More CASA obfuscation?
For the general interest of all flying school operators, here is a slightly redacted letter received today from Mr Skidmore of CASA.
Dear
New flight crew licensing regulations
Thank you for your letter dated 6 May 2015 which responds to my letter dated 30 April 2015 about the implementation of the new flight crew licensing regulations. Please accept my apologies for the lengthy delay in providing you with a response.
Your feedback is welcomed.
The concerns you raise about integrated training, the requirement for operators to hold a Part 142 certificate and the transition process are noted and will be looked into during the post implementation review process.
I would like to comment briefly on the subject of Part 142 and integrated training. Under Part 5 of the Civil Aviation Regulations 1988 (CAR1988), integrated training was managed by the Day VFR Syllabus. There were basic requirements for organising the theory and the practical flight training in a standard plan, which all schools were required to follow. All operators conducting training under that system needed to hold an Air Operator Certificate (AOC).
Also, the system didn't provide many opportunities for schools to develop alternative training programmes. The new flight crew licensing regulations make provision for greater flexibility in the management of pilot training as well as removing the requirement to hold an AOC for certain kinds of training.
The purpose of assigning integrated training, like type rating training, to Part 142 is to ensure the training is conducted according to certain principles. The benefits of conducting integrated training rely upon the training being delivered and managed in a structured and controlled manner, unlike non-integrated training, which can be managed in an ad hoc manner. This doesn't mean Part 141 training can't be as structured and managed; it simply means the Part 142 operator needs to have an exposition that ensures the training is managed according to those principles. The critical differences between Part 142 and Part 141 training lie in the training management system, safety management system, and internal training and checking requirements. However, these requirements should not be forcing operators to implement unnecessary complexity into their training systems.
2
I am aware of concerns about the performance of CASA amongst people in the aviation community and I am committed to addressing the issues behind these concerns. A structural review of CASA is underway and I will be making important decisions about changes to the organisation when this is completed. I agree with you that CASA's performance must improve.
Yours sincerely
Mark Skidmore AM Director of Aviation Safety
So Mr. Skidmore thinks that "these requirements should not be forcing operators to implement unnecessary complexity into their training systems". Well, with all due respect Mr. Skidmore, that is exactly what they are doing. In my view, there is no demonstrable safety case for forcing existing flying training organisations, who currently deliver integrated CPL training, to become Part 142 operators.
Should we hold out hope that Mr. Skidmore believes "that CASA's performance must improve"?
Over to the wolf pack now for your comments.