Hmm..somewhat ironic how a lot of the antagonistic vitriol displayed over the last page and a bit could quite possibly have been sorted if the CVR/FDR had of been appropriately recovered...
Kharon:
However, back on topic the plus side, perhaps (maybe) is the 'flight category' impasse may now be sorted out. The CASA NPRM 1304 is a very good discussion (top marks), and some of the 2004 responses, supporting the CASA proposal present very attractive alternates to the existing system; have a read.
Agree
read it, IMO it is one of the better documents to come out of FF in a very long time. Sure there will be operators that will have reservations about some parts of the FF preferred option...
"
3.3.3 Option 3: Reclassification of Medical Transport flights as Air Transport operations
Helicopter and Aeroplane medical transport operations would be moved into the air transport classification and authorised by an AOC issued in accordance with Part 119 of CASR. Medical transport operations would be subject to the requirements of the applicable air transport regulation (i.e. Parts 121, 133 or 135 of CASR) and any overarching regulations from Part 91 of CASR, as applicable."
...especially amongst the smaller operators who have not yet implemented, or have the necessary resources to implement, a lot of the additional requirements of the preferred option:
The potential disadvantages of the proposed policy change include:
- Some operators may need to upgrade their organisational systems to meet the criteria of Part 119 of CASR.
- Some industry providers who conduct ‘ambulance functions’ as a secondary function may decide to move out of this sector.
- Some operators who do not presently have carrier’s liability insurance cover will be financially disadvantaged by the requirement to gain this for their future operations.
- Some potential for increased operational costs (over those incurred for aerial work requirements) may arise due to the specifications of Part 119 of CASR and operational Part equipment requirements12. For example:
- additional training and checking
- requirement for an AT level of aircraft equipment fit criteria.
From what I know of MT operators, most of what the FF PO contains have already been put in place by responsible operators that intend to enhance their business by adopting best safety practice etc. Besides which most aeromedical tenders automatically require these additional
compliance and relief considerations as conditions of the contract.
The other surprising thing about the NPRM is it is contained within less than fifty pages, is not wrapped up in legalese and is written in plain, readily understandable english...
From the writing of the NPRM there are also strong indications that Boyd (& the NPRM crew..
) have already consulted with certain heavy hitters in the MT sector (refer to, committee requested, late
Submission 20)....
...which would be very much in keeping with
Recommendation 12:
Recommendation 12
6.55 The committee recommends that CASA, in consultation with an Emergency Medical Services industry representative group (eg. Royal Flying Doctor Service, air ambulance operators, rotary wing rescue providers) consider the merit, form and standards of a new category of operations for Emergency Medical Services. The minister should require CASA to approve the industry plan unless there is a clear safety case not to. Scope for industry to assist as part of an audit team should also be investigated where standardisation is an issue. This should be completed within 12 months and the outcome reported publicly.
However the problem is that until such time as the current Iron Ring regime is exterminated, good well founded initiatives like NPRM 1304 will remain as thought bubbles only, or (if eventually actioned) will be so wrapped up in legal weasel words that it will be impractical & unaffordable for most MT Operators to comply...
Here is part of the current IRR policy for the classification of operations- (CEO-PN001-2004, 2009 version borrowed from
MQ AAI tabled docs as there is no FF version currently available..
):
Although in principle this IRR policy could indeed embrace the NPRM 1304 initiative, there is way too much wriggle room for the IR to obfuscate the matter in the interest of their ultimate master lurking in the shadows...
Ironically if the NPRM and the relevant CARs were to find their way to legislation, there should be no requirement for such executive policies...
MTF..
