Part 61 gotcha for Chief Pilots/AOC holders and syndicates.

[roundsounds]

It was my understanding pre CASR Part 61 that a pilot completing induction training with an AOC holder could be trained / considered competent to operate a type within a group (class) by the Chief Pilot. The Chief Pilot didn't necessarily need to hold an instructor rating provided the pilot held the appropriate design feature endorsements. An example might be a pilot with say Cessna 210 experience could be "checked out" by the Chief Pilot to fly a C182RG. Under CASR 61.385 (general competency) the Chief Pilot NOW needs to hold an instructor rating with at least a grade 2 training endorsement. The same story with syndicates, no longer could an experienced member "hold the hand" of a new member to gain experience, this now must be completed by an appropriately rated flight instructor. Refer 61.385, 61.1165(e). CAO 40 didn't specify how this was to be done or what qualifications were required, it just said you needed to know how to operate the aircraft and hold appropriate design feature endorsements.

[Ixixly]

I can't remember the reference but there is somewhere in Part 61 that allows this, it was one of the few sensible things it seemed to introduce! As long as the Chief Pilot holds the correct piece of paper from CASA they're able to check their Pilots on the Aircraft they operate. It's not an Exemption as such, I just can't think of the correct term for it at this particular moment nor the actual reference.

[cogwheel]

Why does something that should be so simple have so many holes in it ??

Oh I forgot, it was written by lawyers not aviators! :mad:

[roundsounds]

I can't remember the reference but there is somewhere in Part 61 that allows this, it was one of the few sensible things it seemed to introduce! As long as the Chief Pilot holds the correct piece of paper from CASA they're able to check their Pilots on the Aircraft they operate. It's not an Exemption as such, I just can't think of the correct term for it at this particular moment nor the actual reference.
Agree, the CP can check the pilot but not train them to be competent - that's the gotcha!
It's a bit like the flight review - an instructor (grade 1 or 2) can conduct a flight review independently of a 141/142 cetificate holder provided they don't do any training! Now, if the pilot asks you to complete a flight review and their steep turns are safe, but untidy do you demonstrate one and provide guidance, then let them practice til they are tidy? No, this is considered instruction so you'll need a Part 141 certificate with all of the administrative stuff (POH, check lists etc for that aircraft type). Alternatively you tell them to go away and practice steep turns until they are tidy, then I'll look at them again or say they're untidy but safe so I'll just sign you off?
The philosophy seems to be you are considered suitable to judge what's safe (checking), but not how to train them to be safe unless you've got the weight of the subject aircraft in paper to support the training.

[Car RAMROD]

Without diving into the regs to clarify, by the sound of it I suspect you are getting a little confused.

If someone is licensed to fly the 210 in your example, you are licensed to fly the 182rg. The CP is not training you for any endorsements or ratings. They still have responsibilities under CAO 82 for check and training, and I do believe that teaching them your SOPs on the 182 is not considered "training" by way of the definition of "training".

Training in the sense of the defined word would be teaching someone without csu/rg ratings to operate an aircraft with such features.

[roundsounds]

Without diving into the regs to clarify, by the sound of it I suspect you are getting a little confused.

If someone is licensed to fly the 210 in your example, you are licensed to fly the 182rg. The CP is not training you for any endorsements or ratings. They still have responsibilities under CAO 82 for check and training, and I do believe that teaching them your SOPs on the 182 is not considered "training" by way of the definition of "training".

Training in the sense of the defined word would be teaching someone without csu/rg ratings to operate an aircraft with such features.
Yes I agree with your interpretation pre Part 61. To understand the way CASA looks at things now you need to read 61.385 and 61.1165(e). CAO 82 only talks about "Check Pilot", not training. I'm going through an exercise with CASA now on this subject, a CAO 82.5 Check and Training Pilot is not considered to be qualified to instruct. This matter is definitely a gotcha and I suspect is going to be tested soon in relation to a recent incident.

