RAAA 2009 Convention
Presentation by Director of Aviation Safety John McCormick, 2 October 2009
The First 200 Days
Thank you for inviting me to your convention. It is good to have the opportunity to speak with you, and to hopefully meet with as people as I can. I have already caught up with quite a few of you last night and earlier this morning.
As to the title of my address, 'The First 200 Days', I have to confess that it is technically not really 200 days since I was appointed - its actually closer to 215 days, but the round 200 has more 'gravitas'. I hope you will forgive me a bit of poetic licence.
There have been, or will be, a number of CASA people talking to you about specific operational issues, so I won't try to duplicate their messages, even though I may stray into their territory on occasions. Rather, I'd prefer to tell you where I have taken CASA so far - that's the 200 days bit. And I'd like to say something about where I see us heading - which is the next 1600 days of my tenure. But if you want to raise issues during the Q & A at the end of this address, whether general or specific, I will be happy to try to respond.
For those of you who don't know my background, I started out in the RAAF in 1974, eventually instructing on Mirage 111s. I then joined Qantas in 1984 as a second officer on 747s, moving to Cathay in 1987, initially focussed on flying training on 747s and then moving on to be Chief Pilot of Cathay's Boeing fleet. From 20O2 I was Cathay's General Manger Operations, a role that included responsibility for regulatory compliance and upkeep of a range of AOCs.
I then took the decision to move back home to Australia and took on a role as a senior training Captain for Cathay, based in Brisbane.
For recreation I fly my own light aircraft. Academically I have a Masters in Aviation Management
And of course I was appointed Director of Aviation Safety at CASA from 1 March this year.
What you can expect from me?
What I have been saying to staff from Day 1, and saying to anyone else who would listen, in terms of what can be expected of me, has been:
I am straight talking, direct, and what you see is what you get. I like to think I am firm but fair, but at least as far as the latter point is concerned, I guess that is for others to judge.
I am happy to listen to different points of view, particularly if they are backed up by facts, but I recognise that at the end of the day a decision needs to be made, and that includes the tough ones. I don't have a 'too hard' basket, or even a 'pending' tray and I'm not one for sitting on the fence– its too uncomfortable. So you will get decisions from me, and I would like to think they will be prompt decisions – whether you will always like them is another matter.
To take the point a bit further, I am certainly open to discussion and consultation with industry, particularly when it leads to safer outcomes, but not to the point of exhaustion. I'll say a bit more about that later.
I have a clear focus on safety. If you are looking to persuade me about a particular course of action that you are wanting to push, the best way to influence me is to demonstrate the real benefits your idea has for improving aviation safety.
I have a determination to build the most effective safety regulatory organisation I can. I have plenty of ideas about how I will be doing that, but I don't claim perfect knowledge. If you have some initiatives in mind that you think would contribute to the process, by all means let me know.
That is probably enough about me, at least for the moment. No doubt a few other insights will emerge as we go along.
The first 200 days
A lot has happened in the 200 days since I joined CASA. Let me give you a random selection.
- We have a fresh organisational structure
- We have a new Board
- I have met with a large cross-section of industry people
- I have visited every CASA office and spoken with most of our people
- We are moving aggressively to resolve the regulatory backlog
- We have implemented drug and alcohol testing
- We are expanding our surveillance activity, particularly in northern Australia
- And I have even had the pleasure of fronting to a Senate hearing.
I'd like to tell you a bit more about some of these initiatives, plus some of the other things we are doing, and where I see us going in the future. But maybe I should first share with you some of my initial impressions as the newly appointed head of the aviation safety regulator.
Some Early Impressions
Firstly, CASA's people. As I said earlier, I have met most of our people in the first 200 days, and I believe I have a reasonable feel for the strengths and weaknesses across the organisation. I believe CASA staff are dedicated, have strong professional skills and are very much up to the task of supporting an aviation safety regulation organisation of world standing. We have a strong management team and I don't see the need for any great slash and burn. I have changed the responsibilities of a number of managers and there may be a need for some further fine tuning along the way, but nothing dramatic, no blood in the streets.
Leadership from the top is obviously a key issue, and that is something that will certainly consume most of my waking hours, with, of course, guidance and support at the strategic level from an astute and highly experienced Board of Directors. I will say something more about that later.
