ATTACHMENT B - Responses to June 2011 CRIS
All emails are in original format with all names and other identifying data removed to
protect the privacy of respondents.
From:
Sent: Monday, 16 May 2011 19:57
To: COSTRECOVERY
Subject: Cost recovery
Dear Sir/madam,
I am pleased to be invited to offer comments on cost recovery.
When I first became a LAME in 1976, the licence was provided FOR LIFE. There
was no renewal fee. There was no exam fees either especially that these were
something required by the Department.
Then there was a departmental change of policy and it was declared that there was to
be a ONE OFF fee of $5.00 for cost recovery purposes.
No-one objected too much to this as it was stressed that it was a one-off after all. But
then a couple of years later, it was then announced by the Department
(DCA,DOT,CAA as name changes evolved) that this was to change and there would
be a small, but ANNUAL fee.
This was strongly objected to by all those in the industry, from pilots to engineers and
their unions.as it was seen as the tip of a very big iceberg. Charges only go UP.
Despite re assurances to the contrary coming from the Department, cost recovery was
going to be permanently entrenched.
So we have moved over the years from a free lifetime renewal to paying an annual
fee, and fees to apply for exams as well as paying for the supervisor overseeing the
exams.
If I want to apply for another type licence, there are more fees and so on. Is it any
wonder that most people feel aggrieved about what's happened over the years and so
their trust in CASA statements.
So there is deep ingrained cynicism about "cost recovery" and the view that costs
recovered are excessive and unnecessary perpetuate.
Costs may be seen by CASA as being small for a particular service or renewal, but
when people have spend a huge sum of money over the years to gain the
qualifications and experience over the years to provide the safety, professionalism and
responsibility to the general public that is far and beyond that of other industries, it
seems greatly unfair to continue to pay.
While it understandable that an infra structure should be supported financially, it is
the responsibility of the Federal Government to provide such support to CASA.
Thanks and regards,
XXXXXXXXXXX
CASA’s Response
CASA is required to seek cost recovery for regulatory services under the Australian
Government Cost Recovery Guidelines July 2005. Through the 2009 Aviation White
Paper, government applied a $15m cap, in real terms, on revenue from fees for
regulatory services for five years. The government recognises that a “user-pays”
approach offers efficiencies for the resourcing of CASA services. However, this cap
implements the government’s commitment to address the burden of regulatory
charges, in particular on regional and general aviation.
In relation to Aircraft Engineering Licenses, these licenses will be perpetual under
Civil Aviation Safety Regulations (CASR) Part 66.
From:
Sent: Monday, 16 May 2011 20:40
To: COSTRECOVERY
Subject: Cost recovery comment
Dear Costrecovery team the Aviation industry is falling further and further behind regarding
financial reward .This is because the Margins are tight.Not much money to go
around.Tiger,Jerstar do you really think they are big payers.We don't want you to start talking
about a basket of fees, for what is fast becoming a very average paying job.There is no
basket of money out there these days.We would like you to understand that.XXXXXX
CASA’s Response
CASA is required to seek cost recovery for regulatory services under the Australian
Government Cost Recovery Guidelines July 2005. Through the 2009 Aviation White
Paper, government applied a $15m cap, in real terms, on revenue from fees for
regulatory services for five years. The government recognises that a “user-pays”
approach offers efficiencies for the resourcing of CASA services. However, this cap
implements the government’s commitment to address the burden of regulatory
charges, in particular on regional and general aviation.
From:
Sent: Wednesday, 18 May 2011 14:58
To: COSTRECOVERY
Subject: Re: Cost recovery comment [SEC=UNCLASSIFIED]
How about going to the companies for your Cost Recovery.They are doing a fleet renwewal
so they must have money.XXXXXX
CASA’s Response
CASA is required to seek cost recovery for regulatory services under the Australian
Government Cost Recovery Guidelines July 2005. Through the 2009 Aviation White
Paper, government applied a $15m cap, in real terms, on revenue from fees for
regulatory services for five years. The government recognises that a “user-pays”
approach offers efficiencies for the resourcing of CASA services. However, this cap
implements the government’s commitment to address the burden of regulatory
charges, in particular on regional and general aviation.
From:
Sent: Monday, 16 May 2011 21:03
To: COSTRECOVERY
Subject: CASA costs
Dear Convener or Officer Concerned,
Please explain to me how you can justify 'cost recovery' when industry has no means
of making input to the efficacy of the services provided, let alone whether or not those
services are necessary or germane to the aviation industry. Its time CASA considered
cost and benefit before imposing any imposts on the aviation industry, especially VH
general aviation (GA) which has been taxed, harassed and over-regulated to a position
close to termination. If you think I exaggerate then check with the fuel companies and
find out how many dozens of re-fueling facilities have been de-commissioned these
last few years.
