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-   The Pacific: General Aviation & Questions (https://www.pprune.org/pacific-general-aviation-questions-91/)
-   -   Community service flights new rules (https://www.pprune.org/pacific-general-aviation-questions/616467-community-service-flights-new-rules.html)

Sunfish 1st Jan 2019 09:17

I am sympathetic to CASA’s position. The lack of payment is not the issue. An Angel Flight pilot is effectively “standing in the marketplace” - available to those who ask for assistance. The moral imperative to assist those in need may overcome the usual prudence and lead to suboptimal personal decisions. Some guidance would be useful.

Old Akro 1st Jan 2019 09:57


The moral imperative to assist those in need may overcome the usual prudence and lead to suboptimal personal decisions.
I have flown a reasonable number of Angel Flights. I memory serves I've cancelled 2 due to weather and one due to aircraft technical issues. I completely disagree with your premise.

aroa 1st Jan 2019 21:23

Sunny...'lack of payment not the issue.
If it was , for CAsA all hell would break loose, 'commerce commerce ' the sky is falling..CPL and AOC needed..(more work for us)..and that would get rid of all pvt players.
Their ,brain snap approach, re engine hours has sfa to do with the decision making processes used by pilots once they are off the ground.
CAsA has this misguided fundamentalist zeal that they can prevent any aviation accident, whatever the cause. Its an impossiblity, but little GA is a very easy target, CFS flights become the 'what shall we do this week' and for CAsA ' we are they ultimate "safety" gurus' so cop this.!
Utter brilliance.!

Sunfish 1st Jan 2019 21:24

Old Akro, who isn’t moved by the sight of a sick and needy child? That natural reaction may possibly overcome ones normal caution and perhaps launch when your instincts might be to wait. Our natural charity could be our undoing.

I have, in my own stupidity, turned out in a fire tanker with a driver who had maybe had one beer too many, such is our natural desire to help unfortunates. - I transgressed the first rule about helping anyone. Angel Flight pilots run that same risk.

Lead Balloon 1st Jan 2019 21:51

Assuming you’re correct, Sunfish, the question is: So what? To put that another way, on the basis of what data are you saying that the increased risk in the circumstances you describe is “unacceptable”?

Not all risk taking ends in disaster. Some disasters are the inevitable consequence of living in a world that will never be risk-free and enjoys a net benefit from risk taking.

I thought you were a guru on risk analysis and cost/benefit analysis?

Sunfish 1st Jan 2019 23:07

i’m not saying that the risk is unacceptable or CASAs prescription is correct. What i am saying is that the risk is potentially different from your run of the mill family jolly ride.

We are all familiar with the dangers of “get thereitis “ which has killed many..

’What I am saying is there is a condition called “get poor deserving kid to hospital-itis “ that may turn out just as badly if it is not managed in some way.

machtuk 2nd Jan 2019 00:02

'Sunny' I happen to agree with you. It's fine for others not to, they have their agenda as we do. CASA are approaching this all wrong, maint isn't the part that is where the risk lies but CASA only tie up safety with risk mechanically in most cases. I've said it before I don't believe these flights ought to be allowed despite all the good intentions, but that's just me. my opinion.

Sunfish 2nd Jan 2019 00:15

Perhaps if there was a cost free road option available then the pressure might be less.

Clinton McKenzie 2nd Jan 2019 02:53

But would the road option be risk free? No. I regularly see Angel Flight tasks from places like Hay and Warren to YSBK. Ever heard of the road toll, especially on country roads?

Would the road option be time free? No. Do the calcs on the delta between the flight time and the drive time from places like Hay and Warren to YSBK. Even economically poor people can be time poor. Some are working a number of jobs to survive.

Would the road option be get-there-itis free? No. I reckon the fatigue risk would be higher than the flight option.

I don't mind if 'private' CSF's are 'banned', provided there is reliable data and analysis to show that the benefits of the ban would outweigh the costs. Where is the reliable data and analysis to show the benefits of CSFs at the current 'standard'?

If 'private' CSF's are 'banned', and there's a fatality during a 'higher standard' CSF, what then? Another kneejerk increase in standards? Deaths occur during charter flights.

Might as well get it over and done with and jump straight to the inevitable: CSFs banned except in transport category aircraft to and from aerodromes with a CATIIIC ILS.

Sunfish 2nd Jan 2019 21:35

Well said Cleared. I am not arguing about CASAs response. i am simply saying that the emotional imperative behind CSFs are different from purely private operations and the associated risks have to be managed and according to you, Angel Flight is aware of this and has procedures in place.

To put it another way, the argument that no money changes hands so the operation is identical to taking your kids for the proverbial $100 hamburger lunch doesn’t wash.

