Why does CASA allow twin engine ETOPS operation at all?

[Dick Smith]

I have recently heard a story about an aeronautical engineer who will not fly on the long trans-oceanic routes in anything less than a Boeing 747 or an Airbus A380. This person claims the reason is safety, and that a twin engine airline jet of similar manufacturing date (and therefore safety features) will never be as safe as a four engine aircraft.

He claims the whole ETOPS system is simply based on probability, and that one day, a twin engine aircraft will end up in the drink.

This person claims the safety difference is very small, but it is there nevertheless.

If this is so, how does CASA justify Part 9A of the Civil Aviation Act, which says that the number one priority shall be safety. In this case, it looks as if the number one priority is moving more passengers at a lower cost.

I would like to know what others comments are on this – especially those who have an aeronautical safety qualification and understand the risk matrix.

Presumably if the twin engine planes were as “safe” there would be no reason for ETOPS restrictions.

[Lead Balloon]

He claims the whole ETOPS system is simply based on probability, and that one day, a twin engine aircraft will end up in the drink.His logic is sound. It’s just that his perception of the consequences means that he vastly over-estimates the probabilities of a ditching caused by loss of both engines. The give-away would be if he’s prepared to drive a car on the highway.

A four-engined jet could end up in the drink one day, too. B747 + Mount Pinatubo = quadruple engine failure.

[Dick Smith]

I don’t believe there is any evidence that he has over estimated the risk.

Just that the risk is higher in the twin.

So why does CASA allow?

[theheadmaster]

So how many twin engine aircraft have been lost due to only having two engines? How does the risk analysis change if you compare an older generation four engine aircraft that is poorly maintained and flown by poorly trained crew to a modern two engine type with good maintenance history and well trained crew? Yes, ETOPs is based on probability, but isn't any safety system? If we were to try to eliminate all risk, regardless of cost, wouldn't air travel become unaffordable? I think a rather outspoken former Chairman of the CAA made this very point about 'affordable safety'. ;)

[VH-MLE]

Go away...

[Dick Smith]

That’s why I said he compared similar generation aircraft.

Headmaster. So you are saying in some cases CASA puts affordability in front of safety? How does that comply with 9a?

[The Green Goblin]

Well tricky dicky, I can see the angle you’re going for here. Using this to leverage something else.

However, provided the risk has been identified and the systems are in place to mitigate it, safety has been compiled with.

Hence the approvals, inspections, training and cost involved in ETOPS twins.

As much as I love the 747, the modern twin is leagues ahead in terms of design, system reliability and safety.

You can’t even start the apu inflight in the 747.

[*Lancer*]

Having Class C airspace everywhere would be safer too, wouldn’t it?

[Dick Smith]

Lancer. Yes. But the reason CASA does not require class C everywhere is that they have put affordability in front of safety.

So why live a lie with 9a ?

Green. No nothing tricky. What’s wrong with the truth? Or is that why you post anonymously when you don’t have to?

Do you benefit when finite safety resources are mis allocated?

[Beer Baron]

Why not mandate 8 engined aircraft? Where do you stop?

You seem to be trying to solve a problem that doesn’t exist. How often has a dual engine failure on an ETOPS aircraft caused an accident?

[wishiwasupthere]

Go away...

:ok:...........

[Dick Smith]

It’s clear that with GA CASA often quotes 9a as the reason they have to put “ safety” in front of cost.

Clearly not consistent. Imagine having to live a lie.

I dare one of you to answer the key point I put in post 1!

Wishy. Don’t you like the hypocrisy being exposed?

[Checklist Charlie]

ETOPS = Engines Turning or Passengers Swimming.
Roger Bacon
Flight International
(Many many years ago)

CC

[virginexcess]

I think the data speaks for itself. Millions of ETOPS hours flown with no defineable risk increase. Additionally ETOPS is dead and gone, it is now EDTO, where much more than just engine failure is considered, and in those areas 4 eng aircraft have zero safety advantage over a modern twin. Further if Australia was to go alone against the globally accepted ICAO EDTO standard, both Australian International airlines would become a footnote in the history books within a year as they became unable to compete against every other airline flying big twins.

That race has been run and won.

The assertion that CASA put cost ahead of safety is a totally different issue and one that I think is beyond doubt, but you will need to come up with a better argument than ETOPS/EDTO.

[compressor stall]

Dick,

You can takeoff from Sydney bound for Perth direct in a twin with a non EDTO approved aircraft that has to stay within 60 mins of Adequate Aerodromes. There is no requirement for these aerodromes to have good weather. They could all be fogged in. Assuming the flight time is 5 hours, you could be 2.5 hours from safety. Legally. And you could have MELs that further reduce the levels of safety (APU out etc).

However if you are EDTO approved twin aircraft (say 120 minute) you need to have weather conditions that are pretty good at your EDTO Alternate Aerodromes a maximum (equivalent) of 2 hours away. And you can't depart with certain systems/items inop lest they reduce the safety margins, you need to actively monitor the weather conditions when underway, AND all your critical systems have been inspected by different engineers in case they make the same mistake on both....

Ergo EDTO can be significantly safer than normal non EDTO flights. Should CASA ban non-EDTO flights?

[haughtney1]

Virgin sums it up perfectly

I think the data speaks for itself. Millions of ETOPS hours flown with no defineable risk increase. Additionally ETOPS is dead and gone, it is now EDTO, where much more than just engine failure is considered, and in those areas 4 eng aircraft have zero safety advantage over a modern twin. Further if Australia was to go alone against the globally accepted ICAO EDTO standard, both Australian International airlines would become a footnote in the history books within a year as they became unable to compete against every other airline flying big twins.

That race has been run and won.

The assertion that CASA put cost ahead of safety is a totally different issue and one that I think is beyond doubt, but you will need to come up with a better argument than ETOPS/EDTO.

Dick,

You can takeoff from Sydney bound for Perth direct in a twin with a non EDTO approved aircraft that has to stay within 60 mins of Adequate Aerodromes. There is no requirement for these aerodromes to have good weather. They could all be fogged in. Assuming the flight time is 5 hours, you could be 2.5 hours from safety. Legally. And you could have MELs that further reduce the levels of safety (APU out etc).

However if you are EDTO approved twin aircraft (say 120 minute) you need to have weather conditions that are pretty good at your EDTO Alternate Aerodromes a maximum (equivalent) of 2 hours away. And you can't depart with certain systems/items inop lest they reduce the safety margins, you need to actively monitor the weather conditions when underway, AND all your critical systems have been inspected by different engineers in case they make the same mistake on both....

Ergo EDTO can be significantly safer than normal non EDTO flights. Should CASA ban non-EDTO flights?

Which also shows the fallacy of your proposition Dick based on regulatory requirements and real world implementation.
FWIW I ferried a 767 from JFK to LGW many moons ago that was effectively missing the correct regulatory piece of paper that would have enabled us to dispatch ETOPs, as a result it was perfectly legal for us to fly via the blue spruce routes with not an airport between St Johns and Prestwick serious options due to a fairly standard North Atlantic winter.
I’ve spent 20 years flying 180-207 mins, I’m far more concerned about an onboard PED or IFE fire than an engine issue simply because that’s the reality.

[Ollie Onion]

Of course it is all based on probabilities etc, CASA is all about risk assessment and deciding what is an 'acceptable' level of safety. Why does your friend fly at all? After all it is a statistical certainty that at some point a passenger aircraft will crash and kill everyone on board, it has happened before and it will happen again so the only way to keep flying safe is for CASA to stop allowing aircraft to fly? How may all engine flameouts have there been, I can think of two off the top of my head:

1 - BA 747, all four out due to volcanic ASH
2 - A320, both out due to bird ingestion.

So on the basis of that it makes no difference if it is a 2 or 4 engine aircraft :-)

[Wizofoz]

Just to be clear- this is Mr "Affordable safety" telling us we need to use less efficient aircraft in spite of decades and millions of hours of safe operation?

Does anyone know what has happened to Dick that he has gotten to this level of idiocy?

[Lead Balloon]

I think you’ll find Dick is trying to make precisely the opposite (and valid) point. Section 9A of the Civil Aviation Act means everything and nothing, when it suits. ETOPS and ETDO balance the infinitesimal probabilities of the double failure against the costs of mitigating the risks. If safety were indeed the most important consideration, it would always ‘override’ cost. And there would be no aviation.

[armeniki]

1 - BA 747, all four out due to volcanic ASH
2 - A320, both out due to bird ingestion.

So on the basis of that it makes no difference if it is a 2 or 4 engine aircraft :-)

Ollie Onion brings up a good point. Fuel starvation would be another thing to affect all your engines.

It would be interesting to put compile a list of events or factors which resulted in either a single (or particular) engine failure vs the failure of all engines... but that's an exercise for another day.

