TB - I think you perhaps have hit the old nail squarely on the head.
Mrdak is an absolute piece of work. His Machiavellian fingers have fiddled in many pies from engineering the sell off of GA airports, to pink bats.
Ah yes the sticky fingers of M&M, behind closed doors, yet again manipulating the many & various two-bit players for his own self-serving, self-preserving reasons...
The most worrying thing is that this bloke has a key to the PM&C vault and has probably already corrupted many of the seriously smart individuals from that office...
The other problem is that although (in the case of the DAS selection) M&M is waiting the outcome of plan B; if that doesn't work he probably has back up plans all the way out to Z...
Kharon - I believe part of their remit is to do a cost/benefit analysis (impact) of new regulation.
This obfuscation and poor administration by FF of their obligations to the OBPR for all new/amended regulations was, among many other issues, highlighted in the REX ASRR submission:
The Australian Government’s handbook on Best Practice Regulation states that
stimulating productivity remains at the forefront of government policy. It also states
that the centrepiece of the Government’s best practice legislation is a Regulation
Impact Statement (RIS) that is mandatory for all decisions made by the Australian
Government and its agencies that are likely to have a regulatory impact on business.
Given CASA’s blatant disregard for its regulatory impact on productivity and the
inadequate or non existent RIS that accompanies each regulatory proposal, CASA is
clearly not following this process but is seemingly a law unto itself.
The resulting increased cost to industry without any demonstrated safety benefit is
felt to be a significant factor in the declining regional aviation sector. The regulatory
barriers for entry into this part of the aviation industry are now almost
insurmountable.
&
The Office of Best Practice Regulation (OBPR), in the Department of Prime Minister
and Cabinet, has published a handbook of guidelines [Dept of Finance and
Deregulation, July 2013] for Australian Government agencies involved in regulatory
reform. Any agency that introduces new rules that may have a regulatory impact on
business must first produce a RIS as part of the regulatory process. The OBPR must
be notified and the agency is required to publish an Annual Regulatory Plan. It
appears that CASA does not comply with any of these OBPR mandatory guidelines
.
FF back in 2012 did put out a RIS for Part 61 (see
here). However it would appear that they did not conduct an amended RIS (as is supposed to happen) to reflect the many & varied amendments/changes to Part 61 since that time...
So our only point of reference is the 2012 RIS that now has outdated figures..
Example SMS set up/ongoing costs for Flying Schools:
Upfront costs
For small businesses employing six or less safety sensitive staff would require an understanding of the safety management system principles and human factor training and the development of safety dataset. CASA has developed a micro SMS tool to assist these businesses.
It is estimated that it would require 2 days for a small business manager to understand SMS principles and a further 2 days training in human factor training for all staff, and 1/2 day to setup an excel spreadsheet for the safety dataset. For small businesses, this would generate an upfront cost of $2689, based on 4.5 days of time valued at the average salary of $128 500 per year and $1600 in human factor training from an external provider for the two days of training, deriving a cost of $4289 per business. In aggregate for the 164 small businesses this would generate a total cost of $0.7m.
For small/medium training businesses employing less than 20 people, the time cost will similar to sole traders with the addition of 2.5 days in time for developing staff training material and an investigation and audit program for the organisation. For individual small organisations this will cost 7 days valued at the average salary of $128 500 per year, generating a cost of $4183 per business, plus $1600 in human factor training from an external provider. In aggregate for the 35 small/medium businesses this will cost a total of $0.2m.
For medium businesses employing up to 50 the time cost will similar to small/medium business, however, the implementation of safety management system will require 2 days in time for developing staff training material and an investigation and audit program for the organisation. For medium businesses the time is estimated at 9 days valued at $5378, plus $1600 in human factor training from an external provider. In aggregate for these 5 businesses this will cost a total of $0.034m.
Ongoing costs
For small businesses, there will be ongoing requirement to demonstrate an understanding the principles of safety management systems and human factors, at a cost of 1 day per year and 1 day to record any safety incident in the database and comply with a safety audit.
The ongoing cost for the SMS will be 2 days per year valued at a salary of $128 500 that is $1195 per small business, plus $800 per year in human factors training, resulting in a total ongoing cost of $1995. With 164 small businesses this is will generate an annual cost of $0.46m.
For small/medium organisations the ongoing costs will be more significant, there will be more safety incidents to report, which will need to be investigated, ongoing risk assessments will be required for assessment of safety risks, developing means of reducing risks and training staff in safety. It is estimated that this will be the equivalent of 20% of the full-time workload for a person nominated as a safety manager within the organisation and when valued at the salary of $128 500, this will cost small/medium businesses approximately $25 700 each year. The human factors training is estimated to cost $800 per employee and assuming 5 employees per business this will cost $4000 per year resulting in a total ongoing cost of $29 700 per business. When aggregated across the 35 small/medium businesses this will generate an ongoing cost of $1.04m.
For training businesses employing up to 50 will be required to perform the same ongoing tasks of a medium sized business, but the additional employees will generate more safety incidents and risks to be assessed and staff to be trained. It is estimated that this will require 40% of the full time workload of one person, valued at $51 400 for each business. The human factors training is estimated to cost $800 per employee and assuming 20 employees per business this will cost $16000 per year resulting in a total ongoing cost of $67 400 per business When aggregated across these 5 businesses this will generate an ongoing cost of $0.34m.
The projected total impact cost to industry was tabled (table 6) on page 16 accompanied by this statement:
Overall Costs
In developing the proposals, CASA has been careful to offset any increased requirements with reductions in other requirements, particularly administrative requirements which have a less direct impact on safety. The total increased costs are estimated to be approximately $8m per year, or $56.3m when discounted over a 10 year period (Table 6).
Oh but the benefits, according to CAsA, will far outweigh the costs..
:
Conclusion
In developing the proposals CASA is not introducing a new regulatory regime, but is simply refining the existing requirements. The options, while making some changes to existing requirements, do not introduce any substantial new imposts on the aviation industry and in fact, will alleviate and simplify a significant number of current requirements.
The purpose of the proposals is to provide clear and consistent regulations for licensing flight crew without significantly increasing industry costs, but they do incorporate proposals for systemic changes designed to improve aviation safety.
Whilst there is a strong case for introducing better flight crew training requirements to improve safety, CASA accepts that the cost of flight training is already high. To contain costs there needs to be a reduction in requirements not directly contributing to safety to allow for additional safety targeted measures. In addition, Australia benefits from aligning flight crew licensing requirements closely with international standards.
Wherever possible CASA has sought to reduce administrative requirements in the flight crew licensing system that do not directly contribute to safety, so that other proposals addressing safety issues do not result in a significant cost to industry. Although some sectors of industry will experience modest increases, the overall result should tend to reduce rather than increase costs.
Errr..again no comment..
MTF...
