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AOCs for Ultralight Schools

 
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Old 22nd Nov 2001, 16:35
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Thumbs down AOCs for Ultralight Schools

I haven't seen any discussion of this issue on pprune yet so I thought I'd pose the question. For those who aren't aware CASA is trying to force AUF registered flying instructors to apply for (and hold and renew) AOCs, in order to conduct flying training. This is despite the fact that the AUF is very efficient in administering sport aviation, including training, in Australia and extra regulation from CASA is not required. Apparently CASA wants to classify ultralight training as "commercial" yet parachute operations are not, and are given specific exemption.

This is a serious issue for the AUF as it would cause many ultralight flying schools to the wall under the extra expense of maintaining an AOC, and would no doubt lead to a decline in sport aviation as it becomes too expensive for many. Apparently the push for this is coming from GAPA, (apparently ultralights are stealing "their" - ie GA's - potential students) although I have heard that this body is not really very representative of GA people generally.

So what do you think? Is it fair that ultralighting should become more expensive for the specific benefit of GA schools? Will CASA and AOCs do a better job of keeping ultralights safe than the AUF can?

JJ
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Old 22nd Nov 2001, 17:01
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The major expense in maintaining an AOC is obtaining a set of Operations Manuals and the application fee for CASA to vet the organization and the manuals. About $5000 to have the manuals written and several hundred for the CASA fee. Any on-going expenses are safety related in complying with the AOC.

If CASA were to get their act together they would set up a standard set of manuals, freely available and require operators to produce an appendix covering differences. Surely then organizations could get up and running a lot quicker and without the expense and delays we experience now.

I suspect CASA is protecting the public once again by requiring operators to maintain a safe and legal operation. I don’t know what legislative ‘bite’ the AUF has but certainly an AOC holder is brought under a raft of legislation.

If the ultralight scene has some unscrupulous operators endangering the unwitting punter coming in off the street then I guess requiring AUF schools to hold an AOC is a good move. But then the requirements haven’t had a lot of impact on some charter operators!
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Old 22nd Nov 2001, 17:19
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I disagree that this would be for the "specific benefit of the flying schools". I agree that the parachuting thing, where oodles of money changes hands, should be classified as aerial work.

If the ultralight schools are safe and efficient now, then having an AOC should not make too much of a difference to their operations. As for cost, the cost of maintaining a flying school AOC is insignificant in the scheme of things.

I've used the analogy before, of comparing how people who drive small cars have to have a licence and pay their rego etc the same as people who drive big cars, because they use the same roads.

Currently the rules and regs are so full of exemptions that the whole thing is a bit of a joke. If CASA can make the rules workable enough that we don't need all these exemptions then I believe life in aviation will be safer and compliance simpler for all of us. If that means ultralight schools abiding by the same rules re mediclas, qualification of instructors etc as the GA schools who use the same airspace, then is that such a bad thing?

GAPA represents the professional AOC holding organisations in GA, unlike another well known organisation who mainly represent private pilots. These are two different aspects of GA, both important, both entitled to have their say, but to say the private pilots represent GA would be like saying private car owners represent eg courier and trucking companies. Apples and oranges.
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Old 22nd Nov 2001, 17:27
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In response to dragchutes post, presumably these AUF schools have some kind of training manuals in place already, which would only need to be brought into line with CASA guidelines for AOCs. This could be done themselves, you don't have to pay someone else to write your ops manuals.

It's refreshing to see CASA taking an interest in something other than the "fare paying passenger"
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Old 22nd Nov 2001, 17:30
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Q:What's the difference between an instructor + student jumping in to a VH c150/172/pa28 and an AUF reg Jabiru/gazelle or similar?
A: The qualifications of the instructor and the maintenance requirements of the aircraft.

Firstly I'm not having a go at ultralights, nor am I saying their instructors are no good and they fly dodgy aeroplanes.
From the other side of the fence why should there be any differenciation between these ops at all?
Frankly CASA's influence as a regulator is the last thing anyone would find constructive to any GA operation. It's easy to say that if we have to put up with the XXXX why shouldn't they (ultralights).
What's really the issue though? Would an AOCed ultralight operation be any safer than the current set up. Probably not, it is true however that overheads would be significantly larger as would the grief factor.
When your local FOI asks you if your carrying your licence and medical or if your logbook times perfectly match your FDTs why don't we ask them what they've done to 'make the skies safer'.
I'd love to hear the answer.
Given the current situation ALL training operations would benefit from less CASA.
Still an unregulated aviation industry is the last thing on any boffins mind, maybe the ALP had the right idea with their proposal for an aviation ombudsman.
The main answer still seems to lie in CASA reform.
Yes, ultralights require regulation as does GA and there is no reason why it shouldn't come under the same umbrella, but whose?
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Old 23rd Nov 2001, 06:14
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CFI,

