The High Priest In Action.

[Sunfish]

The high priest in action: - railing against cost benefit analysis - Feb 2014.

We are to forget science and do what we are told. If we do not use science and mathematics to manage risk, then what else is there? Only the dictats of a high priest who believes HIS truths are superior to any other. Is this still common in CASA? The attitude towards Angel Flight suggests it is.

I was formerly a Chief Airworthiness Engineer in the Civil Aviation Authority, and a member of the Air Navigation Commission’s Airworthiness Panel. I am a graduate of the University of Sydney in Aeronautical Engineering, the RAAF Academy, RAAF Basic Flying Training School, and the RAAF Staff College. I have been elected as Associate Fellow of the Australian Institute of Management and an Associate Fellow of the Royal Aeronautical Society. I have 30 years experience in airworthiness control,especially of aging aircraft, and including numerous accident investigations.

I have made this submission because, with all due respect to the Director and his staff, I strongly suspect that several basic principles of achieving safety in aviation have gone missing in action. CASA appears to be entrenching policies that were forced upon the “captured” CAA in times of financial stringency, and yet corporate management appears to be gold plated. ATSB continues to be ineffective and administrative separation of ATSB from CASA, and CASA from the AGPS, are taken for granted. Is CASA to become little more than a client of the European Airworthiness Authority, the FAA or,manufacturers, and incapable of independent thought and action.


One of the more common cries from the industry, and from other arms of government,a proposal that has some superficial intellectual appeal, especially to those who dislike trusting technocrats.2 is that all proposed aviation safety regulation should be tested by cost-benefit analysis before implementation.

In the aftermath of each successive aviation catastrophe, however, the public cry has been that such a concept is outrageous. "You must not put a value on human life!"Both opinions are most often expressed extempore or off-hand of course, and with little appreciation of just what is being said. The matter is discussed in Appendix A When one pays for aviation safety one pays for a reduction in the risk of an accident. The risk is all but immeasurable and the dollar value of reducing it is inestimable. Cost-benefit analysis is neither appropriate nor practicable in aviation safety regulation. The resulting bald and mainly hypothetical cost-benefit arithmetic, divorced from discussion of the issues essential to the political decision to regulate or not to regulate is of no value.

The class of analysis proposed is unlikely ever to address the issues which should determine whether a proposed safety regulation is implemented or not.

2. A proposition with similar appeal is that the content of all proposed aviation safety legislation should be the subject of industry consultation before promulgation.


Actuaries "put a price on human life" every day for the insurance industry. Indeed, I have just received a quote for over $3000 for insurance on my country property - another example of cost / benefit analysis.

When is the Government going to wake up?

The intellectual arrogance of this submission is devastating.

https://www.infrastructure.gov.au/aviation/asrr/submissions/files/250_a_emmerson_8_feb_2014.pdf

[Lead Balloon]

Cost-benefit analysis is neither appropriate nor practicable in aviation safety regulation. It happens every day in aviation safety regulation, too. That’s why e.g. there’s no tower or ILS at YMIA.

I assume this buffoon would ‘ban’ all aviation operations except in Transport Category aircraft in and out of airports with CATIIIC approach aids. But wait, that’s still not a risk-free activity...

[aroa]

Some interesting stuff and fluff in there.
From an av-plebian, without all the badges as on his collar,and been fcuked over by CAsA twice, I do like the comments in the Recreant Regulator. Says it all really their 'recreancy' destroys their given trust. It most surely does.

When the heads in Av House , St Comode, Dr Discrepancy, Anusnasti et al,, lie cheat and pervert the course of justice, and those in regional offices conspire and perjure themselves ...and this is all seen as the CAsA "normal", no wonder they are despised and not trusted by the industry
Webster Dictionary Recreant...cowardly, mean spirited. (yep!!) and in manner.. basely, falsely.
Yep thats them to a T.

But the problem remains...how to fix the rotten place.?

[FGD135]

Cost-benefit analysis is neither appropriate nor practicable in aviation safety regulation.A truly incredible statement. Only somebody with no background in the private/corporate sector could have come up with it.

[Lead Balloon]

As Sunfish’s naming of the thread suggests, it’s religious zealotry.

However, the ‘High Priest’ got at least one thing right in my view: Standards setting is a political process, not a technical process. Government policy makers, not regulators, are supposed to decide the balance between risk and cost. Unfortunately, when that responsibility has effectively been abdicated to the regulator, the inexorable drive is towards more complex and restrictive regulations.

[LeadSled]

Sunfish,
A name from the NSGODs (Not So Good Old Days) of DCA and later, and yes, it is a pretty good example of the basis of what we have to deal with in CASA ---- all part of the corporate culture.
Not an isolated attitude.
As you can imagine, the DCA thro' CASA resistance to Cost Benefit justification as per OBPR etc has been prodigious over the years.
Indeed, the whole Cth Public Service is not what you would describe as enthusiastic costs cutters, or enemies of red tape.
Tootle pip!!

