VOCA

An aviation researcher, writer, aviation participant, pilot & agricultural researcher. Author of over 35 scientific publications world wide.

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Colmar Brunton report in detail

In he attached, there is a progressive assessment of the Colmar Brunton #casa survey.



Industry perceives CASA as having two roles:

  1.  One as the ‘police’ or the regulator; and
  2. One as the ‘translator’ or the organisation which helps industry to understand regulations and comply in a practical way.For some, this translation would consist of prescriptive documentation, such as a Safety Management System which an organisation could apply directly to their operations.

For others, this role consists of providing practical, sometimes customised advice on how to apply the regulations to operations.

For example, one chief pilot spoke very highly of time he was able to spend with a safety inspector developing a checklist for a new aeroplane which was more appropriate than that which the manufacturer supplied. The inspector helped the chief pilot have this new checklist approved and implemented.

Here is an example, where #casa think they are smarter than the aircraft manufacturer in how the aircraft operates. In the event of a “bingle” or incident, which has legal precedence, the AFM [Aircraft Flight Manual] or the #casa FOI opinion??

I would back, as do the majority of owners, pilots and operators that the AFM is the correct document, which has been approved at the time of aircraft manufacture, by the FAA or EASA in country of manufacture.

The above is an example where #colmarbrunton are “toeing the #casa line”. Doubtless there are further examples.

The principle issue that occupies the minds of #ozaviation, is the “Satisfaction with consistency of CASA’s decision making”, which causes a serious depth of angst.

#colmarbrunton say: “…The results from these questions indicate that stakeholders by in large disagree (with most strongly disagreeing) that:

  •  ‘CASA are consistent in the decisions that are made’ (average agreement of 3.3 out of 10);
  • ‘CASA staff are consistent in how they make decisions’ (average 3.2 out of 10);
  • ‘They understand why CASA makes the decisions it does’ (2.7 out of 10); and
  • ‘CASA makes decisions which reflect an understanding of my aviation activities and/or business’ (2.6 out of 10).

This is a shocking result and cannot be just “waved away by #casa as the comments below the survey results suggest eg. “…we are fixing the web-site….”

No time lines, KPI’s or other measurement parameters are given by #casa.


Let us examine in full one specific area, which [part61] affects all pilots, operators and others.


Indicator 6 – development of aviation safety regulations
What the survey found:
• mean 3.6 on a scale of 0 – 10
• 15% very satisfied or satisfied
• 22% neutral
• 58% dissatisfied or very dissatisfied.
Key issues:
• Charter operators and people involved in flight training were the most dissatisfied.
• People in the industry less than three years, those working in aerodrome services and
recreational/private pilots were more likely to be satisfied or neutral.
5% 10% 22% 20% 38% 5%
0% 20% 40% 60% 80% 100%
Satisfaction with
CASA’s development of aviation safety regulations (n=1,217 sic responders)
Very satisfied (9-10) Satisfied (7-8) Neutral (4-6)
Dissatisfied (2-3) Very dissatisfied (0-1) Don’t know

• More than half of the respondents felt their input would be useful to CASA;

36% said they were not aware they could participate in regulatory consultation.
• CASA is not considered to consult with the most appropriate people.
• CASA is not considered to do a good job providing practical guidance on legal obligations.
• Regulations are not considered to reflect current learning and innovation.

Actions to improve the development of aviation safety regulations:
• Under the renewing CASA program a new internal management structure for the development of regulations has been put in place to ensure greater consistency in the development process. This is enabling a more holistic approach (from development to implementation) and centralised accountability.
• CASA’s manual for regulation development is being revised to reflect the lessons learnt through the implementation of the licensing regulations and the experience of the Part 61 Taskforce.
• Volunteers from the relevant sectors of the aviation industry will be invited to help operationalise new regulations to assist CASA to uncover any unintended consequences. This process is designed to identify unintended duplication, unnecessary rules and missing information, prior to the regulation commencing.
• The experience of these volunteers will be documented and, where appropriate, the findings incorporated into the final implementation. Industry experience may also be used to develop case studies that will be made available to others in the industry.
• Regulations will also be tested before introduction through an internal peer review process where regulatory development and operational staff both review the documentation and assess impacts on industry from their various perspectives.
• The new position of Industry Relations Officer for aviation associations and peak bodies will ensure that these organisations are involved in the regulatory development process early and their feedback considered and incorporated where appropriate.
• New methods of consultation will be trialled including enhanced online and greater face-to-face interaction with a view to incorporating them into the standard consultation activities for future regulations.
• A detailed timetable for the completion of the aviation regulatory reform program was released on 7 June 2016. It was developed after extensive consultation with groups and individuals in the aviation community.
• The timetable takes into account the aviation community’s capacity to implement and adjust to regulatory changes. It also anticipates, and allocates time for, review and rework to ensure any unintended problems are resolved.
• CASA is allowing longer periods of time:

# for consultation on the development of new regulations in order to listen and respond to feedback; and
# for us to provide information, support and guidance before new regulations are introduced.
• The principles of the regulatory philosophy will be applied to future decision making on whether a regulation is the most appropriate mechanism to address an aviation safety issue.

Improved guidance and/or education will be considered as viable alternatives to regulations and the views of the aviation community taken into account.
• A concentrated high profile communication campaign will be implemented that explains the regulatory development process and how people can become involved. The campaign aim is to engender both greater understanding and trust in the process.


Got that??

I think the #casa response really is:

  • We can say we are listening as we have done a survey!!
  • We do not regard the ASRR report as important. Yet this [ASRR] garnered responses by David Forsyth from a wide cross-section and was highly critical of the operations of #casa.

There is no real way forward for #aviation except more of the same.

I am aware of some of the responses to the #colmarbrunton survey, which show disfunction of #casa reaching back over two decades. #casa does not listen and routinely “..plays the man…” rather than getting to the root cause of the real issues.

The sorry and very expensive mess needs a Royal Commission immediately. The Australian Senate holds the power and must act to stem the rapid bleeding to death of what is an essential public function of #aviation, which is being killed-off by poor regulations and an ineffective regulator – #casa.

Even #FAA and #ICAO saw this as early as 2008.

 

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