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Talkfest in Wagga on 2nd March – Will questions be answered??

The latest by Skidmore and follows the Mildura and Townsville events. Moorabbin to follow.


UNCLASSIFIED

Flight Plan 2030 forums

They are still e-mailing people, so maybe not as popular as they like to think. I publish the questions and answers from Mildura below, which I have just found on a non-casa website.

It is worth a read, and see if you come to the conclusion that:

  • There is substantial papering-over of why casa is correct;
  • casa never take any “blame”;
  • A sound way forward is not part of the dialogue.

Some reading of the Mildura Q and A

Future-aviation-safety-issues-Mildura Flight_plan_2030-MIldura-Q_A

Future-aviation-safety-issues-Mildura


What safety issues do you see facing the aviation community over the next five, 10 and 15 years?

Wally about 1 month ago
In my opinion there are a number of issues that may affect safety over the next 5 to 15 years.
I have provided some brief examples below.
Aging aircraft and the way in which their continued airworthiness is being considered.
Regulatory change and how that imposes pressure and therefore risk on both the operator and maintenance organisations.
The limited new pilots and engineers being trained and the resultant age of current professional’s within the industry.
limited availability of qualified and experienced responsible and accountable managers to fill the future demand.
Regulation and the industry organisations not keeping up with technology.
BlueSky 3 months ago
 I feel we are being asked to train and study out-dated techniques which are rarely used in the cockpit or planning room. I would like to see CASA move forward with the presentation of exams and exam material (namely ASL material). We seem to be still in the last century with how we have to answer W & B questions and Nav questions. Isn’t it time to move forward allowing electronic solutions rather than relying on pen and paper?
CASA Admin 2 months ago
Thank you for your comment. An understanding of both ‘weight & balance’ and ‘navigation’ are of fundamental importance in aviation. Most aircraft do not provide electronic solutions for weight & balance or ‘load sheets’, though there are some aftermarket versions available for selected aircraft. Completing load sheets for a flight is a legal requirement, and for many operations, copies of the completed load sheet need to be left at the departure airfield. Equally a basic understanding of the principles of navigation only comes through practice and by using manual means a greater understanding of both topics is commonly achieved.
 Hillard 3 months ago
 As an aircraft owner, I’d like to know what the rulemaking process in Australia is regarding airworthiness matters. When my aircraft was on the US register, the process was explicit – I was required to maintain my aircraft in accordance with the type certificate and any applicable ADs. Any Advisory Circulars and manufacturers recommendations were just that – advisory. If a manufacturer could persuade the FAA that certain actions were necessary to maintain airworthiness then after consultation (NPRMs, etc) the FAA would issue an AD that I was then obliged to implement. It is a system that strikes a fair balance between ensuring flight safety and protecting the interests of aviation consumers.
Since moving to the VH register, I have is no such clarity or certainty. In addition to doing the things required by the regulator (FAA) in the country of manufacture of my aircraft (USA), I am now exposed to “Rulings” (the mechanism used to implement Cessna SIDS) and “Proposed ADs” (the mechanism to amend AD/PROP/1). There are peculiarly Australian inventions that are simply a means of bypassing the consultation mechanisms associated with a proper rulemaking process.
Manufacturers have not succeeded in making their SIDS/TBOs mandatory in the USA because the FAA is obliged to apply proper risk analysis and cost:benefit analysis to such proposals. CASA have not done such analysis and have disregarded the fact that manufacturers, as suppliers of replacement parts and sellers of new aircraft, have a commercial interest in having their “recommendations” made mandatory.
I would like to see a proper explanation of CASA’s airworthiness philosophy and justification for why a US manufactured aircraft should require more maintenance in Australia than it does in the USA.
CASA Admin 3 months ago
Thanks for taking the time to comment. Australia has a different regulatory environment to the USA.
Under Civil Aviation Regulation 42V, a person carrying out maintenance on an Australian aircraft must ensure that the maintenance is carried out in accordance with the applicable provisions of the aircraft’s approved maintenance data.
