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GENERAL AVIATION SUMMIT 2018 - 9th & 10th JULY 2018

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GENERAL AVIATION SUMMIT 2018 - 9th & 10th JULY 2018

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Old 26th May 2018, 02:09
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Not sure independent instructing going to make a big difference.
I assume the independent instructors will be using their own aircraft?
Aircraft costs per hour are lower if the aircraft is more heavily utilised.

Flying schools or clubs typically can offer a variety of aircraft that are more heavily utilised (and therefore cheaper per hour to operate) than if there is only one instructor (utilisation then becomes dependent on the single instructor's availability).

I have no problems with independent instructors per se but think, why not look at encouraging schools and clubs thrive rather than treat them as a problem?
A healthy system would have a variety of schools and flying clubs from small to large providing a variety of experiences and individual points of difference. I would like to see an environment that encouraged that rather than undermine it.
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Old 26th May 2018, 02:23
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Sunfish and co, Being patronising and talking down to me with emotive language instead of backing up your proposal with some concrete answers to my questions isn't helpful to the discussion. Pprune is not an echo chamber, thank goodness, and if you are looking for confirmation bias then this is the wrong place.

I'm not some kind of aero club dinosaur, quite the reverse in fact. I have adapted my business to go with the times. I didn't need anybody's patronage when I started and I don't now. CASA have been the least of my worries and costs for the last 22 years and I have never had any association with the behemoth 142 organisations, I'm talking about 141 training.

If people are going to tinker with the livlihoods of tens of thousands of people then I think details are important.

If you want support from industry you have to stop seeing us as the evil ones standing in the way of your regulation free utopia. You have to sell us your ideas, not with motherhood statements but with solid evidence of research to substantiate your claims. It is what would be expected in any other industry.
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Old 26th May 2018, 02:40
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Originally Posted by jonkster
Not sure independent instructing going to make a big difference.
I assume the independent instructors will be using their own aircraft?
Aircraft costs per hour are lower if the aircraft is more heavily utilised.

Flying schools or clubs typically can offer a variety of aircraft that are more heavily utilised (and therefore cheaper per hour to operate) than if there is only one instructor (utilisation then becomes dependent on the single instructor's availability).

I have no problems with independent instructors per se but think, why not look at encouraging schools and clubs thrive rather than treat them as a problem?
A healthy system would have a variety of schools and flying clubs from small to large providing a variety of experiences and individual points of difference. I would like to see an environment that encouraged that rather than undermine it.
Thanks Jonkster, unfortunately there will always be some organisations who want to set up divisions. There's plenty of room for everyone and all the things you mention are available at Jandakot, including casual instructors!
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Old 26th May 2018, 03:49
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Clare Prop:
Sunfish and co, Being patronising and talking down to me with emotive language instead of backing up your proposal with some concrete answers to my questions isn't helpful to the discussion. PPRuNe is not an echo chamber, thank goodness, and if you are looking for confirmation bias then this is the wrong place.

I'm not some kind of aero club dinosaur, quite the reverse in fact. I have adapted my business to go with the times. I didn't need anybody's patronage when I started and I don't now. CASA have been the least of my worries and costs for the last 22 years and I have never had any association with the behemoth 142 organisations, I'm talking about 141 training.

If people are going to tinker with the livlihoods of tens of thousands of people then I think details are important.

If you want support from industry you have to stop seeing us as the evil ones standing in the way of your regulation free utopia. You have to sell us your ideas, not with motherhood statements but with solid evidence of research to substantiate your claims. It is what would be expected in any other industry.
Clare Prop, I apologise if I sounded condescending. However I take issue with your proposal that if we are going to "tinker with the livelihoods of tens of thousands of people" then we have to convince you that the result is going to be better for you personally by showing you conclusive detailed research that proves the case. Government never does that. It's logically impossible because you are asking me to prove a negative - ie; prove that you won't be worse off.

The Australian textile clothing and footwear sector and whole swathes of Australian manufacturing jobs, including the automotive industry were wiped out, not "tinkered with" with nothing but broad brush economic rationalist theory, which is why consumer goods are now a fraction of the cost they were three decades ago. Nobody showed those industries "the details" prior to change either. So it's a bit rich when change is proposed that might affect you to suddenly demand detailed justifications although its perfectly natural.

