The High Priest In Action.
Thread Starter
The High Priest In Action.
The high priest in action: - railing against cost benefit analysis - Feb 2014.
We are to forget science and do what we are told. If we do not use science and mathematics to manage risk, then what else is there? Only the dictats of a high priest who believes HIS truths are superior to any other. Is this still common in CASA? The attitude towards Angel Flight suggests it is.
Actuaries "put a price on human life" every day for the insurance industry. Indeed, I have just received a quote for over $3000 for insurance on my country property - another example of cost / benefit analysis.
When is the Government going to wake up?
The intellectual arrogance of this submission is devastating.
https://www.infrastructure.gov.au/av...8_feb_2014.pdf
We are to forget science and do what we are told. If we do not use science and mathematics to manage risk, then what else is there? Only the dictats of a high priest who believes HIS truths are superior to any other. Is this still common in CASA? The attitude towards Angel Flight suggests it is.
I was formerly a Chief Airworthiness Engineer in the Civil Aviation Authority, and a member of the Air Navigation Commission’s Airworthiness Panel. I am a graduate of the University of Sydney in Aeronautical Engineering, the RAAF Academy, RAAF Basic Flying Training School, and the RAAF Staff College. I have been elected as Associate Fellow of the Australian Institute of Management and an Associate Fellow of the Royal Aeronautical Society. I have 30 years experience in airworthiness control,especially of aging aircraft, and including numerous accident investigations.
I have made this submission because, with all due respect to the Director and his staff, I strongly suspect that several basic principles of achieving safety in aviation have gone missing in action. CASA appears to be entrenching policies that were forced upon the “captured” CAA in times of financial stringency, and yet corporate management appears to be gold plated. ATSB continues to be ineffective and administrative separation of ATSB from CASA, and CASA from the AGPS, are taken for granted. Is CASA to become little more than a client of the European Airworthiness Authority, the FAA or,manufacturers, and incapable of independent thought and action.
I have made this submission because, with all due respect to the Director and his staff, I strongly suspect that several basic principles of achieving safety in aviation have gone missing in action. CASA appears to be entrenching policies that were forced upon the “captured” CAA in times of financial stringency, and yet corporate management appears to be gold plated. ATSB continues to be ineffective and administrative separation of ATSB from CASA, and CASA from the AGPS, are taken for granted. Is CASA to become little more than a client of the European Airworthiness Authority, the FAA or,manufacturers, and incapable of independent thought and action.
One of the more common cries from the industry, and from other arms of government,a proposal that has some superficial intellectual appeal, especially to those who dislike trusting technocrats.2 is that all proposed aviation safety regulation should be tested by cost-benefit analysis before implementation.
In the aftermath of each successive aviation catastrophe, however, the public cry has been that such a concept is outrageous. "You must not put a value on human life!"Both opinions are most often expressed extempore or off-hand of course, and with little appreciation of just what is being said. The matter is discussed in Appendix A When one pays for aviation safety one pays for a reduction in the risk of an accident. The risk is all but immeasurable and the dollar value of reducing it is inestimable. Cost-benefit analysis is neither appropriate nor practicable in aviation safety regulation. The resulting bald and mainly hypothetical cost-benefit arithmetic, divorced from discussion of the issues essential to the political decision to regulate or not to regulate is of no value.
The class of analysis proposed is unlikely ever to address the issues which should determine whether a proposed safety regulation is implemented or not.
2. A proposition with similar appeal is that the content of all proposed aviation safety legislation should be the subject of industry consultation before promulgation.
In the aftermath of each successive aviation catastrophe, however, the public cry has been that such a concept is outrageous. "You must not put a value on human life!"Both opinions are most often expressed extempore or off-hand of course, and with little appreciation of just what is being said. The matter is discussed in Appendix A When one pays for aviation safety one pays for a reduction in the risk of an accident. The risk is all but immeasurable and the dollar value of reducing it is inestimable. Cost-benefit analysis is neither appropriate nor practicable in aviation safety regulation. The resulting bald and mainly hypothetical cost-benefit arithmetic, divorced from discussion of the issues essential to the political decision to regulate or not to regulate is of no value.
The class of analysis proposed is unlikely ever to address the issues which should determine whether a proposed safety regulation is implemented or not.
2. A proposition with similar appeal is that the content of all proposed aviation safety legislation should be the subject of industry consultation before promulgation.
Actuaries "put a price on human life" every day for the insurance industry. Indeed, I have just received a quote for over $3000 for insurance on my country property - another example of cost / benefit analysis.
