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Old 22nd May 2014, 09:21
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Sarcs
 
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Parting shots from AMROBA

Heard a rumour that the Murky Machiavellian one is currently vetting the WLR report... If true MM here is some parting shots to consider, while reading the draft WLR report and the CVs of the potential future DAS, from AMROBA's latest newsletter...
Regulatory Structures GA
Most governments are against imposing additional requirements on the public and individual participants but few achieve such an outcome.

Over the last decade we have seen a change from outcome based requirements to prescriptive regulations that also shifts the burden of proof from government to industry.

Standards are confusing to say the least.

Increasing unnecessary paperwork is killing the basic foundations of aviation, general aviation.

Splitting the maintenance capability between AOC pax operations and others was and is a backward step.

Nothing is being proposed to reduce the regulatory burden on the non airline and airline sectors. Changes introduced since 1991 has seen private VH registered aviation continue to decrease.

The regulatory changes has seen many shift to non VH registered aircraft where there is less regulatory burden.

Same aircraft, two different standards applied.

Is the safety of aviation affected by the type of person that wants to become a pilot, engineer, etc. or is it affected by the skills of these people.

New Zealand has a “fit & proper” person criteria that an aviation participant must meet prior to obtaining a government issued licence, certificate or approval. Why? Because under the NZ Aviation Act, the CAA(NZ) is also responsible for security matters.

So what is the best structure for GA?

Pilot licensing should be no different to the principles used in North America where there is a thriving non type certificated aircraft industry.

The legislation should be minimal and requiring CASA to promulgate minimum safety standards that this sector would need to comply with. This sector is all about individual standards not organisations.

Getting the structure right is important.

The regulator may not have the skills or knowledge necessary to design and implement an alternative policy instrument. For example, in some technical areas regulators and policy makers may be influenced by the desire to specify highly technical standards, where they have very specific knowledge.”

Before regulatory change happened in aviation post the Authority’s HO move to Melbourne, Australia had the right structure but requirements had two flaws.

1. Orders were not changing quick enough to keep up with changes needed by industry—basically waited for ICAO standards to change.

2. Many requirements did not have a “head of power” in the legislation.

(my bold)The new CASA CEO will need to design a much better structure than the current system. Of course, his/her direction will be driven by the ASRR recommendations.
And perhaps a parting QON (in bold) for our STBR DAS on the subject of EASA v FAR and the possible adoption of the NZ regs...


"...During the Aero Friedrichshafen event (April 9th-12th) EASA made an announcement which came as a surprise to many people – even to those members of the GA Safety Standards Consultation Committee Sub Group. No one – not even NAAs had any prior knowledge of the EASA announcement.

Simpler, lighter, and better rules for General Aviation.

The Agency is committed to changing the way it regulates GA and this new approach comes from the Executive Director (Patrick Ky).

The presenters said transposing CAT (Commercial Air Transport) rules for GA was wrong and the aim now is to make the rules risk based and proportionate which is in line with the requirements established in the GA road map.


Furthermore, EASA wishes to simplify the operations and administration procedures.


Although it was originally decided not to have a specific GA department, EASA is now in the planning for a GA department, the aim of which is to establish a focal point inside EASA for GA, which has accountability for the future health of GA across Europe.


The time frame for this work is 2014 to 2017. So why did we follow EASA?..."


Oh and MM while vetting the WLR draft report and potential DAS CVs, here is an IOS QON, that I know will be dear to your heart...


Q/ Were we the first ICAO signatory State to submit notified differences to, the freshly minted, Annex 19 i.e. SSP?? (reference pg 96-97 here)

Much more to follow...


Hot off the press...


Panel to submit air safety report

A MUCH anticipated federal government report into aviation safety is expected to be with Deputy Prime Minister and Minister for Infrastructure and Regional Development Warren Truss next week.

Panel chairman David Forsyth and fellow members Roger Whitefield and Don Spruston have been working on the review since last year to look at how well Australia’s regulatory system is positioned globally, and have ­attracted a huge response from the industry.

“We’re still doing the final ­editing and we’ve just got a ­couple of issues where we’re double-checking some information, but basically we’re ready to go,’’ Mr Forsyth told The Australian yesterday.

He said the committee had been briefing Mr Truss and the department over the past six months so both were aware of the general thrust.

Mr Forsyth said the committee was happy it had covered the main issues according to the terms of reference and believed it had captured the important ­issues expressed by industry.

“We think we’ve made recommendations that will help to fix those issues,’’ he said.

“Of course, the hard job is for whoever the person is that takes on the role of (CASA director of aviation safety) — it depends on who that is, and how they go.

“But hopefully we’ve given them a bit of a blueprint so they can fix the major issues that have come up.’’

CASA and regulatory reform topped the list of industry concerns in almost 270 submissions and up to 20 supplementary ­papers.

Mr Forsyth said the “major irritant of the regulatory reform program’’ was not all down to CASA and there were also problems in areas such as the way Australia drafts laws.

The committee chairman reiterated his early comments that there was no silver bullet for regulatory reform but said the study had recommended the path it saw as the best.

“Each of the options has pluses and minuses, and we think the one we’ve recommended is on balance is the best way forward,’’ he said.

Last edited by Sarcs; 22nd May 2014 at 15:01.
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