Headmaster. Good advice. I have done that. The problem is how some CASA officers interpret the wording.

The “absolute “ nature of the wording allows this.

Fujii. The FAA constantly keep the costs to GA as little as possible and the airspace accessible and simple

Quite different here.

I know that but GA has nothing to do with thread. I am just wondering why people are only questioning CASA’s approval of ETOPS when it is a international standard.

I would imagine CASA insisting a powerful airline have extra costs would not be possible.

Clearly CASA can impose extra costs on a non powerful GA industry such as part 61 and get away with it.

drivel, as well

So your (and Dick's) argument is there has been no objective risk assessment for safety? Especially given all the data that exists that proves his point that ETOPS operations are unsafe... wait, he's basing all his "data" around one bit of anecdotal data from a single source.

Dick, how about instead of sounding like someone who is willing to just jump on a single bit of anecdotal evidence because you have a bone to pick, show us an intelligent argument by reasonable person and come to us with hard statistical data you've compiled on engines which power ETOPS approved aircraft and show us what the real probabilities are and how the regulator has compromised safety. Then we all can have a reasonable discussion about this subject.

Because right now your argument has the scientific veracity of that of a flat earther.

Was there an “objective risk assessment” for “safety”? What were the probabilities at which the mitigations for the perceived risks of ETOPS operations turned those operations from objectively “unsafe” to objectively “safe”?

Are the probabilities of a passenger fatality on a transport category ETOPS operation higher or lower than the probabilities of a passenger fatality on a 9 seat piston twin charter? CASA certifies both operations. Are they equally “safe”? If not, on what objective basis can they both be permitted to continue?

Someone proposes to use a single turbine engined aircraft in RPT operations. Because of the perceived risks of that operation, the regulator mandates that the engine be changed every 100 hours, prohibits the aircraft from operating over built up areas and requires a twin engined aircraft to fly in front with red flags. Were those mitigations a cost-effective and necessary response to the objective risks of engine failure?

You’re missing Dick’s point (although I do concede that he sometimes makes them poorly).

Dick, I think you have answered your own question.

Like most things in aviation, the meaning swings on the words and the interpretation thereof.

A dictionary says:

consideration
noun
1.
careful thought, typically over a period of time.

"your case needs very careful investigation and consideration"

synonyms: thought, deliberation, reflection, contemplation, cogitation, rumination, pondering, meditation, musing, mulling, examination, inspection, scrutiny, analysis, review, discussion; More

I dont believe there can be any suggestion that casa dont give things such as edto and other safety critical issues, “careful thought” and in most cases “typically over a period of time” much to the annoyance of people trying to actually achieve anything.

The things is the requirement is not to give safety the ONLY consideration.

If that was the case we would all be walking as aviation inherently carries more risk than wrapping yourself in a cocoon and staying in a locked room.

The trick is to manage risk appropriately and in the case of edto that is done with edto/etops design and certification rules, edto fuel policies, edto dispatch policies, edto pilot training, edto maintenance requirements, edto operational requirements etc etc etc.

Wiggly. I have not suggested that ETOP operations are unsafe.

Just that some experts do not believe they comply with the CASA legislation to have safety as the number one consideration.

Possibly in this case CASA has looked at affordability.

Or most likely harmonised with overseas requirements and ignored the act.

Dick, your whole premise is without basis - i.e. that a quad is safer than an ETOPS operated twin. Now, just so you know, I spent 40 years as a propulsion engineer at Boeing, and I know all about the stuff that went into the original ETOPS approvals (called EROPS back then). Spent several years on the Propulsion Safety Board as well.
The bottom line is this: There has never been an ETOPS twin go down due to dual, unrelated (i.e. not common cause) engine failures. There have been trijets and quads that have crashed due to single engine failures. The greatest engine related risk to multi-engine aircraft is not non-common cause engine thrust loss - it's that there is an engine failure that endangers the aircraft - uncontained engine failures being the biggest one with engine fire being a close second. The greater the number of engines, the greater the risk that an engine will fail catastrophically (google Sioux City DC-10 for a rather dramatic example of how a single engine failure can take down an aircraft, and it took a talented crew and more than a little good luck to get that Qantas A380 safely on the ground after the Trent engine uncontained failure).
In short, there is no data that demonstrates a twin, operated under ETOPS rules, is less safe than a quad or a tri. There is data that demonstrates the opposite. As for your aerospace engineer friend, well the less said the better.

So what is your point? Now you are criticizing CASA for harmonising Australian requirements with that of, one presumes, the best of overseas practise to save Australian operators having to comply with uniquely Australian requirements.:ugh:

Why don't you take your case from the court of pprune and go to the media and tell them that thousands of Australian air travellers have been exposed to an unacceptable risk because CASA has breached their own legislation. Then put a legal team together to take CASA to court for their flagrant breach of the law. Only you have the resources and the interest in doing so.

TD. If during the three plus hours a twin on one engine is exposed when heading for an alternate are you suggesting there is no chance of the remaining engine failing?

Would it not be operating at a higher power level?

