What Constitutes Regular Public Transport?
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The following posts were moved from the thread "CASA Pulls Transair AOC." as they constitute a separate and important topic, unrelated to the previous thread subject.
The Dunnunda Moderators
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Creampuff, with respect, from reading your posts over the last week or two leads me to ask you a couple of questions ,
1. You have stated very recently that this version of CASA needs to seriously re-visit CAR 206, yet in the very recent past OLC and CASA FNQ were hanging their hats on this version of CAR 206 WRT RPT etc etc.
As you are acutely aware it was very damaging to many operations, these actions were taken from the same version of CAR 206, yet you are here now stating CAR 206 is inadequate, Q: How has it changed since you were on the wagon ?.
2. You have stated that CASA is not more or less accountable than ever, yet it would appear they are significantly less able to enact direct control over AOC's, no longer can CASA simply remove an AOC, with the new enforcement proceedure in place, CASA is still accountable, but significantly less empowered, Q: Why do you think this is ?.
I can not see how you can comfortably doubt CAR 206 or that CASA is unable to act ( due to the newish enforcement proceedures ) when you were an instrumental part of that process becoming law ?.
Torres, care to comment ?
3. Your statements here and actions of the past seem a little contradictory to me, have you've changed your outlook in the past couple of years ?.
Cheers
The following posts were moved from the thread "CASA Pulls Transair AOC." as they constitute a separate and important topic, unrelated to the previous thread subject.
The Dunnunda Moderators
----------------------------------------------------------
Creampuff, with respect, from reading your posts over the last week or two leads me to ask you a couple of questions ,
1. You have stated very recently that this version of CASA needs to seriously re-visit CAR 206, yet in the very recent past OLC and CASA FNQ were hanging their hats on this version of CAR 206 WRT RPT etc etc.
As you are acutely aware it was very damaging to many operations, these actions were taken from the same version of CAR 206, yet you are here now stating CAR 206 is inadequate, Q: How has it changed since you were on the wagon ?.
2. You have stated that CASA is not more or less accountable than ever, yet it would appear they are significantly less able to enact direct control over AOC's, no longer can CASA simply remove an AOC, with the new enforcement proceedure in place, CASA is still accountable, but significantly less empowered, Q: Why do you think this is ?.
I can not see how you can comfortably doubt CAR 206 or that CASA is unable to act ( due to the newish enforcement proceedures ) when you were an instrumental part of that process becoming law ?.
Torres, care to comment ?
3. Your statements here and actions of the past seem a little contradictory to me, have you've changed your outlook in the past couple of years ?.
Cheers
SF
CASA has a duty to enforce 206, whatever it says. The fact that CASA has been utterly incompetent in achieving any outcome on Commissioner Staunton’s fifth recommendation, does not affect in any way CASA’s duty to enforce the existing provision.
CASA’s interpretation of the existing provision has survived external review. I’ve posted this link – oh, about a dozen times – on prune. I commend the decision to you: http://www.austlii.edu.au/au/cases/c.../1999/329.html. Please read the paragraphs under the heading “The Regular Public Transport Issue”, twice.
As an aside, I note that the regulatory ‘reform’ talkfest on classification of operations now includes none other than Bill Hamilton, who has frequently opined about the ease with which simple rules can be made. I do hope he puts his keyboard where is mouth is, and quickly taps out those oh-so-simple classification of operations rules to an expectant and adoring public soon.
Wrong. Read section 30DC of the Act, twice.
Cheers
CASA has a duty to enforce 206, whatever it says. The fact that CASA has been utterly incompetent in achieving any outcome on Commissioner Staunton’s fifth recommendation, does not affect in any way CASA’s duty to enforce the existing provision.
CASA’s interpretation of the existing provision has survived external review. I’ve posted this link – oh, about a dozen times – on prune. I commend the decision to you: http://www.austlii.edu.au/au/cases/c.../1999/329.html. Please read the paragraphs under the heading “The Regular Public Transport Issue”, twice.
As an aside, I note that the regulatory ‘reform’ talkfest on classification of operations now includes none other than Bill Hamilton, who has frequently opined about the ease with which simple rules can be made. I do hope he puts his keyboard where is mouth is, and quickly taps out those oh-so-simple classification of operations rules to an expectant and adoring public soon.
no longer can CASA simply remove an AOC
Cheers
Last edited by Creampuff; 3rd Nov 2006 at 19:00. Reason: left out 'not' before 'affect' in second sentence.
Stink Finger. I’ll not be drawn on the issue; I’ve mellowed with age and no longer really care. 
