Yes, but to who (or should that be "to whom")Any kind of reform of aviation activities (I don't want to use the word "procedures") in Australia is extremely difficult, with a very pronounced preponderance of nay-sayers to any change.
The objections to "risk based regulation" are very well entrenched in aviation circles, although risk based management has been adopted by almost the rest of Australian industry and their various regulators. In the aviation case, always in favor of the status quo, usually without any idea of how the status quo became the status quo.
Most of the objections to the CAR 166 changes, in favor of the status quo, have been entirley without regard to the various studies of actual pilot behavior at CTAF/CTAF®, earlier CTAF/MBZ. Further, without regard to studies of how "alerted see and avoid" works best ---- what really produces the least risk. aka best safety outcome.
"Mandatory xxxxx" does not produce the best kind of behavior --- where a pilot actually thinks about what to say --- as opposed to "chanting the mantra", putting all the verbal tick in the boxes of any analysis of the voice recorder. It is also pretty clear the "mandatory radio procedures" leads to an entirely false sense of security on the part of the participants, particularly when several pilots are indulging in a bit of do-it-yourself ATC, radio arranged separation (for which there is no legal imprimatur, or any requirement for a pilot to participate, regardless of the hectoring of any other aircraft) to the degree that other aircraft in the area can't get a word in edge-ways.
What the "traditionalists" can't get their mind around, as just one example, is that with very high levels of basic compliance with radio communications requirements ( I don't want to use the word "procedures") , making something "mandatory" does not increase compliance, because compliance rates are so high that most non-compliance is inadvertent, and if "compliance is mandatory", creating that animal first noted in the first Lane Report as an "inadvertent criminal".
John McCormick, in early testimony to a Senate Committee, acknowledged that "mandatory radio procedures" did not improve compliance, and there is quite a considerable body of evidence that rigid " mandatory procedures" actually increase risk (aka decrease safety) by inhibiting proper communications.
And that is why I don't want to talk about "radio procedures", but "radio communications", which is not the same thing.
The rest of the world "communicates", Australia has "procedures", and four or five times the "standard phrases" as recommended by ICAO. The alleged importance of complying "precisely" with "standard procedures", regardless of the appropriateness of "selected phrase or procedure" to the degree that it has been elevated to a potential BFR or License Renewal failure is a nonsense.
Good radio discipline and common sense is what is really required ---- not a straitjacket.
One of my favorites ---- those of us who know what has to be read back in a clearance on controlled airspace clearances will really appreciate this one --- and remember, I heard it myself, I was No2 behind the subject of the story; it went like this:
Sydney Kingsford-Smith early one morning, with one aircraft slow to vacate RW 16R:
Tower: QF xxx, expect late landing clearance.
QF xxx: Acknowledged tower advice.
A short while later ---with xxx on very short final ---
Tower: QF xxx, cleared to land, no readback required (Thinking controller there -- non-compliant phraseology in the interests of safety)
QF xxx: (readback) Cleared to land 16R, no readback required.
A wonderful example of rote adherence to "mandated procedures".
A bit of thread drift ---- but don't anybody be under any illusion about resistance the changes that made the RAOz of today possible --- the legislative changes that (amongst other things) introduced the various experimental categories.
One of these days the history will be written, of an unholy alliance between the nay-sayers of industry and CASA, who all knew that US style Experimental "wouldn't work" in Australia, that we couldn't cope with US style freedom, that Australians needed a stifling cloak of "control" to be "safe".
The history of the last twelve years has proven that to be absolute rubbish, to put it mildly, but the same "the only good change is no change" brigade is alive and well.
Thereafter, the expansion of AUF was explosive.
Regards,