Mr Skidmore Letter on Part 61 - Don’t Mention the Cost!

[roundsounds]

Having just re-read the Regulation Impact Statement (RIS) it seems either industry or CASA has got it all wrong. According to the RIS the additional cost of gaining an ATPL was to be under $10K and Type Endorsements versus Type Ratings - no additional cost - merely an administrative change.! I wonder if the RIS was considered by the authors of the various MOS and the Flight Examiner's Handbook - if not why not? What's the point of creating a RIS, then ignoring it?
http://www.comlaw.gov.au/Details/F2013L00218/6b3523f0-4a46-4cd9-a6b9-358947eec395

[Dick Smith]

Most likely the RIS is a fiction. CASA has a track record of this. Note no individual names are linked to a RIS.

And $10k is a substantial amount. Was there any extra safety claimed from this change?

[roundsounds]

I agree, $10K for no stated or demonstrated safety benefit is totally unacceptable to any industry, let alone one on its knees. I went in search of the Part 61 etc RIS after reading your post regarding ADS-B. Surely there must be some accountability for these documents of fiction? Are the authors of the various regulations required to bear in mind the content of the RIS?

[LeadSled]

Folks,

The bigger problem with Part 61/141/142 is complying at all, at any cost, and the ongoing costs of keeping licenses current under the "new system" is horrifying.

CASA must be forced to comply with its own manuals and mandatory Government policy, including genuine cost/benefit analysis at the beginning -- and this need amendment to S.9A of the Civil Aviation Act 1988 to make it really stick. By the time you get to a RIS it is too late.

Tootle pip!!

[thorn bird]

Dick,
ever noticed that just when "rational" debate starts to develop, just as in your skidmore thread "certain" people turn up and the thread is locked.
Maybe you should have a cup of tea with our Aunty Pru, she rather likes rational debate.

[Dick Smith]

I and many others have received a letter entitled, “Update on New Flight Crew Licensing Regulations” from the Director of Aviation Safety, Mark Skidmore AM, in relation to Part 61.

Twice Mr Skidmore asks for feedback in relation to “what is working well and what is not”, however at no stage does Mr Skidmore mention that they are looking for comments on whether costs have increased because of Part 61. It’s almost as if the code within CASA says, “whatever you do, don’t mention cost”.

In his letter Mr Skidmore says, “I want open and honest feedback on what is working and what is not” - once again, no mention of cost. Presumably Mr Skidmore and the “Iron Circle” don’t want any comments on cost even though cost is the main problem with Part 61. That is, a substantial increase in costs when there was no safety issue to be addressed.

In Australia we share the wealth a lot better than most countries which means our average wage and our minimum wage are far higher, especially compared with places like the USA, Canada, the UK and New Zealand. For us to be able to compete in the international marketplace it means we have to be very much smarter and do things very much more efficiently.

Part 61 is, in fact, the opposite. It has substantially increased costs to many people in the industry and this means they will be less competitive in their businesses.

More to the point, money will be shifted from real safety issues to the Part 61 compliance costs when safety was not an issue.

[triadic]

I don't see any safety benefit whatsoever! So what is the justification?
Why is it such a large document, compared with other countries such as NZ?
Written by the lawyers no doubt?

What was the problem it is trying to fix???:ugh:

[yr right]

As with most things political. 10 minutes to make the change and a life time to understand what the change will do. The engineering licence system is now in complete disarray and know one knows where it's headed. A complete disgrace.

[poteroo]

Let's not miss the opportunity. Clearly CASA can now appreciate that Part 61 is lacking in many sections. This is industrys' chance for 'consultation' from a better bargaining position.

I've wasted no time in submitting a proposal to scrap the 'rating' out of Low Level Rating, and suggested a suite of associated changes which would improve safety.

happy days,

[Mach E Avelli]

Not just costs, but to comply with a set of rules, first one needs to comprehend those rules.
I recall attending a CASA briefing for testing officers in which we were told that instrument proficiency tests on aircraft over 5700 kg were type specific, ie an IPC issued for one type did not entitle the pilot to fly IFR on another type. Now I am told that is not so.
All that is required is that a Flight Review is completed every two years on whichever type I wish to fly, plus to fly IFR, an annual IPC on one of the types. So...I have a need to fly three types in a non airline environment. That is one IPC a year on any of them, and a review on each of them every two years. Or is it? My brain hurts trying to work out whether I would be setting myself up for prosecution.

When CASA officers don't know themselves, what hope have the rest of us?

