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Disunity Is Disaster.


walrus

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Noting the SAAA submission to the Senate RRAT and the RAAust response. All I can say is disunity is a disaster. I’m a member of both organizations. 

 

It would be nice to harmonise regulation and standards if we could keep the best of both organisations. Regrettably, I think we are more likely to end up with the worst features of each; eg. stricter medical requirements for everyone, less access to controlled airspace for all, $800 data packs for registration. etc., etc.. 

 

‘None of this sounds like a win/win situation.

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From what I saw on the recent AOPA/SAAA video there is is a push for all recreational flying (not just ultralights) be brought back to CASA. Looking for simpler and cheaper flying (ie no membership or registration fees) own maintenance and self declaration medicals. Instructors to play by the same rulebook and essentially make self administrators (RAA ASRA etc) redundant. That's what I took from it. Link to the chat below.

 

 

 

Edited by waraton
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I couldn't be bothered to listen to all the AOPA video. I see that they have a new chief, but watching the beginning he didn't get into putting his case very early. Hence I turned it off.

I have attended AOPA seminars and usually came away feeling that they take half an hour to deliver 5 minutes worth of info. They just go on and on.

Maybe they have something to say this time, but I would like someone else to tell me what it is.

I was an AOPA member 50 yeras ago and lapsed because I thought they were whingers, rather than doers. I rejoined about ten years ago and put up with it for a year. It is a pity that SAAA haven't put their case to the general public, or even their members.

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The AOPA/SAAA stance is to be commended. The elimination of the ghastly ASAO's like RAAus and GFA is good thing. At best they are run by well meaning, enthusiastic amateurs and have accident/incident rates well above GA. In the case of the GFA for sure, "well meaning" is on thin ice.

 

CASA needs to properly shoulder its Parliamentary given responsibilities and administer all of civil aviation, not just bits of it. we all fly in the same airspace

 

The disunity at present is caused by CASA's scheme of dividing private and recreational aviators into silos. It is bad for safety as it prevents much cross flow of safety  information and divides political lobbying efforts to achieve more reasonable regulation like owner maintenance (the results of that are in in Canada and acknowledged by the FAA) and simplified, less onerous medicals like the self declaration/private motor vehicle licence.

 

Back in 2003 CASA floated a discussion paper on the Recreational Pilot Licence. It was to have no medical beyond the driver's licence and acknowledged that, while some people would be disquieted by that, there was no evidence that the Class 2 medical had any beneficial effect on safety. The proposal was that you could get endorsements for various classes of aircraft - gliders, ultralights, GA types etc. All very sensible. If people were happy with their existing exemptions/organisations these would be unaffected. So what happened?

 

The GFA's Bob Hall and Henk Meertens along with RAAus's Paul Middleton set up a meeting with the Minister, John Anderson and told him they didn't want a bar of it and to kill it, which he did. This can only have been to maintain their organisations' funding, power and influence, not anything to do with the the interests of people who just wished to fly. Probably the single greatest act of wanton destruction in the history of Australian sport aviation.

 

Hence we now have an RPL with a medical standard the same as a Class 2 but with silly arbitrary restrictions. No, Basic Med does not relax these requirements in any way. "Medical reform" was a blatant lie.

 

Anyone who thinks by joining GFA or RAAus is "getting out from under CASA" is sadly mistaken. Both organisations owe their continued funding, powers, influence and very existence to CASA. CASA approves their rules manuals.

 

These organisations don't need operating manuals or even existence to fly gliders and ultralights. The day VFR bits of Part 91 will do just fine. Launching gliders can be taken care of with a small addition.

 

The CASA Licencing Medical standards can be taken care of with a small change to Part 61: The holder of an RPL who intends to fly aircraft of gross weight less than X (currently 600 Kg) or gliders/motorgliders of less than Y (currently they are limited to 850Kg and there is no strong reason at all to increase this) needs only a declaration in writing that they hold a State Private Motor Vehicle Driver's Licence. CASA is to be notified in writing if this no longer applies.

