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-   -   Now is your chance to remove unnecessary rules and costs/VOR airspace thread merged (https://www.pprune.org/australia-new-zealand-pacific/280106-now-your-chance-remove-unnecessary-rules-costs-vor-airspace-thread-merged.html)

Dick Smith 14th Jun 2007 23:49

Now is your chance to remove unnecessary rules and costs/VOR airspace thread merged
 
I have so far attended two meetings of the Aviation Regulation Review Taskforce set up by Minister Mark Vaile. I believe there will be some very positive changes to assist aviation.

It is obvious to me that after many years of not really getting anywhere, in the last 18 months the people at CASA are focusing more on Government policy in relation to rule writing – that is, to only be prescriptive where required, harmonising internationally wherever possible, and ruthlessly removing any rule which adds to cost without effectively adding to safety.

In relation to this last point, I have been asking people of requirements in Australia which add to costs compared to requirements in other leading aviation countries. I ask one of the Moderators to “sticky” this thread so we can get a list of such items from anyone who is interested.

I will start off with a few here, and I look forward to dozens (if not hundreds) more.

Simply by listing these additional costly requirements does not mean that CASA will necessarily follow what happens (and is proven) overseas. In some situations – but not many – our conditions are different here in Australia. However if the differences can be brought forward, at least the people who have the responsibility in relation to regulatory reform can look at the issues.

I start as follows.

1. The requirement in Australia not to fly above 10,000 feet without oxygen. In the USA it is 12,500 feet for continuous flight and up to 14,000 for 30 minutes. A rough calculation shows that over $1 million per year could be saved in fuel costs alone if we harmonise with this requirement. And of course often the aircraft could be above the inversion layer flying in smooth air.

2. The requirement in Australia that if a pilot is to perform a straight-in approach it must be at least a 5 mile final. Imagine the time that is wasted by a farmer landing on his grass paddock or a cropduster wanting to do a straight-in approach. This is a unique Australian requirement – probably designed for 747s, but hardly necessary for the Piper Cubs and Cherokees which it applies to. A lot of fuel will be saved if this is harmonised internationally.

3. The requirement that flight instructors must operate under an AOC. In the USA, most flying training is by highly experienced instructors – quite often older, more mature pilots – who operate independently without the high cost of an AOC.

4. The unique Australian ADs, including AD/GEN/37, which requires the emergency exit of an aircraft such as a Citation to be operated and inspected every 6 months. Under the FAA requirements it is once every 3 years. This means the Australian cost is 6 times greater, possibly without any measurable increase in safety. There are many other costly ADs like this – such as AD/INST/9, which requires instruments to be removed from the panel every 3 years to be tested accurate. However many modern LCD indicators cannot be tested unless they go back to the factory – costing a small fortune (if indeed it is to be complied with).

These are just 4 examples. I look forward to others. I will compile a list of everything that is posted and send it off to the people who are developing the standards in CASA.

Condition lever 15th Jun 2007 00:46

Dick,

1. Just because they do it in the US does not make it better or safer. The US has far higher terrain and as such MSAs - in some cases necessitating flight above A100 - we don't. The physiological aspects of operating for extended periods with a cabin alt of over A100 must be considered and IMHO not worth the increase in risk in Australia.

2. It is my understanding that the requirement for rejoin via a 5nm final is for licenced airfields only and therefore your example of a farmer & paddock or a crop-duster (unless it is at a licenced field) is erroneous. Given the frequency of most recreational pilots flying I would think it prudent to maintain this requirement so as to facilitate identification of all circuit traffic especially now that you have allowed non-radio equipped aircraft to operate.


Perhaps you might look at how CASA can justify charging $130 (soon to become $75) to process medical licences for those without restrictions ie. no thinking required. Even at $75 this is ridiculously expensive.

Torres 15th Jun 2007 01:45

Cessna 400 series spar cap inspection. Why is Australia the only country in the world requiring Cessna 400 series aircraft to go through a spar cap inspection and replacement each 8,500 hours, at a cost of $50,000 to $100,000?

The Aero Commander 500S was certified in Australia at < 10% above it's FAA Manufacturer approved Maximum Take Off Weight. Why is this aircraft permitted to operate in Australia on commercial passenger operations at weights at which it can not achieve minimum performance requirements?

barra21 15th Jun 2007 02:19

Air taxi category
 
There is a need for an air taxi category to be introduced. Low capacity RPT is dying. It is not viable to operate 9 seats to RPT in the bush.

Capn Bloggs 15th Jun 2007 02:20

I've got one. Get rid of the useless non-radar E airspace band between 185 and 245. It prevents IFR aircraft from using block levels, thereby wasting fuel, discomforting passengers and preventing crews from easily finding smooth air to operate at the most economical speeds, all because of the VERY FEW Australian-registered VFR aircraft that are legally permitted to fly above FL200 and whose pilots are selfish enough to want to put themselves ahead of thousands of other airspace users.


probably designed for 747s, but hardly necessary for the Piper Cubs and Cherokees
There you go, living in your own vacuum again. Have you ever thought of the poor 737 crew trying to spot a bugsmasher joining a 1nm oblique final under their nose? I didn't think so. If you want to remove the rule for your paddock, then that's fine. Just make sure that's all that's changed. Aviation is getting dangerous enough without a free-for-all in the CCT.