Jonee Helms was the administrator for the FAA back in the day (before ETOPS) apparently said he'd never allow it... things change, technology improves, etc.

[Dick Smith]

Wizfox. Why don’t you and others address the simple point I am making.

That is CASA is not complying with 9 a of the act. If the most important consideration is safety why are they allowing two engined aircraft to fly on those long remote ocean crossings?

Surely a four engined aircraft with the same safety features as the twin would be safer?

In this case they are giving the most important consideration not to safety but to affordability .

Why don’t they admit that? Why the deviousness?

[Lead Balloon]

Jonee Helms was the administrator for the FAA back in the day (before ETOPS) apparently said he'd never allow it... things change, technology improves, etc.And that’s what so funny (tragically funny) about aviation safety regulation. So much of it is actually based on some individual’s perception rather than objective analysis. All dressed up in the mystique of aviation of course.

[theheadmaster]

9a says safety of air navigation is the most important consideration, not the only consideration.

[Lead Balloon]

So what does that mean? What flows from that?

In what circumstances can CASA say that saving the costs of mitigating a risk to the safety of air navigation is more important that mitigating the risk?

[Wizofoz]

Surely a four engined aircraft with the same safety features as the twin would be safer?


And an 8 engine aircraft would be safer still.

meanwhile, back in reality.....

Dick, if you are making some arcane point, make it. You are currently just making yourself look foolish.

[601]

So how many twin engine aircraft have been lost due to only having two engines?

I start the count - B777 at Heathrow.

[Capn Rex Havoc]

Best not talk about single eng IFR ops in a pc12, versus a twin. :eek:

[theheadmaster]

I start the count - B777 at Heathrow.

My recollection was that was caused by engine failure due to ice crystals. How would having more engines have overcome that issue?

[Dick Smith]

Wizofox. No. Not an arcane point.

A valid current point. CASA is clearly not complying with the Act.

Now many of us know this but why would CASA not be open and honest about the situation.

If two engines are just as safe why have all these extra restrictions re alternates and single engine exposure time?

[ViPER_81]

Apart from Lead Balloon, everyone seems to be completely missing the point Dick is trying to make.


Yes, he could come out and say exactly what he means, but he is obviously trying to prove a point by playing devils advocate. CASA states that Safety is the number one consideration, but in reality that's not feasible. Nothing is "safe". It should be about risk mitigation.


Otherwise, if you take it to the Nth degree, you basically don't fly ever, at all. Then people would have to travel by car or boat, which is probably more unsafe.

[Dark Knight]

I start the count - B777 at Heathrow.

However, considering the circumstances which caused the engine flame-outs a trimotor or 4 engined aircraft may have lost all.

The answer Dick is a question of probabilities. If one reviews the total components of an aircraft most are covered by MTBO (mean time between overhauls and/or MTBF (mean time between failure) determining when such component should be removed for inspection/overhaul or replacement.

Similarly ETOPS is based upon MTBAEF (mean time between all engine failure) predicated on statistical and operational data where the Actuaries consider and define probabilities which the Regulator makes the decision upon.

The total industry is based upon probabilities yet in 2017 we had a year without any airline fatalities.

[theheadmaster]

From the perspective of statutory interpretation, I don't think the Act is saying what Dick and others think it says.

[dwarfhunter]

If CASA did ban ETOPS/EDTO, it would be banned for all operators. No more 787 to Japan. No more A330 from China. No more international 777, 330, 787, the list goes on but basically good bye tourist industry.

[Dick Smith]

Headmaster. So the act doesn’t mean that the “most important consideration” should be safety.

What then does that wording mean? Can affordability be put in front of safety?

[michigan j]

from the CASA risk-oversight-and-management page

Risk appetite is managed through the application of a risk tolerance matrix contained within the Risk Management Framework. It incorporates applying the 'As Low As Reasonably Practicable' (ALARP) principle to the context in which any decision is being made or activity undertaken.

Safety is CASA's highest priority in all areas of aviation activity and therefore CASA has a low aviation safety risk appetite. That said, as we move from airline passenger transport, through aircraft charter and on to private and recreational aviation our risk appetite will naturally trend upward. This approach recognises both the ALARP principle and the Statement of Expectations which requires CASA to take a pragmatic, practical and proportionate approach to regulation as it applies to different industry sectors having regard to risk.

[Dick Smith]

Michigan

That’s all very well but the legislation clearly does not reflect that position. And it’s obvious that in some cases the statement “Safety is CASAs highest priority” is not complied with.

If you look at the CASA class G paper they refer to the “ most important consideration must be safety “ cargo cult statement.

However most posters here state that does not count for airline passenger operations. In that case CASA clearly puts cost in front.

Why else would they allow cheaper twin engined aircraft to fly over big oceans at night?

[Car RAMROD]

Why else would they allow cheaper twin engined aircraft to fly over big oceans at night?

The plane knows it's over water, AND at night, exactly how?
I've never seen a switch to change the aircraft into "over water", "night" or "over water and at night" mode.

Stop with your scare tactics.

[mustafagander]

Come on Dick, you're just being silly now. The whole of aviation runs on probability. Think take off data, airspace & separation, the list goes on.
As I understand ETOPS or EDTO, it's about quantifying risk, bringing it under management.
I'm not sure of your angle in this new near pointless thread but I'm sure it will become clear with a bit more waffle.
Life as a professional aviator is all about probability and managing risk when all is said and done.

[maggot]

If CASA did ban ETOPS/EDTO, it would be banned for all operators. No more 787 to Japan. No more A330 from China. No more international 777, 330, 787, the list goes on but basically good bye tourist industry.
China etc non etops is no problem, maybe 25mins more flying time. Done it a few times recently.
But that's not really what this contrived point making thread is about :rolleyes:

[maggot]

The plane knows it's over water, AND at night, exactly how?
I've never seen a switch to change the aircraft into "over water", "night" or "over water and at night" mode.

Stop with your scare tactics.

Maybe it's the nav light switch. Hmmm maybe best to leave it off incase it gets more dangerous

[michigan j]

Dick, I know what you are saying. And it is an interesting question, and provided me with an interesting diversion for an hour or so.

But I don't think that s9A is as all-encompassing as it appears. It talks of a "most important consideration" which I think someone above mentioned does not mean "only consideration".

Also, the legislation should be read as a whole. I think s9A "colours" further sections of the legislation.

Some of the case law talks about
"In reaching this conclusion, the Tribunal is mindful of the requirement in s 9A(1) of the CAA which dictates that a suitably cautious approach must be taken to assessing the risks posed to the safety of air navigation by ..."

and

"However, I am satisfied those provisions merely acknowledge the Parliament's intention that safety of air navigation has always been the principal end to be satisfied by the Civil Aviation Act 1988 and that end has now been expressed in clear words by the Parliament."

And policy that is not contradictory to legislation such as the one I lifted from the CASA website (and I assume there is a policy rather than a webpage) is relevant as well.

"In Re Drake and Minister for Immigration and Ethnic Affairs (No 2) [1979] AATA 179; (1979) 2 ALD 634, Brennan J observed that policy is a key factor in attaining consistency in decision making. Consistency is a desirable goal in administration, as the application of differing standards in the exercise of a power by administrators can only result in unfairness and a consequent lack of confidence in the executive. The AAT should therefore apply lawful policy unless to do so would work an injustice in the particular case or there are other cogent reasons for not doing so (2 ALD at 644-645). A similar view was expressed in Re Ruggeri and Secretary, Department of Social Security (1985) 8 ALD 338 at350. "

So, I would argue that a policy talking about ALARP and s9A are not inconsistent. And if ALARP is OK, then ETOPS should be as well...

[Lead Balloon]

Come on Dick, you're just being silly now. The whole of aviation runs on probability. Think take off data, airspace & separation, the list goes on.
As I understand ETOPS or EDTO, it's about quantifying risk, bringing it under management.
I'm not sure of your angle in this new near pointless thread but I'm sure it will become clear with a bit more waffle.
Life as a professional aviator is all about probability and managing risk when all is said and done.You’ve left out the cost of “bringing [the quantified risk] under management”.

Let us assume that the cost of mitigating a quantified risk to the safety of air navigation is $1. Let us assume that the cost of mitigating a different quantified risk with the same consequences is $10billion. How can CASA choose to mandate the mitigation of one but not the other, when the safety of air navigation is the most important consideration in the decision? In this example the consequences of each risk are the same.

The safety of air navigation demanded that Dominic James not be reinstated to ATPL command privileges. The cost to him was completely irrelevant. Or so CASA said.

[JamieMaree]

I have recently heard a story about an aeronautical engineer who will not fly on the long trans-oceanic routes in anything less than a Boeing 747 or an Airbus A380. This person claims the reason is safety, and that a twin engine airline jet of similar manufacturing date (and therefore safety features) will never be as safe as a four engine aircraft.

