Morris Aviation Report and Analysis

Four key features were found to be limiting factors in the Committee’s examination of aviation safety, viz:

“the absence of robust indicators on the safety of aviation or the performance of CASA; the paucity of information on low capacity RPT and the general aviation sectors; an inadequate approach to those sections of industry that exhibit the characteristics of destructive competition; and rampant distrust between the regulator and certain sections of the industry and within CAA/CASA itself.”

The Evidence Submitted to the Committee

The Committee was dismayed by the denigration, venom and viciousness in the evidence submitted, which was found to range from the good, through the not so good, to the nasty. Some sought to use the Inquiry as a forum for airing complaints and there was evidence of misrepresentation in facts in some submissions. Evidence put to the Committee on the question of whether safety had degenerated over the last decade varied from “standards have fallen disastrously” (Australian Licensed Aircraft Engineers Association), through “safety standards/levels have been reduced so that they are closer to the regulated margins” (second Terrell Report), to “there has been no change in safety levels of commuter and general aviation operations, over the last ten years (CAA).”

With evidence and opinion varying to that degree it is understandable that the Committee sees the need for “robust indicators of safety performance” against which safety performance can be measured. With this in mind CASA was asked for performance indicators for its surveillance programme, the “Australian Safety Surveillance System” or ASSP which was introduced on July 1 1994 as the means of assessing all the parameters of the safety regulation disciplines.

The response was that the objectives established for the programme will be assessed in June of this year. The Committee was doubtful as to the ability of CASA to undertake an objective assessment of ASSP and that outside assistance should be sought.

In its conclusions on the level of safety, the Committee found that “there was limited information on inputs, no information on outputs and limited information on outcomes. The accident statistics are of limited use and there are no surveys or safety indicators that can be used as effective alternatives to the statistics. In short, there is a scarcity of measurement of safety.”

30 Australian Aviation March 1996

The Industry

The GA industry situation has been neatly summed up in the Committee’s conclusions that “there is a prima facie case in support of the destructive competition hypothesis. In GA it is a case of too many aeroplanes chasing too little business for too little return thus putting pressure on operators to reduce maintenance expenditure, with adverse effects on safety”.

Seeking a solution to this problem, the Committee has developed a proposal that CASA publish serious deficiency reports monthly, naming the operators. It is proposed that this commence this March, starting with charter operations which is the area of greatest concern.

Whilst this proposal has merit, it has been noted with concern by the industry. With the emotive political and general media reaction to anything remotely reflecting on the level of safety in aviation it is understandable that there is a worry that such a system would be open to misinterpretation by the public, through media hype and by those who would use it for possible political gain.

It would very likely be a case of one strike and you’re out; if nothing else, it would certainly achieve a rapid thinning of the ranks of operators! Perhaps an alternative which would provide some measure of control over such a proposal would be a review panel interposed between CASA and direct publication of the names of offenders. Such a panel would have to have independent professional advisers and would have to act quickly on each occasion.

The Regulatory System

The Committee in its deliberations on the regulatory system has drawn attention to the differences in operating standards, flight crew standards and the equipment that must be fitted to an aircraft, all dependent on the category of operations. These standards are progressively reduced from high-capacity RPT, through low-capacity RPT (commuter), GA charter, aerial work, private operations, and down to sports aviation requirements. At present, the travelling public appears to be unaware that the same aircraft can be maintained and operated to varying standards depending on whether it is on a scheduled service ie RPT, or charter.

An associated matter raised during the inquiry was the question of “codesharing” in which a smaller airline uses the two-letter designator code of a larger airline to list its flights in an airline reservation system. Concern was expressed to the Committee that to an uninformed passenger this might imply that he/she is flying within the larger airline’s organisation whereas such is not normally the case. A passenger might well end up on a charter flight having commenced his or her journey with a high-level RPT operator.

With this in mind, the Committee believes there is a need for passengers to be better informed of the type of service(s) they are buying, through operators and ticketing agents providing the following specific information: the name of the operator/carrier providing the service(s); the type of operation, ie high-capacity RPT, low-capacity RPT, or commuter; the type of aircraft; and a complete, meaningful and easily comprehensible explanation of the different levels of regulated safety for the different types of operations.

This information should be made available for all flight sectors, offered at the point of sale and should be clearly presented in a prominent place on all tickets. (The idea of noting the level of safety on the ticket was first suggested by Dick Smith several years ago.)

One interesting suggestion raised by the Committee was to state clearly on airline tickets the operational status of commuter aircraft when using a primary airline’s codeshare flight number. (Randall Krebs)

Firstly, whilst this is a commendable attempt to educate the public, one wonders whether the Committee really believes that passengers would firstly, read what is on their ticket (how many read and understand the fine print on their ticket now?) and secondly that they would appreciate the differences in the regulated levels of safety. What will the reaction be when the word gets around to the proposition that whilst all aircraft are safe, some aircraft are safer than others? What will be the effect on the industry? Will there be a demand through consumer pressure for all aircraft to be designed and maintained to the same high standard? If this occurs it will surely force many operators to the wall since they will not be able to afford to upgrade their aircraft fleet. One certain outcome would be a massive rise in GA charter rates.

