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CASA Red tape reduction and Audit

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CASA Red tape reduction and Audit

Old 13th Oct 2014, 03:43
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CASA Red tape reduction and Audit

A chance to indicate the true cost of compliance with CASA regulations and the burden placed on industry for compliance. Dont let the Gov't decide how much their policies cost us.

If a reasonable number of GA organizations can contribute to this the government may get some view of the effect over regulation is having on our industry.

Civil Aviation Safety Authority - Red Tape Reduction and Audit

Its worth a shot.
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Old 13th Oct 2014, 04:43
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The cynical side of me says yeah……this will result in more.

I find it hard to believe the amount of costs associated with every single thing we do these days. Not just CASA.

Duly noted and thanks for the link
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Old 13th Oct 2014, 05:06
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Empire building1

It's a Monday arvo joke.. They can't find the last audit. It's either in Canada or back at Fort Fumble being "edited". Bloody hell, someone in Canberra is thick as a brick if they don't already have the answers.. Start with the RRP.

Last edited by Frank Arouet; 13th Oct 2014 at 05:10. Reason: No one owns up to this one. The email is not giving a name of contact.
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Old 13th Oct 2014, 23:25
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The link went down so just in case it goes again.

Red Tape Reduction and Audit

The Australian Government has committed to a red tape reduction programme to boost productivity growth and enhance competitiveness across the Australian economy. One component of the programme is to undertake an audit of all regulations and estimate the compliance cost for a sample of those regulations. Further information about the red tape reduction programme can be found at: Cutting Red Tape website.
Regulations by burden level

As part of the red tape audit, the regulations that CASA is responsible for administering have been ranked in terms of their burden on industry. The ranking of the regulations was produced using a methodology developed by the Department of Prime Minister and Cabinet that takes into account:
  • the type of requirements the regulation imposes;
  • the complexity of the regulation;
  • the reach of the regulation;
  • the frequency of interactions with the regulation;
  • currency of review; and
  • scope for reform.
The initial audit results ranking CASA regulations by burden level are set out in the following spreadsheet: Ranking of Regulations (28KB). CASA invites comment on the appropriateness of the initial ranking of the regulations by the high, medium and low burden level. Suggested changes to the burden level of individual regulations may be provided in the spreadsheet and sent via an email attachment to [email protected].
Compliance costs

CASA has been requested by the Department of Infrastructure and Regional Development to estimate the compliance costs of three regulations as part of the Government’s red tape reduction programme. The three regulations are Civil Aviation Safety Regulations 1998 Part 92, Civil Aviation Safety Regulations 1998 Part 99 and Civil Aviation Regulations 1988 Part 4. The compliance costs have been estimated using a methodology set by the Department of Prime Minister and Cabinet and further information on this methodology can be found at: regulatory burden measurement framework.
A central focus of the methodology is the time it takes individuals or businesses to comply with the regulatory requirements and the value of that time. Several assumptions were made in order to produce the estimates, these assumptions were informed by consultation with a select group of industry participants and now it is important to test that these assumptions are appropriate and representative for the entire industry. CASA invites comments on the appropriateness of the assumptions used to produce the cost estimates in the following three papers and alternative assumptions if that is considered appropriate.
Please send any comments to [email protected] by the 10th November 2014, including any relevant documents/spreadsheets.
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Old 13th Oct 2014, 23:58
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swh

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This is as a result of a feasibility committee formed 8 years ago, which resulted in a comprehensive 5 page report 5 years later leading to the forming on the implementation committee with the first draft distributed to stakeholders last year. With final committee recommendation to the board for their appointment of independent consultants from the health sector on the impact of the proposal to the aviation industry. Initially was to come into effect on April 1, was delayed for a few months while the person who was supposed to issue the draft to industry went on long service leave.

After submissions, another committee will be formed, and additional consultants specializing in Landrace egesta will be engaged. This is thought to only take another 2 years before a final draft is submitted to the minister.