[cattletruck]

The way of the modern world is the executive just want more money, nobody wants to actually do anything hard like heaven forbid - fix things. Bimbo management are now stellar in the corporate world.

[michigan j]

I guess ICAO has got the Reasonably Practicable part of ALARP wrong all this time...

(Just read the excerpts above - no wish to read the rest of the article)

[exfocx]

"Actuaries "put a price on human life" every day for the insurance industry. Indeed, I have just received a quote for over $3000 for insurance on my country property - another example of cost / benefit analysis."

Sunfish, are you going to say that the cost / benefit analysis by an Actuary is the same as for C/B for a multitude of different areas of aviation? When deciding at what price to give life / property insurance, they have a wealth of data to come to a decision for pricing.

For the life of me I cannot see how anyone can interpret this submission the way everyone here has.To accuse this guy of ignoring science / stats is just hysterical given his professional quals compared to anyone here. My take from his comment about C/B in regulation is that at times it isn't always going to be appropriate and those with the technical expertise should prevail. The vast majority here appear to believe the bean counter view should prevail, which to me is surprising given the attitude to bean counters when it comes to running an airline or business in general.

[Vag277]

Read the whole paper and think about Australian social expectations of the 40s & 50s whenhis views evolved. Much of what he writes should be thought about

[Lead Balloon]

It's not an argument about whether "bean counters" should or should not prevail over the decisions of others.

It's about the fact that the number of beans will always be finite, and that all day - every day - decisions must be made about how many of those finite beans will be allocated to mitigate what risks among the infinite number of risks we all face.

We'd all love it if aircraft structures and systems were 100% reliable. And that's what everyone's working towards. I'll say this without intended disrespect to anyone: Any idiot can come up with the idea that it would be great if aircraft structures and systems were 100% reliable and that it's an outcome 'worth' pursuing.

But there will never be an aircraft structure or systems that are 100% reliable. Never.

And dare I say it: The history of aviation is littered with disasters caused by well-meaning engineers - even 'Chief Engineers' - whose bright ideas turned out not to have had a positive impact in the real world, as a consequence of some factor that was not taken into consideration or some failure mode the effects of which were not properly thought through. Each generation seems to consider that it has reached the apotheosis of knowledge and wisdom as a consequence of knowledge of the errors of the past, without realising that was the view of the previous generation and each of the proceeding ones in succession.

We see it on this very day. Today. The contemporary 'High Priest' in airworthiness in CASA has decided that Community Service Flight passengers will be safer if the maintenance requirements of the aircraft in which they are flown are 'upgraded' to 'commercial' standards. That's 'intuition-based' engineering, not 'evidence-based' engineering. No need to do a cost/benefit analysis. It's - I think the engineering term is 'dumb' - dumb to increase risk by mandating maintenance that evidence shows will have a substantial probability of creating more risks than it mitigates.

[exfocx]

Lead Ballon,

"But there will never be an aircraft structure or systems that are 100% reliable. Never."

Correct, and where does he even suggest anything like that? What I'd suggest he is arguing is the difference between what a C/B analysis and what a science / stats based view is, I don't believe they are the same, I'd go as far as to say that a C/B analysis is pretty subjective.

"Any idiot can come up with the idea that it would be great if aircraft structures and systems were 100% reliable and that it's an outcome 'worth' pursuing."

Can you name the idiot who has claimed the above? No, and he hasn't made any such claims either, these are strawman arguments. There is NO 100% reliable ANYTHING!

As to your comments on the ATSB findings on the Community Service Flight accident rate I'd like to see a counter argument on their stats, using statistical analysis, not just someone in a senate hearing claiming they got it wrong. By saying this I'm not making judgement on it, but it would be pretty stupid of them to just randomly make statements like that when it would be easy enough to get a statistician to review it. I would add I think CASA and the ATSB are way too close for my comfort.

"It's about the fact that the number of beans will always be finite, and that all day - every day - decisions must be made about how many of those finite beans will be allocated to mitigate what risks among the infinite number of risks we all face."

Sure, but it's amazing that pilots on Prune lambaste bean counters all the time about the way they count the beans and allocate them. Because it's so subjective. Work for a company that cut up an aircraft which the Flight & Eng depts loved as it was in good condition, except the bean counters said is wasn't as cheap to run! This is what I believe he's arguing against, not a blanket "it must be accident proof", ****, he's an engineer (tertiary trained, not a LAME and by saying that I'm not putting them below pilots) and he'd know ALL about what you are railing against.

I'd suggest he's also against your "The contemporary 'High Priest' in airworthiness in CASA........" for the same reasons.

