AOPA and CASA

[fly_tornado]

Friday, 21th September 2018

 

Mr Michael McCormack MP

 

Deputy Prime Minister

 

Minister for Infrastructure and Transport

 

PO Box 6022, House of Representatives

 

Parliament House

 

CANBERRA ACT 2600, Australia

 

Mr Shane Carmody

 

Director of Aviation Safety, CASA

 

GPO BOX 2005

 

Canberra ACT 2601, Australia

 

Deputy Prime Minister,

 

Further to correspondence sent today to the Civil Aviation Safety Authority and your office, regarding double standards on private pilot medical certification.

 

Quite simply it is either safe or it is unsafe for a private pilot to operate an aircraft with an MTOW of 600Kgs with one passenger outside of controlled airspace. For CASA to assert that it’s risk-assessments have concluded that it is only safe if the pilot is a member of a private company is ridiculous. CASA RPL and PPL holders are trained to a higher pilot standard than their RAAus counterparts and therefore should represent a much lower risk to aviation safety!

 

CASA must now come clean and publicly publish its risk-assessments and explain to the Australian public why it has denied pilots with a higher standard of training access to a self-certification private drivers licence medical. CASA should not be abusing its position and power in forcing unfair and biased aviation safety standards that seek to intentionally disadvantage RPL and PPL pilots, so as to force them into a private self-administration business (RAAus) where they are exposed to monopoly fees and charges that do not exist within the CASA system.

 

There is no doubt that CASA has been influenced into protecting the private business interests of the RAAus, which has reported year on year financial losses, citing stagnant membership growth. During a briefing to their members yesterday at Airventure Australia Cessnock, RAAUs Chairman, Mr Michael Monck, and CEO, Mr Michael Linke, communicated that “…should CASA approve self-certification private drivers licence medicals for RPL and PPL holders, the RAAus would close its doors...”.

 

As a result of this egregious denial of pilot rights, CASA regulated RPL and PPL holders are forced to become customers of a private monopoly business (RAAus) that owns your medical, your licence and your aircraft registration. Pilots are forced to pay fees and charges that are unregulated and are subjected to ad-hoc oversight and disciplinary processes that are at the discretion of the private business and the personalities that run it. And, to prevent pilots from electing to stay within the government regulated general aviation industry, CASA have denied RPL and PPL holders the right to choose by refusing to provide an equal and unbiased self-certification private drivers licence medical standard.

 

Are we now seeing the wholesale corruption of our national aviation safety regulator? Is pay for regulatory-play the way of the future? Why is CASA creating safety standards that disadvantage government regulated RPL and PPL holders, whilst deregulating the rules for a private business to ensure its financial survival? Does any of this pass the pub test?

 

Mr Deputy Prime Minister you must end this abuse of power and demand that all Australian private pilots – regardless of their associations - be regulated equally and fairly. You must announce to the Australian public that any pilot seeking to fly an aircraft with an MTOW of up to 600kgs with one passenger outside of controlled airspace can do so on a self-certification private drivers licence medical regardless of the licence they hold.

 

And, importantly you must affirm to the Australian people that the role of Australia’s aviation safety regulator (CASA) is to provide aviation safety standards that are free of commercial bias and influence.

 

Thank you for your time and I look forward to your reply.

 

Yours Sincerely,

 

BENJAMIN MORGAN

 

Executive Director

 

 

[ave8rr]

This was posted in the AOPA RAA Thread.

 

 

[kgwilson]

Conceptually I agree with Ben Morgan and also with the article by Owen Bartrop in the September Sportpilot. RA-Aus has been pushing all the right CASA buttons with AOPA & SAAA left in the background and RA-Aus jealously trying to hold on to its privileges. This seems to be the root cause of the bitter feuding going on.

 

Aviation need to be separated into "Commercial" and "Recreational" regardless of the aircraft weight or number of engines & seats. Every recreational pilot should have access to CTA with appropriate training & equipment, none should need a class 2 medical. Existing rules can be moulded around this concept, eg 10,000 foot ceiling, IFR & VFR night ratings (which may need medical cert) etc.