He claims the whole ETOPS system is simply based on probability, and that one day, a twin engine aircraft will end up in the drink.

This person claims the safety difference is very small, but it is there nevertheless.

If this is so, how does CASA justify Part 9A of the Civil Aviation Act, which says that the number one priority shall be safety. In this case, it looks as if the number one priority is moving more passengers at a lower cost.

I would like to know what others comments are on this – especially those who have an aeronautical safety qualification and understand the risk matrix.

Presumably if the twin engine planes were as “safe” there would be no reason for ETOPS restrictions.

Dick,
This post tops any other of your loosely based neurotic posts.
Your engineer mate can have any position he likes on which aircraft he wishes to travel but it is no more soundly based than someone else’s view based on religion,politics,skin colour or sexual preference.

[airdualbleedfault]

Next :hmm:

[Dick Smith]

My whole intention was to show that affordable safety is alive and well.

I can see I have done that.

The act is clearly not complied with as cost is often the driving decision maker.

Sad they have to live a lie!

Lead. You clearly get it. Thanks

[theheadmaster]

No.

Just because cost is considered, does not mean it is the 'driving' decision maker, just like saying that safety is the most important consideration does not mean that by considering other aspects, safety has taken second place.

I don't necessarily disagree with your view about affordable safety (as I mentioned in my first response), I just don't agree with your argument about the interpretation of the Act.

[Snakecharma]

Dick, it depends on how you quantify risk.

The premis of your argument in the first post is that 4 engines are safer than 2 and as a consequence casa are not meeting their obligations under the act by not putting safety first.

The basis of this premis is that 4 engines are safer than 2 - is that a fair summation?

I could mount an argument that says the risk of engine fire in a 4 engine aircraft is significantly greater than it is in a twin. It stands to reason that the risk of fire is worthy of consideration and is a significant risk given that the potentially burning engine is located in an area where a fire induced structural failure would be catastrophic. Add to that the fact that the burning engine is directly underneath a fuel tank and the potential is there for the world to come apart. Additionally extra engines increases the risk of an engine failure. It stands to reason that the more engines you have the greater chance you have of one of them giving up the ghost at an inopportune time.

On the basis that most aeroplanes have two or three hydraulic systems, a bunch of electrical systems, a pressurisation system and a couple of redundant controllers, and mostly replicated and redundant systems, regardless of whether they have 2, 3 or 4 engines, there is a strong case that says the more engines you have the riskier it is, so casa may well not be complying with their safety first obligations by banning etops and mandating 4 engine aircraft.

So how is your question answered? Well with the use of probabilities and risk assessments that determine that, on balance, the risk is acceptable given a number of mitigators are in place - these mitigators being the rules around etops/edto.

As for your mate -well he is a dill.

Does he advocate the use of a man with a flag to walk in front of motor vehicles or fit passengers with parachutes or simply ban air travel in its entirety as that would be the safest course of action and without doubt meet CASA’s obligations under the act.

[FlightlessParrot]

I am just a pax: a pax who sat at 35,000'+, in the middle of the night, over the middle of the Pacific, in a 777 for the first time, and consciously re-examined my faith in the ETOPS calculations.

The question sounds a bit bush-lawery. That is, there is surely no longer any serious question about the practical safety of ETOPS, so the question is about the wording of the legislation. That is a question about legal interpretation, not aviation safety.

I am no more a lawyer than an aviation professional, but from a common sense point of view, it would seem that the law would be complied with if the reasoning went like this:

-We want to operate twins over the Pacific, because cheaper.

-We see your point, but our principal objective is safety. Demonstrate that you can do this as safely as flying the Queen of the Skies.

-Engines have got a lot more reliable. Here is a metric merde-tonne of calculations and a set of regulations, beyond what is considered safe for normal twin operations, that support our point.

-You have persuaded us that your calculations are sound, and there will be no diminution of safety, so you may do this, unless/until experience shows we got something wrong.

Experience would seem to indicate that the result has been no diminution of safety. The last time I had an aeroplane on my avoid list, it had nothing to do with the number of engines, and everything to do with the type of batteries.

Meanwhile, the corporate culture of profit-maximization as the first priority (in all airlines) has me more worried than the number of engines.

[FAR CU]

SPECIOUS ARGUMENTS.


('MY WORD' Is a word game, played by people whose business is words.)




In what circumstances can CASA say that saving the costs of mitigating a risk to the safety of air navigation is more important that mitigating the risk?


Did someone just say "dill" ? (whose self-editing is far from flawless.)


Why do the drafters of all these rules and regs use such appalling
terms as "appetite", presumably trying to colour the terminology as to whether or not the regulator is hungry for getting "the matrix" just right, on his plate.

But all that, and all that, is merely muttering in the wings.

[Chris2303]

And an 8 engine aircraft would be safer still.

And then why stop at 8?

[AussieAviator]

However, considering the circumstances which caused the engine flame-outs a trimotor or 4 engined aircraft may have lost all.

The answer Dick is a question of probabilities. If one reviews the total components of an aircraft most are covered by MTBO (mean time between overhauls and/or MTBF (mean time between failure) determining when such component should be removed for inspection/overhaul or replacement.

Similarly ETOPS is based upon MTBAEF (mean time between all engine failure) predicated on statistical and operational data where the Actuaries consider and define probabilities which the Regulator makes the decision upon.

The total industry is based upon probabilities yet in 2017 we had a year without any airline fatalities.

Yes, so true! Also a lot of large twin engine flying all around the world, indicating how safe these aircraft are. Would be interesting to see how many flights suffered engine failure outside 60 minutes from a suitable airport.
2017 safest year for air travel as fatalities fall - BBC News (http://www.bbc.com/news/business-42538053)

[Chris2303]

I don't recollect any DC3 ending up in the water when NAC operated the Coral Route.

[Dick Smith]

Every Australian country town that has a FAR23 certified scheduled service rather than a FAR25 shows that CASA has put affordability as the more important consideration.

They are then clearly not putting safety as the most important consideration.

Pretty simple. I am not opposed to this.

[tail wheel]

A four-engined jet could end up in the drink one day, too. B747 + Mount Pinatubo = quadruple engine failure.

Correction:
A four-engined jet could end up in the drink one day, too. B747 + Mount Galunggung (Indonesia) = quadruple engine failure.

I understand a Manila based TNT owned Bae146 freighter operating Singapore to Manila entered volcanic ash from Pinatubo and came within 2,000 feet of ending up in the South China Sea, before they got some of the Lycoming ALF 502's turning and burning again.

[Lead Balloon]

I stand corrected - Mount Galunggung, not Mount Pinatubo. Back to the topic...

The reality is that affordable safety is everywhere, and is unavoidably everywhere.

The problem in aviation regulation - particularly in Australia - is that the estimation of the probabilities of things happening - like a double engine failure on a 777 or an engine failure in a C208 or PC12 - are almost invariably grossly overestimated. The required mitigations are, accordingly, almost invariably a gross overreaction. It’s across the regulatory spectrum, from air operator certification to medical certification. The proposal for 20nm CTAF procedures is a specific, recent example.

The reason for this is completely uncontroversial and well-understood. The contemplation of awful consequences - like a double engine failure in a twin jet at 35,000’ over the ocean or a mid-air near a CTAF - results in a natural overestimation of the probabilities of it happening.

Dick’s aeronautical engineer - if he exists - is merely being what’s known as ‘human’. He intuitively ‘knows’ that a four engined-aircraft ‘must’ be safer than a two engined-aircraft. His knowledge and experience and objectivity go out the figurative window when he intuitively ‘knows’ the comparative risks.

‘Everyone’ intuitively ‘knows’ that pilots with CVD ‘must’ not be able to meet the same competence standards as pilots without CVD, and therefore pilots without CVD ‘must’ be riskier than pilots without CVD.

Of course, as a matter of objective fact, the intuition is bollocks. But it is natural (and, purely coincidentally, very lucrative for those who make their living out of safety bureaucracy).

Manifestations of this are everywhere. Look at the component overhaul and replacement periodicities in most GA aircraft designed in the 50s/60s/70s. My favourite is the flap flex drive shafts on Beechcraft. There are aircraft with 10,000 hours, plus, flying around with the original shafts. There are thousands of aircraft with multiple thousands of hours on original shafts. What do you reckon the maintenance manual says about the ‘life’ of those shafts?

And then I think of the poor bastard LAME whom CASA crushed for not having replaced vacuum pumps on a Cessna 310 at 500 hours. The pumps were still going strong after 500 hours, one by a further 886.9 hours and the other by a further 1,599.6 hours. But he had to be crushed because someone had plucked 500 out of his arse to put in a maintenance manual 40 years ago, and the number thus became holy writ the breach of which was a safety heresy. The objective evidence of millions of hours of vacuum pump operation and the collective wisdom of what causes vacuum pump failure were irrelevant. That’s aviation ‘safety’ for ya...

