[Peetwo]

ASAP - Spot the disconnect...

Have been tasked by Aunty Pru and the BRB to undertake a review of Chester's latest cynical attempt to placate/obfuscate the GA & Airline industry Alphabets and their concerns, through the formation of the CASA administered Aviation Safety Advisory Panel (ASAP) forum.

I say 'cynical' because as we all know the ASAP does not include either AOPA or AMROBA:

In order to establish the widest possible industry representation and expertise, the following individuals will serve as members of the ASAP for a period of two years, from 1 July 2017:

• Mr Rob Sharp, Group Executive, Virgin Australia
  
• Mr John Gissing, Group Executive, Qantas Group
  
• Ms Caroline Wilkie, Chief Executive Officer, Australian Airports Association
  
• Mr Greg Russell, Honorary Chair, The Australian Aviation Associations Forum (TAAAF)
  
• Mr Jim Davis, Chairman, Regional Aviation Association of Australia and TAAAF member
  
• Mr Michael Monck, Chairman, Recreational Aviation Australia and TAAAF member.
  

The Group Manager, Aviation Group and Group Manager, Stakeholder Engagement Group will represent CASA.

However it is worth reading the ASAP Terms of Reference as it would appear that there is some possible wriggle room for Carmody to rectify Chester's vainglorious effrontery and bias against these two vital GA Alphabets:

3.1 ASAP membership consists of between six and ten individuals representing the aviation community who have agreed to serve as members, plus two representatives nominated by CASA.

3.2 The CEO/DAS will seek membership nominations in order to establish the widest possible industry representation and expertise and invite individuals to serve as members of the ASAP for a period of two years.

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3.4 To ensure there is a sufficient number of qualified members on the ASAP at all times, individual appointments may be made for different terms in the first instance to allow for staggered tenures.

    
Hmm...think I can feel an Aunty Pru/BRB sales pitch coming on...

I also found the TAC section of interest:
   

5. Technical Advisory Committees

5.1 The ASAP may establish Technical Advisory Committees (TACs) for referring specific issues within an industry sector, subject matter or domain for advice.

5.2 Where established, TACs will provide a forum in which broader industry members and relevant technical experts can provide their input to the ASAP on specific technical issues and proposals.

5.3 Members of the TACs serve without remuneration and accept that they, or the organisations they represent, will bear the costs involved in their participation in TAC meetings and related work.

5.4 On the initial establishment of the ASAP, the TACs will reflect the former Sub‐Committees of the Standards Consultative Committee.

5.5 On the initial establishment of the ASAP, the interim members of the TACs will reflect the existing membership of the former SCC Sub‐Committee.

5.6 Any TACs will be tasked by the ASAP directly and do not determine their own work programs.

5.7 For minor technical matters where urgent advice is sought, the tasking can come directly from the CEO/DAS, following consultation with the chair of the ASAP.

"...will reflect the existing membership of the former SCC Sub‐Committee..." 

Despite Chester's intent to isolate and marginalise the AOPA/AMROBA engagement with CASA, those two Alphabets feature more than once within the former SCC sub-committees, see here:

Former Standards Consultative Committee (SCC) sub-commitees archive

The content on this page is provided to assist research and may contain references to activities or policies that have no current application.

The former SCC sub-committees were:

• Airspace and Infrastructure Users Group
  
• Aviation Medical Standards
  
• Certification and Manufacturing Standards
  
• Flight Crew Licensing Standards
  
• Maintenance Standards
  
• Operational Standards
  
• Sport and Recreational Aviation Standards
  
• Unmanned Aircraft Systems (UAS) Standards
  

Last updated: 19 September 2017 P2 comment: Passing strange that the webpage has just been updated today -    

    
Within the SCC sub-committee webpages I note that with the exception of the Medical and UAS standards sub-committees, according to the agenda item and meeting minutes the committees have been dormant for 2 or more years. This is despite there having been many regulatory review issues that these sub-committees would normally have been consulted on...

In reviewing the last minutes (1 April 2014) of the Operational Standards sub-committee - Meeting 28 minutes - I noted a number of significant agenda items still not resolved and/or very much relevant to today's regulatory environment...

Item 3. CASR operational parts updates and discussion

3.1 Stuart Jones gave a presentation on the development and progress of CASR Part 91.

Discussion followed the presentation. Dick MacKerras asked whether there would be any further consultation on the Part. John Grima indicated that there would be no further consultation as the consultation process had been completed and feedback from the previous processes had been incorporated. CASA is obliged to conduct a PIR and this will be the next phase of formal consultation.

Some further discussion ensued regarding the strict liability drafting style, including how to reconcile the inherent conflict between strict liability and promoting a safety culture. CASA is obliged to follow Government policy on legislative drafting, so this is a matter for the Commonwealth to consider...


3.5 Stuart Jones then presented on the proposed CASR Part 135...

...Part 135 proposes that operations to remote islands must nominate suitable alternate. Dick MacKerras said that it was difficult for operations to meet requirement for alternate for Cocos-Keeling, and should be different to other islands because of distance away.

3.6 Dale South then presented on Draft CASR Part 138

Part 138 applies to both aeroplane and helicopter aerial work (AWK). It is proposed that Part 119 AOC holders (for air transport) will also need a Part 138 certificate to also do aerial work operations, but it is envisaged they could structurally include aerial work procedures under the coverage of their exposition, particularly if there is a cross over with aircraft and crew. The issue though still remains regardless of where these are contained they must comply with the Part 138 requirement and would be subject to the conditions of their 138 certificate if one was needed for the task performed. The Part 138 structure should remove the need for CASA to issue exemptions, especially for low-risk operations.

