Mr Skidmore Letter on Part 61 - Don’t Mention the Cost!
...there is nothing with the Civil Aviation Act that says they have to look at cost, so I suppose they won’t.
...consider the economic and cost impact on individuals, businesses and the community in the development and finalisation of new or amended regulatory changes.
Whether they do anything as a result of those considerations seems unlikely though.
I also refer to the recent statement by Mr Skidmore:
My aim is to establish a common understanding with the aviation and wider community about how we will continue to deliver optimal aviation safety outcomes, while responding to a dynamic and growing aviation industry.
How can you continue to do something when you haven't yet started to do it?
AVM Skidmore allegedly wrote :“I want open and honest feedback on what is working and what is not”.
Unfortunately, AVM Skidmore, the AAT and airfields and suchlike are littered with the bodies of people and businesses who had the temerity to give "Honest feedback" to CASA.
I suspect that almost all pilots with the experience to give valuable feedback would not wish to do so for the simple reason that they will be labelled as a trouble maker by CASA staff and earmarked for vengeance.
To put that another way, your feedback will be transmitted, along with your name, to the very person who wrote the regulation. You will not be thanked.
Sorry AVM. Skidmore, unless CASA is broken up nothing will change.
Unfortunately, AVM Skidmore, the AAT and airfields and suchlike are littered with the bodies of people and businesses who had the temerity to give "Honest feedback" to CASA.
I suspect that almost all pilots with the experience to give valuable feedback would not wish to do so for the simple reason that they will be labelled as a trouble maker by CASA staff and earmarked for vengeance.
To put that another way, your feedback will be transmitted, along with your name, to the very person who wrote the regulation. You will not be thanked.
Sorry AVM. Skidmore, unless CASA is broken up nothing will change.
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With the benefit of, ohhhh minutes of experience behind me, I think the entire Part 61 debacle can be wrapped up - with some minor alterations - by the quote from Chet Beates' tome regarding Political Correctness.
"A doctrine fostered by a delusional, illogical minority, and rabidly promoted by an unscrupulous (mainstream media) Governmental department, which holds forth the proposition that it is entirely possible to pick up a turd by the clean end."
Seems quite apt, and there would appear to be a fair bit of overlap...
I also note that, while the impossibility of turd-polishing has been proven time and again, there remain those expert in the rather specialised field of rolling them in glitter and sticking lit sparklers in them.
"A doctrine fostered by a delusional, illogical minority, and rabidly promoted by an unscrupulous (mainstream media) Governmental department, which holds forth the proposition that it is entirely possible to pick up a turd by the clean end."
Seems quite apt, and there would appear to be a fair bit of overlap...
I also note that, while the impossibility of turd-polishing has been proven time and again, there remain those expert in the rather specialised field of rolling them in glitter and sticking lit sparklers in them.
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Part 61 Question
I sent a question to CASA some time ago but nothing back as yet.
Maybe someone out in pilot land has an idea?
If you are a GR1 instructor and are rated on , for example an A330 , can you provide type rating endorsements onto the aircraft in the same way that a GR1 instructor with a formation, aerobatics or other design endorsement ( like pressurisation/retract etc) can do with those aspects under the new regs?
My point is , as a current A330 captain with a GR1 rating , what is the difference training someone on either a small or big aircraft? Assuming I had access to a sim and used the airbus syllabus, what if any are the hurdles??
I was under the impression that this was the whole reason Part 61 was cranked up - to allow qualified pilots with suitable instructional skills to provide training for the industry and reduce to requirements for CASA to do it.
Or is a big aeroplane different to a little one in the regs?
Thanks for any input in advance.
wja
Maybe someone out in pilot land has an idea?
If you are a GR1 instructor and are rated on , for example an A330 , can you provide type rating endorsements onto the aircraft in the same way that a GR1 instructor with a formation, aerobatics or other design endorsement ( like pressurisation/retract etc) can do with those aspects under the new regs?
My point is , as a current A330 captain with a GR1 rating , what is the difference training someone on either a small or big aircraft? Assuming I had access to a sim and used the airbus syllabus, what if any are the hurdles??
I was under the impression that this was the whole reason Part 61 was cranked up - to allow qualified pilots with suitable instructional skills to provide training for the industry and reduce to requirements for CASA to do it.
Or is a big aeroplane different to a little one in the regs?
Thanks for any input in advance.
wja
If only it were that simple, but thankfully it is not. Otherwise the aero club mob really would take over all checking and training right across the board.
They certainly appear to have had considerable influence in CASA in drafting Part 61.
