RAAA Submissions

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RAAA Submissions 2017-01-29T20:29:06+00:00

Overview

An important role undertaken by the RAAA is responding to discussions papers, regulations and other documents issued by the Government, its departments and agencies in relation to issues affecting our members and aviation in regional Australia. The response(s) represent a balanced and collaborative view of the issue in question. This collaborative nature of our response is an important aspect of our work as it provides the ability of a sector wide view as opposed to supporting a singular vested view.

RAAA Submission: Senate inquiry into Remotely Piloted Aircraft (RPAS), Unmanned Aerial Systems (UAS) and associated systems
Senate Standing Committees on Rural and Regional Affairs and Transport

December 21st, 2016|0 Comments

The RAAA supports a proportionate approach to integrating RPAS into the aviation environment. However, in order to retain the excellent safety record of commercial Australian aviation, there is a need for a whole of government approach to RPAS policy and regulation to ensure safety, security and privacy.

There is a need to involve federal and state police in addressing unsafe or unlawful RPAS operations. They are best placed to deter, detect, investigate and as appropriate pursue relevant actions. A stronger public education campaign on the safe use of RPAS and the potential issues that can arise is required and CASA could take the lead in this area.

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RAAA Submission CAO 48.1 Improvements to the new rules for fatigue management for flight crew members
Civil Aviation Safety Authority

May 18th, 2016|0 Comments

The RAAA strongly feels that the proposed changes do not address the basic problem with the new regulations in that they impose needless and substantial costs on operators without a commensurate safety gain.

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RAAA Submission Request for new or changes to existing TAF Services
Bureau of Meteorology

May 4th, 2016|0 Comments

The RAAA submission supports Brisbane West Wellcamp Airports request for a change to TAF services.

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RAAA Submission Airport Curfew Administration Arrangements in Australia
Department of Infrastructure and Regional Development

April 29th, 2016|0 Comments

The RAAA submission provides specific responses to the dicussion paper on airport curfew administration arrangements. These are outlined in the Submission.

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RAAA Submission Australia’s draft State Safety Programme 2016
Department of Infrastructure and Regional Development

February 15th, 2016|0 Comments

The RAAA finds no significant issues with the Policy Statement as it is written. However we have serious concerns about the delta between the proposed situation and reality. The RAAA can cite numerous examples, but recognise most should be addressed in a separate forum to this submission. Therefore this submission will only identify high level concerns.

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RAAA Submission Aviation Rescue and Fire Fighting Services Regulatory Policy Review
Department of Infrastructure and Regional Development

February 3rd, 2016|0 Comments

The RAAA welcomes and supports this review into the regulatory settings around the provision of ARFFS at Australian airports.

In particular, the RAAA welcomes the approach to the establishment/disestablishment of an ARFFS at an airport.

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RAAA Submission CASA CD1510OS Civil Aviation Order 48.1
Civil Aviation Safety Authority

October 2nd, 2015|0 Comments

The RAAA calls for at least a three year delay in the promulgation of CAO 48.1. The existing CAO 48, with Industry Exemptions, is working and has been working well for many years. Strident calls for change are based mostly on industrial arguments, purportedly supported by scientific' data that has not yet convinced anyone of experience across the industry.

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RAAA Submission Long Term Pricing Agreement (LTPA) July 2016 to June 2021 Discussion Paper
Airservices Australia

May 6th, 2015|0 Comments

As stated by the RAAA over consecutive submissions the RAAA has a preference for services provided by Airservices Australia to be based on a network basis and is strongly opposed to location specific charging. It is our understanding that the ICAO principles for charging associated to airports and Air Navigation Services, although having similarities, differ substantially in the application.

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RAAA Submission Cost Recovery Implementation Statement (CRIS)
Civil Aviation Safety Authority

April 17th, 2015|0 Comments

It is the RAAA's view that the Draft Cost Recovery Paper (CRIS) should never have been released in its current form and should be withdrawn immediately. It is generally known across industry that the CRIS was released without the knowledge or approval of the CASA Board's Audit Committee or of CASA senior management.

