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Proof that DAS Skidmore is a new broom

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Proof that DAS Skidmore is a new broom

Old 10th Aug 2015, 07:00
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Proof that DAS Skidmore is a new broom

I had a meeting with the DAS back in April and amongst other things, I had a big cry about nasty Part 61 and how it is ruining my life.

In particular, it is hard to service mining contracts in small aircraft when (effective last September) the second crew member required by the client is not legally allowed to log any flight time.

DAS Skidmore thought this was a bit silly.

Today the exemption has come through HERE

Thank you CASA for listening, congratulations DAS Skidmore and Jeff Boyd for bringing some sense and experience to the table.
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Old 10th Aug 2015, 07:16
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Good to hear he will both listen, and more importantly, act when he sees or is shown a problem.
Credit where it is due.
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Old 10th Aug 2015, 07:16
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While it is great that CASA are responding to the industry's concerns hopefully they back this up with an amendment to the formalize the exemption. An exemption should really be a temporary measure to fix an anomaly not a long term solution as the exemption makes understanding the rules much more complicated....
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Old 10th Aug 2015, 07:27
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no one,

I am hopeful that will be the outcome - that's how we all make short-term changes to our Ops Manuals etc already, isn't it?

Could it be that they are issuing a raft of exemptions and instruments to get past all the worst of the unintended consequences, so that they might have more time to ensure the subsequent amended legislation doesn't get rushed in and make a new, different mess?
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Old 10th Aug 2015, 07:44
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Devil is in the detail?

From Schedule 3

3 Before taking advantage of this exemption, the permitted co-pilot must ensure that a copy of this instrument is included in the operatorís operations manual.
How much and how long to achieve this? I presume printing it and putting it in a tab somewhere probably isn't enough....
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Old 10th Aug 2015, 07:49
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How much and how long to achieve this? I presume printing it and putting it in a tab somewhere probably isn't enough....
Folks,
Seriously, don't forget to send a copy of the amendment to the manual to CASA for "acceptance".
I wonder which CASA office will be the first to knock it back??
Tootle pip!!
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Old 10th Aug 2015, 07:51
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It is a perfect model for simplification: A one sentence law prohibiting everything, and exemptions granted to the squeaky wheels and well-connected.

Think of it: No regulations, orders or manuals of standards. Just one sentence prohibiting everything, and a benevolent regulator granting exemptions to grovelingly-thankful industry participants.

"Beyond a certain point, complexity is fraud."
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Old 10th Aug 2015, 08:28
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Horatio Leafblower,

That would be the hope but CASA do not have a good track record in that regard. For instance take the issue of what markings you need to paint on an aircraft, They issued at least 3 exemptions dating from 2008 allowing an aircraft less than 5700kg and operated within Australia to be operated without marking on the underside of the wings.

CASA EX05/08 - Exemption - display of markings and carriage of identification plates

CASA EX04/12 - Exemption - display of markings and carriage of identification plates

CASA EX16/15 - Exemption — display of markings and carriage of identification plates

The most recent one was in 2015 and is to be in force until the 2015 revision to part 45 comes into force in 2015. 7 years and 3 exemptions to update what is at best a relatively straight forward issue.

Or how about the way that CASA allows builders of experimental amateur built aircraft to do maintenance as an exemption. From time to time it expires and there have been periods when there is no exemption in place.

Hopefully CASA will not be so slow to implement the logging of copilot time in the regulations.

Last edited by no_one; 10th Aug 2015 at 08:29. Reason: typo
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Old 10th Aug 2015, 08:57
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Hopefully CASA will not be so slow to implement the logging of copilot time in the regulations.
No_One et al,
What would be far better is if Australian pilots were able to log time in accordance with ICAO Annex 1, instead of the "Australian" rules that so disadvantage young Australian pilots, vis a vie their counterparts from other ICAO states, that are vying for the same jobs in the real world.
It would mean going the full circle, until the early 1970s, Australia did comply with Annex 1 (and not by notifying a difference).

Tootle pip!!

Re: "new broom", more a very small brush, really.

Last edited by LeadSled; 10th Aug 2015 at 09:05. Reason: Add PS
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Old 10th Aug 2015, 09:53
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I raised this issue 2 years back at one of the CASA part 61 roadshows. The CASA presenter on the day was from their safety team (engineer before joining CASA) and had no idea that some charter companies are required to have 2 crew on certain contracts and the impact Part 61 would have on this.
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Old 10th Aug 2015, 10:32
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The whole idea of the new regulations was to get away from the exemptions but CASA is granting more and more every day. So much for knowing what they are doing.
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Old 10th Aug 2015, 11:39
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I had a meeting with the DAS back in April and amongst other things, I had a big cry about nasty Part 61 and how it is ruining my life.
Yep 20 odd years of frigging around and we got part 61

Thank you CASA for listening, congratulations DAS Skidmore and Jeff Boyd for bringing some sense and experience to the table.
Struth You reckon that is a good outcome? Honest? An exemption? Mate, you been totally brainwashed by these folk or what? How about telling them how stupid the whole shebang is? How frikking dumb that an exemption is needed after 20 years of writing this shite.

