Part 61
Part 61 has been and still is a debacle.
When Part 61 was first mooted we were told/sold that it would be good for the industry in that all the various pilot licencing regs would be brought together in one user friendly easy to-go-to package.
We were also told that an intent was to get rid of all the various exemptions applied to the then current regs.
Can we put up 'Part 61. CASA' on Google to bring up the regs straight away. No
Have additional requirements been brought in the regs with the introduction of Part 61?
Yes.
Have exemptions been eliminated?
No.
I am advised that there are currently some 90 in the system and growing.
Then we had the situation where a few scant weeks before the planned introduction of Part 61 CASA advised that the introduction would be held over for a year 'because industry was not geared up for the introduction (of Part 61).
Industry? Should that have read CASA?
On top of that the Manual of Standards (MoS) was not ready and available for consumption until a few weeks before the introduction of Part 61.
The problems of the above can only be put at the feet of CASA.
With the introduction of Part 61 there have been numerous problems in the interpretation of the new regs. CASA staff have been on the back foot trying to get a handle on the rules and get back to industry. I am still waiting for a question or two to be answered. I do not expect a reply.
The CASA then proposed changing the basic operating rules in Part 91. Many people from industry rightly told CASA that it needed to get its house in order before it sailed into Part 91 and all the problems that would bring. CASA staff level was to be the same for both Part 61 and Part 91 queries. That means that staff would be knocked off their feet trying to answer Part 61 queries plus more from Part 91. If CASA could not answer all Part 61 queries how could it answer all the anticipated Part 91 queries?
Simply put it could not.
Putting on additional staff would not work as staff can take up to a year or more before they came on line. Besides, as I understand it, the public service has a government cap on head numbers.
In summary Part 61 was not totally thought through and all situations pre-sorted out before release.
What we really need is a statement in the CASA Charter, like that of the FAA, that says 'To Foster Aviation' instead of making rules that are not clear, need clarification, are hard to access, do not always make sense, have increased the financial burden on industry and even regulated some operators out of business.