Part 61 Letter from McCormick

[Ace on Base]

I received the informative proverbial part 61 propaganda letter in today's mail...... after reading it, I was quite excited to think that the CASA budget would stretch another bit and there would be MORE education session.... :D

Disheartened to see second last paragraph - "To give pilots a further opportunity to understand the new rules, CASA is holding additional information sessions on 21 October 2013 in six capitol cities.......":ugh:

Is it just my postman (I only live 1 hour drive from a major city, not in a back yard place like Boulia where the mail only arrives once a week), or is this a case of another mistake due to the rushed roll out of Part 61? Did anyone else get their letter today only?:ooh:

Keep Smilin' Sunshiners!

[Ultralights]

i got 2 copies! im special..

[Cactusjack]

Two copies is perfect, will work nicely as robust toilet paper.

[Ace on Base]

seems another case of LACK of PP&PPPPP.....:(

[LeadSled]

Folks,
The problem with the letter is that it reflects what was, perhaps, supposed to be in Part 61, but not what has actually appeared as a regulations package.

Even before Part 61 becomes operative, there is a substantial package of amendments which may of may not (depending on what the legal drafters of the Office of Parliamentary Counsel actually produce) address some of the issues that I believe Mr. McCormick does not believe exist.

His example of the commercial multi pilot may of may not be correct, depending on what else he may be flying, few GA pilots on fly one type, year in, year out.

As to not commenting during consultation, certainly the points I raised have not been addressed. Whether it is correct or not, I do not know, but a usually reliable mate says that, compared with the current rules, and comparing apples and apples, this package introduces 159 new criminal offenses, most strict liability.

Tootle pip!!

[601]

this package introduces 159 new criminal offenses, most strict liability.

What does that have to do with Safety:confused:

[Ace on Base]

fpvdude, too late for the meeting / training, it was yesterday (when I got my letter)....

Thats my point!

Keep Smilin' Sunshiners

[Con_G]

I must be even more special, I got mine on Fri 18th.

[Creampuff]

LeadSled

It would be helpful if you would identify, with precision by reference to the specific regulations, one or two of the “issues” intended to be addressed by the “substantial package of amendments”.

To assist, I will give you the sentences to fill out:
For example, the definition of […LEADSLED TO INSERT…] in Part 61 says […LEADSLED TO INSERT…], and provision […LEADSLED TO INSERT…] says […LEADSLED TO INSERT…]. The unintended outcomes of that include […LEADSLED TO INSERT…].
Consequently, the package of amendments changes provision […LEADSLED TO INSERT…] so that it will in future say […LEADSLED TO INSERT…].If you can’t or won't do that, the content of your post has no credibility.

[601]

Even before Part 61 becomes operative, there is a substantial package of amendments

.........Why:ugh:

[Up-into-the-air]

Still waiting for the letter and by the way Creaamer, FF just don't answer questions on Part 61 or say "..we will fix that later..."

[Creampuff]

... none of which prevents Leaddie from providing specific examples of the issues to which he referred. :=

[Paragraph377]

LETS GET READY TO RUMBLE.....
And so the battle continues.
This match is scheduled for one fall only. In both corners we have regulatory goliaths! One, content with providing solutions interspersed with the occasional 'tootles' and robust discussion, the other calling for defamation suits and removal of posts that may offend. Just like regulatory reform this game could be played out for years with neither party yielding to the other (a bit like the power struggle between 2 field office managers). Great entertainment for the masses. Will Creamy pledge allegiance to the CASA flag? Will Leadie confess to being an active member of the underground Ill Of Society sect like many other players on this website?
Will the two robust bloggers be forced to take their issue 'off line' and compete in a 'regulatory legal definition cage match', in which winner takes all (actually the prize is a copy of the very rare print version SPM), highly collectable due to its age and rarity, truly a seldom used item.
Will Leadie maintain a poker face while hitting Creamy with references to the 'Act', while Creamy retorts by demanding all correspondence from Leadie be put in a minute, Aleck style? Guest referees JMac, Truss and Xenophon will have their work cut out for them that's for certain.
Will the match be interrupted again by Casaweary in an attempt to gain referee Xenophons attention? The excitement is too much to bare my friends.

I'm putting a $50 on Leadie (3/1 odds) maintaining his current composure and winning the dual to the death. Creamy has already shown cracks in his composure and is currently ranked a not so robust 11/1 at this stage.