Furthermore your proposal that reformers have to sell the idea of reform based on detailed research is poppycock. The GA sector is dying under the weight of dysfunctional regulation instigated by a rotten aviation Act. There have been endless reviews and reports documenting that fact - there's your research. As to what shape the industry assumes if the Act is changed, I don't know. I can't know. I don't want to know. I want the shape of the industry to be "designed'(not the right word, I know) by a new set of freedoms and simple and fair regulation and the natural interplay of free market forces. What I do NOT want is some bunch of pr!cks in Canberra determining the shape of the industry according to their own personal proclivities as it was in the days of Sir (Donald?) Anderson and is now thanks to CASA's regulations which make whole swathes of aviation activities uneconomic.

Nobody can guarantee that your school is going to survive such an upheaval, nor should they. Your concerns are quite natural but unfortunately orthodox economics indicate that trying to insulate you from the effects of change will trigger an avalanche of similar demands and kill any hope of reform at all.
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Old 26th May 2018, 04:58
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OK well good luck with that. If you are going to convince industry and government I suggest you have something more than motherhood statements to back up your proposals.

I'm up to speed with economics and market forces in GA thanks, otherwise I wouldn't still be in business. There is nothing unreasonable about asking for clarification when proposals are out up that may mean I have to adapt.

If you will dismiss industry input then who are you actually representing? You've admitted that existing operators should not survive your upheaval so who is going to train the army of instructors waiting in the wings for this brave new world? Or is the need for an instructor rating too much regulation?

Comparisons with other industries that have been affected by cheap imports and high labour costs is irrelevant unless your idea includes putting existing local businesses out of work and allowing cheap imported instructional labour.
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Old 26th May 2018, 05:25
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However I take issue with your proposal that if we are going to "tinker with the livelihoods of tens of thousands of people" then we have to convince you that the result is going to be better for you personally by showing you conclusive detailed research that proves the case. Government never does that. It's logically impossible because you are asking me to prove a negative - ie; prove that you won't be worse off.

Not at all. I'm asking for some evidence that you can use to back this up and convince the whole industry.

Furthermore your proposal that reformers have to sell the idea of reform based on detailed research is poppycock.
Um, OK....!

The GA sector is dying under the weight of dysfunctional regulation instigated by a rotten aviation Act.There have been endless reviews and reports documenting that fact

References please. If you had said the Airports Act then I would agree with you. That is at the forefront of the rot. We can't run a GA industry without affordable accessible infrastructure and landlords who are gouging us.

As to what shape the industry assumes if the Act is changed, I don't know. I can't know. I don't want to know.

OK . I'm baffled as to why you are so determined to change the face of the industry but not care about the outcome.

orthodox economics indicate that trying to insulate you from the effects of change will trigger an avalanche of similar demands and kill any hope of reform at all.

Where did you study economics? Are all demands from industry representatives automatically unreasonable compared to the ideals of people who presumably make their living from some other profession? Are you saying that all industry reform can only be driven by the consumer? How is that going to attract investment?

I'm trying to open up a dialogue and give you the opportunity to expand on your ideas. Why can't you do that instead of trying to shut me down by being patronising? This is PPrune, not an echo chamber. If you don't want to be challenged then you are in the wrong place.
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Old 26th May 2018, 06:13
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[QUOTE]and allowing cheap imported instructional labour. [QUOTE]
Clare Prop,
Where did you get that idea?

Whether you accept it or not, around 70% of pilot training in the biggest aviation market is conducted by a person who is a FAA CFI -- Certified Flying Instructor. If you want to set up an FAA 141 or 142 school, the commercial advantage you get is being able to put a student up for test with less total hours.

Far to many Australian "commentators" heap damnation on "change" proposals with little or no knowledge of what happens in the rest of the world --- and this includes employees of CASA (especially) and Airservices.

When I first started flying, in UK, I did go to an "approved" flying school, because I could get a PPL in 30 hours, just flying with an instructor, minimum 40 hours.

My PPL examiner came from the Royal Aero Club panel of examiners, nothing to do with (what became in 1972) CAA UK.

When I started instructing, I did the required course for an "Assistant Instructor" and the examiner who tested me and granted the certificate was from the Guild of Air Pilots and Navigators,GAPAN, ( now The Honourable Company of Air Pilots and Navigators) nothing to do with CAA , and ALL ON A PPL, not a CPL. In those days, the first time you encountered the "Man from the Ministry" was a CPL flight test.