Your FE rating would need to specify the type e.g. Flight Examiner A-330. And probably somewhere it would say words to the effect 'simulator' or 'aircraft' to differentiate between one who does the type rating/IPC and one allowed to do line checks.
And because you are an FE on an airline type won't give you automatic privileges to instruct or examine on bug smashers.
They certainly appear to have had considerable influence in CASA in drafting Part 61.
Your FE rating would need to specify the type e.g. Flight Examiner A-330. And probably somewhere it would say words to the effect 'simulator' or 'aircraft' to differentiate between one who does the type rating/IPC and one allowed to do line checks.
And because you are an FE on an airline type won't give you automatic privileges to instruct or examine on bug smashers.
---- thanks and sincere respect to VICROADS. Cheers
Sounds just like our local NSW Roads and Maritime, where, incidentally, two former LAME, whom I have known for many years (one was a PPL student of mine) work.
Leadie the MCC seems to be problem #1. No one can do that either!
That alone makes a nonsense of the risible RIS. The best estimate one serious candidate has come up with, so far, is a bit over AUD $60,000.
As a matter of interest, what passes for the CASA idea of what MCC and two pilot operations comprise bears absolutely no relation to the practices of most airlines, or the SOPs of the likes of Boeing, Airbus, Bombardier etc, so what you "learn" in a CASA "approved" MCC course will have to be immediately unlearned at your first job where two crew are required --- unless it is a small company where CASA have imposed their ideas by requiring humungous "two pilot procedures" via the "accepted" operations manual.
Then you really need three pilots, one to look out the window and fly the aeroplane, while "the crew" carry out all the "two pilot procedures".
Tootle pip!!
Last edited by LeadSled; 8th May 2015 at 14:47.
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AHIA Press Release
Found the following this am:
Australian Helicopter Industry Association Limited PO Box 462 Carina Qld 4152 Australia
Mob: 0415 641 774 E: [email protected]
MEDIA RELEASE – AHIA/CASA Meeting – 6 May ‘15
CASR PART 61 AHIA/CASA MEETING - SYDNEY 6 MAY 2015
Recently CASA agreed to request from the AHIA to have a meeting to discuss industry concerns since the implementation of CASR Part 61 – Flight Crew Licensing. This is a critical piece of legislation being the foundation of all the other licensing regulations. We acknowledge the framework of the legislation is sound but some areas require change or modification to better suit the Australian operating environment.
Representatives from CASA at the meeting were: Mark Skidmore, Director Aviation Safety; Peter Boyd, Executive Manager Standards Division; Roger Crosthwaite, Manager Flight Crew Licensing Standards; Dale South, Section Head Rotorcraft Standards and John Grima, Manager Flight Standards Branch.
The AHIA representatives were: Peter Crook, AHIA President; Ray Cronin, AHIA Senior Member Part 61 Review Committee and Richard Davis, AHIA Member, Partner and Aviation Law Specialist HWL Ebsworth.
The meeting concentrated on the post implementation industry concerns on two basic issues:
There was agreement on both sides these issues require addressing. CASA advised a Post Implementation Review (PIR) of the regulation is underway and the important issues raised by AHIA will form part of the review. There were a number of issues identified in the feedback we requested from industry. There was not time to discuss all specific issues but a number of critical issues were identified requiring immediate attention to alleviate the anxiety currently existing.
The AHIA had prepared a list of issues with suggested actions and left this with CASA.
CASA has agreed to work on the critical issues first and should have suggested actions and/or changes to industry as soon as possible. The AHIA offered assistance to CASA by way of industry sector specific processionals to jointly look at areas requiring change and how those changes can be implemented in a manner that is both safe and financially acceptable to industry.
In order to move forward in a positive manner we identified the following specific technical points as the matters of utmost priority, to create pathways for voids created by the implementation of Part 61:
* Expand the 61.040 testing approvals to include grade two instructors and those approved persons who held the relevant qualifications prior to the implementation date.
* Fast track the pending exemptions in relation to low level operations and flight testing for winch, sling and rappel operations and others in the system.
* Create a pathway to allow pilots to obtain an ATPL in Australia, potentially by way of an exemption for the MCC course for the transition period.
The AHIA will increase representation at the CASA Flight Crew Licensing Sub-Committee meetings, the next of which is to occur on the 19 May 2015, we will also be in regular contact with our assigned CASA liaison officer.
This we believe was a "milestone event" as it was a most encouraging and productive meeting.
We will be communicating with CASA on a regular basis and advising the industry of outcomes as they occur.
