[Peetwo]

Comardy/Boyd to KC - "Up yours mate!"


Reference post via Mount NCN thread:

 KC & AMROBA on ASRR R21 & R22.

Somewhat related I note that KC put out a paper that confronts the lack of progress on ASRR R21 & R22, while putting forward a suggested model that embraces the concepts and principles of an ICAO civil aviation system organisational structure:

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I note that in Oz Flying today, Hitch draws attention to the fact that Boyd and presumably the majority of the board, including Comardy, have categorically rejected COO and ASRR recommendations 21 & 22... : 

CASA says it can deliver better value from a more agile approach rather than establishing small regional offices. (CASA)

CASA rejects Regional Offices Recommendation
12 May 2017

The Civil Aviation Safety Authority has said that it won't establish small regional offices as recommended in the Aviation Safety Regulation Review (ASRR).

Recommendation 22 of the ASRR stated that CASA should consider establishing small offices at specific industry centres to "improve monitoring, service quality, communications and collaborative relationships."

In its response to the ASRR, the Federal Government noted the recommendation, but did not agree with it, referring it to CASA instead.

"CASA has been reviewing the value of small regional offices," a CASA spokesperson told Australian Flying. "We are aware that industry wants CASA to be efficient and consistent in the delivery of our regulatory services and that these services are provided without increased costs.

"We believe we can deliver a better outcome for less cost. This includes adopting a risk based approach rather than increasing our office footprint. 

"We are exploring adopting a more agile approach where we will deploy staff short term to work with industry wherever they are required on an operational and safety needs basis."

The government ASRR response linked the recommendation to Recommendation 21, which suggested that CASA needed to change its structure to a "client-oriented output model", something that CASA says it has done through establishing the Stakeholder Engagement Group and the Industry Relations Branch within that group, and the Client Services Centre within the Sustainability Group.

However, the regulator has not at this stage ruled out establishing a general aviation unit under any future re-structure, a concept raised by the government response and not included in the original ASRR recommendation.

Read more at http://www.australianflying.com.au/lates...VSMR8JR.99

  
So once again our unelected, self-serving aviation safety bureaucracy goes against the wishes of the industry, the Alphabets and indeed their 'elected' political masters err Muppets...

Yet another example of where CASA obfuscate their responsibility of truly addressing the industry 'trust' issues that were highlighted in many of the recommendations in the ASRR...

Remember the weasel worded regulatory philosophy - https://www.casa.gov.au/about-us/standar...philosophy - but then we are still yet to see the deletion of former DAS McComic signed Enforcement Manual foreword, that contains his 'black letter' embuggerance dispensation:     

Embuggerance according to Carmody..Oliver..err McComic

Without prejudice; (or even a dog in the fight).

P2 – “Interesting that Comardy is sitting in the position of the decision maker?

It is to hoped that the position ‘decision maker’ (Hoods old job) is vacant; if so, it will one of the very best decisions Carmody ever made; if not ‘the’ best.

P2 – “Will this now be SOP for all 'show cause' enforcement actions or has Carmody sacked anyone else who can make such decisions?”

Dunno mate; but for Carmody’s sake, lets hope he is not basing his decisions on the ‘Enforcement manual’; unless of course he has signed it and now owns it as his very own. I wonder how a serious legal challenge would fare against any ‘action’ taken against a person based on that dreadful ‘McConvict’ drafted section. I reckon that would be ‘interesting’.

Seventeen days after the crash, CASA acting chief executive Shane Carmody wrote to Mr Rhoades to say his air operator’s certificate was suspended immediately because, as chief pilot and business owner, he had allowed flying that “contributes to or results in a serious and imminent risk to air safety”.