Then the issue of examiner liability, now that we are no longer Delegates. Recently I had a very unpleasant encounter with a lesser official in CASA because he interpreted a rule differently to the way I did. He was half right, but a good lawyer would have equally said that I was too. I may have only avoided prosecution because at the time I was actually representing CASA, which is what a Delegate does. Under the new system, an Examiner enjoys no such protection.

This recent nastiness gives me good enough reason alone to drop out of the whole examiner scene (to cheering from some, no doubt). But I know others in the same mind, and they will be a loss to the industry. Perhaps industry should jack up and leave it to CASA to provide all testing. On second thoughts, maybe that's what they really want. To completely cripple aviation so that they can all collect their redundancy packages.

[Dick Smith]

In the USA the instrument rating is forever and requires no renewal. A pilot just has to comply with the recency requirements .

Yes. A BFR is required every two years but no instrument flight is required during the review.

Should we all move our aircraft to the U.S. register?

[Frank Arouet]

The Trans Tasman Mutual Agreement should make NZ a closer link to US type rules and an FAA pilot certificate.


My next jet will be registered in NZ. I may not have one yet but I'm trying.

[Runaway Gun]

Hi Dick, sent you a PM about costs affecting me. If you could get a chance to check it it out. Thanks.

[Captain Nomad]

Runaway Gun send your email regarding cost impacts to:
[email protected]

Quote from Mr Skidmore's letter (bottom para on page 1):
"...I need your feedback. While consultation takes place as rules are being developed, inevitably there are issues or unintended consequences that need to be addressed." (my bolding).

I would say that significant cost impacts could definitely be classified as an 'unintended consequence' that 'needs to be addressed.'

Of course how interested they might be in addressing that unintended consequence remains to be seen but if enough people submit feedback on that point you never know... 'The squeaky door gets the oil' - one can only hope...!

[lee_apromise]

In the USA the instrument rating is forever and requires no renewal. A pilot just has to comply with the recency requirements .

Yes. A BFR is required every two years but no instrument flight is required during the review.

Should we all move our aircraft to the U.S. register?

The best part is one has to re-do IREX theory should it go lapsed. :D

Seriously, why didn't they just do a copy-and-paste of U.S FAR Part 61? :E

Indonesia literally copied and pasted it and it works fine. :}

[ForkTailedDrKiller]

I just completed an IPC to revalidate my Instrument Rating under Part 61!

Cost wise - about the same as previously doing a renewal of my CIR.

Dr :8

[Mach E Avelli]

Forkie, I Dunno if you only fly privately, but guess that you do. A basic IPC is materially the same as the old CIR so quite rightly should not cost more....yet.
But consider the flight school that delivers the IPC. If they have instructors with multiple approvals, they have many more checks to complete. Not good enough that someone from CASA would come in and check various skills on a cyclical basis - ALL must be checked at whatever the stipulated frequency is. So stand by for your costs to increase when these imposts get passed on.
And pity the poor charter operator who wants a pilot to fly, for example, a King Air 200, a King Air 350 and a Baron. It would be nice to think that the 350 would cover the others, or that the 200 is close enough to a 350 that it doesn't matter and if you can fly a King Air you can probably cope with a Baron - but according to Part 61, it ain't necessarily so.
Yet the same set of rules means a pilot can do a tailwheel endorsement in a Piper Cub, followed the next day with an initial multi in a Duchess and then leap straight in to a Beech 18. Do not try this at home.

[Creampuff]

I refer to the Director of Aviation Safety’s letter dated 30 April 2015, inviting feedback on the new flight crew licensing suite of regulations.

As a preliminary point I note that the many stated aims of the new regulations have, over the years, included:
- “safety through simplicity”
- “harmonisation”
- “a less prescriptive, outcomes-based safety regime”, and
- “no exemptions” (because they would no longer be necessary in a simple, harmonised, outcomes-based safety regime).

The new regulations achieve none of those aims. In fact, they achieve the opposite.

The Dreamliner was promised but the Spruce Goose has been delivered. The people who paid and waited for the Dreamliner are now not only stuck with the Spruce Goose, but are expected to take seriously the suggestion that this monstrosity can be “continuously improved” into an even better Dreamliner, this side of hell freezing over.

I invite CASA to identify one provision of the new flight crew licensing regulations that has demonstrably caused an improvement in safety compared with the pre-existing regulations, at no cost or at a cost commensurate with the improvement.

