RAAA

SUBMISSIONS

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Table of Contents

    Note
    The following is a list of submissions the RAAA has made on different issues affecting regional aviation.
    Clicking on "View Document" will allow you to view and download the Document.

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Sydney Airport Corporation Limited

ACCC Price Notification for Regional Air Services

    6 August 2010
    Format: Pdf
    Size: 369kb

    Regional airlines provide vital services to the Australian travelling public and along with regional airports are a key part of Australia’s essential economic infrastructure. Regional airlines are a key driver within the domestic economy ensuring rapid mobility for workers, on-time service and freight delivery, and transporting many thousands of citizens and tourists across vast distances.

    Sydney Airport provides a very important service and is also a key part of Australia’s essential economic infrastructure. Reasonable access to Sydney Airport is essential to the success of Australia’s economy.

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Safeguards For Airports and the Communities Around Them

    31 July 2009
    Format: Pdf
    Size: 218kb

    Airports are important transport infrastructure assets that should be used primarily for commercial and private aviation activities. Airport designers and surveyors usually envisage around a 50 year utilisation. Successful airfield design is a complex task that attempts to strike a balance between aviation needs and the community that the airfield serves.

    The hasty privatisation of many airports means that the industry and government regulators are trying to react as airport owners attempt to extract the maximum profit for their investors. Unfortunately large monopoly infrastructure in private hands can prove questionable.

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Review of Carriers' Liability and Insurance

    07 July 2009
    Format: Pdf
    Size: 770kb

    It is vital that any liability regime that is in place, in addition to providing equitable compensation to victims, does not jeopardise the sustainability of the regional aviation industry. The RAAA's view is that these objectives can best be achieved using the current liability model based on strict liability, but with a cap on the maximum compensation payable.

    The RAAA repeats its earlier submission that compensation regimes should achieve consistent outcomes for victims of transport accidents irrespective of which mode of transport is being used. It is recognised that if the Government is minded to separately regulate air carrier liability, the other preliminary findings outlined the Department's discussion paper do go some way to alleviating the RAAA's concerns regarding inconsistent treatment of air transport operators compared to operators of other modes of transport.

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Improving the passenger experience:
Quality of service monitoring of airports

    02 July 2009
    Format: Pdf
    Size: 624kb

    Airports, both major and regional, are vital parts of Australia's national infrastructure. The protection and development of these assets are integral to Australia's economic and social future. The decision by the last government to privatise most major airports through long-term leases has had a dramatic and often negative impact on commercial aviation viability.

    The airport experience, in the twelve years since privatization commenced, has become increasingly difficult for operators and a trial for the travelling public. If airports are given the same government focus as roads, rails and seaports, Australia has a great chance of becoming a commercial leader within the Asia-Pacific region. Airports need to be developed with the best interests of the nation as a whole at the centre of any new policy.

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Inquiry into the impact of the global financial crisis on regional Australia

    02 April 2009
    Format: Pdf
    Size: 471kb

    Given Australia is a vast country with a relatively small population it is obvious that high quality regional aviation services are essential if regional and remote communities are to continue to develop. These services should be seen in the same light as health, education and telecommunications, that is, a vital part of any town’s infrastructure.

    Regional air routes, particularly those to inland towns and communities, are often very marginal in terms of profit and are under constant review by operators. They do, however, provide an essential link to the coastal cities for business, education and medical services as well as transporting vital freight. The liveability of many towns is enhanced considerably by having access to regional air services

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The National Aviation Policy Green Paper

    02 March 2009
    Format: Pdf
    Size: 1.34mb

    The sixteen priority areas identified by Government in the Green Paper are general goals that the RAAA supports. However, the RAAA proposes that they be expanded to include a focus on increased aviation research and development, as well as support for growth in aviation manufacturing capability.

