AOC Question: Classification of Operations

[Rattlegun]

I have posted this question on another (Helicopter) forum, but I want to gauge wider opinion.

Let’s say I own and operate an IT Support business which sells computer parts and performs computer repairs.

Scenario 1
I hire a car and drive to the customer’s premises to set up a computer which he has purchased from a third party. I invoice the customer for my labour (including labour required to drive the car) and the hire cost of the car.

Scenario 2
Exactly the same as Scenario 1, but replace the words ‘car’ with ‘aircraft’ and ‘drive’ with ‘fly’. (Grammar Gestapo: the first ‘a’ also becomes ‘an’)

Scenario 3
The customer orders a computer from my business, which I send via courier. As soon as it arrives, I hire an aircraft and fly to the customer’s premises and set it up. I invoice the customer for my labour (including labour required to fly the aircraft), the computer parts, and the hire cost of the aircraft.

Scenario 4
Same a Scenario 3, except that instead of sending the computer via courier, I take it with me in the aircraft. Again, I invoice the customer for my labour (including labour required to fly the aircraft), the computer parts, and the hire cost of the aircraft.

Scenario 5
My Customer orders the computer from a third party. I agree to pick it up, fly out and set it up. I invoice the customer for my labour (including labour required to fly the aircraft), and the hire cost of the aircraft.

Scenario 6
The customer orders a computer from my business for urgent delivery, but wants to set it up himself. I hire an aircraft and fly the computer out to him. I invoice for the computer, labour to fly the aircraft and hire of the aircraft.

Which of these qualify as Private Ops?

Reference:

2 Interpretation
(7) For the purposes of these regulations:
(d) an aircraft that is flying or operating for the purpose of, or in the course of:
(v) the carriage of persons or the carriage of goods without a charge for the carriage being made other than the carriage, for the purposes of trade, of goods being the property of the pilot, the owner or the hirer of the aircraft;
Shall be taken to be employed in private operations.

And

206 Commercial purposes (Act, s 27 (9))
(1) For the purposes of subsection 27 (9) of the Act, the following commercial purposes are prescribed:
(a) aerial work purposes, being purposes of the following kinds (except when carried out by means of a UAV):
(viii) carriage, for the purposes of trade, of goods being the property of the pilot, the owner or the hirer of the aircraft (not being a carriage of goods in accordance with fixed schedules to and from fixed terminals);

[Jack Ranga]

Are you serious cuz? Do you enjoy headfarking yourself? What happened to KISS?

[LeadSled]

What happened to KISS?
Jack,
'cause it ain't simple, as the questioner understands.
As to what the legal answers are, consult a lawyer who is familiar not only with the aviation law, but the current court/AAT interpretations of CAR 206.


2 & 3 are private, probably 5, the other two, ?? but probably caught by 206.


As Rattlegun is obviously aware, the critical bit is the legal status of the computer and any tools being carried for the installation.



Tootle pip!!

[TBM-Legend]

Keep flying the aviation world needs more activity like your business aviation in GA aircraft if you're conducting the business is private. In your role as a contractor to your client you are using the aircraft to meet the client needs.

[Rattlegun]

As Rattlegun is obviously aware, the critical bit is the legal status of the computer and any tools being carried for the installation.

You're spot on.

If the cost of the flight is exactly the same with and without the goods on board, then no charge has been made for their carriage.

If carriage is not offered to persons generally (i.e. employees only) and no charge is made for the carriage of goods, why should the legislation (and the safety regulator) be concerned with how the costs of the flight are met?

[Mach E Avelli]

What a classic example of our contradictory rules.

Why not simply invoice for the bits used plus a flat service fee and make no mention of aircraft hire? The service fee could simply state that it is inclusive of travel, accommodation and labour.
Simplistic maybe, but you don't need CASA's involvement in your business.

Your internal accounting is entirely another matter but is still nothing to do with CASA. The ATO is unlikely to consult CASA on any of this and I imagine whoever you hire the aircraft from for your business activities would not be too concerned either.

[Aussie Bob]

I agree with Mach ...

Why bog down your mind with such trivialities? For many years I conducted an electrical business from an aircraft. The tax office was happy, the aircraft was a deduction, the customer was happy, and the flying got done and paid for by being invoiced as travel costs.

