Old 12th Sep 2015, 16:11
  #10 (permalink)  
Join Date: Jul 2001
Location: Australia
Posts: 4,932
So, you are saying the ADS-B requirement fails a cost/benefit analysis, yet you studiously ignore calls to produce a cost/benefit analysis for your airspace proposals?

Very. Big. Hypocrite.
I rather suspect that you do not know the difference between a Cost/Benefit analysis and a "cost/effectiveness" analysis.

In simplistic terms, in a cost/benefit analysis, the person incurring the costs should get some or all of the benefits.

In the latter case, those incurring the costs do not necessarily get any benefits.

With the "airspace reform", it is very effective for AsA, huge costs are being imposed on industry, to save AsA a small fortune. Despite the political and PR position of airlines, it is very difficult to show a saving, given the real traffic levels over Australia.

Dick is quite correct in calling for a proper cost/benefit analysis of the ADS-B debacle. Re-doing a RIS, which CASA has refused to do, doesn't, help, all a RIS tells you is what it is going to cost, after the decisions have been made.

A proper CBA tells you whether you should do it by whatever means, of which regulation should be the last resort, not the first, whatever "it" is, before the "decisions" are made.

CASA culturally hates the idea of CBA, if it was rigorously applied, a large amount of aviation legislation would never see the light of day.

Part 132 is a good example, two simple regulations being turned into scores of pages of regulations and brand and new MOS, all to address problems that are asserted, but nowhere detailed. Nowhere does Part 132 address any known and illustrated problems, because they don't exist, CAR 262Am and CAR 262AN have operated effectively and "economically" since 1998.

Part 132 creates yet another expensive bureaucratic nightmare that will achieve nothing, other than hamstringing Limiter Cat. operations into yet another regulatory straight-jacket.

As for Parts 121 and 135, plenty of coffin nails there --- all to "address" non-problems, except in the minds of those paid to generate regulations.

Tootle pip!!
LeadSled is offline