Suffice to say that, in my opinion CAR 206 is a meaningless, “rubbery” regulation open to a plethora of various interpretations over the years, at the Regulator’s discretion and to suit the Regulator’s need of the moment. I accept others may not agree with that view.
I had correspondence and discussions over a number of years with numerous CASA representatives including Leroy Keith, Mick Toller, CASA Canberra and Cairns staff – even Creampuff – with respect to CAR206, to no avail. In the mid 1990s I discussed the Cape York Australia Post/RASS mail services operation with Leroy Keith and other senior CASA staff. At that time CASA determined those services were RPT in accordance with the then in vogue interpretation of CAR206. In later years, the CAOs were amended with respect to the definition of an airfield, to enable those same services to be operated as RPT.
In recent years, CASA have determined those same air services are not RPT under the same Regulations, as they are not available “to persons generally”, only residents of the various stations which receive Australia Post and RASS subsidized air services.
As the islands of the Torres Strait are by legislation (including the Torres Strait Islands Access Act 1984), closed reserves requiring permission for non residents to visit, those air services are not available to "persons generally" and one wonders why the same rubbery interpretation of CAR206 is not applied to determine Torres Straits island air services are not RPT?
The terms “fixed terminals” and “specified routes” had clear definition under the pre 1988 ANRs (ANR197 to 203 from memory?) but have no definition under the current CARs. Why the various Courts have not leveled criticism against CASA for it’s so far eighteen years of incompetent and inconclusive regulatory reform is beyond me.
Creamie correctly states:
Regardless of Seaview, it's the plethora of CASA ever changing interpretations that are the concern!!
If CASA was required to hold an AOC and took eighteen years to amend it’s “Operations Manual” of legislation and regulation, under the standards it attempts to impose on those it regulates, it would long since have lost it’s AOC and the Chief Pilot and management defrocked as charlatans!
If the Coral Sea Air matter before the AAT is to be used as a precedent for determining a definition of RPT, one must also consider the similar Uzu Air matter before the AAT, which resulted in CASA re-instating that AOC.
Creamie, I love this understatement from the AAT Decision:
No doubt the Tribunal Deputy President detected some performance shortcomings in the dinosaurs that then populated the Jurassic Cairns office!
As the final ATSB Report and Coronial Inquiry of the tragic Lockhart River accident unfolds, I suspect CASA shortcomings and incompetence will again be highlighted.
We can only hope this time someone is listening!
There is a life after aviation and I’m enjoying it! You wish to debate CAR206, find someone who cares!
Suffice to say that, in my opinion CAR 206 is a meaningless, “rubbery” regulation open to a plethora of various interpretations over the years, at the Regulator’s discretion and to suit the Regulator’s need of the moment. I accept others may not agree with that view.
I had correspondence and discussions over a number of years with numerous CASA representatives including Leroy Keith, Mick Toller, CASA Canberra and Cairns staff – even Creampuff – with respect to CAR206, to no avail. In the mid 1990s I discussed the Cape York Australia Post/RASS mail services operation with Leroy Keith and other senior CASA staff. At that time CASA determined those services were RPT in accordance with the then in vogue interpretation of CAR206. In later years, the CAOs were amended with respect to the definition of an airfield, to enable those same services to be operated as RPT.
In recent years, CASA have determined those same air services are not RPT under the same Regulations, as they are not available “to persons generally”, only residents of the various stations which receive Australia Post and RASS subsidized air services.
As the islands of the Torres Strait are by legislation (including the Torres Strait Islands Access Act 1984), closed reserves requiring permission for non residents to visit, those air services are not available to "persons generally" and one wonders why the same rubbery interpretation of CAR206 is not applied to determine Torres Straits island air services are not RPT?
The terms “fixed terminals” and “specified routes” had clear definition under the pre 1988 ANRs (ANR197 to 203 from memory?) but have no definition under the current CARs. Why the various Courts have not leveled criticism against CASA for it’s so far eighteen years of incompetent and inconclusive regulatory reform is beyond me.
Creamie correctly states:
"CASA has a duty to enforce 206, whatever it says.
If CASA was required to hold an AOC and took eighteen years to amend it’s “Operations Manual” of legislation and regulation, under the standards it attempts to impose on those it regulates, it would long since have lost it’s AOC and the Chief Pilot and management defrocked as charlatans!
If the Coral Sea Air matter before the AAT is to be used as a precedent for determining a definition of RPT, one must also consider the similar Uzu Air matter before the AAT, which resulted in CASA re-instating that AOC.