I agree with you that CASAs response - the engine strictures, is pointlesss and destructive. It could be said that the CASA response is perhaps as emotionally loaded as my example pilot. Everyone, including CASA, wants to help the unfortunate. It’s just for a well meaning CASA , the answer to all problems is more regulation.

Clintons argument about road risks is also correct. Being cynical again, it could be said that the lawyers in CASA couldn’t care less about Angel Flight customers, just so long as they don’t get killed in an air crash. If they die on the roads that’s not CASAs problem.

Dexta 2nd Jan 2019 22:09

Sunfish

’What I am saying is there is a condition called “get poor deserving kid to hospital-itis “
Clearedtoreenter

Perhaps some pilots are afflicted by ‘get thereitis’ or ‘watch this’ syndrome.
Sunfish

i am simply saying that the emotional imperative behind CSFs are different from purely private operations
During this holiday season I have seen a few pilots taking to the air with family and friends in less than ideal situations (not unsafe, just not ideal) because that is the only time they can do it, or it was a promised Christmas present, etc. etc. I would say there is some form of pressure in nearly every flight we do (its a beautiful day and the weather for next week is rubbish, I should go for a fly today). Part of the training and ongoing responsibility of being a pilot (Recreational, GA, ATP, etc.) is to recognise and manage pressure. How a person perceives or even creates pressure for themselves and the way they handle that pressure can be a real problem with private flying. One person can be fine the other stressed, one prepared the other unprepared. Whether it is a CSF or a family trip, or even a solo jaunt around the block the mental attitude and preparedness for the flight, if lacking, can lead to accidents.
Since our society seems hell bent on controlling everything we do through regulation and safety initiatives here are a few suggestions...
1. A psychological test must be conducted and submitted to CASA before each flight. (OzRunways could build this into their program)
2. A certificate from a certified psychologist or psychiatrist before commencing flight operations.
3. A Cortisone sensor linked directly to the aircraft master switch, like a breathalyser switch but for stress.
4. Take responsibility for your own actions and state of mind, act in a professional and rational manner, seek additional training, use a support network of other experienced people if in doubt and do not take unnecessary risks.

I wonder which one CASA will choose?

thunderbird five 2nd Jan 2019 22:21

All 7. (you probably missed a few).

thorn bird 2nd Jan 2019 23:16

I am currently preparing a one thousand page operations Manual, a safety management Manual, a quality assurance Manual,
a check & training Manual, Maintenance Manual, ongoing maintenance assurance manual, A CRM Manual, a TEM manual and a detailed FCOM.
This is to support an application for an AOC. I will be employing the 20 or so non technical staff necessary to ensure compliance.
I am hopeful my AOC will be granted within CAsA's ten year estimate for completion so I can be legally approved to hide under my bed.
WE are doomed!!

AngelFlightCEO 3rd Jan 2019 01:16

Introduction of proposed safety standard - community service flights
 
Below is a submission from one of our experienced RPT and private owner pilots: sums it up nicely.

Introduction of proposed safety standard - community service flights

The proposal introduces minimum CSF pilot experience, licensing and medical requirements, requirement of flights at night to be conducted using instrument procedures instead of visual procedures and requires slightly enhanced aircraft maintenance requirements, in line with other operations within Australia involving similar participants.

Please provide feedback below. You may enter as little or as much information as you wish.: Proposed safety standard - Community service flights (CD 1814OS)

The suggestion that CSF passengers are uninformed or even less informed than other private flight/ GA charter passengers is absurd. By the time CSF passengers board an aircraft they have been provided with written information and adequate time to make an informed decision on whether to travel by air or alternative means. This information is provided by the CSF provider & then verbally by the PIC. If a CSF passenger is still ‘uninformed’, it is by choice.

Proposed recency requirement- one landing in the type or class in the last 30 days. I only need 1 landing in the last 45 days to operate a widebody aircraft for an Australian HC AOC holder. The 10 widebody (type) landings I may have conducted in the last 30 days will apparently not count for recency for a CSF in my GA single engine aircraft.

The operational environment for a CSF pilot is benign in comparison to that of a working CPL holder. No employment threats, serviceable & familiar aircraft, the ability to cancel a flight without consequence, flights planned well in advance & no remote areas. To suggest that the experience requirements to operate a CSF flight should be higher than those required for a commercial operation is thus nonsensical.

The proposed requirement for piston engines to meet AD/Eng/4 requirement 2 (calendar life) defies logic. My piston engine is electronically data monitored, is checked & oil changed by a licensed engineer every 4 months, undergoes laboratory oil analysis 3 times/ year & is borescoped & compression checked every 12

months. To suggest that overhauling the engine simply to meet a calendar requirement defies logic. It merely puts the engine back into the high risk zone for catastrophic failure.

