From:
Brian Candler [raaaceo@ozemail.com.au]
Sent:
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
Dear Sir
REGIONAL AVIATION ASSOCIATION OF
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
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
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