VOCA

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

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Where to from here?? with #ozaviation

The question is getting louder and louder, with the representative organisations becoming more vocal.

During the #asrr review of David Forsyth, many of the alphabet soup organisations were vocal, but failed to call for specific inputs of regulations from overseas.

This is seen to change in the current press release, which gives a distinct “call-to-arms”:

TAAAF believes that now is the time for definitive action before the new regulations cause irreparable long-term damage and the loss of jobs and businesses.

That #casa is no on a very low “trust-level” when a straw poll is undertaken and any contact with industry players elicits negative responses, on a much greater level than when David Forsyth fielded almost 300 written responses from the aviation industry.

New CEO, Skidmore is working on “talking to industry”, but there have been no new directions to emanate from this process, except for the 10-commandments. The 10-commandments are released by Skidmore, but there are no metrics by which proper comparisons can be made to see if the “principles” are met by #casa.

In fact:

There is:

  • No “….talking to industry….” prior to this release;
  • No reference to what the industry requires;
  • No reference to the #asrr outcomes.

All of which should be guiding how #casa proactively works with industry.

This is much more of a “…them and us….” approach, with aviation the distinct looser.

To see organisations such as the Cairns Chamber of Commerce able to elicit a heart felt response in early september 2015 at an industry seminar in Cairns, shows that the broader community is starting to have concerns where the industry could go and it’s current parlous state.

The introduction of the NZ-FAR’s or US-FAR’s must be implemented now.


 

AVIATION ASSOCIATIONS FORUM MEETING – TAAAF Communiqué

The Australian Aviation Associations Forum has expressed considerable concern at the slow pace of reform of CASA and the ongoing cost impositions from new regulations.

Recently introduced CASA regulations are threatening the viability of industry and especially general aviation operations, with millions of dollars required to be invested for no commensurate safety gains.

The TAAAF fully supports the Director of Aviation Safety’s Directive 01/2015 on the development and application of risk based and cost effective aviation safety regulation and asked that it be applied to recently introduced CASA regulations.

TAAAF felt effective implementation of the directive will require cultural change within CASA and encouraged the CASA Board to persevere with their clear, Government- mandated cultural change agenda.

The TAAAF recommends the CASA redouble efforts to urgently:

  • Withdraw CAO 48.1 (flight and duty times) – this regulation is against the objectives of the DAS Directive 01/2015 in that hard evidence has not been provided to justify it, it ignores decades of safe operations under previous rules, and imposes massive unnecessary costs and complexity.
  • Establish an industry task force to propose urgent exemptions and amendments to Parts 61, 141, 142 on pilot licencing and training and institute revised transitional arrangements to allow the industry to operate.  In particular, urgent action is needed in respect to firefighting training and the issuing of new ATPL licences for GA pilots as both these essential functions have virtually ceased under the new regulations.
  • Reform Australian aviation manufacturing regulations to harmonise with the modernised US FAR system
  • Undo the damage caused by new maintenance training regulations that resulted in the loss of three TAFE skill providers.

While there is some good work being undertaken by CASA, it is being hindered by the massive problems caused by legacy regulations only now coming into force.

TAAAF believes that now is the time for definitive action before the new regulations cause irreparable long-term damage and the loss of jobs and businesses.


 

AMROBA:

General aviation (GA) participants who know what GA was like pre 1988 understand, with the right regulatory approach, that the airspace would have a lot more aircraft, especially private aircraft, clocking up flying hours which creates employment. The loss of jobs started with the making of the Civil Aviation Regulations (CAR) in 1988 that added regulatory administrative costs resulting in many leaving the VH industry.

But who cared?

GA today relies mainly on commercial GA to support it and some of commercial GA is seasonal. The decline from 1988 to 1995 should have raised alarm bells within government as jobs disappeared.

But who cared?

The CARs created under the Civil Aviation Act implemented requirements that were unsustainable for many in GA and the theme has continued since 1988.

But who cares?

Many pilots left the VH sector for the non-VH recreational aviation sectors and that also affected the sustainability of the GA supporting industry. At the same time, airport operators, the only real profitable sector in general aviation, set about pricing private aviation out of business in populous aerodromes near capital cities. Many supporting aviation businesses had built and invested in their premises on airports but were shocked to receive no re-imbursement from airport operators who took possession of their premises and leased it back to them, some at exorbitant costs.

But who cared?

The Regional Aviation Airline Association lists, on their website (RAAA History), the number of AOCs over the years which shows the demise of the AOCs from a high in 1993 to less than half today.

But who cares?

