Submissions & Publications
The Australian and International Pilots Association (AIPA), through its Safety and Technical Committee, is committed to protecting and advancing aviation standards and operations. The committee works to position AIPA as a key component of the aviation quality control process: through the development of relationships with Government, regulatory bodies and industry to ensure the views of Australia's professional airline pilots are considered in important safety and technical matters.
AIPA is also a co-founding member of the Australian Airline Pilots’ Association (AusALPA) which represents more than 5,000 professional pilots within Australia on safety and technical matters.
Please click on the links below to view recent submissions and publications from AIPA and AusALPA.
AIPA President Letter to Hon. Jo Haylen
AIPA President Tony Lucas writes on behalf of the Australian & International Pilot’s Association to the Hon. Jo Haylen, Minister for Transport to add our voice to the growing calls for airport workers to be exempt from paying the Station Access Fee...
AIPA Submission to COVID-19 Response Inquiry
It is critical to enhance our resilience and preparedness for potential future pandemics to avoid the discordance and incoherence of international flying that occurred during the COVID-19 pandemic. Failure to adequately prepare may subject the...
AIPA’s Submission for Aviation Green Paper
November 2023 AIPA has submitted a response to the Aviation Green Paper, expressing support for green goals while emphasizing the economic and connectivity role of aviation. AIPA calls for a comprehensive National Policy and a purposeful White...
AIPA Submission: Closing the Loophole
AIPA welcomes the government’s proposed ‘Closing the loopholes’ amendments to the Fair Work Act.
AIPA Submission 'Closing the Loopholes' Senate Inq
The Australian & International Pilot’s Association (AIPA) is the union representing airline pilots who fly for Qantas and the Qantas owned subsidiary airlines. AIPA’s particular interest in the Closing the Loopholes amendment relates to the misuse...
AIPA Submission to RRAT re Future of Aviation
AIPA maintains the view that much of the disproportionate damage inflicted on the aviation sector among the severe economic damage induced nationally was largely avoidable and that our future planning must prioritise the preservation of our aviation...
AIPA SUBMISSION TO DITRDC AVIATION ISSUES 2020 DP
November 2020 THE AVIATION ISSUES PAPER 2020 In our attached responses to the specific questions of the Issues Paper, there are many things that fall outside our usual areas of expertise and, with most of our members stood down and surviving...
AIPA SUBMISSION TO RRAT RE RRAT GA INDUSTRY
September 2020 AIPA submission to the Senate Regional Affairs and Transport Legislation Committee inquiry into the current state of Australia’s General Aviation industry.
AIPA re Aeronautical Assessment Hayes Dock
The HPA proposal creates two problems: one, the cranes are significant obstacles; and two, the larger vessels create turbulent wakes in strong winds. AIPA is generally opposed to penetrations of the Obstacle Limitation Surface (OLS) and particularly...
AIPA letter CASA Review of Aviation Fatigue Rules
April 2018 AIPA welcomes the fact that the Review team has agreed that Australia’s fatigue management rules need updating. The fact that very little technical detail in the 2013 Instrument has been identified as requiring amendment reinforces our...
AIPA Response to Modernising Airspace Protection Public Consulation Paper
AIPA firmly believes that the Standards and Recommended Practices (SARPs) developed by ICAO in relation to the design, construction and airspace protection for airports are the minimum acceptable standards for safe operation of aircraft in Australia.
AIPA Submission to the DIRD re Western Sydney Airport Draft EIS 2015
In general, the Association supports the decision to have Badgerys Creek as the site for the WSA and supports the airport being built to the standards and requirements to accommodate up to Code 4F aeroplanes with a plan to expand to a parallel...
AIPA Comments on Draft CAAP48-1(2)
AIPA remains concerned about some aspects of the prescriptive FTL even following the July amendments to the Instrument. We believe that CASA is wilting somewhat under the commercial and political pressure of vested interests that are unwilling to...
AIPA Letter to Treasury re Final Report on Competition
AIPA has submitted a response to the Competition Policy Review Final Report and recommends that the Australian Government note the Panel’s views but decline to vary the approach taken to Air Services Agreements and cabotage in Australia’s current...
AIPA Comments to DIRD on Scope of Asics
AIPA has made comment on the DIRD’s Options Discussion Paper Scope of Aviation Security Identification Cards. AIPA maintained a position on the need for risk-based security and have been critical of the ‘one size fits all’ model used in Australia.