We have an organisation well regarded internationally and I am certainly not intending to do anything that will reduce that high standing. As some of you may know we are actively assisting with several aviation safety projects in the region. This is not only contributing to improving safety in nearby countries where many Australians are travelling, but is assisting to raise safety standards across the region, and this is no bad thing. I should say that we undertake this work as part of a broader aid initiative by the Australian government, with special government funding additional to CASA's regular funding sources– so our safety programs and associated resources within Australia are in no way compromised.
Another early impression I had was that there was work being done in CASA that was not necessarily contributing to safety. Not necessarily large scale, and not necessarily wide spread. And I don't think remediation will be all that difficult. Strong guidance from the top may be required in some cases, and I am happy to supply that where needed, but in other cases it may well be something as simple as a reality check - getting people periodically asking themselves 'is what I am doing making a genuine contribution to safety', and if the answer is 'no' ensuring we have the internal processes in place that give people the confidence to bring shortcomings to attention and also empower their managers to do something about it.
So, broadly I believe I have inherited a strong organisation and that a significant part of my role will be building on the existing strengths, tackling the not too prevalent weaknesses, and ensuring our resources are properly focussed and are being deployed where they will make the best possible contribution to aviation safety.
My Early Priorities
There were four key strategic requirements that I identified quite early in my tenure
- the need to focus on CASA's core activity, the regulation of aviation safety
- the need to strengthen governance arrangements
- the need to ensure that CASA staff are trained and deployed to provide the best possible oversight and surveillance
- the need to complete the regulatory reform programme in an appropriate and timely manner
I am not saying these were the only issues that needed attention and I am also not saying they were previously being ignored - far from it. But it was apparent to me that we needed to increase our focus particularly on each of these areas if we were to be able to position CASA for the inevitable challenges we will face over the next few years.
I will say more about these points as we go on, but let me right now expand on one of them, the governance issue. Good governance is one of those qualities, like patriotism or righteousness, that we all agree is a good thing, but it is not always so easy to agree on what it really means and what you have to do to put it into practice.
I tend to break things like that into smaller parts. For example, probity is a subset of good governance. I believe it is important that as the regulator all our activities should be able to stand the test of scrupulous probity, and to help maintain a high level of probity, you need to have a strong degree of transparency.
I have no reason to think that we at CASA don't already meet high probity standards, but I believe, for example, that if we are able to better document our processes and procedures and make more transparent the way in which we reach particular regulatory positions, that will make us more effective and at the same time will further enhance our regulatory activity. It will also help in producing greater consistency of interpretation of regulations and directives, which has to be good thing, both in terms of our internal governance, and from industry's point of view. And all that stems from good governance, at least as far as an aviation safety regulator is concerned.
Some Guiding Principles
To drill down a little further, not just in terms of the four strategic issues I touched on, but something that I think applies across the board when seeking improvement in an organisation. There is a need for guiding principles that can be applied as a foundation for implementing change, wherever it is required. I have three points particularly in mind that I would like to share with you. These relate to how I am looking to build a more effective and efficient CASA, and in one sense they are internal housekeeping. However, as how CASA organises itself impacts on you and your industry, you may be interested in where I am heading on the housekeeping front.
Quite early in my tenure I identified the need for a clearer focus in CASA's operations in terms of:
By 'Policy' I mean defining the tasks CASA people need to do, and why they need to do them. In defining those tasks and the need for them we are obliged to be very much guided by the Civil Aviation Act and the Regulations. As I said earlier, I think there was work being done in CASA that did not always contribute to safety and I believe if we focus on the things we are required to do under the Act then not only will we be doing the things the government, the parliament and the people intended us to do, we will also have an unambiguous focus on safety.
By 'Purpose' I mean making sure our people understand what CASA expects of them. This sounds obvious but it does not always happen. It is a matter of clearly setting out our requirements, so our people can clearly understand what they have to do (and if necessary what we don't want them to do). It is good when people show initiative, and I encourage that, as long as that initiative does not cause them to divert themselves away from those safety activities which are at the core of our business.
By 'Practice' I mean telling our people how jobs should be done. This among other things involves making sure we have up to date manuals setting out procedures for key tasks, particularly in surveillance and certificate management. I believe one of the outcomes of a robust set of procedural manuals will be greater consistency of rule interpretation, something which I have a sneaking suspicion you will all favour.
None of this is to say we have not been doing a good job in the past, but I believe we can do it better.