[Derfred]

JMHO:

I don't think there is any question that any safety must be affordable safety - the only alternative is an outright ban. What I mean is, you can always make something "safer", by spending more or doing more. You have to draw a practical line somewhere.

We could have the passengers wearing crash helmets and fire-proof suits. That would have saved some lives over the years. We could be building aircraft components out of more expensive materials, and replacing them more often.

CASA needs to decide the rules, using safety as the most important consideration, but that doesn't mean "utmost safety", because that simply doesn't exist.

It needs to be acceptably safe (and in aviation that means a very low risk: no-where near the risks we accept in other areas of life, such as motor vehicles).

So of course CASA is invested in affordable safety, even if they don't use that phrase. If they weren't, they'd have to ban aviation in it's entirety.

But, Dick, using ETOPS (or EDTO as it now is, which also affects 4-engined aircraft) is probably not a good test case if you're mounting an argument to take up the tree. I'm sure you can find a better one.

As for CASA coming down to hard on GA etc, the problem is they keep crashing and killing themselves. The airlines aren't. So CASA have to be seen to be doing something about it. I think that problem actually goes further up the tree than CASA, it's the whole "nanny state" culture that Australia seems to have evolved into, from the top down. I don't know why, it just has. I wish I knew how to fix it.

[FAR CU]

D.S. is peeved. The bureaucrats are lying to him. (Is that such a revelation?)

He has his sympathisers and he has his detractors, obviously. (Did not even Jean Jacques Rousseau endure this, in his "brave new world"?

And do they not , too have their incidental place, those who are so world-weary, as to say, "go away"?

[VH-MLE]

It's not necessarily "world-weary" but SMITH weary although weary is grossly understating things...

[X35B]

He claims the whole ETOPS system is simply based on probability, and that one day, a twin engine aircraft will end up in the drink.

This person claims the safety difference is very small, but it is there nevertheless.

.

Apparently, there are a number of landing options over the oceans and I remember reading about various islands having [not great] airstrips.

Does that count?

[SRM]

Over 50 years in aviation and 12500 hrs worldwide.
Engine Shutdowns
2 Engines nil
3 Engines 1
4 Engines 2

Based on my experience I would say that twin engine aircraft are very reliable, engine wise.

SRM

[Stationair8]

Not to mention the Ansett NSW Fokker F50 glider!

[Derfred]

To quote my previous post:

JMHO:
I don't think there is any question that any safety must be affordable safety - the only alternative is an outright ban. What I mean is, you can always make something "safer", by spending more or doing more. You have to draw a practical line somewhere.


If you can accept that, then the question becomes where to draw the line.

Dick, I think that is what you are actually about... your views on airspace and mandatory ADSB have always been about where to draw the line (and with respect to ADSB, "when" to draw the line, as a cost vs risk equation).

I think perhaps where you need to be heading with this is not just cost vs risk, it's cost vs risk vs benefit.

That is, it should be a three-way analysis, not just a two-way analysis. The third being the benefit to aviation, the economy, and society in general. That is the bit that CASA seems to miss. That's the bit that the FAA seems to get.

Substitute the word "safety" in place of "risk" if you like, it matters little. I dislike the word "safety" because it implies black or white (safe or unsafe), and as you know there is no such thing. It's actually all about risk, unless you are trying to sell something.

[Traffic_Is_Er_Was]

Safety is considered. Twin-engined aircraft must operate to more onerous requirements than four-engined aircraft, so that the overall risk is considered acceptable. CASA do not say that 4 engines are safer than 2 engines, they say that 2 engines operated like this are considered as safe as 4 engines operated like that. They have made safety win over costs by insisting that the "less" safe operate differently. If they didn't care, twins could do what they want.

[ahwalk01]

There's an engineer who won't travel on the jubilee line past westminster due to the lesser blast protection.

He has a point, but a stupid one.

[Gas Bags]

A different spin on the topic of safety as regulated by CASA.
It has now become normal for Engineering managament to have zero aircraft maintenance experience or knowledge. This is approved by CASA. Once these non aviation people are approved to hold a responsible position they also then self regulate.
From my First hand knowledge decades of safety learnt from experience/mistakes/knowledge have all been thrown out the window with these people. For example they will have a satisfactory knowledge of EDTO as taught in a 2 hour course, and as can be read on paper in the MOE, yet will still try to find ways to spin the wording to ask an engineer to get an aircraft in the air when they don’t have a lifetime of aircraft experience to stop them walking into schoolboy errors due to ignorance, and the fact that holding a masters in aviation management means they choose to ignore hundreds of years of experience from people under them.
A big part of maintaining an EDTO approval is the maintenance section yet CASA project their audits in advance and it is now the norm for The same management to present a company pre audit checklist to be carried out within the facility prior to each advertised CASA audit to ensure a pass.

I guess what I am trying to say is EDTO is mainly about maintaining the aircraft to those standards, followed by the correct operation of the machine in the air.

A bigger concern should be that these aircraft are flown by the pilots, carrying unwitting passengers, with these types of unqualified people in charge and approved to be such by CASA. The equivalent would be having a chief pilot with not a single flying hour under their belt.

It is all good whilst people with experience can stand up and say no to these under qualified management. In 20 years with the millennial thought processes firmly in place there will be very few people in the industry with traditional safety first training still in the industry. Perhaps a spike in the graph will show up.

[neville_nobody]

It has now become normal for Engineering managament to have zero aircraft maintenance experience or knowledge. This is approved by CASA. Once these non aviation people are approved to hold a responsible position they also then self regulate.

I remember an ad being run online and in newspaper for being a CPA which had a women who was in charge of a maintenance department at a airline who admitted in the ad that she had no idea what she was doing and she relied on those below her to 'help':ugh::ugh:

The point of the ad was where a CPA can get you but from an aviation perspective it was absolutely horrifying.

[Dick Smith]

Derfred, I agree with the first two paragraphs of your post 57, but unfortunately your third paragraph really goes downhill. It says:

“CASA needs to decide the rules, using safety as the most important consideration …"

Yes, it probably “needs” to do that if it is going to comply with the Act, but in practice, clearly there are many cases when CASA does not decide the rules using safety as the most important consideration. There are times when it uses the marketplace as the most important consideration – as I have said in previous posts.

You state that “CASA is invested in affordable safety”, yet for some reason they like to deny this. Try to get someone within CASA to actually say the words “affordable safety.”

I think many have this belief that the Australian public are so stupid they can’t be informed as to the different levels of safety that are provided under the regulations. Of course these different levels depend on affordability. If we tried to have full FAR25 airline standard aircraft operating to Bourke, the cost of the air tickets would be too high and the service would stop.

You say an argument around ETOPS or EDTO is not a good test case in this particular matter. The reason we have these twin engine operations is not because CASA decided to make the decision, it is because the decision was made in Europe and the USA. Whether people at CASA wanted to differ was not the deciding factor. They simply had to harmonise with what the rest of the world was doing – or become a laughing stock.

I would imagine Boeing went to the FAA and said words to the effect, “We can get a lot more people flying if you would approve twin engine operation over remote areas, and we can make the aircraft acceptably safe.” The FAA no doubt saw the common sense logic in this. Fortunately, the FAA doesn’t have legislation which says that safety has to be “the most important consideration.” They realise there needs to be a balance between safety and participation levels.

That is what this thread is about. It is great to see that people are becoming better informed after just about every post.

If I worked for CASA I would be proud to say that there are a number of different levels of regulated safety based on the ethos of getting as many people as possible going by air travel which is safer than the road.

[Vag277]

From the FAA website home page:

Our Mission
Our continuing mission is to provide the safest, most efficient aerospace system in the world.

Our Vision
We strive to reach the next level of safety, efficiency, environmental responsibility and global leadership. We are accountable to the American public and our stakeholders.

Our Values
Safety is our passion. We work so all air and space travelers arrive safely at their destinations.

[Who stole my meds]

I have recently heard a story about an aeronautical engineer

Why are you blokes even talking about this.
Dick hears a story about an aeronautical engineer who won't fly a twin across water and it's turned into 4 pages of dribble.

[Dick Smith]

Vag. That’s good marketing material.

Do they put safety in front of what the travellers can afford ? Clearly not.

[Switchbait]

Why are you blokes even talking about this.
Dick hears a story about an aeronautical engineer who won't fly a twin across water and it's turned into 4 pages of dribble.

What he said.

[PLovett]

Dick, I know what you are saying. And it is an interesting question, and provided me with an interesting diversion for an hour or so.