When the CAA was created many senior managers left. This loss of management corporate history changed the legal drive to create a ‘new’ aviation approach, supposedly as a result of a Parliamentary Inquiry in the late 1980s, by inexperienced regulators who created more regulations with no regard to the sustainability of the aviation sectors.

But who cared?

Every Australian government through this period promulgated regulatory development guidelines telling departments & agencies to revert to creating regulations as the last resort, but CAA/CASA prioritises the creation of regulations.

But who cares?

Australia, like most advanced aviation countries, has developed a very complex set of rules and regulations for aviation safety. They are the product of a long running (and continuing) process of incremental adjustments stifling the industry.

But who cares?

Each major regulatory change has affected the sustainability of various sectors of aviation. 1988 changes affected private owners more than any other sectors, thus forcing many owners out of the VH aviation sector into either the less regulated recreational sector or out of aviation altogether.

But who cared?

  • Certainly not the government or the CAA/Civil Aviation Safety Authority (CASA) who have continued to create regulations ever since the CAA was formed.
  • CASA (proudly) admits that aviation is now regulated to be only second to the number of taxation regulations/requirements.
  • Obviously CASA thinks every participant in aviation cannot be trusted to be safe and are criminals waiting to be caught.

But who cares?

Private GA was a ‘cottage’ industry that complied with ‘standards’ mainly promulgated in ANOs and then CAOs. Regulators, pre CAA, knew that administrative costs had to be kept to a minimum so private aviation survived. Post 1988, regulations more applicable to airline operations have been applied to GA and has crippled the ‘cottage’ sector.

But who cared?

More recently the move to overlay the airworthiness engineering processes with the EASA system, made more restrictive, has already seen a reduction in jobs.

But who cares?

The decline in growth in GA, compared to increase in registered aircraft, especially in the private sector, is unique to Australia because GA private is growing in New Zealand who took a different regulatory approach than Australia in the early 1990s. GA decline has virtually stagnated over the last 10 years and a lot of people now think that is the norm for GA though more aircraft were registered during that period.

But who cares?

GA is still very active in the USA where minimal regulatory impositions are applied. Since the creation of the Civil Aviation Act and Regulations, the steady growth in aviation changed and the decline started. The number of personnel and organisations involved in engineering and maintenance is dependent on the number of operators and private pilots actively participating, especially in GA. Those sectors are diminishing. The Charter, Aerialwork and Flying schools also declined. We are in crisis.

BUT WHO CARES?

In 1994, the Morris Report listed the number of participants in aerial work, Charter and Flying Schools were significantly higher than the numbers in last year’s CASA Annual Report.
The 1994 list provided to the Morris Report per State & Total compared to 2015 numbers.
* Asked CASA for aerial work figures but no reply – guess 150-200 by some participants?

1. Twenty six years of regulatory and administrative changes that have not been based on “sustainability” – this is what raises the ire of participants.
2. Regulatory reform based on “safety” without including “sustainability” has one outcome for GA – reduction in participants.
Note: The Searle Report in 2008 identified the same issues raised in the ASRR.
The Second Report of the Air Safety Regulation Review Task Force also identified similar issues in 1990.

WHO CARES:

Every industry association that has members in GA sectors are aware that GA can grow IF the FAA system is adapted correctly to Australian GA. The FARs would need to be very compatible with NZ to align with other NAAs in the Pacific region. The NZ system is based on the FARs for the non-airline sectors without the FBO system.
e.g. it would mean adopting FAR Parts 61, 91, 43 as “standards” for the non-airline sectors.

Implementing an Australian variety of the USA Fixed Based Operators (FBO) using a whole of government legislative approach is feasible. The US FBO system is controlled by their Department of Transport through their airport funding model that does not exist here.
Refer FAA AC 150/5190-7, Minimum Standards for Commercial Aeronautical Activities.
Adopting a FBO system where some organisations would not need CASA approval as long as they employ appropriate CASA licenced personnel can be done.

amroba
* CASA approval may be retained for some levels
** CASA approval may be retained for some aerialwork?
Instead of the ‘airports’ setting minimum standards for businesses they permit to operate on their airport, industry sector representative associations could assist with creating minimum standards acceptable to CASA to be applied nationally.
USA FBO specialized aviation service operations include aircraft flying clubs, flight training, aircraft airframe and powerplant repair/maintenance, aircraft charter, air taxi or air ambulance, aircraft sales, avionics, instrument or propeller services, or other specialized commercial flight support businesses.

Based on the US FBO system, independent CASA licence holders could work in an FBO not approved by CASA such as:

  1. How many FBO flying training organisation would exist if CASA did not approve them?
    a. Must be an Australian registered business – WHS etc. apply to businesses.
    b. Can employ an independent flight instructor (same as FAR 61)
    c. The same FBOs may employ a LAME to maintain their aircraft.
  2. How many FBO * maintenance organisations would exist if CASA did not approve
    them?
    a. Must be an Australian registered business – WHS etc. apply to businesses.
    b. Must employ a LAME or LAMEs to maintain aircraft.
    c. Aircraft operating for passenger carrying AOCs excluded.
  3. How many FBO aero clubs would there be if CASA did not approve them?
    a. Can employ independent flight instructor for training.
    b. Can employ a LAME for maintenance.
  4. How many FBO** aerial work operators would exist if CASA did not approve them?
    a. Must be an Australian registered business – WHS etc. apply to businesses.
    b. Aircraft must be certificated for the purpose.
    c. Pilots must be rated to fly such aircraft.
    d. May employ LAME to maintain their aircraft.
  5. When could an independent flight instructor or LAME work outside an FBO or CASA approved operator/organisation?
    a. Privately provide flight instruction.
    b. Work directly for a private owner who provides the data, equipment, tooling, etc.
    c. Work directly for a business aircraft owner who provides the data, equipment,
    tooling, etc.
    d. All work on non-retractable aircraft?
    i. Excluded from major repairs and modifications.

To overcome possibility of safety concerns, the move to the FBO system should rely on FBOs being members of a particular industry sector association, who would be able to provide advice to meet the industry sector minimum standards as suggested in the FAA AC above. Instead of airports setting the standards, the Associations would develop these in conjunction with CASA. One industry sector standard.
All FBOs would need to be Australian registered businesses to meet WHS (safety) requirements. Compliance with a new CASR Part 43 encapsulating FAR 43 & FAR 91, Subpart E and FAR 61, independent flight instructor provisions would need to be adopted.

To achieve such a major change, industry needs to be involved to ensure the impacts on industry would be sustainable and encourage participants’ grow.

 


 

29 Oct ’15. PM hours.

Steve Hitchen, Editor, Australian Flying Magazine, commented online about the TAAAF Medial Release. In addition, he mentioned CASA’s immediate response. For media enquiries contact Steve on 0447 636 450 or email: stevehitchen@yaffa.com.au,

TAAAF Communique urges Reform Speed from CASA

The Australian Aviation Associations Forum (TAAAF) has expressed concern at what they say is the slow pace of reform at CASA and costs imposed by new regulations.

TAAAF members highlighted their issues in a communique to industry released today. “Recently introduced CASA regulations are threatening the viability of industry and especially general aviation operations, with millions of dollars required to be invested for no commensurate safety gains,” the communique stated.

Although supporting CASA Director Mark Skidmore’s directive on developing risk-based regulation, TAAAF members said they believed the directive would become effective only after cultural change happened at CASA, and called for immediate actions on legacy regulation now coming into force.

Specifically, TAAAF called for:

  • CAO 48.1 on flight and duty times to be withdrawn due to lack of hard supporting evidence
  • An industry task force to propose urgent amendments and exemptions from CASRs 61, 141 and 142
  • Manufacturing regulations to be brought in line with the US FAR system
  • New maintenance training regulations to be reviewed in order to repair the damage to industry caused by the loss of three TAFE training colleges.

“While there is some good work being undertaken by CASA, it is being hindered by the massive problems caused by legacy regulations only now coming into force.

“TAAAF believes that now is the time for definitive action before the new regulations cause irreparable long-term damage and the loss of jobs and businesses.”

CASA Responds – CASA later issued the following response to the TAAAF communique.

“As TAAAF members would be aware CASA is currently actively consulting the aviation community on a range of issues including proposed new aerial work regulations, proposed new operating rules, the best ways to implement future regulations and the development of Flight Plan 2030. Extensive consultation with the aviation community on a range of key issues will continue. CASA welcomes feedback from all sectors of the aviation community and will look carefully at all constructive suggestions.

“Earlier this year the Director of Aviation Safety wrote to all pilots asking for feedback on the new licensing suite of regulations, with more than 100 people responding. CASA has been working methodically through the issues raised and has been addressing unintended consequences. Changes have been made to address specific issues such as firefighting operations.

“Because the ATPL flight test is a new requirement, CASA Flight Training Examiners are available to facilitate the conduct of these tests while industry delegates transition to gaining the required privileges and the tests are built in to industry training and checking programs.

“Also, a special CASA forum is being held in November for aviation organisations developing or planning to develop a fatigue risk management system. The aim of the forum is to ensure there is a mutual understanding between CASA and aviation organisations of the requirements and expected outcomes of a fatigue risk management system.

“CASA is committed to listening to the legitimate concerns of the aviation community and we will look carefully at the suggestions being made by the TAAAF.”