Actual Cost Changes Complying with Part 61

[Dick Smith]

I have started this new thread hoping that we can get some factual information in relation to the cost changes that have taken place because of Part 61.

Can posters please state any evidence they have of any cost increases or decreases.

Perhaps if we can get a list going here I would be quite happy to talk to the Minister about this.

Of course, if there are any cost decreases they should also be shown.

If posters can also put an estimated amount of any cost increases/savings then we can get an idea of what this may be industry-wide.

[Honky Tonk]

With the part 61 licence I now have an MEA (multi-engine aeroplane) eliminating dual instructional type specific endorsements for most light twin aircraft. That is a huge saving potentially for either myself or an operator I could potentially work for. ICUS still costs money obviously but it would still have been needed even with a bare bones endorsement. I'm not going to do the math on every twin endorsement out there but a C310 goes for $665 and hour VDO. That's a good $1300 saving at least!!

[Dick Smith]

Great start - do you have an estimate what this will actually save you in a year?

And will it give the industry a saving in the long term?

[Honky Tonk]

Again hypothetically, a company might have three different types of twin A/C. B58, C402, C310. The operator wants you to fly all three. You came to the company with a B76. Someone has saved roughly $4500. Don't forget the money the government has saved in not having to process each endorsement.

Say said company paid for all these endorsements in the past(yeah right) and they had a turnover of 4 pilots a year. There's $13500 big ones.

[dhavillandpilot]

Interesting how someone thinks they are going to save the company money by encompassing all piston twins below 5700 under one endorsement.

Currently we are looking for a pressurised Aero Command pilot.

Sure we have had some really good applicants that the chief pilot is going thru, time permitting. However the number of B76 endorsed applicants applying is unbelievable - all of whom state they are endorsed via part 61.

The actual cost to get them up to speed would be in the order of $3000. Even a current AC500 pilot would need 2 hours, so where is the savings. Then you have to add in 10 hours ICUS to get them IFR charter.

My guess is the saving for say a pilot with 1500 hours TT, 700 twin flying a C402, then going on to a Pa 31 would be real. But in any case NO insurance company will insure a pilot without at least a check ride. Go to the USA and that is exactly what occurs.

[Dempster]

Surely people aren't under the impression that just because you are BE76 endorsed, that a company is going to let them loose on a 310, B58 or 402 because the law says they can. There won't necessarily be an endorsement, but surely there would be a familiarization flight similar to an endorsement.

[dhavillandpilot]

Unfortunately Dempster you would be surprised how many "aces" believe they now have a right to fly anything.

[thorn bird]

The problem Dick with part 61 is, so much of it will depend on what the FOI of the day interprets it to mean.
We have an allegedly Part 61 compliant Check and training manual written by a professional manual writer (ex CAsA FOI). The manual is actually an amalgam of three different FOI opinions.

Objective costs of simply giving a pilot a job based on what is required in this manual, thats for a pilot endorsed and current.

for a light twin around $15,000.

for a turbine (this ones a tad difficult as the regs are contradictory) but conservatively $20 to 25,000.

On a light jet such as yours $30 to 40,000

On a transport category jet $40 to 50,000

To upgrade someone from a normal category aircraft to a transport category aircraft, is difficult to determine there is very little guidance and nobody seems to know what the standards are but it means a whole new multi crew course, and a different IR rating. I know of one outfit trying to get a syllabus approved. Still waiting as CAsA advises they don't have the recourses right now, after two years and a lot of $$$. They were planning to charge around $8,000 for the course plus whatever the hourly rate in the aircraft or simulator you chose to do it in. The rating will only cover that type, so if you want to fly multiple types a separate rating will be required for each.

The conclusion I've come to is it will not be economic to operate more than a couple of types as your pilots will spend most of their time doing checks, and if your aircraft is at the high end of aviation travelling back and forward to the USA to complete them.

When part 135 comes in next year I believe there will not be enough part 145 approved maintenance outfits to maintain all the aircraft anyway, and there certainly will be a lot fewer customers who will be able to afford to charter.

