Scenic Flights NPRM
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Scenic Flights NPRM
CASA have released an NPRM on Scenic Flights
See http://www.casa.gov.au/wcmswr/_asset...nprm1306os.pdf
Interesting reading. Radical thinking as it proposes simplification.
See http://www.casa.gov.au/wcmswr/_asset...nprm1306os.pdf
Interesting reading. Radical thinking as it proposes simplification.
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Add this one to the list as well;
http://www.casa.gov.au/wcmswr/_asset...nprm1319os.pdf
Both of these may stimulate GA.
I have replied to the NPRM suggesting they remove the restriction on the number of passengers to allow the use of newer aircraft such as the Airvan. Somehow I don't think they will drop the restriction this time round.
http://www.casa.gov.au/wcmswr/_asset...nprm1319os.pdf
Both of these may stimulate GA.
I have replied to the NPRM suggesting they remove the restriction on the number of passengers to allow the use of newer aircraft such as the Airvan. Somehow I don't think they will drop the restriction this time round.
Last edited by BPA; 3rd Feb 2015 at 08:13.
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A few years ago CASA was espousing a policy to upgrade the ageing GA fleet and replace old aircraft with new ones, now they are encouraging weekend mercenaries to use old clapped out cessnas to undercut the AOC holders with more modern, safer, larger aircraft.
If you had a small fleet of new Airvans, or even a single Airvan, you can't use this option, but old mate without even a current class one can cross hire an old Cherokee 6 or flogged out 15,000 hr 50 year old 206, and set up next door and undercut you while giving you the CASA approved finger.
Class act CASA, not!
HD
If you had a small fleet of new Airvans, or even a single Airvan, you can't use this option, but old mate without even a current class one can cross hire an old Cherokee 6 or flogged out 15,000 hr 50 year old 206, and set up next door and undercut you while giving you the CASA approved finger.
Class act CASA, not!
HD
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The 5 passenger maximum was just the most popular option from the respondents, 'with some saying that the type of aircraft, rather than passenger numbers, should be considered when setting limits'
Seeing as aircraft such as the Caravan and PAC750 are carrying over 15 people to flight levels every day around the country, often by private pilots, can't see how the 5 seat limit has a compelling 'protecting the public' case.
Operators with AOCs also use 50 year old 206s etc. I don't see the distinction. Think of it the other way: a baby boomer that sells one of their investment properties, goes out and buys a new 206, hires some young pilots and starts a business where previously there was nothing.
Seeing as aircraft such as the Caravan and PAC750 are carrying over 15 people to flight levels every day around the country, often by private pilots, can't see how the 5 seat limit has a compelling 'protecting the public' case.
Operators with AOCs also use 50 year old 206s etc. I don't see the distinction. Think of it the other way: a baby boomer that sells one of their investment properties, goes out and buys a new 206, hires some young pilots and starts a business where previously there was nothing.
The majority of respondents probably do operate clapped out 50 year old 206s, and any new entrant cashed up baby boomers would probably buy the cheapest 5 seater that they could their hands on, not a new 206 !
So , for once CASA listened to the majority. Funny that, when it suits them.
But to exclude much more modern, larger, single turbine aircraft does not say much for CASA's risk analysis expertise.
So , for once CASA listened to the majority. Funny that, when it suits them.
But to exclude much more modern, larger, single turbine aircraft does not say much for CASA's risk analysis expertise.
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HarleyD, I for one think it is a good thing. And if I were an operator, I would certainly not feel threatened - encouraged if anything. The more people that get up and fly the more there will be for all. If you keep it to an exclusive club, it will continue going the way of the exclusive… dinosaurs.
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and just to add… human nature always wants more. Try a first flight in a clapped out Cherokee that is fun and you will want more, bigger, better, shinier. Of course, it may work the other way if it wasn't fun, but me thinks that may be the rarer of the two.
---- does not say much for CASA's risk analysis expertise.
Tootle pip!!
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Sprocket check, do you currently or have you ever owned a GA charter business?
If you had your view would be vastly different.
I spent a considerable amount of borrowed money establishing my business, writing an operations manual, sms, undertaking proving flights, employing appropriately qualified staff for key positions, purchasing operational equipment etc.
We do things properly, do not cut corners, and as such our business has become known locally for our service and attention to detail. We have grown from 2 aircraft to several because our guests want to fly with us for our safety record and our service.
