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Part 61 Letter from McCormick

Old 22nd Oct 2013, 15:08
  #21 (permalink)  
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PDP was great., there's a lot of learning
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Old 23rd Oct 2013, 00:55
  #22 (permalink)  
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Have I read it correctly where you don't need to keep a logbook after 7 years post the last entry?

For someone who has a 40 year career that is alot of data you don't need to have!
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Old 23rd Oct 2013, 06:38
  #23 (permalink)  
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DCM - The letter of choice.

The only letter I want to see is Skulls resignation letter or a copy of his DCM letter, hopefully soon. But my guess is that Truss will give him a letter of commendation for all his work in aviation. TURDS.

The Skulls CV;

The 49ers Story - the Star Chamber

Get that into the Senate records boys. An apt description of factual events, and this bloke has been DAS for 5 years? The Government is a disgrace. ANd Mr Truss, so are you.
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Old 23rd Oct 2013, 06:41
  #24 (permalink)  
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Is this now an official way of getting Regs?

including the preparation and submission of an exposition.
Once again we are being forced to have expositions written to reflect a mix-mash of CARS, CASR and CAOs.

An Operator will just finish this version and another Part of the CASRs will arrive on the scene. Then that will have to be incorporated.

Then getting it "approved"/"accepted"

At what cost??
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Old 23rd Oct 2013, 09:17
  #25 (permalink)  
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ga-trojan said:
Have I read it correctly where you don't need to keep a logbook after 7 years post the last entry?

For someone who has a 40 year career that is alot of data you don't need to have!
The provision that worries me is the related one that says you commit an offence if you do not ensure that each entry in the logbook is retained unaltered throughout the 7 year period after the last entry was made: reg 61.355(2)(b).

Don't go changing that 4.3 to 3.4 when you realise, in retirement, it was an error!

$8,500 thanks.

So far as I can tell, the only way in which you're lawfully permitted to correct an error in a logbook is by direction from CASA under reg 61.360(3). Of course if you don't comply with that direction, you commit an offence.

$8,500 thanks.

Thank heavens for mother CASA to guide us through the incomprehensible complexities of log book entries.
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Old 23rd Oct 2013, 09:25
  #26 (permalink)  
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I guess that adjustments to correct errors and omissions need to be done as new line items similar to financial book-keeping.
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Old 23rd Oct 2013, 10:05
  #27 (permalink)  
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Expositions of course will not actually have to comply with the regulations, rather the"opinion" of the FOI of the day.
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Old 23rd Oct 2013, 11:36
  #28 (permalink)  
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The following from today's Testing Officer PDP in Bankstown:

3 year transition period to go Part 141 or 142 or both. All current flying schools will be issued a Part 141 Certificate (not an AOC).

No sticky strips after December 4, all endorsements made by hand on your licence. All Flight reviews, design features etc written onto your licence. Back to the future?

CASA dudes confirmed that ATOs and CFIs and GA multi-skilled type people will need to do multiple tests and checks each cycle. There is one guy in our group who currently flies 9 different types that will be subject to type ratings and he will need to do 9 Instrument Proficiency Checks to operate them. Every 2 year cycle. Fkn madness.

Add to that a proficiency check for his NVFR (12 months), his instructor rating (24 months), his Flight Examiner Rating (nee ATO approval) (24 months). His Type rating instrument checks (x 9) will cover his Multi Engine Aeroplane flight review, but he will need to do a SEA (Single ngine Aeroplane) flight review to exercise the privs of his SE class rating.

Co-pilots will have to complete a Multi-crew Coordination course to be co-pilots. This is the case not only on Multi-crew aircraft types but also for single-pilot certificated types. MCC courses must be conducted under Part 142 AOCs... anyone seen a 142 AOC? No thats right, there isn't any.

Good news: pilots with existing co-pilot time will be grandfathered. Bad news: everyone else will have to fork out $4k to get a MCC rating to work as a co-pilot.

These Regs (despite McCormick's protestations) have not been adequately consulted with industry and have been pushed through despite their un-workability. The CASA people are tearing their hair out and shaking their heads. Older ATOs are deciding to call it quits. Those of us left are trying to work out how to survive in a very demanding regulatory world.

CASA seem to think we have nothing better to do than re-arrange our paperwork to please them. They seem to regard the industry as an obstacle to regulatory perfection - when in reality we are the only reason they exist.

Long day on the phone to my local member tomorrow

Last edited by Horatio Leafblower; 23rd Oct 2013 at 11:54.
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Old 23rd Oct 2013, 12:03
  #29 (permalink)  
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Do co-pilots on single pilot certified types get grandfathered in as well? Just another spanner for the works....

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Old 23rd Oct 2013, 12:47
  #30 (permalink)  
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Regarding the multi-crew pilot (ATPL) wanting to do some single pilot stuff on the weekend - no, another check will not be required, as long as one has been done at some point (ever, not necessarily your last check). See 61.675

Recent experience requirements, however, include 1hr of flight time and an approach every 6 months. If that expires then I GUESS you need a check done or an hour of ICUS (or the new equivalent). 61.690

The single engine after a multi-IFR check seems to be a non-issue also.
61.695 allows you to fly an aircraft of a particular category. The categories are fixed-wing, rotary, etc., NOT single-engine/multi-engine.