Creamie, I love this understatement from the AAT Decision:
”Pausing here, I cannot refrain from noting that the respondent, through its servants, adopted a somewhat cavalier attitude towards Captain Baldwin's application, and that he has had a raw deal.”
As the final ATSB Report and Coronial Inquiry of the tragic Lockhart River accident unfolds, I suspect CASA shortcomings and incompetence will again be highlighted.
We can only hope this time someone is listening!
There is a life after aviation and I’m enjoying it! You wish to debate CAR206, find someone who cares!
Last edited by Torres; 3rd Nov 2006 at 21:09.
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Creampuff,
Thanks, although i was sort of hoping you'd answer my questions. To me it very much seems you've changed your opinion on a number of issues, i am interested to know why.
Torres,
Im glad you feel that quote:" I’ll not be drawn on the issue; I’ve mellowed with age and no longer really care ", took only a couple hundred word to explain
.
Thanks, although i was sort of hoping you'd answer my questions. To me it very much seems you've changed your opinion on a number of issues, i am interested to know why.
Torres,
Im glad you feel that quote:" I’ll not be drawn on the issue; I’ve mellowed with age and no longer really care ", took only a couple hundred word to explain
.
Well, unlike the Regulator, I have held the same opinion for at least sixteen years which opinion is also held by a number of CASA staff.
That opinion is not necessarily supported by Court precedence over the years nor I’m sure, by Creampuff, however as you note, his opinions have changed over the years. Surprisingly perhaps, I now support many of his comments.
The issue has been debated to death. There can not be an unambiguous definition of RPT operations until CASA completes the task it began eighteen years ago.
How it can
I have no idea. 
And don’t forget Mr Byron’s prophetic – or is that pathetic - words 21 months ago, on February 15, 2005:
I have no reason to believe the regulatory reform process will be completed in my life time!
That opinion is not necessarily supported by Court precedence over the years nor I’m sure, by Creampuff, however as you note, his opinions have changed over the years. Surprisingly perhaps, I now support many of his comments.
The issue has been debated to death. There can not be an unambiguous definition of RPT operations until CASA completes the task it began eighteen years ago.
How it can
”…..enforce 206, whatever it says.”
And don’t forget Mr Byron’s prophetic – or is that pathetic - words 21 months ago, on February 15, 2005:
Mr Byron—I anticipate we would start sending some of them from about the middle of this year. I do not see this delaying the overall program excessively. We have an action item to develop a plan to forward to the minister about when we plan to have them to the minister, and I assume that plan would be done in the next couple of months. I would be hopeful that it would not be long after early 2006 that most of the draft rules are delivered to the minister.
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Rubbery rules?
When I first started flying, we ran a scheduled service in a six seat, single engine PA32. We sold seats, and published timetables. I believe we had a "reg 203 exemption" to allow this to happen. Seems Our regulator can change the rules at will. I also remember, we got a letter from the regulator warning us that we had been naughty. We had done two charter flights, in the same PA32 within one month, and the route flown on these two flights was actually along an airline route. This was not permitted. I wpuld have thought the airline concerned would be able to compete with a PA32.
Is this safety regulation, or regulation for commercial purposes. Is our regulator permitted to dabble in the commercial regulation of aviation. Is it right and proper for them to allow some operators to do things the law prohibits? I am aware that the commonwealth is not permitted to make laws which restrict trade between the states, and sometimes restricting flights may be considered to do this.
Years later I was flying what was really scheduled charter flights, which did not always follow the same route, but varied to suit the loading etc on that day. One time I had an officer from our ragulator on board, checking the operation. He told me that it was really not quite according to the rules, but that they realised there was a need for such a service.
And we did mail runs on the same day each week, carrying mail, freight, and the odd passenger. These have been happening for many decades.
Let's look at some of the rules governing charter flights. Our legal extablishments have ruled that a flight that is booked for the following day is in fact a "scheduled" flight.(see the Coral Sea Airlines proceedings) And I believe that if the route is agreed on it is then "along a fixed route,and between fixed terminals", and usually charter companies offer their services "to the public generally" This seems to make it RPT, even if it only happens once. And that makes it illegal. And it happens all over the country, every day. So charter companies appear to be breaking the law all the time, and CASA are permitting this to happen, all the time.
Some(like Coral Sea Airlines) will lose their AOC because of this, but most will not. Unless they upset CASA.
