GENERAL AVIATION SUMMIT 2018 - 9th & 10th JULY 2018
Sunfish,
Nobody gets "freed" of the rules, just another organisation becomes the contract administrator of the impossibly dysfunctional rules, at your additional expense, and CASA has a convenient liability cutout.
Tootle pip!!
Nobody gets "freed" of the rules, just another organisation becomes the contract administrator of the impossibly dysfunctional rules, at your additional expense, and CASA has a convenient liability cutout.
Tootle pip!!
Don't expect too much from Albanese. He was the Minister in charge of infrastructure for six years, who sat back and allowed HIS tenants, the developers, to sell us out and gouge the federal airports tenants on his watch. He is a politician, he wants to be the next PM, he will say whatever he thinks you want to hear. He is only interested in balancing aircraft noise and votes in his own electorate who will keep his bum on that seat in Canberra. I'm speaking from personal experience in dealing with him while he was Minister for Infrastructure (or whatever they are called this week)
I'm interested in this "independent instructors" thing. Does this mean instructors working outside of any kind of structured flying school environment, or an instructor being able to utilise specialised instructing qualifications at more than one school?
I'm interested in this "independent instructors" thing. Does this mean instructors working outside of any kind of structured flying school environment, or an instructor being able to utilise specialised instructing qualifications at more than one school?
Clare Prop, without copying out the specific US Regs which allow, for want of a better term, independent instructors, it means that you can instruct without the equivalent of our unworkable AOC system.
It was pointed out to me years ago that Australia is probably in breach of it’s international labour agreement by virtue of not allowing a qualified person to work.
The US system is not a free for all and many such ‘independents’ band together and create flying schools. Also such groups as businesses may employ other instructors. Thus there is a considerable range, from the airline pilot who might instruct by him or herself on their days off, through to I think Part 142 schools which have some advantage regarding a lower hour requirement for, say, a consolidated course through to commercial.
I was first alerted to this having been shown a letter from John King of the respected John and Martha King flying training organisation who estimated 70% US pilots trained by ‘independents.’
Incidentally John King was commissioned by CASA some years ago to advise them.
Mike Smith has also recently written about this, could be on the AOPA website.
Nowhere would benefit more than Australia by switching to such a rational, affordable and proven method of flying training because of our sparse population. The US has a better safety record and their pilots are flying in our skies every day, Few people can afford or have the ability to jump through CASA’s high set flaming hoops today, when I started my school it was a bit silly, patronisingly so, but workable. Today nearly impossible except for the largest organisations with the deepest pockets. Even then it will be fraught with difficulties, watch out Qantas, you might get burnt and wish you’d set up your flying school in the States just as you have with some of your major aircraft overhaul business. Sorry to say.
It was pointed out to me years ago that Australia is probably in breach of it’s international labour agreement by virtue of not allowing a qualified person to work.
The US system is not a free for all and many such ‘independents’ band together and create flying schools. Also such groups as businesses may employ other instructors. Thus there is a considerable range, from the airline pilot who might instruct by him or herself on their days off, through to I think Part 142 schools which have some advantage regarding a lower hour requirement for, say, a consolidated course through to commercial.
I was first alerted to this having been shown a letter from John King of the respected John and Martha King flying training organisation who estimated 70% US pilots trained by ‘independents.’
Incidentally John King was commissioned by CASA some years ago to advise them.
Mike Smith has also recently written about this, could be on the AOPA website.
Nowhere would benefit more than Australia by switching to such a rational, affordable and proven method of flying training because of our sparse population. The US has a better safety record and their pilots are flying in our skies every day, Few people can afford or have the ability to jump through CASA’s high set flaming hoops today, when I started my school it was a bit silly, patronisingly so, but workable. Today nearly impossible except for the largest organisations with the deepest pockets. Even then it will be fraught with difficulties, watch out Qantas, you might get burnt and wish you’d set up your flying school in the States just as you have with some of your major aircraft overhaul business. Sorry to say.
