Scenic Flights NPRM
 

CASA have released an NPRM on Scenic Flights
See http://www.casa.gov.au/wcmswr/_asset...nprm1306os.pdf
Interesting reading. Radical thinking as it proposes simplification.

if im reading this correctly, its actually a sensible change... basically relaxing some regulations regarding scenic ops in light aircraft....

Add this one to the list as well;

http://www.casa.gov.au/wcmswr/_asset...nprm1319os.pdf

Both of these may stimulate GA.

I have replied to the NPRM suggesting they remove the restriction on the number of passengers to allow the use of newer aircraft such as the Airvan. Somehow I don't think they will drop the restriction this time round.

A few years ago CASA was espousing a policy to upgrade the ageing GA fleet and replace old aircraft with new ones, now they are encouraging weekend mercenaries to use old clapped out cessnas to undercut the AOC holders with more modern, safer, larger aircraft.

If you had a small fleet of new Airvans, or even a single Airvan, you can't use this option, but old mate without even a current class one can cross hire an old Cherokee 6 or flogged out 15,000 hr 50 year old 206, and set up next door and undercut you while giving you the CASA approved finger.

Class act CASA, not!

HD

The 5 passenger maximum was just the most popular option from the respondents, 'with some saying that the type of aircraft, rather than passenger numbers, should be considered when setting limits'

Seeing as aircraft such as the Caravan and PAC750 are carrying over 15 people to flight levels every day around the country, often by private pilots, can't see how the 5 seat limit has a compelling 'protecting the public' case.

Operators with AOCs also use 50 year old 206s etc. I don't see the distinction. Think of it the other way: a baby boomer that sells one of their investment properties, goes out and buys a new 206, hires some young pilots and starts a business where previously there was nothing.

The majority of respondents probably do operate clapped out 50 year old 206s, and any new entrant cashed up baby boomers would probably buy the cheapest 5 seater that they could their hands on, not a new 206 !
So , for once CASA listened to the majority. Funny that, when it suits them.
But to exclude much more modern, larger, single turbine aircraft does not say much for CASA's risk analysis expertise.

So the PIC requires a CPL but does the aircraft need to be maintained in Charter? Condition H on page 15.

Where do you draw the line

HarleyD, I for one think it is a good thing. And if I were an operator, I would certainly not feel threatened - encouraged if anything. The more people that get up and fly the more there will be for all. If you keep it to an exclusive club, it will continue going the way of the exclusive… dinosaurs.

and just to add… human nature always wants more. Try a first flight in a clapped out Cherokee that is fun and you will want more, bigger, better, shinier. Of course, it may work the other way if it wasn't fun, but me thinks that may be the rarer of the two.

Wot risk analysis expertise??? I have never seen any evidence such expertise in CASA, and I have been around a while.

Tootle pip!!

Sprocket check, do you currently or have you ever owned a GA charter business?
If you had your view would be vastly different.
I spent a considerable amount of borrowed money establishing my business, writing an operations manual, sms, undertaking proving flights, employing appropriately qualified staff for key positions, purchasing operational equipment etc.
We do things properly, do not cut corners, and as such our business has become known locally for our service and attention to detail. We have grown from 2 aircraft to several because our guests want to fly with us for our safety record and our service.
Take one of our competitors for example, who chose not to do things properly and who decided to cut a lot of corners. They were eventually forced to close but not before they attempted to kill 6 people.
From your previous post you are suggesting that under the proposed rules, the well known owner of said business would be able to purchase an aircraft, set himself up with a website and little to no infrastructure and start offering scenic flights with significantly reduced operating costs! And you are telling me we should not feel threatened by this!
I agree that the current rules can be somewhat onerous, however, any potential operator with a great idea currently has to prove to CASA that they have the right staff, systems, procedures and infrastructure in place to operate aircraft safely. We all have to jump through the hoops, some just have a few more hoops to jump through than others. But to remove most if not all of the hoops altogether?
Human nature also looks for the cheapest option...not necessarily the BEST option. Yes there are still those people who are willing to pay more for a better product, but the vast majority will go for the cheaper option, just look at the rise of the low cost carriers.
As far as becoming the domain of the exclusive, it is a very expensive industry to be a part of, more so for business owners, but it is not out of reach of the average person, I am a very good case in point. I fear that any young pilot who has parents with money behind them will be able to buy an aircraft and begin offering flights with little to no experience outside of flying school. And don't tell me that is unlikely to happen because I have already been approached by several such people in the past 2 years who wanted to buy an aircraft and use my hard earned AOC to operate, taking risks and potentially jeopardising my business en-route to attaining their own AOC and attempting to woo clients I have worked hard to please.
Tell me this is still a good idea...

