- Publications and resources
- Rules and regulations
- Safety management
- Licences and certification
- About us
Go to top of pageSpeech by Shane Carmody, Chief Executive Officer and Director of Aviation Safety
Australian Airports Association Conference Gold Coast Convention and Exhibition Centre
Wednesday, November 20, 2019
Let me begin by acknowledging the Yugambeh People, the traditional owners of the land on which we meet, and pay my respect to their elders past and present, and all Aboriginal and Torres Strait Islander Peoples here today.
Thanks to Guy Thompson and Caroline Wilkie for inviting me to address the AAA Conference again this year. This is a great opportunity to explain what we do to a captive audience. CASA is a proud platinum sponsor of the conference and also has a booth again this year to provide you with direct access to some of our staff and see some of our products. Please make sure you have a chat with the staff during your time at the conference.
I would like to take this opportunity to thank Caroline for her contribution to aviation during her term as Chief Executive Officer of AAA. She has provided valuable experience and knowledge to CASA and the aviation industry over the years and I would like to particularly acknowledge her contribution as an inaugural member of the Aviation Safety Advisory Panel which assisted CASA in getting, amongst many other things, the six pack flight operations regulations across the line. Caroline has fostered collaborative working relationships between CASA and the AAA team during her tenure, especially in relation to Part 139. She and the team worked side by side with CASA throughout the Part 139 process which helped make it a much better end product.
CASA is supporting this conference with a number of our staff presenting during the conference or participating in panel sessions over the next couple of days. They range from our Group Executive Manager Aviation – Mr Graeme Crawford participating on the drones panel tomorrow to some of our subject matter expert aerodromes staff Darren Angelo, Jason Rainbird and Joe Hain talking about Part 139, Aerodrome certification and data production as well our safety systems specialist Fred Fernandez discussing the Aerodromes safety sector risk profile.
While I’m here today to discuss some of the new technologies in the aerodromes sector and how our risk-based approach to surveillance and sector risk profiling is making improvements to aviation safety, I would like to mention a few key items before I get to those.
Firstly, CASA is about to celebrate our 25th anniversary, which I must acknowledge comes about because of two very tragic accidents - Monarch (11 June 1993, 7 deaths) and Seaview (2 October 1994, 9 deaths) that occurred in 1993 and 1994. Investigations into those tragic accidents concluded that the then CAA (our predecessor) had placed commercial considerations of operators ahead of the safety of passengers. It is a point that remains very front of mind in CASA these days.
Things have changed quite a lot since then, aviation safety being one of those. Notwithstanding the fact that we all have another 25 years on the clock, CASA has matured in other ways, as has the broader industry.
Technology in particular has come ahead in leaps and bounds and sustainability is at the forefront for everyone these days – these are two key parts of this year’s conference. They should also be for every organisation.
CASA is no exception. Our internally funded Service Delivery Transformation and EAP projects are examples of how we are looking at using technology to improve our services and make efficiencies in our processes. Like all of you, sustainability of our business has long been a consideration for us, but no more so than in the past 8-12 months. In the context of our long term financial sustainability we have been looking at:
- our fees - what we charge for, what we don’t and how we charge. (do you know there are only 10 aerodrome revenue items in this industry sector which last financial year contributed less than $90,000 to our income - much less than it costs us).
- working with the Government on options for the best funding model for the organisation - which has been challenging especially as we are also making efficiencies that will have an impact on future funding. As you may know, around 68% of our funding/revenue comes from domestic fuel excise – Avgas/Avtur (airports don’t use). 20% appropriation. 12% recovery. Putting it another way, around 80% (68+12) of our funding is based on industry activity. This is a challenging funding model, some might say unstainable, but might change.
- and of course, remotely piloted aircraft systems, or drones, and how we manage the fastest growing sector in Australia that isn’t like your traditional aviation operation and therefore doesn’t have your traditional regulatory service fees. We are also looking at how we establish and manage RPAS registration.
