Revenue raising with carbon

The government’s aviation policy actions continually underscore this elemental misunderstanding.

Many policies – including the white paper – ignore the fact that much of aviation business takes place on thin margins. More importantly, there is little understanding that people in the industry persevere because, despite what the government thinks, they are making a vital contribution to the wellbeing of the nation.

From protecting crops to saving houses in bushfires and all of the other varied but essential activities of GA, aviation is a critical component of the Australian economy.

People who seek to regulate and tax industries should actually spend time getting some experience in those industries so policy miscues such as the latest aviation tax hike do not cause unwarranted damage.

Aviation is based on small businesses as well as a few large ones, and so the charge of ‘big polluter’ simply doesn’t stand up to scrutiny. The aviation fuel levy hike of around six cents per litre ignores the fact that aviation only accounts for about 1. 5 per cent of total Australian emissions. Aerial application operations account for less than 0. 03 per cent of Australia’s carbon emissions.

The most cynical element of this grab is that the government is fully aware – thanks to previous submissions by AAAA and others – that aviation cannot adopt any alternative behaviour because of the lack of certified biofuels or engines to run them.

Add to that the already efficient use that every ag aviation company makes of expensive fuel thanks to the pressures of the last eight years of drought, and clearly the fuel levy hike has everything to do with revenue and nothing to do with the environment.

To expect that after so many bad seasons a sector such as aerial application has any option but to pass a significant new tax onto clients is the stuff of the magic pudding.

If the overall tax will not cost most householders anything, then how does the government expect it to act as an incentive for behaviour change? And how does the government possibly imagine that the tax on aviation fuel and eventually heavy transport fuel will not flow through to Revenue raising with carbon every household that buys food and other essential products? But the piece de resistance of policy ineptitude is that the tax will also apply to firebombing aircraft – who are actively engaged in extinguishing bushfires that add directly to Australia’s carbon footprint. The same goes with aircraft involved in mitigating oilspills.

It is great that the RFDS and EMS received a reprieve after industry lobbying – but why not extend the principle to at least those aircraft actively reducing our carbon footprint, like firebombers? This inanity is accompanied by the complete exemption of ‘agriculture’ from the carbon tax, but a decision that applying agricultural products by air is taxable.

AAAA has written to the Prime Minister seeking such an exemption for agricultural and firebombing operations, and has made a submission to the Senate inquiry looking into the carbon tax.

However, without any fundamental understanding of aviation on display by anyone in government, without sound consultative structures such as a ministerial council as other industries enjoy, and without any policy that seeks to promote, develop or encourage aviation, AAAA remains deeply concerned.

CASA GA Task force CASA has established a General Aviation task force and the first cab off the rank is the aerial application sector.

AAAA cautiously welcomes this as a development with a lot of potential for improvements if handled with an eye on improving efficiency and reducing the burden of poor regulation on industry.

Given AAAA has a lot of runs on the board with programs like our Standard Operations Manual, Chief Pilot Training Courses, Professional Pilot Program, the Aerial Application Pilots Manual, safety courses and the Aerial Application Management System, it makes sense for CASA to open up the task force’s work with aerial application.

A vertical integration approach to all regulations that cover aerial application would also be welcome, especially as AAAA has been sitting on committees like the proposed Part 61 – Licencing for about ten years with little to show for it so far. A more consistent approach to competencies, exams, supervision and training is long overdue. The relatively straightforward inclusion of rotary aerial application into Part 137 would also present some opportunities for simplification and improvement.

Hopefully, it may also mean an opportunity to fine tune CASA programs such as the bureaucratic nightmare for small operators that is the Drug and Alcohol Management Plan.

So while it is very early days, AAAA is optimistic that this initiative could bear fruit and provide a model for how a regulator can engage with a sector to create win-win opportunities.