OK, but I'm still not sure exactly what is meant by "independent" instructors that is different to what we have now, with all the sham contracting that still goes on.
I have read your proposal but what gap in the market are you trying to fill? RA-Aus has already taken up much of the recreational flying training. Where are all these instructors and students that CASA are preventing from training?
I held an AOC for 20 years and now have a 141 certificate that has been hanging on the wall for over a year. It meant a few tweaks to the ops manual, which is a living document that needs to be revised regularly anyway, and cost me the grand total of $0. There were no flaming hoops in fact it was easier than applying for an AOC was back in the 90s. Training in remote bases is something that we have done before and we would do again IF there was a market for it.
What I see is possibly a proposal for anyone with an instructor rating to set up anywhere with no oversight and no cost of compliance to basically make existing flying schools worthless.
What we need is enough incentive for instructors to stick around and get the experience and qualifications to be able to do the advanced training and fill the roles needed by the 142 organisations. Can you explain how your proposal is going to fill this gap?
How many flying schools did AOPA engage in consultation about this proposal? Australian ones, not John and Martha King!
I have read your proposal but what gap in the market are you trying to fill? RA-Aus has already taken up much of the recreational flying training. Where are all these instructors and students that CASA are preventing from training?
I held an AOC for 20 years and now have a 141 certificate that has been hanging on the wall for over a year. It meant a few tweaks to the ops manual, which is a living document that needs to be revised regularly anyway, and cost me the grand total of $0. There were no flaming hoops in fact it was easier than applying for an AOC was back in the 90s. Training in remote bases is something that we have done before and we would do again IF there was a market for it.
What I see is possibly a proposal for anyone with an instructor rating to set up anywhere with no oversight and no cost of compliance to basically make existing flying schools worthless.
What we need is enough incentive for instructors to stick around and get the experience and qualifications to be able to do the advanced training and fill the roles needed by the 142 organisations. Can you explain how your proposal is going to fill this gap?
How many flying schools did AOPA engage in consultation about this proposal? Australian ones, not John and Martha King!
Clare Prop’s problem with lowering the barriers to flying training amount to being against competition and sees no benefit to GA as a whole. There must be something horribly wrong with a system where there is “$0” cost to Clare and costs ranging from $8000 up front, just to submit an application (2 yrs ago still nothing), to the situation at MB where in order to manage the time consuming administrative costs existing schools have been attempting to devise a way of splitting costs of $100,000 or more. Speaking to the principal of one such school recently I’m convinced that many flying schools are facing this uphill battle and even more will go to the wall if CASA maintains it’s August deadline. That same principal tells me that they would like to sell out, a story I’ve heard from others, but there are no buyers.
I think we can all understand the precarious position that where schools have committed large capital amounts on leaseholds that have in effect been unfairly altered, this is one enormous problem, the problem of no freehold.
Regarding the max weight 600kg RAAus system, yes there’s some filling of the gap but it has limitations, in particular that these very light aircraft can’t fulfill many of the roles that GA needs. Many pilots will then need to transition to more capable aircraft, just another time consuming and costly procedure mitigating against the uptake of aviation generally, assuming that those in the bush can find a qualified Part 141/142 instructor.
Indepedent instructors is not the total answer but would go a long way to reviving GA
I think we can all understand the precarious position that where schools have committed large capital amounts on leaseholds that have in effect been unfairly altered, this is one enormous problem, the problem of no freehold.
Regarding the max weight 600kg RAAus system, yes there’s some filling of the gap but it has limitations, in particular that these very light aircraft can’t fulfill many of the roles that GA needs. Many pilots will then need to transition to more capable aircraft, just another time consuming and costly procedure mitigating against the uptake of aviation generally, assuming that those in the bush can find a qualified Part 141/142 instructor.
Indepedent instructors is not the total answer but would go a long way to reviving GA
The focus should be about the quality of the product not about the ease of regulatory oversight of the processes involved. Sadly I think it has become the opposite.
