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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 14th Jun 2007, 23:49
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Now is your chance to remove unnecessary rules and costs/VOR airspace thread merged

I have so far attended two meetings of the Aviation Regulation Review Taskforce set up by Minister Mark Vaile. I believe there will be some very positive changes to assist aviation.

It is obvious to me that after many years of not really getting anywhere, in the last 18 months the people at CASA are focusing more on Government policy in relation to rule writing – that is, to only be prescriptive where required, harmonising internationally wherever possible, and ruthlessly removing any rule which adds to cost without effectively adding to safety.

In relation to this last point, I have been asking people of requirements in Australia which add to costs compared to requirements in other leading aviation countries. I ask one of the Moderators to “sticky” this thread so we can get a list of such items from anyone who is interested.

I will start off with a few here, and I look forward to dozens (if not hundreds) more.

Simply by listing these additional costly requirements does not mean that CASA will necessarily follow what happens (and is proven) overseas. In some situations – but not many – our conditions are different here in Australia. However if the differences can be brought forward, at least the people who have the responsibility in relation to regulatory reform can look at the issues.

I start as follows.

1. The requirement in Australia not to fly above 10,000 feet without oxygen. In the USA it is 12,500 feet for continuous flight and up to 14,000 for 30 minutes. A rough calculation shows that over $1 million per year could be saved in fuel costs alone if we harmonise with this requirement. And of course often the aircraft could be above the inversion layer flying in smooth air.

2. The requirement in Australia that if a pilot is to perform a straight-in approach it must be at least a 5 mile final. Imagine the time that is wasted by a farmer landing on his grass paddock or a cropduster wanting to do a straight-in approach. This is a unique Australian requirement – probably designed for 747s, but hardly necessary for the Piper Cubs and Cherokees which it applies to. A lot of fuel will be saved if this is harmonised internationally.

3. The requirement that flight instructors must operate under an AOC. In the USA, most flying training is by highly experienced instructors – quite often older, more mature pilots – who operate independently without the high cost of an AOC.

4. The unique Australian ADs, including AD/GEN/37, which requires the emergency exit of an aircraft such as a Citation to be operated and inspected every 6 months. Under the FAA requirements it is once every 3 years. This means the Australian cost is 6 times greater, possibly without any measurable increase in safety. There are many other costly ADs like this – such as AD/INST/9, which requires instruments to be removed from the panel every 3 years to be tested accurate. However many modern LCD indicators cannot be tested unless they go back to the factory – costing a small fortune (if indeed it is to be complied with).

These are just 4 examples. I look forward to others. I will compile a list of everything that is posted and send it off to the people who are developing the standards in CASA.

Last edited by Dick Smith; 15th Jun 2007 at 00:41.
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Old 15th Jun 2007, 00:46
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Dick,

1. Just because they do it in the US does not make it better or safer. The US has far higher terrain and as such MSAs - in some cases necessitating flight above A100 - we don't. The physiological aspects of operating for extended periods with a cabin alt of over A100 must be considered and IMHO not worth the increase in risk in Australia.

2. It is my understanding that the requirement for rejoin via a 5nm final is for licenced airfields only and therefore your example of a farmer & paddock or a crop-duster (unless it is at a licenced field) is erroneous. Given the frequency of most recreational pilots flying I would think it prudent to maintain this requirement so as to facilitate identification of all circuit traffic especially now that you have allowed non-radio equipped aircraft to operate.


Perhaps you might look at how CASA can justify charging $130 (soon to become $75) to process medical licences for those without restrictions ie. no thinking required. Even at $75 this is ridiculously expensive.
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Old 15th Jun 2007, 01:45
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Cessna 400 series spar cap inspection. Why is Australia the only country in the world requiring Cessna 400 series aircraft to go through a spar cap inspection and replacement each 8,500 hours, at a cost of $50,000 to $100,000?

The Aero Commander 500S was certified in Australia at < 10% above it's FAA Manufacturer approved Maximum Take Off Weight. Why is this aircraft permitted to operate in Australia on commercial passenger operations at weights at which it can not achieve minimum performance requirements?
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Old 15th Jun 2007, 02:19
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Air taxi category

There is a need for an air taxi category to be introduced. Low capacity RPT is dying. It is not viable to operate 9 seats to RPT in the bush.
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Old 15th Jun 2007, 02:20
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I've got one. Get rid of the useless non-radar E airspace band between 185 and 245. It prevents IFR aircraft from using block levels, thereby wasting fuel, discomforting passengers and preventing crews from easily finding smooth air to operate at the most economical speeds, all because of the VERY FEW Australian-registered VFR aircraft that are legally permitted to fly above FL200 and whose pilots are selfish enough to want to put themselves ahead of thousands of other airspace users.

probably designed for 747s, but hardly necessary for the Piper Cubs and Cherokees
There you go, living in your own vacuum again. Have you ever thought of the poor 737 crew trying to spot a bugsmasher joining a 1nm oblique final under their nose? I didn't think so. If you want to remove the rule for your paddock, then that's fine. Just make sure that's all that's changed. Aviation is getting dangerous enough without a free-for-all in the CCT.
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Old 15th Jun 2007, 03:00
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What barra21 said. Re-introduce low capacity RPT operations similar to the previous ANR203 Exemption for aircraft less than 5,700 kg, maximum nine seats.

And why are AOCs not perpetually valid (until suspended or canceled) as was the case in previous years?
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Old 15th Jun 2007, 03:19
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Dick, I agree with your third point. The US CFI system would be a benefit for Grade 1 qualified instructors.

My personal hate is the blunderbus approach for issue of ASIC. Surely there has to be something that could reduce the footprint of sterile areas to only those areas used by RPT. BDV with the same security req as BN is a joke. Surely a trigger would be a Dash8 service as a minimum and only then for an hour either side of ops and only within a confined area in front of that terminal.

Tell the Government to control its tenants wrt leases of GA airports.

Tell real estate hungry councils and developers that an aerodrome is for the exclusive use of aeroplanes and ancillary services. Aeroplanes will make noise around these aerodromes that non-aviation savy people will find offensive. Footprint maps must be included in all transactions over the sale of properties within an exposure area of these aerodromes to ensure that NIMBY groups (normally consisting of one owner making a lot of noise) are fully aware of what they are living next to.

Tell state governments to change their laws that allow mates to charge for the use of airspace above their airports. Unless an aid is bought and payed for by the owner of said airport, they should not have rights to charge for commonwealth owned and operated property.

Tell the Government to seriously look at the feasability of providing a WAAS capable signal from the Japanese MSAT to be beamed over the entire continent and surrounding oceans within the economic zone. This will be of more benefit to the wider community than just aviation. Travel/Tourism, transport, survey industry, shipping, customs, recreational sports,...a lot more people than you would expect. For us it gives a better outcome for regional and remote aerodromes to have a safe and viable option for vertical guided approaches that will not be available from ground based augmentation systems that are currently being promoted.

No one is asking for a subsidy. Aviation is an important piece of infrastructure that just simply falls off the radar when it gets outside the J curve from CNS to AD with a bit out in PH. A community aerodrome is just as important as a bitumen road. The only time it gets noticed is when someone has to move in a hurry, or medical emergencies and natural disasters.
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Old 15th Jun 2007, 04:00
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Condition lever, I knew this had to happen. I have never said that something is better or safer in the USA, I’ve just said that if we have higher costs, our industry will be destroyed – and that is happening.

1. If there was an increase in risk in operating above 10,000 feet without oxygen, this should surely be reflected in the US accident rate – however it is not. If you look at the GA accident rate in the USA there is no measurable difference to our accident rate - even though they have months of snow and ice, huge high mountain ranges and 15 times the amount of traffic.

You state it is:

IMHO not worth the increase in risk in Australia.
Can you advise what information you have that there is a measurable increase in risk?

Also, do you think it is sensible for a pilot and passengers to be bashing around in the most incredible turbulence at 10,000 feet when they could be at 11,000 or 12,000 feet in smooth air? I certainly don’t.

2. Your understanding in relation to the 5 nautical mile final only being required at licensed airfields is wrong. The requirement is for all landings. This means that my example is not erroneous.

Once again, you are resisting change. Everything must remain the same, nothing must ever change. Then we will all be comfortable – won’t we?
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Old 15th Jun 2007, 04:04
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The requirement that flight instructors must operate under an AOC. In the USA, most flying training is by highly experienced instructors – quite often older, more mature pilots – who operate independently without the high cost of an AOC.
I'm not sure that "most" flying training in the USA is by independent instructors and the downside is the higher number of hours that the FAA requires for their students compared to those of an approved school. Still, it seems to work well with "older, more mature pilots" called upon as FAA Safety Counsellors and involved in their WINGS programs etc.
Merging the bottom end of GA with RAA type ops would seem to be part of the answer.

On the hardware side:
There's a requirement for an "export airworthiness approval" per section 7.1 http://casa.gov.au/rules/1998casr/021/021c22.pdf
Some relaxation of this should be considered. A part from the USA with a PMA comes with a release certificate from the manufacturer. If I order a part for my aeroplane I also need a Form 8130.
One example at B&C- an oil filter adaptor for uncertified aircraft sells for $395. I don't have a problem in them recovering the extra costs for the PMA'd one at $450 (exactly same part, they just ask whether you want the extra bit of paper when it is delivered). I have a problem when they say it is for Australia so needs yet another bit of paper and the extra cost just pays for some-one to visit their factory and sign it - for an extra $100.
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Old 15th Jun 2007, 04:21
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Keep them coming! This is really important. In relation to the ASIC, my friends who fly a Falcon 10 in the USA do not have ASICs – they are not required.

What about this one? In Australia a student pilot needs to get an ASIC, with all of the costs and delays involved. In the USA there is no such requirement – and remember the US is the home of September 11 – the instructor simply has to check that the pilot is an American citizen by looking at a birth certificate or passport.

Djpil, you say:

I'm not sure that "most" flying training in the USA is by independent instructors
I can assure you that the latest statistics show that over 60% of training in the USA is performed by instructors who are independent of a flying school which would hold the equivalent of an AOC in Australia. That’s a good idea too, but direct training by an instructor would have great advantages in reducing costs here in Australia – especially in our more remote country towns.

As I said, keep them coming.

Last edited by Dick Smith; 15th Jun 2007 at 04:43.
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Old 15th Jun 2007, 06:30
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How about a rule that allows you to write off an aircraft purchase in 3 years? That would kick start the industry.
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Old 15th Jun 2007, 08:23
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I don't know that the Oz v US O2 rule is that big an issue in an urgent regulatory sense.

Things that do need fixing urgently...in no set order,

* Medical fees: Take it out of CASA's hands and put it in the DAME's..period.

* ASICs: Pure unadulterated stupidity of Pythonesque proportions...particularly as it effects student pilots but also airports that are effected...Toowoomba as just one example...Grafton another...there are LOTS more They should ONLY be a requirement at capital city airports such as SY,ML,CB etc.

* Pilot training: There needs to be a way to facilitate experienced pilots who want to 'put something back'. Pilots with a background in training outside of the ab initio/flying school system but that have a great deal of training and checking experience within the broader regulatory framework. The US model is a good one in this respect.

* The ATO system: It needs modifying so schools cannot pick and choose 'easy' ATOs that pass just about anyone...yes it happens

* Airspace: KISS. I would suggest back to the old CTA/OCA system. Rather than CTAF frequencies simply have all aerodromes operating on a (published on charts etc) area fequency basis with a very few basic mandatory radio calls. CTA would have few classifications...Class C (or B if deemed appropriate at somewhere like SY) and Class D at places like Coffs/BK/MC etc...Class D could be further broken down into 'Radar' D and 'Procedural' D (essentially what GAAP is) if required. Everything else is G with RIS within radar/ads-b coverage.

* User pays: It must be recognised that 'the system' exists only because of the 'big end of town'. I have posted this analogy before...imagine the system the day after every hi cap domestic/international RPT aircraft was grounded and then imagine it the day after every private GA/charter aircraft was grounded. Having recognised that the system requirements are purely driven by hi capacity operators recognise also that GA already contributes more than it costs via sundry indirect taxes, GST etc. As it stands we are being double taxed in many areas by paying GST on top of govt 'fees' for service...this is an obscenity.

Last edited by Chimbu chuckles; 15th Jun 2007 at 13:30.
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Old 15th Jun 2007, 08:58
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* CASA/AsA/BASI. Put them back together, slim the resultant regulatory body down ENORMOUSLY and recognise the fact that it should NEVER have been 'corporatised' in the first place and stop charging for services that federal taxes are paid for, essential national infrastructure. Imagine the political backlash against any state govt that corporatised the Department of Main Roads or Maritime Services Board..aviation is essentially no different

* Fascilitate WAAS as a matter of extreme urgency so that every airport in Australia can have a GPS based version of an ILS with verticle guidance down to Cat 1 minimas. The one thing that would have mitigated the 'worst aircrash' in Australia's history and numerous other fatal accidents. As soon as WAAS is available shut down every NDB in Australia and most of the VORs.

* Fascilitate low level ADS-B.

Last edited by Chimbu chuckles; 15th Jun 2007 at 13:52.
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Old 15th Jun 2007, 09:55
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"3) suggest CASA consider looking into the financial viability of a company that holds an AOC, send in appropriately trained accountants on audits."
No, no, no!!! When my accountant hires aircraft, CASA should get into the financial audit business!!!

CASA tried that - it is far too complex and subjective. On the basis of their debt to equity ratio, neither Qantas nor Virgin would hold an AOC.

Whilst the Act permits CASA to consider other matters in the issue of an AOC, don't give them ideas to re-visit financial viability!!!
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Old 15th Jun 2007, 12:44
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Where, where, do we start?

Dick,

We can but hope that sanity might eventually prevail, but the way the legal profession is driving our industry....I'm not hopeful. But, for the exercise, I'll try a few suggestions in regards to flight training:

(1) Security has become an obstacle to business. Airport 'security' has fenced off our school from public access, and we have lost, and continue to lose, business because of this. Airport owners were panicced into erecting fences willy nilly.....which they now concede are often in the wrong place. ASIC's are required for airports which are 'RPT' for 2 hrs daily - the rest of the time you couldn't find a human being there.

(2) Abolish the AOC system, and allow flight instruction to proceed as per the US model. The result will be flight instruction available to country citizens,on their own airport,at a reasonable price. As mentioned elsewhere - there's a lot of 'retired' instructing talent around Australia - and they could fill the current shortages of instructors. But, they are not about to buy an AOC and be subject to all the hassles.

(3) Appoint more ATO's - the current situation is pathetic. Why should we suffer a 3 month lead for booking a test? If there were enough ATO's - then it would be possible for every PPL test to be done independantly, rather than by the applicants CFI. Standards would improve when the product of each and every flight school is independantly evaluated via such a system. This will do more to lift the 'perceived' lowering of instructional success than any other change.

(4) Allow GA instructors to become RAA instructors subject only to type proficiency - not this silly business of 'you-must-start-at-the-bottom- as at present. The US and UK allow this - why not here?

(5) Allow all aircraft which are LAME maintained to operate in flight training for either GA or RAA....regardless of their registration. They are the same aircraft - just the numbers have changed.


Dick, I realise that we have a deeply conservative 'system' entrenched in Australia. Yes, the air is of a different density, and aircraft do fly 'differently' here.....but, we have to get over these attitudinal aberrations which have become the norm in Canberra.

I sincerely hope that you can represent us there,

happy days,
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Old 15th Jun 2007, 12:55
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OZBUS - many good points there.
Assuming that training AOC's will stay, why the separate charges to add another light single or twin to the AOC? I note in the new scale of charges about to be introduced that MOST charges are HOURLY RATE - just wait till this kicks in!!
Dick, seeing as how you started this thread, could you distill the consensus periodically into some meaningful list - it seems most of us are on the same track.
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Old 15th Jun 2007, 13:16
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Lots of good stuff here.

Re max alt without oxygen. I completely agree with the 12500 foot rule. The air is not that mouch different in oz as it is in USA. Not sure we need the 14000' for 30 mins rule (most likely introduced in the US to pop over the Rockies at a good height, then descent).

Straight in approaches - yep, should be allowed everywhere

Instructors without an AOC - bring it on! A great move. Will also allow people who are experienced and passionate about flight instruction to do it.

ASICs for capital city airports only. And not needed for students.

There should be no difference in maintenance standards and pilot experience for RPT and charter. I have the whole aircraft to myself and get it has to meet a lower standard of maintenance?

Define RPT and charter better - none of this shelf company cross hire stuff to get around it all. One rule for all lighties carrying fare paying passengers, whether it's a fixed terminal/schedule or walk in charter to Kiwikurra.

More to come!

Good work Dick, and many here no doubt appreciate the ability to input. But please, may these suggestions please be tabled and put forward on their merits and not bundled up into an airspace agenda.


NB for the medical side of things - yes the $130 is outrageous, but I understand that your Doc is a Delegate of the CASA doc. If s/he did not pick up your heart irregularity and you have a heart attack killing 5 pax, your doc is covered by CASA' coverage. Can you imagine how large the insurance premiums would be for you local aviation doc? Mine said he'd stop doing aviation medicals.
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Old 15th Jun 2007, 13:43
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The liability issues are adressed as currently. The issuance of a renewed medical should be solely at the discretion of your DAME in 99% of cases...he tests you, passes you fit (or not) and hits 'print' on his computer and it spits out new medical and sends notification to CASA...CASA database updated automagically and you go on your merry way $130 better off. For renewal of ATPL/CPL the exact same procedure but you provide your employer with copy of renewed medical for their files.

It should be so bloody easy

An 'Air Taxi' classification is also an excellent idea. No AOC but with 6 or 12 mthly 'operational audits' that could be carried out by delegated ATOs as part of an increased licence/proficiency check protocol carried out on CPs of air taxi operations...initially 6 mthly and then with proven track record increased to annually and even over time it could be bi annually for really good operators.

It could be a very simple process...it's not like AOCs actually stop anyone breaking rules if they are that way inclined.
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Old 15th Jun 2007, 13:59
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simply have all aerodromes operating on a (published on charts etc) area fequency basis with a very few basic mandatory radio calls
Hear, hear. The amount of extra radio chatter that clutters a circuit nowadays is beyond the pale. Of course, pilots have no choice because it is set in stone in AIP. This superfluous use of radio is the direct result of knee-jerk legal and media attention following a couple of accidents in the circuit area. Unmerciful culling of mandated radio calls is needed if only because a Mayday call may go unheard over the din of such constant gems as "Vacating runway 17". and a few seconds later "Vacated runway 17" plus its various other radio call appendages
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Old 15th Jun 2007, 15:50
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How about we make the ATPL licence actually mean something ?

ie: why is it that a CPL can fly, say, a Bandeirante with 15 pax on CHARTER, but cannot fly it over the same route RPT as PIC? unless he/she has passed the ATPL criteria ?
BUT... a CPL can fly, say, a B200 /c404 with 9 pax onboard over RPT routtes, and NOT have an ATPL ???

why does passing an outdated exam on b727 flight planning/wt and balance etc. make you more qualified pilot to fly 10+ pax on RPT ???

and WHY does it cost so much to sit an exam ? not just the ATPL's, but CPL/PPL/IREX ?

surely this can be outsourced to flying schools who can keep it inhouse at 1/10th the cost ?
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