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Regional Aviation Association of Australia National Convention
RACV Royal Pines Resort, Gold Coast - 30 October 2019
Speech by Mr Shane Carmody - The Chief Executive Officer and Director of Aviation Safety
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 Mike Higgins and Jim Davis for inviting me to address the RAAA Convention. This is an important event because the RAAA is quite a broad church, representing the diversity of our industry and including, amongst others, airlines, airports, engineering and flight training companies and finance and insurance companies. It gives its members a voice in many ways. I’m delighted to be able to address the convention again this year and really consider it to be one of my more important speaking engagements.
At the request of RAAA, CASA is also supporting the convention with three staff members participating in or running workshops, one yesterday by Mr Scott Watson, Manager Operations Standards on Part 135 and two later today by Mr Ash McAlpine one of our Safety performance specialists on SMS and Audits and Mr Jason McHeyzer, Regional Manager Southern on FRMS for Pilots and Engineers. We have a few of our Board members here, including our Chair Tony Mathews, as well as Anita Taylor and Mark Rindfleish. I know those who know them will say hello, for all others, please track them down if you have something to say. We also have a couple of our Aviation Safety Advisors at our CASA stand, who will also be happy to have a chat to you.
I see that this year is 40 years of the RAAA. Congratulations, this is a significant milestone. CASA is pleased to continue its strong and productive working relationship with the RAAA and acknowledges the support the RAAA has provided to aviation safety throughout those years and more recently through the very successful Aviation Safety Advisory Panel (ASAP), through regular representation on Technical Working Groups (TWGs) (with just under 700 interested people registered) and providing feedback to consultation papers we produce.
Speaking of anniversaries, I should acknowledge somewhat more soberly that 2 October was the 25th anniversary of the tragic Seaview accident (2 October 1994) (9 deaths) which led directly, together with the Monarch tragedy (11 June 1993), (7 deaths) to the establishment of the modern CASA in 1995. Investigations into those tragic accidents concluded that the then CAA (our predecessor) had failed in its safety responsibility by placing commercial considerations of operators ahead of the safety of passengers. It is a point that remains very front of mind in CASA these days, the primacy of safety and making sure that we are not captured by industry relationships, ensuring that possible conflicts of interest are identified and managed and that we do not become too close to those we are responsible for regulating. This is front of mind for many regulators given the revelations from the banking Royal Commission.
This takes me to another obvious anniversary, ours. CASA was established on 6 July 1995, as Australia’s Aviation safety regulator with a focus first and foremost on aviation safety. Next year marks 25 years since CASA’s inception. Things have changed quite a lot over those 25 years. CASA has matured and industry has matured. Aside from the fact that we all have another 25 years on the clock, the reality is that many things have improved, aviation safety amongst them. Approaching a significant anniversary provides us with the opportunity to reflect 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.
Earlier this year I outlined to CASA staff my key priorities for CASA to work through in 2019, they included:
- finalise the three remaining Civil Aviation Safety Regulation Parts manage the transitional and consequential amendments related to the seven Regulations made in 2018 and make changes to our maintenance rules. – All well underway, I expect the three remaining Parts this year after consultation.
- establish RPAS registration/accreditation and complete other RPAS initiatives. – Well underway, legislation has been made for registration/accreditation of commercial later this FY.
- improve the Self-Administering Organisations funding model. – Complete, two-year funding arrangements in place from FY 2019-20.
- 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. TWG before end of the year
- establish alpha-numeric registration. – on hold pending some other broader registration matters
- 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.
- finalisation of simplified cost recovery and our long-term funding strategy. – Well underway, our funding arrangements will go to Government next month.
- 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.
My remaining priorities for CASA this year and into the next are to:
- Continue to manage the safe integration of RPAS into Australian airspace and commence registration of commercial and excluded drones during this Financial year. Recreational drone registration will follow.
- Finalise drafting of the remaining civil aviation safety regulations - parachuting, sport and recreational aviation operations and balloons. The associated Manuals of Standards are also progressing well and will be done next year. This has been a 25-year journey since CASA was established.
- 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 - which I hope you have seen and commented on. If you haven’t, you can have a look at one at our stand or from our website. We think it looks pretty good and that it is very useful and readable. If it is good and it is fit for purpose, please say so. We think it’s a sound model.