One of my early initiatives has been a structural re-organisation at CASA. I know a reorganisation is traditional for any new CEO coming into a job, but rather than being ego driven - to show there is a new hand on the helm – in this case the reorganisation had an important operational purpose. There was a clear need for CASA to re-focus on its core business of aviation safety (and I'll say a bit more about this later) and we needed very early in the process a structure to better support that focus.
The reorganisation is based on careful analysis of CASA's current strengths and weaknesses, and was undertaken with input from management and staff at all levels. The idea was to make sure CASA is focused clearly on the business of aviation safety. In particular the changes will allow a more direct linkage of our activities, and the way we operate, with the legislative directions under which we are required to conduct our operations. I am confident the new structure will create a stronger system of governance and accountability at all levels in CASA.
The changes were important but were not radical and I believe we have been able to implement them with a minimum of fuss and without distracting our people from their key responsibilities. While the new structure formally came into effect from 1 July some elements will continue to be phased in over time. I don't believe there is anything in the changes that might be adverse for the regional aviation industry, and there are no dramatic changes in how you relate to and work with CASA and our people. In fact I believe you and the rest of the industry will benefit from having a more effective and focussed regulator.
As part of the reorganisation I have raised the profile of some areas, such as quality assurance, which will be managed out of my office. We now have all our aviation operations under a single Executive Manager, Greg Hood, based in our Operations Headquarters in Brisbane. We have all our permissions work under a single Executive Manager, and one Executive Manger oversees all corporate services functions. None of this is particularly radical, but it was certainly a necessary streamlining that I believe will benefit both CASA and the industry.
The new structure clearly defines where in the organisation responsibilities for meeting particular legislative requirements lie and where our duties are discharged. I believe it will give more direct responsibility and accountability for where and how a particular standard is managed, and it should therefore promote a more consistent interpretation and application of regulations. To take that point a little further, my intention has been to get rid of this history of inconsistency, whether simply alleged or actual, by centralising functions, and putting them clearly under the responsibility of a single person. This might further translate, for example, into having a specific person in charge of maintenance regulations, flying regulations, small aeroplane regulations, and so on.
New CASA Board
As I mentioned earlier, another significant event in my first two hundred days has been the appointment of a Board of Directors for CASA. CASA started its life with a Board, which remained in place until late 2003. So in that sense it is not a radical initiative on the part of the government, and the coming into existence of a new Board from 1 July has proved to have been quite 'seamless' as far as the organisation has been concerned.
As most of you will be aware the Chair of the Board is Dr Allan Hawke. Allan is a past Secretary of Department of Transport, and brings a strong background of strategic thinking and aviation policy development. He is also a past Secretary of the Department of Defence, and past High Commissioner to New Zealand.
Deputy Chair is David Gray, a past CEO of Boeing Australia and the holder of a number of company directorships.
The other independent Board members are Helen Gillies, General Manager of Risk & Compliance and Corporate Counsel at Sinclair Knight Merz, and Trevor Davos a partner at Coors Chambers Westgarth.
They are all well experienced, supportive, and are proving to be a strong source of strategic direction and governance.
As Director of Aviation Safety I am also a member of the Board
Broadcast Calls Part 166
It is probably time that I touched on particular issues that may be of interest to you, and I suppose the broadcast calls is as good a place to start as any.
As I am sure most of you know, given the particular relevance to regional flying operations, the question of broadcast calls near uncontrolled aerodromes has been a fairly contentious issue over the last year, with some parts of the aviation industry taking diametrically opposed positions to other sectors. I know that regional airlines representatives have been vigorous in pushing their position, and there is nothing wrong with that. I am all for a full and frank exchange of views.
Although I had not had the benefit of being part of the earlier discussions, coming new to the issue my initial reaction was that I felt the original NFRM represented a reasonable compromise between the divergent parties, and one that seemed to be reasonably accepted, perhaps reluctantly, by most of the players. Now, I have already said something, and will say more later, about my own reservations about decisions taken on the basis of compromise and consensus, but there had been a lot of discussion on the issue and I believed the issue needed to be put to bed.
However, further concerns were raised with me and I agreed to take another look at the issue. The latest proposal has been circulated as an NPRM and your comments are welcome. That process closes in a couple of weeks and would expect to be making a final decision not long after that.