61.695 (2) then prevents multi-engine fixed wing ops unless you've done the check multi-engine.

Its the strict liability stuff with logbooks etc that I'd be more worried about.. oh, and do I REALLY have to write VH- in the registration box of every single line in the logbook?
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Old 23rd Oct 2013, 13:24
  #31 (permalink)  
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What you got at YSBK sound about right, glekicho's different interpretation just about says it all ---- "CASA" don't know what the package collectively means, which is something completely different to what the Part 61/141/142 documents were actually intended to say.

I don't see your point in setting up a "when did you stop beating yours wife" request/demand.
I am not personally proposing anything by way of amendments, just advising those who not have looked at the CASA web site of the amendment package.

Civil Aviation Safety Authority - CASR Part 61 - Flight crew licensing

Personally, I think that the above only covers a small part of the problem. I have absolutely no intention of spending my time doing a rewrite of the package.

Tootle pip!!

Last edited by LeadSled; 23rd Oct 2013 at 13:27.
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Old 23rd Oct 2013, 13:55
  #32 (permalink)  
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Angry Phelan article read it and weep!!

Horatio you must have been talking to the same ATO as Paul Phelan...
There’s also been serious unrest in the flight training camp about the current regulatory reform event: the activation from December 4 of CASR Part 61 covering personnel licensing, which certainly does appear to mean “different things to different people.”

Here’s the lament of an experienced (18,500 hours) instructor and flying training school operator that typifies industry concerns:

I have been told the following and think that if I understand correctly I will probably have the following costs. Given that I hold the following approvals:
  • Approved testing officer
  • Testing approval for instructor rating (or Grades)..
  • Instructor training.
  • Instrument rating testing
  • Night VFR rating testing.
  • Training of instructors for instrument rating training approval.
  • Training of instructors for twin endorsement training approvals.
  • Multi engine class rating.
  • Multi engine type rating.
  • Single engine class rating.
I am led to believe that all these items are going to have to be proficiency checks separately.

Costs involvedTwo day personal development program (PDP) – time preparing, attending and missed revenue
Multiengine training renewal – aircraft cost
Time lost for the above.
Instructor rating, full day lost plus aircraft costs.
Examiner rating renewal – full day plus lost revenue
“Train the instructor” module (who knows how much?
Night VFR rating check – (who tests the ATO? – Who knows how much?
Single engine class rating check (who tests the ATO?)
Time lost with an examiner.
Instrument rating approval check
Time lost with an examiner.
Instrument approval training endorsement check.
Time lost with an examiner.
Single engine class type rating flight review (who tests the ATO?)
Type rating proficiency check.



Amortised over two years – annual cost


“Is this added safety, or is this bureaucracy gone mad? I actually hold these operational ratings, class ratings and type ratings, and I use them regularly.

“I test for night VFR. Do I have to be reviewed for NVFR expertise when I’m conducting tests and handing out these ratings on a regular basis?

“I fly single engined aircraft and check my instructors to line, I conduct instructor rating training in single engine aircraft, I pass instructors out into the industry in single engine aircraft. Do I really have to do a separate check for single engine class type?”

In her widely-circulated letter to CASA director John McCormick, this instructor has plenty more to say and plenty more questions to ask, and she’s far from being the only person who’s confused and frustrated at the unwillingness or inability of field officers to provide interpretations of these rules.

One question that is repeatedly raised, is where on earth CASA thinks it’s going to find flying operations inspectors or flight test examiners whose experience and recency is comparable with the people they will be testing?”

Another is the flood of amendments, which outstrips even Part 145, and the fact that the Part 61 MOS (where all the hooks and barbs will eventually be found to be buried) is still unpublished at a time when CASA is preparing for its Christmas break:

“CASA told us in Canberra last week that there were now 300 amendments to Part 61, so much of this might well be out of date. But the question is, “would 300 amendments have been made if a mass email had not gone out?”

“And how can one do anything about “consultation” when the MOS hasn’t yet been exposed to it?”

Nor can this flying school operator be accused of identifying problems without proposing solutions. She and numerous other flying school operators, both fixed and flutter wing, are highly critical of CASA’s apparent lack of attention to product quality sampling:

“Safety will not be enhanced by all these new regulations for a very simple reason; nobody in CASA is sampling the present apples in the system who are being let out into the industry en masse. By sampling, I mean going flying with the new PPL or CPL or new instructor or new instrument rated pilot within one month of receiving their licence or rating.

“The very idea of sampling the barrel is totally foreign to the CASA hierarchy which appears to me to be into compliance, more rules and more compliance and more obligations which just because they are written into the legislation means that all will be well!”
Regulatory reform not much closer – comment

Hmm...don't think I will comment might just into my beer instead!
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Old 23rd Oct 2013, 20:19
  #33 (permalink)  
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I don't see your point in setting up a "when did you stop beating yours wife" request/demand.

I am not personally proposing anything by way of amendments, just advising those who not have looked at the CASA web site of the amendment package.

