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Community service flights new rules
The summary of proposed changes on the CASA consultation hub makes for interesting reading.
If your private category piston aircraft engine isn't maintained to AD/ENG/4 charter standards then you will be disqualified from conducting angel flights under the proposed rules. Your engine may have plenty of hours to run to TBO, but if it's on condition due to calendar life it will not comply. Given that this is probably 30-40% of all PVT category aircraft in the Australian GA fleet the impact will be substantial. What's the safety gain? Is there any data on engine reliability comparing overall hours vs calendar age to inform this kind of mandate? If you haven't made a submission.. do it now. PPP |
Originally Posted by Peter Pan Pan
(Post 10339039)
The summary of proposed changes on the CASA consultation hub makes for interesting reading.
If you haven't made a submission.. do it now. PPP On a quick reading, the "justifications" are long on assertions, and very short on facts, let alone a properly detailed description of the risks, and how the proposals will mitigate those risks, let alone a cost/benefit justification of the proposal. In short, the result is that more will suffer, some will die, but because it will not be in an aeroplane, CASA will be able to sit back and say: "Safety is our first priority". Tootle pip!! |
One of the main deterrents the conducting these flights will be no NVFR allowed,especially in the winter months. Once you get west of the Blue mountains few private pilots hold an IFR rating as the weather is just not bad enough on average to justify the cost. Also west of the Blue Mountains most of the flights are all day affairs, as to take someone to the city for an appointment,wait until they are ready to return then get them home again,it is usual to run out of daylight on the way home. Few pilots would bother with the hassle or be able to get enough time off work etc to overnight, not to mention the cost, so will withdraw from the service.
This doesn't take into account the stupid decision in the first place. Someone at CASA has decided NVFR is too risky. I call BS on that having flown NVFR for 30 odd years. So long as you stick to the rules such as weather minimums, lowest safe,fuel reserves for alternates etc, NVFR is quite safe. In fact IMHO what is more risky is single pilot IFR op's in clapped out equiptment in poor weather with the pressure to get the job done so to turn a profit. Very few NVFR flight turn into disaster. The ones that do invariably are not NVFR pilots at all but day VFR pilots that get stuck after dark by pressing on. Like to know the real stats too comparing IFR flights v genuine NVFR in night time crashes as there has been quite a few of those I could list. |
Perhaps some of the very experienced pilots could run mentoring programs or something? Unfortunately it also demonstrates how little the Minister for Infrastructure, Transport and Regional Development cares about-
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I had what I thought was a good read of it. What are the main points of concern? The no NVFR? |
Originally Posted by Squawk7700
(Post 10339763)
I had what I thought was a good read of it. What are the main points of concern? The no NVFR? The main point of concern is that it exists at all --- it is a solution looking for a problem. Many people who use/would have used this form of transport for such as dialysis, chemo treatment and similar vital but non-emergency treatment will forced to use other forms of transport ---- because places of treatment are few and far between, once you are beyond the major coastal and several inland cities. Injury, suffering and death is no concern of CASA, as long as an aeroplane/helicopter is not involved. But CASA will be happy to see the service severely contract or collapse ---- Because "safety is our first priority". Tootle pip!! PS: I hope you remember the CASA proposal, some time back, that any emergency services helicopters would only be able to land at certified or registered aerodromes --- and only if they had current NOTAMS and a TAF. |
They have clearly done this in response to an incident / accident. On the face of it, the requirements seem fairly reasonable and are arguably minimal. Remember we’re expecting aviation uninformed passengers to hop onboard and aircraft flown by a PPL whom they don’t know from a bar of soap. It was only a matter of time after the fatalities that this was going to happen. The NVFR one is an interesting one admittedly. I know a few pilots I would let my family travel with in the dark, but some I definitely wouldn’t. |
Does Angel Flight allow NVFR with the passengers? I have positioned prior to or after the flight by myself NVFR but never with the passengers on board.