Interesting that Aviation in New Zealand contributes almost as much to their economy as their dairy Industry, for the life of me I don't understand why we are throwing ours away, except for that famous line "If I had my way the only aircraft operating in Australian skies would be RPT and the RAAF"

[neville_nobody]

Again hypothetically, a company might have three different types of twin A/C. B58, C402, C310. The operator wants you to fly all three. You came to the company with a B76. Someone has saved roughly $4500. Don't forget the money the government has saved in not having to process each endorsement.

Say said company paid for all these endorsements in the past(yeah right) and they had a turnover of 4 pilots a year. There's $13500 big ones.

But then don't you have do a checkride on every type every year? Or are all <5700kg covered in one check?

[DeltaT]

This aircraft endorsement system sounds very similar to the way it is run in UK.
You still do a type rating on each (subsequent to the first of type) but there is no test required (persay) at the end of that rating because you are supposed to have jumped through the hoops on your initial of type. The way I used to remember it anyway. The real saving kicks in with currency eg previous 90days etc. A higher end aircraft counts for those similar or below it within similar type, so a flight in a high wing c180 will count for currency in c172, c152 for example. The caveat is the individual aeroclubs and organisations end up making their own rules a bit more stringent anyway, to try to reduce accidents and help with their insurance, and that goes in their ops manual. eg currency in a low wing doesn't count for high wing etc etc
Yes, <5700kgs single engine piston would be covered in one check, another check for <5700kgs Multi Piston, and you are covered as far as the annual check goes. But in a business operation you might cover that in a route check for example, or instructor or IR renewal. In your example of the 3 piston twins <5700kgs, you would still need to do some sort of type rating induction, (shorter than the initial of type rating), for a new person that is not rated, however any currency issues for all 3 would be covered by flying any 1 of them.

[Horatio Leafblower]

There is no real cost saving for GA twins - there is a requirement at 61.3xx somewhere that a pilot must take adequate steps (or similar wording) to ensure they are familiar with all aspects of the aircraft's operation, including emergency procedures.

That might, in practice, get pared down with time- but the CASA expectations described in the Airtex AAT hearing would be instructional for those seeking to cut corners.

I have also been told that - where we previously all did internal ICUS - under Part 61 we cannot do ICUS without a Part 42 (Multicrew and integrated flight training) AOC.

This means we will need to contract an approved organisation and approved pilot, at something over $100 per hour I imagine, to ICUS our pilots to a minimum of 10 hours on type.

Most decent companies do between 40 and 50 hours of ICUS with new pilots to ensure everything is covered adequately. This will be a significant cost or - more likely - result in operators seeking to reduce the training they previously provided their pilots. This would lead to lower operational standards, less standardisation, and arguably a decrement in safety. :ugh:

Seeking a CAR217 approval or a Part 42 Certificate - CASA have estimated $7-15k and six months.

The microscopic improvement in "safety" achieved by the new regulations is not proportionate to the regulatory cost burden placed upon the industry.

It is a crock of **** and it stinketh.

[thorn bird]

Horatio, having read through part 61 quite a few times, I'm not even close to understanding them, and the Moss is no help.

I don't believe there is anything in any of it that improves safety, in fact I believe safety will be compromised.

The added costs will severely impact on GA's ability to put out an affordable product.

We already have to suffer standardisation issues from the opinions of the FOI's, it will be even worse now, impossible to align with manufacturers procedures.

Of course CAsA could approve generic manuals which would take the FOI's opinions out of it.

The Ag guys tried that and there was peace in our time for a while. Unfortunately I believe that agreement has been broken now by the FOI's and its back to the old days of heated arguments and threats across the table. CAsA just cannot leave well enough alone.

[JAMUP]

Since we all are on the same page, Can I kindly ask these question on Part 61 ,

1/ Cost of training for CPL and towards ATPL ? will it go up ?\
2/ My main concern is the Flight Instructor rating , does anybody know any changes on this rating , perhaps the cost and hourly requirements?

Thanks

[Two_dogs]

Horatio,

Is there not provision to apply for an authorisation under 61.040 in accordance with 11.055? I thought this was the equivalent of the previously issued CAR 5.20 Approval to give training, and CAR 5.21 Approval to give conversion training. This would be a definite cost saving.