Competition
 

Finally CASA is thawing and realizing that unless they reduce complexity and cost they wont have anything left to regulate. RA AUS has been running joy flights under the guise of Trial Introductory Flights for 20+ years and people are not dying like flies. Of course the old guard will trot out the alarmist scaremongering but the fact is that joy flights are not that complicated as to justify the cost of an AOC. Simple registration and CASA actually regulating instead of legislating are all the oversight that is needed. It provides a much needed bottom rung for operators to get started and move on with cash flow to more complex operations. It also provides new revenue to justify aircraft ownership so they are not just a burdensome toy. Another benefit is getting new punters hooked on Aviation. I would surmise that there are not currently that many operators with an AOC solely providing joy flights, they would have to have other revenue streams to justify the cost of the AOC. Bottom line is the bad eggs will rort the system AOC or not.

If the fears expressed here about private operators cashing in on Scenic Flights eventuates, the Birdsville Races will be bedlam

No ding duck, I have not got a GA operation… I do have one foot only in the aviation world on a professional basis though. I would like to have two, but I want to be in it to have fun, not stress.

From what you are saying, seems like you have a solid, reputable business. I hope it grows, but it will only grow if more people fly, right? Do you only fly scenics? or perhaps majority income? Then you are a rare operator indeed and I can see why you might worry. Although you were better than the other guy who did have an AOC, right? And you probably picked up all the business he built up and consequently lost, right?

The more aviating gets done the better. Just my humble opinion.

NPRM Scenic flight operators
 

Sprocket Check,
We conduct scenic flights and charter in WA. It took 2 years of planning and a lot of money to write an ops manual, conduct appropriate training for our proposed operation and plenty of money I can assure you.
This isn't a case of competition or restricting competition, far from it. This is a case of reduced safety and implied risk. CASA are basically saying that they do not want to know about people operating aircraft with less than 5 seats in scenic flight operations. They are therefore saying that the risk of an accident involving the loss of six lives (pilot plus 5 pax) is acceptable to them. The NPRM is essentially removing all of the regulatory oversight on CASA's behalf and putting the onus of responsibility on the pilot of the said aircraft. You as the owner of a flash new CPL with a 210 that mum and dad or a friend bought, conducting scenic flights, will NOT be covered by the Air Carriers Liability Act and will only require Public Liability Insurance to a level you deem sufficient. If you feel that $5 million is enough, then you can get coverage for only $5 million.
Scenic flying is not rocket science, it involves (generally speaking) flights from point A to point A. The risk however is that anyone with a CPL and an AFR (or someone with no knowledge or experience in aviation and no licence) can purchase up to 5 aircraft each of 5 passenger capacity (25 pax total capacity), turn up anywhere in the country, get 5 pilots who want to fly, pay them nothing to do so, and start selling scenic flights out of the back of a car boot with a sandwich board, no SMS, DAMP, Risk register, ops manual, chief pilot etc etc. To the general public, they see a flash website, brochure or sandwich board and decide to go on a flight. Meanwhile the operator of charter services (air transport ops - Part 121 or 135) will have to maintain an SMS, a DAMP, an organisational hierarchy including Chief Pilot and CEO, undertake appropriate maintenance on their aircraft, training and checking regime and so on. An AOC acts in some part as a deterrent to the very rare cowboys getting a foot in the door and doing the wrong thing. If there is no requirement for an AOC, there is no way for CASA to hold you to account for your actions or to penalise you, except take your licence away as the pilot. But if the owner of the aircraft doesn't have a licence or an AOC then they have nothing to lose and will simply employ another pilot to replace you, or change their company name and start again.
Young pilots need some experience in the industry, training, mentoring to develop the skills and knowledge in order to move on to bigger and better. Companies such as mine and others in northern Australia offer young pilots that opportunity, a start in the industry, with training and guidance under the leadership and responsibility of an experienced Chief Pilot. This is the internship, where you learn about the industry, flying aircraft in a relatively low risk environment, learning about the need for standard operating procedures which you are most certainly going to adhere to in the airlines.
My greatest fear is that this will significantly increase risk at the expense of passenger and pilot safety. When an aircraft or helicopter crashes the media don't care who the company was, who the pilot or passengers involved were. They sensationalise the situation and all aircraft are deemed dangerous and risky. This in turn leads to all aircraft operators being tarnished by association. Any accident is a terrible thing and I hope that it doesn't happen to anyone, but it also affects everyone, not simply the company who suffered directly from the accident.
I would appreciate the thoughts of any other chief pilots, experienced pilots or operators who frequent pprune.

