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Old 19th Jun 2014, 00:22
  #1977 (permalink)  
Sarcs
 
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The Grey embuggerance.

Trolling (as you do..) through HoR Hansard I came across an adjournment speech from the Member for Grey, which perked my interest...

"...Mr RAMSEY (Grey) (21:05): Tonight I want to bring to this place the plight of and challenge for the air service in Coober Pedy in the north of my electorate..."

Now I had been monitoring this story for sometime, reference article example...

Runway changes could hamper regional aviation and force airlines including Rex to curtail outback services


...but the last I'd heard CAsA had for once seen common-sense and this seemed to be reinforced in the context of the Member for Grey speech:
..When these amendments were made, in 2012, I thought common sense would get the best of it—that we would not have to worry about this, because no-one could be so stupid. In fact these aircraft have been landing on this strip for probably about 15 years, without incident. One would think that with that kind of record it should not be all that hard to grant the same exemption that the aircraft have had for all of that period. I have had numerous conversations with Rex and CASA over this issue. In their latest letter CASA assure me of the following:

I would like to reiterate that the widening (upgrading) of Coober Pedy's runways is not required, unless the aerodrome operator wishes to do so as a business decision …
OK so what is the Member's point?? Well the next 2 paragraphs tell the story...:
But CASA are telling Rex, the operators of the aircraft, that they need to go back to Saab and develop a flight supplement that will allow for the narrow-runway landings. They have ordered some simulator tests, and that sounds all reasonable and fair, except that Saab no longer make aeroplanes, so you can see that they may not be totally interested. My point is that if this costs Rex a significant amount of money to develop—maybe $100,000—I do not think they will retain the service into Coober Pedy.


So while CASA are telling us there is nothing to worry about, I am deeply concerned. If the development of the flight supplement with Saab is to cost more than the route is worth to Rex, the flight service will cease on 12 February next year. I continue talking to CASA and they say that it will all be well in hand and will all happen. I just worry about the sands of time drifting out. This has been going since 2012. We are now only seven months away from February, so it is of great concern to me that things are moving too slowly.
The shades of Grey and the parallels with the CVD embuggerance started to steam up like a hot pile of elephant pooh, you know 15 years of safe ops on an exemption etc..etc..

...So I then referred to the REX ASRR submission where I found this:
...It is understood that one of the aims of the regulatory reform program is to enact safety outcome based regulations rather than prescriptive regulations. Rex supports the concept of safety outcome based regulations but unfortunately does not always see this carried out in practice. For example, the proposed amendment to CAR 235A effectively removes the ability for CASA to facilitate air operations where equivalent levels of safety can be achieved. It does this by prescribing the method of compliance rather than the safety outcome required.

The new CAR 235A will require operators using runways narrower than the arbitrary default standards set by ICAO to have procedures for the use of narrow runways set out in both the aircraft’s Aeroplane Flight Manual (AFM) and the operator’s Operations Manual. If the manufacturer does not supply the necessary narrow runway certification then the operation is prohibited. For the Rex operation, SAAB has indicated they will not engage in further flight testing to gain narrow runway operation certification to comply with the ICAO aircraft reference codes (ARC). The SAAB AFM does currently make provision for narrow runway operations, however they are not in accordance with the mandated requirements of the CAAP and therefore not acceptable under the proposed new CAR 235A. The new rule will prohibit Regional Express Airlines, Pel-Air Aviation and Air Link from operating into airports with narrow runways thus denying essential air services to some remote regional communities.

For Rex, this will prevent operations to Coober Pedy where it and Kendell Airlines have operated continuously since 23 August 1986. Coober Pedy Airport has a 30 metre wide runway with a homogenous 18 metre sealed centre section and to date CASA has seen fit to issue Regional Express with an exemption (CASA Instrument EX37/12) from the requirements of the current CAR 235A. The new prescriptive CAR 235A will remove CASA’s ability to issue such exemptions in the future and will prevent Rex from operating to Coober Pedy after the exemption instrument expires on 28 February 2015. This is despite more than 27 years of demonstrated safe operations...
No guesses to who has been briefing the Member for Grey and expand the safety case to 27 years...


That then got me thinking what's with all these recent FF moves to suddenly endeavour to become compliant with the ICAO SARPs??


I then decided to refer to the relevant SARP for Airport runway width requirements i.e. Annex 14 Ch 3 para 3.1.10.





Hmm.....so maybe (like the CVD 30 yr un-notified difference) FF were feeling vulnerable because they hadn't notified a difference to para 3.1.10??


So once again off to our convoluted 97 page AIP GEN 1.7 (H18/14) and x-referenced with the 84 page 2011 version (H12/11), & that was when the penny began to drop...


First latest '14 ND
H18/14 Para 3.1.10 - The existing standards will be strengthened to ensure code 2, 3, & 4 aircraft are operated from fully compliant runway widths…
You kind of think well why bother with the notification?? Then..
H12/11 Para 3.1.10 - Australian legislation permits some variation on runway width.
Wonder how many other little known NDs the FF ICAO compliance crew have been tasked to eradicate??

Hmm..here's a thought for the rumour mill.., maybe the FF numbnuts have got wind of an upcoming surprise (special audit) from the FAA/ICAO??

MTF...

Last edited by Sarcs; 19th Jun 2014 at 08:48.
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