General Aviation Meeting

[owen meaney]

AMROBA is hosting very important meeting in Brisbane 20 April
AMROBA :: Breaking News

[Horatio Leafblower]

If the construction of that document reflects AMROBA's general level of English language skill, it is no wonder they have so much difficulty understanding the regs.

[601]

If the construction of that document reflects AMROBA's general level of English language skill, it is no wonder they have so much difficulty understanding the regs.

I found it easier to read the AMROBA's invite that the convuleted stuff that comes out of FF.

Check the latest from FF
Civil Aviation Order 48.1 Instrument 2013

[tail wheel]

I'd agree with 601 - try making sense of just para 2 and 3 of the attached document as an ordinary pilot, without a degree in law or English! I think it highly unlikely McCormick fully understand the instrument he signed!

I will sticky this thread until the AMROBA meeting date.

[owen meaney]

OPEN INVITATION

Do not forget to RSVP so catering can be arranged
AVIATION INDUSTRY MEETING
Industry organisations from South East Queensland invite all aviation
operators and organisations to a meeting at Archerfield to identify the issues
that are restricting the economical survival of non airline aviation.
Venue: Coopers Colonial Motel
Address: 1260 Beaudesert Road, Acacia Ridge, Queensland 4110
Phone: [phone]
Fax: [phone]
Web: Coopers Colonial Motel | Supplying accommodation to Acacia Ridge, Archerfield, Sunnybank and Coopers Plains
Time: 1230 registration (coffee & light refreshments)
1300 to 1700 meeting.
Date: Saturday, 20th April 2013
RSVP: [email protected] (for catering purposes)

[aroa]

Post meeting...

I hope the transcripts and outcomes of this VERY IMPORTANT meeting are given maximum and widespread exposure.

Owners and operators who need AMEs and LAMEs are interested too.

Its FIGHT BACK time.!! Telling the issues as they are ...and for CASA where to get OFF, is crucial to the survival of GA.

Most of the stuff out of FF is just dross churned up to keep the folk in CB in a 'make-work' job, off the streets and FF at its over bloated, and very costly size.

[Kharon]

The reality check we had to have.

The thing that beats me is what, in all the thousands of words written in proposed, initiated or intended 'new' maintenance administrative legislation will make flying one tiny bit safer? It may hammer a few unfortunate LAME into a criminal court, it may well abrogate CASA responsibility and make a further 'horse's arse' of ICAO compliance. The changes will not ever come close to improving anyone's safety except for the endless stream of "aviation ambulance chasers" which will grow exponentially, fully supported by your friendly neighbourhood workshop.

ICAO is good, compatibility with ICAO compliant states is good, why, oh why do we need this enforced reinvention of the wheel? Are we really that 'unique'?

If Entsch, Truss, Joyce even Katter? would turn up and bring some of the RRAT folk (I reckon Searle would really enjoy the down to earth practicality of what AMROBA has to offer) with them, they may begin to see just how close to the far edges of reality we are, how far removed from the civilized world we are and just what a piss poor state the industry is really in. They may even get a free kick or two at "Our Tony" - bless him.

Theme song? -

Thie me kangaroo down sport

- or; My boomerang won't come back. Vote here.

PS. Don't watch the whole thing, you get it (or not) in the first 60 seconds.

[hiwaytohell]

Owen
Good luck to your guys. But please stay focused because some of the ideas put forward by Ken / AMROBA in the past have been positively nutty, such as adopting FAA regulations. As a result the good ideas have been lost.

[thorn bird]

Adopting FAA reg's "Nutty"????
If FAA reg's are nutty how the hell would you describe the current suite served up by our regulator??? "absolutely positively Insane" springs to mind.

[my oleo is extended]

I agree with the Thorny Bird. The FAA's suite of regs, although not a perfect fit, would be a better option at the moment than our current ****ty tampered with suite of pony pooh. But ultimately we could learn from our CAA brothers across the Tasman. What they have, and from memory (but I could be a little of que) took around 5 years to write and implement. Plus they have the added bonus that the suite pretty much works, again unlike our molested and muddy pile of regulatory ****e.
One thing is for certain, a giant set of jackboots needs to be taken not to industry, but those oversighting industry.

Anyway, best of luck to AMROBA, go in hard. But make sure you have all the 't's crossed and 'i's dotted first. Wear robust artillery, watch the left flank and take aim and fire.....