Bogus Parts

Conflicting evidence was heard on the issue of bogus parts. CASA stated that there is enough evidence overseas to indicate that there is a worldwide pool of parts for which documentary evidence of authenticity and serviceability is either nonexistent or inconclusive. CASA then stated that although it is believed that some of these parts are in Australia, the Authority has no black and white evidence of their use.

Notwithstanding this, examples of specific instances of bogus parts being discovered in country were tendered by a number of witnesses attesting to the fact that the problem is apparently entrenched.

Counter evidence was tendered however, that manufacturers have a vested interest to ensure that their parts are installed despite the fact that the same item might be produced to the same standard but to a lower cost by another organisation. Interestingly, allegations of restrictive trade practices versus free enterprise over the “bogus parts issue” were made in an advertisement in The Australian newspaper subsequent to the release of the Inquiry Report.

The Committee reached the conclusion that there is a clear need for an audit to target bogus parts in maintenance organisations similar to the audits conducted by the US Department of Transportation.

The Civil War Within the CAA

The Committee has devoted a whole chapter in the report to the “civil war” which raged in the CAA from the commencement in 1990 of the radical changes in its structure, brought about by its then Chairman, Dick Smith. The then CAA CEO Frank Baldwin, shared the Chairman’s zeal for reform in what some critics have termed a slash and burn programme of micro-economic reform, or in modern parlance, downsizing. Baldwin described his brief as “to take the CAA — an inert, centralised, bureaucratic edifice — and turn it into an efficient customer orientated business enterprise”.

Factors which influenced this course of action were Dick Smith’s well-known criticism of previous aviation administrations (refer his Two Years in the Aviation Hall of Doom report), the Government’s determination to make the CAA into a GBE with the industry to be forced to pay for its own regulation.

What was missing in this economic rationalisation was the human factor. Alarm was raised both within the CAA and by industry that the whole process was being forced along too quickly and that the CAA was rapidly being de-skilled. A natural outcome was the infighting that took place as sections within the CAA sought to maintain their authority and status. The popular media and those with a political axe to grind fell on the discredited Authority like jackals attacking a wounded animal.

In its conclusions on this most unfortunate aspect of the safety issue, the Committee has stated: “The directions for the future are clear. There is a need for the re-emphasis of process and the measurement of outcomes, something which is lacking even today. But above all there is a need for effective consultative decision planning, bolstered by a high quality industrial democracy plan”.

Summary

In regard to the adequacy of air safety standards and compliance with those standards, the Committee reached the conclusion that “the public should have full confidence that the standards are adequate”; however in the matter of compliance, the picture is by no means clear.

The Committee is critical of CASA’s confidence in ASSP (which is to be reviewed (validated) in June 1996) and is of the opinion that CASA “does not have all the programme evaluation skills to undertake the review. The evaluation should be undertaken by people with skills in programme evaluation and should cover the articulation of clear and achievable objectives, relevant strategies and appropriate performance indicators which can be used to measure performance over time.”

The next report will cover unfinished matters including flying training, sports aviation and ultralights, Section 20A of the Civil Aviation Act 1988 and the impact of Government charges on air safety.

Comment

The Standing Committee has produced a useful and detailed report into safety in the commuter and general aviation sectors, however its task was not made easy by the need to carefully sift the evidence to attempt to get at the truth.

In general, its recommendations call for an expected tightening up all round with two specific recommendations which have direct relevance to the travelling public, that is monthly publishing of serious deficiency reports and specific ticketing information.

It will be interesting to see the outcome of these two recommendations should they be adopted.

There is no doubt that the CAA’s successor, CASA needs time and space to settle down and sort itself out. Unfortunately, AOPA, the leading general aviation industry body, under its new leadership has decided to adopt an aggressive, denigrating approach to the new Authority. In commenting on the Inquiry Report, the Senior Vice President of AOPA, Boyd Munro, has taken the opportunity yet again to aggressively attack CASA over the ELT issue (see p 23 Dec 95 AA).

There is little doubt that in the light of hindsight, CASA would have taken much greater care with its use of statistics to support the case for C91a ELTs (refer ELT story elsewhere this issue); it unprofessionally left itself wide open to attack on this one, but that doesn’t call for the vituperative outpourings against it that we are now seeing regularly in the AOPA magazine.

One wonders whether the AOPA membership as a whole is comfortable with the organisation’s new ‘fight at all costs’ style or would prefer to give CASA a go and a chance to settle down; the Inquiry Committee particularly noted the mistrust between CASA and AOPA and views the situation with great concern. Most within the aviation industry will agree with the Committee.