Not saying the independent instructor idea is without merit but if the idea is to reduce the regulatory restrictions enough to allow independent instructors to operate - why not just reduce those restrictions, fees, pointless form filling, hoop jumping, box ticking, cost overheads etc from the existing school model?
We had a system that worked once - a plethora of schools, flying clubs (remember them?) etc. There are advantages in maintaining and fostering the school/club model rather than doing things that may undermine it.
Jongster’s point:- “why not just reduce those restrictions, fees, pointless form filling, hoop jumping, box ticking, cost overheads etc from the existing school model?” is another method of achieving the same objective. The revival of flying training where it is needed. One essential ingredient from which all other growth and improvements can grow.
GA schools have always had plenty of competition. I have no problem with that. All this talk of jumping through flaming hoops isn't my experience of the system and I am no fan of CASA, just did what I had to do to be compliant and did it myself rather than pay some "consultant". The $8000 dollars you mention is probably about the same, adjusted for inflation, as I paid to start up over 20 years ago. How do these hundreds of thousands of dollars you mention break down?
Instructors can still instruct out in the bush under existing arrangements if the customers are there. I'm interested in what new markets this is going to open up and if it is worth devaluing existing operators' investments, that presumably all of you have benefitted from. I've shared my real life experience of the system and been shot down which gives me an insight into the amount of real industry knowledge that may have gone into this proposal. Sadly this is the sort of thing that put so many off AOPA in the past .
I'd need to see objective market research and effective consultation with industry to be convinced.
So far I see opinions and motherhood statements..
My questions are:
What is an "independent instructor" in terms of aviation law, employment law and tax law and how does it differ from the current system?
Where and who are the people who are currently being prevented from teaching and learning that need this change?
How many Australian flying schools did AOPA consult before coming up with this proposal?
Where is the market research that shows that this will "revitalise" GA?
Convince me.
Instructors can still instruct out in the bush under existing arrangements if the customers are there. I'm interested in what new markets this is going to open up and if it is worth devaluing existing operators' investments, that presumably all of you have benefitted from. I've shared my real life experience of the system and been shot down which gives me an insight into the amount of real industry knowledge that may have gone into this proposal. Sadly this is the sort of thing that put so many off AOPA in the past .
I'd need to see objective market research and effective consultation with industry to be convinced.
So far I see opinions and motherhood statements..
My questions are:
What is an "independent instructor" in terms of aviation law, employment law and tax law and how does it differ from the current system?
Where and who are the people who are currently being prevented from teaching and learning that need this change?
How many Australian flying schools did AOPA consult before coming up with this proposal?
Where is the market research that shows that this will "revitalise" GA?
Convince me.
Absolutely correct and this is where we need some action from the government, there never was and never will be freehold at the Commonwealth airports but at the same time the monopolies that are gouging their tenants need to be brought to account.
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Clare, as an instructor you can work independently of an AOC. It's the same as an instructor in the current system being able to do Flight Activity or Design Feature training outside of a flying school setting but in the States extends to PPL training as well. (I'm not sure if you can do independent training for CPL & Instrument Ratings in the States?)
Thank you, I understand that but would like to see a clearer picture of how this is going to benefit anyone and "revitalise" GA?
How is it going to provide more work for the existing instructors who are rattling around the flying schools without enough to do.
How is it going to provide more work for the existing instructors who are rattling around the flying schools without enough to do.
Presumably there has been a consensus of industry professionals that says otherwise. I look forward to seeing survey questions and responses published. You may find you no longer have a choice but to be an independent instructor.
If a small town, remote area independent instructor is good at it, and students enjoy his teaching, and learn to fly safely..he/she probably gets more business by word of mouth.
A slack jack would lose custom and have to take down his shingle and try something else.
Its the nature of capitalism, competition and being an 'entrepreneur.
And CAsA hates individuals like that. You must be micro-managed and controlled, and only "they" will allow you to do ...if you tug the forelock.
Perhaps the GA Industry should start a Class Action with the ACCC as CAsA is a supplier of Control and Regulation unfit for proper purpose, and damaging to all users..
And they cant tell the truth in advertising either.