The mail runs were made RPT, by city dwellers, and the people of the outback who depend on such services, objected strongly. Now, apparently they are not RPT any more. Nothing has changed. the same aeroplanes are still flying the same routes, carrying the same things, using the same schedules. But lots of city people are running around with peices if paper, changing the rules, and changing them back. And nobody really knows what the rules actually are this week.
Is this safety regulation? Surely it would be safer if we all knew what the rules are this week and every week. The uncertainty and stress caused by the ever changing rukes, and varying interpretations of the same rules do not help safety.
If you look at the Phelan papers, and/or just do some research yourself you will find a number of charter companies have been put out of business by our regulator, for running "scheduled services" and such things. Not for safety breaches. Our "safety authority" shut them down for breaching commercial items. Is this commercial regulation? It does not appear to be safety regulation. In many cases there does not seem to be any safety issue involved.
There is a need for major change.
Why don't we stop pretending that a C210 is the same as a Boeing? And fooling the public. Why don't we call them light aircraft? Anything below 5700kg. Why don't we licence them to provide "light aircraft services" to the public? Scheduled or unscheduled. The scheduled part is purely commercial, and has no bearing on safety.
At the moment a charter company may be operating a Gulfstream, or a C210. The public does not know. They just know that it is an unscheduled service.
And the charter operators do not know what they will be permitted to do next week. Or when they will be hauled over the coals for running a "scheduled service". Many are going out of business. And there are safety issues that our regulator does not seem to care about.
Is this safety regulation, or regulation for commercial purposes. Is our regulator permitted to dabble in the commercial regulation of aviation. Is it right and proper for them to allow some operators to do things the law prohibits? I am aware that the commonwealth is not permitted to make laws which restrict trade between the states, and sometimes restricting flights may be considered to do this.
Years later I was flying what was really scheduled charter flights, which did not always follow the same route, but varied to suit the loading etc on that day. One time I had an officer from our ragulator on board, checking the operation. He told me that it was really not quite according to the rules, but that they realised there was a need for such a service.
And we did mail runs on the same day each week, carrying mail, freight, and the odd passenger. These have been happening for many decades.
Let's look at some of the rules governing charter flights. Our legal extablishments have ruled that a flight that is booked for the following day is in fact a "scheduled" flight.(see the Coral Sea Airlines proceedings) And I believe that if the route is agreed on it is then "along a fixed route,and between fixed terminals", and usually charter companies offer their services "to the public generally" This seems to make it RPT, even if it only happens once. And that makes it illegal. And it happens all over the country, every day. So charter companies appear to be breaking the law all the time, and CASA are permitting this to happen, all the time.
Some(like Coral Sea Airlines) will lose their AOC because of this, but most will not. Unless they upset CASA.
The mail runs were made RPT, by city dwellers, and the people of the outback who depend on such services, objected strongly. Now, apparently they are not RPT any more. Nothing has changed. the same aeroplanes are still flying the same routes, carrying the same things, using the same schedules. But lots of city people are running around with peices if paper, changing the rules, and changing them back. And nobody really knows what the rules actually are this week.
Is this safety regulation? Surely it would be safer if we all knew what the rules are this week and every week. The uncertainty and stress caused by the ever changing rukes, and varying interpretations of the same rules do not help safety.
If you look at the Phelan papers, and/or just do some research yourself you will find a number of charter companies have been put out of business by our regulator, for running "scheduled services" and such things. Not for safety breaches. Our "safety authority" shut them down for breaching commercial items. Is this commercial regulation? It does not appear to be safety regulation. In many cases there does not seem to be any safety issue involved.
There is a need for major change.
Why don't we stop pretending that a C210 is the same as a Boeing? And fooling the public. Why don't we call them light aircraft? Anything below 5700kg. Why don't we licence them to provide "light aircraft services" to the public? Scheduled or unscheduled. The scheduled part is purely commercial, and has no bearing on safety.
At the moment a charter company may be operating a Gulfstream, or a C210. The public does not know. They just know that it is an unscheduled service.
And the charter operators do not know what they will be permitted to do next week. Or when they will be hauled over the coals for running a "scheduled service". Many are going out of business. And there are safety issues that our regulator does not seem to care about.
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Hi Bushy,
What a brilliant point you make, the regulations are "Rubbery".
CAR 1 ( definitions )was supposed to be the answer to many similar problems, but we still are stuck without a definition of the most elemental ones, what is a fixed route, what is to the general public, which is a fixed schedule, what is a fixed terminal ?.
All of these could very simply be defined in CAR 1 and the problem ends.