On one memorable trip an airstrip was marked out for me in a field of wheat stubble by an ex CFI retired to farming.

Just go do it ....

[LeadSled]

Mach E,
Sadly, not the way it works, it is not how the money changes hands, or even if money changes hands. Under the "relevant" provisions of CAR 206, it is the characteristics of the operation that determine whether it is private, or an AOC and a minimum of a CPL is required.
Conversely, money can change hands without the operation being caught by CAR 206.
As a word of advice, the courts have taken a very dim view of "arrangements" to get around CAR 206, and CASA's very varied interpretations of CAR 206 over the years have changed markedly.
Tootle pip!!

[tail wheel]

It is Monday. I'm sure CASA will have yet another interpretation of CAR206 today!

Pre 1988 in the ANRs most if not all of those activities would have been classified as Aerial Work, requiring an AOC.

For example, in the 1950s a stock and station agent who flew from property to property buying and selling cattle was required to hold an AOC, as was a mechanic who few to properties with his tools in the course of his work. In those saner days, AOCs were free and only took a few days to organise.

More recently CASA secured a conviction against a private pilot who took photos of properties with a hand held camera from his aircraft then sold the photos.

[neville_nobody]

CASA also grounded a guy doing pest inspections in remote areas and mine camps. Even though he wasn't selling anything they deemed his chemicals to be for sale. He was arguing that the chemicals were tools of the trade. He had no money to challenge CASA in court so now someone charges twice as much and drives to these places......

[LeadSled]

He had no money to challenge CASA in court so now someone charges twice as much and drives to these places...... Folks,
But, of course:"Empty Skies are Safe Skies".

And, in microcosm, an example of how over- regulation is driving Australia's productivity into the dirt.

It is worth noting that US does not even have an "aerial work" category, most of what we call aerial work, and require a monumental bureaucratic edifice, including the dreaded "accepted operations manual" (you know the one, with all the enforceable provisions that appear nowhere in the CASR/CAR/CAO/MOS, but are the whim of some FOI, or some CASA policy, "formal" or informal, that has no legal head of power, other than the power to enforce the provisions of an operation manual) that you have to create - the auditable shelfware.
Tootle pip!!

[Old Akro]

This is really a risk management exercise. I would have said that if a) the flying was incidental to the task and b) aeroplanes, pilots and flying never appear on the invoice then your risk is low.

Unless you are doing it regularly or flaunt it, how will CASA know? If they ramp you its your equipment that you are taking on a private trip (probably assuming you are not in a company uniform). If they get hold of the invoice there is nothing to say how you or the computer got there. So, I think that I'd accept that it is a reasonable thing to do with low risk and save the week of your life that would be required to figure out the correct legal status.

[tail wheel]

It probably also has something to do with how big you are and how much money you have.

I recall some fairly significant Australian "private" operations, including extensive operation of Gulstream, Lear and Bombardier aircraft, the operating cost of which would have been included in the price of goods and services sold by the owners. I am also aware some of those same companies bill the cost of aircraft operation to other companies who "utilise" (or charter) the aircraft under pseudo "share cost" arrangements.

There are also aero medical and Police flying operations which are deemed "private" but bill the aircraft cost to other client Government departments at very commercial rates.

[LeadSled]

Civil Aviation Safety Authority - CASR Part 94 (http://www.casa.gov.au/scripts/nc.dll?WCMS:PWA::pc=PC_93317)

CASA can't help themselves, the above is intended to spread a regulatory wet blanket across what are now mostly private operations, all without any justification for the intended rules --- There is, quite simply, no operational justification, let alone a cost/benefit justification, just another example of the CASA mindset that they have to "regulate to the greatest possible extent" -- the new phrase for an old obsession.

And it goes without saying, another jobs generator for bureaucrats.

It is interesting ( if you have nothing better to do - like watch paint dry) to look at draft CASR Part 136, Aerial Work.

There are 22 categories described as aerial work:
Five are incorrect categorization, they should either be private or "aerial application".
Eleven, at least, would be "private" under the US system, probably more.
Seven involve training --- which has its own Parts, and;
Two, take your pick, and;
This was a all to be completed and commence from January 2005 !!!