Your whole structure in terms of cost is completely out of control, twenty three years
to do the regulation upgrade and still not finished? How much money wasted? What a
disgrace.
Don't think that industry participants have any warm feelings about your consultation
process.
--
XXXXXXXXXXXXX
Victoria Australia
CASA’s Response
CASA is required to seek cost recovery for regulatory services under the Australian
Government Cost Recovery Guidelines July 2005. Through the 2009 Aviation White
Paper, government applied a $15m cap, in real terms, on revenue from fees for
regulatory services for five years. The government recognises that a “user-pays”
approach offers efficiencies for the resourcing of CASA services. However, this cap
implements the government’s commitment to address the burden of regulatory
charges, in particular on regional and general aviation.
From:
Sent: Monday, 16 May 2011 21:30
To: COSTRECOVERY
Subject: is the increase in fees going to help the industry or remain the same?
Hi,
I am willing to accept a pay increase with the times. For certain regulatory services I believe
in paying for that through fees to help CASA.
However when talking about normal admin in an office job like the CLARC team. How much
is their cost and is theirs increasing? For? More staff to deal with the paper work? How do
we know if more staff are employed?
I will say that my dealings with the CLARC team have been good and bad. Given that I once
filled up a form and need it processed for an interview they helped me out very well and was
very happy with their service but I for the last 2 years I have noticed with an update on the
system there has been a very poor standards in service and performance. I did an IFR
renewal in June 2010 and I called up about 4 to 5 months later and it was not in the system.
Once again this year I did a renewal on the 4th of April, once again I called up 2, 4, 6 weeks
and last time today to see if it was in the system and once again it is not in the system. I have
repeatedly requested for my renewal to try and be found and to be processed ASAP so I can
convert my license. But they have told me it is not in the system. How is that possible? Is the
mail service that bad? I don’t think so I think Australia has a fantastic service. My ATO has
resubmitted a new form for me sometime around the 7th of May. How long will it take to be
processed? Is my job going to be compromised because they take a long time to process my
renewal and license? I just cannot see how an increase in fees is helping us in the industry.
As much as I would like to complain about the situation I understand the amount of paper
work they are required to do. But taking months to update a renewal is very sad.
If it is to make things better I am all for it but if you are telling me that it will remain the
same that I am not for an increase.
Yours sincerely
XXXXXXXXXXXXX
CASA’s Response
CASA is required to seek cost recovery for regulatory services under the Australian
Government Cost Recovery Guidelines July 2005. Through the 2009 Aviation White
Paper, government applied a $15m cap, in real terms, on revenue from fees for
regulatory services for five years. The government recognises that a “user-pays”
approach offers efficiencies for the resourcing of CASA services. However, this cap
implements the government’s commitment to address the burden of regulatory
charges, in particular on regional and general aviation.
From:
Sent: Tuesday, 17 May 2011 01:28
To: COSTRECOVERY
Subject: cost to service ratio offered by CASA
Dear CASA cost recovery service,
The Cost recovery situation needs some serious thought. I am a pilot and go business with
casa for licencing and medicals.
I also do Business with the FAA for my USA Licencing and the difference and service
is noticeable from the first time you see the FAA licence. They are proud of their
Aviation industry and the attitude of their people reflects that. The FAA licence is easy to read
particularly for those who do not understand English. There is no room
for unnecessary questions by foreign authorities. The Casa licence is so scattered it is hard
for a person to understand what is what, and invited stupid questions from difficult people. I
have been told my licence is no longer valid every time because my medical is on a different
sheet of paper. and the licence does not say perennial.
I would like to see a complete change to the way the CASA licence is presented. this licence
needs to be far more secure against feud and presented in an easy to understand manor.
i think the 75 dollar fee for a medical is way to dear. No one in Aviation gets paid enough
money this is just making things harder on everyone. 15 dollars is probably
more respectable, considering it was free only a few years ago and the doctor is very
expensive and does all the paperwork and the examination.
The medical and licence should be printed on a small credit card size plastic card and is
renewed each year with a new medical. Maybe this would be worth the fee charged. The card
would have every thing valid to your day to day requirements and expiry dates. The card will
be difficult to copy similar to a drivers licence that costs $50. Every pilot will have a licence
that is no more than 12 months out of date or 3 years for a PPL. most pilots chose not to pay
the 25 dollar fee when getting a new qualification. Because they cant afford it. the licence
must be easy to understand For foreign authorities. i fly in central and south america and
they all have great difficulties with my paper licence.