[Duck Pilot]

Is the reg talking about a class rating or type rating? If it's a class rating (which is the case now for most GA aircraft) the pilot only needs to have the class rating in the licence and be satisfied that he/she is confident that they are competitent on the aircraft. Type ratings require specific training on the particular aircraft type.

Example would be that if a pilot had a class rating on a multi engine piston twin, and say had a lot of time in a PA31 and then wanted to fly say a PA34, the pilot could legally fly in the PA34 provided that the pilot was satisfied that he/she were competent enough to fly the PA34. How that competentcy is achieved is up to the pilot/operator to determine. Reading the POH and doing a flight with another pilot experienced on the aircraft might be all that is required, and that other pilot does not have to be an instructor.

I can't see how a syndicate would be drawn into this, they don't hold AOCs.

[roundsounds]

Is the reg talking about a class rating or type rating? If it's a class rating (which is the case now for most GA aircraft) the pilot only needs to have the class rating in the licence and be satisfied that he/she is confident that they are competitent on the aircraft. Type ratings require specific training on the particular aircraft type.

Example would be that if a pilot had a class rating on a multi engine piston twin, and say had a lot of time in a PA31 and then wanted to fly say a PA34, the pilot could legally fly in the PA34 provided that the pilot was satisfied that he/she were competent enough to fly the PA34. How that competentcy is achieved is up to the pilot/operator to determine. Reading the POH and doing a flight with another pilot experienced on the aircraft might be all that is required, and that other pilot does not have to be an instructor.

I can't see how a syndicate would be drawn into this, they don't hold AOCs.
I agree with your view, pre part 61 is how a relatively inexperienced pilot flying a new type within a class would have been checked out by an operator. Under part 61 you need to hold an instructor rating to be authorised to deliver this training, it's as though CASA have created a pseudo "type rating" for every aircraft and the only relief a class rating gives is for the notification to CASA. I've held CP / ATO roles in the past so understand how things were done versus how CASA see it under Part 61. This has been highlighted to me as the result of a recent incident. The minute you step into an aircraft to fly with a pilot to assist them in becoming competent in a new type you need to hold an instructor rating, holding a CP authorisation alone is not enough. You need to read 61.385, 61.1165(e) and the information sheet (see link below) to understand CASA's view on this.

https://www.casa.gov.au/sites/g/files/net351/f/_assets/main/lib100268/general-competency-pilots.pdf

[Duck Pilot]

What kind of aircraft/s are you specifically referring to? Most of the GA aircraft are now bundled into class ratings.

[roundsounds]

The point I'm trying to make here is CASR 61.385 effectively creates a pseudo "type rating" for every type. If you've got experience in a broad range of types and were conversant with the procedures loading etc on a new type you might be able to argue in court that you met the general competency requirements, but you'd only be in court if there was an incident so that might be difficult. If you're not that experienced and sought assistance from a more experienced person they must hold an instructor rating for the "training" to be valid. If there was an incident the person "helping" the less experienced pilot gain experience would be dragged into the enquiry.
If you haven't read the references I quoted above you won't understand CASA's current stand in this regard.

[thorn bird]

Know a CP who applied for Reg 217 and put himself up as head of check and training, 15,000 hours not enough apparently.

CAsA required him to get an instructors rating, 400 hours of basic instructional experience, then multi-engine training approval, then 300 hours instructing under IFR in multi engine aircraft. The gentleman concerned would long be in his grave by the time he'd obtained all that. So I guess we are going to see a lot of 21 year olds with brand new grade ones and no experience doing C&T on high performance aircraft now. Still when you look at the experience levels of some of the CAsA FOI's struggling through type ratings on some very sophisticated machinery to become the anointed experts, one can only wonder when the next training accident will occur

Incidentally did I read somewhere that Qantas C&T's are going to be granted automatic instructors ratings?

I don't have a problem with that, but it sort of makes a mockery of all those kids who have stumped up the money got all the required ticks in the required boxes and put in the time and effort.

