The latest by Skidmore and follows the Mildura and Townsville events. Moorabbin to follow.
UNCLASSIFIED
They are still e-mailing people, so maybe not as popular as they like to think. I publish the questions and answers from Mildura below, which I have just found on a non-casa website.
It is worth a read, and see if you come to the conclusion that:
- There is substantial papering-over of why casa is correct;
- casa never take any “blame”;
- A sound way forward is not part of the dialogue.
Some reading of the Mildura Q and A
Future-aviation-safety-issues-Mildura Flight_plan_2030-MIldura-Q_A
I have provided some brief examples below.
Aging aircraft and the way in which their continued airworthiness is being considered.
Regulatory change and how that imposes pressure and therefore risk on both the operator and maintenance organisations.
The limited new pilots and engineers being trained and the resultant age of current professional’s within the industry.
limited availability of qualified and experienced responsible and accountable managers to fill the future demand.
Regulation and the industry organisations not keeping up with technology.
Reply Agree Disagree Alert moderator Share
Reply Agree Disagree 1 Alert moderator Hide reply (1) Share
Reply Agree 1 Disagree Alert moderator Share
Since moving to the VH register, I have is no such clarity or certainty. In addition to doing the things required by the regulator (FAA) in the country of manufacture of my aircraft (USA), I am now exposed to “Rulings” (the mechanism used to implement Cessna SIDS) and “Proposed ADs” (the mechanism to amend AD/PROP/1). There are peculiarly Australian inventions that are simply a means of bypassing the consultation mechanisms associated with a proper rulemaking process.
Manufacturers have not succeeded in making their SIDS/TBOs mandatory in the USA because the FAA is obliged to apply proper risk analysis and cost:benefit analysis to such proposals. CASA have not done such analysis and have disregarded the fact that manufacturers, as suppliers of replacement parts and sellers of new aircraft, have a commercial interest in having their “recommendations” made mandatory.
I would like to see a proper explanation of CASA’s airworthiness philosophy and justification for why a US manufactured aircraft should require more maintenance in Australia than it does in the USA.
Reply Agree 1 Disagree 1 Alert moderator Hide replies (2) Share
Under Civil Aviation Regulation 42V, a person carrying out maintenance on an Australian aircraft must ensure that the maintenance is carried out in accordance with the applicable provisions of the aircraft’s approved maintenance data.
Under Civil Aviation Regulation 2A(2)(c) Approved maintenance data represents instructions, issued by the manufacturer of an aircraft that specify how maintenance on the aircraft is to be carried out i.e. Supplemental Inspection Documents (SIDs). Aviation Ruling 01/2014 merely clarified a Regulation that has been in place since 1988.
Reply Agree Disagree 1 Alert moderator Share
Reply Agree Disagree Alert moderator Share
Reply Agree 5 Disagree Alert moderator Hide replies (2) Share
CASA is also organising a series of maintenance presentations at various regional locations, covering Cessna supplemental inspection documents (SIDs); the benefits of CAR 42C system of maintenance; the prototype matrix tool; and the new defect reporting service. There will be a one-hour presentation followed by ample
opportunity for questions. The first one will be on 1 November at Stawell, Victoria.
Reply Agree Disagree 1 Alert moderator Share
Reply Agree 1 Disagree Alert moderator Share
“Almost all fatal flying accidents are caused by loss of control during a turn!”
From the ATSB in 2007:
“general aviation fatal accidents … most prevalent type of accident was a UFIT”
From CASA in 2007:
“Three quarters of aviation accidents in Australia result from problems with the operation or handling of an aircraft.”
Meanwhile, in the USA more recently:
“Loss of Control-Inflight remains the top fatal accident category in GA …
and occurs most often .. while turning…….
The biggest single cause of fatal GA accidents is stall/spin from a turn.”So, what safety issues do I see facing us over the next 5, 10 and 15 years? Firstly, I see exactly the same big safety issue that has been facing us over the last 70 years – loss of control/stall/spin.Secondly, in the next 5 years I see the result of CASA’s Part 61 will be to aggravate that situation. i.e. some aspects address the above however all of the other onerous solutions to problems which do not exist are generally counterproductive to safety and some I see as having a direct adverse effect on the above.
Reply Agree 2 Disagree Alert moderator Hide reply (1) Share
Reply Agree Disagree Alert moderator Share
Reply Agree 1 Disagree Alert moderator Hide reply (1) Share
casa’s implementation of Part 61 has been a shambles both at a regulatory level as well as at at basic procedural level.
It is UNACCEPTABLE that it takes 2 months to issue a new pilots license!
it is UNACCEPTABLE that it takes 6 months to issue a UAV operators certificate!
It is UNACCEPTABLE that it takes 6 months to add an aircraft type to an aerial work AOC!
These should be simple things to do.