Under Civil Aviation Regulation 2A(2)(c) Approved maintenance data represents instructions, issued by the manufacturer of an aircraft that specify how maintenance on the aircraft is to be carried out i.e. Supplemental Inspection Documents (SIDs). Aviation Ruling 01/2014 merely clarified a Regulation that has been in place since 1988.
Hillard 2 months ago
 I’d asked you for a logical justification of your policy and instead you’ve responded with a restatement of the legal subterfuge that you’d used to avoid a proper rule making process. Why, given that legal argument, is one particular “instruction issued by a manufacturer” (i.e. SIDS) part of “Approved Maintenance Data” … but many thousands of others are not? Such inconsistency reinforces the fact that owners of VH registered aircraft have no clarity or certainty about how the airworthiness regulatory process is supposed to work in Australia.
Hillard 5 months ago
There are about 9,000 fixed wing GA aircraft in Australia. Most of them were built in the USA and the vast majority of the worldwide fleet – 155,000 aircraft – operate there. If airworthiness issues arise with US-built GA aircraft then the FAA will issue an Airworthiness Directive (AD) and implementation of that AD would be mandatory under existing Australian regulations. Yet CASA continue to pursue initiatives that would result in “precautionary” maintenance for private GA aircraft that is additional to what would be required under FAA regulations – e.g. Cessna SIDS, mandatory 6 year propeller overhauls and mandatory 12 year engine overhauls. CASA should not seek to create airworthiness requirements, additional to those of the country of manufacture, when there is already a mechanism in Australian legislation to address any future issues as they arise.
CASA – administrator 5 months ago
 Thank you for your comment – have you seen the new material posted on the CASA website relating to SIDs? (www.casa.gov.au/sids(External link))
CASA is also organising a series of maintenance presentations at various regional locations, covering Cessna supplemental inspection documents (SIDs); the benefits of CAR 42C system of maintenance; the prototype matrix tool; and the new defect reporting service. There will be a one-hour presentation followed by ample
opportunity for questions. The first one will be on 1 November at Stawell, Victoria.
Hillard 3 months ago
 I have seen the material on your website and it does not address the point raised. In my experience, your public forums are simply an opportunity to “talk at us” and offer little opportunity for constructive discussion. What is the purpose of this forum if you do not provide a substantive response to issues raised?
djpacro 5 months ago
 From the 1944 book, Stick and Rudder:
“Almost all fatal flying accidents are caused by loss of control during a turn!”
From the ATSB in 2007:
“general aviation fatal accidents … most prevalent type of accident was a UFIT”
From CASA in 2007:
“Three quarters of aviation accidents in Australia result from problems with the operation or handling of an aircraft.”
Meanwhile, in the USA more recently:
“Loss of Control-Inflight remains the top fatal accident category in GA …
and occurs most often .. while turning…….
The biggest single cause of fatal GA accidents is stall/spin from a turn.”So, what safety issues do I see facing us over the next 5, 10 and 15 years? Firstly, I see exactly the same big safety issue that has been facing us over the last 70 years – loss of control/stall/spin.Secondly, in the next 5 years I see the result of CASA’s Part 61 will be to aggravate that situation. i.e. some aspects address the above however all of the other onerous solutions to problems which do not exist are generally counterproductive to safety and some I see as having a direct adverse effect on the above.
Fixed wing mustering training is in crisis. Changes to regulations are confusing and CASA staff are unable to consistently interpret the rules. The current instructors issuing endorsements are unable to comply with the new requirements and are leaving the industry. CASA apparently doesn’t have staff that are able to approve new instructors to issue mustering endorsements. The risk is that the process has become so difficult that mustering operations will be conducted with untrained pilots. CASA will not divulge the details of anyone that is qualified to issue a mustering endorsement, so it isn’t possible to find them anyway.
Unhappy 4 months ago

 casa’s implementation of Part 61 has been a shambles both at a regulatory level as well as at at basic procedural level.

