CASA New Part 91

[no_one]

A link to the proposed part 91 regulations was posted in the "New Broom" thread. I think that perhaps it is important enough to warrant its own thread so here it is below.

https://www.casa.gov.au/regulations-and-policy/standard-page/cd-1511os-part-91-casr-and-associated-mos-general-operating-and

Comments in to CASA by 6th of October 20156 but according to them these are the final rules subject to minor changes and the comments will be for future reviews.


CASA is keen to ensure that the rules operate in practice as they are designed to. Minor changes may appear in the final version of Part 91 on that basis. We have listened to what you told us and incorporated your suggestions where possible, however if you have additional comments for consideration in future reviews, please email project leader Stuart Jones by close of business, 6 October 2015.

[no_one]

91.495 Operating on manoeuvring area, or in the vicinity, of non-controlled aerodrome—landing and taking off into the wind
(1) This regulation does not apply in relation to an aircraft engaged in an aerial application operation in accordance with the requirements of regulation 137.160.
(2) The pilot in command of an aircraft for a flight contravenes this subregulation if:
(a) the aircraft is operated on the manoeuvring area of, or in the vicinity of, a non-controlled aerodrome; and
(b) the pilot does not, to the extent practicable, land and take off
into the wind.
(3) Subregulation (2) does not apply if:
(a) the aircraft flight manual instructions for the aircraft allow the aircraft to land or take off downwind; and
(b) the pilot is satisfied that traffic conditions at the aerodrome enable such a landing or take-off to be carried out safely.
(4) A person commits an offence if the person contravenes
subregulation (2).
Penalty: 50 penalty units


So this one is interesting... Say you have an aircraft where the POH is silent on tailwind takeoffs. You fly into a runway that slopes fairly steeply but landing up hill will mean that you land with a 5 know tailwind.

$9000 please

[Ultralights]

ATIS info. winds variable 5kts, occasional tailwind..

[wishiwasupthere]

Surely most if not all aircraft Flight Manuals specify a correction value to takeoff and landing distances in the event of a tailwind, thereby meeting subreg 3A and making this a bit of a moot point?

[Vag277]

If you read the summary document you will see that vety little is new comparedto the current rules

[Styx75]

I'm yet to see a performance chart that doesn't allow the headwind/tailwind to be taken into consideration...

[no_one]

I am pretty sure that the old piper charts only had the zero wind condition in the performance section. Some like the Pawnee dont even have a performance section.

[LeadSled]

no-one,
Re.91.495.
This is the same as the current regulation, CAR 166A, the reference to not having to operate into wind was a change to the long standing rules, several years ago, so that Regionals, who have always arrived on the nearest runway to where they have come from, and depart pointing as close to where they are going, regardless of traffic, would no longer be committing an offense each time they operated out of wind.

In short, schedule and cost trumps risk minimization (aka "safety").

As for the example given, don't worry about Part 91, the Act, which is not changing, covers that, S.20A.

If you read the summary document you will see that vety little is new compared to the current rules I wish. If you believe the summary, you probably believe in the tooth fairy.
Somebody did work out the number of new strict liability criminal offense, but I don't have the numbers.

Tootle pip!!

PS: For wind limitations, see the Limitations section of the AFM.

[no_one]

The current rule(CAR 166A) reads:

(h) if the pilot takes off from, or lands at, the aerodrome, the pilot must take off or land into the wind if, at the time of the take-off or landing:

(i) the pilot is not permitted under subregulation (5) to take off or land downwind; and

(ii) it is practicable to take off or land into the wind.


Under the current rules you can takeoff with a tail wind but down slope if taking off up the slope is not practicable. Under the new rules this is an offence.

Here's another one:


(1) The pilot in command of an aircraft for a flight contravenes this
subregulation if:
(a) the aircraft is flown in meteorological conditions other than
IMC; and
(b) during the flight, IMC conditions are simulated; and
(c) a requirement mentioned in subregulation (2) is not met.
(2) The requirements are the following:
(a) a pilot (the safety pilot) must:
(i) occupy a pilot seat fitted with fully functioning flight controls; and
(ii) have adequate vision forward and to each side of the aircraft;
(b) a pilot (the second pilot) flying under simulated IMC must occupy a pilot seat fitted with fully functioning flight controls;
(c) the safety pilot must hold one or more of the following:
(i) an instrument rating;
(ii) a flight instructor rating;
(iii) a flight examiner rating.