I mentioned consultation earlier. Consultation is important. Of course we are required by law to consult, but even if we were not we would be crazy not to actively seek the views of industry. I don't profess to have all wisdom on all things, and I don't believe CASA necessarily has all the wisdom. We can and do learn a lot from industry. So I'm happy to go on the record to confirm that we are committed to full and frank consultation with everyone who has a legitimate position to put to us.
But at the end of the day we are the regulator and whatever decision we make we have to take responsibility for. It is no good us saying, if something goes wrong and we get accused of making a bad call –“ not our fault, we did what the industry wanted us to do”. Not only will that not wash in terms of public or parliamentary opinion, it would be abrogating our responsibility and accountability as the safety regulator, and that is not going to happen under my watch.
So, we will consult, and I'm sure there will be many situations where we will be accepting of suggestions made by the industry, even if those suggestions are not the course we may have originally favoured. But such acceptance will not be because we have been intimidated, or because we feel it is a compromise, or a path of least resistance. It will be because we have been convinced by the evidence that the changes provide a better safety outcome. Similarly, if we have made a decision, and if objective evidence from industry or elsewhere, shows that the decision needs to be modified, I will have no difficulty doing that.
Consultation and Regulatory Review
Having hopefully persuaded you of our willingness to consult, I have to add the rider that there has to be a limit to consultation. I think the regulatory development process has been a case in point. We do not have a particularly proud history in regulatory development over the years. There have been a lot of reasons for this, some within CASA's control, some not. But I suspect one of the contributing factors has been, at least on some occasions, that we have erred on the side of too much consultation, or of allowing the consultative process to drag on too long, as far as regulatory development is concerned. There is always the risk of a consultative process, if not managed well, dragging on, and degenerating into stalemate or compromise, neither of which usually serves the interests of any of the parties.
From CASA's viewpoint, in the broad consultative process, or even in our one-to-one discussions with the industry, if we are wrong, we should be prepared to admit it, to do so promptly, and move on. We should be advocating a position not simply because it is something we happen to like, or have a gut-feel that it is the way to go – it should be because we have objective and transparent reasons that a certain course of action is the one we should follow.
As to the regulatory review program itself, I would like to be able to say we will complete the reform program tomorrow, or in six months. That won't be the case, but you have my assurance that I intend to have the elements that CASA can influence completed at the earliest opportunity consistent with their safe implementation and I will be keeping the pressure on to achieve that.
My earlier comments on consultation lead naturally on to events associated with our actions to do something about mid-air collisions at and around GAAP aerodromes. No doubt you are all aware of the events which led up to the current situation, and the studies we commissioned. As most of you are probably also aware one study concluded there were 'intolerable risks' at a number of the GAAP airports. Such a conclusion, by an independent and reputable aviation industry consultancy organisation is something a safety regulator cannot ignore.
I imagine most of you will know about our response to the problem, both in terms of changed procedures at GAAP aerodromes and increased educational effort. I can report the new procedures are generally operating smoothly, after an initial settling-in period. I would like to thank the many pilots who operate at these airports, no doubt including some here today, for their efforts in taking on board the new procedures as quickly as possible and adjusting the way they fly. Particular congratulations are due to the flying schools at these airports for their work in not only learning the new procedures, but in making sure their students were given easy-to-understand and practical tuition in the new requirements.
I can assure you CASA only made the changes to procedures for sound safety reasons, after careful evaluation of operational data. We understand that when changes are made the aviation industry needs support in the form of education and training and that is why we have rolled out a comprehensive information program over the last few months.
However, things are not set in stone for evermore. You will be aware we are holding meetings at GAAP airports to hear industry views about the new procedures. Any ideas and initiatives you may have to further reduce the risk of mid-air collisions are most welcome, particularly in terms of pilot training and education and smoothing out of traffic flows ahead of the introduction of Class D airspace at all GAAP aerodromes by April 2010. This introduction of Class D will better harmonise airspace arrangements in Australia with current International Civil Aviation Organization airspace classification.
Classification of Operations
I don't know how large our Classification of Operations, also called Classification of Activities looms on your radar, but it is something that has had a fair bit of time and effort spent on it in CASA over the last year or so, and quite a bit of industry consultation has been involved, so I assume that at least some of you have had more than a passing interest in the subject. The aim has been to develop a new Classification of Operations which moved away from the traditional approach of classifying aircraft operations substantially on their commercial nature, and placing a greater focus on a risk-based approach. I have no particular difficulty with heading in this direction, especially as I believe very strongly that CASA is a safety regulator, not an economic or commercial regulator. I am also a strong supporter of risk based regulation and surveillance.