It is UNACCEPTABLE that it takes 2 months to issue a new pilots license!
it is UNACCEPTABLE that it takes 6 months to issue a UAV operators certificate!
It is UNACCEPTABLE that it takes 6 months to add an aircraft type to an aerial work AOC!

These should be simple things to do.
When the simple things cant be done it is no wonder that more complicated things are stuffed up too.

 In my limited experience, it is a sad joke among pilots and aircraft owners that it seems that CASA’s philosophy seems to be “The only ‘safe’ airplane is one that doesn’t fly”. I think this is because CASA’s central remit is safety, yet CASA is the industry regulator. In the US, the body charged with safety is separate from the regulatory entity. The safety body investigates incidents and accidents and makes reccomendations to the regulator. The regulator (FAA) is charged with encouraging and fostering aviation, so that the reccomendations put forward by the safety body are considered through the lens of their potential impact on the viability of aviation. Here in OZ, CASA is the “safety” body and also the regulator, and I don’t believe that CASA has a mandate to “encourage” aviation, merely to keep aviation “safe”.
The elephant in the room is that the two roles CASA does play have resulted in more and more expensive regulation that is effectively strangling the GA industry out of existence. An example is the implementation of the SIDs program. I have been told by some Cessna owners that in the US, SIDS is applicable only to the commercial fleet, whereas here in Oz it has been applied to the WHOLE Cessna fleet. Another example is the controversial restrictions imposed on Jabiru powered aircraft. These are widely viewed as heavy handed and an over-reaction to some engine reliability issues. Our regulatory and safety functions should be separated as in the US
PaulH 5 months ago
 I saw Marks talk about how he would like more consistency in CASA responses. One suggestion would to make more use of your Youtube channel and devote video’s to specific regulations.
Videos that don’t read out the regulation verbatim but explain the reasoning, CASA’s interpretation and real world application. If we have something like this we can level the playing field in terms of consistency. Especially between CASA’s officers and regional offices
Thank you for hearing us out.
I have never seen a cost benefit analysis of the new part 61. This ridiculously complex and costly legislation has only had the effect of alienating industry from CASA. The only way to fix it is to remove any legislation that adds cost to an operator or crew member. There is no evidence that those rules will do anything to improve safety in the first place. Admit that you made a mistake and rectify it. You are not there, in your tax payer funded jobs, to cover your own backsides. You are there to serve a once great industry.Ask yourselves a question: when you go home at night to your family, can you tell them that you are doing your best to fix what you have admitted was a very problematic roll out of part 61? Or do you need to tell them that you sat by when increased costs led to peoples livelihoods, (and in many peoples minds a whole industry) being at stake, and that you can’t/won’t admit the error and fix it.I’ll say it again, remove all legislation that has led to increased costs. These costs are unsustainable.Two major schools have had their 142 applications rejected, applications filled out using CASA guidance material, to be told the material CASA provided was incorrect in the first place? What a joke, and you wonder why you have industry offside.

 CASA – administrator 5 months ago
Thanks for taking the time to comment. CASA acknowledges that the implementation of Part 61 hasn’t been flawless. However, we have been listening to the feedback we’ve received and are actively working to resolve the issues that have been identified. You can find a full list of the activities underway as part of the flight crew licensing regulations suite post implementation review (https://www.casa.gov.au/standard-page/flight-crew-licensing-regulations-suite-post-implementation-activity(External link)) on our website.
 Panda 5 months ago

 Unfortunately the level of industry cynicism around CASA and its motives means that having a forum to encourage the industry to “have your say” after it (the industry) has already provided significant feedback through previous mechanisms only further reinforces the belief that CASA isn’t listening. If CASA is going to be serious about this “have your say” forum and make it worthwhile for us in the industry to bash our heads against the wall yet another time, then create transparency around what mechanism (if any) takes any feedback from this forum and feeds it into the management decision-makings levels of CASA. Like most in GA, I assume that nothing posted here will have any impact. The ball is in your court CASA, prove us wrong!