Peter Crook
President
Australian Helicopter Industry Association
[email protected]
Mob: 0415 641 774 E: [email protected]
MEDIA RELEASE – AHIA/CASA Meeting – 6 May ‘15
CASR PART 61 AHIA/CASA MEETING - SYDNEY 6 MAY 2015
Recently CASA agreed to request from the AHIA to have a meeting to discuss industry concerns since the implementation of CASR Part 61 – Flight Crew Licensing. This is a critical piece of legislation being the foundation of all the other licensing regulations. We acknowledge the framework of the legislation is sound but some areas require change or modification to better suit the Australian operating environment.
Representatives from CASA at the meeting were: Mark Skidmore, Director Aviation Safety; Peter Boyd, Executive Manager Standards Division; Roger Crosthwaite, Manager Flight Crew Licensing Standards; Dale South, Section Head Rotorcraft Standards and John Grima, Manager Flight Standards Branch.
The AHIA representatives were: Peter Crook, AHIA President; Ray Cronin, AHIA Senior Member Part 61 Review Committee and Richard Davis, AHIA Member, Partner and Aviation Law Specialist HWL Ebsworth.
The meeting concentrated on the post implementation industry concerns on two basic issues:
- Perceived COST, and
- INTERPRETATION (Complexity).
There was agreement on both sides these issues require addressing. CASA advised a Post Implementation Review (PIR) of the regulation is underway and the important issues raised by AHIA will form part of the review. There were a number of issues identified in the feedback we requested from industry. There was not time to discuss all specific issues but a number of critical issues were identified requiring immediate attention to alleviate the anxiety currently existing.
The AHIA had prepared a list of issues with suggested actions and left this with CASA.
CASA has agreed to work on the critical issues first and should have suggested actions and/or changes to industry as soon as possible. The AHIA offered assistance to CASA by way of industry sector specific processionals to jointly look at areas requiring change and how those changes can be implemented in a manner that is both safe and financially acceptable to industry.
In order to move forward in a positive manner we identified the following specific technical points as the matters of utmost priority, to create pathways for voids created by the implementation of Part 61:
* Expand the 61.040 testing approvals to include grade two instructors and those approved persons who held the relevant qualifications prior to the implementation date.
* Fast track the pending exemptions in relation to low level operations and flight testing for winch, sling and rappel operations and others in the system.
* Create a pathway to allow pilots to obtain an ATPL in Australia, potentially by way of an exemption for the MCC course for the transition period.
The AHIA will increase representation at the CASA Flight Crew Licensing Sub-Committee meetings, the next of which is to occur on the 19 May 2015, we will also be in regular contact with our assigned CASA liaison officer.
This we believe was a "milestone event" as it was a most encouraging and productive meeting.
We will be communicating with CASA on a regular basis and advising the industry of outcomes as they occur.
Peter Crook
President
Australian Helicopter Industry Association
[email protected]
Last edited by Up-into-the-air; 9th May 2015 at 04:48. Reason: adds
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Once the expected changes come in for NVFR, you will require two pilots to fly NVFR.
Soooo, do they need to do a MCC course? Really?!? How do they do that?
Would it also be correct to say that all Grade 1 & 2 instructors need to be able to fly at night, so all instructors need a MCC course!
Soooo, do they need to do a MCC course? Really?!? How do they do that?
Would it also be correct to say that all Grade 1 & 2 instructors need to be able to fly at night, so all instructors need a MCC course!
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For years aviation law in Australia has been the same. Concoct a stupid law that nobody understands including politicians who refuse to pick up the document for debate in the House thus it automatically becomes law, then, QUOTE Fast track the pending exemptions QUOTE.
I heard Dick on "Macca" ABC Sunday this am from Forrest and he gave CAsA a blast re Part 61 and straight after that Howie Hughes from Ballina, (Hughes RAA Aircraft) giving them a good wrap including how they, (CAsA), have incorporated the US style of regulation in Australian aviation Law.
Squeeze me! Did I miss something?
I heard Dick on "Macca" ABC Sunday this am from Forrest and he gave CAsA a blast re Part 61 and straight after that Howie Hughes from Ballina, (Hughes RAA Aircraft) giving them a good wrap including how they, (CAsA), have incorporated the US style of regulation in Australian aviation Law.
Squeeze me! Did I miss something?
Last edited by Frank Arouet; 10th May 2015 at 01:45. Reason: Mothers Day.
In all seriousness though. I know of an experienced Global Express co-pilot with CPL who flies all over the world with 3000 hours in GA and Global Express time trying to get his ATPL. Seems he cannot qualify because there is no Global E simulator in Australia he can be tested on. Unless he buys an Airbus, or 737, or Dash Eight, or similar turbo prop full type rating on which to be tested, he is stuffed.