When is the Government going to wake up?
The intellectual arrogance of this submission is devastating.
https://www.infrastructure.gov.au/av...8_feb_2014.pdf
Last edited by Sunfish; 17th Oct 2019 at 01:09.
Cost-benefit analysis is neither appropriate nor practicable in aviation safety regulation.
I assume this buffoon would ‘ban’ all aviation operations except in Transport Category aircraft in and out of airports with CATIIIC approach aids. But wait, that’s still not a risk-free activity...
Some interesting stuff and fluff in there.
From an av-plebian, without all the badges as on his collar,and been fcuked over by CAsA twice, I do like the comments in the Recreant Regulator. Says it all really their 'recreancy' destroys their given trust. It most surely does.
When the heads in Av House , St Comode, Dr Discrepancy, Anusnasti et al,, lie cheat and pervert the course of justice, and those in regional offices conspire and perjure themselves ...and this is all seen as the CAsA "normal", no wonder they are despised and not trusted by the industry
Webster Dictionary Recreant...cowardly, mean spirited. (yep!!) and in manner.. basely, falsely.
Yep thats them to a T.
But the problem remains...how to fix the rotten place.?
From an av-plebian, without all the badges as on his collar,and been fcuked over by CAsA twice, I do like the comments in the Recreant Regulator. Says it all really their 'recreancy' destroys their given trust. It most surely does.
When the heads in Av House , St Comode, Dr Discrepancy, Anusnasti et al,, lie cheat and pervert the course of justice, and those in regional offices conspire and perjure themselves ...and this is all seen as the CAsA "normal", no wonder they are despised and not trusted by the industry
Webster Dictionary Recreant...cowardly, mean spirited. (yep!!) and in manner.. basely, falsely.
Yep thats them to a T.
But the problem remains...how to fix the rotten place.?
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Cost-benefit analysis is neither appropriate nor practicable in aviation safety regulation.
As Sunfish’s naming of the thread suggests, it’s religious zealotry.
However, the ‘High Priest’ got at least one thing right in my view: Standards setting is a political process, not a technical process. Government policy makers, not regulators, are supposed to decide the balance between risk and cost. Unfortunately, when that responsibility has effectively been abdicated to the regulator, the inexorable drive is towards more complex and restrictive regulations.
However, the ‘High Priest’ got at least one thing right in my view: Standards setting is a political process, not a technical process. Government policy makers, not regulators, are supposed to decide the balance between risk and cost. Unfortunately, when that responsibility has effectively been abdicated to the regulator, the inexorable drive is towards more complex and restrictive regulations.
Sunfish,
A name from the NSGODs (Not So Good Old Days) of DCA and later, and yes, it is a pretty good example of the basis of what we have to deal with in CASA ---- all part of the corporate culture.
Not an isolated attitude.
As you can imagine, the DCA thro' CASA resistance to Cost Benefit justification as per OBPR etc has been prodigious over the years.
Indeed, the whole Cth Public Service is not what you would describe as enthusiastic costs cutters, or enemies of red tape.
Tootle pip!!
A name from the NSGODs (Not So Good Old Days) of DCA and later, and yes, it is a pretty good example of the basis of what we have to deal with in CASA ---- all part of the corporate culture.
Not an isolated attitude.
As you can imagine, the DCA thro' CASA resistance to Cost Benefit justification as per OBPR etc has been prodigious over the years.
Indeed, the whole Cth Public Service is not what you would describe as enthusiastic costs cutters, or enemies of red tape.
Tootle pip!!
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The way of the modern world is the executive just want more money, nobody wants to actually do anything hard like heaven forbid - fix things. Bimbo management are now stellar in the corporate world.
"Actuaries "put a price on human life" every day for the insurance industry. Indeed, I have just received a quote for over $3000 for insurance on my country property - another example of cost / benefit analysis."
Sunfish, are you going to say that the cost / benefit analysis by an Actuary is the same as for C/B for a multitude of different areas of aviation? When deciding at what price to give life / property insurance, they have a wealth of data to come to a decision for pricing.
For the life of me I cannot see how anyone can interpret this submission the way everyone here has.To accuse this guy of ignoring science / stats is just hysterical given his professional quals compared to anyone here. My take from his comment about C/B in regulation is that at times it isn't always going to be appropriate and those with the technical expertise should prevail. The vast majority here appear to believe the bean counter view should prevail, which to me is surprising given the attitude to bean counters when it comes to running an airline or business in general.
