Truss: Aviation Safety Regulation Review

[Kharon]

RAAA - V

The issues raised in item 'V' (5 in new money) only lightly, almost unnoticeably touches on the very real issues associated with "manuals".

For starters; the very grey and much abused "accepted" or "approved" area is (IMO) one that must be addressed. As it stands, it's open slather and Raffetry's rules. This must be clearly redefined to the FOI dealing. If a thing is to be accepted then a personal 'preference' may be discussed, but ultimately it's the Chief pilot, not the FOI who carries then can. Where an "approval" is to be issued, then the FOI is only obliged to ensure compliance; not dictate how a manual may be structured and what it should or should not contain. This dislocation is most clearly apparent on "FCOM" and "Check lists". Subjective opinion is inflicted under duress lest the delay in obtaining 'approval' become financially unacceptable. For example this ridiculous idea of regurgitating almost the entire AFM into 'Part B' is so wrong, in so many way it's beyond being even remotely sane. Check systems (not lists) are another very contentious issue, some examples bordering on lunacy are actually out there, in use......Tick tock.

The idea of renewing an AOC to include a new, similar aircraft type is a great little earner. The costs are phenomenal, the time taken unbelievable and achieve little in the way of 'improved' safety. It's really just a rip off.

The good idea of 'upgrading' an AOC is another time consuming, expensive operation; another area which needs to be streamlined.

To actually start from scratch and obtain an AOC the patience of Job, the wealth of Croecus and the wisdom of Solomon are essential prerequisites; thats bad enough but the creatures to be dealt with beggar the imagination. The Kiwi's and even EASA guarantee three months and will refund any monies not used during process. Australia – can take up to a twelve month and will require a financial 'top up' at least once during process.

The 'red tape' and 'system' collude so very well, but unlike a tick, which will leave the host when the animal is dead, once CASA latches on – it stays on, feeding on the rotting carcass.

2008 was the time for the demanded changes; the Albo era gave us the McComic system of glutinous, black letter micro management and embuggerance. The Senate and Forsyth report insist there must be real changes. How about it, just once; can we have some value for the unimaginable amounts of money the industry has ploughed into the dead soil of 'Reform'; yes Sir, that is Real Reform with a capitol R.

Toot toot...