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RAAA Submission Scope of Aviation Security Identification Cards (ASICs)
Office of Transport Security (OTS) Department of Infrastructure and Regional Development

January 20th, 2015|0 Comments

The RAAA views all the proposals as positive steps for reducing compliance obligations on regional airports. While there is a small chance of confusion during the implementation period the benefits appear to far outweigh any downside issues.

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RAAA Submission Airport and Aviation Security Inquiry
Senate Rural and Regional Affairs and Transport References Committeet

January 20th, 2015|0 Comments

Aviation is the most highly regulated industry in Australia with high associated regulatory and government imposed costs. Regional aviation services are essential services underpinning the economy of many regional and remote communities. For many years regional aviation margins have remained low with some aircraft operators providing a community service for remote communities at a loss, subsidised by either other more profitable routes or by State Government subsidies through a regulated route system.

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RAAA Submission Cutting Red Tape
Department of the Prime Minister and Cabinet

July 17th, 2014|0 Comments

The examples provided are indicators that historic government monopoly and service behaviour is having a significant and deleterious effect on the regional aviation industry's ability to grow and thrive. Such behaviours must be expunged and the dead-weight of the government aviation bureaucracies lifted from an industry that is essential to Australia's economic and social development. Excessive red-tape only serves bureaucracies and throttles the industries that actually pay the taxes that keep government functioning. Aviation is particularly susceptible to excessive red-tape because it is a highly regulated industry. Overblown safety and security arguments are often used to enable increases in red-tape and regulation for zero safety or operational gain.

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RAAA Submission Draft Report – Review of the Disability Standards for Accessible Public Transport 2002
Department of Infrastructure & Regional Development

July 11th, 2014|0 Comments

As we have previously highlighted in our response to this review, and also at the public consultations we attended, it is important that a "one hat fits all" approach is avoided. In relation to aviation there is an array of different sized aircraft and aircraft capability being used to provide services to the travelling public, a large difference in the size and capabilities of the operators providing these services, a multitude of business models being used to ensure the viability of operations, and a large difference between the airport infrastructure found at different locations around Australia.

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RAAA Submission – Aviation Safety Regulation Review Report
Department of Infrastructure & Regional Development

July 1st, 2014|0 Comments

The RAAA welcomes the release of the ASRR Report and commends Deputy Prime Minister Truss for delivering on his pre-election promise to put Australia's aviation regulatory system under the microscope. In general, the RAAA endorses the key aspects of the report and looks forward to seeing them implemented. In addition the RAAA recommends that the philosophy of just culture be incorporated into legislation through the Civil Aviation Act, CASRs and the Transport Safety Investigation Act, rather than through a CASA formulated policy document.

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RAAA Submission – Standing Committee on State Development Inquiry into Regional Aviation Services
NSW Legislative Council

March 24th, 2014|0 Comments

Regional aviation services are vital to the economic and social wellbeing and development of Australia's regional and remote communities. To most communities, the local aerodrome is a symbol of their prosperity, and a generator of business in the surrounding region. Nearly all communities wish to retain their local airport despite the cost of having them sometimes exceeding their direct income. However, the economics of regional air services are posing a threat to their existence, and creating a pressure for their rationalisation.

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RAAA Submission Aviation Safety Regulation Review
Department of Infrastructure & Regional Development

February 7th, 2014|0 Comments

The RAAA believes the bulk of its concerns stem from a poor culture in CASA which itself results from poor senior management and governance over several decades. If the Government of the day is not to take a more active role in the formulation of aviation policy generally and, through the relevant Department, a more active role in the management of the aviation bureaucracy, it must be prepared to create a more substantial and active Board to oversight CASA's management.

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Proposed Curfew at Brisbane Airport
Department of Infrastructure & Regional Development

October 29th, 2013|0 Comments

The RAAA is opposed to any attempt to limit operating hours of Brisbane Airport due to the substantial negative impact it would have on charter, FIFO and possibly RPT services to and from Brisbane. The RAAA endorses the Brisbane Airport Corporation response to the Discussion Paper.

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2012 Review of the Disability Standards for Accessible Public Transport 2002 (Transport Standards)
Department of Infrastructure & Regional Development

June 3rd, 2013|0 Comments

It is important to RAAA Members that persons with disabilities have an equal opportunity to travel by air. Critical to this for our members is that this travel allows them to travel with dignity. It is important to understand that the Australian domestic aviation industry is made up of a diverse range of Operators each with different capabilities not only due to the size of the operation but also due to the operating model they work under and the size of the aircraft used.

