Charter operators held to airline safety standards

[Dick Smith]

So goes the headline on page 2 of The Australian this morning. Wow, how can this be a affordable?

Would someone be able to advise if our Part 135 is more onerous than the US Part 135? The FAA certainly don’t claim that their Part 135 is the same standard as their airline requirements.

Does this mean we have leapt ahead of the USA here and Australian charter passengers will be able to have a safer level of transport than the equivalent charter in the USA? It is certainly good to see what we are leading the world. Those Americans are so incompetent.

[LeadSled]

So goes the headline on page 2 of The Australian this morning. Wow, how can this be a affordable?

Would someone be able to advise if our Part 135 is more onerous than the US Part 135? The FAA certainly don’t claim that their Part 135 is the same standard as their airline requirements.

Does this mean we have leapt ahead of the USA here and Australian charter passengers will be able to have a safer level of transport than the equivalent charter in the USA? It is certainly good to see what we are leading the world. Those Americans are so incompetent.

Dick,
Leading the (aviation) world down the drain ---- It is beyond ludicrous to even suggest that say, a Cessna 206, can be operated at the same risk levels as a large passenger transport aircraft ---- but sadly the gullible public, who will never fly in Part 135, will swallow the PR nonsense ---- of course the "Australian" Part 135 in operation will be nothing like the US equivalent --- as I have posted in earlier threads, the aerodrome requirements alone will kill much light end charter, no more flying cattle buyers into farm strips --- or even many council aerodromes.

A good number of strips in ERSA (the operator has to determine "compliance") and, I would guess, a majority of the strips in the AOPA Guide and similar will not qualify for Part 135 use.

As for "scaleability" --- you can't hire a tenth of a person, so "safety manager" requires a minimum of one whole person, the overhead costs of solving non-problems will be crippling.

And, as ever, the final result will depend on what restrictions are imposed on operators by conditions forced on them by inclusion in the Operations Manual/Exposition by gung-ho FOIs.enthusiastically enforcing the CASA "policy".

Tootle pip!!

[Dick Smith]

I notice the airline pilot believes it’s a good idea.

i would imagine these new rules will close down even more charter companies and result in more people going on the roads or by airline.

Can someone post an example of the more expensive requirements?

[LeadSled]

I notice the airline pilot believes it’s a good idea.

i would imagine these new rules will close down even more charter companies and result in more people going on the roads or by airline.

Can someone post an example of the more expensive requirements?


Dick,
Part 139H aerodrome requirements compliance, maintenance only to Part 42 in a Part 145 organisation.
Tootle pip!!

[Snakecharma]

I just wish some airline operators were held to the standard required of airline operators, not pointing fingers, just a generalisation.

[Dick Smith]

Here is a link to a copy of the aviation safety brochure (http://rosiereunion.com/file/Safety%20brochure%201998.pdf) that was prepared during my time as CASA Chairman.

Are we now to believe there is just one standard of safety?

It is interesting – we sent the brochure out to every politician in Australia and to journalists, and received absolutely no controversy at all. Many people said to me, “Dick, that is just common sense. It should have been said before.”

I understand when I resigned from CASA that the brochure disappeared. Someone reckoned it was shredded, others said it was simply dumped. Does anyone know what actually happened to it?

Should it now be re-written to show we have one level of safety and the reality of affordability is no longer a factor?

[thorn bird]

Leadie, regardless of the "rools", maintenance must still be conducted according to the Manufacturers maintenance Manuals plus all
CAsA's inane add on's. The difference with part 145 will be all the hangers that will need to be built to store the added paperwork and employing
dozens more engineers to fill the paperwork in. Oh forgot CAsA has made getting an aircraft maintenance ticket so expensive and onerous nobody
wants to do it anymore. Maybe CAsA could bring in a new licence category called LAMB (Licenced Aircraft Maintenance box ticker).
I guess the industry cannot say they were not warned, both you and Dick tried, now, GA is being lead like lambs to the slaughter, GA, as
we knew it, is finished in Australia.
Emergency work will be handled by the Corporations masquerading as charities, they pay no Tax, GST, air NAV charges, and receive considerable
tax payer largess, so they will survive. When you can gain a licence overseas for half the cost in Australia, flying training will desert us. As happened in Europe the availability and cost of the last men standing in Corporate charter will drive those who avail themselves of those services to buy their own.
Keep them on foreign registers, with foreign crew and maintenance.
All in the name of safety of course.
If Australia is so safe, safest in the world they tell us, why are all these obviously dangerous foreign airlines permitted to fly into Australia?

[Dick Smith]

This is consistent with CASA maintaining that the words -“ the most important consideration is safety” remain.