The Victorian tragedy sent shivers down my spine at the time and I am surprised CASA didn't jump on this sooner. |
Originally Posted by YPJT
(Post 10339896)
Does Angel Flight allow NVFR with the passengers? I have positioned prior to or after the flight by myself NVFR but never with the passengers on board.
The Victorian tragedy sent shivers down my spine at the time and I am surprised CASA didn't jump on this sooner. On the basis of some of the logic here, why not extend the proposal to ALL PRIVATE FLYING, except for the pilot of the aircraft and other pilots, who could reasonably be expected to understand the risk of being a passenger in a light aircraft versus an A-380. After all, some years ago, CASA proposed a "PRIVATE OPERATIONS AOC", which was to be required for all operations except the carriage of the "immediate family" of the owner/pilot. Just extend the "ONE STANDARD OF SAFETY" one step further down the food chain than "charter" (Part 135) After all, SAFETY IS OUR FIRST PRIORITY, forget practicality, common sense, precedent and the right of people to take charge of their own lives. After all, it is well recognised that the greatest contribution to "more safety" is more bureaucracy ---- isn't it?? I know, from real world experience, that people getting into a C206 know it is an NOT airline aircraft. The balance of risk and consequences is meaningless if you demand that the only outcome, aviationwise, is zero death or injury. That is NOT risk management. One of the things I have battled for years is the dumb bxxxxrds who want to ban two kids in one seat, based on a ridiculous pommy analysis that in turbulence they could clap head, despite the fact that, from the very first Flying Doctor flight with Fred McKay and Arthur Affleck, we have carried two kids in one seat, and there has never been a consequential injury. A while ago now, two of us in two C-182s evacuated a whole bunch of kids from one of the Cape Missions to hospital in Cairns (the other was Tony Mathews --- many of you will remember the Flying Parson from Normanton) during a raging flue epidemic. Would it have been "safer" to get those kids to medical attention days later?? How many would have died --- but not on an aircraft. Tootle pip!! |
I'm not a fan of this sort of thing as much as the intention is well meaning. What price do we put on risk?
There are well established organizations that do aeromedical work in at times a very challenging environment, this is no place for Pvt pilots or even more advanced pilots to be when there would be a level of 'pressure' on the pilot to complete the task. The biggest trouble is pilots always tend to overestimate their abilities especially in the decision making process! The planes themselves are not the real issue, CASA have it all wrong in that area. I would never put one of my family members on one of these flights, too risky, but that's just me! |
Originally Posted by Clearedtoreenter
(Post 10339924)
No they do not. Passenger carrying VFR flights are allowed by day ONLY. In some cases a pilot might decide to return home by NVFR after delivering passengers. In which case it’s not a community service flight. It’s a non issue but it’s not a bad thing that CASA have now put it in writing for all CSF’s.. If you make it too hard pilots will simply walk away. They are volunteers after all. Angel flight tells it's clients requesting a flight that it is a private flight usually in single engine aircraft. See their website. So if clients want to take advantage of the service fair enough they know the risks. That said, the risks are overstated in my opinion. Little different to catching a lift with an unknown driver on country roads at speed for long periods at a time. We need to get away from this notion that flying is unsafe. Essentially it is safe! As with surface transport the bigger the vehicle the safer it is, ie trains safer than cars so too 4 engine jets safer than twin piston aircraft etc. But that doesn't make cars or single engine aircraft unsafe just not as safe. As stated above poor decision making is the issue here,not the aircraft. As also stated above CASA has the solution looking for a problem! |
Here’s what I said about the issue of “community service flights” in my (published) submission to the review of Avmed: A related and relevant point was made in the Canberra Aero Club’s submission in response to DP 1317OS – “Safety standards for community service flights conducted on a voluntary basis”. CASA’s response to a fatal accident during a community service flight was to propose, among other things, an increase in the standards and regulatory approvals required to engage in those operations. But the only rational way to decide whether to increase those standards and requirements and, if so, to what, was to determine the opportunity cost to society of the increase. CASA could set the standards such that community service flights must be conducted only in transport category aircraft, to and from airports equipped with CATIIIC ILSs. When carried at that standard, passengers would be, comparatively, extraordinarily safe. However, the operation