Surely there would be a small measurable chance of a second failure?

If that was at night over a rough ocean could that have serious consequences?

Look left. CASA quotes 9a to prevent GA moving to lower costs. Look at ADSB and part 91.

As always Dick you sidestep the question then throw in an irrelevant response.

You are not talking about GA or ADSB in this thread. You are referring to CASA not following 9a WRT ETOPS or EDTO specifically.

You made the following statement: As you are a vocal critic of CASA not following this practise it would seem that you are now accusing them of following the practise of taking the best ideas from overseas and therefore putting the Australian public in danger. :confused:

Take it to Ean Higgins and let him know of this latest attempt by CASA to fail to follow their own legislation.

I support ETOPS. I support CASA supporting ETOPS.

I support CASA when it makes safety decisions that take into account affordability.

I reckon it would be better for the CASA legislation to clearly reflect this position.

Does anyone agree?

Dude, did you even read what I wrote?
The probability of a catastrophic engine related accident does not go down with more than two engines - it goes up. There is a massive statistical data base that backs that up. Sure, an extended single engine diversion might be unpleasant - but it's not inherently unsafe, it's taken into account in the processes and procedures, and it's quite rare.
Statistically, two engines are safer than four. Your claim that CASA isn't following their own regulations by allowing twin ETOPS is not supported by any facts. All your bleating to the contrary simply makes you look silly.


No, and we're still looking for you to provide any evidence to back up your claims (gut feel doesn't count).

You’re new here, then?

I’m honestly struggling to see the point of this thread, except as an exercise in attention-seeking.

Tdracer. Who are you trying to protect?

I will give a simpler example. CASA allows lower certified standard airline aircraft to service small country towns. This is clearly not giving the most important consideration to safety- it is putting affordability in front of costly extra safety features.

CASA is not complying with the act. Do you understand?

That is the reason for the thread. Imagine having to live a lie in your everyday work?

The prime reason that the major aircraft manufacturers have pushed for ETOPS approvals is so they can sell more aircraft , get more people flying and make more money.

It was not to improve safety over four engined aircraft. Not once has anyone claimed that is was to increase safety. If that was so they would say so!

See Dick, you can't keep your own argument on the logic path.:D

You finally admit that you support ETOPS then you launch into this:

Now you're against the manufacturer's and their capitalistic ways. How utterly contemptible for any company to want to increase their profits.

The main reason you started this thread is you wanted everyone in pprune land to acknowledge that you are right and that CASA are not applying their legislation consistently and you were just using ETOPs as an example. Well there's a revelation , CASA have one rule for one lot and a different rule for the rest all embedded in the same rules. There is nothing new in what you have discovered, have you seen the difference between the requirements for aerial work and that for charter?

The biggest mistake people have made on this thread is taking you at face value in suggesting that ETOPs is the issue.:=

https://en.m.wikipedia.org/wiki/Air_Transat_Flight_236

Fortunate passengers to have a glider pilot captain.

I am not against the manufacturers. I support the concept of affordable safety. Always have

CASA should tell the facts about this

Dick, how far do you want to take the "safety must be the most important consideration" thing?

Do you want to mandate that every aircraft must take off with full tanks, and must plan to land with half remaining?
And also wrap every passenger in flame proof bubble wrap and wear a helmet in case of a crash? And with a small scuba setup in case of a ditching?
Because after all, that is surely safer than allowing passengers to wear shorts, singlets and thongs!


I think you are twisting words and interpreting what's written with your own agenda clouding things.

As for the Airbus Glider, it probably would have been good if the pilots didn't pump fuel overboard. That in itself is not an EDTO or two-engine-aircraft-only screwup. If they had 3, 4 or even 12 engines the outcome would have been the same.

Car. You completely misunderstand what I am saying.

My view has always been the opposite to what you are implying.

It is the CASA act that states the myth that safety is the most important consideration.

Why not get the act to reflect what happens in practice. I would support that.

Ok let's use your regional air service point. You reckon CASA are putting cost ahead of safety by allowing "lesser" aircraft to service them. So what do you expect if safety was put first; tiny towns to upgrade runways to take CAT D/E 4 engine aircraft with level 10 RFFS and ATC and CATIII ILSs to each runway?

Wow. This is difficult.

I expect CASA to be open and honest and state that in many cases they do not put safety in front of affordability.

And to be consistent. The unique early ADSB mandate has done extraordinary damage to GA. Too late now to do anything about it.

No other country I know of has the absolute statement “ most importantly consideration should be safety “

The bureaucracy over 20 years ago forced this into legislation. They insisted that the traveling public is so dumb they can’t be told the truth about affordable safety.

Well why don't you collect evidence and challenge them?