Torres 15th Jun 2007 03:00

What barra21 said. Re-introduce low capacity RPT operations similar to the previous ANR203 Exemption for aircraft less than 5,700 kg, maximum nine seats.

And why are AOCs not perpetually valid (until suspended or canceled) as was the case in previous years?

OZBUSDRIVER 15th Jun 2007 03:19

Dick, I agree with your third point. The US CFI system would be a benefit for Grade 1 qualified instructors.

My personal hate is the blunderbus approach for issue of ASIC. Surely there has to be something that could reduce the footprint of sterile areas to only those areas used by RPT. BDV with the same security req as BN is a joke. Surely a trigger would be a Dash8 service as a minimum and only then for an hour either side of ops and only within a confined area in front of that terminal.

Tell the Government to control its tenants wrt leases of GA airports.

Tell real estate hungry councils and developers that an aerodrome is for the exclusive use of aeroplanes and ancillary services. Aeroplanes will make noise around these aerodromes that non-aviation savy people will find offensive. Footprint maps must be included in all transactions over the sale of properties within an exposure area of these aerodromes to ensure that NIMBY groups (normally consisting of one owner making a lot of noise) are fully aware of what they are living next to.

Tell state governments to change their laws that allow mates to charge for the use of airspace above their airports. Unless an aid is bought and payed for by the owner of said airport, they should not have rights to charge for commonwealth owned and operated property.

Tell the Government to seriously look at the feasability of providing a WAAS capable signal from the Japanese MSAT to be beamed over the entire continent and surrounding oceans within the economic zone. This will be of more benefit to the wider community than just aviation. Travel/Tourism, transport, survey industry, shipping, customs, recreational sports,...a lot more people than you would expect. For us it gives a better outcome for regional and remote aerodromes to have a safe and viable option for vertical guided approaches that will not be available from ground based augmentation systems that are currently being promoted.

No one is asking for a subsidy. Aviation is an important piece of infrastructure that just simply falls off the radar when it gets outside the J curve from CNS to AD with a bit out in PH. A community aerodrome is just as important as a bitumen road. The only time it gets noticed is when someone has to move in a hurry, or medical emergencies and natural disasters.

Dick Smith 15th Jun 2007 04:00

Condition lever, I knew this had to happen. I have never said that something is better or safer in the USA, I’ve just said that if we have higher costs, our industry will be destroyed – and that is happening.

1. If there was an increase in risk in operating above 10,000 feet without oxygen, this should surely be reflected in the US accident rate – however it is not. If you look at the GA accident rate in the USA there is no measurable difference to our accident rate - even though they have months of snow and ice, huge high mountain ranges and 15 times the amount of traffic.

You state it is:


IMHO not worth the increase in risk in Australia.
Can you advise what information you have that there is a measurable increase in risk?

Also, do you think it is sensible for a pilot and passengers to be bashing around in the most incredible turbulence at 10,000 feet when they could be at 11,000 or 12,000 feet in smooth air? I certainly don’t.

2. Your understanding in relation to the 5 nautical mile final only being required at licensed airfields is wrong. The requirement is for all landings. This means that my example is not erroneous.

Once again, you are resisting change. Everything must remain the same, nothing must ever change. Then we will all be comfortable – won’t we?

djpil 15th Jun 2007 04:04


The requirement that flight instructors must operate under an AOC. In the USA, most flying training is by highly experienced instructors – quite often older, more mature pilots – who operate independently without the high cost of an AOC.
I'm not sure that "most" flying training in the USA is by independent instructors and the downside is the higher number of hours that the FAA requires for their students compared to those of an approved school. Still, it seems to work well with "older, more mature pilots" called upon as FAA Safety Counsellors and involved in their WINGS programs etc.
Merging the bottom end of GA with RAA type ops would seem to be part of the answer.

On the hardware side:
There's a requirement for an "export airworthiness approval" per section 7.1 http://casa.gov.au/rules/1998casr/021/021c22.pdf
Some relaxation of this should be considered. A part from the USA with a PMA comes with a release certificate from the manufacturer. If I order a part for my aeroplane I also need a Form 8130.
One example at B&C- an oil filter adaptor for uncertified aircraft sells for $395. I don't have a problem in them recovering the extra costs for the PMA'd one at $450 (exactly same part, they just ask whether you want the extra bit of paper when it is delivered). I have a problem when they say it is for Australia so needs yet another bit of paper and the extra cost just pays for some-one to visit their factory and sign it - for an extra $100.

Dick Smith 15th Jun 2007 04:21

Keep them coming! This is really important. In relation to the ASIC, my friends who fly a Falcon 10 in the USA do not have ASICs – they are not required.

What about this one? In Australia a student pilot needs to get an ASIC, with all of the costs and delays involved. In the USA there is no such requirement – and remember the US is the home of September 11 – the instructor simply has to check that the pilot is an American citizen by looking at a birth certificate or passport.

Djpil, you say:


I'm not sure that "most" flying training in the USA is by independent instructors
I can assure you that the latest statistics show that over 60% of training in the USA is performed by instructors who are independent of a flying school which would hold the equivalent of an AOC in Australia. That’s a good idea too, but direct training by an instructor would have great advantages in reducing costs here in Australia – especially in our more remote country towns.