CAR 153 only requires that the safety pilot is a competent pilot and CAO 40.0(2.7) only requires that the safety pilot hold a pilots licence other than a students and is endorsed on the aircraft.

[dubbleyew eight]

the first cross country I did across australia was done with a friend.
we loaded the luggage in accordance with the very scant loading information in the DCA stamped flight manual.
first leg was 2 1/2 hours to kalgoorlie.
about half the way I noticed that the elevator trim had no more range and was on the forward stop.
for the last half hour into Kal I was applying more and more forward elevator.
this continued on each leg all the way across to albury, the destination.

on my return I decided to investigate and jacked the aircraft in the hangar.
I did a full first principles measure up of the weight and balance.
I considered and weighed up every scenario that was possible for flying the aircraft.

after some weeks of deliberation I came to the conclusion that putting the luggage in a sausage bag (sports bag) to about the dimensions of a human torso, sitting this in the seat on its end and strapping it in with the lap sash seat belt was the safest option for cross country flight.
after all if a passenger was safe sitting there in the lap sash belt then a sports bag of the same dimensions would be equally as secure.

of course my aircraft only has two seats and as part of its confguration it has dual controls. the passenger rudder pedals sit flat on the floor and are inactive until lifted up on to the detents. the control column has its counterpart for the passenger.

it should be obvious to blind freddy that when you put the bag in the seat you ensure that the bag can never foul the movement of the control column.

I have flown solo across australia and back twice doing this. it changes the character of the aircraft completely since at all times the cg remains in the centre of the range.

enter the new regulations...
(3) The pilot in command of an aircraft engaged in a flight commits an offence if, at any time during the flight, the pilot permits cargo to be carried in the aircraft on a flight control seat.
Penalty: 50 penalty units.

thanks CAsA you have just made the safest method of carrying luggage in my homebuilt a subject of a draconian penalty.
how about rewording it to "the pilot permits cargo to be carried unrestrained on a flight control seat" that would fix the problem.

[glekichi]

"To the extent practicable "

Your downhill tailwind takeoff is allowed because the steep uphill takeoff is not practical or safe. At least that's how I read it.

[Sunfish]

Doubleyeweight, Perhaps confirm that "Cargo" and "Baggage" are Two different things?

If they aren't then a flight bag or headset case on the RHS are problematic as well.

[kaz3g]

Or an iPad and ERSA?

My aircraft doesn't have a FM or POH!

Kaz

[kaz3g]

I can see the next re-write occupying lots of time and taxpayers money already.

Scenario: A couple of Warriors and a C172 with low hour student pilots practising circuits and landing on 18 in light and variable conditions tending southerly. Perfect for short time solos. The runway direction is away from the adjacent town.

I join the circuit but the wind swings around to less than a couple of knots from the north. Everyone else legally and sensibly continues with circuits on 18.

I have no FM or POH so don't qualify for the exception and announce I'm changing direction even though the change in wind is probably very transient. PANIC!

Who writes theses things?

Why an "and" instead of an "or" in the exception?

Ridiculous!

Kaz

[kaz3g]

I don't have hours to spare to scroll through the new regs for a definition but the 1988 Regs state ...

"cargo " means things other than passengers carried in aircraft.

Kaz

[LeadSled]

Folks,
Given the number of exceptions popping up, the poster who suggested that the new new rules should just prohibit everything, and the exceptions become the rules, had something.

I still have a copy of the first draft of Part 91 from 1998, simple and straightforward, every iteration since has got sillier and sillier.

You will notice that Mr. Skidmore has knocked back allowing individual instructors to teach as per USA ---- once again, all because it would reduce our supposedly world wide reputation for very high training standards.

Where can I hire salesmen (salespersons??) that can sell a pitch like that to an otherwise intelligent person, I will make a fortune selling hamburgers to Hindus.

Your downhill tailwind takeoff is allowed because the steep uphill takeoff is not practical or safe. At least that's how I read it.

And you are correct, and this is another example of CASA ignoring the basic "rules" for rule writing, with a hefty fine in the offing, who gets to decide, in the real world, what is "practicable". There are plenty more of these in Part 91, and if you don't flood CASA with complaints by way of the NPRM, don't complain when nothing changes. And copy in your local member, the Minister, Senator Fawcett and the Chairman of the CASA Board on every NPRM reply.

