Hey Rob how about having a chat with Phil to get a feel for how your current conciliatory approach will eventually end in tears while dealing with the current toxic FF culture. I'm sure he will enlighten you...
See pages 6-7 & appendix one here:
ASRR Recommendations – Responses from AAAA
"The more concerning issue, however, is that the current members of the CASA Board thought it appropriate to write to AAAA while the review process was still in train.
The apparent intent of the CASA letter appears to be to intimidate a representative body participating in the Aviation Safety Regulatory Review and to undermine the validity of the AAAA submission.
The willingness of the CASA Board to actively participate in the ‘politics’ of the ASRR process should sound clear alarm bells to the Minister and anyone else interested in the appropriate discharge of responsibilities by the current CASA Board.
Apart from its factual errors, the CASA letter served no purpose other than to provide further evidence to the ASRR Panel (if more was needed) of the very problems of poor culture, bullying and intimidation highlighted in many of the submissions – with clear evidence – to the ASRR."
Also RR FFS ask PH what AAAA's considered opinion is on what should be happening to Part 61 (in it's current form). Or if you prefer read the following:
CASR Parts 61, 141, 142
Recommendation 31 says that all regulations not currently made should be reshaped into a three tier structure with the aim of gaining significant simplification and thereby improved compliance.
AAAA strongly believes that the current CASR Parts 61,141 and 142 should again be deferred for implementation and should be the first regulations subject to the ASRR Recommendation 31.
The simple fact that CASA have only recently released critical parts of the Manual of Standards for industry to consider, and that there is ongoing conjecture from within CASA about the transition of roles such as ‘approved pilots’ in aerial application, suggests that any move to make the regulation ‘active’ by September is simply premature.
The complexity of the writing of the CASR 61 itself works against compliance by being so difficult to understand. Consider the difficulties when trying to trace the requirements for training, licensing and, critically, privileges of each licence/rating/endorsement across a number of licences (eg CPL, low-level rating, application rating, firefighting endorsement, etc), having to manage both the regulations and the MOS of over 1500 pages.
"In addition, some areas of the MOS that cover competencies for aerial application and firefighting are not acceptable to industry in their current form and require further refinement. It appears that a range of prerequisites suggested by industry have not been included, nor has adequate recognition of prior learning for an application pilot, for example, to attain a firefighting endorsement."
To ask industry to absorb and be functionally capable of working with over 1500 pages of regulations and standards when the latest requirements have only been released in the last few weeks makes a mockery of any implementation ‘strategy’.
For those companies having to transition to Part 141 operations so as to be able to provide the critical role of training for aerial application sector within the current timeframe is another problem. It is highly unlikely that the companies will be able to develop the appropriate operations manuals now required under CASA’s ‘simplified’ approach within the current timeframe due to the need to develop curriculum and competency training syllabus and assessment procedures that are in line with the new Part 61/141. The flight test requirements were only released in the last few weeks and have NOT been the subject of industry consultation – as is the case with much of the recent MOS related publications.
It is also highly unlikely that CASA will be able to assess and accept the various requirements mandated in the MOS and Part 141 before the commencement of operations under the new regulations.
The only logical outcome is to put the current Part 61/141/142 on hold until it can be subject to the ASRR recommendations. As an absolute minimum the September start date should be deferred for at least 12 months to enable training organisations to absorb what has only recently been released...
Here you go here is the contact details webpage:
AAAA contact
MTF...