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Review of Aerodrome Forecast Services for the Aviation Industry
Bureau of Meteorology

March 28th, 2013|0 Comments

This review clearly notes among the critical stakeholders regional communities and regional airlines. The central thrust of the review's recommendations, however, is to substantially reduce services to those stakeholders with what the review itself says "comes at an economic and environmental cost". We say it also reduces regional infrastructure with consequent detrimental social impacts and potential reductions in safety.

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Draft State Aviation Strategy
Western Australian Government

January 29th, 2013|0 Comments

We agree very strongly with the statement in the Minister's Forward "it is imperative that Perth Airport now needs to bring forward the development of a third runway to avoid any further damage and disruption to air traffic".We agree very strongly with the statement in the Minister's Forward "it is imperative that Perth Airport now needs to bring forward the development of a third runway to avoid any further damage and disruption to air traffic".

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National Security Strategy
Department of Infrastructure & Transport

January 25th, 2013|0 Comments

The RAAA noted with interest the PM stated in a major recent national security speech that the national risk profile has changed significantly. Her new security priorities are clearly those risks associated with tensions arising because of behaviour between sovereign states. The lesser risk now is that of non-state protagonists such as terrorist groups. This group has been the main driver of aviation security policies for over a decade and this notion has been challenged by the PM.

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Brisbane Airport Runway Demand Management Scheme
Australian Competition and Consumer Commission

January 14th, 2013|0 Comments

The design of the new Runway Demand Management Scheme at Brisbane Airport raises a competition issue that affects 7 of the 10 operators who currently conduct charter and freight services out of Brisbane Airport and reduces customer choice from 10 operators to 3 operators (only one of which is an independent regional operator). Brisbane Airport Corporation (BAC) has introduced a Runway Demand Management Scheme (RDMS) to operate from the start of the Northern Winter 2012 scheduling season until such time as the new parallel runway is completed (anticipated to be 2020) or possibly longer. The RDMS will be administered by Airport Coordination Australia (ACA).

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NPRM 0903OS Australian Air Transport Operators – Certification and Management
Civil Aviation Safety Authority

September 5th, 2012|0 Comments

This regulation should not be capable of being used as a substitute for accident or incident reporting or for aircraft defect reporting. Nor should it be capable of being used as an investigative tool for enforcement action. The RAAA is opposed to any proposal to provide the Civil Aviation Safety Authority (CASA) with access to safety information provided to the ATSB through mandatory reporting.

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Enhanced Aviation Mandatory and Confidential Reporting
Australian Transport Safety Bureau

August 10th, 2012|0 Comments

The issues discussed are complex and require careful handling. Any mishandling of these issues could damage the ATSB/industry relationship to a point that would be significantly detrimental to both parties. The relationship with industry is fundamental to the quality of the ATSB's output and both should not be compromised by a change in reporting behaviour. In the long term, such a change could have negative safety consequences. Individuals and entities will only provide quality data if they feel free of external or third party threat. This is the basis of the ATSB/industry relationship and must not be diluted.

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Draft Regulation Impact Statement – Aircraft avionics equipage mandates for satellite-based IFR navigation, Mode S/ADS-B transponders and forward fitment of TCAS II version 7.1
Civil Aviation Safety Authority

July 10th, 2012|0 Comments

The RAAA has consistently supported these initiatives for their value in enhancing aviation safety in a cost effective way. In relation to the RIS, the RAAA does not question the overall savings anticipated. However, it does note that some of the savings claimed as future savings, especially in relation to the benefit of ADS-B in allowing more flexible routing, have been taken already. The expected greater efficiency in the management of approaches has been and continue will be lost if Traffic Flow systems do not operate effectively.

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NPRM 1202OS – May 2012 Fatigue Management for Flight Crew Members
Civil Aviation Safety Authority

June 29th, 2012|0 Comments

The RAAA considers that the proposals in the NPRM have been developed primarily with the "big end of town" in mind and do not sufficiently balance the cost impacts on regional aviation with any suggested safety benefit. Whilst the RAAA supports efforts to gain a better understanding of fatigue management and has generally favoured the flexibility allowed to operators to develop FRMSs as an alternative to the prescriptions of CAO 48, we are not aware of any body of evidence linking fatigue to accidents or incidents. We believe that CAO 48 with the Standard Industry Exemptions is working reasonably well and should be departed from with care. Although there is a growing body of literature on fatigue, its practical application to aviation is largely theoretical.