When I got my first Test Pilot certification (nothing fancy, just "Production and Post Maintenance, all aircraft up to 12,600lbs, but a hard way to get D.P. Davies autograph) that came from the ARB, aka the Air Registration Board Ltd, a company jointly owned by most of the companies that made up the UK aviation industry. The ARB (not a Government body, but set up by Government legislation pre-WWII) set and administered airworthiness certification and maintenance standards. Interestingly, UK decided to not harmonize with US in those days, because UK had what we would now call "performance based" or "outcome based" design and certification standards, and considered the US far to rigid. In those days, UK was a major manufacturer of light aircraft, that was all killed largely by post WWII bureaucratic intervention.

And after all these years ( post 1972) of the bureaucracy ( CAA , aka the Campaign Against Aviation) having swallowed up everything, and strangling aviation, in may ways the UK is now reverting to what worked so well many years ago. And I do not doubt the Brexit will accelerate the change.

And the reason for all of the above exposition ---- just to show there are other ways of doing business, not just in the US. And that everywhere, public "service" bureaucracy is the existential enemy, not a friend.

In Australia we are beset with prescriptive and restrictive regulation to the max, a regulatory frame work that is the worst in the world, and getting worse, not better, not a glimmer (except for CASR Parts 21-35) of the reforms in many countries in recent years. And the common thread through all the genuine reforms ----- to get rid of mountains of accumulated restrictive regulation that does nothing for air safety outcomes. And allow the "aviation industry" to take responsibility where it should fall, not on micro-managing bureaucrats whose default position is "NO"

Except in Australia.

Tootle pip!!
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Old 26th May 2018, 06:27
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Clare Prop,
On a slightly different note, CASA is an air safety regulator, it has no economic regulatory function, have a look at the Act. It is specifically barred as an economic regulator.
CASA cannot make decisions based on economic outcomes, as we know all too well.
If there are far too many flying schools on an aerodrome to make commercial sense, that is nothing to do with CASA.
In part, that is why the Act must be changed, to make certain that that proper coast/benefit analysis is mandatory in justifying any regulation , but ONLY for management of risk (aka Safety) , not economic outcomes.
Tootle pip!!
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Old 26th May 2018, 06:56
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And reg 206 (4) photography) is commercial. No AOC or CPL..... BANG !!! Gotcha, You're dead. !!
reg 2 (7) d using an aircraft for a commercial purpose. , ie photography...BANG !!! Gotcha. Coup de grace !!.

Note ..it doesnt say using an aircraft for a dangerous, reckless or negligent purpose...a commercial purpose. FFS !!
Which shows, as we all know..the Cretins Against Sensible Aviation have NFI about "safety",but plenty about power and control.
How amusing...! Not if you lose yr job.
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Old 26th May 2018, 07:30
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Over regulation is not the answer. Lack of regulation and 'free market' is not the answer either. Common sense is.
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Old 26th May 2018, 07:33
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Devil

Originally Posted by aroa
And reg 206 (4) photography) is commercial. No AOC or CPL..... BANG !!! Gotcha, You're dead. !!
reg 2 (7) d using an aircraft for a commercial purpose. , ie photography...BANG !!! Gotcha. Coup de grace !!.

Note ..it doesnt say using an aircraft for a dangerous, reckless or negligent purpose...a commercial purpose. FFS !!
Which shows, as we all know..the Cretins Against Sensible Aviation have NFI about "safety",but plenty about power and control.
How amusing...! Not if you lose yr job.
And under FAA style rules, just Part 91, private, FARs don't even have an Aerial Work catagory.
That CAR 206 has caused so much trouble over the years is one of the most glaring examples of half completed regulatory change, there are other remnants scattered throughout the "rools".
Tootle pip!!
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Old 26th May 2018, 08:14
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LeadSled, I came through the UK system as well, I did the CAAFU CPL flight test at EGHH and worked as an AFI/QFI in EGJA and EGJJ, when I did it there was no more instructing on a PPL though I was trained by some PPL instructors, some were great, some were atrocious, like anywhere, and most were building hours towards the CPL which as you would know required 700 hours then. I also hold FAA qualifications.

