Australia Aviation Regulatory Burden - A Tragedy
Thread Starter
Australia Aviation Regulatory Burden - A Tragedy
Is it just me that has noted that the burden of compliance is ever increasing and becoming impossible to meet.
At some operations I know, there have been people working almost non stop on writing operations manuals for the majority of a decade and it’s still nowhere near done.
The extra staff required to meet regulatory compliance is eye watering. The work load and stress caused by CASA compliance is just incredible.
The majority of the burden stems from the most poorly structured and written suite of rules I have ever seen.
Very few Australian regulations are written in a style for operators or end users but designed to be for lawyers to form the noose with which to hang an operator after an event.
I have nightmares about getting a good working knowledge on the current regulatory Flight Duty times when flight operations cross into 3 or 4 of the Annex definitions.
Part of the burden is also self inflicted because the Operations Manuals are no longer just one simple manual but now a never ending suite of volumes that are each of a size and complexity such that they are almost impossible to have a good working knowledge of let alone retain.
Combine the above with the poorly written extra curricular studies (CRM, RVSM, RNP, TCAS, EGPWS, HF, TEM, EMERGENCY DRILLS, DGs) and I see how costs just skyrocket- because it must be almost impossible to make a profit under this burden.
And it is certainly not SAFER.
Safe is NOT having an 800 page AIP, a 1000 page Operating Manual suite and untold hundreds of pages of CARs, CASRs, CAOs, MOSs, and NOTAMs to recall when things go wrong on a dark and stormy night or when your eyeballs are hanging out during a miserable grey wet first light approach after an oceanic or ITCZ crossing. At that point there are only a handful of numbers that are important and they may all be in an AFM for which there is no longer working brain space to store.
I see that it’s time for operators to stand up and stop this snowball effect. It’s time that we got back to some good simple flying basics in this way too complicated CASA regulatory world. For a start it’s long overdue that we had regulations written for operators and not lawyers and Ops Manuals that were designed for operating and not arse covering.
At some operations I know, there have been people working almost non stop on writing operations manuals for the majority of a decade and it’s still nowhere near done.
The extra staff required to meet regulatory compliance is eye watering. The work load and stress caused by CASA compliance is just incredible.
The majority of the burden stems from the most poorly structured and written suite of rules I have ever seen.
Very few Australian regulations are written in a style for operators or end users but designed to be for lawyers to form the noose with which to hang an operator after an event.
I have nightmares about getting a good working knowledge on the current regulatory Flight Duty times when flight operations cross into 3 or 4 of the Annex definitions.
Part of the burden is also self inflicted because the Operations Manuals are no longer just one simple manual but now a never ending suite of volumes that are each of a size and complexity such that they are almost impossible to have a good working knowledge of let alone retain.
Combine the above with the poorly written extra curricular studies (CRM, RVSM, RNP, TCAS, EGPWS, HF, TEM, EMERGENCY DRILLS, DGs) and I see how costs just skyrocket- because it must be almost impossible to make a profit under this burden.
And it is certainly not SAFER.
Safe is NOT having an 800 page AIP, a 1000 page Operating Manual suite and untold hundreds of pages of CARs, CASRs, CAOs, MOSs, and NOTAMs to recall when things go wrong on a dark and stormy night or when your eyeballs are hanging out during a miserable grey wet first light approach after an oceanic or ITCZ crossing. At that point there are only a handful of numbers that are important and they may all be in an AFM for which there is no longer working brain space to store.
I see that it’s time for operators to stand up and stop this snowball effect. It’s time that we got back to some good simple flying basics in this way too complicated CASA regulatory world. For a start it’s long overdue that we had regulations written for operators and not lawyers and Ops Manuals that were designed for operating and not arse covering.
The following 7 users liked this post by ramble on:
The following 2 users liked this post by Big Silver Spoon:
It’s a national embarrassment. As it’s been for longer than my 30 yr career. About the only thing that changes is the organisation’s name and logo. (About 4 times from memory)
That’s the best solution here, but it will never happen.
The problem is that CASA make themselves needed. It’s a self-propagating department that introduces incredible amounts and layers of bureaucracy to sustain their own employment.
Any suggested shift away from CASRs would be quashed with Helen Lovejoy type pontificating about how adopting the FARs will make the skies fall in.
