feel good novel.
iii) The ICAO SSP concept as articulated in Annex 19 is the basis of how a State administers aviation oversight and reporting at the state level and internationally to ICAO.
iv) Such a SSP Program Document should articulate who is accountable and in the sub parts who is responsible for the component parts. The Document should state how the Program will work, what the component parts are and the overall performance goals are set and measured. It will state the role of CASA and other Departments in the overall delivery.
v) If an effective SSP existed any inter departmental ‘turf wars’ as we have witnessed in the past few years will be evident immediately and action taken to remedy the situation.
I could go on but because it is well reasoned and easily readable (14 pages) I'll let those interested do the reading..
So finally to the SAAA recommendations:
1) Minister intervention to force timely and correct change;
a) The SAAA requests CASA revisits the Project CS 13/01and apply some of the logic that allowed non TSO EFB in the cockpits of all the high and Low Capacity RPT aircraft in Australia.
b) Resource and direct a project to consider the application and empower the SAAA deliver the Flight Training project it initiated in 2008.
c) Resource and direct a project to consider SAAA to manage the delegations on behalf of CASA necessary to deliver trained Authorised Persons for the issue of Certificates of Airworthiness for experimental aircraft.
d) Resource and direct a project to consider S SAAA to manage the delegations on behalf of CASA necessary to issue Maintenance Authorities to members.
e) Mandate that all Amateur Built Aircraft builders and operators operate within a management stream of SAAA or a like organisation so that adequate standards are maintained and thus funds are available to deliver the proposed programs.
2) The Government review the State Safety Program (SSP)
a) The SSP concept as articulated in Annex 19 is the basis of how a State administers aviation oversight and reporting at the state level and internationally to ICAO.
b) Recommend the Government overhaul the SSP and use it to administer all aviation activities in Australia not as a spectator role it takes at present.
Next was the Warbirds contribution, which was really a
'in support of' submission but does make some worthy points:
Australian Warbirds - Submission to the Aviation Safety Regulation Review Panel
"...We strongly believe that, as part of its charter, CASA should be tasked with the support and promotion of Australian aviation. This would include but not be limited to protection of the nation’s airport infrastructure from overzealous or neglectful councils and landlords, the crafting of regulations that are conducive to investment in the industry and which eliminate a large amount of the red tape that currently exists, and efforts to bolster ties and cooperation with other nations and their respective national aviation agencies. With its sole stated purpose currently being aviation safety, CASA is in a perverse way fostering an environment that is in our opinion both less safe and overly consumed with regulatory compliance masquerading as safety. As more emphasis is placed on paperwork and more compliancy requirements pile up as part of the everyday operating demands of Australia’s general aviation sector, the incentives increase on otherwise professional businesses to cut corners and/or conduct things "off the books". These requirements are also leading to a dramatic increase in costs for operations such as flight instruction with very little or no benefit...
...The current environment has deteriorated to the degree that the general aviation community on a whole has lost faith in CASA in its present form to effectively regulate. Where a clear, well-understood, and accepted foundation for regulations should exist; we instead have a disjointed and inconsistent model. As a solution, the Australian Warbirds Association feels adoption of the New Zealand regulatory model for general aviation presents the best way forward. This will not solve all the problems currently affecting Australia’s aviation sector, but it will in our opinion put us on the right track. New Zealand, in contrast to Australia, has a vibrant aviation community. We hope to see the same here.."
Again (IMO) the AWA submission gets the IOS tick of approval...