A Part 61 conundrum for Australian ATPL applicants
So the system of regulatory development is to presumptively create **** sandwiches unless all the people who're going have to eat them take the time to object? That would explain a lot.
And in the case of Part 61, the weight of the informed submissions were to the effect that Part 61 was going to turn out precisely how it did turn out: A complete clusterf*ck.
The sytem of regulatory development and post-implementation review is completely broken. It's a perpetual mess-maker. It's pointless trying to interface logically and reasonably with a completely broken system.
And in the case of Part 61, the weight of the informed submissions were to the effect that Part 61 was going to turn out precisely how it did turn out: A complete clusterf*ck.
The sytem of regulatory development and post-implementation review is completely broken. It's a perpetual mess-maker. It's pointless trying to interface logically and reasonably with a completely broken system.
But where in all the high-sounding policies for regulation generally and aviation safety in particular does it say: "Feel free to create whatever complexity, cost and frustration you like for those who don't have the time or energy to protest about it, even when there's no safety justification"?
Aren't all the high-sounding policies intended to avoid that in the first place, and isn't CASA being paid to implement those policies anyway?
These NPRM and other processes run by CASA remind me of the Brandolini theorem (the 'Bull**** Asymmetry' in the vernacular): It takes 10 times the amount of energy and resources to refute bull****/a bad regulatory idea than it does to produce it in the first place.
Aren't all the high-sounding policies intended to avoid that in the first place, and isn't CASA being paid to implement those policies anyway?
These NPRM and other processes run by CASA remind me of the Brandolini theorem (the 'Bull**** Asymmetry' in the vernacular): It takes 10 times the amount of energy and resources to refute bull****/a bad regulatory idea than it does to produce it in the first place.
But you still can't see any increase in safety can you havic? It's a waste of money.
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Are you serious?
So you're unhappy that CASA requires you to undergo a test by CASA or a CASA licenced Examiner (in many cases completed in a CAR 217 world as part of command upgrade) to get the ATPL required to operate in command of multi engine RPT ops (etc). Really?
Would you really like to explain that to the public? Really?
Have you read the MOS for the ATPL test? It is much more than an IPC. Much more. Again, would you like to explain to the public that you think you shouldn't have to be tested for your ability to command a multi-crew cockpit in normal and non-normal conditions?
You'll be at a BBQ or two in the days ahead. Tell your friends that the nasty Commonwealth wants you to do a test for an ATPL and see how much sympathy you get.
The history of the professions is the history of upgrade of qualifications. GPs used to do surgery. Not now. Primary teachers once only needed 2 years training. Not now. There were once no P plates. Not now. All that has changed. And more. Society demands higher standards now. And the Part 61 ATPL is a higher standard
Would you really like to explain that to the public? Really?
Have you read the MOS for the ATPL test? It is much more than an IPC. Much more. Again, would you like to explain to the public that you think you shouldn't have to be tested for your ability to command a multi-crew cockpit in normal and non-normal conditions?
You'll be at a BBQ or two in the days ahead. Tell your friends that the nasty Commonwealth wants you to do a test for an ATPL and see how much sympathy you get.
The history of the professions is the history of upgrade of qualifications. GPs used to do surgery. Not now. Primary teachers once only needed 2 years training. Not now. There were once no P plates. Not now. All that has changed. And more. Society demands higher standards now. And the Part 61 ATPL is a higher standard
My understanding that this change was driven by an ICAO SARP. Had Australia chosen to file a difference, it is possible that Australian ATPL's may not have been recognised overseas.
Sherm,
I was about 25 night hours short when the new rules came in. I wasn't going to pay for 25 night hours out of my own pocket I thought. Well maybe I should have as Tiger have told me they won't consider me without a full ATPL even though I have all the requirements. Two Biz jet operators have said the same.
Tiger said they don't want to bear the cost of added training for the MCC and ATPL flight test and do extra training if I mess it up.
Where is the fairness?
I was about 25 night hours short when the new rules came in. I wasn't going to pay for 25 night hours out of my own pocket I thought. Well maybe I should have as Tiger have told me they won't consider me without a full ATPL even though I have all the requirements. Two Biz jet operators have said the same.
