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Now is your chance to remove unnecessary rules and costs/VOR airspace thread merged

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Now is your chance to remove unnecessary rules and costs/VOR airspace thread merged

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Old 20th Jun 2007, 09:20
  #61 (permalink)  
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.. it seems there is a reference in ERSA after all

.. and we didn’t swear at each other once
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Old 20th Jun 2007, 09:39
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To take this LAME/AME/A&P thing further.

Just changing what they are called and varying the qualifications alone will do little to impact the costs of maintenance unless the regulatory burden is removed also.

That regulatory burden includes massive compliance red tape/costs imposed by CASA/AsA/EPA etc on top of increasing costs associated with hangar/site lease imposed by local councils/airport owners.

That regulatory burden has been solely responsible for chasing many self employed LAMEs out of the business and reducing competition for the private aircraft maintenance $. It all just got way too fecking hard and they closed up shop, retired or went to work for someone that had a thicker skin.

The analogy I will use is that of the tucker truck v Milk Bar/takeaway shop.

This may be one of the best arguments for GA self regulation for private/airwork category aircraft < 2000kg (for instance). A system where a LAME/AME/A&P can set up a business from home where he has a van set up and can travel to your aircraft and do annual inspections/general maintenance in your hangar...with none of the regulatory overheads that have zero effect on the quality of the maintenance carried out.

Annual inspections cost 6+ times what they did 20 years ago. Yes some of that expense is driven by the fact that we left a regulatory regime based around 3 yearly airworthiness inspections and moved to a annual inspection regime but that is not the whole story...the regulatory compliance burden imposed on licenced maintenance hangars is extreme both in a pure cost sense and a time wasted sense...and it has zero effect on the bottom line...maintaining an ageing fleet.

Labour rates for LAMEs are up around $80/hr...yet the individual gets probably only 1/2 that...the rest goes on covering the overheads. That is where the savings are in aircraft maintenance.

Last edited by Chimbu chuckles; 20th Jun 2007 at 11:27.
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Old 20th Jun 2007, 10:50
  #63 (permalink)  

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I have a question for you Dick.

AsA have deserted SBAS/WAAS in favour of GBAS/GRAS, despite the EU,US,India and North Asia adopting SBAS...GBAS/GRAS is a system that will very likely be uneconomical for GA aircraft...certainly those older aircraft not fitted with the integrated G1000 style avionics.

On that basis we appear to be starting down a path that could, in time, exclude most GA aircraft from the ability to carry out GPS based precision approaches.

Why would that be?

Last edited by Chimbu chuckles; 20th Jun 2007 at 15:03.
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Old 20th Jun 2007, 13:51
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Torres,
It is a sad fact of life that there are very few maintenance outfits employing apprentices. They scrounge for the LAME's they can get and supplement them with 'AME's, a loose term to describe unindentured apprentices, or mature people working on their schedule of experience in preparation for their LAME ticket.
As Chimbu said, almost ALL labour gets charged out at the same rate, LAME or otherwise.
The aircraft owners are paying for the training on type - not the maintenance organisations!
Sorry to get a bit off thread, but the subject is relevant given the high degree of regulatory cost involved in maintenance.
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Old 21st Jun 2007, 00:45
  #65 (permalink)  
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Is it possible to focus again on requirements in Australia which add to costs compared to requirements in other leading aviation countries?

I have agreed to make up a list to present at the next Taskforce meeting on 2 July.

Here is another one.

Helicopter low flying endorsements
In the USA under the FAA system, a low flying endorsement (with all the additional costs) is not required. The FAA regulations are written so this is not required. This is logical as once a helicopter pilot gets his or her licence, he or she can land basically anywhere that they have the owner’s permission – which obviously means they must be trained at flying low.

I should point out that lots of people are complaining about the new CASA costs for regulatory services. I agree this is a real impost, however compared to the on cost from unique Australian requirements, they pale into insignificance.

Also if we update the rules and harmonise as per Government policy, there will be no need to make these extra payments. For example, the cost of getting a low flying endorsement will be removed as it won’t be required for helicopters.
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Old 21st Jun 2007, 01:58
  #66 (permalink)  
 
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Question Helicopter low flying endorsements

Dick,

Helicopter low flying endorsements

Technically, no such animal: a common industry misnomer!

For some applications, CASA require a pilot to have completed the low flying syllabus of either the Ag or the Mustering endorsement. The Low Flying Approvals on my AOC require pilots to have this for filming & photography, and I must confess that I have no issue with it as a condition. It goes some way toward ensuring that pilots are trained and up to speed before they get down in the weeds tracking a car in a commercial, or similar.