The CSF with which I am familiar has operated nearly 23,000 flights & suffered 2 accidents in 15 years. A sensible approach to improving safety would be to examine what the 22,998 flights have been doing successfully rather than impose a grab bag of untried limitations.

The proposed changes as documented conflict with the CASA fairness values. Decisions are to be risk based & evidence driven, both of which are absent from CD1814OS.

Marjorie Pagani
Chief Executive Officer
Angel Flight Australia

LeadSled 3rd Jan 2019 11:23

Marjorie,
Time for a major petition, with plenty of publicity, on something like Change.org.
AOPA should be able to arrange an email out to every Federal and State politician with multiple shots to very news outlet.
CASA do not like lots of very public attention.
Tootle pip!!

AngelFlightCEO 3rd Jan 2019 20:58

Thanks Leddie. Ben at AOPA has been very helpful. But I think the real focus is on how they are attempting to bypass proper democratic and legislative processes ( quite apart from lack of consultation with AF and industry). To take away rights or impose restrictions on licence holders, with the stroke of the CEO’s pen, is dictatorial and an abuse of process. Our licences and maintenance requirements are governed by the Regs: any amendment should be by proper Regulatory change . By ambushing us all on the eve of long holidays , and by proposing an administrative direction, ensures no ‘interference’ by our elected representatives in parliament. Parliamentary members can disallow Regs - they cannot disallow a direction, and nor does it have to be presented to either House. The implications of this high-handed and undemocratic action, if allowed to proceed, sets a dangerous precedent which could see all or any of our aviation rights cancelled at the whim of CASA, and not the legislature.

Contacting State and Federal members to alert them to this proposed action would be helpful, particularly the attempt to block them from having a say in this process, which fundamentally alters the rights of licence holders and aircraft owners/operators.

Clinton McKenzie 3rd Jan 2019 21:01


The suggestion that CSF passengers are uninformed or even less informed than other private flight/ GA charter passengers is absurd. By the time CSF passengers board an aircraft they have been provided with written information and adequate time to make an informed decision on whether to travel by air or alternative means. This information is provided by the CSF provider & then verbally by the PIC. If a CSF passenger is still ‘uninformed’, it is by choice.

Proposed recency requirement- one landing in the type or class in the last 30 days. I only need 1 landing in the last 45 days to operate a widebody aircraft for an Australian HC AOC holder. The 10 widebody (type) landings I may have conducted in the last 30 days will apparently not count for recency for a CSF in my GA single engine aircraft.

The operational environment for a CSF pilot is benign in comparison to that of a working CPL holder. No employment threats, serviceable & familiar aircraft, the ability to cancel a flight without consequence, flights planned well in advance & no remote areas. To suggest that the experience requirements to operate a CSF flight should be higher than those required for a commercial operation is thus nonsensical.

The proposed requirement for piston engines to meet AD/Eng/4 requirement 2 (calendar life) defies logic. My piston engine is electronically data monitored, is checked & oil changed by a licensed engineer every 4 months, undergoes laboratory oil analysis 3 times/ year & is borescoped & compression checked every 12 months. To suggest that overhauling the engine simply to meet a calendar requirement defies logic. It merely puts the engine back into the high risk zone for catastrophic failure.

The CSF with which I am familiar has operated nearly 23,000 flights & suffered 2 accidents in 15 years. A sensible approach to improving safety would be to examine what the 22,998 flights have been doing successfully rather than impose a grab bag of untried limitations.

The proposed changes as documented conflict with the CASA fairness values. Decisions are to be risk based & evidence driven, both of which are absent from CD1814OS.
Well said.

The terms “absurd”, “nonsensical” and “defies logic” are justified in the circumstances.

Eddie Dean 4th Jan 2019 05:58

Could be the thin edge of the wedge as we head toward no on condition at all.
Most of the comments here would support that

kaz3g 4th Jan 2019 07:23

Does this affect Fun Flight too?

kaz

LeadSled 5th Jan 2019 08:18


Originally Posted by AngelFlightCEO (Post 10351035)
Thanks Leddie. Ben at AOPA has been very helpful. But I think the real focus is on how they are attempting to bypass proper democratic and legislative processes ( quite apart from lack of consultation with AF and industry). To take away rights or impose restrictions on licence holders, with the stroke of the CEO’s pen, is dictatorial and an abuse of process. Our licences and maintenance requirements are governed by the Regs: any amendment should be by proper Regulatory change . By ambushing us all on the eve of long holidays , and by proposing an administrative direction, ensures no ‘interference’ by our elected representatives in parliament. Parliamentary members can disallow Regs - they cannot disallow a direction, and nor does it have to be presented to either House. The implications of this high-handed and undemocratic action, if allowed to proceed, sets a dangerous precedent which could see all or any of our aviation rights cancelled at the whim of CASA, and not the legislature.