Tootle pip!!

[ramble on]

Is it not similar to privately licenced GPs flying themselves in their own aircraft to medical clinics in Australias bush towns.

Oh and the nice new high speed rocket was acquired under a capital expenditure tax exemption - all for work purposes of course.

[Rattlegun]

Is it not similar to privately licenced GPs flying themselves in their own aircraft to medical clinics in Australias bush towns.

Or LAME's flying out for breakdown maintenance with the spare parts (for trade)? Or Veterinarians flying station to station with the antibiotics, vaccines, steroids, etc. (for trade). Or mechanics flying out for field repairs with spare parts (for trade) the list goes on. Often these pilots operate on a PPL, and without an AOC.

It makes little sense to me that an AOC is required (to the extent of the scenarios outlined above) ONLY if the goods are the property of the Pilot, owner or hirer of the aircraft. You can carry exactly the same stuff if the goods are owned by a third party, without charging for the carriage, quite legally on a PPL.

Is there a good reason for this law (CAR206(1)(a)(viii)) that I have overlooked?

[thorn bird]

Rattlegun,
even McComic himself said Reg 206 was a cr..p regulation.
It has been used since back in the two airline days to suppress
general aviation. It is too useful to CAsA as a tool to interfere in
"business" to repeal or modify.

[JustJoinedToSearch]

It makes little sense to me that an AOC is required (to the extent of the scenarios outlined above) ONLY if the goods are the property of the Pilot, owner or hirer of the aircraft. You can carry exactly the same stuff if the goods are owned by a third party, without charging for the carriage, quite legally on a PPL.

So sell the goods to the customer beforehand and then either offer to send them via courier or just bring them along with you when you come up yourself - no charge.

You could argue that was a private op or just as easily (and probably more successfully) have CASA argue it isn't.

Quality regulations we have...

[LeadSled]

Folks,
Cast your mind back to a particular Assistant Director, in the early part of this century, who suggested that all pilots should be micro-chipped, like pet dogs.

Yes!! That "wonderful fellow" . Also at that time "CASA" proposed that "private flying" be redefined to limit it to "flying an aircraft by a pilot and the immediate members of his or her family for recreational purposes".

ALL OTHER what is now private flying, not just Part 92, was going to require an AOC.

One of the more lunatic proposals was that, if any aircraft was used for a purpose that enabled depreciation to be claimed for tax purposes, that was evidence of a commercial purpose, and therefor an AOC would be required. Wouldn't something like that cause an immediate demand for CASA approved chief pilots??

All part of the doctrine that is now called:"Regulating to the greatest possible extent".

And the really sad thing about all this is that the only reductions in accidents has come about as a consequence of the collapse in private and light business flying hours ---- if you delve into the statistics, this becomes very obvious. The "regulations" actually have a minimal impact on safety outcomes.

Tootle pip!!

[Checkboard]

More recently CASA secured a conviction against a private pilot who took photos of properties with a hand held camera from his aircraft then sold the photos.

What - like this one?

http://thumbs2.ebaystatic.com/d/l225/m/mKyJ2stucEnWFzC42SDK_NA.jpg

[tail wheel]

Checkboard, you missed my other comment:

It probably also has something to do with how big you are and how much money you have.

I think the guy that was done for taking and selling photos was a little guy in FNQ, which says it all really.

You can take photos from a private car or private boat and sell them, but according to CASA one can't do the same from an aircraft without a CPL and an AOC.

[Creampuff]

The fundamental mistake that people make is to assume the regulations that classify the various operations do so on the basis only of differences in objective safety risk. Plug a few scenarios into the regulations and it becomes quickly and abundantly clear that there are the tell-tale remnants of industrial/political interference in the rules. (That’s one of the reasons no one’s game to make rules that classify operations on the basis only of objective differences in safety risk.)

I can conduct agricultural operations for money, on a private licence without an AOC, provided the aircraft I’m operating is owned by the owner and occupier of the land on which I’m conducting those operations. If the owner of the land moves out and rents it to someone else who has the same farming expertise, or I want conduct the same operations on identical land next door, I need a CPL and AOC. Difference in objective safety risk: Nil.

