Actual Cost Changes Complying with Part 61

[Dick Smith]

I have started this new thread hoping that we can get some factual information in relation to the cost changes that have taken place because of Part 61.

Can posters please state any evidence they have of any cost increases or decreases.

Perhaps if we can get a list going here I would be quite happy to talk to the Minister about this.

Of course, if there are any cost decreases they should also be shown.

If posters can also put an estimated amount of any cost increases/savings then we can get an idea of what this may be industry-wide.

[Honky Tonk]

With the part 61 licence I now have an MEA (multi-engine aeroplane) eliminating dual instructional type specific endorsements for most light twin aircraft. That is a huge saving potentially for either myself or an operator I could potentially work for. ICUS still costs money obviously but it would still have been needed even with a bare bones endorsement. I'm not going to do the math on every twin endorsement out there but a C310 goes for $665 and hour VDO. That's a good $1300 saving at least!!

[Dick Smith]

Great start - do you have an estimate what this will actually save you in a year?

And will it give the industry a saving in the long term?

[Honky Tonk]

Again hypothetically, a company might have three different types of twin A/C. B58, C402, C310. The operator wants you to fly all three. You came to the company with a B76. Someone has saved roughly $4500. Don't forget the money the government has saved in not having to process each endorsement.

Say said company paid for all these endorsements in the past(yeah right) and they had a turnover of 4 pilots a year. There's $13500 big ones.

[dhavillandpilot]

Interesting how someone thinks they are going to save the company money by encompassing all piston twins below 5700 under one endorsement.

Currently we are looking for a pressurised Aero Command pilot.

Sure we have had some really good applicants that the chief pilot is going thru, time permitting. However the number of B76 endorsed applicants applying is unbelievable - all of whom state they are endorsed via part 61.

The actual cost to get them up to speed would be in the order of $3000. Even a current AC500 pilot would need 2 hours, so where is the savings. Then you have to add in 10 hours ICUS to get them IFR charter.

My guess is the saving for say a pilot with 1500 hours TT, 700 twin flying a C402, then going on to a Pa 31 would be real. But in any case NO insurance company will insure a pilot without at least a check ride. Go to the USA and that is exactly what occurs.

[Dempster]

Surely people aren't under the impression that just because you are BE76 endorsed, that a company is going to let them loose on a 310, B58 or 402 because the law says they can. There won't necessarily be an endorsement, but surely there would be a familiarization flight similar to an endorsement.

[dhavillandpilot]

Unfortunately Dempster you would be surprised how many "aces" believe they now have a right to fly anything.

[thorn bird]

The problem Dick with part 61 is, so much of it will depend on what the FOI of the day interprets it to mean.
We have an allegedly Part 61 compliant Check and training manual written by a professional manual writer (ex CAsA FOI). The manual is actually an amalgam of three different FOI opinions.

Objective costs of simply giving a pilot a job based on what is required in this manual, thats for a pilot endorsed and current.

for a light twin around $15,000.

for a turbine (this ones a tad difficult as the regs are contradictory) but conservatively $20 to 25,000.

On a light jet such as yours $30 to 40,000

On a transport category jet $40 to 50,000

To upgrade someone from a normal category aircraft to a transport category aircraft, is difficult to determine there is very little guidance and nobody seems to know what the standards are but it means a whole new multi crew course, and a different IR rating. I know of one outfit trying to get a syllabus approved. Still waiting as CAsA advises they don't have the recourses right now, after two years and a lot of $$$. They were planning to charge around $8,000 for the course plus whatever the hourly rate in the aircraft or simulator you chose to do it in. The rating will only cover that type, so if you want to fly multiple types a separate rating will be required for each.

The conclusion I've come to is it will not be economic to operate more than a couple of types as your pilots will spend most of their time doing checks, and if your aircraft is at the high end of aviation travelling back and forward to the USA to complete them.

When part 135 comes in next year I believe there will not be enough part 145 approved maintenance outfits to maintain all the aircraft anyway, and there certainly will be a lot fewer customers who will be able to afford to charter.

