Of lunatics and asylums.
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Of lunatics and asylums.
This single item is one of four available and needs some serious thought. It is the most readily told and, for clarity the easiest understood.
The cast : a senior ATO with many hundreds of 'test' hours logged and couple of junior line pilots.
The story so far: One fine day three CIR renewals were satisfactorily completed. That is, to the satisfaction of a very senior, intelligent experienced testing officer.
After the tests were complete, the ATO was asked by the Chief Pilot to 'jot' down some pointers on where the company training dollar may be best spent. This was duly done, all knocked off and went home.
Not long after, the safety watchdog turns up and audits the files. Guess what, the ATO is now up to his ass in alligators because he should (in the watchdogs humble opinion) have failed them, based on the simple notes made.
It is tragic, the cost of defending a good name outweighs the revenue generated from doing tests and the ATO is seriously considering retirement.
How can people not properly qualified to judge, who did not witness the flights in question jeopardize a career, deprive the industry of a worthy check training pilot and then still swagger about the place, crowing about a job well done, based on some quietly made observations of how 'young spotty' could improve. Beats me. Fair dinkum, it does..
This must qualify as gross bollix. Too much lobotomy and testosterone combined with total power.
The cast : a senior ATO with many hundreds of 'test' hours logged and couple of junior line pilots.
The story so far: One fine day three CIR renewals were satisfactorily completed. That is, to the satisfaction of a very senior, intelligent experienced testing officer.
After the tests were complete, the ATO was asked by the Chief Pilot to 'jot' down some pointers on where the company training dollar may be best spent. This was duly done, all knocked off and went home.
Not long after, the safety watchdog turns up and audits the files. Guess what, the ATO is now up to his ass in alligators because he should (in the watchdogs humble opinion) have failed them, based on the simple notes made.
It is tragic, the cost of defending a good name outweighs the revenue generated from doing tests and the ATO is seriously considering retirement.
How can people not properly qualified to judge, who did not witness the flights in question jeopardize a career, deprive the industry of a worthy check training pilot and then still swagger about the place, crowing about a job well done, based on some quietly made observations of how 'young spotty' could improve. Beats me. Fair dinkum, it does..
This must qualify as gross bollix. Too much lobotomy and testosterone combined with total power.
Last edited by Rose_Thorns; 8th Aug 2010 at 09:42. Reason: the usual!!.
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I am torn between "what did you expect" and "sounds about right".
I had similar experiences here in NZ. The CAA here is stuffed full of people who either couldn't get in to Air NZ or are ex-RNZAF squadron buddies. They are mostly useless. Some of them, refugees from Ansett NZ who couldn't get a flying gig, hang onto the past with a grip of steel and refuse to move on. The only worthwhile people are the ones they import from overseas, very few of whom last more than a couple of years before terminal frustration, and the dawning knowledge that nobody is listening to them, cause them to resign in disgust.
So when they are presented with a very experienced airline check and training guy, medium jet and turboprop qualified and over 10K hours of airline flying in the book, who wants to give something back to GA, but who doesn't have current NZ ratings, they make it as difficult as they possibly can for this guy to get himself going, while at the same time bemoaning the lack of experienced trainers in NZ.
The guy works out that, with the cost of the stuff they want him to do to prove he can fly and instruct, he would have to work part-time for ten years just to break even. Guess what he does...
If it wasn't so sad, it would be funny...
I had similar experiences here in NZ. The CAA here is stuffed full of people who either couldn't get in to Air NZ or are ex-RNZAF squadron buddies. They are mostly useless. Some of them, refugees from Ansett NZ who couldn't get a flying gig, hang onto the past with a grip of steel and refuse to move on. The only worthwhile people are the ones they import from overseas, very few of whom last more than a couple of years before terminal frustration, and the dawning knowledge that nobody is listening to them, cause them to resign in disgust.
So when they are presented with a very experienced airline check and training guy, medium jet and turboprop qualified and over 10K hours of airline flying in the book, who wants to give something back to GA, but who doesn't have current NZ ratings, they make it as difficult as they possibly can for this guy to get himself going, while at the same time bemoaning the lack of experienced trainers in NZ.
The guy works out that, with the cost of the stuff they want him to do to prove he can fly and instruct, he would have to work part-time for ten years just to break even. Guess what he does...
