More CASA obfuscation?
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More CASA obfuscation?
For the general interest of all flying school operators, here is a slightly redacted letter received today from Mr Skidmore of CASA.
Dear
New flight crew licensing regulations
Thank you for your letter dated 6 May 2015 which responds to my letter dated 30 April 2015 about the implementation of the new flight crew licensing regulations. Please accept my apologies for the lengthy delay in providing you with a response.
Your feedback is welcomed.
The concerns you raise about integrated training, the requirement for operators to hold a Part 142 certificate and the transition process are noted and will be looked into during the post implementation review process.
I would like to comment briefly on the subject of Part 142 and integrated training. Under Part 5 of the Civil Aviation Regulations 1988 (CAR1988), integrated training was managed by the Day VFR Syllabus. There were basic requirements for organising the theory and the practical flight training in a standard plan, which all schools were required to follow. All operators conducting training under that system needed to hold an Air Operator Certificate (AOC).
Also, the system didn't provide many opportunities for schools to develop alternative training programmes. The new flight crew licensing regulations make provision for greater flexibility in the management of pilot training as well as removing the requirement to hold an AOC for certain kinds of training.
The purpose of assigning integrated training, like type rating training, to Part 142 is to ensure the training is conducted according to certain principles. The benefits of conducting integrated training rely upon the training being delivered and managed in a structured and controlled manner, unlike non-integrated training, which can be managed in an ad hoc manner. This doesn't mean Part 141 training can't be as structured and managed; it simply means the Part 142 operator needs to have an exposition that ensures the training is managed according to those principles. The critical differences between Part 142 and Part 141 training lie in the training management system, safety management system, and internal training and checking requirements. However, these requirements should not be forcing operators to implement unnecessary complexity into their training systems.
2
I am aware of concerns about the performance of CASA amongst people in the aviation community and I am committed to addressing the issues behind these concerns. A structural review of CASA is underway and I will be making important decisions about changes to the organisation when this is completed. I agree with you that CASA's performance must improve.
Yours sincerely
Mark Skidmore AM Director of Aviation Safety
So Mr. Skidmore thinks that "these requirements should not be forcing operators to implement unnecessary complexity into their training systems". Well, with all due respect Mr. Skidmore, that is exactly what they are doing. In my view, there is no demonstrable safety case for forcing existing flying training organisations, who currently deliver integrated CPL training, to become Part 142 operators.
Should we hold out hope that Mr. Skidmore believes "that CASA's performance must improve"?
Over to the wolf pack now for your comments.
Dear
New flight crew licensing regulations
Thank you for your letter dated 6 May 2015 which responds to my letter dated 30 April 2015 about the implementation of the new flight crew licensing regulations. Please accept my apologies for the lengthy delay in providing you with a response.
Your feedback is welcomed.
The concerns you raise about integrated training, the requirement for operators to hold a Part 142 certificate and the transition process are noted and will be looked into during the post implementation review process.
I would like to comment briefly on the subject of Part 142 and integrated training. Under Part 5 of the Civil Aviation Regulations 1988 (CAR1988), integrated training was managed by the Day VFR Syllabus. There were basic requirements for organising the theory and the practical flight training in a standard plan, which all schools were required to follow. All operators conducting training under that system needed to hold an Air Operator Certificate (AOC).
Also, the system didn't provide many opportunities for schools to develop alternative training programmes. The new flight crew licensing regulations make provision for greater flexibility in the management of pilot training as well as removing the requirement to hold an AOC for certain kinds of training.
The purpose of assigning integrated training, like type rating training, to Part 142 is to ensure the training is conducted according to certain principles. The benefits of conducting integrated training rely upon the training being delivered and managed in a structured and controlled manner, unlike non-integrated training, which can be managed in an ad hoc manner. This doesn't mean Part 141 training can't be as structured and managed; it simply means the Part 142 operator needs to have an exposition that ensures the training is managed according to those principles. The critical differences between Part 142 and Part 141 training lie in the training management system, safety management system, and internal training and checking requirements. However, these requirements should not be forcing operators to implement unnecessary complexity into their training systems.
2
I am aware of concerns about the performance of CASA amongst people in the aviation community and I am committed to addressing the issues behind these concerns. A structural review of CASA is underway and I will be making important decisions about changes to the organisation when this is completed. I agree with you that CASA's performance must improve.
Yours sincerely
Mark Skidmore AM Director of Aviation Safety
So Mr. Skidmore thinks that "these requirements should not be forcing operators to implement unnecessary complexity into their training systems". Well, with all due respect Mr. Skidmore, that is exactly what they are doing. In my view, there is no demonstrable safety case for forcing existing flying training organisations, who currently deliver integrated CPL training, to become Part 142 operators.
Should we hold out hope that Mr. Skidmore believes "that CASA's performance must improve"?