would be very costly and the flights would be inaccessible or useless to most of the population. Some of the vast majority of the people who miss out may be unable to access the required medical treatment to which they would otherwise have access, and die of their condition, or may die in a road accident trying to get to that treatment. CASA could instead set the standards such that community service flights may be conducted in ultralights powered by motor mower engines, to and from any convenient paddock. At that standard the service would be, comparatively, very cheap and accessible to the vast majority of the population, but there would be many more accidents than if the standards were set at the other end of the spectrum. The only rational way to decide where within that spectrum to set the standards is to consider, among other things, objective cost/benefit data across that spectrum. But CASA does not have or consider that data, and is not competent to make decisions about it, even if it had the data. Decisions about and balancing the risks to which society will be exposed, what counts as benefits to society and what price is considered reasonable for society to pay for those benefits, are essentially political decisions. That is why the aviation classification of operations regime in Australia continues to be a muddy mess, around 20 years after Commissioner Staunton recommended an “urgent” review of one of the fundamental definitions within that regime. That is also why the flight and duty time rules have been in a state of flux for even longer. Therefore, it is not enough for CASA to say that an increase in medical-related incapacitation is, of itself, justification for CASA to continue to conduct general aviation medical certification, even if there were overwhelming evidence that there would be an increase [which evidence does not exist]. The benefits have to be ascertained and weighed as well. And I see the good ol’ let’s-pull-it-apart-to-find-out-why-it’s-working-so-well cancer can never be killed. But why would any private owner pull a perfectly running low time engine to pieces, when all of the vital signs like oil analysis, borescope compressions are perfect? Makes no sense at all. Requirement 2 is sensible for charter operators who thrash their high time 40 year old hacks to death. CASA seem to be acknowledging that CSF’s are Private operations... so why arent Schecule 5 and AD/ENG/4 Requirement 1 good enough? Many CSFs currently take place using these standards.... and NONE of the problems have been remotely linked to maintenance standards for private aircraft. Overhauling or replacing a well-running, performance-monitored high-time engine is merely buying the risk of infant mortality - catastrophic failure early in an engine’s life. But, as is so sadly typical these days, CASA is proposing to make things “safer” by implementing a measure that will increase the risk of catastrophic failure. And despite objective evidence, of course. |
“Risk-based structure having regard to the circumstances of passengers and participants.” If only. Much of the structure is based on intuition and convenient fictions. One of those convenient fictions is the one to which you referred. The regulatory regime treats a tourist who pays for a flight from A to B as being a private passenger if B happens to be the top of a tandem parachute descent, but a charter passenger if B is Kangaroo Island. Apparently the tourist understands and accepts the different risks of the flight. If I buy an aircraft and pay Bob to fly my family and me around, it’s a private flight. If Bob instead owns the aircraft and I pay Bob to fly my family and me around, it’s a charter flight. Apparently my family “understand” and “accept” the different risks. If I own a property and agricultural aircraft, I can pay Bob to conduct agricultural operations in my aircraft on my property and it’s a private opertion. If I pay Bob to conduct agricultural operations in my aircraft on my neighbour’s property, it’s a commercial operation. Apparently the aircraft ‘knows’ who owns the land under which the aircraft is operating. Again, from the Canberra Aero Club’s submission on DP1307OS: The Proposal also perpetuates the myth that it is possible to “ensure that prospective community service flight passengers are fully advised of the risk levels associated with such flights”. The only valid, understandable information that could be provided about “risk levels” is that the standards applicable to a flight are, for example, ‘higher’ than another category of flight or ‘lower’ than another category of flight, and therefore the passenger is likely to be safer or less safe than s/he would be on those other categories of flight: A perfectly useless piece of information if the person does not have a choice as to the category of flight and does not have access to the more important piece of information: Will I or my dependant loved one be safer if I or they do nothing or go instead by road? |
risk based bull****. Risk compared to what? |
Too much change
Too many changes going on, if there is a risk, its within...