When I came to Australia it was quite a surprise to see how different things were here and I have seen many regulatory changes over the past 20 years. Some good, some bad and a lot of hysteria from people adverse to change at any cost. I have taken changes in my stride and kept my business going while many have failed for all kinds of reasons (mostly an inablility to adapt to changes in regulation or market forces and/or simple bad management)

The two things I have observed that have contributed most to the decline in GA are the Airports Act and the raising of the weight limit for RA Aus. The FEE-Help hasn't helped, where students are lured away from the smaller schools to the behemoths for "free flying" and risk finding their logbooks in a skip if the school goes into liquidation. As Sunfish has rightly said in another thread, RA Aus changes can allow the remains of GA to be swept into a small dustbin. That is a result of easing restrictions. There is room for us all, but I feel that any changes should be done with industry consultation rather than just consumer opinions. Otherwise next time you need an AFR you might just find tumbleweeds where the runway used to be.

When you have CASA filled with drongoes who are either ex military or ex sheltered behemoth environments then of course they can't be expected to understand economic realities because they are the untouchable ones with a nice fat pension to look forward to no matter how much they ^^^^ up. The economics are up to the operators.

We operators are not sitting on pots of gold but assets that have plummeted in value such as buildings on commonwealth airport sub- leaseholds that will be pulled out from under us at renewal time and *maybe* rented back to us at massive expense. THIS is what needs to be sorted out, no matter what regulatory environment you are working in you can't have a thriving GA industry with unaffordable infrastructure and hostile landlords and a minister who, like Albanese in his time, just lets them run amok; if they had their way there would be no GA airports in the capital cities.

IS the solution to move training away from the capital cities? Thing is the sort of people who can afford to fly are likely to be time poor so driving for hours for a lesson isn't an option for everyone. Hence airports within a couple of hours drive of the city are mostrly deserted when they should be humming with activity.

I'm all for looking at proposed changes but it would be irresponsible to make major business decisions and investments based on motherhood statements. I suspect most finance companies would see it the same way. So please, answer my questions.

If you think CASA regulation is restrictive try working in the food manufacturing industry....Aviation isn't a special case. It has high consumer expectations too.
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Old 26th May 2018, 09:18
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Quote ClareProp “......so who is going to train the army of instructors waiting in the wings for this brave new world? Or is the need for an instructor rating too much regulation?”

i would think that existing schools could benefit from a regulatory environment such as the FARs because they would be in a position to supply instructor training and the instructor required experience level.

If we have a reform program that is getting results, and we remain on the warpath, it’s much more likely that the question of tenure on government airports will get the attention it deserves. I’ve always believed that the airside should remain public, like roads, and the landside be privately owned, for the obvious reasons of security and capital preservation for the aviation business owners.

There are a number of other areas crying out for reform which might well come under the spotlight once we establish the general need and have have some reform action. Measures to encourage growth, incentives such as relief from ASICs, a minimum acceptable start might be 5 year validity for those with commercial licences, or having held licences for more than 10 years, or think of a graduated system (a senior’s card?).

Recently a new PPL candidate known to me was told he had to have an ASIC to have his licence issued. For that, apart from the forms, birth certificate paperwork and associated police checks, he had to drive to security controlled airport and have the ARO sign a paper confirming that he needed the ASIC because he had a need to fly into that airport.
The ASIC, truly A Sick and Asinine procedure which cost this PPL applicant $283 plus a 1:5 hr drive. Now read the CASA website on ASICs and AVIDs, I defy anyone to come to definite conclusion about exactly where one or the other will suffice. Why you could not do with the cheaper 5 year AVID is beyond rational comprehension. They don’t have this in the US, this is just our penchant for massive and costly overkill with zero follow up to check for actual benefits.

We should work to achieve more incentives through regulation, say double the validity of the AFR for higher licence categories and for aircraft ownership. Since retirement I have had to waste much time and money demonstating my aircraft (BFR/AFR) to my colleagues to retain my flying status. It is enjoyable to fly with one’s peers but there’s an element of waste and the system could easily be more practical and much less wasteful.

This paper from AOPA Australia is background to improvements that are being sought :-
Discussion Paper: Independent Flight Instructors

Background

Australia has experienced a decline in active pilot numbers and in new trainees that is impacting the aviation industry at all levels. Traditional flight schools are struggling to meet the requirements of CASR §61 and this has led to an increase in the cost of training and virtually excluded small schools from the market. In regional Australia, where Aero Clubs once flourished, flight training is almost non-existent. In addition to the fees charged by CASA to process applications, applicants endure significant compliance and related costs during the certificate life-cycle.

