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Old 17th Oct 2014, 02:18
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Sarcs
 
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AF sub - “not acceptable under any circumstances’’ except do nothing.

Kudos to SC from the Oz for following up on last week's article - Ex-CASA chief blasts Angel Flight curbs - with this...Angel Flight rails at ‘discrimination’...

It would appear that MT has combined forces with another former heavyweight to help author the 80 odd page AF submission addressing the FF DP1317OS...:
ANGEL Flight has urged the Civil Aviation Safety Authority to abandon its “proposed regulatory discrimination’’ in a lengthy submission that warns any move to make the charity organisation a regulator or part of a regulated authority would be unworkable.

The organisation, which has the backing of senior aviation ­figures such as former CASA boss Mick Toller and former Virgin Blue chief pilot John Raby, lodged an 80-page document that urges CASA to review its own licensing and maintenance regime if it ­believes it is inadequate.

The submission is in response to a CASA discussion paper into safety standards for voluntary community service flights such as those operated by Angel Flight carrying disadvantaged regional patients and their families to medical centres.

CASA stirred up a hornet’s nest in regional Australia by expressing a preference for an option that would see an organisation formed to assess and authorise ­pilots, require proficiency checks and assessments and approve aircraft types. It ­argues it could monitor safety standards under the system without imposing undue regulatory burdens such as an air operator’s certificate.

It has since emphasised that it may not proceed with any changes that would affect Angel Flight but made no apologies for canvassing safety issues.

Angel Flight’s submission rejected all options as “not acceptable under any circumstances’’, except the one to do nothing.

It noted that there have been no safety issues identified by CASA in 84,500 flights {Hmm..flight hours maybe Steve??} flown by volunteer pilots in the 16,900 flights Angel Flight has facilitated since its ­inception. It said the ­organisation “could not and would not” become a regulatory authority or part of one.

“Angel Flight has approximately 6000 volunteer drivers and pilots,’’ it said. “To become ­either a regulator or a regulated aviation body would be unworkable due to the expense, skills and training required to regulate, administer, or comply, as an aviation organisation, with an independent aviation regulator, particularly in circumstances where the pilot volunteers have a broad spectrum of licences, skills, endorsements, ratings, and where the different aircraft types would number hundreds.

“Moreover, where pilots and their aircraft are dispersed across the entire nation, often in remote locations, the training and checking regimes would be a financial and practical impossibility: that is the job of the government regulator, the Civil Aviation Safety Authority — not a registered charity.’’ The submission said the charity’s mercy missions were private flights operating under rules set by CASA.

If CASA was satisfied with its current standards, there was no need to create a special category dedicated to the type of people flown or the purpose of the flight.

“Angel flights are not ambulance flights,’’ it said. “They are not commercial flights. They are not airline transport or RPT flights. They are private flights conducted under the rules relating to such flights as set by CASA. Provided pilots comply with these rules, there is no need for intervention. If pilots fail to comply with relevant rules, then they are subject to the administrative, regulatory and/or criminal sanctions that apply to them as individuals.’’

In his submission to CASA, Mr Raby accused the authority of a flawed approach that drew “sweeping conclusions” from an analysis of the one fatal accident Angel Flight had suffered in some 17,000 flights.

Mr Raby disputed that community service organisations were insufficiently regulated and said issues raised by CASA as germane to community service flights were relevant to all flying operations.

“There is simply no credible measure presented which indicates targeted activity presents a safety risk above and beyond that inherent in all general aviation activity,’’ he said.
Mr Raby don't you know by now that FF are simply not interested in empirical evidence that proves a safety issue is really a non-issue...

Oh well hopefully FF will soon make the DP submissions publicly available, it could make for some fascinating reading...

RAAA convention wrap & other related matters:

In Dougy's insight this week he gives a summary of the RAAA convention..: Editor's Insights 16 October 2014

The bit that amused me was the part on Tezza's speech, which apparently went down like a fart in an elevator with the delegates..:
Acting DAS Terry Farquharson delivered a sober defence of the Regulator which didn’t go down so well with industry delegates. I was surprised that Terry would front the RAAA given that he’s just keeping the seat warm until the new DAS is named (any day now). So I guess it was a courageous appearance, even if a bit out of tune with the mood of the audience.
While on the new DAS position SC in another article - New CASA chief on final approach - apparently has the goss that the former FAA heavyweight has suddenly got cold feet & pulled the pin.. :
A NEW head of the Civil Aviation Safety Authority is expected to be announced in the next two weeks, government sources have confirmed.