[dhavillandpilot]

Can anyone enlighten me on the 5 hours VFR and 10 hours IFR requirement for charter under part 61 on type that use to be part of the endorsement for commercial operators

Now if you have retract, constant speed, pressurisation on say a C421 then under the part 61 this entitles you to immediately fly say a Monave after a check out without having done the ICUS

[Car RAMROD]

61.385 mentions nothing about having to hold an instructor rating. Not sure where you are coming up with that? I don't think it is creating a "pseudo type rating". Type and class ratings are clearly defined.
By your logic, if a pilot friend asked you at the bar one night "hey, I've forgotten, what was the stall speed on (insert the plane we both fly)?" then you would be giving training!

61.1165e allows an instructor to obviously teach the general competency requirements of 61.385. If the list of privileges for an instructor didn't let them teach that stuff then that would be silly!


Yep you need an instructor rating to teach someone how to fly an aircraft that they are not allowed by regs to fly because of say, a design feature or the aircraft not being a type or class that they are licensed on, or to conduct a flight review.
I've had it clearly from casa that "training" (ie giving icus to) a pilot who is licensed to fly an aircraft we operate in our sop is not training that requires a flight instructor rating. The pilot has already been trained/reviewed/certified competent by an instructor already, hence why they are licensed to fly it. The operator still has to ensure they cut the mustard and are up to their standard.

It does get a little more complex though when you start having type ratings, OPCs, approved check and training etc all involved.


Thorny, just because he has 15,000 hours doesn't necessarily mean he knows how to check and train. Without any more details, this 15,000 hour guy might have 14,500 hours single, maybe some single turbine, have his 500 multi command, and maybe he has just put a jet on the AOC and wants to train people himself in that! All without ever being in a formalised C&T process himself.

[roundsounds]

61.385 mentions nothing about having to hold an instructor rating. Not sure where you are coming up with that? I don't think it is creating a "pseudo type rating". Type and class ratings are clearly defined.
By your logic, if a pilot friend asked you at the bar one night "hey, I've forgotten, what was the stall speed on (insert the plane we both fly)?" then you would be giving training!

61.1165e allows an instructor to obviously teach the general competency requirements of 61.385. If the list of privileges for an instructor didn't let them teach that stuff then that would be silly!


Yep you need an instructor rating to teach someone how to fly an aircraft that they are not allowed by regs to fly because of say, a design feature or the aircraft not being a type or class that they are licensed on, or to conduct a flight review.
I've had it clearly from casa that "training" (ie giving icus to) a pilot who is licensed to fly an aircraft we operate in our sop is not training that requires a flight instructor rating. The pilot has already been trained/reviewed/certified competent by an instructor already, hence why they are licensed to fly it. The operator still has to ensure they cut the mustard and are up to their standard.

It does get a little more complex though when you start having type ratings, OPCs, approved check and training etc all involved.


Thorny, just because he has 15,000 hours doesn't necessarily mean he knows how to check and train. Without any more details, this 15,000 hour guy might have 14,500 hours single, maybe some single turbine, have his 500 multi command, and maybe he has just put a jet on the AOC and wants to train people himself in that! All without ever being in a formalised C&T process himself.
This time last week I would have stood by you supporting your view, your view is as I understood it. However recent events and discussions with CASA have changed my understanding. If you want to get an insight to CASA's interpretation on their shiny new regs go to their website and read the "Information Sheets" (hard to locate, best do a search on the site). The info sheet supports the FOI's interpretation and guidance on how to satisfy the intent of 61.385. I don't stand to gain anything by bringing this matter to the attention of operators, pilots and aircraft owners, I'm simply sharing what I believe to be a nasty consequence of the new FCL rules.

[Sunfish]

What possible benefit does the new part 61 bestow on the aviation industry?

From this thread it appears that all it does is load in more costs!

[roundsounds]

Sunfish - having CASA create their own version of ICAO Flight Crew Licencing rules is like putting the rats in charge of the cheese factory!!
What user pays and airport privatisation started, part 61 will finish. RIP GA...

[LeadSled]

The info sheet supports the FOI's interpretation and guidance on how to satisfy the intent of 61.385.