- When I spoke to you in 2016, I undertook to resolve longstanding concerns over Fatigue rules. That has been done and we have broad support for the new approach. The new rules commenced on 2 September this year, with the first transition period (for high capacity RPT planning requirements) being 30 November this year and everyone, including all other operators, to comply by 1 July 2020 (or October 2020 for those who apply for a FRMS by 30 June 2020).
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. To guard against this, in CASA we have a lot of change underway to improve our business. Things like the forms project I earlier mentioned to reduce and rationalise the number of forms you need to fill in – and move them on-line. A fees project to reduce the number of individual fee items (some 360) at present and get them down to a more manageable number, around 110, through aggregation, removal or the development of some fixed fees for defined service. You’ll hear much more about these over the next year and beyond.
But those are just two of the smaller projects. We also 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 you 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 85% of the ARNs issued, we do that in 2 minutes – and we aim to get better). System changes over the previous weekend have seen this lift to well over 90%. 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 being able to be completed on-line).
- And for the future:
- we are working on an on-line digital aircraft registration system (do you realise that 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) (do you realise that we around 750 pilot licencing transactions every week of the year?)
Ultimately our intent is to improve the way our systems work both internally and externally, to improve the way our CASA staff do business and to give on-line or self-service access to industry to the maximum extent we can.
- 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. All the new work we are doing in SDT 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.
- The first phase of this work was the development of our National Surveillance Selection Program (NSSP) 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 scheduled.
- This program will deliver one central area we are currently calling a guidance centre through which all questions will come and from which all answers will flow. No longer will we have different interpretations from different inspectors or different regions. A simple example is fatigue that I mentioned earlier. Policy and decision making on fatigue and FRMSs will be centrally controlled. All questions will be fed through the guidance centre.
- This is a really challenging and transformative project. We are using it to review all the “in aircraft’’ activities undertaken by our FOIs. The big question being, does it have to be done in an aircraft at all? If yes, does CASA have to do it or can industry do it on our behalf? Or is there a simulator available? This means that some of our inspectors are getting more flying to bring up their skills, whilst some are getting less or none.
- Similarly, on maintenance. If we are approving an overseas maintenance organisation wouldn’t it be sensible to first determine whether it is FAA or EASA certified and has been recently audited by a quality Aviation regulator? And if it has, this might reduce our workload. And rather than just “going over for a look”, we are going when an Australian aircraft is undergoing maintenance to see how it happens on the ground. This means that some people are travelling a bit less than they might have in the past.
- These are but two examples of changes underway under this part of our broader business transformation agenda. There is much more.
These updates provide you with some insight into just some of our achievements over the last year and our plans for change.
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. But I can’t just sit around and not action a safety improvement simply because some people might not be happy. Maintaining Australia’s and the industry’s strong aviation safety record and constantly focussing on the evolving nature of risk and the safety of our passengers is very important to us, that’s who I’m making my decisions for.
Aside from the project deliverables I have covered already, we have also made some other big decisions this year. The grounding of Boeing 737-8 MAX was one of those. We did so on a precautionary basis when we thought it was necessary, and, as it happens, well before the Federal Aviation Administration or European Union Aviation Safety Agency or Transport Canada to name just a few. CASA’s actions didn’t go unnoticed globally, that’s one of the reasons we were one of nine global safety regulators to be asked to participate in the Joint Authorities Technical Review (JATR) of the Max.
Next was the G8 Airvan. As state of design and in the knowledge that we have some level of responsibility for over 220 Airvans flying globally and 60 plus in Australia alone, we acted quickly to ground the GA8 Airvan after the tragic accident in Sweden that resulted in nine deaths. We also lifted the grounding in record time, as soon as we could be satisfied that there was not an inherent safety concern that led to the catastrophic failure of this aircraft in flight. We remain very conscious of costs to industry from our decisions.
Next, despite opposition we went ahead with our risk-based decision on improving the safety of community service flights after two tragic accidents led to six easily avoidable deaths.
Unlike the other two big decisions which were generally well received, and while many pilots I have spoken to are very comfortable with the changes imposed, the CSF matter has resulted in a lot of unnecessary criticism. The most problematic has been the maintenance requirements. As you probably know, we have imposed a 100 hours or 12 months maintenance requirement. Although this applies to commercial activities, under Schedule 5, it doesn’t normally apply to private because most private flying doesn’t reach 100 hours per annum – the average is around 50 hours.
Again, I don’t see it as a problem. This provision is specifically designed to catch the relatively few CSF pilots who significantly exceed this benchmark. Frankly, if you are flying 200 or 300 hours you should probably be doing some maintenance!
With regard to criticism, as a regulator we do cop some. It goes with the territory. I accept that sometimes this may well be called for but, causing difficulties and hindering the industry is most definitely not our intention. I do often wonder about those who continually push so hard against regulators and safety regulation.
I have also heard people (and associations) say that CASA is trying to “destroy General Aviation” and using phrases like “kill off, shut down GA, destroy GA”, “regulate people out of business, prefer to see no aircraft flying”. This is both ridiculous and patently untrue, particularly if you step back and look at what CASA actually does to promote safe aviation across all sectors. But, I suppose, some people have their own motivations!
Now criticism comes in many forms, the simple comment from an “individual” – and believe me I get a lot of those either directly or through my CEO inbox (3 or 4 every day) or through various other traditional means such as letters. Some are easy to fix. Others are not. They relate to everything from food, seats and delays (not my problem) to drones, overflights, safety. We answer them all.
So don’t be fooled by the negativity. 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 working well, but I go back to my earlier comment – we still can’t please everyone, every time. I will however go on record and say how much I appreciate the time and effort it takes to provide comments and the passion and commitment you show to maintaining aviation safety in Australia when you do that.
This line of thinking also made me reflect more generally on another topic which has been vexing me of late. It’s the question of attitude and, in this case a very worrying trend – poor pilot attitude.
Some of my own research is starting to indicate to me that it is often those who work hardest at pushing back against the regulator, are often the same ones who end up having serious accidents or incidents in flight. You all know someone like this! It seems to me that they can’t see past their own narrow self interests to realise the overall importance of safety and safety regulation. When you look at some recent tragic accidents, as I do, I think my concerns are well founded. We have had pilots who were constantly trying to get around the rules to suit themselves. They criticise CASA (and others) at every turn and they end up killing themselves and others. I could (but I won’t) cite in detail several tragic examples in the last two years or so involving pilots with a history of poor judgement, a history of ignoring regulation or skirting around it, a history of Facebook bluster or criticism of the regulator (knowing of course we won’t respond) thinking they can operate above the rules, that they know better or they are bullet proof. My colleagues in the Australian Transport Safety Bureau won’t and can’t call out pilot error, it’s not their role. But that restriction doesn’t bind me. My real point is that attitude is important. I’d ask you as industry experts to very closely scrutinise some of these very high quality ATSB reports and ask yourself. Some key questions: why did/would pilot knowingly fly into IMC; why was the pilot flying after last light; why did the pilot have passengers on board when they shouldn’t have, why was the pilot engaged in manoeuvres in aircraft that they wasn’t licenced skilled or qualified to undertake. It isn’t simple oversight ladies and gentlemen. It isn’t forgetfulness either. Its attitude.
In wrapping up I have tried to outline where we are going, what initiatives will make us a better safety regulator over the next couple of years, what improvements in service and oversight you can expect and how, together, we will continue to improve the safety record of our industry.
I touched earlier on the changes to the Civil Aviation Act, which were passed through Parliament last week and promised to provide a little more. Although we still have to wait for Royal Assent from the Governor General (this usually takes 7-10 days) before it becomes law, 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.
Although it is at times a challenging role, I’m pleased and honoured to be leading CASA. My comments today are not in any way saying we’re perfect – I’m acknowledging we can grow more and have more to do as a regulator – which I’m committed to doing. While I’m doing that, I will also try to find as many efficiencies to our processes as we can, as I believe this goes a long way to help you in the industry work better and understand your regulatory obligations better.
Before I conclude though I’d like to refer to the fine young aviators and engineers who accepted RAAA scholarships and spoke so eloquently last night. I think the future is in good hands and I wish them every success in their chosen careers.
I would like to thank the RAAA for hosting their convention to discuss matters relevant to aviation industry and for their continued support in maintaining high levels of aviation safety.
Thanks for your attention.