As far as cost recovery goes in the late 1990's aviation changed to user a pays system
removing service tax. the system was great it reduced a lot of indirect taxes. however the
GST then made this system expensive because every time you use a user pays system u also
spend 10% GST. CASA need to calculate how much GST is generated from the greater
aviation industry and get this money from the government to fund the infrastructure.
licencing and enforcements. also to improve the technology used to transmit and process
data and applications.
The last change I'd like to see is to move away from printing applications and faxing them
across the world to CASA. We all need and deserve a seamless website that is easy to use
free and can accept applications for any thing CASA in a few minutes. the data is then
processed by a person simply looking over the application and emailing the results back and
posting the minimum correspondence (ie a Shiny new Licence Card) the licence/medical
would be verified as up to date by a printable emailed form that is valid for 4 weeks. i think a
fee for prompt service is valid considering the industry is here to serve as a time saver to
customers traveling. I waited 3 months for a form to be returned and i had business with the
FAA waiting on this paper work. I had to call every day until it was done because it kept
getting lost.
If you have any questions please feel free to email me back i would like to help you make
casa a great organisation. and grow aviation in Australia for everyone to enjoy.
Kind Regards
XXXXXXXXXXXX
CASA’s Response
The costs associated with maintaining the civil aviation licensing, certification and
registration systems are significant. For example, the work done by CASA to support
medical certification includes a system that supports the industry medical examiners,
handles complex cases and maintains expertise that is required to ensure pilots and air
traffic controllers are able to continue operating when their medical fitness is at the
minimum standards. All documentation from Designated Aviation Medical
Examiners (DAME) needs to be reviewed by trained CASA medical assessors. In
relation to pilot licensing, support is required for the computer system and expertise
for dealing with Approved Testing Officers and other experts in this field.
Consideration has been given to using credit card like licences and enhancing the
security features of licences. New regulations for flight crew licences are being
developed and could include changes to the format of the licence document. CASA is
also working on establishing e-business in the future.
From:
Sent: Tuesday, 17 May 2011 07:48
To: COSTRECOVERY
Subject: RE: Cost recovery for new regs
Good morning Craig,
Just a suggestion, have you considered giving students who are studying aviation a discount
on their air law docs through their flying training schools?
I just find being a part time student studying my CPL docs get expensive and if I am not flying
I don’t buy new amendments for the next year because I am not using them. I buy a whole
new package the following year when I start my flying training again.
Anyway just thought to let you in on this thought and I am sure many students who aren’t
working maybe thinking similar ideas.
Thanks for your time.
Regards
XXXXXXXXXXXXXXXX
(CPL Student in Queensland)
CASA’s Response
This is a policy issue for Air Services Australia. We will forward your request to
their Publications Unit for consideration.
From:
Sent: Tuesday, 17 May 2011 08:10
To: COSTRECOVERY
Subject: RE: Invitation to comment on CASA's Cost Recovery Impact Statement
Good Morning Cost Recovery Team,
While on the subject of Cost Recovery, I am aware that CASA, at a fair bit of expense, hold a
library of maintenance manuals, IPC's, SB's, etc.
Have you ever considered setting up a "pay per view" type system whereby maintenance
organisations can access this library?
Kind Regards
XXXXXXXX
Queensland 4655
CASA’s Response
There is some logic in making CASA’s library materials available to industry,
however there are some restrictions that make this option unviable. CASA has
agreements with the majority of manufacturers and data providers wherein the data
they provide is to be used only by internal staff and for regulatory purposes. With
these arrangements, in most cases, the manufacturers provide access to the data free
of charge. These arrangements allow CASA to keep, what can be a very high cost
expense, to a minimum.
From:
Sent: Tuesday, 17 May 2011 08:57
To: COSTRECOVERY
Subject: Fill ya boots.
Chief Financial Officer
In my opinion charge the full amount and more, user pays system, outsource the lot
and if it costs you say a $1.00 per document to print, charge $1.50, make a profit, its a
user pays system, and if you use it pay, if not get out of the industry, there should be
no financial impact to the tax payer.
Increase the fees as much as you like, its better for the industry and the members of
the public.
Cheers
CASA’s Response
It is Australian Government policy for CASA to recover the cost of providing
regulatory services to the aviation industry, subject to the cap of $15m specified in the
2009 Aviation White Paper. Charging fees in excess of cost would be inconsistent
with this policy.
From:
Sent: Tuesday, 17 May 2011 07:53
To: COSTRECOVERY
Subject: RE: Invitation to comment on CASA's Cost Recovery Impact Statement
Everyone would like to pay less for anything but I don’t think this is going to happen.
Would CASA consider easing the costs of becoming a pilot by considering other sources for
gathering information?
My case for this would be that as a member of the ADF and a holder of a NSW Firearms
licence, some of the medical and security checks double up.