Contacting State and Federal members to alert them to this proposed action would be helpful, particularly the attempt to block them from having a say in this process, which fundamentally alters the rights of licence holders and aircraft owners/operators.

Marjorie,
Inadvertently or otherwise, you have given a pretty good rundown on CASA Standard Operating Procedures.
And, as another poster has pointed out, if the pain, suffering and worse in not associated with an aeroplane, CASA is actively disinterested.
Tootle pip!!

Vag277 5th Jan 2019 09:53

Everyone seems to be missing the point that this thread staretd with a link to a set of CONSULTATION DOCUMENTS

Sunfish 5th Jan 2019 15:41

Scene: A country road in outback New South Wales, three police cars are conducting random breathalyser checks. An SUV has just been flagged down for a breath test....


Officer: “Good morning, blow into the machine till I tell you to stop”.


Driver: (Blows into machine). “Morning Officer, is the reading OK?”


Officer: “You’re fine, by the way, your kid in the back seat is not looking very well”.


Driver: “Oh that’s not my kid, that’s a neighbours kid, Timmy, I’m taking him to Sydney for his chemo treatment, poor little fella.”

8
Officer: “What? Say that again.”


Driver: “Timmy has cancer, I’m taking him to hospital for his regular chemotherapy session, happens every month. His mother doesn’t have a car and can’t get anymore time off work either.”


Officer: Don’t you understand you’re breaking the law by doing this? You can’t take a patient to hospital except in an ambulance. I don’t see any flashing lights on your car, this doesn’t look like an ambulance.”


Driver: “It isn’t an ambulance , it’s just my Toyota. Timmy is strapped into his safety seat, what more do I need? We have water and some snacks and his painkiller medication, this is going to be a five hour drive.”


Officer: “You obviously don’t understand, the law says that only an ambulance can take a patient to hospital for treatment. It’s for safety! You don’t have emergency lights, siren, a flouro vest and a uniform, your not an accredited paramedic either”.


Driver: “But Timmy’s mother isn’t a parawhatsit either, if she had a car, couldn’t she drive him to hospital? Why not me? She doesn’t have the time and she’s not a very good driver as well.


Officer: “The law is quite clear. She can take him but you can’t. Don’t you understand? What you are doing is highly dangerous without being specially trained, in an ambulance, with a safety manual to follow and a procedures manual, operations manual and a log book and a mission statement. I should warn you, the penalties for this are severe. Your car tires look a bit scuffed as well.”


Driver: “ You mean I can take Timmy and a whole car load of screaming kids to McDonalds, Dreamworld or wherever and that’s OK, but if I want to take him to hospital I can’t?”


Officer: “Precisely(smiling). I see you understand. It would be far too dangerous to make that hospital trip.”


Driver: “Well this is crazy. I can do anything I like except help people. Not only that, me and my friends have been driving poor kids to doctors and hospitals for years without any trouble, but you now tell me it’s forbidden because it’s too dangerous? What is Timmy supposed to do if I’m not here - take non existent public transport? Hitchike?


Officer: “It sounds to me like you and your friends are engaged in a criminal conspiracy! Wait till my boss hears this! I should get a promotion for shutting you down. As for Timmy, the law doesn’t care what happens to him. All we care about is safety above everything else. If Timmy can’t travel to hospital then he can’t have an accident during the trip. The logic of the law is simple and unchallengeable. Now turn around and take the kid back home!”



mostlytossas 6th Jan 2019 22:52

May I make this point quite clear about CSF flights and any perceived pressure to get the passenger requiring treatment etc to his/her appointment. There is none from the patients point of view. Out patient treatment is what we are talking about here and as such a day or two late is here nor there. I know this from personal experience having had a child with childhood cancer many years ago. Luckily for us as we lived in the country some 500km from the city where treatment was carried out, I had a pilots licence, and every month would take my child by private aircraft that I would hire from the local Aero Club or a mate with a plane and do the trip. It certainly beat driving which was 5 hr each way as apposed to a bit over an hour by aircraft. These were the days before Angel flight ever existed and to ever be taken by Air Ambulance/ Flying Doctor you had to be at deaths door. If the weather was too bad to fly we would either drive ( only if the weather was expected to hang around for days ),travel to the nearest larger centre that had an RPT service like the Ansett Fokker Friendship service etc if we had to. Usually however it was just a matter of phoning the treating Hospital explaining the situation as they knew about us country folk that flew in for appointments from the bush ( I think it used to amuse them really) and another appointment would be made. This went on for 3 years.
Only once did I ever have to declare a mercy flight when our child took suddenly sick and the local GP didn't have a clue about how to handle it and told us to get to the city quick. You see when someone is on Chemo their immune system is very low to nil. A simple case of chicken pox can and does kill. That is why we preferred not to use public transport of any kind as you don't know who you are sitting near. On that occasion I have to say Air Services were brilliant. This was in the days of full reporting. They followed us all the way and we had priority landing clearance ahead of the jets waiting to land. An airport vehicle was waiting to lead us to a parking area out of the way near a gate and a taxi was then summoned to take us to the hospital. I take my hat off to them that day.
So from someone who has lived it ,and worried about if your child will survive or not let me say this. Angel Flight or any other outfit/individual who provides this service, it is a valuable and needed service ( not essential as in the Air Ambulance) but valuable none the less, especially where infection is a risk. CASA and some on here do not have a clue , only worried about safety. It is a pity those that came up with such a proposal don't have to put their names to it rather than hide behind the public service cone of silence. What is safe about exposing someone to 100 people in a tin can with any sort of ailment? The flu is serious if on Chemo let alone any other bugs floating around. They should butt out and leave well alone.
As a final note our child did make it and 30 odd years on owes his life to technology as only a few years prior was a certain death sentence.

