Truss: Aviation Safety Regulation Review
Alliance - Get on with it
From AA today...
: Alliance backs ASRR recommendations
MTF...
: Alliance backs ASRR recommendations
Alliance Aviation Services managing director Scott McMillan has called on the government to get on with acting on the 37 recommendations of the recently published review into Australia’s aviation sector.
McMillan told shareholders at Alliance’s annual general meeting the Aviation Safety Regulation Review (ASRR) had identified a wide range of recommendations that would benefit the industry.
“We look forward to the Commonwealth government implementing the wide range of recommendations from the recently published Aviation Safety Regulation Review,” McMillan said in prepared remarks on Tuesday.
“These much needed changes will go a long way towards reducing the unnecessary regulatory burden and inefficiency that our industry had endured for many years.”
The ASRR was commissioned by the federal government and authored by former Airservices chairman David Forsyth, former Director-General of Civil Aviation at Transport Canada Don Spruston and former Head of Safety at British Airways Roger Whitefield. The report, published in June, called for substantial cultural and structural change at the Civil Aviation Safety Authority (CASA), as well as better leadership of and coordination between Australia’s aviation safety agencies.
It noted that Australia had an “excellent” airline safety record and an “advanced” aviation regulatory system.
However, there were “opportunities for the system to be improved to ensure Australia remains a leading aviation state”.
The federal government has pledged to respond to the review’s 37 recommendations before the end of 2014.
Meanwhile, Alliance chairman Steve Padgett said Alliance was the current economic environment brought with it some challenges.
“We also must accept that we are operating in a competitive environment and we need to continually meet the needs of our customers,” Padgett said.
“As a result we remain focused on the development of the new revenue resources for Alliance and looking for opportunities to diversify the business and sources of revenue.”
McMillan told shareholders at Alliance’s annual general meeting the Aviation Safety Regulation Review (ASRR) had identified a wide range of recommendations that would benefit the industry.
“We look forward to the Commonwealth government implementing the wide range of recommendations from the recently published Aviation Safety Regulation Review,” McMillan said in prepared remarks on Tuesday.
“These much needed changes will go a long way towards reducing the unnecessary regulatory burden and inefficiency that our industry had endured for many years.”
The ASRR was commissioned by the federal government and authored by former Airservices chairman David Forsyth, former Director-General of Civil Aviation at Transport Canada Don Spruston and former Head of Safety at British Airways Roger Whitefield. The report, published in June, called for substantial cultural and structural change at the Civil Aviation Safety Authority (CASA), as well as better leadership of and coordination between Australia’s aviation safety agencies.
It noted that Australia had an “excellent” airline safety record and an “advanced” aviation regulatory system.
However, there were “opportunities for the system to be improved to ensure Australia remains a leading aviation state”.
The federal government has pledged to respond to the review’s 37 recommendations before the end of 2014.
Meanwhile, Alliance chairman Steve Padgett said Alliance was the current economic environment brought with it some challenges.
“We also must accept that we are operating in a competitive environment and we need to continually meet the needs of our customers,” Padgett said.
“As a result we remain focused on the development of the new revenue resources for Alliance and looking for opportunities to diversify the business and sources of revenue.”
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Oh yes, good ol Scotty Mac. He never did think to highly of fort fumble, and to be honest he probably had good reason. I do recall one particular CASA inspector who was ex Alliance who would at any opportunity make his former employer go through living hell over any and all small and insignificant issues. He was more vengeful than Osama bin laden in New York City!!!
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Soteria,
More vengeful than Osama Bin Laden in New York is a terrible thing to say! To equate the actions of a minor public servant to the actions of a purely evil man with no regard for human life is sickening.
Your comment is offensive! Especially to those who have lost loved ones to terrorism!
More vengeful than Osama Bin Laden in New York is a terrible thing to say! To equate the actions of a minor public servant to the actions of a purely evil man with no regard for human life is sickening.
Your comment is offensive! Especially to those who have lost loved ones to terrorism!
More vengeful than Osama Bin Laden in New York is a terrible thing to say! To equate the actions of a minor public servant to the actions of a purely evil man with no regard for human life is sickening.
Your comment is offensive! Especially to those who have lost loved ones to terrorism!
Your comment is offensive! Especially to those who have lost loved ones to terrorism!
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Cartel
DB,
Get over yourself and grab a Kleenex. Wipe your eyes. Those comments of Soteria were merely an analogy. When you consider the cartel and protection regime, largely sponsored by MrDak for CASA & the ATSB, I agree with the frustrations of other IOSS members. Why don't you focus your efforts on the real issue at hand, the cartel?
Get over yourself and grab a Kleenex. Wipe your eyes. Those comments of Soteria were merely an analogy. When you consider the cartel and protection regime, largely sponsored by MrDak for CASA & the ATSB, I agree with the frustrations of other IOSS members. Why don't you focus your efforts on the real issue at hand, the cartel?
Last edited by Jinglie; 15th Oct 2014 at 12:53.
AF sub - “not acceptable under any circumstances’’ except do nothing.
Kudos to SC from the Oz for following up on last week's article - Ex-CASA chief blasts Angel Flight curbs - with this...Angel Flight rails at ‘discrimination’...
It would appear that MT has combined forces with another former heavyweight to help author the 80 odd page AF submission addressing the FF DP1317OS...:
Mr Raby don't you know by now that FF are simply not interested in empirical evidence that proves a safety issue is really a non-issue...
Oh well hopefully FF will soon make the DP submissions publicly available, it could make for some fascinating reading...
RAAA convention wrap & other related matters:
In Dougy's insight this week he gives a summary of the RAAA convention..: Editor's Insights 16 October 2014
The bit that amused me was the part on Tezza's speech, which apparently went down like a fart in an elevator with the delegates..
:
While on the new DAS position SC in another article - New CASA chief on final approach - apparently has the goss that the former FAA heavyweight has suddenly got cold feet & pulled the pin..
:
Which is certainly strange because rumour was, that even after reading the ASRR report (& possibly pprune) etc..etc., that this gentleman was very much relishing the opportunity to clean out the FF trough & dismantle the iron ring; I think there is a little more to this sudden withdrawal by said preferred candidate...
Moving on...SC also gives Paul Tyrell from the RAAA the opportunity to provide a bit of a wrap on the convention last week..:
Hmm.. IMO this statement by PT on why Part 61 continues to cause angst...
“not because it’s a bad regulation but because it was rushed and the education program hasn’t been well managed’’
...is nothing more than a load of bollocks..