I note that a person required to keep a personal logbook commits a criminal offence if the person does not retain the logbook, unaltered, for seven years after the last entry was made in the logbook: CASR 61.355. I invite CASA to describe one realistic scenario in which the throwing of a pilot’s logbook into the bin, 6 or so years after the pilot’s last flight as crew, would cause any material safety risk. Just one realistic scenario. (Hell, even an unrealistic scenario might shed some light on what’s going on in the head of whoever decided that making this a crime would contribute to safety.)

I note the exquisite genius of the confusion created by the convoluted complexity of the meaning of “flight time” in Part 61 of CASR compared with the definition of “flight time” in the 1988 Regulations. In the 1988 regulations, the duration of a flight starts when an aircraft first moves under its own power for the purpose of taking off. That definition in itself causes some chronically-unresolved issues. E.g. the PIC can’t give binding directions to PAX during ‘push-back’, because 309A is linked to the definition of ‘flight time’ in the 1988 regulations.

But now we also have Part 61, in which the duration of a flight starts from the moment an aircraft begins moving, whether or not under its own power, in preparation for flight. Does that mean I log PIC time from the moment I tow my aircraft out of the hangar in preparation for flight? If so, I’ve just increased my aeronautical experience by about 25%, by all the hangar door closing, head scratching, nervous weeing and paperwork I do before turning the key. Am I therefore 25% safer?

Of course, it’s not possible to understand what all of the new regulations mean, without knowing about and understanding the effect of the myriad of exemptions that may variously negate, alter or extend the effect of the regulations. Given that I realised, about 10 years ago, that almost nothing in the ever-growing piles of regulations and manuals and exemptions made much practical difference to the safe conduct of flying activities, I doubt whether I’ll ever be inclined to gain that understanding, or that my safety will be compromised by not doing so.

Importantly, I realise that many in CASA are among us poor passengers stuck on the Spruce Goose. Although lots of people blame CASA for the design of the Spruce Goose, I realise that CASA has neither the resources nor the competence to design a safety regulatory regime and, to the limited extent that CASA has come up with good design ideas, changes have often been dictated by people outside CASA - the government equivalent of the marketing gurus and the bean counters and the legal department, all of whom have irreconcilable demands and won’t be on the test flight.

But problems are difficult to solve unless there’s an understanding and genuine acknowledgement of the real extent of the problem.

The problem here is that the new regulations are a monstrosity, and no amount of continuous improvement is going to change that.

CASA needs to genuinely acknowledge and confront that problem, or it will continue to be part of and blamed for it.

[Arm out the window]

It’s almost as if the code within CASA says, “whatever you do, don’t mention cost”.


No it isn't! All silliness aside, if it asks about what's working and what's not, that could quite easily include whether the cost effectiveness of it is working or not.

Honestly, Dick, you are a bigger master of spin than Warney, or at least you use it a hell of a lot!

[ForkTailedDrKiller]

Yes Mach E. I do only fly privately these days but I was only giving my experience of Part 61. From my perspective, I can't see any real issues with it, but I gotta ask why the change? What was the problem with the "old" way?

I have always flown my renewals in the aeroplane and a typical flight was and RNAV appr, and ILS and an NDB appr (if I wanted the latter - which I never use anyway).

Under Part 61 I need to fly a 3D appr, a 2D appr and ensure I have covered a CDI indicator and an azimuth indicator in those if I want to use them.

Am I a better pilot because of Part 61 - No!

Am I a safer pilot because of Part 61 - No!

Not that I can see anyway - but hey, I know I only operate near the bottom of the piloting dung heap!

Dr :8

PS:....and if someone knows the implication of Part 61 on PIFR privilages - please enlighten me cause I haven't figured that out yet!

[roundsounds]

Below is a link to the document CASA used to get the Flight Crew Licencing rule changes through parliament. Read it and see if what we are paying now comes near what was forecast...
Start with an ATPL flight test - quoted as 2 hours @ $800 / hour.

http://www.comlaw.gov.au/Details/F2013L00218/6b3523f0-4a46-4cd9-a6b9-358947eec395

[Jabawocky]

Creamie, (POTY material by the way :ok:) as you well know, the problems lay in one particular area more than most. This also affects the standards folks and so on. the rot is uncontrolled.

I spent the day with a recent retiree of senior (very) ranks and even he describes JMAC's frustrations with the poor delivery of proper outcomes of the very department he was supposed to be running. I learned a few things that suggested he may well have been yet another victim of a systemic problem.

We all know where those problems breed……..like an infectious disease. A bit like Ebola for GA.

[Dangly Bits]

Can ANYONE in Australia do the ATPL flight test? Or do I have to go to the USA to get an Australian ATPL?

