CASR Part 61 cost of compliance understated?
 

Having just re-read the Regulation Impact Statement (RIS) it seems either industry or CASA has got it all wrong. According to the RIS the additional cost of gaining an ATPL was to be under $10K and Type Endorsements versus Type Ratings - no additional cost - merely an administrative change.! I wonder if the RIS was considered by the authors of the various MOS and the Flight Examiner's Handbook - if not why not? What's the point of creating a RIS, then ignoring it?
http://www.comlaw.gov.au/Details/F2013L00218/6b3523f0-4a46-4cd9-a6b9-358947eec395

Most likely the RIS is a fiction. CASA has a track record of this. Note no individual names are linked to a RIS.

And $10k is a substantial amount. Was there any extra safety claimed from this change?

CASR Part 61 cost of compliance understated?
 

I agree, $10K for no stated or demonstrated safety benefit is totally unacceptable to any industry, let alone one on its knees. I went in search of the Part 61 etc RIS after reading your post regarding ADS-B. Surely there must be some accountability for these documents of fiction? Are the authors of the various regulations required to bear in mind the content of the RIS?

Folks,

The bigger problem with Part 61/141/142 is complying at all, at any cost, and the ongoing costs of keeping licenses current under the "new system" is horrifying.

CASA must be forced to comply with its own manuals and mandatory Government policy, including genuine cost/benefit analysis at the beginning -- and this need amendment to S.9A of the Civil Aviation Act 1988 to make it really stick. By the time you get to a RIS it is too late.

Tootle pip!!

Dick,
ever noticed that just when "rational" debate starts to develop, just as in your skidmore thread "certain" people turn up and the thread is locked.
Maybe you should have a cup of tea with our Aunty Pru, she rather likes rational debate.

Mr Skidmore Letter on Part 61 - Don’t Mention the Cost!
 

I and many others have received a letter entitled, “Update on New Flight Crew Licensing Regulations” from the Director of Aviation Safety, Mark Skidmore AM, in relation to Part 61.

Twice Mr Skidmore asks for feedback in relation to “what is working well and what is not”, however at no stage does Mr Skidmore mention that they are looking for comments on whether costs have increased because of Part 61. It’s almost as if the code within CASA says, “whatever you do, don’t mention cost”.

In his letter Mr Skidmore says, “I want open and honest feedback on what is working and what is not” - once again, no mention of cost. Presumably Mr Skidmore and the “Iron Circle” don’t want any comments on cost even though cost is the main problem with Part 61. That is, a substantial increase in costs when there was no safety issue to be addressed.

In Australia we share the wealth a lot better than most countries which means our average wage and our minimum wage are far higher, especially compared with places like the USA, Canada, the UK and New Zealand. For us to be able to compete in the international marketplace it means we have to be very much smarter and do things very much more efficiently.

Part 61 is, in fact, the opposite. It has substantially increased costs to many people in the industry and this means they will be less competitive in their businesses.

More to the point, money will be shifted from real safety issues to the Part 61 compliance costs when safety was not an issue.

I don't see any safety benefit whatsoever! So what is the justification?
Why is it such a large document, compared with other countries such as NZ?
Written by the lawyers no doubt?

What was the problem it is trying to fix???:ugh:

As with most things political. 10 minutes to make the change and a life time to understand what the change will do. The engineering licence system is now in complete disarray and know one knows where it's headed. A complete disgrace.

Let's not miss the opportunity. Clearly CASA can now appreciate that Part 61 is lacking in many sections. This is industrys' chance for 'consultation' from a better bargaining position.

I've wasted no time in submitting a proposal to scrap the 'rating' out of Low Level Rating, and suggested a suite of associated changes which would improve safety.

happy days,

Not just costs, but to comply with a set of rules, first one needs to comprehend those rules.
I recall attending a CASA briefing for testing officers in which we were told that instrument proficiency tests on aircraft over 5700 kg were type specific, ie an IPC issued for one type did not entitle the pilot to fly IFR on another type. Now I am told that is not so.
All that is required is that a Flight Review is completed every two years on whichever type I wish to fly, plus to fly IFR, an annual IPC on one of the types. So...I have a need to fly three types in a non airline environment. That is one IPC a year on any of them, and a review on each of them every two years. Or is it? My brain hurts trying to work out whether I would be setting myself up for prosecution.

