Table of Contents
Note
The following is a list of submissions the RAAA has made on different issues affecting regional aviation.
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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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