 

 

[turboplanner]

The first question for RAA subscribers is whether the two Michaels did in fact say that RAAus Ltd would close its doors subject to not getting their way.

 

The second is whether there was any authorisation from AOPA members for what Ben said.

 

The conclusion of a Minister could well be; this is all too risky, we’ll adopt the safer standard.

 

There are some statements you make to government when you need something, but this isn’t one of them. It could lead to wiping out hundreds of flyers.

 

This is certainly not the measured and responsible AOPA that Facthunter talks about and that I knew.

 

 

[facthunter]

Dunno that the Aust AOPA has always been measured and responsible, Turbs. Often the current (of the time) AOPA Pooh Bah was on a mission based on grudges of a personal nature..

 

I don't think Ben is in this instance. He is taking it to the CASA for the future of GA and when the previous (short lived) CASA CEO was hoist on his own petard somewhat by actions of AOPA and departed abruptly, we can't say the AOPA is not being effective.. Numerous reports have highlighted CASA's shortcomings over a considerable period now and are consistently not being taken notice of. . I warned of the approach by "OUR" (I use the title loosely) organization going down like a lead balloon in proposing to be the New GA. That concept was close to impossible to sell . We may have some numbers but not the standing.in the Industry. Co -operation is required not unilateral action and especially trying to deny a move that is entitled to rightfully apply to all across the Non Airline /RPT segment in principle.. In fact the initial serous thrust came form the SAAA which operates under GA PPL and above licenses and it was a fair while ago now

 

As to whether the AOPA membership have or should have, been asked to approve of Ben's letter , that's not usually how it works but as in the past If the president (or equivalent) acts contrary to the member's wishes they don't last long.. Like it or hate it the AOPA IS the only show in town that can without fear of the consequences tell CASA where they are wrong.. The "Authority" has not been slow to let people know that's what they are in the past. IF you end up in court their self claimed "deeper pockets" will see you off easily every time...

 

The Part of the minister.. Well He's brand new and "WE" are such a miniscule part of his NEW Portfolio I doubt WE will get much real attention. I doubt also HE will have much knowledge now or ever of what U/L flying is about. . HE would be no different from the average Joe (or Joan ) in the street, in that regard.. Being the highest NAT person in the present government, currently, he might have more "important " things to occupy his mind with at the moment . Not a pretty or encouraging picture really . Nev

 

 

[turboplanner]

I think you're right; "aviation" isn't even mentioned in his department's name, so it can't be like the old days where we had a Minister for Aviation.

 

However, that doesn't mean everything doesn't get close attention.

 

That letter will be given to someone with a report date set.

 

Where you have to have extremely careful in what you are saying to a Minister, and particularly this one, is that the person available to check out that issue may be an ex ship's captain, an Infrastructure planner, someone from Albury, of a sociologist good at developing Cities.

 

It's probably never as bad as that, but you can guarantee that the person who gets the job will be investigating whether the letter has any merit first, and could be told anything from anyone.

 

CYA will ensure the information is cross checked before the Minister gets his report, and a lot of unwanted side effects will often float to the surface.

 

 

[Thruster88]

All this fighting has been caused by Raa's we must grow mantra from the two M's. RAA aircraft numbers have been stagnant for the last six months at about 3350, the only source of growth is further mining of the VH fleet. I fly a thruster, beech23 recreationaly with the required class 2 medical, we should all be treated equally, self certification for all rec.

 

 

[jetjr]

and what is CASA agree and say medicals for everyone?

 

Reckon maybe AOPA should focus on looking after its members rather than attacking RAA. Its exactly what CASA want as it then shows clearly that rec flyers are not a single group and can be distracted by a few media releases.

 

RAA have medical exemptions for good reasons, low weight, slow stall speed and 1 pax

 

No discussion I think of no medical for pilots of higher weight IF RAA ever get there

 

 

[Downunder]

The first question for RAA subscribers is whether the two Michaels did in fact say that RAAus Ltd would close its doors subject to not getting their way.

and perhaps whether they were under instruction from the RAA boad and members....

