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Old 17th Jun 2014, 04:53
  #941 (permalink)  
 
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Creampuff I think the second sentence in paragraph 6.13 may be slightly longer - I counted 184 words before I nearly fell asleep. But I'm not sure what it means - perhaps you can decipher it? I think it means "We couldn't be stuffed introducing an internal review process for regulatory decisions". To be sure, I could be wrong because by the time I got to the end I forgot what it was about and I didn't have time to go back to the beginning.

Last edited by Boratous; 17th Jun 2014 at 07:00.
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Old 17th Jun 2014, 07:29
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Pineapples at dawn!

Although not nearly as long as Bor-it-up-em's... 6.13 word count, however 6.22 is worthy of respect (162 words by my count) as it is a full and complete para with no bullet-points. I can also (unbelievably..) understand large slabs of it, maybe because FF are quite proud of their achievements in the area of enforcement action.

With that in mind, and to put 6.22 in context I have decided to quote the whole relevant section.

WARNING : BYO bucket.. {I believe this warning is in red}:
Assessing the Effectiveness of Enforcement

6.21 As all regulators, and those who closely study the processes of regulation, know only too well, it can be difficult to accurately and reliably measure the effectiveness of enforcement action.55 One useful and objective measure of the effectiveness of CASA's enforcement processes is reflected in the number of CASA decisions affirmed in the AAT and the number of prosecutions mounted by the CDPP in which convictions or findings of guilt were obtained.

6.22 On these measures-which appear in CASA's 2012-13 Annual Report for that year and the preceding five years,56 and which have been updated to 31 December 2013 in material recently provided to the Review Panei-CASA's performance may fairly be characterised as very good and steadily improving. As the Review Panel will have seen in the data we have already provided, there has been a significant increase in the number of what might be described as 'successful' enforcement outcomes for CASA over the past three years. And whilst there may be a number of reasons for this, one compelling explanation is that the enforcement action taken in response to the breaches identified has been more appropriate, and the decisions taken were the product of greater circumspection and consideration. At all events, these results arguably reflect the positive effects of CASA's commitment to, and a growing appreciation amongst CASA's managers and staff for the importance of, better informed and better disciplined decision-making.

6.23 More importantly, as the majority of potential enforcement matters that have arisen in recent years have been subject to the Coordinated Enforcement Process, it is notable that, in the last 12 months, of the approximately 300 matters referred to the Coordinated Enforcement Process, 46 resulted in recommendations for initiating administrative action (usually to vary, suspend or cancel an authorisation), 103 infringement being notices issued and 14 matters being referred to the CDPP.
{I believe 6.22 is in green??} Besides the obvious self-congratulation going on in those paragraphs, I think what FF are inferring is..."We are a law unto ourselves"......however I'm not entirely sure??

On the same subject matter I noticed that the REX submission had this much more understandable summary (with stats) on page 15:
6. INDUSTRY RELATIONSHIP WITH CASA

This has deteriorated in recent years. CASA seems preoccupied with acting as a ‘Big R’ regulator rather than working in partnership with industry to achieve better safety outcomes. The amount of enforcement activity has increased while the service delivery standards established in 2006 are no longer applied.

Examination of CASA annual reports show a strong upward trend in the number of infringement notices issued by CASA.

FY/Notices '05/79 '06/107 '07/109 '08/146 '09/153 '10/171 '11/135 '12/197 '13/190

The CASA Service Charter says, in part:
A good regulator will demonstrate fairness, good judgement, and be
flexible and responsive to the changing environment in which the aviation
industry operates… CASA must provide a high level of client service, and
treat clients with consideration and courtesy.


Rex is of the view that CASA is not fulfilling its obligations with respect to client services. As an example, there has been a lengthening of the processing time for aircrew medical certificates leading to periods when pilots are unable operate aircraft.

Over the past year Rex has lost 20 pilot days as a result of the late renewal of aircrew medical certificates.

The CASA approved Rex Group Audit Manual provides at section 2.2.4: 2.2.4 Third Party Supplier/Contractor Self Assessment Review and Reminder.

Self assessment forms are distributed to each supplier/contractor via email or posted via mail biennially. Once returned, the completed forms are reviewed, the supplier/contractor is risk rated and the relevant "Third Party Suppliers Register" is updated.

CASA is a supplier of regulatory services and accordingly was requested to complete a Third Party Self-Assessment Review form. CASA denied the request on the grounds that the services it provides to Rex are in accordance with its statutory obligations, and are not subject to contract.