The more Charter operators that go out of business the better the Airlines do.

Try and charter a modern twin from Bankstown. Not possible!

[LeadSled]

thornbird,
Re. maintenance --- exactly, the "hands on" is the same, but a staggering increase in overhead costs that contribute exactly zero to risk reduction (safety??) in a very small fleet of very small aircraft.

Imposing a system designed for a large fleet of one type of large aircraft, onto a diverse fleet of many types of small aircraft ---- the cost is scary.

One "interpretation" I have from an FOI is that a pilot will no longer be able to do a daily inspection, LAME only.

Needless to say, the CASA "145" is quite different to FAA or even EASA --- on the basis of "we know best", the administrative burden and associated $$$$ of the "complexity by CASA" is what will be just one nail ---- but the most important and unjustified are the operational limitations.

If you can't fly "there" because the airfield is not in the FCOM, no aerodrome forecast and NOTAMs, and the obstacle survey is not up to date (what obstacle survey for a private VFR strip) etc., etc., etc., all "operator responsibility", doesn't matter how "well" the aircraft is maintained, if you are not permitted to "fly the route".

The whole thing is a nonsense, don't forget it is combined with an equally nonsensical Part 91, where the ICAO/Rest of the World rights of the pilot in command have been largely "legislated away" --- we can only hope a disallowance motion is moved and is successful.

Tootle pip!!

[Horatio Leafblower]

This isn't about "raising the standards" of existing operators - the effective outcome is that existing small RPT operators will survive, and non-RPT operators will not.

Large operators will survive, small operators will not.

Corporates will survive, family businesses will not.

Currently one person can fill the roles of Chief Pilot, HOTAC, HAAMC, Safety Manager etc. When times are tough a business can contract and all the roles are filled, all the jobs are done, AOC requirements met.

The article makes much of the "scalability" but let's look at the cumulative effect. I have had this priced up for my business which is middle to large "family owned" charter shop, 4 pilots plus self plus 1 x Admin.
- Safety Management -outside contractor $35,000/year
- Part 42 CAMO - $15,000/year
- Part 145 maintenance +50% on current spend = ~$150,000
- Add approved MEL and SOM on each aircraft currently operated on Charter: $2,000 each (remember that a MEL and a SOM is operator specific so I can't short term cross-hire any more)
- Add Fatigue Risk Management System $25,000 OR add extra pilot due loss of operational flexibility $85,000
- Contract C&T services - about $2500/pilot/year about $12,500

Total effect - estimated - about $250,000 in the first year and then $200,000+ per annum going forward.

Add to this GA insurance premiums rising for all operators on average 20% and increased borrowing costs into next year because the USA is raising interest rates, even if Australia isn't, and the AUD is dropping so the banks are paying more for the funding too.

Lots of cheap aircraft, hangars, and business owner's houses going cheap from March 2021.

What THAT means, in turn, is that I need to find another $1.5m in revenue each and every year which translates to between 700 and 1200 hours of revenue flying, which in itself adds another 2 full time pilots, maintenance, fuel, CAMO charges, SMS charges, Check & Training costs.....
-

[Sunfish]

The airlines and the military seem to be in league with CASA in their push to destroy GA. The motives include:

- property development. (CASA and it’s masters)

- Commercial growth opportunities and elimination of possible competition (airlines).

- removal of a nuisance. (defence)

‘’We just want a nice quiet club where everyone scratches each other’s backs.

[Ex FSO GRIFFO]

And I can remember the time when an aeroplane was either 'safe' or 'not safe' to fly, regardless of the 'type' of operation...…

i.e. I would not fly an 'lower standard of safety' aircraft in a private op., and then a 'higher standard of safety' in a Charter op.

I (foolishly it seems), expect that the aircraft be simply 'safe'.

It either is, or it isn't. What was wrong with that??

No cheers.....

(Hat, coat...…)

[neville_nobody]

Nothing will change CASA will just start handing out exemptions for everything that they have put into law. Thats how the system has always worked.

It will just take one charter operator with strong political connections or an Aboriginal Corporation to create a political problem for someone and it will all be solved with exemptions all round

[LeadSled]

One has to wonder what CASA is up to. The rumour is that charity flights and volunteer pilots are going to have new ‘directions’ and there’ll be some kind of ‘document’ for feedback ..... over the Christmas holiday. Cant help thinking what else they might be trying to reregulate parachute ops? gliding? Scout flying?



Clear etc.,
Not "re-regulate", that's the wrong word, there is only one "regulator", and that is CASA ---- but they think they can produce the written equivalent of an Airbus flightcontrol program in words, to describe, define and direct every minute phase of flight, micromicromanagement to the max, and your absolute 100% compliance (or give up flying) on pain of a criminal record and huge penalties (50pp is now over $10,000) will ensure something called "safety" as the end result.

