Here’s what I said about the issue of “community service flights” in my (published) submission to the review of Avmed:
A related and relevant point was made in the Canberra Aero Club’s submission in response to DP 1317OS – “Safety standards for community service flights conducted on a voluntary basis”. CASA’s response to a fatal accident during a community service flight was to propose, among other things, an increase in the standards and regulatory approvals required to engage in those operations. But the only rational way to decide whether to increase those standards and requirements and, if so, to what, was to determine the opportunity cost to society of the increase.
CASA could set the standards such that community service flights must be conducted only in transport category aircraft, to and from airports equipped with CATIIIC ILSs. When carried at that standard, passengers would be, comparatively, extraordinarily safe. However, the operation would be very costly and the flights would be inaccessible or useless to most of the population. Some of the vast majority of the people who miss out may be unable to access the required medical treatment to which they would otherwise have access, and die of their condition, or may die in a road accident trying to get to that treatment.
CASA could instead set the standards such that community service flights may be conducted in ultralights powered by motor mower engines, to and from any convenient paddock. At that standard the service would be, comparatively, very cheap and accessible to the vast majority of the population, but there would be many more accidents than if the standards were set at the other end of the spectrum.
The only rational way to decide where within that spectrum to set the standards is to consider, among other things, objective cost/benefit data across that spectrum. But CASA does not have or consider that data, and is not competent to make decisions about it, even if it had the data. Decisions about and balancing the risks to which society will be exposed, what counts as benefits to society and what price is considered reasonable for society to pay for those benefits, are essentially political decisions. That is why the aviation classification of operations regime in Australia continues to be a muddy mess, around 20 years after Commissioner Staunton recommended an “urgent” review of one of the fundamental definitions within that regime. That is also why the flight and duty time rules have been in a state of flux for even longer.
Therefore, it is not enough for CASA to say that an increase in medical-related incapacitation is, of itself, justification for CASA to continue to conduct general aviation medical certification, even if there were overwhelming evidence that there would be an increase [which evidence does not exist]. The benefits have to be ascertained and weighed as well.
As I recall the actual submission also referred to the nonsensical idea that a person would be prohibited from being exposed to risks, when on a ‘community service flight’, to which risks the person would be permitted and could choose to be exposed when flying ‘for fun’. Pilot: Josephine, I can take you and your son on a private NVFR flight from A to B for fun, but I can’t take you on a private NVFR flight from A to B if you are going to B to take your son for a medical test. Apparently the difference makes the latter flight “dangerous”.
And I see the good ol’ let’s-pull-it-apart-to-find-out-why-it’s-working-so-well cancer can never be killed.
But why would any private owner pull a perfectly running low time engine to pieces, when all of the vital signs like oil analysis, borescope compressions are perfect? Makes no sense at all. Requirement 2 is sensible for charter operators who thrash their high time 40 year old hacks to death. CASA seem to be acknowledging that CSF’s are Private operations... so why arent Schecule 5 and AD/ENG/4 Requirement 1 good enough? Many CSFs currently take place using these standards.... and NONE of the problems have been remotely linked to maintenance standards for private aircraft.
Well said, Cleared. But I disagree on one point: Requirement 2 isn’t even sensible for charter operators who know how to run their engines properly and do so, supported by evidence from monitoring “vital signs like oil analysis, borescope compressions”.
Overhauling or replacing a well-running, performance-monitored high-time engine is merely buying the risk of infant mortality - catastrophic failure early in an engine’s life. But, as is so sadly typical these days, CASA is proposing to make things “safer” by implementing a measure that will increase the risk of catastrophic failure. And despite objective evidence, of course.