[Roundsounds]

it’s time members of these organisation called for their management to work on a united front to achieve the best outcomes for the industry, rather than playing silly political games.

 

Whether you’re an AOPA, SAAA, RAAus, GFA or any other Sport/GA group I’m sure we just want to go Flying with minimal fuss and cost without all of the political dramas. Whilst these individuals continue to poke each other in the chest CASA will continue to regulate us out of the air.

 

 

[Thruster88]

.RAA have medical exemptions for good reasons, low weight, slow stall speed and 1 pax

No discussion I think of no medical for pilots of higher weight IF RAA ever get there

Without medical exemption no VH owner is going to bring their aircraft to the the RAA, you would still need lame maintenance,the medical plus $400 In fees.

 

 

[Jim McDowall]

a sociologist good at developing Cities.

There has NEVER been a sociologist good at developing cities. Ever since the days of the "Garden City" movement which led to the "planning system" we have today, planning for our communities has been focused on the "touchy feely" rather than the development of infrastructure to reflect the future growth of our towns and cities which has left us with the infrastructure mess we have today. At least engineers with vision like Brunel provided infrastructure which is still fit for purpose today.

 

 

[turboplanner]

There has NEVER been a sociologist good at developing cities. Ever since the days of the "Garden City" movement which led to the "planning system" we have today, planning for our communities has been focused on the "touchy feely" rather than the development of infrastructure to reflect the future growth of our towns and cities which has left us with the infrastructure mess we have today. At least engineers with vision like Brunel provided infrastructure which is still fit for purpose today.

Well in that case you might get a sociologist (strike 1) who is bad at developing Cities (strike 2)

 

 

[Lloydy]

Friday, 21th September 2018Mr Michael McCormack MP

 

Deputy Prime Minister

 

Minister for Infrastructure and Transport

 

PO Box 6022, House of Representatives

 

Parliament House

 

CANBERRA ACT 2600, Australia

 

Mr Shane Carmody

 

Director of Aviation Safety, CASA

 

GPO BOX 2005

 

Canberra ACT 2601, Australia

 

Deputy Prime Minister,

 

Further to correspondence sent today to the Civil Aviation Safety Authority and your office, regarding double standards on private pilot medical certification.

 

Quite simply it is either safe or it is unsafe for a private pilot to operate an aircraft with an MTOW of 600Kgs with one passenger outside of controlled airspace. For CASA to assert that it’s risk-assessments have concluded that it is only safe if the pilot is a member of a private company is ridiculous. CASA RPL and PPL holders are trained to a higher pilot standard than their RAAus counterparts and therefore should represent a much lower risk to aviation safety!

 

CASA must now come clean and publicly publish its risk-assessments and explain to the Australian public why it has denied pilots with a higher standard of training access to a self-certification private drivers licence medical. CASA should not be abusing its position and power in forcing unfair and biased aviation safety standards that seek to intentionally disadvantage RPL and PPL pilots, so as to force them into a private self-administration business (RAAus) where they are exposed to monopoly fees and charges that do not exist within the CASA system.

 

There is no doubt that CASA has been influenced into protecting the private business interests of the RAAus, which has reported year on year financial losses, citing stagnant membership growth. During a briefing to their members yesterday at Airventure Australia Cessnock, RAAUs Chairman, Mr Michael Monck, and CEO, Mr Michael Linke, communicated that “…should CASA approve self-certification private drivers licence medicals for RPL and PPL holders, the RAAus would close its doors...”.

 

As a result of this egregious denial of pilot rights, CASA regulated RPL and PPL holders are forced to become customers of a private monopoly business (RAAus) that owns your medical, your licence and your aircraft registration. Pilots are forced to pay fees and charges that are unregulated and are subjected to ad-hoc oversight and disciplinary processes that are at the discretion of the private business and the personalities that run it. And, to prevent pilots from electing to stay within the government regulated general aviation industry, CASA have denied RPL and PPL holders the right to choose by refusing to provide an equal and unbiased self-certification private drivers licence medical standard.

