A CBA report, prepared during 2011 by DSTL for the implementation of CWS on Tornado GR4 aircraft, came up with an overall cost of £7 million for each life lost. This includes all training cost. The report also recommended that a Gross Dispropotion Factor (GDF)of 9.9 be used, where, according to HSE guidelines, 10 is at the Tolerable/Intolerable boundary and 1.0 at the Tolerable/Broadly Acceptable boundary. So you can see how expensive the 2012 collision was; £210 million. Not ALARP.
In his Tolerable and ALARP statement of 11th Sept 2011 AVM Atha used an overall cost figure of £4 million and a GPF of 1.0. He also concluded that, based on historical data, that there would be one fatality over the next 25.8 years, which equated to 0.15 fatalities before the OSD. He came up with an disproportionate cost of just £0.6 million and declared the risk as being ALARP
That is why AVM Atha must explain the justification for his statement in a court of law, as per MAA regulations.
DV