 

Likewise the maintenance regs can have the same provisions with Owner Maintenance. THEN we can talk of raising weight limits.

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Owner maintenance is now permissible in EASA land on private ops aircraft up to 2760kg. I wonder if CASA made a submission in the rule making process as all NAA's are invited to respond. If they did I wonder what it said. Mike Borgelt's point about keeping the various organisations apart is well made and typical of many bureaucratic approaches to problem solving - keep the interested parties apart to stop them presenting a unified position that may have political clout.

Some may talk about liability as an issue but the CASR's already contain a provision in relation to experimental and limited category aircraft saying that "Neither the Commonwealth nor CASA is liable in negligence or otherwise for any loss or damage incurred by anyone because of, or arising out of, the design, construction, restoration, repair, maintenance or operation of a limited category aircraft or an experimental aircraft, or any act or omission of CASA done or made in good faith in relation to any of those things."

If it can be done for those aircraft categories it can be done for aircraft under 600, 760 or 850kg.

On medicals, despite all the evidence CASA has ignored the approaches taken in the US and UK to wind back the medical requirements that have their roots in the military of days gone by.

On the subject of Licencing, aside from examination of the basis principals of navigation, examination of navigation/flight planning skills should reflect the technology of the day by testing the use of Avplan or Ozrunways. Afterall, when was the last time you purchased paper maps and other required docs?

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And another thing.... The performance and capability of 600kg. limit aircraft is rapidly approaching and perhaps surpassing larger/heavier GA types, at least as far as a value proposition is concerned. There is also the emergence of the “STOL’ market segment - people who want to keep right away from airports of any kind, that seems to be appealing to a younger demographic. What this means to me is that the boundaries between GA, experimental and RAA are going to be further blurred. Without some harmonisation, absurdities are going to proliferate.

 

In addition CASA is, in my opinion, unlikely to be able to keep up with the technology driven performance changes. For example, according to what I’ve been told, AsA will occasionally agree to a request for non entitled RAA aircraft to traverse controlled airspace. Similarly certain non TSO avionics are accepted for some tasks. UAV’S are going to add to the confusing mix as well. Then there are glaring. holes in parts of the regulations themselves.....

 

 

 

 

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On 09/10/2020 at 7:57 PM, walrus said:

Noting the SAAA submission to the Senate RRAT and the RAAust response. All I can say is disunity is a disaster. I’m a member of both organizations. 

 

It would be nice to harmonise regulation and standards if we could keep the best of both organisations. Regrettably, I think we are more likely to end up with the worst features of each; eg. stricter medical requirements for everyone, less access to controlled airspace for all, $800 data packs for registration. etc., etc.. 

 

‘None of this sounds like a win/win situation.

That’s how life goes Sunny;  each group has quite different operations and needs. W

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7 minutes ago, turboplanner said:

 each group has quite different operations and needs.

That's the BS that CASA perpetuates. How is it that the USA can have the multitude of operations WITHOUT anything resembling Part 149 organisations, with a higher density of operations, worse climatic extremes and a generally more challenging terrain? And they are not alone!

All airspace users have to play by the same set of rules, CASA has an effective delegation system and it is not beyond the wit of a regulator to rationalise the sports and private ops arrangements.

The only real challenge CASA has is its snail paced approach to aviation regulation. If they had been running the COVID response they would still be writing the NPRM on defining the disease!

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16 minutes ago, Jim McDowall said:

That's the BS that CASA perpetuates. How is it that the USA can have the multitude of operations WITHOUT anything resembling Part 149 organisations, with a higher density of operations, worse climatic extremes and a generally more challenging terrain? And they are not alone!

All airspace users have to play by the same set of rules, CASA has an effective delegation system and it is not beyond the wit of a regulator to rationalise the sports and private ops arrangements.

The only real challenge CASA has is its snail paced approach to aviation regulation. If they had been running the COVID response they would still be writing the NPRM on defining the disease!

