A good point you make SIUYA, 2 conservative governments with the same desire to reduce red tape and therefore cost to industry stakeholders. However that is where the similarity stops...
The UK initiative started with the govt putting down the GA red tape challenge (RTC)...
CAP 1123quote from the CEO of the CAA
The UK General Aviation (GA) sector finds itself under increasing strain as costs of operation rise due to fiscal pressures, a greater focus on environmental issues and the application of a European regulatory framework, and perceived over regulation by the CAA. Too much prescription in the rules and a lack of proportionality have both impacted adversely on the sector.
The Government's GA Red Tape Challenge (RTC) was both timely and welcome. It has given my colleagues and I at the CAA a powerful reminder that we need to inject more pace into how we introduce a more proportionate and risk-based regulatory regime for the UK GA sector and push harder for change across Europe to meet the demand evident from
the GA community.
Hmm..certain parts of the following sound very familiar..
A fundamental theme running across the Red Tape Challenge was communication between the CAA and the GA community. Many felt that the CAA’s website could be improved and accessibility of CAA guidance made better. The Flight Crew Licensing: Mandatory Requirements, Policy and Guidance2, CAP 804, attracted particular criticism.
Another common concern was that regulations appeared to be introduced without due consideration of how they might impact on the GA sector. Many suggested that before any new regulations, interventions or guidance are introduced, their impact on the GA sector should be assessed and suitable changes made to reduce the impact, without compromising safety.
They asked that regulatory interventions should be risk-based, proportionate and the minimum necessary for safety.
There was naturally a strong desire to see greater efficiency from the CAA and a more customer-centric approach.
There was a general dissatisfaction with EASA rules and a perception that the CAA is prone to gold-plating these rules. The CAA has already responded publicly to this challenge. The CAA announced on 4 June that it is "committed to identifying and eliminating any such gold-plating".3
Interesting that the PBR approach (SIUYA post) is apparently strongly backed by EASA & ICAO..
Mark Swan (
CAP 1184):
"...Performance-based regulation (PBR) is central to EASA's and ICAO’s future plans. The CAA is working closely with our international colleagues to shape how PBR works in practice. The UK industry has fed back that it believes PBR should make the CAA more proportionate and targeted, have a greater degree of commercial awareness and be more transparent about how money is spent..."
And the timeframe/progress report so far for the UK CAA PBR initiative
We aim to adopt a full PBR approach by April 2016. So far we have established:
- Performance-based oversight – A new process for carrying out safety oversight based on known risks and safety performance.
- An initial total aviation risk picture and a series of prioritised risk mitigation activities with associated safety projects.
- The requirements for an integrated safety risk reporting and management system to better inform strategic decisions made by the CAA Board, and the allocation of resources to act on them.
- The key governance fora (a Safety Action Group and Safety Review Board) that will underpin the CAA’s internal Safety Management System.
Great initiative but unfortunately it doesn't really help us much...
However before we all start drowning our sorrows in despair or jumping the ditch to NZed, please reconsider the rather optimistic message from the RAAA newsletter. Then consider the following recent RAAA submission to the PMC (cc'd to the miniscule):
RAAA SUBMISSION - CUTTING RED TAPE
Table of Contents
I. RAAA BACKGROUND 1
II. EXECUTIVE SUMMARY 3
III. EXPENSIVE, UNNECESSARY CASA MAINTENANCE VISITS OVERSEAS 4
IV. CASA AUDITS 4
V. CASA APPROVAL OF MANUALS 5
VI. DRUG & ALCOHOL PROGRAM 5
VII. OVERLAPPING BUILDING CONTROL REGULATIONS 5
VIII. FAILURE TO UP-DATE NOISE CURFEW REGULATION TO
RECOGNISE NEWER, QUIETER AIRCRAFT 6
IX. LACK OF PERFORMANCE STANDARDS FOR CASA REGULATORY
SERVICES 6
X. MEDICAL RENEWALS 7
XI. LETTERS TO DAMES, PILOTS AND AOC HOLDERS REGARDING
COLOUR VISION DEFECTS (CVD) 7
XII. ENGLISH PROFICIENCY FOR STUDENT PILOT LICENCE 7
XIII. SIMULATORS 7
XIV. CONCLUSION
II. Executive Summary
The Government has published the document “The Australian Government’s Guide to Regulation” to help policy makers in the future ensure that regulation is never adopted as the default solution, but rather introduced as a means of last resort(1). This initiative is welcomed by the RAAA but does not address the excessive regulatory burden currently
borne by industry.
The examples below are indicators that historic government monopoly and service behaviour is having a significant and deleterious effect on the regional aviation industry’s ability to grow and thrive.
Such behaviours must be expunged and the dead-weight of the government aviation bureaucracies lifted from an industry that is essential to Australia’s economic and social development.
Excessive red-tape only serves bureaucracies and throttles the industries that actually pay the taxes that keep government functioning.
Aviation is particularly susceptible to excessive red-tape because it is a highly regulated industry. Overblown safety and security arguments are often used to enable increases in red-tape and regulation for zero safety or operational gain.
The RAAA hopes sincerely that the government’s red-tape review is a serious attempt to release industry, and aviation specifically, from systems that serve no-one except the people administering them.
Given the losses or poor margins experienced by most parts of the aviation industry action on government red-tape can’t come soon enough.
Considering the above, & the fact that the previous RAAA Chairman is now sitting on the FF board, does anyone seriously think (for a moment) that the RAAA are just going to chuck it in cause we currently have another small speed bump (i.e. an ailing miniscule)??
Put your feet up Minister, give the job to Barnaby and Fawcett and let loose the dogs of war.
TICK..TOCK miniscule
ps Love the CVD para..
Whatever the merits of any arguments about CVDs, the letters mentioned above were totally inappropriate in the way they attempted to shift responsibility to assess the medical risks to the letter recipients. CASA issues medical certificates and industry participants are entitled to rely on those certificates. Creating uncertainty in this way, when supposedly new medical evidence has not been tested and the manner in which implications when tested might be applied to aviation had not been discussed with or forecast to the industry, was entirely unacceptable.
When this argument is juxtaposed with the fact that a closely related issue is being tested currently at the AAT, the reasons and justifications for the CASA letter appear problematic, possibly an abuse of process, and out of step with the Government’s guidelines for cutting red tape.