Rex considers that the regulatory services functions of CASA are the same as any other supplier and should be subject to the same scrutiny. In some cases services have been contracted out by CASA to third parties where they are then subject to audit.

The relationship with CASA presents a significant business risk for the Rex Group and it is only prudent that Regional Express should seek to scrutinise the internal processes of CASA to ensure they comply with its statutory obligations and requirements.

Alternatively, CASA should be subject to scrutiny from an independent body. CASA’s Industry Complaints Commissioner is a part of CASA and reports directly to the Director so cannot be considered independent. Rex believes that CASA should be oversighted by a specialist Ombudsman similar to those that exist in other industries such as telecommunications.
Now there is a passage of text & stats that even the man at the back of the room can get his head around...

{Comment: On Section 6 Improving Oversight and Enforcement of
the Aviation Regulations,
I note that they forgot to mention the DAS (STBR) embuggerance loophole, as proudly stated (by the DAS) in the foreword of the enforcement (embuggerance) manual}:
Most of the regulatory decisions CASA makes are such that conformity with authoritative policy and established procedures will be conducive to the achievement of these outcomes. From time to time, however, decision-makers will encounter situations in which the strict application of policy, in the making of a decision involving the exercise of discretion, would not be appropriate. Indeed, in some cases, the inflexible application of policy may itself be unlawful.
MTF...

Last edited by Sarcs; 17th Jun 2014 at 07:40.
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Old 17th Jun 2014, 08:04
  #943 (permalink)  
 
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CASA hoist with its own petard:

6.23 More importantly, as the majority of potential enforcement matters that have arisen in recent years have been subject to the Coordinated Enforcement Process, it is notable that, in the last 12 months, of the approximately 300 matters referred to the Coordinated Enforcement Process, 46 resulted in recommendations for initiating administrative action (usually to vary, suspend or cancel an authorisation), 103 infringement being notices issued and 14 matters being referred to the CDPP.
Translation:

300 referrals broken down as :

137 - No action.

!03 - Infringement notices.

46 - suspensions or cancellations.

14 - Prosecution attempts.

1. Out of 163 allegedly actionable events, only 14 (8%) were found to have enough evidence admissible in a court of law to be capable of prosecution.

2. Out of 60 cancellations or suspensions, only 14 (23%) were found to have enough evidence admissible in a court of law. The balance (77%) were not tested in court.
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Old 17th Jun 2014, 09:51
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Prosecution serves different policy purposes to suspension or cancellation action.

(Well played, Boratous: 6.13 is now in the lead! )
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Old 17th Jun 2014, 10:42
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I can see a pattern in CAsA's legal work. you create a term cobbled together out of nonsense words. then you make it a heinous crime. then you mount an inquisition hunting for miscreants.

ok could someone please tell me what the term 'endangering the safety of aerial navigation' actually means.

I've only been at this aviation pursuit of mine for 41 years.
I've tried to make sense of the term but in all honesty it is an assembly of nonsense words.
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Old 17th Jun 2014, 11:44
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Sunfish.
How ever the cost involed for the inacent still would have amounted to thousands of dollars and added stress that was not needed or called for.
There own actions should be accountable for a start as a minimum. If they stuff up they should have to pay costs. This is the joke we now all living.

Cheers
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Old 17th Jun 2014, 11:49
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REX are right on the money! However I pity them during the next audit, CAsA don't like bad things said about them
They said,
Alternatively, CASA should be subject to scrutiny from an independent body. CASA’s Industry Complaints Commissioner is a part of CASA and reports directly to the Director so cannot be considered independent. Rex believes that CASA should be oversighted by a specialist Ombudsman similar to those that exist in other industries such as telecommunications
I heard on ABC radio this morning that there may be an independent audit of Fort Fumble coming up, but I guess seeing is believing. But it would be interesting to see the ANAO, FAA and ICAO all undertake a robust audit of the "long sentence, wank word spewing big 'R' regulator"

P.S Rather unfortunately I have read a number of transcripts and silly articles by the Witchdoctor over the years, and I am sure that there are other sentences in those ridiculous writings that beat Sir Boratous and Creamy's postings! However the Doctors ramblings are so painful to endure that I would rather count the hairs on Chairman Hawkes spotty ass, watch paint dry, or spend an entire year cleaning the worm castings out of the Brisbane CAsA HQ worm farm with my teeth.
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Old 17th Jun 2014, 12:00
  #948 (permalink)  
 
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If I were the man at Rex I would video record all of CAsA's next inspections.

