- Submission to the Aviation Safety Regulation Review
- Proposed Legislation for Enhanced Aviation Safety Mandatory and Confidential Reporting – Comments by the Australian Sport Aviation Confederation.
ASAC, and the ASAC organisations, have always considered that the independence of ATSB is essential to the achievement of the best safety outcomes. Accordingly, ASAC would not support any change which detracts from this independence, either directly or as an unintended outcome of any proposed change.
The document proposes three overall changes. Two of which were the subject of consultation some time ago.With respect to these previously consulted changes, the view of ASAC, and the ASAC organisations has not changed. ASAC remains of the view that the timelines for notification reports will, from time to time, be a problem for sport aviation and that the drivers for these timelines do not apply to safety occurrences in the Sport Aviation disciplines. ASAC remains concerned that our members may be dependent on leniency in cases where a written report is delayed by circumstances.ASAC has some serious concerns regarding the new proposal for increased access by CASA.
- ASAC RESPONSE TO DP 1102AS – Revised Plan for Navigation and Surveillance Equipage in this Decade
ASAC is very pleased at the response of CASA to the views, and their justification, expressed in the various responses to the previous DP on this subject (DP 1006AS). However, ASAC remains very concerned, and will insist at every stage, that the development and implementation of these proposals are always strictly dependent on a risk management justification, aimed to ensure that the many potential negative effects on Sport and Recreational Aviation, and GA generally, are minimised
Most importantly, ASAC is particularly pleased and encouraged to see the continuation of the ‘general exemption’ for aircraft unable to power, at least until developments in avionics make the removal of this exemption justifiable on a risk management and cost benefit basis (see the ASAC response to DP 1006AS for details).
Nevertheless, ASAC wishes to point out that this general exemption is justified on a risk management basis and not simply the ‘inability to power’ and, as above, ASAC will insist that the imposition of requirements on Sport and Recreational Aviation, and GA generally, must, at every stage, be justified on a risk management basis, and ASAC will not agree – either now in principle, or in future, at implementation – to any mandatory proposals which cannot, or, have not been justified by this risk management basis.
ASAC is pleased at the targeting of the proposals described in the current DP (DP 1102AS), to areas of immediate need, recognising that, for many reasons the ‘big bang’ approach taken previously, has only delayed the introduction of urgently needed and clearly justifiable proposals, including, specifically, IFR operations in WA and the earlier introduction of GNSS navigation, with the consequent cost savings and potential to target CFIT accidents, rather than just MAC accidents.
Finally, on a more general note, ASAC is pleased at the manner in which the carefully crafted, industry wide, consensus views prepared by ASTRA have been taken into account – recognising that these are consensus views and not just ‘another’ view from the industry.
- ASAC RESPONSE TO NPRM 1101CS – Proposed Performance Standards for Aircraft Pressure Altimetry and Maintenance Requirements for Certain Aircraft
ASAC is not satisfied with CASA’s consultation on this issue. The NPRM bundles up a number of issues which do not seem related to the basic proposal for single standard for altimetry. Further, while ASAC understands the logic behind this basic proposal – these changes go way beyond a simple rationalisation of testing standards for altimetry. There appears to have been no consultation regarding the effect on VFR operations, no attempt to outline the safety improvements expected, and no attempt at a risk management justification for these additional costs.
ASAC is aware of and supports the views expressed by AOPA.
- An Approach to Airspace Risk Assessment and Risk Criteria – Sep 09
The Ambidji report on GAAP aerodromes establishes, once again, that the ATM risk outcomes criteria used by CASA are currently dysfunctional and need further development.The use of F/N curves in the report can be criticised as they are based entirely on societal risk criteria, depend on annual frequency of accidents and cannot take account of the size or scope of the system under study. The individual risk criteria produced by DNV (a risk assessment consultancy engaged by Airservices Australia) also takes account of societal issues, and can accommodate differently sized systems, but unfortunately, needs further development to include a rational basis for apportioning allowable individual risk between types of hazard.This paper reports an attempt to combine these criteria by using the DNV individual risk criterion for the critical participant, to provide a rational basis for moving the risk lines – which define the allowable accident rates on the F/N curve – to take account of the size or scope of the system under study.
- REVISION OF THE AUSTRALIAN AIRSPACE POLICY STATEMENT (AAPS) – 24 July 2008
REVISION OF THE AUSTRALIAN AIRSPACE POLICY STATEMENT (AAPS) –
- RISK ASSESSMENT APPROACHES – 4 July 2008
RISK ASSESSMENT APPROACHES
- Submission to the inquiry into the Administration of CASA – 29 June 2008
ASAC Submission to the inquiry into the Administration of the Civil Aviation Safety Authority
and related matters
- TOWARDS A NATIONAL AVIATION POLICY STATEMENT – 27 June 2008
ASAC COMMENT ON ISSUES PAPERTOWARDS A NATIONAL AVIATION POLICY STATEMENT
- Implementation of GPS Based Avionics – 21 June 2008
Implementation of GPS Based Avionics
- TOWARDS A MODERN APPROACH TO SAFETY REGULATION – 17 April 2008
ASAC paper TOWARDS A MODERN APPROACH TO SAFETY REGULATION
- SPORT AVIATION PRELIMINARY RESPONSE ADS-B – 15 August 2007
SPORT AVIATION PRELIMINARY RESPONSE TO:
JCP: Transition to Satellite Technology for Navigation and Surveillance
- ASAC response on Joint Consultation Paper: Transition to Satellite Technology for Navigation and Surveillance – 15 Aug 07
SPORT AVIATION RESPONSE TO:
Joint Consultation Paper (JCP): Transition to Satellite Technology for Navigation and Surveillance
- MAKING ROOM FOR SPORT AND RECREATIONAL AVIATION – 17 May 2007
COMMENT on the AUSTRALIAN ATM STRATEGIC PLAN
MAKING ROOM FOR SPORT AND RECREATIONAL AVIATION
A STRATEGIC VIEW
- ASAC Comment on proposed ADS-B discussion and cost benefit – 2 March 2007
THE PROPOSED DISCUSSION PAPER and RENEWED COST BENEFIT ANALYSIS of ADS-B
COMMENTS by ASAC.