[hiwaytohell]

In 2008 and 09 the FAA was actively consulting with the ATA regarding discarding a whole bunch of outdated regs. This included their Part 65 which they know is out of date and totally compromised, and replacing with Part 66.

At the same time AMROBA (Ken) was actively lobbying anyone that would listen that we should forget about Part 66 and adopt the FAA A&P (Part 65). His comments were reported in some of the aviation media at the time.

Even the FAA's Dr Bill Johnson commented on the AMROBA proposal ... that "Australia would be nuts" to adopt the old FAA regs, when the EASA regs were becoming the world standard. Indeed at the time the FAA were actually following the way Australia was adopting the EASA regs.

Nutty seems about right.

Anyway all I am saying is stay focused on the good ideas. And if you keep Ken's past personal issues with CASA out of it, you can do a lot of good.

As for the new regs

our current ****ty tampered with suite of pony pooh

the problem was not the regs but what OLC did with them plus the regulatory reform process was not finished.

And yes the Kiwi CAA has done a pretty good job, but take a look at the composition of their Board and Charter compared to the irrelevant mob on the CASA Board.

[Kharon]

Slightly disgusted.

I've never been a great admirer of the sneak attack – Ken may well have a couple of old bones to pick over with the regulator, who has not?. Most of the experienced sane 'experts' do, in one form or another have a pet hobby horse which gets a flogging every now and then; some even revert to a familiar, default 'comfort zone' setting from which to expound a theory. Right or wrong KC is trying his very best to correct what he perceives as yet another iniquity, impost and increase in administrative costs being inflicted on industry. (i.e. to your benefit). I would like to see some of his detractors run an organisation like AMBOBA, achieve the same level of influence, present some form of alternate system and then have the balls, brains, energy and system knowledge to make a difference.

An erudite discussion of the various systems would be welcome here; FAA, EASA, NZ, PNG, Ghana all valid topics, how's about stating a case for or against (as pleases), rather then trying to denigrate the mans efforts. Who knows, he may even be philosophically wrong. Don't just bag the argument – put up an alternate.

There now, I feel much better. Steam off.

[Sunfish]

The main problem is going to be selection and maintenance of the aim.

Unless you guys can get very very clear about what you want to do and encapsulate it in a single easily understood sentence you will fail.

I suggest that your objective is:

- Easily understood simple plain english regulations, universally applied the same way throughout the country. In other words standard weberian bureaucracy with no possibility of creative interpretation by either operator or CASA operatives. And enforced in a reasonable and fair manner in line with the concepts of equity, procedural fairness and natural justice


How you achieve that is another matter. I am a great believer in the "strategy follows structure" school of business planning.

If the regulations were written by one group and enforced by a separate entity and audited by an independent ATSB there would be hope that something like the above might be achievable. However with the current mishmash of CASA and ATSB, reform is impossible.

For example, it is risible to watch CASA attempting to lock the door after the horse has bolted by its sudden discovery of the issue of "Fatigue Management" having hung out Dominic James to dry over the Norfolk Island ditching, whitewashing his employers fatigue management process and now coming up with new standards that they previously said were not needed - and incorporated in their best crappy mind numbing legalese to boot:

Civil Aviation Order 48.1 Instrument 2013

.......And of course the double jeopardy problem remains. CASA must always have someone to prosecute and no liability itself:

16.1 It is a condition on each flight crew licence that the licence holder must not operate an aircraft if, considering the circumstances of the flight to be undertaken, he or she has reason to believe that he or she is suffering from, or is likely to suffer from, fatigue which may so impair performance that the safety of the operation may be affected.


16.2 An FCM employed by an AOC holder must, before any FDP, disclose to the AOC holder anything affecting the FCM or connected with the FDP, which he or she has reason to believe may affect his or her ability to meet the AOC holder’s fatigue risk management policies or the limits and requirements of the Appendix or Appendices that the holder has chosen to apply to the FCM.

Anyway, good luck, my guess is that this effort will once again fail. Don't be bought off with the standard bureaucratic tricks either (eg: A "working group" etc.)

[Kharon]

Nope, steam back on.

Sunny spot on: I have taken the liberty of spending four minutes rehashing some of the AMROBA adpositional phrases. It's not first class I admit, but it shows by rephrasing a law or a statement, how intention (spirit and intent) becomes clear. One may then agree or disagree with the argument, that's a democracy: but until the point, the pro's and con's, and a general acceptance has been achieved; you remain well and truly divided and ultimately conquered. Now that, is a truly tried and tested method.