Continue gentleman, and no hitting below the robust belt...

[Horatio Leafblower]

5 marks for creativity, Para, but you have been marked down heavily for poor spelling (or rather, blind use of a spell checker).

Could do better if he tried harder. :=

[kellykelpie]

Just received my letter - too late for the info session! Not a good start...

[Creampuff]

Actually P337, I’m on Leaddie’s side, conceptually. But I know his fundamental weakness, as does CASA.

It’s his complete inability to cite particulars of specific issues.

It’s why he gets laughed off and dismissed by the regulator. I’d prefer that he didn’t. The lot of GA in Australia might have benefited more from his experience and unstinting efforts if he didn’t.

GA representatives speaking in scary generalities about aviation regulation has never resulted in any substantial change. Never.

[Jack Ranga]

Any chance one of you who got the letter could scan and post on here.

[dubbleyew eight]

I'm afraid Mr McCormic's letter read well but will be ignored.
I stopped listening to anything put out by CASA about $180,000,000 ago.
I dont care how competent some of the individual officers are, casa really are the clueless arseholes stopping aviation.

[Mail-man]

An extract from CASA's regulation impact statement pertaining to the implementation of part 61

"The implementation/transition phase will provide for Australia-wide education and training programmes to assist industry and CASA staff in the application of the new rules"

There was no "definitions" section in this document so "Australia wide" is ambiguous. I would suggest given the amount of confusion here it has been unsuccessful so far.

[Mail-man]

Fpv dude,
I would think to hire a twin (single pilot) and operate IFR the "cyclic" would have to have been single pilot op.

My question is, If they group ME <5700kg "class" aeroplanes together (i.e. no specific type ratings) would a renewal conducted in a single pilot "MEA" >5700 kg's (BE350/Metro) allow that pilot to act as PIC IFR on the aforementioned?

[-JLS-]

Any chance one of you who got the letter could scan and post on here.

Was about to scan it but noticed they've already PDF'd it on their website...amongst the 57,873 other pages they've piled in there to 'explain' the changes.

http://www.casa.gov.au/wcmswr/_assets/main/pilots/download/pilot_letter_signed_update.pdf

[Horatio Leafblower]

FPVdude,

I have just done a CASA online thingo and I have an ATO school tomorrow and Thursday on the new regs.

PPRuNe is not a good place to look up rules and you will get more mis-information on here than good oil, but I will have a crack at answering a few questions on Friday when I have received the Part 61 Enema.

Cheers

[SmoothCriminal]

PDP was great., there's a lot of learning
Smoothie.,.,.,:ok:

[ga_trojan]

Have I read it correctly where you don't need to keep a logbook after 7 years post the last entry?

For someone who has a 40 year career that is alot of data you don't need to have!

[Up-into-the-air]

Who Pays??

The following is from: http://www.casa.gov.au/wcmswr/_assets/main/lib100224/rr61_fs_flight_crew_training.pdf

New "notes" directed from the magic "TTTwwwIIItttEEErrr"

New requirements will apply immediately and in full to operators authorised to conduct flight crew training on or after 4 December 2013, including the preparation and submission of an exposition.

and a read I found:

49?s and the Star Chamber | Assistance to the Aviation Industry (http://vocasupport.com/?p=2199)

[CASAweary]

The only letter I want to see is Skulls resignation letter or a copy of his DCM letter, hopefully soon. But my guess is that Truss will give him a letter of commendation for all his work in aviation. TURDS.

The Skulls CV;

The 49ers Story - the Star Chamber (http://www.cathaypilotsunion.org/generaldocs/StarChamber.htm)

http://www.cathaypilotsunion.org/inthenews/SCMP12Oct08A.pdf

Get that into the Senate records boys. An apt description of factual events, and this bloke has been DAS for 5 years? The Government is a disgrace. ANd Mr Truss, so are you.

[601]

"TTTwwwIIItttEEErrr"
Is this now an official way of getting Regs?

including the preparation and submission of an exposition.

Once again we are being forced to have expositions written to reflect a mix-mash of CARS, CASR and CAOs.

An Operator will just finish this version and another Part of the CASRs will arrive on the scene. Then that will have to be incorporated.

Then getting it "approved"/"accepted"

At what cost??

[Creampuff]

ga-trojan said:Have I read it correctly where you don't need to keep a logbook after 7 years post the last entry?