A global shortage of airline pilots has resulted in airlines in the major markets such as North America and Europe cancelling flights caused by the inability to source adequate numbers of qualified personnel. There is an urgent need to address the global demand for trained pilots that could be met by Australian flight instructors.

ICAO

ICAO Annex 1 outlines the Standards and Recommended Practices for Personnel Licensing, including pilot licenses. Annex 1 provides for training by authorized instructors working as individuals or providing training as part of an approved course.

CASA’s implementation of Annex 1 standards does not allow for instructors to work outside of an approved school. Australia therefore has flight schools individually authorized by CASA under CASR §61 or §141.

FAA

There are three flight instructor certificates available in the USA. These certificates are commonly referred to as: Certified Flight Instructor (CFI), Certified Flight Instructor Instrument (CFII) and Multi Engine Instructor (MEI). All are stand-alone certificates i.e. there is no requirement to hold any one instructor certificate before you can hold any of the others.

Although flight instructors can and do work independently, most work for a flight school that may or may not hold an FAA §141 certificate. As an example, ATP with over 300 aircraft, 300 instructors, 42 locations and delivering about 190,000 hours of training annually do this under §61. It is estimated that 70% of pilots are trained under §61. For those schools wishing to be certificated under §141, the process is relatively straightforward forward with the FAA providing templates for the required manuals and processing the application with no fee attached.

A flight instructor need only hold a class three medical certificate since the FAA views the service a flight instructor is being paid for is their teaching services, not their piloting services. If the student is legally entitled to be the pilot in command, the flight instructor need not hold a medical certificate at all. An example of this is an instructor teaching a commercial student who already holds a private certificate, the student is entitled to be PIC and therefore the instructor does not require a medical. Similarly, for a Flight Review, provided the candidate has a current medical and their Flight Review currency has not lapsed, the flight instructor conducting the review need not have a current medical. There is no requirement for the FAA to be notified that a Flight Review has been conducted.

There is no need to go to a §141 school for any training for a pilot certificate or rating. Even flight instructors can be trained by other flight instructors under §61. The only limitation is that an instructor must have held an instructor certificate for 2 years and have given at least 200 hours of flight instruction before they can recommend an applicant for their first instructor certificate. Even this limitation is currently the subject of a discussion paper that proposes to remove this requirement.

The situation is similar for mechanics who can perform most maintenance without working for the holder of a §145 certificate. Certificated A&P mechanics can perform most of the maintenance required to be performed on flight school aircraft and holders of Inspection Authorizations can certify for annual inspections. These activities do not require FAA certification beyond the individual’s certificates.

PROPOSAL

Adopt the FAA interpretation of ICAO Annex 1 and permit authorized flight instructors to provide flight training for any CASA pilot license without the need to hold or work for the holder of a CASA flight school certificate. During a transitional period, grant existing holders of §61 flight school certificates provisional §141 status.

Implementation

CASA would seek the repeal of those sections of CASR §61 that require an operating certificate for individuals or organizations that provide flight training. CASR § 141 would remain to allow for schools to take advantage of the reduced training hour requirements that ICAO Annex 1 provides for when undertaking training as part of an approved course.

CASA would continue to make regulations that give specificity to ICAO training standards such as the minimum aeronautical experience required for each license as well as the knowledge requirements to be met. Instructors would be required to ensure that all required training is completed before students may progress to solo for example, and prior to being recommended for a flight test.

Other Considerations

Existing flight schools often express concern that the independent instructor system would undermine their business. In contrast to the Australian experience, the FAA process to gain a §141 pilot school certificate is straightforward and in-expensive, CASA should follow a similar, simple and affordable process. In transitioning to the new arrangements, existing CASA certificated flight schools under §61 should be granted provisional §141 status and then have two years to meet the applicable requirements for a pilot school certificate (non- provisional).

Some believe that safety is compromised however, this is not supported by FAA experience.




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Old 26th May 2018, 09:21
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Originally Posted by jonkster
Not sure independent instructing going to make a big difference.
I assume the independent instructors will be using their own aircraft?
Aircraft costs per hour are lower if the aircraft is more heavily utilised.