If it wasn't so sad, it would be funny...
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I'm disappointed, I thought this post was going to be about a guy who runs a light aircraft forum that had been finally admitted to an asylum. Oh well.
Back to topic sorry.
Back to topic sorry.
All I can say, since I have no bad experience of CASA, is that if any of the allegations made around here are true, then a cultural audit of CASA and it's customers is going to be depressing reading.
I know of one such audit in the telecommunications industry where the findings were so bad the report had to be suppressed.
I know of one such audit in the telecommunications industry where the findings were so bad the report had to be suppressed.
Rose Thorns...
I'd fight this one bloody hard.
What it seems to demonstrate is that the original regulatory authority certification audit of organisation AND (if any) subsequent audits were less than satisfactory if now, because of some notes on file about how to improve the situation, that is construed by the regulatory authority to signify non-compliance.
I'd also be asking the regulatory authority for evidence to demonstrate that the original certification personnel and those subsequently used for renewal audits were appropriately qualified to assess the original application and renewals.
Sunfish, unfortunately there are presently other allegations of 'problems' concerning CASA and AOCs, and some of those 'problems' have already reached the Courts I believe. If what I read about one of the matters is true, then I think don't CASA will emerge 'unscathed'.............reputation-wise OR cost-wise.
The matter that Rose Thorns raises just seems to highlight the depressingly familiar experience here in Australia that continues to demonstrate that we have a totally dysfunctional regulatory authority which doesn't and can't function correctly in its present form, that represents a huge waste of taxpayers'funds with no practical results, and that needs to be replaced (Minister too............hopefully that will be quite quickly) with something that actually works.
Adopting the NZ CAR Parts for regs. would be a bloody good start, instead of persisting with the never-ending idiocy of regulatory reform that's now been going on for years here.
Not long after, the safety watchdog turns up and audits the files. Guess what, the ATO is now up to his ass in alligators because he should (in the watchdogs humble opinion) have failed them, based on the simple notes made.
What it seems to demonstrate is that the original regulatory authority certification audit of organisation AND (if any) subsequent audits were less than satisfactory if now, because of some notes on file about how to improve the situation, that is construed by the regulatory authority to signify non-compliance.
I'd also be asking the regulatory authority for evidence to demonstrate that the original certification personnel and those subsequently used for renewal audits were appropriately qualified to assess the original application and renewals.
Sunfish, unfortunately there are presently other allegations of 'problems' concerning CASA and AOCs, and some of those 'problems' have already reached the Courts I believe. If what I read about one of the matters is true, then I think don't CASA will emerge 'unscathed'.............reputation-wise OR cost-wise.
The matter that Rose Thorns raises just seems to highlight the depressingly familiar experience here in Australia that continues to demonstrate that we have a totally dysfunctional regulatory authority which doesn't and can't function correctly in its present form, that represents a huge waste of taxpayers'funds with no practical results, and that needs to be replaced (Minister too............hopefully that will be quite quickly) with something that actually works.
Adopting the NZ CAR Parts for regs. would be a bloody good start, instead of persisting with the never-ending idiocy of regulatory reform that's now been going on for years here.
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....the never-ending idiocy of regulatory reform that's now been going on for years here.
And there are people (on another Thread) arguing that the current audit of CASA's Safety Management System will not find anything untoward that has impacted on pilots or operators 
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Could it be that they do not want to change anything, and the reform will never happen?
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Just gets worse.
The latest tall tale solves the mystery of how to get things done (Abridged version). Seems legal clout is not effective, letters from respected legal companies are treated with contempt, but when a Poly calls; ah! well now that of course is different.
Way I heard it, the mob concerned bought a lovely new shiny little biz jet to meet client demands. All the toys, loads of power, safety plus and brand spankers.
"That's a jet", spoke the oracle (quick ain't they) "now we all know that there is a lot of difference between a jet and a proper aircraft". "We all know that there has been a policy in place for years and years which prevents operators of machinery under 5700 Kg from having an internal check and training organisation". "But, because it's a jet, you must have one, immediately "or we'll shut you down".
Anyway, long story short, despite the increased cost and the impost of having to write a manual, they did it, just inside the deadline. (Phew!!).
"Too bloody late mate", they said chuckling with glee and grounded the poor buggers there and then.
Next day. Up rocks the Poly, wanting to go on the charter as booked.