All a bit too ‘subjective’ for my taste. I’d expect most reading here have operated in ‘turbulent’ conditions, most have probably operated passenger flights in aircraft without a cockpit door; done ‘joy flights’ and ‘scenic flights’ or even back in the day, ‘commuter’ flights. How would you like a beer in the fridge for every time you’d heard a passenger ‘scream’ or similar when you hit the bumpy bits; or when you level off and come back to cruise power, or ‘crank it over a bit’ so folk can see what they came to see? It is, IMO perfectly understandable that folk are ‘nervous’ when confronted with a tiny, one engine aircraft, a stranger for a pilot and all ‘crammed’ into the small area allotted. The noises (engine and airflow) all perfectly acceptable to the ‘pilot’ heighten sensitivity, and any ‘abrupt’ change of ‘state’ increases the tension level. It is a fair bet that at least one of three passengers in a C172 just did not want to be there anyway. In defence of this pilot, it would be reasonable to argue that unless one of the passengers was an accredited pilot, capable of ‘judging’ the manner in which the flight was handled; then hearsay evidence from passengers is not only worthless, but prejudicial. If this fellah has been ‘acting the goat’; then by all means, string him up, after proof beyond reasonable is accepted by the court.  

"The flight, including the wail of the stall warning horn, is recorded in a video taken by a passenger and recovered by police."

These Qld CASA chaps do seem to like their ‘video’ evidence; the Quadrio matter is not forgotten and there may be a line of defence in those ‘images’ and recordings of ‘passengers squealing’.

Mr Carmody wrote that the video showed Mr Woodall flying at 150-200 feet; risky, because if something went wrong such as engine failure, “he would have only minimal altitude, and therefore (minimal) time, to safely manage the upset”.

Precautionary search? Seems like a very ‘safe’ precaution to landing ‘on the beach’. I would say that not to do so was certainly a risk. The procedure should be cast in stone in the company operations manual; that would be mandatory. Accepted or ‘approved’ by CASA is academic as CASA approve the Air Operators Certificate and by extension – the operations as writ. Had this fellah not done a PS and had an event on the ‘strip’ then crucifixion would be in order. Again the intent to be unsafe can be discredited, a saving of an additional five or perhaps six minutes operating costs could be avoided by ‘skipping’ the PS. So it comes back to just what is ‘unsafe’ and who is making the judgement.

Mr Carmody criticised what he called “aerobatic manoeuvres”, saying the recording “includes an audible ‘squeal’ from a passenger at the beginning of the abrupt pitch inputs”. The CASA chief said Mr Woodall should have kept up his airspeed after the engine failed, not risked a stall by banking hard, and landed on water if necessary. He alleged the plane’s fuel supply might have been contaminated by debris.

Try to define ‘aerobatic’ in this context. Provided the aircraft was not operated outside of the specified envelope, then a steep turn, or whatever is quite legal. A badly executed ‘manoeuvre’ may demonstrate a lack of skill and/or judgement; but can it be considered ‘dangerous’ without the benefit of a 'G' meter record? It is all very well to say Mr Woodall ‘should’ have done this or that after the event, indeed most pilots who have been involved in any sort of ‘event’ can recount exactly what they ‘should’ have done; and would do, if it ever happens again. I wonder if CASA ever mandated a training requirement, specific to that beach area, dedicated to establishing ‘best practice’ in the event of an engine failure, at low level on the go-around after the precautionary search? If not why not, surely that would be ‘proper’ oversight of the safety of the operations approved by CASA.

Perhaps this was a cowboy operation; perhaps not. But consider all the evidence, before pronouncing a sentence.

When we teach someone to fly – what is the noise heard during the flare and touch down? What is the purpose of that noise? Is it absolutely safe to slow the aircraft down to stall warning speed? What does the pilot have at his ready disposal to maintain the speed at which the warning occurs?

Nope, no quarrel with CASA shutting down a rogue, non at all; provided they have got all the ducks lined up and back ‘em up with proof, beyond reasonable doubt; and, perhaps adjust their thinking toward ‘prevention’ rather than prosecution.

My two bob for its worth.

Toot toot.

Ps Embuggerance manual tracking update: Download preface.pdf

It would appear that J Mac is still the real DAS/CEO at Aviation House - UDB!

"..plus ça change, plus c'est la même chose.."  - Alphonse Karr


MTF...P2