But otherwise, there is no Helicopter Low Flying Endorsement from CASA: has someone raised this with you as an issue?
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Old 21st Jun 2007, 03:20
  #67 (permalink)  
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John, point taken – maybe they are just letters of dispensation.

Can you advise how a private pilot gets approval for low flying – say for private photography purposes?

I will look forward to your advice.
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Old 21st Jun 2007, 06:10
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Dick,
Re low flying endorsements- Unfortunately the rules have to cater for the lowest common denominator. A poorly trained chopper pilot might fly low and spook livestock such as a horse and cause all sorts of problems such as throwing a rider off one's mount.
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Old 21st Jun 2007, 06:28
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Dick,

Interesting point re a PPL(H), and one which I haven't had to deal with

My best guess would be to apply to CASA for a Permission against CAR157, but (as we all know....) the answer will vary from State to State and from FoI to FoI

Have you had any direct experience of such a requirement?
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Old 22nd Jun 2007, 02:05
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Local ownership for towers and fire fighting

Why hasn’t anyone come up with this big money saver? We all know that Airservices are now operating Class D towers in the USA at a claimed 50% reduction in cost compared with the cost of the FAA running them. This is because of the FAA Contract Tower program. It has saved the American aviation industry tens of millions of dollars.

Why hasn’t anyone proposed it here? It is in fact Government policy. I’ve been contacted by many air traffic controllers and a group of firies who want to run their own businesses. They say that savings could be up to 50%.

I understand the main reason the Government hasn’t gone ahead is that there has been no support from industry. Why would this be so?

If the FAA can get a 50% saving, and if virtually every other country in the world (other than possibly Russia) operates fire stations locally at the most competitive price, why can’t we? The last time I looked, the Australian average per tonne landed fire fighting charge was double that of the average charge in New Zealand – where the fire stations are locally run by the airports at the most competitive price.

I look forward to comments on this.
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Old 22nd Jun 2007, 02:08
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What about Part 135 – Air Taxi?

We presently have a crazy system in Australia, where if you want to charter a Navajo from Dubbo to Narromine, it has a completely different regulated system of safety compared to flying on a scheduled service on the same route with the same plane. This is ridiculous. As pointed out in the Commission of Inquiry into the Seaview crash, passengers could not possibly understand the difference.

In the USA they have Part 135 Air Taxi, and Part 135 Scheduled Air Taxi. Surely that is what we should be going to here. I understand it could save a huge amount of money, because presently our scheduled 9 passenger services have to comply with some type of sham airline regulations – even though this is obviously not possible.

Is there any support for this?
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Old 22nd Jun 2007, 05:17
  #72 (permalink)  
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John, you say you have no issue with the CASA requirement for a pilot to complete the low flying syllabus of either the ag or mustering endorsement – but this adds to costs compared to an equivalent business in the USA. I’m sure you understand this. Why should we have higher costs here if they are not required in the USA, and if the resultant level of safety is the same?

This is one of the problems I see. With virtually every potential saving I can see, there is someone in the industry who says that they support this particular “extra cost” but they are against others. When CASA goes to change the rules to harmonise with other leading countries, they get many people saying we should have higher costs and more regulations!

In relation to flying below 500 feet, when I flew around the world I obtained some type of approval to fly lower, as you will probably see in some of the documentaries I made. I’ll dig out the approval – I must have it in my files somewhere.

The main point once again is that getting this approval costs time, and in future will cost money. In the USA a pilot can fly at these lower levels without extra costs and bureaucracy.
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Old 22nd Jun 2007, 05:43
  #73 (permalink)  
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Re ARFF and TWR's

... could you explain where one could obtain information (from a credible source) to the support those claims?

.. following on, if the 50% claim is credible, where is the efficiency difference generated and who pays??
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Old 22nd Jun 2007, 06:56
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Dick,

Re the "cost" of low flying. I understand your point, but I do believe that high risk low level operations require a degree of control, albeit that control is at a cost. Where do we draw the line as to who is capable/qualified enough to be filming and chasing a car at 10 feet, avoiding power lines/trees/turbulence? Is a 1000 hours enough? 50 hours? By complying with a known syllabus of training, there is a good chance that the pilot is aware of risk factors, and will plan and fly accordingly. What about firefighting: what do you consider a suitable endorsement to be to qualify a pilot to lug a tonne or more of water on the end of a 100 foot line through smoke and turbulence?

I would strongly suggest that some aspects of aviation do require a higher degree of skills, and achieving those skills must come at a cost. What height would you consider plausible for a new PPL/CPL(H) to be allowed down to as part of his everyday operation?

Thanks

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Old 22nd Jun 2007, 07:01
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Dick:

Here's one for you.....