Sunfish, are you going to say that the cost / benefit analysis by an Actuary is the same as for C/B for a multitude of different areas of aviation? When deciding at what price to give life / property insurance, they have a wealth of data to come to a decision for pricing.
For the life of me I cannot see how anyone can interpret this submission the way everyone here has.To accuse this guy of ignoring science / stats is just hysterical given his professional quals compared to anyone here. My take from his comment about C/B in regulation is that at times it isn't always going to be appropriate and those with the technical expertise should prevail. The vast majority here appear to believe the bean counter view should prevail, which to me is surprising given the attitude to bean counters when it comes to running an airline or business in general.
It's not an argument about whether "bean counters" should or should not prevail over the decisions of others.
It's about the fact that the number of beans will always be finite, and that all day - every day - decisions must be made about how many of those finite beans will be allocated to mitigate what risks among the infinite number of risks we all face.
We'd all love it if aircraft structures and systems were 100% reliable. And that's what everyone's working towards. I'll say this without intended disrespect to anyone: Any idiot can come up with the idea that it would be great if aircraft structures and systems were 100% reliable and that it's an outcome 'worth' pursuing.
But there will never be an aircraft structure or systems that are 100% reliable. Never.
And dare I say it: The history of aviation is littered with disasters caused by well-meaning engineers - even 'Chief Engineers' - whose bright ideas turned out not to have had a positive impact in the real world, as a consequence of some factor that was not taken into consideration or some failure mode the effects of which were not properly thought through. Each generation seems to consider that it has reached the apotheosis of knowledge and wisdom as a consequence of knowledge of the errors of the past, without realising that was the view of the previous generation and each of the proceeding ones in succession.
We see it on this very day. Today. The contemporary 'High Priest' in airworthiness in CASA has decided that Community Service Flight passengers will be safer if the maintenance requirements of the aircraft in which they are flown are 'upgraded' to 'commercial' standards. That's 'intuition-based' engineering, not 'evidence-based' engineering. No need to do a cost/benefit analysis. It's - I think the engineering term is 'dumb' - dumb to increase risk by mandating maintenance that evidence shows will have a substantial probability of creating more risks than it mitigates.
It's about the fact that the number of beans will always be finite, and that all day - every day - decisions must be made about how many of those finite beans will be allocated to mitigate what risks among the infinite number of risks we all face.
We'd all love it if aircraft structures and systems were 100% reliable. And that's what everyone's working towards. I'll say this without intended disrespect to anyone: Any idiot can come up with the idea that it would be great if aircraft structures and systems were 100% reliable and that it's an outcome 'worth' pursuing.
But there will never be an aircraft structure or systems that are 100% reliable. Never.
And dare I say it: The history of aviation is littered with disasters caused by well-meaning engineers - even 'Chief Engineers' - whose bright ideas turned out not to have had a positive impact in the real world, as a consequence of some factor that was not taken into consideration or some failure mode the effects of which were not properly thought through. Each generation seems to consider that it has reached the apotheosis of knowledge and wisdom as a consequence of knowledge of the errors of the past, without realising that was the view of the previous generation and each of the proceeding ones in succession.
We see it on this very day. Today. The contemporary 'High Priest' in airworthiness in CASA has decided that Community Service Flight passengers will be safer if the maintenance requirements of the aircraft in which they are flown are 'upgraded' to 'commercial' standards. That's 'intuition-based' engineering, not 'evidence-based' engineering. No need to do a cost/benefit analysis. It's - I think the engineering term is 'dumb' - dumb to increase risk by mandating maintenance that evidence shows will have a substantial probability of creating more risks than it mitigates.
Lead Ballon,
"But there will never be an aircraft structure or systems that are 100% reliable. Never."
Correct, and where does he even suggest anything like that? What I'd suggest he is arguing is the difference between what a C/B analysis and what a science / stats based view is, I don't believe they are the same, I'd go as far as to say that a C/B analysis is pretty subjective.
"Any idiot can come up with the idea that it would be great if aircraft structures and systems were 100% reliable and that it's an outcome 'worth' pursuing."
Can you name the idiot who has claimed the above? No, and he hasn't made any such claims either, these are strawman arguments. There is NO 100% reliable ANYTHING!
As to your comments on the ATSB findings on the Community Service Flight accident rate I'd like to see a counter argument on their stats, using statistical analysis, not just someone in a senate hearing claiming they got it wrong. By saying this I'm not making judgement on it, but it would be pretty stupid of them to just randomly make statements like that when it would be easy enough to get a statistician to review it. I would add I think CASA and the ATSB are way too close for my comfort.