Interesting that Aviation in New Zealand contributes almost as much to their economy as their dairy Industry, for the life of me I don't understand why we are throwing ours away, except for that famous line "If I had my way the only aircraft operating in Australian skies would be RPT and the RAAF"

[neville_nobody]

Again hypothetically, a company might have three different types of twin A/C. B58, C402, C310. The operator wants you to fly all three. You came to the company with a B76. Someone has saved roughly $4500. Don't forget the money the government has saved in not having to process each endorsement.

Say said company paid for all these endorsements in the past(yeah right) and they had a turnover of 4 pilots a year. There's $13500 big ones.

But then don't you have do a checkride on every type every year? Or are all <5700kg covered in one check?

[DeltaT]

This aircraft endorsement system sounds very similar to the way it is run in UK.
You still do a type rating on each (subsequent to the first of type) but there is no test required (persay) at the end of that rating because you are supposed to have jumped through the hoops on your initial of type. The way I used to remember it anyway. The real saving kicks in with currency eg previous 90days etc. A higher end aircraft counts for those similar or below it within similar type, so a flight in a high wing c180 will count for currency in c172, c152 for example. The caveat is the individual aeroclubs and organisations end up making their own rules a bit more stringent anyway, to try to reduce accidents and help with their insurance, and that goes in their ops manual. eg currency in a low wing doesn't count for high wing etc etc
Yes, <5700kgs single engine piston would be covered in one check, another check for <5700kgs Multi Piston, and you are covered as far as the annual check goes. But in a business operation you might cover that in a route check for example, or instructor or IR renewal. In your example of the 3 piston twins <5700kgs, you would still need to do some sort of type rating induction, (shorter than the initial of type rating), for a new person that is not rated, however any currency issues for all 3 would be covered by flying any 1 of them.

[Horatio Leafblower]

There is no real cost saving for GA twins - there is a requirement at 61.3xx somewhere that a pilot must take adequate steps (or similar wording) to ensure they are familiar with all aspects of the aircraft's operation, including emergency procedures.

That might, in practice, get pared down with time- but the CASA expectations described in the Airtex AAT hearing would be instructional for those seeking to cut corners.

I have also been told that - where we previously all did internal ICUS - under Part 61 we cannot do ICUS without a Part 42 (Multicrew and integrated flight training) AOC.

This means we will need to contract an approved organisation and approved pilot, at something over $100 per hour I imagine, to ICUS our pilots to a minimum of 10 hours on type.

Most decent companies do between 40 and 50 hours of ICUS with new pilots to ensure everything is covered adequately. This will be a significant cost or - more likely - result in operators seeking to reduce the training they previously provided their pilots. This would lead to lower operational standards, less standardisation, and arguably a decrement in safety.

Seeking a CAR217 approval or a Part 42 Certificate - CASA have estimated $7-15k and six months.

The microscopic improvement in "safety" achieved by the new regulations is not proportionate to the regulatory cost burden placed upon the industry.

It is a crock of **** and it stinketh.

[thorn bird]

Horatio, having read through part 61 quite a few times, I'm not even close to understanding them, and the Moss is no help.

I don't believe there is anything in any of it that improves safety, in fact I believe safety will be compromised.

The added costs will severely impact on GA's ability to put out an affordable product.

We already have to suffer standardisation issues from the opinions of the FOI's, it will be even worse now, impossible to align with manufacturers procedures.

Of course CAsA could approve generic manuals which would take the FOI's opinions out of it.

The Ag guys tried that and there was peace in our time for a while. Unfortunately I believe that agreement has been broken now by the FOI's and its back to the old days of heated arguments and threats across the table. CAsA just cannot leave well enough alone.

[JAMUP]

Cost of Training

Since we all are on the same page, Can I kindly ask these question on Part 61 ,

1/ Cost of training for CPL and towards ATPL ? will it go up ?\
2/ My main concern is the Flight Instructor rating , does anybody know any changes on this rating , perhaps the cost and hourly requirements?

Thanks

[Two_dogs]

Horatio,

Is there not provision to apply for an authorisation under 61.040 in accordance with 11.055? I thought this was the equivalent of the previously issued CAR 5.20 Approval to give training, and CAR 5.21 Approval to give conversion training. This would be a definite cost saving.

Admittedly, I am no Rhodes Scholar (one needs to be, lately) and I do have trouble making sense of it all. Despite having the several documents open at the same time for cross-referencing, (need more screens) I am no closer, but I do have a headache.