For someone who has a 40 year career that is alot of data you don't need to have!The provision that worries me is the related one that says you commit an offence if you do not ensure that each entry in the logbook is retained unaltered throughout the 7 year period after the last entry was made: reg 61.355(2)(b).

Don't go changing that 4.3 to 3.4 when you realise, in retirement, it was an error!

$8,500 thanks.

So far as I can tell, the only way in which you're lawfully permitted to correct an error in a logbook is by direction from CASA under reg 61.360(3). Of course if you don't comply with that direction, you commit an offence.

$8,500 thanks.

Thank heavens for mother CASA to guide us through the incomprehensible complexities of log book entries. :ok:

[Up-into-the-air]

The following is the upshot of a long lived issue:

Star Chambers Findings (http://www.cathaypilotsunion.org/proceedings/FACV13_2011.pdf)

and:

Public Victory for Wronged Pilots. (http://www.cathaypilotsunion.org/inthenews/COFASCMP30Sep12.pdf)

[djpil]

I guess that adjustments to correct errors and omissions need to be done as new line items similar to financial book-keeping.

[thorn bird]

Expositions of course will not actually have to comply with the regulations, rather the"opinion" of the FOI of the day.

[Horatio Leafblower]

Chaps.

The following from today's Testing Officer PDP in Bankstown:

3 year transition period to go Part 141 or 142 or both. All current flying schools will be issued a Part 141 Certificate (not an AOC).

No sticky strips after December 4, all endorsements made by hand on your licence. All Flight reviews, design features etc written onto your licence. Back to the future?

CASA dudes confirmed that ATOs and CFIs and GA multi-skilled type people will need to do multiple tests and checks each cycle. There is one guy in our group who currently flies 9 different types that will be subject to type ratings and he will need to do 9 Instrument Proficiency Checks to operate them. Every 2 year cycle. Fkn madness. :ugh:

Add to that a proficiency check for his NVFR (12 months), his instructor rating (24 months), his Flight Examiner Rating (nee ATO approval) (24 months). His Type rating instrument checks (x 9) will cover his Multi Engine Aeroplane flight review, but he will need to do a SEA (Single ngine Aeroplane) flight review to exercise the privs of his SE class rating.

Co-pilots will have to complete a Multi-crew Coordination course to be co-pilots. This is the case not only on Multi-crew aircraft types but also for single-pilot certificated types. MCC courses must be conducted under Part 142 AOCs... anyone seen a 142 AOC? No thats right, there isn't any.

Good news: pilots with existing co-pilot time will be grandfathered. Bad news: everyone else will have to fork out $4k to get a MCC rating to work as a co-pilot. :ugh:

These Regs (despite McCormick's protestations) have not been adequately consulted with industry and have been pushed through despite their un-workability. The CASA people are tearing their hair out and shaking their heads. Older ATOs are deciding to call it quits. Those of us left are trying to work out how to survive in a very demanding regulatory world.

CASA seem to think we have nothing better to do than re-arrange our paperwork to please them. They seem to regard the industry as an obstacle to regulatory perfection - when in reality we are the only reason they exist.

Long day on the phone to my local member tomorrow :*

[Mail-man]

Horatio,
Do co-pilots on single pilot certified types get grandfathered in as well? Just another spanner for the works....

Madness...

[glekichi]

Regarding the multi-crew pilot (ATPL) wanting to do some single pilot stuff on the weekend - no, another check will not be required, as long as one has been done at some point (ever, not necessarily your last check). See 61.675

Recent experience requirements, however, include 1hr of flight time and an approach every 6 months. If that expires then I GUESS you need a check done or an hour of ICUS (or the new equivalent). 61.690

The single engine after a multi-IFR check seems to be a non-issue also.
61.695 allows you to fly an aircraft of a particular category. The categories are fixed-wing, rotary, etc., NOT single-engine/multi-engine.

61.695 (2) then prevents multi-engine fixed wing ops unless you've done the check multi-engine.

Its the strict liability stuff with logbooks etc that I'd be more worried about.. oh, and do I REALLY have to write VH- in the registration box of every single line in the logbook?

[LeadSled]

Horatio,
What you got at YSBK sound about right, glekicho's different interpretation just about says it all ---- "CASA" don't know what the package collectively means, which is something completely different to what the Part 61/141/142 documents were actually intended to say.