AIPA Comments to CASA on NPRM 1411AS Unserviceability Markings and Ground Signals
AIPA has responded to CASA’s NPRM 1411AS – Unserviceability Markings and Ground Signals. AIPA endorses the adoption of the ICAO standard 36m markings and, to the extent that CASA adequately risk assessed the conspicuity of the 9m markings of 18 and...
AIPA Submission to the Senate Rural and Regional Affairs and Transport References Committee Enquiry into Airport and Aviation Security
AIPA maintains its position on the need for risk-based security and highlighted the need to redress the inadequacy of screening applied to those who gain airside access other than through terminal secure areas and the need to secure apron areas...
AIPA Comments to CASA re Draft CAAP 48-1 November 2014
AIPA has concerns regarding the prescriptive FTL, particularly in areas of the SIE that AIPA believes is lacking in scientific and verified operational experience. AIPA is also concerned that there are several provisions that could potentially...
AIPA Letter to CASA re NPRM 1320AS Navigation Approvals
AIPA has recently reviewed the NPRM and is, in general, supportive of CASA’s decision to align navigation authorisations with the ICAO PBN Manual (Doc 9613) and to create provisions/criteria for Advanced PBN, in addition to trying to rationalise the...
AIPA Letter to Office of Transport Security re Review of Aviation Prohibited Items List
AIPA has recently reviewed the discussion paper and is, in general, supportive of the Department’s decision to align the Prohibited Items List with ICAO and other international practices; and welcomes the shift to a risk-based security.
AIPA Submission on the Recommendations of the ASRR Panel
AIPA has responded to the Aviation Safety Regulatory Review (ASRR) and has offered the commentary on the 37 recommendations made by the ASRR Panel in relation to improving the performance of the Australian Government agencies within the system,...
AIPA Submission to CASA Notice of Proposed Change to Section 6.2 Runways 139
AIPA has responded to CASA’s NPC 139-05 and believes that the MOS139 should be equal to or more restrictive than ICAO Annex 14. Any regulatory relief granted should be considered as transitional, with a timeframe given for full compliance. Approval...
AIPA Submission to the Aviation Safety Regulation Review
AIPA made a number of recommendations relating to the structures, effectiveness and processes of all agencies involved in aviation safety; the relationship and interaction of between those agencies, as well as with the DIRD; the outcomes and...
AIPA President Introduction to Disallowance Brief
Despite representing a significant improvement of existing practices, the Instrument falls short of the necessary standard for safe operations in a number of areas. In AIPA’s view, disallowance will not adversely affect most operators and the...
AIPA President Letter re Why we need the parliament to disallow civil aviation order 48.1 instrument 2013
AIPA is a fervent supporter of FRMS. We applaud the introduction by CASA of “operator obligations” as a means to impose some FRMS processes on those operators who choose to operate only under the prescriptive rules set out in the Instrument but we...
AIPA Submission re CASA Consultation Draft - Civil Aviation Legislation Amendment (Flt Crew Licensing) Regulation
AIPA is not confident that the Part 61 MOS will lead to any improvement to current training standards, which we still see as a latent risk and believe that much greater consultation will be required. AIPA also believes that it is critical that AIPA...
AIPA Comments to CASA re NPRM 1213CS Addition of Safety Based Requirements
AIPA is supportive of any proposal that considers practical means of provided enhanced security and operational safety for flight crew as well as any proposal that considers practical, cost-effective means of ensuring post-accident entry to the...
AIPA Submission to Consultative Draft Part 61 MOS
AIPA has expressed concerns that the Part 61 MOS will not lead to any improvement to current training standards, which we still see as a latent risk in an operational world that is just beginning to realise the price being paid in terms of skill...
AIPA Submission to NPRM 123OS EDTO
AIPA is ambivalent about the proposed changes because, while there will be no reduction in safety, we do not believe that the changes have been adequately justified. Notwithstanding the lack of transparency in the true scope and depth of CASA’s EDTO...
AIPA Submission to Deputy PM & Minster for Infrastructure and Regional Development re Colour Vision Deficiency
AIPA recommends that the Minister for Infrastructure and Regional Development accepts the evidence of many years of safe operations by CVD affected pilots in Australia that this is not a safety issue and that the Minister consequently intervene to...
AIPA Submission to BOM Draft TAF Review
AIPA supports the 15 recommendations made in the Draft Review. The idea that aerodrome operators might consider BOM as a revenue source when seeking rent for the installation of equipment required for the provision of met services for that aerodrome...