You can see the news interviews now “CASA and our regulations must stay, because, you know - safety.”
The other fundamental problem with CASA is that some of their employees are industry rejects and dropouts. They’re paid significantly less than most people working in the industry. If one can earn $100k as a CASA FOI or $250k as a TRE, what sort of candidates do you think they’re attracting?
CASA staff should be the best of the best and should be paid as such. The CASRs should be wiped and replaced overnight with the FARs. AVMED should be cleaned out overnight. And the head of power should be returned to the transport minister so there’s some accountability.
But CASA themselves will make sure that never happens.
The problem is that CASA make themselves needed. It’s a self-propagating department that introduces incredible amounts and layers of bureaucracy to sustain their own employment.
Any suggested shift away from CASRs would be quashed with Helen Lovejoy type pontificating about how adopting the FARs will make the skies fall in.
You can see the news interviews now “CASA and our regulations must stay, because, you know - safety.”
The other fundamental problem with CASA is that some of their employees are industry rejects and dropouts. They’re paid significantly less than most people working in the industry. If one can earn $100k as a CASA FOI or $250k as a TRE, what sort of candidates do you think they’re attracting?
CASA staff should be the best of the best and should be paid as such. The CASRs should be wiped and replaced overnight with the FARs. AVMED should be cleaned out overnight. And the head of power should be returned to the transport minister so there’s some accountability.
But CASA themselves will make sure that never happens.
It’s not just CASA it is in anything in Australia. I would hate to own/run a business.
I nearly fell off my chair on comprehending the extent to which basic information has been removed from the AIP. Check out this 'useful' information:
People are being paid to reinvent the wheel into a shape that doesn't rotate. Cue Yakety Sax.
2. VISUAL METEOROLOGICAL CONDITIONS (VMC) - TAKE-OFF, EN ROUTE AND LANDING
2.1 The cloud and visibility criteria for VMC, including specific additional requirements, are contained in section 2.07 of the Part 91 MOS.
2.1 The cloud and visibility criteria for VMC, including specific additional requirements, are contained in section 2.07 of the Part 91 MOS.
The following users liked this post:
A lot of the regs can be some what irrelevant on a day to day basis for an airline pilot. But I I'd hate to own an aviation business. I Don't know how they do it...
I figure if I know the AIP, the company manuals and the FCOM The rest of it... eh who cares really.
What makes it even more ridiculous is that on 2 December 2021 when the new Flight Operations Regulations came into force, CASA issued a lot of Supplementary Exemptions and Directions Instruments that basically had the effect of providing relief until December 2024 against certain provisions in CASR Parts 91, 119, 121, 133, 135, and 138....I think there's more but they're the ones I'm currently looking at.
In other words, the current mess of regulatory requirements have become incomprehensible to the point of being almost impossible to understand any more.
ramble on is absolutely correct...…. CASA is completely oblivious to the fact that the burdens of it's compliance requirements are complicated, ever increasing, becoming impossible to meet, and presenting real challenges to aviation organisations in terms of significant costs, operational inefficiencies, reputational damage, and legal consequences if they can't comply.
But given the history of the regulatory reform process NOTHING will change for the better I'm afraid.
In other words, the current mess of regulatory requirements have become incomprehensible to the point of being almost impossible to understand any more.
ramble on is absolutely correct...…. CASA is completely oblivious to the fact that the burdens of it's compliance requirements are complicated, ever increasing, becoming impossible to meet, and presenting real challenges to aviation organisations in terms of significant costs, operational inefficiencies, reputational damage, and legal consequences if they can't comply.
But given the history of the regulatory reform process NOTHING will change for the better I'm afraid.
Last edited by SIUYA; 13th Dec 2023 at 06:42.
We all know someone from our past, that when we find out they now work for CASA , you think "yeah that figures."
I was kind of bricking it, but I did it anyway. I got a call from another CASA person, we had a good chat and he agreed to change the testing person.
The problem with Australians are they are gutless, they accept mediocre authority telling them 'how it is' when industry should be contributing to 'how it is'
Note: The gutless comment does not apply to all Australians, there are clearly some people who stand up. But it needs the majority to stand up, not just a few individuals.
The following users liked this post:
