[Peetwo]

AMROBA latest newsletter: Volume 14 Issue 11 (November 2017)

After the snub that KC received at the hands of Chester, one has to admire if nothing else the stoicism and ability of KC to steadfastly remain on message - makes you wonder if he knows something that we don't because buggered if I'd be putting up with the spin'n'bulldust platitudes and time delaying tactics of this miniscule to date...
 
Via KC & AMROBA:

1. Safety is the responsibility of industry.

The Civil Aviation Act states in Section 9(2) that:-

"CASA also has the following safety-related functions:

(a) encouraging a greater acceptance by the aviation industry of its obligation to maintain high standards of aviation safety,"

When you have a willing industry, why would you not adopt and implement performance based regulations that includes delegated authority as has been incorporated in the modernised FARs?

Refer our recent Breaking News - see: Further TAAAF update & AMROBA latest newsflash - where comparisons with the FAA’s modernised FAR Part 21, including consequential amendments to FAR Parts 45, 43, 91 & other operating regulations that provided significant savings to the industry. The FAA devolved many of their regulatory services to industry recognising the technical and organisational expertise that now exists in industry. Also reduced the FAA overall costs but enhanced safety.

2. Regulatory Reform Scorecards Ups & Downs.

As most reviews look at either the airline or sport aviation, it is time that GA private, small operators and GA charter be put under review. These are the sectors that have stagnated and/or reduced since regulatory reform started in 1990. The government’s policy states: "Our vision for aviation in Australia is to help the industry grow in an environment that is safe, competitive and productive."

A regulatory environment that is ‘safe, competitive and productive’ exists for GA in the USA but not Australia. Adopting the FARs for the non-airline sectors would help the industry to grow in an environment that is also safer than current regulatory standards.

Do we have general aviation private and small operators’ participation that we had in 1990 before reform started? The answer is NO. So the vision to help the industry to grow has been a bureaucratic regulatory reform failure.

3. GA Private & Commercial Aircraft Ops?

To get jobs and growth back into aviation, the aviation regulatory system needs major changes to recognise the difference between private and commercial use of aircraft to make a living.

Private operations not only includes private owners but aerialwork operations and associated maintenance services as well. All of these

operational and maintenance sectors have been swamped with regulatory requirement more akin to airline operations.

Maintenance organisations should be those that are approved to maintain airline operations to those that require no approval from CASA to maintain other aircraft. An organisation not requiring formal approval should still be required to register with CASA if they do aircraft maintenance.

Aero clubs, business aircraft owners, aerialwork operators and individual owners should be able to directly employ an appropriately rated LAME to maintain their own aircraft on condition they provide all the data, equipment and tooling to perform the maintenance.

A CASA registered AMO that complies with all the FAA FBO/SASO standards should be considered – similar to the past approval meeting CAO requirements.

MTF...P2