Admittedly, I am no Rhodes Scholar (one needs to be, lately) and I do have trouble making sense of it all. Despite having the several documents open at the same time for cross-referencing, (need more screens) I am no closer, but I do have a headache. :ugh:

After several readings of;
11.055 Grant of authorisation
61.040 Approvals by CASA for Part 61
61.150 People who may grant flight crew licences, ratings and endorsements
61.170 Grant of flight crew endorsements
61.180 How examiner, instructor or approval holder issues rating or endorsement
141.035 Approvals by CASA for Part 141
141.050 Part 141 flight training—requirement for Part 141 certificate or approval,

I thought one could apply for an 'approval holder' delegation and conduct training in-house. Probably still going to cost a shedload of dollars to produce ($1500), and get approved, sorry, accepted, ($15000) a course which shows show compliance with 61.040 (2)

Is this a correct reading of the legislation? Or would this scenario just be too practical?

[thorn bird]

JAM, the cost of obtaining an ATPL will increase significantly. You will have to do a Multi crew course, nobody really knows at present what that is, and a proficiency check in a transport category multi crew aircraft thats assuming you can find a part 142 organisation who operates transport category aircraft. Costs could be upwards of fifty grand because you'll need a type rating on the aircraft you do the test in. Much better and a hell of a lot cheaper to to head overseas if you want to learn to fly.

[Horatio Leafblower]

This ATPL business is a red herring. Yes, most airline recruits in Australia hold an ATPL but that merely reflects the unique pilot hiring market in Australia and our licencing system.

You only need an ATPL to act as Pilot in Command >5700kg, ie Multi-crew ops.

Multi-crew co-ord courses will evolve to be be similar to DG and CRM courses.

You won't be getting command >5700kg straight out of a Chieftain - you will spend a period as FO and your ATPL flight test will probably be part of the company's check and training system, incorporated into your command Check flight.

In 20 years of flying I know a lot of airline pilots.... I bet you NOT ONE of them was legally required to HOLD an ATPL on joining. (Company reqts notwithstanding).

The company will only put you up for command when you are ready for command and, logically, ready to hold an ATPL.

Lastly- remember that apart from the 100 or so pilots in GA who currently hold an ATPL, every new CPL is in exactly the same boat as you. Concentrate on getting the exams done and flying professionally, keeping your nose clean, building your reputation amongst your peers.

ONLY the most insecure, rich queue-jumping tossers would try to pay for an ATPL.

[Horatio Leafblower]

Thank you for that, I will obviously need to do some digging ...and not rely upon advice from CASA FOIs!

[Two_dogs]

Horatio,

Also see,
Subpart 61.U Flight examiner ratings
Division 61.U.1 Privileges and requirements for grant of flight examiner ratings
61.1255 Privileges of flight examiner ratings
61.1265 Limitations on exercise of privileges of flight examiner ratings—endorsements
61.1270 Limitations on exercise of privileges of flight examiner ratings—professional development
61.1275 Limitations on exercise of privileges of flight examiner ratings—recent experience
61.1280 Limitations on exercise of privileges of flight examiner ratings—flight reviews and subject matter proficiency checks
61.1285 Limitations on exercise of privileges of flight examiner ratings—examiner proficiency check
61.1290 Requirements for grant of flight examiner ratings
Division 61.U.2 Obligations of flight examiners
61.1295 Obligations of flight examiners—flight tests: strict liability offences
61.1300 Obligations of flight examiners—flight tests: other offences
61.1305 Obligations of flight examiners—proficiency checks
Division 61.U.3 Privileges and requirements for grant of flight examiner endorsements
61.1310 Kinds of flight examiner endorsement
61.1315 Privileges of flight examiner endorsements
61.1318 Limitations on exercise of privileges of flight examiner endorsements – flight tests in aircraft
61.1320 Requirements for grant of flight examiner endorsements


I think there is room to hold a flight examiner rating/endorsement (ATO approval?) without an instructor rating. I could be wrong.

[Sarcs]

Maybe Dick you should have a chat to Ken, it would seem he is currently conducting a similar but more general project within the AMROBA membership...;):Increasing Costs & Red Tape (http://amroba.org.au/images/association_news/Red_Tape_Increasing_Costs.pdf)

Recently some of our members have been bringing to my attention the massive increase in red tape and costs, costs that we find are far beyond what the regulatory service should cost. It is obvious that CASA has not yet come under the influence of this government. It is to be expected based on their track record to ignore previ-ous government and judicial recommendations.

