The ATSB notes that neither the operator nor the regulator specifically addressed the discouragement of fatigue reporting by flight crew due to potential financial penalty. The ATSB would welcome the opportunity to receive a summary of the post-implementation review following the trial period to ascertain if there has been a decrease in fatigue reporting.

The ATSB notes ECE concerns have previously been raised through REPCON RA2022-00053. At the time, CASA had not been provided detailed information on the proposed implementation. The ATSB has since received additional concerns as above. The ATSB therefore asked Airservices and CASA to provide any updates / comments on the proposed implementation and risk management plan.