Part 138 includes provision for an ‘AWK passenger’ in addition to a task specialist. A task specialist is not a passenger, and is defined as being essential for conducting the aerial work purpose. They would be suitably trained in safety actions. AWK passengers may be those who are made aware of risks and those who don't have the opportunity to be made aware of risks associated with AWK operation (eg a person being recovered from the sea in a SAR operation).

AWK passenger definitions would only apply in relation to the AWK activity, potentially in an approved ‘AWK Zone’ for example firefighting operations; when transported by air at other times they would be air transport passengers. This Aerial work passenger policy relates to concept of informed consent. Similarly, police operations involving taking people into custody during a tactical police operation would differ from flights which are regularised prisoner transport.

Medical transport operations are proposed to be regulated as Air Transport. NPRM on this was released last year and the summary of responses is currently being drafted.

It is likely that some relief will be made in the operational Parts in relation to some AT standards. This then becomes more aligned with other countries' categorisation, which useful as the AOC would be also recognised overseas.

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5. A320 operations on 30m runways (in particular the Sunshine Coast upgrade) – (Ron Stacey, AFAP)

Ron Stacey queried the building work at the SC airport. He advised he was concerned that runway excursions continue to occur and the building work represents a higher level of risk if aircraft leave the runway. He does not agree with the policy of leaving the decision to operators to use narrow runways based on flight manual supplements.

Ron advised he will make it known that these runways shouldn't be used by aircraft which he believes require wider runways. Ron advised doesn’t believe that simulator models provide an accurate simulation of actual performance of aircraft. He also doesn’t believe that the relative cost of runway upgrades is significant. He said that pilots should not be blamed for running off of a narrow runway.

David Yeomans indicated that the SC airport master plan was available on-line, including substantial runway discussion.

Mal McGregor indicated that Part 139 of CASR is generally consistent with Annex 14. Airport design no longer requires nomination of a ‘model aircraft’ for which the runway is suitable.

Miles Gore-Brown indicated that CAR 235A and CASR 139 require operators to upgrade to ICAO standards. What CASA is doing is in agreement with what Ron is saying, but de-linked from aircraft operations. Not all aerodromes can be upgraded as some were built prior to the implementation of aerodrome codes. B737 and A320, and other aircraft have manufacturer-approved flight manual supplements that allow them to operate on narrow runways too. All have demonstrated maximum crosswind limits, but some have theoretical limits which puts pilots in a ‘test pilot position’.

 
There was obvious heated but constructive debate amongst the Operational Standards sub-committee this I believe is a good thing and hopefully after a 2 year hiatus the TAC process can get back on track under the new ASAP system.

However I fear the effectiveness of such industry engagement forums will be severely compromised if the Chester prejudice against AOPA & AMROBA is allowed to continue...

For those interested the following is a summary with a link provided for the minutes of the 1st ASAP meeting held on the 4th of September:

Aviation Safety Advisory Panel meeting - 4 September 2017

4 September 2017

The Aviation Safety Advisory Panel (ASAP) held its inaugural meeting today, in Sydney.
Professor Pat Murray, independent Chair of the ASAP joined Shane Carmody, CASA’s Chief Executive Officer and Director of Aviation Safety in welcoming the panel members, including representatives from industry and CASA.

Role of the ASAP and panel members

Members supported the role of the ASAP in providing the Director of Aviation Safety with informed, objective high-level advice from the aviation community on current, emerging and potential issues that have, or may have, significant implications for safety and the way CASA performs its functions.

Members agreed that the panel would consider issues from a whole-of-industry perspective rather than the specific interest of individual sectors.

Consultation and engagement

Members reinforced the need to streamline the consultation processes and recast engagement with industry.

The panel recommended that CASA close out the current structure of supporting committees to the former Standards Consultative Committee (SCC) and move quickly to seek expressions of interest from industry members interested in contributing to future engagement. The panel emphasised that the work of any supporting technical groups must be guided and tasked by the ASAP to ensure alignment with agreed strategies and priorities and that reporting procedures to the ASAP be developed.

Regulatory program priorities

The panel endorsed CASA’s drive to complete the regulatory reform program by December 2018 acknowledging the need to balance risk, simplicity and timeliness.

Guiding principles

The panel reviewed CASA’s guiding principles for development and implementation of safety regulations (as originally outlined in the DAS Directive issued in 2015) and agreed they formed a sound basis, but asked that they be refreshed with a view to stronger emphasis on:

• risk analysis forming a fundamental tenet of assessing the approach to safety regulation
  
• ensuring simplicity/clarity in the principles to effectively support the exercise of discretion
  
• considering 'uniqueness’ of the Australian environment an exception rather than a default
  
• recognising that timeliness is an important factor.
  

Immediate priorities

The panel supported a number priorities that needed quick resolution. These include:

• medical certification standards for pilots
  
• radio frequencies for use in low level uncontrolled airspace
  
• validation of the principles underpinning planned reform of the flying operations regulations (Part 91, Part 119, Part 121, Part 133, Part 135, Part 138)
  
• future policy directions to safely support growth in drones
  
• concluding the outstanding actions from the aviation safety regulation review (ASRR).
  

The panel considered that the work of any supporting technical groups must be guided and tasked by the ASAP to ensure alignment with agreed strategies and priorities.

Next meeting

The ASAP will meet again on 22 November 2017.

Meeting minutes

ASAP meeting minutes, 4 September 2017

Last updated: 19 September 2017

MTF...P2