I think it does threaten current operators with an aoc, and those operators will be safer with all those systems in place. However for a 182 to do a couple of laps around the Harbour bridge in good weather, a CPL is safe enough.

From the NPRM;
3.4 CASA’s preferred option for change
Responses to DP 1210OS reveal a range of views, with an overall preference for a simplified entry control structure with minimal additional conditions. CASA shares that preference and proposes a policy based on a CASA authorisation that is simpler than, and does not fall within the AOC approval processes.
CASA agrees with industry’s preference to limit operations to VFR by day and for a maximum of 5 passengers. CASA proposes to regulate scenic flights on the basis of a VFR by day-only limitation, with operations constrained to a 50 NM radius unless otherwise approved by CASA. CASA also proposes a mandatory limit of 5 passengers for scenic flight operations.
CASA disagrees with industry’s preference for a rigid A to A flight profile. CASA proposes to proceed on the basis of A to A with no intermediate stops, unless approved by CASA. CASA would consider permitting intermediate stops within the following constraints:
• the 50 NM radius restrictions must remain unaltered unless otherwise approved by CASA
• all passengers must return to the departure point on the same day but not necessarily on the same flight (subject to CASA approval).
3.4.1 Requirements of the person exercising operational control
Under this condition, the person who exercises operational control in the scenic flight business would be required to:
• hold a commercial pilot licence (CPL) or air transport pilot licence (ATPL)
• be authorised under Part 61 to operate all aircraft of the class operated by the business
in scenic flights (e.g. single engine aeroplane, multi engine aeroplane, single engine helicopter)
Note: Pilot licences and class ratings are perpetual and once obtained do not expire even if a pilot is not current or does not hold a medical. A person exercising operational control who is licenced can reasonably be expected to have adequate aeronautical knowledge in order to manage aviation operational risk. It is not the policy intent to require that the manager or business owner be checked for proficiency nor have a medical and the current ability to operate the flight in their own right
The scenic flight business would be required to have in place an operations manual that includes a hazard and risk identification and management plan.
Access to the CASA on-line Manual Authoring and Assessment Tool (MAAT) would be expanded to include operators who elect to use the proposed simplified authorisation system. This would provide operators with a simple, low-cost means of creating an operations manual that would satisfy the proposed condition.
A hazard and risk identification and management plan for small non-complex operations would replace the proposed Part 119 of CASR 1998 AOC requirement to have a safety management system (SMS) and a safety manager. In essence, it would require an operator to have a procedure for:
• identifying hazards that could place any aspect of the operation at risk
• documenting those identified hazards
• developing processes for safely managing or eliminating the resulting risks

So as you can see you still require an OPS Manual and a Risk program, just no Chief Pilot or DAMP.

