Seizing the opportunity

Australia has an enviable record in aviation safety built on a strong regulatory system and a commitment to safety across the industry. This includes the thousands of people responsible for the operation of Australia’s airports, large and small, which are a vital part of our national aviation infrastructure.

The AAA made a number of positive recommendations to the review to ensure that the regulation of our industry keeps pace with the ever-changing nature of our industry.

The AAA has called for a full technical review of the Manual of Standards Part 139 – Aerodromes.

Such an important document, dealing with highly technical and complex issues, requires regular and dynamic review. The industry believes that MOS Part 139 lacks clarity, which has the potential to cause safety risks at aerodromes and amendments must be considered as a priority.

CASA has adopted a new approach to Aerodrome Compliance and Safety Audits with zero tolerance to non-compliance with the standards prescribed in MOS Part 139. This significant change in approach has occurred without prior notification, formal consultation or training and has caused considerable difficulties for many airports with significant investment of finances and man-hours to respond to the non-compliance notices. An increase in stakeholder engagement in relation to any changes to the Compliance and Safety audits would alleviate these difficulties and ensure that any key changes to safety regulation are guided by optimising and promoting safety through a risk based approach.

Aviation in general has always had a very open and productive relationship with regulators. The best safety outcomes will be achieved by industry and the regulators working collaboratively. The AAA has a cooperative relationship with CASA, but is of the opinion that a more formalised approach should be adopted to meet future regulatory challenges more effectively. This can be achieved by establishing a joint working group between CASA and the AAA to work in partnership on the future regulatory requirements and practices for aerodromes in Australia and the development and provision of training services in the area of airport operations.

Enforcement has been shown to work best when there is segregation between those making the rules, those policing the rules and those making determination of actions and prescribing penalties. The current structure of CASA means that the policies are being created by the same agency responsible for the policing and adjudicating. The AAA believes that a separation of the responsibilities of policy maker and regulator from the one agency would provide industry with the confidence to engage with the relevant agencies.

The capacity of an airport to operate as an airport is fundamentally dependent on what occurs on the land surrounding it. The erection of structures that physically intrude into the flightpaths of arriving anddeparting aircraft can clearly limit or prevent use of the airport. There is no uniform regime that requires developments around airports to be subjected to scrutiny to assess their potential impact upon an airport. CASA has limited capacity under Regulations made under the Civil Aviation Act 1988 to approve or not approve buildings or structures in limited areas around airports, but only in respect of Sydney, Bankstown, Moorabbin, Adelaide, Melbourne and Essendon airports. There is need for CASA to have its capacity increased under the regulations to approve or not approve developments that could impact on airport safety.

The AAA recognises the wide scope of responsibilities that CASA has in establishing a regulatory framework, securing compliance with the regulations, issuing certificates and licences and assessing safety-related decisions taken by industry that impact on aviation safety. The resourcing of the regulator to perform all these responsibilities is a key aspect of ensuring that Australia remains at the forefront of aviation safety and the current levels of resourcing within the Aerodrome section of CASA should be increased to meet the growing industry demands.

A key recommendation of the Senate Inquiry into the Administration of CASA and Related Matters held in 2008 was the introduction of a small board to provide enhanced oversight and strategic direction for CASA. The AAA recognises that the present board is comprised of respected and notable individuals, but industry is concerned about the lack of airport management knowledge and experience on the board. In the development of policy and processes the practical implementation of safety regulation is an important consideration. The size of the board needs to be increased to allow greater representation and input from industry. The current size and structure of the Airservices board is a model that could be adopted by CASA and would allow for better cooperation between safety agencies and industry.

Safety is a central theme for members of the AAA and our members are committed to providing a safe environment for passengers, staff and visitors to airports across Australia.

The positive recommendations the AAA has made to the review will ensure that the Australian aviation sector stays on the right track to meet the future challenges that the growing demand on aviation presents to this evolving and dynamic industry.