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CASR Part 142 Integrated and multi-crew pilot flight training and contracted recurrent training and checking Consultation Response
Civil Aviation Safety Authority

February 10th, 2012|0 Comments

Whilst the RAAA readily recognises the need for regulation of aviation activities to protect both users and third parties, it has a real concern for regulation that is not effective and efficient. Unnecessary regulation is an unwarranted cost imposition on an industry that is already hard pressed economically. Poor or unnecessary regulation which mandates compliance that cannot be justified in the interests of aviation safety brings the whole regulatory infrastructure into disrepute and involves a diversion of resources, both human and financial, which degrades rather than improves safety.

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Jet Fuel Supply Sydney Airport
National Competition Council

November 14th, 2011|0 Comments

The RAAA supports the two applications for declaration lodged by the Board of Airline Representatives of Australia (BARA) under Part IIIA of the Competition and Consumer Act 2010 (Cth) ("the Act"). Regional airlines, aero medical providers, charter companies, freight operators and other aviation entities operate frequently into and out of Sydney Airport and rely on the refuelling services provided at the airport. All of these operators depend on the ongoing availability of reasonably priced fuel and fuel services for the ongoing success and competitiveness of their operations. Fuel supply companies and on-airport refuellers must have access to the fuel infrastructure provided at Sydney Airport (JUHI facility and on-airport pipeline network) as well as the Caltex pipeline which delivers fuel to the airport JUHI (collectively referred to as the "Airport Fuel Infrastructure"), in order to provide their services to airlines and other customers.

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Discussion Paper 1102as Revised Plan for Aircraft Communication, Navigation and Surveillance Equipage in this Decade
Civil Aviation Safety Authority

November 7th, 2011|0 Comments

The key concern of the RAAA is safe operations and any regulatory and legislative means to achieve enhanced safety outcomes, deemed necessary as a result of robust safety based risk analysis, is most welcome. The RAAA is broadly supportive of those proposals that will progress directly to NPRM contained with CASA's Discussion Paper – Revised Plan for Aircraft Communication, Navigation and Surveillance Equipage in this decade (Document DP 1102AS September 2011).

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Review of Civilian Aviation Access to Air Force Fields
Royal Australian Air Force

November 1st, 2011|0 Comments

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Inquiry into Economic and Social Development in Central Western New South Wales
NSW Government Standing Committee on State Development

October 18th, 2011|0 Comments

Aviation is a natural partner for the highly dispersed regional and remote communities across Australia given the large distances often involved, and the need by many to access the major cities.This is true for regional NSW notwithstanding a number of challenges. There are now almost no intra-regional airservices, other than charter, with operators focussed on services between Sydney and the major regional towns. Most passengers, particularly those travelling for business, want to fly out from a regional centre and return later that evening.

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Inquiry into the use of ‘fly-in, fly-out’ (FIFO) workforce practices in regional Australia
House of Representatives Standing Committee on Regional Australia

October 5th, 2011|0 Comments

Fly-in/fly-out (FIFO) remains a popular and sustainable practice for many in the resource industry. It has been used in WA for decades and is increasingly used as a legitimate labour transport practice in other states and territories. The resources sector is experiencing ongoing skills shortages. FIFO enables a wider range of employees to access opportunities offered by the resources sector. These include indigenous people, women and skilled migrants.

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Economic Regulation of Airport Services Draft Report
Productivity Commission

September 29th, 2011|0 Comments

The RAAA is disappointed that in its draft report, the Commission has not attempted to balance the competing interests within the aviation industry and has viewed all the issues through the prism of ensuring that airport investment continues to be strongly encouraged. However, given the terms of reference, the Commission has focused, understandably, on the five major airports and their major customers - which are typically large, often international, airlines with considerable bargaining power.