http://www.pprune.org/pacific-general-aviation-questions/568156-casa-have-your-say.html(External link)

CASA – administrator 5 months ago
 We understand your frustration at past events; however, things are changing. Feedback from this online forum, as well as the face-to-face forums currently being held around the country (Flight Plan 2030 and the series on how CASA implements new regulations) will feed directly into the Flight Plan 2030 document due in mid-2016. The Director is also happy to receive feedback directly via the CASA website, just click on the ‘Feedback to CASA’ button at the top right of the home page.
skiesforall 5 months ago
I recently heard that Busselton Airport is kicking out the Aero Club and GA aircraft that have been there for countless years and have become a key part of the WA Aviation community simply because the RPT operators can’t operate in the same skies.
A key issue I see is how we are going to stop this kind of madness ruining GA completely. How are RPT and GA going to work together? We can’t keep having General Aviation being steamrolled in favour of an airline lobbying in the name of ‘Safety’. GA is almost dead in Western Australia no young people are getting into it. We have far fewer airports than the east coast so we need to retain access to them as there’s already hardly anywhere to visit or stop along many of these flight routes – having access to friendly aero clubs and airports where you can stop and refresh is critical to GA. We need to do whatever we can to protect them – especially the clubs who are responsible for introducing young people to aviation. RPT and GA can safely co-exist other airports have done it all around the world.The biggest challenge I see is how do we achieve good safety without going to far as in this case.
 CASA – administrator 5 months ago
 hank you for taking the time to comment, but this is really a matter for the local council as the aerodrome owner. However, the master plan quoted on their website does include though the statement that: ‘A general aviation precinct will provide hangar and airside access for aviation-related businesses’.
Thank you for the opportunity to highlight areas of concern regarding CASA and legislative change.
Please recognise that administrative change for changes sake is not dealing with Safety issues.
I and several of my colleges have recently raised matters dealing with Part 61 through the Commonwealth Ombudsman and CASA complaints as well as the Federal ministers.
We asked for dialogue and resolution. We got a wave-off!
This is because CASA will not listen. Our group (APUAC) has written to the CASA CEO MarK Skidmore requesting dialogue which has not been forthcoming. So much for genuine transparency and the true ability to have a say or find mutual resolution or compromise to industry concerns.
CASA apparently has no idea that Airline Pilots also fly GA. In fact the majority of us came via that route and still are having a love affair with light aircraft and experimental amateur built. Its recreational flying at its best…
Many of us hold a PIFR ratings. This has been kept current by our own check and training organisation (Qantas, Virgin, Jetstar, and Tiger). Typically with 16 hours of level 7 Flight Simulator testing p.a. under full IFR conditions, renewing all 2D and 3D approach aids with approx. 800 -850 hours per year in IFR flight operations in high performance aircraft is well above many pilot’s recency and flight experience levels across the industry within Australia.
Additionally we undergo a 12-16 month proficiency check, (route and flight check by a CASA delegate) flying in the world’s busiest ATC environments and through CATIII and CATII weather. It is totally absurd to fully unreasonable to ask these pilots of complex systems, heavy-metal and high performance to undergo yet another proficiency check for a PIFR rating in a light aircraft such as a C-172. There is no logical reason to this requirement by CASA? There are no safety/crash statistics to support the change from the current position.
The FAA and the Canadians accept me and my colleagues and/my licence as fully capable of IFR flight in there airspace in GA aircraft based on my current ratings?
This is therefore folly, silliness and absurdity if reviewed in the cold hard facts of aviation ability and experience of the pilots with such experience and there are many of us!
I am not the sole participant affected here, there a many pilots all owners of General Aviation certified aircraft, Experimental and Amateur Built aircraft with IFR capacity and capable pilots are grossly affected here. I would assume many more will be affected or not aware that there ratings are about to disappear into the ether into the next few months!