The preliminary report indicated that the reduction in red tape would not be a viable business case as the cost of the various committees and consultants over the ten year feasibility and implementation phase will outweigh any savings to the industry. The positive outcome of the reduction in red tape program will the creation of an additional 20 jobs initially based in Rockhamption, Toowoomba, Armidale, Albury, Salisbury, Kalgoorlie, Geraldton, Kununurra, and Katherine to implement and monitor the program only costing the industry 4.8 million per year.
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Old 14th Oct 2014, 19:52
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swh,
Yep, thats about the size of ot.

What more proof that we are over regulated does anyone need?
A simple comparison of other juristrictions equivalent parts makes that glaringly obvious.

Last edited by thorn bird; 14th Oct 2014 at 20:17.
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Old 14th Oct 2014, 20:35
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For an excellent example of clarity of regulation in another jurisdiction, have a gander at New Zealand CAA Part 61.39 (b), and for those with the time, take another 10-15 minutes to absorb the whole of their Part 61. It really is that easy to understand.
Then weep for the cost and confusion interpreting and complying with the clusterfckuk that is our own Part 61. For private flying, this alone gives me reason enough to depart our system for the Dark Side.
Thinking if I ever upgrade from a RA category bugsmasher to something a bit heavier, I will either ZK it or leave it on the N register. In the latter case, the way to own it while not being a USA citizen would be via a Delaware Trust. A thousand bucks well spent to set it up. You can fly N rego non commercial on your home country's licence in your home country, or if you have a FAA ticket there is bound to be someone out there can do a FAA BFR and there are enough doctors can do the medical. There should be someone in this wide brown land can do annual inspections on aircraft, and if not, a dozen or so owners could chip in once a year to get someone over.
If all private owners went down this track we could probably never have any contact with CASA again but still be perfectly legal.

Last edited by Mach E Avelli; 15th Oct 2014 at 04:12.
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Old 16th Oct 2014, 01:33
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Miniscule SOE nobbled by the Act??

Clearedtoreenter - Sounds familiar? We don't even need a 50/50 case here. The CVD (non)issue is a case in point that has shown that even when we have a wealth of evidence against some of the stupidest red tape, the red tape wins. As for Part 61 and the tax payer money that's been wasted on that labyrinth of red tape!

CASA red tape reduction? Do me a favour! I wonder where that [email protected] email address actually goes...doesn't matter I guess. Keeps the natives quiet for a bit longer maybe though eh?
Good points you make CTR...

Basically put RTR is simply not in the current Fort Fumble's DNA.. Until such time as the organisation is totally gutted & the trough is emptied; they will continue to obfuscate their required responsibilities to the present Govt policy of red tape reduction....

However I do wonder if they have underestimated the heavy commitment by the RTR crew to their cause, after all the RTR program is not only heavily backed by the PM but is also administered by his department i.e. the PMC...

Perhaps those IOS members contemplating responding to the FF bollocks - FF self-assessed RTR audit results - should cc to the OBPR, PC, PMC, TA & his Parliamentary Secretary Josh Frydenberg...