Over to the wolf pack now for your comments.
CASA response
That response from CASA deserves this follow up question.
If the training delivered by the 142 and 141 organisation is so different. Why is it that both candidates do the same flight test and are required to demonstrate the identical competencies, on that test?
If the training delivered by the 142 and 141 organisation is so different. Why is it that both candidates do the same flight test and are required to demonstrate the identical competencies, on that test?
CASA aside, I think we have two types of students, more so today then even a few years ago.
The first type is the original, pay as you go, lesson here, lesson there, bit in an RAA machine and so on till they either quit or achieve their goal. Somewhere amongst this they self study then sit the required exams.
The "new" type fronts up with cash or a government funded debt and expects continual training, in house exam schooling and a quick path towards their goal. These students should need less hours (perhaps).
Do we need new types of fight school, new parts for each, new ops manuals and new air operators certificates? I don't think so. I just quit as a CFI because at this stage in life the pay wasn't enough for me to be inclined to frig around with the paperwork. Also, unfortunately, every time I opened part 61 my eyes suddenly glazed over and I got a terrible thirst coupled with a dire need to be elsewhere.
The first type is the original, pay as you go, lesson here, lesson there, bit in an RAA machine and so on till they either quit or achieve their goal. Somewhere amongst this they self study then sit the required exams.
The "new" type fronts up with cash or a government funded debt and expects continual training, in house exam schooling and a quick path towards their goal. These students should need less hours (perhaps).
Do we need new types of fight school, new parts for each, new ops manuals and new air operators certificates? I don't think so. I just quit as a CFI because at this stage in life the pay wasn't enough for me to be inclined to frig around with the paperwork. Also, unfortunately, every time I opened part 61 my eyes suddenly glazed over and I got a terrible thirst coupled with a dire need to be elsewhere.
If the training delivered by the 142 and 141 organisation is so different. Why is it that both candidates do the same flight test and are required to demonstrate the identical competencies, on that test?
When Joe Bloggs comes in to do his training on an ad hoc basis, he's always going to end up with some holes in his knowledge no matter how good the flying school is and how motivated he himself is. The integrated course, for those who have the time, money and situation to sign up for it, should (if well run) turn out a more consistently trained pilot. Of course it won't work for everyone, but the idea is reasonable.
I guess the whole Part 142 thing is an attempt to strike a better balance between ad hoc and structured training - a small hours reduction for a structured course, an hours increase for your more casual situation. Interesting to see how it pans out in practice.
triadic,
Have a look at MOS for stall and recovery, compared to when you and I learned to fly.
The current CASA MOS "competency standard" requires a demonstration of the "competency" that gave us Colgan Air, AF 447, and a number of serious incidents in Australian regional operators.
Probably unsurprisingly, said MOS apparently ignores current Boeing and Airbus recommendations, and in my view, doesn't even understand why we do these exercises in the first place --- to recognise the situation through the set of your pants, and never get near them in day to day operations.
Tootle pip!!
Have a look at MOS for stall and recovery, compared to when you and I learned to fly.
The current CASA MOS "competency standard" requires a demonstration of the "competency" that gave us Colgan Air, AF 447, and a number of serious incidents in Australian regional operators.
Probably unsurprisingly, said MOS apparently ignores current Boeing and Airbus recommendations, and in my view, doesn't even understand why we do these exercises in the first place --- to recognise the situation through the set of your pants, and never get near them in day to day operations.
Tootle pip!!
From Part 61 MOS:
Why don't you put up a better set of competency standards then, LeadSled?
What would you prefer?
(i) Using seat of pants, recognises conditions leading to stall;
(ii) Discontinues manoeuver before stall actually occurs;
(iii) There is no step (iii)
A5.1 – Enter and recover from stall
(a) perform pre-manoeuvre checks for stalling;
(b) recognise stall signs and symptoms;
(c) control the aeroplane by applying the required pitch, roll and yaw inputs as appropriate in a smooth, coordinated manner, trims aeroplane accurately to enter and recover from the following manoeuvres:
(i) incipient stall;
(ii) except for multi-engine aeroplanes, stall with full power applied;
(iii) stall without power applied;
(iv) stall under the following conditions:
(A) straight and level flight;
(B) except for multi-engine aeroplanes, climbing;
(C) except for multi-engine aeroplanes, descending;
(D) approach to land configuration;
(E) except for multi-engine aeroplanes, turning;
(d) perform stall recovery as follows:
(i) positively reduce angle of attach;
(ii) use power available and excess height to increase the aircraft energy state;
(iii) minimise height loss for simulated low altitude condition;
(iv) re-establish desired flight path and aircraft control;
(e) recover from stall in simulated partial and complete engine failure configurations.