Of course they do!! This is "CASA's opinion" of what the bugger's muddle of Part 61 means. Maybe that is an improvement, at least some FOIs agreeing with their employer/themselves.
The crunch comes when such matters are adjudicated on by a court, and it would be a brave person who relied on the info. sheets as legal interpretation documents.

Re. "Instructor's Ratings", the policy, embodied in the plain language drafts of the original Part 61, said that all present C&T, by whatever name, would AUTOMATICALLY get "Instructor's Ratings" limited to precisely what they were qualified for in the airline training department, CAR 217 organisation of whatever. It would be a change of name, not function.

The policy never was that an airline C&T could suddenly conduct basic flying training, unless he/she was otherwise qualified. It is the b###sh1t interpretations of the FOIs (most of then ex-GA/Mil) that have shafted the intent, and are now not differentiating between "instructors" at flying school level, and airline/CAR 217 level.

This is a problem generated entirely within CASA, as a result of the shambles of the final version of Part 61.

Tootle pip!!

[Grogmonster]

Guys,

A lot of hysteria here. Nothing has changed. CP can check anybody to line under CAO 82. You all used to have to do endorsements right ?? So for aircraft under 5700kg what you do is you still go to a suitably qualified Instructor and do a ground school, if required, and then enough flying, say 3-5 hours to pass a flight review in that type. Then you have the basics and hopefully wont scare the CP who doesn't have an instructor rating. It has never been the job of a CP to endorse you on type.

Leadsled I think you mentioned the thing about Part 61 that really annoys most people in that T & C approvals were not automatically turned into Flight Examiner ratings. That process is at the mercy of the individual FOI and costs thousands if you can convince them to let you do it. The CASA Impact Study said, "no appreciable cost to industry", which was one of the bigger stuff ups I have seen in recent history.

Groggy

[roundsounds]

Extract from the CASA website:
"General competency requirement
What is the general competency rule?
Every pilot must abide by the general competency requirement, which is covered in Civil Aviation Safety Regulation 61.385. This regulation means that you are responsible for ensuring you are competent to fly a particular aircraft and conduct a particular kind of operation, even if you hold the necessary authorisations. That includes being competent in:

- operating the aircraft's navigation and operating systems
- conducting all normal, abnormal and emergency flight procedures for the aircraft
- applying operating limitations
- weight and balance requirements
- applying aircraft performance data, including take-off and landing performance data, for the aircraft.
Pilots should consider undertaking training from a qualified person before flying a type of aircraft they have not previously flown, even if they hold the relevant class or type rating.

Always apply prudent airmanship before flying an aircraft you are not familiar with or haven't conducted a kind of operation recently."

[Duck Pilot]

roundsounds,
I can't see anywhere in 61.385, 61.1185 or any of the CAO 82 regs that states that a Chief Pilot would need to hold a G2 instructor rating.

The info sheets aren't legislation, they are merely advice/guidance material. The info sheet could be incorrect!

Check your PM.

[aussie027]

IF the new Pt 61 regs were to be greatly simplified, the general competency requirements listed above would some up most things as far as what is expected of a pilot to do before flying any type/class of airborne vehicle!!

Know your stuff and be competent and be safe!!:ok:

[roundsounds]

roundsounds,
I can't see anywhere in 61.385, 61.1185 or any of the CAO 82 regs that states that a Chief Pilot would need to hold a G2 instructor rating.

The info sheets aren't legislation, they are merely advice/guidance material. The info sheet could be incorrect!

Check your PM.
Thanks Duck Pilot. It's not the checking that's of concern, it's the training required to achieve competence for a new type within a class. See PM response.

[sillograph]

So who logs what, I thought ICUS was finished.

Only one can log PIC, what does the CP log... in say a 310, just duty?

So a new pilot has 8hrs twin total in class <5700kg, he needs 10 for IFR charter.