Tootle pip!!

[djpil]

dubbleyew eight enter the new regulations...
(3) The pilot in command of an aircraft engaged in a flight commits an offence if, at any time during the flight, the pilot permits cargo to be carried in the aircraft on a flight control seat.
Penalty: 50 penalty units.What para is that?

Para 91.690 Carriage of cargo - unoccupied seats - makes no mention of that.

[kaz3g]

92.470 better check your fuel for quality and contamination BEFORE you put it in your aircraft to avoid offending this Reg.

Kaz

[Jabawocky]

Time for civil disobedience.

everyone keep doing what you are doing safely…..if you get ramped make them prove the old way was dangerous.

I give up, I refuse to comply with stupid…..and anyone challenging me can get :mad:

I will not go out of my way to kill myself, promise ;)

[Sunfish]

I especially like the self incrimination regulation. If you think you are about to use part of your reserve, you must declare an emergency.

Get ****ed CASA.*

All your new regulations will do is entirely alienate the aviation community and ensure that no one EVER declares a fuel related emergency.

* And I mean get ****ed. The mark of a Gentleman is that he does not give offence unintentionally. In the case of part 91, when you wish to label me a felon If I transgress your draconian regulations, I say get ****ed - and I say that because I know a few judges, and that is what they say about the law and those in front of them, and each other in private.

There is no point arguing with CASA. This whole part needs withdrawal and redrafting - starting with removal of strict liability.

To put it another way; the draft regulation is designed to stitch up people like Dominic James - who are faced with ambiguous situations and commercial pressures - and ensure without any doubt that the regulator and Airservices will never be blamed for the consequences of their stupidity and corruption.

Get ****ed CASA!

To put it yet another way, in the words of an eminent jurist who is an acquaintance: " If you want to strengthen this regulation, water it down" - meaning that courts don't like to enforce draconian bull****. CASAS proposed regulations actually decrease safety and should be opposed because of it.

[Sunfish]

On another note, I have yet to find a C172 for hire that has an "approved" Cessna cargo net.

My response is to apply lashings of Spectra (stronger than steel) yachting line to make sure our bags are restrained - which has the added effect of ensuring that I get charged with Two offences - unrestrained bags and unapproved equipment. I assume others do the same. Good one CASA! Should I have merely left the bags unrestrained it would only be one offence!

[djpil]

Its OK Sunfish - read the reg for carry-on baggage.

[Horatio Leafblower]

Jaba,
The whole point of differentiating between commercial pilots and private pilots is to ensure CPLs have the training and support and integrity to deal with "commercial pressure and ambiguity".
The rules regarding fuel reserves that seem so draconian to a PPL strike me as describing a fundamental duty of a CPL's (let alone ATPL's) employment.
The reserves stipulated in the new 91 are substantially less than the normal fixed reserve hitherto applied in any commercial op I have ever seen.
If you breach those fuel levels you are fkn insane and if I employed you we would be having a short chat (no need for a long one).
Notwithstanding I have not done more than flick through the Part quickly, and the whole "strict liability" thing aside, I don't see the problems here.

[dubbleyew eight]

for djpil

91.545 carriage of cargo on unoccupied seats
section (3) was a cut and paste from the pdf.

50 penalty units.

I think I'd love to get into parliament. my private members bill would set the value of a penalty unit at 1 zimbabwian cent.

[Lead Balloon]

I don't see the problems here.It seems to me that you're assuming that people are complaining about what I'll call the 'operational intent' of the proposed rules about fuel.

That's not what we (or at least me) are complaining about.

The proposed rules aren't "draconian".

Here's the problem: The change to the rules is unnecessary and will inevitably have unintended consequences.

The operational intent is already achievable, and is being achieved within the framework of the current rules. And the people who, through incompetence or commercial pressure, run out of fuel under the current rules will run out of fuel under the proposed rules. There are already more than enough mechanisms under the current legal framework to take the pilot's licence away, prosecute the pilot, sue the pilot for damages and produce an ATSB report that attributes the cause entirely to the pilot. So we can already scapegoat the pilot, in accordance with contemporary safety management system and just culture principles.

There is, therefore, no safety problem to which the proposed new fuel rules is a solution.