Perhaps PT should get out more, stop listening to the crat-spin and have a chat to some of the other TAAAF members, especially Aerialag Phil who has been quite vocal in regards to the Part 61 monster - Pilot licensing rules put aviation sector in a tailspin...
“I think the industry will give you a pretty firm view that this is just so overcomplicated for the task it does that we’ve actually gone backwards,’’ he said.
“I’d challenge anyone to get their head around the 800 pages of regulations and clearly enunciate how all of those rules work together.’’
Phil (or SC) could probably put PT in touch with this bloke for a real at the coalface perspective on Part 61:
Maybe PT was misquoted or he had a few too many Chardy's but either way IMO that statement does not enhance the credibility of the RAAA...
MTF...
It would appear that MT has combined forces with another former heavyweight to help author the 80 odd page AF submission addressing the FF DP1317OS...
:
ANGEL Flight has urged the Civil Aviation Safety Authority to abandon its “proposed regulatory discrimination’’ in a lengthy submission that warns any move to make the charity organisation a regulator or part of a regulated authority would be unworkable.
The organisation, which has the backing of senior aviation figures such as former CASA boss Mick Toller and former Virgin Blue chief pilot John Raby, lodged an 80-page document that urges CASA to review its own licensing and maintenance regime if it believes it is inadequate.
The submission is in response to a CASA discussion paper into safety standards for voluntary community service flights such as those operated by Angel Flight carrying disadvantaged regional patients and their families to medical centres.
CASA stirred up a hornet’s nest in regional Australia by expressing a preference for an option that would see an organisation formed to assess and authorise pilots, require proficiency checks and assessments and approve aircraft types. It argues it could monitor safety standards under the system without imposing undue regulatory burdens such as an air operator’s certificate.
It has since emphasised that it may not proceed with any changes that would affect Angel Flight but made no apologies for canvassing safety issues.
Angel Flight’s submission rejected all options as “not acceptable under any circumstances’’, except the one to do nothing.
It noted that there have been no safety issues identified by CASA in 84,500 flights {Hmm..flight hours maybe Steve??} flown by volunteer pilots in the 16,900 flights Angel Flight has facilitated since its inception. It said the organisation “could not and would not” become a regulatory authority or part of one.
“Angel Flight has approximately 6000 volunteer drivers and pilots,’’ it said. “To become either a regulator or a regulated aviation body would be unworkable due to the expense, skills and training required to regulate, administer, or comply, as an aviation organisation, with an independent aviation regulator, particularly in circumstances where the pilot volunteers have a broad spectrum of licences, skills, endorsements, ratings, and where the different aircraft types would number hundreds.
“Moreover, where pilots and their aircraft are dispersed across the entire nation, often in remote locations, the training and checking regimes would be a financial and practical impossibility: that is the job of the government regulator, the Civil Aviation Safety Authority — not a registered charity.’’ The submission said the charity’s mercy missions were private flights operating under rules set by CASA.
If CASA was satisfied with its current standards, there was no need to create a special category dedicated to the type of people flown or the purpose of the flight.
“Angel flights are not ambulance flights,’’ it said. “They are not commercial flights. They are not airline transport or RPT flights. They are private flights conducted under the rules relating to such flights as set by CASA. Provided pilots comply with these rules, there is no need for intervention. If pilots fail to comply with relevant rules, then they are subject to the administrative, regulatory and/or criminal sanctions that apply to them as individuals.’’
In his submission to CASA, Mr Raby accused the authority of a flawed approach that drew “sweeping conclusions” from an analysis of the one fatal accident Angel Flight had suffered in some 17,000 flights.
Mr Raby disputed that community service organisations were insufficiently regulated and said issues raised by CASA as germane to community service flights were relevant to all flying operations.
“There is simply no credible measure presented which indicates targeted activity presents a safety risk above and beyond that inherent in all general aviation activity,’’ he said.
The organisation, which has the backing of senior aviation figures such as former CASA boss Mick Toller and former Virgin Blue chief pilot John Raby, lodged an 80-page document that urges CASA to review its own licensing and maintenance regime if it believes it is inadequate.
The submission is in response to a CASA discussion paper into safety standards for voluntary community service flights such as those operated by Angel Flight carrying disadvantaged regional patients and their families to medical centres.
CASA stirred up a hornet’s nest in regional Australia by expressing a preference for an option that would see an organisation formed to assess and authorise pilots, require proficiency checks and assessments and approve aircraft types. It argues it could monitor safety standards under the system without imposing undue regulatory burdens such as an air operator’s certificate.
It has since emphasised that it may not proceed with any changes that would affect Angel Flight but made no apologies for canvassing safety issues.
Angel Flight’s submission rejected all options as “not acceptable under any circumstances’’, except the one to do nothing.
It noted that there have been no safety issues identified by CASA in 84,500 flights {Hmm..flight hours maybe Steve??} flown by volunteer pilots in the 16,900 flights Angel Flight has facilitated since its inception. It said the organisation “could not and would not” become a regulatory authority or part of one.
“Angel Flight has approximately 6000 volunteer drivers and pilots,’’ it said. “To become either a regulator or a regulated aviation body would be unworkable due to the expense, skills and training required to regulate, administer, or comply, as an aviation organisation, with an independent aviation regulator, particularly in circumstances where the pilot volunteers have a broad spectrum of licences, skills, endorsements, ratings, and where the different aircraft types would number hundreds.
“Moreover, where pilots and their aircraft are dispersed across the entire nation, often in remote locations, the training and checking regimes would be a financial and practical impossibility: that is the job of the government regulator, the Civil Aviation Safety Authority — not a registered charity.’’ The submission said the charity’s mercy missions were private flights operating under rules set by CASA.
If CASA was satisfied with its current standards, there was no need to create a special category dedicated to the type of people flown or the purpose of the flight.
“Angel flights are not ambulance flights,’’ it said. “They are not commercial flights. They are not airline transport or RPT flights. They are private flights conducted under the rules relating to such flights as set by CASA. Provided pilots comply with these rules, there is no need for intervention. If pilots fail to comply with relevant rules, then they are subject to the administrative, regulatory and/or criminal sanctions that apply to them as individuals.’’
In his submission to CASA, Mr Raby accused the authority of a flawed approach that drew “sweeping conclusions” from an analysis of the one fatal accident Angel Flight had suffered in some 17,000 flights.
Mr Raby disputed that community service organisations were insufficiently regulated and said issues raised by CASA as germane to community service flights were relevant to all flying operations.
