The suggestion that CSF passengers are uninformed or even less informed than other private flight/ GA charter passengers is absurd. By the time CSF passengers board an aircraft they have been provided with written information and adequate time to make an informed decision on whether to travel by air or alternative means. This information is provided by the CSF provider & then verbally by the PIC. If a CSF passenger is still ‘uninformed’, it is by choice.
Proposed recency requirement- one landing in the type or class in the last 30 days. I only need 1 landing in the last 45 days to operate a widebody aircraft for an Australian HC AOC holder. The 10 widebody (type) landings I may have conducted in the last 30 days will apparently not count for recency for a CSF in my GA single engine aircraft.
The operational environment for a CSF pilot is benign in comparison to that of a working CPL holder. No employment threats, serviceable & familiar aircraft, the ability to cancel a flight without consequence, flights planned well in advance & no remote areas. To suggest that the experience requirements to operate a CSF flight should be higher than those required for a commercial operation is thus nonsensical.
The proposed requirement for piston engines to meet AD/Eng/4 requirement 2 (calendar life) defies logic. My piston engine is electronically data monitored, is checked & oil changed by a licensed engineer every 4 months, undergoes laboratory oil analysis 3 times/ year & is borescoped & compression checked every 12 months. To suggest that overhauling the engine simply to meet a calendar requirement defies logic. It merely puts the engine back into the high risk zone for catastrophic failure.
The CSF with which I am familiar has operated nearly 23,000 flights & suffered 2 accidents in 15 years. A sensible approach to improving safety would be to examine what the 22,998 flights have been doing successfully rather than impose a grab bag of untried limitations.
The proposed changes as documented conflict with the CASA fairness values. Decisions are to be risk based & evidence driven, both of which are absent from CD1814OS.
Well said.
The terms “absurd”, “nonsensical” and “defies logic” are justified in the circumstances.