Creamie,
I don't see your point in setting up a "when did you stop beating yours wife" request/demand.
I am not personally proposing anything by way of amendments, just advising those who not have looked at the CASA web site of the amendment package.

Civil Aviation Safety Authority - CASR Part 61 - Flight crew licensing (http://www.casa.gov.au/scripts/nc.dll?WCMS:PWA::pc=PARTS061)

Personally, I think that the above only covers a small part of the problem. I have absolutely no intention of spending my time doing a rewrite of the package.


Tootle pip!!

[Sarcs]

Horatio you must have been talking to the same ATO as Paul Phelan...:rolleyes:

There’s also been serious unrest in the flight training camp about the current regulatory reform event: the activation from December 4 of CASR Part 61 covering personnel licensing, which certainly does appear to mean “different things to different people.”

Here’s the lament of an experienced (18,500 hours) instructor and flying training school operator that typifies industry concerns:


I have been told the following and think that if I understand correctly I will probably have the following costs. Given that I hold the following approvals:

Approved testing officer
Testing approval for instructor rating (or Grades)..
Instructor training.
Instrument rating testing
Night VFR rating testing.
Training of instructors for instrument rating training approval.
Training of instructors for twin endorsement training approvals.
Multi engine class rating.
Multi engine type rating.
Single engine class rating.
I am led to believe that all these items are going to have to be proficiency checks separately.


Costs involvedTwo day personal development program (PDP) – time preparing, attending and missed revenue
$2000
Multiengine training renewal – aircraft cost
$1800
Time lost for the above.
$500
Instructor rating, full day lost plus aircraft costs.
$1500
Examiner rating renewal – full day plus lost revenue
$1500
“Train the instructor” module (who knows how much?
$1000
Night VFR rating check – (who tests the ATO? – Who knows how much?
$1000
Single engine class rating check (who tests the ATO?)
$1000
Time lost with an examiner.
$500
Instrument rating approval check
$1800
Time lost with an examiner.
$500
Instrument approval training endorsement check.
$1800
Time lost with an examiner.
$500
Single engine class type rating flight review (who tests the ATO?)
$1000
Type rating proficiency check.
$8000


Total

$24,400

Amortised over two years – annual cost

$12,200

“Is this added safety, or is this bureaucracy gone mad? I actually hold these operational ratings, class ratings and type ratings, and I use them regularly.

“I test for night VFR. Do I have to be reviewed for NVFR expertise when I’m conducting tests and handing out these ratings on a regular basis?

“I fly single engined aircraft and check my instructors to line, I conduct instructor rating training in single engine aircraft, I pass instructors out into the industry in single engine aircraft. Do I really have to do a separate check for single engine class type?”

In her widely-circulated letter to CASA director John McCormick, this instructor has plenty more to say and plenty more questions to ask, and she’s far from being the only person who’s confused and frustrated at the unwillingness or inability of field officers to provide interpretations of these rules.

One question that is repeatedly raised, is where on earth CASA thinks it’s going to find flying operations inspectors or flight test examiners whose experience and recency is comparable with the people they will be testing?”

Another is the flood of amendments, which outstrips even Part 145, and the fact that the Part 61 MOS (where all the hooks and barbs will eventually be found to be buried) is still unpublished at a time when CASA is preparing for its Christmas break:

“CASA told us in Canberra last week that there were now 300 amendments to Part 61, so much of this might well be out of date. But the question is, “would 300 amendments have been made if a mass email had not gone out?”

“And how can one do anything about “consultation” when the MOS hasn’t yet been exposed to it?”

Nor can this flying school operator be accused of identifying problems without proposing solutions. She and numerous other flying school operators, both fixed and flutter wing, are highly critical of CASA’s apparent lack of attention to product quality sampling:

“Safety will not be enhanced by all these new regulations for a very simple reason; nobody in CASA is sampling the present apples in the system who are being let out into the industry en masse. By sampling, I mean going flying with the new PPL or CPL or new instructor or new instrument rated pilot within one month of receiving their licence or rating.

“The very idea of sampling the barrel is totally foreign to the CASA hierarchy which appears to me to be into compliance, more rules and more compliance and more obligations which just because they are written into the legislation means that all will be well!”

Regulatory reform not much closer – comment (http://proaviation.com.au/news/?p=1697)

Hmm...don't think I will comment might just :{ into my beer instead!:confused:

[Creampuff]

Ceamie,

I don't see your point in setting up a "when did you stop beating yours wife" request/demand.