When the simple things cant be done it is no wonder that more complicated things are stuffed up too.
Reply Agree 1 Disagree Alert moderator Share
The elephant in the room is that the two roles CASA does play have resulted in more and more expensive regulation that is effectively strangling the GA industry out of existence. An example is the implementation of the SIDs program. I have been told by some Cessna owners that in the US, SIDS is applicable only to the commercial fleet, whereas here in Oz it has been applied to the WHOLE Cessna fleet. Another example is the controversial restrictions imposed on Jabiru powered aircraft. These are widely viewed as heavy handed and an over-reaction to some engine reliability issues. Our regulatory and safety functions should be separated as in the US
Reply Agree 5 Disagree Alert moderator Share
Videos that don’t read out the regulation verbatim but explain the reasoning, CASA’s interpretation and real world application. If we have something like this we can level the playing field in terms of consistency. Especially between CASA’s officers and regional offices
Reply Agree 2 Disagree Alert moderator Share
I have never seen a cost benefit analysis of the new part 61. This ridiculously complex and costly legislation has only had the effect of alienating industry from CASA. The only way to fix it is to remove any legislation that adds cost to an operator or crew member. There is no evidence that those rules will do anything to improve safety in the first place. Admit that you made a mistake and rectify it. You are not there, in your tax payer funded jobs, to cover your own backsides. You are there to serve a once great industry.Ask yourselves a question: when you go home at night to your family, can you tell them that you are doing your best to fix what you have admitted was a very problematic roll out of part 61? Or do you need to tell them that you sat by when increased costs led to peoples livelihoods, (and in many peoples minds a whole industry) being at stake, and that you can’t/won’t admit the error and fix it.I’ll say it again, remove all legislation that has led to increased costs. These costs are unsustainable.Two major schools have had their 142 applications rejected, applications filled out using CASA guidance material, to be told the material CASA provided was incorrect in the first place? What a joke, and you wonder why you have industry offside.
Reply Agree 4 Disagree Alert moderator Hide reply (1) Share
Reply Agree Disagree Alert moderator Share
Unfortunately the level of industry cynicism around CASA and its motives means that having a forum to encourage the industry to “have your say” after it (the industry) has already provided significant feedback through previous mechanisms only further reinforces the belief that CASA isn’t listening. If CASA is going to be serious about this “have your say” forum and make it worthwhile for us in the industry to bash our heads against the wall yet another time, then create transparency around what mechanism (if any) takes any feedback from this forum and feeds it into the management decision-makings levels of CASA. Like most in GA, I assume that nothing posted here will have any impact. The ball is in your court CASA, prove us wrong!
http://www.pprune.org/pacific-general-aviation-questions/568156-casa-have-your-say.html(External link)
Reply Agree 6 Disagree Alert moderator Hide reply (1) Share
Reply Agree Disagree Alert moderator Share
A key issue I see is how we are going to stop this kind of madness ruining GA completely. How are RPT and GA going to work together? We can’t keep having General Aviation being steamrolled in favour of an airline lobbying in the name of ‘Safety’. GA is almost dead in Western Australia no young people are getting into it. We have far fewer airports than the east coast so we need to retain access to them as there’s already hardly anywhere to visit or stop along many of these flight routes – having access to friendly aero clubs and airports where you can stop and refresh is critical to GA. We need to do whatever we can to protect them – especially the clubs who are responsible for introducing young people to aviation. RPT and GA can safely co-exist other airports have done it all around the world.The biggest challenge I see is how do we achieve good safety without going to far as in this case.
Reply Agree 2 Disagree Alert moderator Hide reply (1) Share
Reply Agree Disagree Alert moderator Share
Please recognise that administrative change for changes sake is not dealing with Safety issues.
I and several of my colleges have recently raised matters dealing with Part 61 through the Commonwealth Ombudsman and CASA complaints as well as the Federal ministers.
We asked for dialogue and resolution. We got a wave-off!
This is because CASA will not listen. Our group (APUAC) has written to the CASA CEO MarK Skidmore requesting dialogue which has not been forthcoming. So much for genuine transparency and the true ability to have a say or find mutual resolution or compromise to industry concerns.
CASA apparently has no idea that Airline Pilots also fly GA. In fact the majority of us came via that route and still are having a love affair with light aircraft and experimental amateur built. Its recreational flying at its best…
Many of us hold a PIFR ratings. This has been kept current by our own check and training organisation (Qantas, Virgin, Jetstar, and Tiger). Typically with 16 hours of level 7 Flight Simulator testing p.a. under full IFR conditions, renewing all 2D and 3D approach aids with approx. 800 -850 hours per year in IFR flight operations in high performance aircraft is well above many pilot’s recency and flight experience levels across the industry within Australia.