DB

[The name is Porter]

As with most things political. 10 minutes to make the change and a life time to understand what the change will do. The engineering licence system is now in complete disarray and know one knows where it's headed. A complete disgrace.

Finally.............yr right is getting his 9 year old child to type his post! Only two errors! :D

[The name is Porter]

Can ANYONE in Australia do the ATPL flight test? Or do I have to go to the USA to get an Australian ATPL?

DB

There have been significant changes in the FAA ATPL. Much more expensive but the requirements are clearly defined and there are courses that seem sensible. But I think you may be talking about anyone in Australua being able to conduct the test?

[Dangly Bits]

Correct. Is there a Part 142 school and a Flight Examiner that can conduct the ATPL test in Australia. I want my ATPL!

[LeadSled]

D. Bits,
Have you done your CASA approved Multi-Crew Cooperation Course (or whatever it is called), if the answer is yes, where did you find it?? A lot of people would like to know.
If not, the current apparent 100% lack of anybody to do an ATPL flight is not a problem.
Tootle pip!!

[aroa]

Porter...didnt your Grandmother ever tell you...

Never denigrate or criticise those whose language and spelling is not as perfect like your own.
They may have a disability or may not have been as fortunate to have the same education as your (brilliant) self.

[The name is Porter]

aroa, my grandmother died before she could teach me that lesson, (the other one was a drunk & didn't teach me anything).

And I wasn't denigrating him, I'm celebrating being able to understand his post.

I wouldn't call my education brilliant so I can't claim brilliance, I do however read a lot and try my best to continue my education, don't want to end up with Alzheimer's.

[Lookleft]

Looks like you have a secret admirer Creampuff. Apparently, those so outraged by their treatment on Pprune, keep coming back for a look because they are bored with the sound of their own typewriter. I bit like the silly old people who are so outraged by Alan Jones that they have to keep turning the radio off.

Shamelessly lifted form the UP boards.

There are some who can distil a sound argument into common sense. The inestimable "Creampuff" continues to provide a balanced point of view. Pearls cast before swine mostly, but I admire his wit, tenacity and logic. Shamelessly lifted form the UP boards, from the thread – HERE - :- Creamy – on song.

Maybe Kharryon will dedicate one of his stupid shantys to you. Anyway thought you might like a laugh.:p

[lee_apromise]

I was thinking a number of different ways to obtain CASA ATPL and this seems to be the easiest way and the most cost effective way as well.

For those holding CASA CPL and 1500 hours total time:
1) Go to U.S, pass FAA IR written, get FAA ATPL concurrently with a a type rating such as B737CL or A320. This will get you a FAA ATP with instrument rating.

2) Go to NZ, pass NZ IR written and NZ ATPL written tests. Rent a Air NZ sim (B737 or A320) and get your ATPL checkride done. AFAIK, instrument checkride and ATPL checkride can be done concurrently.

3) After you obtain NZ ATPL, convert it to CASA ATPL by just paying a small fee.

For those holding ICAO ATPL and working as a F/O in overseas: (This is what I'm working on)
1) Get 1000 hours SIC time (post-ATPL issuing date) on ATPL issuing state reg aircrafts.

2) Go to NZ and get a ATPL checkride after passing NZ ATPL Air Law.

3) After you obtain NZ ATPL, convert it to CASA ATPL by just paying a small fee.

[Captain Nomad]

And every single one of those options costing WAAAYYY more than:

Start with an ATPL flight test - quoted as 2 hours @ $800 / hour.

http://www.comlaw.gov.au/Details/F20...9-358947eec395

Especially after one factors in travel costs...

The cheapest of the options you have presented is for those working overseas as FO and who already hold an ICAO ATPL...

Besides, what kind of a country is it turning us into when we have to go offshore to gain a qualification...?!!

Glad this doesn't affect me but I feel sorry for anyone without a pre-Part 61 issued ATPL these days...

[lee_apromise]

@Captain Nomad

I beg to differ. And realistically no one will be able to get sim rental cost less than 800 bucks an hour in Australia. One can also bypass this stupid MCC CASA is introducing.

MECIR training done on a piston twin engine aircraft is more expensive than getting a FAA ATP. That's why I said the first option is for those without MECIR. But granted, one might have to do multi-engine rating and instrument rating done in U.S prior to getting onto a sim. But still hell a lot cheaper. But for those doing his/her training through VET FEE-HELP, it ain't working for them.

