National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register Organisation: ACT & Region Chamber of Commerce & Industry ACT Government Adelaide Airport Ltd Aerial Agricultural Association of Australia Aircraft Owners and Pilots Association Airlines of Tasmania Pty Ltd Airvan Flight Services Pty Ltd ANU Centre for Climate Law and Policy, ANU College of Law Archerfield Airport Chamber of Commerce Arts Access Australia Attorney-General‟s Department Austcorp Group Ltd Australia Pacific Airports Corporation Australian & International Pilots Association Australian Air League Australian Airports Association Australian Association of Flight Instructors Australian Business Aircraft Association Inc (ABAA) Australian Construction Industry Forum Limited Australian Federation of Air Pilots (AFAP) Australian Federation of Disability Organisations Australian General Aviation Alliance (AGAA) Australian Hotels Association Australian Local Government Association Australian Mayoral Aviation Council Australian Mooney Pilots Association (AMPA) Australian Network of Environmental Defender‟s Offices Inc (ANEDO) Australian Services Union Australian Sport Aviation Confederation (ASAC) Australian Tourism Export Council (ATEC) Australian Unmanned Aircraft Systems (UAS Australia) Australian Workers‟ Union Aviation Maintenance, Repair & Overhaul Business Assoc (AMROBA) Aviation Safety Forum Aviation Safety Foundation Australasia Aviation Sunshine Coast Inc Ban Aircraft Over Residential Brisbane (BARB) Bankstown Airport Limited Bankstown Airport Out - Tourism In Bankstown City Council Baulkham Hills Shire Council Board of Airline Representatives of Australia (BARA) Boeing Australia Holdings Briggs Aerospace Technologies Brisbane Airport Corporation Burnie Airport Corporation Cairns Airport and Tourism Tropical North Queensland Cairns Community Legal Centre Inc Canberra Business Council Canberra International Airport Casino Canberra Ltd CEAC Inc Central Queensland Regional Development Australia Committee Chamber of Commerce & Industry Western Australia City of Geraldton-Greenough City of Holdfast Bay City of Kingston City of Melville City of Salisbury City of West Torrens Civil Air Cobham Flight Operations and Services (Australia) Coffs Harbour City Council Colonial Airways / Colonial Ground Training Systems Committee for Melbourne Curfew4Canberra Inc Deafness Forum of Australia Department of Climate Change Department of Economic Development & Tourism, Tourism Tasmania Department of Education, Employment and Workplace Relations (DEEWR) Department of Families, Housing, Community Services and Indigenous Affairs (FaHCSIA) Department of Foreign Affairs and Trade (DFAT) Department of Immigration and Citizenship (DIAC) Dingley Village Community Association Inc Disability Discrimination Legal Service District Council of Ceduna District Council of Lower Eyre Peninsula Dubbo City Council Emirates Faculty of the Built Environment, University of New South Wales Submitters - published c881b607-596f-4051-9a30-26bbf47edd36.xls 1 of 206 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register Fairfield City Council Flight Training Group Forte Airport Management Future Pilot Task Force Georganas, Federal Member for Hindmarsh, Mr Steve MP Government of South Australia GPSat Systems Aust P/L Graham Banks Airport Consultancy Griffith University Guild of Air Pilots and Air Navigators Harris Miller Miller & Hanson Inc. Hornsby Shire Council Hotel Motel & Accommodation Association Hume City Council Hunter Economic Development Corporation Hunter Land Pty Ltd Industry Funds Management Pty Ltd International Air Transport Association James Cook University QLD Jandakot Airport Holdings (Pty) Ltd Liquor Hospitality and Miscellaneous Union Local Government Association of NSW and Shires Association of NSW Local Government Association of Queensland Mackay Ports Authority Marrickville Council Mission Aviation Fellowship Moorabbin Airport Residents Association (MARA) Moree Plains Shire Council Newcastle Airport Limited Northern Territory Airports Pty Ltd Northern Territory Govt (NT Department of Planning & Infrastructure) NSW Business Chamber NSW Disability Discrimination Legal Centre Inc NSW State Government Overnight Airfreight Operators Association Parkes Shire Council Paspaley Pearls Group Peel Development Commission Penrith City Council Perth Airport Perth Airports Municipalities Group Phoenix Aero Club Physical Disability Council of Australia (PDCA) Planning Institute of Australia Public Interest Advocacy Centre Qantas Group QBE Australia Queanbeyan City Council Queensland Airports Limited Queensland Aviation Industry Leaders Council Queensland State Govt . Queensland University of Technology Rapiscan Systems Recreational Aviation Australia Regional Aviation Association of Australia Regional Express Richmond Valley Council Rivermouth Action Group Inc Royal Aero Club of Western Australia (inc) Royal Aeronautical Society Australian Division Royal Federation of Aero Clubs of Australia Royal Victorian Aero Club Safeskies Conferences Incorporated Save the Moorabbin Golf Course Group Shopping Centre Council of Australia Singapore Airlines South Australian Freight Council Inc Spitfire Memorial Defence Fellowship Sunshine Coast Airport Sustainable Transport Coalition of WA Swinburne University of Technology Sydney Airport Corporation Tasmanian State Government (Minister for Infrastructure) Tiger Airways Tourism & Transport Forum Tourism Industry Council - ACT & Region Tourism Western Australia Transport Workers Union of Australia Unisys Asia Pacific United Firefighters Union of Australia (UFU) - Aviation Branch Unmanned Aircraft Technology Applications Research (UATAR) WG 27 Submitters - published c881b607-596f-4051-9a30-26bbf47edd36.xls 2 of 206 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register Urban Development Institute of Australia Urban Taskforce Australia Victoria Tourism Industry Council (VTIC), VEIC, HMAA & BOAV Victorian Airfreight Council Ltd Victorian State Government Victorian State Opposition Village Building Co Virgin Blue Airlines Vision Australia V-TOL Aerospace Pty Limited Wakefield Group Western Australian Local Government Association Western Australian State Govt (Department for Planning and Infrastructure) Western Sydney Alliance Western Sydney Regional Organisation of Councils Ltd (WRSOC) Wexco Individual: Allan, Mr Matthew Anderson, Mr Bevan Bailey, Mr Graham Bailey, Mr David Bill, Mr Charles Blemings, Mr & Mrs Hugh & Lucy Boxall, Mr/Ms TG Brabin-Smith, Mr Richard Brennan, Mr Nigel Brent, Ms Jessie Bull, Mr Tim Candy, Mr Glenn Clark, Dr John Corcoran, Ms Margaret Dee, Mr/Ms Ashley Deragopian (Thunderbolt Designs), Mr George Deuvall, Dr James Eacott, Mr John Ely, Dr William (Bill) Faulkner, Mr John Firth, Ms Angela Fisher, Ms Margaret Gabriel, Dr William Gavin CPA, Mr Paul Gillespie, Mr David Gordon, Ms Moishe Gould, Mr Alan Hamilton, Mr William Harman, Captain Ken Harrington, Mr Andrew Hennessy OAM, Ms Aminta Hesse, Mr Trevor Hodges, Mr/Ms J Hogg, Ms Bev Huynh, Mr Khoa C Jenssen, Mr Harold Karykowski, Mr Jeffrey Kimpton AM, Mr James Lovett, Mr Peter Maddigan MP, State Member for Essenden, Ms Judy Maroon, Mr Keith Marshall, Mr Robert (Bruce) May, Dr Murray Mazzarino, Mr/Ms Sal McCall, Ms Marion Morandini, Mr John Mushalik, Mr Matt Palmer, Ms Barbara D. Partridge, Ms Jo-An Paton, Mr Tony Patton, Mr Ron and Mrs Cynthia Pauka, Mr Charles Penfold MP, Member for Flinders, Ms Liz Phillips, Mr Stephen J Prestidge, Ms Corinne Rainsford , Ms Judy Rees, Mr Tony Rejto, Mr Peter Richens, Ms Alison Rose, Mr Ben Rose, Mr Eric Sayer, Mr David Schroeder, Mr/Ms Hugh & Lucy Submitters - published c881b607-596f-4051-9a30-26bbf47edd36.xls 3 of 206 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register Simmons, Mr Clayton Sloggie, Mr Neil Spring, Ms Harriet Stanier , Mr Robin Stewart, Ms Margaret Tanner, Mr/Ms Kip Tarrant, Mr Kevin Thomas, Mr/Ms Tiju Thomson MP, Federal Member for Wills, Mr Kelvin van de Wiel, Mr Stan Vlaskine, Mr Vsevolod Walton, Ms Nancy-Bird Willans, Mr G.P. Wirga, Dr Maria-Stefania Wood MP, Federal Member for La Trobe, Mr Jason Woollard & Margaret Ann Killen, Mr & Ms Bruce Gordon Wright, Mr/Ms RG Yap, Mr David Yowie Man, Mr Tim the Zeil, Mr Jochen Submitters - published c881b607-596f-4051-9a30-26bbf47edd36.xls 4 of 206 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ Areas covered in submission: 1 Australian aviation industry 1.1 International services 1.2 Domestic services 1.3 regional & general aviation 1.4 addressing skills needs in aviation industry 2 Aviation infrastructure 2.1 airport planning and development 2.2 air traffic management Individuals' name summary/key words ACT & Region Canberra airport: curfew, Supports international flights for Canberra and Chamber of Commerce international flights development of Canberra as a freight hub. & Industry ACT Government International, domestic, regional The ACT and surrounding region would benefit if To further increase domestic competition, consideration could The same security and safety measures should be adopted The Australian Government, in consultations with State and There needs to be an airport infrastructure planning process There is concern about airports undertaking development and GA, skills training, passengers could fly direct between the ACT and be given to allowing international carriers to carry domestic for regional services as for major trunk routes and the Territory Governments, should develop a national aviation pilot to address and allocate costs of off airport works required to outside local planning processes and local communities having infrastructure and planning, overseas countries. An open skies policy has the passengers between Australia cities. Australian Government should fund additional costs for training program. support future airport expansion. An outcome of this process to meet off site infrastructure costs to support airport safety, climate change, potential to increase competition, lower prices, boost security/safety upgrades for regional airports. GA has been could be an Infrastructure Plan that identified the expansion. There is also concern about the competitive consumer protection, disability services and traffic and promote the development of affected by rising costs as a result of privatisation of airports infrastructure investment required and an agreed financial advantage gained by airports conducting non-aviation based standards, security. additional airports. Allowing on carriage of passengers and by security demands at major and secondary airports. In contribution by the relevant stakeholders. The ACT activities over commercial rivals that are subject to jurisdictional on international flights would introduce more the future there may be a need to consider relocating GA Government supports the Government's decision to direct planning controls. This is inconsistent with national competition competition into international and domestic markets. operations from Canberra Airport to a new GA facility. the the ACCC to monitor parking fees at major airports. The policy. The Airports Act should be amended to require the Introducing more international competition into the Australian Government should develop a specific policy on Australian Government, in consultation with state/territory Minister to formally consider state, territory and local Australian market could place domestic based carriers wether GA should continue to coexist with RPT services at governments, should undertake a review of arrangements government planning and environment policies during at a disadvantage and would need to be considered major airports. for the provision of emergency services at non-airside areas assessment of Airport Master Plans and major developments. carefully. The Australian Government should accept of major airports. The Australian Government and airport Non-aviation businesses on airports should be subject to state responsibility for funding additional security operators should make known the requirements associated territory and local planning provisions. Master Plans should be infrastructure and resources arising from expansion of with tall structures around airports in a non-technical and required to provide full disclosure of information to the public. airline operations to Australia. Open skies for freight clear way. An independent panel should be appointed in each warrants consideration. state/territory to asses and provide advice on AMP's and major planning proposals to assist the Federal Minister in the final decision on the plans. Adelaide Airport Ltd Open skies; international; slot Supports the “Open Skies” Policy in principle but In general we agree on restrictions to international carriers Australian Government needs to provide a supportive role to Government should continue the early work on expressing Supports recent revisions to the Airports Act but there is still a Airservices Australia is ahead of the game in the implementation allowance; network pricing; Training- understands that unilateral declaration of such status however, where there is a demonstrable shortfall in capacity State/Territory and Local Governments in encouraging air encouragement for “blue” collar or trades education. considerable amount of effort required of State and Local of satellite navigation technologies. The only issue we would have HECS; airport planning, ATM; on all routes may adversely affect Australia‟s base on domestic routes such operators may be allowed to services to Regional and Remote communities. Similar programs as the HECS be developed for trade government to recognise the important role aviation has on is that they do not appear to be able to change some of their old CASA/Canadian self administration; carriers and thereby engender instability in the market. augment the capacity at least in the short term or pick up any Regional and Rural planning must be encouraged to respect entrants. their relative economies of airports in any Strategic Planning CASA Regulations. emissions; noise-ANEF; Open skies needs to work for all parties and not just seasonal demand which the domestic carriers may find hard future aviation growth and support infrastructure with funding The education system from the secondary level be encouraged scenarios. disability/awareness; security foreign based companies. to accommodate. from the beneficiaries not just the passenger base. to focus on career path studies and be offered tax breaks in the Similar consultation guidelines could be developed by AAL believes that some attention needs to be given to the ground May be possible to establish “network price” within the State equipping and supply of necessary machinery or infrastructure. state/local authorities. movement to increase capacity and would particularly recommend Use of word “regional” may create confusion for Supports the status-quo with some reservations on state- for RPT and GA operators alike. Security and Safety Regular support of Careers Expos and apprenticeship grant Strongly supports current planning framework in balancing non- call for start procedures be introduced and which has the benefit of international carriers. supported airlines. measures should be risk based outcome focused schemes. aeronautical developments on and off airports. The fact that unnecessary fuel burn. In addition sequencing of aircraft access to The issue is industry wide from pilots and licensed engineers to one may have freehold(off airport) advantages over the other the runway to minimize separation by mode should be introduced Supports a system that recognises QANTAS/VIRGIN General aviation participate in all the benefits that are airport inspectors and competent regulators. who only has leasehold(on airport) use with the obvious long and not „first come first served‟ as exists now. AAL recognises we as the home based operator and that then requires all available that the deregulated and privatised industry has Take lessons from those areas that are draining our workforce term asset values should be considered as a balancing may need to provide more taxiway infrastructure for such other international operators be required to comply to brought – such as improved infrastructure, increased safety and implement similar or competitive programs. argument procedures. the same safety and security standards that QF/DJ is and security and so on – but has not grown out of the Investigation of a wider qualification through the 457 visa and PSZs should be based on US and UK criteria. mandated within country. Examples of the UK and the Government funded mind set of two decades ago. other appropriate channels to „tap‟ into the global workforce. Encourage CASA to use the powers that they have and to also USA with particular African based airlines may be encourage State/Territory and Local Governments to amend relevant and ICAO may not be the best bench-mark. planning rules to make reporting of developments mandatory. Too often we believe that a compromise is reached e.g. A slot allowance system should be developed where shadowing (where an existing building which itself penetrates an international carrier is permitted a dedicated the OLS is then used to approve several others). number of slots to the major ports when they achieve Supports current pricing oversight. that number they are then required to negotiate with the secondary majors – such as Adelaide. We need to discuss the issue of “open cargo policy” in greater detail as we are not certain at this stage how that may be defined by the Federal Government. The Australian Government needs to review its border agency staffing allocations and use the most up to date data available. Aerial Agricultural aviation policy in context of broader Complete support for a national aviation In respect of airport infrastructure as previously stated A national aviation strategy must take account of the wider Access to HECs for trainee commercial pilots and aerial Association of Australia economic policy, access to airports, strategy including: benefits of aviation to the Australian community, especially in application pilots. CASA, harmonisation of state terms of the provision of essential services such as Tax initiatives: regulatory requirements aviation strategy that provides context for emergency services including firebombing and especially in Greater direct support to aerial application companies during the aviation industry within the the context of cost-recovery by CASA. drought to maintain critical skills in rural Australia development goals of the nation. This is A national aviation strategy is a critical „missing link‟ in especially important in terms of providing informing and directing CASA to its wider obligations of aviation with appropriate status within the fostering and promoting aviation while regulating for aviation agriculture, tax, education, training, safety. manufacturing, tourism, security, Within a national strategy, aerial application and aerial work emergency services, and related issues require suitable attention without the policy being government policies. focused solely or principally on airline operations. Maintaining a national system of aerodromes that all aircraft to promoting and fostering aviation as part have access to at reasonable prices. of national development goals. Establish a national aerial chemical distribution licence for all aerial applicators rather than individual state licencing as is now the case, and as the COAG working group on qualification recognition has also identified. Harmonisation of OH&S regulations across states Aircraft Owners and International, domestic, regional and Competition is good for the travelling public and The current deregulated market has worked. Councils should be provided to local Councils for aerodrome To enable GA to meet Australia's future pilot training needs, The monopoly given to private airport owners has resulted in Privatisation of airports has resulted in aviation interests being GA is disadvantaged by the tailoring of airspace to suit the Pilots Association GA, skills training, infrastructure and tourism, but an open skies policy would harm the maintenance. If necessary, subsidies should be provided to incentives are required, such as a moratorium on airport charges that are not sustainable for the aircraft owner. Lack sacrificed for financial gain. Planning airport land use needs to commercial airline industry. The cost of implementation of new planning, ATM, safety, regulatory Australian airline industry. It is important to insist that all enable continuation of vital services. Selling off aerodrome charges, security of tenure and reduced rents. Government of taxation incentives and high airport charges are the major be controlled by one independent body to remove the conflict satellite technologies should be borne by AA. The airspace is not reform, climate change, security. airlines flying to Australia comply with ICAO standards. infrastructure has resulted in loss of services to many assistance in the form of HECS needs to be considered. factors in preventing fleet replacement. generated by state and local government relationships with well managed as it has not followed ICAO and is therefore not Restrictions on cabotage should be maintained. communities to allow for non aviation commercial Industry can contribute, but the main driver behind resolving the developers. All development applications should have to be compatible with international practice. development. This needs to be corrected. GA is in decline skills shortage id government assistance and funding of submitted to an aviation authority to ensure that safety is not because of over regulation and the less onerous programs. A shortage of instructors is a major concern and a compromised. Restrictions on housing developments near requirements for recreational aviation need to be applied to national school to train chief flying instructors would ensure a airports are essential. GA. The decline has been exacerbated by the lack of uniform and high standard. infrastructure caused by selling off aerodromes. Pricing policies of owners has forced the closure of numerous flying schools and engineering facilities. Quarantining any further sell offs must be a priority. Airlines of Tasmania replacing aircraft, pilot training, Small airlines invest a lot in training pilots only to see them lost Pty Ltd security to larger airlines. Airvan Flight Services Essendon Airport Supports continuing operation of Essendon Airport as a key Pty Ltd metropolitan airport. Encroaching developments near the airport should not pressure the airport to close on safety grounds. ANU Centre for Climate Emissions Law and Policy, ANU College of Law Archerfield Airport Regional and general aviation, inc The GA industry is not buoyant as suggested in the Issue Flying training organisations need to be profitable to pay their Maintenance and development of smaller airports is clearly Development and planning approvals should not be given for Chamber of Commerce safety, security and infrastructure Paper. Archerfield aircraft movements are well down on pre- instructors and remain internationally competitive. They are beyond most local councils and this should be considered as any development that is not aviation related. Secondary airports privatisation levels and seven of the nine flying schools at the being undermined by price gouging by airport operators, lack of part National Defence strategy and funded from the should be required to operate to at least the same level as prior airport have shut down or been acquired by foreign airline security of tenure of leases at airports and sudden rises in Defence Budget or National Infrastructure fund. Government to privatisation. State government should enforce state law with consortiums. Investment in new aircraft will only occur if the charges. Government funding is needed for flying training via should acquire land now for future additional secondary regard to Public safety Areas and local government should only industry is profitable. the education system. airport sites as part of essential education, training and approve developments that do not encroach on or inhibit airport defence infrastructure. Privatisation has been a disaster for operations. GA, including for the flight training industry. Government should ensure security of leases and introduce price controls. . Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 5 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ 3 Aviation safety 3.1 safety regulation & regulatory reform 4 Customer & community protection - addressing 4.1 aviation emissions and climate change 4.2 aircraft noise 4.3 consumer protection 4.4 disability standards 4.5 compensation arrangements in the event of an 5. Aviation Security Individuals' name impacts of aviation accident ACT & Region Opposed to any curfew on restrictions on Canberra Chamber of Commerce airport. & Industry ACT Government Airports should be required to address aviation Every attempt should be made to keep noise sensitive Further consideration should be given to a Consumer Consideration should be given to to amending current The same security and safety measures should be adopted for emissions issues in the Master Plans, including the land uses well outside approach and take off routes. Affairs Victoria recommendation to develop voluntary Transport Standards to bring them into line with regional services as for major trunk routes. There should be a development of proposals to reduce emission levels. Curfews are a major impediment o commercial airline service customer charters as has been dome in international positions and the UN Convention on the consistent approach to passenger screening regardless of operations. The ACT Government does not support the US and to a lesser extent in Europe. Rights of Persons with Disabilities. aircraft type and flight type. The Australian government should proposed residential developments that would likely undertake a review of implementation of the recommendations lead over time to complaints about aircraft noise from in the Wheeler review, specifically including the establishment the new residents and which could cause adjustment and operation of the specialised airport policing units. to flight paths in ways that could cause noise sharing over Canberra. The ACT Government is strongly in favour of independent monitoring of noise levels from aircraft using Canberra Airport to support an inquiry into the future impact of aircraft noise on the Canberra community. Adelaide Airport Ltd We believe that by reducing the political and one issue Adelaide Airport recognizing the direction that global The ANEF system is somewhat dated and needs to be Consumer protection in our industry should not be We are an active participant on the Disability The present leasehold requirement for $1.5 billion of Adelaide Airport is cognizant of and an active participant into the lobbyists intrusions would permit CASA to get on with warming and carbon emission control was going has reviewed to a more readily understandable system. treated any differently than any other business. Market Standards Review committee and feel that the current liability insurance is out of step with the rest of the world. suite of reviews currently being undertaken by Government into their mandate which would be enhanced by having introduced significant measures towards being carbon The DITRDLG environment branch has a system that forces will determine the best way forward. transport standards for air travel are more than It adds a cost impact to airports (and therefore landing the security of airports and airlines and would propose that the competently trained risk auditors within the CASA neutral as a company by mid 2009 and in conjunction may well be the way forward called TNIP. adequate. An awareness campaign to the public at fees) that is unnecessary. The limit should be significantly outcomes of those reviews receive further consideration in the structure. More responsive and accountable airport with the AAA we are liaising with the Dept of Climate large that the airline carriers in Australia are prepared reduced after a proper risk/maximum loss assessment is “Green Paper” consultative period – e.g. computers, shoes, inspectors. Equal focus to be given to operational Change to ensure an appropriate level of compliance Airports themselves do not generate any significant to assist provided they have advance notice of special undertaken. belts, scissors etc., etc. outcomes as to the content and style of documents. for airports noise and the noise emissions from today‟s modern needs – the community has got used to advising aircraft are significantly less now than when the ANEF airlines in advance of any special dietary requirements It would seem that internationally aviation security has raised the Given the scope of the task and the demand on CASA system was developed. Highway/road noise is a more and the needs of persons with disabilities can be given level to a standard that makes it difficult for the terrorists to to consult extensively the regulatory reform process is intrusive yet constant source than aviation. the same attention provided there is notice. achieve their aims easily at airports or on airlines and they have not as bad as it appears – it may have been improved changed their modus operandi to other forms of transport and if the requirement to consult was not obligatory but one It is our recommendation that there be a complete mass gatherings. It would seem logical that the same measure can only guess at the political backlash that may have review of the curfew impost on airports particularly in of intensity should be directed to rail and coach public transport caused? relation to the Regulations and their currency given the and to places of mass gathering including nightclubs and changes which have occurred over the past decade or sporting arenas. Should investigate Canadian model for self- so AAL has a number of suggestions to make in this administration. regard. Given the advances in aircraft technology, We would suggest that it is important to undertake some exit since curfews were developed in the late 1970‟s, the strategies where there is overlap in the knowledge that any draw socio economic benefits that aviation brings to a back can be re-instated should the threat level vary. community, measures already introduced to minimize noise in nearby residents and paid for by the travelling If we initiate measures to overcome every likely scenario we will public, the need to minimize carbon emissions and fuel suffocate the business. Current reviews and technology burn then it would be irresponsible for Government to advances may well be the answer to better manage the not review this archaic impost. procedures we currently have with newer technologies and profiling procedures. As it is a national issue it should be nationally funded. We would support a National service provider (Government or Private) charging a network fee – if the threat level warrants. The role of AFP would then need to be clarified. Aerial Agricultural Transport Security Plans for aircraft marginally above were put The original intent when the legislation and regulationsthe 5700 Association of Australia ongoing protection of safety reporting information Transport Security Plans for aircraft marginally above the 5700 kg trigger and regional/remote aerodromes of CASA‟s functions, driven by industry leaders including AAAA. industry peak bodies on aviation safety issues and CASA management. the direct linking of this to accountability to industry, including greater peak body representation on any CASA Board (if reintroduced), the abolition of the ASF, and the removal of the Regulatory Advisory Panels. activity policy that focuses on fare-paying passengers. systems within CASA to streamline, simplify and cut the cost of CASA-industry interactions. bodies with specialist expertise and a proven track record of performance in government partnerships. involve the carriage of fare-paying passengers. operations in the face of government policy to Aircraft Owners and CASA needs to be more proactive and less punitive in introduce drug and alcohol testing, fatigue CASA does not have the respect of the industry and Improved traffic flow via more efficient ATC, pilot The Department has failed to recognise that security needs to be Pilots Association its dealings with GA. CASA should adopt the approach the appointment of a CASA board to oversee training to reduce delays and more fuel efficient aircraft tailored to suit assessed risk at each location. Otherwise security of the US FAA, as NZ has done in modified form. The management is essential. CASA needs to clean up the would help reduce emissions. EMTs would have measures are a waste of money and resources. result is that the NZ industry has reduced costs and is regulatory framework before handing over the minimal impact. buoyant while ours is declining. Government promoted administration of GA. training and education should be made available for implementation of SMSs by the GA industry. Airlines of Tasmania Appropriate replacement aircraft are expensive and Security at small airports is inconsistent and out of proportion to Pty Ltd airlines need support from local communities before the risk, particularly in comparison to other modes of transport or embarking on replacement programs. other potential risk areas. Airvan Flight Services Pty Ltd ANU Centre for Climate Concerns over the growing contribution of aviation due Law and Policy, ANU to forecast demand. Considers current industry College of Law initiatives not sufficient to stabilise emissions in accordance with necessary targets to mitigate climate change in the absence of a reduction, or restrictions, in demand. Archerfield Airport Australia should learn from the NZ experience, where Security measures adopted at major airports are not appropriate Chamber of Commerce significant deregulation has resulted in a complete turn for regional and remote services. Small aircraft do not pose a around, with an exponential increase in activity and re- high security risk. Fencing of regional airports to capital city investment in newer aircraft. airport standards is a waste of taxpayers money. Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 6 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ Areas covered in submission: 1 Australian aviation industry 1.1 International services 1.2 Domestic services 1.3 regional & general aviation 1.4 addressing skills needs in aviation industry 2 Aviation infrastructure 2.1 airport planning and development 2.2 air traffic management Individuals' name summary/key words Arts Access Australia Disability standards Attorney-General‟s International/Regional services, Recommends an exemption from current cabotage Recommends the practice of allowing articles in air services Department airport pricing, compensation, policy be granted to allow international carriers to fly arrangements that prohibit the Government from charging security (NB includes synopsis of between Christmas Is, the Cocos (Keeling) Is, and foreign carriers airport user charges that are higher than initial submission from Robert Cornall South East Asian destinations on the grounds this is those levied on our own airlines receive consideration in any and no synopsis of ASIO submission consistent with Government policy to support air discussion on airport pricing due to the potential for airport due to classification) services to remote communities where not operators to impose a higher charge and render the commercially viable. Government in breach of international obligations. Austcorp Group Ltd Airport planning, particularly high-rise Sees a need for greater integration between prescribed urban development and airspace airspace regime and state and local govt planning regimes. Considers improved awareness of an airport's activities and airspace needs and impacts for urban planning is required. Suggests airspace regulation not appropriate to be vested in local authorities and existing regulation at the Federal level is ambiguous and provides for little involvement by the proponent. Believes airport and urban development can occur in a balanced fashion given improvements in aviation technology. Australia Pacific International, regional and GA, The failure of airlines to take up the offer of open The general approach taken by successive governments has There is a case for direct fiscal support for regional airport While it is for the industry to ultimately solve skills shortage Investment in airports is strong and prices by world There is scope to reduce regulatory burdens while at the same Oppose the move by Airservices to network based pricing for Airports Corporation domestic, skills shortages, access to regional destinations is evidence that served Australia well and there is no need for policy reform in infrastructure in certain circumstances and for services to problems, there does appear to be a lack of a coordinating standards are in most cases relatively low. Existing policy time improving transparency and public confidence in the ARFFS provided to category 6 aircraft and are deeply concerned infrastructure, airport development market realities are the driving force for new services. this area. remote communities. However, support for regional aviation force to bring together the various industry participants and has served Australia well and will continue to do so. planning framework. Consideration should be given to by suggestions Airservices is looking to extend this approach to and planning, ATM, Safety, climate Too much effort has been wasted on agreements that should not distort competitive outcomes or effectively tax training service providers. The Government's Aviation training Australia's approach to the economic regulation of airports incorporating in the master planning process an approach terminal air navigation services. The Government needs to change, noise, security. offer little commercial advantage and the focus should users of services not involved with the provision of services to package is an important first step and the Commonwealth since 2002 has facilitated massive investment to refurbish similar to that in the UK where developments that do not involve carefully consider this issue and provide certainty about its be on agreements that deliver the greatest benefit, eg regional Australia.. should continue to provide strong leadership in aviation industry ageing assets and given the industry a degree of flexibility new runways are given "as of right" approval to support a approach, otherwise it will risk stifling infrastructure investment and China, the ME, SE Asia and emerging markets. There skills development. that would not be found in an environment of price controls. certain level of passenger throughput and/or aircraft route development by airlines serving major capital cities. is no compelling reason why the current foreign Regulation should only extend to those services where movements. The current planning framework does not have ownership rules specific to Qantas should persist. If the market power exists and is likely to be used in ways that serious systemic problems. Where poor outcomes have 49% foreign ownership limit is to be removed for damage economic efficiency and this should lead to the dual occurred they have had more to do with poor decision making airlines, there is no good reason why it should not be till approach being favoured over the single till approach. We than fundamental problems with the Airports Act. That said, it is removed for airports, although this is not a high priority do not believe there is a case for the expansion of services clear the Government has serious concerns with the planning for airport owners or investors. The Government being monitoring, in particular car parking. provisions of the Act. Regrettably the Issues Paper does not should seek to remove national ownership as an issue make clear what those concerns are and it would be in gaining access to international markets. appropriate that further consultation occur prior to the publication of the Green Paper so that all stakeholders have input into the options being considered. Australian & International policy, domestic policy, · Future negotiating priorities must explicitly consider Market forces alone will not produce satisfactory aviation · Ensure competitive pressures and the current shortage does · Guarantee that aeronautical requirements of airports and · Modernise the Australian Air Traffic Management (ATM) system International Pilots skills and training, airport the likely impact of “open skies” agreements on industry and safety outcomes. not reduce pilot operating and licensing standards from airlines take precedence over non-aeronautical developments to effectively and efficiently handle the forecast traffic growth in the Association development, airspace industry employees‟ and the stability of the industry. Australia‟s „best practice‟ to global minimum standards. of airports. medium to long term. management, emissions · Retain foreign international airlines‟ restricted access to the · Cater for closer commercial relationships between domestic market as the current level of competition, quality · Tackle the pilot shortage through a multi-faceted approach, · Ensure Australia subscribes to the world best practice (ICAO · Utilise satellite based communication, navigation and surveillance airlines in the form of equity alliances rather than and frequency of services in the domestic market is sufficient. combining both short and long-term measures. Recommendations) with regards to aeronautical developments. technology in the course of modernising the ATM infrastructure. mergers. · Amend the Qantas Sale Act to increase the aggregate · Attract greater interest in flying as a profession and expand · Establish an airport industry working group to investigate the · Endorse the ATM Strategic Plan issues paper Air Traffic · Promote competition but ensure adequate aviation equity held by foreign airlines to 49 per cent, with a maximum FEE-HELP and other schemes to cover flight training, reducing issue of mechanical turbulence and develop appropriate Management 07 – A Strategic Vision for Australia developed by safety safeguards are in place. held by a single foreign airline to 24.5 per cent. upfront training costs. standards as a world first. the Australian Strategic Air Traffic Management Group in December 2007. · Use bilateral Air Service Agreements to promote, or · Amend the Qantas Sale Act to prevent the situation where · Improve the utilisation and career path of pilots within the · Establish an Airport Consultative Committee comprising in certain circumstances require, international airlines the Qantas Group may be dependent on majority foreign- Qantas Group via removing the artificial barriers between industry, Government, professional pilots and other · Develop a programme to attract, train and retain air traffic flying into Australia comply with Australian standards owned subsidiaries for its aircraft, freight services or brand mainline, QantasLink and Jetstar. stakeholders to facilitate safe and efficient aeronautical airport controllers similar to that proposed by AIPA for pilots. and recommendations where they exceed ICAO loyalty programme. developments, review operations and assess future needs. minimums. · Establish a national body comprising industry, Government · Restore the original spirit and intent of the Qantas Sale Act and pilot representatives, dedicated to overseeing safety in · Develop a secondary airport for regional and domestic · Ensure Australia‟s bilateral agreements provide for by amendments ensuring that subsidiaries, such as Jetstar, professional aviation through administering pilot training and operator use and thereby release capacity at Sydney airport for enhanced safety accreditation processes where mutual are subject to the Act. certification standards. high capacity domestic and international flights. recognition of safety certification appears to be inadequate. Encourage airlines to address underinvestment in training and · Introduce new technology in the form of a category II or III adopt a longer term focus through offering scholarships that instrument landing system or Global Navigation Satellite subsidise the cost of full-time flight training. System technology to airports periodically closed due to weather below minima such as Sydney and Canberra (Melbourne‟s introduction is already scheduled). Australian Air League GA Effect of landing and ground parking charges, bi-annual flight Volunteer-staffed air activities centre at Camden Airport. Pilots Instead of increasing number of GA airports around large cities, checks and navigation exercise, radio procedure changes - are not renewing licences: Spirally costs for all services (incl airports like Hoxton Park is sold for housing. Bankstown & daunting, expensive and time consuming. licence applications & renewals, security passes, airservices Canberra has portions sold off to other industry, with some GA was promised an alternative "Recreational Pilots fees, etc.) fuel, aircraft hire. Centralisation of activities to CASA runways closed. Licence" (cf USA and adopted by RAA) has led to processing delays. Flying schools used to issue Student Pilot Licences on CASA's behalf - now CASA does it & it can take months. Drop out rate is a prime concern to GA. Cost of fleet replacement such that most (85%) of the flying school fleet was manufactured in 1970s. Expressed concerns re shortage of instructors, student pilots, lack of airports, and engineers. Cadre of LAME's in GA are approaching retirement age, no replacements for this specialist industry. Australian Airports support for light-handed investment Supports unlimited international airline access all Curfews affect airlines' ability to conduct domestic 'back of Proposes tax concessions to support regional and GA and to Airport planning, airfield standards, OLS and specialist Support continued application of a light-handed regulatory Broadly supportive of ASA's management of Australia's airspace. Association regime, need for review of Australian airports and government strategies to attract the clock' operations to popular tourist destinations. Slot fix ageing aircraft. „One size fits all' security model is not engineers and qualified airfield lighting technicians are now in regime. Any future reviews of airport regulation should be Airports/Environment Act interface, international airlines to Australia and to secondary limitations on the east coast deter foreign domestic airlines commensurate with risk at regional/remote airports. The short supply. There is no overall strategy to develop and train undertaken by the Productivity Commission. The Airports Act support for market liberalisation, airports. Poses the question whether Australia with from entering the market. Government should consider a process to actually identify sufficient numbers of these types of staff. Insufficient planning provisions and Government issued consultation support for smaller airports, beter access to international routes denied. Perhaps and quantify the contribution made to 'local' communities and specialised security training framework for regional airports. guidelines are sufficient. Major Development Plan process has road planning, review ANEF system, Australia should be more generous in granting 5th their economies by airports and aviation generally. Tax incentives extended to those working in rural, regional and become complicated because of interaction between Airports review security measures Freedom Traffic Rights. States that current airport remote locations to address attraction and retention issues. and Environment Planning and Biodiversity Conservation acts. curfews are an unnecessary constraint on international Commonwealth should limit new residential developments on operations. Suggests that revenue raised by the greenfield sites under the flight paths of major capital city Passenger Movement Charge should be used to better airports. Integrated approach to airport planning and road resource boarder agencies at international gateway provision and should recover costs from respective State airports as well as operations at any 'emerging' and/or Territory Governments if they fail to provide adequate international airports in the regions. access. The present system of identifying and evaluating potential breaches of the OLS and Pans Ops at airports should be reviewed and CASA should become more proactive in the assessment process. Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 7 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ 3 Aviation safety 3.1 safety regulation & regulatory reform 4 Customer & community protection - addressing 4.1 aviation emissions and climate change 4.2 aircraft noise 4.3 consumer protection 4.4 disability standards 4.5 compensation arrangements in the event of an 5. Aviation Security Individuals' name impacts of aviation accident Arts Access Australia Does not believe current Transport Standards meet the needs of travellers with a disability. Supports the view that HREOC be granted powers to self initiate and refer cases direct to the Federal Court. Suggests improvements to the Disability Discrimination Act to simplify complaint and compliance mechanisms including the right for advocacy groups to make representations in their own right and increased funding for public interest cases to be brought forward. Also seeks investigation of compliance certification processes for major airlines, as commercial entities, and evaluation of the UK model and its application in Australia. Attorney-General‟s In reviewing domestic compensation arrangements, Notes that the Air Security Officer program is subject to review Department recommends consideration of two draft ICAO and that consideration is being given to a Closed Circuit conventions currently under development on Television Code to improve surveillance at airports. Considers compensation for damage caused by aircraft to third the background checking regime for overseas ASIC applicants parties, including as a result of unlawful interference. requires enhancement and cross-agency activity is being undertaken in this regard. Austcorp Group Ltd Australia Pacific Supports the reinstatement of a CASA board provided Market based solutions (including emissions trading) lie The challenge is for the airport and the air traffic Existing security measures should be reassessed to determine Airports Corporation CASA is given full operational independence, without at the heart of ensuring that emissions are ultimately services provider to involve the community in an whether the rationale on which they were based continues to political interference.. Supports the risk based, as reduced. Care needs to be taken to ensure that in overarching strategic way as opposed to simply hold true. Such a review should lead to a streamlining of opposed to a prescriptive infrastructure-based seeking to address emissions, Australian airlines are seeking ex post facto justification of current positions passenger processing while maintaining or possibly enhancing approach to safety. not disadvantaged when operating in markets where and previous decisions. These efforts would be greatly security. The establishment of the Security Screening External competitors are not subject to similar regimes. By assisted by the Commonwealth clarifying its Advisory Group and the approach adopted by the OTS in reducing their own energy consumption airports can expectations in relation to responsibilities of airports dealing with the aviation sector in recent years demonstrates make a contribution, albeit small, to reducing and Airservices which have become blurred over time. their willingness to engage with the private sector in a meaningful emissions. way. Supports the move away from the categorisation approach to security to a more risk based and outcomes focussed approach. There should, however, be greater transparency to the process so interested parties have an opportunity to contribute to its application. strongly opposed to the extension of network pricing to the provision of aviation security services. Australian & · Ensure competition policy is balanced by regulatory · Adopt measures which reduce aviation‟s International Pilots vigilance and sufficient resources for safety environmental footprint such as continuous descent Association compliance to guarantee existing safety standards are approaches, more efficient fuel consumption, reduced not undermined. noise emissions and improved airframe and engine technology. · National aviation policy must provide CASA with the necessary compliance enforcement systems, · Contribute greater resources to promoting voluntary resources and independence from industry to play the carbon offset schemes. role of an effective balancing weight. · In line with shift toward outcome based regulation, · Promote the establishment of an emissions trading CASA‟s resource focus must more fully transition from scheme but allow for a phased introduction. their traditional role of prescriptive oversight to one emphasising safety vigilance and systems compliance · Ensure an Australian emission trading scheme is part auditing. of a global solution. · Safeguard and protect Australia‟s “worlds-best” aviation safety standards from being replaced by the global minimum standard. Australian Air League Self regulation in recreational aviation is real pattern for Govt and CASA to develop for GA. Lots of talk of deregulation of GA, but CASA seems reluctant to let go. Australian Airports CASA should have an 'independent' Board. CASA If airports exceed the established threshold, will trade The AAA proposes that, as aircraft continue to be Consumer protection for 'aviation customers and Should there be any unintentional conflict between No third party or additional liability coverage should be Security risk assessments, business cases and community cost Association needs to stop endless consultation and take decisive in the Australian Emissions Trading System for credits designed with air frames and engines that are consumers' should be treated no differently to any disability standards and CASA's safety requirements, contemplated at this time benefit analyses should govern aviation security decision. A 'one action in regulatory reform program. There is still a to meet their requirements. The calculations of aviation successively quieter, the use of capacity controls at other part of Australian industry; the CASA requirement must always prevail size fits all' approach is not appropriate, security measures high level of inconsistency in the way in which field greenhouse gas emissions should be undertaken by airports based on noise emission, such as curfews and introduced at capital city airports appear to have been officers interpret regulations. Self-administration of using a standardised method and be independently slot allocations, should be annually reviewed. A new inappropriately deemed to be suitable or required for regional aviation should not be encouraged without qualification verified and reported by the responsible party. The system for assessing and managing background noise, airports. Air cargo security appears non-existent at regional and strict CASA oversight. Self-administration of safety AAA supports the cap and trade-system for emissions which has measurable units and can be readily locations. The Department also needs an 'exit strategy' for rules applicable to airports, via delegates, should be trading as proposed by the Department of Climate understood by communities, and all three tiers of security measures which are no longer relevant. The given due consideration by CASA. Change, but wishes to ensure the unique position of Government in land use planning around all airports, introduction and management of new security measures also airports is reflected in the way the system will operate should be developed. The AAA proposes that a needs a much more 'savvy' and effective media. That the for aviation. review of aircraft noise and land use planning should current aviation security requirements ought to be reviewed, be undertaken to define a common Australian aircraft amended as appropriate, and simplified for the benefit of noise protocol passengers and industry participants. We are in favour of any initiative likely to enhance security arrangements for air cargo. Any strengthening of the ASIC eligibility criteria would be supported. Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 8 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ Areas covered in submission: 1 Australian aviation industry 1.1 International services 1.2 Domestic services 1.3 regional & general aviation 1.4 addressing skills needs in aviation industry 2 Aviation infrastructure 2.1 airport planning and development 2.2 air traffic management Individuals' name summary/key words Australian Association GA vs RA-Aus standards, training Differences in standards between CASA and RA-Aus AAFI has limited its response to selective “White Paper” of Flight Instructors issues administered safety oversight questions where it considers key policy change will reward a compliant flight training industry standard in aeroplanes exceeding 600 kilograms. The structure of the “White Paper” questions has prompted a need to repeat several solutions and the Appendix Section to define the key elements. AAFI‟s overriding aim is encourage a policy that offers equal opportunity to deliver competent flying training at all levels in aeroplanes exceeding 600kg prompts the following questions:- 1. Replace the current GST exemption ruling that discriminates against organisations or trainees unable to meet requirements and are penalised 10% penalty to fund others to achieve the same standard. 2. Amend a policy that allows a trainee to terminate a GST exempt course without achievement and penalty? 3. Allow a blanket GST to build an industry fund aimed to promote a compliant employment work force with qualified school trainees rewarded with fixed rebates at established levels. 4. Eliminate current policies that fail to distribute funding in a fair proportion to AOC operators? 5. Recognise and support a common competency flying training syllabus in aeroplanes above 600kg delivered by a Part 61 qualified skilled work force employed at or above award conditions. 6. How will the passenger protection policies vary Australian Business General aviation, air traffic Lack of tax incentives is a major factor against introducing from fare paying to cost sharing and how will the pilot training Private business and charter flights operating in controlled Aircraft Association Inc management, noise. new and safer aircraft. A one-off investment allowance of say airspace and at busy airports are often treated as low priority by (ABAA) 40% for new equipment ordered within two years would Airservices. This unfair and discriminatory practice should be provide an excellent opportunity to replace older aircraft. Any reviewed and corrected. profit from the sale of old aircraft should be free of capital gains tax, enabling it to be used towards the purchase of the replacement aircraft. Australian Construction Need for Commonwealth airports to Sub-regional (i.e. 'airport region') plans for airports, prepared Industry Forum Limited be develpoed consistent with local, with tri-governmental and private input, funding and support, regional and state planning and encompassing the broad gamut of off-airport considerations environmental, economic and social considerations (including network infrastructure provision, transportation, orientation of land uses to the airport, location of commercial and activity centres, building heights, urban design etc) should be considered. These plans could be given legal force under state instruments. These sub-regional plans would also require airports to properly address the extent of their economic, social and environmental impacts arising from their aeronautical and non-aeronautical development on the efficiency of off-airport operations and development. It would be understood that these plans would be compatible with and integrated into broader metropolitan strategies. The need to ensure that airport development is fully integrated with metropolitan planning processes is a major plank of the Planning Institute's position statement on development of airport land (Australian Planner, 43, 3, 2006). If need be, to ensure tri-governmental co-ordination and integration, the Commonwealth Government should enter into binding agreements with airport owners that requires non- airport development on airport land to comply with state planning policies and instruments. Amendment of Airports Act and Regulation If Commonwealth Ministerial control of airports is to continue, ACIF suggests that amendments to the Airports Act would align the operation of the legislation more closely with planning Australian Federation international air services, regional Encouragement of the development of new Australian It is preferable to have “Australian International airlines” Government and industry policy towards regional and remote Pilots who wish to continue studying should have access to the The encroachment of community development around best practice: There is currently a shortage of qualified air traffic controllers and it of Air Pilots (AFAP) airports, security, GA, skills, international airlines, such as V Australia, is preferred majority owned by foreign airlines than what would have communities should be to provide a safe service to all HECS-HELP scheme. The fact that the training is conducted airports may lead to the very disaster the original planners is impacting on air traffic and placing more pressure on pilots in infrastructure, safety to the Government allowing international operators to occurred had the private equity consortium, APA, been communities, an economically viable service to those by other than universities should not be an impediment. A specifically sought to avert. Entrepreneurs purchasing airport their day to day operations. The Government must be prepared to conduct operations as if they were Australian. There is successful. There need to be protections to ensure Australian communities which can afford to pay for the service and reinvigorated TAFE system would provide another alternative. sites for commercial development is a worrying trend that fund the technological development required for air traffic no benefit in opening up the Australian domestic carriers function economically and efficiently whilst still continued subsided services to smaller remote communities A resurrection of the Commonwealth Flying Scholarship will inhibit aviation development in the future. management. Advanced navigation systems, technology and new market to international operators. Australia is not their maintaining the primary role of serving the Australian public. which cannot afford the service. There needs to be an Scheme should also be considered. The major airlines have generation aircraft demand an independent review of current „core‟ market and their involvement may result in an Limitations on numbers on the Board may be one approach. assessment of the mix of government assistance and the benefited significantly from GA output and should be required airspace architecture, e.g. SIDS and STARs, free from political Australian domestic operator being destroyed. The Australia deregulated airline market is working in the free market to achieve the best outcome. The development to make a greater contribution towards the training of pilots. interference. Australia cannot rely on foreign airlines operating into terms intended; providing a reasonably high standard of of more efficient regional aircraft, carrying more passengers, Initiatives such as providing scholarships to aspiring pilots in this country meeting the standards we require. service that offers choice and reasonably priced fares. has been significant over the past 10 years. As this regional and indigenous communities would also broaden the Whether the aircraft are owned or leased the same continues, centres that were not previously well served may recruitment base and make the retention of pilots in these standards need to apply. The costs and implications have better options in the future. Depreciation of aircraft is communities more likely. The costs associated with maintaining associated with multiple international airports bring into one logical way to unhinge the aged aircraft. However, it may qualifications are also a significant factor. The policy of cost question whether international airports outside capital also lead to unwanted aircraft in the industry. In order to recovery has seen the costs of achieving and maintaining cities are viable or of value to the locality. Supports a maintain continued safe operation of ageing aircraft, safety qualifications increase dramatically. CASA costs in particular cost/benefit approach to international airport regulations need to target all commercial operations carrying need to be looked at. The standardisation of pilot and air traffic development with an outcome that encourages commercial passengers. controller training and certification, and the sharing of training expenditure to be put into the major centres. resources and infrastructure by civilian and military trainees, should be supported. Australian Federation Access to airline services for people with 1. The Australian Government should consider the a. A specific code of practice should be developed for the 1. The development of better facilities for people with The Australian Government should require that airlines and Consultation with State and local authorities and with the of Disability disabilities. regulatory practice of the European Union, Canada airline industry and administered by a Federal Government disabilities at regional airports would assist with the airports ensure staff are trained and regularly updated in the community must include people with disabilities. Regulation, Organisations and the United States of America in the area of access Transport agency. development of regional aviation. provision of appropriate assistance for a range of people with similar to that introduced in the European Union, should be by people with disabilities to services and with a view b. The overall regulatory framework for the airline industry 2. The recreation sector of the airline industry needs to disabilities. The training program schedule should be available developed in Australia. The European Regulation is CF1107- to improving competition for the airline international would be enhanced through development of a consultation examine its provision of access to people with disabilities. to the public and list the general content, plus there should be 2006 and it specifies that: services as part of an airline licensing conditions. obligation. an annual release of the training outcomes achieved by airlines. a. The management of assistance for people with disabilities 2. With the ratification of the UN Convention on Mandatory monitoring and reporting through a relevant As part of this requirement there should be a mandatory has been taken out of the hands of individual airlines and Human Rights for People with Disabilities before the Federal minimum level of competency for all staff with regards to placed within the management of the airport authority. House of Representatives in the Federal Government, transport agency to ensure national consistency. disability awareness. In particular, this minimum standard b. That the responsibility for ensuring that all airport at present, the negotiations of air service agreements should include an ability to respect the judgement of the management are adhering to the CF1107-2006 regulation has with airlines from other countries must be closely customer with a disability when it comes to the type and been given to the Civil Aviation Authority in each European monitored and the Convention must impact on the amount of assistance they need. Staff should be able to take Country (see Attachment C). provision of International Services. advice from customers in this regard, and to negotiate the best possible solution. Australian General regional & GA, skills, airport Acknowledgement that we NEED general aviation for GA directly and indirectly provides jobs and apprenticeships for There appears to be no appreciation or understanding of the Air space and air services should be more user friendly for G.A. Aviation Alliance planning, air traffic management, transport and regional development. There seems to be little many thousands of people. It serves as a training ground for need to provide adequate airports and emergency landing including weather briefing from voluntary Met. Observers. (AGAA) safety, environment. knowledge and certainly NO policy in any of the tiers of the Air Force and the airlines who are starting to suffer from the grounds for GA. Existing airfields are being closed or made government for the development and promotion of General shortage of professional people. There is already a shortage of uneconomically viable by State and Local Government Aviation. aircraft maintenance personnel and aeronautical engineers organisations lured away by “Developers” solving short term because of the Decline in G.A. The government policy on G.A self imposed financial problems. Town planning training does should provide for the encouragement of training and support not include airport planning/ provision of aviation infrastructure. of air shows, forums, school programs and general public An airport is a community asset, an infrastructure necessity. It relations promotions. should not have to pay for itself directly. More airstrips are required, these don‟t need to be an “aerodrome” as such but a landing strip. Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 9 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ 3 Aviation safety 3.1 safety regulation & regulatory reform 4 Customer & community protection - addressing 4.1 aviation emissions and climate change 4.2 aircraft noise 4.3 consumer protection 4.4 disability standards 4.5 compensation arrangements in the event of an 5. Aviation Security Individuals' name impacts of aviation accident Australian Association of Flight Instructors Australian Business As more modern, quieter business jet aircraft become Aircraft Association Inc available such aircraft should be added to the list of (ABAA) aircraft approved to operate at Sydney Airport during curfew hours. The current approval process could be simplified and streamlined without increasing noise. Australian Construction Industry Forum Limited Australian Federation The current demarcation of CASA and ATSB functions CASA has been the subject of unrelenting change and A national Carbon Trading Scheme involving the A cost benefit analysis is needed to determine whether it is of Air Pilots (AFAP) should remain. “Flag of convenience” carriers should scrutiny and the lack of a clear role for it has resulted in issuing of emission permits with incentives for those beneficial to provide security outbound at regional airports versus not be allowed to enter Australia, but if they are, that years of uncertain management. From the point of making early reductions will be a step forward. An „opt providing security inbound at the major cities into which entry should be subject to stringent surveillance. The view of the people we represent in CASA there has out‟ rather than an „opt in‟ option would increase the passengers fly. It may be that money being spent on security at question of self administration remains unanswered in been a marked degradation in the level of technical take up rate of offset schemes. The reality is that if the regional airports is better spent ensuring the most modern certain areas but overriding any self administration expertise and knowledge required by CASA. In NZ the projected growth in air travel is realised the security technology is used at the major centres. There is a regime is the need for adequate and competent CASA review of regulations occurred far more rapidly and greenhouse gas emissions of the aviation industry will limited amount of funds to spend on security at airports outside oversight. that process may be used as a template in Australia become a much larger proportion of the global total. the major airports and those funds could be better utilised. We rather than the all inclusive approach that has possibly Advances in airframe and engine technology will partly seriously challenge the efficacy of air marshals and believe the contributed to the protracted reviews. There is a address the issue. New generation aircraft have money could be better spent elsewhere. Our members regularly dilemma here for the industry because it demands reduced environmental footprints which needs to be provide examples of inconsistencies in screening procedures consultation and involvement and the formulation of recognised. If this is achieved carbon emissions will be and their application. New technology and vetting of persons new regulations represents the same interests as the significantly reduced. prior to a flight will facilitate transition of passengers in a security people that are critical of the process and length of the sense and minimise the threat to aviation security and delay to review. passengers. Australian Federation The Civil Aviation Safety Authority in conjunction with That a more effective system than the carbon offset To address the requirement for one hundred per cent That the standard conditions of carriage is revised The airline industry should develop Disability Action Security divisions at airports should undertake security checks in of Disability the Australian Government and the airline industry schemes to help reduce greenhouse gas emissions is access to information by overcoming aircraft noise against the Transport Standards and the Disability Plans under the Disability Discrimination Act 1992 and a timely manner, so that passengers can get to their flights. They Organisations should make their safety regulations consistent to allow investigated by the Department of infrastructure, issues for passengers who are hearing impaired, Discrimination Act 1992; and, a plain English version of the Accessible Public Transport Standards 2002 . should also review their processes and policies in regard to for the inclusion of people with disabilities on aircraft. Transport and Regional Development and Local airlines should provide portable neck loops available the suitably revised conditions of carriage be prepared. This should be done in consultation with people with people with disabilities. In the review process they should consult Government. upon request during a flight. Airlines should not be permitted to restrict the disabilities. people with disabilities. transferability of tickets, except where absolutely An industry-based complaints process that is The procedure for accessing information about wheelchair necessary; and airlines should be required to offer accessible to all consumers, which can provide timely details be reviewed. passengers refunds instead of credits where a outcomes and result in systemic improvements to passenger is unable to travel for reasons beyond their service delivery. control. That the Department of Infrastructure, Transport, Airlines be required to expand the grounds on which a Regional Development and Local Government and the person may be eligible for a refund; and, airline industry incorporate the proposals developed by The compensation available to people with disability for the Public Interest Advocacy Centre‟s publication cancelled or rescheduled flights should be increased. “Flight Closed” into the regulatory system needed to As required by the Transport Standards, air transport improve the conditions for people with disabilities in the providers should offer information to consumers in airline industry. plain English and make available the full terms and conditions in alternate formats, on request. Operators review the restrictions they place on carriage to ensure they are consistent with the Transport Standards and the Disability Discrimination Act 1992. Australian General Self-Administration for private G.A. should be The use of G.A. for transport compared with motor Aviation Alliance delegated to an appropriate industry organisation. vehicles would have a profound benefit on the (AGAA) CASA regulations should be tempered with a policy for Australian environment considering that aircraft burn the development and promotion of G.A. and fuel much cleaner than automobiles requirements which are not strictly of an important safety matter should be amended if not eliminated. Breaching of regulations should NOT be a CRIMINAL offence. New Zealand and USA regulations should be used as an example. Cost Recovery should be transparent with a proper independent audit of costs incurred. Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 10 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ Areas covered in submission: 1 Australian aviation industry 1.1 International services 1.2 Domestic services 1.3 regional & general aviation 1.4 addressing skills needs in aviation industry 2 Aviation infrastructure 2.1 airport planning and development 2.2 air traffic management Individuals' name summary/key words Australian Hotels International air services policy The aviation and the hotel industries are key elements The National Aviation Policy Statement should recommend the Association (AHA) in the tourism supply chain. Therefore, Australia‟s new removal of current obligations that reduce the efficiency and National Aviation Policy Statement must be linked to effectiveness of major airports. Relocating regional air services the Australia‟s National Long-Term Tourism Strategy, to Bankstown Airport would increase the capacity of Sydney which will also soon be developed, and both should Airport to handle future international traffic and alleviate the guide legislation, regulation and other processes to need for a second international airport in Sydney. help maximise the number of visitors to Australia and To assist with improving regional access in and around Sydney, travel/tourism within Australia. it is the submission of the AHA that Newcastle and Canberra Aviation access to Australia must be based on current airports could accommodate overflow passenger and cargo air and future demand for all potential visitors. This traffic and that these facilities should be linked to Sydney by a includes visitors who travel for reasons of leisure, Very Fast Train (VFT). business, meetings, exhibitions and conventions, to Transport links to and from Melbourne Airport would be further their education, medical treatment or to visit enhanced with the establishment of a high-speed rail link friends and relatives. between the city centre and the airport at Tullamarine. The Australia should adopt a robust process to monitor AHA favours a similar option as part of the redevelopment of bilateral air service agreements (ASAs) to assess if Perth Airport. they help or hinder competitive air access to this country. The AHA believes that a formal process should be established to enable a review of bilateral arrangements on an identified transport/tourism corridor if they are impeding visitor access to Australia. This should apply a “use it or lose it approach” that could allow designated airlines to operate on specific routes between Australia and other countries, even if that airline is neither based in Australia nor in the country at the other end of the route or routes. A final decision should be based on a demonstrable demand for that service which is not being met by approved carriers and the assessment of the total net benefit to Australia. Australian Licenced Safety, regulatory reform, Emissions, Australian hotels would derive benefits important role The Government should recognise the from increased The policy contains a statement that the Commonwealth „Systems of maintenance‟ schemes, certification standards, The construction or development or redevelopment of any Aircraft Engineers Domestic, International, Airport Qantas has played as the national airline, its Government‟s spending on Government contracts and competency requirements, in civil and military aviation will be airport must contain reserved space for the construction of Association (ALAEA) planning, Skills contribution to the economy and the Government‟s domestic air travel will be fair and equitable and allocated on consistent and aligned. Group or co-operative training maintenance facilities interest in keeping Qantas as an Australian based a formula basis. arrangements should be established using appropriate funding airline. and incentives. Australian Local Regional aviation, remote air Supports continuation of subsidies to support services to Should evaluate the policy of devolving responsibility of support Government Association services, airport planning and remote areas. funding to local governments within the context of the Inter- development Governmental Agreement Establishing Principles Guiding Inter- Governmental Relations on Local Government Matters. While local Government appreciates support given to regional airports for security etc, there is no strategy behind the support. Should appropriately consult with local governments and explicitly state in any decision whether developments are consistent with state and local plans and if not why they should proceed. Consideration should be given to charging the equivalent of rates and developer contributions to councils to help pay for infrastructure requirements. Australian Mayoral International air services, Noise, Sydney Airport Capacity: Sydney airport is well beyond Rate equivalent payments and the broader question of Land Aviation Council Consumer protection, environmental, capacity and is likely to be so long before the expiry in Use Planning for non-aeronautical commercial development on GA, security 2023/24 of the current Master Plan. The only effective airports - airport operators should not have an unfair method to improve the international capacity is to reduce or competitive advantage over other property owners. The displace the domestic capacity to a second airport. The Department of Transport and Regional Services administering limitation on the capacity of Sydney Airport will have “flow the airports‟ leases did not take action to require the airports to on” effects for other major airports. comply with the provisions of those leases dealing with rate equivalent payments. When dealing with public money a higher level of accountability is expected and that Department failed to properly administer that lease. There have been instances where it has been alleged that the work projects on airports have been broken down into its various parts so that the cost does not exceed the limit of $10 million (now $20 Million) which is the trigger in the Airports Act to require the preparation of a Draft Major Development Plan. Such attempts to avoid the provisions of the Airports Act should be prohibited by the proper administration of the Act. The Airports Act, at section 94, nominates the matters which the Minister must have regard to in deciding whether to approve the plan. None of the matters includes the effect upon the community. The current Airports Act does not countenance the possibility that a fatal flaw may be found in a Draft Major Development Plan at consultation stage and, therefore, makes no provision for the proponent of Australian Mooney GA, rural regional, CASA-regulatory, There needs to be a federal commitment to the improvement Pilot training could be brought into the HECS scheme. such a plan to go back to start again. The Airports Act is access In order to promote aviation there needs to be adequate The ADF has been granted exclusive use over a significant Pilots Association Airport access, security, air traffic and maintenance of the infrastructure. Clearly major to airports. A possible solution to this may be access to existing proportion of airspace which seems unnecessary when compared (AMPA) management infrastructure (such as air traffic control, radio networks etc) military facilities needs to be considered. There are a number to other international models even before the relatively small scale needs to be managed federally. Other components, such as of global precedents for the safe, effective use of military of the ADFs aviation activities is taken into account. This creates a local airfields, need more support. airports by GA. significant inconvenience to GA flights. A commitment needs to be made to a satellite based GNSS augmentation system and ADS- B. Given the level of technology currently available, we believe that the weather information available to pilots in the air is not acceptable. As the Flightwatch network can be undependable and does not cover remote areas Real Time weather should be available. An ideal model would be the XM satellite system available in the US where near real-time storm information, and current forecasts are available to pilots without the need for direct contact with a with an ATC/Flightwatch operator. A number of airports with ILS are not accessible to GA or require this to be pre- arranged. The lack of VHF radio coverage is a major concern. The lack of coverage compromises safety and limits operations (e.g. it often precludes IFR operations). Surely it is time to fill the gaps in Australia‟s VHF network so that the whole country has VHF above Australian Network of Emissions, airport planning Comprehensive environmental assessment of all airport 5000 feet and much more area with coverage to circuit heights. Environmental expansions and new airports should include comprehensive Defender‟s Offices Inc (ANEDO) evaluation of greenhouse impacts. Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 11 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ 3 Aviation safety 3.1 safety regulation & regulatory reform 4 Customer & community protection - addressing 4.1 aviation emissions and climate change 4.2 aircraft noise 4.3 consumer protection 4.4 disability standards 4.5 compensation arrangements in the event of an 5. Aviation Security Individuals' name impacts of aviation accident Australian Hotels Climate change and the expectation airlines (and other The Federal Government has indicated that it will Association (AHA) businesses) will have to (further) cut carbon emissions maintain existing airport curfews. The AHA is in the near future will have major commercial fundamentally opposed to airport curfews because implications for the aviation sector, particularly long- they reduce the efficient and effective use of airport haul destinations, such as Australia. The AHA does not infrastructure and are a barrier to cost-effective air support the unilateral imposition of a national levy or access. tax to help tackle this issue. Aviation and the broader tourism industry need to be seen as an export-exposed industry and treated accordingly within Australia‟s proposed emissions trading scheme. Australian Licenced Aviation maintenance” should be recognised for its Regulatory reform should not lower Australian “Aviation maintenance” should be recognised within the Aircraft Engineers contribution to air safety. Airlines who use Australian standards of competence, certification, maintenance policy as an essential tool in reducing and managing Association (ALAEA) airspace are expected to maximise their contribution to and/or safety. carbon emissions and an airline that performs light and the Australian economy by establishing and heavy maintenance of its aircraft within Australia will be maintaining maintenance capabilities within Australia given carbon credits in recognition that the efficiency of employing Australian based workers and to comply airframe and engines is being maintained to the with Australian aviation maintenance standards. CASA acceptable Australian standard so as to maximise fuel will communicate to persons with responsibilities under burn efficiency. the CAA or its Regulations within a relevant corporation any concerns, problems or alleged breaches and maintain a strict regime of inspection, audit and ensure compliance with the CAA and it‟s Regulations without regard to commercial or political influences. CASA should remain party to the ICAO standards whilst recognising they are the global minimum standard and where Australian standards are better or higher they will be maintained. Australian Local Government Association Australian Mayoral There is a pressing need for an Aviation Ombudsman Carbon offset schemes will do nothing directly about Complaints about noise and curfew incursions are That aviation security be subject to a comprehensive objective Aviation Council who could provide a method for dealing with the effects of emissions upon the communities currently recorded by the telephone answering review to determine if the current levels of security are complaints about airports and airlines for which there is surrounding airports which are currently suffering machine set up for the purpose by Airservices Australia appropriate or necessary. no reasonable avenue of appeal other than the airports deleterious effects from those emissions. The but there is little evidence that the complaints are taken and airlines themselves. emissions trading schemes seem to be little more than seriously. There should be a review of the properties a permit to go on polluting by paying for the privilege. surrounding the major airports to determine if the benefits of the sound insulation programme which applied to Sydney Airport could be applied some of those properties. Airbus A380 and the Boeing 787 aircraft may, in the future, if it can be demonstrated that they meet the appropriate controls, become acceptable to operate outside curfews. The ANEF system is flawed if the information upon which it is prepared is supplied by the airport and it is not then subject to any objective review of its validity. A possible solution restricting aircraft to very limited approach/departure paths and to treat the houses effected by noise with appropriate soundproofing and other measures. If any home could not be effectively so treated it would be compulsorily acquired and accommodation found elsewhere for those residents. At the present time aircraft noise is “shared” around over so many houses that it is economically impossible Australian Mooney The culture that permeates CASA is one that does not to insulate all of them so there is no end in sight to the GA pilots face is the lack of a common security access systems Pilots Association include the concept of the promotion of aviation. The at airports. (AMPA) constant changing of rules and regulations is a disincentive to participating in GA. Australian Network of The Australian Government must introduce regulatory Environmental and non-regulatory mechanisms to reduce aviation Defender‟s Offices Inc (ANEDO) emissions. Offset schemes should be limited in use. Offsets should be limited to projects that are verifiable, permanent and ecologically sustainable, to ensure genuine accounting of emissions. Federal Government guidelines that codify strict offsetting standards should be introduced. This will ensure that only genuine offsets are used and will also improve consumer confidence. Mitigation measures, such as demand side management, should be the primary focus of government funding and industry action. Demand management initiatives include the introduction of a flat- rate greenhouse charge on domestic flights and a kerosene tax, both of which will increase costs for consumers and reduce demand. The Federal Government should provide funding and facilitate research into alternative fuels, improved operating procedures, advances in fuel efficiency and research into engineering options. The Federal Government should investigate viable surface-based transport options to reduce demand for air travel. Potential proposals include high speed rail links between Sydney, Canberra, Melbourne and Brisbane. Lifestyle and business operational changes should be Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 12 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ Areas covered in submission: 1 Australian aviation industry 1.1 International services 1.2 Domestic services 1.3 regional & general aviation 1.4 addressing skills needs in aviation industry 2 Aviation infrastructure 2.1 airport planning and development 2.2 air traffic management Individuals' name summary/key words Australian Services International, domestic and regional Sees deregulation of industry as . Considers a national airline critical to ensuring continued Supports continued subsidy of services to regional and Supports the introduction of the National Aviation Training Pricing of car parking (and physical locations) and other Focus on commercial development is impacting core Union air services, skills shortages, airport detrimental to Australian jobs, wages and commitment to servicing domestic network remote communities Standards and seeks its expansion to cover all fields services at airports prohibitive for workers aeronautical business including passenger facilitation. planning, safety, security, aircraft conditions and contributing to the push to experiencing skill shortages including tourism. Aeronautical infrastructure in need of maintenance and noise, consumer protection and 'off-shore' work. Also sees deregulation as upgrades disability standards. exposing Australian carriers and industry to unsuitable levels of competition and threatening safety standards and conditions through 'flag of convenience' carriers. Australian Sport support for current safety oversight, Improve risk management approach to classification of airspace Aviation Confederation consultative risk assessment, ATM and review regularly (ASAC) strategic planning, asccess to small airports, airspace, safety, security Need for a strategic Air Traffic Management Plan. Australian Tourism International air services, airport A rapid unilateral move by Australia to “open skies” ATEC is yet to be convinced of the need for a second Export Council (ATEC) planning. would lead to an upheaval in the short term, as new international airport within or outside the Sydney basin. Global entrants “cherry-pick” profitable routes (with a strong experience in regional airport development sustains a strong business travel mix) to the possible detriment of less argument that market forces should be allowed to operate with profitable routes with a stronger leisure travel mix. respect to the further development of Newcastle and Canberra Supportive the progressive liberalisation of our aviation airports. To this end, ATEC also supports the investigation by markets as long as it leads to sustainable benefits for the Western Australian Government into whether market forces the tourism industry. Any decisions need to be mindful would support a domestic and international-capable airport for of, if not subject to, the commercial interests of Qantas the Margaret River region, and fully endorses the ongoing (and Virgin Blue) and the government should process for Broome International Airport to develop a service to vigorously pursue liberal access to foreign markets on Singapore. behalf of the Qantas Group and the Virgin Group. ATEC welcomes the participation in Australia of many foreign carriers. We also welcome the entry of new carriers, mainly from Asia, the Americas and the GCC, and “low-cost” carriers from the Asia-Pacific region. A sustainable competitive mix of profitable national and foreign carriers is critical to the future of Australia‟s tourism industry. Australian Unmanned Unmanned aircraft systems and Seeks recognition that unmanned aerial Aircraft Systems (UAS regulatory oversight including R&D. system industry exists and that it is a Australia) Provides ten letters of endorsement growing component of the aviation for position paper provided by UAS community. Seeks a commitment to work Australia. with the UAS industry to collaboratively explore regulatory issues by funding research and the establishment of dedicated UAS program function within CASA and Airservices Australian Workers‟ regional regulation, training and The Australian Government establishes a national review into That the Department of Education, Employment Relations, Union safety regional aviation services and develops a national strategy to establish a review into apprenticeships within the aviation support Australia‟s regional communities that includes airport sector and develop a new strategy with all stakeholders that will development, regional route planning, and fuel cost review. encourage young Australians to enter the industry and retain them long term. That the Department of Transport in association with the Civil Aviation Safety Authority develop a new training program and licensing scheme that involves multi level licensing for Australian nationals. Aviation Maintenance, International - safety & competition; Aviation must be treated not separately, The past fixation with competition will not improve air Deregulation has not benefited the community on other than Major regional centres should have a regulated system to Trade qualifications for LAME's must be compatible with North Privatisation of airports has been a failure, with owners There should be national building codes for all commercial and Repair & Overhaul deregulation;GA & regional regulate but as part of a government National services to and from Australia or support an Australian major east coast routes. There are not enough passengers support their region and small regional centres may need America and Europe and CASA should recognise a national extracting 'enormous' profits and airlines suffering increasing private buildings within a specified radius of an aerodrome. Business Assoc & support; skills & qualifications; (AMROBA) Transport Policy, addressing all modes of based industry. The Government should be negotiating available to regional and remote areas to support a free government assistance to provide air services to their industry trade qualification system that enables industry wide costs. Government assistance should be provided for Most privately, not so much community, owned airports charge infrastructure; insurance on all transport. with other Asia Pacific countries to adopt similar market. community. Governments should return to licensing employability and transportable qualifications. CASA should aerodrome maintenance and improvements based on the excessive fees to maximise returns to share holders. There is aircraft; harmonise security standards regulatory and business standards for all operators in operators to regional and remote areas to remove have a licensing system based on globally acceptable trade ability of community owned aerodrome operators to attract little transparency and resident businesses are forced to accept the region. Opening markets usually means safer competition. This would enable operators to invest in new qualifications. Aviation maintenance training should be under aviation business, as in the US. their costs or leave the aerodrome. operators will reduce costs, sometimes affecting safety aircraft. Australia should adopt a free market to support an the Transport& logistics Industries Skills Council, with skills standards, to compete with low cost carriers. The cost air taxi system, like in the US, utilising aircraft no older than training for other transport modes. of spreading border control capabilities to regional 20 years. This would remove ageing aircraft from the market aerodromes would far exceed the benefits. and provide competition to airlines that are maintaining unprofitable regional services. GA is still over regulated, preventing growth. It needs to be deregulated, like in the US and NZ. Aviation Safety Forum Safety, skills shortages, Lessons to be learnt from international practices of Early consultation with CASA on proposed development to Of the view Airspace Act and Policy Statement be permitted to infrastructure and liberalisation safety regulators ensure safety issues addressed under a project-specific risk work through a cycle before policy settings are examined. A number of observations and management approach Supports use of new technologies. recommendations on operational CASA issues that may warrant individual consideration outside of the NAPS process Aviation Safety Safety; CASA Board Considers CASA should maintain a strict approach to Considers safety measures for regional RPT should Identifies skills shortages as a major challenge for safety. Foundation Australasia foreign operators safety standards and AOC acknowledge low capacity aircraft can pose additional safety surveillance. risks. Aviation Sunshine International, domestic and regional Supports application of 'Regional Package' and Supports deregulation Air connectivity to capitals is essential of social and economic Sees a need for improved training facilities and financial Airports need protection from encroachment, particularly Supports current network pricing for ATM and ARFFs. Coast Inc services, skills, airport planning suggests dispersal of border services to regional ports sustainability. Sees a devolution from a Federal assistance to address the pilot shortage including flight regional and GA airports, through legislated protection for noise including noise, and security under network pricing model to encourage carriers responsibility to a local govt one without commensurate instructors. corridors and airspace for both current and future airport needs. funding and support from Federal or state govts. Suggests a regional airport infrastructure fund to ensure sustainability of services. Recommends 'second tier' airports at regional centres must be treated separately from capital city airports under regulatory regimes. Sees access to capital city airports by GA as restricted and has concerns over ongoing viability of sector due to fuel prices, aging aircraft and poor infrastructure planning. Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 13 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ 3 Aviation safety 3.1 safety regulation & regulatory reform 4 Customer & community protection - addressing 4.1 aviation emissions and climate change 4.2 aircraft noise 4.3 consumer protection 4.4 disability standards 4.5 compensation arrangements in the event of an 5. Aviation Security Individuals' name impacts of aviation accident Australian Services Views the airlines focus on profit over safety as Sees drive for competition as detracting from Suggests review of arbitrary curfew measures to Sees consumer awareness of ticket restrictions for Provision of appropriate equipment, training and Concerned that adequate screening of pax, baggage and cargo Union detrimental to safety standards and considers that if measures to address environmental issues balance amenity of community with needs of the 24 travel on LCCs as crucial and onus is on industry and infrastructure needed in order to facilitate movement of not occurring at regional airports and sees it as a Govt, not liberalisation agenda pursued it should be with hour economy, particularly air freight. Govt to promote disabled pax industry, issue to address. Sees lack of customer interface and countries that have strong safety records. Considers ID requirements, eg through self-check kiosks, as flaws in 'air rage' a risk to worker safety and recommends layered security regime. Considers air cargo screening requires improved passenger facilitation, signage warning of improvement along with consultation on security measures. penalties and training of staff. Recommends streamline of ASIC renewal process for on-going employees. Australian Sport 1. Increased funding for self-administration. Security requirements have not been risk based and have been Aviation Confederation 2. Increase auditing by CASA detrimental to industry. (ASAC) 3. Introduce auditing by ATSB 4. Modernise safety systems to place greater responsibility on pilots rather then the regulator 4. A National Training School should be set up with responsibility for Instructor and instructing standards. This organisation should contain a joint Industry/CASA National Safety and Training Panel with the responsibility to recommend competency standards and instructional techniques and oversee this changed level of responsibility towards SMS systems for pilots. Self administration should not be adopted as a cost saving measure, rather as a means of improving safety. Supports a CASA Board. ODLP needs resources to expedite drafting of regulations. Australian Tourism Export Council (ATEC) Australian Unmanned Considers CASA leadership in the arena of unmanned Aircraft Systems (UAS aircraft a positive that has recently been overtaken by Australia) international development. Seeks review of airworthiness certificate impediments to the operation of UAS in Australia. Australian Workers‟ That the Australian Government establish an inquiry Union into the impact of outsourcing aviation maintenance to foreign countries and develop a strategy in partnership with all stakeholder that will encourage the long term sustainability of aviation maintenance in Australia. Aviation Maintenance, Australia should do what Canada has done and All aircraft should be required to have at least third party Australia's security standards should harmonise with the Repair & Overhaul develop a complete aviation system that fits into property insurance. countries that aircraft directly fly to and from and Australia must Business Assoc (AMROBA) Australian legislative practices, style and format, not a work with foreign countries to standardise security standards. conglomeration of regulations based on FAA, EASA Currently, security provisions at regional and remote aerodromes and unique Australian regulations. are no more than a political stunt. Nobody has identified a real threat in dealing with the small aircraft sector. Security should be based on identified risk, not one size fits all. Industry should not have to bear the cost of security. It is the Government's responsibility to provide the necessary policing and enforcement agencies to protect the public. Frequent travellers should be able to obtain a security clearance that enables them to access a simpler security check at airports. Freight forwarders and their staff should be security cleared to the same level as other airside personnel. Aviation Safety Forum Considers CASA can better relate to stakeholders, Sees merit in the reintroduction of CASA Board. Pace including working relationships across Govt, through of reform can be improved through resourcing by Govt consultation, communication and education leading to or issuing Civil Aviation Orders to implement pending improved safety outcomes enactment of legislation. Aviation Safety Considers ICAO 'Global Aviation Safety Roadmap', Supports introduction of a board for CASA if its Foundation Australasia with an emphasis on SMS, should be the framework composition is balanced between industry experience for Australian regime and supports international and governance skills. Sees merit in a consultative harmonisation and mutual recognition through Bilateral body between the board and industry such as the Aviation Safety Agreements. Aviation Safety Forum. Acknowledges complex role of safety regulator and eductator and sees merit in continuation of measures to foster industry outreach and enforcement such as self-regulation where appropriate, awareness raising and consultation, streamlined regulatory practices and strong enforcement action where warranted. Supports outcomes focussed regulatory approach in partnership with industry and sees the growth in aviation industry as a challenge to be met with a dynamic approach to regulation including mechanisms to promote self regulation by industry where appropriate. Aviation Sunshine Supports ongoing regulatory reform and suggests the Sees a need for international guidelines to monitor and Considers AS 2021 & ANEF to have failed as effective Considers the Dept has failed to consult effectively on strategic Coast Inc process be extended to security report on effectiveness of measures and considers land use planning tools and recommends a better security issues and views the application of measures to regional accreditation of local off-set projects will make model be developed to protect airports and inform aviation and airports as arbitrary. Sees cost imposition of measures more accessible to regional communities. communities including information for prospective measures at regional airports to be disproportionate for no purchasers of noise affected property. tangible security outcome, particularly CBS and airside inspection. Sees security as a Federal responsibility and suggests resumption of responsibility for security or subsidisation of costs. Considers investigation in necessary of network pricing models, standardisation of costing models for mandatory measures and evaluation of charging regime for in relation to future planning and cost recovery from airlines. Suggests threat assessments need to be prepared for each airport and operator to provide the basis for security measures rather than application of 'one size fits all' approach. Mandatory technological solutions need to be considered where risk and cost benefit can be demonstrated by the regulator. Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 14 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ Areas covered in submission: 1 Australian aviation industry 1.1 International services 1.2 Domestic services 1.3 regional & general aviation 1.4 addressing skills needs in aviation industry 2 Aviation infrastructure 2.1 airport planning and development 2.2 air traffic management Individuals' name summary/key words Ban Aircraft Over Airport noise Residential Brisbane Bankstown Airport Bankstown Airport and its role in Bankstown Airport has the potential for direct services to such Passenger operations will generate a range of new Integration of Bankstown (multi-use), Kingsford Smith (high Currently ATM is based on a segmented approach for each airport Limited development of Western Sydney cities as Melbourne, Brisbane and Canberra. Importantly, employment opportunities in maintenance, customer service, quality gateway pax), Camden (light sport and recreational) and in the Sydney basin. Sharing load to Bankstown can better Bankstown Airport can be developed as a hub operation for operations, security, catering and manufacturing. Richmond Airports (defence, freighters). Approval processes manage congestion. services from regional NSW connecting through Bankstown for non - aeronautical development should not be increased. to these major cities. Non aviation complementary developments are essential for maintaining infrastructure, especially GA. Bankstown Airport Out - Airport planning, specifically Believes a second Sydney airport outside of the Basin Believes all privatised airports should pay rates equivalent and Tourism In Bankstown and second Syd airport, necessary and recommends evaluation of site at Goulburn. urban services fees under the 'user pays' principles. Seeks a and security All international traffic should be relocated to the new site cap on movements and 7-7 curfew at Bankstown and its closer with domestic, regional and freight activities consolidated at within a 5-10 year time frame KSA. Bankstown City Council Airport planning, noise, security Bankstown Council supports continuing operation of Fundamental problems with the current airport planning regime Bankstown Airport as a GA facility but opposes any proposal include: to cater for expanded RPT growth for Sydney, outside of ·The continued exemption of commercial development at what is currently approved in the Airport Master Plan airports from state and local planning laws - resulting in developments which may be inconsistent or incompatible with surrounding developments or local growth strategies. · The absence of any developer contributions regime to ensure that Airport Lessee Companies (ALCs), and not the local ratepayers, pay for the enhanced infrastructure costs of their developments. · The inadequate community consultation, lack of transparency and public accountability in the development approval process for developments worth less than $20 million. · The inadequate planning assessment, which fails to consider impacts of airport development on environment, amenity, infrastructure, properties and business in surrounding areas. · Ineffective master planning and development approval process resulting in unrestrained retail development at airports at the expense of future aviation expansion needs. Baulkham Hills Shire Infrastructure, airport planning and Investigations ought to be carried out into providing The MOU with Bankstown Council model used for Bankstown Council development. additional capacity for Sydney by using the Richmond RAAF Airport is an appropriate framework for consultation and Base for small scale commercial operations, similar to planning with local councils. Local, State and Federal transport Williamtown where commercial flights operate without projects need to be linked, planned and integrated so that the compromising military operations. ability of aviation infrastructure to expand is not compromised and, conversely, expansion of aviation infrastructure does not lead to overloading of local infrastructure. Also diversification of airports to retail uses can have detrimental impacts on local centres and early communication is essential. Board of Airline International, infrastructure, safety, Aviation policy should accept that governments cannot Cross subsidisation of regional services by charges on Government has a role to play in assisting in the investment in To deal with the emerging problem of uncontrolled retail The Government should follow ICAO principles and put the BARA generally supports the deployment of ADS-B and GNSS Representatives of air traffic management, climate selectively encourage the development of non-capital international or domestic trunk route services will damage skills for the aviation industry. A nationally coordinated expansion at international terminals, the ACCC's quality of onus on the proponent to demonstrate that a development will technologies, but opposes any cross subsidisation by airlines of the Australia (BARA) change, noise, consumer protection, city gateways contrary to market forces, unless competition, reduce efficiency and become unsustainable if approach to promoting Australia internationally as a centre of service monitoring should give specific consideration to the not adversely interfere with operations, rather than the costs of retaining redundant facilities to support military operations disability standards, compensation, supported by subsidies and incentives. Any such there is a downturn in demand for those services from which excellence for training should be considered, as should relative distribution of terminal areas between retail and Department having to demonstrate that it will. CASA is not or "cross industry" funding to assist the GA industry with the aviation charges, security, border subsidies should be transparent and direct, without the subsidy is extracted. BARA is concerned about the removing barriers to entry to training programs. Taxation and aeronautical operations. freight facilities should also be active enough and the regulations should be strengthened to transition. Also, network pricing should be avoided for ATM control. cross subsidy from other aviation stakeholders. ACCC acceptance of network pricing for ARFFS and the skills training policy need to be complementary so the cost of included in this monitoring. The light handed regulatory policy require it to provide safety advice on all development services. Similarly, making access to major city airports precedent that this could set for the provision of other investment in training is minimised. now in place has sufficiently clear pricing principles to deliver applications. A priority for the NAPS should be procedures for conditional on serving a regional port distorts the services, including navigation services. airport charges that are reasonable. However, a more robust improving planning and coordination of airport development market. approach to price monitoring and reregulation is required. parameters between Commonwealth, State and local The passenger movement charge is an inefficient funding governments. The nomination of a second Sydney airport site mechanism and should be abolished. needs urgent consideration. Options near to Sydney include Newcastle or Richmond and expansion of the existing airport to Kurnell. A greenfield site is another alternative. BARA does not advocate a particular option at this time. Boeing Australia International, skills needs, Boeing support liberalisation and believes Australia The Government should increase funding for universities and National, state and local governments need to consider long Australia has and should continue to be a leader in introducing new Holdings infrastructure and planning, ATM, should grant beyond rights to Asia, the ME and the US. TAFE's for engineering and trade training. term airport capacity growth needs before permitting residential technologies, such as ADS-B and GNSS. Australia should also safety, climate change, security. More competition on these routes will drive increased development close to the airport. continue to focus on global interoperability. trade and investment and further propel economic growth. Briggs Aerospace GA, security, skills, safety, airport Pilot training does not include business training, leading to the There is no pilot shortage, most pilots are finding it hard to get Landing fees have increased. Non aviation property Technologies planning. GA industry being not being quipped to run businesses or a job. Also Australian based airlines still require much more development on airports hampers the growth of aviation. market themselves. flight experience compared to overseas airlines. Pilots are Marketing of aviation at airports is not happening leading to the discriminated against as training is not subsidised. decay of airports and airports being rundown and sold-off for non-aviation purposes. Brisbane Airport Airport planning and infrastructure Key economic driver of employment and Supports competition and liberalisation particularly for Supports current policy Sees maintenance of viable sector as important to insulate Supports current Federal planning regime and seeks nationally Privatisation has directly resulted in significant, private sector Corporation investment, noise management, services hub carriers and emerging markets such as China and capital city airports from aging aircraft and ancillary services consistent standards for statutory planning documents. Looking investment in aviation infrastructure. Airport and off-airport competition and liberalisation, India and automatic 'own stopover' traffic in ASAs. for greater coordination of off-airport land use planning to planning needs to recognise the regional role of airport as security and emissions Urges cautionary approach to liberalisation of cargo strategic infrastructure prevent residential creep and high-rise encroachment on services airspace Burnie Airport Regional and GA, skills, airport The policy should express the economic and social It is becoming increasingly difficult to retain airfield staff at The AWP must recognise that airports are the risk takers of Government needs to give certainty that investment in Corporation planning and development, safety, importance of aviation in regional Australia & also recognise regional airports. Without local airport expertise there can be no the industry and infrastructure investments cannot be moved. infrastructure will be protected and not devalued. emissions and climate change, that there are a number of privately owned/operated airfields RPT services. In the longer term we may need to consider Better enforcement mechanisms needed for airport planning. aircraft noise, aviation security. that receive no financial support from any government and assisted training schemes, such as HECS type schemes or Airport charges are only a small part airline expenses, given the are also provide essential services. Policy should support incentives to remain in rural areas similar to the Rural Doctors huge capital investments required, it could be argued that the these facilities & assist with provision of long term vital Scheme. airports are currently under charging. infrastructure such as runways. A more active and integrated planning approach should be We have a Roads to Recovery Program, why not an Airports taken in regards to airport planning, particularly in terms of road to Recovery Program? Regional airlines are often in a access to airports. dominant or monopoly position when dealing with regional airports. Cairns Airport and International, regional and GA, ATM, Offering beyond rights to international airlines out of While region specific marketing should ultimately be Economic efficiency supports location specific, cost reflective Tourism Tropical North security. regional airports would provide greater impetus for undertaken by regional bodies, to the extent that the Federal pricing. However, equity or regional development considerations Queensland airlines to offer such routes. Triangulation rights with Government seeks to pursue regional development may suggest something more akin to network pricing (or targeted major airports could also increase services at regional objectives in areas that are highly tourism dependent, there is subsidies). If airport charges are not to pose an impediment to airports. If international airlines constrained by their a strong case for Federal Government marketing assistance. regional airports competing with capital city hubs for international allowable capacity into the four major airports could flights, then a model that does not produce significant price augment their limit through a route to a regional airport, differentials between the two is necessary. where capacity to the major airport was increased by the number od services to regional destinations, this would provide an incentive for those airlines to offer services to regional airports. Carriers with an Australian AOC, irrespective of principal place of business or ownership, should be permitted to operate international services at regional airports. Australian society not passengers benefit from the Passenger Movement Charge (PMC) and it is an unwarranted impost on the tourism industry, with a disproportionate impact on regional airports. There is a strong case for Federal funding of the PMC. Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 15 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ 3 Aviation safety 3.1 safety regulation & regulatory reform 4 Customer & community protection - addressing 4.1 aviation emissions and climate change 4.2 aircraft noise 4.3 consumer protection 4.4 disability standards 4.5 compensation arrangements in the event of an 5. Aviation Security Individuals' name impacts of aviation accident Ban Aircraft Over Concerns over community impact of parallel runway at Residential Brisbane Brisbane and recommends a curfew be imposed. Bankstown Airport Better management of ATM and integration of airports The introduction of passenger services at Bankstown Limited will make movements more efficient and reduce would be matched with additional noise management environmental impacts. procedures and wide community consultation concerning off airport impact. Bankstown Airport Out - Considers current airport-managed community Seeks a cap on movements at Bankstown Considers urgent review of security at secondary airports is Tourism In consultation process to be ineffective. required with a view to upgrading measures Bankstown City Council 1. Australia should continue to work through ICAO and 1. The Airports Act 1996 should be amended to An immediate independent security and risk assessment of the with other international aviation stakeholders to ensure require airports, including major secondary and GA Bankstown Airport (and other similar airports) should be implementation of voluntary industry initiatives for airports to: undertaken and appropriate security measures such as fencing, emissions reduction, including advanced technology, (a) Review and remodel ANEF contours every five CCTV surveillance and other appropriate measures should be fuel efficiency, and operational improvements. years. considered, with an ongoing commitment to investment in 2. Once a positive evaluation of the EU ETS for (b) Produce and publish revised ANEF and N60 or security and risk management at the Airport. aviation is available, Australia should consider N70 contours every five years. For secondary airports with considerable forecast growth in replicating it. (c) Develop and make available to public detailed and movements, including passenger movements: 3. As planned by the European Commission, light easy-to-understand information including flight path (a) A series of protocols, under an overall emergency aircraft, military, police, air ambulance, customs, flights maps, and respite charts on current and proposed management framework, need to be established that would on state business, training or testing flights may be flight paths within 30 nautical miles of an airport. provide details as to how the Airport would manage an incident exempted from the emissions trading scheme. 2. The 'endorsement' process for technical accuracy of and allocate roles and responsibilities to various emergency ANEFs undertaken by Airservices Australia be support services to ensure adequate preparedness, response enhanced and made comprehensive to also include a and recovery. check for soundness of assumptions and forecasts (b) The feasibility of establishing an on-site emergency response used by airports for developing these. unit to provide initial response during an incident may be 3. Noise management experience gained at Sydney investigated. Airport through community and council participation and initiatives under its noise abatement and sharing regime called the LTOP (Long Term Operating Plan), which included publishing of detailed flight path maps for the community, provision of 'respite' or break from aircraft noise, noise sharing between suburbs, and rotational use of runways should be considered for use in major secondary or GA airports including Bankstown, where practicable. 4. A curfew (11pm - 6am) which effectively prohibits night time aircraft movements would be Council's preferred option for Bankstown Airport. However, if a curfew is not feasible, a night time movement cap be introduced in major secondary or GA airports like Baulkham Hills Shire Bankstown to protect surrounding communities from Council Board of Airline High priority needs to be given to completion of the Environmental benefit from taxes and charges is very Curfews should be avoided as far as possible and not Any guidelines regarding disability standards must be BARA has endorsed the Government's amendments to Aviation security legislation and regulations require review to Representatives of CASA reform process, with the CASRs to be revised uncertain, reducing the capacity of airlines to invest in be used as a first resource. mode specific to take account of the unique the legislation to bring into law in Australia the provisions remove unnecessarily restrictive interference in airline operations Australia (BARA) where necessary to provide uniformity with other newer, cleaner equipment. What is needed is a circumstances applicable to air transport and must be of the Montreal Convention. BARA believes that the due to security procedures that deliver little if any security benefit. national aviation safety authorities' legislation and properly designed ETS, with equal obligations to other developed in consultation with industry. current family support provisions set out in the ICAO terminology. The ATSB should be completely industries and globally harmonised. Department's Family Support Code represent appropriate separate from other agencies and CASA should not be minimum requirements to be adopted by the airlines. involved in safety investigations. Boeing Australia Australia is world leader in aviation safety. To remain a Boeing recognises that climate change is a serious It is important that a risk management approach that is taken to Holdings leader, CASA would be wise to strengthen its problem and that a global approach needs to be taken. ensure that limited resources are being effectively applied and involvement in ICAO in order to set the future direction Boeing supports mandatory yet flexible frameworks to the commercial aviation industry is in fact truly more secure. in a manner that supports the national regulatory address carbon emissions. ATM improvements framework and thereby the industry as a whole. It is represent the greatest short term opportunity for important that CASA work closely with industry, using significant reductions by streamlining routes and the Global Aviation Safety Roadmap adopted by reducing delays. ICAO. South East Asia would benefit from more Australian participation in developing a strengthened regional safety plan. Briggs Aerospace There is no on-site ARFFS provided at Bankstown ASIC cards are expensive, with no low-income discount and Technologies airport. This is a busy training airport with some RPT time consuming to obtain. services- safety risk. Should reduce CASA‟s responsibility for safety and put more emphasis on pilots self-policing. Endorsement fees set by CASA are too high. Different endorsements are also required for similar aircraft. Recommends that CASA should adopt the US system where one endorsement covers a similar genre of aircraft. There is no institution to police bad flying clubs/schools. Brisbane Airport Need to manage disproportionate taxes and measures Need for improved noise modelling and national Opposes increase to Passenger Movement Charge on Requires more intelligence, risk-based approach to better target Corporation the industry is subjected to with regard to its emissions standards, including curfew, to better inform off-airport grounds it over-recovers actual facilitation and border resources. Air cargo sector requires attention. Does not support planning. Sees ANEF as a tool open to interpretation control services provided which consistently require cross-subsidies to recover security costs. to support incompatible off-airport land use planning. increased resourcing from Govt Burnie Airport The Government needs to clearly outline what CASA's The party that is responsible for and has operational There are flaws in state government planning policies Security measures at major capital airports should not be Corporation role is and then resource them accordingly. control over emissions should account for and report meaning that local governments are not required to necessarily applied at regional airports. Security should be the emissions. Should airports exceed the established implement controls under AS2021 and that residential based on risk, not necessarily whether an aircraft is jet or threshold they will trade in the ETS for credits to meet developments are encroaching to closely to airports. turboprop and we risk assessments include cost-benefit their requirements. Clear and enforceable legislation should be analysis. As security screening at regional airports benefits major implemented to enforce the requirements of the ANEF destination cities, a national ticket levy should be implemented (or its replacement). and paid to screening authorities. Cairns Airport and Airport security is increasingly becoming national security and Tourism Tropical North passengers, while part beneficiaries, are bearing the cost of a Queensland broader national security campaign. Security charges are largely misdirected and, particularly in the light of other cost pressures within the industry, are an undesirable burden on international travellers. Accordingly, there is a strong case for the Federal government to fund mandated security costs. Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 16 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ Areas covered in submission: 1 Australian aviation industry 1.1 International services 1.2 Domestic services 1.3 regional & general aviation 1.4 addressing skills needs in aviation industry 2 Aviation infrastructure 2.1 airport planning and development 2.2 air traffic management Individuals' name summary/key words Cairns Community Disability access Legal Centre Inc Canberra Business Importance of Canberra Airport to Canberra Business Council stresses the critical importance of Council local and national economy. Canberra International Airport (CIA) as a stimulant to continued growth in Canberra and across the Capital Region. It is fundamental to the future development of Canberra as the nation‟s capital and a unique world city. It is also fundamental to the growth of Queanbeyan, which is “joined at the hip” to Canberra in terms of its economy. It is a significant determinant in the economic growth of Yass, Goulburn, Cooma and the region to the coast. Canberra Business Council strongly supports the development of world-class terminal facilities to stimulate developments in the volume and types of passenger and freight traffic. Canberra Business Council urges CIA to continue its high level of co-operation with the airlines to develop the terminal and its approaches as a gateway to the ACT so that it stands out among international terminals around the world as memorable and impressive. Canberra Business Council strongly opposes the institution of a curfew on the Canberra International Airport, which would hamper the full economic growth potential of Canberra and the Capital region, particularly Queanbeyan. Casino Canberra Ltd Canberra Airport - support for airport Supports international services to Canberra Canberra Canberra Council notesin attracting aircraft currently Supports Business Airport's role that freight tourists to and international services Canberra as an important economic benefit. CEAC Inc Noise, international, security, GA, In relation to the above questions CEAC considers that If all the costs are taken into consideration, viz the costs of The majority of airports in Australia are now operated by the CEAC is most concerned about the flight path conflict between environment, safety, ATM international air services should only use major airports Airservices and other Federal Government aviation bodies private sector therefore there is absolutely no valid or logical Essendon Airport and Melbourne Airport. There have been that have the requisite security infrastructure in place that provide services to the industry, then the general aviation reason that these operators are not compelled to pay State numerous incidents where aircraft have attempted to land at and that these airports should have a substantial sector is certainly not paying its way. It is freeloading on Government taxes, such as Land Tax and rates to local Essendon Airport with the pilots thinking that it was Melbourne barrier/ buffer between the airport and surrounding taxpayers and ratepayers. governments. It is not right that airports such as Essendon Airport and vice versa. residential areas. Airports such as Essendon Airport Airport can freeload on others in the community who pay their should not be permitted to have international flight taxes and rates. Government bodies, such as Vicroads, that traffic irrespective of whether it is passenger or freight. own land beside airports should not be permitted to sell such land as „residential land‟ (as it has) but instead this land should be turned into a green buffer between the airport and residential properties. The planning and development process completely fails to ensure that the rights of the local community are protected. It contravenes the principle of natural justice by preventing the usual third party appeal process. In the Master Planning Process, Airports should be compelled to send a letter to every householder within a 2-kilometre radius of the airport. Consultation meetings should properly publicised and held after hours when the majority of people could attend. The planning and development process under the Airports Act in relation to Essendon Airport has been a dismal failure. It does not integrate into the planning objectives of the State Government‟s 2030 Vision or the Moonee Valley Strategic Plan. Relevant State Government and local authorities should be tasked to Central Queensland Supports the continuation of the combination of commercial oversee and approve developments at these sites. Regional Development Remote and emergency air services, and government subsidy for rural and remote air services. Australia Committee infrastructure upgrades and security Governments, as a community service obligation, should at Gladstone and Emerald provide financial assistance to ensure that landing lights are standard equipment at remote aerodromes. Consideration should also be given to assisting remote and local governments to ensure landing strips are fenced for safety purposes. Attention is drawn to the need for substantial infrastructure upgrades to Gladstone and Emerald Airports. Chamber of Commerce Regional, skills shortages, noise, The current regulatory framework in WA which restricts The Federal Government should introduce a HECS-HELP & Industry Western climate change, security competition is not in the public interest, especially in the scheme to help address the costs of pilot accreditation and Australia current climate of fast economic growth. review restrictions imposed by CASA. The airlines should do more to retain trainee pilots that could include paying for training. City of Geraldton- Regional and GA WA regulation of intra-state routes means RPT pax are Greenough forced to subsidise smaller ports. Restrictions are placed on a 2nd Geraldton-Perth RPT provider which do not apply to incumbent providers. Government should have a responsibility to ensure air transport access to remote communities. Remoteness should be based on kms to nearest RPT, distance from capital city, population, road access. Where necessary infrastructure and air services should be Government subsidised. This could be achieved by a ticket levy on all passenger movements. City of Holdfast Bay MDP, noise, Adelaide Airport Incorporation of the assessment if non-aviation related development within state planning regimes to ensure that airport development is better integrated with surrounding communities. Improving the way in which airports consult with local authorities and communities by prescribing a minimum level of information that is to be provided for new development proposals which is consistent with state planning requirements. City of Kingston Airport planning, noise The City of Kingston considers that proper consideration of state and local government strategic planning needs to be integrated into the planning process for federal airports (focus on Moorabbin). The Federal Government needs to be more explicit about where the balance lies between aeronautical and non- aeronautical development ion long term planning. Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 17 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ 3 Aviation safety 3.1 safety regulation & regulatory reform 4 Customer & community protection - addressing 4.1 aviation emissions and climate change 4.2 aircraft noise 4.3 consumer protection 4.4 disability standards 4.5 compensation arrangements in the event of an 5. Aviation Security Individuals' name impacts of aviation accident Cairns Community Evidence through case studies noted in the Flight Legal Centre Inc Closed report supports the contention that air travel has actually been made more difficult for passengers with disabilities. Recommendations: 1 that separate legislation which safeguards the rights of airline passengers with disabilities is enacted. 2 regarding appointment of modal sub-committees should be expanded to not only develop Guidelines under the Transport Standards, but to redraft the Transport Standards itself into a modality based document 3 regarding a national labelling scheme for mobility aids will have no practical effect as the current Transport Standards contain no limits on the type, size or weight of mobility aids that are required to be transported. 