I can fly Bob and his family around for money, on a private licence without an AOC, provided Bob owns the aircraft. If Bob sells the aircraft to John, and John lets me continue flying Bob and his family around, I have to have a CPL and an AOC. Difference in objective safety risk: Nil.

There are lots more, but it’s depressingly boring…. :(

[601]

Please don't ask CAsA for an opinion.
If you do we will never get the "new" regs up and running.

Just look at the "history" of "Aerial Baiting"
Until March 2003 it required an AOC. The "Aviation Ruling" 1/2003 determined that it did not need an AOC.
Then we had Part 137 in 2007 that capture "Aerial Baiting" under "Aerial Application." But that only applied to aeroplanes.

But wait, 1/2003 applied to aircraft so one could be in the stupid bureaucratic situation of being able to drop baits from a R44 in the morning without having an AOC to do so, but if the R44 went u/s, you could not do the same in your C182.

So CAsA comes out with an Instrument that has been rewritten several times since the first issue.

Rattlegun

So I doubt that CAsA legal section could give you a legal and binding determination on what you can or cannot do.

[aroa]

"Safety" operates thus.... This is CAsA's logic Ref R 206 and all that sh*te.

If you are a PPL chappie/chapess, AND a photographer, you may fly your aircraft , take photographs and GIVE them to your friends. Its quiet SAFE to do so.

But if professional** (or not) photographer who is also a PPL takes photgraphs and GOD forbid, SELLS them, them it is UNSAFE for you to do so and a danger to the travelling public and those that lie beneath the airways.
And many people in Oz have been stuck by falling aircraft,

**Making money from the taking and selling of imagery strangely enough is usually what Pro photographers do. Que? BUt for CAsA...NO NO NO :mad:

So follow the thought train of the regulatory numbnuts...Same pilot, same 'plane, same airspace,....BUT ITS ILLEGAL...ONLY if MONEY results at the end product. MONEY is a danger !!!! UNSAFE UNSAFE.!

Yes folks this is a capitalist democracy, where Polliwafflers of all persuasions keep telling us about our freedoms, and what a great country it is where we can all be free to do our thing and reach our own potential. Haha!

Pity they dont mention the Stalinist organisations like CAsA that execute folk like J Quadrio and others on a whim, or request of a "mate" /competitor company, or the just because some AWI has sh*t on the liver. :mad::mad:

The real name of this cuntry is Regulatastan...and you should be very afraid of any land than ends in ..stan eg Pakistan etc.

Earlier this year the current ceo (doesnt warrant upper case) re-iterated in a Senate hearing ""..again, CAsA is a safety agency, not a commercial regulator" Yeah, really...?????
I couldn't hand McCormick a shovel big enough for the sh*t that person spouts. :mad:

But his statement does make a mockery of the photography logic. Just ask all those that have been done over by R 206. :mad::mad::mad:

[Cactusjack]

Seems like it is time for us aviators to band together and just do things our way. It has become illogical to 'do the right thing' as this thread is pointing out in regards to aerial photography. So you know what? Don't get caught. F#ck CASA and its silly arse rules. Take all the photos you want. Take a mate or a family member with you who can assist, plus they can help you cover your tracks. Even better, pay them cash, that way you can stick it ip the ATO's ass as well. Do it on the sly, stealth like. Be sneaky, who cares anymore, the world and CASA have gone mad. F#ck the lot of them, make your own rules, it works for individuals at CASA, and to hell with Inspector plod and his Gestapo mates.
It's time we fought back in this country against the Stalin like hold that greedy business and Government is inflicting on us.

[Howard Hughes]

What if a pilot takes video and puts it on youtube? Video gets 2,000,000 hits and youtube give him a share of the advertising revenue, AOC required?

What if said aircraft was an RAA aircraft?

There has to be some common sense somewhere!

[aroa]

Someone put a video on You Tube ...and look what happened to John Quadrio !!!
Some CAsA clown sees it and thinks a "king hit" for the pilot is the go.
BIG safety issues involved, of course
Then CAsA' s "finest" get involved ...and its all downhill from there. !!!
For EVERYONE, esp JQ...and the taxpayer
FFS...what do these plonkers do for "brains" (sic).:mad::mad:

And with CAsA there is NO practical and COMMON sense ANYWHERE..it has been regulated away.