A slack jack would lose custom and have to take down his shingle and try something else.
Its the nature of capitalism, competition and being an 'entrepreneur.
And CAsA hates individuals like that. You must be micro-managed and controlled, and only "they" will allow you to do ...if you tug the forelock.
Perhaps the GA Industry should start a Class Action with the ACCC as CAsA is a supplier of Control and Regulation unfit for proper purpose, and damaging to all users..
And they cant tell the truth in advertising either.
I might not have made it clear that the quoted $8000 upfront fee was simply to start an application. In this case there’s still no result two years later. Clare P yes now it not called an AOC now but there’s no practical difference.
Just like Examiners of Airmen are now called Flight Operations Inspectors or have they changed that too? Used to be Grades A, B, & C instructors. Now its 1, 2, & 3. Used to be Biennial Flight Review now its AFR if that’s not changed since I last looked. All part of the living fluidity of The Rules, and totally unnecessary changes which have to be incorporated into everyone’s ops manual or what do they call that now? ‘Exposition’ I heard someone say, like a story book to put your children to sleep.
Reminded me when CASA required us AOC holders to write a supplemental explanation of how we would comply with each of CASA’s rules. Just like the government should be requiring all citizens to read the criminal code and describe how not to murder people. Chief pilots and CFIs all over Australia spending weekends and nights for many months to make this new part to their ops manual. They pestered me for about three years but I stalled, eventually purchased the supplement.
This was truly a crass exercise of bullying the industry, huge waste of time and when put to the test in fact legally CASA could not enforce it because mine read on each line repeated for each reg; “ management acknowledges it’s responsibility”. Page after page and same line after line for all the regs. That was accepted because they couldn’t do otherwise.
PS I sold my Wren 460, sadly what with SIDS etc and decided to drop that as my pseudonym and because I don’t have a need for anonymity. The Wren went back to the States and now resides on Fullerton Airport. Coincidentally it left there as a new aircraft in 1964 to live initially in PNG.
Just like Examiners of Airmen are now called Flight Operations Inspectors or have they changed that too? Used to be Grades A, B, & C instructors. Now its 1, 2, & 3. Used to be Biennial Flight Review now its AFR if that’s not changed since I last looked. All part of the living fluidity of The Rules, and totally unnecessary changes which have to be incorporated into everyone’s ops manual or what do they call that now? ‘Exposition’ I heard someone say, like a story book to put your children to sleep.
Reminded me when CASA required us AOC holders to write a supplemental explanation of how we would comply with each of CASA’s rules. Just like the government should be requiring all citizens to read the criminal code and describe how not to murder people. Chief pilots and CFIs all over Australia spending weekends and nights for many months to make this new part to their ops manual. They pestered me for about three years but I stalled, eventually purchased the supplement.
This was truly a crass exercise of bullying the industry, huge waste of time and when put to the test in fact legally CASA could not enforce it because mine read on each line repeated for each reg; “ management acknowledges it’s responsibility”. Page after page and same line after line for all the regs. That was accepted because they couldn’t do otherwise.
PS I sold my Wren 460, sadly what with SIDS etc and decided to drop that as my pseudonym and because I don’t have a need for anonymity. The Wren went back to the States and now resides on Fullerton Airport. Coincidentally it left there as a new aircraft in 1964 to live initially in PNG.
Last edited by Sandy Reith; 25th May 2018 at 14:21. Reason: Missing verb
Expositions are only required for Part 142 organisations. They are similar to manuals required in many other industries, not exclusive to aviation.
The point I'm trying to make is that what you are proposing is pretty much what already exists in Part 141, including the ability to train at remote bases. Part 141 is not onerous and has cost me nothing.
Training in remote areas has challenges such as finding an instructor willing to go there, having enough students to make it cost effective, fuel, maintenance, the cost of getting an examiner up there etc. But there is nothing under Part 141 preventing people from doing this if they wish to.
Could you or someone else involved with this proposal answer the following questions:
What is the definition of an "independent instructor" and why can they not operate under an existing Part 141 arrangement?