Btw, I haven't bothered to read anything other than the quoted parts of his submission, and don't think I need to otherwise it should have been included in the piece.

[Lead Balloon]

"because it's so subjective".

The amount of money that's spent to mitigate risks in aviation is, sadly, substantially subjective.

That's the problem.

Subjective risks can be objective nonsense.

[exfocx]

lolololol

Lead Ballon, so you agree. I think the gentleman was / is arguing for actuarial style decision making, not the C/B subjective analysis decision making by people who are mostly lacking the technical skills required.

[Sunfish]

Exfocx, your pathetic faith in technical skills is touching. Me, I prefer data driven decision making, not some Bishop making an Ex Cathedra judgement about what she thinks is “safe”.

It also begs the question about what RAAF/military aircraft designers think is “safe” and what Civil aviation manufacturers and operators think is “safe”.My experience is that in some cases they are worlds apart and that experience of one doesn’t necessarily translate to the other.

[exfocx]

Sunfish, you're kidding yourself if you think you're data driven, you're belief driven just like your Bishop. It shows up in your comments / reaction.

[aroa]

"CAsA and ATSB too close for comfort" They have an MOU and are joined at the hip. And the Hooded One ex CAsA.

[Sunfish]

Sunfish, you're kidding yourself if you think you're data driven, you're belief driven just like your Bishop. It shows up in your comments / reaction.

This is a non sequitur.

[exfocx]

And yours is an ad hominem strawman!

[Lead Balloon]

So let’s cut to the chase, exfocx: Is the imposition of ‘upgraded’ maintenance standards on aircraft engaged in ‘Community Service Flights’ a decision that results in a decrease of the ‘safety of air navigation’ or an increase in the ‘safety of air navigation’?

Increase in the safety of air navigation?

Yes or no.

[exfocx]

Lead Ballon,

I cannot answer your question as yet as I'm only up to pg 10 at present (So far no mention of the Angel Care Flts). But I feel fairly certain that you have not read his submission (Emmerson's) anywhere near its entirety. My guess is he pretty much against DS and changes he brought about.

[Lead Balloon]

Once you get to a ‘yes’ or ‘no’, please post your answer. Your answer to my question.

[exfocx]

Lead Ballon,

Having finished Emmerson's submission I have neither a Yes or a No for you. I have no knowledge whatsoever of the difference in standards to be able to make any comparison and I have no expertise in the area. I also presume the submission precedes the Angel Flight saga (of which I'm only vaguely aware) and I have no idea to whom it was made or the reasons. However I assume your beef is with his argument against CBA. To be honest I'm somewhat flummoxed by your attitude towards him, I don't see him as a technocrat in the derogatory way as you and Sunfish have described him and I found his attitude and position on regulation to be well argued and I didn't find him to be ideologically fixated in his professional opinions. I believe a good example of of his lack of ideology is evident on page 23 under the heading: The relative Roles of Standards and Good Judgement (for some reason I cannot C & P from the PDF).

In my opinion I found him to be arguing for a professional regulator free of undue industry influence and not suffering from regulatory capture as was demonstrated in the Hayne RC (ASIC & APRA).

[Sunfish]

The problem Exfocx is that “good judgement” of which you speak exists only in the brain of the judge.

‘’What we have currently in CASA is exactly the same as a priesthood. Like the Catholic Church, they have their dogma and anyone who argues against it risks excommunication or being burned at the stake, like Glen Buckley.

A harmful part of that dogma is to reject cost benefit analysis as preached by ICAO. This is exactly the same as the Catholic church rejection of the heliocentric model.

Ever heard of FMEA?

[exfocx]

Sunfish,

Imo he'd most likely agree with you about the present setup! His argument is about a professional CASA, which some may argue we had 30+ yrs ago. If you have read his piece on CBA you have the same situation as what you have said about judgement. I'd say his view of CBA is that it is nothing like your actuarial work, but bloody subjective and open to selective use of data etc.

No (FMEA), but have since looked it up. My guess is he would state that CBA is not on par with that.

I cannot help but feel you may not have read it completely. Why don't you try and contact him and get a better idea of where he stands, maybe you'll find you're a lot closer than you think. He doesn't come across to me as a closed minded idiot.

[Lead Balloon]

As to your comments on the ATSB findings on the Community Service Flight accident rate I'd like to see a counter argument on their stats, using statistical analysis, not just someone in a senate hearing claiming they got it wrong. By saying this I'm not making judgement on it, but it would be pretty stupid of them to just randomly make statements like that when it would be easy enough to get a statistician to review it. I would add I think CASA and the ATSB are way too close for my comfort.The Angel Flight submissions put up a ‘counter argument’ to the ATSB’s (selective) use of stats.Angel Flight rejects the claim in the ATSB report that, for Angel Flight passenger carrying flights, the “fatal accident rate was more than seven times higher per flight than other private flights” as invalid.