Approaching a significant anniversary of 25 years provides us with the perfect opportunity to reflect not only on our sustainability but on our safety role, our achievements, improvements made and yet to come and the technological advances that have occurred over the years. Most importantly where we are headed and how we can get there more safely, efficiently and effectively.
Obviously, our focus is broad. Broader than just aerodromes, though without aerodromes…
I had a number of key priorities for CASA to work through in 2019, they included:
- finalise the three remaining Civil Aviation Safety Regulation Parts and managing the implementation of the recent regulations made (the 6-pack) – All well underway, I expect the three remaining Parts this year.
- establish RPAS registration/accreditation and complete other RPAS initiatives. – Well underway, legislation has been made for registration/accreditation.
- implement safety improvements in the Community Service Flights sector. – Complete, in effect 19 March 2019.
- further review AvMed and medical processing. – planning is underway for a full review of Part 67. Technical Working Group expected before end of the year.
- conduct a review of penalties and manage implementation of the changes to the Civil Aviation Act. – (1) Well advanced underway, (2) I will talk a little more about this later.
- As I previously mentioned, finalisation of simplified cost recovery and our long-term funding strategy. – Well underway.
- rationalise the number of forms in use, we have a dedicated form reduction project and
- progress the next phases of the Service Delivery Transformation program. – Both well underway and milestones being reached.
- Perform regulatory requirements for major infrastructure projects including new runways and Western Sydney Airport – we have been developing new processes for engaging with aerodromes, including engaging earlier, in development and participating in advisory and steering groups to ensure regulatory delays do not impact these projects (approx 45 reviews of various versions of major development programs per year. Numerous major airport master plans developed per year and approx 400 development assessments per year. Of course, this is broader than just aerodromes e.g. Windfarms for example)
My remaining priorities for CASA this year and into the next are to:
- Continue to manage the safe integration of RPAS into Australian airspace.
- Commence registration of commercial and excluded drones with recreational drone registration to follow soon after.
- Progressively enhance our service delivery capabilities using digital transformation – adding to our online ARN application process and Remote Pilot Licences (RePL) and RPA Operators Certificates (ReOC) capabilities.
- Finalise consultation on the Part 91 Plain English Guide and work on producing others.
- Implementation of the new fatigue rules and flight operations regulations.
We have three very large initiatives underway to improve the way we do business.
The first is:
- Service Delivery Transformation - best described our big ‘client facing’ project. The intent is for industry to get services from CASA much more quickly and simply than in the past.
- So far, we have delivered ARNs (it used to take 3.5 days to check ID and issue an ARN, now for around almost 90% of the ARNs issued, we do that in 2 minutes – and we aim to get better). There have already been over 23,000 online ARNs issued since July 2018 and the current average monthly issuance is around 2,000. And now organisational ARNs can also be issued on-line.
- New easier licencing for RePLs and ReOCs (these things didn’t exist a few years ago and now there are over 13,500 RePLs and 1,600 ReOC’s) with the majority now able to be completed on-line.
- And for the future:
- we are working on an on-line digital aircraft registration system (We have 200 transactions in aircraft registration every week of the year?)
- and an electronic pilot licencing system (domestic first – because we can, and then international in line with ICAO) (We process around 750 pilot licencing transactions every week of the year).
- More will come on these in the next year or so as our plans mature.
- The second is what we call EAP (short for European Aviation Program) where we are implementing similar software to numerous regulators around the world for storage and manipulation of data. Ultimately EAP will contain all our Aviation data (e.g. pilot, LAME, AOC holder, COA holders, aircraft information etc.) in one place and will be our single source of truth. Our Aerodromes work hasn’t yet transitioned to EAP, but when it does it will provide us with more robust and reliable data as well as the benefits of digital data management and automation. All the new work we are doing in the SDT program that I mentioned a few moments ago, is already being captured and stored in EAP.
- The third is our Regulatory Services and Surveillance Transformation initiative. This is our entry control and surveillance project which will see us transform the way we manage all sorts of tasks into a more targeted and streamlined approach. This is being done over three phases and is expected to be in place mid-2021.