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Inquiry into the Carbon Tax Pricing Mechanism
Senate Select Committee on the Scrutiny of New Taxes

August 12th, 2011|0 Comments

One of the primary objectives of the carbon tax (CT) is to encourage behaviour change so that higher carbon emitting activities are replaced by those that will emit less carbon. This is simply not possible with regional airlines given that their turbo-props and jet engines are already designed to operate at maximum fuel efficiency. Increasing fuel efficiency has been a large part of engine and airframe design for over fifty years. The CT will not result in less carbon emission per kilometre. In addition bio-fuels for aviation are 20-30 years away in terms of being available in commercial quantities.

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ACCC Preliminary View of Airservices Australia Price Notification
Australian Competition and Consumer Commission

July 27th, 2011|0 Comments

The Regional Aviation Association of Australia (RAAA) is appreciative the ACCC has offered us the ability to comment on its Preliminary View to the Airservices Australia Draft Price Notification. The RAAA supports the views expressed by the ACCC in that Airservices needs to be seen as transparent and accountable in their dealings with all stakeholders on all levels of their operations whether operational or capital in nature.

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Supplementary Submission Inquiry Into The Ratio Of Cabin Crew Members On Aircraft
House Standing Committee on Infrastructure and Communications

June 7th, 2011|0 Comments

The RAAA presents the following points in support of an Australian acceptance of the 1:50 Cabin Crew Ratio international standard: ICAO Annexes 1, 6, 8, 11, 13 and 14 require that the acceptable level of safety (ALoS) to be achieved shall be established by the State. This is repeated in the Department of Infrastructure and Transport document Australia's State Aviation Safety Program that was published in January 2011. ICAO defines acceptable level of safety as the minimum degree of safety that must be assured by a system in actual practice. The international standard for achieving an ALoS for cabin safety is a crewing ratio 1:50 and this standard is used in aircraft certification.

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Additional Submission Inquiry Into The Economic Regulation Of Airport Services
Productivity Commission

May 26th, 2011|0 Comments

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Airservices Australia Draft Price Notification Issues Paper
Australian Competition and Consumer Commission

May 11th, 2011|0 Comments

Regional air services form an essential part of Australia's transport infrastructure. Regional operators accept that AsA is a monopoly service provider that works within the framework of over-arching government policies of reasonable access for regional communities to high quality transport, telecommunications, education and health services. Government needs to ensure that AsA's service provision costs are reasonable and fair and not passed on as an open-ended user pay system.

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Context To The Ambidji Group’s Study On The Airspace Of 10 Class D Towers
Civil Aviation Safety Authority

April 20th, 2011|0 Comments

The Regional Aviation Association of Australia shares the ASTRA Council's concerns at both the report by Ambidji to the Office of Airspace Regulation (OAR) and the Airservices Australia (AsA) implementation plan. There has been an obvious lack of industry consultation on the implementation front which is clearly remiss given that it is the aviation industry that will pay for any roll-out. It is acknowledged however that OAR is seeking industry comment regarding the Ambidji Report in its own right.

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Inquiry Into The Economic Regulation Of Airport Services
Productivity Commission

April 13th, 2011|0 Comments

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Inquiry Into The Ratio Of Cabin Crew Members On Aircraft
House Standing Committee on Infrastructure and Communications

March 24th, 2011|0 Comments

The world standard from both a FAA and EASA standpoint with respect to cabin crew ratios is 1:50. This is a harmonised policy between these two bodies. Modern aircraft are certified to operate with this ratio and it is part of the manufacturer's recommended operating procedures. It is a desirable outcome that Australia also harmonise its cabin crew regulations with the above regulatory bodies.

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Enhanced ATS And Surveillance Arrangements At Regional Airports
Airservices Australia

March 9th, 2011|0 Comments

There has been considerable progress in airspace design since the Directive. The Office of Airspace Regulation is doing a sound job with its aeronautical risk assessments. The RAAA would wish to see this assessment process applied to the regional airports mentioned in the Direction. It would be timely to assess fully where regional Class D towers could safely use Class E or procedural Class C above, instead of an expensive and possibly unnecessary Class C with surveillance.