However, I had some reservations about the form of the Classification of Operations I saw when I arrived at CASA and I suspended its application to give me the opportunity to undertake my own review. For example, I think the FAA and ICAO have not gone quite as far as we have and I want to be comfortable we don't get too far in front of international practice, even if in this case it is the right way to go.
I had a further concern in that that the proposed Classification of Operations incorporated a risk hierarchy which implied we might not be all that interested in or devote resources to non-passenger carrying operations. However, reality is not always so simple and risk hierarchies that look good on paper are not always so clear-cut in practice. So I am planning some modifications to the Classification of Operations to get its take on the risk balance a little closer to where I think it needs to be.
Of course, as far as the regional airlines sector is concerned, nothing really changes. Whether we are talking RPT or charter, you are still carrying passengers and those passengers deserve the best standards of safety, and the highest level of regulation and surveillance from the regulator.
As a final point on the Classification of Operations, while it is an important pointer as to how we will prioritise the allocation of our resources in the pursuit of better aviation safety outcomes, there is no intention that we will pass up our responsibilities in any sector. Safety needs to be the prime consideration in every area of aviation activity. But some sectors will get more attention from us than others, based on risk.
I expect to be in a position to issue a new Classifications of Operations Policy Notice in the near future.
I spoke a little earlier about my initial impressions of our people. One of the other people-related things I have become aware of in my first 200 days is the CASA age profile. We have tended to recruit people later in life, I am one of them, and I know there have been good reasons for taking on older people. Experience and maturity are not bad attributes for someone working for a regulator. But it does mean we have an age profile skewed towards the older end and I'd like to get a better balance and involve younger and fresher minds and bodies.
If we can get some younger people into the organisation, and be able to offer them a clear career path and retain them, that would be a real benefit for CASA. And even if they do leave to go to the industry, that to me is still a positive because they will have some understanding of the regulatory side of things and the reasons for standards and the way those standards are developed. I can only think it will add value to the industry to have a few people with this sort of background to draw upon.
I also plan to introduce a graduate management program within CASA and to increase our sponsorship of young licensed aircraft maintenance engineers and young commercial pilots, if we can do it. We are in the process of putting in place comprehensive initial, on-the-job, recurrent and specialist training programs for our technical staff, including continuous monitoring, review and evaluation. As with our other fields of endeavour all training functions will be centralised under one person, and coordinated from a central area.
In doing all this I am trying to take a slightly longer term view than we might have taken in the past as far as developing our own people, and if there is a spin-off for the industry, so much the better. I hope it will represent a useful contribution to the ongoing success of aviation in Australia.
I want to get more of our people out in the field and doing more 'hands on' surveillance. But strong regulations and robust surveillance is not the whole story. I believe CASA can contribute significantly to safety through education and training available to industry, where that is needed, and I plan to up our game on that front as well.
As a final point in the people area I am keen to introduce measures to eliminate internal 'silos' and 'stovepipes', such as limiting a particular inspector to conducting surveillance only on small aircraft. As far as I am concerned there is no reason that with appropriate training they should not conduct surveillance on a whole range of aircraft, big and small. Something like this makes better use of the available talents, gives us more flexibility to meet changing demands and priorities, and may reduce bottlenecks in our own processes that may sometimes limit our ability to provide timely regulatory services to industry.
We are required to carry out surveillance which at one level, the level best understood by the public at least, involves physical presence on an aerodrome and actual inspection of aviation operations. I am a strong supporter of 'hands on' surveillance and I am keen to see more of our resources devoted to that role. It therefore to me seemed inappropriate and inconsistent to push on with CASA's previously announced policy of closing our Townsville office. So we are not going to do that.
Indeed, I am keen to extend our presence in regional areas, particularly in northern Australia, where there is a high level of aviation activity, and where there has been a higher level of incidents and accidents, particularly in mustering and helicopter activities.
We are in the process of establishing new work-bases for air safety inspectors in north-west Western Australia, while maintaining existing offices in Cairns and Darwin, and of course Townsville as I mentioned earlier. The intention is for the network of offices to support an increased presence of CASA inspectors in large and small aviation centres across northern Australia.