"Can't do her in the jet mate, that's been grounded". The story is told and the poly is offered a 25 y.o. piston placebo.
"Not bloody likely" says the man ands gets on the blower. Half an hour later they are airborne in the new toy, restrictions lifted.
Not true, better believe it. Only way to go - Poly power.
Way I heard it, the mob concerned bought a lovely new shiny little biz jet to meet client demands. All the toys, loads of power, safety plus and brand spankers.
"That's a jet", spoke the oracle (quick ain't they) "now we all know that there is a lot of difference between a jet and a proper aircraft". "We all know that there has been a policy in place for years and years which prevents operators of machinery under 5700 Kg from having an internal check and training organisation". "But, because it's a jet, you must have one, immediately "or we'll shut you down".
Anyway, long story short, despite the increased cost and the impost of having to write a manual, they did it, just inside the deadline. (Phew!!).
"Too bloody late mate", they said chuckling with glee and grounded the poor buggers there and then.
Next day. Up rocks the Poly, wanting to go on the charter as booked.
"Can't do her in the jet mate, that's been grounded". The story is told and the poly is offered a 25 y.o. piston placebo.
"Not bloody likely" says the man ands gets on the blower. Half an hour later they are airborne in the new toy, restrictions lifted.
Not true, better believe it. Only way to go - Poly power.
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And there are people (on another Thread) arguing that the current audit of CASA's Safety Management System will not find anything untoward that has impacted on pilots or operators 
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Adopting the NZ CAR Parts for regs. would be a bloody good start
All thanks to the highly questionable Swedavia report from the '80s.
Don't go there.
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An ATO delegation is just that, a delegation. CASA cannot dispute a test result from an ATO...unless it is an observed test. However CASA can "sit in" on the next few tests and reprimand or even cancel the delegation should the ATO show gross deficiencies. I don't think this happens that often.....please correct me if i am wrong. One thing that i could never quite grasp is how an FOI who has never done any flight training or does not hold an Instructor rating can test an applicant for either Initial issue or renewal or back seat a test, to test the tester.
i reckon once the hoo haa stops and the dust settles this particular ATO will continue on life as normal. He'll get over it.
I remember a FOI going crook at me for failing an engine below 500' saying that was extremely unfair to the applicant. i replied in a very much heated debate that i was the testing officer and suggested that engines do fail below 500'. Much cursing and swearing from both parties to eventuate in a truce....to let me do what i do best.....test!
i reckon once the hoo haa stops and the dust settles this particular ATO will continue on life as normal. He'll get over it.
I remember a FOI going crook at me for failing an engine below 500' saying that was extremely unfair to the applicant. i replied in a very much heated debate that i was the testing officer and suggested that engines do fail below 500'. Much cursing and swearing from both parties to eventuate in a truce....to let me do what i do best.....test!
remoak said:
Fair enough.........my suggestion was only based on the fact that NZ CAR Parts looks as though it will become the de facto Oceania regulatory standard via PASO. That's why I suggested following it.
NZ CAR Parts have been adopted in other areas of our region, and whether you like it or believe it or not remoak, they are actually working quite well in spite of (or despite of??) their respective controlling regulatory authorities!
Sure, I agree the NZ CAR Parts aren't perfect...............but neither are the Australian CASA CARs just right now, and nor have they been for the past 22 years by any stretch of the imagination while CASA's been fcuking around with them, under the guise of regulatory reform.
Sorry to say, but most of the management of CASA wouldn't know what regulatory reform was if they fell over it, and the NZ CAR Parts presently beat the present CASA system hands down.
remoak, I've worked in a lot of different locations, in a lot of different areas in high-capacity transport-category operations, and I've yet to see a perfect set of regulatory requirements. When I worked in the Middle East in the 90's, the dump that I was working in on a regulatory reform assignment was basically unregulated until the locals decided to adopt JAR-OPS at our suggestion...........things went OK after that.........sort of!
I'm happy to suggest as an alternative EU-OPS if you're game to go there. They're far superior in terms of regulatory requirements for an ICAO Annex 6 Part I operator than the NZ CAR Parts, but 'they're also probably also far too sensible AND/OR advanced for them to be readily understood by CASA management I'm afraid. Also, they would represent a big 'cultural' shift for most operators, and they'd still leave Part 125 and 135 operators out in the cold.