Strangely, most other nations with an aviation sector anything like Australia (say, USA, CA,NZ, UK, EEC/EASA) with a GA sector are going in the opposite direction. Of course, the US safety record is way better than AU.

Interestingly, if you look up the record, FAA removed "scheduled air taxi" from their Part 135 some years ago and elevated it into Part 121, where it became the Regional airline sector ( much like Australia starting with the old ANO 203 exemption [or was it 208] which is where our "Commuters" started) and after some years did a very careful post-implementation review. FAA (unlike CASA) does admit mistakes -- FAA admitted that, for the several hundreds of millions of $$ expended by operators---- FAA COULD NOT IDENTIFY ANY SAFETY BENEFIT. Proving that imposed $$$ administrative burden does not have any necessary inverse relation to accident rates.

NO OTHER COUNTRY --- that I have been able to find ---- even suggest as a policy, let alone black letter law, that a C-206 can be operated to "the same level of safety" as a large airline aircraft --- they are just not that stupid.

And please look at Parts 119 and 91, just reading Part 135 will not give you anything like the "big picture" of this administrative juggernaut soon to roll over you.

Tootle pip!!

PS: CASA have plenty more administrative solutions in search of a problem.

[Jetman346]

This is complete madness, gone are the good old days of GA, as much as i miss flying i just could not be bothered with the whole process anymore, casa seem to have no clue and really need guys like dick with operational experience and common sense not pencil pushers who have little idea about aviation

jetman

[Dick Smith]

I have recently received an email from a friend of mine who has been involved in the industry for a long time. It contained the following truism.

“Some operators will go out of business due to new Parts 135 ad 121. Absolutely unnecessary, with no increase in safety.”

Does anyone have any information on who may be going out of business and the reasons for this?

[Horatio Leafblower]

Dick,
There's currently over 500 entities holding AOCs in Australia authorising Charter operations in Single-Pilot certified aircraft (B1900, Metro 23 and down).

Of those, 23 hold AOCs authorising RPT operations in single-pilot certified aircraft.... Hardys, Chartair, Aviair, Corporate etc.

Everyone currently operating a Grand Caravan, a B200 KingAir, a Bandierante or a Metro II on Charter with more than 9 passenger seats will jump from Charter straight to Part 121, same as Qantas. The vast majority of those organisations will disappear.

Everyone operating 9 seats and below who does not have an RPT certificate or >10 full-time pilots will not survive.

If Parts 119, 121 and 135 are enacted as made I predict there will be less than 50 General Aviation Air Transport AOCs remaining in 2022 from the 500 today.

[Duck Pilot]

Jetman,
I spent 2 years of my working life trying to write Part 91 and 135 and I went to CASA with a lot of good broad operational experience. In the end I got absolutely frustrated with the processes and subsequently transferred to Darwin as an FOI. Sadly I only spent 12 months as an FOI before moving into the Oil and Gas industry.

CASA will never be able to retain experienced industry professionals in the current climate, particularly with regards to pilots.

I honestly have no idea how CASA are going to get all their inspectors trained up to manage the transition, whilst the organisation continues to manage BAU.

[Lead Balloon]

I honestly have no idea how CASA are going to get all their inspectors trained up to manage the transition, whilst the organisation continues to manage BAU.Actually, like a number of others on this forum, you have sufficient first-hand knowledge to reasonably predict the likely outcome: The transition will be another clusterf*ck.

But it’s fine. The only collateral damage will be the destruction of businesses and careers and the life’s work of people in GA charter. Safety is, after all, the most important consideration.

Fortunately those who deliver this ‘safety’ are secure in their six figure annual salaries.

[roundsounds]

Jetman,
I spent 2 years of my working life trying to write Part 91 and 135 and I went to CASA with a lot of good broad operational experience. In the end I got absolutely frustrated with the processes and subsequently transferred to Darwin as an FOI. Sadly I only spent 12 months as an FOI before moving into the Oil and Gas industry.

CASA will never be able to retain experienced industry professionals in the current climate, particularly with regards to pilots.

I honestly have no idea how CASA are going to get all their inspectors trained up to manage the transition, whilst the organisation continues to manage BAU.




probably to same standard as they have trained their staff in the application of Parts 61, 64, 141 and 142. “If in doubt, revert back to CAR 5, CAO 40 etc.” seems to be the approach. Even a significant number of CAAPs still make references to CAR 5, the Flight Review CAAP being a classic example.

[LeadSled]

Folks,
In the real world, which excludes Canberra, what was the problem, to which this is the answer.
Tootle pip!!