This is a discussion paper only, so you have the opportunity to have these comments included to balance what CASA want
Do you think anyone in Australia will get off their arses rather than whinge & moan about CASA. The aviation community is pathetic in it's lobbying, if you call running to Dick Smith & begging him to get involved lobbying.
CASA have nominated some preferences which seem to me to mainly move liability from CASA to the people carrying out the service.
I certainly wouldn't like to be liable for something I don't control.
If you look at the Horsham crash and the workload of the pilot that day, and the decisions he made, you'd have to say AF has elements of commercial requirements.
Of course they have. Certainly not implied by them. I have no doubt that they don't imply any pressure themselves. Some pilots do a very good job of putting that pressure on themselves.
The ATSB report mentions ten North American organisations doing similar work and found one required a course to mitigate pressure and manage risk, one required all flights to be daytime VFR, and three required pilots to be instrument rated - all a bit haphazard, but being a DP you've got the opportunity of getting something sensible on paper. As someone mentioned there have probably been other incidents in addition to the Horsham crash.
All worth looking at. Why is it you all jump up & down (whinge, bitch & moan) rather than contribute to a discussion that can possibly make something safer & more accountable?