This could reduce the time taken rather than the hourly rate and time saved is well, time
saved.
Regards
XXXXXXXX
CASA’s Response
CASA looks to ways of reducing the cost of pilot licensing. The background checks
required for security identifications and licensing are covered by the Aviation
Transport Security Regulations 2005. Background checking is done for specific
purposes and it is not possible under the current system to recognise other background
checks.
Likewise for medicals, the requirements for aviation medical certification are
different to other areas, for example the affects of altitude on fitness. Also, CASA
medical certificates are based on international standards and it is important to be
consistent with those standards.
From:
Sent: Tuesday, 17 May 2011 09:01
To: COSTRECOVERY
Subject: Cost recovery fees
The time it takes CASA officers to travel to deliver a regulatory service continues to be charged
at the relevant hourly rate.
To keep these costs to a minimum, CASA employees are instructed to schedule regulatory and
surveillance activities in the same area wherever possible. Travel time is then pro-rated across
all planned activities according to the time spent on each activity, resulting in savings for
operators requiring regulatory services.
The above extract from the CASA cost recovery policy document “answers” is an example of
how CASA is discriminating against operators based in regional areas away from CASA field
offices.
As an example an instructor rating renewal which is normally “estimated” at 4 hours at $160
per hour ($640) becomes double that amount when 2 hours travelling time in each direction is
taken into account. A local example of this is a CASA Flying Operations Inspector (FOI)
travelling from Brisbane to Toowoomba and return for the purpose of carrying out an
instructor rating renewal. The estimate is then doubled to $1280. Estimates for centres further
away than the quoted Brisbane/Toowoomba distance of about 150 Ks must obviously be
much more.
This problem is exacerbated by the current CASA policy of only using specialist FOIs
attached to the Flight Training and Testing Office based on Bankstown for these tasks. This
office does not allow tasking of these FOIs on other duties such as “regulatory and
surveillance activities” consequently there is no chance of any offset for “pro-rated travel time”
Consequently instructors based in regional areas are making every attempt possible to avoid
being flight tested by a CASA FOI for initial issue or renewal of their instructor ratings
because of the sheer financial costs involved. A flight test by a CASA Approved Test Officer
including travel costs is typically about half the cost of a CASA “estimate” for an FOI.
In effect CASA is pricing itself out of the market and at the same time losing control of the
overall standards of flying training by not making sufficient samples of the industries current
practices in regional areas.
It is recommended that CASA review this “relevant hourly rate” for travel time as it
discriminates heavily against any persons and operators who are not based at a CASA field
office site.
XXXXXXXX
Note – The Author spent 24 years in CASA and its forebears as an FOI
CASA’s Response
CASA does not charge for domestic costs such as flights or accommodation where
travel is required to perform a regulatory service. However the time it takes CASA
officers to travel to perform a regulatory service is charged at the relevant hourly rate.
CASA employees are instructed to schedule regulatory and surveillance activities
wherever possible in the same area to keep these costs to a minimum, with travel time
pro-rated across all planned activities.
CASA’s recovery of domestic travel costs is consistent with that of several other
Commonwealth regulatory authorities, including the Australian Maritime Safety
Authority, Australia Communications and Media Authority and Australian Fisheries
Management Authority. These entities often charge for both domestic travel time and
for associated costs such as accommodation and incidentals.
From:
Sent: Tuesday, 17 May 2011 19:47
To: COSTRECOVERY
Subject: Draft Cost Recovery Impact Statement
Dear Sirs, thank you for your email on this matter. I am a 13 ½ yr old student pilot and
cannot understand 99.9% of the Statement. However I think it reasonable for CASA to be
paid for services provided to Industry so long as the price of the services to small business
does not cause the business to become uneconomic. Yours faithfully XXXXXXXXXXX
CASA’s Response
No specific response required.
From:
Sent: Tuesday, 17 May 2011 20:24
To: COSTRECOVERY
Subject: Cost Recovery
Seems fair
Regards
XXXXXXXXXX
Environment and Community Relations Manager
CASA’s Response
No specific response required.
From:
Sent: Tuesday, 17 May 2011 21:34
To: COSTRECOVERY
Subject: feedback
Thank you for the invitation to provide industry feedback on casa cost recovery. My
feedback will be historical and largely general. I have been a private GA pilot for at least 46
years and I have operated an experimental home built aircraft for about the last 7 years.