4 regarding power of the Human Rights and Equal Opportunity Commission (HREOC‟) to refer cases of breaches of the Transport Standards directly to the Federal Court should be clarified to include power to initiate investigations into suspected breaches. See our further views on this recommendation below. 5 regarding mandatory reporting framework for Commonwealth, State and Territory governments should be expanded to also require air operators and providers to report to the Minister on their compliance with the Transport Standards. 6 regarding Australian Bureau of Statistics collection of data relating to public patronage of public transport by people with disabilities may assist with quantitative data to reflect recommended mandatory reporting. Canberra Business However, it would prove more useful if the questions Council Casino Canberra Ltd CEAC Inc There have been a remarkable number of aircraft Where the Federal Government has a role is, in light of Residents are experiencing an increase in jet aircraft Regional or non-major airports such as Essendon Airport that incidents arising from the flight path conflict between the growing scarcity of fossil fuels and global warming, (large and small) that are replacing light planes. There want to encourage corporate jet aircraft and other passenger Essendon Airport and Melbourne Airport. Aircraft using to make it obligatory, that operators utilise aircraft that has also been a substantial increase in the number of and freight services should have the same level of security and Essendon Airport, particularly older aircraft, should be are fuel-efficient and that less efficient aircraft should helicopters using the airport as their base. Overall this safety measures as those adopted by major airports. Passenger fitted with technology warning the pilots that they are not be allowed to fly. The aviation industry should pay has impacted adversely on the health and general screening requirements should be expanded to cover non-jet straying to close to other aircraft in flight. There is no for the whole impact that it has on the environment. quality of life of local residents. CEAC wants to see the aircraft irrespective of capacity, speed or weight. Security fire and emergency services at this airport, this service This should not be limited to carbon emissions but complete cessation of aviation activities at Essendon systems should encompass all passenger flights whether regular should be reintroduced at EAPL‟s cost whilst the should also include compensation for noise and Airport within 3 years. The „Clayton‟s curfew‟ at or charter. CEAC would like to see the airport operators airport remains in operation. This airport is surrounded amenity impacts on local communities. The charging Essendon Airport only precludes jet aircraft and a contributing more to the total cost of security. by a densely populated residential area, EAPL has system should be of a robust construction ensuring that small number of aircraft exceeding a certain weight. shortened the runways and there is no over-run safety the polluter really pays. The Federal Government and Noisy aircraft (including helicopters) fly in and out 24 area, therefore there is simply nowhere to go for a pilot other governments should encourage the investment in hours day causing significant disturbance to families. A in an emergency situation. Strongly oppose self- and use of alternate low energy modes of transport. strong curfew should be in place which would not administration by parts of the aviation industry, Rail services between capital cities should be permit aircraft movements daily between 10pm to especially the marginal operators in the general upgraded and improved. 7am. Airports such as Essendon Airport that are aviation sector. We also encourage the Federal inappropriately located too close to residential Government to increase the regulatory oversight of properties should be closed. The existing noise aviation operators particularly those that operate from enquiry/complaint services are a toothless tiger and the non-major airports. It is our view that these smaller employees of that service have confirmed this to players are not receiving the scrutiny by safety CEAC representatives. Most people in the community regulators, which we believe to be warranted. are not aware of the service and those that are think it‟s a waste of time lodging a complaint because nothing ever happens. Central Queensland Consideration may be given to increased security, including Regional Development passenger and baggage screening, at Gladstone and Emerald Australia Committee Airports. Chamber of Commerce Airlines should follow the lead of Qantas and reassess To maximise access to overseas markets for Perth The AFP should adopt a risk assessment approach to airport & Industry Western flight paths to improve efficiency, introduce more fuel Airport, improved land planning use will eliminate the security to ease compliance cost burdens on regional airports Australia efficient engines and carry less fuel where practicable. need to introduce curfews. and airlines at low risk. Airport infrastructure should be improved to reduce waiting times. City of Geraldton- The introduction of checked back screening to regional airports Greenough is cost prohibitive. Currently RPT jets have CBS requirements whereas charter and large capacity turbo prop RPT do not have these same requirements. City of Holdfast Bay Through legislation, make it mandatory for new residential development in areas affected by aircraft noise to meet an appropriate noise attenuation standard. Establishing government and airport sponsored community education and funding programs to assist affected communties to implement best practice noise attenuation measures in new and existing residential buildings to reduce the impacts of aircraft noise. City of Kingston Supports greater community consultation in Master Planning process. Doesn‟t see councils as having the resources to regulate noise around airports – it is more properly a role for state and federal governments. Supports creation of an Airports Ombudsman to deal with noise issues around airports. Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 18 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ Areas covered in submission: 1 Australian aviation industry 1.1 International services 1.2 Domestic services 1.3 regional & general aviation 1.4 addressing skills needs in aviation industry 2 Aviation infrastructure 2.1 airport planning and development 2.2 air traffic management Individuals' name summary/key words City of Melville Aircraft noise, specifically at Jandakot City of Salisbury Alternative secondary airport for Recommends Parafield Airport be relocated due to urban Adelaide encroachment and the greater value that could be obtained through alternate land uses of the site. Civil Air ATC shortage; airport planning; ATM; Critical skills shortages affecting ATCs, an ageing workforce Tension of commercial vs aeronautical interests leading to Artificial movement caps in capacity (LTOP) should be removed. noise sharing with around 320 operational controllers within 5 years of safety compromises such as new buildings located close to Supportive of the introduction of ADS-B to reduce delays retirement. ASA must be directed by Government to take runways navigation aids and guidance systems being sited in associated with climbing and descending, but the biggest immediate steps to increase the retention of existing ATC‟s as non optimal positions because of the unavailability of land. Daily impediment for aircraft delays airport infrastructure, not airspace. well as making the entry positions as attractive as possible. Air holding is rapidly trending upwards at Perth, Sydney and Endorses the current plans for amendments to airspace Traffic Control as a profession has been completely devalued Melbourne airports due to a lack of terminal space, or the lack classifications. ATM services in some classes of airspace are ill or by ASA‟s need to be a profit-making organisation. of landing facilities. Airport facilities such as rapid exit taxi-ways, under defined. ATCs and Pilots must be clearly aware of the and improved navigation aids such as CAT-III ILS systems can service that is provided in a particular class of airspace. CAT-III increase aerodrome capacity and reduce holding and ILS systems must be available at remote aerodromes or those diversions. Slot management needs a national system wide often subjected to fog (Melbourne, Canberra, Sydney and Perth). approach. Profit pressures have led to ASA to reduce expenditure for, training resources and technology spending. Civil Air calls on the Government to remove the profit imperative (return to shareholder) from Airservices Australia‟s charter. Cobham Flight CASA Governance, climate change, (Ageing aircraft) There is no specific c action warranted by Operations and ageing aircraft, airport planning , Government to address ageing aircraft. As long as these Services (Australia) noise, security aircraft are properly maintained and oversighted by CASA, safety is not an issue. Coffs Harbour City International, Regional, GA, security, There are opportunities for smaller regional ports to Peak-time access to Sydney airport is a major issue. There Supportive of an integrated planning regime with objective of Council safety, airport planning operate similar international services for niche markets. is pressure from the airport operator to remove the regional protecting and growing aviation infrastructure. Aviation should These opportunities exist mainly within tourism but ringfence. These slots should be made more secure or turbo- not become the poor cousin to retail or commercial niche markets for health, sport and cultural exchange prop aircraft should be excluded from Sydney Airport‟s development at any privatised airport. should not be ignored. If the Government believes movement cap as they generate less noise than jet aircraft. One of the most critical issues for airports is protecting airspace there is merit in having international services into Government could assist regional communities to manage around airports to allow it to function and grow this includes regional Australia the cost of providing customs and and maintain their airports and assist small RPT operators from both man-made and natural incursions. quarantine services needs to be addressed. Cabotage with tax concessions to purchase aircraft to service remote would introduce competitive imbalances into the routes. Airport master plans should have an allocation of domestic air market where Australian carriers would affordable aviation zoned land set aside for GA and require have to compete with airlines enjoying much lower airport management to have strategies to maintain an agreed labour and fuel costs. level of GA activity at airports. Address issue of ageing GA aircraft through tax concessions. Provide business management training for GA operators. Work with industry and airports to encourage GA operators to decentralise to regional Australia where property rentals and the cost of doing business is less. Colonial Airways / Regional, training - assistance & For the industry itself a fuel-rebate scheme must be The industry needs to adopt the same guidelines and support Colonial Ground incentives introduced by government if the cost of Turbine and AVGAS as promulgated for student tertiary assistance. Ideally HECS Training Systems fuel continues to trend and spiral upwards. should be made far more available to participants training for professional qualifications at recognised aviation training institutions. Specific Tax incentives should be introduced to ease the burden of on-going Aircrew qualification and endorsement. Both for the individual and for the Company employing them. Specific Tax incentives should be introduced to ease the burden of on-going Aircrew qualification and endorsement. Both for the individual and for the Company employing them. Skills in this industry naturally lend themselves to be part of the Vocational Framework and as such should be fully supported by government under the AQTF qualification scheme opening up many more avenues of training and qualification for young Australians not just as Aircrew but to cover the many dynamics of this multi-faceted industry. Commercial Pilot subjects could be introduced as VET (Vocational Education and Training) into the school system. Approved Training organisations under the guidance of significant stakeholders should introduce a worlds-best-practice ISO2000+ National Air-Crew Training Program. This could also Committee for International and domestic services. cover RAAF candidates. A national Program with HECS and The Committee advocates extending this liberalisation The Committee acknowledges domestic deregulation has Melbourne trend in Australia‟s international air policy to an open been very successful and although regulation is required to skies environment - fifth freedom and beyond. This ensure operators meet safety standards, airlines, not move will enable airlines to freely transport passengers governments, are best placed to assess the level of demand into and from Australia, particularly airports other than for their services. Sydney. This will lead to lower flight costs and improved availability benefit leading to more tourism visitors, more business tourists and more business events. Curfew4Canberra Inc Noise (Canberra Airport) Deafness Forum of Need for accessiblility for hearing- Australia impaired travellers Department of Domestic, international, regional and Tasmania's future aviation development Tourism Tasmania supports liberalisation of It is vital that Australian aviation policy continues to foster free Increased Federal Government support to underpin the cost It is critically important to identify resource shortages in There should be an integrated approach to planning airport Economic Development GA, skills, airport planning, climate capability will depend on Australia's international markets. If Australian carriers do not and open competition for airlines looking to compete in the of travel to isolated locations is pivotal to the continuation of advance and work with the airline industry and educational infrastructure issues, involving communities, businesses and all & Tourism, Tourism change. Tasmania aviation policy continuing to foster free and support this, their interest may be best protected by a domestic market. such services along with support to the GA sector. The institutions to provide for the long term needs of the industry. levels of government. Approach and departure zones should be open competition in both the domestic and "first right of refusal" to any new route proposed by a Federal Government should consider such measures as tax kept free of inappropriate development. There should be an international markets. foreign carrier. Liberalisation could also include offering concessions for GA operators, accelerated depreciation for equal (level) playing field for on and off airport site non- cabotage to foreign carriers operating to Australia new aircraft and fuel subsidies similar to those for primary aeronautical commercial developments. where such a service is not considered viable by producers. Australian operators. Domestic tourism growth may be aided by allowing cabotage to foreign carriers. Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 19 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ 3 Aviation safety 3.1 safety regulation & regulatory reform 4 Customer & community protection - addressing 4.1 aviation emissions and climate change 4.2 aircraft noise 4.3 consumer protection 4.4 disability standards 4.5 compensation arrangements in the event of an 5. Aviation Security Individuals' name impacts of aviation accident City of Melville Concerned over need to increase aircraft activity due to private airport operator interests and the corresponding impacts on communities. Recommends the 'Fly Neighbourly' policy be more stringently monitored and enforced and noise complaints mechanism be improved. Also considers effective noise attenuation measures required for all single and twin engine aircraft and limiting or prohibiting flight circuit training over residential areas. Suggests noise insulation program as last resort and supports the relocation of Jandakot to a rural site or the transfer of circuit training to a rural location. City of Salisbury Civil Air Civil Air contends that any regulatory reform must LTOP is causing delays resulting in greater emissions Recommends a nation-wide review of noise sharing, include a far greater oversight of Airservices Australia and increased fuel costs to airlines and pax. Curfews curfews and flight paths. Previously, curfews and flight by an independent regulator than that which currently should be reviewed in light of environmental impacts paths have been motivated by political concerns. The exists. as benefits from reducing flight times through „User current LTOP pushes the peak into other hours and Preferred Routes‟ can be lost due to the curfew. spreads movements out over the day; where as if the movement cap was removed then we believe the noise intensity periods would be reduced in length, albeit, with more movements in the peaks. New technology such as Required Navigation Performance should be utilised as a method of „sharing noise‟. Cobham Flight Supports the establishment of a CASA Board. A Board Aviation has traditionally been a leader in improving Balance of development has moved to commercial Current security arrangements do not appear to be risk or threat Operations and structure would allow CASA greater access to fuel efficiency. Cobham believes a cooperative uses rather than aviation uses. Review should focus on based. Introduction of new technology needs to also consider Services (Australia) contemporary and emerging issues affecting the approach with industry is warranted rather than ensuring airports maintain expansion options for cost and threat. aviation industry whilst also facilitating the development arbitrary targets. It may be more productive to focus on aeronautical use. ENTER Ability to limit marginally Does not support special arrangements for frequent travellers. of a closer working relationship with industry. less efficient industries. compliant aircraft should remain national rather than Inconsistency in the delivery of security services. being devolved to local airports. ENTER Planning Delays in background checking for ASICs are unacceptable. should be improved to limit residential development Background checking should be extended to managers/directors near airports which then results in demands for of companies who employ ASIC holders. restrictions on aviation use at the airport. Coffs Harbour City CASA needs to have sufficient resources to continue Security resources concentrated on areas of risk rather than one Council its broader auditing role but also to concentrate on size fits all. Fir eg, ASICs for GA is overkill and may in fact be sectors of industry that need special attention. CASA contributing to a lack of security culture in GA. Complacency in needs to develop a succession plan to replace the this area is our biggest hurdle. The cost to provide security skilled experienced staff that will be leaving the systems and personnel in smaller facilities attracts a far greater organisation over the next 3-5 years. Much of the unit cost than for major centres. It is not realistic to believe that industry works with low margins and high capital small rural ports will have the skills to effectively screen outlays, this is not a good environment for self- passengers should a threat arise – most operators feel it would administration. be better to cancel services should a threat occur. It should make no difference whether the aircraft is jet or turbo-prop, same sized aircraft should be treated in the same way. The decision as to whether charter passenger should be subject to screening like RPT should be based on risk assessment. Consistency of approach right across the nation‟s aviation network is important. Colonial Airways / Colonial Ground Training Systems Committee for Melbourne Curfew4Canberra Inc Using the Canberra Airport as an example, this submission highlights the inadequacies in protecting surrounding communities from the noise impacts of expanded airport operations and the need for curfews to maintain the health and quality of life of nearby residents. In the process the submission also refers to a number of other challenges identified in the issues paper, such as the need for improved community consultation, sharing information on aircraft noise and appropriateness of current airport regulatory regimes. Urges the Federal government to introduce an 11 pm to 6 am curfew at Canberra Airport. Deafness Forum of From the start to the end, the journey must be Australia accessible. The lack of accessibility at an airport can seriously hamper the safety, comfort and enjoyment of a person who is Deaf or hearing impaired who is using air services. Meeting the needs of these passengers is both a personal and corporate responsibility. Deafness Forum strongly suggests that airports, air carriers, associated contractors and relevant government bodies adopt the recommendations outlined above to ensure that travelers who are Deaf or hearing impaired are not discriminated against on the basis of their deafness (33 detailed recommendations on improving accessibility for hearing-impaired included in submission). Department of While supporting efforts to reduce emissions, aviation Economic Development and tourism should not carry an unequal share of & Tourism, Tourism Tasmania achieving these vital reforms. Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 20 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ Areas covered in submission: 1 Australian aviation industry 1.1 International services 1.2 Domestic services 1.3 regional & general aviation 1.4 addressing skills needs in aviation industry 2 Aviation infrastructure 2.1 airport planning and development 2.2 air traffic management Individuals' name summary/key words Department of Skills Labour shortages are common in many areas of the workforce Education, Employment at present. Aircraft maintenance engineers have been added to and Workplace Relations (DEEWR) the MODL list. DEEWR survey of recruitment experiences for pilots in 2007 recommended • Implement transparent workforce planning and clearly communicate future recruitment needs to one another; • Consider alternative retention strategies that offer increased workplace flexibility, in order to attract and retain pilots and encourage retired pilots to stay engaged with the workforce, particularly in flying training; • Improve and market the image of becoming a pilot as a career option by visiting schools, having a presence at career fairs and increasing the number of cadetship and traineeship programs; and • Increase the use of „return of service‟ or bonding arrangements that meet the cost of initial training as a way of reducing the cost barriers for people interested in becoming pilots. Department of Regional and remote services, The primary concern is the inadequacy of existing Families, Housing, community protection and disability infrastructure. There is a lack of suitable airstrips and Community Services standards (inc security) and Indigenous Affairs properly-maintained supporting infrastructure such as roads. (FaHCSIA) Significant investment is required to make even minor improvements. The Remote Aerodrome Safety Program (RASP) is welcome, however, the program is not Indigenous specific, and it does not provide for routine maintenance. Thus, it may perpetuate a service gap. Department of Foreign Aviation industry, international, Aviation is an important export industry for Exchanging reciprocal cabotage could increase Affairs and Trade climate change, aviation security Australia, bringing large numbers of competition on some domestic routes, benefiting (DFAT) overseas visitors to Australia, carrying consumers and businesses. Consideration should be substantial amounts of freight by air and given to allowing foreign airlines to operate between exporting aviation related services, Australia and the US, possibly in exchange for rights to including the provision of technical fly beyond Asia and the ME. Australia should continue assistance and flight training services. to seek the most liberal outcomes possible in negotiating bilateral agreements and should be open to the possibility of joining regionally based multilateral agreements where they will benefit Australia. On negotiating priorities, a liberalised agreement with the EU would result in significant commercial benefits, aviation is a key issue in bilateral relationships with many SE Asian countries, including Singapore, Australia should continue to liberalise agreements with the countries of North Asia and negotiate capacity ahead of demand, Australian aviation policies should continue to encourage and facilitate reform in the Pacific and Australia should seek stronger aviation connections with Latin America through liberalised agreements. Department of International services, skills, Supportive of Govt liberalisation policy. DIAC should Advocates the use of existing immigration mechanisms such as Immigration and passenger facilitation, security and continue to be consulted on all Air Services 457 visa in addressing skills needs of industry. Citizenship (DIAC) biometric technology Agreements and each AsA needs to contain article (s) that mandate airlines requirement to provide passenger detail for Advanced Passenger Processing. Suggests that if this requirement is refused it is grounds to not enter the AsA. Considers Govt consideration of issues concerning new international airports be reflected along with the work of the Passenger Facilitation Taskforce. Dingley Village Airport planning; noise Planning and development mechanisms are not working Community Association effectively - residents groups form to try & get input to issues Inc because of lack of input from govt depts. These are largely ignored by airport lease holders & developers as they have no teeth. Planning controls should be vested in local govt & state govt. Developers build inappropriately to what Council consider appropriate for balance of area/municipality; ignore State legislation (eg green wedge zoning); residents have no say. Off-airport commercial competition issues more effectively handled by Councils if have control over airport development. Disability Discrimination Disability access Legal Service Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 21 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ 3 Aviation safety 3.1 safety regulation & regulatory reform 4 Customer & community protection - addressing 4.1 aviation emissions and climate change 4.2 aircraft noise 4.3 consumer protection 4.4 disability standards 4.5 compensation arrangements in the event of an 5. Aviation Security Individuals' name impacts of aviation accident Department of Education, Employment and Workplace Relations (DEEWR) Department of The government could consider including clauses in Government and industry should review the Disability Security alarms should be both visual and auditory at security Families, Housing, procurement arrangements requiring airlines to make Transport Standards with a view to providing greater checkpoints. Community Services and Indigenous Affairs aircraft available in response to disasters or other accessibility for people with disability. Airport (FaHCSIA) community emergencies. All recognised airports redevelopments and new airport infrastructure should should have contingency plans to deal with disasters or include the use of both new and existing technology to emergencies. The plan should be developed in provide better access to information and services by conjunction with the local communities and people with disability. The current standards are not communicated to all residents on an ongoing basis to adequate to ensure removal of discrimination. ensure all residents are informed and prepared should Disability awareness training should be made a situation arise. compulsory for all air and ground staff, including security staff. Disability organisations or peak bodies should be included in consultations when building development applications are being considered. Guidelines for the carriage of guide dogs should be clear and concise. Transport Standards Review suggests the development of a national scheme to label mobility aids. Upon implementation of this suggestion, prescribed mobility aids should not be classified as baggage by airlines if they comply with the standards. The airline industry should develop Disability Action Plans in consultation with people with disability and disability peak bodies. Operators should review existing restrictions placed on carriage to Department of Foreign Australia has taken the lead in the establishment of the ensure they are consistent with the DDA and Transport With low cost carriers seeking to use secondary airports, the Affairs and Trade APEC Aviation Emissions Task Force and is also Government will need to ensure appropriate security standards (DFAT) active in efforts in ICAO to develop a Program of are maintained both here and abroad to address an expanded Action on international aviation emissions. terrorist risk to planes and passengers. An international best practice approach to aviation security gives us credibility in encouraging other regional and international partners to implement more effective counter terrorism regimes, including in areas beyond aviation. There would be significant foreign policy implications of any lessening of Australia's commitment to the very highest standards of aviation security as well as risk public confidence in the safety of Australia's aviation industry. Department of Security interventions need to be as unobtrusive as possible and Immigration and application of security technology, including biometrics, should Citizenship (DIAC) be consistent at all international airports. Dingley Village Preserve adequate open space on airport land. Resist Address protection of community by constructing new Complaints are not re the number of flights but the Community Association commercial exploitation ie building, golf courses ok - airports away from urban development. Upgrade noise of the flights. Noise suppression of ALL aircraft is Inc factories not. Off airport building height should be existing rural airports; pilot training in rural airports nr a partial solution. Newer planes may be quieter, but regulated by local govt/CASA cooperation to prevent coast for circuits over vacant/ocean areas. Eg at with fleet's >30yo average age, so most are noisy. compromising the safety of flight paths. Cranbourne rather than Moorabbin. Those non-fitted should be restricted to rural or isolated airfields. Performance may be reduced but community benefit of less noise outweighs reduction. Relocate nosier helicopter circuit training. Noise complaints system is not effective. EPA & CASA not interested in aircraft noise complaints. Airservices Australia appears ineffectual - poor at identifying individual flights or assessing height variations, correct runway departures or other regulatory breaches. Need a complaints officer at the airport for immediate action, a hotline for each suburban airport through its operating hours, funded by airport lease holder, pilots and local council. Disability Discrimination Recommendations: that: Legal Service - carers or support persons for passengers with disabilities travel free of charge. This may lead to airlines considering the reasonableness of their independent travel criteria. - eligibility criteria for Independent Travel be standardised across all airlines and created with input from representatives from the disability community who may be best placed to advise airlines on the practicalities of their requirements. - First Aid training to staff is expanded to cover administration of Epi Pens and other common „medications‟ that currently prevent people with illness/disability travelling independently. - space set aside on all aircraft where a person can sit in their own wheelchair, with appropriate safety straps to hold the wheelchair in case of emergency. Similar safety precautions are used on Wheelchair Accessible Taxis. - the role of Travel Agents and the system of internet bookings be standardised in order to prevent failure of notification to the airlines of a person‟s requirements, and to create a mechanism where passengers receive timely confirmation of the arrangements made for them. - passengers needing minor assistance in slicing flight issued food items or moving from their seats to the toilet are specifically advised that flight personnel are available to provide such assistance. - one member of cabin crew is designated to be a disability liaison officer for the duration of the flight. - Staff training is expanded to include providing minor mobility assistance to passengers to and from the toilet Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 22 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ Areas covered in submission: 1 Australian aviation industry 1.1 International services 1.2 Domestic services 1.3 regional & general aviation 1.4 addressing skills needs in aviation industry 2 Aviation infrastructure 2.1 airport planning and development 2.2 air traffic management Individuals' name summary/key words District Council of Aviation industry including regional Industry should be considered as an Considers governments need to share the risk with local Considers tax concessions given aging fleet issues and more Local expertise is necessary to ensure viability of regional National policy requires a recognition that airport Considers Govt should show leadership in penalising State Acknowledges Airservices reputation as 'best practice' provider. Ceduna services, airport planning and economic driver and not in isolation government for infrastructure investment to attract sustainable support for regional and GA is required together with airports and there are some concerns over the drain of skilled development, both aeronautical and non, is essential for Govts for failing to provide necessary transport links to airports. infrastructure, noise, skills, consumer particularly given the spectrum of roles RPT services. quantification of the social and economic significance of personnel to larger airports and the need to rely on a ongoing investment and that such investment, once made, protection and security played by city through to remote airports aviation to regional communities. diminishing pool of consultants for the smaller airports. cannot be moved like an airlines fleet deployment. Airport and air services. investment also requires long periods for amortisation and depreciation. District Council of GA planning; safety; reg reform; The viability of regional air services is affected by high per Regional airports are reliant on specialist