“There is simply no credible measure presented which indicates targeted activity presents a safety risk above and beyond that inherent in all general aviation activity,’’ he said.
Oh well hopefully FF will soon make the DP submissions publicly available, it could make for some fascinating reading...
RAAA convention wrap & other related matters:
In Dougy's insight this week he gives a summary of the RAAA convention..
: Editor's Insights 16 October 2014 The bit that amused me was the part on Tezza's speech, which apparently went down like a fart in an elevator with the delegates..
:
Acting DAS Terry Farquharson delivered a sober defence of the Regulator which didn’t go down so well with industry delegates. I was surprised that Terry would front the RAAA given that he’s just keeping the seat warm until the new DAS is named (any day now). So I guess it was a courageous appearance, even if a bit out of tune with the mood of the audience.
:
A NEW head of the Civil Aviation Safety Authority is expected to be announced in the next two weeks, government sources have confirmed.
The announcement comes after the appointment was apparently delayed by a false start in which a US candidate favoured for the job is understood to have withdrawn his application.
It is believed the new candidate is local and the appointment is due to go before Cabinet towards the end of the month.
The announcement comes after the appointment was apparently delayed by a false start in which a US candidate favoured for the job is understood to have withdrawn his application.
It is believed the new candidate is local and the appointment is due to go before Cabinet towards the end of the month.
Moving on...SC also gives Paul Tyrell from the RAAA the opportunity to provide a bit of a wrap on the convention last week..
:
The appointment and the safety review response were hot topics at last week’s annual convention of the Regional Aviation Association of Australia.
Association chief executive Paul Tyrrell welcomed the news that an appointment of a new CASA director of aviation safety was imminent, and said the appointment of industry veteran Jeff Boyd to the CASA board was also a tick for the government.
“The rest of the board hasn’t been appointed and that’s something we really need,” Mr Tyrrell said.
“The government’s response to the ASRR is also eagerly awaited.’’
Mr Tyrell also called on Mr Truss to follow through on the “long-awaited’’ ministerial advisory council that was part of the coalition’s aviation election platform. He said his association’s conference also heard that the Part 61 pilot licensing rules were continuing to cause angst “not because it’s a bad regulation but because it was rushed and the education program hasn’t been well managed’’.
However, the interaction with CASA on changes to parts 135 and 121 appeared to be much better.
On the safety review, Mr Tyrrell said the industry had responded months ago with almost as many submissions as had been lodged initially. “So there’s a huge amount of data and feedback they’ve got,’’ he said.
“They know exactly what the industry thinks, so we’re hoping the government’s working very hard on the response.’’
More generally, Mr Tyrrell said a theme of the convention had been to avoid talking down the industry. “We have a lot of international visitors and they commented that it always appears a struggle in the Australian aviation industry and they don’t get that in other parts of the world,’’ he said. “So we’ve got to be careful we don’t get too enmeshed in the problems and fail to look to the future.’’
He said this meant encouraging young people into the industry and looking beyond Australia’s shores to see where the local industry could engage and add value with what was essentially an international industry.
“We’re trying not be too gloomy,’’ he said.
“It’s more that it’s sort of a limbo period at the moment.’’
Association chief executive Paul Tyrrell welcomed the news that an appointment of a new CASA director of aviation safety was imminent, and said the appointment of industry veteran Jeff Boyd to the CASA board was also a tick for the government.
“The rest of the board hasn’t been appointed and that’s something we really need,” Mr Tyrrell said.
“The government’s response to the ASRR is also eagerly awaited.’’
Mr Tyrell also called on Mr Truss to follow through on the “long-awaited’’ ministerial advisory council that was part of the coalition’s aviation election platform. He said his association’s conference also heard that the Part 61 pilot licensing rules were continuing to cause angst “not because it’s a bad regulation but because it was rushed and the education program hasn’t been well managed’’.
However, the interaction with CASA on changes to parts 135 and 121 appeared to be much better.
On the safety review, Mr Tyrrell said the industry had responded months ago with almost as many submissions as had been lodged initially. “So there’s a huge amount of data and feedback they’ve got,’’ he said.
“They know exactly what the industry thinks, so we’re hoping the government’s working very hard on the response.’’
More generally, Mr Tyrrell said a theme of the convention had been to avoid talking down the industry. “We have a lot of international visitors and they commented that it always appears a struggle in the Australian aviation industry and they don’t get that in other parts of the world,’’ he said. “So we’ve got to be careful we don’t get too enmeshed in the problems and fail to look to the future.’’
He said this meant encouraging young people into the industry and looking beyond Australia’s shores to see where the local industry could engage and add value with what was essentially an international industry.
“We’re trying not be too gloomy,’’ he said.
“It’s more that it’s sort of a limbo period at the moment.’’
“not because it’s a bad regulation but because it was rushed and the education program hasn’t been well managed’’
...is nothing more than a load of bollocks..
Perhaps PT should get out more, stop listening to the crat-spin and have a chat to some of the other TAAAF members, especially Aerialag Phil who has been quite vocal in regards to the Part 61 monster - Pilot licensing rules put aviation sector in a tailspin...“I think the industry will give you a pretty firm view that this is just so overcomplicated for the task it does that we’ve actually gone backwards,’’ he said.
“I’d challenge anyone to get their head around the 800 pages of regulations and clearly enunciate how all of those rules work together.’’
Phil (or SC) could probably put PT in touch with this bloke for a real at the coalface perspective on Part 61:
A veteran flying training operator with almost four decades in the industry said there was a lack of background, forms that didn’t yet exist and information that was still in draft form.
“The industry is crying,’’ the operator said.
He said the industry had been promised there would be no additional cost but there were “horrific costs involved’’.
“There are government guidelines saying there should be the removal of red tape, that there should be stuff done in simple language,’’ he said.
“Everything’s been done in legal speak again that we can’t understand.
There are actually things in different parts of the regs that contravene each other.’’
“The industry is crying,’’ the operator said.
He said the industry had been promised there would be no additional cost but there were “horrific costs involved’’.
“There are government guidelines saying there should be the removal of red tape, that there should be stuff done in simple language,’’ he said.
“Everything’s been done in legal speak again that we can’t understand.
There are actually things in different parts of the regs that contravene each other.’’
MTF...
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"Amen"-Delayed due technical difficulties..