I have experienced both the pre cost recovery and cost recovery periods of GA, so I can tell
you that I have seen dramatic changes over this time in both the emergence of recreational
aircraft and the steady decline of general aviation. I remember the heady 1960s when it was
common to share a GAAP circuit with up to 6 other aircraft. Overseas student pilots still seem
to keep aircraft in the air at that aerodrome, but it is rare to see more than one in that circuit
these days. I now operate at a small country airport in NSW with a daily RPT service. Often a
day can go by without seeing a light aircraft in the circuit. When I started flying in the 1960s
the industry was subsidised to encourage young people to take up flying as a career or
as part of the military reserve. I used to think it was quite a waste to get so many navigation
documents that it was almost a relief to eventually be able to buy what I needed when I
needed it. Then over the years the costs piled up and it became increasing difficult to
maintain a recreational interest in flying.
I eventually saved up enough to buy an aircraft. However, for the last few years I have had to
search further a field for a GA instructor to conduct my biannual flight reviews. Two of my last
3 instructors retired complaining about the burden of CASA regulations and the other
was relatively young enough to be gobbled up by the regional airline industry.
I have personally found cost recovery an obsticle for access to the aviation in Australia. For
example, landing fees would have to be one of the more annoying and unnecessary aspects
of cost recovery. For example, on several occasions I have been incorrectly charged landing
fees and had to spend considerable time proving that it was not my aircraft or that my aircraft
had never been to the airport in question.
Finally, I believe that lack of federal government commitment to pilot training over at least the
last 20 years and the preoccupation with cost recovery have been nails in the coffin for our
declining general aviation industry. Please do something about this.
Yours sincerely
XXXXXXXXXXXX
CASA’s Response
CASA is required to seek cost recovery for regulatory services under the Australian
Government Cost Recovery Guidelines July 2005. Through the 2009 Aviation White
Paper, government applied a $15m cap, in real terms, on revenue from fees for
regulatory services for five years. The government recognises that a “user-pays”
approach offers efficiencies for the resourcing of CASA services. However, this cap
implements the government’s commitment to address the burden of regulatory
charges, in particular on regional and general aviation.
From:
Sent: Wednesday, 18 May 2011 12:35
To: COSTRECOVERY; Discussion of issues relating to Soaring in
Australia.
Subject: Fees for rubber stamping annual medicals
In response to the request for feedback
The charge of $75.00 to rubber stamp Civil Aviation Certificate by
CASA when the DME has certified you fit to fly at your bi-annual
medical is iniquitous.
If there is a problem, then charge an hourly rate.
Even $25.00 for a rubber stamp by a clerk, printing, sending it out
and filing is too much!
XXXXXXXXX
CASA’s Response
CASA charges $75 for processing documentation from Designated Aviation Medical
Examiners (DAME). All applications need to be reviewed by trained CASA medical
assessors. The same process applies for renewals because the medical conditions of
people change over time.
From:
Sent: Wednesday, 18 May 2011 14:19
To: COSTRECOVERY
Subject: Cost recovery.
There needs to be some distinction between Airline RPT and General aviation. If any
company in general aviation were to charge $190 per hour they would not have customers
for long. No GA customer can afford these rates and the industry cannot survive in a safe
manner if maintenance organisations are forced to increase their costs to over $100 per
hour in order to recover these exorbitant fees from CASA. What justification do CASA have
to believe that their staff are more valuable than a highly trained and extensivly experienced
LAME, or a business operator undergoing constant scrutiny from an organisation which
interferes in every aspect of their business and demands a considerable amount of their
time on a regular basis.
Perhaps you should survey the GA industry and discover what the average charge out cost is
and use this as your non variable rate.
XXXXXXXXX
CASA’s Response
CASA has not increased its hourly rate fees since 1 July 2007. CASA has four hourly
rates for regulatory services: $100, $130, $160 and $190.
The application of the $100 and $130 hourly rates are prescribed in Regulation 4(2) of
the Civil Aviation (Fees) Regulations 1995. These rates allow CASA to charge
equitably for services that have a higher administrative component, are relatively noncomplex or do not require the skills of specialist technical staff.
The $190 hourly rate is used where the interests of air safety navigation requires that
the regulatory service be provided by a senior CASA officer or by a CASA officer
with particular experience or qualifications. Generally, the $190 rate is used for the
Regular Passenger Transport (RPT) sector and not the General Aviation (GA) sector.
However, there may be circumstances in GA where the service requires a senior
officer with particular experience or qualifications. In these circumstances the $190
rate may be used.
CASA’s Response
CASA does charge $25 for reprinting medical certificates, consistent with the fee for
reprinting pilot licenses.