A valid analysis addressing passenger risks would require comparison of passenger carrying Angel Flights and other passenger carrying private flights. Since no such data are available for other private operations, the only reasonable comparison is between all Angel Flight operations and all other private operations. Even then, results must be treated cautiously because an unknown proportion of private operations involve circuit training and short local flying whereas all Angel Flight operations involve flights with an average sector length of 1.5 hours.

The analysis in Table B2 on page 69 shows that, when all Angel Flight sectors are included, the fatal accident rates are 0.5 and 0.2 per 10,000 flights for Angel Flight and other private flights respectively, and the difference is not significant. Furthermore, when all accidents are included, the rates are 1.1 and 1.5 per 10,000 flights for Angel Flight and other private flights respectively.

And where is the ATSB finding to the effect that lack of maintenance or any airworthiness issue had any causal connection with either of the Angel Flight accidents? There is none. Yet ‘someone’ decided to mandate more maintenance for aircraft engaged in Community Service Flights, despite the evidence that it will increase risk (and cost). I’d like to see a ‘counter argument’ to this: https://www.savvyaviation.com/wp-content/uploads/articles_eaa/EAA_2011-03_the-waddington-effect.pdf

Being the defenceless end of the ‘food chain’, GA just has to cop whatever intuition-based mumbo jumbo the safety zealots come up with.

[exfocx]

Lead Ballon,

I don't accept the old "there are lies, damn lies and statistics", I would agree there are stats and there are stats, statistics don't lie, but they are open to the manipulation of data to produce desired results. Thus there is a problem, claim and counter claim via stats!

With regards to the Angel Flt situation, I don't know, however I still agree with the view of Emmerson, which I think you are confusingly tying into this.

[Sunfish]

Exfocx, I did the statistics on Angel Flight months ago and showed that the ATSB was talking BS. I used to do analysis work like this professionally for an airline, including setting up monitoring systems to pick trends, data that we shared with the regulator.

CASA is a regulator that thinks the aircraft knows when it is doing an Angel Flight and then, like the vicious creatures they are, decides to deliberately break or fail. That is why extra maintenance is needed for Angel Flight aircraft.

Aircraft also know when they are flying over water.....you can hear the engine note change; ta pocketa pocketa pocketa..........

[exfocx]

Sunfish no offence, but what is your training on stats?

As to water, that's risk management. What happens when one stops, which statically will happen?

I doubt anything will statisfy you.

p.s. I'm done.

[OZBUSDRIVER]

In simplest of terms...CASA are nothing but professionalised knee jerks.

[Sunfish]

Exfocx; statistical quality control. I used to even do it at an ammunition factory as a Uni student.

[aroa]

ozbusdriver...sure its the knee.? I'm convinced its something else.

[Ex FSO GRIFFO]

Re ...''Aircraft also know when they are flying over water.....you can hear the engine note change; ta pocketa pocketa pocketa....'...…

Maybe not quite correct Sunny,....but I can tell you that each time I crossed Torres Strait, to & from, I could hear those valves opening and closing......TROOLY...….
And, its only 105nm....with a couple of 'options'.....

But we all survived.....
Cheeerrrsss...https://www.pprune.org/images/statusicon/user_offline.gif https://www.pprune.org/images/buttons/report.gif (https://www.pprune.org/report.php?p=10599546)

[Sunfish]

The secret life of walter mitty reference: “ta pocketa pocketa pocketa “

[aroa]

Over water...if the engine does stop ...then with the prop standing up, unmoving, I guess exfocx is "statically" correct.
Then one considers the options available.!!
Forget the engine ,it has absolutely no idea where it is , over water or jungle covered mountains.
Its all in the pilots head. And where you fly depends on the risks you are prepared to take. and the preparations you have made in the unlikely event of...
....pocketa, pocketa, BANG.! and.silence but for the wind noise.
A forced landing sure does concentrate the mind..!!

[LeadSled]

Folks,
Apparently, unlike any post to date, I have actually made the acquaintance of, and had professional dealings with, the gentleman who is substantially the subject of this thread.

In my opinion, it is the attitude conveyed in his submission that encapsulates an approach to civil aviation regulation that is the basis for so many of the "Australian" aviation problems.

Described in an inquiry report, many years ago, as the Mystique of Aviation safety, bamboozling politicians and the public alike, used as a management technique that aggregates all power for the management of civil aviation (NOT just administration of air safety regulation) to "the authority" ---

If you believe aviation is best served by "the authority" having absolute and unfettered power of every aspect of civil aviation, the "authority" to micro-manage every aspect of civil aviation, without intrusion from industry, political or any international influence, or real world commerce, I believe you will have found a supporter..

Tootle pip!!