Nice to see the Rev. on song and leading the faithful toward salvation, but as usual the forces of evil won't go away, because one good man says they must, will they now children??. Bit like children's belief in the Bogey Man; it's all well and good for Mummy to tell the kids not to worry, no such thing: but when things go bump in the night and the murky Machiavellian crew are out to hunt and haunt – Mum's glib remarks seem somehow – inadequate.
Oh; Just a bit of it – and the 'powers that be' – are not helping to regain the trust which is an absolute given in ant decent relationship. The persistent rumour that Farq-u-hardson is tu tu be DAS is just a starter; seems the FAA high roller has pulled the pin, if the reports, quotes and rumours floating about the place are true. Whether these are just a 'sampler' to see what the general reaction is; or, that the FAA are coming – mob handed and there is a conflict of interest; or, as Sarcs mentioned, the mutt has read Pprune and decided the game is not worth the candle, are just some of the speculations in the wind today. Lets make it clear – the boss of the Golden West Mafia (GWM) his cronies, catamites and sycophants are unacceptable; at any level. They are perceived as being the radical cause of most of the surface level 'trust' issues which have, through the McComic Regime brought the administration and management of Australian aviation to this sorry impasse.
To add fuel to the flames, the idiots who 'developed' Part 61 are begging industry assistance to sort out the unbelievable mess. If this industry wants to survive it must tell the CASA to take 61 away, do the homework and impact statements we paid them to do, re-write the regulation, seek industry consultation and then, suggest a proper period of adjustment, education and assistance to bed the revised law down. As it stands Part 61 is open slather on operators, exemptions, instruments , 'accommodations'; all 'at discretion'. It's bollocks and they have the hide to expect industry to fish their chestnuts out of the flames – after having paid the fools to write it. Your response to the pitiful CASA cries for assistance should be a simple one: - "We paid for it, you stuffed it, now, stick it where the sun don't shine; bring it back fixed; or, pay us for the time we must spend sorting out your amateurish, second rate work". Fools, shiftless, lazy, incompetent, purblind bloody fools and sneaky with it.
Trust the current outfit ? fix up 61 for them?? – what strange, whimsical notions.
Sarcs # 1412 - Rev Forsyth – "However, trust between Australia’s aviation players and the Civil Aviation Safety Authority (CASA) would take longer, Forsyth says."
To add fuel to the flames, the idiots who 'developed' Part 61 are begging industry assistance to sort out the unbelievable mess. If this industry wants to survive it must tell the CASA to take 61 away, do the homework and impact statements we paid them to do, re-write the regulation, seek industry consultation and then, suggest a proper period of adjustment, education and assistance to bed the revised law down. As it stands Part 61 is open slather on operators, exemptions, instruments , 'accommodations'; all 'at discretion'. It's bollocks and they have the hide to expect industry to fish their chestnuts out of the flames – after having paid the fools to write it. Your response to the pitiful CASA cries for assistance should be a simple one: - "We paid for it, you stuffed it, now, stick it where the sun don't shine; bring it back fixed; or, pay us for the time we must spend sorting out your amateurish, second rate work". Fools, shiftless, lazy, incompetent, purblind bloody fools and sneaky with it.
Trust the current outfit ? fix up 61 for them?? – what strange, whimsical notions.
Last edited by Kharon; 17th Oct 2014 at 06:21. Reason: Slowly catching up – MTF..
Last minute Hitch on RTR FF rankings & that caravan.
Good to see you back Mr Ferryman....it was a bit quiet around here without you...
This week in the last minute Hitch...:
Hmm...no comment..
MTF...
psss if you want to know more about FF's dodgy regulatory burden rankings go here and please think about calling bollocks by making a response as I suggested...
"...Perhaps those IOS members contemplating responding to the FF bollocks - FF self-assessed RTR audit results - should cc to the OBPR, PC, PMC, TA & his Parliamentary Secretary Josh Frydenberg..."
..it was a bit quiet around here without you...This week in the last minute Hitch...
:
One thing CASA doesn't lack is the courage to pick up a stick and ram it hard into the side of a large bear. They've done it again with their rankings of regulatory burden. CASR Parts 66 and 147 have been ranked low burden, whilst CASR Part 145 has been ranked as medium burden. The maintenance, repair and overhaul (MRO) industry may consider all of this as high burden in their review, if their past stance on these suites is any indicator. On the upside, CASA has ranked Part 67 on medicals as high burden. Those with long memories, however, will recall the Byron days when the burden was officially recognised, resulting in nothing happening at all. Same under McCormick, so we have to question if this high ranking for Part 67 means anything of substance. We have the opportunity to send CASA our own rankings, but we need to be honest and resist the temptation to rank everything as high burden; that would give CASA an excuse to ignore our input.
Richard Rudd and Rob Cumming's Caravan to Canberra expedition highlights where the general aviation industry is at with the regulator: they've had enough. Richard and Rob will arrive in the capital this weekend bringing exactly that message on a mobile billboard. It's true that there is not a lot they can tell politicians that the politicians haven't been told before, and although they will get a sympathetic ear from supporters, they'll still get a deaf ear from CASA. However, Richard and Rob are doing something rather than just sitting and complaining, and you've got to applaud that.
Qantas Founders Museum has added a Super Connie to their museum in Longreach, The aircraft has been derelict in The Philippines for years, so it will need a good clean-up and restoration before taking up its spot beside the B707 and B747 already there. The Connie is a significant aircraft for Qantas and a vital addition to their collection. What might have been nice is if the announcement had been about flying a B767 up there instead of consigning them all to the graveyards in the USA. There might still be time for them to consider this, although Qantas might not feel the 76 deserves a place in their history, despite being their first Extended Twin Engine Operations (ETOPS) aircraft and having the first glass cockpits in the Qantas fleet. There's also the matter of money; they might still be able to sell some of them given the economy they still represent.
May your gauges always be in the green,
Hitch
Richard Rudd and Rob Cumming's Caravan to Canberra expedition highlights where the general aviation industry is at with the regulator: they've had enough. Richard and Rob will arrive in the capital this weekend bringing exactly that message on a mobile billboard. It's true that there is not a lot they can tell politicians that the politicians haven't been told before, and although they will get a sympathetic ear from supporters, they'll still get a deaf ear from CASA. However, Richard and Rob are doing something rather than just sitting and complaining, and you've got to applaud that.