Take one of our competitors for example, who chose not to do things properly and who decided to cut a lot of corners. They were eventually forced to close but not before they attempted to kill 6 people.
From your previous post you are suggesting that under the proposed rules, the well known owner of said business would be able to purchase an aircraft, set himself up with a website and little to no infrastructure and start offering scenic flights with significantly reduced operating costs! And you are telling me we should not feel threatened by this!
I agree that the current rules can be somewhat onerous, however, any potential operator with a great idea currently has to prove to CASA that they have the right staff, systems, procedures and infrastructure in place to operate aircraft safely. We all have to jump through the hoops, some just have a few more hoops to jump through than others. But to remove most if not all of the hoops altogether?
Human nature also looks for the cheapest option...not necessarily the BEST option. Yes there are still those people who are willing to pay more for a better product, but the vast majority will go for the cheaper option, just look at the rise of the low cost carriers.
As far as becoming the domain of the exclusive, it is a very expensive industry to be a part of, more so for business owners, but it is not out of reach of the average person, I am a very good case in point. I fear that any young pilot who has parents with money behind them will be able to buy an aircraft and begin offering flights with little to no experience outside of flying school. And don't tell me that is unlikely to happen because I have already been approached by several such people in the past 2 years who wanted to buy an aircraft and use my hard earned AOC to operate, taking risks and potentially jeopardising my business en-route to attaining their own AOC and attempting to woo clients I have worked hard to please.
Tell me this is still a good idea...
If you had your view would be vastly different.
I spent a considerable amount of borrowed money establishing my business, writing an operations manual, sms, undertaking proving flights, employing appropriately qualified staff for key positions, purchasing operational equipment etc.
We do things properly, do not cut corners, and as such our business has become known locally for our service and attention to detail. We have grown from 2 aircraft to several because our guests want to fly with us for our safety record and our service.
Take one of our competitors for example, who chose not to do things properly and who decided to cut a lot of corners. They were eventually forced to close but not before they attempted to kill 6 people.
From your previous post you are suggesting that under the proposed rules, the well known owner of said business would be able to purchase an aircraft, set himself up with a website and little to no infrastructure and start offering scenic flights with significantly reduced operating costs! And you are telling me we should not feel threatened by this!
I agree that the current rules can be somewhat onerous, however, any potential operator with a great idea currently has to prove to CASA that they have the right staff, systems, procedures and infrastructure in place to operate aircraft safely. We all have to jump through the hoops, some just have a few more hoops to jump through than others. But to remove most if not all of the hoops altogether?
Human nature also looks for the cheapest option...not necessarily the BEST option. Yes there are still those people who are willing to pay more for a better product, but the vast majority will go for the cheaper option, just look at the rise of the low cost carriers.
As far as becoming the domain of the exclusive, it is a very expensive industry to be a part of, more so for business owners, but it is not out of reach of the average person, I am a very good case in point. I fear that any young pilot who has parents with money behind them will be able to buy an aircraft and begin offering flights with little to no experience outside of flying school. And don't tell me that is unlikely to happen because I have already been approached by several such people in the past 2 years who wanted to buy an aircraft and use my hard earned AOC to operate, taking risks and potentially jeopardising my business en-route to attaining their own AOC and attempting to woo clients I have worked hard to please.
Tell me this is still a good idea...
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Competition
Finally CASA is thawing and realizing that unless they reduce complexity and cost they wont have anything left to regulate. RA AUS has been running joy flights under the guise of Trial Introductory Flights for 20+ years and people are not dying like flies. Of course the old guard will trot out the alarmist scaremongering but the fact is that joy flights are not that complicated as to justify the cost of an AOC. Simple registration and CASA actually regulating instead of legislating are all the oversight that is needed. It provides a much needed bottom rung for operators to get started and move on with cash flow to more complex operations. It also provides new revenue to justify aircraft ownership so they are not just a burdensome toy. Another benefit is getting new punters hooked on Aviation. I would surmise that there are not currently that many operators with an AOC solely providing joy flights, they would have to have other revenue streams to justify the cost of the AOC. Bottom line is the bad eggs will rort the system AOC or not.
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No ding duck, I have not got a GA operation… I do have one foot only in the aviation world on a professional basis though. I would like to have two, but I want to be in it to have fun, not stress.