Lead Balloon 6th Jan 2019 23:46


Originally Posted by Vag277 (Post 10352459)
Everyone seems to be missing the point that this thread staretd with a link to a set of CONSULTATION DOCUMENTS

You seem to be missing some of the context of the “consultation”, Vag.

This is not the first time a “consultation” on this issue has occurred. This time around we get the addition of yet another bright idea: Time-based engine TBOs, despite what the data show.

The CEO of Angel Flight should not have to say this:


To take away rights or impose restrictions on licence holders, with the stroke of the CEO’s pen, is dictatorial and an abuse of process. Our licences and maintenance requirements are governed by the Regs: any amendment should be by proper Regulatory change . By ambushing us all on the eve of long holidays , and by proposing an administrative direction, ensures no ‘interference’ by our elected representatives in parliament. Parliamentary members can disallow Regs - they cannot disallow a direction, and nor does it have to be presented to either House. The implications of this high-handed and undemocratic action, if allowed to proceed, sets a dangerous precedent which could see all or any of our aviation rights cancelled at the whim of CASA, and not the legislature.
This is not evidence-based or risk-based regulation. This is not “safety through simplicity”.

The process itself is a manifestation of how busted the regulatory paradigm is. An accident or incident occurs and the regulator is “responsible” for responding to it. And what’s the only thing the regulator is ‘good’ at? Regulating. So the regulator trots out a bunch of proposals that will impose more costs, restrictions and complexity and asks: Whaddayareckon? But if the regulator actually cared and listened to what we reckon, the regulator would have listened and heeded the feedback that’s been provided for decades and wouldn’t have come up with the bunch of proposals in the first place, unsupported by any valid cost/benefit/risk data. But that doesn’t matter, because the most important and relevant data that should be essential considerations in standards setting are irrelevant externalities to the regulator.

YPJT 7th Jan 2019 01:49

Great stuff LB. May I suggest people start contacting their MPs. I have just been onto the office of the Member for Durack as I happen to personally know one of her staffers. He is also forwarding to the member for Oçonnor for me.
Time to ramp this s>>t up folks. Well articulated and strong argument on PPRUNE is great but it is not going to kill this thing. We need to get the pollies on side.

aroa 7th Jan 2019 05:37

Mta's story gives us the pub and smell tests of CSF. All positive. So CAsA ,..'butt out' and bugger off.!,

CEO Angel is on the mark. This is yet another dictitorial, undemocratic, no due process 'brain snap' so common of CAsA.
And has all the hallmarks of the underhand methods, timing, and etc.

Time for a riot at 16 Furzer St.to get the message across.

Alpha Whiskey Bravo 7th Jan 2019 22:23

I for one am glad that Angel Flight got away from calling the flights, "Missions" and had total "Missions" attributed to individual pilot's on their website. That was asking for trouble from the start. My brother does them often and will nearly always welcome new passengers with a blind person's white cane and a special "How to Fly" Checklist that he uses. Funny Bugger!

Ex FSO GRIFFO 8th Jan 2019 04:56

Hey Mr 'AWB'.....'That' must be 'confidence inspiring' …..at first glance anyway....

Re "Now turn around and take the kid back home!”
Gee Sunny, under what authority do you have to drive the kid home?
Does it matter which direction you are facing....i.e. 'to' or 'from'....

In the eyes of 'Officer Adolf', your vehicle is definitely NOT an ambulance, and therefore definitely NOT suitable for transporting the kid!
So what do you do now?
You cannot take 'the kid' either backwards or forwards.....

I guess you could either -
1 - Give him over to the 'officer' to take home.... But then, the 'officer's vehicle is NOT an 'Ambo' either!
or
2 - Tip him out onto the road, as YOU cannot transport him ANYWHERE anymore....
3 - Suggest to 'officer' Adolf that HE call out the ambos...AND he pay the bill.