I am not personally proposing anything by way of amendments, just advising those who not have looked at the CASA web site of the amendment package.

Civil Aviation Safety Authority - CASR Part 61 - Flight crew licensing

Personally, I think that the above only covers a small part of the problem. I have absolutely no intention of spending my time doing a rewrite of the package.QED (again).

[Mach E Avelli]

The experienced instructor who laments the $12000 p.a. costs of keeping all her approvals current will have little choice but to pass on those costs to her students. Somehow the students will find the money - if there are enough of them. If there are not, she would appear to have the choice of letting some approvals go, or copping a loss. Good experience going to waste. CASA needs to think about that.

Also, how many additional testing officers will CASA need to put on payroll to process all these approvals? Where will suitably experienced people be sourced from, if not the industry itself? CASA needs to think about that.

If they can't get enough people to do a proper job, those who do it will either be overloaded, or cut corners, or approvals will lapse. CASA needs to think about that.

Surely, if someone holds a Flight Examiner Rating to examine examiners, only two tests would be required in a two year cycle. One to determine the person's own flying ability in their most complex aircraft and another to determine on a random or cyclic basis that they still know how to properly conduct tests, possibly at the other end of the scale - such as a Grade Three Instructor being upgraded to a Two, or maybe a Night VFR test. Everything in between should be automatically included. You wouldn't test a brain surgeon in his ability to insert stitches.

[Up-into-the-air]

Yes MEV:

You wouldn't test a brain surgeon in his ability to insert stitches. That is what casa appear to require. After all, if you test more stuff, you get more money in, you force people to change an AOC's "exposition", more money.

Sorry bad UITA, stop being a cynic.

AND:

Oh yes No-one understands the regs - Need more people

[Paragraph377]

Part 61 and its frayed edges is becoming yet another example of CASA's disconnection with reality. A poorly constructed tangled web of stupidity. Of course it is easy for CASA to sit in an airconditioned office, draft some rules and regulations along with a policy or two then throw it out the window for us dogs to fight over. Executives sitting on half a million dollars per year (naturally some dont even have a pilots licence) and to them $12k or even $20k is just a drop in their ocean of opulence. But to the real man/woman living in the real world this is far from reality.
Australia has a real problem here. 25 years of incompetence, continuous mismanagement of all things aviation, a group of executives that are so out of the loop that they dont know an aileron from an oil gauge. A long term Minister who has failed his portfolio, and successive senior ministers for infrastructure who only ever see rows 1 and 2 on QF's Cityflyer.

Mr Truss, you have inherited one of the worlds largest aviation lemons. Are you going to eat the proverbial sh#t sandwich, display your robust coconuts and fix this Palaver once and for all, and finally? Or are you going to spend your last few years prior to retirement living under the microscope, as although industry is being raped mercilessly not all are going to disappear my friend, not in your lifetime. Until we see the changes required, including YOU personally listening to the Senators and acting upon the findings of their enquiry.
Time for you to stop being fed mushroom material from your Lieutenant, time for you yourself to get out there and see, smell and taste what has happened to this vital industry, and time for YOU to personally take hold of these issues and fix them. You've got your hammer and bag of nails, its time to hammer the last few nails into the coffin.

[601]

little choice but to pass on those costs to her students

With all the test and a 3 day audit thrown in, when will she have time for students?

[thorn bird]

What students?? their all in New Zealand!!

[GADRIVR]

A thought whilst doing nothing for 10-15 mins.
Heard a rumour that JMAC was at a conference no too long ago and was ripped into by a few individuals for various reasons over drinks who all had various agendas/problems with CASA.
The reply they ALL, to their surprise , (if you believe what you hear), got was "here's my card, call me next week, come to Canberra if you can or call me, and lets make this issue work/go away/get resolved",I believe you are possibly correct

Anybody take him up on it?

Just a thought.
DRIVR

[Cactusjack]

Don't bother phoning him as your number will probably be traced, analysed and logged in an IOS data base. Better off calling him and blowing an air horn down the line! Would love to be a fly on the wall at 0100 when that occurred. He would be somewhat testy about the entire episode :ok: Would be even funnier if his number ended up scrawled on the walls of all the Newfarm park ****ters!