After several readings of;
11.055 Grant of authorisation
61.040 Approvals by CASA for Part 61
61.150 People who may grant flight crew licences, ratings and endorsements
61.170 Grant of flight crew endorsements
61.180 How examiner, instructor or approval holder issues rating or endorsement
141.035 Approvals by CASA for Part 141
141.050 Part 141 flight training—requirement for Part 141 certificate or approval,

I thought one could apply for an 'approval holder' delegation and conduct training in-house. Probably still going to cost a shedload of dollars to produce ($1500), and get approved, sorry, accepted, ($15000) a course which shows show compliance with 61.040 (2)

Is this a correct reading of the legislation? Or would this scenario just be too practical?

[thorn bird]

JAM, the cost of obtaining an ATPL will increase significantly. You will have to do a Multi crew course, nobody really knows at present what that is, and a proficiency check in a transport category multi crew aircraft thats assuming you can find a part 142 organisation who operates transport category aircraft. Costs could be upwards of fifty grand because you'll need a type rating on the aircraft you do the test in. Much better and a hell of a lot cheaper to to head overseas if you want to learn to fly.

[Horatio Leafblower]

who needs ATPL?

This ATPL business is a red herring. Yes, most airline recruits in Australia hold an ATPL but that merely reflects the unique pilot hiring market in Australia and our licencing system.

You only need an ATPL to act as Pilot in Command >5700kg, ie Multi-crew ops.

Multi-crew co-ord courses will evolve to be be similar to DG and CRM courses.

You won't be getting command >5700kg straight out of a Chieftain - you will spend a period as FO and your ATPL flight test will probably be part of the company's check and training system, incorporated into your command Check flight.

In 20 years of flying I know a lot of airline pilots.... I bet you NOT ONE of them was legally required to HOLD an ATPL on joining. (Company reqts notwithstanding).

The company will only put you up for command when you are ready for command and, logically, ready to hold an ATPL.

Lastly- remember that apart from the 100 or so pilots in GA who currently hold an ATPL, every new CPL is in exactly the same boat as you. Concentrate on getting the exams done and flying professionally, keeping your nose clean, building your reputation amongst your peers.

ONLY the most insecure, rich queue-jumping tossers would try to pay for an ATPL.

[Horatio Leafblower]

TwoDogs

Thank you for that, I will obviously need to do some digging ...and not rely upon advice from CASA FOIs!

[Two_dogs]

Horatio,

Also see,
Subpart 61.U Flight examiner ratings
Division 61.U.1 Privileges and requirements for grant of flight examiner ratings
61.1255 Privileges of flight examiner ratings
61.1265 Limitations on exercise of privileges of flight examiner ratings—endorsements
61.1270 Limitations on exercise of privileges of flight examiner ratings—professional development
61.1275 Limitations on exercise of privileges of flight examiner ratings—recent experience
61.1280 Limitations on exercise of privileges of flight examiner ratings—flight reviews and subject matter proficiency checks
61.1285 Limitations on exercise of privileges of flight examiner ratings—examiner proficiency check
61.1290 Requirements for grant of flight examiner ratings
Division 61.U.2 Obligations of flight examiners
61.1295 Obligations of flight examiners—flight tests: strict liability offences
61.1300 Obligations of flight examiners—flight tests: other offences
61.1305 Obligations of flight examiners—proficiency checks
Division 61.U.3 Privileges and requirements for grant of flight examiner endorsements
61.1310 Kinds of flight examiner endorsement
61.1315 Privileges of flight examiner endorsements
61.1318 Limitations on exercise of privileges of flight examiner endorsements – flight tests in aircraft
61.1320 Requirements for grant of flight examiner endorsements


I think there is room to hold a flight examiner rating/endorsement (ATO approval?) without an instructor rating. I could be wrong.

[Sarcs]

Perhaps combine resources Dick?

Maybe Dick you should have a chat to Ken, it would seem he is currently conducting a similar but more general project within the AMROBA membership...:

Increasing Costs & Red Tape

Recently some of our members have been bringing to my attention the massive increase in red tape and costs, costs that we find are far beyond what the regulatory service should cost. It is obvious that CASA has not yet come under the influence of this government. It is to be expected based on their track record to ignore previ-ous government and judicial recommendations.