B737CL type rating costs only around $8K in Miami. Last time I checked, it costs almost $20K to get MECIR in Australia. Schools charge $20K for 20 hours of flight time and 20 hours of sim time. I mean, seriously WTF?

All due respect, as of now, airlines in Australia should drop "ATPL" as a pre-requisite for FO jobs. They should drop the minimum to CASA CPL + MECIR + ATPL theories + MCC (preferably not) so that type rating checkride is to be done concurrently as ATPL checkride. This has been the norm in the states and it is fair for everybody.

[triadic]

What is the problem this crap reg is meant to fix ????:ugh::ugh:

What and where are the SAFETY benefits??

Where is the cost/benefit analysis ??

The easiest way for CASA to fix this mess is to bin it and start again, using input from industry.

[Dick Smith]

Arm out the Window - the point I am trying to make is that anything CASA sends out at the present time should be linked to what is the industry’s major concern and that is a one-way ratchet in the increase of costly regulations for aviation - especially when there is no safety reason for this one-way increase in cost.

Haven’t you noticed that Mr Skidmore is not game to actually mention this important fact? Why wouldn’t his letter say, “many in the industry appear to be concerned that Part 61 has increased costs when they were told this would not be the case. If you have any evidence of costs being increased, please advise.” Now that would be worthwhile! But it’s interesting, he doesn’t actually say this. Nor does anyone else within the “group think Iron Ring” actually get on top of this most important issue.

Then again, there is nothing with the Civil Aviation Act that says they have to look at cost, so I suppose they won’t.

[Dangly Bits]

Leadie the MCC seems to be problem #1. No one can do that either!

Looks like I'm heading to the USA to do their ATP CTP, then the Written Exam, then the flight test which is a 2 crew IF initial really! (In a Duchess if I want to!)

This is crazy!

[ozbiggles]

You would have to be thick not to understand that you could include that in the feedback...IMHO. Of course it is a great excuse for another whine.
A few threads could be merged here I reckon.
PS not defending part 61, how could you...but I think we all get it.

[glenb]

I had to go into the Regulators office the other day. I had some licencing and transfer documentation I had to attend to.

I was greeted at the front and directed to my appointment exactly on time. The place had a bit of a buzz about it. Much like you might find in Private Enterprise. The forms were all so easy to fill out. I had a couple of potentially difficult questions. The two staff at the counter were obviously very knowledgeable about the rules and regulations and addressed them succinctly. Very obliging as well. The whole well informed, clearly understood requirements made such a good impression on me. As I exited the building after my seamless experience somewhat ahead of schedule, I turned and went back in side. It was quicker, less painful than I anticipated, and somewhat cheaper than I feared. I thought I must pass on my sincere appreciation. I go in there regularly, and it always operates in such a manner. The staff were very happy to receive my positive feedback. In fact they had the Area Manager in the building and I got the opportunity to thank him, and in fact I followed the whole process up with a letter. How could they all be so happy and efficient. Constantly dealing with licences, safety, rules, regulations, maintenance etc. Yuck!

Anyway I am so sorry to tie up an Aviation forum but I just wanted to pass on my congratulations, thanks and sincere respect to VICROADS. Cheers

[dubbleyew eight]

like all of us in aviation I started out responding to the NPRM's and found consistently that all suggestions were ignored totally and CAsA just went along doing whatever they wanted.

so about 10 years or so ago I decided to totally ignore all suggestions demands and legislation coming out of CAsA.
I have in the last decade or so done all the maintenance on my own aircraft and gone out and flown regularly.
I have totally ignored all CAsA requirements.

was I unsafe? never.
my aircraft is now a vintage homebuilt, it first flew in 1985, it is in better condition now than when I first flew it.
it cruises 15 knots faster. the engine runs absolutely to the numbers and I no longer pollute the air with lead residues.

When I got Skidmore's letter I was tempted to give an honest response.
Why bother?
The system for the past 15 years has been going so far off the rails that it is pointless even bothering to comment.
as just one example the much vaunted biennial flight review has now caused 6 deaths that I would wager would not have occurred otherwise.

The CAsA system is totally fcuked.

The things that really would improve safety haven't a hope of being introduced by these clueless incompetents.
They are so engrossed by their ex RAAF memories that they will never listen to common sense.
So we are stuck with their system if we care to be legal and it doesn't work.
All CAsA ordained maintenance ever does is see to a slow inexorable decline in the airworthiness of aircraft maintained under the system.

In terms of flying competence the new approach is one of fear uncertainty and doubt where before a pilot used to develop a sense of mastery of the challenges and some competent risk evaluation skills.