As I said, keep them coming.

Chronic Snoozer 15th Jun 2007 06:30

How about a rule that allows you to write off an aircraft purchase in 3 years? That would kick start the industry.

Chimbu chuckles 15th Jun 2007 08:23

I don't know that the Oz v US O2 rule is that big an issue in an urgent regulatory sense.

Things that do need fixing urgently...in no set order,

* Medical fees: Take it out of CASA's hands and put it in the DAME's..period.

* ASICs: Pure unadulterated stupidity of Pythonesque proportions...particularly as it effects student pilots but also airports that are effected...Toowoomba as just one example...Grafton another...there are LOTS more:ugh: They should ONLY be a requirement at capital city airports such as SY,ML,CB etc.

* Pilot training: There needs to be a way to facilitate experienced pilots who want to 'put something back'. Pilots with a background in training outside of the ab initio/flying school system but that have a great deal of training and checking experience within the broader regulatory framework. The US model is a good one in this respect.

* The ATO system: It needs modifying so schools cannot pick and choose 'easy' ATOs that pass just about anyone...yes it happens:rolleyes:

* Airspace: KISS. I would suggest back to the old CTA/OCA system. Rather than CTAF frequencies simply have all aerodromes operating on a (published on charts etc) area fequency basis with a very few basic mandatory radio calls. CTA would have few classifications...Class C (or B if deemed appropriate at somewhere like SY) and Class D at places like Coffs/BK/MC etc...Class D could be further broken down into 'Radar' D and 'Procedural' D (essentially what GAAP is) if required. Everything else is G with RIS within radar/ads-b coverage.

* User pays: It must be recognised that 'the system' exists only because of the 'big end of town'. I have posted this analogy before...imagine the system the day after every hi cap domestic/international RPT aircraft was grounded and then imagine it the day after every private GA/charter aircraft was grounded. Having recognised that the system requirements are purely driven by hi capacity operators recognise also that GA already contributes more than it costs via sundry indirect taxes, GST etc. As it stands we are being double taxed in many areas by paying GST on top of govt 'fees' for service...this is an obscenity.:ugh:

Chimbu chuckles 15th Jun 2007 08:58

* CASA/AsA/BASI. Put them back together, slim the resultant regulatory body down ENORMOUSLY and recognise the fact that it should NEVER have been 'corporatised' in the first place and stop charging for services that federal taxes are paid for, essential national infrastructure. Imagine the political backlash against any state govt that corporatised the Department of Main Roads or Maritime Services Board..aviation is essentially no different:ugh:

* Fascilitate WAAS as a matter of extreme urgency so that every airport in Australia can have a GPS based version of an ILS with verticle guidance down to Cat 1 minimas. The one thing that would have mitigated the 'worst aircrash' in Australia's history and numerous other fatal accidents. As soon as WAAS is available shut down every NDB in Australia and most of the VORs.

* Fascilitate low level ADS-B.

Torres 15th Jun 2007 09:55


"3) suggest CASA consider looking into the financial viability of a company that holds an AOC, send in appropriately trained accountants on audits."
No, no, no!!! When my accountant hires aircraft, CASA should get into the financial audit business!!! :mad:

CASA tried that - it is far too complex and subjective. On the basis of their debt to equity ratio, neither Qantas nor Virgin would hold an AOC.

Whilst the Act permits CASA to consider other matters in the issue of an AOC, don't give them ideas to re-visit financial viability!!! :sad:

poteroo 15th Jun 2007 12:44

Where, where, do we start?

Dick,

We can but hope that sanity might eventually prevail, but the way the legal profession is driving our industry....I'm not hopeful. But, for the exercise, I'll try a few suggestions in regards to flight training:

(1) Security has become an obstacle to business. Airport 'security' has fenced off our school from public access, and we have lost, and continue to lose, business because of this. Airport owners were panicced into erecting fences willy nilly.....which they now concede are often in the wrong place. ASIC's are required for airports which are 'RPT' for 2 hrs daily - the rest of the time you couldn't find a human being there.

(2) Abolish the AOC system, and allow flight instruction to proceed as per the US model. The result will be flight instruction available to country citizens,on their own airport,at a reasonable price. As mentioned elsewhere - there's a lot of 'retired' instructing talent around Australia - and they could fill the current shortages of instructors. But, they are not about to buy an AOC and be subject to all the hassles.

(3) Appoint more ATO's - the current situation is pathetic. Why should we suffer a 3 month lead for booking a test? If there were enough ATO's - then it would be possible for every PPL test to be done independantly, rather than by the applicants CFI. Standards would improve when the product of each and every flight school is independantly evaluated via such a system. This will do more to lift the 'perceived' lowering of instructional success than any other change.

(4) Allow GA instructors to become RAA instructors subject only to type proficiency - not this silly business of 'you-must-start-at-the-bottom- as at present. The US and UK allow this - why not here?

(5) Allow all aircraft which are LAME maintained to operate in flight training for either GA or RAA....regardless of their registration. They are the same aircraft - just the numbers have changed.


Dick, I realise that we have a deeply conservative 'system' entrenched in Australia. Yes, the air is of a different density, and aircraft do fly 'differently' here.....but, we have to get over these attitudinal aberrations which have become the norm in Canberra.