Back in 2013, the LNP Aviation Policy stated that the Coalition would support the growth of the aviation industry by reducing red tape, reform the structure of CASA, establish a formal Aviation Industry Consultative Council and, among other promises, establish a high level review of aviation safety and regulation.

So far the government has only met one promise. The Forsyth Report achieved what had not been possible in the past, a government review of safety and regulation whose outcomes are industry supported. The govern-ment has issued Guide for Better Regulation but, based on what CASA continues to produce, the government Aviation Policy and Red Tape Reduction processes are being totally ignored. Red Tape Principles:

1. Regulation should not be the default option for policy makers: the policy option offering the greatest net ben-efit should always be the recommended option.
2. Regulation should be imposed only when it can be shown to offer an overall net benefit.
3. The cost burden of new regulation must be fully offset by reductions in existing regulatory burden.
4. Every substantive regulatory policy change must be the subject of a Regulation Impact Statement.
5. Policy makers should consult in a genuine and timely way with affected businesses, community organisations and individuals.
6. Policy makers must consult with each other to avoid creating cumulative or overlapping regulatory burdens.
7. The information upon which policy makers base their decisions must be published at the earliest opportunity.
8. Regulators must implement regulation with common sense, empathy and respect.
9. All regulation must be periodically reviewed to test its continuing relevance.
10. Policy makers must work closely with their portfolio Deregulation Units throughout the policy making pro-cess.

Why is industry still being subject to all the negatives that the Forsyth Report identified, and industry had also identified to the LNP prior to becoming government? - most now feel deceived because of the lack of govern-ment action. It is almost 12 months since the government was elected.

For instance, British GA will benefit from a GA system that will be closer to the FAR system than Australia, even though the non-airline sectors have been lobbying for the FAR system for the last decade. CASA consultation is a joke in that it does not listen to their own industry because "they know best" ????

CAA(UK) Red Tape Reduction program has commenced—it will be completed within two years.

The CAA(UK) Performance Based Regulation program will also be completed within two years.
For CAA(UK) future work there will be two guiding ambitions and principles:
deregulation and delegation to remove the bulk of GA from the current regulatory oversight of the CAA.

Since September last year when the government was sworn in, this industry has been patiently waiting for CASA to start to be seen as adopting and implementing government’s policies and directions. However, the industry has seen CASA continue with increasing prescriptive regulations and red tape.

Under the government guidelines, all regulations proposed and made during the past 5-10 years also need to be totally reviewed.
What I need to create is a submission to government with examples of recent costs for regulatory services. If any member is willing to provide me with the costs and the service provided that is seen as excessive, then I will collate as evidence of over charging.

Other government departments/agencies are working to reduce regulatory costs, if the principles were properly applied, not only would costs be lowered for industry but improved productivity would benefit all.
Ken Cannane
24/08/2014
It would also be worth having a chat with the RAAA who were apparently asked, or perhaps it was of their own initiative, by the PMC for input on the government RED TAPE REDUCTION policy:RAAA SUBMISSION CUTTING RED TAPE (http://www.raaa.com.au/issues/submissions/RAAA-Response-Cutting-Red-Tape-July14.html)

I'm sure the RAAA would be able to provide examples of costs before the Part 61 farce and the effect after, garnered from their membership of course..:D They may also be able to cut out the middle man and get you an audience in the big office...:rolleyes:

Before you do finally rock up with the evidence in hand to the miniscule or PM office, maybe you should have a gander at my post - Follow the links - 'Fat dumb but unhappy!' (http://www.pprune.org/australia-new-zealand-pacific/429828-merged-senate-inquiry-114.html#post8667362) - to get a sense of how our fellow ANZACs in arms went about and maintain their policy of nurturing & cutting costs to their aviation industry. This could provide a possible framework for the miniscule or PMC to work with in their future endeavours for RTP and hopefully to action (in reality) a PBR approach. Which apparently most of the other first world aviation countries are rapidly adopting..:D

Finally Dick don't go on your own mate, fill up your Van & take a crew along with you, you know safety in numbers & all that...;)

MTF...:ok:

Ps And if you want a DRAFT amendment for Part 61 drawn up...I know a bloke who knows a bloke that reckons he could get it done all legal within 2 days...:E

Pps Dick whatever you do time is ticking so get on with it mate..:{

[Two_dogs]

Ps And if you want a DRAFT amendment for Part 61 drawn up...I know a bloke who knows a bloke that reckons he could get it done all legal within 2 days...:E

I am not able to READ part 61 in two days. :yuk:

[c100driver]

Not really because that is how it has occurred in New Zealand for ever. We have always had a flight test for ATPL. It is held in-house by CAA approved Instructor pilots.

