Fort Fumble and the Money Spend Continues

[advo-cate]

At Page 11 of AC 21-36(1) JANUARY 2013
GLOBAL NAVIGATION SATELLITE SYSTEM (GNSS) EQUIPMENT: AIRWORTHINESS GUIDELINES

11. DESIGN, DEVELOPMENT AND APPROVAL OF MODIFICATIONS
11.1.1 FAA AC 20-138C is endorsed by CASA as appropriate guidance material for the design, development and approval of modifications intended for Australian registered aircraft involving the installation of GNSS equipment. Copies of this AC may be obtained from the FAA website at RGL Home.

11.1.2 References to the FAA procedures, documentation and regulatory requirements contained in FAA AC 20-138C are not applicable to Australian registered aircraft. All modifications to Australian registered aircraft must comply with Australian regulations

11.1.3 Related CASA guidance material AC 21-38 – Aircraft Electrical Load Analysis and Power Source Capacity and AC 21-99 – Aircraft Wiring and Bonding provide additional guidance material for consideration during design and installation.

The full document is at:

http://casa.gov.au/wcmswr/_assets/ma...021/021c36.pdf

I giveth in one hand and take away with the other

OR:

Well Mr. FAA we just think you are the best.

My thoughts on this are that when the only references for Australia are those done by casa, with no luminary Australian University "stuff", what is casa really doing??

[thorn bird]

Mate,
haven't you heard, CASA only regulate
not too many there who would know what a GNSS
was, so they let the FAA take the lead then produce
regulations that make it impossible to follow that
lead

[Jabawocky]

There is an increasing amount of totally absurd stuff coming from CASA at the moment.

I may not have been around as long as some, but I think it is safe to say that the levels of incompetent garbage being pumped out are at all time record highs.

I am truly appalled. I think the words of Jim Richards (1992), subsitute "race fans" with "CASA" are quite appropriate.

[Fission]

Indeed, they're churning out buckets of 'stuff' but when you ask for a service, pay up front but don't expect anything on a reasonable timescale (ie MONTHS for something simple)

Where do I tick the 'Vote of NO CONFIDENCE' box ?

[Flying Binghi]

...the levels of incompetent garbage being pumped out are at all time record highs...

...Indeed, they're churning out buckets of 'stuff'...

Never fear, they got it covered...


...CASA subscribes to the Governments energy efficiency policy and has in place a number of environmental initiatives such as using energy efficient light fittings, timed lighting and recycling of waste...

Civil Aviation Safety Authority - CASA's Environmental Management System


...



.

[Lodown]

I had a couple of paragraphs written, but then...:ugh :

[Creampuff]

This comedy gold popped up on the CASA website, recently:

It has been long-standing CASA policy that if a navigation instrument or item of equipment is required by regulation to be fitted to or carried in Australian aircraft then that instrument or equipment must be approved by CASA. …

Who cares what your policy is. Either it’s a legal requirement or it’s not.

This means that the instruments or equipment listed in CAO 20.18 must be approved by one of the processes specified in Civil Aviation Safety Regulation 1998 (CASR) 21.305.

Are you sure about that CASA? What about the watch someone wears to comply with the accurate timepiece requirement in 20.18? Are you sure 20.18 doesn’t itself contain approvals under 207(2)? After all, that can be done by CAO: CAR 5.

Approval is normally gained by means of a PMA/APMA or a TSO/ATSO. Other forms of approval include STC or approval as part of an aircraft type approval process.

“Normally”? Other forms “include”? Are you sure that’s all?

In each case, the manufacturer is required to demonstrate that the instrument or equipment meets the performance and accuracy standards that have been determined by a NAA, and will continue to do so under all expected operational conditions while being maintained in accordance with approved data.

Really? So all pilots who use their watch to satisfy the accurate timepiece requirement in 20.18 need to have his/her watch go through the PMA/APMA or TSO/ATSO process? Are you sure about that?

The regulation under which this policy has been applied since 1988 is Subregulation 207(2) of CAR 1988.

There is no ‘policy’ to be ‘applied’ under CAR 207(2). You issue valid directions or grant valid approvals, and otherwise STFU.

The absence of a clear statement to the effect that subregulation 207(2) of CAR means that all mandatory flight and navigation instruments and equipment must be approved by CASA , has resulted in a number of amateur-built experimental aircraft being issued with approvals to fly under IFR using non-approved instruments.

No, CAR 207(2) means what it says. It doesn’t need anyone to make a ‘clear statement’ about it. And any ‘clear statement’ about what someone earnestly hopes it means is very interesting but largely irrelevant to the question as to what directions and approvals have validly been issued and given under the regulation.

