Thank you Ferryman (K9) the PAIN (part) submission and your previous post...
A friend indeed..gives me a perfect launching pad for a long weekend recognition of some of the small business players who contributed to the ASRR in the way of submissions.
While the miniscule malaise hangs, like a 'pea souper', over the whole Forsyth report a lot of the small business (MP) submitters must now be wondering if it was worth the risk to make a contribution..
After all they have now effectively outed themselves to an historically vindictive big "R" regulator...
However throughout human evolution in times of conflict there is only two decisions that naturally present themselves; that is to 'fight' or 'flight' and in this case, for future self-preservation reasons, now is the time to 'fight' or face future oblivion.
Reflecting on the Billson small business speech and the apparent non-conformance our miniscule has to the Coalition red tape reduction policy; I thought I would give a plug to a little known QLD backbench Senator speech (given earlier in the week):
Senator McGRATH (Queensland) (19:16): ...Tonight, however, I want to talk about red tape and the growing need to further reduce red tape in order to support small businesses and the economy. As I have travelled throughout Queensland, I have spoken often about the burden of red tape and have had many occasions to listen to people's concerns about red tape. Just a few weeks ago in Gympie, at a Gympie First forum with Tony Perrett, our Liberal-National Party candidate, I heard firsthand further examples of the damage that red tape and green tape are doing to local businesses and farmers in the Gympie district. Gympie is in my home region of the beautiful Sunshine Coast, and local businesses, community groups and community leaders there are calling for further action on red tape. They acknowledge that the state government has done some sterling work in reducing red and green tape. They also acknowledge that the federal government has also done some fantastic work—which I will come to later—in this area.
But red tape and overregulation are destroying confidence. In a region that needs jobs and economic growth, I—like my fellow Liberal and National Party senators—have a very strong interest in ensuring that these unnecessary barriers are removed. Sadly, it is a big task. The Australian economy is drowning under the weight of red and green tape. The volume, complexity and duplication of red-tape requirements are stifling innovation, investment and productivity. This overwhelming regulatory burden is exacerbating cost-of-living pressures on Australian families and increasing uncertainty about job security and job creation. Australians can no longer afford to waste thousands of hours on pointless paperwork, compliance and regulation. This applies to almost every sector—from small business to big business, from aged care to education, from the not-for-profit sector to agriculture.
Just last year, the Queensland Chamber of Commerce estimated (1) that red-tape compliance costs are equal to 10 per cent of a local independent supermarket's daily takings, (2) that red tape adds an additional $20 to $30 per head to the cost of a wedding at a function centre, (3) that red tape adds approximately five per cent to the average cost of a meal at a restaurant, and (4) that red tape and government fees and charges represent approximately a quarter, 25 per cent, of the ticket price for a regional tourist attraction. A report by Jobs Australia found there were over 3,000 pages of Job Services Australia rules. Indeed, these rules required paper records to be kept of all applications made through Job Services Australia. This left one provider requiring over 330 filing cabinets.
With universal support for a reduction in red tape, the previous Labor government left an appalling legacy of inaction. Kevin Rudd and Labor promised before the 2007 election that, for every regulation they brought in, they would abolish one regulation. You might think, 'That sounds promising'—and Labor did abolish over 220 regulations. You might think, 'That's pretty good; they probably get a gold star for that.' But, in little more than 5½ years, Labor introduced 975 new or amending pieces of legislation and over 21,000 additional regulations. A current secretary of state in the UK, Eric Pickles—whom everyone here should know I have a bit of man love for—does not have a one-in one-out policy. At the moment his record is that, for every regulation he brings in, he is getting rid of eight regulations. I think that sets the benchmark this government should be aiming for in getting rid of red tape.
On Labor's watch, Australia's ranking in the World Competitiveness Yearbook declined from seventh in 2008 to 15th in 2012, and ABS data showed that the country's productivity fell by three percent between July 2007 to June 2012.
In contrast to Labor's record of all talk and no action, the coalition government is ready to deliver a paradigm shift in Australia's approach to regulation. Already, this government removed over 10,000 pieces and 50,000 pages of legislation and regulation during its first-ever repeal day in March this year. This historic event alone has delivered savings of over $700 million in compliance costs.
Pull out your diaries, get very excited about this, tell your kids and your grandkids and tell your staff: another very exciting repeal day is coming up, scheduled for 29 October. Josh Frydenberg, the Parliamentary Secretary to the Prime Minister, is leading the charge on this. I think he deserves a lot of praise and a proper gold star for the work that he is doing to reduce regulation and red tape. This is just one part of the coalition government's red tape reduction program.
The government is committed to cutting over $1 billion in red and green tape each year. To do this, the government will focus on five key areas. Firstly, we are going to tackle the volume of regulation, which is clearly already too high. Secondly, we are going to work to eliminate the extensive duplication and regulatory overlap that exists between the different levels of government. Thirdly, we are going to improve the quality of consultation between government and those to be affected by any new regulations. Fourthly, we will ensure that there are rigorous and mandatory post-implementation reviews to determine how effective new regulations have been. Fifthly, we are going to ensure that regulators are at all times transparent, accountable and efficient in administering regulations.
