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Old 28th Jul 2015, 22:58
  #37 (permalink)  
Sunfish
 
Join Date: Aug 2004
Location: moon
Posts: 3,564
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gchriste:

Could you imagine anyone in CASA having the ability to step up and basically say" You know what, we have wasted several hundred million of your money, are throwing it all out, and doing a cut and replace on some better regs from over the pond".

Sadly, will never happen, without political direction otherwise. They are so far vested into seeing it finish, they will pump more and more money into it.

No! No! No! You do not understand! The way the CASA executive team have set this up is so that it can Never finish!!!!!! The way the regulations are crafted sets up a perpetual employment machine.

This is why, for example, whole swathes of aviation, like experimental and the RAA live from day to day on "exemptions" that have a fixed shelf life - a Two year expiry date, by which time they must be "renewed" again! As we have seen, sometimes there is a Two or Three week delay in renewing the exemption that sees the entire sector stop flying.

From my own public service experience, I can advise you that "renewing" an exemption is not a trivial matter if the regulator does not want it to be. If I were doing it, I would start with a review of the assumptions, reasons and recommendations underlying the brief to management recommending the previous exemption, then I would test each against the evidence for and against that has accumulated in the previous Two years, then I would review how changes in current and future technology and regulations might impact the making of a new exemption, then I would write a discussion section on the impact of making a new exemption, then I would make my recommendation….

If I couldn't string that out into a years work then I'm a failure.

Furthermore there is the delicious narcissists game that is played every time: "will we renew your exemption? Maybe we will, maybe we won't." Watch your clients tie themselves in knots like the poor old SAAA did last time there maintenance exemption was delayed.

To put that another way: If you think that renewing an exemption is trivial, think again. this is just one example of the "make work" that goes on in CASA.

I say again: CASA is a perpetual regulation machine, they hate the very idea of finality - the distillation of the regulations in to clear concise plain English puts most of them out of a job.
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