Comment
The Aircraft Owners and Pilots Association's (AOPA) Project Eureka papers released last week contain several recommendations the authors believe will revitalise the general aviation industry in Australia.
It has been hailed as the last stand for GA, hence the name "Eureka", after the Ballarat miners' revolt in 1854, rather than the Greek word meaning "I have found it."
Eureka collects the expert opinions of several general aviation advocates and uses their voices to show how AOPA's solutions for GA are connected to the realities. It exhorts the government to recognise the opportunities that the industry can provide to all Australians, and the ramifications of the very real possibility of the industry disappearing.
For most part, the recommendations reinforce the cornerstone arguments of key general aviation advocates, which adds further weight to those aspects and presents a consistent message to the government. The Eureka recommendations are:
- Automatic approval of overseas licences and regulations.
- Aircraft maintenance regs should follow the regulations of the country of manufacture
- Fully implements the Aviation Safety Regulation Review
- Amend the Civil Aviation Act (the Act) to allow the current CASA CAR/CAO EASA bias rules to apply to only Part 121 RPT operators and not GA
- Amend the Act to allow US FAR or NZ CAA rules for general aviation
- Mandate US FARs to save costs and get the regulatory reforms completed
- Adopt the NZ model for mandating ADS-B, which comes into force one year after the US mandate, therefore 2021
- A stay of en-route charges for 10 years for operators that have already upgraded to ADS-B and paid a higher cost for conformance
- An investigation into the 2009 Regulatory Impact Statement (RIS) and the assumptions made
- Abolish barriers against overseas pilots and engineers from countries with compatible standards to Australia
- Re-introduce independant flying instructors with no requirement to hold an Air Operator's Certificate (AOC)
- Remove user-pays fees for general aviation aircraft and operations
- Sell Airservices Australia and use the revenue to re-invest in general aviation for development and technology and to buy back the secondary capital city Class D airports
- Charges from the privatised Airservices to be subject to review
- Amend the Act to require the regulator to take into account the sustainablility of the general aviation industry
- Rename CASA to the Civil Aviation Division and re-absorb it back into the Department of Infrastructure and Regional Development
- Modify Class 2 medical requirements to bring them into line with recreational standards and have the medical examiners issue the certificates
- Fully implement the National Airspace System (NAS)
- CASA to consult with overseas National Aviation Authorities (NAA) to determine if Jabiru engine failures are the result of maintenance practices in Australia
- CASA to establish a program to allow individual Jabiru-powered aircraft to be inspected and have the restrictions lifted.
It takes only one read through to establish the over-arching desire of Project Eureka: get rid of CASA and simply adopt the US way of doing things. It's a call that has been echoing through general aviation for some years now, and one that, of all recommendations, we are most unlikely to get. If any paper or policy had the credibility to recommend this, it was the Aviation Safety Regulation Review (ASRR), and David Forsyth and his team didn't see the need to include such a drastic step in their report to Canberra.
This is not an admonishment of AOPA for including this in Eureka; GA is in such a state that any solution is probably hidden deep inside something improbable, so all options are up for exploration, provided they are presented with integrity.
However, no matter how logical it would be to adopt the FARs as our own, any recommendation to do so (again, something not in the ASRR) ignores the political imperative of not wanting to tell the taxpayers they've wasted hundreds of millions of dollars over 28 years and gotten nowhere (albeit the truth!). There are some things the pollies will be red-penning the moment they see them, and this will be one of them. Including this in Eureka may have a side-effect that is of more value: it may prompt the new minister to ask "is this right that reform has gone on for 28 years when we could have used the US system?" There is no answer CASA can give that will cover them in glory.
Some recommendations, such as the ADS-B mandate, full NAS implementation and DAME medicals, are battlegrounds still being fought over, and right now each one has reached stalemate. They needed to be included or Eureka could not be held up as the definitive needs of general aviation. In the case of ADS-B and NAS, they are issues plagued by contention within the GA ranks: we're not all in formation with opinions and solutions ... except the medical thing. The failure to implement the DAME medical despite promises from three Directors of Aviation Safety and recommendations from the ASRR is still bewildering.
AOPA has come up with one truly innovative idea: the industry trust fund. The idea is that the government sell off Airservices and use the money to create an industry trust fund for technological development and venture capital, and the big one, to buy back the leases on the secondary capital city airports. This is blue-sky thinking, and unfortunately will remain that way. The cost of buying back the leases to airports like Bankstown, Archerfield, Jandakot and the other ex-GAAPs would be so astronomical that there'd be nothing left of the cash from the AsA sales. The leaseholders would probably demand also compensation for the money they'd invested as well as loss of income from having their projected cash flows cut off. A solution needs to be found for the ails the government has inflicted on GA by selling the leases, but I don't think buying them back is an option; the cash outlay to do so would be just too high. I would not have tied that to the industry trust fund concept.
It was good to see AOPA push for independent flying instructors that don't need an AOC. This would bring aviation back to towns that lost their flying schools simply because the cost of maintaining an AOC was too high. The biggest entry barrier to pilot training is the cost, and most of it is unnecessary burden that brings about no safety benefit for anyone. Go to any Australian flying school and ask to see their ops manual and you will understand how bad this is immediately after you are pointed to a shelf containing about 10-12 lever arch folders. This is counter to aviation safety because it means the best instructors have to spend time shuffling papers and not out there passing on years of flying experience. AOPA, push hard for this one; it's not out of reach.
As a working document, I believe Project Eureka has many strengths and many weaknesses, which is something that could in truth be said about most aviation papers presented in the last 20 years, except the White Paper ... that had no strengths. If the government was to implement all the recommendations, we would see a complete revolution in the general aviation industry in Australia. Perhaps that's what is needed to revitalise GA, but is the government willing to do that? It all comes down to whether or not they really want a GA industry, which is a question that has never been satisfactorily answered in word or deed.
With project Eureka, as with the impending The Australian Aviation Associations Forum (TAAAF) policy paper, we won't really know the impact until the goverment responds (if they do). Stand alone, I don't believe Project Eureka will achieve anything; papers are very easy to file away. It's true value is as a position paper for AOPA. Now they need to start an exhaustive program of constant lobbying to support their recommendations and show leadership for the GA community.