- Part of this work introduced a National Oversight Plan, which allows us to monitor compliance, test the adequacy of safety control measures and assess the compliance attitude and capability. It has four pillars with the core pillar being the National Surveillance Selection Program (NSSP) that was introduced in 2018/19. This is a critical program through which we decide, on a risk basis, what industry surveillance needs to be done, where and in what order. This brings predictability, certainty and consistency. It is now just beginning its second year and we learned a great deal from year one. In year one we scheduled 1,032 surveillance events and completed 917 (98%). In 2019 we have 1,218 audits/surveillance events scheduled with 120 aerodromes per year.
- This is a really challenging and transformative project and we are challenging ourselves just us much as anyone else. We want to look at how we do things – can we do it better? What we should do ourselves – could it be done in a simulator or by a delegate? What else is out there already – third party audit reports or certification by another National Aviation Authority?
From my perspective, if you are not pushing forward to change and modernise your business you are standing still which means, in effect, you are going backwards. You can tell from our priorities that we have a lot of change underway in CASA to improve our business but my updates provide you with only some insight into our day to day business – there is plenty more going on.
This brings me back to future technologies and safety sector risk profiles and the work going on in those areas.
Satellite-Based Augmentation System
One of the more high profile technologies is Satellite-Based Augmentation System (SBAS), which was allocated $225 million in the 2018-19 Federal Budget to go towards better positioning systems for Australia to deliver an operational SBAS. Is primary aim being to improve integrity, availability and accuracy of basic GPS signals for aircraft navigation.
It will greatly reduce the chance of controlled flight into terrain, provide a reduction in fuel consumption, operational efficiency and greater airport capacity during adverse weather. Many Instrument Flight Rule capable aircraft (mostly regional and general aviation operators) are already equipped for SBAS due to the 2016 Global Navigation Satellite System fitment mandate.
Geoscience Australia are managing the program and we are providing guidance and advice to them on regulatory matters. It’s expected that there will be further consultation with airports and advice to airlines and airports on SBAS in mid to late 2021 with a view for SBAS delivery in 2023-24.
Safety Sector Risk Profiles
We continue to produce our Sector Safety Risk Profiles which provide a collaborative approach between the aviation sectors and the regulator to ensure that the unique sector risks are identified, managed and where appropriate additional risk treatments (controls) are developed. We have published four of these so far, including Aerodromes, and have many more approaching publication or planned.
They will link with the future technologies we are working on to map across as data, resulting in more meaningful ‘safety information’ for our analysis team to use when producing the Profiles.
They key success of this program for me is the opportunity it provides us to work more closely with industry on developing controls with increased safety margins.
Mr Fernandez will go into more detail on the Aerodrome profile tomorrow.
I mentioned only some of our priorities earlier, which were more of a general update, so I thought I’d focus on few aerodrome related items before I wrap up today.
As you would know, Part 139 was made in February this year and commences in August 2020. The commencement provides up to two years to transition. We are working on guidance material and a range of templates to support aerodrome operators to develop or update any of their documentation. One of those items will be a sample aerodrome manual template, which we expect to be available next month. We are also aiming for you to be able to use the Manual Authorising and Assessment Tool to create a new aerodrome manual or redevelop an existing one from around early 2020. We progressively publishing Advisory Circulars to provide industry with guidance in understanding the new rules. Two were recently opened for consultation (closing 27 November) on aerodrome standards and aerodrome certification.
We also realise that some of you want to get in as early as possible to meet the new regulations, so we are considering “opt-in” transitional provisions to allow you to apply some of the new standards before they commence.
Mr Angelo will provide you with an update on Part 139 tomorrow.
CASA’s Future Air Navigation, Research and Development Program is another area of work going on which links to the Minister’s Statement of Expectations to commits us to work with Airservices and the Department of Infrastructure, Transport, Cities and Regional Development to “lead a national strategic airspace plan”. There are many different aircraft that need to operate in Australian airspace from large aircraft using top of the line technology to gliders and everything in between. All of them need to be managed safely.