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Due to a couple of unfortunate CFS events...just like in Charter ops...CAsA, the fount of all av-wisdom has decided there is a "risk"
Therefore to completely eliminate this risk, the engine o/h requirement will eliminate the pvt volunteer entirely...so job done Risk eliminated.! See.. 'Safety is our first priority' |
Due to a couple of unfortunate CFS events...just like in Charter ops...CAsA, the fount of all av-wisdom has decided there is a "risk" Therefore to completely eliminate this risk, the engine o/h requirement will eliminate the pvt volunteer entirely...so job done Risk eliminated.! See.. 'Safety is our first priority' Both accidents (the one near Horsham and the one near Mt Gambier) would have occured under the new guidelines. This is political grandstanding by CASA. And its being done before the ATSB releases its report on community service flights, which makes one even more suspicious about the true motive. |
Originally Posted by aroa
(Post 10343257)
Therefore to completely eliminate this risk, the engine o/h requirement will eliminate the pvt volunteer entirely...so job done
The CAsA wizards should take the time to aim the legislative weapon before pulling the trigger. A lot more collateral damage than intended victims will come from this 'improvement'. |
cleared to enter Risk Management 101 is all about identifying exposure to undesirable outcomes and then reducing or elimating those exposures ’Contrary to CASA BS, you can put a price on human life - actuaries do it every day in computing insurance premiums. Risk management is about minimising the total cost to the community of the risks inherent in life. That requires a cost/benefit analysis which CASA makes a virtue of ignoring. Examples - reducing all road speed limits to 20 kph - reduces the cost of accidents but massively hits economic activity. Ditto making everyone wear helmets, etc., etc. There are numerous cranks who have pet ideas for reducing risk but don’t compute the associated costs. CASA seems to have more than it’s fair share of them. |
Sunfish,
Well said. Fact is, the determined and wilful ignorance of the proper meaning of "risk management" is , aviation-wise, not confined to CASA. To wit, one well known pilot's union that insists that a perception of a risk, even when no risk can be established as existing in the real world, must still be treated as a genuine "risk" and mitigated regardless. It is clear that, with only a small handful of exception, nobody in the aviation sector has ever bothered to attempt to understand the principles that underlay risk management and cost benefit justification, much less read and understand risk management standards, either the old AS/NZ 4360, or the later ISO standards, much less Government (both sides of the House) policy on the subject, policy pointedly ignored by CASA because of a perverted interpretation of S.9A of the Act. Tootle pip!! |
For information, Australian government policy on value of human life: https://www.pmc.gov.au/sites/default...dance_note.pdf
...and Due diligence - a common law defence against negligence Where it is possible to guard against a foreseeable risk, which, though perhaps not great, nevertheless cannot be called remote or fanciful, by adopting a means, which involves little difficulty or expense, the failure to adopt such means will in general be negligent. Chief Justice Sir Harry Gibbs. Turner v. The State of South Australia (1982) (High Court of Australia before Gibbs CJ, Murphy, Brennan, Deane and Dawson JJ). |
Vag277, “which involves little difficulty or expense” exactly consistent with risk management principles. |
Originally Posted by Vag277
(Post 10343406)
For information, Australian government policy on value of human life: https://www.pmc.gov.au/sites/default...dance_note.pdf
...and Due diligence - a common law defence against negligence Where it is possible to guard against a foreseeable risk, which, though perhaps not great, nevertheless cannot be called remote or fanciful, by adopting a means, which involves little difficulty or expense, the failure to adopt such means will in general be negligent. Chief Justice Sir Harry Gibbs. Turner v. The State of South Australia (1982) (High Court of Australia before Gibbs CJ, Murphy, Brennan, Deane and Dawson JJ). It ain't that simple. There is a lot of case law since that judgement, although it is beloved of Civilair. A most recent one is the successful appeal by Taree Council re. aeroplanes versus kangaroos --- there is a thread about it. An important judgement that should be looked at is: Jones v Bartlett [2000] HCA 56. 205 CLR 166; 75 ALJR 1; 176 ALR 137. 16 Nov 2000. Case Number: P59/1999. Look at para.23, in particular, for as good as any definition of "safety" in risk management terms. In addition, consumer law now allows that "adventure sports" allow participants to assume a risk inherent in the activity, and limits the participant's ability to sue negligence if the outcome is an injury that can be anticipated when things go wrong. Tootle pip!! |
My point is that the life of an Angel Flight passenger is worth no more or no less than the life of any other passenger that at a private pilot might fly. And most of the Angel Flight pilots have a multiple of hours greater than many CPL's who fly charter flights. The two accident pilots were mature, experienced pilots with lots of hours and very good currency. If there is a standards issue with Angel Flight Pilots, then there is a standards issue across all pilots, in which case CASA needs to look in the mirror, not point fingers.
