CASA Costly Low Flying Endorsement

[Dick Smith]

At the time I was Chairman of CASA it was decided by the management team that CASA would follow FAR91.119 re minimum safe altitudes for aircraft. This allows a fixed wing aircraft to fly at any low altitude providing it is at least 500 feet from a person, vessel, vehicle or structure, with a helicopter exempt from having to comply with the 500 feet rule in relation to a person, vessel, vehicle or structure as long as it can be done without “hazard to persons or property on the surface”.

However, since my time at CASA I understand that CASA has changed this to where it requires a special low flying endorsement – even for Recreational Aviation Australia ultralight pilots!

Just yesterday I was phoned and told that there is now a renewal requirement for the low flying endorsement. Can anyone advise if this is so? And if it is, is it six monthly, annual or biennial? Of course, all these costs add unnecessarily to general aviation and make us even less competitive with our overseas counterparts.

[Squawk7700]

Well Dick, it certainly looks like you are correct on the face of it, however I can't quite nail the exact requirement. Possibly you struggled like I did.

Learn about new rules for proficiency checks – in effect since 1 September 2014.

http://www.casa.gov.au/wcmswr/_assets/main/lib100191/rr61_proficiency_checks_fs.pdf

Whilst I can't find something that specifically mentions it, the following is located within the link above:

Do I need to do a proficiency check if I complete a flight review?

Yes. Flight reviews are not specified for ratings that require
a proficiency check. However, if you complete a proficiency
check in a particular type or class of aircraft, the flight review
requirement for that class or type of aircraft is satisfied by
completing the proficiency check.

An aerial application proficiency check satisfies the low-level
rating flight review requirement (61.1060).

If I've got this right, you need to conduct a proficiency check of your ratings?

[Stikybeke]

Dick,

You might find some of the posts by Yr Right within the last couple of pages of the Milton Jones threads quite tempting. e.g.

I will state again. If it's YOUR poperty you can fly over it below 500 feet. You need no vh rego no m/r no pilot lic nothing to do with RAA.

You may over your property use an aircraft for fire fighting if it's your own aircraft and if it's your poperty. You however May not use it over at your nabours place

Apparently he's read a regulation (which is not CAR 157) which (we think) gives him some guidance in this regard however, as usual, he's not sharing it which is unusual as (according to him) he's got vast legal experience and has given expert evidence in a matter or matters which he's also not sharing.

Enjoy,
Stiky
:rolleyes:

[no_one]

Dick,

There is a huge difference in how low level flight is treated between the USA and Australia. In the USA you can fly below 500 feet as long as you are not closer than 500feet to any person, vessel, vehicle or structure. You do not need a reason to be doing it you can. If you want to cruise up the coast of the Outer Banks of North Carolina at 50feet go for it as long as there aren't any cars(or people) on the beach.

The Australian rules are far more restrictive.
CIVIL AVIATION REGULATIONS 1988 - REG 157 Low flying (http://www.austlii.edu.au/au/legis/cth/consol_reg/car1988263/s157.html)

[Dick Smith]

I am told that under the old CAR5 low level training was a one-off and it was perpetual. However, under Part 61 the low level flying needs to be assessed every two years. Amazing! Imagine the cost of that!

It’s interesting – CASA said that Part 61 was to have no negative economic effect on the industry. It is clear that it is going to have a major economic effect and further destroy a once viable aviation industry.

As I have said many times before, it is all very sad and so unnecessary. Then again, I suppose if you work for CASA or for the Department you would say there is nothing anywhere that says you have to look at cost and as far as CASA and the Department are concerned, the more expensive it is, the fewer people who fly and so fewer problems. Remember that dishonest “Yes Minister” episode about the hospital with no patients? Well, that type of dishonesty has been carried through to the Department and CASA at this present time.

[no_one]

Here in black and white at 61.1060:

http://www.comlaw.gov.au/Details/F2014C01095/Html/Volume_2#_Toc399231173

[yr right]

-stikybeke

If you are going to dripple crap at least get it right. I have never said I have vast legal experience. What I did say if it's YOUR place. Which means you have legal entitlement you can do what you wish.

[mcgrath50]

yr right, your property is only the land, the air is not private property and therefore subject to the same regulations as your neighbours place. This is why it may be trespassing for me to land at your joint but not to fly over it. Your 'advice' is once again uttter tosh.