"It's about the fact that the number of beans will always be finite, and that all day - every day - decisions must be made about how many of those finite beans will be allocated to mitigate what risks among the infinite number of risks we all face."
Sure, but it's amazing that pilots on Prune lambaste bean counters all the time about the way they count the beans and allocate them. Because it's so subjective. Work for a company that cut up an aircraft which the Flight & Eng depts loved as it was in good condition, except the bean counters said is wasn't as cheap to run! This is what I believe he's arguing against, not a blanket "it must be accident proof", ****, he's an engineer (tertiary trained, not a LAME and by saying that I'm not putting them below pilots) and he'd know ALL about what you are railing against.
I'd suggest he's also against your "The contemporary 'High Priest' in airworthiness in CASA........" for the same reasons.
Btw, I haven't bothered to read anything other than the quoted parts of his submission, and don't think I need to otherwise it should have been included in the piece.
"But there will never be an aircraft structure or systems that are 100% reliable. Never."
Correct, and where does he even suggest anything like that? What I'd suggest he is arguing is the difference between what a C/B analysis and what a science / stats based view is, I don't believe they are the same, I'd go as far as to say that a C/B analysis is pretty subjective.
"Any idiot can come up with the idea that it would be great if aircraft structures and systems were 100% reliable and that it's an outcome 'worth' pursuing."
Can you name the idiot who has claimed the above? No, and he hasn't made any such claims either, these are strawman arguments. There is NO 100% reliable ANYTHING!
As to your comments on the ATSB findings on the Community Service Flight accident rate I'd like to see a counter argument on their stats, using statistical analysis, not just someone in a senate hearing claiming they got it wrong. By saying this I'm not making judgement on it, but it would be pretty stupid of them to just randomly make statements like that when it would be easy enough to get a statistician to review it. I would add I think CASA and the ATSB are way too close for my comfort.
"It's about the fact that the number of beans will always be finite, and that all day - every day - decisions must be made about how many of those finite beans will be allocated to mitigate what risks among the infinite number of risks we all face."
Sure, but it's amazing that pilots on Prune lambaste bean counters all the time about the way they count the beans and allocate them. Because it's so subjective. Work for a company that cut up an aircraft which the Flight & Eng depts loved as it was in good condition, except the bean counters said is wasn't as cheap to run! This is what I believe he's arguing against, not a blanket "it must be accident proof", ****, he's an engineer (tertiary trained, not a LAME and by saying that I'm not putting them below pilots) and he'd know ALL about what you are railing against.
I'd suggest he's also against your "The contemporary 'High Priest' in airworthiness in CASA........" for the same reasons.
Btw, I haven't bothered to read anything other than the quoted parts of his submission, and don't think I need to otherwise it should have been included in the piece.
"because it's so subjective".
The amount of money that's spent to mitigate risks in aviation is, sadly, substantially subjective.
That's the problem.
Subjective risks can be objective nonsense.
The amount of money that's spent to mitigate risks in aviation is, sadly, substantially subjective.
That's the problem.
Subjective risks can be objective nonsense.
lolololol
Lead Ballon, so you agree. I think the gentleman was / is arguing for actuarial style decision making, not the C/B subjective analysis decision making by people who are mostly lacking the technical skills required.
Lead Ballon, so you agree. I think the gentleman was / is arguing for actuarial style decision making, not the C/B subjective analysis decision making by people who are mostly lacking the technical skills required.
Thread Starter
Exfocx, your pathetic faith in technical skills is touching. Me, I prefer data driven decision making, not some Bishop making an Ex Cathedra judgement about what she thinks is “safe”.
It also begs the question about what RAAF/military aircraft designers think is “safe” and what Civil aviation manufacturers and operators think is “safe”.My experience is that in some cases they are worlds apart and that experience of one doesn’t necessarily translate to the other.
It also begs the question about what RAAF/military aircraft designers think is “safe” and what Civil aviation manufacturers and operators think is “safe”.My experience is that in some cases they are worlds apart and that experience of one doesn’t necessarily translate to the other.
Thread Starter
So let’s cut to the chase, exfocx: Is the imposition of ‘upgraded’ maintenance standards on aircraft engaged in ‘Community Service Flights’ a decision that results in a decrease of the ‘safety of air navigation’ or an increase in the ‘safety of air navigation’?
Increase in the safety of air navigation?
Yes or no.
Increase in the safety of air navigation?
Yes or no.