…

In the interim, it is necessary to clarify and regularise the policy.

A masterpiece in weasel-words!

And while you’re ‘regularising’ your ‘policy’, you might want to look at the constraint in 207(4) and work out how you’re going to show that the present arrangements have produced any material risk to the safety of air navigation.

[Jack Ranga]

That really is a piece of work. These morons are stooping to a new beaurecratic low. Was talking to a mate about this and the discussion went along the 'imagine if the FAA pulled a stunt like this in the States' line. Politicians would be lined up against a wall until it was removed.

This organisation must be full of psychopaths? What is going on in there? Who do these people think they are? Standby for the lawsuits, more taxpayer dollars thrown at defending the indefensible

[Jabawocky]

GO CREAMIE!!!!!!!

[Cactusjack]

Fiscal supremacy?

Environmental policy, how delightful indeed!
My source tells me that in the Brisbane office they put up Danger signs on the lawns during summer warning about snakes, and in the basement they have a worm farm!
Seems like a robust and proactive regulator who is passionate about all things environmental and desires to 'do the right thing'?
Maybe they will sound proof the Skulls office on behalf of the environmental noise impact reduction program?
Will they enhance the eco system in Brisbane by placing Inspectors outdoors on the lawn so as to cut down further on electricity waste and reduce the carbon jackboot footprint?
Will Mr Skull be banned from smoking stoogies between the basement and staff car park to reduce ozone destroying emissions?
What about the shower nozzles in the showering facilities on each level of the building? Do they have water limiting devices installed?
And the fleet cars, do they all run on gas? Are they detailed and washed with plain water containing nil detergents that could harm the precious environmental precinct in Brisbane?
And Mr Skulls Friday Hawaiin shirts?? Designed to attract native birds to the buildings gardens so they will contribute to the environmental policies outlined in Sith Albanese's green policy?
And the dishwashers, fridges, microwaves and jacuzzis in the building? Are they all 5 star energy rated?
What about the large TV screens dotted around the BNE building and lunch rooms? All flat screen units that optimise minimal power output for the Inspectors as they tune into The Benny Hinn Hour, Hogans Heroes, Judge Judy and re-runs of Miami Vice?

So you see, all those knockers and ockers of the Regulator wouldn't be aware of such robust measures, and that they really do care.

[Jabawocky]

They have made a change to the web page already,not fixed it by saying ooops sorry we farked up, but changed the "slight error" with respect to which part of Part 91 was posted.

And I had an unsolicited phone call today from someone with very interesting stories to tell.

Casa will be forking out millions for a long time fallout of several of them.

What a mess.

[Kharon]

Yeah, but the Methane.

I'm just amazed the place hasn't gone up in a bright green /blue flash methane explosion. The extraction system must be first class: worms in the basement, overnight snakes, possums at rafter level, place full of squirrels eating nuts all day, pigs in troughs and cash cows everywhere.

One spark from cheap stoggie after a round of the flaming conga line dance could do the trick.

PS> We are having a whip round to buy our leader a box of fat cigars for a 'surprise' present, anyone want to contribute.

[thorn bird]

Jaba,
don't tell me they are at each others throats?? what's the argument?
division of the bonus pool maybe?
I have no idea what CASA's motives are but one thing for
sure there is no way the industry can survive this onslaught
of pony poo.
What happens to all the incompetents when there is no industry
left. Do they just go on churning out regulations that there is nobody
left to comply with.
People, its long past time for a united front.
Until the industry bands together, and as Creamie advises, learns how to lobby aviation in Australia will continue its slide into irrelevance.

[Jabawocky]

Until you get AOPA, AWAL,AAAA,SAAA,AMROBA,RAA,HGFA,GFA, and all the ones I have forgotten in one room with a clear decisive mandate to work together it will not happen.

In the USA the FAA play silly games too, and some dodgey stuff goes on, but they really do have a very healthy respect for the EAA and AOPA.

Unfortunately the Associate Director, not so much the Head Honcho, prefers the adverserial approach to everything yet will not put his name to anything much for it might bite him on the arse.

So Thorn Bird.....how do we fix all that? I am at a loss.

[aroa]

Oz little...

K.. I'll contribute a cigar to the cause. The exploding one.

Re EAA and US AOPA. MANY, many more folk make up those two organisations than all of little OZ.

AND..they do have a very fervent belief in the US of A in individual rights and freedoms. And a Bill of Rights.
They just don't put up with any sub-standard output from the regulator there..AOPA will field a team of lawyers etc to go to Washington for a "chat".

Here you wouldn't even get through the bloody door and past "Security".

That CASA is a supreme pisser up against the wall function for taxpayers dollars here's some examples....