The following passage is from Part 3 of the PC Audit Framework (my bold):
Other institutional developments
In addition to their election commitment to audit the performance of government regulators, the current Government committed to a number of other initiatives relevant to the issue of regulatory burden on business. These include:
• the issuing of Ministerial statements of expectation (SOEs) to the heads of Commonwealth regulatory agencies.
• the establishment of deregulation units within each department and agency
• requirements that each department and agency audit and quantify the cost to businesses and individuals of complying with regulation
• the establishment of Ministerial Advisory Councils, consisting of industry stakeholders, for each Cabinet Minister
These developments also have implications for the implementation of the proposed regulator audit framework, particularly the issuing of Ministerial SOEs. For example, ensuring some degree of consistency between SOEs for regulators and the principles of good practice used in the proposed regulator audit framework (effective communication, a risk-based approach to inspections, proportionate responses to compliance breaches etc.) could achieve greater commitment to the overall process, and enhance the prospects of achieving genuine improvements in regulator performance.
The Government is in the process of developing a whole-of-government risk management framework. The critical element of any risk management framework is the recognition of the cost of managing risk relative to the benefits achieved. These benefits depend on the probability and cost associated with the risk and on the effectiveness of the efforts to reduce risk or to mitigate the costs should the risk eventuate. This audit framework, as it focuses on minimising the cost to businesses while achieving the objectives of the regulation, should support the adoption of a risk-based approach to enforcement and compliance by Commonwealth regulators that will form part of this broader risk management framework.
Across many developed countries, there has been a tendency towards increasingly strong regulatory interventions to reduce risk to the public. In part this is because the demand for many of the things that regulation addresses, such as safety and the natural environment, tends to rise with income. But it is also due to false perceptions of risk, and a lack of understanding that many risks cannot be easily removed, and that attempts to reduce one risk can easily result in risk transfer rather than risk reduction (see for example, Bayer 1993, Graham and Weiner 1997).
As set out by the OECD (2010) a comprehensive approach to risk management would include:
… comprehensive regulatory impact assessment of the full portfolio of impacts of risk reduction efforts; both ex ante (prospective) regulatory impact assessment to inform initial policy decisions, and ex post (retrospective) regulatory impact assessment to inform subsequent policy revisions and to improve ex ante assessment methodologies; even-handed use of regulatory analysis both to discourage undesirable policy proposals and to encourage desirable policy proposals; greater use of economic incentive instruments in regulation; and better coordination and oversight of risk regulation policies across agencies within each government, and across governments internationally. (p. 12).
As summarised in table 1, Australian governments have a number of these elements in place already. However, Commission studies have found that not all regulatory impact assessments function as well as they should (PC 2012), and that gaps remain in ex post assessment of the need for and performance of regulations (PC 2011). Moreover, while Australia has been a leader in introducing risk-based approaches to regulation with many regulators adopting these approaches, there is still considerable scope for further improvement (box 2).
Rigorous application of the framework set out in this paper should work to reduce unnecessary compliance costs. But more fundamental efforts will be required to ensure that regulation is only implemented and continued where the economic and social benefits exceed the costs, and that where this is the case the most cost effective approaches are applied. This will require a more informed conversation with the Australian public about what governments can do to manage risk and what it will cost, not just for government but to businesses and other regulated entities, and the public more generally. The costs are not only financial, but include ‘social’ costs such as curtailing individual freedoms and eroding personal responsibilities.
The first bullet point (above) on miniscule SOEs perhaps highlights another major roadblock for effective reform, not only with the RTRP but also for the ASRR. Here is a reminder of the desired outcomes by the miniscule in implementing the 'Forsyth review':
Outcomes

The report of the review will:
  • examine and make recommendations as required on the aviation safety roles of CASA and the Australian Transport Safety Bureau (ATSB) and other agencies as appropriate;
  • outline and identify any areas for improvement in the current interaction and relationships between CASA and the ATSB, as well as other agencies and Infrastructure;
  • examine and make recommendations as required on the appointment process and criteria applied for key aviation safety roles within CASA and the ATSB;
  • examine the current processes by which CASA develops, consults on and finalises changes to aviation safety regulations and other legislative instruments (such as civil aviation orders) and make any proposals for improving these processes such that new regulations are best practice in safe operations for each relevant sector of the aviation industry;
  • review the implementation of the current aviation safety regulatory reform programme and assess the effectiveness of the planning and implementation of regulatory changes, including cost impacts on industry;
  • examine and make recommendations on options for improving future aviation safety regulatory reform having regard to international experience and stakeholder views, and the Government's objective of reducing the cost of regulation to business;
  • provide advice to Government on priorities for future regulatory development and implementation strategies; and
  • provide advice to Government on options for improving oversight and enforcement of aviation regulations, including rights of review.
And here is the Coalition intended policy in regards to FF prior to the election:
a. Strategic direction

Enhancing CASA’s capability as Australia’s aviation safety regulator must start with establishing a firm strategic direction for the organisation.
Following the Review referred to in initiative three above, the Coalition will issue CASA with a new statement of strategic direction as allowed under Section 12A of the Civil Aviation Act 1988.
However many of the IOS strongly believe that until you change certain sections of the Act...

Example from AMROBA submission (page 25 here): "...CASA once had a Mission Statement that stated “a safe and viable aviation
industry” which kept the focus on making “business-type” aviation requirements instead of the descriptive detail that is in legislation today
.