You should apply for the DAS job Jim.

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Bloke I know applied for the job of DAS when it was open last time or the time before. Got an interview and was asked" What is the first thing you would do as DAS?"

 

"Fire all you baskets".

 

Needless to say he didn't get the job.

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No, the different groups do not have different needs and requirements. Back asswards as usual, Turbs. The different rules exist BECAUSE there are different organisations all seeking to justify their own existence.

 

Let's go back to what we are trying to achieve:

 

1. Protect innocent third parties on the ground from having flying machines or ones that used to be until recently, fall on them.

2. Protect other legitimate airspace users including passengers.

3. You could add protect people from themselves but that is a slippery slope and isn't the intent of current regulation. Don't go there.

 

Currently we have a complete dog's breakfast of rules. GA aircraft require maintenance by Licenced Workshops and LAME's, pilots require a Class 2 or Basic Med (same medical standard). RAAus and Gliding require self declaration/Private motor vehicle licence medical standards. RAAus can have owner maintenance unless for training. Gliding requires maintenance qualifications with ridiculous hours of training required. RAAus has 600Kg weight limit, gliders 850Kg. Gliders can fly in controlled airspace without a Class 2 medical or equivalent for the pilot. There are more.

If anyone can find a QUANTITATIVE risk analysis of all this, please let us all know. What a shambles.

 

 

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Well the more relevant answer is that we really are talking about 40,000 people in this discussion, and then you have another 40,000 people in commercial aviation you have to take into account if you are flying through commercial airpsace (which can include IFR VH aircraft at low levels).

 

You really can't just look at the activities of two in isolation if you want to go down that path.

 

Here is some interesting information from CASA:

 

Sport Aviation – Sport Aviation Bodies

Sport aviation covers almost half the aircraft operating in Australia. It involves about 40,000 participants, more than 9000 aircraft and 360,000 parachute jumps each year.

Sport aviation offers a wide range of activities and is an economical way to take part in aviation. It also provides a proving ground for new aviation concepts and technology.

The Australian sport aviation industry includes manufacturers, training facilities, organised competitions, and enthusiasts who all contribute to growth in Australian aviation.

Are you new to sport aviation?

Sport aviation offers a wide range of aircraft and activities. Many of the aircraft are not designed or built to any recognised civil aviation standard and many of the activities are only allowed through exemptions to the regulations.

A person who takes part in this form of aviation is defined as an informed participant*. Participants in sport aviation do so for their own enjoyment and as such, may need to be a member of an approved self-administering organisation.

Find out more about being an informed participant in sport aviation.

Participation in sport aviation is mostly limited to private flying and flying training to obtain a certification. There are other operations that can be approved by CASA for these aircraft, however require separate approval.

Find out more about the different types of sport aircraft.

Sport aviation and what it covers

 

What is informed participation?

Informed participation in sport aviation relies on the premise that before you take part or pay for an activity that you are fully aware of the potential risks and consequences.

This may include asking questions of the operator, researching their website, checking with the relevant self–administering organisation/s, further research on the internet, in other literature such as CASA or ATSB publications, or simply by discussing with other participants.

However you inform yourself of the risks, it is important that you consider the consequences of the intended activity, which may include death or permanent disability as worst case scenarios, and how this would affect you and your family.

Do people have to understand and accept the risks?

Yes. Before you undertake a sport aviation activity as an informed participant you may:

  • have to read and sign a document acknowledging you have been told and understand the risk involved in that particular activity or
  • be given a verbal brief or presentation on the risks for that particular activity.

Depending on the type of aircraft there may also be a warning placard indicating that CASA and the self-administering organisation do not guarantee the airworthiness of that aircraft and all pilots operate these aircraft at their own risk.

This means that you need to accept the risks of flying in, or jumping from, the aircraft as an informed participant and be aware of the potential consequences for you and your family.

 

*Informed Participant

What is informed participation?