From:
Sent: Thursday, 19 May 2011 16:30
To: COSTRECOVERY
Subject: Comment
Dear CASA Cost Recovery,
I am concerned about your approach to getting honest feedback on issues that significantly
affect the Aviation Industry. It is my experience with other agencies, when seeking honest
feedback from ‘customers’ who they also regulate, that it is proper practice for an independent
third party to take and summarise submissions which are then treated as confidential. In my
limited time in the industry I have heard a lot of criticism of CASA and the cost recovery
implementation. I doubt that CASA would have been given the same feedback as industry
insiders like myself will always be concerned about the effects of negative feedback directly to
the body responsible for approving and regulating their operations.
Regards,
XXXXXXXXXXXXX
Rockhampton QLD 4700
CASA’s Response
Whilst we note your concerns the industry emails were sent to a specific email
address to which only two CASA staff members had access. All identifying data on
the emails was removed to protect the privacy of respondents before they were
forwarded to internal subject matter experts.
From:
Sent: Thursday, 19 May 2011 12:29
To: COSTRECOVERY
Subject: Cost Recovery
To Whom It May Concern,
I think the fees you charge to Pilot's are absolutely ridiculous and embarrassing on your behalf.
To charge the $25 fee in particular just to obtain a new piece of paper with an updated
qualification is criminal.
No wonder flight training in Australia has declined because CASA and other factors obviously but
mainly CASA, who should lead by example, deter potential pilots with ridiculous fees!
Kind Regards,
XXXXXXXXXXXX
CASA’s Response
The cost of processing a licence reprint is based on the work required to issue the
licence document as well as the systems that support the licensing, registration and
certification system.
From:
Sent: Friday, 20 May 2011 08:25
To: COSTRECOVERY
Subject: Cost recovery
I would have no problem with the concept of cost recovery if there
were a number of independant organisations providing the same
service, as this would promote genuine competition and help ensure
that the service is beining provided efficiently. To impose an
dolloar amount to be recovered regardless of the level of service
provided and the actual costs involved does not promote efficiency of
good value for money.
XXXXXXXXXX
CASA’s Response
CASA notes your concerns. CASA has not increased any of its fees, including the
hourly rates, since 1 July 2007.
From:
Sent: Friday, 20 May 2011 13:15
To: COSTRECOVERY
Subject: RE: Invitation to comment on CASA's Cost Recovery Impact Statement
Hi
My feeling as a pilot, is that regulatory bodies scrutinising me, are serving the general public,
keeping them safe. I feel that seeing as the service is benefitting the travelling public, which
is generally the entire population of the country, then it is not unfair for the public
(government) to foot the bill. Perhaps a user pays policy should consider the user is the
travelling passenger or aircraft hirer and charterer. Therefore passing costs to operators, or
head taxing passengers is a fair option, because the cost at the end of the day is met by the
user.
However, increasing costs to pilots training (exam fees) and charging to review our medicals
we have already paid a CASA approved DAME an inflated non medicare deductable fee to, is
completely unfair.
Especially in Western Australia, a great deal of the states wealth comes from mining heavily
reliant on FIFO workers, and this means even the population not directly involved with FIFO
or mining, still benefit from the National wealth it creates, made possible by aviation.
Therefore I strongly believe that the whole nation is benefitting from the work of the CASA,
and some of the lowest paid staff supporting the mining industry are the pilots flying the
FIFO workers, and we should not be the ones who have to pay. In my view the CASA should
not have to recover its costs, it is a time wasting exercise, the government should find
another source to pay for the costs of keeping the travelling public safe.
Regards,
XXXXXXXXXXX
CASA’s Response
CASA is required to seek cost recovery for regulatory services under the Australian
Government Cost Recovery Guidelines July 2005. Through the 2009 Aviation White
Paper, government applied a $15m cap, in real terms, on revenue from fees for
regulatory services for five years. The government recognises that a “user-pays”
approach offers efficiencies for the resourcing of CASA services. However, this cap
implements the government’s commitment to address the burden of regulatory
charges, in particular on regional and general aviation.
From:
Sent: Sunday, 22 May 2011 16:11
To: COSTRECOVERY
Subject: Cost recovery feedback: Fees for Aviation Medicals
Thank you for this opportunity to provide feedback regarding CASA's
cost recovery model.
I have an ongoing concern about the CASA fees for issuance of class
2 aviation medical certificates.
Charging a $75 fee to produce a piece of paper based on a DAME's
documentation is plainly ridiculous, and it's difficult to see how
it's in any way related to CASA's internal cost of service delivery.
The magnitude of the charges in relation to renewals is even more
detached from reality: You already have the details from the
previous medical certificate on file, and in the absence of serious
health changes you ought to be able to produce a new one by
retrieving an old certificate and changing the expiry date.
Some foreign ICAO member states have abandoned the requirement for an
aviation medical for PPL(A) holders altogether, by setting the
standard at the same level as that required for operating a motor
vehicle and using the issuance of a drivers license as evidence of
compliance.