I sincerely hope that you can represent us there,

happy days,

CHAIRMAN 15th Jun 2007 12:55

OZBUS - many good points there.
Assuming that training AOC's will stay, why the separate charges to add another light single or twin to the AOC? I note in the new scale of charges about to be introduced that MOST charges are HOURLY RATE - just wait till this kicks in!!
Dick, seeing as how you started this thread, could you distill the consensus periodically into some meaningful list - it seems most of us are on the same track.
CHAIRMAN

compressor stall 15th Jun 2007 13:16

Lots of good stuff here.

Re max alt without oxygen. I completely agree with the 12500 foot rule. The air is not that mouch different in oz as it is in USA. Not sure we need the 14000' for 30 mins rule (most likely introduced in the US to pop over the Rockies at a good height, then descent).

Straight in approaches - yep, should be allowed everywhere

Instructors without an AOC - bring it on! A great move. Will also allow people who are experienced and passionate about flight instruction to do it.

ASICs for capital city airports only. And not needed for students.

There should be no difference in maintenance standards and pilot experience for RPT and charter. I have the whole aircraft to myself and get it has to meet a lower standard of maintenance?

Define RPT and charter better - none of this shelf company cross hire stuff to get around it all. One rule for all lighties carrying fare paying passengers, whether it's a fixed terminal/schedule or walk in charter to Kiwikurra.

More to come!

Good work Dick, and many here no doubt appreciate the ability to input. But please, may these suggestions please be tabled and put forward on their merits and not bundled up into an airspace agenda.


NB for the medical side of things - yes the $130 is outrageous, but I understand that your Doc is a Delegate of the CASA doc. If s/he did not pick up your heart irregularity and you have a heart attack killing 5 pax, your doc is covered by CASA' coverage. Can you imagine how large the insurance premiums would be for you local aviation doc? Mine said he'd stop doing aviation medicals.

Chimbu chuckles 15th Jun 2007 13:43

The liability issues are adressed as currently. The issuance of a renewed medical should be solely at the discretion of your DAME in 99% of cases...he tests you, passes you fit (or not) and hits 'print' on his computer and it spits out new medical and sends notification to CASA...CASA database updated automagically and you go on your merry way $130 better off. For renewal of ATPL/CPL the exact same procedure but you provide your employer with copy of renewed medical for their files.

It should be so bloody easy:ugh:

An 'Air Taxi' classification is also an excellent idea. No AOC but with 6 or 12 mthly 'operational audits' that could be carried out by delegated ATOs as part of an increased licence/proficiency check protocol carried out on CPs of air taxi operations...initially 6 mthly and then with proven track record increased to annually and even over time it could be bi annually for really good operators.

It could be a very simple process...it's not like AOCs actually stop anyone breaking rules if they are that way inclined.:hmm:

Centaurus 15th Jun 2007 13:59


simply have all aerodromes operating on a (published on charts etc) area fequency basis with a very few basic mandatory radio calls
Hear, hear. The amount of extra radio chatter that clutters a circuit nowadays is beyond the pale. Of course, pilots have no choice because it is set in stone in AIP. This superfluous use of radio is the direct result of knee-jerk legal and media attention following a couple of accidents in the circuit area. Unmerciful culling of mandated radio calls is needed if only because a Mayday call may go unheard over the din of such constant gems as "Vacating runway 17". and a few seconds later "Vacated runway 17" plus its various other radio call appendages

apache 15th Jun 2007 15:50

How about we make the ATPL licence actually mean something ?

ie: why is it that a CPL can fly, say, a Bandeirante with 15 pax on CHARTER, but cannot fly it over the same route RPT as PIC? unless he/she has passed the ATPL criteria ?
BUT... a CPL can fly, say, a B200 /c404 with 9 pax onboard over RPT routtes, and NOT have an ATPL ???

why does passing an outdated exam on b727 flight planning/wt and balance etc. make you more qualified pilot to fly 10+ pax on RPT ???

and WHY does it cost so much to sit an exam ? not just the ATPL's, but CPL/PPL/IREX ?

surely this can be outsourced to flying schools who can keep it inhouse at 1/10th the cost ?

Tinstaafl 15th Jun 2007 18:16

Have more than one - preferably lots - of organisations who are approved to conduct exams. Nothing like competition to drop the price imposed under the current monopoly.


Re. Instructing without an AOC: There needs to be some means of quality control over the instructor. The US doesn't just let instructors instruct willy-nilly. The FAA monitors the instructor's pass rate for students s/he recommends for a test.

auto throttle 16th Jun 2007 00:59

How about reducing the costs involved in importing an aircraft and putting it on the "VH" register. A lot of people including our company don't want to fork out hundreds of thousands of dollars just to change it from "N" (US)registered to "VH" registered, especially if it is the first type in Australia. For example, there are about 80 "VH" (non commercial) jets compared to 80,000 "N" registered jets. It would be great to see more modern and safer aircraft operating on Australian AOC's. The aircraft are here, and I'm sure if the costs were reasonable, then some of the aircraft would change their registration and put it on an AOC... I know we would. Operators would also be able to justify the costs in updating all their aircraft, and with todays technology, this would mean more reliable and safer planes...just my two cents worth???