Due to missing information from CAR 1 , there are a multitude of Rulings to explain these types of concerns, also end of problem in those cases.
It would appear this thread is being hi-jacked, sorry folks.
Re: Transair, in my opinion they are no better or worse than most Aviation companies, this is a ass covering exercise, if i was BB, i would be supporting Transair, mentoring even ( taking a very personal interest ), standing up for the actions of my FOI / AWI's and TLFO's, atleast that way i would appear in control.
"What do you mean you were not happy with Transair, yet you let them keep flying ?", that would be a hard situation to politically survive.
What goes up, might come down.
What a brilliant point you make, the regulations are "Rubbery".
CAR 1 ( definitions )was supposed to be the answer to many similar problems, but we still are stuck without a definition of the most elemental ones, what is a fixed route, what is to the general public, which is a fixed schedule, what is a fixed terminal ?.
All of these could very simply be defined in CAR 1 and the problem ends.
Due to missing information from CAR 1 , there are a multitude of Rulings to explain these types of concerns, also end of problem in those cases.
It would appear this thread is being hi-jacked, sorry folks.
Re: Transair, in my opinion they are no better or worse than most Aviation companies, this is a ass covering exercise, if i was BB, i would be supporting Transair, mentoring even ( taking a very personal interest ), standing up for the actions of my FOI / AWI's and TLFO's, atleast that way i would appear in control.
"What do you mean you were not happy with Transair, yet you let them keep flying ?", that would be a hard situation to politically survive.
What goes up, might come down.
Bushy. At least someone is old enough to know what a “specified route” is! 
Air Navigation Regulations 1947, signed by Governor General Sir William McKell on August 6, 1947, and Australia’s Two Airline Agreement, defined a “specified route” as a dedicated airline route, allocated exclusively to the two airlines, Ansett/ANA and TAA and shown and defined on aeronautical charts.
Other commercial operators could fly over a “specified route” only once in 28 days, and in later changes, not within eight hours before, or four hours after a scheduled airline service (the Eight Hour/Four Hour Rule.)
(A “fixed terminal” was a Commonwealth owned airline terminal, defined in legislation and jointly tenanted by the two airlines. Only Ansett/ANA and TAA could conduct air services from the “fixed terminals”, other operators were required to conduct operations from other than defined airline terminals.)
Intrastate airline operations could be granted an airline licence (by both the Commonwealth and each State) – Airlines of NSW, East West, Butlers, Bush Pilots etc – but were excluded from interstate airline operations by virtue of the Two Airline Agreement. Their demise predictably coincided with the end of the Two Airline Agreement.
Air charter operators, limited to aircraft not exceeding 12,500 pounds max gross weight (“half a DC3”), could operate intrastate and interstate scheduled air services by obtaining an exemption to ANR203, but were not permitted to operate over the airline's “specified routes” except with approval once in 28 days.
CAR206 is an attempt to define the various nature of commercial flying operations. Unfortunately, certain definitions were lost in the transition from ANRs to CARs in 1988. Due to the ambiguity or lack of definitions of terms, it has been subject to a plethora of interpretations by CAA and CASA over the intervening years.
One senior CASA manager of no particular talent, ability or intelligence once told me that any aircraft departing one airport with the specific intention of landing at another airport, was operating over a "specified route".
He didn't seem to comprehend that most aircraft have a tendency to do exactly that!
Air Navigation Regulations 1947, signed by Governor General Sir William McKell on August 6, 1947, and Australia’s Two Airline Agreement, defined a “specified route” as a dedicated airline route, allocated exclusively to the two airlines, Ansett/ANA and TAA and shown and defined on aeronautical charts.
Other commercial operators could fly over a “specified route” only once in 28 days, and in later changes, not within eight hours before, or four hours after a scheduled airline service (the Eight Hour/Four Hour Rule.)
(A “fixed terminal” was a Commonwealth owned airline terminal, defined in legislation and jointly tenanted by the two airlines. Only Ansett/ANA and TAA could conduct air services from the “fixed terminals”, other operators were required to conduct operations from other than defined airline terminals.)
Intrastate airline operations could be granted an airline licence (by both the Commonwealth and each State) – Airlines of NSW, East West, Butlers, Bush Pilots etc – but were excluded from interstate airline operations by virtue of the Two Airline Agreement. Their demise predictably coincided with the end of the Two Airline Agreement.
Air charter operators, limited to aircraft not exceeding 12,500 pounds max gross weight (“half a DC3”), could operate intrastate and interstate scheduled air services by obtaining an exemption to ANR203, but were not permitted to operate over the airline's “specified routes” except with approval once in 28 days.