There is a bunch of people, paid six figure salaries year after year and decade after decade, producing all of this stuff. It wouldn't be so bad if all they did was produce unnecessary stuff that had no consequences in reality. But sooner or later, industry will start finding real and unintended operational consequences in the proposed Part 91. Decades and tens of millions of dollars, and it will create unintended operational consequences - I will guarantee it.

The self-licking ice cream has the solution: Exemptions. Then start a project to do a post-implementation review. "It is expected that the post-implementation review will ....".

Just imagine how much work this creates for the bunch of people on six figure salaries producing all of this stuff, decade after decade. And their colleagues, who draft exemptions and arrange for tabling and all of the other governance around disallowable instruments are eternally grateful too.

And all this has to be paid for in fees by the industry or appropriations from the taxpayers' coffers.

All in the name of 'safety', of course.

"Beyond a certain point, complexity is fraud."

[LeadSled]

Folks,
As many of you will know (it has all been on pprune) the latest EASA innovation is the new boss fired the whole EASA rule making bureau, for pretty much the reasons Lead Balloon mentioned --- although the EASA press releases were a tad more diplomatic.

That was a real "new broom", swept the whole kit and caboodle right out the DCM door.

Tootle pip!!

[zanthrus]

I especially like the self incrimination regulation. If you think you are about to use part of your reserve, you must declare an emergency.

Get ****ed CASA.*

All your new regulations will do is entirely alienate the aviation community and ensure that no one EVER declares a fuel related emergency.

* And I mean get ****ed. The mark of a Gentleman is that he does not give offence unintentionally. In the case of part 91, when you wish to label me a felon If I transgress your draconian regulations, I say get ****ed - and I say that because I know a few judges, and that is what they say about the law and those in front of them, and each other in private.

There is no point arguing with CASA. This whole part needs withdrawal and redrafting - starting with removal of strict liability.

To put it another way; the draft regulation is designed to stitch up people like Dominic James - who are faced with ambiguous situations and commercial pressures - and ensure without any doubt that the regulator and Airservices will never be blamed for the consequences of their stupidity and corruption.

Get ****ed CASA!

To put it yet another way, in the words of an eminent jurist who is an acquaintance: " If you want to strengthen this regulation, water it down" - meaning that courts don't like to enforce draconian bull****. CASAS proposed regulations actually decrease safety and should be opposed because of it.

There is no way to enforce this anyway. If you crash because you run out of fuel you have bigger problems than CASA.

Otherwise CASA has no manpower to run around checking fuel tanks everywhere.
I will refuse to let them near my aircraft and they can get stuffed!

[dubbleyew eight]

the whole purpose of the mandatory fixed reserve is so that you had some reserve amount of fuel that could be used if all else failed.

the original intent of the rules wasn't to tanker around a blast load of fuel it was so that that fuel could be used.
I would wager that it was based on some experience at needing it.

to make it illegal to actually use the fixed reserve when needed is patently bloody absurd.
....but that is the fcukwitted world we get when clueless lawyers get involved in an engineering environment.

[djpil]

dubbleyew eight, we are not looking at the same version. I downloaded the latest exposure draft. 91.545 is Safety when aeroplane operating on the ground.

[dubbleyew eight]

there was something in I think part 91 that stunned me.

consider that you were a pilot yourself and you were in MH370 and you became aware that not everything was going to plan.
you were off course, the aircraft had changed altitude, and the emergency oxygen masks had dropped.
things were decidedly weird.
the cabin crew were as utterly perplexed as you.

you had in your top pocket your personal locator beacon as a result of the previous MH370 ongoing mystery.

CAsA have made it illegal for you to pop your locater beacon in the window and activate it.
now I don't mind untrained passengers being told that they couldn't set of emergency beacons but me as a pilot, and a seasoned airline traveller, with the hairs on the back of my neck standing on end.

get fckued CAsA I'll be popping my PLB to give someone a hope of finding us.

[dubbleyew eight]

djpil I simply followed the link that one of the posters had put in his post in this thread.

a late edit.
I downloaded the pdf from the casa website.
are you telling me that these people are so clueless that they have the wrong version posted on their website.
or multiple wrong versions.

are you starting to believe that they really are incompetent, yet???

ps even the pprune spellchecker thinks that case is an error :-) :-) and keeps changing casa to case

[cessnapete]

I can't believe what I read here re CASA Rules for Oz pilots. I thought EASA here in Europe was bad enough. As for 'penalties' for getting it wrong, words fail me.
A pilot cannot possibly memorise all that paperwork.
What happened to good old airmanship learnt from good instruction, and gained from experience!