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Possible Security Classifications For Australian Airports
Department of Infrastructure & Transport

February 24th, 2011|0 Comments

We welcome the government's acknowledgement that passenger and baggage screening requirements impose substantial costs on the industry (both capital and operational) and that there should be flexibility in the settings that determine the levels of security applying. We also highlight that the regional aviation industry must rely on the threat analysis of OTS and can only react to draft security policies in a limited way and without the full policy context. All security measures presumably flow from detailed threat analyses, the competence of which the regional aviation industry must take on trust.

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2011 Long Term Pricing Agreement Draft Proposal
Airservices Australia

January 25th, 2011|0 Comments

The Regional Aviation Association of Australia (RAAA) is strongly opposed to pricing on a location specific basis and supports network charging. This has been the RAAA's consistent position for over ten years and has expressed this view regularly to AsA and the Australian government. Regional air services form an essential part of Australia's transport infrastructure. Regional operators accept that AsA is a monopoly service provider that works within the framework of over-arching government policies of reasonable access for regional communities to high quality transport, telecommunications, education and health services.

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The Transport Safety Investigation Regulations 2003 Draft Amendments
Australian Transport Safety Bureau

January 25th, 2011|0 Comments

The Regional Aviation Association of Australia (RAAA) is grateful for the opportunity to respond to these proposed amendments. The RAAA is happy to support the proposed amendments on the basis of the response the ATSB has received from one of our Members, Regional Express (Rex). Overall, the RAAA finds that the proposed amendments simplifies, clarifies and removes anomalies found in the previous regulations, but does note that the proposed amendments appear to increase the compulsory reporting requirements which may be a burden on operators with limited resources.

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CASA NPRM 1007os Mandatory Flight Simulator Training Proposed Amendments To Civil Aviation Orders (CAOs) 40.0 and 82.0
Civil Aviation Safety Authority

January 21st, 2011|0 Comments

If the government is determined to pursue a mandated approach for simulator training then it should be carefully tailored so as not to impose unnecessary costs and restrictions on operators. In particular mandatory requirements should not be imposed if there is no simulator available within Australia, as per the Canadian model that covers North American access to appropriate simulators. Operators of aircraft without in-country simulators should be given the opportunity to design CASA approved in-aircraft non-normal training regimes that would mirror the safety benefits of the simulator.

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CASA Discussion Paper 1006as Proposed Regulatory Plan In Support Of The Australian Government’s Aviation White Paper
Civil Aviation Safety Authority

December 17th, 2010|0 Comments

The RAAA welcomes the opportunity to comment on CASA's Discussion Paper(DP) Proposed Regulatory Plan in support of the Australian Government's Aviation White Paper, December 2009: Communication, Navigation and Surveillance Equipage in this decade (Document DP 1006AS October 2010). The key concern of the RAAA is safe operations and any regulatory and legislative means to achieve enhanced safety outcomes, deemed necessary as a result of robust safety based risk analysis, is welcome.

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Joint Study On Aviation Capacity In The Sydney Region
Department of Infrastructure & Transport

November 17th, 2010|0 Comments

The most important concern for regional airlines operating into Sydney is that the legislated access and protections for NSW regional operators with respect to Sydney Airport remain in place. Being able to fly into Sydney Airport using regional airlines ensures NSW regional communities have appropriate access to the state capital's facilities as well as sound domestic or international flight connections. In addition businesses and families in Sydney have a convenient way, through Sydney Airport, to carry out their activities in NSW regional towns. This is vital for the growth of the state and national economy.

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Inquiry Into Pilot Training And Airline Safety
Senate Standing Committee on Rural Affairs and Transport

September 29th, 2010|0 Comments

The focus of this Inquiry should remain on the competencies necessary to become a safe, proficient air transport pilot. There is no evidence to support the view that more hours equate to more safety however there is a good deal of evidence to support the use of competency-based curricula to train pilots and increase aviation safety. Australia's major airlines, the regional airlines and the RAAF provide sound examples of the use of competency versus a simplistic hours based approach to training/licensing.

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Sydney Airport Corporation Limited ACCC Price Notification For Regional Air Services
Australian Competition and Consumer Commission

August 6th, 2010|0 Comments

Regional airlines provide vital services to the Australian travelling public and along with regional airports are a key part of Australia's essential economic infrastructure. Regional airlines are a key driver within the domestic economy ensuring rapid mobility for workers, on-time service and freight delivery, and transporting many thousands of citizens and tourists across vast distances. Sydney Airport provides a very important service and is also a key part of Australia's essential economic infrastructure. Reasonable access to Sydney Airport is essential to the success of Australia's economy.