(a) perform pre-manoeuvre checks for stalling;
(b) recognise stall signs and symptoms;
(c) control the aeroplane by applying the required pitch, roll and yaw inputs as appropriate in a smooth, coordinated manner, trims aeroplane accurately to enter and recover from the following manoeuvres:
(i) incipient stall;
(ii) except for multi-engine aeroplanes, stall with full power applied;
(iii) stall without power applied;
(iv) stall under the following conditions:
(A) straight and level flight;
(B) except for multi-engine aeroplanes, climbing;
(C) except for multi-engine aeroplanes, descending;
(D) approach to land configuration;
(E) except for multi-engine aeroplanes, turning;
(d) perform stall recovery as follows:
(i) positively reduce angle of attach;
(ii) use power available and excess height to increase the aircraft energy state;
(iii) minimise height loss for simulated low altitude condition;
(iv) re-establish desired flight path and aircraft control;
(e) recover from stall in simulated partial and complete engine failure configurations.
What would you prefer?
(i) Using seat of pants, recognises conditions leading to stall;
(ii) Discontinues manoeuver before stall actually occurs;
(iii) There is no step (iii)
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I believe the problem is that this often not taught for a variety of reasons, one of which is the instructor in many cases is afraid of the stall him/herself. Bring back spinning would be one solution. X/w ops also fall into the same category with some instructors avoiding flights in such conditions. You can quote as much as you like from pt61 but it does little to improve instructors or the end product. Sadly I have seen CFI's and ATO's fall into this category - with the resultant poor end product.
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Casual observation, but adherence to every line of the rules seems to be the instructors modus operandi now.
Talking with their peers about rules rather than a students progress...??
Yep thats a plus for safety
Talking with their peers about rules rather than a students progress...??
Yep thats a plus for safety
It falls to the individual instructor, in the end, to deliver appropriate training which to my mind should aim to develop a pilot's ability to save his or her arse when the time comes.
Rules these days, for better or worse, are written in such a way as to overtly specify every little detail that in the old days would have fallen under the blanket of good airmanship or simply ability to do something properly or not.
Using the quoted Part 61 MOS excerpt as a basis, you could teach stalling pretty much any way you liked as long as you could put your hand on your heart afterwards and say you covered the sequences appropriately and passed on your knowledge so as to help create a safe and aware pilot.
This doesn't imply or enforce any difference from what instructors would have done 20 or 30 years ago, and leaves scope for any of the 'good airmanship' tips any instructor would want to pass on. The sometimes awkward sounding wording of 'elements of competency' etc. are just part of the worldwide phenomenon of trying to quantise and specify all those things which were previously assumed (and which could mean different things to different people). I'm not a big fan of this over-detailed waffle, but it doesn't mean the sky's falling.
I'm not saying the new system is great, but I just get sick of people automatically bagging it for the sake of it, chiming in with 'CASA is f***ed, Part 61 is f***ed and the whole future of aviation is f***ed' any time it gets mentioned.
If you're an instructor teaching stalling, teach it the best way you know how, ensure you cover the bits they tell you to cover and add all your hard-earned hot tips. No change there, no matter what set of rules we use, I would hope, and maybe all the new age quantification of human factors will prompt us to examine whether we actually try to teach that to students or just assume they'll pick it up by osmosis.
Rules these days, for better or worse, are written in such a way as to overtly specify every little detail that in the old days would have fallen under the blanket of good airmanship or simply ability to do something properly or not.
Using the quoted Part 61 MOS excerpt as a basis, you could teach stalling pretty much any way you liked as long as you could put your hand on your heart afterwards and say you covered the sequences appropriately and passed on your knowledge so as to help create a safe and aware pilot.
This doesn't imply or enforce any difference from what instructors would have done 20 or 30 years ago, and leaves scope for any of the 'good airmanship' tips any instructor would want to pass on. The sometimes awkward sounding wording of 'elements of competency' etc. are just part of the worldwide phenomenon of trying to quantise and specify all those things which were previously assumed (and which could mean different things to different people). I'm not a big fan of this over-detailed waffle, but it doesn't mean the sky's falling.
I'm not saying the new system is great, but I just get sick of people automatically bagging it for the sake of it, chiming in with 'CASA is f***ed, Part 61 is f***ed and the whole future of aviation is f***ed' any time it gets mentioned.
If you're an instructor teaching stalling, teach it the best way you know how, ensure you cover the bits they tell you to cover and add all your hard-earned hot tips. No change there, no matter what set of rules we use, I would hope, and maybe all the new age quantification of human factors will prompt us to examine whether we actually try to teach that to students or just assume they'll pick it up by osmosis.
Arm Out the Window,
Firstly, Triadic is on the money.
A whole string on that list has not been demonstrated, let alone taught, in may years. If that happened in practice, and the student was competent in all recoveries. there would be no complaints from me.