From what you are saying, seems like you have a solid, reputable business. I hope it grows, but it will only grow if more people fly, right? Do you only fly scenics? or perhaps majority income? Then you are a rare operator indeed and I can see why you might worry. Although you were better than the other guy who did have an AOC, right? And you probably picked up all the business he built up and consequently lost, right?
The more aviating gets done the better. Just my humble opinion.
From what you are saying, seems like you have a solid, reputable business. I hope it grows, but it will only grow if more people fly, right? Do you only fly scenics? or perhaps majority income? Then you are a rare operator indeed and I can see why you might worry. Although you were better than the other guy who did have an AOC, right? And you probably picked up all the business he built up and consequently lost, right?
The more aviating gets done the better. Just my humble opinion.
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NPRM Scenic flight operators
Sprocket Check,
We conduct scenic flights and charter in WA. It took 2 years of planning and a lot of money to write an ops manual, conduct appropriate training for our proposed operation and plenty of money I can assure you.
This isn't a case of competition or restricting competition, far from it. This is a case of reduced safety and implied risk. CASA are basically saying that they do not want to know about people operating aircraft with less than 5 seats in scenic flight operations. They are therefore saying that the risk of an accident involving the loss of six lives (pilot plus 5 pax) is acceptable to them. The NPRM is essentially removing all of the regulatory oversight on CASA's behalf and putting the onus of responsibility on the pilot of the said aircraft. You as the owner of a flash new CPL with a 210 that mum and dad or a friend bought, conducting scenic flights, will NOT be covered by the Air Carriers Liability Act and will only require Public Liability Insurance to a level you deem sufficient. If you feel that $5 million is enough, then you can get coverage for only $5 million.
Scenic flying is not rocket science, it involves (generally speaking) flights from point A to point A. The risk however is that anyone with a CPL and an AFR (or someone with no knowledge or experience in aviation and no licence) can purchase up to 5 aircraft each of 5 passenger capacity (25 pax total capacity), turn up anywhere in the country, get 5 pilots who want to fly, pay them nothing to do so, and start selling scenic flights out of the back of a car boot with a sandwich board, no SMS, DAMP, Risk register, ops manual, chief pilot etc etc. To the general public, they see a flash website, brochure or sandwich board and decide to go on a flight. Meanwhile the operator of charter services (air transport ops - Part 121 or 135) will have to maintain an SMS, a DAMP, an organisational hierarchy including Chief Pilot and CEO, undertake appropriate maintenance on their aircraft, training and checking regime and so on. An AOC acts in some part as a deterrent to the very rare cowboys getting a foot in the door and doing the wrong thing. If there is no requirement for an AOC, there is no way for CASA to hold you to account for your actions or to penalise you, except take your licence away as the pilot. But if the owner of the aircraft doesn't have a licence or an AOC then they have nothing to lose and will simply employ another pilot to replace you, or change their company name and start again.
Young pilots need some experience in the industry, training, mentoring to develop the skills and knowledge in order to move on to bigger and better. Companies such as mine and others in northern Australia offer young pilots that opportunity, a start in the industry, with training and guidance under the leadership and responsibility of an experienced Chief Pilot. This is the internship, where you learn about the industry, flying aircraft in a relatively low risk environment, learning about the need for standard operating procedures which you are most certainly going to adhere to in the airlines.
My greatest fear is that this will significantly increase risk at the expense of passenger and pilot safety. When an aircraft or helicopter crashes the media don't care who the company was, who the pilot or passengers involved were. They sensationalise the situation and all aircraft are deemed dangerous and risky. This in turn leads to all aircraft operators being tarnished by association. Any accident is a terrible thing and I hope that it doesn't happen to anyone, but it also affects everyone, not simply the company who suffered directly from the accident.
I would appreciate the thoughts of any other chief pilots, experienced pilots or operators who frequent pprune.
We conduct scenic flights and charter in WA. It took 2 years of planning and a lot of money to write an ops manual, conduct appropriate training for our proposed operation and plenty of money I can assure you.