When CASA officers don't know themselves, what hope have the rest of us?

Then the issue of examiner liability, now that we are no longer Delegates. Recently I had a very unpleasant encounter with a lesser official in CASA because he interpreted a rule differently to the way I did. He was half right, but a good lawyer would have equally said that I was too. I may have only avoided prosecution because at the time I was actually representing CASA, which is what a Delegate does. Under the new system, an Examiner enjoys no such protection.

This recent nastiness gives me good enough reason alone to drop out of the whole examiner scene (to cheering from some, no doubt). But I know others in the same mind, and they will be a loss to the industry. Perhaps industry should jack up and leave it to CASA to provide all testing. On second thoughts, maybe that's what they really want. To completely cripple aviation so that they can all collect their redundancy packages.

In the USA the instrument rating is forever and requires no renewal. A pilot just has to comply with the recency requirements .

Yes. A BFR is required every two years but no instrument flight is required during the review.

Should we all move our aircraft to the U.S. register?

The Trans Tasman Mutual Agreement should make NZ a closer link to US type rules and an FAA pilot certificate.


My next jet will be registered in NZ. I may not have one yet but I'm trying.

Hi Dick, sent you a PM about costs affecting me. If you could get a chance to check it it out. Thanks.

Runaway Gun send your email regarding cost impacts to:
[email protected]

Quote from Mr Skidmore's letter (bottom para on page 1):
"...I need your feedback. While consultation takes place as rules are being developed, inevitably there are issues or unintended consequences that need to be addressed." (my bolding).

I would say that significant cost impacts could definitely be classified as an 'unintended consequence' that 'needs to be addressed.'

Of course how interested they might be in addressing that unintended consequence remains to be seen but if enough people submit feedback on that point you never know... 'The squeaky door gets the oil' - one can only hope...!

The best part is one has to re-do IREX theory should it go lapsed. :D

Seriously, why didn't they just do a copy-and-paste of U.S FAR Part 61? :E

Indonesia literally copied and pasted it and it works fine. :}

I just completed an IPC to revalidate my Instrument Rating under Part 61!

Cost wise - about the same as previously doing a renewal of my CIR.

Dr :8

Forkie, I Dunno if you only fly privately, but guess that you do. A basic IPC is materially the same as the old CIR so quite rightly should not cost more....yet.
But consider the flight school that delivers the IPC. If they have instructors with multiple approvals, they have many more checks to complete. Not good enough that someone from CASA would come in and check various skills on a cyclical basis - ALL must be checked at whatever the stipulated frequency is. So stand by for your costs to increase when these imposts get passed on.
And pity the poor charter operator who wants a pilot to fly, for example, a King Air 200, a King Air 350 and a Baron. It would be nice to think that the 350 would cover the others, or that the 200 is close enough to a 350 that it doesn't matter and if you can fly a King Air you can probably cope with a Baron - but according to Part 61, it ain't necessarily so.
Yet the same set of rules means a pilot can do a tailwheel endorsement in a Piper Cub, followed the next day with an initial multi in a Duchess and then leap straight in to a Beech 18. Do not try this at home.

I refer to the Director of Aviation Safety’s letter dated 30 April 2015, inviting feedback on the new flight crew licensing suite of regulations.

As a preliminary point I note that the many stated aims of the new regulations have, over the years, included:
- “safety through simplicity”
- “harmonisation”
- “a less prescriptive, outcomes-based safety regime”, and
- “no exemptions” (because they would no longer be necessary in a simple, harmonised, outcomes-based safety regime).

The new regulations achieve none of those aims. In fact, they achieve the opposite.

The Dreamliner was promised but the Spruce Goose has been delivered. The people who paid and waited for the Dreamliner are now not only stuck with the Spruce Goose, but are expected to take seriously the suggestion that this monstrosity can be “continuously improved” into an even better Dreamliner, this side of hell freezing over.

I invite CASA to identify one provision of the new flight crew licensing regulations that has demonstrably caused an improvement in safety compared with the pre-existing regulations, at no cost or at a cost commensurate with the improvement.