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"If there is a standards issue with Angel Flight Pilots, then there is a standards issue across all pilots, in which case CASA needs to look in the mirror, not point fingers."
Exactly Akro, In the US Angel flights are a massive undertaking. Lots of esoteric talk about causality, but it is obvious the incidents here were weather related. In the US 80% of private pilots hold instrument qualification, here, hardly any. The reason? In the US gaining and maintaining instrument qualification is affordable, here it is not. Therefore the question comes to mind, is Australia's unique over regulation an impediment to safety? I believe the answer is self evident. |
Originally Posted by thorn bird
(Post 10343542)
"If there is a standards issue with Angel Flight Pilots, then there is a standards issue across all pilots, in which case CASA needs to look in the mirror, not point fingers."
--- is Australia's unique over regulation an impediment to safety? I believe the answer is self evident. Exactly, The short answer is yes. The longer answer is have a close look at the statistics, the steady improvement in the US over many years, here there is no underlying improvement, the only "improvements" here have come from the collapse in flying hours in some sectors. And CASA have now put the PIFR out of reach of most PPLs, with just a few seemingly "minor" tweaks to the "rools" --destroying the original and successful in practice PIFR. Tootle pip!! |
Originally Posted by Old Akro
(Post 10343518)
My point is that the life of an Angel Flight passenger is worth no more or no less than the life of any other passenger that at a private pilot might fly. And most of the Angel Flight pilots have a multiple of hours greater than many CPL's who fly charter flights. The two accident pilots were mature, experienced pilots with lots of hours and very good currency. If there is a standards issue with Angel Flight Pilots, then there is a standards issue across all pilots, in which case CASA needs to look in the mirror, not point fingers.
I believe CASA should put a stop to it, but that's just my opinion. |
So basically your opinion is all GA should be shut down Mach?
Would you apply the same reasoning when we inevitably are faced with a large smoking hole with a boeing tail pocking out of it? Shut down RPT. Hundreds of people die on our roads every year. If angel flights are stopped, forcing patients onto the roads there is a high chance, compared with private aviation, that patients will die driving, and probably have already. After you've banned patients from driving to appointments Whats left for the poor patients? walk to the doctors?....Walking carries a high risk ......Oh bugger it, just stay home and die from the disease....hang on a minute didn't I read somewhere most accidents happen in the home?....good grief we are doomed! I've been told Hundreds of angel flights occur every day in the US, they to have had two accidents, but their regulator has applied no restrictions fortunately they recognise aviation in whatever form carries risks, but way less than other forms of transport. |
Originally Posted by Old Akro
(Post 10343518)
My point is that the life of an Angel Flight passenger is worth no more or no less than the life of any other passenger that at a private pilot might fly. And most of the Angel Flight pilots have a multiple of hours greater than many CPL's who fly charter flights. The two accident pilots were mature, experienced pilots with lots of hours and very good currency. If there is a standards issue with Angel Flight Pilots, then there is a standards issue across all pilots, in which case CASA needs to look in the mirror, not point fingers.
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Some very important data that are missing: How many lives have been saved, extended or improved as a consequence of CSFs? What is the value of that? How many lives will be lost, lifespans reduced and lifestyles impaired if the number of CSFs is reduced? What is the cost of that? What’s the delta between the two? As noted by others, a reduction in the number of CSFs may cause a net negative for society. |
So what then for mercy flights? |
Originally Posted by Sunfish
(Post 10344411)
So what then for mercy flights? |
If this is successful, the next logical step is to expand the definition of Community Service Flights to include services like FunFlight. A kid from a disadvantage breakground is probably less informed about the nature flight risks than a patient seeking treatment.