Is there any other country that has strict laibility for EVERYTHING, and prefaces its regs with...".A pilot commits an offence if...." ??:eek:

Cactus J...banding together should mean that the WHOLE industry just goes into "civil disobedience " mode and ignores CAsA entirely...and gets on doing its thing , safely and well. Its all that we have left, talking is past

NO more "expositions", manuals, Parts, edicts or instruments will be accepted, received or acted upon by the Industry UNTIL.....
Add anything you like to the list of demands

If such a doc was sent to any MInister stating that CAsA will be shut out until demands are met..SOMETHING might happen...??? :ok:maybe

If drastic action doesnt happen soon we will just continue to be slowly raped by regulation, without consent, as in the past.
AS WE HAVE ALLOWED.:{

[PLovett]

Quick and dirty answer:

2 to 5 are private, 6 is commercial.

Basis for that opinion is that 2 to 5 require your presence which is what you are charging for, the carriage, or not, of the computer is irrelevant in those cases. In 6 you are essentially setting yourself up as a freight service and therefore require an AOC etc.

The legislation is a nightmare and I doubt you would get a consistent answer from CASA or a lawyer. Similarly, I don't think the case law is of much assistance either as there has been such a mess of facts and decisions that it would be hard to get a definitive view from them.

[SgtBundy]

Devils advocate.

Assume we can start from scratch with a mythical rewrite of the regs - how do you define what requires an AOC and the associated saftey oversight that goes with it, and what does not? Should it be as simple as if you advertise it as a primarily aviation service (i.e survey, ag work, baiting, charter), then its a commercial operation. If you don't advertise it (i.e the aircraft use is incidental to the main business) the its private? Would that work? How do you cover businesses that then structure themselves to avoid the regulatory work to save a buck, but still perform essentially the same functions?

I would argue that when there is money changing hands oversight is needed - expressly for those that are willing to shortcut safety in the aim to save a dollar. Sure, the PPL sticking a camera out the window as long as they follow all the appropriate rules should be able to go about using their flying skills. But you can't divorce aviation and commercials without some sort of safety impact.

[Sunfish]

Sgt. Bundy, you do not "start from scratch and rewrite the regs", not ever!

There is no reason to rewrite regulations, it is a waste of time and money that might produce just as bad a cockup as today.

What you do Sgt. Bundy, is to acquire either a copy of the FAA regs or perhaps better still the New Zealand regulations (which are based on the FAA) and you install them in their entirety, if necessary changing Australian law to match the regulations.

This approach is axiomatic in business - you install a new system, you change your business practices to match the new system. "Customising" anything to match your "specific requirements" is a mugs game that has bought many consultants and advisors their second beach house, and I speak from bitter experience.

To do such a thing would require that CASA not be allowed anywhere near the process since they would immediately pervert the project to their own ends and 25 years and $300 million later you would have nothing recognisable or usable at the end.

What would be needed is an Advisory Board composed of industry participants, working to a very strong Parliamentary Committee, and then having a fresh drafting team of lawyers, preferably under the direction of Department of PM and Cabinet.

To do anything less simply opens the project to deliberate sabotage by lawyers, CASA and industry axe grinders.

Take the N.Z laws as they are and change as little as humanly possible. Dont try for any grand plan to reconcile the FAA with Europe for example, just concentrate on something that is simple and meets 90% of requirements, its trying for the perfection of that last 10% that costs the millions and takes forever. If there is some irreconcilable conflict between the new regs and the Australian legal system in that last 10%, then change the law, dont try and rewrite the regs.

The first thing that has to be removed is this "strict liability" crap otherwise the project is pointless anyway.

[halfmanhalfbiscuit]

Sunfish, good plan. The Swiss adopted EASA regulation despite not being part of the EU.

Casa mistake was mixing chalk and cheese. FAA and EASA based regs. EASA advised stick to one. Both internationally acceptable. Can't do half and half hence the 10% causing the issues.

[601]

But if professional** (or not) photographer who is also a PPL takes photgraphs and GOD forbid, SELLS them, them it is UNSAFE for you to do so and a danger to the travelling public and those that lie beneath the airways.

I wonder if Google Earth has an AOC for images it sells of Australia in Australia.