consultants to provide State planning controls provide limited protection against Lower Eyre Peninsula security screening; technology passenger costs resulting in communities needing to expert advice and assistance on a range of technical issues - inappropriate development near airports. Consideration needs subsidise airport running costs above what can be collected there is a looming skills shortage in this areas as experts leave to be given to some legislative mechanism to enable an airport in user charges. the industry with low numbers of young people being trained in to have a measure of control over developments that may this area. Government should explore ways to foster and affect the capacity of the airport to operate. There is also the encourage employment and training of new people in issue of unregulated land use, such as tree planting on private specialised airport related disciplines. property which can affect airports. Dubbo City Council Access to Sydney Airport, The NAPS needs to provide a way forward for regional, rural The Federal Government must support and encourage the The Federal Government needs to assist with infrastructure infrastructure funding, security at and remote aviation and the Government needs to increase industry to invest in skill development. The shortage of pilots funding. The Government should introduce a classification regional airports, skills training, E115 its role in supporting and facilitating positive change in the and engineers is stifling growth and the Government should system for airports, based on a hub and spoke principle safety regulation reform. Network industry. Access to Sydney Airport for regional airlines is provide incentives, through the taxation system or grant funding which will support the Government in delivering services to pricing for security charges. essential for meeting the business, recreational, health and for training programs. The Government could assist flying regional communities in a sustainable manner. other needs of rural communities and the slot system should schools in setting up operations in regional airports such as not be diminished. The time and cost of getting to and from Dubbo which would help the industry and have economic spin Bankstown would make air travel totally unviable. offs for local communities. Emirates International services, air traffic Strong advocate for open skies and urges adoption of Very supportive of innovation, such as FlexTracks, and the management, noise, emissions a true open skies policy by Australia with the primary relationship between industry best practice and environmental and objective to provide consumers with a range of airline economic benefits. Of the view that current ATM practices at options, routings, products and competitive fares. Sydney are inflexible and should be subject to ongoing review to enable operational flexibility. Faculty of the Built Airport planning Sees a need for more strategic infrastructure planning Endorses the development of 'airport plans' as sub-regional Environment, University between airports and broader regional development planning documents based on criteria such as a defined radius of New South Wales particularly in light of off-airport impacts of non-aeronautical from the airport and the use of MOUs between airports and developments local authorities. Considers community consultative forums could be formalised or codified to provide more effective mechanisms for information exchange and liasion, cites Bankstown as a good example and suggests SACF in its current form is less than effective. Seeks the establishment of inter-governmental planning committees to comprise members from all jurisdictions to coordinate airport and area planning. Suggests amendments to the Airports Act to strengthen provisions relating to consistency with state and local planning regimes in Master Plans and MDPs and greater consideration of off-airport impacts, include reference to sustainable development. Also suggests the Minister provide reasons for all decisions, give mandatory consideration to off-airport impacts, enhance provisions relating to conditions on approvals and reversal of the deemed approval provision to a deemed rejection. Fairfield City Council Australian aviation industry, Before considering utilising other than New and upgraded land transport systems are required to A greater level of responsibility should be placed on airport infrastructure, airport planning and major airports, the government should ensure passenger movements can be facilitated efficiently. operators to provide more data about operations and the development, noise, climate change, consider future air cargo trends and their potential impact upon development. The regulatory regime safety, disability standards. impact on terminal capacity. The could be improved through publication of data on airport movement of air cargo to regional centres operations, including height restrictions and fly zones. A will require additional infrastructure and an national infrastructure development fund integrated with a assessment of environmental and other regional transport plan would need to be developed, in concert impacts on areas around airport sites and with state, federal and local governments, to ensure the these will need to be considered in transport system to and from the airport is thoroughly consultation with local communities and developed and funded. The airport operator should be made local government. An open cargo policy is accountable for external impacts on the surrounding area. supported. However, the impact of these operations on local communities needs to be assessed Flight Training Group skills The introduction of an industry training levy could create a funding pool to subsidise training costs. The process would be managed by Government with an industry representative. Better promotion of vocational training in schools with students allowed to begin apprenticeships/licence qualifications while still in the school system. Schemes developed to provide structured careers paths with guaranteed outcomes. Cathay and FTA fund majority of pilot training fee and are guaranteed to be fast tracked into Cathay on completion as long as they remain at FTA as an instructor for up to 4yrs. Collective industry awareness advertising plus overseas marketing. Training subsidies, tax incentives or regional benefits and migration assistance should be considered to retain employees in key aviation careers. Better workforce planning, training schools need to have targets commensurate with expected industry growth. Better coordination of defence and civilian training- sharing of flight instructor courses. Forte Airport regional and GA Smaller airports with low or no RPT are unlikely to be Management financial meaning that it is not possible for them to adequately maintain existing, or invest in new aviation infrastructure. Propose that State/Commonwealth Government assistance be available for airports with aviation income below $500,000 and provide significant community benefit. Particular attention needs to be given to reseals and asset preservation. Future Pilot Task Force International policy, regional policy, [In terms of access for foreign airline] The Adequate and affordable air travel is essential to the The skills shortage cannot be resolved by the aviation industry The main General Aviation airports in or near capital cities are The issue here appears to be that AirServices Australia see airport policy, skills, airspace answer must be a resounding NO. If continued viability of many remote and regional centres and if alone. Whilst operators must awaken to the reality of a operated by private companies which in general do not appear themselves as the „managers‟ of air space and air traffic for the management Australia is to have a viable aviation this requires government support that must be forthcoming sustainable and liveable wage, in particular for pilots and to have the interests of the aviation industry at heart. With few sake of management rather than the management of both for the industry Government cannot allow foreign and there must be unified support from all levels of engineers, the government must also awaken to the need for exceptions the aviation operators at these airports are under benefit and safety of ALL users. The management philosophy carriers to „cherry pick‟ the revenue strong government. In many cases the providers involved operate better levels of support with respect to both initial training and continual financial pressure due to increasing charges with little needs to be one which recognises that the needs of ALL users routes/sectors and then expect the local over a number of states and to limit support to local or state the maintenance of those skills. A national rather than or no improvement in services as airport owners‟ drive towards should be met and that no single user group should be operators to compete on those and cover government would not be appropriate. The policy approach randomised state approach to the provision of technical training higher commercial returns through the development of non- disadvantaged by the management of the air space or traffic. A the less revenue rewarding routes/sectors. must be one of support on the basis of need and along with the more focussed employer support is necessary. aviation sites within the airport boundaries. return to a less commercially driven provision of services would be Few countries allow „cabotage‟ and there reasonableness with a whole of government approach – The introduction of some form of FEE-Help for both pilot and In many cases the lack of aviation specialist support and a good first step. are no imperatives for Australia to do so, which may require moving away from de-regulation. engineer training would be a major step forward and one that increasing costs have driven aviation operators either away nor should we encourage or support 7 th need not cost the community in the long term. Provision of FEE- from these airports or worse out of the industry – this is a real freedom rights. Help must be in such a way that both the operator and the detriment to the industry where those leaving have been trainee are protected. Given that all aviation training providers maintenance providers. must be approved by CASA (and are subject to CASA surveillance and audit) the requirement for RTO status is questioned. Industry and government need also to recognize that pilot training is not a one size fits all. Australia is one of a few countries which does not recognise the distinct differences between recreational/private flying training and commercial/professional flying training. A serious approach to Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 23 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ 3 Aviation safety 3.1 safety regulation & regulatory reform 4 Customer & community protection - addressing 4.1 aviation emissions and climate change 4.2 aircraft noise 4.3 consumer protection 4.4 disability standards 4.5 compensation arrangements in the event of an 5. Aviation Security Individuals' name impacts of aviation accident District Council of Considers a standardised method for calculating Sees a need for review of ANEF system citing lack of Of the view there should be no special treatment for Support for current Transport Standards with CASA Considers domestic provisions to be in line with the Considers a national policy should not adopt a 'one size fits all' Ceduna emissions is necessary and that the party responsible currency. aviation as opposed to any other industry. safety standards to take precedence in the event of Montreal Convention and does not see the need for third regulatory regime is an inflexible imposition but rather a foster an for the emission is accountable. conflict. party or additional liability coverage at this time. environment that is flexible to the needs of individual airports. Considers the extension of CBS to regional airports to have occurred with no consultation and no regard for actual threat. Sees a need for an 'exit strategy' for the removal of security measures no longer required and seeks a review of current requirements towards simplifying for the benefit of passengers and industry. District Council of A one size fits all approach is not appropriate-security Lower Eyre Peninsula requirements for regional airports need to be assessed on a location specific risk based approach. The recurrent cost of screening and related terminal upgrades affects regional airport's ability to attract jet RPT services. If passenger or check bag screening is required at regional airports consideration should be given to delivery of the service on some subsidised basis such as an industry wide pricing arrangement. Dubbo City Council There needs to be consistency in what is required to This is the area that probably most affects future growth and be included in an airport Safety Management System operations at Dubbo airport. There is inconsistency with the and proper checking by CASA against that system. A screening requirements between different types of aircraft of consistent approach to regulation is required. The similar size. Dubbo has been denied access to grant funding for regulatory reform process has been long and arduous, the introduction of jet services, while airports with fewer with little progress made from an airport perspective. passengers have received this support. The Wheeler review More resources may be needed to speed up the found Dubbo to be a low risk airport and the Government should process. consider threat levels on a regional as well as a national basis. Emirates Considers Emirates is an industry leading in investing Considers global industry demands 24 hour scheduling in new aircraft and operating practices to minimise and views blanket policies targeting noise without environmental impacts. Encourages Government to consideration of specific aircraft potentially impacts take a holistic and balanced view on environmental competitiveness of some airports. Supportive of the protection measures and the link to the aviation Transparent Noise Information Package and believes it industry. should be the industry standard. Faculty of the Built Environment, University of New South Wales Fairfield City Council Ageing aircraft need to be phased out by requiring CASA should have a complaints mechanism system The establishment of local airport community Underutilisation of capacity is a problem and airlines New systems should be established that place The current exemption from the Disability Transport compliance with fuel consumption standards and that is transparent and enforceable. consultation forums should be reviewed. should be required to offer access to spare capacity to responsibility for reducing aircraft noise on the operator Standards for small aircraft should be discussed with a emission and noise requirements. other carriers or penalties will be imposed. Every effort and not the community. A Flight Tracker System to view to having the exemption removed or amended. should be made to reduce kilometres travelled under monitor noise impacts should be mandatory for maximum capacity. airports within a designated impact zone. The ANEF system should be replaced by a scheme that is more readily understood by the community. Airports should be responsible for managing and enforcing noise requirements and breaches of local conditions. Flight Training Group Forte Airport Management Future Pilot Task Force Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 24 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ Areas covered in submission: 1 Australian aviation industry 1.1 International services 1.2 Domestic services 1.3 regional & general aviation 1.4 addressing skills needs in aviation industry 2 Aviation infrastructure 2.1 airport planning and development 2.2 air traffic management Individuals' name summary/key words Government of South International, domestic, regional & The regional benefits package has been ineffective. It The SA Government supports domestic deregulation and The NAP needs to include policies that recognise that many The SA Government supports extension of FEE_HELP loans Airport lessees should be required to provide detailed plans of The SA Government does not support location specific charging Australia GA, skills taining, airport planning, air should be made clear to foreign governments that allowing foreign owned airlines to operate in Australia, as long remote area air services are not commercially sustainable. to vocational education. proposals as part of the Major Development Plan process. for ATM services. The approval of network charging for ARFFS, traffic management, safety, when their airlines approach the limits of their capacity as they are formed as Australian based subsidiaries. The SA Government believes that the Remote Aerodrome Integration of airport development with funding and construction and the "basin" cross subsidies of terminal navigation charges at emissions, noise, disability, security entitlements at the big four gateways they will be Safety Program provides a model of cooperation across of off-airport road access could be improved. The Airports Act metropolitan GA airports, serve as models for a return to network expected to examine using their existing entitlements at governments on which further service and infrastructure lacks a simple statement in its Objects section to the effect that charging for all ATM services. secondary gateways before being granted additional funding measures could be based, that all other existing the primary purpose of the leased sites is to serve the needs of major gateway capacity. This could be given practical assistance programs should continue and that ways to aircraft operators. Local authorities must recognise the effect by not counting major gateway capacity against reduce the costs of security and safety regulatory reform importance of the application of Airports Regulations in entitlements when it is operated in conjunction with a must be investigated. controlling building heights. Similarly, state and local secondary gateway. Progress in regional dispersal governments must ensure that development around airports is needs to be measured against set targets, say from compatible with aircraft noise. The pricing regulatory framework the current 7 to 10% over two years. should allow low cost carriers to pay lower terminal fees than legacy carriers if they choose a lower level of terminal services. GPSat Systems Aust Air space management Aviation GNSS should be set as a national priority with P/L coordination directed through the Department of Infrastructure and possible funding linked from the National Future Fund. The flow-on benefits are clear for general aviation, broader Australian commerce (communications, agriculture, mining etc.) and ongoing nurturing of local aviation industry for realising the huge future export potential. Dept Infrastructure to implement a national Aviation GNSS Plan. Through the provision of coordinated infrastructure planning, consistent funding (not necessarily only from ASA‟s budget), and broader strategies to grow local aviation technology industries will drive these modernisation enhancements. a.) It is hoped that the new Department of Infrastructure will resurrect the DOTAR‟s policy in some form and then put in place new genuine initiatives to nurture future Australian GNSS industry growth for both aviation and other commercial sectors. b.) To develop these technologies requires coordinated infrastructure planning, proper and consistent funding (not necessarily only from ASA‟s budget), a broader strategy to grow local aviation technology companies and finally a comprehensive export strategy. This is function / responsibility that should be channelled through the Department of Infrastructure. Linking ASA, CASA, and ATSB-Aviation establish two Graham Banks Airport All issues Considers the Govt can do more to further liberalise Largely supports current policy and considers Australian Considers govt partnerships required in order to ensure Considers the current training system to be sufficient but could Considers issues are largely the consequence of historical Concerned that non-aeronautical development, particularly at Generally supportive of Navigation (GNSS) national test and comprehensive Satelliteexisting arrangements but suggests Consultancy services and encourage new airlines to the market domestic airlines should be able to access foreign capital. continued services through the use of incentives if required. be augmented with incentives such as financial assistance, planning decisions in the location and development of city GA airports, is detrimental to ongoing aeronautical activity. adoption of a wide area augmentation system in line with US. including the use of entry incentives and cabotage. All Concerned that privatisation of GA airports has had a scholarships exchange programs and attraction strategies. airports and that no satisfactory resolution to aviation Considers greater integration of planning can occur. E.g. Considers a move to satellite based systems without appropriate international operators should be ICAO and IATA detrimental effect on safety and on aeronautical Does not support a centralised flying school as a duplicate of infrastructure developments and ongoing use and implementation of public safety areas under runway splay into support or 'back up' systems to be a risk and is of the view the compliant with federal regulators to ensure standards. infrastructure and suggests Govt regulate commercial existing system. community impacts unless existing airports are relocated or local planning schemes as buffer zones and fostering funding of Airservices is flawed which results in over reliance on activities to ensure aeronautical interests are protected. new airports built. Supports price regulation of aeronautical compatible development off-airport under planning schemes. cost recovery. services. Griffith University Skills (aviation sector education and Sees no further role for Govt but emphasises need for tertiary training) and Safety education and training as stand-alone qualifications and/or to supplement existing vocational models. Emphasis on tertiary institution involvement with industry on workforce planning and as a source of direct advice to Govt. Guild of Air Pilots and Air services policy focused on GA, Considers a balanced approach necessary between Supports current policy including ownership criteria for Sees adequate and affordable air services as essential for Supports a subsidy for pilot training through FEE-HELP style Recommends the Govt commission a review of future Sees a conflict in private operators' development intentions vs Seeks a less commercially driven regulatory model that is Air Navigators skills, airport planning and tourism interests and the need for competition and domestic airlines wanting to operate international services. ongoing viability of some regional and remote centres and scheme and considers attractive career paths and airport needs on a national basis including a 2nd Syd airport aeronautical investment. Considers off airport planning should consistent with international models and considers the needs of all infrastructure, air traffic sees emerging markets, such as China and India, as considers Govt support should be available on a 'whole of remuneration to be key issues. Supports a national flying and that price and service quality monitoring occur at all be the function of a single state body with correct geographic airspace users in management of airspace through improved amangement, safety and security growth areas. Does not support cabotage or trading of govt' basis similar to road funding. Considers the school concept and sees it funded through an industry levy or airports. placement of future airports and limits on surrounding systems and consultation with industry. Supports the 7th freedoms and considers the regional package an privatisation of local aerodromes to have been detrimental to by Govt (similar to Maritime College in Tas). Considers residential developments a key issue. implementation of ADS-B. unreasonable incentive to attract services to secondary the GA sector and that Govt policy should guarantee retention of aging workforce an issue and emphasises airports. minimum infrastructure standards, access and cap charges helicopter pilot skills in addition to fixed wing. for GA sector and monitor airport operators for economic fairness in their GA dealings. Supports tax incentives and short term loans to rectify ageing aircraft fleet. Harris Miller Miller & Noise Hanson Inc. Hornsby Shire Council aviation and climate change, aircraft noise, use of private helicopters Hotel Motel & Competition in aviation services and HMAA believes that in a globalised economy, and HMAA believes that the Government should work with Accommodation its impact on the tourism industry, when dealing with the world‟s most genuinely global airlines and the industry to build an operational and regulatory Association international airport access and industries (travel and tourism), a fully global policy climate which encourages better (and cheaper) services to services, global warming. approach is now appropriate. Thus, HMAA urges regional destinations. This will bring significant benefit not just consideration of the implementation of a full “open to tourism, but to rural and regional communities more skies” approach for Australia‟s international and broadly. An issue which should be addressed as part of this domestic aviation markets (subject to the continued approach is the current (local government focused) application of the highest of safety standards). Clearly, ownership structure of regional airports, and whether this is such an approach should be matched with the removal the most appropriate model for the future. of any remaining ownership restrictions on Australian based airlines. Policy which encourages growth to multiple airports, supports additional airport capacity within the Sydney Basin, government services, particularly quarantine must be provided at all international airports. Hume City Council International, airport planning, skills, Maintaining and improving direct flights with countries Many organisations have begun to explore the option of The preparation and implementation of Airport Master Plans noise. throughout Asia and the Middle East will help improve „adopting a school‟ to highlight aviation careers. should be subject to the same process involved in the planning Australia‟s access to the Halal food market. It is of non-airport land. The current provisions of the Airports Act important that capital city airports be maintained for related to the preparation and approval of master plans and use by larger airlines whole smaller commuter aircraft major development plans are inadequate. A review of the be located at secondary or regional airports. The master plan consultation and approval process is required to capacity of major gateway airports to act as high level establish an independent review of the master plans and intermodal freight hubs is yet to be fully realised. The submissions leading to their approval. The integration of airport aggregation of logistics in these hubs can realise a planning and development with the prevailing planning system number of efficiencies, particularly in the areas of would facilitate the assessment of the economic impact of non customs and quarantine. There is a primary role for aeronautical development on surrounding areas. The „mainport‟ Government in funding key pieces of infrastructure that or Airport City concept is becoming widespread and it is clear allow greater access to the key airport node and allow that the trend is for airports to develop not only as key transport a greater flow if freight and transport to and from the interchanges involving the transfer of people and freight airport. The provision of quality of public transport between different modes of transport but also as allows airports to behave as alternate CBDs. complementary centres of activity that support existing city Businesses should be clustered around key aviation centres rather than compete with them. There is a need to centres with key component suppliers, manufacturers, provide free or reduced fee parking at airports to facilitate training institutions and maintenance facilities passenger pick up. encouraged to locate around airports. Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 25 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ 3 Aviation safety 3.1 safety regulation & regulatory reform 4 Customer & community protection - addressing 4.1 aviation emissions and climate change 4.2 aircraft noise 4.3 consumer protection 4.4 disability standards 4.5 compensation arrangements in the event of an 5. Aviation Security Individuals' name impacts of aviation accident Government of South By and large the SA Government has supported the The SA Government supports an ETS that includes The lack of clarity in the Disability Standards is causing The level of security and the measures to provide it at Australian Australia regulatory reform process and its outcome based domestic aviation. International aviation should be uncertainty and the need for recourse to the legal airports should be based on the proper and comprehensive approach. excluded at this stage, with a watching brief on what system and needs to be addressed. assessment of risk. The SA Government is satisfied with the happens in other jurisdictions. current risk assessment process, but remains concerned about the disparity between security levels at regional airports and the major airports to which they are connected. If required, upgrading security at regional airports would be beyond the means of the airlines and airport operators and alternative sources of funding would need to be identified. GPSat Systems Aust P/L Graham Banks Airport Concerned that amending operational standard below Sees ambiguity and confusion in the roles of CASA Sees R&D and appropriate govt investment and Does not support curfews as they force the airport to Considers consumers are adequately protected under Sees areas for improvement in access to facilities by Supportive of existing arrangements but suggests Generally supportive of existing measures noting that no security Consultancy the ICAO standard for major airports to accommodate and ATSB and suggests clear delineation of incentives as necessary to address these issues. operate below efficiency and considers mutually existing arrangements with service levels and standard people with a disability such as boarding and consumers be offered the option to purchase insurance is fail safe. Supports the use of new technologies to improve A380 aircraft has resulted in a lower safety outcome. responsibilities is required so only one body is satisfactory outcomes are not possible for existing conditions of carriage well documented by airlines. disembarkation. Considers complaints mechanism to for a specified 'pay out' in the event of an accident to security measures including screening and biometric and responsible for safety. Considers safety standards are residents as whatever measures are likely to benefit be effective. transfer the risk from the airline to the passenger. considers security outcomes should not be compromised under often compromised due to commercial interests. the community will impact the airports operations. any circumstances. Sees off-airport planning and regulating residential encroachment as an option along with airport relocation in order to resolve issues. Griffith University Sees enhanced aviation safety standards arising from evidenced based research in SMS and collaboration between tertiary institutions and Govt researchers like CASA and ATSB. Guild of Air Pilots and Sees a need for greater education and consultation Considers a 'top down' approach to a safety culture is Improvements in air traffic control and pilot practice Generally supportive of current measures, including legislation Air Navigators with GA sector, in particular on safety management necessary for both industry and Govt agencies with together with incentives for 'best practice' and enforcement, and 'user-pays' principles but sees a need to systems. safety mandate. Supports greater self administration re-assess risk and measures in place at regional airports. Also for industry where appropriate following independent considers Govt spending could be better targeted at gaps in the enquiry into applications in consultation with industry. system such as non-primary airports and that measures should be applicable to non-jet aircraft that share a jet RPT profile. Considers the need for ASIC by low end aviation sector to be excessive. Harris Miller Miller & Suggests noise management should be based on Hanson Inc. empirical data that quantifies actual affect of noise on communities rather than more general measures to inform decisions on which techniques to employ such as sound insulation and night time operations scheduling and runway use. Hornsby Shire Council Aviation industry should play its part in reducing ANEF model for measurement of aircraft noise is greenhouse gas emissions including offsets, limited. ANEFs should be used for planning but technological improvements and policy measures such complemented with a Person-Events Index more as carbon taxes. appropriate for measuring impacts on residents. Civil aviation laws should be reviewed to prevent use of helicopters for private transport from houses. Hotel Motel & A “green Australia” will increasingly be a desirable Accommodation destination in a global warming sensitive world, but a Association green Australia will not be achieved by the tourism or aviation industry and its constituent businesses alone, but with significant partnerships with governments and consumers. Hume City Council Considers ANEF in combination with AS2021 works well as the basis for the development planning tools to control development around airports. Also some benefit in reviewing AS2021 to bring the standard in line with the contemporary land use planning descriptors. The Melbourne Airport Environs Strategy Plan suggested that street directories or similar could be used to widely identify noise affected areas and encourage people to make further enquiries. There is considerable scope for airport and community partnerships to be developed to better manage noise and other impacts of airport operations. There is a lack of mechanisms to ensure compliance with current noise abatement procedures. Melbourne airport is strategically placed to remain curfew free. Airports in conjunction with the Commonwealth could assist by regulating the types of aircraft that use the airport at night and mandating the phasing out of older aircraft. It is not appropriate that surrounding communities experience older noisier aircraft at night. The noise enquiry services need to be better resourced to match noise complaints to specific aircraft to provide more detailed responses to noise complaints and to analyse the date collected to improve noise abatement procedures and their enforcement. Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 26 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ Areas covered in submission: 1 Australian aviation industry 1.1 International services 1.2 Domestic services 1.3 regional & general aviation 1.4 addressing skills needs in aviation industry 2 Aviation infrastructure 2.1 airport planning and development 2.2 air traffic management Individuals' name summary/key words Hunter Economic Infrstructure, airport planning and The relationship between the RAAF and civil aviation is Closer liaison with local council must ensure residential Development development (Williamtown). critical to the continued viability and growth of Williamtown development areas do not encroach into unsuitable areas Corporation airport. A more robust agreement on the use of the RAAF which may inhibit future expansion of military and civil base for civil operations may be necessary to accommodate operations. growth in both domestic and limited international operations. Williamtown defence and civil operations contribute to the diversity of the Hunter economy and growth in both should be promoted. Williamtown is in a unique position to relieve some pressure on Sydney by acting as a regional airport. Restrictions on civil aircraft movements and shortening of the runway during military operations causes delays and reductions in civil services. Hunter Land Pty Ltd airport planning and infrastructure Compatible off-airport development being undertaken at Williamtown. Subsequent infrastructure investment will see Newcastle Airport placed to mitigate congestion and capacity constraints at Sydney and also play a role in the national air freight network. Industry Funds Competition, airport planning, Very supportive of deregulation which has improved Supports current policy settings which promote competition in Management Pty Ltd environmental competition in the Australian airline industry, fostered growth the Australian aviation market. Policy settings facilitate and facilitated investment. investment from organisations such as Industry Funds Management, which invests for a number of superannuation funds. Airports enjoy strong market positions in major capital cities but market power is reversed in other cities where airlines‟ decisions whether or not to fly routes are determining factors. International Air International & domestic services, Seeking greater commercial freedom for Not supportive of price monitoring regime which does not Transport Association infrastructure and air transport, free of restrictions currently curb market power of airport monopolies and does not environmental/community protection over and above any other industry whose provide adequate pricing guidelines or appeal processes. goods and services are traded across borders. James Cook University Safety/regulatory - bat strikes QLD Jandakot Airport Airport privatisation and planning Considers cooperation between airports and local planning Supportive of planning requirements under Federal jurisdiction Holdings (Pty) Ltd authorities to have improved since privatisation along with but considers simplification of current planning and community consultation. development would benefit the industry. Liquor Hospitality and Security Miscellaneous Union Local Government Regional aviation services, Sustainable services vital to ongoing viability of communities Sees a need for improved training facilities and financial Opposes the development of a second Sydney airport within Acknowledges airports economic significance and Federal Association of NSW airports/aerodromes and equitable access and access for professionals, services etc. Considers route assistance to address the pilot shortage. the Sydney basin due to adverse impacts on residents and jurisdiction but does not consider this sufficient to justify and Shires Association of regional services to Sydney Airport, of NSW second Sydney Airport, airport licensing to be adequate but sees a need for a policy environment. Supports investigation of alternative site development outside of transparent and robust planning development, noise, security and skills response by both Federal and State govt to ensure continued options, in consultation with State and local govt, outside of processes that take account of broader impacts, particularly services are provided on an equitable and comparable basis the basin. Seeks a consistent approach to airport charging non-aeronautical development. Recommends a clearly defined with metropolitan services. State govt needs to ensure on- at regional airports including the possibly of govt subsidies to mechanism for consultation with State and local govt on airport going viability of routes where it intervenes. Seeks a share the taxation burden across communities. development and believes local govt should have a role in guarantee that regional airline access to Sydney airport, inc planning and developing an integrated approach to terminal facilities, will be maintained and does not see any development including airports. Suggests the Minister be viable alternative to the continued use of Sydney by required to consult with local govt and take account of population of regional and rural NSW. developments on other infrastructure and communities and that consideration be given to charging commercial developments on airports the equivalent of rates or developer contributions. Local Government ALOP and other regional airport Many local airports are not financially viable. The Airport planners must build stronger relationships with local and Association of needs, security, planning at airports, Commonwealth needs to recognise that it has a key role in state planning and infrastructure authorities, through regular Queensland including development around supporting local government to keep these airports open and meetings and more transparent sharing of information. The airports, safety documents relating to adequately maintained. The LGAQ would welcome the problems are often in the interpretation or implementation of airports opportunity to work with both spheres of government to the existing regulatory regime rather than the regime itself. develop policy options to maintain the sustainability of this Relationships with local communities need to be well resourced vital infrastructure. and ongoing. Communities will reject tokenistic approaches or approaches that just seek to achieve regulatory tick-off. The Government policy needs address the significant differences Port of Brisbane is an example of a similar master planned between small remote airports and the larger regional area for which the Port of Brisbane Authority engages in a well airports. Most small airports are run primarily as a resourced and continuous engagement with the community. Community Service Obligation and require considerable ongoing financial support to just maintain essential services. Queensland has had a State Planning Policy (SPP) on Whereas many of the larger regional airports are able to development in the vicinity of airports since 1992. The current maintain essential services through landing charges but could SPP 1/02 came into effect in 2002. The SPP has provided a have the potential to expand their services if they were to long running coherent policy that has been included in local receive additional support from government. government planning schemes and development assessment to ensure the safeguarding of airport infrastructure in Queensland. It is a good model to be considered or adopted in other jurisdictions. Mackay Ports Authority Aviation Safety with better air traffic 1. Local Government Councils and their airports should enter The work being carried out by Airservices Australia with ADS-B management, recognition of the negative into a memorandum of understanding, recognising that airports (Automatic Dependence Surveillance – Broadcast) and GRAS effects on domestic air travel caused by the higher airfares due to fuel outside the Airports Act need to be able to develop non- (Ground Based Regional Augmentations Systems) should be surcharges, high exchange rate of AUD, aeronautical revenue in order to remain competitive. That continued to be supported by Government and industry to improve higher interest rates, petrol and grocery airports also acknowledge any affect on airport developments safety and reduce carbon emissions. Mackay Ports has prices, Network pricing of Airservices will have on Council infrastructure and the need to work with the participated in the test bed for GRAS and made a commitment of charges, Network charging of passenger local planning authorities and where appropriate make a fair $75,000 to assist in funding ground installations. Supports a pure and checked bag screening costs, Recognition of the need for increased contribution. network price for terminal services. non-aeronautical revenue for regional 2. A national policy on developments in the vicinity of airports airports in order to contain airport charges should be introduced along similar lines to SPP 01/02 or at to the airlines, Recognition of the need for least guidelines are available for National and State planning a National Planning Policy for authorities and airports and reference material made available developments in the vicinity of airports, The need for a carbon trading scheme for airports to assess their public safety area risk contours. rather than a carbon tax . Marrickville Council Sydney Airport, security vs airport Advocates development of an alternative airport for Sydney Planning issues: obstacle limitation surface limits apartment access and a reduction of impacts in the interim through capacity building heights. NSW govt requirement that industrial land caps on Sydney Airport, curfew extension /enforcement and cannot be rezoned for residential. Wants firm commitment for widening of noise insulation subsidies. Is opposed to further alt airport site/investigation. Consultation: support improved airport privatisation and does not support renewal of SACL's dialogue between Sydney airport and councils. Need to limit lease. major expansion of commercial floor space at airports. Council reaffirms its commitment to State and local planning controls over airport land. Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 27 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ 3 Aviation safety 3.1 safety regulation & regulatory reform 4 Customer & community protection - addressing 4.1 aviation emissions and climate change 4.2 aircraft noise 4.3 consumer protection 4.4 disability standards 4.5 compensation arrangements in the event of an 5. Aviation Security Individuals' name impacts of aviation accident Hunter Economic Development Corporation Hunter Land Pty Ltd Industry Funds Treatment of airlines and airports should be separated Management Pty Ltd under an emissions management regime. International Air Considers aviation industry already undertaking Transport Association significant initiatives to reduce emissions. James Cook University Risk of wildlife strikes, particularly from bats is not QLD appropriately managed. Recommendations: - A federally funded and regulated system for the identification of wildlife strikes from animal remains be created - The support of research projects by ATSB be reinstated - That a national strategy for „bat strike‟ be created - That support for collaborative groups continue - Development of a proforma management strategy for bats, to assist implementation of appropriate risk avoidance strategies at airports suffering from bat strikes. Jandakot Airport Holdings (Pty) Ltd Liquor Hospitality and Wants to see screening of all pax on all services based on Miscellaneous Union perceived risk. Looking for emphasis on improved training, remuneration and technical equipment for screening. Supports 'express lane' concept for pax facilitation, further training for dealing with special needs pax and background checks for employers of aviation security personnel. Local Government Seeks assurance that affected communities are Considers security to be a Federal responsibility along with the Association of NSW consulted on noise and environmental issues and cost. and Shires Association of NSW endorses SACF as a forum for ongoing consultation. Local Government A number of regional airport operators expressed their The level of security and safety measures appropriate for small Association of satisfaction in their relationship with CASA citing that airports should be significantly less complex than for major Queensland their approach has always been practical and the airports. safety management systems are appropriate and did not see the need for a review. A remote airport Security screening at regional and remote airports is very operator had a different perspective and suggested expensive and a part-time role which councils find difficult to that: resource efficiently. Any increase in security requirements for “For isolated and remote communities the Safety airports must be fully funded and that a provision be made for Management System could be enhanced by ensuring ongoing maintenance funding. The Australian Government that documents are reader friendly and that on site needs to recognise and value the crucial role of regional and assistance is made available from professionals for remote airports and recognise that for the majority of these they training etc.” do not have the volume of traffic to make them sustainable in the long term and therefore require ongoing financial assistance. Mackay Ports Authority The need for a carbon trading or offset scheme rather 1. The Commonwealth Government should fund the cost of than a carbon tax that would further suppress travel passenger screening and checked bag screening, whilst leaving demand and strength of the national economy. A the operation of those services with the airlines and airports carbon trading or offset scheme is a more effective rather than form a new Homeland security department. way to actually physically reduce emissions. 2. If the Government is not prepared to fund these costs then the introduction of a network per passenger or MTOW charge similar to Enroute charges by Airservices Australia. The information for charging purposes is already available through BTRE – Aviation Statistics or Avcharges. Marrickville Council Continued legislative certainty for distribution of noise Improved security should not occur at the expense of walking impacts. Expansion of noise insulation subsidy zone and cycling access to, through and around airports. funded by re-intro of noise levy. Improving info on noise complaints, by local government area & publishing of complaints. Need to modernise aircraft fleet to reduce noise impacts. Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 28 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ Areas covered in submission: 1 Australian aviation industry 1.1 International services 1.2 Domestic services 1.3 regional & general aviation 1.4 addressing skills needs in aviation industry 2 Aviation infrastructure 2.1 airport planning and development 2.2 air traffic management Individuals' name summary/key words Mission Aviation Regulatory reform, ageing aircraft, The RASS scheme should be reviewed in light of the Fellowship remote air services proposed CASR Part 135 removing the RPT/charter distinction. The direct capital funding of an air service may be necessary in special circumstances. The certification process for new aircraft needs to be expedited. Urgent implementation of CSR Part 135 will allow a more feasible business model for remote air services, removing the distinction between charter and RPT services. Market forces will eventually prevail on the issue of aircraft renewal. Financial institutions have all sorts of creative ways of funding new aircraft, these things are not out of reach of most operators. A sensible business case can be made to justify new aircraft with only minimal equity, for the vast majority of operators in Australia. Moorabbin Airport Noise and airport consultative and Reclamation of golf course for development without adequate Sees transponders as mandatory to improve efficiency in flight Residents Association planning frameworks at Moorabbin compensation to community for loss of amenity. planning and reduce time over aerodrome. (MARA) Moree Plains Shire Regional & GA; Skills, aiport There should be a Government contribution towards regional Government should consider regional scholarships to attract Government should fund airports as it does roads. Need to tighten up call signs when approaching runways. Maybe Council planning, ATM, consumer airport infrastructure. skilled workers to regional areas. Recommends establishment of a community airport focus implement e-tags for aircraft. standards, security Safety and safety measures implemented at major airports Federal Government should support training endeavours by group. are not affordable for regional services. Security measures local aero club OLS and zones should be included in local environment plans are inconsistent. The Australian Government needs to identify nationally for future developments. No role for local government in renew ageing aircraft. CASA significant skills and support essential skills shortages with Need to ensure adequate land available for future development should ensure strict adherence to maintenance standards. appropriate policies and incentives. More cost efficient to have of airport. flying schools located in regional areas. Strategic planning needs to be longer term. Moree wants continued access to Sydney – not Williamtown. Not enough transparency in airport pricing. Newcastle Airport Airport planning, international NZ should be treated as domestic through reduced, A deregulated aviation market as the best model for the Govt needs to incentivise capital investment in regional Consideration should be given to industry development for Newcastle faces convoluted procedures in seeking planning ATC & ARFF are currently provided by RAAF Williamtown. Limited services, passenger facilitation, customs, immigration and quarantine (CIQ) delivery of air services. A continued move into privatised airlines through appropriate fiscal policy plus government airport management skills based training and also ATC. and development approval owing to meeting federal state, local regional, skills, safety/regulatory, requirements. A lack of funding of border agencies and airports allowing market driven response to growth is investment in airport infrastructure for secondary airports and government and Defence requirement. Believes there is a clear noise, security CIQ infrastructure inhibits growth for regions, including supported. connector transport infrastructure (roads, rail). need to clarify development controls at both the local cargo. New international airlines should be encouraged government and federal levels. Also that responsibility for particularly where point to point services are transport infrastructure to airports needs to be clarified. Market sustainable outside of capital city markets, particularly forces should be a key driver of pricing at airports given their focusing on the emerging markets of India and China. inherent differences but the principal of a dual till approach Newcastle want a 2 daily international flights using the should continue to be supported. same aircraft as domestic and believe it would not affect defence activities. Northern Territory International air services policy, It is recommended that the Australian Government: Recognising both that NT Airports has acted responsibly and 11. re-instate the national uniform system for all Air Services Airports Pty Ltd 1. Introduce a New Regional Access Package with the the countervailing power of the airlines, continue to exclude Australia charges; and following elements:• existing foreign carrier Darwin International Airport and Alice Springs Airport from price 12. retain the existing charging system in the event a national concessions retained;• any Australian domestic carrier, monitoring. uniform system of charges is unacceptable; and regardless of ownership, could operate limited 13. not move to location specific Air Services Australia charges. international services under the following conditions: Make amendments to the Airports Act 1996 that enable airport- gateways must be outside Sydney, Melbourne, lessee companies to voluntarily opt to have non-aeronautical Brisbane and Perth; sector length up to 2,500 nautical land subject to the local planning regime in exchange for miles; narrow body (single aisle) aircraft must be used; gaining freehold tenure over that same land. and capacity under the relevant Bilateral International Air Services Agreement would be allocated in Adopt the Ultimate Capacity ANEF, or at least a long range 40 accordance with normal International Air Services year ANEF, as the ANEF planning tool; 6. incorporate Commission procedures; and Department of Defence military aircraft noise forecasts into the 2. adopt a policy whereby the Passenger Movement Darwin ANEF as per the Joint User Deed; and 7. investigate Charge is the only charge levied on charters to non- the use of High Noise Corridors as a planning tool to prevent designated gateways for barrier agency services. noise sensitive land uses near airports. Northern Territory Regional/domestic/international In general, the NT supports a continued move towards Deregulation of the domestic market has benefited There is market failure in regional aviation that requires This question of equity is becoming more significant as DIA There are opportunities to better integrate civil and military Department of Planning aviation, security, passenger more liberalised arrangements in bilateral air service consumers and increased competition. The continuation of government intervention. moves away from land uses supporting aviation towards other resources and infrastructure at joint user airports like Darwin & Infrastructure facilitation, Airport planning, noise, agreements where it is in the national interest. This will the existing policy approach is supported. . Seed funding should be considered to help develop a commercial land uses in competition with existing commercial where over 80% of traffic is civil aviation operations. consumer protection increase tourism and trade and see market suitable replacement aircraft for the 9 – 19 seat market. development on Territory land; noting that DIA‟s non- developments that benefit the nation. Consideration may need to be given to some contingency . There is a need to pursue a cooperative approach among aeronautical development programme is absolutely dependant Air Services‟ charging regime is of particular importance at planning for dramatic shocks to the industry which would governments to supporting regional air services on urban infrastructure and services provided by state and local regional airports which are characterised by a relatively low A review of the Regional Package is required with due threaten the Australian economy. Emergency measures to . Consideration could be given to an indigenous RASS governments, but is not subject to the associated fees, rates number of users. The NT calls for a network charging approach weight given to regional development and equity maintain air services may involve cabotage or 7th freedoms. scheme run from the Aviation Division of the Department of and charges. across Australia. At worst, the existing Airport Rescue and Fire arguments. Infrastructure. There is also opportunity for Airport land to form part of the Fighting hybrid network model should be retained and extended to . There may be scope for governments to better coordinate future expansion of urban land uses south of Alice Springs, and approach and terminal navigation charging at regional airports. NT supports an open cargo policy for dedicated cargo travel demand to support more regular air services. it follows that land use planning by the Territory should have full The enroute subsidy is important and should continue with ongoing services. regard for the potential of Commonwealth airport land. consideration of special charging arrangements for aircraft A Memorandum of Understanding could ensure that land use operations of less than 5.7 tonne. NT does NOT support limiting international operations, planning for Territory airports is integrated into land use including charters, to defined international airports. planning for the NT. If, in the interests of public safety and future flexibility for The NT calls for consistent customer service to be commercial and military aviation, the Commonwealth considers benchmarked across all international airport facilities development under approach splays to be undesirable then its and border controls to improve passengers‟ arrival and regulatory framework should reflect this. departure experience. The rationalisation of the civilian and military OLSs into one airspace control plan that the NT Planning Scheme could reference would provide greater transparency to developers of land in the vicinity of the airport, and provide more certain protection for the joint user airspace. NSW Business Airport infrastructure and regional Considers growth in regional passengers numbers should Sees a need for infrastructure investment to support the Sees a need for provision of improved transport links and Chamber services equate to investment in infrastructure opening of new markets and develop links between cities facilities at regional airports and regional areas NSW Disability Consumer protection and disability Discrimination Legal standards Centre Inc NSW State Government All issues Supports the development of additional bilateral The efficient use of KSA needs to be balanced with the Information about career pathways and availability of aviation The current land use planning and development approval agreements along the lines of the recent Open Skies interest of regional airline passengers (continued access to VET could be improved by a school and VET aviation strategy mechanisms at major airports are not working effectively with agreement with the US. It should be reviewed whether KSA). ACCC oversight of pricing of aeronautical services to and a communication strategy targeting students and mid regard to either aviation-related development or non-aviation there is a net public benefit from continuing to place regional airline services should continue. Review of CASA career people looking to retrain. The establishment of a virtual development. Airport land transport infrastructure is struggling restrictions on the ownership of Australian-based charges and possible adjustment of the Enroute Charges training school that is a cooperative between universities, to manage the passenger task. Master plans have focused on international airlines. ASAs should provide for the Rebate scheme or other subsidies need to be considered TAFE, the private sector, industry and Governments. The future developments within the airport boundaries and assumed application of transparent, rigorous and accountable where the economic viability of services is challenged. The aviation industry could benefit from a HECS/FEE-HELP style that State Government and others will ensure the land transport safety and maintenance standards. Consideration threshold for eligibility of remote aerodromes for the Remote assistance in occupations where there are identified skill infrastructure is adequate to the task. Dealing with these should be given to allowing foreign airlines to access Air Service Subsidy needs to be reviewed to widen its shortages. Proposal for COAG to consider a system that will impacts will require a collaborative approach between airport the Australian domestic market provided that coverage and the terms of its application. The allow individuals to gain qualifications from organisations other operators, Local and State Government. Consideration should Australian airlines are granted foreign access, and that Commonwealth Government should consider funding the than universities and then repay that debt through the income be given to formal mechanism to ensure that planning for foreign carriers are subject to Australia‟s safety and provision and maintenance of minor airports and aircraft tax system, where there is an identified skill shortage. growth in aviation transport at KSA does not constrain future regulatory regime. The same principle of access maintenance facilities and if market failure is substantiated in Government could encourage companies to expand and growth of sea transport at Port Botany and vice versa. it is should be applied to granting international airlines GA take into consideration the consequences of that market increase flexibility and accessibility of cadetships; Government proposed that all airport non-aviation development should be access to domestic aviation markets. Supports the failure. funded/subsidised cadetships; - increase the FEE-HELP cap planned as part of the region within which it is located and be growth of international services from regional airports, for aviation students to $102,000 to be consistent with other subject to relevant State and Territory Planning legislation, regionally-based facilities could reduce some of the high cost degrees such as medicine and dentistry; review of the policies and procedures. Further, any land the Commonwealth load on KSA. Expanding the number of direct access and the terms of FEE-HELP assistance; use of RAAF may subsequently acquire and lease for airport use that is put international gateways would incur significant costs infrastructure to provide training; adding pilots to the Skilled to non-aviation use should also be subject to relevant State and related to airport capacity to handle aircraft and border Migration List; and investment in pilot training facilities in the Territory Planning legislation, policies and procedures. control/quarantine. Future air freight networks should Sydney basin and regional NSW. The industry has Memoranda of Understandings between airport operators and be planned as sea freight was planned for through considerable capacity to fund training and receives a high rate State and local government it is required to consider general Auslink. Possible opportunity to develop a regionally- of return for investment in training, as staff are likely to remain community interests. All master plans and major planning sited (such as at Dubbo) international air freight facility. in the industry for most of their career. proposals on airports should be subject to review and the Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 29 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ 3 Aviation safety 3.1 safety regulation & regulatory reform 4 Customer & community protection - addressing 4.1 aviation emissions and climate change 4.2 aircraft noise 4.3 consumer protection 4.4 disability standards 4.5 compensation arrangements in the event of an 5. Aviation Security Individuals' name impacts of aviation accident Mission Aviation Urgent implementation of CSR Part 135 will allow a Fellowship more feasible business model for remote air services, removing the distinction between charter and RPT services. Moorabbin Airport Wants greater recognition and engagement by airport Seeks restricted aircraft movements, more transparent Strongly supports user-pays principle for necessary security Residents Association operator and Govt on community impact issues. and consultative ANEF system and improved measures. (MARA) grievance mechanisms such as Airport Noise Ombudsman. Moree Plains Shire Remove curfew at Sydney, reduces access to regional Lack of facilities when making connections. Transport standards are not ensuring adequate service Review security screening requirements with a view to making Council services. for people with disabilities. consistent between jet and non-jet. Security infrastructure at regional airports is adequate. Security is a federal government responsibility. New technology should be introduced to increase efficiency. Level of security should be based on individual risk assessment. Newcastle Airport Regional airports are not resourced to cope with the Newcastle is working with Defence/RAAF to manage Risk based approach. Government support for regional airports. Limited increasing level of regulatory reform including the flight paths and noise impact perceptions. Airport Encourage competition by not discriminating between small jet levels of consultation departments are demanding. The operators would like to see standard operating hours and turboprop aircraft. Centrally funded security approach. cost of regulatory reform for regional airports is not aligned with Australian curfew standard 6am – 10pm commensurate with benefit. (increase to 11pm). Northern Territory It is recommended that the Australian Government: Airports Pty Ltd 8. fund security costs at the low volume airports – say all airports (designated and non-designated) below 3 million passengers per annum; 9. if Australian Government funding is unacceptable, introduce national uniform pricing per passenger for domestic and international security for the 11 security designated airports; and 10. implement Recommendation V of the Wheeler Review which recommended a review of the CTFR requirement at airports. Northern Territory The NT notes there is a Senate Inquiry into the Civil Government policies on climate change are likely to The current 2004 – 2024 Master Plan for Darwin The NT notes the recommendations from the recent The high cost of security charges at regional ports, due to Department of Planning Aviation Safety Authority underway, which may provide have a significant impact on the aviation industry. International Airport includes the 2024 ANEF‟s which Victorian investigation of low cost airline consumer relatively low passenger through put, acts as a disincentive for & Infrastructure directions for policy settings. A good regulator is able There is a need for the industry to incorporate climate are less conservative than the previous 2019 exposure issues. These recommendations and the development airlines considering the viability of new or increased services. to uphold the law while educating and supporting their change principles so as to mitigate its impact on the forecasts. This difference is mainly the result of not of best practice airline and airport customer service This is especially true for low cost carriers which now provide the customers. environment without adversely affecting related modelling low level military operations. The noise charters, subject to the development of RIS majority of international seat capacity to the NT. industries and communities dependent on its services. consultant‟s report to Air Services Australia assessments, should be considered in policy The Australian Government needs to show leadership Hence, policies should aim to encourage the industry recommended that “Until it can be confirmed that low development. As Alice Springs airport is one of the 11 security designated to ensure the regulatory reform process is completed to achieve this objective. level flights