This isn't a case of competition or restricting competition, far from it. This is a case of reduced safety and implied risk. CASA are basically saying that they do not want to know about people operating aircraft with less than 5 seats in scenic flight operations. They are therefore saying that the risk of an accident involving the loss of six lives (pilot plus 5 pax) is acceptable to them. The NPRM is essentially removing all of the regulatory oversight on CASA's behalf and putting the onus of responsibility on the pilot of the said aircraft. You as the owner of a flash new CPL with a 210 that mum and dad or a friend bought, conducting scenic flights, will NOT be covered by the Air Carriers Liability Act and will only require Public Liability Insurance to a level you deem sufficient. If you feel that $5 million is enough, then you can get coverage for only $5 million.
Scenic flying is not rocket science, it involves (generally speaking) flights from point A to point A. The risk however is that anyone with a CPL and an AFR (or someone with no knowledge or experience in aviation and no licence) can purchase up to 5 aircraft each of 5 passenger capacity (25 pax total capacity), turn up anywhere in the country, get 5 pilots who want to fly, pay them nothing to do so, and start selling scenic flights out of the back of a car boot with a sandwich board, no SMS, DAMP, Risk register, ops manual, chief pilot etc etc. To the general public, they see a flash website, brochure or sandwich board and decide to go on a flight. Meanwhile the operator of charter services (air transport ops - Part 121 or 135) will have to maintain an SMS, a DAMP, an organisational hierarchy including Chief Pilot and CEO, undertake appropriate maintenance on their aircraft, training and checking regime and so on. An AOC acts in some part as a deterrent to the very rare cowboys getting a foot in the door and doing the wrong thing. If there is no requirement for an AOC, there is no way for CASA to hold you to account for your actions or to penalise you, except take your licence away as the pilot. But if the owner of the aircraft doesn't have a licence or an AOC then they have nothing to lose and will simply employ another pilot to replace you, or change their company name and start again.
Young pilots need some experience in the industry, training, mentoring to develop the skills and knowledge in order to move on to bigger and better. Companies such as mine and others in northern Australia offer young pilots that opportunity, a start in the industry, with training and guidance under the leadership and responsibility of an experienced Chief Pilot. This is the internship, where you learn about the industry, flying aircraft in a relatively low risk environment, learning about the need for standard operating procedures which you are most certainly going to adhere to in the airlines.
My greatest fear is that this will significantly increase risk at the expense of passenger and pilot safety. When an aircraft or helicopter crashes the media don't care who the company was, who the pilot or passengers involved were. They sensationalise the situation and all aircraft are deemed dangerous and risky. This in turn leads to all aircraft operators being tarnished by association. Any accident is a terrible thing and I hope that it doesn't happen to anyone, but it also affects everyone, not simply the company who suffered directly from the accident.
I would appreciate the thoughts of any other chief pilots, experienced pilots or operators who frequent pprune.
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I think it does threaten current operators with an aoc, and those operators will be safer with all those systems in place. However for a 182 to do a couple of laps around the Harbour bridge in good weather, a CPL is safe enough.
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From the NPRM;
3.4 CASA’s preferred option for change
Responses to DP 1210OS reveal a range of views, with an overall preference for a simplified entry control structure with minimal additional conditions. CASA shares that preference and proposes a policy based on a CASA authorisation that is simpler than, and does not fall within the AOC approval processes.
CASA agrees with industry’s preference to limit operations to VFR by day and for a maximum of 5 passengers. CASA proposes to regulate scenic flights on the basis of a VFR by day-only limitation, with operations constrained to a 50 NM radius unless otherwise approved by CASA. CASA also proposes a mandatory limit of 5 passengers for scenic flight operations.
CASA disagrees with industry’s preference for a rigid A to A flight profile. CASA proposes to proceed on the basis of A to A with no intermediate stops, unless approved by CASA. CASA would consider permitting intermediate stops within the following constraints:
• the 50 NM radius restrictions must remain unaltered unless otherwise approved by CASA
• all passengers must return to the departure point on the same day but not necessarily on the same flight (subject to CASA approval).
3.4.1 Requirements of the person exercising operational control
Under this condition, the person who exercises operational control in the scenic flight business would be required to:
• hold a commercial pilot licence (CPL) or air transport pilot licence (ATPL)
• be authorised under Part 61 to operate all aircraft of the class operated by the business
in scenic flights (e.g. single engine aeroplane, multi engine aeroplane, single engine helicopter)
Note: Pilot licences and class ratings are perpetual and once obtained do not expire even if a pilot is not current or does not hold a medical. A person exercising operational control who is licenced can reasonably be expected to have adequate aeronautical knowledge in order to manage aviation operational risk. It is not the policy intent to require that the manager or business owner be checked for proficiency nor have a medical and the current ability to operate the flight in their own right
The scenic flight business would be required to have in place an operations manual that includes a hazard and risk identification and management plan.