Informed participation in sport aviation relies on the premise that before you take part or pay for an activity that you are fully aware of the potential risks and consequences.This may include asking questions of the operator, researching their website, checking with the relevant self–administering organisation/s, further research on the internet, in other literature such as CASA or ATSB publications, or simply by discussing with other participants.

However you inform yourself of the risks, it is important that you consider the consequences of the intended activity, which may include death or permanent disability as worst case scenarios, and how this would affect you and your family.

Do people have to understand and accept the risks? Yes.

Before you undertake a sport aviation activity as an informed participant you may:

  • have to read and sign a document acknowledging you have been told and understand the risk involved in that particular activity or
  • be given a verbal brief or presentation on the risks for that particular activity.

Depending on the type of aircraft there may also be a warning placard indicating that CASA and the self-administering organisation do not guarantee the airworthiness of that aircraft and all pilots operate these aircraft at their own risk.

This means that you need to accept the risks of flying in, or jumping from, the aircraft as an informed participant and be aware of the potential consequences for you and your family.

As a start to what the legal implications of an Informed Participant are, the Tort of Negligence in Victoria is regulated by the Wrongs Act 1958 and case law.

 

 

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CASA claims as to the number of participants is overblown and can only be accounted for by including a guess as to the number of model aircraft flyers who are not allowed to operate near airfields - but then they cant be counting aeromodellers as if that was the case there would be more aircraft.

Leaving aside warbirds as they are VH registered aircraft not operated under the 95 series of CAO's you would be lucky to have 20,000 participants, let alone ACTIVE participants.(In the same way all the members of your local footy club don't play football). As to the claim of 360,000 parachute jumps - simply fantasy.

ATSB knows that hours flown by GFA and RAAus aircraft that they report are fictitious but it suits the cosy little game that CASA, ATSB and the ASAO organisations play to support each of their agendas.

No one is talking about "commercial airspace" as the majority of us fly VFR and have no desire to fly in controlled airspace. As to interacting with IFR aircraft we already do that outside of controlled airspace. This is not a REAL issue in the regulation (de-regulation?) of recreational aviation discussion.

 

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As an ex public servant we were always interested in the metrics.
One politician for each 60k voters etc. One police officer for every 350 civilians.

I wonder how many CASA employees there are for say 20,000 pilots?

Using the police metric, 58 is plenty!
Ken

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Just under 900 In CASA for a handful of fatalities per year. Compared to SA they should be able to handle 25 fatal accidents in one year and then complete them within 1 year. Not the 2 plus Years that it takes at the moment.

Ken

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1 hour ago, Kenlsa said:

ATSB and Air services is about 4.5k so that is about 5,900 employees for 20,000 pilots. Wow, each one is responsible for 3.4 pilots!

Ken

Now you've added the equivalent of all the road authoities on top of police, plus the Councils involved in oad construction and maintenance. 

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2 hours ago, Kenlsa said:

Compared to SA they should be able to handle 25 fatal accidents in one year and then complete them within 1 year. Not the 2 plus Years that it takes at the moment.

It is my understanding that ATSB sometimes investigates GA accidents and makes recommendations to CASA for their consideration. This arrangement diffuses responsibility and keeps the blood of CASA's hands (so to speak).

So the question is what do 900 employees actually do? especially those in the sports aviation branch.

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There are just under 2 million Federal, State and Local govt employees for 24 million  Australians ——1 for every 12.  
So with the aviation “public service industry” running at 1/3.4 they are over 3 times bigger than the average or need to be.

This was called “building castles” in our sector.

Seems too many Workers for too little Work..

Ken

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1 hour ago, Kenlsa said:

There are just under 2 million Federal, State and Local govt employees for 24 million  Australians ——1 for every 12.  
So with the aviation “public service industry” running at 1/3.4 they are over 3 times bigger than the average or need to be.

This was called “building castles” in our sector.

Seems too many Workers for too little Work..

Ken

We live in clown world. This is truly insane.

If you add in the unemployed and people on the pension it just leaves me an a couple of other people doing all the work.

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