Fhead 16th Jun 2007 02:09

ooh danger with the competition for tests. They would not only compete on price but also pass rates. Casa already charges what is $150 to sit an exam why can't they do what are being done by these companies? All they have to do is make the questions and send them out to the flying schools even if they don't send out the answers but take the test back to be marked by a computer or over the net like now.

Also why can't all none passenger charter GA aircraft be RAA registered, or aircraft not belonging to an AOC be RAA. Some of the ultralights nowa days out preform some GA aircraft anyway.

nomorecatering 16th Jun 2007 02:48

A good idea would be to eliminate the silly requirement to have 10 hrs on type on a twin to instruct, even if you have hundreds and hundreds of hrs on a similar type eg BE76 to PA44.

Also allows CFI's to issue student licences so they can go solo when ready, not after CPL NAV 7 when it finally arrives.

Rich-Fine-Green 16th Jun 2007 06:04

DS:
I don't agree on a free-for-all - letting Instructors teach where, when and who they like.

How about a system that lets said Instructors gain a limited AOC with minimal expense and most of all - LITTLE DELAY!!.

The REAL cost for many small start-ups is the long, long, long time it takes to get an initial issue AOC or an Amendment to an existing AOC. A 6-12 month wait is not uncommon these days!!.

How about a system that allows for a one-man band Grade 1 Instructor become his/her own DAY/VFR/S.E. 'flight school' that teaches in a student's own aircraft by:

1. Establishing a Business Name.
2. Purchase a standardised Operations Manual 'On-Line'.
3. Have a quick interview by web-cam or telephone to save travel time.
4. CASA then emails the AOC in pdf for printing. No need to wait for 2 months while the signatory is away on long service or stress leave.

The process could be done in days - not months.

As suggested already, the quality of the Instructor can be measured by the pass rate. Few passes - No more Limited AOC.

Wind back a couple of decades when I first had an AOC, adding a new type for charter or aerial work did not need expense or approvals.

Also, how about giving a CP or CFI an INITIAL Interview only and not make the poor buggers go through the same process every time they change jobs. Why does one CASA office accept a CFI yet another CASA office knocks the same person back?.

triadic 16th Jun 2007 10:01

Dick, good to see you asking for input.... are the others doing that as well?

Here is my 2c worth for consideration:


1) The regs should be made more user-friendly. Back at the CASA FLOT Conference in ‘03, one of the points that came out was that the greatest hazard to aviation was the Attorney’s Generals Department for the way they required the regs/rules to be drafted etc. Aviation is one activity where those in it, such as pilots etc work with the various regs/Acts etc in their face all the time. If you are learning to drive, you go down the newsagent and buy the rule book that covers all you need to know including pictures ! There is none of that in aviation, tho’ in the USA they have the AIM which most refer to before the FARs. We don’t have an AIM. All we have is a strict liability statement on every other page, making the document most un-user friendly – ugly in fact! Either we need an equivalent to the AIM or some major redrafting of our regs etc to make them more user friendly and readable.

2) Student pilot licences must be able to be issued by a CFI. The existing wait for security serves no useful purpose and certainly does not enhance security when you consider the risk and the cost.


3) Issue of ASICs must be streamlined. The existing system and charge is driving many away from the industry.

4) Independent instructors could be a good thing, but as said previously there must be some way to ensure standardisation.


5) ATOs must not be permitted to test their own students. PPL only with prior approval and certainly not CPL and IR.

6) It was said at an industry conference a few years back in support of increased flying training standards, that “there were approx 400 places in Oz where you could learn to fly, and only 15 or so places where you could train to be a lawyer!”. What that says is that not every flying school should be permitted to teach above PPL/NVFR. Schools that teach CPL/IRR must jump a higher bar. The standards of trainee CPL pilots coming out of the schools over the past few years are in a word poor! A pilot passing a CPL in the last year or so would not have passed a PPL 15 years ago – go figure!!


7) Get the FOIs out of the office and do more tests. The standards only went down when they stopped testing, now many of them are trapped in the office driving paper and not doing what they are trained (!) to do.

8) Aviation has change as its middle name; however that change over the past decade or more has been very poorly managed (if at all?) and certainly in the airspace world not at all managed as a major project with change management experts involved. This must change and all proposals for change, no matter what, must be properly managed accordingly. This must always include risk analysis and appropriate cost / benefit analysis. On-going education must be part of any change and not just for a few months, but for ever if the change is significant. (and, it must be in someone’s budget!!) Every change should have to pass a user-friendly test and one that considers how the change will encourage aviation and not drive it underground.


9) Various tax liability charges changed at the same time as GST was introduced. Prior to that, aircraft parts etc were duty free, now everything is +10% minimum. Aviation and aircraft operators are at a significant disadvantage post this change (and nobody seems to care?).(no votes in Aviation !!)

10) I agree re the write-off of new aircraft over 3 years or so.


11) In order to encourage GA, AirServices should consider not sending out an invoice if the total is less say than $100 per Qtr. This would encourage private GA in particular to fly more, keep current and use ATC airports in lieu of staying away, with perhaps increased risks (?). I am sure the lost revenue as a result would be minimal and the resultant increase in safety would be significant.