Tis a 'CROCK' ain't it..??

p.s. Or, one day we wake up'...It was just a nightmare...................................

No cheers...….NOPE! NONE at ALL!!!!

Sunfish 8th Jan 2019 20:41

Ex FSO, not quite. Under the proposed rules you can take "timmy" anywhere anytime. Just as long as the flight isn't an Angel Flight.

I wrote that example as an essay in explaining the CSF predicament to ordinary Australians in terms they understand. Once it gets technical the average punter loses interest.

I'm not original either, its modelled on the timeless "bag of peanuts" accounting example.


https://www.forbes.com/sites/boblutz.../#18c92a2e69ef

Lead Balloon 10th Jan 2019 22:02


The safety benefits of the standard significantly outweigh the requirements being imposed. These actions are consistent with CASA’s regulatory philosophy where air safety is not compromised, and the proposal reflects a proportionate risk-based approach.
Just goes to show, once again, that CASA does not understand how proper standards setting is supposed to work. CASA can’t even get it’s empty rhetoric right.

The empty rhetoric should have been “outweigh the costs of the requirements being imposed”. However, because CASA doesn’t have any cost data and wouldn’t care less about it in any event, a bunch of waffle and cliches is their only option to paper over what is, in fact, a knee jerk reaction.

No precise quantification of the “benefits”. No precise quantification of what “significantly” means. No precise quantification of the costs of compliance including the costs in terms of people who may no longer have access to CSFs. No precise quantification of the risks taken into account in the claimed ‘risk-based’ approach. None of that has been spelt out because it does not exist.

Sunfish 11th Jan 2019 00:17

I live three hours drive from melbourne. My wife had breast cancer three years ago. We had two years of chemo, hospital, mastectomy, ultrasounds, radiation, blood tests, physio and reconstruction. Each trip (and there were at least 25 per year) involved a minimum of six hours driving, three days lost time and then overnight hotel accommodation. We are just now in the middle of a weeks worth of follow up consultations, fortunately OK so far.

Out of pocket costs for transportation at least $15,000 p.a., not including accomodation and meals, plus the huge opportunity costs associated with my lost time. Any cost/benefit analysis has to take such significant costs into account.

mostlytossas 24th Jan 2019 00:45

Just a note to remind ppruners time is running out to get your surveys in.
I will be telling CASA to back off. As above I have personal experience to back it up.
One of the biggest advantages of CSF (or any other private transport for that matter ) is the ability to control infection. And also the ability to divert to another airport should your passenger take ill from the effects of treatment and give them a break to recover. Even if that means an overnight stop somewhere. That is not possible on public transport of any kind.
CASA have had a brain fade with tunnel vision on this IMHO.

aroa 3rd Feb 2019 03:43

As amply demonstrated with the CSF brain fart, its way past the time that 'the mind numbing hypocrisy and incompetence of this "organisation" (sic) should be brought out in the open with a JUDICIAL INQUIRY. An RC would be better

Then the sorely put upon Industry that was GA / or whats left of it, can hang CAsA's dirty washing on the public line.

thorn bird 4th Feb 2019 05:00

"CASA chief executive Shane Carmody said they believed it was “appropriate to establish a regulatory baseline that provided clarity regarding an appropriate minimum safety standard”.

Err don't those standards already exist? Private pilots are trained, tested and licenced under regulations and standards CAsA enforces.

Is Mr Carmody trying to say they have no confidence that their regulations and standards make private flying safe? If not why not?

Maybe he should stop beating around the bush and say he believes "Private flying is Unsafe in Australia".

What other countries have specific regulations for community service flights?

A little bit of scratching around the web revealed some interesting Data.

Angel flights, or their equivalents, seem to be worldwide phenomena, more so in the USA and Canada.

I guess that would only to be expected considering their GA industries are valued and have not been regulated out of business by rapacious regulators.

The ethos in the USA and Canada being foster and promote, educate and consult backed with sensible easy to comprehend regulations, rather than the regulate and prosecute approach which applies in Australia. They’re also safer than we are!! Goodness how do they do that?

In Canada over 12,500 Angel flights are conducted every year, without incident. Considering the atrocious weather conditions they have to contend with, a remarkable achievement.

In the USA there are various charities throughout the country that conduct Angel Flight type operations,Angel Flight being by far the biggest organisation.

Angel Flight USA and its affiliates conduct over 34,000 flights every year, all over the country.

Angel Flight Australia conducts around 4000 flights per year.

Wikipedia list only six accidents worldwide since 2008 of Angel Flight aircraft, two of those in Australia.