I note that a person required to keep a personal logbook commits a criminal offence if the person does not retain the logbook, unaltered, for seven years after the last entry was made in the logbook: CASR 61.355. I invite CASA to describe one realistic scenario in which the throwing of a pilot’s logbook into the bin, 6 or so years after the pilot’s last flight as crew, would cause any material safety risk. Just one realistic scenario. (Hell, even an unrealistic scenario might shed some light on what’s going on in the head of whoever decided that making this a crime would contribute to safety.)

I note the exquisite genius of the confusion created by the convoluted complexity of the meaning of “flight time” in Part 61 of CASR compared with the definition of “flight time” in the 1988 Regulations. In the 1988 regulations, the duration of a flight starts when an aircraft first moves under its own power for the purpose of taking off. That definition in itself causes some chronically-unresolved issues. E.g. the PIC can’t give binding directions to PAX during ‘push-back’, because 309A is linked to the definition of ‘flight time’ in the 1988 regulations.

But now we also have Part 61, in which the duration of a flight starts from the moment an aircraft begins moving, whether or not under its own power, in preparation for flight. Does that mean I log PIC time from the moment I tow my aircraft out of the hangar in preparation for flight? If so, I’ve just increased my aeronautical experience by about 25%, by all the hangar door closing, head scratching, nervous weeing and paperwork I do before turning the key. Am I therefore 25% safer?

Of course, it’s not possible to understand what all of the new regulations mean, without knowing about and understanding the effect of the myriad of exemptions that may variously negate, alter or extend the effect of the regulations. Given that I realised, about 10 years ago, that almost nothing in the ever-growing piles of regulations and manuals and exemptions made much practical difference to the safe conduct of flying activities, I doubt whether I’ll ever be inclined to gain that understanding, or that my safety will be compromised by not doing so.

Importantly, I realise that many in CASA are among us poor passengers stuck on the Spruce Goose. Although lots of people blame CASA for the design of the Spruce Goose, I realise that CASA has neither the resources nor the competence to design a safety regulatory regime and, to the limited extent that CASA has come up with good design ideas, changes have often been dictated by people outside CASA - the government equivalent of the marketing gurus and the bean counters and the legal department, all of whom have irreconcilable demands and won’t be on the test flight.

But problems are difficult to solve unless there’s an understanding and genuine acknowledgement of the real extent of the problem.

The problem here is that the new regulations are a monstrosity, and no amount of continuous improvement is going to change that.

CASA needs to genuinely acknowledge and confront that problem, or it will continue to be part of and blamed for it.

No it isn't! All silliness aside, if it asks about what's working and what's not, that could quite easily include whether the cost effectiveness of it is working or not.

Honestly, Dick, you are a bigger master of spin than Warney, or at least you use it a hell of a lot!

Yes Mach E. I do only fly privately these days but I was only giving my experience of Part 61. From my perspective, I can't see any real issues with it, but I gotta ask why the change? What was the problem with the "old" way?

I have always flown my renewals in the aeroplane and a typical flight was and RNAV appr, and ILS and an NDB appr (if I wanted the latter - which I never use anyway).

Under Part 61 I need to fly a 3D appr, a 2D appr and ensure I have covered a CDI indicator and an azimuth indicator in those if I want to use them.

Am I a better pilot because of Part 61 - No!

Am I a safer pilot because of Part 61 - No!

Not that I can see anyway - but hey, I know I only operate near the bottom of the piloting dung heap!

Dr :8

PS:....and if someone knows the implication of Part 61 on PIFR privilages - please enlighten me cause I haven't figured that out yet!

Below is a link to the document CASA used to get the Flight Crew Licencing rule changes through parliament. Read it and see if what we are paying now comes near what was forecast...
Start with an ATPL flight test - quoted as 2 hours @ $800 / hour.

http://www.comlaw.gov.au/Details/F20...9-358947eec395

Creamie, (POTY material by the way :ok:) as you well know, the problems lay in one particular area more than most. This also affects the standards folks and so on. the rot is uncontrolled.

I spent the day with a recent retiree of senior (very) ranks and even he describes JMAC's frustrations with the poor delivery of proper outcomes of the very department he was supposed to be running. I learned a few things that suggested he may well have been yet another victim of a systemic problem.

We all know where those problems breed……..like an infectious disease. A bit like Ebola for GA.

Can ANYONE in Australia do the ATPL flight test? Or do I have to go to the USA to get an Australian ATPL?

