White paper or white flag?

The amount of improvement required between the green paper and the final product may simply be too large for the Government to bridge, especially as engagement with industry in the interim has been either a one-way street or non-existent.

Contributory reviews and discussion papers on insurance and airports provide little comfort that the Government has heard industry. The suggestion for a mandatory third party insurance scheme for all aircraft seems to ignore other parts of the policy framework that largely address the same issues – and this is likely to be another cost imposed on industry for little to no tangible benefit.

The White Paper still has the potential to map out a policy agenda that could breathe new life into aviation, but it needs to be based on freeing-up potential rather than a new series of restrictions and costs.

Some of the suggestions AAAA has put on the table include giving trainee pilots access to HECS , establishing and funding a national database and mandatory reporting for tall structures such as wind monitoring towers, and improved tax measures including income averaging and accelerated depreciation to encourage updating of the fleet. Submissions identified real steps forward that would assist the industry, make a difference to safety and cost the government very little.

CASA has come in for a lot of attention through the White Paper process, but AAAA has been encouraged by the new management approach that seems to have a clearer understanding of strategic direction and some of its own shortcomings. The ongoing debacle of the regulatory reform program – which has been characterized by on again/off again directions, a lack of resources, staff churn and the legal drafting bottleneck in Attorney General’s department – will not be easy to resolve.

However, a huge amount of work has already been done on parts such as 91 (General Operating Rules), Part 61 (Licencing) and even Part 133/138 (Rotary Ops). Someone will eventually realize that you never get draft regs 100% perfect and that it is often best to put regs out that cover all the safety aspects, but ensure a review and refinement within the first 12 months.

The experience with Part 137 was exactly that – although now it appears that the promised review has stalled – despite the industry already operating to one major essential exemption. AAAA’s advice is to get the reg as close as you reasonably can, ensure you will not create major safety issues and then promulgate, review and repair as necessary. Otherwise, it will be another decade before we realize the benefits of simpler regs, some of which were originally drafted almost 10 years ago. We are already seeing the need for some drafts to go back through the Regulatory Impact Statement requirements.

The content of the white paper will be judged by the level of uptake of practical and outcome-focused suggestions from industry and by the real difference it is likely to make to the future of the industry.

An underlying tenant of AAAA’s submissions has been the importance of Government engagement with the industry it seeks to regulate and hopefully assist to be more innovative and sustainable.

If government – including Ministers, advisers and top bureaucrats – expect to really understand industry while remaining isolated from it, they are kidding themselves. They run the real risk of placing themselves and the future of the industry in the hands of consultants who are not really independent, may not be aware of current industry best practice and who may bring their own agenda to the table. This is particularly unnecessary when there are professional associations like AAAA who represent a significant proportion of the industry.

The odd speech at national conferences – while a valid message delivery system – is not real engagement. Real engagement goes in both directions. Genuine understanding comes from spending time actually seeing what industries do.

So after the white paper coming and going, it will still be critical that government people get out of their offices and come and see what industry actually does. It will remain incumbent on industry to stimulate and facilitate this engagement – but it must start with a change of heart at the highest level to actually understand what industry does and how it does it.

Without ongoing and genuine engagement, the white paper is more likely to be a flag of surrender.

AAAA Convention 2010

The AAAA Convention for 2010 will be held 8-9 June at the Holiday Inn, Surfers Paradise, Queensland. Details will be on the AAAA website over coming months.