Sorry Skidmore but the best thing you could do with CAsA is shut it down completely. it does not create a safe environment and it does not engender competence.

[Arm out the window]

Arm out the Window - the point I am trying to make is that anything CASA sends out at the present time should be linked to what is the industry’s major concern and that is a one-way ratchet in the increase of costly regulations for aviation - especially when there is no safety reason for this one-way increase in cost.

Fair enough, Dick, I understand one of your common modes of operating is to generate outcry and discussion to stir up a bit of reaction which is better than apathy, I just can't help reacting to the overt spin you use to do it! It's how the world works in these days of the sound bite and media grab, so fair play to you if you get what you set out to get.

Still, the letter from Skidmore basically says 'if there's anything you think is wrong with what the new regs, tell us', which to me clearly doesn't need a specific mention of the cost factor. If he said in Colonel Klink style 'Dooooon't mention ze cost!' then that would be a different story!

[SIUYA]

...there is nothing with the Civil Aviation Act that says they have to look at cost, so I suppose they won’t.

Maybe not Dick, but Truss' Statement of Expectations for the Board of CASA for the Period 16 April 2015 to 30 June 2017 includes (amongst other things) an expectation that CASA will:

...consider the economic and cost impact on individuals, businesses and the community in the development and finalisation of new or amended regulatory changes.

Whether they do anything as a result of those considerations seems unlikely though.

:ugh:

I also refer to the recent statement by Mr Skidmore:

My aim is to establish a common understanding with the aviation and wider community about how we will continue to deliver optimal aviation safety outcomes, while responding to a dynamic and growing aviation industry.

Source: Civil Aviation Safety Authority - April (http://www.casa.gov.au/scripts/nc.dll?WCMS:STANDARD::pc=PC_102483)

How can you continue to do something when you haven't yet started to do it? :confused:

[Sunfish]

AVM Skidmore allegedly wrote :“I want open and honest feedback on what is working and what is not”.

Unfortunately, AVM Skidmore, the AAT and airfields and suchlike are littered with the bodies of people and businesses who had the temerity to give "Honest feedback" to CASA.

I suspect that almost all pilots with the experience to give valuable feedback would not wish to do so for the simple reason that they will be labelled as a trouble maker by CASA staff and earmarked for vengeance.

To put that another way, your feedback will be transmitted, along with your name, to the very person who wrote the regulation. You will not be thanked.

Sorry AVM. Skidmore, unless CASA is broken up nothing will change.

[Spinner73]

With the benefit of, ohhhh minutes of experience behind me, I think the entire Part 61 debacle can be wrapped up - with some minor alterations - by the quote from Chet Beates' tome regarding Political Correctness.
"A doctrine fostered by a delusional, illogical minority, and rabidly promoted by an unscrupulous (mainstream media) Governmental department, which holds forth the proposition that it is entirely possible to pick up a turd by the clean end."


Seems quite apt, and there would appear to be a fair bit of overlap...
I also note that, while the impossibility of turd-polishing has been proven time and again, there remain those expert in the rather specialised field of rolling them in glitter and sticking lit sparklers in them.

[woodja51]

I sent a question to CASA some time ago but nothing back as yet.

Maybe someone out in pilot land has an idea?

If you are a GR1 instructor and are rated on , for example an A330 , can you provide type rating endorsements onto the aircraft in the same way that a GR1 instructor with a formation, aerobatics or other design endorsement ( like pressurisation/retract etc) can do with those aspects under the new regs?

My point is , as a current A330 captain with a GR1 rating , what is the difference training someone on either a small or big aircraft? Assuming I had access to a sim and used the airbus syllabus, what if any are the hurdles??

I was under the impression that this was the whole reason Part 61 was cranked up - to allow qualified pilots with suitable instructional skills to provide training for the industry and reduce to requirements for CASA to do it.

Or is a big aeroplane different to a little one in the regs?

Thanks for any input in advance.

wja

[Mach E Avelli]

If only it were that simple, but thankfully it is not. Otherwise the aero club mob really would take over all checking and training right across the board.
They certainly appear to have had considerable influence in CASA in drafting Part 61.
Your FE rating would need to specify the type e.g. Flight Examiner A-330. And probably somewhere it would say words to the effect 'simulator' or 'aircraft' to differentiate between one who does the type rating/IPC and one allowed to do line checks.
And because you are an FE on an airline type won't give you automatic privileges to instruct or examine on bug smashers.

[LeadSled]

---- thanks and sincere respect to VICROADS. Cheersglenb,
Sounds just like our local NSW Roads and Maritime, where, incidentally, two former LAME, whom I have known for many years (one was a PPL student of mine) work.