It has always been very difficult for someone not "requiring" an ATPL to do a flight test outside a Part 119 (121, 125) operator certificate.

Airlines have always had "ATPL subjects" not usually the ATPL itself in New Zealand for jobs.

[Tankengine]

The cost of flight reviews for many pilots will skyrocket. For example an Airline pilot with licence renewed under a cyclic training programme used to be OK.:ok:

It seems with the new rules that if they do a bit of light twin flying, and single flying, and a spot of floatplaning then they need to do a review in the twin, plus single, plus float, plus NVFR as they are different classes!:ugh::mad:

In the USA they need only one!

[neville_nobody]

As for your defence of an ATPL flight test "not being an issue", trying telling that to those poor bastards who now face the prospect of not even getting their resumes glanced at, due to not meeting the requirements.
What requirements? Like the multiple ones on AFAP that require an ATPL for FO and equivalent positions.

I agree entirely, the whole ATPL thing is now a gift to airlines who will effectively lock up the pilot labour market in Australia. No more will pesky FO's be leaving to the middle east or to Asia as they won't be able to.

Not really because that is how it has occurred in New Zealand for ever. We have always had a flight test for ATPL. It is held in-house by CAA approved Instructor pilots.

Out of interest does Jetstar NZ pay for the license upgrades of FOs over there?

Will CASA also relax the requirement for Long Haul FO's to have ATPLs now as well?

[c100driver]

Cannot answer the JQ ATPL isssue question with VH tails but with the ZK jet operations it is a sim ride. Very simple and is only about 2 hours in the bouncing box and a 2 hour oral on flight planning with part 121 operation questions. The operator pays for the sim time and supplies one of its ATPL approved flight examiners. The pilot just pays for the licence issue fee.

NZ has no such animal as a "command rating", a type rating is a type rating it does not matter from which seat you do it.

One ZK turboprop operator would not do the flight test unless you were doing a command upgrade. This because pilots used to just do the ATPL and then leave!

Long haul ZK the first officer is required to have an ATPL as when the PinC is off the flight deck they are SinC and required to supervise the SO.

[Horatio Leafblower]

So... These cadet types. All the arlines have them now. Are they going to stop training cadets?

...or are they going to upgrade them internally when the time comes? :confused:

Some of you guys are just dying to see the sky falling. calm the f*ck down and stop looking for extra drama. :rolleyes:

[training wheels]

Having worked overseas for a combined total of 6 years, and knowing the license requirements outside of Australia, before 1st September, Australia was one of the few places in the world where you could be issued with an ATPL without having flown a large transport category aircraft. It's no wonder the 'A' in our ATPL stands for 'Air' and not 'Airline' like it does in other countries.

The new system will put us inline with what happens in most countries with respect to gaining the ATPL. Perhaps CASA should consider bringing back the SCPL or Senior Commercial Pilots License for those who have passed the ATPL subjects and already have the hourly requirements, but still flying GA category aircraft?

[Clare Prop]

Student pilots no longer have to fork out and wait for a Student Pilot Licence. Also they don't need to get an ASIC until they are applying for the PPL.

[Car RAMROD]

I have also been told that - where we previously all did internal ICUS - under Part 61 we cannot do ICUS without a Part 42 (Multicrew and integrated flight training) AOC.I have been told this too. Only to be told that in-house ICUS was ok. Then told again it was not. Then once more that it was ok. All by the same FOI.


I still believe that it can be done, like everyone who wasn't CAR 217 etc did previously. It will reside with the Chief Pilot still as under the CAO 82 point something they have the C&T Responsibilities. If you look at the Part 61 reg, it doesn't say "Check and Training Organisation" which would equal a 217 or other cyclic organisation.