Where and who are the people who are currently being prevented from teaching and learning that need this change?
How many Australian flying schools did AOPA consult before coming up with this proposal and where are the responses published?
Where is the market research that quantifies how this will revitalise GA?
The point I'm trying to make is that what you are proposing is pretty much what already exists in Part 141, including the ability to train at remote bases. Part 141 is not onerous and has cost me nothing.
Training in remote areas has challenges such as finding an instructor willing to go there, having enough students to make it cost effective, fuel, maintenance, the cost of getting an examiner up there etc. But there is nothing under Part 141 preventing people from doing this if they wish to.
Could you or someone else involved with this proposal answer the following questions:
What is the definition of an "independent instructor" and why can they not operate under an existing Part 141 arrangement?
Where and who are the people who are currently being prevented from teaching and learning that need this change?
How many Australian flying schools did AOPA consult before coming up with this proposal and where are the responses published?
Where is the market research that quantifies how this will revitalise GA?
Clare Prop:
Clare Prop, I feel your pain and have very little comfort to give you.
You have taken the time and the effort to jump through CASA's flaming hoops and are now faced with the probability of increased competition if a new Aviation Act releases the fetters that prevent new market entrants. Everyone who has invested time and money to meet CASA's absurd regulations thinks the same way - you are comfortable in your chains and face the possibility that the value of all that paperwork you invested in is potentially zero.
To put that another way, you feel exactly like the horse buggy manufacturers did when the motor car entered mass production, or the Australian manufacturing sector felt when tariffs were phased out.
The only way the GA sector can be saved is by stimulating investment, jobs and growth. That requires reducing the business risk associated with entering the GA market and that entails removing barriers to entry. By definition, that will hurt those living behind the barriers that will now be demolished.
The only comfort I can give you is that in the long term your costs should drop more than the prices you can charge so overall you will be better off. You get a smaller slice but the pie is larger.
However with CASA's assistance and a few more voices like yours, including the engineers and the federation of aero clubs with their big schools and other self interested groups muddying the waters by asking for endless details, the chances of real reform are just about zero. We need a new Act that provides that any and all regulations are analysed through the principles of free market economics. That process creates winners and losers.
Could you or someone else involved with this proposal answer the following questions:
What is the definition of an "independent instructor" and why can they not operate under an existing Part 141 arrangement?
Where and who are the people who are currently being prevented from teaching and learning that need this change?
How many Australian flying schools did AOPA consult before coming up with this proposal and where are the responses published?
Where is the market research that quantifies how this will revitalise GA?
What is the definition of an "independent instructor" and why can they not operate under an existing Part 141 arrangement?
Where and who are the people who are currently being prevented from teaching and learning that need this change?
How many Australian flying schools did AOPA consult before coming up with this proposal and where are the responses published?
Where is the market research that quantifies how this will revitalise GA?
You have taken the time and the effort to jump through CASA's flaming hoops and are now faced with the probability of increased competition if a new Aviation Act releases the fetters that prevent new market entrants. Everyone who has invested time and money to meet CASA's absurd regulations thinks the same way - you are comfortable in your chains and face the possibility that the value of all that paperwork you invested in is potentially zero.
To put that another way, you feel exactly like the horse buggy manufacturers did when the motor car entered mass production, or the Australian manufacturing sector felt when tariffs were phased out.
The only way the GA sector can be saved is by stimulating investment, jobs and growth. That requires reducing the business risk associated with entering the GA market and that entails removing barriers to entry. By definition, that will hurt those living behind the barriers that will now be demolished.
The only comfort I can give you is that in the long term your costs should drop more than the prices you can charge so overall you will be better off. You get a smaller slice but the pie is larger.
However with CASA's assistance and a few more voices like yours, including the engineers and the federation of aero clubs with their big schools and other self interested groups muddying the waters by asking for endless details, the chances of real reform are just about zero. We need a new Act that provides that any and all regulations are analysed through the principles of free market economics. That process creates winners and losers.