Given that the Australian Government has not seen fit to do the same
thing, the least they can do is to be realistic about the magnitude
of the compulsory charge for the class 2 medical certificate.
Regards,
XXXXXXXXXXX
CASA’s Response
CASA charges $75 for processing documentation from Designated Aviation Medical
Examiners (DAME). All applications need to be reviewed by trained CASA medical
assessors. The same process applies for renewals because the medical conditions of
people change over time.
From:
Sent: Monday, 23 May 2011 08:56
To: COSTRECOVERY
Subject: unjust cost recovery
How can you justify more cost recovery, when you are ineffiecent, inneffective and unable to
complete the work that the industry has put to you now.
If your not doing something right you cant expect to charge or even be paid for those
services.
if anything you should be lowering your fees until CASA has understood the reason its
actually there for.
from
XXXXXXXXXXX
CASA’s Response
CASA is required to seek cost recovery for regulatory services under the Australian
Government Cost Recovery Guidelines July 2005. Through the 2009 Aviation White
Paper, government applied a $15m cap, in real terms, on revenue from fees for
regulatory services for five years. The government recognises that a “user-pays”
approach offers efficiencies for the resourcing of CASA services. However, this cap
implements the government’s commitment to address the burden of regulatory
charges, in particular on regional and general aviation.
From:
Sent: Monday, 23 May 2011 12:55
To: COSTRECOVERY
Subject: Re: Invitation to comment on CASA's Cost Recovery Impact Statement
Hi CASA Cost Recovery Team,
I looked through the draft Cost Recovery Impact Statements (CRIS) and believe the
proposed amendments concerning Civil Aviation Safety Regulations (CASR) Parts 42, 66,
145 and 147 are economically feasible providing it stays within the $15m cap.
Regards,
XXXXXXXXX
CASA’s Response
No specific response required.
From:
Sent: Saturday, 28 May 2011 09:43
To: COSTRECOVERY
Subject: a submission from Shane Wiley, 16 Parapet Place, GLENHAVEN
I would like to look at things here from the other direction, most of the focus is
on the front end, ie funding existing costs, rather than looking at reducing
costs.
My example is Camden Airport, which is now a full on class D towered facility
following a report that stated that this is required for safety.
The environment that prompted this was related to high traffic movements.
My problem is a lack of flexibility responding to these reports, as the Indian
students have shot thru due to the GFC, flying organisations are going broke,
and some days Camden is pretty damn quite, but instead of just identifying
the quite times (yes, can be done) and flicking over to the CTAF on these
days, the users are paying for highly qualified controllers just doing not much.
And guess what, those controllers will leave the industry if they have a boring
job.
I also think the Unicom solution can be used at some aerodromes, with RPT
and senior flight instructors given a new role in directing junior traffic if that is
required (this actually sort of happens informally at certain airports).
So for the lack of flexibility in responding to new situations, and inability to
think outside the square, we are all paying too much.
CASA’s Response
This is an operational issue for Air Services Australia and has been forwarded to them
for consideration.
From:
Sent: Saturday, 28 May 2011 19:36
To: COSTRECOVERY
Subject: Licence Reprints
Dear sir,
With regard to cost recovery I understand it is an inevitable fact of modern life, but in this
modern life we have access to modern IT. Why is it that we can access “ Crew Web Portal “
online yet cannot do a simple reprint of our licence?
It is a password protected site.
Regards,
XXXXXXXXXXXXX
CASA’s Reponse
CASA is working on an e-business solution to regulatory services. The present portal
provides a very basic service including updating personal contact details. New
systems are being developed that in the future will include e-business.
From:
Sent: Monday, 30 May 2011 17:40
To: COSTRECOVERY
Subject: Feedback
Good Morning,
Under the current climate, I find it difficult to support your claims of raising fees for your
"services". Considering that CASA already charges exhorbitant amounts for essentially clerical
duties, I find it completely unacceptable to be attempting to raise rates further.
To charge $25 to reprint a CASA licence for pilots, for example, is unjustifiable.
Essentially, paper is placed in a printer, the print button is pressed, the paper is placed in
an envelope and posted.
I do not charge you a fee at present (my hourly rate is much higher) when I have to spend
my time chasing up my licence or medical reprints which have regularly failed to arrive.
Perhaps I should be billing you for this.
If anything, the fees should be revised downwards.
Regards,
XXXXXXX
CASA’s Response
CASA applies the government's direction to recover the costs of delivering regulatory
services. The fee for providing an updated copy of a licence has been longstanding
and reflects the work required to issue the licence document as well as the systems
that support the licensing, registration and certification system.