[Kharon]

GA <funny you should bring that little episode up>.. Not quite the way I heard it; you are no doubt familiar with the old saw about how Swedish girls hold their liquor (by the ears). My source reports that a certain party forgot to hold onto the proverbial 'ears' and bollocked a visiting 'dignitary' who has, by all accounts launched, accompanied by a legal type to visit certain members of a Parliament uttering blood curdling noises which may only be silenced by financial or operational concessions.

Hard to know what to believe these days, init? - but it's good yarn for the BRB to kick off with this arvo; now those gentlemen know how a liquor should be held. Should be a great meeting with lots of juicy rumour to provide the hilarity required.....http://images.ibsrv.net/ibsrv/res/src:www.pprune.org/get/images/smilies/thumbs.gif

[ForkTailedDrKiller]

Got my letter today (25/10) - inviting me to an information session ............last Monday (21/10)!

I'm gonna get a new pilot's licence, apparently. That will be my fourth, or is it my fifth (?), different style of pilot's licence in the last 40 years.

As for the rest? Well I really don't know - it all makes my head hurt! I guess I will just go along to my friendly ATO (if such still exists) with aeroplane in hand and say, "Make me legal"!

Dr :8

[CASAweary]

Got my letter today (25/10) - inviting me to an information session ............last Monday (21/10)!
And you wonder why they can't regulations correct after 25 looooooooong years? Complete fools, Skull and Co even make Australia Post look efficient.
Hey John, you know what you can do with that letter old son.......
And all the current talk about a change of DAS, people climaxing over the appointment of Truss, it's all a smoke screen, all BS. Nothing will change, corruption and greed is the foundation of the CASA pyramid. Why not hire Joyce and Max 'more money in the bank' Wilting to run CASA, the quality, intellect and experience is about the same. Hell, bring back Toomey and maybe Shlong Sharp while you are at it.

Anyway, I am off to do some light maintenance on my plane before doing some circuits tomorrow. Catch me if you can Inspector Plod:mad:
Memememememememememe

[601]

friendly ATO

With public liability now, or soon to be, up to the ATO, they may be thin on the ground and even less thin in the air

[VR-HFX]

The Aya Toller and the Screaming Skull could each have held their farewell parties in HKG in a phone booth.

Not because they couldn't fly an aeroplane but because no-one else wanted to be in close proximity to them for extended periods.

CASA should cease appointing ex-airline pilots with inflated egos. A crop-duster with some grease under his nails would be a far better choice IMHO.:ugh:

[Up-into-the-air]

Always wondered what the real cost of the cyber-exam system was - a Saturday afternoon and found this information:

http://i1324.photobucket.com/albums/u608/vocasupport/casacyberexams_zpsaff30f40.png (http://s1324.photobucket.com/user/vocasupport/media/casacyberexams_zpsaff30f40.png.html)

Well about a Million a year - Wonder if Senator Nash can ask some further comments on this one - Another "Pete the Potplant" ??

[Paragraph377]

I wonder if ASSESSMENT SERVICES PTY LTD is related by chance to Sky Sentinel, and then any person at CASA or their family members or former acquaintances? Maybe an ASIC check would reveal anything interesting? Just curious, nothing more. And do either company provide pot plant maintenance services also?

[Sarcs]

Kharon post: Is the end of agony in sight? (http://www.pprune.org/pacific-general-aviation-questions/490723-merged-casa-regulatory-reform-12.html#post8119301) ...."When the NZ regs are brought in..."???:confused:

Love the optimism "K", maybe you know something the rest of us don't...:E

Got to agree with your comments though on NZ CAA vs FF CASR especially in regards to Part 61...79 pages vs 511: PART 61 NZ (http://www.caa.govt.nz/rules/Rule_Consolidations/Part_061_Consolidation.pdf)
PART 61 Fort Fumble (http://www.comlaw.gov.au/Details/F2013L00218/Download)

The Kiwis must be falling over backwards with laughter when their regs are contained within 500 pages and ours..well what is the last page count:confused::confused:.

The rumour (if true) that we could have received a template of the Kiwis' regs for a cool mil makes it even more diabolically embarrassing!!:ugh::ugh:

[Up-into-the-air]

I know this is an old one, but this may be all there is left for the ATO industry:

http://i1324.photobucket.com/albums/u608/vocasupport/ce34179a-6cf1-4c2f-90f6-22caa4577918_zps6073a0cf.jpg (http://s1324.photobucket.com/user/vocasupport/media/ce34179a-6cf1-4c2f-90f6-22caa4577918_zps6073a0cf.jpg.html)