Regulators are at the front line of this debate and it is our strong view that we have to bring them along as part of any sweeping new cultural change. Australia is home to over two million businesses, many of them family-run operations that create jobs and opportunities in our communities. I, like my coalition colleagues, want to see a strong and prosperous Australia. These important measures to reduce red tape will deliver unprecedented changes to the regulatory landscape in Australia. They will help those over two million businesses and help create jobs.
I have previously made a commitment to personally monitor our progress of red tape reduction to keep the government, which I am a proud member of, and my party, the Liberal Party, on track. I repeat that commitment today. I will be doing an annual red tape report. I will further update the Senate on this progress at a later date. This area of reform is critical for Australia's future. Done correctly, the government will support growth, build confidence and create an environment full of opportunity. This is certainly an outcome that I hope all of those who dislike red and green tape—those on the other side might like it—would agree with.
Perhaps those IOS members presiding in QLD should give the good Senator some input for his annual red tape report...
Moving on and for those owner/operators (a Small/Medium Enterprise {SME}) the stats quoted by Billson are contained in the following:
The Australian Industry Group - NATIONAL CEO SURVEY - Burden of Government Regulation
A quote & table from page 13 of the AIG survey document:
The Commission included in its report the results of a Council of Small Businesses of Australia (COSBOA) survey of 87 SMEs, which showed that 82% of the respondents felt that SMEs face disproportionately high compliance costs, while 44% indicated that they do not have the skills or capacity to understand their compliance obligations (Chart 13). These results agree with the findings in Ai Group’s surveys that suggest that some regulatory arrangements (e.g. payroll tax, GST as noted above) are more likely to place a medium to high cost burden on SMEs than on larger businesses. In addition, the Commission noted that;
“Australian studies have found that small businesses [alone] spend, on average, up to five hours per week on compliance with government regulatory requirements and deal with an average of six regulators per year”.
Chart 13: Small businesses supporting different treatment, percentage by reason
Probably something we all know but basically put the regulatory burden imposed by CAsA's RRP has had (& continues to have) a far greater impact on Small/Medium owner/operators than on the larger airline operators. Perhaps this impact could be one of the causal chain of factors that has seen the demise of 16 regional airlines in recent years...
So to the ASRR MP submissions and starting with
#sub220 - Michael Tucker. Mr Tucker's sub was largely in support of the AOPA submission but had some salient points worthy of consideration...
:
Submission to the Aviation Safety Regulation Review by Michael Tucker
I wish to add my support to the submission by AOPA and expand on 2 points
1. I think we all agree that one of the major problems of the current regulations is the content of Reg 206 defining commercial operations and that the fix is the new regulations.
I quote from CASA website on CASR Part 135 Australian air transport operations - Small Aeroplanes
" In 1999, CASA was directed to "minimise the distinction between charter and Regular Public Transport (RPT) operators". To address this, Part 135 will set in place a common level of safety for operators who are authorised to provide 'Air transport operations' - an amalgamation of current charter and RPT operations and standards - in order to carry Passengers in small aeroplanes. The safety level applies irrespective of whether an operation is scheduled or non-scheduled as described by the International Civil Aviation Organization in Part I of Annex 6.''
and we agree that the same level of safety should apply irrespective of whether an operation is scheduled or non-scheduled or is a closed charter or open to the public - BUT for a given aircraft size.
we note that no amount of over regulation will make a flight in a 4 seat single engine aircraft or a 10 seat twin as safe as one in a 30 seater or a 737
We believe that CASR 135 with the associated maintenance regulations are over the top, too onerous, too complex for small aircraft and would be unworkable for the smaller operators and remote operations
We believe that we should adopt/copy the New Zealand system and regulations of
CAA Part 135 - Small Aircraft & helicopters - < 9 seat & < 5700kgs MTOW - safe
CAA Part 125 - Medium Aircraft - 10 - 30 seats or SEIFR ops Safer
CAA Part 121 - Large Aircraft - > 30 seats Safest
CAA Part 119 - Air Operator - Certification
with no distinction between scheduled or non-scheduled or whether it is a closed charter or open to the public.
2. We would also like to reiterate the concerns raised about CASA's enforcement approach and methods. Their handling of Barrier aviation AOC suspension and others was unconscionable, the timings of their actions seem to occur when they will do most harm and without notice.
For justice to be seen to be done we believe Sect 30DC of the ACT should be amended to enable CASA to give a direction that will stop that part of an operation that is a "Serious and imminent risks to air safety" and a "show cause notice" should have to be issued before the AOC is suspended
The possibility that a company can be closed down unjustly without a chance to rectify the problem is just "un Australian" and does nothing to encourage investment in Aviation.
I support AOPA's call for an effective ombudsman reportable to the Minister and the CASA Board.
Yours sincerely
Michael Tucker
MD Tasfast Airfreight, 33 years aviation experience inc RPT ops, own & operate 6 x PA31-350
[email protected], 0359444375, 0412365397
Good start Mr Tucker anyone else care to contribute???
MTF...