Additionally we undergo a 12-16 month proficiency check, (route and flight check by a CASA delegate) flying in the world’s busiest ATC environments and through CATIII and CATII weather. It is totally absurd to fully unreasonable to ask these pilots of complex systems, heavy-metal and high performance to undergo yet another proficiency check for a PIFR rating in a light aircraft such as a C-172. There is no logical reason to this requirement by CASA? There are no safety/crash statistics to support the change from the current position.
The FAA and the Canadians accept me and my colleagues and/my licence as fully capable of IFR flight in there airspace in GA aircraft based on my current ratings?
This is therefore folly, silliness and absurdity if reviewed in the cold hard facts of aviation ability and experience of the pilots with such experience and there are many of us!
I am not the sole participant affected here, there a many pilots all owners of General Aviation certified aircraft, Experimental and Amateur Built aircraft with IFR capacity and capable pilots are grossly affected here. I would assume many more will be affected or not aware that there ratings are about to disappear into the ether into the next few months!
This group are awaiting an outcome of the Ombudsman and CASA as the CEO has shut-the door on having a conversation. That’s right we find this plastic-website an affront after taking the time over weeks to engage with Skidmore and be feed autocratic gobbledygook in a letter that did not address once concern or any of the issues we raised!
If common sense does not prevail then CASA will enjoy a class-action (litigation) and a public media campaign as the matter progresses to the AAT (Administrative Appeals Tribunal) or relevant court (Federal) to seek injunction and review.
Whilst I regretfully submit that it will probably head this way, after many years on representative aviation committees and as a member of a number of Australian and foreign aviation organisations, I also appreciate that dialogue and common-sense can prevail.
We asked you CASA for your safety management appraisal on this matter. I have never seen a cost benefit analysis of the new part 61 and the change for this rule nor were forwarded any evidence why the change was promulgated. The facts are simply this…. this is CASA making regulatory change for regulator changes sake! Jobs for bureaucrat as there is no evidence, no logical reason why Part 61 had to change.
This ridiculously complex and costly legislation has only had the effect of alienating the wider arm of the aviation industry as more changes come to light. It now looks as if a media a campaign and litigation are required to in order to be have any dialogue with CASA (another cost to the public purse!) and to actually find any hard evidence for all these most foolish changes.
We tried to talk to you CASA and you closed the door in our face. Please don’t tell me that you are now having a conversation.
There is no reason to have IFR rated Airline Pilots under a matrix of C&T do another check to keep their PIFR GA rating current. CASA has no evidence to do so. As for the rest of Part 61 Why?
Reply Agree 2 Disagree Alert moderator Hide reply (1) Share
Reply Agree Disagree Alert moderator Share
Reply Agree 5 Disagree Alert moderator Share
Reply Agree Disagree Alert moderator Share
How can we meet these safety challenges?
7 comments
Better communication, trust and a concerted effort by government/CASA to assist financially in areas of recruitment, training and reducing administrative burdens is required.
CASA is committed to listening to industry, it needs to show it has listened and provide services that meets industry expectations. Unrealistic industry expectations will frustrate the process, sensible communication should be encouraged.
Reply Agree Disagree Alert moderator Share
I and several of my colleges have recently raised matters dealing with Part 61 through the Commonwealth Ombudsman and CASA complaints as well as the Federal ministers.
We asked for dialogue and resolution. We got a wave-off!
CASA needs to STOP Part 61 NOW and re-engage with the industry. Forcing change on GA will not increase Safety.This is because CASA will not listen.
Let me tell you about our experience….
Our group (APUAC) has written to the CASA CEO MarK Skidmore requesting dialogue which has not been forthcoming. So much for genuine transparency and the true ability to have a say or find mutual resolution or compromise to industry concerns.
CASA apparently has no idea that Airline Pilots also fly GA. In fact the majority of us came via that route and still are having a love affair with light aircraft and experimental amateur built. Its recreational flying at its best…
Many of us hold a PIFR ratings. This has been kept current by our own check and training organisation (Qantas, Virgin, Jetstar, and Tiger). Typically with 16 hours of level 7 Flight Simulator testing p.a. under full IFR conditions, renewing all 2D and 3D approach aids with approx. 800 -850 hours per year in IFR flight operations in high performance aircraft is well above many pilot’s recency and flight experience levels across the industry within Australia.
Additionally we undergo a 12-16 month proficiency check, (route and flight check by a CASA delegate) flying in the world’s busiest ATC environments and through CATIII and CATII weather. It is totally absurd to fully unreasonable to ask these pilots of complex systems, heavy-metal and high performance to undergo yet another proficiency check for a PIFR rating in a light aircraft such as a C-172. There is no logical reason to this requirement by CASA? There are no safety/crash statistics to support the change from the current position.
The FAA and the Canadians accept me and my colleagues and/my licence as fully capable of IFR flight in there airspace in GA aircraft based on my current ratings?