I have been down the road of writing Ops Manuals. Many hours of time spent researching CAR’s, CAO’s, CAAP’s, Flight Manuals, syllabuses, state regulations, dangerous goods manuals and any other documentation that is involved. Submission of the draft followed by re-write and resubmission. The man-hours involved and the time delay in obtaining approval is more expense and trouble than my schedule has time for.

There are however people who specialize in such manuals and are able to tailor a suitable manual to fit any operation, and in a surprisingly short space of time. Their manuals have been submitted time and time again and all the bugs are ironed out. This is worry free and cheaper, if I add up my time, than using the self-sacrifice method!
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Old 23rd Nov 2001, 06:43
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CFI,

The AUF has its own centrally controlled Ops Manual and all AUF flying schools operate to the same manual. The AUF operations manager knows almost every AUF instructor personally and certainly knows all the AUF CFIs.

Goulburn is a good example of a town that needs the AUF system as it stands; not a lot of flying but a keen and professional flying instructor who gives everything for her school. She estimates that 60-70% of all her flying is AUF, for which she does all the instructing and testing.

For the GA side she has to retain the services of an old local fella who is a Grade 1 and approved GA CFI at greater cost and expense than that required for AUF.

Scone in the Hunter Valley is another operation that has benefitted from AUF efficiencies: the GA instructor there is always struggling to make the school financially attractive for a Grade 1 to act as CFI. A 2000 hour PPL and LAME has done his AUF instructors course and the Aero Club is now thriving.

I wrote to our local member about this matter in the lead-up to the election and I received a reply from the transport Minister stating that after the election Mr Anderson would instruct CASA to back off.

Regards
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Old 23rd Nov 2001, 18:18
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All,
Has it occurred to all the fans of AOC's and mountains of paperwork, all those tidy minded clerks with a pilot's licence, that the real answer is to get rid of AOC's for ALL GA flying.

Level the playing field by reducing costs for all, not artifically inflating costs for an AUF that is doing a good job.

Have a look at a few other countries, you might be surprised. Remember the G.O.D's, when an Operations Manual was little more than a statement that thou shall obey all the sundry Regs, Orders etc.

Has the vast expansion in paperwork and general bureaucratic micro management of GA resulted in an ever increasing standard of pilot, or better safety outcomes???

Has it hell.

Tootle Pip!!!
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Old 24th Nov 2001, 06:58
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Leadsled
Bullseye!!
Strangely enough, it can be done - if you can find enough industry and government players to form the nucleus and a Minister with the guts to support them.
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Old 24th Nov 2001, 08:03
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One of the chief problems faced by GA flying schools is the appalling attitude of the many of the staff to prospective students.

Recently I visited a number of schools nearby, looking at getting into the air. I left a number of the GA schools thinking "I won't go there again", my wife had quite a bit to say on the subject. I finished up going to an AUF school several hours away and my wife will be going there for the full course shortly. As a generalisation I would say that the AUF instructors have far more experience than GA ones especially the instructors she would have.

The chief offenders appear to have no interest in the students other than to get more hours. GAPA appears to have the attitude "The money belongs to us"
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Old 24th Nov 2001, 09:32
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Surely if you are a flying school operator who pays some external party to write your manuals, you haven't looked into the rules and procedures yourself and are looking for a 'rubber stamp' way to discharge your personal responsibilities?

From the point of view of regulation, it would make sense that operators know the rules, rather than hire someone to write a book that says the right things.
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Old 24th Nov 2001, 10:45
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It would be interesting to hear some alternatives for an AOC for flying schools. For example, what checks would be in place to prevent any instructor setting up "You Beaut Flying School" without any kind of control.
As for the mountains of paperwork, they are there more to protect us from lawyers and insurance companies rather than CASA.
Just as relevant however big or small your aeroplane.
I heard of one ultralight club who apparently have recently been sued for a couple of mill(?) when a doddery pilot, allegedly not medically fit to drive a car, crashed his ultralight, killed himself and paralysed his passenger. Yes this could happen anywhere, the lawyers will find somebody who didn't exercise duty of care somewhere; at least with an AOC it's a bit easier to prove that you've done all you can to ensure safety.
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Old 24th Nov 2001, 14:51
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Dear CFI,

AOC's have got nothing to do with other than an ever expanding CASA payroll making busy work. No words in an AOC will stop a damages claim when somebody is injured or killed. That's modern life, aeroplane, car or tandem unicycle.