The announcement comes after the appointment was apparently delayed by a false start in which a US candidate favoured for the job is understood to have withdrawn his application.

It is believed the new candidate is local and the appointment is due to go before Cabinet towards the end of the month.
Which is certainly strange because rumour was, that even after reading the ASRR report (& possibly pprune) etc..etc., that this gentleman was very much relishing the opportunity to clean out the FF trough & dismantle the iron ring; I think there is a little more to this sudden withdrawal by said preferred candidate...

Moving on...SC also gives Paul Tyrell from the RAAA the opportunity to provide a bit of a wrap on the convention last week..:
The appointment and the safety review response were hot topics at last week’s annual convention of the Regional Aviation Association of Australia.

Association chief executive Paul Tyrrell welcomed the news that an appointment of a new CASA director of aviation safety was imminent, and said the appointment of industry veteran Jeff Boyd to the CASA board was also a tick for the government.

“The rest of the board hasn’t been appointed and that’s something we really need,” Mr Tyrrell said.

“The government’s response to the ASRR is also eagerly awaited.’’

Mr Tyrell also called on Mr Truss to follow through on the “long-awaited’’ ministerial advisory council that was part of the ­coalition’s aviation election platform. He said his association’s conference also heard that the Part 61 pilot licensing rules were continuing to cause angst “not because it’s a bad regulation but because it was rushed and the education program hasn’t been well managed’’.

However, the interaction with CASA on changes to parts 135 and 121 appeared to be much better.

On the safety review, Mr Tyrrell said the industry had responded months ago with almost as many submissions as had been lodged initially. “So there’s a huge amount of data and feedback they’ve got,’’ he said.
“They know exactly what the industry thinks, so we’re hoping the government’s working very hard on the response.’’

More generally, Mr Tyrrell said a theme of the convention had been to avoid talking down the ­industry. “We have a lot of international visitors and they commented that it always appears a struggle in the Australian aviation industry and they don’t get that in other parts of the world,’’ he said. “So we’ve got to be careful we don’t get too enmeshed in the problems and fail to look to the future.’’

He said this meant encouraging young people into the industry and looking beyond Australia’s shores to see where the local industry could engage and add value with what was essentially an international industry.

“We’re trying not be too gloomy,’’ he said.

“It’s more that it’s sort of a limbo period at the moment.’’
Hmm.. IMO this statement by PT on why Part 61 continues to cause angst...

“not because it’s a bad regulation but because it was rushed and the education program hasn’t been well managed’’

...is nothing more than a load of bollocks.. Perhaps PT should get out more, stop listening to the crat-spin and have a chat to some of the other TAAAF members, especially Aerialag Phil who has been quite vocal in regards to the Part 61 monster - Pilot licensing rules put aviation sector in a tailspin...

“I think the industry will give you a pretty firm view that this is just so overcomplicated for the task it does that we’ve actually gone backwards,’’ he said.

“I’d challenge anyone to get their head around the 800 pages of regulations and clearly enunciate how all of those rules work ­together.’

Phil (or SC) could probably put PT in touch with this bloke for a real at the coalface perspective on Part 61:
A veteran flying training operator with almost four decades in the industry said there was a lack of background, forms that didn’t yet exist and information that was still in draft form.

“The industry is crying,’’ the operator said.

He said the industry had been promised there would be no ­additional cost but there were “horrific costs involved’’.

“There are government guidelines saying there should be the removal of red tape, that there should be stuff done in simple ­language,’’ he said.

“Everything’s been done in legal speak again that we can’t understand.

There are actually things in different parts of the regs that contravene each other.’’
Maybe PT was misquoted or he had a few too many Chardy's but either way IMO that statement does not enhance the credibility of the RAAA...

MTF...
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