Back when I was in GA, the CP/CFI where I worked was only in the office twice a month and was really there just to satisfy the AOC requirements There was no DAMP and we operated a large fleet of singles and twins did joy flights every day of the week over Sydney with no issues.

So I see this rule change being very similar to how we operated way back then.

Happens in the airlines all the time. 250 TT gets you into the second in command position on a Boeing 777 or 737 in Asia and other parts of the world.
Experience counts for nothing nowadays.

Happens both ways - 15,000 hours in many types and many areas of the world and you still have to join Qantas as a Second Officer... :suspect:

Experience counts for nothing nowadays. :ouch:

Bring it on

Did a little digging on this subject
 

Wont be happening any time soon, watch it quietly fade away, squashed by the usual factions. That's OK soon the banks will come knocking at a few of the doors of those involved as the whole industry collapses. (aircraft repossessions are already under way)

Just cant wait to get out of aviation and get back to building the RV8

Folks,
I just love the idea that shelfware has much to do with aviation safety.

When I cast my mind back to my first "Charter License", it was somewhat more simple than CASA is now proposing for joyrides. All single engine, daylight VFR --- IFR was a real rarity in those days, as were twin engine aircraft.

It took me about two days to assemble the 20 odd page manual, which was accepted by DCA without amendment -- in fact they were really only interested in P1, all the names and addresses and the nominated Chief Pilot, the only formal position, and P2, a statement that all operations would be conducted in conformity with the Act, ANRs and ANOs, signed by the Chief Pilot.

No inspections, interviews, proving flights and all that rubbish.

In Australia, there has been no improvement in airsafety outcomes, over the years, to match the increasingly expensive and complex CASA requirements, indeed, in the last several years, GA safety outcomes have gone backwards.

CASA requirements as detailed by Ding Duck are a pretty good exposition on what is wrong with aviation regulation in Australia, a sledgehammer to crack a nut. A light aircraft operation is not an airline, FCS.

Folks, have a look at the FAA requirements for joyflights!! Their accident rate is about half the Australian equivalent.

Tootle pip!!

So few months on now, any news with this?

Gone by the wayside..
 

Have it from a reliable source that it has been strangled at birth by some big operators. So this patiently waiting (2 years), wannabe scenic flight pilot (me) is selling the aircraft that's been sitting idle waiting for this to come through.

Latest
 

Been watching these new rules and have receive the latest update.

Basically CASA are to busy with all the other changes underway at the moment that this has been put into a hold. They said unlikely to have any movement until the second half of next year. :ugh:

I am all for the change. I think all the cost and fees involved makes a small operation have to run on an oily rag and a operator that is struggling will try save some money from somewhere. There goes money spent on doing other things right.

To many rules and fees can cause money spent on things that aren't as important. Rather a nicer plane and working environment than a expensive piece of paper saying she will be right.

A small scenic operation running according to the criteria specified is no more dangerous than taking your mates up for a lap. Pilots are giving a CPL because they prove they can make safe decisions. If they can't be safe and handle running a C206 up and down VFR then they never should have been granted a licence from CASA. An AOC for this operation is basically saying they don't believe pilots have common sense. Any decisions about safety in these ops a licensed pilot should know so to me an AOC for this is just a hassle, cost and waste of time.

Besides the proposed changes aren't meaning nothing required just cheaper and less time consuming.

To be honest there is no trust left to operators and pilots. CASA sometimes forgets the pilot likes his life as well (most I hope) :ooh:

I believe most against the idea will already be operators that were nagged they had to go through the AOC process and are just jelly that its going to get easier. Come on guys that isn't the point of the change, its about safety. :=

Reduced fees for GA, will improve GA.:D

AOC clearly overkill for scenics
 

Here was casa s chance for a win with GA pilots, operators and the public. A simplified low cost option.

Mr Skidmore please reconsider. This could be top of the regulatory reform list to show the way for your staff. To get something to completion that is not controversial and In the interests of getting GA going again. And most important..low cost. AOC costs for GA are just crazy.

so i guess this is dead in the water?