Qantas Founders Museum has added a Super Connie to their museum in Longreach, The aircraft has been derelict in The Philippines for years, so it will need a good clean-up and restoration before taking up its spot beside the B707 and B747 already there. The Connie is a significant aircraft for Qantas and a vital addition to their collection. What might have been nice is if the announcement had been about flying a B767 up there instead of consigning them all to the graveyards in the USA. There might still be time for them to consider this, although Qantas might not feel the 76 deserves a place in their history, despite being their first Extended Twin Engine Operations (ETOPS) aircraft and having the first glass cockpits in the Qantas fleet. There's also the matter of money; they might still be able to sell some of them given the economy they still represent.
May your gauges always be in the green,
Hitch
MTF...
psss if you want to know more about FF's dodgy regulatory burden rankings go here and please think about calling bollocks by making a response as I suggested...
"...Perhaps those IOS members contemplating responding to the FF bollocks - FF self-assessed RTR audit results - should cc to the OBPR, PC, PMC, TA & his Parliamentary Secretary Josh Frydenberg..."
Last edited by Sarcs; 17th Oct 2014 at 09:59.
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Disinformation minefield. A good read.
Soteria - "It's time for you to go bye byes, please. And one other thing - take Boyd, Campbell, Ferrit-a-day, Gibson and Wodger with you and please don't bang the door on the way out, ok?
Jinglie "[And} an interesting anecdote, was Sleepy actually interviewed for his Deputy job or just appointed by his mate Herr Screamer??
Sunny – "By my way of thinking, it is not a good idea for CASA management to assume that the Government will continue to put up with their antics."
Sarcs – "Or you could refer to the following leaked response to the DP from the former CAsA boss Mick Toller."
Sarcs – "Some may say this is typical of government (past & present) obvious dis-interest in all things aviation but on a quick perusal of Bob Baldwin's CV it is quite obvious this man is not a light weight in political circles, the man is a doer rather". etc.
Sarcs – thanks for the Hitch link – interesting. Why I am not surprised at the CASA signed confession, that a CP is only valued at AUD $35 ph, or that they have no clue about the impact their Frankenstein has on the cost of doing business with CASA. I believe part of their remit is to do a cost/benefit analysis (impact) of new regulation. The Muppets supporting Part 61 certainly did no such thing, and now they want 'us' to analyse the ducking thing and report back. How flaming condescending, arrogant, ignorant of them and how very obliging of us to once again, unquestioningly, to do their bidding (and work) at our expense.
I will only join the Creampuff Laborial Aviation Party (CLAP) if pink bunny suits are made mandatory (strict liability – no option); what a hoot – bet they never saw a sight like that – in daylight at least - coming up the drive to parliament house..Led by the R&R ute, with the hand painted signs and VH- F#c^D flying overhead. ...
Toot toot.
Last edited by Kharon; 17th Oct 2014 at 21:01. Reason: And sometimes - I just sits.
Which is certainly strange because rumour was, that even after reading the ASRR report (& possibly PPRuNe) etc..etc., that this gentleman was very much relishing the opportunity to clean out the FF trough & dismantle the iron ring; I think there is a little more to this sudden withdrawal by said preferred candidate...
(a) You are not being appointed to "reform" CASA, you are being appointed to appear to reform CASA in order to silence CASAs critics.
(b) You do not have authority from me to reform anything. You must not make waves or cause the Government or me and my department any trouble at all.
This is the trouble with Americans in management....they actually want to DO SOMETHING..... and we can't have that, can we?
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Sunny,
I think you perhaps have hit the old nail squarely on the head.
Mrdak is an absolute piece of work. His Machiavellian fingers have fiddled in many pies from engineering the sell off of GA airports, to pink bats.
He tried to influence the DAS selection at the start but was thwarted when people started asking questions about transparency. People like him do not give up easily, I would not be surprised at all if the fiddle went in.
The man has no soul, illustrated, I'm told when confronted by the flight nurse from the Pelair debacle seeking assistance from someone, anyone, to obtain some reasonable support for her ongoing medical issues, he brushed her off like she was a piece of cow sh..t stuck to his trousers, not even a kind word of sympathy.
I think you perhaps have hit the old nail squarely on the head.
Mrdak is an absolute piece of work. His Machiavellian fingers have fiddled in many pies from engineering the sell off of GA airports, to pink bats.
He tried to influence the DAS selection at the start but was thwarted when people started asking questions about transparency. People like him do not give up easily, I would not be surprised at all if the fiddle went in.
The man has no soul, illustrated, I'm told when confronted by the flight nurse from the Pelair debacle seeking assistance from someone, anyone, to obtain some reasonable support for her ongoing medical issues, he brushed her off like she was a piece of cow sh..t stuck to his trousers, not even a kind word of sympathy.
The 3Ms (i.e.Murky Machiavellian Manipulation)
TB - I think you perhaps have hit the old nail squarely on the head.
Mrdak is an absolute piece of work. His Machiavellian fingers have fiddled in many pies from engineering the sell off of GA airports, to pink bats.
Mrdak is an absolute piece of work. His Machiavellian fingers have fiddled in many pies from engineering the sell off of GA airports, to pink bats.
The most worrying thing is that this bloke has a key to the PM&C vault and has probably already corrupted many of the seriously smart individuals from that office...
The other problem is that although (in the case of the DAS selection) M&M is waiting the outcome of plan B; if that doesn't work he probably has back up plans all the way out to Z...
Kharon - I believe part of their remit is to do a cost/benefit analysis (impact) of new regulation.
The Australian Government’s handbook on Best Practice Regulation states that
stimulating productivity remains at the forefront of government policy. It also states
that the centrepiece of the Government’s best practice legislation is a Regulation
Impact Statement (RIS) that is mandatory for all decisions made by the Australian
Government and its agencies that are likely to have a regulatory impact on business.
Given CASA’s blatant disregard for its regulatory impact on productivity and the
inadequate or non existent RIS that accompanies each regulatory proposal, CASA is
clearly not following this process but is seemingly a law unto itself.
The resulting increased cost to industry without any demonstrated safety benefit is
felt to be a significant factor in the declining regional aviation sector. The regulatory
barriers for entry into this part of the aviation industry are now almost
insurmountable.
stimulating productivity remains at the forefront of government policy. It also states
that the centrepiece of the Government’s best practice legislation is a Regulation
Impact Statement (RIS) that is mandatory for all decisions made by the Australian
Government and its agencies that are likely to have a regulatory impact on business.
Given CASA’s blatant disregard for its regulatory impact on productivity and the
inadequate or non existent RIS that accompanies each regulatory proposal, CASA is
clearly not following this process but is seemingly a law unto itself.