[Jabawocky]

Leafie

Jaba,
The whole point of differentiating between commercial pilots and private pilots is to ensure CPLs have the training and support and integrity to deal with "commercial pressure and ambiguity".
The rules regarding fuel reserves that seem so draconian to a PPL strike me as describing a fundamental duty of a CPL's (let alone ATPL's) employment.
The reserves stipulated in the new 91 are substantially less than the normal fixed reserve hitherto applied in any commercial op I have ever seen.
If you breach those fuel levels you are fkn insane and if I employed you we would be having a short chat (no need for a long one).
Notwithstanding I have not done more than flick through the Part quickly, and the whole "strict liability" thing aside, I don't see the problems here.

Yeah I agree with you, in fact, my whole flight planning for fuel is done at the typical commercial standards 15% etc. I am not likely to ever run out or short…..thats because I don't want stress. But IF the day comes where I need to dip 1 litre into my reserves because of a wx diversion and then a delay at the alternate like an a/c on the runway with a flat tyre, that took a while to remove, I would manage my fuel so it was all in the one place and not have to land on half a runway.

I don't care what the rules say…..safety is a state of mind. :ok: (and yes I know you get that too)

Problem is CASA are trying to write a rule for everything and often the baby goes out with the bath water.

[Capt Casper]

"91.120 Carriage of documents—certain flights
(1) This regulation applies in relation to a flight of an aircraft other than:
(a) a VFR flight conducted by day and within 50 nautical miles of the aircraft’s point of departure; or (b) a flight conducted: (i) within the flying training area for an aerodrome; and (ii) if the flying training area for the aerodrome is not adjacent to the aerodrome—along the flight path between the flying training area and the aerodrome.
(2) The pilot in command of an aircraft for a flight contravenes this subregulation if, when the flight begins, a document mentioned in subregulation (3) is not carried on the aircraft.
(3) The documents are as follows: (a) the authorised aeronautical information for the flight; (b) an authorised weather forecast applicable to the route of the flight and any probable diversionary route; (c) the flight technical log for the aircraft.
(4) Subregulation (2) does not apply in relation to the documents mentioned in paragraph (3)(b) if circumstances prescribed by the flight planning (weather assessments) requirements apply for the flight.
(5) A person commits an offence of strict liability if the person contravenes subregulation (2). Penalty: 50 penalty units. Note: A defendant bears an evidential burden in relation to the matters in subregulation (4): see subsection 13.3(3) of the Criminal Code."

Can anyone put para 4 above in plain english for me???

[Jabawocky]

I would hope it means……I am going from Toowoomba to Caloundra and I can see the coast is visible because it is a gin clear day and weather is irrelevant.

I fear I would be wrong.

Who writes this rubbish :ugh:

[no_one]

Casper, I think that it means that you have to have a weather forecast unless part 91.325 applies


91.325 Flight planning (weather assessments) requirements
(1) The Part 91 Manual of Standards may prescribe requirements relating to flight planning and weather assessments (the flight planning (weather assessments) requirements).
(2) The pilot in command of an aircraft for a flight contravenes this subregulation if a flight planning (weather assessments) requirement is not met for the flight.
(3) A person commits an offence of strict liability if the person contravenes subregulation (2).
Penalty: 50 penalty units.

[Lead Balloon]

Mr Jabbawocky

In order to understand this stuff, you have to adopt the mindset of someone who is a congenital complicator and micro-manager. Once you do that, it's easier to comprehend that "flight planning (weather assessments) requirements" is a new defined term that points to that paradise for complicators and micro-managers - a "Manual of Standards" - with their own penalty for non-compliance.

So instead of being able to know, from the face of the regulation alone, what you have to do to comply, you have to also know all of the "flight planning (weather assessment) requirements" in the MOS, because that is the only way to know which is the applicable requirement.

Watch out! There could be a flight planning (weather assessment) requirement for the route Toowoomba to Caloundra in the MOS - you won't know if you don't check. If there isn't, you're back to the requirement for an authorised weather forecast, even if you can see it's gin clear from Toowoomba to the coast and beyond.

But don't worry: you only need to have carried the documents when the flight began. Given the definition of "flight", you can therefore pass all the documents out of your aircraft's door or window as you taxi out, and continue the flight without them.

