The Terms of Reference (ToR) for the Federal Government's White Paper don't properly address current issues in the aviation industry, according to a submission made by the Regional Aviation Association of Australia (RAAA).
Accompanied by a cover letter signed by RAAA CEO Steve Campbell dated 8 March, the submission focuses on the purpose of the ToRs and a perceived lack of understanding of the aviation industry.
"The RAAA recognises the importance of a forward-looking White Paper, however, we are concerned that the focus asset out in the Purpose section does not articulate clearly the need to overcome current burdens on the industry," the submission states.
"There is a need to understand where the industry is at today before you can assume what it will be tomorrow. The RAAA would like to see a statement that will ensure, through this process, that a snapshot of the health of the industry is undertaken to better understand what levers can be used to bridge the gap to what will be required in the years ahead."
The ToRs, which were open to public consultation from 7 February to 10 March, covered:
- aviation’s role in economic development, trade and the visitor economy – general, domestic, regional and international aviation
- how to maximise the aviation sector’s contribution to achieving net zero carbon emissions including through sustainable aviation fuel and emerging technologies
- changing aviation technologies and ways to position our policies, regulations and systems to encourage uptake and manufacturing of new, more efficient, transport technologies
- airport development planning processes and consultation mechanisms that consider the impact and changing nature of aircraft noise and related expectations on the role of noise sharing and noise mitigation
- how to support and regenerate Australia’s general aviation sector
- future industry workforce skills and training requirements
- appropriate consumer protections and access to services
- maintaining fit-for-purpose aviation safety, air navigation and aviation security systems and service delivery agencies
- the role of airlines and airports in supporting regional economies
- other significant issues raised during the consultation process.
According to the RAAA, much of what the white paper seeks to understand is already available through the previous government's policy for the recovery of the aviation sector published in December 2020.
"Whilst this is obviously an important metric to understand, work on understanding this ‘role’ of aviation has already been undertaken in the previous government’s paper on The Future of Australia’s Aviation Sector – Flying to Recovery in 2020.
"The paper opens with this statement: Aviation is central to Australia’s economy and quality of life. Aviation underpins Australian business: transporting workers, tourists and high value freight. The sector directly employed over 90,000 people and contributed $20 billion to the economy before COVID-19. Furthermore, the sector indirectly enables the tourism, mining, manufacturing and higher education sectors.
"So the need for further deep dives into understanding the value of the aviation industry seems unnecessary and could possibly lead to distraction from the main value of the white paper in addressing policy issues the industry are facing now and into the future."
In addressing the ToRs, the RAAA submission has also raised concerns about:
- the need for a clear pathway to net-zero emissions by 2050
- encouraging new technology manufacture in Australia
- making airport lease-holders accountable under the Airports Act
- maintenance training pathways
- the cost of security systems at regional airports
On the matter of general aviation, the RAAA points out in the submission that the government's push to achieve net-zero emissions by adopting Sustainable Aviation Fuel (SAF) has placed some doubt on fuel supplies for GA.
"It is also important to understand how the move to net zero could affect GA in fuel and technological advances," the RAAA believes. "All these new technologies come at a fairly hefty cost, something that we would like to understand [is] how the government thinks GA can overcome these hurdles.
"Our current GA fleet cannot operate on SAF (mostly) and there is increasing uncertainty around the supply of avgas at regional airports."
The Federal Government has not yet called for submissions to the green paper that will precede the white paper, prompting the RAAA to commit to reviewing the green paper when it is published and raising new issues that may be overlooked.
The full submission to the white paper ToRs is on the RAAA website.