CAR206 is an attempt to define the various nature of commercial flying operations. Unfortunately, certain definitions were lost in the transition from ANRs to CARs in 1988. Due to the ambiguity or lack of definitions of terms, it has been subject to a plethora of interpretations by CAA and CASA over the intervening years.
One senior CASA manager of no particular talent, ability or intelligence once told me that any aircraft departing one airport with the specific intention of landing at another airport, was operating over a "specified route".
He didn't seem to comprehend that most aircraft have a tendency to do exactly that!
SF: Your perception that I have changed my position on classification of operations, is not correct.
My view as to what CAR 206 means has never changed – I am comforted by the fact that the independent umpire agrees with it.
My view as to CASA’s duty to enforce CAR 206 has never changed.
I did not say “recently” that CAR 206 needs to be “revisited”. Commissioner Staunton said it in far stronger words, 10 years ago. I have consistently highlighted CASA’s abject failure to produce any outcomes in respect of Commissioner Staunton’s CAR 206 recommendation, on this very forum.
Believe me, the people with the duty to enforce CAR 206 would jump for joy if any one of the successive head dabblers with responsibility for regulatory ‘reform’ had actually delivered on any of their promises. However, the successive failure of those head dabblers to deliver on those promises, or to take some leadership responsibility by stating a clear policy position on what they say CAR 206 means and how it should be enforced in the interim, produces the kinds of circumstances highlighted in this thread.
Successive head dabblers and Ministers could have fixed this mess in a stroke of the pen. Please don’t visit their sins on the poor sods who have a duty to enforce 206 in a policy and leadership vacuum.
My view as to what CAR 206 means has never changed – I am comforted by the fact that the independent umpire agrees with it.
My view as to CASA’s duty to enforce CAR 206 has never changed.
I did not say “recently” that CAR 206 needs to be “revisited”. Commissioner Staunton said it in far stronger words, 10 years ago. I have consistently highlighted CASA’s abject failure to produce any outcomes in respect of Commissioner Staunton’s CAR 206 recommendation, on this very forum.
Believe me, the people with the duty to enforce CAR 206 would jump for joy if any one of the successive head dabblers with responsibility for regulatory ‘reform’ had actually delivered on any of their promises. However, the successive failure of those head dabblers to deliver on those promises, or to take some leadership responsibility by stating a clear policy position on what they say CAR 206 means and how it should be enforced in the interim, produces the kinds of circumstances highlighted in this thread.
Successive head dabblers and Ministers could have fixed this mess in a stroke of the pen. Please don’t visit their sins on the poor sods who have a duty to enforce 206 in a policy and leadership vacuum.
History in the making - I could not agree more!
I know exactly what should constitutes a "scheduled air service", particularly into unlicenced airports or airports which may be within the operating aircraft capability but not meet CAO minimum requirements, but should the people of rural Australia be denied cost effective air services simply because CASA is too incompetent to delivery appropriate legislation?
More pity the rural air service and GA operators, trying to define their operations in the face of very ambiguous regulation and multiple definitions from the regulator.
I have no confidence in the current crop of CASA "head dabblers" to delivery appropriate regulatory reform at any time in the foreseeable future.
Eighteen years so far - there's a few more jobs-to-retirement in this project yet!
I know exactly what should constitutes a "scheduled air service", particularly into unlicenced airports or airports which may be within the operating aircraft capability but not meet CAO minimum requirements, but should the people of rural Australia be denied cost effective air services simply because CASA is too incompetent to delivery appropriate legislation?
More pity the rural air service and GA operators, trying to define their operations in the face of very ambiguous regulation and multiple definitions from the regulator.
I have no confidence in the current crop of CASA "head dabblers" to delivery appropriate regulatory reform at any time in the foreseeable future.
Eighteen years so far - there's a few more jobs-to-retirement in this project yet!
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Right
I agree with Torres. The ambiguous rules and definitions are a HUGE problem, for operators. There is no certainty, and CASA can attack at any time, using this uncertainty. I wonder if that is the purpose of these unsatisfactory rules.
Things like this are one of the reasons why the industry has little respect for CASA. And this lack of respect makes it harder for them. And there are many other negative effects
.
Not just eighteen years. We seem to be still using some of the rules from 1947.
Things like this are one of the reasons why the industry has little respect for CASA. And this lack of respect makes it harder for them. And there are many other negative effects
.
Not just eighteen years. We seem to be still using some of the rules from 1947.