 

Are we now seeing the wholesale corruption of our national aviation safety regulator? Is pay for regulatory-play the way of the future? Why is CASA creating safety standards that disadvantage government regulated RPL and PPL holders, whilst deregulating the rules for a private business to ensure its financial survival? Does any of this pass the pub test?

 

Mr Deputy Prime Minister you must end this abuse of power and demand that all Australian private pilots – regardless of their associations - be regulated equally and fairly. You must announce to the Australian public that any pilot seeking to fly an aircraft with an MTOW of up to 600kgs with one passenger outside of controlled airspace can do so on a self-certification private drivers licence medical regardless of the licence they hold.

 

And, importantly you must affirm to the Australian people that the role of Australia’s aviation safety regulator (CASA) is to provide aviation safety standards that are free of commercial bias and influence.

 

Thank you for your time and I look forward to your reply.

 

Yours Sincerely,

 

BENJAMIN MORGAN

 

Executive Director

I am ashamed to say that I am a member of AOPA when I read the garbage Ben Morgan writes in this letter to Dep PM. To say that RAAus are the problem, and then for him to say RA pilots are trained to an inferior standard compared to GA pilots - that’s just utter bull$hit. And, why didn’t AOPA attend AirVunture? Probably too unsafe, crap. Never will I renew my membership to such an biased and confrontationalist organisation run by current naysayers.

 

Lloyd Kay.

 

 

[kaz3g]

Wondering what you regard as garbage in Ben Morgan’s statement?

 

If RAAus made a threat of closing should GA get the driver medical, and it seems they did, and if CASA acted on this threat, which seems likely, I think it’s a fair call to point out the discrimination if not the illogicality of CASA’s thinking.

 

CASA clearly agrees that the training to PPL goes beyond the training for RAAus. The RPL is really just a re-visitation of the old restricted PPL/GFPT at least until the add-ons have been signed off.

 

Many drivers of the more traditional (AUF) type of aircraft have complained for years and years about apparently relentless push for more and more of the privileges/rights attaching to PPL’s so it doesn’t seem unreasonable to argue that, if they are being considered now as more or less interchangeable, that this should extend both ways.

 

Kaz

 

 

[Tucano]

This is the most clear example of why aviation regulation / operation / manufacturing is the mess that it is in Australia - To many organiziations barking a the regulator with some showing a partizian desire to roll a certain hen coop. The USA is successful because there is one dominant organization for the recreational pilots that supports and receives the support and respect of those representing all the other forms of aviation.

 

RAA petty decision has just created division for some perceived advantage leaving the regulator to place it in the too hard draw.

 

As for maintaining the current L1, how is someone with limited training and aviation experience going to maintain his 6oo kg supercharged,intercooled,retractable, constant speed aircraft - omce these aircraft entered RAA's orbit it was going to change.

 

 

[fly_tornado]

Wondering what you regard as garbage in Ben Morgan’s statement?

I'm always a bit suspicious when someone joins the forum and only posts in one thread and that post is defending the RAA by attacking its critics...

 

 

[poteroo]

CASA clearly agrees that the training to PPL goes beyond the training for RAAus. The RPL is really just a re-visitation of the old restricted PPL/GFPT at least until the add-ons have been signed off.

Yes, but CASA contradict themselves, once again, by 'recognition' of the RPC training as equivalent to that of RPL in a GA school. Further, they also 'recognise' the cross-country endorsement from RPC over into RPL. The full PPL is not included in these recognitions, and neither should it be, because of the CTA/CTZ experience. There's also issues over the transference of design feature and flight activity endorsements from RAAus to GA, and also the use of an RAAus registered aircraft for joint RAAus/GA BFRs. happy days,

 

 

[kasper]

[billwoodmason]

As for maintaining the current L1, how is someone with limited training and aviation experience going to maintain his 6oo kg supercharged,intercooled,retractable, constant speed aircraft - omce these aircraft entered RAA's orbit it was going to change.

 

I don’t see why, 600 kg aircraft have been being maintained by their owners (perahps with help where required) for the last decade. All’s well a long as manufacturers recommendations are followed. No need for added regulations.

