The Australian Aviation Associations Forum (TAAAF) has sent three new policy papers to CASA CEO Shane Carmody, covering what it says are issues of great concern to the aviation industry: engineering training, flight training and a revitalisation of general aviation.
The three papers were written with the idea that they would be discussed at the next meeting of CASA's Aviation Safety Advisory Panel (ASAP) in two weeks' time.
"We've been working on these papers for a while and sent them into the government about three weeks ago," TAAAF Honorary Chairman Greg Russell told Australian Flying. "We think there's a response coming to us shortly.
"I have asked that these three papers go to the next ASAP meeting. I think that's a legitimate way for TAAAF to formulate policy and put it into a consultative process now that we have this panel in place.
"We tried to keep them concise and there are recommendations there that cover more than just CASA, for example, the question of engineering training.
"I think [presenting the papers] is a logical development of the whole forum approach, and now with this consultation mechanism in place, we think this is the right way to get this material into the forum."
TAAAF says the engineering training program in Australia has "all but collapsed" citing data that indicates that in 2009 there were 779 apprentices, 398 in 2013 and estimates that put next year's figure at less than 100.
"Firstly, there is a lack of a transparent training pathway for students to enter the industry and identify and career pathway," the TAAAF position paper says, "and secondly, the funding arrangements for RTOs [Registered Training Organisations] across the various states are confused and diverse.
"Additionally, these RTO’s are now required to have an additional CASA Approval, namely as a Maintenance Training Organisation (MTO)."
In the paper, TAAAF congratulates CASA for implementing a review of CASR Part 66 maintenance training regulations, but says the issue of funding is one that still needs attention, and recommends "that the Federal government assume control over the funding and management of the training requirements specified by CASA in order to produce appropriately skilled engineers whose licences include greater scope and are recognised internationally."
According to TAAAF, the new flight training regulations, CASR Parts 61, 141 and 142 "impose undue complexity and cost on the aviation industry that will lead to a significant reduction in training capacity."
The paper lays the blame for the situation on four main issues:
- Students at CASA-approved flight training schools (as distinct from university-backed courses) have to access to HECS or other government funding
- CASA will not indemnify instructors with a Flight Examiner rating the way they did for Authorised Testing Officers
- The new CASRs place very high demands on training organisations and individuals that TAAAF believes will lead to a capacity reduction
- The Federal Goverment tightened 457 visa requirements, which restricts the ability for Australia to recruit instructors from overseas.
"This combination is leading to pilot shortages in various areas, a reduction in the operations of existing flight training schools, a restriction on availability of specialised training, and an overall reduction in capabilities across the industry," TAAAF says.
To correct the situation, the position paper recommends that ASAP establishes a joint industry/CASA review of the three new regulation suites to be completed within three months; that the Federal Government extend funding to all CPL candidates and those doing operational ratings, and the Federal Government take steps to simplify aviation industry access to 457 visa candidates to enable a greater exchange of international expertise.
Revitalising General Aviation
That general aviation is in decline is a position the entire industry has taken over the past 10-15 years, and the TAAAF paper on the subject refines the problem down to four main issues:
- Overly-prescriptive regulation
- CASA's lack of focus on GA
- A failure of state and federal policies on training
- Cost of access to training facilities and airports
Whilst recognising that many different factors have contributed to the decline of GA, the paper goes on to point out that there are several things that can be laid at CASA's doorstep.
"The key issue is that CASA has struggled with general aviation issues for at least a decade largely because it has not enunciated a clear policy or organisational structure that relates risk and controls to the different needs and capacities of the different sectors it regulates.
"This has led to a slow and overly complex regulatory reform process and significant new costs and complexity."
With CASA currently considering an internal restructure, TAAAF has grabbed the opportunity to recommend the regulator set-up a GA directorate and take a more relevant regulatory stance toward the industry in line with the results of the Aviation Safety Regulation Review (ASRR).
TAAAF is a co-operative group made up of Australia's peak aviation bodies designed to give the industry coherence when dealing with government and regulators. It is due to review and release an updated major policy statement next year.