I will now go and think of some more.....

cheers:ok:

MMSOBGYTAST 17th Jun 2007 06:36

Dick,

Why don't you reply to Capn Bloggs post? I think he has hit the nail on the head.

John Eacott 17th Jun 2007 07:24

Dick,

Whilst D & G has a tendency to FW, there is an enormous cost to the Australian helicopter industry as a result of our peculiar interpretation of the helicopter >2750kg ruling. Not only is the requirement that all (well, nearly all, your 109E being an exception!) helicopters >2750kg be maintained to Transport Class A regardless of complexity, there is also a doubling of hours required for endorsement training, compared to Class B helicopters.

A severe rationalisation of the training hours required is long overdue, and would save $10's of thousands per year for each helicopter currently >2750kg :ok:

Ovation 17th Jun 2007 12:40

My two bobs worth:
(1)
Adopt the US regime for IFR recency requirements
2)
Develop some means of reducing the frequency of the issue and updating of approach plates and charts (and reduce the cost)

Charlie Foxtrot India 17th Jun 2007 14:24

Agree with the points already mentioned:

CFIs to issue Student Pilot Licences

DAMEs to be able to issue immediate initial medicals for student pilots

Remove charges for medical issue and renewal unless they can justify it

Allow flying schools to conduct cyberexams up to CPL level

Minister to enforce the airports act on airport lease holders

Make AOCs perpetual

More independant ATOs and no more in-house flight tests

PLUS
Reprint the VFR flight guide

Airservices to sort out their billing - it's a mess - earlier this year they tried to charge double for landings following a session of circuits - I hope everyone was checking thier invoices and only paying what is in the standard contract .

Remove the requirement for overseas ICAO licence holders to have to get a certificate of validation - delegate CFIs to approve ICAO licence holders to fly privately here as per other ICAO countries

#1AHRS 17th Jun 2007 22:52

On a broader picture, Australian procedures and regs seem to have (like the marsupials) developed in isolation to the rest of the world. For a country that is flat, has fine weather and is relatively quiet traffic wise, you seem to have made a science out of something that the rest of the world easily achieves. Europe and USA, with far more challenging natural and traffic conditions, achieve better with less fuss and expense and with the same or better level of safety. Why? Casting the thought a little further abroad to those that do a lot more of it on a daily basis is one step in the right direction. However, changing the "we know better" attitude that seems to often permeate through Aus aviation, will be your biggest hurdle. C'mon CASA, as a leader, show some initiative and leadership.

Creampuff 18th Jun 2007 03:04

Dick

In a way, I am surprised that you have to ask this question. Given all that you have said about common sense and the self-evident way ahead with the rules, I would have thought that you (and folks like Leadsled) would have drafted them twice over by now. Why can't you (or Leadsled) simply plonk them on the table and say: 'Minister, sign these and the world of Australian aviation will be a better place.'

The reality is, of course, that there is no easy, clear, self-evident way ahead with aviation safety regulatory rules. If there were, it would have been taken decades ago.

The reality is that all rules are about reconciling irreconcilable differences - if they weren't, they wouldn't need to be made. That fundamental practical problem is exacerbated in Australia by the ever-increasing politicisation of what are supposed to be independent regulators. Most of the issues raised in this thread are about political compromises that have been imposed on aviation, not by CASA, but by broader government decisions in which political interests have been the determining factor. Why else would Australia have its current SPL arrangements, when similar arrangements were not considered necessary, and have not been imposed, in the USA, despite 9/11?

The government's only interest at the moment is to avoid bad headlines in the lead-up to the election. One person capable of generating bad headlines for the government is Dick Smith. That's why you got this gig, and David Hicks has been brought home.

Could you please describe precisely what the 'taskforce' of which you are a member is going to produce, when is it going to be produced, and what is going to be done about what you produce, when and by whom?

Surely you would agree that any body that is created by the government should be transparent and accountable.

Dick Smith 18th Jun 2007 03:23

Thanks everyone for the really good posts – I understand the “powers that be” at CASA are already reading and taking notes. I will of course prepare a list of the changes which have been mentioned here (in précis form) and post it, as well as sending it to CASA and bringing it forward at the next Taskforce meeting.

In relation to the unique Australian requirements for an ASIC and approval of student pilots, at the next Taskforce meeting we are to have a presentation from the experts in the Department on this issue. I believe they have open minds, and if it can be shown that by harmonising with what they do in the USA money can be saved without any measurable impact on safety, I’m sure that will happen.

Remember, these requirements came in not so long after September 11 when everyone wanted to be ultra-conservative in their decision making. Now that we can look at what the USA and other countries are doing – without any terrorist problems from small planes – we can obviously make better decisions.

I find it fascinating that posters such as Rich-Fine-Green state that we should not follow the US system where an instructor is allowed to teach without an AOC, but believes that there should be some form of “limited AOC with minimal expense.” This adds unnecessarily to costs. Can you imagine if when Mark Vaile signed the Free Trade Agreement with the USA, that we ended up with a situation of a “limited duty” with “minimal expense” which worked against Australian farmers. This would be crazy! It would stop us competing.

Australia competes on the world market for flying training. If our costs are higher we will lose business – that is obvious.