Recommendation 2: Amend 3A to read similar to the NZ Objectives: e.g.
a) CASA to undertake the government's functions in a way that contributes to the aim of achieving an integrated, safe, responsive, and sustainable aviation system; and
(b) to ensure that Australia’s obligations under international civil aviation agreements are implemented.

The changes can include many points currently in the Minister’s Strategic Direction to the Board and the CASRs can be used to provide regulatory direction to promulgate CASSs..."

...the effectiveness of a strongly worded miniscule strategic direction, under s12A (SOE), to CAsA (under the current regime) would only serve to reinforce the Iron Ring's continued embuggerance of the industry...

{Comment: Not to mention we have an ailing miniscule, asleep at the wheel, that apparently doesn't give a toss about fostering & promoting the aviation industry...}

However, perhaps too slowly for some, the winds of change are happening and with continued sustained pressure from the IOS etc. the GA industry may yet be saved from extinction.

To me the FF RTR self-audit results are a signed confession and should be exploited as such by the IOS...

MTF...
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Old 23rd Oct 2014, 06:39
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RTR repeal day next week.

From a transcript of a SKY News interview with the miniscule's assistant Jamie Briggs MP with an example of RTR within his area of remit...
Kieran Gilbert: I want to talk about the issue of red tape. Josh Frydenberg has been leading this within the Government.

Jamie Briggs: Yes.

Kieran Gilbert: It's apparently now going to reach more than $2 billion in savings for businesses and individuals through tax returns and so on. Labor says it wants to see the detail. I guess that's only proper, isn't it? Particularly given it did have concerns last time about inadvertent implications on competition and so on?

Jamie Briggs: Well all credit to Josh Frydenberg in this respect. He's done an outstanding job in finding a way through the bureaucracy, across legislative impediments to reduce the amount of red tape that operates in our system. Red tape holds back businesses from employing and it makes it more difficult for people to go about enterprise in our country. Josh is tenacious in his pursuit of this. In my own portfolio of infrastructure and regional development, we recently abolished a small but very significant piece of red tape, which cost about $12 million a year, and it was a piece of legislation, or a regulation if you like, which required an additional extension to mudguards on motorcycles. Now, some, when we announced this, sort of made fun of the announcement. The reality is, it saves $12 million a year. It was a small announcement, it was a small change but it's quite a significant reduction in cost, if you like.
Strange that the miniscule himself seems loath to cast his jaundiced eye over the behemoth of regs contained within the CASR 1998. Instead he merely accepts the piecemeal efforts being put forward by the current regime in Fort Fumble...

This would seem to be so totally out of step with many of his front bench colleagues, including his Assistant miniscule - from further on in the SKY News interview:
Jamie Briggs: Look it's a good point, and that's a challenge for Josh I guess leading this role within Government. I thought Malcolm Turnbull put it very well a couple of days ago when he said that it's a real discipline on ministers to consider every regulation that we're responsible for, and whether the need for it still exists. And in that sense what Josh is doing is pushing us all to consider the regulations for which we're responsible. Are they necessary? Do they actually achieve the purpose they were originally put in place for, or are we better off without them, and does that mean that we can get on and create opportunities? I think, as I said, Josh has been tenacious on this, the Prime Minister wanted him to be, and I think the Prime Minister is very pleased with the performance that Josh has brought to the table in that respect.
Hmm...I also thought the following comment from JB was extremely topical and amusing in light of the many Wodger wabbits wunning around the FF warren...

"...Josh has been, as I said, tenacious in pursuing those smaller issues of red tape, which he's just pursued like rabbits down a burrow in order to reduce the cost of doing business in Australia..."

I wish Josh would take the (pick preferred method for extermination); Mixo/Ferrets/Cyanide bombs/Wabbit twaps/Shotty to the FF wabbit warren...