I don't have a clue how long you have been in the aviation training business, but we used to get along quite nicely with nothing like the recent AOC nonsense. Some of the current AOC restrictions I have seen are lulu's. Would you like to be in the situation that you are un-competitive because your FOI, or whatever he is called this week, has lumbered you with AOC/Ops Manual requirements that don't apply to the guy next door.

Do you even know that you are not already in this un-competitive position ???

In US, a CFI, a certified flying instructor, can work out of the boot of his car, the commercial advantage for the "approved Schools" is that the minimum hours are reduced.

Have a look at the US safety outcomes, our GA record is about 50% worse than US, and we are not improving. Most of the JAA countries, with similarly vast, oppressive and inflexible bureaucracies, produce quite staggeringly bad safety outcomes.

The vast expansion of bureaucratic micro management in ALL levels of Australian aviation is quite staggering, and the industry by and large just supinely cops it. No other major Australian industry behaves in this irrational way.

If all this current nonsense is really required to protect us from ourselves, I just can't imagine how I survived all these years, without having my hand held.

Quite frankly, anybody who needs CASA to hold their hand shouldn't be in the aviation industry.

I think the whole GA industry is exhibiting a mass "Stockholm Syndrome". For anybody who doesn't understand what that is, look it up. I am beginning to think that this is the only possible explanation for a group of people who not only don't rise up against their captor/ oppressor/executioner, but actively support their own extinction/(commercial) execution.

There is simply NO WAY increased costs and restrictions are going to bring about a GA renaissance, but that is exactly what CASA have planned.

See for yourself, it's all on the CASA web site.

When is the penny going to drop in GA circles, that the rapid expansion of AUF flying is the result of perfectly rational people making perfectly rational decisions about spending their hard earned after tax discretionary dollars. And having a really fun time doing it!! And they are now making perfectly rational demands of their MPs and Senators, to make certain that it stays that way.

The AUF were the ONLY aviation group mentioned by the Minister in his election policy. Didn't hear any Ministerial support for the CASA/GAPA position. What jolly bad luck, the Minister's got it right on this one.

Somehow I don't think the AUF will let him forget his promise.

Oh, and by the way, CFI, have a look at the FAA morbidity studies and ALL aircraft accidents where there was an incapacitation component. There is NO relation between the class of medical certification of a pilot and the occurrence of in-flight incapacitation.

Tootle pip!!!.
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Old 24th Nov 2001, 15:10
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AOC's are not required for flying training below CPL. Flight testing and appropriate guidelines will maintain standards.

This industry is going backwards fast as a result of what simply put is over regulation.

If we want to progress then there needs to be change at the bottom end, and quick.
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Old 25th Nov 2001, 10:30
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I believe both the AUF and AOPA are together on this AOC issue:
"AOCs should and must be limited to organisations conducting charter and RPT operations for fare paying passengers only - all other requirements for AOCs must be abolished. Flying schools are required to have an AOC that adds considerably to the cost of flying. There is no logical reason why schools training to PPL should be burdened with this cumbersome process"

this was a quote from VP of AOPA Russell Kelly. The sooner that these fraternities get together to form a strong and common stance, the better general and recreational aviation will be
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Old 25th Nov 2001, 11:51
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Thumbs down