[QDMQDMQDM]

The 500 foot thing seems crazy to me. I am far safer in my cub at 100 feet over these east coast uninhabited beaches than 2,000 feet over miles of forest. Regulation for regulation's sake?

And if they're so concerned, went do they allow single engine into Banks town over urban Sydney?

[50 50]

Can we please stop yr_right hijacking another thread? For gods sake no one mention wind turbines or LAME's, or anything within 100nm of Crookwell.
Don't poke the idiot with a stick please, he will only sing.

[Stikybeke]

Fair call 50/50...

I was going to but on reflection he's never shared any of his experience regarding his evidence in court where he allegedly "took CASA on" and won regarding a maintenance issue so I'll put the stick back into the fire....

Stiky
:E

[601]

I am told that under the old CAR5 low level training was a one-off and it was perpetual

Under the old CARs or for that matter no CASA issued Low Level Certificate.
However, CASA could issue a Permit against the requirements of CAR 157(4)(b) with a condition that the pilot conducting operations in accordance with the provisions of the Permit had to undergo training as detailed the company OM.

As there was no training syllabus published by CASA as such the first 5 hours of the mustering approval syllabus was considered suitable and was either referenced as the syllabus or the syllabus included in the OM and a company "Low Flying Training Certificate" issued.

One could argue that this Certificate would only be applicable while the pilot was employed by the Operator as the training was in accordance with the Operator's syllabus.

In theory, a pilot who had an AG Rating issued under the CAO or the equivalent under Part 137, could not conduct a photography flight at low level as that pilot's training would not be in accordance with the OM unless the OM made provision for this.

I have not read or not am I interested in the machinations of Part 61.

I will leave that to those still active in the industry.

[LeadSled]

Dick,
Have you worked out yet the number of "flight reviews" and IR renewals you now have to do under Part 61, with your variety of aircraft?
Once you do, it is going to horrify you.
Tootle pip!!

PS: The way I read the low level requirements, you have to do 5h dual for each one. You can get a PPL in less hours.

[allthecoolnamesarego]

I am far safer in my cub at 100 feet over these east coast uninhabited beaches than 2,000 feet over miles of forest. Regulation for regulation's sake?

Not sure this is necessarily true. One could argue you are 'safer' at 2000' over the coast than at 2000' over the forest, but I think your argument is flawed.

Are you 'safer' at 100' over the coast or at 100' over the forest?
If arguing about height, you really should keep the other variables constant, otherwise your argument looses validity.

As to low flying. I think some people might be confusing low level 'cruising', ie a nice 50' jaunt up the beach, with 'low level flying', ie, mustering, Vallely flying etc.

I would argue that LL flying, requires the pilot to be truly 'in tune' with their aircraft and surrounds (WX etc), and as such does require some form of training.

To argue that you can Solo in 5 hours but can't low fly in that is distorting the argument. After 5 hours of flight, a student will fly at a safe height (except for the takeoff and landing bit :) ) where, errors in speed, G or general aircraft handling are more forgiving.

That luxury is not afforded at low level.

I am not arguing for any particular training scheme, or recurrency time frame, however, wanted to make the points above.

Statements of 'safer' or such, need to be examined.

Coolnames

[YPJT]

Ok so is there anyone with low level training approval care to comment on this? Particularly what will be required to satisfy review requirements

[Dick Smith]

Leady It will be five different renewals .

In the USA I would do one to cover everything - the yearly CJ3 single pilot renewal.

Fortunately I can afford this stupidity but it's clear that the commercial side of the industry will be in real troubles .

A huge increase in cost without one little bit of evidence that there is an existing safety problem!

[gerry111]

I'm currently reading James Holland's very interesting 2012 book:


"DAM BUSTERS. THE RACE TO SMASH THE DAMS 1943."


I wonder how many of those young 617 Sqn RAF Lancaster pilots would have passed current CASA low flying requirements?

[triadic]

It has been said.....
"A pilot passing Commercial flight test today would not have passed a Private test twenty years ago"

After flying with some newbe's I would have to agree. The standard today (with few exceptions) is poor. Trouble is CASA don't see it!!:ugh:

[LeadSled]

After flying with some newbe's I would have to agree. The standard today (with few exceptions) is poor.

Triadic,
If you are talking about the stick and rudder skills plus common sense, I certainly agree.

But the current generation can regurgitate often quite amazing volumes of regulation (whether they understand it, or not).

I could not have done the same thing, as a PPL, one reason being that the vast volumes of regulation simply did not then exist!!