Back in 2013, the LNP Aviation Policy stated that the Coalition would support the growth of the aviation industry by reducing red tape, reform the structure of CASA, establish a formal Aviation Industry Consultative Council and, among other promises, establish a high level review of aviation safety and regulation.

So far the government has only met one promise. The Forsyth Report achieved what had not been possible in the past, a government review of safety and regulation whose outcomes are industry supported. The govern-ment has issued Guide for Better Regulation but, based on what CASA continues to produce, the government Aviation Policy and Red Tape Reduction processes are being totally ignored. Red Tape Principles:

1. Regulation should not be the default option for policy makers: the policy option offering the greatest net ben-efit should always be the recommended option.
2. Regulation should be imposed only when it can be shown to offer an overall net benefit.
3. The cost burden of new regulation must be fully offset by reductions in existing regulatory burden.
4. Every substantive regulatory policy change must be the subject of a Regulation Impact Statement.
5. Policy makers should consult in a genuine and timely way with affected businesses, community organisations and individuals.
6. Policy makers must consult with each other to avoid creating cumulative or overlapping regulatory burdens.
7. The information upon which policy makers base their decisions must be published at the earliest opportunity.
8. Regulators must implement regulation with common sense, empathy and respect.
9. All regulation must be periodically reviewed to test its continuing relevance.
10. Policy makers must work closely with their portfolio Deregulation Units throughout the policy making pro-cess.

Why is industry still being subject to all the negatives that the Forsyth Report identified, and industry had also identified to the LNP prior to becoming government? - most now feel deceived because of the lack of govern-ment action. It is almost 12 months since the government was elected.

For instance, British GA will benefit from a GA system that will be closer to the FAR system than Australia, even though the non-airline sectors have been lobbying for the FAR system for the last decade. CASA consultation is a joke in that it does not listen to their own industry because "they know best" ????

CAA(UK) Red Tape Reduction program has commenced—it will be completed within two years.

The CAA(UK) Performance Based Regulation program will also be completed within two years.
For CAA(UK) future work there will be two guiding ambitions and principles:
deregulation and delegation to remove the bulk of GA from the current regulatory oversight of the CAA.

Since September last year when the government was sworn in, this industry has been patiently waiting for CASA to start to be seen as adopting and implementing government’s policies and directions. However, the industry has seen CASA continue with increasing prescriptive regulations and red tape.

Under the government guidelines, all regulations proposed and made during the past 5-10 years also need to be totally reviewed.
What I need to create is a submission to government with examples of recent costs for regulatory services. If any member is willing to provide me with the costs and the service provided that is seen as excessive, then I will collate as evidence of over charging.

Other government departments/agencies are working to reduce regulatory costs, if the principles were properly applied, not only would costs be lowered for industry but improved productivity would benefit all.
Ken Cannane
24/08/2014

It would also be worth having a chat with the RAAA who were apparently asked, or perhaps it was of their own initiative, by the PMC for input on the government RED TAPE REDUCTION policy:RAAA SUBMISSION CUTTING RED TAPE

I'm sure the RAAA would be able to provide examples of costs before the Part 61 farce and the effect after, garnered from their membership of course.. They may also be able to cut out the middle man and get you an audience in the big office...

Before you do finally rock up with the evidence in hand to the miniscule or PM office, maybe you should have a gander at my post - Follow the links - 'Fat dumb but unhappy!' - to get a sense of how our fellow ANZACs in arms went about and maintain their policy of nurturing & cutting costs to their aviation industry. This could provide a possible framework for the miniscule or PMC to work with in their future endeavours for RTP and hopefully to action (in reality) a PBR approach. Which apparently most of the other first world aviation countries are rapidly adopting..

Finally Dick don't go on your own mate, fill up your Van & take a crew along with you, you know safety in numbers & all that...

MTF...

Ps And if you want a DRAFT amendment for Part 61 drawn up...I know a bloke who knows a bloke that reckons he could get it done all legal within 2 days...

Pps Dick whatever you do time is ticking so get on with it mate..

[Two_dogs]

Ps And if you want a DRAFT amendment for Part 61 drawn up...I know a bloke who knows a bloke that reckons he could get it done all legal within 2 days...

I am not able to READ part 61 in two days.