[SgtBundy]

There is no reason to rewrite regulations, it is a waste of time and money that might produce just as bad a cockup as today.

My meaning was as a thought exercise in clarifying legislation, not as a literal suggestion for something to be done. If you could, how would you define commercial and private aviation?

[aroa]

Bundy...were you not aware that the last 25 years of re write has been mythical and the waste of taxpayers time and money is legend. And all for what????
A Safer and more vibrant GA????

601... if Google had a head office in Oz no doubt CAsA would be stupid enough to demand one.
Its all safe tho, because if the Space Imagist drops his camera...can he do that?..no ..lets it drift away on a divergent vector, it will not make it to earth. Burn up ..as he would too.
No danger to the public there.!

Since it is asked ....
A Commercial operation would be one where a pilot conducts an operation that involves the carriage of fare paying passengers, as in CHTR, RPT.

A PRIVATE operation involves " a pilot, with his "tool box" etc ", NO paying passengers.
Oh my goodness, where have I heard that before ..ah yes 1997 Classification of Operations Policy adopted by the Minister and the Board ...and promptly ignored by the rusty "Iron Ring" and all those tossers in CAsA who really know what true "safety" is all about.
Its not about useful, efficient,workable, common-sense rules...its micro-management, convoluted, complex and confusing crap.
The more pages a Part...the "safer" it will be.

The last traces of the 1997 brain snap vanished off the CAsA screens in 2003.
And so we still have the "buggers muddle" of 206 and all the other nonsense that goes with it.

The impingment of light/photons onto film or a ccd has nothing to do with aviation safety, as does not, whether the computers, light bulbs are for sale or not, or the toolbox carrying the LAMEs spanners for work after the flight.
The "commerce" of photography, computer sales or light bulb installation all occur post flight and have totally SFA to do with the safety of the flight and is NOT and should NOT be the business of CAsA.

CAsA's business is that the pilot is duely licenced, the flight conducted by the VFR/IFR rules and that the a/c has a current MR.
Who has any problem with that ?

CAsA is a "safety" regulator (sic...very sick)right ?..., NOT a division of the Dept of Commerce restricting trade. Which it does ...and its probably unconstitutional. But dont let a little law and reality get in the way of the CAsA "safety" fundamentalist and control freaks. :mad:

Until we get those NZ regs Oz will remain the worlds leading Dogs Breakfast of Regulatory Vomitus. :mad:

[004wercras]

Leadie - Choccy frog for you, that is the post of the week. 9.5/10 :ok:
( I gave you an extra .5 for use of the term 'rusty' iron ring, very accurate and true).

"Safe skies are photon free skies"

[Dexta]

I was always under the impression that the reason for the "Commercial Operation" rule was because Private Pilots are not trained to handle commercial pressure, I.e. the flight must take off now, or we must get there by ..., I must carry x load etc. A photographer may want a specific shot at a certain time, you must be at a clients place at a specific time etc. All this puts pressure on the pilot. I personally think its bollocks, because any pilot can put pressure on themselves to "get there" or "I must go now". So my interpretation of a Commercial Operation is one were there is commercial/financial pressure or motivation to fly.
I think it should be though - Any operation were a person pays for a seat or cargo space for the purpose of a flight above and beyond simple cost sharing.

[LeadSled]

Folks,

Various of you talk about "adopting EASA rules".

Are you aware that EASA does not have a comprehensive set of rules, where EASA is deficient, EASA NAAs continue to use their "old" rules.

Where EASA has rules applicable to GA (not much) they are far more restrictive than here. For example, the great majority of executive flight operations, which most of the world treat as private operations, are Public Transport in EASAland, with all that means for cost and complexity, with no improvement in air safety outcomes, because there is not a problem to solve.

As the creation of a multi-national bureaucracy, JAA/EASA rules are, unsurprisingly, bureaucratic to the max, and very inflexible. Timescales to change rule are right up there with Australia, decades. Again, unsurprisingly, they are very expensive for pilots, operators, owners and maintainers.

EASA does have a set of rules for pilot licensing, they set such a high benchmark, even for a PPL, that many EASA nations now have a "National PPL". The PPL medical standards, alone, sets a ridiculously high standard, arguably higher than an Australian Class 1, with many additional tests not even required for a Class 1 in Australia. Regular Colour Vision tests are a particularly controversial matter.