My experience in business shows that the difference between success and failure is a razor’s edge. It is all the small costs which have been listed here which are the difference between a business being successful or not. During discussions, whenever I mention extra costs in Australia – such as VFR aircraft not being able to fly at high levels to save the enroute Airservices IFR charge, I’m told “Dick, that is only a small cost – you should be concentrating on other things.”

Please keep the list coming.

I have another one. In the USA a pilot can get a helicopter instrument rating in a Robinson 22. In Australia, the helicopter needs to be IFR certified – and there are virtually none available. The interesting thing is that the resultant level of safety for helicopter ops is about the same between Australia and America – in effect, all the extra high costs of training in an IFR machine doesn’t give a higher level of safety.

John Eacott 18th Jun 2007 03:44


I have another one. In the USA a pilot can get a helicopter instrument rating in a Robinson 22. In Australia, the helicopter needs to be IFR certified – and there are virtually none available. The interesting thing is that the resultant level of safety for helicopter ops is about the same between Australia and America – in effect, all the extra high costs of training in an IFR machine doesn’t give a higher level of safety.

Dick,

One step further: my NVFR BK117 has ILS/VOR/GNSS, etc, which I can use to maintain approach currency.

But I can't use it to do my IR renewal :hmm:

gaunty 18th Jun 2007 04:12

Mr Smith

Once again you present us with a dilemma. How to use your undoubtedly high profile and access, to progress Australian aviation in an atmosphere of positive and mutual respect for each others views, usefully, without those same views being "Dick Smithed".

It may or may not be news to you that PPRuNe has been read and discussed by those in the halls of power for way longer than you have been a member. It may or may not be news to you that PPRuNe was, and maybe still is although the jury is out on it for the moment, where those in the halls of power came to find out the "real story", as distinct from an agenda or distorted information that maybe their "advisors" were feeding them.

I need not dilate on the details, they are well known here and there and you were not as often the subject as you may imagine. PPRuNers discriminate equally in so far as loose logic or specious argument is concerned.

Yours has been but one view expressed here, it carries no more nor less weight that any other PPRuNer, anonymous or not. The only weight it does carry is whether it can support a logical and/or factual basis for argument and that opinion is clearly disscociated from fact.

One can only applaud your motivation in offering to present PPRuNers views as a "chance to remove unecessary rules and costs" by your membership of the Ministerial advisory group. My worry is, and the evidence of the past suggests it may be so that apart from the really obvious stuff that has appeared here it that will be your agenda and not the industries which will be ultimately presented.

I digress, back to the dilemma, and I'll be blunt, the very value of PPRuNe is its anonymous nature, the ability of posters to speak plainly, even against accepted employer, Goverment or regulatory positions without fear of retribution. You have not valued that in the past we do not have any evidence that you will present the views from here without personal comment.

You may best advise your fellow members and the Govt et al to continue to do what they have since PPRuNe started get it directly from the horses mouth.

The argument or views presented here do not magically become logical or not when the PPRuNer does or does not identify themselves.

The sun may rise in the west before it happens, but there is a logical argument for you to post anonymously. At least there may be a chance that your arguments or views may get a chance to be assessed without the bagagge, there would be no more or less rigour and yes sometimes dumbosity applied to it but at the least you would find out, like some of the policy and rule changes floated here, whether it would fly or not.

huntsman 18th Jun 2007 07:30

  • Instructors to have a minimum 1000hrs TT
  • At about $200 per hr, CASA should supply a decent service under "User Pays"
  • Remove any need for ATPL Theory - or ATPL period

werbil 18th Jun 2007 12:21

Straight in approaches
 
CB - How is it physically easier to see an aircraft flying a normal base leg of a full circuit than an aircraft joining an oblique final 1nm from the threshold? :confused:

If the issue is with heavy jet aircraft, don't impose restrictions on operations where heavy jets can't operate. Under the legislation as it stands, an ag pilot flying off an ag strip legally has to either fly three legs of the circuit or join a 5nm final, as does any pilot operating at ANY uncontolled aerodrome in VMC. :ugh:

This is not advocating a free for all in the circuit - currently if you are on a straight in approach you are legally required by CAR 166 to give way to ANY aircraft that is flying a normal circuit (at least three legs). Keep the rule the same, or even give jets priority if that will make you happier .

IMHO appropriate, accurate, concise radio communication is the key to collision avoidance in the terminal area. It is much easier to see an aircraft when you know where it is, and if you can't see it both pilots can positively separate themselves. At any airport that is serviced by jet RPT I believe that either CTAF(R) is in place if not Class D.

Do you want to go back to the "old" days (pre straight in approach) where everyone had to fly three legs of the circuit? :yuk: Back then I heard a regional turbo prop calling "joining downwind" when they were on a 5nm oblique final (a local at the airport said this was standard practice). Even earlier than that at another airport I watched / heard a regional turbo prop come barrelling in on a straight in approach and the aircraft backtracking down the runway had to make a hurried cross country departure from the runway. :eek:

W

BTW A few months ago a 737 nearly had to fly a full circuit as I was established on a 5nm final and he was no 2 also on a straight in approach. If I'd been able to join at 2nm I would have been 2 minutes further ahead (I was appoaching at about 90 degrees to the runway direction) with no pressure to clear the runway. There were only 2 aircraft within 10nm of the aerodrome at the time (the 737 and myself), and there is normally only around 5 jet movements a day at this aerodrome. (DS condemned this airport (YBPN) as being the most dangerous in Australia a few years ago even though there is very little activity apart from the jet RPT).

