BALANCING SAFETY & INFORMED PARTICIPATION
Recreational Aviation Australia (RAAus) was founded on the principle of informed participation; a culture of enabling a set of privileges for our members that could not be afforded within the risk appetite of the Civil Aviation Safety Authority (CASA). But what does this really mean for our members, and how do we balance the safety of our members whilst protecting the freedoms they have come to enjoy?
Safety is core at RAAus with a commitment to our membership that we will embed a safety culture that is just and fair, yet accountable. We set out to minimise the risks associated with our aircraft operations to a point that is low as reasonably practical. However, the qualifications to maintain and operate an aircraft are seen as lower than that required within the CASA regulatory regime. So how can this be? After all, aren’t we operating the same aircraft in the same sky as our CASA counterparts? One primary difference is that RAAus operates on the basis of informed participation.
As you climb into any RAAus aircraft, you will be greeted with a warning placard on the firewall: “This aircraft is not required to comply with the safety regulations for standard aircraft. Persons fly this aircraft at their own risk”. The pilot may have a self-declared driver’s licence medical and may also conduct their own maintenance. Whilst RAAus has demonstrated a history of safe operations with these simplified requirements, the warning placard acts as a reminder. It is there to remind a pilot or passenger of the aircraft that you are not confirmed the same level of assurance as the equivalent aircraft within the CASA system, maintained by a Licenced Aircraft Mechanical Engineer (LAME) with a pilot who has likely undergone a more rigorous medical examination. As a pilot or passenger of an RAAus aircraft, you are informed of these differences and therefore may assess the level of risk you are willing to accept. You also have the ability to adjust your risk tolerance which may include operating a factory-built aircraft compared to an amateurbuilt machine, or electing to have your maintenance conducted by a level 2 maintainer.
As an RAAus member operating within the model of informed participation, it is important that this does not affect the safety of other airspace users. Imagine that when operating within the informed participation model there is a bubble which encompasses the aircraft. Within that bubble the occupants may have accepted a higher level of operational risk, however informed participation must be limited to the confines of this bubble. Everywhere that aircraft travels must comply with the appropriate ruleset to ensure the safety of other airspace users is maintained.
SO, IF THE RISK APPETITE OF RAAUS IS HIGHER THAN THAT WITHIN CASA, HOW DO WE MANAGE THE ONGOING SAFETY OF OUR MEMBERS?
Safety is intertwined in everything we do at RAAus, yet we must balance this with our founding principles of maintaining access to a simplified system of lowcost aviation and protecting the privileges of our membership. An example of this is based around the proposal by Airservices Australia to lower class E airspace to 1,500ft AGL on the East Coast of Australia. Whilst this decision would undoubtedly increase safety for operators within the proposed class E airspace, it imposes a high level of cost for the fitment of transponders and radios which remains out of reach for many RAAus aircraft owners. Of course, there are two sides to this safety case. With only 30% of RAAus aircraft equipped with a transponder, this proposal will undoubtedly push many of our members into operating below 1,500ft AGL, minimising options for the safe transit and operation of aircraft, resulting in a significant reduction in safety for our membership base.
What we must accept is the organisation must grow with the times. Gone are the days of operating only below 300ft and not over roads. Much of our membership base now operate highly advanced aircraft within high density areas of airspace. With airlines increasingly operating Regular Public Transport (RPT) flights into regional airports, it is important that our members ensure they complete appropriate procedures and communications when operating around these aerodromes. It is highly possible that increased requirements such as transponder use around these high-density areas may be mandated at some stage in the future and that some members may need to upgrade their systems to maintain the privilege of operating in this space. However, RAAus will not support a blanket rule change that takes away the privileges of a large portion of our membership or increases the cost of participation unless there is a reasonable need for this. We must work collaboratively with industry to find a solution that benefits all airspace users whilst keeping safety front-of-mind.
Every year RAAus reviews hundreds of reports submitted through our Occurrence and Complaint Management System (OCMS). These reports result in a number of safety actions, many of which take place beyond the visibility of our everyday membership. We work with manufacturers to implement important service bulletins, we review and educate members to improve the safety of all airspace users, and we may need to suspend or remove the privileges of some members where there is a clear disregard for the rules. We work to prepare safety publications and update members with safety information. We contact aircraft owners where an immediate safety threat is identified. It is through the dedication of our membership in improving this safety culture that we have seen a large reduction in fatal accidents over the past 10 years.
So where does this leave us with the balance of safety versus informed participation? RAAus does accept a higher level of risk compared to that of the regulator. In some cases, we operate identical aircraft to our CASA counterparts, yet we are not the same. As RAAus pilots, we accept that our level of risk may be higher than those operating an aircraft with VH- markings on the side and our organisation places increased trust in members to operate safely. As a result, our operations are limited to day VFR flight with only one passenger. However, if we continue to take ownership for our own actions, increase awareness of our accountabilities as pilots and maintainers and improve the safety of our operations, then we will continue to demonstrate to industry that we are much more than amateur aviators. We are a cohort of pilots and maintainers passionate and competent in taking ownership of the privileges we have been afforded with RAAus.