will never be a feature of military airports in Australia, the 1500 daily users of this small regional as soon as possible to provide stability for industry. In progressing to a green paper, the commentary operations in the longer term, it may be prudent to airport are in the inequitable position of bearing all the costs of section would benefit from expressing carbon dioxide retain the ANEF that has been in place for some the security measures that are required at Australia‟s largest Due to the downturn in RPT services, closed charters emissions as carbon dioxide equivalents and account years”. However the statutory requirement is to airports. are now an important category for the servicing of for all greenhouse gases, as is standard practice in comply with the ANEFs presented in the current DIA remote community needs in the NT. Closed charters other sectors. Giving only the 2% carbon-dioxide figure Master Plan. The Securing our Regional Skies program has had positive are somewhat of a grey area and regulatory is not adequate to inform discussion. Similarly, the outcomes and contributed to the ability of remote airports to clarification is required. Consideration should be given Issues Paper only gives information on the global This under representation of the longer term exposure ramp up arrangements when required to do so if the threat level to an Air Taxi category for remote Australia for contribution of aviation to total greenhouse emissions. to aircraft noise has temporary weakened the NT‟s were to increase. operations by aircraft of nine seats or less. Some Australian figures would be the minimum ability to resist inappropriate development on land that required to inform discussion of the issues. will be subject to high ANEFs. This is strong argument The age of the Australian aircraft fleet and rate of to shift towards airport planning based on Ultimate replacement needs to be explored further. While the Noise Exposure Forecasts. Issues Paper mentions that new engines are significantly more efficient, it doesn‟t indicate the average age of the current Australian aircraft fleet, what proportion of current aircraft have such new engines, nor how fast the fleet is being renewed. This NSW Business is basic data regarding the issue of fuel efficiency – Chamber NSW Disability Low cost carrier services have introduced inconsistent Recommend implementation of regulations based on Discrimination Legal and restrictive airline policies to the Australian market. the EU model to ensure uniformity of policies and Centre Inc Implementation of recommendations of the 'Flight practices and provide a more effective monitoring and Closed' report are considered necessary and seen as complaints process. mutually beneficial to disabled travellers and the industry. NSW State Government Consideration should be given to a reporting system Supports the retention of the existing curfew Ministers supported the development of best practice The national Companion Card initiative should be Concerns raised about the airport policing require, as a matter of for actual savings achieved by operators adopting restrictions at KSA and Coolangatta airports. airline and airport customer service charters, subject to considered given the application of „independent travel urgency, development of an all government/industry action plan measures to improve fuel efficiency, as a way to Increased aircraft movements at Bankstown airport development of a regulatory impact statement, and criteria‟ by some airlines and the position of some addressing all elements of regional, State and Commonwealth record the effectiveness of these measures. An outside that agreed in the current master plan should requested that the Commonwealth consider this issue airlines to require people with a disability to travel with aviation issues. Consideration of the threats, risks and emissions trading scheme, including domestic aviation trigger curfew consideration. There should be a clear as part of its review of the national aviation policy. a carer. associated costs need to inform decisions on the level and emissions, will therefore be a useful mechanism for separation between airport operators and the regulator nature of security arrangements imposed. Risk based minimising greenhouse emissions related to the that sets ANEF because these contours dictate the arrangements need to be adopted at regional airports, and domestic aviation sector. The NSW Government also land uses in the vicinity of the airport – effectively a support by the Commonwealth is appropriate for costs of supports the exploration of clean engine technology zoning prohibition. The ANEF must not be set by providing security at regional airports. The security infrastructure and clean fuels as other medium term measures to Airport operators. The Government should explore at KSA should be upgraded. A security „footprint‟ should be minimise the impact of aviation emissions on the alternate aircraft noise forecasting systems to better introduced under the direction of ICAO and Air Services environment. inform land use planning by state and local Australia across all Australian airports to enable consistency in governments and to better inform communities around the screening of passengers, baggage and freight. Consistent airports. Locally negotiated airport community with the Commonwealth Disability Strategy, the Government as approaches are one way in which this could be a purchaser of services could ensure this issue is properly achieved. These could include specific measures to considered in the purchasing of security services and regulation improve the amenity and reduce the conflict between of providers. The NSW Government supports the maintaining land use. It is imperative for legislative approaches to and further strengthening of the ASIC regime. The definition of be retained to ensure that the noise amenity and health 'aviation security relevant offence' in the Aviation Transport of the local community is protected. Security Regulation 2005 to include offences involving firearms, ammunition or prohibited weapons as well as trespass. Offences under the Customs (Prohibited Imports) Act 1956 should all be included within the meaning of 'aviation security related offences'. Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 30 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ Areas covered in submission: 1 Australian aviation industry 1.1 International services 1.2 Domestic services 1.3 regional & general aviation 1.4 addressing skills needs in aviation industry 2 Aviation infrastructure 2.1 airport planning and development 2.2 air traffic management Individuals' name summary/key words Overnight Airfreight Air freight, airport planning and Support open cargo policy. Abuse of monopoly power by airports. Operators Association pricing, noise, security There is an urgent need for stronger and more stringent regulations or even a new regulator to be employed to monitor airport pricing across Australia. Need to protect aviation infrastructure through better state and local government planning. Need to prevent OLS penetration. Parkes Shire Council Air cargo, regional and general Considers facilitation of air cargo movements to Seeking Govt investigation and support to ensure sustainable Considers assistance to smaller airports is essential to allow Sees opportunities to integrate airport infrastructure with off- aviation, airport planning and pricing regional areas would link to existing transport hub services to regional Australia including adequate fees to be set to attract consumers and off-set costs. airport infrastructure, particularly for freight strategy. infrastructure. Suggests returning fuel excise for maintenance and infrastructure investment along with greater monitoring of airlines to minimise abuse of market power in negotiating with marginal airports. Seeks Govt support for airports in attracting and retaining GA services. Paspaley Pearls Group Skills and training, recognition of Regional & GA services are subject to direct competitive Skills shortages are a significant through to GA viability. Policy The significance of the GA sector needs to be recognised The development of ATM standards and technologies for RPT general aviation industry pressures and higher cost pressures than RPT due to framework is needed that harmonises training and licensing for under infrastructure programs need to address equivalency of outcomes and investment for GA. considerations and support for an remoteness and lack of buying power. Investment in GA overseas skills including appropriate immigration regime, industry structure that promotes infrastructure and fleet has suffered as a consequence. development of a national training standard, a joint industry- growth across all sectors. Considers restructure of sector possible through market Govt commitment to develop career paths and employment forces subject to revised policy framework. Seeks a options and financial support, tailored to GA, for training commitment to GA through incentives to invest, attract organisations. Financial support for individuals, development of business development and skills and regulatory oversight a managerial career path within the sector, public awareness which recognises client influence on GA operations together campaign and recognition of remoteness issues are also with Govt procurement processes that support GA sector. sought. Peel Development Secondary airport infrastructure There should be a clear, documented and ratified agreement Provision of infrastructure may include to the development of The planning and development mechanisms under the Airports Commission planning between the three tiers of government that establishes the regional training centres that are located in strategically located Act need to ensure opportunistic lease holders seeking to roles and responsibilities of each authority with regard to regional airports (close to large population centres, transport, realise quick profits from the non-aeronautical development infrastructure provision both on and off-airport, (for both infrastructure, business and industry). potential of existing airports are not afforded the prospect of leased and other airports), with a view to maximising the This includes pilots but may further extend to other aviation divesting themselves of an operational airport with an agreed return on investment in existing infrastructure and achieving related positions such as air traffic controllers and engineers. Master Plan in favour of financial gains and the promise of the long term sustainability of current and future airport The Government may provide the infrastructure and related establishing a new facility in another location. operations. The agreement should delineate the hierarchy of facilities (lease-hold arrangement); partner with a relevant The establishment of a State level planning policy based on the strategic land use planning mechanisms that each sphere of organisation or association to: agreed government framework outlined above would provide government should be responsible for and the agreed nature 1. Train pilots for the domestic and international markets. for consistency and improvement with regard to consultation at and duration of consultation and referrals between the 2. Include the training (under the Skills Australia program) to all levels. Long term strategic land use planning should protect different levels. The agreement needs to establish the cost fund other related aviation positions. existing, and identify new, airport sites. Future sites should contribution and recovery mechanisms at each level. The partnership must be sustainable with sufficient linkages consider the proximity of other existing and planned Protection will be afforded by an investment in, and between the local community and the training providers to infrastructure, services and populations to reduce establishment commitment to the outcomes of, long term strategic land use support the development of this industry. Prospective and maintenance costs to all spheres of government, maximise and master planning as well as careful consideration of organisations such as overseas airlines should also be functionality and utilisation of airport infrastructure, provide diversification options so that the airport operation is not considered however there needs to changes made to the access to a skilled workforce as well as generate minimal prejudiced. restrictions on overseas airlines in order to progress this community and environmental impacts. arrangement. Penrith City Council Disbility standards Perth Airports Airport planning Airports can effectively plan and build whatever they like, as Municipalities Group evidenced by the brickworks at Perth Airport and developments at Jandakot City. A panel should be established comprising commonwealth, state and local governments to assess MDPs. The Department should publish evaluation criteria for MDPs to ensure transparency. Planning assessment should take place regardless of $$ value. Developments should be consistent with local, regional and state planning goals. Phoenix Aero Club General aviation, airport The GA industry is in crisis due to a loss of GA facilities and There is a shortage of trained pilots and most critically Privatisation of secondary airports has had a devastating infrastructure, skills training. skilled staff, rising costs and burden of compliance with experienced flying instructors. Lack of government support for impact on GA. Airport owners are transferring as much land regulations and increasing costs of flying training and flying training means it is in a very poor state and the industry as possible to non-aviation purposes and unless the declining numbers of students. The industry is too cannot respond to export opportunities. Government acts erosion of airport facilities will continue, demoralised to take advantage of opportunities. with some disappearing altogether, as evidenced by closures in Western Sydney. While access to regional airports for GA is a concern, access to major capital city airports is more of a problem. Physical Disability Disabled access, safety regulation, Many domestic airlines are still not providing seamless Airports should be located outside cities to minimise Council of Australia airports, airline compliance with services to people with disabilities and are demanding that environmental and other impacts. (PDCA) disability standards, compensation, they travel with a support person. security. Planning Institute of Airport develoment planning, inc non- Airports are an integral part of the cities in which they operate Australia areonautical development on airport and non aviation commercial developments on airport sites sites. must be subject to the same state and local planning rules, and National Competition Policy competitive neutrality principles, as other private developers. Account must be taken of their impact on infrastructure and a process that identifies funding responsibility for transport services and infrastructure triggered by airport developments is paramount. Proponents of the developments must contribute. All three levels of government must be engaged in the process and current legislation should be amended to ensure mandatory consultation occurs for proposed developments on airport land. Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 31 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ 3 Aviation safety 3.1 safety regulation & regulatory reform 4 Customer & community protection - addressing 4.1 aviation emissions and climate change 4.2 aircraft noise 4.3 consumer protection 4.4 disability standards 4.5 compensation arrangements in the event of an 5. Aviation Security Individuals' name impacts of aviation accident Overnight Airfreight Need to improved system to replace ANEF. Biggest threat to security is the unintended carriage of Operators Association dangerous goods. Acknowledges curfew arrangement at Australian airports but curfews need to be standardised regarding Should standardise air freight security measures with which aircraft are allowed to operate during curfew international standards. hours. Measures at regional airports should be commensurate with Should replace BAe146 aircraft operating at Sydney threats involved. with aircraft meeting the 90/95 rule. Reports from the Noise Enquiry, Complaints service should be standardised to avoid influence by repetitious complainants. Parkes Shire Council Paspaley Pearls Group Supports a consultative regulatory approach to safety Suggests a joint Govt and industry framework to Considers aviation industry to have made substantial Seeks consistent security standards nationally on a risk based oversight and seeks an educational mandate for provide incentives for investment to reduce progress in addressing environmental impacts such as approach that tailors security outcomes to operations outside of CASA. Sees a need for safety management systems, environmental impacts and that regulatory regime noise but progress in GA sector limited due to RPT. Also seeks a commitment to prosecute misuse of ASIC effective oversight by industry and clear regulatory needs to consider international developments. investment constraints. cases. boundaries for industry with consistent, transparent interpretations and enforcement. Supports network pricing for CASA services and sees harmonisation of regulatory standards with international practice as a key element of reform. Peel Development Commission Penrith City Council Seeking compliance by airlines to equitably meet the needs of travellers with a disability by ensuring accessible toilet facilities. Also supports the Human Rights & Equal Opportunity Commission being granted powers to refer breaches of the Transport Standards to the Federal Court. Perth Airports Municipalities Group Phoenix Aero Club Physical Disability Any airport that connects to overseas arrivals or Australia should consider the regulatory practices of Insurance should include damage to wheelchairs and Some security checks are unnecessary and very difficult for Council of Australia departures should be curfew free. the EU, Canada and the US. The airlines must develop other mobility devices. people with disabilities. (PDCA) action plans and consult with people with disabilities. Current transport standards are adequate provided the airline industry adheres to them. The current complaints system is fraught with problems for people with disabilities. Facilities should be made more accessible for people with disabilities. Planning Institute of A risk assessment should be undertaken of major Policy frameworks for dealing with developments Australia airports to ensure they can adapt to climate change. around airports and noise vary between state and territory. PIA supports transparent policy developed consultatively that clearly outlines the requirements for development controls around airports. Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 32 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ Areas covered in submission: 1 Australian aviation industry 1.1 International services 1.2 Domestic services 1.3 regional & general aviation 1.4 addressing skills needs in aviation industry 2 Aviation infrastructure 2.1 airport planning and development 2.2 air traffic management Individuals' name summary/key words Public Interest Airline travel for people with Advocacy Centre disabilities Qantas Group All issues A sustainable, competitive industry should Trade of 7th freedoms considered case-by-case and Sees strong domestic network operations as indivisible from Supportive of competition where sustainable and Sees opportunity for Govt to enhance existing policy and Creation of a defined framework for airports including Seeks amendments to the Airports Act ensure civil aviation is Considers regulatory regime has lagged behind the pace of not be taken for granted and an Australian only where a clear, useable commercial trade for competitive international operations. Seeks removal of recommends the development of federally-based network for programs such as Tools for Your Trade and removing the FEE- application of ICAO pricing principle that precludes pre- the priority in approving Master Plans including consideration of technological advancement and industry initiatives eg GNSS & based industry makes an important Australian carriers eg 5th freedoms. Opposes trade of restrictions of Qantas Sale Act to enable access to capital such services be explored to allow all airlines to work under a HELP cap for aviation qualifications along with extension of funding of capital expenditure, recognises contribution of local and state planning documents and Master Plans for any ADS-B. Seeks Govt endorsement of ASTRA plan and formal contribution to the national interest. consecutive cabotage on grounds it would undermine and facilitate consolidation and growth. nationally consistent approach. travel concession cards, motor vehicle subsidy and training fee airlines to revenue and return on non-aeronautical assets, airport that could be an alternative airport. Seeking mandatory sanction of ASTRA and links to Govt aviation bodies. Broadly supportive of current policy domestic networks and believes investment cabotage voucher system to cover all years of apprentice training. Seeks defines customer agreement for pricing purposes to prevent consultation and arbitration processes and regular forums for Recommends a policy framework that provides a sustainable emphasising factors like lack of level is a sufficient mechanism to allow domestic access for the addition of pilots to the migration occupations in demand deemed agreement by continuing to use the airport and airport users and local planning authorities on development of balance between RPT operators and military requirements playing field and complexity of the bilateral foreign carriers. Supports liberalisation of cargo list. Would like to see the extension of state-based initiatives to clear criteria for airports to which it applies. Seeking a clear airports and surrounds to resolve planning coordination issues. including Flexible Use Airspace and supports a policy position that system which put Australian carriers at a arrangements. Considers designation by ownership encourage aviation careers on a national basis, the provision of response to the PC recommendations on pricing and a Inclusion of CASA in decision making with regard to building enables RPT jet aircraft to nominate the use of military airfields as disadvantage. and control as restrictive to access to capital and funding to assist a Qantas Engineering Summer School coordinated, national regime for pricing that provides a heights and positions off-airport and regulations to ensure a pre- alternates for the purposes of flight planning. Asks Govt to industry consolidation and seeks changes to taxation Program and Govt working with industry to promote Australia balance between non-aeronautical development and condition of development approvals off-airport detail how consider performance targets and measurements for regulatory and depreciation arrangements to improve as a aviation centre of excellence. Also wants accelerated aeronautical requirements under either a single or dual till airport master plan and future air space requirements are being agencies to drive performance and the inclusion of industry experts competitiveness. Considers passenger facilitation and depreciation provisions and R&D tax concessions for learning approach. Considers clear guidelines and criteria for incorporated. Would like to see planning framework apply to in official delegations to international forums. Also seeking border control arrangements require attention. and skills development equipment and technology. airports regulated under 'light handed monitoring' need to be major and regional airports regardless of ownership. Seeks strategies to make air traffic control a career of choice. established. more flexibility with operations into Sydney and Sydney Basin and a review of curfew and capacity constraints at airports and opposes introduction of new or additional curfews and constraints. Supportive of development of policy framework to enable operations of civilian RPT jet aircraft at selected military airfields sensitive to the needs of Defence. QBE Australia Carriers liability, consumer protection Queanbeyan City Airport planning, noise regulation Master Plans and Major Development Plans lack specific detail Council and accompanying traffic or similar studies that would usually be required for developments of a similar scale proposed for land outside airports. To overcome such shortcomings it is suggested that a Regulation be introduced which sets out guidelines in regard to the extent of information that should be included in Preliminary Draft Master Plans in relation to section 71(2)(c), and in relation to Major Development Plans. Submissions to Master Plans and MDPs should be reviewed by planning authority, not airport proponent. Non-aeronautical commercial and retail developments should be passed to the relevant urban planning authority (e.g ACTPLA), which has the expertise to assess the impacts of large non-aeronautical developments. Time period for consultations should be increased Airport plans should be subject to the same requirements as developments off airport, including analysis of impact of competition on surrounding businesses. Queensland Airports International, domestic, regional and The Regional Airports Entitlement Package should be The current policy settings have served Australia well. High The Federal Government should seek to reduce costs of There should be a national accreditation or incentive scheme Airports and the Commonwealth need to be proactive with Airservices should be encouraged to maintain its leadership in Limited GA, skills training, infrastructure and included in all bilateral negotiations, as well as capacity jet services now service more regional destinations mandated government charges at regional airports. Without with support from government. Universities and TAFE's should state and local authorities to ensure that community transport innovation in the application of GPS technologies. Australia is the planning, ATM, safety, regulatory supported by marketing the benefits by Federal than would ever have eventuated under the earlier high cost the ability to reduce costs, the above regional entitlements be involved with the private sector in developing tailored infrastructure can accommodate current and future aviation only country in the world where the ANS provider is responsible for reform, climate change, security. Government agencies in tourism and transport. This regulated model. package becomes difficult to sell to prospective airlines as courses to align with long term aviation needs. Establish a needs. There is a need for an Australia-wide planning initiative the provision of ARFFS and this leads to inefficiencies and should be supported more proactively by regional secondary airports need to have lower costs as an incentive centre of excellence encompassing the main skills to supply the to establish runway end protection zones consistent with duplication of resources. The only benefit is that it allows ARFFS airports. Our geographical position does not support compared to congested capital city airports. Examples of industry. international standards. At joint user and Defence airports, services at regional airports to be cross subsidised by the charges allowing more foreign airlines to operate from Australia key cost reduction are Airservices charges which are Defence must agree to provide services in accordance with the at the major airports. ARFFS should be made contestable. to third markets. The recent increase in the passenger significantly higher at regional airports and the cost of CASR's. The "light handed" pricing regulatory regime has movement charge is another disincentive to security. A tiered system should be developed instead of resulted in a surge of airport investment and should be international tourists and should be reconsidered. blanket measures for security so it is destination specific. continued. Australia's active border intervention policy State and local government need to make provision in their necessitates expensive border control processes and planning to protect GA facilities or reserve sites for new GA relatively large establishments that are difficult to infrastructure. sustain at low volume international airports. Content review-ALL c881b607-596f-4051-9a30-26bbf47edd36.xls 33 of 205 printed: 1/24/2011 at 1:52 PM National Aviation Policy Statement (NAPS) Issues Paper to Green Paper Submissions Register organisation/ 3 Aviation safety 3.1 safety regulation & regulatory reform 4 Customer & community protection - addressing 4.1 aviation emissions and climate change 4.2 aircraft noise 4.3 consumer protection 4.4 disability standards 4.5 compensation arrangements in the event of an 5. Aviation Security Individuals' name impacts of aviation accident Public Interest Agrees with the statement „air travel is accessible to PIAC refers the Department instead to the Part 4 of Current airline and/or airport practices in relation to the security Advocacy Centre more people than ever before‟. the Flight Closed report, which sets out 57 screening process do not adequately address the requirements recommendations, or proposals to improve air travel of people with disabilities. However, people with disability do not appear to have for people with disabilities. These proposals cover Examples of some of the difficulties experienced by passengers benefited from these changes in the same way or to compliance, service quality, policies and practice of with disabilities are set out at Part 4.14 of Flight Closed and anything like the same extent as the rest of the airline services and training of personnel. They include: include the following: community. The experiences of passengers and their a proposal for a specific code of practice to be passengers being required to undergo physical checks if unable families outlined in Flight Closed suggest that it may developed for the airline industry and administered by to pass through scanning equipment; now, in fact, be more difficult for them to travel by air an authority that administers other regulatory passengers experiencing difficulty in removing their shoes and than it was previously. requirements for the airline industry; other items of clothing or supports as part of a physical check; a system for ongoing consultation with people with passengers being unable to understand requests and directions disabilities and their organisations that is integrated into from airport security staff; and the design, planning and delivery of air transport passengers being required to undergo physical checks in view of services; and members of the public, and finding this confronting and mandatory standards for staff training, particularly in embarrassing. respect of disability awareness, and for communications processes within airlines. Flight Closed made 57 recommendations for improving the travel experiences of passengers with disabilities. It is PIAC‟s submission that many of these improvements could be implemented at nominal or low cost to airlines. These recommendations have the potential to improve the travel experience of all passengers generally, hopefully resulting in Australia‟s domestic carriers being lifted from the bottom of consumer surveys. They also have the potential to make Qantas Group Focused on CASA reform and suggests the Seeking support for accelerated introduction of Wants to see the development of national noise Supports current legal framework and considers Australia‟s airlines more accessible to an ageing Seeks review of Disability Standards for Accessible Supports Montreal Convention standards for international View that aviation security strategies to be largely reactive and appointment of a project manager to oversight and the Required Navigation Performance in Australia and standards that eclipse constraints of ANEF system, Qantas Group as the industry leader in applying best Public Transport for number and weight of mobility and recommends the Carriers Liability Act be amended to considers a need to develop, in conjunction with industry, a secondment of industry experts to assist preparation of financial, or other, recognition in the trade-off between improved awareness and consultation such as noise practice consumer protection standards. aids permitted free of charge and minimum training specify state regimes are applicable to domestic holistic and integrated national strategy and regulatory guidance material. Encourages direct and ongoing priorities eg noise vs emissions. Looking for an memorials on titles and Airport Environment Education standards assistance animals along with development passenger claims, exclude 'pure nervous shock' claims framework that is sufficiently flexible to take account of the engagement with industry across CASA including incentive scheme for R&D into new fuel types and an Centres staffed by community volunteers and a better of aviation specific guidelines in consultation with and state that it provides exclusive remedies in the complex operating environment and that, wherever possible, within OAR and at the CEO level. Recommends increase in deduction from 125% for R&D expenditure enquiry and complaint service. Ensure that state and industry representatives. carriage of passengers, baggage and cargo along with Australia's standards and procedures are harmonised and review of CASA governance and ensuring they are in this field. Seeks support for the development of an local governments are integrated into the noise amendments to the Damage by Aircraft Act to cap mutually recognised internationally. accountable for quality management systems. Would international framework to manage tax-related issues management process and adopt a more pro-active operators liability and exclude or limit liability for acts of Would like to see an examination of security policy setting that like to see CASA develop and implement mandatory arising from aviation's inclusion in emissions trading role in noise education and planning, including ensuring terrorism. encompasses the effectiveness of airport categorisation, airport SMS requirements and suggests some CASA schemes and the allocation of free permits to aid the off-airport development considers 'worst-case' noise policing and activities such as Air Security Officers. Suggests a administrative requirements be devolved to industry. transition. Recommends the introduction of a 'green' scenarios. centralisation model for a single screening authority and single Wants to ensure CASA has the objective of depreciation regime for new aircraft that are cleaner security training authority and federal approach to licensing. international harmonisation of legislation and and more efficient. Recommends the development of network pricing to apportion regulations and suggests consideration be given to security costs across industry. Supports current exemption of granting autonomy to the ATSB.