Your thanking them for making you work harder and having to meet with them? No wonder this industry is faarked.
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Old 10th Aug 2015, 12:07
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Credit where it's due Bob.

How much change do you reckon we would have had under the Skull?
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Old 10th Aug 2015, 12:11
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I think the thanks is for allowing us to do what we used to do. Minor victory in the grand scheme of part 61.
Without a few people kicking and screaming (yeah, I've bashed my head into brick walls about this too, it isn't fun), we wouldn't get these exemptions.

Seemingly Mark is listening at this point in time. Better than the last bloke. Long way to go yet!
CAO 48 possibly being put back another 12 months is also good for industry.


Yep bob, it's a good outcome. Better than nothing being changed and us poor buggers having to trudge along without anything being fixed.
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Old 10th Aug 2015, 12:21
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Ok,
so you can use this exemption, provided its included in your ops manual.

Can you simply insert said document and proceed, or do you need your ops manual reviewed by CASA? Afterall you have made an amendment.

Cheers
Jas
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Old 10th Aug 2015, 12:51
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jaz24zzk,
As it seems likely you are aware, all manual amendments have to be forwarded to CASA, hence my previous remarks.
It is not for "review", but acceptance, theoretically not "approval". Sadly, the "acceptance" is all to often "negative acceptance".
Tootle pip!!
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Old 10th Aug 2015, 13:09
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How can CASA knock back the insertion of a CASA instrument in a manual?
Sorry Leadsled I just don't have your negative experience in my daily dealings with the dreaded evel empire.
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Old 10th Aug 2015, 15:26
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there will be seen to be a new broom when we get in this country....

canadian owner maintenance.
the ability to decertify a commercially built privately owned aircraft and maintain it on a standalone basis.
an experimental- amateur maintenance category for privately owned aircraft.

until then the changes are all just ponypoo, window dressing and more of the same "wee know safety" nutter palaver.
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Old 10th Aug 2015, 15:52
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Hopefully they'll remove that stupid flight test for an ATPL.
Pain in the arse (and wallet for that matter)
Add the MCC course requirement to that.
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Old 10th Aug 2015, 20:48
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Unfortunately Leafblower, my take on what happened to you is this. Permit me to be the devils advocate.

You went cap in hand to a regulator and grovelled. You then received a temporary allowance of something that should have been your right in the first place!

Be aware that each exemption issued is one more noose around your neck. It can be used to strangle you at will and the best part from a bureaucrats point of view is that they literally have to do nothing to terminate your aviation since the exemption "expires" all on its own.

But wait, there is more…… Not being content with merely hanging a new sword over your head, each new exemption creates more work, and thus job security, for the bureaucrats.

You see in the public service, nothing gets done by a decision maker without a brief of advice from a bureaucrat recommending action.

So in the case of your new exemption. To renew it, the following sequence of writings must occur:

1. A statement about the regulation and why the exemption was given in the first place.

2. The experience of CASA of the effect of the exemption over the last Two years - anecdotal or otherwise evidence of what the exemption actually achieved. (Maybe a bit of international comparison as well if that can be parleyed into an overseas study trip.)

3. The regulations as they stand now, especially the impact of any changes during the currency of the exemption.

4. Mature and scholarly discussion of whether the making of a new exemption is in line with current CASA policy as well as real or foreshadowed changes in regulation or regulatory climate. Please note, the viability of your business, your career, industry economics, fairness, equity and natural justice play no part in this discussion because CASA is not bound to consider such matters and has proven time and again that it does not.

5. ..And finally a recommendation to Skidmore: "That you sign the attached exemption". If I can't string that out into Three months work then I'd be a failure.

To put it another way, the very fact that you had to do what you did is an indictment of the whole rotten, corrupt system. I suppose I could have put that more offensively if I tried, bootlicking, etc.

Glad it helps you….but in Two years the anxiety returns again!


On a related note, it appears to me from my own limited research that advances in technology, particularly avionics, are happening far faster that the current regulatory and exemption system can cope with. The strain between what is now available and the associated capabilities and technical environment the regulations were designed for is becoming to great to bridge, even for CASA and its unlimited budget.

For example Dynon Skyview now has data logging, wifi and video hanging off it as well as ADS-B in and out and intelligent radios. None of it is certified, but the price/perfomance gap is eventually going to be unbridgeable.

Last edited by Sunfish; 10th Aug 2015 at 21:06.
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