Yep, the pointy headed folk in Canberra would have seen to that. They flew this like a kite, knowing "the industry" would advise them it's all too dangerous. A bit like flying instructors having to work under an AOC. ICAO only require an AOC type structure for integrated pilot training courses and multi-crew training activities.

In my own experience, I can name a few larger operators whom would be very threatened by this occurring, whilst they don't necessarily take the majority of their money from Scenic Flights it keeps them afloat and increased competition from competitors that have entered the market with a much lower operating cost is certainly going to hurt them.

That being said, those same operators also use slightly larger Aircraft, 7 or 12 seaters for example which by their nature when full are exceptional money makers, but this would make it far more difficult for them to fill those aircraft. I think for those to work properly Aircraft need to be considered by Type, not just seats, I'd dare say a good Caravan would be far safer than a clapped out 206 or 182 and this should be about the safety of the Aircraft rather than just how many people dead from a flight CASA are willing to see in the headlines.

Personally I think this has great potential for more operators to get up and running, to increase the number of GA Aircraft in the air and the potential for newcomers to get some experience and start their careers. But perhaps we should be looking at the Aircraft being used, perhaps limiting the Age and Types of Aircraft in an attempt to encourage operators to be using better quality, this would bring up their initial costs due to Aircraft Purchase Price but their overall costs would be lower making it easier and perhaps balance out whilst creating a good safety standard and preventing just anyone would getting in?

Perhaps we need a new regulation:I'm sure there will be no end of suggestions as to what the criteria should be.

Maybe we need a "Clap Inspector" Lead Balloon, a person whose job it is to apply common sense and decide when something is "Clapped Out" :D

Bit different to the usual "Clap Inspections" some of us undergo...

Ah good ol' "common sense".

If everyone had the same "common sense", why would these "clapped out" aircraft be flying?

I thought that only happened in the military and then many years ago? ;)

Whats the obsession with the age of aircrafts? When was the last time a piper or cessna disintergrated in mid air due to metal fatigue? Pilots have proven to be more than capable of crashing brand new state of the art jetliners vs. a 40yo cessnas

Scenic flights NPRM
 

Not Dead...yet.
I inquired about it last year and was told that it was bottom of the list of competing projects for its team lead. Anyone who would like to see it moved higher up the list email the project team lead:
[email protected]

The squeaky wheel gets the oil....even in CASA

That's right: Waste your energy writing to the latest Pollyanna pretending it's all going to happen. Soon.

You CASA folk stand out like the proverbials, P.

If you don't like what I wrote then why don't you provide a constructive answer? Or you could instead waste your energy moaning on internet forums about how the industry is dying and CASA never do what you want.

By writing to "Pollyanna's" I have: had a hand in overturning a proposed AD, helped several operators achieve CASA certification and found solutions which allow existing operators to be more profitable - in the last 12 months.What have you achieved LB?

Those who know me can attest to the fact that I DO NOT WORK FOR CASA
and HAVE NOT EVER WORKED FOR CASA.

If you think that writing to CASA makes thing one of difference in the regulatory reform program, other than to make it more complicated and costly, good luck to you. You obviously don't subscribe to the orthodox definition of "insanity".

Good work on the prop AD. You weren't alone. That work hopefully gave you an insight into the lack of intellectual rigour, risk analysis, failure data and time in service data analysis and cost/benefit analysis that goes into CASA-initiated "safety" requirements.

I've made many submissions and assisted others to do the same in relation to aviation regulation. Just not to CASA. It's pointless. CASA's a self-licking ice cream.

I apologise for accusing you of working for CASA. It is a serious slur on your character if untrue.

RE invigorate GEneral Aviation
 

Here’s a plan.

1. Get this simplified scenic flights model up and flying. (And get rid of that RAA scenic flights mascarading as trial instructional flights nonsense. ). AOC costs and time demands is a huge roadblock to small business startups.

2. Get instructors untied from AOC requirements.

3. Give RAA simple low cost opportunities to be trained up for Controlled Airspace.