This group are awaiting an outcome of the Ombudsman and CASA as the CEO has shut-the door on having a conversation. That’s right we find this plastic-website an affront after taking the time over weeks to engage with Skidmore and be feed autocratic gobbledygook in a letter that did not address once concern or any of the issues we raised!
If common sense does not prevail then CASA will enjoy a class-action (litigation) and a public media campaign as the matter progresses to the AAT (Administrative Appeals Tribunal) or relevant court (Federal) to seek injunction and review.
Whilst I regretfully submit that it will probably head this way, after many years on representative aviation committees and as a member of a number of Australian and foreign aviation organisations, I also appreciate that dialogue and common-sense can prevail.
We asked you CASA for your safety management appraisal on this matter. I have never seen a cost benefit analysis of the new part 61 and the change for this rule nor were forwarded any evidence why the change was promulgated. The facts are simply this…. this is CASA making regulatory change for regulator changes sake! Jobs for bureaucrat as there is no evidence, no logical reason why Part 61 had to change.
This ridiculously complex and costly legislation has only had the effect of alienating the wider arm of the aviation industry as more changes come to light. It now looks as if a media a campaign and litigation are required to in order to be have any dialogue with CASA (another cost to the public purse!) and to actually find any hard evidence for all these most foolish changes.
We tried to talk to you CASA and you closed the door in our face. Please don’t tell me that you are now having a conversation.
There is no reason to have IFR rated Airline Pilots under a matrix of C&T do another check to keep their PIFR GA rating current. CASA has no evidence to do so. As for the rest of Part 61 Why?
 CASA – administrator 5 months ago
Thanks for taking the time to comment. CASA acknowledges that the implementation of Part 61 hasn’t been flawless. However, we have been listening to the feedback we’ve received and are actively working to resolve the issues that have been identified. Many of these have already been addressed under the post-implementation review process. The policies relating to flight reviews and proficiency checks are being reviewed. You can find a full list of the activities underway as part of the flight crew licensing regulations suite post implementation review (https://www.casa.gov.au/standard-page/flight-crew-licensing-regulations-suite-post-implementation-activity(External link)) on our website. The register on this page is being updated periodically.
Hillard 5 months ago
 CASA appears to be prioritising projects that have little to do with safety – GA pilots don’t generally die from not having a new Part 61 licence or structural failure of an older aircraft. The NTSB (and CASA/ATSB reports) show that the primary cause of more than 75% of GA accidents is pilot error. Should CASA not be putting more of its time and resources into addressing the real safety issue in GA? – e.g. by engaging with the aircraft Type Groups to expand the safety and proficiency programs that tackle the root cause of many such accidents.
SteveS 5 months ago
 UAV Licensing and operating requirements are over governed and ridiculous qualifications set. I operate a small business that wishes to utilize a small UAV/RPA aircraft to expand my operations. I have purchased a ‘state of the art’ drone which had a MTOW of 1.8 kgs. I am my business sole owner. Currently, to operate the UAV on a commercial basis I need a Controller certificate and Operators Certificate. Fortunately as a GA pilot I am exempt from the PPl exam component of the Application, but, it is estimated that to get to operator requirements which includes preparation of Operations manuals, maintenance etc, etc the cost is about $7000, then the CASA costing(which is an undetermined and varying cost) could be an additional $4000, of course there is the additional insurance premuim of around $2000. To add insult to injury CASA has informed applicants that there is a 6 months delay in issuing Operators licences, presumably because of staffing inadequacies, if all the requirements are met in the application. In contrast, New Zealand’s CAA has no such requirements for UAV operators. Australia’s new Prime Minister has recently declared that the Government is one for 21 century ideas, perhaps CASA might follow this reasoning for UAV Operator requirements, instead of the current archaic reasoning and cost burden to UAV Operators.

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