He used to go on a charter and get ICUS from CP, now if you do that who logs what. Does the Newbie log PIC and the CP nothing, surely not as newbie doesn't qualify for IFR charter as he only has 8hrs twin PIC, so the CP logs PIC what does the newbie log? how can he get his extra 2 hrs.

Maybe just fly empty for 2 hrs.....

[Car RAMROD]

From the CASA briefing newsletter, October 2015:

CASA has received feedback from the aviation community seeking clarification about how the new flight crew licensing regulations affect pilot in command under supervision (PICUS) operations. The concern is about who can be the pilot in command of a PICUS operation under Civil Aviation Safety Regulation Part 61. Operators who do not have a training and checking organisation under Civil Aviation Regulation (CAR) 217 may conduct PICUS operations. For these operations the pilot in command does not have to be an instructor or examiner. The reference in Part 61 to training and checking responsibilities does not mean there has to be a training and checking organisation in place. All chief pilots have training and checking responsibilities, even if the operator does not have a training and checking organisation under CAR 217. Operators regularly conduct PICUS operations by assigning a suitably qualified and competent pilot in the command seat as the pilot in command and another qualified company pilot in the other control seat, who acts as pilot in command under supervision. Civil Aviation Safety Regulation 61.095 does not preclude this activity. However, a chief pilot must be satisfied the pilot in command is competent operating from the other control seat and the operations manual needs to have adequate procedures in place for the operation to be conducted safely. Consideration has to be given to normal and emergency circumstances.


Roundsounds, if your having difficulty with the regs, bombard them questions. Copy your FOI, the team leader, and many other names up the chain asking questions. It does work and eventually you may get a satisfactory answer.

[Radix]

.............

[Radix]

.............

[djpil]

To add to roundsounds' post I suggest a look at
https://www.casa.gov.au/standard-page/general-competency-pilots-0

[roundsounds]

That is incorrect too, fortunately. You are NOT training them. They have already been trained (by Part 141/142) and found competent as their license irrevocably proves. You are just helping them understand what they already know, and you are not teaching them anything they didn't know.
Ok, maybe you could explain the intent of CASR 141.015(1)(g), convince CASA FOIs and have the information sheet amended?

[roundsounds]

Wrong. Nothing has changed. Although the information sheets give the wrong impression. Your license class rating is enough.

Some CASA people have been found to spread this misinformation too. Very unhelpful.

61.385 says precisely nothing by the way. Read it.
Several years ago I attended a CASA forum for Chief Pilots, a lawyer made a presentation based on the reg's. The point was made that according to the Civil Aviation Act reg's are to be interpreted on their intent and not literal reading.
The information sheets explain the intent. Although 61.385 doesn't say only an instructor can deliver training to get a pilot up to the MOS competency standard, CASR Part 61 (61.1165(e) Read it) only authorises a flight instructor rating holder to deliver the training to satisfy 61.385.

[djpil]

roundsounds: ... a lawyer made a presentation based on the reg's. The point was made that according to the Civil Aviation Act reg's are to be interpreted on their intent and not literal reading.Do you have a reference or a copy of the presentation please? It would help respond to a recent email that I (and others it seems) got from CASA about their inability to transition my privileges to Part 61 "In addition, this job requires some additional technical assessment, due to the complexities of CASR Part 61 and how they relate to your particular qualifications." Per their information sheet it is not complex at all "All flight crew will retain their current flying privileges throughout and following the 1 September 2014 transition." That seems consistent with the intent of the reg and, to me, seems the same as the literal reading but people in CASA seem to have a "safety" reason a pre-Part 61 privilege cannot be retained post-part 61.

[roundsounds]

roundsounds: Do you have a reference or a copy of the presentation please? It would help respond to a recent email that I (and others it seems) got from CASA about their inability to transition my privileges to Part 61 "In addition, this job requires some additional technical assessment, due to the complexities of CASR Part 61 and how they relate to your particular qualifications." Per their information sheet it is not complex at all "All flight crew will retain their current flying privileges throughout and following the 1 September 2014 transition." That seems consistent with the intent of the reg and, to me, seems the same as the literal reading but people in CASA seem to have a "safety" reason a pre-Part 61 privilege cannot be retained post-part 61.
Unfortunately not, Ron Bartsch was the presenter.
This might help though:

"ACTS INTERPRETATION ACT 1901 - SECT 15AA
Interpretation best achieving Act's purpose or object
In interpreting a provision of an Act, the interpretation that would best achieve the purpose or object of the Act (whether or not that purpose or object is expressly stated in the Act) is to be preferred to each other interpretation."