But I don't think that s9A is as all-encompassing as it appears. It talks of a "most important consideration" which I think someone above mentioned does not mean "only consideration".

Also, the legislation should be read as a whole. I think s9A "colours" further sections of the legislation.

Some of the case law talks about
"In reaching this conclusion, the Tribunal is mindful of the requirement in s 9A(1) of the CAA which dictates that a suitably cautious approach must be taken to assessing the risks posed to the safety of air navigation by ..."

and

"However, I am satisfied those provisions merely acknowledge the Parliament's intention that safety of air navigation has always been the principal end to be satisfied by the Civil Aviation Act 1988 and that end has now been expressed in clear words by the Parliament."

And policy that is not contradictory to legislation such as the one I lifted from the CASA website (and I assume there is a policy rather than a webpage) is relevant as well.

"In Re Drake and Minister for Immigration and Ethnic Affairs (No 2) [1979] AATA 179; (1979) 2 ALD 634, Brennan J observed that policy is a key factor in attaining consistency in decision making. Consistency is a desirable goal in administration, as the application of differing standards in the exercise of a power by administrators can only result in unfairness and a consequent lack of confidence in the executive. The AAT should therefore apply lawful policy unless to do so would work an injustice in the particular case or there are other cogent reasons for not doing so (2 ALD at 644-645). A similar view was expressed in Re Ruggeri and Secretary, Department of Social Security (1985) 8 ALD 338 at350. "

So, I would argue that a policy talking about ALARP and s9A are not inconsistent. And if ALARP is OK, then ETOPS should be as well...

Dick, I see that you are not willing to answer michigan j's response. While the cases he cites are AAT and therefore not binding, the principles used in those cases are derived from the High Court decision in Project Blue Sky Inc. v ABA, which is most certainly binding. The case is the leading authority on the interpretation of legislation and I suggest that it be read before trying to embarrass CASA on this.

I understand what you are trying to do but posting what you believe to be rhetorical questions on this site are misplaced. Nothing will change in CASA until they are forced to change by political pressure.

[Dick Smith]

Plovett.

I think what is important is what happens in practice. Over the last decade CASA appears to have been responsible for a one way ratchet in increasing costs on GA.

The unique ADSB mandate is just one example. And also part 61.

I have been told many times by CASA people that they do not have any legislative requirement to promote a profitable industry or get more people flying so they can benefit from a safer form of travel.

Seems strange to me that you say they will have to be forced to change. Why would they not want to change and get more people flying.?

[Lead Balloon]

Michigan and PLovett: If you can find an AAT or Federal Court matter in which CASA does not argue that section 9A(1) justified and was the overriding consideration in the decision in question, please post the link/s.

[B772]

Spare a thought for the crew and pax on B777-200ER UA842 AKL-HNL 17/03/03. 191 mins on a single engine after nbr 2 engine was shut down.

[Wiggley]

Your argument is about as sound as; why does your insurance company allow you to fly a JetRanger when there are twin engine helicopters? Is it because they just want you to die?

[Lead Balloon]

The insurance company makes an objective assessment of the probabilities of having to pay out, puts a price and margin on that risk, and off Dick goes in his JetRanger and insurance cover. That’s a commercially-driven decision, not a safety decision.

Dick’s point is that CASA makes equivalent decisions, but pretends they are determined by safety considerations.

For example, there is no safety basis for the classification of operations. Passengers boarding a charter flight on a 9 seat piston aircraft and passengers boarding an RPT flight on a twin jet have no idea about the absolute and comparative probabilities of each aircraft being involved in a fatal accident. Amazingly, if the passengers on the first aircraft happen to be a patient being medevacd, and her husband, the flight is acceptably ‘safe’ at aerial work standards, but not acceptably ‘safe’ if they are just ‘plain old passengers’.

The classification of operations scheme results in some people being less safe than others, based on cost and practical considerations. “Cost and practical considerations” is long-hand for “politics”.

[Dick Smith]

B772. You are stating that a large capacity airline aircraft flew for over three hours as a single engined aircraft.

No doubt during that three hours there was a chance that the single engine could fail.

Can someone provide details on what that chance actually was ?

[theheadmaster]

Dick, I think I have pointed out a couple of times what I believe, broadly, is the error of your interpretation of s9A. The argument you are making is one with a foundation in the correct interpretation of the Act. Might I suggest that rather than bouncing ideas off PPRUNE readers, many of whome have a good practical appreciation of affordable safety and risk management, that you speak to someone who is a specialist in statutory interpretation. That is a barrister, preferably one who works in this area of the law. I am sure that with your background and resources that would not be difficult to do.

Regards,

TM

[fujii]

I don’t know why CASA is the focus of this thread. Every aviation regulatory authority approves ETOPS including the FAA which people want Australia to copy.

[Dick Smith]

Headmaster. Good advice. I have done that. The problem is how some CASA officers interpret the wording.

The “absolute “ nature of the wording allows this.

Fujii. The FAA constantly keep the costs to GA as little as possible and the airspace accessible and simple

Quite different here.

[fujii]

Headmaster. Good advice. I have done that. The problem is how some CASA officers interpret the wording.

The “absolute “ nature of the wording allows this.

Fujii. The FAA constantly keep the costs to GA as little as possible and the airspace accessible and simple

Quite different here.

I know that but GA has nothing to do with thread. I am just wondering why people are only questioning CASA’s approval of ETOPS when it is a international standard.

[Dick Smith]

I would imagine CASA insisting a powerful airline have extra costs would not be possible.

Clearly CASA can impose extra costs on a non powerful GA industry such as part 61 and get away with it.

[zanzibar]

and it's turned into 4 pages of dribble.

drivel, as well

[Wiggley]

The insurance company makes an objective assessment of the probabilities of having to pay out, puts a price and margin on that risk, and off Dick goes in his JetRanger and insurance cover. That’s a commercially-driven decision, not a safety decision.

Dick’s point is that CASA makes equivalent decisions, but pretends they are determined by safety considerations.

For example, there is no safety basis for the classification of operations. Passengers boarding a charter flight on a 9 seat piston aircraft and passengers boarding an RPT flight on a twin jet have no idea about the absolute and comparative probabilities of each aircraft being involved in a fatal accident. Amazingly, if the passengers on the first aircraft happen to be a patient being medevacd, and her husband, the flight is acceptably ‘safe’ at aerial work standards, but not acceptably ‘safe’ if they are just ‘plain old passengers’.

The classification of operations scheme results in some people being less safe than others, based on cost and practical considerations. “Cost and practical considerations” is long-hand for “politics”.

So your (and Dick's) argument is there has been no objective risk assessment for safety? Especially given all the data that exists that proves his point that ETOPS operations are unsafe... wait, he's basing all his "data" around one bit of anecdotal data from a single source.

Dick, how about instead of sounding like someone who is willing to just jump on a single bit of anecdotal evidence because you have a bone to pick, show us an intelligent argument by reasonable person and come to us with hard statistical data you've compiled on engines which power ETOPS approved aircraft and show us what the real probabilities are and how the regulator has compromised safety. Then we all can have a reasonable discussion about this subject.

Because right now your argument has the scientific veracity of that of a flat earther.

[Lead Balloon]

Was there an “objective risk assessment” for “safety”? What were the probabilities at which the mitigations for the perceived risks of ETOPS operations turned those operations from objectively “unsafe” to objectively “safe”?

Are the probabilities of a passenger fatality on a transport category ETOPS operation higher or lower than the probabilities of a passenger fatality on a 9 seat piston twin charter? CASA certifies both operations. Are they equally “safe”? If not, on what objective basis can they both be permitted to continue?

Someone proposes to use a single turbine engined aircraft in RPT operations. Because of the perceived risks of that operation, the regulator mandates that the engine be changed every 100 hours, prohibits the aircraft from operating over built up areas and requires a twin engined aircraft to fly in front with red flags. Were those mitigations a cost-effective and necessary response to the objective risks of engine failure?

You’re missing Dick’s point (although I do concede that he sometimes makes them poorly).

[Snakecharma]

Dick, I think you have answered your own question.

Fortunately, the FAA doesn’t have legislation which says that safety has to be “the most important consideration.”

Like most things in aviation, the meaning swings on the words and the interpretation thereof.

A dictionary says:

consideration
noun
1.
careful thought, typically over a period of time.

"your case needs very careful investigation and consideration"

synonyms: thought, deliberation, reflection, contemplation, cogitation, rumination, pondering, meditation, musing, mulling, examination, inspection, scrutiny, analysis, review, discussion; More

I dont believe there can be any suggestion that casa dont give things such as edto and other safety critical issues, “careful thought” and in most cases “typically over a period of time” much to the annoyance of people trying to actually achieve anything.

The things is the requirement is not to give safety the ONLY consideration.

If that was the case we would all be walking as aviation inherently carries more risk than wrapping yourself in a cocoon and staying in a locked room.