- COLLISION AVOIDANCE PROCESSES for SPORT and RECREATIONAL AVIATION – 19 September 2005
ASAC Paper on COLLISION AVOIDANCE PROCESSES for SPORT and RECREATIONAL AVIATION
and the APPLICATION of GPS BASED TECHNOLOGY
- Basis For Cost-Benefit Analysis for ADS-B post radar -10 November 2005
Basis For Cost-Benefit Analysis of the Extension of ADS-B Beyond Replacement of Radar
- PROPOSAL TO MANDATE CALLS AT UNTOWERED AIRFIELDSPROPOSAL TO MANDATE CALLS AT UNTOWERED AIRFIELDS –
- Response to the CASA Proposal to Mandate Specific Radio Calls
The Australian Sport Aviation Confederation strongly opposes the recent decision by the CEO of the Civil Aviation Safety Authority to return to prescriptive rule-making in mandating specific radio calls at airfields. (Oct 2008)
- ASAC Comments on the Ambidji Report on CTAF Vs CTAF(R)
ASAC believes that, in order to ensure the continued safety of the travelling public and all aviation participants, the Civil Aviation Safety Authority:a) must not return to outdated and discredited prescriptive rule-making,b) must, based on safety principles, continue to rely on the now proven NAS 2c principles,c) must provide the necessary resources, including pilot Training and Education and improved documentation, to continue to implement a modern risk management and outcomes-based approach in order to retain these demonstrated safety benefits as achieved in other jurisdictions such as the US.
- Mandated radio calls in Class G airspace
ASAC is forced to reject CASA’s Notice of Final Rule Making because the effect of these rules, as now proposed, would be to change fundamentally, all operations in Class G airspace with unknown, but clearly serious consequences, to the safety of the travelling public and all aviation participants.
- Sport Aviation Response to NPRM 0814OS
Sport Aviation rejects the return to prescriptive rule making in the proposed changes to CAR 166 outright.
- National Aviation Policy
ASAC response to the Government’s National Aviation Policy Green Paper
- Radio Calls at Untowered Airfields
Sport Aviation welcomes the decision by CASA to conduct an overall review of the rules and procedures at untowered airfields.
- ASAC response to NPRM on Radio calls at non-towered aerodromes – Oct 09
ASAC, and the ASAC organisations, strongly support the proposed outcome or performance based approach in which the Regulations mandate the desired outcome and advisory material provides the details of the means of compliance.
The strong preference by ASAC, and the Sport Aviation Organisations represented by ASAC, for outcome based requirements for radio use at non-towered airfields has been detailed throughout the consultation process, is well known and will not be repeated here. ASAC points out that repeated, concerted attempts to define prescriptive regulations prove the failure of prescriptive regulations, particularly in this instance.
ASAC rejects the proposal to mandate carriage of radio at all registered and certified airfields as not being based on a sound risk management approach.
In this approach the material in the advisory circulars is critical and ASAC believes that the proposed ACs are clear, concise and well written. However, given that the purpose of these ACs is to define pilot behaviour required to deliver the best safety outcomes, ASAC believes that some aspects of this advisory material need alteration.
- ASAC Response to DP1006AS -Proposed Strategy and Regulatory Plan in support of the Australian Government’s Aviation White Paper
Response submitted by the Australian Sport Aviation Confederation (ASAC) – the Confederation of Air Sport Associations – including the ABF (Ballooning), APF (Parachuting), GFA (Gliding), and the HGFA (Hang Gliding).
This submission represents the combined views of the Air Sport Organisations.
ASAC consents to having its name published as a respondent to the Discussion Paper
ASAC is not satisfied with CASA’s consultation on this issue as the DP was prepared exclusively by CASA without involvement of the relevant SCC working group and the DP presents only one matured option.
ASAC would like it known that ASAC is aware of the content of the very well researched response by AOPA and ASAC is happy to support this response.
- ASAC Response to the Proposed Amended Transport Safety Investigation Regulations 2003
- ASAC Response to ATM Policy Directions Paper
While the Paper correctly identifies the components necessary for an effective national ATM strategy, ASTRA considers that greater attention is needed to the underlying strategic processes and relationships before it is accorded the primacy that this initiative deserves.