As you may also know we recently offered some tangible evidence of our increased interest focus on in aviation in the north with what we called Operation Croc Sweep, which finished a month or two ago. I believe it was a very positive demonstration of CASA fulfilling its role of being what I call a 'capital R' regulator. The operation covered northern and central Australia from east to west, and back again. The CASA team carried out safety checks at dozens of aerodromes, from small airstrips at local communities to large centres such as Alice Springs. There were close to 100 ramp checks completed, plus many informal discussions with aviation people and lots of safety advice dispensed to pilots who were mostly keen to take advantage of CASA's presence.
I would like to hope that there would now be few aviation people across northern Australia unaware of CASA's recent visit and I would hope this exercise would have helped to have safety and safety compliance at the very forefront of their minds. While we cannot be at every aerodrome every day, we can and will be present regularly at regional and remote centres, and not just at the obvious locations.
We will have more of these special events like Croc Sweep, but I'm not trying to take a high profile approach in everything we do. In fact, much of our work goes on quietly behind the scenes, where safety is reviewed and improved without any dramatic outcomes. In most cases safety improvements come incrementally and potential problems are identified and rectified before adverse events occur. This is as it should be. What I am looking for is an aviation system operating smoothly and safely, day in and day out. But, to be an effective safety regulator we also need to be visible to the aviation industry and active in the places where aircraft are operating and being maintained. As with all things it is a matter of balance, and getting that balance right.
CASA and the RAAA
It may be appropriate if I conclude my remarks by saying something about the relationship between CASA and the aviation industry, and then the CASA- RAAA interaction in particular. And in doing so I might start by commenting on something my predecessor Bruce Byron raised at this Convention last year.
I understand Bruce put forward the idea, which is not a new one and which I think he only half jokingly categorised as 'an impossible dream, that the aviation industry at some stage and at least on some issues might get itself into the position of speaking with a single voice. I have a lot of sympathy for this point of view. Certainly from CASA's viewpoint, I know it would be nice if we only had to deal with a single unified industry voice. In other words, how useful would it be if the aviation industry were able to sort out an agreed position on all, or at least some, of the various things that need to be consulted, negotiated, and discussed between us, rather than CASA receiving a myriad of often conflicting and diametrically opposed viewpoints that we then have to sort through.
I would certainly prefer a situation where the regulator does not also have to be a negotiator, a facilitator, and a mediator between various industry interests, or have to make Solomon-like judgements deciding between opposing industry views on particular issues, which usually result in one side or another appearing to win or lose, or alternatively, as I have said earlier, the result can be some sort of compromise, where no-one is happy.
And I would have thought that such an approach makes sense whether you are dealing with CASA, Airservices, the Department or the Minister's office. And it certainly would not mean the demise of organisations such as the RAAA. There will always be a place for interest groups to provide input to the formulation of an industry position, to organise forums such as this, and to pursue issues that may only have relevance to a particular sector, rather than the industry as a whole. Impossible dream? Probably. But one way to be sure it never happens is not to raise it once in a while in a forum such as this. I may not agree with everything Bruce did or said, but on this one we are singing from the same hymn book.
Obviously that is not a message directed just at the RAAA, and I am realistic enough not to expect much to happen along these lines any time soon. So in the meantime, as I have also tried to make clear to you, I have no difficulty making a decision, whether it is informed by unified or divergent industry input. That is what I am paid to do and I am not about to shirk that responsibility.
So, to get to more practical points, and given I am speaking to the RAAA Convention, it is probably appropriate for me to comment briefly on some of the particular views relating to CASA that your organisation has put, either to me or more widely, over recent times. And it may surprise you to find that in most cases I have no particular difficulty with them.
One of the issues raised concerns has been what is suggested are excessively high regulatory costs which were said to be “…artificially high because much of what CASA does has no safety benefit...”. You have gone on to say “Yet CASA seems disinterested in becoming more efficient”
I touched on this point earlier, but I would like to focus on it again given that you have specifically raised it with me.
I don't know if it is legitimate to characterise regulatory costs as artificially high, but on the efficiency question, while I am not qualified to speak on what may or may not have been approaches taken by previous administrations, I'm happy to go on the record today to say that CASA under my watch will be very focussed on being as efficient and effective as I can make it. On the issue of whether there is stuff we do that has no safety benefit, I have already said that I believed there was some evidence of that following my initial look around the organisation, so I have no dispute with you there.