A number of European nations now have a string of bi-lateral agreement to recognise National PPL licenses across national boundaries.

Forget EASA, the US is the way to go, the NZ version is good, but even that needs a bit of a regulatorectomy before adoption here.

Don't confuse "higher (more restrictive) standards" with improved air safety outcomes, the US (whether you want to believe it or not) is the benchmark for air safety outcomes.

Many of you will have seen yesterday's Australian, with a forecast of up to a third of helicopter flying schools closing because they will be unable to comply with the new rules, Part 61/141/142.

The rubbish CASA is churning out is a disaster, EASA is NOT the answer to that problem.

Tootle pip!!

[aroa]

WTF Dexta...what a bizarre and unusual "impression" you have of what it takes to conduct a flying operation. !!

Any PPL that I know does exactly what a CPL does in taking an aircraft from one place to another.

Both are licences to kill, if you do it wrongly...but the CPL can do it for money, THAT is the only difference.

Not aware that CPLs have any extra Commercial Pressure Training 101.
They either get the experience on the job, or if they are slow on the uptake killl themselves and a few others who have PAID to be with them.

I can assure you that if your planning and timing is right: ie.. dont be running late, have the aircraft and camera all prepared and ready to go the night before, wx is fine for the project etc, all is low key and good. Just fly and enjoy. No probs.

CHTR CPLs get the stress of bad wx, irate bosses, late pax who just HAVE to get there no matter what and etc. Or put THEMSELVES under pressure by poor planning performance and/or timing.

PPL photographers don't have any of that if they are properly sorted.
And if the wx is unsuitable for the project area...you dont fly. Simple as that.
And during the period when CAsA was on a mission, at great taxpayer expense to prevent "commerce" occuring, in FNQ there was a rash of 7 CHTR accidents and 21 fatalities !!
So you can see where THEIR priorites lie.
What about the STRESS those CAsA %!!%$£$"" can cause.! :mad::mad:
Now THAT is a major issue in GA.

[LeadSled]

You can take photos from a private car or private boat and sell them, but according to CASA one can't do the same from an aircraft without a CPL and an AOC.

Tailwheel,
Actually another wonderful area for weird CASA interpretations. Another in the Annals of Lunacy (aka CASA Official History), the proposer of the micro-chipping of pilots --- as anyone who went to the CASA FLOP (sorry, FLOT) conference years ago will remember -- the joker was very publicly asked if the bleeding great stud in his ear was a case of personally trialing his micro-chip, came out with the following wonderful "206 interpretation", which I probably still have in writing somewhere, the truly weird logic, but incredibly inventive, went something like this:

Aerial photography is caught by CAR 206, so;
(1)only certified aircraft can be used for aerial photography, because an AOC is required and, in his opinion only normal cat. aircraft can be used on an AOC, therefor;
(2)If you don't have a standard C.of A, it ain't a certified aircraft, therefor you can't use it as a photo plane, so;
(3)The aircraft in (2) can't be used in a photo shoot, therefor;
(4) All the air to air, over the years, with the photographer in the back seat of a Harvard/T-6 or a T-28, with the canopy open, were illegal, and;
(5) He was going to go through years of warbirds magazines, and go after those who committed photography from an aircraft that did not have a standard C.of A., and certainly were not working on an AOC.

With apologies to K-Tel: "But wait, it gets weirder", he also claimed, in writing, that you could only do air to air, if the subject aeroplane also had a standard C.of A.

The particular subject of his irettention was a great set of shots of the HARS Connie flying up and down the coast east of Wollongong,published in one of the local magazines featuring "warbirds".

Tootle pip!!

[aroa]

He of item (5) ..." going to go thru years of warbird mags and go after those who committed photography...."

Which is proof positive that the LOONIES really are out free and running the Asylum, and this tosser doesnt have a proper job and obviously has nothing to do and all day to do it in.:mad:

And we, the taxpayers have to fund these plonkers and their idiot missions..FFS!! :mad: :mad:

"safe skies are camera free skies"

How big is a photon?
Slightly bigger than the brain of a CAsA the magazine reader! :eek: