14th Australian International Aerospace Conference
Presentation by Director of Aviation Safety John McCormick, 2 March 2011
Addressing the Current and Future Challenges in Aviation Safety
Thank you for the opportunity to address you today.
I would like to give you a broad overview of some of the key challenges in aviation safety today and into the future.
I am sure you will appreciate I will not be going through an exhaustive list. The aviation environment is dynamic and constantly changing, but I hope to give you an idea of the broad range of issues that need to be addressed to meet the current and future challenges in aviation safety.
How we, CASA and the aviation industry, respond to the challenge of ageing aircraft is a real current and future challenge.
There has been significant interest regarding ageing aircraft in Australia. The Australian Transport Safety Bureau’s report ‘The impact of ageing aircraft on aviation safety’ from 2005 found that the average age of multi-engine piston aircraft used for regular public transport was 31 years old. Single engine piston fixed wing aircraft were on average 30 years old.
The ATSB also found that if current trends continued, by 2015 the average age of the single-engine general aviation fleet would be 37 years, and the average age of the multi-engine fleet would be 40 years.
The Civil Aircraft Register reveals that one third of power driven aircraft in Australia were manufactured in the 1970s. This amounts to over 3,400 aircraft.
It is important to note that the age of an aircraft, while important, is not necessarily a key factor in the safe operation of an aircraft. Other contributing factors have to be taken into account, for example, the type of operations the airframe is used in, total hours of operation or cycles flow, maintenance, and any other identified concerns for specific types of aircraft.
I note that at least two papers are being presented here associated with ageing aircraft: ‘Risk Analysis of Safety By Inspection of Ageing Aircraft from Ken Watters and ‘Ageing Aircraft Systems Audit - Fighting the Ageing Process’ from Robert Boykett.
I think this highlights the broad concern in the aviation community around ageing aircraft.
In addition, there is also a dedicated ‘Ageing Aircraft Management Forum and Showcase’ at Avalon this year which will include an overview of stage one of CASA’s Ageing Aircraft Management Program which CASA is developing to address the safety issues around an ageing aircraft fleet.
The Ageing Aircraft Management Program is scheduled to run in three stages.
Stage one will scope the magnitude of the ageing aircraft issue and recommend risk mitigation strategies.
Stage two will consider and implement the recommendations of stage one.
Stage three will be an ongoing yearly review of the effectiveness of the mitigation strategies adopted.
Unmanned Aircraft Systems (UAS)
Like other safety regulators, CASA faces a number of challenges responding to a changing aviation environment, a dynamic international and domestic industry and the need to ensure that safety related considerations are at the forefront of our thinking. One of the key challenges is the rapid pace of development in the unmanned aircraft systems (UAS) sector.
A significant area of innovation and development in the aviation industry is being directed towards UAS. The UAS sector is potentially the most innovative sector of the aviation industry. The development of the potential of unmanned aircraft systems is a key future challenge to which CASA must respond.
There are currently 13 holders of Operators’ Certificates in Australia who operate UASs for commercial purposes. All of these operate aircraft in the ‘small UAS’ category - Large UASs are generally only operated by the Australian Defence Force, however, we can expect the technology, scope of operation and size of unmanned aircraft to increase as technology is developed in the civil sector.
The number of enquiries being made to CASA relating to UASs strongly suggests interest in this sector will grow rapidly over the coming years – we are receiving around 15 enquiries a month from organisations exploring the possibility of operating UASs.
Globally, while assessments indicate that 45 per cent of the civil market will be made up of Government operators, there will still be significant growth. In the US, it is anticipated that by 2017, there will be 2,900 UAS – the majority of which will be small low altitude systems, and in Europe there will be significant growth in the next ten years.
I would expect that similar levels of growth will be seen throughout our region.
In responding to these demands, it is important to highlight that CASA is not an economic regulator. We have no authority to allow economic or commercial implications to influence the safety-related decisions we are obliged to make.
It is only after all relevant safety-related factors have been considered with due diligence, that the economic or commercial consequences of that decision might be taken into account. Where a less onerous, but equally safe, alternative is allowed by the law, CASA will certainly entertain that option. But in every case, commercial and economic considerations will be subordinated to safety-related matters.
In this regard there is a clear distinction in the design of UAS for the civil and military market. Aerospace Industry’s design of military UAS is ‘application driven’ – What does the UAS need to do? While the aerospace industry’s design of civil UAS is ‘regulation driven’ – how safe does it have to be?
Where more than one course of action is equally acceptable to CASA to achieve the required safety outcomes, then those options should be considered. And as I have said, where one option is financially or commercially less onerous CASA should always opt, and allow the aviation industry to opt, for that course of action. In every case, however, the interests of safety must come first.
A key challenge for the safety regulator is how do we develop and maintain expertise in such a rapidly changing field?
Internally, we have established a UAS Steering Committee and UAS Working Party. The terms of reference for these groups include:
- overseeing the development of UAS policies and procedures
- assessing the priorities for oversight of UAS activities within CASA’s overall strategic program;
- performing a key governance role advising and making recommendations on the management, budgeting and performance of CASA’s UAS program of work;
- informing the processes governing the safety regulation of civil UAS operations;
- supporting the development of CASA’s policies and procedures with a view to strengthening the organisation’s capabilities in UAS; and
- fostering an awareness within the wider aviation community of the importance of UAS safety and compliance with relevant legislation.
Importantly, these groups draw together experts from across CASA, such as our UAS specialists, Flying Operations Inspectors, Airworthiness Inspectors, Airspace experts and others to ensure a wide range of skills are brought to bear to respond to UAS developments.
I am proud to say that Australia has led the world in civil regulation of UAS and was the first country to have developed regulations - CASR Part 101, Unmanned Aircraft and Rocket Operations.
These regulations provide the framework under which all classes of UAS can be operated in Australian airspace, and are also supported by a set of guidance material.
Australia also has dedicated airspace for UAS operations including West Sale in Victoria, Marulan in NSW and Kingaroy in Queensland, and due to this many countries bring their systems here for trials.
There is growing pressure in Australia from operators considering the use of UAS for fire-fighting related tasks and there are suitable sensors currently available in the civilian market that may provide the data required for fire spotting and hot spot identification for fire fighting related purposes.
However, there a wide range of issues that must be addressed before we can approve these operations, including how these aircraft operate where RPT aircraft may be operating, and UAS operations over populous areas.
These and other issues will require further assessment and resolution before the widespread deployment of UAS in Australian airspace may be safely considered. In the meantime, however, CASA has been examining submissions and approving limited operations of UAS having regard to demonstrable compliance, or the ability to comply, with the applicable legislation, the areas in which operations are conducted, and the types of operations and vehicles proposed.
CASA is working closely with the International Civil Aviation Organization (ICAO) in the development of certification standards for UAS, and continues to evaluate permissions sought under CASR Part 101 on a case-by-case basis. In the assessment of applications for such permissions, the onus is on the operator to prepare a satisfactory safety case/risk analysis.
Australia currently chairs ICAO’s unmanned aircraft systems study group which has been formed to develop the standards in accordance with which UAS operations can be integrated safely into non-segregated airspace alongside manned aircraft.
We will be under increasing pressure to allow greater use of UAS, both from industry and our governments. My own Minister has reinforced to me, through the National Aviation Policy Statement, that he expects CASA to enhance our oversight of the operation of UAS. This only reinforces to me that safety must remain our focus.
However, it is a big challenge for us to effectively oversight the safe operation of these systems. We need to develop procedures and processes, be mindful of the work of ICAO, and the leading manufacturers of UAS such as in the USA and Europe, and identify training and experience requirements for our inspectors and related staff.
Not a small task, but one I am sure we can step up to.
Air Traffic Management Future Technology
The Government’s National Aviation Policy Statement published in December 2009 requires CASA to continue establishing a regulatory basis that supports airborne and ground-based infrastructure implementation by the aviation industry and the Air Navigation Service Provider - Airservices Australia.
The objective of this process is to improve the safety and efficiency of Air Traffic Management and for aircraft-to-aircraft conflict alerting and collision avoidance. The means to provide airspace and on-aerodrome safety and efficiency improvements both in the near and the longer term future is by the implementation of modern Communications, Navigation and Surveillance (CNS) infrastructure.
CNS technology, utilising satellite and ground based electronic systems for both the airborne and the ground based segments, is mature, internationally standardised, and available now or will be in the near future.
CASA has released a discussion paper that introduces and outlines a proposed regulatory plan to the end of this decade that would support a phased, gradual technology up-take and operational transition for the Australian aviation industry.
It is based on the implementation of CNS technology in aircraft avionics equipment to provide modern navigation and surveillance capabilities supporting:
- a future national satellite and ground-based, more efficient, flexible, ATM system utilising air-to-ground data-link surveillance for traffic separation;
- aircraft sole means satellite navigation without the need to resort to ground based aids in normal situations;
- the eventual capability of air-to-air surveillance for traffic conflict avoidance; and
- more efficient traffic manoeuvers, whereby pilots use procedures such as flexible routing, in-trail climbs, aircraft sequencing and merging on approach.
All this builds on the policy goals of the National Aviation Policy Statement by outlining a proposed regulatory plan for aircraft avionics fitment that will provide the interoperability for the ATM infrastructure of the future.
The plan is focussed on existing safety risks and also takes into account the ICAO ‘Operational Concept for Air Traffic Management’ that is also predicated on continuing the transition to technology – specifically the wider application and use of satellite technology for aircraft navigation and position determination and air-ground data-links for ATM and air-to-air surveillance.
CASA sees its role in technology advancement as providing a regulatory basis for the use of technology in aircraft where we consider that it will enhance safety and efficiency and reduce environmental impacts, to the extent that the cost to industry is justified.
Industry comments on this discussion paper will be valuable in gauging the extent of industry support for the phased implementation approach over the next 10 years, and we expect to remain closely engaged with the aviation community though-out its development.
The Aviation White Paper presented CASA with some significant challenges, including a requirement to complete the reform in 2011. Regulatory reform is partly a misnomer – we currently have regulations in place – regulations that work – but we are enhancing, modernising and refining them.
That said, I am committed to meeting the timeframes set for us by the White Paper – and have made it clear that this is a priority for CASA.
In order to meet the commitments and deadlines for regulatory reform as set out in the Aviation White Paper, CASA and the Attorney General’s Department have adopted a taskforce approach. The taskforce comprises four legal drafters from the Office of Legislative Drafting and Publishing (OLDP), about the same number of CASA legal officers, and several CASA technical staff who develop and instruct on our regulatory policies. The taskforce members are co-located on OLDP premises.
Finalising and implementing the outstanding CASR suites involves a huge amount of work and considerable resources for CASA and the OLDP, not to mention the resources that, you, the aviation industry, have to devote to reviewing and commenting on our consultation documents and draft regulations.
In addition to drafting the legal text of the new regulations, we also have to ensure that we publish adequate advisory and guidance material, supported by training and education materials, for both industry and CASA staff.
In the past, progress with regulatory reform has been affected by shifts in CASA policy, competing Government legal drafting priorities, and the fact that CASA’s policy and standards functions were fragmented across several organisational groups. These impediments have now been addressed.
The Operational rules and Flight Crew Licensing suite of CASRs are currently being drafted by the OLDP and good progress is being made. As individual CASR Parts come out of legal drafting we will be consulting on the text with our industry stakeholders.
CASA has developed and will deliver a comprehensive and rigorous implementation program for the new CASR suites, with a view to ensuring a smooth and safe transition. Implementation periods will be sufficiently long to allow both operators and CASA to comply with all implementation requirements.
I should also mention that if regulatory issues need to be addressed on a more urgent basis and in advance of the new CASR Parts, we will continue to make use of CAR and CAO amendments, as we have done in the past. For example, CAO amendments mandating SMS for RPT operators were made in 2009, well in advance of our future CASR Part 119 requirements for SMS. While we are trying to minimise the number of interim CAR and CAO amendments we make, in many cases early implementation will facilitate future implementation of the same requirements in the new CASR Parts.
A key achievement was reached on 8 December 2010 with the sign-off of CASA’s new suite of maintenance regulations, which will affect regular public transport operations only.
The next stages in this key CASA project will be the communication, education and implementation of the new maintenance regulations.
An internal team has now been appointed to guide the transition by industry to the new regulations.
This work has already begun and will continue into the new year until all maintenance engineers, maintenance organisations and maintenance training organisations covered by the new rules make the transition to the Civil Aviation Safety Regulations.
We are working on a system to electronically convert all CAR 31 licences into the new Part 66 structure. The conversion is expected to be ready by March next year at which point we will convert all existing current CAR 31 licences and CAO 100.66 Maintenance Authorities.
By early April, we will send a letter to licence holders including a draft copy of the Part 66 licence they may expect to receive on transition. The letter will explain the conversion and what the licence holder needs to do if any discrepancies are found in the draft licence document.
By June, CASA will produce new official Part 66 licences and send them to the licence holder. Part 66 licences are effective on 27 June 2011. CAR 31 licences and CAO 100.66 maintenance authorities cease to be valid on 27 June 2011.
These new regulations are a significant change for both the industry and CASA, but I am confident that they can be implemented successfully.