Civil Aviation Safety Authority - CASR Part 61 - Flight crew licensing

Personally, I think that the above only covers a small part of the problem. I have absolutely no intention of spending my time doing a rewrite of the package.
QED (again).
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Old 23rd Oct 2013, 22:48
  #34 (permalink)  
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The experienced instructor who laments the $12000 p.a. costs of keeping all her approvals current will have little choice but to pass on those costs to her students. Somehow the students will find the money - if there are enough of them. If there are not, she would appear to have the choice of letting some approvals go, or copping a loss. Good experience going to waste. CASA needs to think about that.

Also, how many additional testing officers will CASA need to put on payroll to process all these approvals? Where will suitably experienced people be sourced from, if not the industry itself? CASA needs to think about that.

If they can't get enough people to do a proper job, those who do it will either be overloaded, or cut corners, or approvals will lapse. CASA needs to think about that.

Surely, if someone holds a Flight Examiner Rating to examine examiners, only two tests would be required in a two year cycle. One to determine the person's own flying ability in their most complex aircraft and another to determine on a random or cyclic basis that they still know how to properly conduct tests, possibly at the other end of the scale - such as a Grade Three Instructor being upgraded to a Two, or maybe a Night VFR test. Everything in between should be automatically included. You wouldn't test a brain surgeon in his ability to insert stitches.

Last edited by Mach E Avelli; 23rd Oct 2013 at 22:54.
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Old 23rd Oct 2013, 23:29
  #35 (permalink)  
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Part 61 and its frayed edges is becoming yet another example of CASA's disconnection with reality. A poorly constructed tangled web of stupidity. Of course it is easy for CASA to sit in an airconditioned office, draft some rules and regulations along with a policy or two then throw it out the window for us dogs to fight over. Executives sitting on half a million dollars per year (naturally some dont even have a pilots licence) and to them $12k or even $20k is just a drop in their ocean of opulence. But to the real man/woman living in the real world this is far from reality.
Australia has a real problem here. 25 years of incompetence, continuous mismanagement of all things aviation, a group of executives that are so out of the loop that they dont know an aileron from an oil gauge. A long term Minister who has failed his portfolio, and successive senior ministers for infrastructure who only ever see rows 1 and 2 on QF's Cityflyer.

Mr Truss, you have inherited one of the worlds largest aviation lemons. Are you going to eat the proverbial sh#t sandwich, display your robust coconuts and fix this Palaver once and for all, and finally? Or are you going to spend your last few years prior to retirement living under the microscope, as although industry is being raped mercilessly not all are going to disappear my friend, not in your lifetime. Until we see the changes required, including YOU personally listening to the Senators and acting upon the findings of their enquiry.
Time for you to stop being fed mushroom material from your Lieutenant, time for you yourself to get out there and see, smell and taste what has happened to this vital industry, and time for YOU to personally take hold of these issues and fix them. You've got your hammer and bag of nails, its time to hammer the last few nails into the coffin.

Last edited by Paragraph377; 23rd Oct 2013 at 23:34.
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Old 23rd Oct 2013, 23:59
  #36 (permalink)  
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little choice but to pass on those costs to her students
With all the test and a 3 day audit thrown in, when will she have time for students?
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Old 24th Oct 2013, 12:42
  #37 (permalink)  
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What students?? their all in New Zealand!!

Last edited by thorn bird; 24th Oct 2013 at 12:43.
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Old 25th Oct 2013, 01:37
  #38 (permalink)  
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A thought whilst doing nothing for 10-15 mins.
Heard a rumour that JMAC was at a conference no too long ago and was ripped into by a few individuals for various reasons over drinks who all had various agendas/problems with CASA.
The reply they ALL, to their surprise , (if you believe what you hear), got was "here's my card, call me next week, come to Canberra if you can or call me, and lets make this issue work/go away/get resolved",I believe you are possibly correct

Anybody take him up on it?

Just a thought.
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Old 25th Oct 2013, 03:28
  #39 (permalink)  
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Friday arvo and all that.

GA <funny you should bring that little episode up>.. Not quite the way I heard it; you are no doubt familiar with the old saw about how Swedish girls hold their liquor (by the ears). My source reports that a certain party forgot to hold onto the proverbial 'ears' and bollocked a visiting 'dignitary' who has, by all accounts launched, accompanied by a legal type to visit certain members of a Parliament uttering blood curdling noises which may only be silenced by financial or operational concessions.

Hard to know what to believe these days, init? - but it's good yarn for the BRB to kick off with this arvo; now those gentlemen know how a liquor should be held. Should be a great meeting with lots of juicy rumour to provide the hilarity required.....
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Old 25th Oct 2013, 04:07
  #40 (permalink)  
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Got my letter today (25/10) - inviting me to an information session ............last Monday (21/10)!

I'm gonna get a new pilot's licence, apparently. That will be my fourth, or is it my fifth (?), different style of pilot's licence in the last 40 years.

As for the rest? Well I really don't know - it all makes my head hurt! I guess I will just go along to my friendly ATO (if such still exists) with aeroplane in hand and say, "Make me legal"!


Last edited by ForkTailedDrKiller; 25th Oct 2013 at 04:13.
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