• Under the RAAus proposal, recreational aircraft and LSAs such as this Ekolot Topaz would need to be transferred to the Australian Civil Register. (Steve Hitchen)
    Under the RAAus proposal, recreational aircraft and LSAs such as this Ekolot Topaz would need to be transferred to the Australian Civil Register. (Steve Hitchen)

The Sport Aircraft Association of Australia (SAAA) has called for CASA to abandon the self-administration system and transfer all aircraft to the Australian civil register in a controversial submission made public today.

The call was published in the SAAA's submission to the Senate Standing Committee on Rural and Regional Affairs and Transport's (RRAT) inquiry into the general aviation industry.

Although the submission is broad enough to encompass any organisation operating as an Approved Self-administering Aviation Organisation (ASAO), it singles out the example of Recreational Aviation Australia (RAAus) for particular attention.

With the legislation that enables RAAus to act as an administrator–CAO 95.55–set to expire on 31 January next year, SAAA believes the time is right for the administration of recreational aeroplanes to be brought back to CASA.

"There should be one central registration scheme for all aircraft operating in Australia that is administered by CASA and with no exceptions where this responsibility is sub-contracted to a private organisation outside of government control," the submission states.

"There should be one set of standards for pilot medicals, pilot and flight instructor training, and aircraft maintenance as a function of and as relevant to the nature of operation (private / commercial; visual / instrument / night / transport; airspace class etc) [and] aircraft complexity, weight and performance (speeds, power etc).

"The same set of standards should apply irrespective of whether a pilot, instructor or aircraft is regulated and administered by CASA or any organisation or individual to whom CASA may delegate such responsibilities – as is the case in all other major aviation jurisdictions."

RAAus currently functions as an administration organisation for aircraft with a maximum take-off weight up to 600 kg, soon to be 750 kg. Owners of both recreational and light sport aircraft registered with RAAus enjoy lower medical and maintenance standards, which translates to a cost savings.

However, the SAAA believes this means a greater complexity of regulations and is not mirrored in any other jurisdiction in the world.

"What is the objective of pursuing a path that we don’t believe has worked elsewhere in the world?", the submission asks. "We are only aware of one such attempt where South Africa implemented a process, similar to the current implementation of CASA’s Part 149 legislation, to devolve the regulator’s administration responsibilities to a private organisation.

"It did not work. Consequently, the process was reversed, and administrative responsibilities were returned to the regulator. What is the worth of in effect conducting such an experiment in Australia? What is the driver? Who benefits and why? And at what financial and human cost? Can we afford to accept the consequences of failure where the ultimate measure is a deterioration in safety outcomes?

"In this context, a UK regulatory review suggests caution around devolving administration of regulations to private organisations. This is discussed [in this submission], as is also a CASA proposal to further extend devolution to a private organisation(s), yet CASA’s own data presented suggests a less than favourable fatality rate performance for the one organisation that stands to gain from this proposal."

RAAus Chairman Michael Monck told Australian Flying that although the SAAA submission made some reasonable points, his organisation "respectfully disagreed" with the position and pointed out that it could be detrimental to GA.

"Obviously if they got their way and our authorities were removed, there'd be 10,000 pilots forced into the CASA regime," he remarked.

"SAAA has been quite vocal, as have many organisations, about the failings of CASA when it comes to GA, so I think it's quite contrary to their regular position to say that 'CASA is struggling to administer this and they're doing a very poor job', yet here they are in this paper saying they want to force every pilot in the self-administering sector back under CASA!

"There are some 15-20,000 pilots who have their aircraft under self-administration, so that would be another 15-20,000 pilots back under a failed system.

"I think a lot of them would rather walk away from aviation, to be honest. I know we have many members who are fed up with the red tape that's involved with Part 61 and the maintenance regimes, and you've only got to look around the country to see how many VH-registered aircraft are sitting in hangars and haven't been flown for years.

"There's a lot of people that have already walked away."

The SAAA has also accused CASA of pressuring RAAus and other self-administering organisation to transition to the new CASR Part 149 rules.

"We are also most concerned, and as are we understand most recreational aircraft organisations being pressured by CASA to migrate to Part 149 operation, that CASA is currently on a path to devolve itself from the day-to-day responsibilities yet hold private organisations accountable via strict liability.

"This is nothing more than a vailed abrogation of the CASA prime directive. But perhaps most disturbing – this introduces serious impediment to these organisations getting on with what they know best – being to keep their associated aviators and the public safe, and to open the flood gates for further proliferation of different aviation standards."

Included in the actions that the SAAA wants CASA to take from 31 January 2021 are:

  • convert all RAAus-issued Recreational Pilot Certificates (RPC) to CASR Part 61 Recreational Pilot Licences (RPL)
  • transition all RAAus flying schools to Part 141 regulations, or move all Part 141 flying schools to RAAus training rules
  • harmonise PPL medical standards with the RAAus manual
  • harmonise maintenance rules with RAAus operations
  • migrate all registrations from RAAus to the CASA civil register by 1 July 2021.

"Quite simply, CASA administered and registered aircraft and licensed pilots must be afforded the same rules as ASAO administered registered aircraft and licensed pilots. CASA should administer everything, meet Australia’s ICAO obligations – remove the confusion, remove the commercial inequities and focus on improving safety outcomes and not regulatory experiments."

The full SAAA submission can be read on the senate inquiry website.

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