1. Need a clean sheet statement, written in CB, signed..?? Registered mail to FNQ... $5 CASA personage to visit / holiday in FNQ to get statement signed....$ 5000.?

2. Need to ask a question of an FNQ person why a court case went tits up?
Does email exist??. Que??
My sympathies dont lie with the Furzer Ave cave -dwellers tho August is a very cold month in CB, so two? people fly to TVL (warm) to ask ONE question of the case cocker-upper. Wot went wrong Peter? (Larard)
Oh, I didnt read my (totally bullsh*t) statement properly and I just used the generic term "elevators" by mistake.!! TVL holiday.. $10K..?? FFS !!

Total cost to the taxpayer of this failed CASA case has been whinged at $350 K
Small bikkies!
3.Total cost of the JQ debacle ...Millions and counting.!! More to come.
4. Recent CNS "investigation" cock up, Haslam et al, How many $s K?
Why should we know.

I suppose we have to be thankful these "people" are not in charge of the IMF. They could drive the world crazy .. and broke.

SOMETHING MUST BE DONE TO TERMINATE THIS DEBACLE.

[Frank Arouet]

Until you get AOPA, AWAL,AAAA,SAAA,AMROBA,RAA,HGFA,GFA, and all the ones I have forgotten in one room with a clear decisive mandate to work together it will not happen

Thanks for that nightmare.

I can see already the mass debate of alpha males/ females and the bloody carnage and will find it difficult to get out of my mind after prayers tonight.

Now I lay me down to sleep....................................................... ....

[Sunfish]

You need to get the various associations togehter not to rewrtie the rules, but to rewrite the regulators charter with an agenda to break it up.

THere needs to be a disconnection of "rule writing" and "enforcing". There needs to be a physical disconnect and an intelllectual or logical as well as statutory disconnect.

The reason for that is because of the powers CASA awards itself (I know its Parliament officially, but lets get real here). Those powers involve both criminal and economic sanctions and very wide latitude in their application. There is no administrative check on the exercise of these powers as there are in other departments and there needs to be one.

The splitting of CASA would thus require the rules to be much clearer, since otherwise the enforcers can't enforce. The associations can then fight with CASAs successor tooth and claw over rules - at least they have a clear target separate from the enforcers. And the rule makers have to write their rules with an eye on the cost and efficiency of enforcing them.

This is not rocket science, its public administration 101 - read your Weber.

Shirley the associations know this?

[Creampuff]

THere needs to be a disconnection of "rule writing" and "enforcing". There needs to be a physical disconnect and an intelllectual or logical as well as statutory disconnect.

Correct.

Apart from anything else, CASA does not have the corporate competence to write rules. That’s one of the reasons – not the only reason – for Australia now having 1,541 pages of (uncompleted) civil aviation regulations, laughingly proffered as the output of a process of ‘simplification’ of 155 pages of regulations.

While it is true that if you give a thousand monkeys a thousand typewriters they’ll eventually produce a literary masterpiece like ‘War And Peace’, you have to wait a loooooong time. Further, in CASA there’s a bunch of monkeys with a bunch of personally held policies that they want to ‘regularise’.

One of the other key reasons has been noted by blackhand in another thread: CASA has been trying to listen to and reconcile the irreconcilable preferences of every interest group.

The policy of the rules should be decided by the portfolio agency with responsibility for the legislation CASA administers. That’s the Transport Department. That Department should take responsibility for managing the legislative process to ensure rules are made to give effect to the policy of the government. CASA should then regulate by reference to the rules it is given, using the tools it is given, by government, rather than CASA being itself the driver of policy and the rulemaking process.

However, that Department clearly had enough smarts to suck CASA into to doing it, as well as to fool most of the industry into shifting the blame to CASA.

Evidently successive Ministers aren’t responsible for anything.

[601]

A slight thread drift - but along the same lines.

Quote:

The project will amend CAO 29.6 to bring it in line with the policy for helicopter external load operations outlined in the drafting instructions for CASR Part 138.

How can CASA amend a CAO to reflect a draft CASR?

How can you have policy as a basis for a CAO?

I was under the obviously misguided assumption that a CAO must have a head of power in an existing CAR.

[Up-into-the-air]

casa and the effect on commercial operations

Head of Power

From australia.gov.au

The Commonwealth (Australian Government) heads of power is at section 51 of the Constitution.

The Australian Government also has power to make laws for Australia's territories (section 122).

A quick look at the concept of "Head of Power" will give you a lead in this 601.

Going in this direction [No doubt the casa spin doctors will say other wise] is not legal.

It is the regulations that must reflect the "head of power" of the CAA and the CAO.