    The RAAA believes that all Australians regardless of their home location, should have a reasonable degree of access to the services necessary for their social and economic well-being. Distance, road conditions, weather and the small size of many regional and remote communities all conspire to limit true equity of access in keeping with services available to those living in metropolitan areas.

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The Aeronautical Pricing "Show Cause" Inquiry

    05 February 2009
    Format: Pdf
    Size: 269kb

    It is the RAAA’s understanding that complaints can be sent to the Minister or the Department and an assessment will be made as to whether the matter requires further investigation. If so, a letter will be issued asking the airport operator to show cause why its conduct should not be subject to a formal price inquiry under Part VIIA of the TPA or another appropriate investigative mechanism specifi ed in the letter.

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Airservices Australia Pricing Policy

    24 October 2008
    Format: Pdf
    Size: 148kb

    The RAAA is supportive of the current pricing model with a number of caveats which will be discussed later in the paper. It is understood that Airservices Australia (AsA) offers services on a modified cost recovery basis to enable the pool of air navigation services and ARFF costs to be recovered, 'while minimising the undesirable distortions to airport usage'. There are however a number of improvements to the model that can be considered.

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Infrastructure Australia

    15 October 2008
    Format: Pdf
    Size: 155kb

    Australia has an extensive aviation history extending from the earliest days of controlled flight. This country saw early on the possibility of using air travel to link a small but widely dispersed population scattered across a large land mass. The growth of aviation has been an enormous boon on many development fronts, including mining and industry, aero-medical, tourism and access to education to name just a few.

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Australia's Future Tax System

    09 October 2008
    Format: Pdf
    Size: 162kb

    As highlighted in the forward of "Architecture of Australia's tax and transfer system", Australia faces significant economic, social and environmental challenges. It is the RAAA view that any taxation system, existing or proposed, needs to take into consideration the broader impact across all areas of the initiative and not solely from a revenue collection standpoint. It is also felt that current taxes, estimated at 125 separate taxes paid by Australians every year, needs to be reviewed and simplified to provide substantial incentives for Australian individuals and businesses to invest in a sustainable future for Australia.

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Carbon Pollution Reduction Scheme

    09 September 2008
    Format: Pdf
    Size: 186kb

    Depending on the source, the aviation industry is responsible for approximately 2 % of all global CO2 emissions and around 1% of domestic emissions. Even though this is a relatively small percentage the RAAA takes this issue seriously as a partner in Australia's efforts to reduce this country's overall emissions. The RAAA supports initiatives to provide a clean, productive and sustainable natural environment, but not at any cost.

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Aviation Discussion Paper

    26 June 2008
    Format: Pdf
    Size: 1.3mb

    The RAAA argues strongly that regional aviation is a vital part of Australia's national infrastructure. Regional aviation policy should be developed alongside policies supporting national quality education, health, telecommunications and rail/road/port systems. RAAA members are keen to partner with government to ensure that regional communities have access to cost effective, efficient aviation services to reinforce the economic and social development of those communities.

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Senate Inquiry Into CASA

    26 June 2008
    Format: Pdf
    Size: 237kb

    The regulatory reform process has lost its way eg the switch from FARs to EASA. Since 2003 CASA has made little or no progress in the high risk area of Transport category operations (CASR 19 and CASR 121) and General Operating and Flight Rules under CASR 91 – two core areas of aviation regulation.

    CASA seems focussed on theories of Safety Management instead of the practicality of creating a set of regulations that comply with ICAO standards. There has been no audit or quality control of inspectors’ decisions leading to inconsistencies between offices.

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CRITERIA FOR ESTABLISHMENT AND DIS-ESTABLISHMENT OF CTAF (R)

    01 February 2008
    Format: Pdf
    Size: 21.4kb

    The following comments are offered in the context of a widely held concern, noted also in the report on the NAS2c Post Implementation Review, that operations in the vicinity of non-towered aerodromes are inherently less safe than before the introduction of NAS2c, and that the risk created by the NAS2c changes is increasing as regional aviation activity increases.

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