CASA NPRM 1502SS comments period expires 21/10/16

[JEM]

Just a heads up for members interested. Has everybody had a look at this NPRM and commented to CASA.

 

CASA NPRM 1502SS is said to have the potential to effect most aircraft owner, pilot and maintainer members. The draft for comments and submissions period expires/is due by this Friday 21 October 2016.

 

 

[turboplanner]

Ah good, a day to comment, and I've just finished a one hour presentation where about 3,000 pages had to be checked and commented on to catch the cunning trucks of the villains, the latest ojne being, when I say something is black; "There's nothing in there to say it's not white".

 

 

[JEM]

Hot off the CASA press 4.50pm today

 

Part 149 consultation extended to 28 October

 

At the request of the aviation community, consultation on the draft Part 149 regulation and Manual of Standards (MOS) will stay open for an extra week to allow more time for feedback.

 

The extension will help ensure all interested organisations and individuals have sufficient time to review the proposed changes to the arrangements for approved self-administering aviation organisations and provide their considered feedback.

 

Click here to view the draft regulation and MOS in Notice of Proposed Rule Making - NPRM 1502SS and submit an online response.

 

Consultation will close on Friday 28 October.

 

 

[dsam]

FYI, the formal RA-Aus response to CASA NPRM 1502SS is now on the member website for all to read. I've only scanned it quickly, but it looks like it highlights many valid concerns, and is highly critical of CASA (not very surprising...)

 

Who knows whether CASA will take any notice of the numerous concerns, but I would hope that RA-Aus also give the Minister (Hon. Darren Chester) a personalised briefing on the matters at hand, rather than him just listening to the CASA mandarins advocating for their own warped view of things.

 

 

[poteroo]

Part 149 is CASAs' preferred option for administration of RAAus and similar bodies. Unfortunately, their proposal is, unsurprisingly, heavily weighted towards them holding the reins of power ever more tightly. The era of strict liability is not over, and if we think that CASA is softening its' approach to 'little aircraft' - then think again.

 

I've carefully read the RAAus response, and I believe it is sufficiently constructive, whilst indicating that RAAus isn't about to roll over and have its' tummy tickled.

 

The major issue is in the CASA reference to its' Manual-of-Standards, (MOS). Other MOS that I've seen are written in such a prescriptive format that they become almost laughably impossible or impractical. (Part 61 is hilarious in parts! You wonder what they were on!). Key Proposal 2 from RAAus indicates that RAAus is concerned as to the value of an MOS.

 

A not unanticipated clause in the NPRM allows for CASA to terminate any agreement with RAAus for a number of reasons. As is their wont, CASA play the 'safety' card whenever they want to belabour the industry with their big stick, and they have it included in the Part 149 proposal. Essentially, it allows CASA, pretty much on the slightest whim, to suspend RAAus from any further activity. (their famous Friday afternoon fax at 16:55 telling you to cease operations under a show cause excuse). Good to see we are awake to this, (Key proposal 6), and, whilst conceding their ultimate power in the game, we are stating a requirement for meaningful consultation prior to any decision.

 

Thats' the extent of my reading of the RAAus response, and I must say that I'm pleased we are now committing our concerns to paper before the event.

 

happy days,

 

 

[dsam]

Now that Mr. Skidmore has left CASA, one wonders whether there is anybody left in that organisation that is worth RA-Aus engaging with in a rational conversation?

 

There is probably more to be achieved by lobbying the Minister, and other Senators that have shown they understand the many problems.

 

CASA itself, would seem to be the ultimate definition of an "unmovable object", sadly.

 

 

[turboplanner]

I would've looking at how much in YOUR day does CASA intrude. That might lead to asking why others have problems, and what problems they may be.