If I suggested that to some instructors of my acquaintance, they would be off like fartled stawns to Safe Work Australia, complaining about "An unsafe working environment)
Secondly, the way the "MOS" is applied in practice, including IFR tests, where zero height loss in the recover is the "be all and end all" of the assessment. Hence my reference to Colgan Air and AF 447.
Is that for real??
Tootle pip!!
Firstly, Triadic is on the money.
A whole string on that list has not been demonstrated, let alone taught, in may years. If that happened in practice, and the student was competent in all recoveries. there would be no complaints from me.
(ii) except for multi-engine aeroplanes, stall with full power applied;
Secondly, the way the "MOS" is applied in practice, including IFR tests, where zero height loss in the recover is the "be all and end all" of the assessment. Hence my reference to Colgan Air and AF 447.
(i) positively reduce angle of attach;
Tootle pip!!
(i) positively reduce angle of attach;
Maybe that was written for the F111...Hopefully that's a typo!
Recovery from incipient stall covers recognising symptoms leading up to the fully developed stall and taking action to avoid it, surely? (e.g. apply full power and adopt an attitude to prevent the stall etc)
As far as reducing angle of attack (notwithstanding the 'attach' typo) to recover from the stall, what's the issue with that, as long as full power is applied at the same time? We're talking Cessna after all, not Boeing or Airbus. Yoke or control column centrally forward sufficient to unstall the wings, rudder to prevent further yaw, along with full power works for me.
So yes, I would say 'reduce angle of attack' is for real.
As far as reducing angle of attack (notwithstanding the 'attach' typo) to recover from the stall, what's the issue with that, as long as full power is applied at the same time? We're talking Cessna after all, not Boeing or Airbus. Yoke or control column centrally forward sufficient to unstall the wings, rudder to prevent further yaw, along with full power works for me.
So yes, I would say 'reduce angle of attack' is for real.
Arm Out the Window
AOTW, you make some valid points.
However, if it is competency based training, then surely the candidate must meet the required standards to sit the test. Its quite academic how he got there (150 v 200)as long as he meets the standards. Both the 150 hour candidate and 200 hour candidate are addressing identical criteria on a similar, standardised flight test.
However that option to deliver a 150 hour option will be removed from the Part 141 organisations, and be the exclusive domain of Part 142s. Effectively the "specialist" provider for all the Multi Crew components will deliver the integrated training to the Single pilot, and the organisations specialising in the Single Pilot aspects of Flight Training force there candidates onward for another 50 hours flying, even if they met the standards back at 150 hours.
I must be missing something obvious, and I mean that quite sincerely. But from my side of the fence, its jaw droppingly ridiculous.
However, if it is competency based training, then surely the candidate must meet the required standards to sit the test. Its quite academic how he got there (150 v 200)as long as he meets the standards. Both the 150 hour candidate and 200 hour candidate are addressing identical criteria on a similar, standardised flight test.
However that option to deliver a 150 hour option will be removed from the Part 141 organisations, and be the exclusive domain of Part 142s. Effectively the "specialist" provider for all the Multi Crew components will deliver the integrated training to the Single pilot, and the organisations specialising in the Single Pilot aspects of Flight Training force there candidates onward for another 50 hours flying, even if they met the standards back at 150 hours.
I must be missing something obvious, and I mean that quite sincerely. But from my side of the fence, its jaw droppingly ridiculous.
Fair points also, glenb. As per most people, I think, I don't have any inside knowledge of the motivations and logic behind the new rules, and am scratching my head at a lot of them.
Regarding the difference between Part 141 and 142 providers, my thoughts are that what CASA are trying to do is force flying schools to 'smarten up their act' when it comes to integration of theory with practical training with the aim of ideally turning out a more consistent product. The incentive for students to sign up with a Part 142 school is the hours reduction, but of course not everyone can do that.
On your point about the Part 141 school being the single pilot specialist and the 142 more multi-crew, it could be taken that way, but I think the apparent mismatch is simply a by-product of the above - they're just saying that a student who does an integrated course should get to the same level of competency in a shorter time, all things being equal, hence the lesser hours.
Multi-crew cooperation would be a separate add-on on top of the bare CPL I would think(?) Happy to be corrected on this if anyone has a clearer picture.
Regarding the difference between Part 141 and 142 providers, my thoughts are that what CASA are trying to do is force flying schools to 'smarten up their act' when it comes to integration of theory with practical training with the aim of ideally turning out a more consistent product. The incentive for students to sign up with a Part 142 school is the hours reduction, but of course not everyone can do that.
On your point about the Part 141 school being the single pilot specialist and the 142 more multi-crew, it could be taken that way, but I think the apparent mismatch is simply a by-product of the above - they're just saying that a student who does an integrated course should get to the same level of competency in a shorter time, all things being equal, hence the lesser hours.
Multi-crew cooperation would be a separate add-on on top of the bare CPL I would think(?) Happy to be corrected on this if anyone has a clearer picture.