MTF...
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Old 23rd Oct 2014, 18:40
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....If brother 'Josh' is stuck for cleaning out the Sleepy Hollow wabbit warrens ideas, I'd be more than happy to assist his efforts. I know – I can't be first, but I can be next – give me call Josh. 131 Boom....
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Old 30th Oct 2014, 02:13
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RTR repeal day - The Miniscule wakes up (briefly)

Yesterday - RTR repeal day - the miniscule actually woke up....for a brief period and delivered this joint Media Release:
Rigorous infrastructure policy approach is cutting red tape

Improving productivity growth and enhancing competitiveness are key focuses of the Australian Government's deregulation policy, embodied by today's Spring Repeal Day.
Deputy Prime Minister and Minister for Infrastructure and Regional Development Warren Truss said the regulation ‘spring clean’ is an opportunity for the Coalition Government to focus its attention on ways it can encourage growth and improve productivity by reducing compliance costs for industry.
“The Coalition Government is committed to saving business, individuals and the wider community at least $1 billion a year, by reducing the costs of unnecessary and inefficient regulation. The Government has already announced $2.1 billion in net savings—more than double our target—thanks to our drive to cut red tape,” Mr Truss said.




Reforms in the Infrastructure and Regional Development Portfolio include:
  • The Australian Maritime Safety Authority (AMSA) has replaced overly-prescriptive technical requirements for the design and construction of vessels to improve safety outcomes and increase flexibility for boat designers, builders, owners and operators (a $6 million saving to industry)
  • New motorcycles sold in Australia will no longer require modification to be fitted with an Australian specific rear mudguard, bringing Australia in line with Europe (a $14 million saving to industry)
  • Changes introduced by the Civil Aviation Safety Authority (CASA) to licensing and flying training regulations will save the aviation industry more than $2.5 million while maintaining Australia's high safety standards
  • CASA has recently removed a regulatory barrier prohibiting the use of smart phones and tablets during take-off and landing, adding around 40 minutes of productive time for business passengers
Assistant Minister Jamie Briggs said 4,309 unnecessary and outdated regulations within the portfolio were in the process of being repealed.
“A major review of the Motor Vehicle Standards Act 1989 is also underway to identify options to reduce the regulatory burden on business and consumers, while improving safety outcomes,” Mr Briggs said.
Mr Truss said he will continue working to find efficiencies wherever possible.
“While the Coalition Government has made significant progress, there is still more work to do,” he said.
“Future priorities include reducing red tape in coastal shipping regulation, the heavy vehicle industry and at airports.”
For more information on the Australian Government's deregulation agenda in the Infrastructure Portfolio, visit www.infrastructure.gov.au/department/deregulation/index.aspx
Now if you follow the above Dept link and go to the bottom of the webpage you will find another link:

Deregulation in aviation DOCX: 471 KB PDF: 187 KB

Quotes from the PDF version:

Safety improvements
  •  The Civil Aviation Safety Authority (CASA) is conducting an ongoing programme of reform to remove redundant provisions in its legislation and regulations—some 3,000 items were removed on the Autumn Repeal Day 2014 and more are expected to be repealed in future repeal days.
  • CASA has also made changes to simplify and improve administrative processes, and to remove the duplicative and outdated requirements no longer required in a contemporary aviation environment. Many of these changes benefit industry participants in both commercial and general aviation.
Global competitiveness
  • The Qantas Sale Amendment Act 2014 was introduced to ease foreign ownership restrictions on flag carrier Qantas, providing business flexibility for Qantas consistent with other airlines based in Australia.
  • The Airports Amendment (Service Monitoring) Regulation 2014 was updated to remove unnecessary record keeping requirements for four major airports.
Future areas of focus
  • The Government is actively considering its response to the Aviation Safety Regulation Review, released on 3 June 2014. A key finding is the importance of regulator behaviour, which is also a major component of the Government’s drive for best practice regulation.
  • The Department is continuing to undertake reforms at the 19 leased federal airports in light of the feedback from a comprehensive Review of the Airports Building Control and Environment Protection Regulations in 2013.
  •  The Minister for Infrastructure and Regional Development, Warren Truss, has encouraged regulatory agencies to adopt best practice regulation standards, with a particular focus on achieving transparency, accountability, clear communications and risk-based approaches wherever possible.
Without any empirical or factual evidence, the parts in bold are what I consider at this stage (until proven otherwise) merely weasel words and therefore - absolute bollocks!
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