Tiger said they don't want to bear the cost of added training for the MCC and ATPL flight test and do extra training if I mess it up.
Where is the fairness?
My understanding that this change was driven by an ICAO SARP. Had Australia chosen to file a difference, it is possible that Australian ATPL's may not have been recognised overseas.
So you're unhappy that CASA requires you to undergo a test by CASA or a CASA licenced Examiner (in many cases completed in a CAR 217 world as part of command upgrade) to get the ATPL required to operate in command of multi engine RPT ops (etc). Really?
Would you really like to explain that to the public? Really?
Have you read the MOS for the ATPL test? It is much more than an IPC. Much more. Again, would you like to explain to the public that you think you shouldn't have to be tested for your ability to command a multi-crew cockpit in normal and non-normal conditions?
You'll be at a BBQ or two in the days ahead. Tell your friends that the nasty Commonwealth wants you to do a test for an ATPL and see how much sympathy you get.
The history of the professions is the history of upgrade of qualifications. GPs used to do surgery. Not now. Primary teachers once only needed 2 years training. Not now. There were once no P plates. Not now. All that has changed. And more. Society demands higher standards now. And the Part 61 ATPL is a higher standard]
Would you really like to explain that to the public? Really?
Have you read the MOS for the ATPL test? It is much more than an IPC. Much more. Again, would you like to explain to the public that you think you shouldn't have to be tested for your ability to command a multi-crew cockpit in normal and non-normal conditions?
You'll be at a BBQ or two in the days ahead. Tell your friends that the nasty Commonwealth wants you to do a test for an ATPL and see how much sympathy you get.
The history of the professions is the history of upgrade of qualifications. GPs used to do surgery. Not now. Primary teachers once only needed 2 years training. Not now. There were once no P plates. Not now. All that has changed. And more. Society demands higher standards now. And the Part 61 ATPL is a higher standard]
Please, stop.
I got my CASA helicopter ATPL out of a cornflakes box under the old system. Though since I've moved to the US I've had to take a flight test for my helicopter FAA ATP, and now I also had to do the FAA ATP-CTP course (around 7k fortunately my airline pays for that) and take my ATP fixed wing flight test as part of my final type ride on the embraer 145.
Cool story. Irrelevant
I guess my point is that there's no reason that Australia shouldn't have a flight test like the rest of the world.
Really? Can't think of a single reason? How about the enormous cost? The absolute absence of any evidence of an improvement to flight safety? The bungled implementation? The significant reduction in opportunities to otherwise suitably qualified pilots like pilotchute? I could go all day. I've asked you several times (as have others) to show evidence that safety is increased by the introduction of this test. Silence has been the consistent response. "Others have it" is not an argument.
I don't agree with all the requirements that CASA have lumped into it, but the FAA process is now arguably equally as expensive now that you have to do a CTP course which requires 10 hours in a level D sim, just to be able to take the ATP multi engine fixed wing written.
More cool stories
So yes, I think CASA should change some things about the ATP flight tests, but I don't disagree with the fact that an Aussie wanting an ATP should be required to take a flight test like the rest of the world regardless of your background.
You're welcome to your opinion. Still waiting for that evidence.
You had the opportunity to go the cornflakes box route, and chose not to, so I have no sympathy about you moaning about the current requirements.
As I stated, my situation is irrelevant. I went on to explain why, predictably you have ignored it. So, again for the people in the back. That may be true, its totally irrelevant to the subject at hand. That I could have avoided the difficulty of the process does not mean the process is vindicated in any way. They are not related. I don't know how to say it any more simply.
Before you tell me to pipe down, I personally facilitated the first two CASA helicopter ATPL's under PT61 (I was in the aircraft) and helped make the cost cheaper to subsequent applicants by working with the AHIA and CASA with regard to aircraft types that can be used amongst a host of other items.
All irrelevant.
By the way, did you actually make any submissions under the NPRM time before PT61 was put into effect or are you now complaining after the fact?
I have been in contact with CASA regarding these ATPL part 61 changes on many occasions and have been part of a group that have pushed and successfully lobbied to at least have the process approved. Dispensing with the KDR requirements and introducing a caveat for those with previous multi crew experience etc.