The trick is to manage risk appropriately and in the case of edto that is done with edto/etops design and certification rules, edto fuel policies, edto dispatch policies, edto pilot training, edto maintenance requirements, edto operational requirements etc etc etc.

[Dick Smith]

Wiggly. I have not suggested that ETOP operations are unsafe.

Just that some experts do not believe they comply with the CASA legislation to have safety as the number one consideration.

Possibly in this case CASA has looked at affordability.

Or most likely harmonised with overseas requirements and ignored the act.

[tdracer]

I have recently heard a story about an aeronautical engineer who will not fly on the long trans-oceanic routes in anything less than a Boeing 747 or an Airbus A380. This person claims the reason is safety, and that a twin engine airline jet of similar manufacturing date (and therefore safety features) will never be as safe as a four engine aircraft.Dick, your whole premise is without basis - i.e. that a quad is safer than an ETOPS operated twin. Now, just so you know, I spent 40 years as a propulsion engineer at Boeing, and I know all about the stuff that went into the original ETOPS approvals (called EROPS back then). Spent several years on the Propulsion Safety Board as well.
The bottom line is this: There has never been an ETOPS twin go down due to dual, unrelated (i.e. not common cause) engine failures. There have been trijets and quads that have crashed due to single engine failures. The greatest engine related risk to multi-engine aircraft is not non-common cause engine thrust loss - it's that there is an engine failure that endangers the aircraft - uncontained engine failures being the biggest one with engine fire being a close second. The greater the number of engines, the greater the risk that an engine will fail catastrophically (google Sioux City DC-10 for a rather dramatic example of how a single engine failure can take down an aircraft, and it took a talented crew and more than a little good luck to get that Qantas A380 safely on the ground after the Trent engine uncontained failure).
In short, there is no data that demonstrates a twin, operated under ETOPS rules, is less safe than a quad or a tri. There is data that demonstrates the opposite. As for your aerospace engineer friend, well the less said the better.

[Lookleft]

Wiggly. I have not suggested that ETOP operations are unsafe.

Just that some experts do not believe they comply with the CASA legislation to have safety as the number one consideration.

Possibly in this case CASA has looked at affordability.

Or most likely harmonised with overseas requirements and ignored the act.

So what is your point? Now you are criticizing CASA for harmonising Australian requirements with that of, one presumes, the best of overseas practise to save Australian operators having to comply with uniquely Australian requirements.:ugh:

Why don't you take your case from the court of pprune and go to the media and tell them that thousands of Australian air travellers have been exposed to an unacceptable risk because CASA has breached their own legislation. Then put a legal team together to take CASA to court for their flagrant breach of the law. Only you have the resources and the interest in doing so.

[Dick Smith]

TD. If during the three plus hours a twin on one engine is exposed when heading for an alternate are you suggesting there is no chance of the remaining engine failing?

Would it not be operating at a higher power level?

Surely there would be a small measurable chance of a second failure?

If that was at night over a rough ocean could that have serious consequences?

Look left. CASA quotes 9a to prevent GA moving to lower costs. Look at ADSB and part 91.

[Lookleft]

As always Dick you sidestep the question then throw in an irrelevant response.

You are not talking about GA or ADSB in this thread. You are referring to CASA not following 9a WRT ETOPS or EDTO specifically.

You made the following statement: Or most likely harmonised with overseas requirements and ignored the act.

As you are a vocal critic of CASA not following this practise it would seem that you are now accusing them of following the practise of taking the best ideas from overseas and therefore putting the Australian public in danger. :confused:

Take it to Ean Higgins and let him know of this latest attempt by CASA to fail to follow their own legislation.

[Dick Smith]

I support ETOPS. I support CASA supporting ETOPS.

I support CASA when it makes safety decisions that take into account affordability.

I reckon it would be better for the CASA legislation to clearly reflect this position.

Does anyone agree?

[tdracer]

TD. If during the three plus hours a twin on one engine is exposed when heading for an alternate are you suggesting there is no chance of the remaining engine failing?

Would it not be operating at a higher power level?

Surely there would be a small measurable chance of a second failure?

If that was at night over a rough ocean could that have serious consequences?

Look left. CASA quotes 9a to prevent GA moving to lower costs. Look at ADSB and part 91.

Dude, did you even read what I wrote?
The probability of a catastrophic engine related accident does not go down with more than two engines - it goes up. There is a massive statistical data base that backs that up. Sure, an extended single engine diversion might be unpleasant - but it's not inherently unsafe, it's taken into account in the processes and procedures, and it's quite rare.
Statistically, two engines are safer than four. Your claim that CASA isn't following their own regulations by allowing twin ETOPS is not supported by any facts. All your bleating to the contrary simply makes you look silly.


Does anyone agree? No, and we're still looking for you to provide any evidence to back up your claims (gut feel doesn't count).

[itsnotthatbloodyhard]

Dude, did you even read what I wrote?

You’re new here, then?

I’m honestly struggling to see the point of this thread, except as an exercise in attention-seeking.

[Dick Smith]

Tdracer. Who are you trying to protect?

I will give a simpler example. CASA allows lower certified standard airline aircraft to service small country towns. This is clearly not giving the most important consideration to safety- it is putting affordability in front of costly extra safety features.

CASA is not complying with the act. Do you understand?

That is the reason for the thread. Imagine having to live a lie in your everyday work?

[Dick Smith]

The prime reason that the major aircraft manufacturers have pushed for ETOPS approvals is so they can sell more aircraft , get more people flying and make more money.

It was not to improve safety over four engined aircraft. Not once has anyone claimed that is was to increase safety. If that was so they would say so!

[Lookleft]

See Dick, you can't keep your own argument on the logic path.:D

You finally admit that you support ETOPS then you launch into this:

The prime reason that the major aircraft manufacturers have pushed for ETOPS approvals is so they can sell more aircraft , get more people flying and make more money.

It was not to improve safety over four engined aircraft. Not once has anyone claimed that is was to increase safety. If that was so they would say so!

Now you're against the manufacturer's and their capitalistic ways. How utterly contemptible for any company to want to increase their profits.

The main reason you started this thread is you wanted everyone in pprune land to acknowledge that you are right and that CASA are not applying their legislation consistently and you were just using ETOPs as an example. Well there's a revelation , CASA have one rule for one lot and a different rule for the rest all embedded in the same rules. There is nothing new in what you have discovered, have you seen the difference between the requirements for aerial work and that for charter?

The biggest mistake people have made on this thread is taking you at face value in suggesting that ETOPs is the issue.:=

[Dick Smith]

https://en.m.wikipedia.org/wiki/Air_Transat_Flight_236

Fortunate passengers to have a glider pilot captain.

I am not against the manufacturers. I support the concept of affordable safety. Always have

CASA should tell the facts about this

[Car RAMROD]

Dick, how far do you want to take the "safety must be the most important consideration" thing?

Do you want to mandate that every aircraft must take off with full tanks, and must plan to land with half remaining?
And also wrap every passenger in flame proof bubble wrap and wear a helmet in case of a crash? And with a small scuba setup in case of a ditching?
Because after all, that is surely safer than allowing passengers to wear shorts, singlets and thongs!


I think you are twisting words and interpreting what's written with your own agenda clouding things.

As for the Airbus Glider, it probably would have been good if the pilots didn't pump fuel overboard. That in itself is not an EDTO or two-engine-aircraft-only screwup. If they had 3, 4 or even 12 engines the outcome would have been the same.

[Dick Smith]

Car. You completely misunderstand what I am saying.

My view has always been the opposite to what you are implying.

It is the CASA act that states the myth that safety is the most important consideration.

Why not get the act to reflect what happens in practice. I would support that.

[Car RAMROD]

Car. You completely misunderstand what I am saying.

My view has always been the opposite to what you are implying.

It is the CASA act that states the myth that safety is the most important consideration.

Why not get the act to reflect what happens in practice. I would support that.



Ok let's use your regional air service point. You reckon CASA are putting cost ahead of safety by allowing "lesser" aircraft to service them. So what do you expect if safety was put first; tiny towns to upgrade runways to take CAT D/E 4 engine aircraft with level 10 RFFS and ATC and CATIII ILSs to each runway?

[Dick Smith]

Wow. This is difficult.

I expect CASA to be open and honest and state that in many cases they do not put safety in front of affordability.

And to be consistent. The unique early ADSB mandate has done extraordinary damage to GA. Too late now to do anything about it.

No other country I know of has the absolute statement “ most importantly consideration should be safety “

The bureaucracy over 20 years ago forced this into legislation. They insisted that the traveling public is so dumb they can’t be told the truth about affordable safety.

[Car RAMROD]

Well why don't you collect evidence and challenge them?