Leadie the MCC seems to be problem #1. No one can do that either!I think I made that point, in the context that there have been no (non-airline) ATPLs since Part 61 arrived, because there is no MCC course around, although I hear that there will be one shortly in SA, with a course cost for individuals of around $13,000, plus whatever your accommodation and travel will cost.

That alone makes a nonsense of the risible RIS. The best estimate one serious candidate has come up with, so far, is a bit over AUD $60,000.

As a matter of interest, what passes for the CASA idea of what MCC and two pilot operations comprise bears absolutely no relation to the practices of most airlines, or the SOPs of the likes of Boeing, Airbus, Bombardier etc, so what you "learn" in a CASA "approved" MCC course will have to be immediately unlearned at your first job where two crew are required --- unless it is a small company where CASA have imposed their ideas by requiring humungous "two pilot procedures" via the "accepted" operations manual.

Then you really need three pilots, one to look out the window and fly the aeroplane, while "the crew" carry out all the "two pilot procedures".


Tootle pip!!

[Up-into-the-air]

Found the following this am:

Australian Helicopter Industry Association Limited PO Box 462 Carina Qld 4152 Australia
Mob: 0415 641 774 E: [email protected] ([email protected])



MEDIA RELEASE – AHIA/CASA Meeting – 6 May ‘15

CASR PART 61 AHIA/CASA MEETING - SYDNEY 6 MAY 2015

Recently CASA agreed to request from the AHIA to have a meeting to discuss industry concerns since the implementation of CASR Part 61 – Flight Crew Licensing. This is a critical piece of legislation being the foundation of all the other licensing regulations. (http://vocasupport.com/part-61-and-the-aviation-industry-skidmore-undertakings/)We acknowledge the framework of the legislation is sound but some areas require change or modification to better suit the Australian operating environment.

Representatives from CASA at the meeting were: Mark Skidmore, Director Aviation Safety; Peter Boyd, Executive Manager Standards Division; Roger Crosthwaite, Manager Flight Crew Licensing Standards; Dale South, Section Head Rotorcraft Standards and John Grima, Manager Flight Standards Branch.

The AHIA representatives were: Peter Crook, AHIA President; Ray Cronin, AHIA Senior Member Part 61 Review Committee and Richard Davis, AHIA Member, Partner and Aviation Law Specialist HWL Ebsworth.

The meeting concentrated on the post implementation industry concerns on two basic issues:



Perceived COST, and
INTERPRETATION (Complexity).


There was agreement on both sides these issues require addressing. CASA advised a Post Implementation Review (PIR) of the regulation is underway and the important issues raised by AHIA will form part of the review. There were a number of issues identified in the feedback we requested from industry. There was not time to discuss all specific issues but a number of critical issues were identified requiring immediate attention to alleviate the anxiety currently existing.

The AHIA had prepared a list of issues with suggested actions and left this with CASA.

CASA has agreed to work on the critical issues first and should have suggested actions and/or changes to industry as soon as possible. The AHIA offered assistance to CASA by way of industry sector specific processionals to jointly look at areas requiring change and how those changes can be implemented in a manner that is both safe and financially acceptable to industry.

In order to move forward in a positive manner we identified the following specific technical points as the matters of utmost priority, to create pathways for voids created by the implementation of Part 61:

* Expand the 61.040 testing approvals to include grade two instructors and those approved persons who held the relevant qualifications prior to the implementation date.

* Fast track the pending exemptions in relation to low level operations and flight testing for winch, sling and rappel operations and others in the system.

* Create a pathway to allow pilots to obtain an ATPL in Australia, potentially by way of an exemption for the MCC course for the transition period.

The AHIA will increase representation at the CASA Flight Crew Licensing Sub-Committee meetings, the next of which is to occur on the 19 May 2015, we will also be in regular contact with our assigned CASA liaison officer.

This we believe was a "milestone event" as it was a most encouraging and productive meeting.

We will be communicating with CASA on a regular basis and advising the industry of outcomes as they occur.

Peter Crook
President
Australian Helicopter Industry Association
[email protected]

[CYHeli]

Once the expected changes come in for NVFR, you will require two pilots to fly NVFR.
Soooo, do they need to do a MCC course? Really?!? How do they do that?:ugh:

Would it also be correct to say that all Grade 1 & 2 instructors need to be able to fly at night, so all instructors need a MCC course!