[LeadSled]

----- flight planning and weather assessments (the flight planning (weather assessments) requirements).

Folks,
Who would ever have imagined that "flight planning and weather assessments" included "the flight planning(weather assessments) requirements".
Tootle pip!!

[thorn bird]

Who assesses that the assessment by the assessor has been assessed in accordance with the assessment requirements of the assesse assessor?
What happens if the assesse assessor assesses that the assessment by the assessor is not in accordance with the assesse MOS, but the assessor disagrees with the assessment by the assesse and asks for an assessment of whether the assessors assessment was in accordance with the assessment manual? err got it!..I think?

Regarding a flight plan. A flight plan is THE plan on which one makes the changes. There are many types of Plans...who assesses when a plan is a plan....Good grief don't get me started on this assessment crap again... I'm so confused...now Who assesses when confusion is lack of assessment in the basic assessment of assessing a plan....OH buggrit...."BANG" ****!! missed!! now who assesses when an attempted suicide is assessed as a genuine attempt or...AGGH!

[LeadSled]

Thornbird,
Isn't the answer obvious:

Its the approved assessment by the approved assessor has been assessed for approval in accordance with the approved assessment requirements of the approved assessement by the approved assessor?

The approved assesse's approved assessor's approved assessment assesses that the approved assessment by the approved assessor is not in approved accordance with the approved assesse MOS, but the approved assessor disagrees with the approved assessment by the approved assesse and asks for an approved reassessment of the approved assessment of whether the approved assessors approved assessment was in approved accordance with the approved (or is that accepted) assessment manual?

More importantly, if you initial in error, and erase the initials, should you initial the erasure.

Tootle pip!!

[gassed budgie]

Its the approved assessment by the approved assessor has been assessed for approval in accordance with the approved assessment requirements of the approved assessement by the approved assessor?

The approved assesse's approved assessor's approved assessment assesses that the approved assessment by the approved assessor is not in approved accordance with the approved assesse MOS, but the approved assessor disagrees with the approved assessment by the approved assesse and asks for an approved reassessment of the approved assessment of whether the approved assessors approved assessment was in approved accordance with the approved (or is that accepted) assessment manual?

More importantly, if you initial in error, and erase the initials, should you initial the erasure.

......and that's officially official.

85fx0LrSMsE

[dubbleyew eight]

as a result of djpil's prompting I went back to the casa web site to find the real part 91.

I searched and I can't find it. so I'm assuming that since I can't find it it doesn't apply to me.

oh that's such a relief.:ok:

.....seriously I can't locate the rules.

[Duck Pilot]

I assume all the comments posted here have been sent to CASA formally.

Dont expect any changes if you don't address them in the correct manner 😀

[LeadSled]

I assume all the comments posted here have been sent to CASA formally.
Don’t expect any changes if you don't address them in the correct manner.Duckie,
Presumably on the approved form, using the approved format of approved language and expecting an approving response.
Best of luck.
Tootle pip!!

PS:
Seriously, folks, a lot of effort in your NPRM responses, please, politely vigorous and detailed. Don’t leave it to “somebody else”, weight of numbers is important. A lot of effort went into forcing the NPRM system on CASA, don't waste it.

Don't just use the "approved" response form or the tick a box (bit like a multi choice) with very limited room for comment.

Demand that each and everything you object to, to be assessed against the Government rule making criteria, where regulation is the last option, not the first, and cost/benefit must be proven positive. A Regulatory Impact Statement is not nearly enough, all that tells you is how much CASA thinks it is going to cost, and that is often wildly wrong, witness Part 61.

Better still, demand that the whole of Part 91 be justified under the Government's mandatory regulation making Red Tape Reduction criteria, regulation is the last resort.

And copy your NPRM response, with a covering letter, to your local Federal member, the Minister, and Senators Fawcett, Sterle,Heffernan and Xenophon. Remember, twenty or thirty responses on a single subject, on a members desk is "an avalanche of public opinion".

[Duck Pilot]

I sent a few comments in via email the other day and got a positive response today. There are no online forms to fill out. Sure you are responding to the correct link?

Leadie,
You use the word presumably???? In all seriousness you obviously have no idea of the process! It's not hard to reply.... Just send an email to the link/person!

Formality is via an email stating you concerns in a professional context. It isn't hard! If there is a special link please post here for us dumb people.