Flying schools or clubs typically can offer a variety of aircraft that are more heavily utilised (and therefore cheaper per hour to operate) than if there is only one instructor (utilisation then becomes dependent on the single instructor's availability).....
Seems to me that the comparison with the system in the USA should be addressed rather than independent instructors vs others.

A typical small flying school or club in the USA would be a Part 61 school - a business not requiring FAA approval - compare that with the relatively onerous Part 141 here. Of course there are independent instructors operating as a one man band but very many more who work for Part 61 schools.
https://www.faa.gov/training_testing...pilot_schools/

There is no reason for Australia's Part 141 and Part 142 vs the USA's Part 61 and Part 141,
Then compare the FAA Part 141 with our Part 142.
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Old 26th May 2018, 09:45
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Originally Posted by djpil
Seems to me that the comparison with the system in the USA should be addressed rather than independent instructors vs others.

A typical small flying school or club in the USA would be a Part 61 school - a business not requiring FAA approval - compare that with the relatively onerous Part 141 here. Of course there are independent instructors operating as a one man band but very many more who work for Part 61 schools.
https://www.faa.gov/training_testing...pilot_schools/

There is no reason for Australia's Part 141 and Part 142 vs the USA's Part 61 and Part 141,
Then compare the FAA Part 141 with our Part 142.
So their system divides flight training into basically into 2 types: you can be 'certified' (with higher compliance and oversight requirements) or 'non certified' (with less requirements)?

Seems on the face of it to be reasonable. I could see a role for the 'non certified' schools for aero clubs and smaller operations. I would still like to see commonality of competency/testing standards of pilots (and instructors) across both but lowering the operational compliance hurdles for smaller schools or clubs seems to be a reasonable idea on the face of it.
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Old 26th May 2018, 10:43
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Back to one of Clare Props Q's ..... "where are the new students coming from " ?

When Instructing in Melbourne over the years , it has been my observation the only schools doing well are those with contracts for foreign airline cadets , essentially it's been Asian airlines keeping the Australian flight Training industry going .

When I fly in rural Aus' , all the aeroclubs are dead or dying with virtually no young people at all .... nothing like enough for viable flight training in any guise !

People have neither the spare income nor the interest in learning to fly anymore ... for a host of reasons , but changing to independent Instructors will change none of that nor do Airlines want them training their cadets
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Old 26th May 2018, 22:55
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This thread has deteriorated into a discussion of one tiny part of the over regulation problem - flight schools.

Continue to carry on like this instead of looking at the bigger picture and you will get no reform and confirm the death spiral of GA.
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Old 26th May 2018, 23:22
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Well Sunny, you certainly didn't spare any keyboard strokes giving us your views on the matter.
Maybe those who have questioned this one aspect of the proposed changes have been around long enough to realise that the devil is in the detail.
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Old 27th May 2018, 00:02
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YPJT, yes, the devil is indeed in the detail but the "detail" has to depend on The Act. You can't write detail without referring to The Act. The reason we are in such a mess is because the current Act is deliberately loosely written to maximise CASA's ability to do what it wants with no responsibility for outcomes.

If you get a new Act right, then the detail you ask for will automatically reflect common sense.

By getting "the Act right", I mean framing it in outcome based terms that are amenable to measurement - without that there can be no accountability. The current act deliberately talks about "safety" which is a meaningless nominative word.
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Old 27th May 2018, 03:14
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I would agree with Sunfish about changing the Act in terms of outcome rather than prescriptive measures. One example I can think of is the whole issue of colour vision testing. Currently, in CASR Part 67, the medical standard is (my paraphrase) you need to pass the 24-plate Ishihara test - this test is specifically mentioned but is only useful for measuring red-green colour blindness. Now, red-green colour blindess is an inherited disorder which doesn't change with time (i.e. you don't suddenly develop red-green colour blindness). That is the reason why we have to do this useless test, for some of us, every year, to confirm for the 50th time you are not red-green colour blind, or to rub your nose in it that you are.

There are much similar, but better, tests out there which can measure blue-yellow colour blindness (which the Ishihara doesn't). Blue-yellow colour blindness can acquired, i.e. develop at any time due to head injury/trauma or stroke. But we're not testing for it because the Regulations say specifically - test with the Ishihara plates - an example of a prescriptive measure that is past it's use-by date.

Change the Act - but watch for the Devil in the details!
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