The resulting increased cost to industry without any demonstrated safety benefit is
felt to be a significant factor in the declining regional aviation sector. The regulatory
barriers for entry into this part of the aviation industry are now almost
The Office of Best Practice Regulation (OBPR), in the Department of Prime Minister
and Cabinet, has published a handbook of guidelines [Dept of Finance and
Deregulation, July 2013] for Australian Government agencies involved in regulatory
reform. Any agency that introduces new rules that may have a regulatory impact on
business must first produce a RIS as part of the regulatory process. The OBPR must
be notified and the agency is required to publish an Annual Regulatory Plan. It
appears that CASA does not comply with any of these OBPR mandatory guidelines.and Cabinet, has published a handbook of guidelines [Dept of Finance and
Deregulation, July 2013] for Australian Government agencies involved in regulatory
reform. Any agency that introduces new rules that may have a regulatory impact on
business must first produce a RIS as part of the regulatory process. The OBPR must
be notified and the agency is required to publish an Annual Regulatory Plan. It
So our only point of reference is the 2012 RIS that now has outdated figures..
Example SMS set up/ongoing costs for Flying Schools:
Upfront costs
For small businesses employing six or less safety sensitive staff would require an understanding of the safety management system principles and human factor training and the development of safety dataset. CASA has developed a micro SMS tool to assist these businesses.
It is estimated that it would require 2 days for a small business manager to understand SMS principles and a further 2 days training in human factor training for all staff, and 1/2 day to setup an excel spreadsheet for the safety dataset. For small businesses, this would generate an upfront cost of $2689, based on 4.5 days of time valued at the average salary of $128 500 per year and $1600 in human factor training from an external provider for the two days of training, deriving a cost of $4289 per business. In aggregate for the 164 small businesses this would generate a total cost of $0.7m.
For small/medium training businesses employing less than 20 people, the time cost will similar to sole traders with the addition of 2.5 days in time for developing staff training material and an investigation and audit program for the organisation. For individual small organisations this will cost 7 days valued at the average salary of $128 500 per year, generating a cost of $4183 per business, plus $1600 in human factor training from an external provider. In aggregate for the 35 small/medium businesses this will cost a total of $0.2m.
For medium businesses employing up to 50 the time cost will similar to small/medium business, however, the implementation of safety management system will require 2 days in time for developing staff training material and an investigation and audit program for the organisation. For medium businesses the time is estimated at 9 days valued at $5378, plus $1600 in human factor training from an external provider. In aggregate for these 5 businesses this will cost a total of $0.034m.
Ongoing costs
For small businesses, there will be ongoing requirement to demonstrate an understanding the principles of safety management systems and human factors, at a cost of 1 day per year and 1 day to record any safety incident in the database and comply with a safety audit.
The ongoing cost for the SMS will be 2 days per year valued at a salary of $128 500 that is $1195 per small business, plus $800 per year in human factors training, resulting in a total ongoing cost of $1995. With 164 small businesses this is will generate an annual cost of $0.46m.
For small/medium organisations the ongoing costs will be more significant, there will be more safety incidents to report, which will need to be investigated, ongoing risk assessments will be required for assessment of safety risks, developing means of reducing risks and training staff in safety. It is estimated that this will be the equivalent of 20% of the full-time workload for a person nominated as a safety manager within the organisation and when valued at the salary of $128 500, this will cost small/medium businesses approximately $25 700 each year. The human factors training is estimated to cost $800 per employee and assuming 5 employees per business this will cost $4000 per year resulting in a total ongoing cost of $29 700 per business. When aggregated across the 35 small/medium businesses this will generate an ongoing cost of $1.04m.
For training businesses employing up to 50 will be required to perform the same ongoing tasks of a medium sized business, but the additional employees will generate more safety incidents and risks to be assessed and staff to be trained. It is estimated that this will require 40% of the full time workload of one person, valued at $51 400 for each business. The human factors training is estimated to cost $800 per employee and assuming 20 employees per business this will cost $16000 per year resulting in a total ongoing cost of $67 400 per business When aggregated across these 5 businesses this will generate an ongoing cost of $0.34m.
For small businesses employing six or less safety sensitive staff would require an understanding of the safety management system principles and human factor training and the development of safety dataset. CASA has developed a micro SMS tool to assist these businesses.
It is estimated that it would require 2 days for a small business manager to understand SMS principles and a further 2 days training in human factor training for all staff, and 1/2 day to setup an excel spreadsheet for the safety dataset. For small businesses, this would generate an upfront cost of $2689, based on 4.5 days of time valued at the average salary of $128 500 per year and $1600 in human factor training from an external provider for the two days of training, deriving a cost of $4289 per business. In aggregate for the 164 small businesses this would generate a total cost of $0.7m.
For small/medium training businesses employing less than 20 people, the time cost will similar to sole traders with the addition of 2.5 days in time for developing staff training material and an investigation and audit program for the organisation. For individual small organisations this will cost 7 days valued at the average salary of $128 500 per year, generating a cost of $4183 per business, plus $1600 in human factor training from an external provider. In aggregate for the 35 small/medium businesses this will cost a total of $0.2m.
For medium businesses employing up to 50 the time cost will similar to small/medium business, however, the implementation of safety management system will require 2 days in time for developing staff training material and an investigation and audit program for the organisation. For medium businesses the time is estimated at 9 days valued at $5378, plus $1600 in human factor training from an external provider. In aggregate for these 5 businesses this will cost a total of $0.034m.
Ongoing costs
For small businesses, there will be ongoing requirement to demonstrate an understanding the principles of safety management systems and human factors, at a cost of 1 day per year and 1 day to record any safety incident in the database and comply with a safety audit.
The ongoing cost for the SMS will be 2 days per year valued at a salary of $128 500 that is $1195 per small business, plus $800 per year in human factors training, resulting in a total ongoing cost of $1995. With 164 small businesses this is will generate an annual cost of $0.46m.
For small/medium organisations the ongoing costs will be more significant, there will be more safety incidents to report, which will need to be investigated, ongoing risk assessments will be required for assessment of safety risks, developing means of reducing risks and training staff in safety. It is estimated that this will be the equivalent of 20% of the full-time workload for a person nominated as a safety manager within the organisation and when valued at the salary of $128 500, this will cost small/medium businesses approximately $25 700 each year. The human factors training is estimated to cost $800 per employee and assuming 5 employees per business this will cost $4000 per year resulting in a total ongoing cost of $29 700 per business. When aggregated across the 35 small/medium businesses this will generate an ongoing cost of $1.04m.