Surely CASA must be aware of this anomaly and change the rules to fix this sort of ridiculous situation which affects a significant number of CPL pilots seeking to qualify for the ATPL flight test.
Surely CASA must be aware of this anomaly and change the rules to fix this sort of ridiculous situation which affects a significant number of CPL pilots seeking to qualify for the ATPL flight test.
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Stop messing around here. The USA ATPL looks to be a good program now. Get your ATPL over there (cheaper), keep all the receipts, send the receipts to your local member and tell them you would have spent the thousands of dollars here in Australia in the local economy but it's impossible. Money talks, only money talks in this society!
CASA a to adopt risk and cost based regulatory approach!
For those who missed it this should give some ammunition to dick and others looking to reduce the cost of compliance
http://www.casa.gov.au/wcmswr/_asset...70/01-2015.pdf
http://www.casa.gov.au/wcmswr/_asset...70/01-2015.pdf
The above post was sensibly put on as a new thread.
Why would a mod then move it to this thread ?
So it will be hidden from as many as possible ?
What was the reason for moving it? No wonder many are moving away from prune !
Why would a mod then move it to this thread ?
So it will be hidden from as many as possible ?
What was the reason for moving it? No wonder many are moving away from prune !
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Dick if you have a foot or two in the reality of private aviation, and then you read
the posts on pprune, I reckon about 50% of the posters in the Australian threads
are CAsA staff ardently working at polishing the turd.
The loss of face from so many experienced pilots and owners utterly ignoring the $30 million rewrite of the regs must be being sorely felt.
The problem has been in the past that CAsA was seen as the retirement home
of the ex-RAAF. that may have passed to some extent and now we have the era of the aero club flying instructors.
None of these people have ever really privately owned and maintained aircraft.
The reality we live in has never been experienced by these people and it shows.
CAsA is Australia's (poor excuse of a) national airworthiness authority.
How many competent aeronautical engineers are employed by CAsA?
I'll bet that it is a very round figure that looks like a wendy's donut.
the real tragedy is that these fckuwits don't realise how irretrievably incompetent they are.
we have a rough ride ahead. see you in prison :-)
the posts on pprune, I reckon about 50% of the posters in the Australian threads
are CAsA staff ardently working at polishing the turd.
The loss of face from so many experienced pilots and owners utterly ignoring the $30 million rewrite of the regs must be being sorely felt.
The problem has been in the past that CAsA was seen as the retirement home
of the ex-RAAF. that may have passed to some extent and now we have the era of the aero club flying instructors.
None of these people have ever really privately owned and maintained aircraft.
The reality we live in has never been experienced by these people and it shows.
CAsA is Australia's (poor excuse of a) national airworthiness authority.
How many competent aeronautical engineers are employed by CAsA?
I'll bet that it is a very round figure that looks like a wendy's donut.
the real tragedy is that these fckuwits don't realise how irretrievably incompetent they are.
we have a rough ride ahead. see you in prison :-)
Mr Smidmores directive reads extremely well BUT
Will his minions actually implement it
Of course not, lip service is what we'll get as each of them continues to carve out their own little empires
The only government department who appear to assist industry participant is the Immigration Department assisting Transfield with those pesky "boat tourists"
Will his minions actually implement it
Of course not, lip service is what we'll get as each of them continues to carve out their own little empires
The only government department who appear to assist industry participant is the Immigration Department assisting Transfield with those pesky "boat tourists"
The problem has been in the past that CAsA was seen as the retirement home
of the ex-RAAF.
of the ex-RAAF.
Many stayed until retirement, while at the same time the airlines snapped up experienced GA pilots. Few GA pilots wanted to fly desks in DCA Head Office and I recall clearly that in those days Reg Ansett wasn't interested in hiring former RAAF pilots because he preferred to give GA pilots a go. Fine sentiments of course. On the other side of Essendon where TAA had their ops office, they preferred to hire ex RAAF. Horses for courses I suppose.
I have no facts as far as the recruiting of civilian or ex-military aircrew into CASA or previous regulator names, but there are always going to be "difficult" personalities recruited by government agencies as well as nice people. But it is unwise to automatically rubbish someone who is recruited by CASA simply because they may have been in the RAAF or the RAN Fleet Air Arm years ago.
None of these people have ever really privately owned and maintained aircraft.
The reality we live in has never been experienced by these people and it shows.
The reality we live in has never been experienced by these people and it shows.