These statistics would suggest to me that there are some fundamental flaws in CAsA's risk analysis processes, if they actually have one.

By its reaction to two accidents is CAsA admitting they have no confidence in the standards they set? perhaps its an admission their oversight of those standards is deficient? Or maybe a knee jerk reaction to two accidents which all the regulation in the world would not have prevented, but perhaps a bit of communicate, collaborate, educate not over regulate might have.

Bob Katters quote of the week

“CAsA HAS DOWNED MORE AIRCRAFT THAN THE RED BARON”

Little video for you in a country where General aviation is valued and utilised.


Old Akro 4th Feb 2019 08:50

I think either the US AOPA or one of the US Angel Flight organisations published the number of lives that have been saved by Angel Flights vs the expected fatality rate from driving to the various medical appointments.

Clinton McKenzie 4th Feb 2019 09:42

Sadly, those kinds of opportunity costs are unknown to and irrelevant externalities in decisions made by CASA. It is an example that highlights the fundamental flaw in the standards setting paradigm.

thorn bird 4th Feb 2019 10:21

A little perspective that puts the lie to Carmody's Bullsh$t.

Unfortunately, human factors in every activity that humans are involved with plays a major role in loss of life, a small but sombre reminder that aviation is not alone. Whilst it may make a few within CASA feel good that they have been seen to be doing something, or someone has paid them a great deal of money. The reality is that only through communication, collaboration and education will we come close to helping solve the issue. No measure of strict regulation and excessive rules will prevent people from making mistakes.

There have been six deaths in six years on Angel flights, that's one per year average.

LADDER DEATHS: Every year, on average, three Victorians are killed falling off ladders - and they have almost exclusively been men aged over 55 who have fallen while doing odd jobs at home, according to research by The Alfred hospital that was recently published in the Injury journal - Feb 2016

Now if CAsA was in charge of ladders they would enact regulations that would make ladders so expensive nobody could afford them.

DROWNING AT BEACHES: The newly released Royal Life Saving National Drowning Report 2017 shows 291 people died as a result of drowning in Australia in the 2016/17 financial year. This is a 3% increase on the 282 drowning deaths in 2015/16.Sep 12, 2017

Now if CAsA was in charge the regulations regarding standards for surf boards and floatation devices would make their cost unaffordable for all but the wealthy.

CONSTRUCTION WORK DEATHS: In the 14 years from 2003 to 2016, 3,414 workers lost their lives in work-related incidents. In 2016, there were 182 worker fatalities, equating to a fatality rate of 1.5 fatalities per 100,000 workers—the lowest rate since the series began in 2003 (Figure 1).Sep 20, 2018

Now if CAsA was in charge thousands more OH&S would be enacted making the cost of compliance so expensive that the building industry in Australia would collapse.

MEDICAL ERROR DEATH: Shockingly, 18,000 to 54,000 Australians are killed each year by their medical treatment —official description “iatrogenic death”. According to Medical Errors Action Group Australia.

Good grief....if CAsA were in charge there would be so many restrictions and regulations enacted that major hospitals would be shifting their surgery to overseas suppliers.

JET SKI DEATHS: Between 1st July 2000†and 31th December 2012, there were 20 deaths reported to an Australian Coroner (as identified on the NCIS database) associated with jetskis where the coronial investigation was completed.

With CAsA in charge expect a mass exodus of recreational skiing to New Zealand.

FARM DEATHS: There was a rise in the annual number of on‐farm injury deaths in 2017 compared to the previous year, according to research by the Australian Centre for Agricultural Health and Safety (University of Sydney). Overall, there were 68 deaths reported in the Australian media last year, according to centre director Dr Tony Lower. Tractors (13) and quad bikes (11) were the leading causes of death, making up over 40 per cent of the total. Tragically, 9 of the fatal cases (13 per cent) involved children aged under 15 years, with the involvement of quads accounting for one‐third (3) of these incidents.

With CAsA in charge, all farms in Australia would be in Chinese hands operating under Chinese rules. All produce would be required to be exported, then re-imported before retail sale in Australia. No real affect on cost as its pretty much what happens now.

DEATH BY FOOD POISONING: A 2005 report found that approximately 120 people die from food-borne illnesses in Australia every year. A British survey found that 82% of people, and particularly the elderly (87%), think they're unlikely to get food poisoning from food at home.

Oh my god I can't imagine what CAsA would do about this. Would eating food have to move underground?

BICYCLE DEATHS: Since the 1990s, cyclist deaths in road crashes have constituted on average between 2 and 3 per cent of the total deaths in road crashes in Australia. In the 1990s, the number of cyclist deaths ranged from 40 to 80 per year. In the 2000s so far (2000 to 2005), the range has been from 26 to 46 per year.