Speaking generally, the program will start by looking at the “who and what” – Who needs to use the airspace and what requirements will they have/need. We’ll look at the risks, technologies and infrastructure to effectively deliver airspace classes, management and plans.
And of course, we need to ensure drones fit into this picture. We undertook a drone detection trial earlier this year at a number of major airports and locations to see how many drones were identified operating in the 5.5km radius of the airport who were not following the rules. The results were varied between locations, but it identified the need for a drone detection capability which will be implemented at 29 civilian controlled aerodromes under a phased implementation program. The first phase is underway with passive drone detection systems being installed at each of the Airservices control towers. The second and third phases will see active monitoring of drones through live feeds, refining response protocols and then some sort of effective and efficient integration into the air traffic management system.
We have also initiated a drone safety signage campaign that provides standardised national drone safety signage, which is available from our website. Airports, airport owners, local councils and other stakeholders can download two different signs – warning sign and prohibition sign. You will need CASA approval to display the prohibition sign (can only be displayed within 5.5ks of the movement area of a controlled aerodrome or airport and in the approach and departure paths so we want to ensure accurate installation), but the warning sign can be used where there may be added conditions or laws that could prevent someone from operating their drone in that area.
We have also focussed a bit on Aerodrome Rescue and Fire Fighting Services lately, especially related to the Government’s response earlier this month to the Senate Rural and Regional Affairs and Transport References Committee report. This committed CASA to a number of things, with the key outcome being the preparation of a dedicated CASR Part – 176 Aerodromes Rescue and Firefighting Services. Work is well underway, and we expect the draft to be ready for the ASAP early next year with a recommendation for a TWG to be established to engage stakeholders for input.
Looking back at our achievements I mentioned earlier, I know that not everyone will agree with my assessment of our achievements and some observers would prefer we tackle their rub point before all others. It’s pretty much an impossible task to please everyone as a regulator. And we do cop criticism on what we do – it comes with the territory. I accept that sometimes this may be called for, but when it extends to causing difficulties and hindering the industry – that perplexes me.
We try very hard to maintain Australia and the industry’s strong aviation safety record and are constantly focussing on the evolving nature of risk and the safety of our passengers – which is very important to us and it’s who I’m making my decisions for.
Please don’t be fooled by the negativity you may hear. Focus on what is being delivered. We always do aim to make the right choices. We do listen to industry, we do genuinely consider feedback from industry through our consultation mechanisms. The Consultation Hub, the ASAP and TWGs are proving to be key to our improved stakeholder engagement that went from 4.2 out of 10 to 6.2 out of 10 between two surveys conducted in 2015 and 2018.
I mentioned earlier the changes to the Civil Aviation Act, which were passed through Parliament and received Royal Ascent earlier this month. The Bill that was passed amends Section 9A of the Civil Aviation Act by adding a new subsection 3:
- Subject to subsection (1) [safety], in developing and promulgating aviation safety standards under paragraph 9(1)(c), CASA must:
- consider the economic and cost impact on individuals, businesses and the community of the standards; and
- take into account the differing risks associated with different industry sectors.
The amendment confirms in legislation what CASA already does. This was recognised in the second reading speech in the House ‘Existing regulatory practice is already based on this approach’. The language of the amendment is lifted directly from the current Minister’s Statement of Expectation.
In short, the way we make this work is to approach the making of any broadly applicable aviation safety standards in a way that demonstrably takes COST and RISK into account. Our processes will need to be (better) disciplined and documented. This means we’ll need to make some changes to our protocols and templates for developing aviation safety standards – we are working on this.
Being a safety regulator is not without its challenges, but I’m pleased and honoured to be leading CASA. My comments today acknowledge we will continue to grow using technology, better collaboration and improving our services –as there is more we can do as a regulator – which I’m committed to doing.
I encourage you to listen, participate as much as possible during the following days of the conference and take the opportunity to mingle with others in attendance and go and visit CASA’s booth to speak to our staff while they are close at hand.
As we are almost in December already, I hope that you have a safe and Merry Christmas and New Year.
Thanks for your attention.