Why would you do that you might ask?

evidence me lud, evidence. ...CAsA will work hard not to create any

Last edited by ib-jason; 1st Jul 2014 at 21:01. Reason: Admin testing editing functionality
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Old 17th Jun 2014, 16:22
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Put the casa snippet above into a readability index tool. Didn't come out as bad as I expected!

Readability Test Bookmarklet
The Readability Test Tool
Let's make the unreadable readable
Readability Test Results

This page has an average grade level of about 17.

It should be easily understood by 22 to 23 year olds.

Tweet this result!

Readability Indices

Flesch Kincaid Reading Ease 23.4
Flesch Kincaid Grade Level 17.9
Gunning Fog Score 20.2
SMOG Index 15.1
Coleman Liau Index 14.2
Automated Readability Index 18.5
Text Statistics

No. of sentences 10
No. of words 320
No. of complex words 69
Percent of complex words 21.56%
Average words per sentence 32.00
Average syllables per word 1.78
What do these results mean?

The indicator bars give a visual guide for the readability of the text. Red is a low readability score. Green is easily readable.

Flesch Kincaid Reading Ease

Based on a 0-100 scale. A high score means the text is easier to read. Low scores suggest the text is complicated to understand.

206.835 - 1.015 x (words/sentences) - 84.6 x (syllables/words)
A value between 60 and 80 should be easy for a 12 to 15 year old to understand.

Grade Level indicators

These equate the readability of the text to the US schools grade level system.

Flesch Kincaid Grade Level

0.39 x (words/sentences) + 11.8 x (syllables/words) - 15.59
Gunning Fog Score

0.4 x ( (words/sentences) + 100 x (complexWords/words) )
SMOG Index

1.0430 x sqrt( 30 x complexWords/sentences ) + 3.1291
Coleman Liau Index

5.89 x (characters/words) - 0.3 x (sentences/words) - 15.8
Automated Readability Index (ARI)

4.71 x (characters/words) + 0.5 x (words/sentences) - 21.43
Coleman Liau and ARI rely on counting characters, words and sentence. The other indices consider number of syllables and complex words (polysyllabics - with 3 or more syllables) too. Opinions vary on which type are the most accurate. It is more difficult to automate the counting of syllable as the English language does not comply to strict standards!

Creampuff's sentence didn't fair well

Reading Ease

A higher score indicates easier readability; scores usually range between 0 and 100.

Readability Formula Score
Flesch-Kincaid Reading Ease 11.7
Grade Levels

A grade level (based on the USA education system) is equivalent to the number of years of education a person has had. Scores over 22 should generally be taken to mean graduate level text.

Readability Formula Grade
Flesch-Kincaid Grade Level 21.2
Gunning-Fog Score 23.2
Coleman-Liau Index 14.6
SMOG Index 15.8
Automated Readability Index 22.1
Average Grade Level 19.4
Text Statistics

Character Count 397
Syllable Count 142
Word Count 77
Sentence Count 2
Characters per Word 5.2
Syllables per Word 1.8
Words per Sentence 38.5

Last edited by halfmanhalfbiscuit; 17th Jun 2014 at 17:09. Reason: Another example.
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Old 17th Jun 2014, 20:00
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Ear to the ground.

I would prefer to wait, a very long wait before havng to endure the Sleepy Hollow spin machine swinging into action. But word is the slaves are in the basement, sweating and cursing shovelling coal into the spin boiler as part of the pre start check. The GWM in their favourite ensemble de jour, Mai Tai in one hand, whip in 'tuther; keeping the trolls and catamites 'at it'.

It won't be too long before the 'machine' starts phase two. Historically it's their default defence; start producing masses of stultifying, sacrin sweet, meaningless, motherhood nonsense in glossy covers – "But minister – look-see here, we done all this real good stuff" (produces large pile of twaddle) "we tried hard" (shows sweaty hanky) "but they are obdurate and stubborn, just the ills of society, impossible creatures; here read this world class educational material", (hands over large pile of bumf with smirk). – Safe in the knowledge that no one political will read it, certain the mystique of air safety will protect and having no doubt at all that no one would dare question 'the authority': even if they could understand it....

They could of course save the coal, too little, too late and way too much damage to repair. Sack them minister, sack the whole bloody lot. Save the dollars and shut the spin machine down before it gets going and we have to wade through anymore nauseating clap trap. You watch – 'Understanding the new regulations 101' will on the streets before the ink is dry.

Now, if you think their submission to Forsyth was risible, wait until the dross and Tosh for industry starts to flow through. Masters of cynical deception, Kings of spin, the artful dodgers of the legal and aeronautical world; smoke and mirrors specialists all. All without a blind clue of how to manage aviation. For expert, experienced advice on industry, stick with professionals; read their submissions and compare. Don't let 'em fool you mate – not again.

