LeadSled.
I’m impressed.
Because Mr Toller’s ramblings about the word “commercial” in subsection 27(9) of the Act and CAR 206 were redolent of your ramblings on the same subject – indeed, eerily redolent of the ramblings of the ‘Technical VP’ of a large aviation-related association – I expected you to attempt to defend the indefensible.
The tealeaf behind which the defenders of unauthorised ‘sports aviation’ flying training used to hide was that magic word “commercial”. The pretence was that if money wasn’t changing hands, or if it was just changing hands intra-association, it wasn’t “commercial” so need not have been authorised by an AOC.
Of course, the fact was and remains that lots of money changed and continues to change hands in ‘sports aviation’ flying training. It’s big business; very big business. So even if you take the view that the only flying training operations that could be prescribed were “commercial” ones, most sports aviation flying training was and is required by law to be authorised by an AOC.
But now even the “commercial” tealeaf has been removed. Flying training is an activity that must be authorised by an AOC, whether or not money changes hands. And that is completely consistent with regulation based upon objective risk.
Yet in the strange, reverse-logic universe in which aviation exists, the deletion of the word “commercial” is perceived by some as having the effect of both reducing the scope of operations that may be prescribed and assisting the sports aviation lobby’s position.
It is going to be very interesting when the amendments to CAR 206 that CASA has already decided should be made so as to exclude ‘sports aviation’ flying training from the AOC requirement, are blocked or disallowed. Whither the tealeaf then? (pun intended)
You should start the thread on insurance, LeadSled. I’m happy to contribute. There are a number of substantial impediments to the dire outcome that I used as an example and you seized upon. Among those impediments is that in order for compulsory insurance to be imposed upon all intra-state operations, each of the States would have to agree to corresponding amendments to its carriers’ liability legislation. I doubt that is politically achievable. In any case, the consultation process on insurance issues is being run by people with a little more integrity than those who are making decisions about sports aviation flying training AOCs. So you can lay down the smokescreen, and I’m happy to spray the dispersant.
Jjagungal
How do you know the AUF has an excellent track record in dealing with safety issues?
Where are the publicly-available hours flown, and accident and incident statistics? Where is the evidence of independent and objective investigation and analysis of the sports aviation safety record?
Methinks that youthinks the AUF has an excellent track record in dealing with safety issues, merely because the AUF says so.
I’m not saying it isn’t true; I’m just saying that an organisation’s own statements as to its own performance are not the only things on which a prudent person relies in making an objective assessment. And I’m far from being convinced that an apples-with-apples comparison would demonstrate that sports aviation flying training is any safer than ‘GA’ flying training. And if it would not, how can the imposition of an AOC requirement on one but not another be justified on safety grounds?
CFI: Don’t go muddying the waters by positing facts and applying orthodox logic. We all know that in theory the rule making process should include a cost-benefit analysis, which, by definition, includes an objective analysis of cost. But in aviation you apparently need only to consult with the beneficiaries of a proposed rule change, and you can accept at face value their bare assertions that the costs of complying with the rule if it is not changed would be unreasonable. And in the reverse-logic universe of aviation, there is no inconsistency in imposing rules for safety reasons on the one hand, then granting exemptions from those rules on the other.