Access to the CASA on-line Manual Authoring and Assessment Tool (MAAT) would be expanded to include operators who elect to use the proposed simplified authorisation system. This would provide operators with a simple, low-cost means of creating an operations manual that would satisfy the proposed condition.
A hazard and risk identification and management plan for small non-complex operations would replace the proposed Part 119 of CASR 1998 AOC requirement to have a safety management system (SMS) and a safety manager. In essence, it would require an operator to have a procedure for:
• identifying hazards that could place any aspect of the operation at risk
• documenting those identified hazards
• developing processes for safely managing or eliminating the resulting risks
So as you can see you still require an OPS Manual and a Risk program, just no Chief Pilot or DAMP.
Back when I was in GA, the CP/CFI where I worked was only in the office twice a month and was really there just to satisfy the AOC requirements There was no DAMP and we operated a large fleet of singles and twins did joy flights every day of the week over Sydney with no issues.
So I see this rule change being very similar to how we operated way back then.
3.4 CASA’s preferred option for change
Responses to DP 1210OS reveal a range of views, with an overall preference for a simplified entry control structure with minimal additional conditions. CASA shares that preference and proposes a policy based on a CASA authorisation that is simpler than, and does not fall within the AOC approval processes.
CASA agrees with industry’s preference to limit operations to VFR by day and for a maximum of 5 passengers. CASA proposes to regulate scenic flights on the basis of a VFR by day-only limitation, with operations constrained to a 50 NM radius unless otherwise approved by CASA. CASA also proposes a mandatory limit of 5 passengers for scenic flight operations.
CASA disagrees with industry’s preference for a rigid A to A flight profile. CASA proposes to proceed on the basis of A to A with no intermediate stops, unless approved by CASA. CASA would consider permitting intermediate stops within the following constraints:
• the 50 NM radius restrictions must remain unaltered unless otherwise approved by CASA
• all passengers must return to the departure point on the same day but not necessarily on the same flight (subject to CASA approval).
3.4.1 Requirements of the person exercising operational control
Under this condition, the person who exercises operational control in the scenic flight business would be required to:
• hold a commercial pilot licence (CPL) or air transport pilot licence (ATPL)
• be authorised under Part 61 to operate all aircraft of the class operated by the business
in scenic flights (e.g. single engine aeroplane, multi engine aeroplane, single engine helicopter)
Note: Pilot licences and class ratings are perpetual and once obtained do not expire even if a pilot is not current or does not hold a medical. A person exercising operational control who is licenced can reasonably be expected to have adequate aeronautical knowledge in order to manage aviation operational risk. It is not the policy intent to require that the manager or business owner be checked for proficiency nor have a medical and the current ability to operate the flight in their own right
The scenic flight business would be required to have in place an operations manual that includes a hazard and risk identification and management plan.
Access to the CASA on-line Manual Authoring and Assessment Tool (MAAT) would be expanded to include operators who elect to use the proposed simplified authorisation system. This would provide operators with a simple, low-cost means of creating an operations manual that would satisfy the proposed condition.
A hazard and risk identification and management plan for small non-complex operations would replace the proposed Part 119 of CASR 1998 AOC requirement to have a safety management system (SMS) and a safety manager. In essence, it would require an operator to have a procedure for:
• identifying hazards that could place any aspect of the operation at risk
• documenting those identified hazards
• developing processes for safely managing or eliminating the resulting risks
So as you can see you still require an OPS Manual and a Risk program, just no Chief Pilot or DAMP.
Back when I was in GA, the CP/CFI where I worked was only in the office twice a month and was really there just to satisfy the AOC requirements There was no DAMP and we operated a large fleet of singles and twins did joy flights every day of the week over Sydney with no issues.
So I see this rule change being very similar to how we operated way back then.
I fear that any young pilot who has parents with money behind them will be able to buy an aircraft and begin offering flights with little to no experience outside of flying school.
Experience counts for nothing nowadays.
Experience counts for nothing nowadays.
Experience counts for nothing nowadays.