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If this is successful, the next logical step is to expand the definition of Community Service Flights to include services like FunFlight. A kid from a disadvantage breakground is probably less informed about the nature flight risks than a patient seeking treatment. Then, what about the pilots who (lawfully) use their aircraft to fly employees around? This is a pandora's box. Ben Morgan's letter for the AOPA calling for CASA to revoke the proposal is very good, rational & measured. A private pilot should have all the skills required to conduct flights in a non commercial environment safely. If not, CASA needs to examine its training syllabus. The CPL training is primarily about operating in an operations manual driven environment with commercial "must get there" and at minimum cost environment. If CASA was genuine about wanting to improve safety it: a) would wait for the outcome of the ATSB investigation b) not release the draft in the days before Christmas with a Jan 31 response deadline c) consult with industry bodies (eg Angel Flight) before compling the draft d) understand that the 2 accidents that CASA is "knee jerk" reacting to would have complied with the new regs, thus realising that they are only increasing bureacracy and not improving safety e) canvass real safety initiatives like making flight following more readily accessible, allowing experienced pilors to act in coaching or mentoring roles (which CASA effectively outlawed in the early 90's) |
Originally Posted by Old Akro
(Post 10346986)
The list goes on and on. Fun Flight, flights sold at raffles / auctions to raise money for the local school. Taking your kids school friends for a fly, scouts, families from the local aero club, the list goes on and on.
Then, what about the pilots who (lawfully) use their aircraft to fly employees around? This is a pandora's box. See my post about "Private Operations AOC", and have a search around for the original CASA proposal. Captures all of the above. "Private Operations", without the benefit of the said AOC, ie: Private Operations as ICAO/the Rest Of the World knows it, would be limited to the owner/pilot of the aircraft and immediate family. What is happening here is a resurrection of the CASA Private Operations AOC proposal, and yet again, an example of how hard it is to kill a bad idea, once it takes hold in CASA. A real live example of the process is Part 132, no real substance, no answer to any known problem, just an answer looking for a problem ---- introduced in very questionable circumstances, hundreds of pages to do what several paragraphs in the then existing regulation had successfully done for about eighteen years. The seemingly unstoppable creep of bureaucratic micro-management, despite Government (bi-partisan) policy to the contrary. But, as you all understand" "Safety is our first priority" ------ the safety of our very lucrative bureaucratic sinecures. Tootle pip!! |
Leadie's last line. Now aint that absolutely the truth.
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Some very good arguments here so please go online and complete the survey. CASA not likely to read Pprune |
Cleared, this is the point you be making in your submission - the premise is flawed. CASA must demonstrate there is a case for change rather than making simple assertions. The problem of "mustgoitis" is a well known risk within private flying (unfortunately) in this regard there is nothing special about CSF.
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Originally Posted by ANCIENT
(Post 10347846)
Some very good arguments here so please go online and complete the survey. ... In any event, CASA will ignore the results. As is the usual case (and as happened the previous time the regulatory hydra grew the CSF head) the outcome will be determined by politics. If Angel Flight can again marshal a groundswell of community support to lobby their federal politicians (mainly Coalition members) to preserve the regulatory status quo, the head will be cut off again. But this time around CASA is banking on the pollies being focussed on other stuff for the next few months. And we all know what happens each time you cut off one of the Lernean Hydra’s heads... |
Originally Posted by Flying Ted
(Post 10348475)
Cleared, this is the point you be making in your submission - the premise is flawed. ....
My favorite flawed premise is the first sentence of the abstract of Dougal Watson's paper Lack of International Uniformity in Assessing Color Vision Deficiency in Professional Pilots: Color is an important characteristic of the aviation environment. Pilots must rapidly and accurately differentiate and identify colors. |
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