[Frank Arouet]

For years aviation law in Australia has been the same. Concoct a stupid law that nobody understands including politicians who refuse to pick up the document for debate in the House thus it automatically becomes law, then, QUOTE Fast track the pending exemptions QUOTE.


I heard Dick on "Macca" ABC Sunday this am from Forrest and he gave CAsA a blast re Part 61 and straight after that Howie Hughes from Ballina, (Hughes RAA Aircraft) giving them a good wrap including how they, (CAsA), have incorporated the US style of regulation in Australian aviation Law.


Squeeze me! Did I miss something?

[triadic]

I hear that all the Senators have been lobbied on Part 61.. With the suggestion that it should be trashed and re written?? Anyone know more ????

[Centaurus]

In all seriousness though. I know of an experienced Global Express co-pilot with CPL who flies all over the world with 3000 hours in GA and Global Express time trying to get his ATPL. Seems he cannot qualify because there is no Global E simulator in Australia he can be tested on. Unless he buys an Airbus, or 737, or Dash Eight, or similar turbo prop full type rating on which to be tested, he is stuffed.

Surely CASA must be aware of this anomaly and change the rules to fix this sort of ridiculous situation which affects a significant number of CPL pilots seeking to qualify for the ATPL flight test.

[The name is Porter]

Stop messing around here. The USA ATPL looks to be a good program now. Get your ATPL over there (cheaper), keep all the receipts, send the receipts to your local member and tell them you would have spent the thousands of dollars here in Australia in the local economy but it's impossible. Money talks, only money talks in this society!

[Progressive]

For those who missed it this should give some ammunition to dick and others looking to reduce the cost of compliance

http://www.casa.gov.au/wcmswr/_assets/main/lib100270/01-2015.pdf

[Dick Smith]

The above post was sensibly put on as a new thread.

Why would a mod then move it to this thread ?

So it will be hidden from as many as possible ?

What was the reason for moving it? No wonder many are moving away from prune !

[dubbleyew eight]

Dick if you have a foot or two in the reality of private aviation, and then you read
the posts on pprune, I reckon about 50% of the posters in the Australian threads
are CAsA staff ardently working at polishing the turd.

The loss of face from so many experienced pilots and owners utterly ignoring the $30 million rewrite of the regs must be being sorely felt.

The problem has been in the past that CAsA was seen as the retirement home
of the ex-RAAF. that may have passed to some extent and now we have the era of the aero club flying instructors.
None of these people have ever really privately owned and maintained aircraft.
The reality we live in has never been experienced by these people and it shows.

CAsA is Australia's (poor excuse of a) national airworthiness authority.
How many competent aeronautical engineers are employed by CAsA?
I'll bet that it is a very round figure that looks like a wendy's donut.

the real tragedy is that these fckuwits don't realise how irretrievably incompetent they are.

we have a rough ride ahead. see you in prison :-)

[dhavillandpilot]

Mr Smidmores directive reads extremely well BUT

Will his minions actually implement it

Of course not, lip service is what we'll get as each of them continues to carve out their own little empires

The only government department who appear to assist industry participant is the Immigration Department assisting Transfield with those pesky "boat tourists"

[Centaurus]

The problem has been in the past that CAsA was seen as the retirement home
of the ex-RAAF.

That certainly may be the perception and which soon turns into a wide generalisation. Fact is that after WW2 DCA needed aviation orientated people fast and there was no shortage of well qualified ex RAAF people looking for jobs. Many became flying instructors at aero clubs on paltry pay (nothing has changed there) and later were recruited by DCA.

Many stayed until retirement, while at the same time the airlines snapped up experienced GA pilots. Few GA pilots wanted to fly desks in DCA Head Office and I recall clearly that in those days Reg Ansett wasn't interested in hiring former RAAF pilots because he preferred to give GA pilots a go. Fine sentiments of course. On the other side of Essendon where TAA had their ops office, they preferred to hire ex RAAF. Horses for courses I suppose.

I have no facts as far as the recruiting of civilian or ex-military aircrew into CASA or previous regulator names, but there are always going to be "difficult" personalities recruited by government agencies as well as nice people. But it is unwise to automatically rubbish someone who is recruited by CASA simply because they may have been in the RAAF or the RAN Fleet Air Arm years ago.

[Arm out the window]

None of these people have ever really privately owned and maintained aircraft.
The reality we live in has never been experienced by these people and it shows.


None, never ... in reality a lot of military or ex-military people have owned and or maintained their own aircraft as per their training and qualifications; in fact Mark Skidmore owns and operates his own VH machine, so these generalisations are clearly wrong.