One more puzzling thing that has been brought to my attention is the fact that Synthetic Trainers approved under CAO 45.0 may not actually be, under the Part 61 regs, an "approved" device to use for instrument approach currency. Has anyone else come across this and been given or found an answer? I hope I'm actually current then because I use one of these trainers for approach recency requirements when they cannot be done in an aircraft!! This could be a massive impact on so many operators out there! Just about every flying school has one, not to mention some larger GA companies scattered around the country who use them for currency purposes.


The whole "which aircraft covers you for what" thing is as clear as mud. I can go fly the metro over 5700kg (which is a "single pilot type that requires a type rating") with a 2nd pilot on board because the client wants them to be there even though the rules don't need them there, but it supposedly will not cover me for single pilot IFR ops in say, the Baron or 310. So I have to make sure I do a flight that meets the criteria for currency in that type.
Previously, a renewal on a single pilot twin under 5700kg would cover me for the single pilot certified twins over 5700kg. Not any more! So here's another increased cost to us all. Instead of spending about 1000 bucks on a renewal, it's doubled or more.


Gaining Part 142 approval too. It's going to cost $30+ thousand dollars (not my estimate, someone else's).. Great. How are companies going to recoup this cost?


No matter how many times I try and read this new stuff, it doesn't get any clearer. Can they please be scrapped, and re-written over the next however many years in a way that we can all understand, please???

[DeltaT]

The NZ scene is a different kettle of fish regarding ATPL licences, so I wouldn't compare Australia to NZ on that basis. NZ has *one* big airline that hires once in a bluemoon so there has never been a demand for ATP holders, hence J* and JC based in NZ can't ask for it as they won't get it!
Compare the situation to Auz with so many jet airlines -and- turboprop operators there is a much bigger demand, and the system allowed for pilots to gain the qualification. Now they cannot without a struggle.
As for the ATP not being legally required for a FO position in Australia, let me remind you that 500Multi PIC isn't either, but everyone in Australia wants it regardless.
Unless you intend to slap every HR person silly, it will take until the market dries right up before those requirements will change, and thats if they do. They will probably start asking for more 457 visas instead!

[Arm out the window]

Good idea, Dick. I don't know what sort of relationship you have with the AHIA, but there is some bloody good discussion on the Aussie-specific rotary forum on this very subject, so if you're not already looking at that it'd probably be worthwhile having a gander.

Cheers

[Two_dogs]

Silly me, here I was getting wound up over nothing. 360 pages of complex legislation succinctly formatted into a 21 page A5 booklet. About 15 pages of content if you don't count the cover pages or graphics.

http://www.casa.gov.au/wcmswr/_assets/main/lib100191/part61booklet.pdf

I particularly like Part 1, Introduction, which has allayed all my concerns, followed by Part 2, Benefits at a glance, which made me feel all warm and fuzzy. So, no noticeable changes and benefits too boot.:yuk::yuk::yuk:

.

Introduction
All flight crew will retain their current flying privileges throughout
and following the 1 September 2014 transition. For most people,
the only noticeable change is that they will be issued a licence in
a slightly different format.


Benefits at a glance
›› Reflects best international practices. Your new licence document will be
ICAO compliant.
›› Safety standards will be lifted.
›› Addresses important lessons learnt from past accidents.
›› Training requirements will be more clearly defined

.

[Kharon]

The real acid test of part 61 will be reflected in the COM (exposition, if you will); after chief pilots and crew burning the midnight oil, tearing out hair, struggling to unscramble the 61 mess have 'rearranged' their manuals to accommodate this mares nest of a regulation. The 'trick' is to build compliance into the company system in a 'practical' manner. The benefits maximised, the dangers minimised. The thing keeping them awake will be 'subjective interpretation'. It is a serious flaw in this sloppy, complex regulation; you could drive a horse and cart through some of the holes. The irony is that the very people who espoused this confection will be the beneficiaries of industry efforts; firstly by using 'their' translation to generate multiple NCN and secondly, by claiming 'they' sorted out the wrinkles.

It is grossly unfair to dump a work in progress on industry, then malign industry as 'too fick' to understand it. It can only get worse as the extensions come on line, parts 121, 125, 135 and 142. Grown up rule sets make it clear that say for a part 135 operation certain things must be done and the prohibitions are clearly stated – easy stuff to deal with; the part 61 in concert with the 'operational standards'. Not so in Australia, the 'operational' rule sets will only serve to deepen the confusion, to chaos levels.