In putting together the reorganisation I mentioned earlier, a driving element has been my desire to ensure CASA's focus is on safety, and you have my assurance that if, after objective analysis, there is something we are doing in our operational role that does not contribute to safety, it will have a very doubtful future. As I said earlier, and as I have said to our staff, I believe that work done in CASA that is not adding to safety is not in line with our legislative responsibilities. In other words it is work we should not be doing and I would argue have no legislative backing to be doing it.
So I think both your Association and I share the same desire to ensure that CASA's resources, and the costs associated with those resources, are fully focussed on safety. I for one am certainly not “disinterested” in having CASA become more efficient, and I am certainly very interested in ensuring we are not doing stuff which does not have a safety benefit, and I will be working hard on both issues.
However, it does not necessarily end there. I accept that there is always the potential for a perception that when an organisation looks at itself, even with a new CEO and a new structure, that it might run the risk of concluding that everything in the garden is rosy and everything we do, by definition, is contributing to safety.
So there is a role here for you to play as well, if you choose to. If you really want to back up your assertions, and to make a positive contribution, please identify specific areas or activities you are aware of where you don't believe we are contributing to safety, or indeed areas where you think our resources could be used to make a greater contribution to safety. I'm not talking about broad assertions that “CASA could be quicker in issuing certificates” or CASA's surveillance leaves a lot to be desired”. If you have specific and well defined examples of areas where you believe CASA activity is not contributing to safety, let me know. Maybe I won't agree. Maybe I will already be aware of them, and doing something about it. But maybe I will have not as yet identified them, and your input will help to focus my attention. You will have my commitment to review whatever you come up with, and if it checks out, to do something about it.
You have also raised the issue of consultation, emphasising your support for the consultative process, but making the point that industry consultation has to be brought to a close. As you will have picked up from my earlier remarks I could not agree more.
You also placed some focus on the need for consistency in decision making on the part of CASA. Again, as I have said earlier, I totally agree.
I also noticed you have put forward the idea that in terms of regulatory development there is a need to get the regulatory reform program done. You even raised the suggestion that maybe it would be easier if Australia just adopted what the New Zealander's have done.
On the first point, you get no argument from me and I have already flagged that getting some finality into the regulatory reform program is one of the key priorities I set soon after I arrived at CASA and it is one I will follow through on. On the second point, picking up someone else's regulations, is in fact something I raised for discussion not long after I arrived. Of course it would involve conceding considerable bragging rights to our friends across the Tasman if your specific suggestion was taken up, but sometimes sacrifices have to be made in the interests of progress. However, it was made clear to me that adoption of another jurisdiction's regulations would involve so much work to convert it into something that would fit the Australian legislative form that it would take longer than taking the existing regulatory development program, which in reality is well down the track, to completion. But you will be pleased to know the idea was considered.
I also understand you do not like our penalty points system. It was introduced before my time, but I'm not ducking the issue because of that – obviously I own it now. It is not something I have given much thought to in these first 200 days, and it is not at the forefront of my priorities, but it is something I'll look to get my mind around. I have to say to you that I understand the penalty points system was introduced, at least in part, to give greater flexibility, both from the point of view of the regulator and the regulated. There was concern that previously there had not been a lot in between the 'slap on the wrist' and the 'sledge hammer' approach.
I suppose most of you would not be too complaining about application of the wrist slap for some proven transgression. But if the only other available penalty is pulling a licence, for example, I would have thought you might have had more than a passing interest in the insertion of a broader range of graduated penalties, to more closely fit the punishment to the 'crime'. So the intention behind the introduction of the infringement notice/penalty point system was to increase flexibility. But if unintended consequences have emerged, I will be happy to listen to all sides of the argument and look at the issue if I am persuaded there are problems with it.
However, I should warn you that I believe a regulator, if it is to do a proper job, needs to have available to it penalties that it can apply when necessary to those who break the rules, particularly when they do so knowingly and deliberately. It may be that the way in which those penalties are applied need to be fine tuned. It may be that some of the processes and procedures that go along with the penalties could require some adjustment in the light of experience. If you want to put forward some specific issues, I'd be happy to look at them.
Thank you for the opportunity to say a few words to you today. I hope I have been able to give you a reasonable overview of my first 200 days at CASA, where I am coming from and the path along which I am hoping to lead the organisation in the ongoing task of improving aviation safety. I look forward to working with all those, including I am sure everyone here today, who share the same goal.
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