Regardless, again your inability to differentiate what is relevant to the argument and what isn't shines through. Even if I had said or done nothing before its introduction, it in no way has any bearing on the validity of my position or veracity of the facts I present. You're transparently trying to slide a stipulation into the argument that only those who contributed to the NPRM have standing to make comment on the present situation. Just as you have tried to do the same by implying that because I could have avoided this idiotic test, I'm in no position to criticise it (a wonderful logical disconnect).
Cool story. Irrelevant
I guess my point is that there's no reason that Australia shouldn't have a flight test like the rest of the world.
Really? Can't think of a single reason? How about the enormous cost? The absolute absence of any evidence of an improvement to flight safety? The bungled implementation? The significant reduction in opportunities to otherwise suitably qualified pilots like pilotchute? I could go all day. I've asked you several times (as have others) to show evidence that safety is increased by the introduction of this test. Silence has been the consistent response. "Others have it" is not an argument.
I don't agree with all the requirements that CASA have lumped into it, but the FAA process is now arguably equally as expensive now that you have to do a CTP course which requires 10 hours in a level D sim, just to be able to take the ATP multi engine fixed wing written.
More cool stories
So yes, I think CASA should change some things about the ATP flight tests, but I don't disagree with the fact that an Aussie wanting an ATP should be required to take a flight test like the rest of the world regardless of your background.
You're welcome to your opinion. Still waiting for that evidence.
You had the opportunity to go the cornflakes box route, and chose not to, so I have no sympathy about you moaning about the current requirements.
As I stated, my situation is irrelevant. I went on to explain why, predictably you have ignored it. So, again for the people in the back. That may be true, its totally irrelevant to the subject at hand. That I could have avoided the difficulty of the process does not mean the process is vindicated in any way. They are not related. I don't know how to say it any more simply.
Before you tell me to pipe down, I personally facilitated the first two CASA helicopter ATPL's under PT61 (I was in the aircraft) and helped make the cost cheaper to subsequent applicants by working with the AHIA and CASA with regard to aircraft types that can be used amongst a host of other items.
All irrelevant.
By the way, did you actually make any submissions under the NPRM time before PT61 was put into effect or are you now complaining after the fact?
I have been in contact with CASA regarding these ATPL part 61 changes on many occasions and have been part of a group that have pushed and successfully lobbied to at least have the process approved. Dispensing with the KDR requirements and introducing a caveat for those with previous multi crew experience etc.
Regardless, again your inability to differentiate what is relevant to the argument and what isn't shines through. Even if I had said or done nothing before its introduction, it in no way has any bearing on the validity of my position or veracity of the facts I present. You're transparently trying to slide a stipulation into the argument that only those who contributed to the NPRM have standing to make comment on the present situation. Just as you have tried to do the same by implying that because I could have avoided this idiotic test, I'm in no position to criticise it (a wonderful logical disconnect).
Last edited by das Uber Soldat; 27th Dec 2016 at 09:31.
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As a CAO 82.5 operator Tiger would already be conducting CRM/human factors for RPT training. This was recognised in the recent MCC exemption as being very similar to the MOS standard for MCC training. In their CAR 217 command upgrade programme they'd be doing a LOFT style test and an IPC. So the cost to them is minimal. And if you had to do retraining....really, they take that risk with every pilot they hire.
I believe CASA has been working with quite a number of operators to build the ATPL test into their command training programmes. I have a CASA mate in SYD who was involved in briefing the operators.
I believe CASA has been working with quite a number of operators to build the ATPL test into their command training programmes. I have a CASA mate in SYD who was involved in briefing the operators.
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To das Uber Soldat.
Soldat.
Met many of your type. Often only in accident records or at exit interviews after termination or failure to pass an interview or flight test.
Know it all. Don't look at facts. Whinge and carp.
Well mate, you are the very reason why MCC training and an MCC focused ATPL flight test is now required.
If you are a professional pilot which I doubt, do your bit for flight safety and stay away from aeroplanes.
Met many of your type. Often only in accident records or at exit interviews after termination or failure to pass an interview or flight test.
