Confusion and a lack of guidance from Parts 141/142 remain. phil hurst
Old culture
‘We know better than you’ – still
Despite the ongoing calls from the CASA CEO for increased engagement and cooperation from industry, actions by CASA staff continue to prove that the old culture of ‘we know better than you’ is still dominant.
In a ridiculous ‘make work’ and ‘add red tape’ scenario, CASA is now requiring specific mention of ‘firefighting’ on AOCs, as distinct from a broad approval for Part 137 operations, for example. In reality, no additional ‘approval’ is required.
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It is a clear case of added cost and time wasting for no safety gain.
Unfortunately, this is not an isolated example of a few people not getting the ‘change in direction’ message.
CASA still requires even small GA companies to have a head of aircraft airworthiness and maintenance control (HAAMC), even though the Act makes it clear this is not a mandatory requirement.
Regional offices have created a 10‑age quiz on the responsibilities of the HAAMC position and an interview to determine whether the candidate –often the already-approved chief pilot –is a ‘fit and proper person’. This is despite previous written CASA policy not to require this.
Then there is the ongoing fiasco of Parts 61/141/142.
After consulting with AAAA and others in December as part of the new Part 61 Taskforce, CASA produced an exemption for firefighting training that is unusable. AAAA was not shown a draft. This is despite goodwill and a clear and common goal on both sides of the table. It was the execution that failed. That exemption now has to be redrafted and reissued.
The training cost and complexity created by Parts 141/142 is very real. The simple concept of using CASR 61.040 approvals for highly-specialised, low-throughput training, informed by an agreed AMC, is still under discussion, but it is now 18 months since these Parts were introduced and confusion and a lack of guidance remain.
The stubbornness being shown towards genuine industry concerns with CAO 48.1 is simply bizarre. CAO 48.1 will impose massive costs and complexity, ignores decades of safe operations under the previous regime and is inflexible for highly seasonal aerial work. It solves no problem.
Whole-of-government mandates regarding red tape reduction and small business regulation are being ignored.
Additional complexity and costs on industry are piling up thanks to policy, forms and regulations that are not subject to the excellent DAS Directive 01/15.
Two key issues remain –the lack of a deep commitment from some CASA staff for genuine cooperation with industry and the need for systems to stop the crazy independent policymaking at the lower levels of the organisation.
CASA simply does not have expertise in some areas, but rather than building transparent systems to utilise expertise from industry, it is easier to default to the ‘we know better’ culture –despite all evidence to the contrary. Only a centralised policy‑efining area will help CASA realign with risk management, improved efficiency, sound policy-making principles and effective problem solving. Importantly, this area must be open to industry input.
Under such a centralised function, the examples above would simply not stand up to scrutiny. Striking out nonsense developed by regional factions would send a very strong message that would resonate with the Forsyth recommendations, the Minister’s directions, the board’s hopes and management’s claims.
Many of these policies should be promulgated directly and urgently by the CASA board. A good starting point would be a new philosophy of regulation for GA (as put forward by AAAA to the Minister’s GA Action Group) and a classification of operations policy to drive simpler regulations and processes for aerial work companies and pilots. We need a new cooperative paradigm on both sides –not just industry.
The Minister and the CASA board need to get involved and create executive directions that help both industry and CASA –with significant consequences for staff that can’t or won’t comply.
Scholarship applications open
Applications for both the Col Pay Scholarship – for assistance with an application rating – and the QBE Aerial Application Scholarship for research or activities in support of the industry are now available on the AAAA website. What a great start to your application career or a boost for an issue close to your heart! Applications close April 30.
AAAA Convention June 15-16
The annual AAAA Convention, with a full trade show and top speakers, will be held at the Surfers Paradise Marriott Resort, with the two main days being Wednesday the 15th and Thursday the 16th of June. Registration and program are available from the AAAA website – www.aerialag.com.au.
It is a clear case of added cost and time-wasting for no safety gain.
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