[Lead Balloon]

The point was made that according to the Civil Aviation Act reg's are to be interpreted on their intent and not literal reading.

The information sheets explain the intent.Whatever else the lawyer might have been trying to say, he wasn't saying that "information sheets" determine what the law means. The law determines what the law means.

Section 15AA of the Acts Interpretation Act? The "purpose" and "object" of the Civil Aviation Act and regs is, allegedly, safety. Which gets you precisely nowhere in working out the intent of the bugger's muddle, because one person's opinion about what is "safer" is another person's opinion about what is "less safe".

The "information sheets" are merely what the author earnestly hopes the law means. Nothing more.

[roundsounds]

Whatever else the lawyer might have been trying to say, he wasn't saying that "information sheets" determine what the law means. The law determines what the law means.
Section 15AA of the Acts
The "information sheets" are merely what the author earnestly hopes the law means. Nothing more.
I agree, the law does determine the law and if there's anything left open to interpretation the authority creating/enforcing the law has a responsibility to explain the intent - hence information sheets.
Let's say a scenic flight operator employs a keen new CPL holder to do scenic flights using an aircraft type the CPL holder hasn't flown, although they hold the appropriate class rating and design feature endorsements. The CP trains the CPL holder up in the type and lets him lose on scenic flights. The CPL holder mishandles a problem and in the aircraft in the course of a scenic flight, bends the aircraft and the pax suffer permanent injuries. The CP doesn't hold an FIR, how would the courts view the CP training up the CPL holder? The pax wouldn't need to work too hard to prove the pilot wasn't competent to fly the aircraft, nor would the insurance company.

[Lead Balloon]

I have NFI, except to say that the last thing the court would look at to determine what the applicable legal requirements were is an "information sheet".

[Radix]

.............

[roundsounds]

I have NFI, except to say that the last thing the court would look at to determine what the applicable legal requirements were is an "information sheet".
The courts are required to follow the direction of the Act directing how Acts are to be interpreted. This says wherever there's more than one way of interpreting a regulation the intended meaning is to be applied. CASA have effectively written the regulation and provided further information on the intended meaning of the regulation and you suggest the courts wouldn't look at this information?

[outlandishoutlanding]

roundsounds, the s15AA of the Acts Interpretation Act means that clauses are interpreted in light of s3 of the Civil Aviation Act 1988 (plus any other declarations of purpose, such as ministerial second reading speeches, etc).

viz.,

The main object of this Act is to establish a regulatory framework for maintaining, enhancing and promoting the safety of civil aviation, with particular emphasis on preventing aviation accidents and incidents.

(I am not a lawyer.)

[Lead Balloon]

CASA have effectively written the regulation and provided further information on the intended meaning of the regulation and you suggest the courts wouldn't look at this information?If the courts "look at" the "further information" it will merely be to be observe that it contains someone's earnest hope as to what the law actually means. It would be no different than the courts "looking at" a lawyer's opinion as to what the law actually means.

The courts will then get on with the job of interpreting the law in accordance with the laws for interpreting laws.

It's why some CAAPs contain this statement:A CAAP is not intended to clarify the intent of a CAR, which must be clear from a reading of the regulation itself, nor may the CAAP contain mandatory requirements not contained in legislation.Atrociously worded - yes. But the gist is correct: The law means whatever the law means. This CAAP (or "information sheets" or whatever) contains the regulator's earnest hope as to what the law requires and permits.

What you appear to be suggesting is that if CASA changed its "information sheet" the requirements of Part 61 would change as a matter of law.