DB

Finally.............yr right is getting his 9 year old child to type his post! Only two errors! :D

There have been significant changes in the FAA ATPL. Much more expensive but the requirements are clearly defined and there are courses that seem sensible. But I think you may be talking about anyone in Australua being able to conduct the test?

Correct. Is there a Part 142 school and a Flight Examiner that can conduct the ATPL test in Australia. I want my ATPL!

D. Bits,
Have you done your CASA approved Multi-Crew Cooperation Course (or whatever it is called), if the answer is yes, where did you find it?? A lot of people would like to know.
If not, the current apparent 100% lack of anybody to do an ATPL flight is not a problem.
Tootle pip!!

Porter...didnt your Grandmother ever tell you...

Never denigrate or criticise those whose language and spelling is not as perfect like your own.
They may have a disability or may not have been as fortunate to have the same education as your (brilliant) self.

aroa, my grandmother died before she could teach me that lesson, (the other one was a drunk & didn't teach me anything).

And I wasn't denigrating him, I'm celebrating being able to understand his post.

I wouldn't call my education brilliant so I can't claim brilliance, I do however read a lot and try my best to continue my education, don't want to end up with Alzheimer's.

Looks like you have a secret admirer Creampuff. Apparently, those so outraged by their treatment on Pprune, keep coming back for a look because they are bored with the sound of their own typewriter. I bit like the silly old people who are so outraged by Alan Jones that they have to keep turning the radio off.

Maybe Kharryon will dedicate one of his stupid shantys to you. Anyway thought you might like a laugh.:p

I was thinking a number of different ways to obtain CASA ATPL and this seems to be the easiest way and the most cost effective way as well.

For those holding CASA CPL and 1500 hours total time:
1) Go to U.S, pass FAA IR written, get FAA ATPL concurrently with a a type rating such as B737CL or A320. This will get you a FAA ATP with instrument rating.

2) Go to NZ, pass NZ IR written and NZ ATPL written tests. Rent a Air NZ sim (B737 or A320) and get your ATPL checkride done. AFAIK, instrument checkride and ATPL checkride can be done concurrently.

3) After you obtain NZ ATPL, convert it to CASA ATPL by just paying a small fee.

For those holding ICAO ATPL and working as a F/O in overseas: (This is what I'm working on)
1) Get 1000 hours SIC time (post-ATPL issuing date) on ATPL issuing state reg aircrafts.

2) Go to NZ and get a ATPL checkride after passing NZ ATPL Air Law.

3) After you obtain NZ ATPL, convert it to CASA ATPL by just paying a small fee.

And every single one of those options costing WAAAYYY more than:

Especially after one factors in travel costs...

The cheapest of the options you have presented is for those working overseas as FO and who already hold an ICAO ATPL...

Besides, what kind of a country is it turning us into when we have to go offshore to gain a qualification...?!!

Glad this doesn't affect me but I feel sorry for anyone without a pre-Part 61 issued ATPL these days...

@Captain Nomad

I beg to differ. And realistically no one will be able to get sim rental cost less than 800 bucks an hour in Australia. One can also bypass this stupid MCC CASA is introducing.

MECIR training done on a piston twin engine aircraft is more expensive than getting a FAA ATP. That's why I said the first option is for those without MECIR. But granted, one might have to do multi-engine rating and instrument rating done in U.S prior to getting onto a sim. But still hell a lot cheaper. But for those doing his/her training through VET FEE-HELP, it ain't working for them.

B737CL type rating costs only around $8K in Miami. Last time I checked, it costs almost $20K to get MECIR in Australia. Schools charge $20K for 20 hours of flight time and 20 hours of sim time. I mean, seriously WTF?

All due respect, as of now, airlines in Australia should drop "ATPL" as a pre-requisite for FO jobs. They should drop the minimum to CASA CPL + MECIR + ATPL theories + MCC (preferably not) so that type rating checkride is to be done concurrently as ATPL checkride. This has been the norm in the states and it is fair for everybody.

What is the problem this crap reg is meant to fix ????:ugh::ugh:

What and where are the SAFETY benefits??

Where is the cost/benefit analysis ??

The easiest way for CASA to fix this mess is to bin it and start again, using input from industry.

Arm out the Window - the point I am trying to make is that anything CASA sends out at the present time should be linked to what is the industry’s major concern and that is a one-way ratchet in the increase of costly regulations for aviation - especially when there is no safety reason for this one-way increase in cost.