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Terminal Navigation Pricing Review
Airservices Australia

June 4th, 2010|0 Comments

It should be noted that regional aviation provides most of the training for pilots and many engineers that often directly benefits larger aviation companies as people progress their careers. This is a direct benefit provided by the regional aviation sector to another part of the industry. In addition regional aviation is a vital transport infrastructure network in a country with vast distances and relatively sparse population. The regional RPT, aero-medical, charter and fly-in/fly-out operations are fundamental in linking regional centres to the capital cities and vice versa. A large part of the economic growth of Australia can be attributed to the development of high quality regional aviation services.

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Inquiry into Airservices Australia’s Management Of Aircraft Noise
Senate Standing Committee on Rural and Regional Affairs and Transport

February 5th, 2010|0 Comments

Passenger carrying aircraft are now significantly quieter and this trend will continue. It is quite possible that within 20 years aircraft noise will not be a significant issue at most major capital city and regional airports. This is true for jet and turboprop aircraft. The aviation industry takes noise issues very seriously and is spending millions on researching ways of making aircraft quieter. The investment is ongoing and communities are and will reap the benefit.

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Safeguards For Airports And The Communities Around Them
Department of Infrastructure, Transport, Regional Development and Local Government

July 31st, 2009|0 Comments

Airports are important transport infrastructure assets that should be used primarily for commercial and private aviation activities. Airport designers and surveyors usually envisage around a 50 year utilisation. They attempt to design a safe and efficient airfield that will serve the needs of aircraft, the travelling public and mitigate as much as possible any negative impacts on the surrounding community through a series of buffer zones. Successful airfield design is a complex task that attempts to strike a balance between aviation needs and the community that the airfield serves.

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Review of Carriers’ Liability and Insurance
Department of Infrastructure, Transport, Regional Development and Local Government

July 7th, 2009|0 Comments

It is vital that any liability regime that is in place, in addition to providing equitable compensation to victims, does not jeopardise the sustainability of the regional aviation industry. The RAAA's view is that these objectives can best be achieved using the current liability model based on strict liability, but with a cap on the maximum compensation payable. Compensation regimes should achieve consistent outcomes for victims of transport accidents irrespective of which mode of transport is being used.

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Improving The Passenger Experience Quality Of Service Monitoring Of Airports
Department of Infrastructure, Transport, Regional Development and Local Government

July 2nd, 2009|0 Comments

During the preparation for major airport privatisation in 1996-7 there was considerable debate in senior public service circles as to whether the policy was in the nation's best interests. Even with conflicting advice the government of the day went ahead with the winding down of the FAC and the tendering of the airports. From a regional operator's view the policy has lead to a dramatic increase in costs with no or little increase in the quality of service from the airport owners.

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Inquiry Into The Impact Of The Global Financial Crisis On Regional Australia
House of Representatives Standing Committee on Infrastructure, Transport, Regional Development & Local Government

April 2nd, 2009|0 Comments

Initially, the challenge is to ensure the maintenance of existing regional air services. Further retreat will harm regional Australia by discouraging people from moving to regional centres and towns. It is understood that governments do not control markets but the removal of certain government charges imposed on regional airlines would encourage the development of air routes. It may be no coincidence that regional aviation flourished when there were few government charges and air traffic control and regulatory services were funded through consolidated revenue.

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The National Aviation Policy Green Paper
Department of Infrastructure, Transport, Regional Development, & Local Government

March 2nd, 2009|0 Comments

The sixteen priority areas identified by Government in the Green Paper are general goals that the RAAA supports. However, the RAAA proposes that they be expanded to include a focus on increased aviation research and development, as well as support for growth in aviation manufacturing capability. It is important that the construction of Australia's first national aviation policy is not simply a mapping exercise or a statement of high level intent but a serious attempt to chart a course for the future of aviation. It is also important to co-opt those who need to participate to achieve the policy's objectives.