FARs..............no, don't go there.
So where else remoak? Or do we wait for another 22 years in the hope that CASA's re-reinvention of the regulatory reform wheel will be completed by that stage? It won't!
Don't go there [the NZ CAR Parts way].
NZ CAR Parts have been adopted in other areas of our region, and whether you like it or believe it or not remoak, they are actually working quite well in spite of (or despite of??) their respective controlling regulatory authorities!
Sure, I agree the NZ CAR Parts aren't perfect...............but neither are the Australian CASA CARs just right now, and nor have they been for the past 22 years by any stretch of the imagination while CASA's been fcuking around with them, under the guise of regulatory reform.
Sorry to say, but most of the management of CASA wouldn't know what regulatory reform was if they fell over it, and the NZ CAR Parts presently beat the present CASA system hands down.
remoak, I've worked in a lot of different locations, in a lot of different areas in high-capacity transport-category operations, and I've yet to see a perfect set of regulatory requirements. When I worked in the Middle East in the 90's, the dump that I was working in on a regulatory reform assignment was basically unregulated until the locals decided to adopt JAR-OPS at our suggestion...........things went OK after that.........sort of!
I'm happy to suggest as an alternative EU-OPS if you're game to go there. They're far superior in terms of regulatory requirements for an ICAO Annex 6 Part I operator than the NZ CAR Parts, but 'they're also probably also far too sensible AND/OR advanced for them to be readily understood by CASA management I'm afraid. Also, they would represent a big 'cultural' shift for most operators, and they'd still leave Part 125 and 135 operators out in the cold.
FARs..............no, don't go there.
So where else remoak? Or do we wait for another 22 years in the hope that CASA's re-reinvention of the regulatory reform wheel will be completed by that stage? It won't!
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The NZ system is just a thinly disguised American system, doesn't suit the environment at all, and replaced a system that wasn't broken in the first place. It was a mind-numbingly expensive process, paid for by the industry, that has little tangible benefit and ends up costing the end user even more.
.......my suggestion was only based on the fact that NZ CAR Parts looks as though it will become the de-facto Oceania regulatory standard via PASO. That's why I suggested following it.
As tailwheel says, we, the Australian taxpayer, paid to put the NZ rules in place in PNG ( the BALUS program) because the Australian rules used previously were considered no longer usable.
To PASO, Fiji and PNG you can add a number of the CIS (ex-USSR) states, and it looks like some of the ex-British possessions in the Caribbean will do the same thing.
The Republic of China has also modeled their new rules on US,(already in use in Taipei) and that was the Australian decision of the then Minister for Transport, John Sharp, unanimously supported by all sections of the Australian aviation community/industry in 1996, when the CASA Review was put in place.
Have a look at CASR Parts 21 to 35, and then tell us all why they don't work, and why they haven't worked since they went in place in 1998, and how and why we would all be better off with the pre-1998 Australian unique certification standards.
Once again, it looks like a few of you believe Australia is the only soldier in the battalion in step.
Tootle pip!!
PS:
Sadly, it is the EASA rules that are also going in the right direction ( not just JAA re-heated) being outcome based ----- absolute anathema in Canberra, where absolutely prescriptive criminal law for aviation is the chosen direction ---- as it suits the CASA culture.
If you want to see how Australia can screw up EASA rules, you don't have long to wait, the (originally) EASA based maintenance rules will hit the table some time quite soon.
JAR/OPS 1 rewritten by CASA would be a nightmare to end all nightmares.
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SIUYA
Two things: the CAR (rules) are just the old rules re-packaged, which were originally more or less word-for-word re-writes of the British regs from the '60s. The "parts" are just a direct lift from the US system, which only work logically in the US regulatory context. The two don't sit that well together and there are still holes.
The other problem is that a lot of the NZ rules these days are unnecessarily anal and have no place in a modern system (for example, the new procedure whereby you have to read back the runway that you are cleared to takeoff from or land on - just in case you accidentally taxi to the other end and take off on the wrong vector...)
EASA. Plain and simple.
NZ CAR Parts have been adopted in other areas of our region, and whether you like it or believe it or not remoak, they are actually working quite well in spite of (or despite of??) their respective controlling regulatory authorities!
