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Old 19th Nov 2014, 13:22
  #1472 (permalink)  
LeadSled
 
Join Date: Jul 2001
Location: Australia
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The Forum rejected the current CASA move toward the use of non-regulatory measures such as advisory material
Folks,
This is an absolutely crazy statement.

We have had CAAPs for years, they are advisory material.

We have had Advisory Circulars since 1998, without problems.

Both have exactly the same legal status, they are "a way, but not the only way" to comply with the related regulation. Why is that such a problem?? You don't have to "comply" with the CAAP, but you do have to comply with the related regulation, so your alternative is to negotiate an alternative means of compliance.

Do you all really want the contents of all the CAAPs/AC to be legislative instruments, that have been worked over by the legal drafting mob at the Parliamentary Counsel's office.

We already have an absolutely ridiculous volume of aviation legislative instruments. It is crazy that, very time an airline wants to change something like a minima, it has to go through the whole Parliamentary process

The bulk of technical detail under the US system is in Advisory Circulars, likewise EASA (AMCs and TGLs). What's the problem there, the answer is none.

Both the US and EEC (EASA) have two tier legislation, we have had it since 1998, where's the problem that more (not less) aviation regulation is needed in Australia.

With all the whinging about the amount of aviation regulation in Australia, why is the industry demanding more regulation??

Tootle pip!!

PS: The idea of translating something like the technical specifications for a Level 7 ( or D, if you prefer) via the Office of Parliamentary Counsel (the intent of IACO Doc. 9625, Issue 3) into a Legislative Instrument is the thing of nightmares, and that is what is being advocated by "the industry".

How about the ACs for certifying a aircraft, or an engine, or avionics and instruments --- do you really want that translated into the language of a legislative instrument???
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