IMO, the only hope industry has now is to collectively and independently do what the Rev. Forsyth suggested, without government support or consultation with the clowns who drafted the regulation, have an industry consult. I don't believe it would be too hard to arrange a single point of contact to receive and collate the identified 'nonsense' areas of the regulation. Once the sticking points are identified, draft a report, clearly defining why 'industry' believes the regulation is 'bad-law' and how it may best be fixed. A unilateral declaration that 'we' unanimously reject part 61 and will not accept it until the errors are rectified may have more effect than numerous single complaints. The big issue is that industry allowed this rule set to happen. Consultation and industry say provided 'in hindsight', retrospectively may not be brilliant, but it's better than nothing at all. Much better than just meekly accepting this poor regulation and struggling to come to grips with the beast, now cast in stone as 'law'.

Perhaps Phil Hurst?, a University?, or Law society? etc or look-a-like competition winner (not AOPA) could host an industry single point of contact – email would work just fine. Grab a wordsmith or two and generate a report back to Truss; slide a copy to the Senate crew though (to be sure). It's probably cheaper, quicker and easier to kick the ball back to CASA than it is to continue trying to comprehend the incomprehensible and placing the AOC at risk. Part 61 as it stands is a devils playground for the unscrupulous, the ambitious and the vengeful; it is also a potential bottomless pit which will devour time, money and effort, for no return or improved standards.

I am certain that one or two 'experts' could be persuaded to donate some time and effort, in a worthy cause. Don't whine and grovel: fling the useless thing back at them or; learn to live with it. Two choices, no options.

Two bob's worth of just saying please...

[Howard Hughes]

Lastly- remember that apart from the 100 or so pilots in GA who currently hold an ATPL
I reckon there's a few more than that, I know at least 50! ;)

[triadic]

Dick,
The following questions must be addressed:

Has CASA conducted either:
a) A cost benefit analysis,
or
b) A safety case.

On the new Part 61

As far as I can see it is regulation for the sake of regulation with no cost benefit and no safety benefits over what we had before (??) Not to mention the time required to work it all out...

[thorn bird]

Triadic,

mate of course there is a "Cost benefit".

At $160 bucks an hour, mega bucks for all the approvals that will require FOI "Expertise" to decide what the "Law" requires and what it doesn't, CAsA being the beneficiary.

Someone has to pay for the Montreal junkets.(Wonder who's paying for the skull's "retreat" over there?)

The big question, does it make things safer?

Other than driving more people out of the industry by making aviation more unaffordable, does part 61 make aviation in Australia safer??

I believe Part 61 will make aviation less safe and a whole lot more expensive.

CAsA is a completely corrupt organization, apparently the minister has no control over this Authority, so we just have to get used to being milked, corruption is now government CONDONED in Australia...if you have any doubts, read Ziggies post!!

CAsA make Eddie Obied look like a saint!!

[triadic]

Someone has to pay for the Montreal junkets.(Wonder who's paying for the skull's "retreat" over there?)

Goss is that he has a job with ICAO ???

My use of cost benefit is to the industry, NOT, CASA.
I agree it will cost industry big time for no benefit or improvement in safety.

As I said, regulation for regulation sake:ugh:

[thorn bird]

Tell me it isn't so!!!

The Skull at ICAO!! :ooh::eek:

Good god man, pass out the tin hats. INCOMING!!:uhoh:

A reign of terror is about to be released upon aviation world wide..http://www.pprune.org/images/icons/x.gif

This could be worse than ISIL!

[Sarcs]

Warning: Bucket definitely required...:yuk::yuk:

From Steve MMSM today more spin & bulldust designed to placate one dopey miniscule:Aviation authority rejects complaints about new pilot licensing rules (http://www.theaustralian.com.au/business/aviation/aviation-authority-rejects-complaints-about-new-pilot-licensing-rules/story-e6frg95x-1227078213960)

THE Civil Aviation Safety Authority says it is conducting a comprehensive information and education campaign to get people up to speed on controversial new pilot licensing rules.

Operators of smaller aviation concerns have complained about confusion over the new rules, describing them as hard to comprehend, not backed by education, and contradictory in places.