I believe CFI has been running a flying school for a very long time. I have been involved in running a flying school for 20 years. I firmly believe that there is only one airspace and that ALL users of that airspace should be governed by the one body, whichever or whoever that is. By slicing off areas of responsibility to the AUF and GFA, there is diminishment of responsibility to the paying public - and I don't give a hoot about your "non profit" clubs. Parachuting, gliding and ultra light flying ALL carry fare paying passengers and should therefore be subject to the same regulatory responsibilities as the the GA and RPT sectors are. If flying hours gained in the non GA and RPT sectors are to be given professional recognition towards professional (i.e. CPL) qualifications, then the providers of the training for those flying hours should be similarly qualified. At present, the majority of AUF Instructors do have those professional qualifications, but that will not always be so in the future. Over the years we have had many glider and ultralight pilots walk in the door and expect to convert to a GA licence on the strength of many hours of flying their glider or ultralight and "a quick circuit or two" in a C150 or PA28 and she'll be right mate - only to walk away shaking their head in dismay at what they didn't know. (Every single one flies IFR - I follow roads. I remeber watching with horror as a Glider instructor doing a take-off run in a motorised glider with a student temporarily lost control and the glider wing hit the ground several times before lifting off and was told that it's ok, gliders are built to do that. The "glider" then proceeded to do circuits - that's right - touch and goes, but exercising the priviledges of a glider, i.e. to be able to cut in front of a pwoered aircraft already established on final! The glider instructor has not ever held a GA licence, PPL, CPL or Instructor rating!
Yes, regulatory reform is needed, but it needs to be fair right across the board. And is AUF flying, gliding and parachuting really any cheaper for the public at large than GA? I really wonder when you pay $400 for a weekend to experience parachuting and only actually get one jump, or pay $60 for a flight in a glider for 20 minutes or less, and then only if you hang around for a few hours. Put these cost up against 3 hours in a C152 in the one day for $411 and I know which is the better value! ($60 will get you a solid 30 minute Trial Introductory flight).
As for AOC costs, if you're paying $5000 to get one up and running, you're getting ripped off. We wouldn't have spent that much in maintaining and updating in 20 years - and CASA are very happy with our operation.
I know many pilots who are unable to meet the requirements of the CASA medical who are now flying ultralights and gliders. I have no doubts as to the genuine intent of the AUF and GFA to maintain safe, low cost, aerial sport. But it set out to be just that, a sport, and that is where they should stay, not do a gradual take over by stealth of the GA industry. If they want to be professional money making businesses, then put your bloody gloves on and get into the ring under the same rules and stop trying to put another face on it! By the way, I don't know of any ulralight "clubs" (mmm, maybe Lethbridge), as far as I know they are privately run businesses making a good dollar for their owners, as are quite a few of the parachuting mobs around.
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Old 25th Nov 2001, 19:47
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The "should and must" style of rhetoric as quoted by airwave indicates how unwilling some types are to listen to reasoned debate. Why "should and must" anybody "require" that they have their way, which could threaten the livlihood of thousands of people employed in the flying training and ancilliary industries legitimately going about their hard won business? If that sounds defensive, wonder how some of them would like it if people set up "el cheapo" versions of whatever it is they do for a crust outside their workplaces and "require" that they "should and must" accept amateurs attempting to interfere in their professional lives.

The cost of an AOC does NOT "add considerably to the cost of flying". The biggest cost I had when setting up my school was setting up the company and the purchase of the office computer and printer; the ops manual cost paper and inkjet cartridges, and the issue of the AOC cost about $300.00.

The cost of maintaining my AOC is around 0.0003% of my total annual running costs. It is things like the overheads of the premises, fuel, maintenance, insurance and wages/super/compo that dictate the flying rates. IE market forces, not CASA!

I'll now sit back and wait for the replies from people who have never run a flying school or held an AOC telling me how wrong I am!

[ 25 November 2001: Message edited by: Charlie Foxtrot India ]
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Old 26th Nov 2001, 01:28
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You guys should take a few steps back and look at the big picture. Previous comments regarding the state of the industry in this country are true. It is going out the back door fast and I call for someone to say how this should be fixed. Unless it is you will all be out of business!
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Old 26th Nov 2001, 01:58
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CFI et al, I'm not too sure that the direct cost is really the issue of a new AOC application, more the cost in real terms of having to wait anywhere from six to twelve months for the complete issue process to grind away and soak-up all of your financial backing at an alarming rate, whilst you still cannot turn a prop in anger whilst waiting. The costs of the dormant infrastrucure just sitting there whilst you pay rent, leases and repayments on them would be frustrating to say the least.

Some of the stories that I have heard from just one CP I know who only wanted a minor variation to his AOC would make you hair stand on end as to what the official answers were from CASA, and the associated costs of compliance with them were almost enough to puchase another a/c for the operation.

Cheers.
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Old 26th Nov 2001, 02:21
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Talking

It has been my experience that the good operators who do their homework properly and have a proper business plan and don't under capitalise are ably assisted by CASA when making ammendments to their AOC. I also have acquaintances in the business who experiencer nought but grief in similar dealings but the difference is always their attitude and the number of NCNs at the previous audit. Before making a firm decision about adding an aircraft or even applying for an initial AOC, people should speak to CASA and get their requirements, time frames, and costings in writing before taking the next step. Antone who has been so stupid as to outlay money, sign leases etc before doing this deserves to lose their money.
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