The other problem is that a lot of the NZ rules these days are unnecessarily anal and have no place in a modern system (for example, the new procedure whereby you have to read back the runway that you are cleared to takeoff from or land on - just in case you accidentally taxi to the other end and take off on the wrong vector...
)
So where else remoak?
remoak,
Do you actually understand how little of a total regulatory suit JAA/EASA actually had/has, and how much remains to be done.
If you try and apply FAR/EASA(JAA) 145 to GA maintenance, it is un-affordable overkill, there is no continuing airworthiness set for small aircraft. Maintaining an A380 and a PA-28 are not quite the same thing.
The graduated standards called up by FAR 43 and the FAR 121/125/135 Ops. Spec works well.
There isn't ( or wasn't last time I looked) any EASA(JAA)/OPS 2 , only I and 3.
If you want a system that cannot easily be integrated into the present Australian legal system, the European system is it.
The new EASA approach, which I actually support in principle --- if not the contents, as outcome based legislation ( and is Australian Government policy, but you would never guess from looking at the latest ultra prescriptive aviation regulations) versus the traditional (JAA) ultra-prescriptive regulation.
With the commonality of the US and Australian legislative system, legal system, and system of government, there is no problem about using the FAA/NZ/PRC/CA ( although CA looks a bit different) etc. system of regulation ---- as NZ has proved.
If you understood, in depth, Commonwealth legislative history, from 1901 to the present, you would know that quite significant Australian legislation has been adopted "by reference" to US legislation. Our very first Trade Practices Legislation was the US Sherman Act, adopted by reference. That, in itself, is an interesting piece of history.
Some minor whinge about readbacks in NZ is hardly a reason to condemn the whole package ---- and have you checked the latest amendments to ICAO Annex X, Vol 2, or PANS/RAC 4444, to make certain it isn't a SARP??
Have you ever bothered to see how expensive the EASA pilot licensing requirements are, with ( but not only) the medical overkill, now about to require, amongst other totally unjustified impositions, an annual color vision test of a type that will knock out an estimated 10-20% of present pilots. Many of whom will have been operating satisfactorily for years, and have successfully passed previous color vision test.
I can only conclude that you have a very limited understanding of the various systems. Your understanding of the origins of our present regulations is obviously equally limited ---- which are, and have always been, far removed from the old Colonial Air Navigation Order 1945 (??), to which I think you refer. We have had our own Air Navigation Act 1920 since ---- wait for it ---- 1920, most of the ANRs were translated into CARs in 1988.
Being really good at growing regulations, Australia has the dubious distinction of having an Air Navigation Act and Regulations almost 7 years before the US managed an equivalent. We are great at growing rules, not nearly as good at growing an industry.
You are quite correct about the design/certification/manufacturing standards ---- what would you suggest we do, go back to Australia's previous setup, that severely disadvantaged Australian airlines, versus the international competition. A setup that markedly increase the cost of all aircraft into Australia, aircraft that had to be modified to meet Australia's unique and unjustified impositions.
Tootle pip!!
Do you actually understand how little of a total regulatory suit JAA/EASA actually had/has, and how much remains to be done.
If you try and apply FAR/EASA(JAA) 145 to GA maintenance, it is un-affordable overkill, there is no continuing airworthiness set for small aircraft. Maintaining an A380 and a PA-28 are not quite the same thing.
The graduated standards called up by FAR 43 and the FAR 121/125/135 Ops. Spec works well.
There isn't ( or wasn't last time I looked) any EASA(JAA)/OPS 2 , only I and 3.
If you want a system that cannot easily be integrated into the present Australian legal system, the European system is it.
The new EASA approach, which I actually support in principle --- if not the contents, as outcome based legislation ( and is Australian Government policy, but you would never guess from looking at the latest ultra prescriptive aviation regulations) versus the traditional (JAA) ultra-prescriptive regulation.
With the commonality of the US and Australian legislative system, legal system, and system of government, there is no problem about using the FAA/NZ/PRC/CA ( although CA looks a bit different) etc. system of regulation ---- as NZ has proved.
If you understood, in depth, Commonwealth legislative history, from 1901 to the present, you would know that quite significant Australian legislation has been adopted "by reference" to US legislation. Our very first Trade Practices Legislation was the US Sherman Act, adopted by reference. That, in itself, is an interesting piece of history.