Know it all. Don't look at facts. Whinge and carp.
Well mate, you are the very reason why MCC training and an MCC focused ATPL flight test is now required.
If you are a professional pilot which I doubt, do your bit for flight safety and stay away from aeroplanes.
I've met yours too mate. When met with evidence, runs and obfuscates with silly comments such as that.
The irony of you accusing me of not looking at facts is delicious. You've been harping on about the MOS for how long, yet when I called you on your bluff and actually listed the relevant MOS sections in detail (as linked above), you simply ignored it (as you have everything you can't refute).
You want to talk about the issues, I say about time. I'm right here. You want continue to evade and ignore, then don't complain when I call you on it with some puerile ad hominem attack.
And you didn't answer my question. (imagine my surprise). How does that help pilotchute?
The irony of you accusing me of not looking at facts is delicious. You've been harping on about the MOS for how long, yet when I called you on your bluff and actually listed the relevant MOS sections in detail (as linked above), you simply ignored it (as you have everything you can't refute).
You want to talk about the issues, I say about time. I'm right here. You want continue to evade and ignore, then don't complain when I call you on it with some puerile ad hominem attack.
And you didn't answer my question. (imagine my surprise). How does that help pilotchute?
Originally Posted by Soldat
When met with evidence, runs
Love your work though Shermy. Declaring that I'm unsafe to operate after spending the entire thread arguing those who have passed the ATPL flight test are at a higher safety standard. That'd be me sunshine. So which is it? If you say I'm safe, then your words above are shown to be wrong. If I'm unsafe, yet I've passed an ATPL flight test, then it disproves your argument that the test provides a higher (or even minimum!) level of safety. Its not often my opponent wins the argument on my behalf. Thanks champ.
In other news, if the test needs to exist for international compliance reasons (which at least would be a reason), then it needs to be adapted. It can't be part of a command upgrade process. Many people work in smaller companies where the prospects of command are marginal at best. It needs to be administered by the internal checking department and ideally should be part of the IPC with a few extra boxes to tick. It took CASA at months before approvals for 217 organisations in any volume were given to administer the test. Thats a long time for someone waiting for a job. The barriers of cost and inconvenience need to be removed so opportunities aren't vastly reduced for those looking to move up the aviation chain.
Tiger, Cobham and a host of employers require an ATPL to even apply, yet are taking people with less relevant experience simply because they hold a bit of paper they got out of a cereal packet. If the test was so valuable and increased safety or skills as is implied in this thread, they would be prioritising people who had done the ATPL flight test over all other candidates. Yet this isn't happening.
Look at the picture as a whole. Have opportunities for pilots increased with this new scheme? Demonstrably not. Has cost increased for candidates? Yes, vastly. Has safety been improved by this new test? No evidence exists that it has.
Last edited by das Uber Soldat; 28th Dec 2016 at 04:28.
We can only hope. In the meantime, a lot of people have had careers set back by years for no tangible benefit to anyone.
Last edited by das Uber Soldat; 28th Dec 2016 at 04:25.
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"So you're unhappy that CASA requires you to undergo a test by CASA or a CASA licences Examiner"
Have you ever examined the background, experience and qualifications of many of CAsA's type experts who conduct flight tests??
Have you ever examined the background, experience and qualifications of many of CAsA's type experts who conduct flight tests??
When Tiger, Cobham etc. eventually realise they have a recruitment problem they will change their requirements.
The history of the professions is the history of upgrade of qualifications. GPs used to do surgery. Not now. Primary teachers once only needed 2 years training. Not now. There were once no P plates. Not now. All that has changed. And more. Society demands higher standards now. And the Part 61 ATPL is a higher standard
However in aviation before someone can actually exercise the priviledge of a ATPL they would have to passed numerous OPCs, line checks, endorsement, then the entire command upgrade program. Then after that they are tested regularly.
You'll be at a BBQ or two in the days ahead. Tell your friends that the nasty Commonwealth wants you to do a test for an ATPL and see how much sympathy you get.
Alternatively could also pass your ATPL flight test and then fail the endorsement!! What does that say about the ATPL flight test??
Last edited by neville_nobody; 28th Dec 2016 at 23:32.