Rich-Fine-Green 18th Jun 2007 12:44

DS:

I find it fascinating that posters such as Rich-Fine-Green state that we should not follow the US system where an instructor is allowed to teach without an AOC, but believes that there should be some form of “limited AOC with minimal expense.” This adds unnecessarily to costs. Can you imagine if when Mark Vaile signed the Free Trade Agreement with the USA, that we ended up with a situation of a “limited duty” with “minimal expense” which worked against Australian farmers. This would be crazy! It would stop us competing.
Read My post again.....:rolleyes:

My point was MORE the real costs with an AOC is the incrediblely long delay.

and No, there should not be a free-for-all. We ALL know of Instructors out there that should not be let off the leash without some kind of check and control. Thankfully, these people are very much in the minority. A free-for-all approach will allow some of the few unemployable Instructors loose without any controls.

Call it an AOC, Training Approval or whatever. A quick and inexpensive way of checking and approving such an Instructor is not unreasonable.

What would be unreasonable and damn expensive is to delay this Instructor.

Anyway, it's all hypothetical as all issues posted here by our fellow ppruners are not new and have been flagged to the different forms of CASA over the decades - including when you held the reins Dick.

Now i'm sure you did your very best during your short stay in CASA. It's not my place to comment or judge what was or wasn't done when you had the chance to make changes.

As much as I would like to hope your Taskforce will actually be taken seriously, there has not been much evidence in the last few decades that Industry opinion is in any way valued by CASA or the Govt. Du Jour. I've lost count of the number of Industry taskforces, Forums and Focus Groups that have been assembled over the years - all without result.

Dick - have you considered that this Taskforce may be a great way of keeping you occupied before an Election?.

Use your talents Man!. A hint of a statement from DS will bring the Journos running.

Lodown 18th Jun 2007 14:47

Dick, I was in two minds whether to respond. You charge into a topic like a bull into a china shop, make a big impact, get people fired up with a few key phrases and then turn the tables and expectations by presenting your agenda and publicly claiming to have wide support. Call me cynical, but you appear to be doing it again! You burst in like a white knight and aviation saviour and then proceed to pooh-pooh any suggestion that doesn’t fit with your version of “common-sense”. Reread your post “correcting” Rich-Fine-Green. :=

Forgive me for thinking that you have a purpose in mind for starting this post counter to seeking ideas. I get the feeling that you’re trolling for a couple of good topics that you can hang your hat on to regenerate personal aviation support. In the process, maybe you intend to ditch your image as a Liberal backer and replace it with a preferred image in the current political environment once again as an apolitical crusader for aviation reform and cuddle up to Labor supporters. In the general period of government departmental inactivity preceding and briefly following the next election, maybe I could be pardoned for thinking that you anticipate cementing a new influence and are seeking additional support by starting somewhat conciliatory and emotional topics on Pprune.

The campaigning and political positioning for the next election is well and truly underway. A pox on me for my cynicism. :yuk:

YesTAM 18th Jun 2007 19:43

1. Immediately introduce WAAS and forget about developing an (Australia only)ADS-B, in other words, stop developing instrumentation and use what the rest of the world uses. If someone wants to obtain a PhD in electronics, let them do it in their own time.

2. Harmonise and standardise what is taught in ab initio training and get rid of this stupid minimalist "outcomes based" or "Competency based" whatever its called CASA syllabus and go back to a traditional approach. One of the reasons I hang around Pprune is to pick up the odd Gem of wisdom that NO ONE has ever mentioned before, and believe me I fly with instructors as often as I can.

Examples include:

(a) Spending $1500 in insurance excess for a C172 firewall after bouncing one very badly because NO ONE had taught me what happens when you get it wrong and land too fast. I "demonstrated competence" on my endorsement without any understanding of what the potential errors were and what their effect would be. I understand that the C172 firewall thing is way too frequent - why?

(b) Doing a CS and Retractable endorsement and NO ONE mentioned the practice of checking manifold pressure and fuel flow as well as RPM and T's and P's on starting your roll. - I picked that up last week here. Anyone care to think how "expensive" that could be?

3. Iimmediately get rid of the requirement that a student needs an ASIC before First Solo and streamline the medical so that a DAME can issue one. Schools have lost students because of the delay.

4. DO NOT under any circumstances allow "accelerated depreciation" or any similar tax breaks for aircraft. If this happens, the tax scheme operators will dive in and rort it very quickly, totally distorting and poisoning the industry. PM me if you want more information as to why and how.

5. Most importantly somehow encourage CASA to adopt a culture of the "90 percent solution" BECAUSE IT IS INFINITELY CHEAPER. That means that if there is a system or practice overseas that meets 90 percent or more of Australias requirements, then CASA and the industry adopts it and WE CHANGE OUR BUSINESS PRACTICES to accomodate the 10 percent difference.STOP DEVELOPING ONE OFF SYSTEMS THAT MEET "100 PERCENT' OF A UNIQUELY AUSTRALIAN REQUIREMENT IMMEDIATELY! .


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