Toot toot

Last edited by Kharon; 17th Jun 2014 at 20:48.
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Old 17th Jun 2014, 22:04
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Kharon, with 267? Submissions there must be patterns evident. Surely can't be a coincidence and all fake from ios.

A visit from FAA or icao could be the straw that breaks camels back.

But yeah, they may just pull off another magic trick and fool the minister.

It is like the emperors new clothes though.
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Old 18th Jun 2014, 00:42
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Infringement notices...

While CAsA may pat itself on the back with IF/PNs count,one has to ask what they were all for and the relevance to any "safety case"...if there was one.??

For example... Phil The Dill (LIster of Barrier infamy) got CAsA $550 from a PPL for adding hydraulic fluid to his brake reserviour. Perp failed to enter that action on the MR...because now in Sched 8 there is a new footnote statement.. that an entry be made in the MR .."if appropriate".
So Phil decides on the appropriateness of an MR entry or otherwise.
And the result is one seriously pissed off PPL and the benefit to the "safety case" is, as usual ZERO. Some fn statistic! Bet there are similar others.

This is the method of totalitarianism...one never knows how the "rules" will play out. Nothing is fixed.

Cooperative approach by CAsA? NO. Safety benefit? NO
But it does allow tossers to exercise the small penile power muscle and pretend they are saving Australia from falling aeroplanes and ensuring the safety of air navigation.

Last edited by IBobi; 30th Jun 2014 at 21:38. Reason: Admin edit -- no threats
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Old 18th Jun 2014, 01:15
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What is safer? 10,000 penalty notices issued or Zero penalty notices issued?

accidents / incidents per thousand hours is the only true measure.

as for cost benefit analysis, there is plenty of published methodology for that.

what for example, is the point of me fitting ADS-B? I thought about a GTN650 as a certified nav source with a Garmin 330 transponder. AhHa! I thought, little Sunfish will be plainly visible to all and sundry and ATC will smooth my path for me on occasion.

Then I realised that all I was doing was fitting an automatic infringement generator with zero safety benefit to me personally. A simple ADSB feed to CASA from Airservices and CASA is alerted my flying and can track my every move in real, or pseudo real, time.

And I still don't see why a GA VFR aircraft needs a certified ($8000) GPS when we are not supposed to be anywhere near big jets, and in any case the ADSB message has a quality of fix field that can be set to a lesser value then certified GPS anyway.

Then of course there is the barbed hook that once its fitted, it must be used and if it fails you have only three days grace to fix it.
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Old 18th Jun 2014, 01:31
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Oh Yuk......how gross.

It appears the Spin boiler is up and running – just in time for the budget to be spent. Use it or loose it. If you can stomach it, here the latest offering from - Robert Virtue - of the ABC.

Remember the old game of Simon says – well, here's what Peter says. Aw, stone the bloody crows – fetch the bucket.

Impending rule changes for pilots has prompted the nation's aviation authority to go on an education tour through the NSW central west.

Flying seems to be one of those things that you either love or hate.

For the haters, you're likely to be riddled with stress about soaring up into the clouds, and probably won't enter into a career as a pilot.

For the lovers, there's something almost-therapeutic about the rattle and rumble of a plane tracking along a runway and the lurch as you lift-off the ground.

Some love it so much they enter into a career in aviation, perhaps as a steward, or even a pilot.

The NSW central west is littered with small airports and aerodromes that are used to varying degrees- from commercial carriers offering flights to the city, to farmers soaring over their paddocks.

"Pilots in the central west have got pretty good flying conditions. Particularly at the smaller aerodromes, they've got plenty of room to do their flying," says spokesman for the Civil Aviation Safety Authority (CASA), Peter Gibson.

"They've always got questions about procedures; how to follow the rules successfully; how to get the best training and keep up to date."

A suite of new rules for pilots is coming into force in September, focussing on licensing.
CASA is holding training workshops in Parkes and Cowra this week for pilots looking to get up to scratch with the rules.

"It's a good time to sit down with local pilots and talk to them about what the rule changes might mean for their flying, and importantly, answer their questions and get any feedback," says Peter.

"It's important all current pilots in regional areas understand these changes."

Over recent months, a light plane crashed at Narrabri; while a pilot was killed when his ultra-light aircraft crashed near Ivanhoe in May.

"We're always looking at the aviation safety system and aviation safety trends, and looking for ways to make improvements," says Peter.

"One of the ways you can make improvements is to bring in new safety rules; [and] we'll certainly be doing things to improve safety, but it's an ongoing process.