He won't, because the evidence that ETOPS twins are less safe than quads doesn't exist.
Again, demonstrably false. To obtain ETOPS approval, Boeing submitted several analysis to the FAA and EASA (JAA in those days) showing ETOPS twins were at least as safe as quads. I have first hand knowledge of this. I presume Airbus did something similar.
You're arguing based on emotion, not facts. The facts say that ETOPS twins are at least as safe as quads.
Bottom line is your gut tells you four engines are safer than two. Facts say otherwise. Emotion once said "if man was meant to fly, he'd have wings" Fortunately enough people listened to the facts that said otherwise. Regulations based on emotions instead of facts usually kill people.
Dick, you just go on and continue arguing that two plus two equal five. Just don't expect the rest of us to play your silly game - I'm tired of arguing with a fool and I'm out of here.

Looks as if Regulators believe that there is a difference in safety because restrictions are put on twin engined aircraft operations that are not put on three or more engines. Wonder why they do that if identical safety levels? Very mysterious

I get what you're saying Dick (many posters here don't seem to), it is about the fact that CASA's official objective doesn't reflect what they actually do.

However, can you imagine the field day the media would have when they got wind that our aviation regulator stated its objective to be something like "to ensure an aviation industry with a fair balance between cost and safety".

Are you able to elaborate on how regulators overseas have worded their objectives in a way that you think would be more suitable?

“There’s no such thing as bad publicity,”
-- P. T. Barnum

SImple; CASA allowed for ETOPS in the rules and the manufacturers and Airlines eventually came up to the standard and have gained approval ..if CASA hadn’t wanted ETOPS then they wouldn’t have had it in the CAOs and Australia would’ve been an outlier in world aviation

If CASA has examined an operation, and considers the same degree of safety can be accomplished by alternative means and one of them happens to be cheaper than the other, what is the issue? By ruling an operation safe, have they not fulfilled their obligation to make that their primary concern?

Dick has tried to make a point using a somewhat obtuse argument. However his point is valid. He knows that EDTO in two engined airliners is safe. Even airlines say their number one priority is safety but we know that this is is board room lip service, they need to squeeze every cent they can out of an operation. If it was their priority then they would go broke. Even with the CASA QUANGO, high costs and the Aussie love of regulation I'm not sure that our tiny market can support a very large aviation sector anymore, even the US appears to be struggling.

Traffic. You state “ by ruling an operation safe”

That is the problem. That is an absolute statement and would be an untruth.

The word “safe” means without risk. There is no such aviation operation. There should be no problem in communicating the truth.

If you communicate the truth it means you can allocate the limited and finite resources to where the greatest improvement to safety can be made. It probably means you would not introduce mandatory ADSB for VFR and let pilots spend the money to fly more and gain more recent experience.

A factual statement could be “ extremely safe”.

What, “extremely without risk”, then?

Dick, you’ve effectively contradicted yourself within a couple of lines. One moment, you’re claiming safety is an absolute, binary concept, and the next, you’re allowing it has different levels.

I’d consider that a rusty old VW Beetle with dodgy suspension and no seat belts is an unsafe car, and a brand new Volvo is a safe car. But neither is completely without risk. Safety can only ever be a relative thing. If your argument hinges on it being an absolute, then I think you’re in trouble, as you’ve just demonstrated with your own self-contradiction.

Safe is an absolute and means without risk. Extremely safe is not an absolute and means what it says. It clearly means there is some risk.

There is no contradiction.

“ the most important consideration is safety” means it is more important than affordability.

CASA only appears to comply with that when those affected are weak.

I see - it’s an absolute, except for when it isn’t. We could probably discuss whether your approach is “moderately unique”, but I suspect that like the rest of this thread, it’d be pointless.

Mattyl. It was my board in about 1990 that introduced the automatic airworthiness acceptance from five leading aviation countries. This was opposed by a number of senior CAA bureaucrats.

Up until then properly FAA certified aircraft such as the Beech 1900 could not fly here.Ask Max Hazelton. Read the relevant chapter in Two Years in the Aviation Hall of Doom.

In those days people such as Mel Dunn resisted the affordable safety fact. CASA appears to be doing that again.

It’s not.

No! If you use the word “safe” by itself it clearly means “ without risk”

If you state “ very safe” or “ extremely safe” it means something that is quite different. Sorry but this is a fact !

AsA is also supposed to give primacy to safety. Why don’t they then re allocate their profit dividend that normally goes to the government to extra safety- say a tower at Ballina?

Hint. Just like CASA they don’t comply with their act. It’s a sham to mislead the public. Polititions have been conned into believing that they cannot tell the public the truth.

It means that safety considerations should be given more weight than others, but does not mean that safety should be the only consideration, nor does it mean that the results of that consideration cannot be mitigated by other influences.

If that was the way CASA interpreted the act they would not allow lesser safety standard FAR 23 certified aircraft to provide scheduled services to country towns.

If they gave “ more weight” to safety considerations than the cost of air tickets they would mandate the safer FAR 25 standard.

Pretty simple really.

In practical terms you have got to ask “if safety is the most important consideration - then - it is clearly more important than cost”

But they only selectively comply with this.

The wording is flawed but is intentionally there to mislead and allow large amounts of money to be mis allocated

OK then, TIEW. Walk me through what matters CASA takes into consideration, and what weights are attributed to to each matter, in deciding the standards that should be set for ‘Community Service Flights’.