As one particular Canberra based nincompoop said, at a consultative meeting: "It's easy to write safety rules, the problem is forcing people to comply with them".

This from the same branch as a fellow said:"As far as I am concerned, pilots and engineers are just criminal who haven't been caught yet".

There you have an over-simplistic, but nevertheless reasonable example of the core "CASA culture".

Tootle pip!!

PS: Anybody had a look yet at the new CAAP for Operations Manuals, it is so bad it makes Part 61 look concise, useful and reasonable.

[LeadSled]

In the USA I would do one to cover everything - the yearly CJ3 single pilot renewal.Dick,
Which is what I needed to do here, until Part 61.
Now the total for me is (at least) 6, and I can't afford it (even if I can afford the "new " medical test standards, it ain't just CVD).
Airline pilots who fly in GA are in for a bit of a surprise, when they find out none of their airline training and checks counts any more.
Tootle pip!!

[poteroo]

I have been conducting LL training under CAO 29.10 for the past 20 years. I hold an Instructor 1 and Ag2. I have considerable LL time doing surveys, tracking, and dropping - and these activities continue today. To date I have completed somewhere close to 90 LL courses of training.

Under the previous system, I was able to both train and 'test' for the training, (not a rating), because I was not required to hold an ATO approval. The trained pilot was not required to undergo recurrent testing etc, because the 'LL' was just a course. On the mustering or survey job, the pilot would be subject to the LL approved Operators training schedule.

Under Part 61, it appears I will require a FE,(ATO), approval just to issue a few LL's annually. I cannot see myself undertaking the training and costs just for this. I think this is how many older instructors will also see the future.

I have forwarded a detailed proposal to CASA which offers them several alternative approaches to this hastily conceived imposition. That was 2 months ago, and I have heard nought.

happy days,

[allthecoolnamesarego]

Would be interested to read your ideas. Any chance you could post some options here?

Cheers

Coolnames

[Stikybeke]

Poteroo

We can only live in the hope that CASA listen to what you have to offer.

Stiky:D

[poteroo]

I'll have my nurse read it to me:rolleyes: happy days,

[poteroo]

Options for LL Training

1. Include a couple hours in the basic RPL course - this may have the desired effect in convincing the student that it's a high risk environment and they should think before doing a beatup

2. Under Part 61 - allow those LL instructors who have a longstanding record of instruction to be 'delegated' or 'approved' to do the training, testing and reviewing. this avoids the FE issue,and also takes the pressure off existing FE's who probably don't want to do LL but may feel pressured into it

3. Under Part 61 - extend the renewal times to perhaps every 3-4 years. this will ease the burden of renewal compliance

4. Under Part 61 - cancel the requirement for LL to become a rating, and it then becomes similar to a formation endorsement where there is no renewal requirement. 90 day currency might be a more applicable limitation on LL. This allows all existing LL instructors to continue as at present.


There is no fundamental logic behind creating a LL rating. Pilots are going to fly low and continue to have accidents because they will not ever bother with a rating. If they don't queue up to undertake LL training under the current system - then they certainly won't under the Part 61 LL Rating.

The only people who might do the LL rating are probably CPL's who may use it to further their careers instructing or mustering. They are a more responsible cohort who would probably not have been involved in low flying accidents anyway - CAR or CASR system.

Why do we have instrument flying in the RPL/PPL? Correct, in part to perhaps save lives, but in the main - it's to demonstrate to pilots just how difficult it is, and perhaps prevent them from going illegal IFR.

The same approach could be used to reduce the LL incident/accident rate. Once pilots have a healthy respect for LL perils, I believe that this will make an improvement in the LL accident rate.

Making LL into a difficult to achieve and maintain rating is not the way to fix the problem.

happy days,

[aroa]

Low level flying WAS part of the PPL training done many moons ago. Effects of turn upwind or downwind in and out of the turn, setting up with slightly nose up trim, so if you relax a bit the aircraft will climb away from the ground etc. And as a hazard over water !
"Very good son, but when that fisherman standing up in his dinghy lay down I did get the impression you were wanting me to swim home. A bit higher if you will !"

Spinning was also on the agenda. But decades later new licences were issued and those things got wiped.."because we don't do that now".
So nothing on the record.

And since then those valuable lessons not taught or learned.:mad:

#1 and etc Excellent ideas poteroo. Back to the future :ok:

ps. Has there been a recent growth in low flying accident stats?