 

 

[kasper]

As for maintaining the current L1, how is someone with limited training and aviation experience going to maintain his 6oo kg supercharged,intercooled,retractable, constant speed aircraft - omce these aircraft entered RAA's orbit it was going to change.I don’t see why, 600 kg aircraft have been being maintained by their owners (perahps with help where required) for the last decade. All’s well a long as manufacturers recommendations are followed. No need for added regulations.

I'd agree except for 1 thing that is in my opinion a VERY big thing ...

RAAus, CASA and most owners of kit built RAAus aircraft have the clear mindset that there is a manufacturer somewhere that they MUST obey and follow.

 

The structure of 95.55 and the principle behind the entire amateur built aircraft under RAAus was that the builder takes ALL design responsibility at the time of construction and AT ALL TIMES thereafter.

 

This mindset that a kit manufacturer is the designer therefore what they say goes is a VERY GA view of the world and is absolutely killing the concept and principles of the self built self certified self maintained airframes that we got in '98.

 

20 years later and from watching the slow decline in independence within the membership and the clear GA here we come to take you over attitude of RAAus I despair that WHEN CASA push through part 149 we will see the revamped equivalents to the CAOs under which currently operate looking more and more like the old CAO 101.28 that was used to throttle self built in Australian under SAAA for over 35 years before the reforms in '98.

 

I recognise that you say 'recommendations' but you i'm afraid call them manufacturers ... they are not... They are designers and manufacturers of the kit of parts that the OWNER manufacturers and takes responsibility for from then on.

 

I am sad to admit that I think it is too late to recover the heart of what the AUF was built on. Yes they made very large admin errors and were not terribly professional as demonstrated in the CASA audits ... but the RAAus response has been to bend over backwards to become GA and defend the plans to take it over for all recreational GA.

 

 

[turboplanner]

Part 149 is law.

 

The consultation process for the Manual Of Standards is underway.

 

This would be a good time to read the documents very carefully, and decide, as self administrators what you want those standards to be.

 

If you want the structure of 95.55 then put forward the policies required to make it work, and make it work safely.

 

If you fly rag and tube, or you want simplicity now is the time to step forward and let CASA know.

 

If you think RAA Ltd or ELAAA, or any other existing or future Self Administering Organisation will look after your interests, then you don't need to do anything.

 

 

[facthunter]

Weight has nothing directly to do with maintenance except to perhaps (in a positive way) enable a simpler design to do the job with a higher weight design. The sophisticated Euro composites are a very specialist job to repair. If you can't build them it's not likely you can satisfactorily repair them. or assess the extent of hidden damage when an incident happens.. Nev

 

 

[bushcaddy105]

They are designers and manufacturers of the kit of parts that the OWNER manufacturers and takes responsibility for from then on.

At a Cessnock forum I sought confirmation that currently 19- registered 600kg MTOW aircraft would continue with the L1 maintenance AND modification conditions that currently apply, ie anything goes but the owner/builder takes FULL responsibility. This was clearly confirmed. The factory approval (or MARAP) for repairs and/or modifications only applies to aircraft registered under the LSA provisions.

 

 

[kasper]

At a Cessnock forum I sought confirmation that currently 19- registered 600kg MTOW aircraft would continue with the L1 maintenance AND modification conditions that currently apply, ie anything goes but the owner/builder takes FULL responsibility. This was clearly confirmed. The factory approval (or MARAP) for repairs and/or modifications only applies to aircraft registered under the LSA provisions.

And could the good men and women at RAAus clarify why when it is flight at own risk in 19- reg the second and subsequent owners are treated entirely differently from the original owner builder? Or why and for what purpose the major change grounding until “cleared” by RAAus is needed? There are major lofical inconsistencies that RAAus have allowed and/or requested in the current tech manual that make me fear that engineering control and design substantiation are not far around the corner and the openly stated desire to “support” LAME businesses is an anathema to the rationale for RAAus experimental.

And I’ll stop here because I know I’m a broke. Record on this one and the majority of members either disagree or are apathetic.