From: Brian Candler [raaaceo@ozemail.com.au]
Sent:
Monday, 4 July 2005 3:52 PM
To: Committee, JCPAA (REPS)
Subject: Review of Aviation Security in Australia

 

 

         ABN 23 008 568 054

 

Committee Secretary

Joint Committee of Public Accounts and Audit

Department of the House of Representatives

Parliament House

Canberra   ACT   2600

 

 

Dear Sir

 

REGIONAL AVIATION ASSOCIATION OF AUSTRALIA SUBMISSION IN RELATION TO THE COMMITTEE’S REVIEW OF AVIATION SECURITY IN AUSTRALIA

 

The RAAA is very concerned that this review is being conducted in an atmosphere of hysteria, misinformation and total confusion between law enforcement and border control on the one hand and aviation security on the other.

 

Unfortunately, the Committee itself seems to have fallen into this same confusion.  Of the seven “publicly reported security incidents” referred to in the Committee’s media release of 26 May 2005 only three are realistically security incidents.  The other four are acts of stupidity, criminality or vandalism.  In particular to refer to an act of petty vandalism on two aircraft with minor, if any real, safety implications, as an early morning sabotage raid on a fleet of aircraft in the security context (December 2004, Victoria Air Ambulance) is to fan, arguably in an irresponsible manner, an ill-informed public anxiety.

 

The May 2005, April 2005, and March 2005 incidents are simple criminal conduct which ought to be dealt with as such.   They are matters of policing and/or border control and should be dealt with by way of an inquiry into the adequacy of federal and/or state law enforcement and into the border control agencies. 

 

The January 2005 delay in the readiness of the rapid deployment teams demonstrates just to what extent the responses to aviation security have been ill-thought out, costly knee-jerk reactions.  The security outcomes to be achieved by these expensive teams are far from clear.  If the real problems are in the major gateway ports the funds devoted to these teams would have been better spent there.  In a rational world the funds being wasted on insignificant security risks in regional Australia would be better spent on ensuring regional Australia had adequate basic services, such health, communications and transport (including aviation services).

 

The September 2004 lack of screening of contract workers also highlights the knee-jerk nature of the so-called security exercise.  ASIO’s vetting performance has been less then impressive and caused substantial business losses while employees and clients wait for clearances.  The legislation appears to be inconveniencing the law abiding in a futile effort to prevent identity fraud by the expert criminals.  This will only get worse as private-business and private-recreational pilots get dragged into the net for no appreciable gain in security terms.

 

The July 2004 Korean incident was simply a breakdown, albeit a serious breakdown, in an overly complex system and probably the only real breach of security in the incidents listed.

 

Turning to the particular terms of reference our comments are –

 

(a)       DOTARS regulation of aviation security is driven by Regulations, which were not challenged in either House of the Parliament, which not are outcome based and which are unnecessarily prescriptive producing large cost impositions for no appreciable security gain, for example, the repeated screening on one day of pilots of regional aircraft or the absolute requirement to secure unattended aircraft.  DOTARS response to the very few security incidents since June 2004 has been appropriate in terms of the heavy handedness of the legislation it has been given to administer.

 

(b)       Compliance with Commonwealth security requirements by airport operators has been extraordinarily good given the haste of their imposition and their cost to the industry.

 

(c)        Compliance with Commonwealth Security requirements by airlines has been extraordinarily good given the haste of their imposition and their cost to the industry.

 

(d)       We make no comment on the impacts of overseas security requirements on the Australian aviation industry.

 

(e)       The impact of cost imposts on regional airports and regional operators for security upgrades may well be a reduction of services to remote and regional communities.  Although the Commonwealth has provided some funding for security upgrades, it is not sufficient, especially for as there is no allowance for continuing maintenance.  The shortfall will be passed on to operators, who will have to decide whether it is possible to pass it onto passengers or whether a marginally viable route has become unviable.  Equally costs imposed directly on operators, such as supervision of unattended aircraft can be expected to reduce if not terminate marginal services.  Overnighting aircraft at remote ports may be come prohibitively expensive so that the quality of service is dramatically reduced or even terminated.

 

(f)         We make no comment on the privacy implications.

 

(g)       The capital costs of new technologies generally make them too expensive for use in regional Australia, especially when considered against the negligible risk involved.

 

Officers of the RAAA would be happy to appear before the Committee to give evidence if so desired by the Committee.

 

Yours faithfully

 

 

Brian J Candler

Chief Executive Officer