From:
Sent: Tuesday, 31 May 2011 19:20
To: COSTRECOVERY
Cc:
Subject: Re Invitation to comment on CASA's Cost Recovery Impact Statement
Please find attached our comments on the CASA's Cost Recovery Impact Statement.
We trust that our comments are received in the positive manner that they are intended. The
following points refer:-
1. Items 3.13 thru 3.18: Request that they refer to the applicable regulation to which
they relate (ie in new CASR Part 42 or 145 etc) to provide greater clarity to CASA and
industry alike for the charges being imposed.
2. Item 3.3- 3.3.10 on page 29 there is a typographical error that we believe should read
"General Minimum Equipment Lists" in lieu of "General Maintenance Equipment
Lists".
3. Item 3.11 should include Deputy Maintenance Controllers.
4. Item 2.1 - item 2.25 (ie pages 33 thru 35) excellent table showing the costs that will
disappear as the new CASR Maintenance suite transition into effect.
5. Item 3.1 re repair design approvals should be included in the new CASR Part 21 but
does not appear to be included in this proposal. Timing of the changes may have
been an issue here as the new Regulations in Part 21 have not yet been issued but
must come into force on the 27th of June.
6. Items in pages 36 thru 38. Please include Fee reference numbers and the regulations
to which they apply. (The subsequent pages 39 thru 41 appear to provide a link to
the existing fee item numbers).
In summary,
It appears that the current proposal is primarily an update to reflect the last suite of CASA
regulations, but minor updates are required as indicated above. The proposal appears to
reflect costs charged by CASA as required by the applicable regulations.

It appears as though some costs to industry may have been increased in specific
areas for the Part 3 Maintenance (Continuing Airworthiness) estimates, however,
some other areas will benefit industry, when the current approvals are passed down



to the new CAMO and AMO organisations. Where industry have the competence and
qualifications to perform the activity, it should still be able to be performed by industry
(under the audit / oversight of CASA).
CASA invoicing policy should include reference to the applicable regulations and to
the item numbers of the charges so industry can truly understand the costs being
imposed on them for services, administration and more importantly regulatory
functions.
We understand that the costing system is an essential part of regulatory
management, but we request that the process allows a monthly billing system that
has an itemised monthly charging process which is more appropriate for large
organisations.
Any hourly rates charged should reflect the nature and level of the approval
performed by CASA.
Please advise if we can assist in clarifying any of the above. Once again we trust that our
comments assist.
regards
XXXXXXXXXXX
CASA’s Reponse
CASA would like to advise the following responses to you queries:
1.
It has been not been CASA practice to include the applicable regulation with the
respective fees items as you would appreciate the regulations and manual of
standards can change in a short period of time. If the applicable regulations were
printed with the fees then every time there is a regulatory change the fee regulations
would have to go through legislative process each time. This processing would add
significantly to the overheads of supporting the regulatory framework. This approach
is also followed by other regulatory authorities such as Australian Maritime Safety
Authority and Australian Fisheries Management Authority.
2.
Thank you this has been corrected in the final version.
3.
The supporting regulation has no reference to a 'Deputy Maintenance
Controller'. The regulations only refer to a maintenance controller and as such the fee
item reflects the regulations.
4. Thankyou. Please note the table is for reference only and may be subject to
change.
5. Agree with your sentiment but as you point out Part 21 had not been passed at
the time these fee regulations were drafted.
6.
The proposed fee item numbers have now been included in the final version.
In response to the issues you raise under 'In summary' we provide the following:

CASA's fees for Part 3, including the proposed fees, have not increased.
Organisations that comply with the transition requirements will not be charged
for transitioning on a 'like for like' basis.



CASA's current financial management system does not have the capacity to
include the applicable regulation reference. This may be reviewed when our
financial management system is replaced.
CASA's regulatory framework, Civil Aviation Act 1988 (the Act), Section 97,
requires that where a prescribed fee is payable for the doing of anything under
the Act, that thing is not required to be done until the fee is paid.
Organisations are able to apply for a line of credit if they wish. This remains
CASA's policy position.
CASA has four hourly rates for regulatory services: $100, $130, $160 and
$190. The application of the $100 and $130 hourly rates are prescribed in
Regulation 4(2) of the Civil Aviation (Fees) Regulations 1995. These rates
allow CASA to charge equitably for services that have a higher administrative
component, are relatively non-complex or do not require the skills of specialist
technical staff. The $190 hourly rate is used where the interests of air safety
navigation requires that the regulatory service be provided by a senior CASA
officer or by a CASA officer with particular experience or qualifications.
Generally, the $190 rate is used for the Regular Passenger Transport (RPT)
sector and not the General Aviation (GA) sector.