[tdracer]

Well why don't you collect evidence and challenge them?

He won't, because the evidence that ETOPS twins are less safe than quads doesn't exist.
It was not to improve safety over four engined aircraft. Not once has anyone claimed that is was to increase safety. If that was so they would say so
Again, demonstrably false. To obtain ETOPS approval, Boeing submitted several analysis to the FAA and EASA (JAA in those days) showing ETOPS twins were at least as safe as quads. I have first hand knowledge of this. I presume Airbus did something similar.
You're arguing based on emotion, not facts. The facts say that ETOPS twins are at least as safe as quads.
Bottom line is your gut tells you four engines are safer than two. Facts say otherwise. Emotion once said "if man was meant to fly, he'd have wings" Fortunately enough people listened to the facts that said otherwise. Regulations based on emotions instead of facts usually kill people.
Dick, you just go on and continue arguing that two plus two equal five. Just don't expect the rest of us to play your silly game - I'm tired of arguing with a fool and I'm out of here.

[Dick Smith]

Looks as if Regulators believe that there is a difference in safety because restrictions are put on twin engined aircraft operations that are not put on three or more engines. Wonder why they do that if identical safety levels? Very mysterious

[mikewil]

No other country I know of has the absolute statement “ most importantly consideration should be safety “I get what you're saying Dick (many posters here don't seem to), it is about the fact that CASA's official objective doesn't reflect what they actually do.

However, can you imagine the field day the media would have when they got wind that our aviation regulator stated its objective to be something like "to ensure an aviation industry with a fair balance between cost and safety".

Are you able to elaborate on how regulators overseas have worded their objectives in a way that you think would be more suitable?

[Plazbot]

“There’s no such thing as bad publicity,”
-- P. T. Barnum

[mattyj]

SImple; CASA allowed for ETOPS in the rules and the manufacturers and Airlines eventually came up to the standard and have gained approval ..if CASA hadn’t wanted ETOPS then they wouldn’t have had it in the CAOs and Australia would’ve been an outlier in world aviation

[Traffic_Is_Er_Was]

If CASA has examined an operation, and considers the same degree of safety can be accomplished by alternative means and one of them happens to be cheaper than the other, what is the issue? By ruling an operation safe, have they not fulfilled their obligation to make that their primary concern?

[ernestkgann]

Dick has tried to make a point using a somewhat obtuse argument. However his point is valid. He knows that EDTO in two engined airliners is safe. Even airlines say their number one priority is safety but we know that this is is board room lip service, they need to squeeze every cent they can out of an operation. If it was their priority then they would go broke. Even with the CASA QUANGO, high costs and the Aussie love of regulation I'm not sure that our tiny market can support a very large aviation sector anymore, even the US appears to be struggling.

[Dick Smith]

Traffic. You state “ by ruling an operation safe”

That is the problem. That is an absolute statement and would be an untruth.

The word “safe” means without risk. There is no such aviation operation. There should be no problem in communicating the truth.

If you communicate the truth it means you can allocate the limited and finite resources to where the greatest improvement to safety can be made. It probably means you would not introduce mandatory ADSB for VFR and let pilots spend the money to fly more and gain more recent experience.

A factual statement could be “ extremely safe”.

[itsnotthatbloodyhard]

The word “safe” means without risk.
.
.
.
A factual statement could be “ extremely safe”.

What, “extremely without risk”, then?

Dick, you’ve effectively contradicted yourself within a couple of lines. One moment, you’re claiming safety is an absolute, binary concept, and the next, you’re allowing it has different levels.

I’d consider that a rusty old VW Beetle with dodgy suspension and no seat belts is an unsafe car, and a brand new Volvo is a safe car. But neither is completely without risk. Safety can only ever be a relative thing. If your argument hinges on it being an absolute, then I think you’re in trouble, as you’ve just demonstrated with your own self-contradiction.

[Dick Smith]

Safe is an absolute and means without risk. Extremely safe is not an absolute and means what it says. It clearly means there is some risk.

There is no contradiction.

“ the most important consideration is safety” means it is more important than affordability.

CASA only appears to comply with that when those affected are weak.

[itsnotthatbloodyhard]

I see - it’s an absolute, except for when it isn’t. We could probably discuss whether your approach is “moderately unique”, but I suspect that like the rest of this thread, it’d be pointless.

[Dick Smith]

Mattyl. It was my board in about 1990 that introduced the automatic airworthiness acceptance from five leading aviation countries. This was opposed by a number of senior CAA bureaucrats.

Up until then properly FAA certified aircraft such as the Beech 1900 could not fly here.Ask Max Hazelton. Read the relevant chapter in Two Years in the Aviation Hall of Doom.

In those days people such as Mel Dunn resisted the affordable safety fact. CASA appears to be doing that again.

[Dick Smith]

It’s not.

No! If you use the word “safe” by itself it clearly means “ without risk”

If you state “ very safe” or “ extremely safe” it means something that is quite different. Sorry but this is a fact !

AsA is also supposed to give primacy to safety. Why don’t they then re allocate their profit dividend that normally goes to the government to extra safety- say a tower at Ballina?

Hint. Just like CASA they don’t comply with their act. It’s a sham to mislead the public. Polititions have been conned into believing that they cannot tell the public the truth.

[Traffic_Is_Er_Was]

“ the most important consideration is safety” means it is more important than affordability.
It means that safety considerations should be given more weight than others, but does not mean that safety should be the only consideration, nor does it mean that the results of that consideration cannot be mitigated by other influences.

[Dick Smith]

If that was the way CASA interpreted the act they would not allow lesser safety standard FAR 23 certified aircraft to provide scheduled services to country towns.

If they gave “ more weight” to safety considerations than the cost of air tickets they would mandate the safer FAR 25 standard.

Pretty simple really.

In practical terms you have got to ask “if safety is the most important consideration - then - it is clearly more important than cost”

But they only selectively comply with this.

The wording is flawed but is intentionally there to mislead and allow large amounts of money to be mis allocated

[Lead Balloon]

OK then, TIEW. Walk me through what matters CASA takes into consideration, and what weights are attributed to to each matter, in deciding the standards that should be set for ‘Community Service Flights’.

[PLovett]

Plovett.

I think what is important is what happens in practice. Over the last decade CASA appears to have been responsible for a one way ratchet in increasing costs on GA.

The unique ADSB mandate is just one example. And also part 61.

I have been told many times by CASA people that they do not have any legislative requirement to promote a profitable industry or get more people flying so they can benefit from a safer form of travel.

Seems strange to me that you say they will have to be forced to change. Why would they not want to change and get more people flying.?

What is important is what is argued in court. I have no dispute with you over the ever-increasing costs imposed on GA in the supposed name of safety.

The requirement to consider the industry was removed from the legislation following the Monarch and Seaview airlines crashes. We now have what we have because it was argued that the then CAA (I think) was too close to the industry.

I have long thought that CASA does not want more people flying unless it is in a proper high-capacity airliner. Something they can understand - they have no hope of understanding GA so they would rather it didn't exist. They will have to be forced to change, I see no other way. The industry cannot agree on what day it is let alone come together for a concerted attack on CASA. The pressure must come though the politicians and the only way they will move is if they think they will lose votes. As you might have guessed I don't hold out high hopes for a long-lived GA sector.

[Dick Smith]

Plovett

You make some very good points.

What is clearly now happening was probably not intended. That is a very damaged and contracting training industry. Reported 30% reduction in the last 5 years. This will result in pilots having to be imported if not corrected. Many will come from developing countries and we just have to hope that our extraordinary airline safety record will be maintained.

You are correct that the present cargo cult “safety before cost” claim came in after the Monarch and Seaview fatals. But it was a con. CAA personnel were not too close to these companies. The CAA people were just slack and did not take proper enforcement action when there was a history of non compliance. Also there was not a proper, and still isn’t, administrative fine system.

One day those involved with air safety regulation will see it’s better to be honest with politicians and the traveling public and explain that there will often be decisions made on what the people paying for the benefit can afford. Then the GA training industry will be able to grow again.

[Traffic_Is_Er_Was]

OK then, TIEW. Walk me through what matters CASA takes into consideration, and what weights are attributed to to each matter, in deciding the standards that should be set for ‘Community Service Flights’.

I have no idea what they look at, but I imagine that they examine all aspects, and if they decide that the operation is 'safe' relative to whatever circumstances are proposed to conduct it, they allow it, or allow it if certain conditions are met. It doesn't have to be so safe as to make it impossible, just 'safe', ie not 'unsafe'. Then they've met their obligations as far as I'm concerned.

[Lead Balloon]

Your imagination is perfectly reasonable.

Alas, the reality is starkly different from what you imagine. CASA would’t have a clue, doesn’t have a clue and therefore produces clueless proposasl on what the standards should be for ‘Community Service Flights’.