"Peter says flying into regional airports and aerodromes can be particularly dangerous for pilots.

"There aren't air traffic control towers at all the regional aerodromes, so pilots have got to manage that themselves.

"They've got to talk to other aircraft and be very aware of when scheduled airline services are coming in, and work with them to make sure there are no conflicts."

CASA offers a range of other training modules for local pilots to complete to improve their knowledge.

"We've got a number of online tools where pilots can go in, do exercises, and get information that will help improve the safety of their flying," says Peter.

"That's a great thing to be doing all the time, so that you're continuously updating and improving your safety knowledge."

For more details on the workshops being held in Parkes and Cowra, visit the CASA website.
6 Peter says – is this Muppet paid by the word, where in all the hells is his self respect. (your pick of Muppet). Urrghh - retch.
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Old 18th Jun 2014, 04:14
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Peter says:
"Pilots in the central west have got pretty good flying conditions. Particularly at the smaller aerodromes, they've got plenty of room to do their flying," says spokesman for the Civil Aviation Safety Authority (CASA), Peter Gibson.
Really? Well there you go! Must be true if 'Peter says'! 004 says 'Peter is a '
Lucky pilots in the central west. Don't think the pilots in Brisbane South feel the same way about approaching Archerfield.

Did somebody say Muppets? This one is close to Peter in likeness:
https://m.youtube.com/watch?v=ck4ND9W6tkU
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Old 18th Jun 2014, 06:21
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re P Gobsome...

A reverse quote for the Spin Doctor...
..."some people hate aviation so much the make a career out of telling lies and bull****ting about it.'

PG is so full of it, he should turn himself into the nearest sewerage farm for treatment.

and we pay for these people..!!??

Aah do love Peters Puerile Postulations. Bucket please.!
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Old 18th Jun 2014, 06:38
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Wonder what peter's second name is???

Maybe Simon????

and the bit here aroa:

"We're always looking at the aviation safety system and aviation safety trends, and looking for ways to make improvements," says Peter.

"One of the ways you can make improvements is to bring in new safety rules; [and] we'll certainly be doing things to improve safety, but it's an ongoing process.


I guess HMHB, that means if we don't get you with the current rules, we will make them harder again, then "we gotcha"

Remember "Pete", rules do not equal safety.

Last edited by Up-into-the-air; 18th Jun 2014 at 06:43. Reason: More info
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Old 18th Jun 2014, 08:15
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Jeez Sarksi,
can you hold off the colour coded posts, freaking me out!!
Read down then suddenly Oh ****e..."I'M GOING BLIND....BLIND I TELL YOU"
Missus says "what's wrong sweetheart??"....."That paragraph it's RED, for god sakes..and that's BLUE...I'll never fly again!!"


"For goodness sake get a grip they are RED and BLUE!!"...Oh really?? PHEW!! my whole life passed before my eye's there for a second.
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Old 18th Jun 2014, 08:46
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The NSW central west is littered with small airports....
littered? littered!!!!

you arrogant fckuwit gibson.
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Old 19th Jun 2014, 02:37
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Submissions to the WLR.

Well, I'm done – read the lot; even a couple of the 'confidential' ones (Cheers P7, wish you'd publish the first part). The things that stand out, to me at least are (a) the diverse paths the submitters took to arrive at the same conclusion; and. (b) how the different disciplines all arrived at pretty much the same 'bottom line'.

The legal fraternity, naturally enough, approached from where the holes in the legal cheese were, how the flaws in the regulations and how CASA chose to act within that frame work created their 'issues'. The engineers, same but from an engineering perspective; operations same; medical same; pilots same; insurers same. It's interesting to see the various 'start points', follow it through the 'logic' part and arrive at the tailor made conclusions and proposed 'solutions'. There was some very fine work done at a very credible level; hate to have to pick a winner.

But the inescapable conclusion, when you chart it out is: Legal – stuffed: Engineering – stuffed: Insurance – stuffed: Operations – stuffed: Flight training – stuffed: Medical – stuffed. Gliding – almost stuffed: Fun flying – bloody near stuffed. etc. etc

In every discipline, across the board, experts in 'their' fields through diverse paths, all arrived at the same conclusion; there is not one area where things are good, not even the bloody administrative hum-drum of issuing licences (bring in the RTA). There is a need for immediate, sweeping reform, now. It's a complete buggers muddle, and CASA in denial are 'business as usual. How fast can we get these reforms in?, better add the Senators suggestions as well, for good measure.

Toot toot...

Last edited by Kharon; 19th Jun 2014 at 02:51.
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