Primarily, the proposed meeting is not focussed on the integrity or quality of maintenance provided to Australian aircraft, but on background administrative and regulatory compliance issues which have no or little effect to the physical well being of an aircraft or the safety of air operations.

Industry operators and organisations are finding it difficult to be certain that compliance with the implemented regulatory requirements is achieved. The uncertainty is partly due to ambiguity within legislative requirements; and, partly due to the often confused, differing applications and interpretation made by individual CASA offices and staff. This is particularly noticeable where the legislation combined with subjective interpretation presents a 'hidden', unintended effect exposing the organisation or individual to prosecution.

The confusion, uncertainty and ambiguity creates an impression that a businesses while attempting to comply may be incriminating itself and subjected to prosecution as a result. This perception makes interaction between safety regulator and industry businesses uncomfortable and strained.

Now for a coffee and perhaps a cigar, who knows - it being Sunday and all.

[thorn bird]

"the problem was not the regs but what OLC did with them plus the regulatory reform process was not finished."

Ermm?? problem not the reg's ??? Its not??? Oh I see its the lawyers fault.

Now I seem to recall way back when Abraham was a pup that a good deal of reformed regulations were just about ready to go, nicely aligned with the FAA.
These were discarded because, in between cocktail parties and visiting sacred sights in Europe, someone got convinced that EASA was the all new way to the promised land. Of course the clique within the regulator, who opposed any sort of change, let alone going the FAA way, jumped on this as a perfect opportunity to derail the reform momentum, hence the quarter of a billion dollars of tax payers money and 25 years p..ssed up against the fence.
Now lets see, which country by far builds and operates the most aircraft be they airliners or GA types?
Have their regulations, though unreformed, "FOSTERED AND PROMOTED" their industry??
Have their regulations, though unreformed, "PRODUCED BETTER SAFETY OUTCOMES" than Australia's have??.
Is this country about to embark on a massive reform program? not to bury its industry in further administrative costs and imposts but to free it up and actively find ways to reduce regulatory cost burdens.
They understand that there are limits to what a customer is prepared to pay for a service. For a commercial operator it is two thirds cheaper to operate the same aircraft there than in Australia, and it aint the cost of fuel!!
In Australia we have reached the tipping point of cost, people will look for cheaper alternatives, generally to go by road, which of course is a lot safer than by air. Then again it may be difficult to find and operator given the number that have been raped by CASA largely for minor administrative infractions that have nothing to do with safety.
I wonder, since the reign of the screaming skull began what the dollar cost has been in destroyed businesses, and additions to the dole queue.
So what's happening in EASA land???
I hear that due to complaints from industry and various regulators they are having a rewrite, really!!..already??.
Not to worry the "Reformed" Australian regulations are not even close to EASA ones except for the chapter headings so Swanny and Albo wont have to find another quarter billion.
All this begs the question what is ICAO for? if your not going to follow it other than the neat all expenses paid trips to Montréal and Switzerland (hear the skiing there is awesome).
Want an example of what good regulation does, look no further than over the Tasman, wrote them in five years, only cost five mil or so, and already their industry is starting to thrive. Aligned with FAA..you bet!!!
Singapore, almost the same as Kiwi land and the only reg's so far completely ICAO compliant. Aligned with the FAA...you bet!!!
I think there's only one Nut on this forum and it aint Ken.

[Avgas172]

Bloody Hell! a first, I can actually understand what Kharon is on about ... but I digress .... one of the problems we seem to have with the current CASA regulation rewriting (amongst other things) is the issue of constantly trying to re-invent the wheel in Australian Aviation. All of our aircraft (with a very small exception) systems, hardware , software, etc etc come from somewhere else (mostly the USA) but we seem to be able to tell the makers of same how it all should be run, spending millions on the way to prove F@ck all, (rant paused) but why should we be surprised with the current crop of dimwits that seem to be our leaders spending the country into a Banana Republic, with no return in any concrete infrastructure that we can take into the future, bring on September 14th (or the meteor shower on
22nd Apr) to help us end it all.

[Kharon]

Blame the Leader of the Opposition.

The My bloody Kitchen rules thing is on the TV tonight, so I get to play on Pprune; and just this one time, for Avgas – I'll attempt to explain some of my Pprune twiddles. Avgas says -

"Bloody Hell! a first I can actually understand what Kharon is on about" etc.

