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Comment now on proposed self-administering rules


DWF

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From the latest CASA Briefing:

 

Comment now on proposed self-administering rules

 

It’s time to comment on detailed proposals for a new approach to the regulation of self-administering aviation organisations. CASA has proposed clarifying, simplifying and modernising the arrangements for self-administering aviation organisations. Current arrangements are complex and are based almost entirely on exemptions rather than positive rules. The proposed changes would allow existing self-administering aviation organisations to continue to operate as long as they meet the relevant new standards. There would be a stronger legal framework for self-administration, providing a modern, efficient and effective alternative to conventional regulation. A notice of proposed rule making on the issue says self-administration is not self-regulation as CASA retains oversight of the organisations. Under the proposed new framework an approved self-administering aviation organisation would have a direct regulatory relationship with CASA under a specified set of largely outcome-based regulations. The proposed rules are designed for the sport and recreational aviation community. This includes light recreational and microlight aircraft, gliders, hang gliders, parachuting, paragliders, recreational ballooning, warbirds, gyroplanes, model aircraft, rockets and kites as well as amateur- built and experimental aircraft. Part 149 envisages the potential for bringing a growing range of self-administering aviation organisations into this regulatory framework.

 

Find out more about the self-administering proposals and comment before 21 October 2016.

 

 

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"CASA and industry representatives have been involved in the development and formulation of the proposals contained in this NPRM" and included model aircraft (MAAA), rotorcraft (ASRA), balloons (ABF), gliders (GFA), parachuting (APF and ASA) and even the Air Sport Australia Confederation (ASAC) [of which RAAus is NOT a member] BUT NOT RAAus!

 

 

Why not!

 

RAAus is a RAAO that is probably bigger than the rest of those organisations put together - and should have had input into the development of the proposal.

 

It will certainly significantly affect our organisation.

 

 

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On a second read, it looks like CASA are putting another step between them and litigation.

 

RAA was not mentioned because we are already self administrating.

 

Lets say a builder of an oversize R/C aircraft wants permission to operate his model.

 

At present he needs an approval and permit from CASA. If things go pear shaped with his model, both the owner and CASA

 

are prime targets for litigation.

 

But if the MAAA becomes Self Administrating, the builder would apply to the MAAA for permission and approval, then if it goes pear shaped, the Owner

 

and MAAA are prime targets, and CASA can claim immunity, because they didn't need to know, but as a Regulator, they will now take action.

 

 

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RAA was not mentioned because we are already self administrating.

I'd suggest RAAus must be involved in the development of the Part 149 MOS.

 

- Firstly, has the organisation has experience in the field they can provide valuable input

 

- secondly and more importantly, to influence the development t of the MOS so it doesn't contain any unreasonable requirements.

 

It's too late to try and change the rules after they've been developed.

 

I have experienced this in the Part 61 reg's, there are organisations who should have made subject matter experts available during the development of the various Part 61 MOS, instead we are now trying to repair things with exemptions and 61.040 approvals.

 

 

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I'd suggest RAAus must be involved in the development of the Part 149 MOS.- Firstly, has the organisation has experience in the field they can provide valuable input

- secondly and more importantly, to influence the development t of the MOS so it doesn't contain any unreasonable requirements.

 

It's too late to try and change the rules after they've been developed.

 

I have experienced this in the Part 61 reg's, there are organisations who should have made subject matter experts available during the development of the various Part 61 MOS, instead we are now trying to repair things with exemptions and 61.040 approvals.

I agree.

 

RAAus needs to take a long hard look at the NPRM to ensure, as far as possible, that we agree with or can live with its contents and requirements - and fights hard to remove items that are not in our interest.

 

RAAus has been self-administering for quite a while and should have some idea of how the system does and/or should work.

 

Let's try to help CASA get it right this time - before it is too late to amend and we end up with another Part 61 debacle.

 

 

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I agree.RAAus needs to take a long hard look at the NPRM to ensure, as far as possible, that we agree with or can live with its contents and requirements - and fights hard to remove items that are not in our interest.

RAAus has been self-administering for quite a while and should have some idea of how the system does and/or should work.

 

Let's try to help CASA get it right this time - before it is too late to amend and we end up with another Part 61 debacle.

Agree, but RAAus may have missed the boat! The opportunity to have input, as taken up by the GFA, Balloon Federation etc, has been missed. It will be difficult to make any significant changes now, it would arrogant to expect so.

 

 

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Agree, but RAAus may have missed the boat! The opportunity to have input, as taken up by the GFA, Balloon Federation etc, has been missed. It will be difficult to make any significant changes now, it would arrogant to expect so.

Let's be arrogant - or at least assertive. What have we got to lose?

 

 

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Maybe more effort in working with other industry groups and CASA developing the 149 reg's and less on internal administrative matters is called for?

You can't build empires by working with other empires unless you plan on conquering them!

 

 

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