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The Aeronautical Pricing Show Cause” Inquiry”
Department of Infrastructure, Transport, Regional Development, & Local Government

February 5th, 2009|0 Comments

It is the RAAA's understanding that complaints can be sent to the Minister or the Department and an assessment will be made as to whether the matter requires further investigation. If so, a letter will be issued asking the airport operator to show cause why its conduct should not be subject to a formal price inquiry under Part VIIA of the TPA or another appropriate investigative mechanism specified in the letter.

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Pricing Structure Options
Airservices Australia

October 24th, 2008|0 Comments

The RAAA is supportive of the current pricing model with a number of caveats which will be discussed later in the paper. It is understood that Airservices Australia (AsA) offers services on a modified cost recovery basis to enable the pool of air navigation services and ARFF costs to be recovered, 'while minimising the undesirable distortions to airport usage'. There are however a number of improvements to the model that can be considered. AsA is a monopoly provider of services and thus has significant and legislated responsibilities to the aviation industry, and operators in particular.

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Infrastructure Australia

October 15th, 2008|0 Comments

Australia has an extensive aviation history extending from the earliest days of controlled flight. This country saw early on the possibility of using air travel to link a small but widely dispersed population scattered across a large land mass. The growth of aviation has been an enormous boon on many development fronts, including mining and industry, aero-medical, tourism and access to education to name just a few.

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Australia’s Future Tax System
Department of Finance

October 9th, 2008|0 Comments

As highlighted in the forward of "Architecture of Australia's tax and transfer system", Australia faces significant economic, social and environmental challenges. It is the RAAA view that any taxation system, existing or proposed, needs to take into consideration the broader impact across all areas of the initiative and not solely from a revenue collection standpoint. It is also felt that current taxes, estimated at 125 separate taxes paid by Australians every year, needs to be reviewed and simplified to provide substantial incentives for Australian individuals and businesses to invest in a sustainable future for Australia.

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Carbon Pollution Reduction Scheme Green Paper
Department of Climate Change

September 9th, 2008|0 Comments

Depending on the source, the aviation industry is responsible for approximately 2 % of all global CO2 emissions and around 1% of domestic emissions. Even though this is a relatively small percentage the RAAA takes this issue seriously as a partner in Australia's efforts to reduce this country's overall emissions. The RAAA supports initiatives to provide a clean, productive and sustainable natural environment, but not at any cost.

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Senate Inquiry Into CASA
Senate Standing Committee on Rural and Regional Affairs and Transport

June 26th, 2008|0 Comments

It is government policy to appoint a competent CASA Board. The RAAA strongly supports the establishment of the new Board. To restore industry confidence in CASA the organisation must deliver comprehensible legislation that is compliant with ICAO standards and recommended practices.

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Towards a National Aviation Policy Statement
Department of Infrastructure, Transport, Regional Development and Local Government

June 26th, 2008|0 Comments

The RAAA argues strongly that regional aviation is a vital part of Australia's national infrastructure. Regional aviation policy should be developed alongside policies supporting national quality education, health, telecommunications and rail/road/port systems. RAAA members are keen to partner with government to ensure that regional communities have access to cost effective, efficient aviation services to reinforce the economic and social development of those communities.

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Criteria For Establishment And Dis-establishment Of CTAF (R)
Civil Aviation Safety Authority

February 1st, 2008|0 Comments

The RAAA position is that the CTAF (R) is very much a second rate solution to the problem of providing adequate safety for commercial passenger transport operations in the vicinity of non-towered aerodromes. A vastly preferred option would be for all passenger transport aircraft with 10 or more seats to carry and use TCAS. However such a solution could only be effective if all powered aircraft could be relied on to carry and use transponders, which in effect means mandating their carriage and use.

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Aviation Leislation Amendment (2007 Measures No 1) Bill 2007
Senate Standing Committee on Rural and Regional Affairs and Transport

July 4th, 2007|0 Comments

The RAAA is unaware of a major alcohol and/or other drug problem within the professional part of the industry, and believes that the concentration on the Hamilton Island accident (which may or may not have been attributable to drug and/or alcohol impairment) as justification for the proposed legislative action, only serves to illustrate how little evidence there is of a problem. The RAAA fully supports the provision of adequate security measures to prevent the occurrence in Australia of terrorist or criminal attacks on the industry. However it is concerned at a number of aspects of the current security regime.

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