If CAsA was in charge they would ban cars

DANCE PARTY/MUSIC FESTIVAL DEATHS: At least nine people have died from suspected drug overdoses at Australian music festivals in the last five years, according to media reports. At least five people died while attending dance parties in 2015, with one of the deaths occuring at Defqon. A year earlier, a 19-year-old died from a suspected drug overdose at Sydney's Harbourlife music festival. Another person died at Defqon festival in 2013.

This is an Easy one. If CAsA was in charge they could enact regulations that require everyone in Australia to convert to a particular religion that bans music and dancing. Their FOI's could then be inducted as religious police to enforce regulations banning music and dancing.

DEATH BY ELECTROCUTION: Whilst an average of 20 people died each year nationally due to unintentional electrocution (between 2001 and 2008, being years where most cases have been closed), this is less than levels of a few decades ago3. Despite this, it is likely that most of these deaths are still preventable.

If CAsA was in charge we'd all be using kerosine lanterns and candles.

NEED WE CONTINUE WITH THIS?

Dexta 4th Feb 2019 21:10

Wow! CASA would be having a fit if they watched that video from ACA - Volunteer Pilots, what with children manipulating the controls, not wearing hi-vis jackets on the apron, using LSA aircraft. Oh the humanity!!!

peuce 4th Feb 2019 22:38

Thorn Bird...perhaps the real issue is....why does our community put such an emphasis on death by aeroplane, as opposed to death by ladder or death by snake? Imagine if the Government spent as much on the Civilian Ladder Safety Authority as they did on aviation??? But they don't...why? We have a perception that an aircraft accident is so much more....I don't know...newsworthy? nasty? horrendous?. Can we alter that perception and reduce the aviation protection business back down to a realistic level? Unfortunately, I don't think so.

Clinton McKenzie 5th Feb 2019 00:06

peuce: It’s called “cognitive bias” and it’s an entirely uncontroversial and incontrovertible human foible. As I said in my submission to the review of medical certification (footnotes omitted):


A key definition: cognitive bias

For the purposes of this submission, I use the term “cognitive bias” to mean - out of the many forms of bias the term covers - the form of bias that Cass Sunstein[1] calls “probability neglect”. Sunstein observes:


Dreadful possibilities stimulate strong emotional responses, such as fear and anxiety. Fortunately, most high-consequence negative events have tiny probabilities, because life is no longer nasty, brutish and short. But when emotions take charge, probabilities get neglected. Consequently, in the face of a fearsome risk, people often exaggerate the benefits of preventive, risk-reducing, or ameliorative measures. In both personal life and politics, the result is harmful overreactions to risks.
Referring to Sunstein’s work, George Dvorsky[2] uses a comparison between driving a car and flying in an aircraft as an example of probability neglect:


Neglecting Probability

Very few of us have a problem getting into a car and going for a drive, but many of us experience great trepidation about stepping inside an airplane and flying at 35,000 feet. Flying, quite obviously, is a wholly unnatural and seemingly hazardous activity. Yet virtually all of us know and acknowledge the fact that the probability of dying in an auto accident is significantly greater than getting killed in a plane crash — but our brains won't release us from this crystal clear logic (statistically, we have a 1 in 84 chance of dying in a vehicular accident, as compared to a 1 in 5,000 chance of dying in an plane crash [other sources indicate odds as high as 1 in 20,000]). It's the same phenomenon that makes us worry about getting killed in an act of terrorism as opposed to something far more probable, like falling down the stairs or accidental poisoning.

This is what the social psychologist Cass Sunstein calls probability neglect — our inability to properly grasp a proper sense of peril and risk — which often leads us to overstate the risks of relatively harmless activities, while forcing us to overrate[sic] more dangerous ones.

The effects of cognitive bias in aviation regulation

I suggest that:

• Aviation is an example, par excellence, of an activity that evokes dreadful possibilities in many minds, especially when contemplating the prospect of the incompetence, incapacitation or mental illness – for whatever reason - of the pilot/s of an aircraft.

• The current approach to aviation medical certification neglects an objective consideration of the probabilities of those dreadful possibilities.

• This results in – to use Sunstein’s words - “an exaggeration of the benefits” of the current medical certification process as well as building “harmful overreactions to risks” into that process. (In my view, the same may validly be said of the broader aviation safety regulatory regime in Australia.)

The overreactions include intrusive medical investigations and interventions, and operational restrictions, which are unjustified by the risks, benefits and costs. The harm includes cost, stress, the deliberate withholding of potentially relevant information from DAMEs, anxiety about consulting medical practitioners ‘when in doubt’ and, in some cases, the unjustified destruction or impairment of careers and participation in private aviation. This harm is among a number of factors that have had, and continue to have, a stultifying effect on what should be a vibrant and growing general aviation sector in Australia.


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