Some minor whinge about readbacks in NZ is hardly a reason to condemn the whole package ---- and have you checked the latest amendments to ICAO Annex X, Vol 2, or PANS/RAC 4444, to make certain it isn't a SARP??
Have you ever bothered to see how expensive the EASA pilot licensing requirements are, with ( but not only) the medical overkill, now about to require, amongst other totally unjustified impositions, an annual color vision test of a type that will knock out an estimated 10-20% of present pilots. Many of whom will have been operating satisfactorily for years, and have successfully passed previous color vision test.
I can only conclude that you have a very limited understanding of the various systems. Your understanding of the origins of our present regulations is obviously equally limited ---- which are, and have always been, far removed from the old Colonial Air Navigation Order 1945 (??), to which I think you refer. We have had our own Air Navigation Act 1920 since ---- wait for it ---- 1920, most of the ANRs were translated into CARs in 1988.
Being really good at growing regulations, Australia has the dubious distinction of having an Air Navigation Act and Regulations almost 7 years before the US managed an equivalent. We are great at growing rules, not nearly as good at growing an industry.
You are quite correct about the design/certification/manufacturing standards ---- what would you suggest we do, go back to Australia's previous setup, that severely disadvantaged Australian airlines, versus the international competition. A setup that markedly increase the cost of all aircraft into Australia, aircraft that had to be modified to meet Australia's unique and unjustified impositions.
Tootle pip!!
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Fair call – Regulatory reform.
It is not so much that the regs are naff. That's a given. The endemic, systematic internal corruption of a crippled system is the bit that I resent.
The thing that gets my panties in a bunch is the way that the lunatics can choose, almost on a whim how their personal, subjective interpretation can be used. There has of late been some evidence of fairly blatant 'manipulation' of the rules to suit the asylum purpose. Remember, these are criminal charges.
A simple matter, such as a stuff up on an MR can be waived and forgiven, or escalated into a show cause as it pleases.
This is the part that's wrong.
We need some form of framework, I agree,. But there must be checks and balances in place to provide a level playing field.
That, or we get a minister with balls, a department with more brains than an part educated dunny seat and a director with an attention span better than that of a well trained racing rabbit.
"Anything you say may be used against you, as it pleases me". Don't quite fit the democratic model or the criminal code does it kids.
.
The thing that gets my panties in a bunch is the way that the lunatics can choose, almost on a whim how their personal, subjective interpretation can be used. There has of late been some evidence of fairly blatant 'manipulation' of the rules to suit the asylum purpose. Remember, these are criminal charges.
A simple matter, such as a stuff up on an MR can be waived and forgiven, or escalated into a show cause as it pleases.
This is the part that's wrong.
We need some form of framework, I agree,. But there must be checks and balances in place to provide a level playing field.
That, or we get a minister with balls, a department with more brains than an part educated dunny seat and a director with an attention span better than that of a well trained racing rabbit.
"Anything you say may be used against you, as it pleases me". Don't quite fit the democratic model or the criminal code does it kids.
.
don't think CASA will emerge 'unscathed'.............reputation-wise OR cost-wise
merely because no one else understands the rules
Bwahhahhhaaaahaaaaawww!!!!!! REPUTATION?!! CASA??!! UNDERSTAND THE RULES?!!
ROTFPMFL!!! Until I realise how serious it actually is, AND WE PAY FOR IT
i reckon once the hoo haa stops and the dust settles this particular ATO will continue on life as normal. He'll get over it
If they were all knowledgable, constructive individuals it nearly wouldn't be a problem - but as can be seen by the plethora of anecdotes such as Rose_Thorns has offered here, and numerous other threads attest, more often you encounter small minded, ego wielding, "point to prove", "chip on shoulder", industry reject types, who can do - and do do - irrepairable damage to lives and businesses. At our expense. And if they are in fact identified as such, and as behaving inappropriately, it's hushed up and they are never brought to account.
The regulation re-write? This alone shows what a farcial situation we operate under every day.
There is another thread, discussing the finer detail of operations into Norfolk Island, and whether the category of flight dictates whether "island reserve" is required. Now apparently CASA are "moving to close the loophole..."
I could comment there - but it's more appropriate here. I'd like to ask who wrote that CAO 82 ammendment (in the late 90s or early 00s, IIRC, in response to an incident/accident) and allowed the "loophole" to exist in the firstplace (if in fact it does)?CR