This is not criticism of CASA. CASA wouldn’t know.

[Traffic_Is_Er_Was]

It's only my opinion. I am no defender or fan of CASA. Your 'reality' is also only your perception and opinion. Like the OP continually fails to realise, perception and opinion are not facts.

[Derfred]

Dick,

I have long thought that CASA does not want more people flying unless it is in a proper high-capacity airliner. Something they can understand - they have no hope of understanding GA so they would rather it didn't exist

You’d be surprised.

When part 61 came into force a couple of years’ ago the airlines (and the FOI’s who inspected them) were astonished to learn that the whole of part 61 was written for GA. It included zero understanding of the way airlines run check and training. This has caused quite a lot of disruption to airline check and training, and is currently not scheduled to be resolved until mid 2019.

[PLovett]

Dick,



You’d be surprised.

When part 61 came into force a couple of years’ ago the airlines (and the FOI’s who inspected them) were astonished to learn that the whole of part 61 was written for GA. It included zero understanding of the way airlines run check and training. This has caused quite a lot of disruption to airline check and training, and is currently not scheduled to be resolved until mid 2019.

Derfred, it might of been written with GA in mind but they didn't get it right, even for GA. It is a total dogs-breakfast.

I heard an interesting comment the other day, albeit third hand. A FAA inspector was talking to an Australian airport inspector and said that he wished the FAA would adopt the NZ legislation. It was everything they had been trying to do but were stymied due to political pressure. Incidentally, the NZ legislation has been adopted by most of our Pacific brethren and we gave foreign aid to PNG so that they could adopt the NZ legislation as well.

[Derfred]

It is a total dogs-breakfast

Yeah, the most expensive dogs-breakfast I ever saw.

[Dick Smith]

Here is an interesting answer to the question from a professional pilot:

https://www.quora.com/Are-4-engine-planes-safer-than-2-engine-planes

The additional safety from four engines is marginal, but it is still there – that is, four engines are safer if the aircraft are of the equivalent most modern, latest certification standards.

I also found this quote from a professional pilot:

“The engines are very reliable these days, so the chance of even one of them stop functioning is low.

Four engined airplanes are more expensive to maintain and even to buy than twin engine airplanes. This is not what airlines want, they want an airplane that is very economical and reliable because it is a business and business is always about making profits.”

[Dick Smith]

Mikewil, yes here is an example. This is what the British CAA Act says:

‘To secure that British airlines provide air transport services which satisfy … public demand at the lowest charges consistent with a high standard of safety in operating the services and an economic return to efficient operators … and with securing the sound development of the civil air transport industry in the UK.

As you can see, their statement clearly reflects that companies need to be viable to be safe.

No lies about the most important consideration being safety!

[compressor stall]

Dick, that quora reply is from Tim Morgan - a web designer who holds a ME CPL and as far as I can tell never flown a jet. Hardly the expert to pontificate on the relative safety of 2 vs 4.

And the second quote is from a first officer from a small Indian Ocean island country of less than two years airline experience.

[CurtainTwitcher]

Dick Smith, rather than sourcing your arguement from Quora, why don't you try one of the other regulators, EASA: AMC 20-6 rev. 2
Extended Range Operation with Two-Engine Aeroplanes ETOPS Certification and
Operation (https://www.easa.europa.eu/system/files/dfu/Annex%20II%20-%20AMC%2020-6.pdf)


I welcome a critique of the certification specifications.

Have a good read of that document, especially the rationale behind ETOPS maximum diversion time based on in-service Inflight Shutdown Rate (IFSD) - this is what determines the maximum ETOPS time interval, a probability based assessment.

[Matt48]

Over 50 years in aviation and 12500 hrs worldwide.
Engine Shutdowns
2 Engines nil
3 Engines 1
4 Engines 2

Based on my experience I would say that twin engine aircraft are very reliable, engine wise.

SRM
There you go, Your experience shows the folly of believing that 4 engines are always going to be safer than two, and if old mate engineer drives to and from the airport, then his argument is null and void.

[De_flieger]

Dick, unfortunately Quora really shouldn't be treated as a key source of expertise as it lets anyone answer any questions, with the only requirement being a real name for their username (which can be faked). There's the ability to upvote answers or writers, which helps to some degree but there's still no real guarantee of accuracy - as you've seen, anyone with a CPL can list themselves as an expert, and if you look through some of the military questions the answers are clearly written by people who get their expertise through Call of Duty on the XBox - some of them are also still in their early teens, which seems a bit young to have their claimed years of special forces combat experience :rolleyes:

There's also quite a few "experts" who write authoritatively on numerous topics, listing their expertise in fields that would take several lifetimes to accumulate...the Special Forces soldier/CIA agent with the expertise in nuclear weapons, hand to hand combat, billion-dollar business administration, submarine warfare and computer hacking...luckily that's entirely unlike any Rumour Networks for Profeshionull Pilots!

[Dick Smith]

Here is a link to Chapter 5 in Two Years in the Aviation Hall of Doom (http://rosiereunion.com/file/Two%20Years%20in%20the%20Aviation%20Hall%20of%20Doom%20Chapt er%205%20-%20The%20ARP%20smokescreen%20-%20re%20Metro%20III.pdf) that covers the relevant issue about the Metro III. In fact, Max Hazelton had a Beech 1900 sitting in the Hawker hangar for over 8 months as they were trying to modify it to comply with the unique Australian rules. It was only when my Board approved the first of type from five countries that this aircraft was allowed to operate – and indeed, further improvements came in that allowed more people to fly, such as ETOPS.

Have a read and cry about the fact that we are now back where we were then in the Two Years in the Aviation Hall of Doom days. Just look at the recent CASA class G ARP or whatever it is now called.

[Dick Smith]

Compressor. Looks as if he has loads of commonsense!

[Dick Smith]

Curtain. Very strange. Why would there be extra restrictions placed on two engined aircraft if they are as safe as three or four engined?

Now that’s a difficult one to answer.

[CurtainTwitcher]

Curtain. Very strange. Why would there be extra restrictions placed on two engined aircraft if they are as safe as three or four engined?
To ensure equivalence of safety.

You can have four engines maintained to a lesser standard, or two to a higher standard. Manufacturers & airlines concluded the best overall cost optimisation for equivalent safety or better was to go with the twinjet system.

One large operator used to take the engine cores from an ETOPS twin once it went out of spec and then install it on it's four engine aircraft.

In 400+ sectors on a four engine jet, I had 3 inflight shutdowns. I've spent 9 hours in cruise across the pacific on 3 engines. In 4,500+ sectors on a twinjet, I've never had an engine miss a beat, never.

So, about the Certification Specifications critique...

[Dick Smith]

Thanks Curtain. Personally I have always been comfortable with the decisions made internationally in relation to certification standards.

That’s why I was instrumental in the introduction of CAA acceptance of first of type from the five leading countries.

The problem I have is with 9a of the act. It would be great to have the act reflect what CASA often does in practice.

[michigan j]

What about this argument?

Given
1) s9A does not mean that safety is the only consideration
2) CASA policies (shadowing ICAO) say that risks should be kept 'As Low as Reasonably Practicable' (also see s11 - international agreements)
3) Policies that are not in conflict with legislation are relevant for the interpretation

Then doesnt this mean that ALARP is already a consideration for decision making? (Or, if it isn't, then a court may find that it should be...)

And terms like 'reasonable' are very established legal concepts... Cost is very much a test of 'reasonableness'

It also occurred to me that the ATO has quite well established rules thanks to the 20 odd million taxpayers (some of whom are quite litigious) who are constantly testing the system. Contrast with the 2000 odd AOC, AMO, aerodromes etc, none of whom want a bar of dealing with CASA.

[Lead Balloon]

So apply your reasoning to setting standards for Community Service Flights.

What standards should Community Service Flights meet? Walk us through all of the matters you take into consideration, and how you weigh up the costs and benefits and relative importance of each, to set the those standards.

(Reaches for popcorn...)

[Derfred]

Thanks Curtain. Personally I have always been comfortable with the decisions made internationally in relation to certification standards.

That’s why I was instrumental in the introduction of CAA acceptance of first of type from the five leading countries.

The problem I have is with 9a of the act. It would be great to have the act reflect what CASA often does in practice.

Agreed, Dick,

And as I said in my earlier post, an ETOPS/EDTO challenge is not the appropriate argument to support your problem with 9a.

You need to come up with a better one. The ETOPS/EDTO argument can be shot out of water. Surely you can find something better for your 9a challenge.

If I was looking for one, I’d be looking for an example of significant reduction of important services to rural communities caused by CASA’s apparent adherence to 9a with undue cost/benefit. That would get community support, raise headlines, and ruffle CASA and Government feathers. Isn’t that what you’re after?

Regards, Fred