For training businesses employing up to 50 will be required to perform the same ongoing tasks of a medium sized business, but the additional employees will generate more safety incidents and risks to be assessed and staff to be trained. It is estimated that this will require 40% of the full time workload of one person, valued at $51 400 for each business. The human factors training is estimated to cost $800 per employee and assuming 20 employees per business this will cost $16000 per year resulting in a total ongoing cost of $67 400 per business When aggregated across these 5 businesses this will generate an ongoing cost of $0.34m.
Overall Costs
In developing the proposals, CASA has been careful to offset any increased requirements with reductions in other requirements, particularly administrative requirements which have a less direct impact on safety. The total increased costs are estimated to be approximately $8m per year, or $56.3m when discounted over a 10 year period (Table 6).
In developing the proposals, CASA has been careful to offset any increased requirements with reductions in other requirements, particularly administrative requirements which have a less direct impact on safety. The total increased costs are estimated to be approximately $8m per year, or $56.3m when discounted over a 10 year period (Table 6).
:
Conclusion
In developing the proposals CASA is not introducing a new regulatory regime, but is simply refining the existing requirements. The options, while making some changes to existing requirements, do not introduce any substantial new imposts on the aviation industry and in fact, will alleviate and simplify a significant number of current requirements.
The purpose of the proposals is to provide clear and consistent regulations for licensing flight crew without significantly increasing industry costs, but they do incorporate proposals for systemic changes designed to improve aviation safety.
Whilst there is a strong case for introducing better flight crew training requirements to improve safety, CASA accepts that the cost of flight training is already high. To contain costs there needs to be a reduction in requirements not directly contributing to safety to allow for additional safety targeted measures. In addition, Australia benefits from aligning flight crew licensing requirements closely with international standards.
Wherever possible CASA has sought to reduce administrative requirements in the flight crew licensing system that do not directly contribute to safety, so that other proposals addressing safety issues do not result in a significant cost to industry. Although some sectors of industry will experience modest increases, the overall result should tend to reduce rather than increase costs.
In developing the proposals CASA is not introducing a new regulatory regime, but is simply refining the existing requirements. The options, while making some changes to existing requirements, do not introduce any substantial new imposts on the aviation industry and in fact, will alleviate and simplify a significant number of current requirements.
The purpose of the proposals is to provide clear and consistent regulations for licensing flight crew without significantly increasing industry costs, but they do incorporate proposals for systemic changes designed to improve aviation safety.
Whilst there is a strong case for introducing better flight crew training requirements to improve safety, CASA accepts that the cost of flight training is already high. To contain costs there needs to be a reduction in requirements not directly contributing to safety to allow for additional safety targeted measures. In addition, Australia benefits from aligning flight crew licensing requirements closely with international standards.
Wherever possible CASA has sought to reduce administrative requirements in the flight crew licensing system that do not directly contribute to safety, so that other proposals addressing safety issues do not result in a significant cost to industry. Although some sectors of industry will experience modest increases, the overall result should tend to reduce rather than increase costs.
MTF...
Last edited by Sarcs; 18th Oct 2014 at 01:07.
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"The purpose of the proposals is to provide clear and consistent regulations for licensing flight crew without significantly increasing industry costs, but they do incorporate proposals for systemic changes designed to improve aviation safety."
Pity they don't follow their own spin. Until they devote a little time to training their own enforcers, inconsistency will reign supreme. Ten different FOI's ten different opinions, therefore ten different operators conducting operations differently.
If CAsA cant get "Consistency" in their own interpretation and enforcement of the regulations they write, then the biggest thing they could do to assist the industry is to provide generic operations manuals, approved at the highest echelon, that FOI's cannot fiddle with.
That would go a long way to removing inconsistency, and relieve a lot of CP angst, everyone would be operating on the same page. We are all supposed to be complying with the same regulations, to the same standards.
Why should everyone have to be different?
I believe the Ag boys had great success with generic operations manuals under Byron, who would skin an FOI alive if they tried to tamper with it.
The arrival of the skull put paid to that when the rogue FOI's were let off their leads to run rampant through the industry. Might explain Air Ag's anger and frustration today?
Its always seemed to me to be completely inconsistent that many of the costly checks we are required conduct are not common across the industry. For example, a 20:11 check with one operator should be acceptable to another, same for proficiency checks.
I know of one operator who has been inflicted by their FOI with pilot induction requirements that cost upwards of 20K just to employ a pilot for a simple piston twin, and that's for a person current, qualified and experienced.
These sort of impositions and costs are simply unsustainable for the small businesses that GA operators are and do nothing to improve safety.
"Whilst there is a strong case for introducing better flight crew training requirements to improve safety, CASA accepts that the cost of flight training is already high. To contain costs there needs to be a reduction in requirements not directly contributing to safety to allow for additional safety targeted measures. In addition, Australia benefits from aligning flight crew licensing requirements closely with international standards."
I'm not at all sure that we have "Aligned" with international standards.
I have certainly never experienced anything like Part 61 and 142 anywhere else in the world.
These two parts alone positively encourage commercial operators to export their checking and training overseas.
I believe that without the government subsidy of Vets, flying schools in Australia would simply vanish.
Travel around the country airports and count the paint peeling signs for the Galaganbone Aeroclub or the Kickatinalong flying school, empty, but for the spider webs and echo's of memories past.
Contrast us with NZ. How is it they can elucidate a clear, plain language rule set for pilot standards also called part 61 in eighty odd pages,bout the same as the US.
Why does it take our regulator 800 pages of legalise plus a MOS which is supposed to explain the legalize, but in effect makes it about as clear as mud? .
NZ aviation is thriving, their safety record is "World Class" their regulations are being adopted across the region.
Australia is just an international Joke, a pimple on the ass of the aviation world.
If, as I suspect our regulator believes safety is entirely dependent on the volume of regulations, why is our safety record worse than the US? Why is our industry all but dead, when it could be contributing so much to the economy of this country?
Pity they don't follow their own spin. Until they devote a little time to training their own enforcers, inconsistency will reign supreme. Ten different FOI's ten different opinions, therefore ten different operators conducting operations differently.
If CAsA cant get "Consistency" in their own interpretation and enforcement of the regulations they write, then the biggest thing they could do to assist the industry is to provide generic operations manuals, approved at the highest echelon, that FOI's cannot fiddle with.
That would go a long way to removing inconsistency, and relieve a lot of CP angst, everyone would be operating on the same page. We are all supposed to be complying with the same regulations, to the same standards.