From me a big, big smile... - why????. Avgas probably completely understands the maintenance issues, therefore the arguments, subtle or overt, pro and con are 'seen' and may be 'discussed' on an equal footing.

Point - It's when the reader fails to understand the context (plot) that the reader struggles with the refinements of the subtext and where problems with 'comprehension' arise; it's no ones fault. Just like a rocket scientist may have a 'shorthand' chat with another; or an expert LAME may have a deep and meaningful with the manufacturer on the specifications of a complex system – all double Dutch to me.

But, Avgas managed to "get it", why?; because the problem is understood, by him; therefore the response can be assessed and a rebuttal offered; it's called a discussion (row or dust up if you like). If you don't 'know' the problems or issues, (like a books characters, the hero's, the villains or who's the good sort) in a complex issue such as the AMROBA presented case, then it may as well be writ Mandarin. Anyway Avgas – I always try to get the message through to those who'll best understand it; sometimes, it's just not possible to do anything else other than be cryptic. I would like to be less so, indeed, I can be when the muse descends - but mostly - needs must when the Devil drives.

Anyway, in an attempt to elaborate the point, I have taken further liberties with the AMROBA invitation – (Some just can't be bothered to see past the 'words' and read what's written) so, with apologies to Ken and crew, elaborating the AMROBA opinion from above:-

Seeking legal advice has now become a reality as CASA attempts to prosecute ‘safety’ into the industry. The net result is that CASA, due to a failure to manage change now prosecute businesses rather than assist an industry adapting to a significantly changed regulatory and administrative processes. CASA is now seen as a policing agency, rather than a safety regulator.

The involvement of legal advice increases the cost of complying with an ever growing, confusingly 'unique' system of administrative and regulatory management not compatible with the majority of international NAA systems; we fail to even harmonise with our close neighbours – New Zealand and Papua New Guinea.

During the transition process, CASA have failed to identify ‘causes’ underlying many operator or organisations perceived 'administrative' deficiencies. World practice calls for the implementation of an ICAO model Corrective Action Plan as a primary action, before initiating any form of punitive or enforcement action as a last resort.

ICAO also calls for educational programs to assist industry through a transition period. CASA has provided no in-depth training, assistance or guidance to an industry which has been under philosophical, operational, administrative and regulatory change for over two decades.

Without adequate education and training for the Chief Engineers legally responsible for regulatory compliance, it is becoming impossible for small businesses to comply with the burden of ever changing regulatory legislative system.

Without a marked improvement in communication, education and the almost non existent flow of information the industry cannot, fully and comfortably participate in promoting aviation regulatory reform without seeking legal advice in support of any correspondence with the Authority.

CASA are not promulgating the International Civil Aviation Organisation (ICAO) Standards and Recommended Practices; but are instead instructing the Government to ‘criminalise’ ICAO “Standards”. CASA is very effectively abrogating its responsibility under the Civil Aviation Act by persuading the government into converting “Standards and Recommended Practices” into criminal regulations for administrative, not operational safety purposes.

A rose, by any other name etc..

[Creampuff]

“Selection and maintenance of the aim”?

Sunfish, your well-intentioned objective has been the stated objective of the regulatory reform process and ‘charter letters’ for decades. The precise terms of the various motherhood statements have changed a bit, but the warm fuzzy feeling they (used to) provide is the same.

The single most effective way to achieve real change in Australia is to stop electing Laborials. The Coalition’s shadow Minister for Transport cares as much about regulatory reform and CASA, the ATSB and Airservices as the incumbent Minister.

You want to really change things?

Elect Independents!

If people in the GA sector are unwilling (as most are) or unable, as a block (that’s the killer: there are not enough votes in GA) to elect people who actually care for their constituents rather than power for power’s sake, nothing will change.

[Avgas172]

The single most effective way to achieve real change in Australia is to stop electing Laborials. The Coalition’s shadow Minister for Transport cares as much about regulatory reform and CASA, the ATSB and Airservices as the incumbent Minister.

You want to really change things?

I like Dogs, however if the dog I have at the moment keeps biting me, I shoot him and get another dog, hopefully trained a bit better this time. However I dont go and get a giraffe because it isn't going to do the job my dog does, I believe Mr Windsor & Mr Oakshot proved this last time around.

[halfmanhalfbiscuit]

Little initiative from the UK CAA
Red Tape Challenge - General Aviation Theme