Notice of proposed rule making - Post-implementation review of the legislative framework for Part 139 - Aerodromes (NPRM 1426AS)

CASA staff do not appear to understand 'outcome based standards' and, inn the case of Part 61, cannot give up micro management of every process leading to the 'outcome'. Additionally CASA appears to have difficulty defining the desired outcome and resorts to motherhood statements such as 'an acceptable level of safety' when the task is not phsically definable.

This question assumes that the only respondents are aerodrome operators

Please define the term 'safety'

Aerodromes above the threshold usually have internal technical staff to keep the facilities operating to standard. It is the small often council operated aerodromes who do not have access to the skills and expertise to identify and fix problems, and it is these aerodromes
that need the annual inspection BY AN ACCREDITED AND SKILLED INSPECTOR to kick them back into compliance.

NO OF PAX IS NOT THE ONLY RISK FACTOR

There are 2 levels of management in the operation of an aerodrome.
1. The first is overall business management usually by a general manager or in small airports by the council CEO.
2. The second level is the 'operations manager' who carries responsibility for the operation of aircraft and vehicles on the aerodrome.

Even though the draft mentions accountable managers in the plural, the text does not list any manager as responsible for the actions of the safety officers.

It does not align with operators, maintainers and ATC as the aerodrome managers are not examined by CASA

In my work in certifying aerodrome lighting and visual aids I have met many persons responsible for the management of aerodromes and have been entirely underwhelmed by their knowledge of the regulatory regime in which they operate, and the technical standards for which they are accountable. They rely on the advice of consultants and contractors (many of whom have a conflict of interest) and in most cases lack sufficient knowledge to properly commission a scope of work and create appropriate tender documents and assess the response. This is particularly relevant to aerodrome lighting where the work is buried without inspection. The final 'outcome' inspection of aerodrome facilities used to be performed by AIRWAYS SURVEYORS who looked at the aerodrome from the end user perspective. That no longer happens and there is no doubt in my mind that a significant number (and probably the majority) of aerodromes have significant defects - the cause is a failure of the inspectorate starting with CASA. I find it ludicrous that a person can become operations manager of an RPT jet airport without examination or qualification yet the community requires training and certification to work as a hairdresser!