[LeadSled]

Duckie,
I understand in very great detail just how the NPRM system works, after all, I helped set it up in the first place.
Tootle pip!!

PS: Your sense of humour is offline, try rebooting it!!

[Duck Pilot]

Send me a current form or a link please Leadie, you are obviously knowledgeable on the process, I take my comments back with due respect!

[no_one]

It looks like those that fly private operations, night VFR are going to be disappointed. There is virtually no difference in the required instruments for IFR compared to VFR at night.

For instance the new part 91 rules require heated Pitot and a means of detecting that it inst working as well as many other things


(a) A system to indicate speed must:
(i) include a means to prevent malfunctioning due to condensation or icing; and
(ii) include an indicator to warn of the failure of the means to prevent malfunctioning;


Compare this with the requirements in the USA from FAR 91.205:


(b) Visual-flight rules (day). For VFR flight during the day, the following instruments and equipment are required:
(1) Airspeed indicator.
(2) Altimeter.
(3) Magnetic direction indicator.
(4) Tachometer for each engine.
(5) Oil pressure gauge for each engine using pressure system.
(6) Temperature gauge for each liquid-cooled engine.
(7) Oil temperature gauge for each air-cooled engine.
(8) Manifold pressure gauge for each altitude engine.
(9) Fuel gauge indicating the quantity of fuel in each tank.
(10) Landing gear position indicator, if the aircraft has a retractable landing gear.
(11) For small civil airplanes certificated after March 11, 1996, in accordance with part 23 of this chapter, an approved aviation red or aviation white anticollision light system. In the event of failure of any light of the anticollision light system, operation of the aircraft may continue to a location where repairs or replacement can be made.
(12) If the aircraft is operated for hire over water and beyond power-off gliding distance from shore, approved flotation gear readily available to each occupant and, unless the aircraft is operating underpart 121 of this subchapter, at least one pyrotechnic signaling device. As used in this section, “shore” means that area of the land adjacent to the water which is above the high water mark and excludes land areas which are intermittently under water.
(13) An approved safety belt with an approved metal-to-metal latching device for each occupant 2 years of age or older.
(14) For small civil airplanes manufactured after July 18, 1978, an approved shoulder harness for each front seat. The shoulder harness must be designed to protect the occupant from serious head injury when the occupant experiences the ultimate inertia forces specified in§ 23.561(b)(2) of this chapter. Each shoulder harness installed at a flight crewmember station must permit the crewmember, when seated and with the safety belt and shoulder harness fastened, to perform all functions necessary for flight operations. For purposes of this paragraph—
(i) The date of manufacture of an airplane is the date the inspection acceptance records reflect that the airplane is complete and meets the FAA-approved type design data; and
(ii) A front seat is a seat located at a flight crewmember station or any seat located alongside such a seat.
(15) An emergency locator transmitter, if required by§ 91.207.
(16) For normal, utility, and acrobatic category airplanes with a seating configuration, excluding pilot seats, of 9 or less, manufactured after December 12, 1986, a shoulder harness for—
(i) Each front seat that meets the requirements of§ 23.785 (g) and (h) of this chapter in effect on December 12, 1985;
(ii) Each additional seat that meets the requirements of§ 23.785(g) of this chapter in effect on December 12, 1985.
(17) For rotorcraft manufactured after September 16, 1992, a shoulder harness for each seat that meets the requirements of§ 27.2 or § 29.2 of this chapter in effect on September 16, 1991.

(c) Visual flight rules (night). For VFR flight at night, the following instruments and equipment are required:
(1) Instruments and equipment specified in paragraph (b) of this section.
(2) Approved position lights.
(3) An approved aviation red or aviation white anticollision light system on all U.S.-registered civil aircraft. Anticollision light systems initially installed after August 11, 1971, on aircraft for which a type certificate was issued or applied for before August 11, 1971, must at least meet the anticollision light standards ofpart 23, 25, 27, or 29 of this chapter, as applicable, that were in effect on August 10, 1971, except that the color may be either aviation red or aviation white. In the event of failure of any light of the anticollision light system, operations with the aircraft may be continued to a stop where repairs or replacement can be made.
(4) If the aircraft is operated for hire, one electric landing light.
(5) An adequate source of electrical energy for all installed electrical and radio equipment.
(6) One spare set of fuses, or three spare fuses of each kind required, that are accessible to the pilot in flight.