Haven’t you noticed that Mr Skidmore is not game to actually mention this important fact? Why wouldn’t his letter say, “many in the industry appear to be concerned that Part 61 has increased costs when they were told this would not be the case. If you have any evidence of costs being increased, please advise.” Now that would be worthwhile! But it’s interesting, he doesn’t actually say this. Nor does anyone else within the “group think Iron Ring” actually get on top of this most important issue.

Then again, there is nothing with the Civil Aviation Act that says they have to look at cost, so I suppose they won’t.

Leadie the MCC seems to be problem #1. No one can do that either!

Looks like I'm heading to the USA to do their ATP CTP, then the Written Exam, then the flight test which is a 2 crew IF initial really! (In a Duchess if I want to!)

This is crazy!

You would have to be thick not to understand that you could include that in the feedback...IMHO. Of course it is a great excuse for another whine.
A few threads could be merged here I reckon.
PS not defending part 61, how could you...but I think we all get it.

I walked into a Government Office
 

I had to go into the Regulators office the other day. I had some licencing and transfer documentation I had to attend to.

I was greeted at the front and directed to my appointment exactly on time. The place had a bit of a buzz about it. Much like you might find in Private Enterprise. The forms were all so easy to fill out. I had a couple of potentially difficult questions. The two staff at the counter were obviously very knowledgeable about the rules and regulations and addressed them succinctly. Very obliging as well. The whole well informed, clearly understood requirements made such a good impression on me. As I exited the building after my seamless experience somewhat ahead of schedule, I turned and went back in side. It was quicker, less painful than I anticipated, and somewhat cheaper than I feared. I thought I must pass on my sincere appreciation. I go in there regularly, and it always operates in such a manner. The staff were very happy to receive my positive feedback. In fact they had the Area Manager in the building and I got the opportunity to thank him, and in fact I followed the whole process up with a letter. How could they all be so happy and efficient. Constantly dealing with licences, safety, rules, regulations, maintenance etc. Yuck!

Anyway I am so sorry to tie up an Aviation forum but I just wanted to pass on my congratulations, thanks and sincere respect to VICROADS. Cheers

like all of us in aviation I started out responding to the NPRM's and found consistently that all suggestions were ignored totally and CAsA just went along doing whatever they wanted.

so about 10 years or so ago I decided to totally ignore all suggestions demands and legislation coming out of CAsA.
I have in the last decade or so done all the maintenance on my own aircraft and gone out and flown regularly.
I have totally ignored all CAsA requirements.

was I unsafe? never.
my aircraft is now a vintage homebuilt, it first flew in 1985, it is in better condition now than when I first flew it.
it cruises 15 knots faster. the engine runs absolutely to the numbers and I no longer pollute the air with lead residues.

When I got Skidmore's letter I was tempted to give an honest response.
Why bother?
The system for the past 15 years has been going so far off the rails that it is pointless even bothering to comment.
as just one example the much vaunted biennial flight review has now caused 6 deaths that I would wager would not have occurred otherwise.

The CAsA system is totally fcuked.

The things that really would improve safety haven't a hope of being introduced by these clueless incompetents.
They are so engrossed by their ex RAAF memories that they will never listen to common sense.
So we are stuck with their system if we care to be legal and it doesn't work.
All CAsA ordained maintenance ever does is see to a slow inexorable decline in the airworthiness of aircraft maintained under the system.

In terms of flying competence the new approach is one of fear uncertainty and doubt where before a pilot used to develop a sense of mastery of the challenges and some competent risk evaluation skills.

Sorry Skidmore but the best thing you could do with CAsA is shut it down completely. it does not create a safe environment and it does not engender competence.

Fair enough, Dick, I understand one of your common modes of operating is to generate outcry and discussion to stir up a bit of reaction which is better than apathy, I just can't help reacting to the overt spin you use to do it! It's how the world works in these days of the sound bite and media grab, so fair play to you if you get what you set out to get.

Still, the letter from Skidmore basically says 'if there's anything you think is wrong with what the new regs, tell us', which to me clearly doesn't need a specific mention of the cost factor. If he said in Colonel Klink style 'Dooooon't mention ze cost!' then that would be a different story!