Clarie....
Balanced view? Have you actually read that risk assessment?
Good to see you have spotted one of the glaring errors in the risk assessment. The RAPAC Convenors did also.
It should be noted that they consider the risk assessment (RA) invalid because:
a) It was conducted over a year after the change - which creates doubt over the results as they may well be in support of the change (??)
b) There was no CASA ID or file number or reference on the document
c) The date is only found within the document (was it really then or perhaps at all?)
d) The change process and the RA was not discussed with industry
at any stage and not tabled at the RAPACs, which is the forum for such matters,
e) After being conducted, the RA was kept secret for over a year and one approach from a RAPAC member for same was told to go to FOI to get it! It was only after a direct approach to the then DAS that it was released and a commitment to have the MULTICOM DP was made.
f) The names and qualifications/experience of those participating are blacked out. As anyone that conducts such reviews and audits would know the identity and experience of those participating in the RA
must be shown in order to validate the discussions.
It is not valid for this reason alone.
g) One comment from an experienced aviator and auditor asked how an extreme risk might be mitigated by a radio procedure? It can’t be!
As indicated by Clarie the RA is full of errors and shows that experience in class G operations was perhaps minimal and without representatives from industry which has such experience it is really a total embarrassment to CASA and should not have been published.