Currently, Single-Engine Piston aircraft can not conduct IFR Charter Flights or VFR Night Charter Flights.

However, this is now possible in the USA.

Check this company out: http://www.satsair.com

SATS Air is authorised by the FAA to conduct Part 135 Air Taxi in a Single-Engine Piston aircraft - In this case it is the Cirrus SR22.

Apparently, SATS Air has this approval because: SR22 has downloadable Engine Data for trend Monitoring, The SR22 has multiple backup systems (2 x Alternators etc), SATS Air Maintenance program and the Cirrus Parachute System.

In order to save costs, CASA should consider certain operators to be able to use single-engine piston aircraft for IFR Charter if:

1. Suitable Operations Manual proceedures in place.
2. Suitable Single-Engine Piston Aircraft (need not be an SR22 as a C182 can be also be fitted with a parachute as an after-market mod).
3. Suitable maint. program with trend monitoring and oil analysis etc.
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Old 22nd Jun 2007, 09:24
  #76 (permalink)  
 
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Dick:

We presently have a crazy system in Australia, where if you want to charter a Navajo from Dubbo to Narromine, it has a completely different regulated system of safety compared to flying on a scheduled service on the same route with the same plane. This is ridiculous. As pointed out in the Commission of Inquiry into the Seaview crash, passengers could not possibly understand the difference.
We used to have ANR 203 scheduled services in Australia (approval to conduct scheduled air services without holding an airline license).

Read the pre 1988 ANR 197 to ANR 203.

Reg 203 air services developed rural Australia and were the origins of many airlines, including Eastern and Hazelton/REX.

Neither ANR203 scheduled services, nor rural air services exist in Australia. My estimate, 100 plus rural Australian air ports lost their services in the past 20 years.
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Old 22nd Jun 2007, 11:38
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Why hasn’t anyone come up with this big money saver? We all know that Airservices are now operating Class D towers in the USA at a claimed 50% reduction in cost compared with the cost of the FAA running them. This is because of the FAA Contract Tower program. It has saved the American aviation industry tens of millions of dollars.

Why hasn’t anyone proposed it here? It is in fact Government policy. I’ve been contacted by many air traffic controllers and a group of firies who want to run their own businesses. They say that savings could be up to 50%.

I understand the main reason the Government hasn’t gone ahead is that there has been no support from industry. Why would this be so?

If the FAA can get a 50% saving, and if virtually every other country in the world (other than possibly Russia) operates fire stations locally at the most competitive price, why can’t we? The last time I looked, the Australian average per tonne landed fire fighting charge was double that of the average charge in New Zealand – where the fire stations are locally run by the airports at the most competitive price.

I look forward to comments on this.
Was waiting for this one.

There are two things wrong here, still. 50% cheaper than the FAA doesn't mean cheaper than Australia and 2) Because they are doing it doesn't mean it is profitable, now does it? The paper cost to industry hasn't changed at all; just the way the buckets have shifted the money. Since ASA moved in providing the costs at 50% of the FAA have charges gone down by 50%? No didn't think so. With the greatest respect you love a headline; but what is the substance of the story. ASA is probably making a break even type operation; but now that they have to change the hours of coverage will they be able to do so 'profitably'?

You may note that under the new business structure ASA is positioning the RFF for a "fire sale"; can't see it being sold as single station units, just one business; want to buy it; how else do you get a monoply type business not subjected to true competition. The private equity money men will be beside themselves to secure that baby; will the industry benefit; hah! Of course there will be strict service limitations legisilation about minimums etc. but watch the costs spiral shortly after they "own the business"; in the same way that FIS provision has been done in the USA; $3M in fines for $170M or so in extra revenue; all in the name of cost savings that aren't realised in practice.

Who are this 'group'? I want to talk to them and get on board; it won't save the industry a cracker, but I'm willing to line my pockets.
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Old 22nd Jun 2007, 12:18
  #78 (permalink)  
 
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If it was me I'd remove Dick Smith AND all the high-drag stuff he has imported. Class E airspace f'rinstance. 250 knots below ten. What is the use of letting yourself be ruled by other country's solutions to problems you don't have?
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Old 22nd Jun 2007, 13:28
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2) Because they are doing it doesn't mean it is profitable, now does it? ASA is probably making a break even type operation;
I would be appalled if Australian taxes, or income from my charges was being used to subsidise the cost of airways services in the USA!!!!!

I trust there is no truth to your allegations.

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Old 23rd Jun 2007, 00:33
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Wouldn't surprise me. Transfer pricing isn't limited to the supermarket chains. We sell the world's best quality wheat at a discount to the domestic price ! Australia is possibly unique in that you are asked to 'tender' a price to Government or big business - when you are the only providor of that service!

happy days,
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