Let's think about that.

Let's assume an information sheet says:Although 61.385 does not say only an instructor can deliver training to get a pilot up to the MOS competency standard, CASR Part 61 only authorises a flight instructor rating holder to deliver the training to satisfy 61.385.Someone in CASA wakes up tomorrow morning and decides that wasn't intended, and changes that information sheet to instead say:61.385 does not say only an instructor can deliver training to get a pilot up to the MOS competency standard. Therefore, CASR Part 61 does not prohibit someone other than a flight instructor rating holder from delivering the training to satisfy 61.385.Did that change in the information sheet change Part 61?

[roundsounds]

If the courts "look at" the "further information" it will merely be to be observe that it contains someone's earnest hope as to what the law actually means. It would be no different than the courts "looking at" a lawyer's opinion as to what the law actually means.

The courts will then get on with the job of interpreting the law in accordance with the laws for interpreting laws.

It's why some CAAPs contain this statement:Atrociously worded - yes. But the gist is correct: The law means whatever the law means. This CAAP (or "information sheets" or whatever) contains the regulator's earnest hope as to what the law requires and permits.

What you appear to be suggesting is that if CASA changed its "information sheet" the requirements of Part 61 would change as a matter of law.

Let's think about that.

Let's assume an information sheet says:Someone in CASA wakes up tomorrow morning and decides that wasn't intended, and changes that information sheet to instead say:Did that change in the information sheet change Part 61?
Let's see what comes out of the courts over the next year or so?

[Radix]

.............

[MakeItHappenCaptain]

Can anyone enlighten me on the 5 hours VFR and 10 hours IFR requirement for charter under part 61 on type that use to be part of the endorsement for commercial operators

Now if you have retract, constant speed, pressurisation on say a C421 then under the part 61 this entitles you to immediately fly say a Monave after a check out without having done the ICUS

Big mistake. Big. Huge. (Quote: Julia Roberts)

CAO 82.1 Para 4.1.1

Aside this, as a general note on the requirement for type training (beacuse I missed DH's comment about the check being done on first reading), there is the requirement to have done training to the requirements of the MOS before jumping into another aircraft. A Kingair falls under the MEA without a specific type rating and you might already have a Caravan endo and 20 hours in a Semenhole, but you'd have to be an absolute moron to think that allows you to jump in and blast off. I've already seen one potential jump pilot who thought because he had a duchy endo it allowed him to jump into a Navajo with nothing further required....:rolleyes::ugh::=

[dhavillandpilot]

Makeothappencaptain

It was a question rather than a statement

You're right no owner or operator is going to let anyone just jump into an aircraft and blast off.

My question was more in terms of very similar aircraft eg Seminole and dutchess

[roundsounds]

Information from further up the CASA info line confirms, as others have said here, the training and checking functions of an AOC allow the training to be conducted without holding a FIR.
Outside of an AOC, you definitely require a FIR (they're looking into what training endorsements are required). So private owners, syndicates and clubs need to ensure they only use a FIR holder to satisfy 61.385.

[Lead Balloon]

All just the earnest hopes of those in the CASA "line", where ever they happen to be in it.

What if Mr Skidmore's view of the "intent" is different?

Will that mean that what Part 61 means as a matter of law could change again? :eek:

[MakeItHappenCaptain]

Makeothappencaptain

It was a question rather than a statement

Sorry, the lack of a question mark on the second sentence kind of threw me there. No ill feelings there towards you and yes, any CP worth their salt should knock this issue on the head quick smart.

Ref. Duchess vs Semenhole, I would think that a 55 vs 58 Baron may be acceptable here, but Piper vs Beechcraft are definitely NOT in the same ballpark.

The second half was because there are some operators in "private" operations who are willing to believe whatever some junior burger CPL told them was their half arsed interpretation of the rules in an attempt to get some twin time up any way possible. My previous example was an actual occurrence, with the pilot having convinced the owner all was legal and showing up to start "ICUS" until I spent half an hour of my time covering system differences to illustrate why further training was required.