Industry sectors such as flight training, helicopter operations and aerial agriculture lobbied hard to get the September 1 introduction of the Civil Aviation Regulation Part 61 changes delayed because they did not believe either side was adequately prepared.

But CASA, which had issued 570 Part 61 licences by Tuesday, rejected the claims.

“There is a wealth of information on the CASA website for pilots, flying instructors and flying training organisations,” a CASA spokesman said.
“We are progressively updating and refining this information based on feedback from the aviation community and the questions being asked.’’

The spokesman said there were currently 19 plain-English information sheets available covering topics ranging from student pilots through to flight reviews and proficiency checks, with three more about to be released.

These were short and easy to follow, covering the central elements of the new licensing suite.

A series of AvSafety seminars focusing on the new rules had been running since July, with 22 already conducted and 20 more planned.

The authority also did not believe the new regulations contained contradictions.

“However, we are always open to feedback and suggestions from people in the aviation community,’’ the spokesman said. “ If there are indeed issues relating to the new regulations that can be usefully addressed, we will do so. CASA encourages anyone with comments or suggestions about the new licensing suite to bring them to our attention.’’

The spokesman also disputed the claims that the new rules were costing more and said CASA was not charging people to make the transition. He said pilots who held a ­licence before September 1 were issued a new Part 61 licence at no cost when they notified CASA of a flight review or proficiency check, or they gained a rating or endorsement.

There had been lengthy and detailed consultations with the aviation community during the development of the new licensing suite over a number of years and there was an extended transition period of four years for pilots and three years for training organisations.

“The new regulations bring in significant improvements for the flying training sector such as the abolition of the student pilot ­licence, the inclusion of the recreational pilot licence and the wider use of the aircraft class rating system,’’ he said.

“It introduces greater flexibility, more options and a common structure for all pilot training. Under the previous regulatory arrangements there were many different and sometimes inconsistent arrangements covering training which are now streamlined and standardised.

“This makes the rules easier to understand and provides for better safety outcomes.”:yuk::yuk:
Hmm...it's all good miniscule we've got it under control...:ugh:

MTF...:ok:

[Kharon]

Hmm...it's all good miniscule we've got it under control..
Perhaps if everyone kept a log of the hours spent sorting out the CASA mess for them and invoiced Truss at CASA rates, a reasonable assessment of cost to industry could be realised; the fee for providing your expert advice to CASA could be charged double. I'd also be inclined to add on the cost of counsel, because to deal with any of the weasel word phrases, you will need 'expert' top cover. The legal eagles must be salivating, panting with lust for the upcoming fray. Save time, save money – tell 'em "put it where the sun don't shine".

And put in a submission to fire W2 – it's his pet project.

FFS...:mad:.:yuk:..:mad:..:yuk:

[Horatio Leafblower]

fpvdude,

Where is the confusion?



:hmm:

[J.L.Seagull]

Blower,

Umm... no! Look up CASR 61.075 and 61.080.

1. ALL of your time as a "pilot" counts towards your aeronautical experience.
2. You are a "pilot" when you are...
* flying solo
* receiving training
* instructing
* examining
* PIC
* PICUS

and...

* COPILOT!

It's all there in the regs!

The corn maze that is CASA's website is fractured, and full of half-updated information.

Things are different now, under part 61.

[Horatio Leafblower]

fpvdude,

my apologies for the smug and incorrect reply above - it appears I was entirely wrong. :ouch:

I can't find any reference in the regs to "Grand Total" or anything other than "Aeronautical eperience", and everything about "aeronautical experience" seems to include 100% of Copilot time.

After attending two testing-officer training days on this stuff over the last 2 years, I am blown away that this wasn't mentioned or highlighted as a major change. :suspect:

...what else?

[Horatio Leafblower]

ICUS allows an operator to do "line training" on their pilots.

It means a pilot who is FULLY QUALIFIED to perform the flight in every respect EXCEPT having 10 hours on type can do revenue flights, with a qualified supervisory pilot in the right hand seat.

My opinion only:
Nothing wrong with ICUS. A guy coming to me with 50 hours ICUS on type - assuming it's real legit ICUS - has more experience than a guy with a bare 5 hours on type. Assuming they are half good, it means we can supervise them for only as long as is necessary (which may be more, or less, than 10 hours) before sending them out on revenue operations solo.