A_F_2015_03_04_

it is possible to guard against a
foreseeable risk which, though
perhaps not great, nevertheless
cannot be called remote or fanciful,
by adopting a means which involves
little difficulty or expense, the failure
to adopt such means will in general
be negligent” but CASA ignores
the “little difficulty or expense”
to industry and regularly fails to
provide a Cost Benefit Analysis or
Regulatory Impact Statement (RIS)
to provide a balance between actual
statistical risk and cost to industry.
Did you know CASA exempted
itself from a RIS for the change from
GAAP to Class D “because it will
have only a low impact on business”?
Airservices extra ATC staffing alone
was estimated at $3 million – who pays
for that “low impact” in the ultimate?
Consistency and safety? As but
one example, despite my drawing it
to the attention of John McCormick,
CASA went ahead with expensive
change to instrument calibration for
general aviation aircraft but ignored the
instruments of RA Aus aircraft flying in
the same airline shared airspace because

RA Aus is not under the “Civil Aviation

Regulation 1988, Part 4, Airworthiness

Requirements.” So we need to ensure

separation between airliners and

general aviation aircraft by instrument

calibration but exempt RA Aus aircraft

sharing the same airspace?

Safety first? Another example: the

big-brother-knows-best removal of

safe working approved Non Precision

Approaches from GA airports not

certified or registered – because

obstacles might suddenly jump up

overnight in the approach path.

Obvious consequences are scud

running to get home (that’s OK we can

blame pilot error if a crash even though

we know “get-home-itis” is a reality) or

home- made approaches in the GPS

User Database, far riskier than the

original NPA. Where is the trust in

the airfield operator to manage his

airport and monitor the surrounds?

I’ll throw another one in even

though Mark doesn’t mention ethics.

The RIS provided to the Minister for

the equipage mandate for Mode S/

ADS-B transponders - something

very expensive for general aviation

as it funds savings for Airservices

and the airlines - contained the

very misleading statement “A major

benefit of ADS-B for Australia is

that it provides complete airspace

coverage allowing air traffic control

to accurately view and track

the locations of aircraft across

Australia.” We all know ADS-B

does not cover much of Australia

below 10,000 feet altitude and this

was pointed out before the RIS went

forward. The RIS was not changed

and only under pressure did CASA

later publish clarification on their

website (does the Minister read

that?) after the incorrect RIS was

approved “with an apology for any

confusion this may have caused ”.

General aviation is not thriving

because CASA adopts a regulatory

and punitive approach and a “one size

fits all” rule set based on ICAO and

airline guidelines (ICAO actually

allows discretion at local level). The

FAA manages a larger fleet with

more discretion for general aviation

and even Europe has seen the light

• at the November 2014 EASA
  conference the focus was towards
  achieving a more proportional
  approach to GA via a framework
  focusing on safety culture, safety
  promotion and common sense!
  To be honest, the words of Patrick
  Ky, the new executive director EASA,
  gave me far more inspiration than
  Mark ’s comments in the CASA
  Briefing. EASA is now committed to
  changing the way it manages general
  aviation and wants to action the real
  safety problems in the most effective

13

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I suggest we all know the

above ideals are unmeasurable

and unmanageable