This is therefore folly, silliness and absurdity if reviewed in the cold hard facts of aviation ability and experience of the pilots with such experience and there are many of us!
I am not the sole participant affected here, there a many pilots all owners of General Aviation certified aircraft, Experimental and Amateur Built aircraft with IFR capacity and capable pilots are grossly affected here. I would assume many more will be affected or not aware that there ratings are about to disappear into the ether into the next few months!
This group are awaiting an outcome of the Ombudsman and CASA as the CEO has shut-the door on having a conversation. That’s right we find this plastic-website an affront after taking the time over weeks to engage with Skidmore and be feed autocratic gobbledygook in a letter that did not address once concern or any of the issues we raised!
If common sense does not prevail then CASA will enjoy a class-action (litigation) and a public media campaign as the matter progresses to the AAT (Administrative Appeals Tribunal) or relevant court (Federal) to seek injunction and review.
Whilst I regretfully submit that it will probably head this way, after many years on representative aviation committees and as a member of a number of Australian and foreign aviation organisations, I also appreciate that dialogue and common-sense can prevail.
We asked you CASA for your safety management appraisal on this matter. I have never seen a cost benefit analysis of the new part 61 and the change for this rule nor were forwarded any evidence why the change was promulgated. The facts are simply this…. this is CASA making regulatory change for regulator changes sake! Jobs for bureaucrat as there is no evidence, no logical reason why Part 61 had to change.
This ridiculously complex and costly legislation has only had the effect of alienating the wider arm of the aviation industry as more changes come to light. It now looks as if a media a campaign and litigation are required to in order to be have any dialogue with CASA (another cost to the public purse!) and to actually find any hard evidence for all these most foolish changes.
We tried to talk to you CASA and you closed the door in our face. Please don’t tell me that you are now having a conversation.
There is no reason to have IFR rated Airline Pilots under a matrix of C&T do another check to keep their PIFR GA rating current. CASA has no evidence to do so.As for the rest of Part 61 it is simply change for changes sake.
Save the monies and revert to the previous workable system. We have no reason to follow ICAO in this matter as our aviation infrastructure and safety records show we had it correct before some bureaucrat decide there was a promotion in destroying the fabric of our licencing systemThese changes do naught for Safety.
Reply Agree 2 Disagree Alert moderator Hide reply (1) Share
Reply Agree Disagree Alert moderator Share
You need to focus on the things that are dangerous and not worry about the things that are safe.
Upgrading the instruments in an Aircraft is far more costly in Australia than compared to the USA. Newer instruments, improve navigation accuracy, situational awareness and stall avoidance. The FAA has sought to streamline the installation AOA displays and electronic AH instruments to replace vacuum ones. In Australia the casa imposed regulatory process requires engineering orders significantly increasing the cost of installing such equipment. WHY?
CAAP 5.81-1(1) outlines the requirements for flight reviews. In that casa recommends a navigation exercise as part of the flight review. Many instructors I have spoken too say that when they are audited by casa they are pulled up if they do not have a cross counrty for each flight review they have given. With modern GPS how many pilots get lost? How many times does being lost result in a fatality? Wouldn’t the time be better spend focusing on other aspects of aviation that are far more likely to result in a fatal accident rather than showing that we know how to correct for wind drift?
Reply Agree 1 Disagree Alert moderator Share
And the FAA’s WINGS Pilot Proficiency Program https://www.faasafety.gov/WINGS/pub/learn_more.aspx(External link)
“The objective of the WINGS Program is to address the primary accident causal factors that continue to plague the general aviation community. By focusing on this objective, we hope to reduce the number of accidents we see each year for the same causes. As you will see, it is not a simple “Award” program but is instead a true proficiency program, designed to help improve our skills and knowledge as pilots.
…To ensure you receive a well-rounded learning experience, only certain flight activities fulfill specific credit requirements.
…
The program encourages an on-going training program that provides you an opportunity to fly on a regular basis with an authorized flight instructor.
…
Reviewing and refreshing your knowledge is just as important as actual flying. To meet this goal, we provide you many opportunities to complete online courses, attend seminars and other events, and participate in webinars. Many 3rd party activities, such as those offered by AOPA, ASA, Sporty’s, Gleim Publications, and others, qualify for WINGS credit and will indicate such credit on their web site.
…
Note that completion of any Phase of WINGS satisfies the requirement for a flight review. So not only will you complete a review of the most common weak areas that have led others to the accident site, but you end up with a flight review, as well!”
Reply Agree Disagree Alert moderator Share
http://www.kitplanes.com/issues/29_1/exploring/Unusual_Attitude_Safety_is_a_culture_20336-1.html(External link)
It seems to me that it would be worthwhile for you to look at how the FAA does things.
Reply Agree Disagree Alert moderator Hide reply (1) Share
http://www.avweb.com/avwebflash/news/2015_LOC_FRM_Agenda.php