Why should everyone have to be different?
I believe the Ag boys had great success with generic operations manuals under Byron, who would skin an FOI alive if they tried to tamper with it.
The arrival of the skull put paid to that when the rogue FOI's were let off their leads to run rampant through the industry. Might explain Air Ag's anger and frustration today?
Its always seemed to me to be completely inconsistent that many of the costly checks we are required conduct are not common across the industry. For example, a 20:11 check with one operator should be acceptable to another, same for proficiency checks.
I know of one operator who has been inflicted by their FOI with pilot induction requirements that cost upwards of 20K just to employ a pilot for a simple piston twin, and that's for a person current, qualified and experienced.
These sort of impositions and costs are simply unsustainable for the small businesses that GA operators are and do nothing to improve safety.
"Whilst there is a strong case for introducing better flight crew training requirements to improve safety, CASA accepts that the cost of flight training is already high. To contain costs there needs to be a reduction in requirements not directly contributing to safety to allow for additional safety targeted measures. In addition, Australia benefits from aligning flight crew licensing requirements closely with international standards."
I'm not at all sure that we have "Aligned" with international standards.
I have certainly never experienced anything like Part 61 and 142 anywhere else in the world.
These two parts alone positively encourage commercial operators to export their checking and training overseas.
I believe that without the government subsidy of Vets, flying schools in Australia would simply vanish.
Travel around the country airports and count the paint peeling signs for the Galaganbone Aeroclub or the Kickatinalong flying school, empty, but for the spider webs and echo's of memories past.
Contrast us with NZ. How is it they can elucidate a clear, plain language rule set for pilot standards also called part 61 in eighty odd pages,bout the same as the US.
Why does it take our regulator 800 pages of legalise plus a MOS which is supposed to explain the legalize, but in effect makes it about as clear as mud? .
NZ aviation is thriving, their safety record is "World Class" their regulations are being adopted across the region.
Australia is just an international Joke, a pimple on the ass of the aviation world.
If, as I suspect our regulator believes safety is entirely dependent on the volume of regulations, why is our safety record worse than the US? Why is our industry all but dead, when it could be contributing so much to the economy of this country?
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Biccy,
Not to mention the Sky Sentinel debacle, all of which is Tezza's doing. He will be a rabbit in the spotlight this week. He's got Boyd backing him up. He's going to need a lot more than that wimp. The Voodoo man could be going into overdrive with more babble and spin.
Not to mention the Sky Sentinel debacle, all of which is Tezza's doing. He will be a rabbit in the spotlight this week. He's got Boyd backing him up. He's going to need a lot more than that wimp. The Voodoo man could be going into overdrive with more babble and spin.
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Through the looking glass.
Jinglie –"The Voodoo man could be going into overdrive with more babble and spin."
Senator – "Well, you must have been aware of the travesty inflicted on this chopper pilot; you provided the paper work for the case, supplied the legal team for the AAT, interviewed the star witness in prison; supplied the police escorts and examined all the evidence; then, despite CDPP advice, ran the case in the AAT and achieved a massive victory, further, you managed to spend in the region of AUD $250,000 to ruin the career of one individual; a humble joy flight pilot".
LSD – "We were shocked to discover that our department had been used to facilitate such a travesty". "We were horrified to learn of the tactics employed to support the case and that we had been misled". "We have now brought the matter to the ethics committee, instigated an AFP investigation and are attempting to reach an under the counter agreement with the injured party; see here, this is what we have done so far".
Course, it's all bollocks and neatly steps around the fact that the injured party is complaining about the very people who sit on the ethics committee; including the ICC who was the leading light in achieving the CASA victory in the AAT.
The Monday morning prayers at FF will include a delicately phrased request that the Murky Machiavellian crew can pull enough levers and push enough buttons to cover the collective CASA ass. A rider will be that the clever lads in the Senate have not got a plan, a pile of evidence and that the collective disgust for CASA has, overnight, turned into some form of benevolent protection credo. I doubt it; (IMO) there is a fully hatched plan, but we shall see. Just can't see the MM crew strolling into the inner sanctum and saying, "how about knocking off fellah's, we can fix this internally"; not if they intend to pursue lucrative careers.
Babble and spin, Babble and spin in the land where deception thrives.
Babble and spin, Babble and spin in the wrecking of other folks lives;
Babble and spin, Babble and spin mixed with open contempt, can lead to another planet, where Her Majesty pays your rent.
Anyway – He-who-do-voodoo has more sense – even if it's just a sense of self preservation. I shall watch with interest and not be disapointed; at the very least there'll be a laugh or two in the video and gods know, we could stand a laugh or two.
"The time has come," the Walrus said,
"To talk of many things:
Of shoes--and ships--and sealing-wax--
Of cabbages--and kings--
And why the sea is boiling hot--
And whether pigs have wings.
Lewis Carroll.
Toot toot.
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Biblical Sunfish.
On who's hands will be the blood??; them as knows, that's who. The world and it's wife knows and Fawcett is no shirker. One of the larger stumbling blocks CASA face is 'expert' opinion from someone with enough horsepower to stare them down on the technical side and enough guts to call bull- on the 'operational' safety case. Then, there is the question of legal argument with folk who can and do understand the law. It's a pretty even contest, but this time, the committee is not an obliging team of nodding Muppets. CASA is on uncertain ground in a hostile environment, armed only with an unreliable minuscule and being led along by one will sell 'em down the river to protect his rice bowl. The rules of engagement allow for penalties to be given for telling gross porkies. There is far too much on the debit side of the ledger for Truss to balance, he'll let the Senate do his dirty work; he has little to loose and much to gain from the exercise and he keeps his hands pristine (ish).
Don't think that will bluff the Senators anymore than it would bluff industry; we all know its a load of old
Sunny - "Senator, your actions are compromising air safety!".
Isaiah 59.3. "For your hands are defiled with blood And your fingers with iniquity; Your lips have spoken falsehood, Your tongue mutters wickedness. No one sues righteously and no one pleads honestly. They trust in confusion and speak lies; They conceive mischief and bring forth iniquity.…
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Just remember 9A
The use of CAA 9A by skull in the last estimates against a question by the Heff, was noted in a CVD question.
This certainly seems to be the fall-back position to take, where "...the safety of air navigation can be compromised..." - 9A applies.
This certainly seems to be the fall-back position to take, where "...the safety of air navigation can be compromised..." - 9A applies.
