Today from the AuntyPru Forum: CASA Roast
Kharon:
A new years resolution- broken.
There are 134 pages of the AMROBA Part 61, which is an excellent start as it is well within the reading, comprehension and absorbance levels of most. Moreover, it frames the ASRR opinion. – HERE –
Quote:The following converts FAR Part 61 into high level CASR Part 61 and all the detail promulgated in Sec 9(1)(c ) Aviation Safety Standards as per the ASRR Report.
Only had time for a quick skip through; but, I have downloaded the text and will study it further. It may not appeal to the pedantic, there are some rough patches and occasional ‘clumsy’ adaptations- however, in the main, it makes a whole lot more sense than the heavily patched up existing monster CASA keep trying to fix.
It is high time 61 was put out of it’s misery. As it stand now it’s almost nugatory anyway. Seriously, how can we have allowed a thing like that to exist, even more of a mystery is the collective minds that drafted it; what a tangled mess that must be: I digress. Part 61 now has so many necessary exemptions as to render it farcical, it is no longer a law, but a crippled vehicle which the owners must keep repairing to salve their egos.
OST bleats on about it be a ‘complex’ situation and how we could not possibly understand the delicacy and deep legal tenets involved; there is also the huge, insurmountable problem of English ‘law’ v American ‘law’ to consider. Etc. Then there’s ‘constitutional’ matters to ponder.
BOLLOCKS – the ducking Act is ‘unconstitutional’: this is a known fact; the other known fact is no one could afford to test that in court and so it stands as a testament to the base intent of those who manipulated it, to suit. Bit like the ‘airports’ imbroglio, where fast and loose interpretations allowed the current travesties to persist.
AMROBA’s Part 61 could be fine tuned, in short order by a couple of half smart legal types; hells bells I’d bet someone like Creampuff could knock it into shape between first and second coffee on a Sunday morning before doing the Times crossword.
It’s a risible notion that a ‘law’ can only be made to work by a constant stream of exemption to that law; how can that be ‘safely’ enforced. I’d pay to watch a trial where someone not exempt was prosecuted while others, who are ‘exempt’ continued on their merry way.
Will I stop there? I think so, I’m never quite sure if I’ll break out in hysterical laughter or start tearing the limbs off fluffy toys whenever I touch on 61. So, kettle on, breathe and endit.
Toot toot.
Peetwo:
AMROBA v Skidmore Part 61 – UDB!
The following is the history/& short insight into the ever evolving cancerous growth that is Part 61 which still threatens the sustainability of an industry that continues to be embuggered with regulatory red tape by a seemingly uncontrollable bureaucracy – :
Quote:CASR Part 61 – Flight crew licensing – History
Consultation updates in 2016
AC 61-05 v1.0 – Night VFR rating
This AC has been published.
12 Apr 2016
Draft AC 61-05 v1.0 – Night VFR rating
All comments should be sent to the project leader, Damien Fing by close of business 29 February 2016.
15 Feb 2016Consultation updates in 2015
FS 99/02 – CASR Part 61: Flight crew licensing
This project is now closed
Refer to the project closure notes for further information.
13 May 2015Consultation updates in 2014
Project FS 14/25 – Post-implementation review of the Flight Crew Licensing regulations – Part 61
Project approved.
3 Dec 2014
Project FS 03/01 – Periodic review and ongoing amendments to include endorsements for new types and models introduced to Australia
This project is now closed
Refer to the project closure notes for further information.
3 Dec 2014
Civil Aviation Order (Flight Crew Licensing) Repeal and Amendment Instrument 2014 (No. 1)
Civil Aviation Order made.
27 Aug 2014
Civil Aviation Legislation Amendment (Flight Crew Licensing) Regulation 2014
Regulation made.
21 Aug 2014
Draft AC 61-08 v1 – Teaching and assessing non-technical skills for single pilot operations
All comments should be sent to the Project Leader, Roger Crosthwaite by close of business 31 July 2014.
16 Jul 2014
Project OS 14/12 – Performance Based Navigation and Reduced Vertical Separation Minima regulatory review.
Project approved.
2 May 2014Consultation updates in 2013
Civil Aviation Legislation Amendment (Flight Crew Licensing and Other Matters) Regulation 2013
Regulation made.
12 Dec 2013
Civil Aviation Legislation Amendment (Flight Crew Licensing Suite) Regulation 2013
Regulation made.
21 Nov 2013
Consultation Draft for proposed amendments to the Flight Crew Licensing Suite
All comments should be submitted via the Project Leader, Mike Juelg by close of business Friday 25 October 2013.
4 Oct 2013
Consultation Draft for Part 61 Manual of Standards (MOS)
All comments should be submitted to the Project Leader via mos61@casa.gov.au by close of business 2 August 2013.
5 Jun 2013
Civil Aviation Legislation Amendment Regulation 2013 (No 1)
Regulation made.
14 Feb 2013Consultation updates in 2011
Consultation Draft – CASR Part 61 – Flight crew licensing
Comments on this consultation draft are to be submitted via the online form by close of business 3 February 2012.
17 Nov 2011Consultation updates in 2009
Project FS 06/02 – Multi-Crew Pilot Licensing (MPL)
This project is now closed.
6 Feb 2009Consultation updates in 2007
Multi-crew Pilot Licence (MPL) Project team provided with Draft CAR 5 amendment15 Aug 2007
Consultation updates in 2006
Project FS 06/02 titled Multi-crew Pilot Licence (MPL)
New multi-crew pilot licence project has been registered.
29 May 2006Consultation updates in 2004
Industry consultation briefings cancelled
The Part 61 and 141 MOS consultation briefings scheduled for 23 August through to 15 September have been cancelled.
19 Aug 2004Consultation updates in 2003
NPRM 0309FS – Flight Crew Licensing
NPRM 0309FS – Flight Crew Licensing, associated Annexes and Draft MOS Part 61 have been published. Your comments are invited by 29 September 2003.
18 Jul 2003
Project FS 03/01 – Periodic review and ongoing amendments to include endorsements for new types and models introduced to Australia
Project opened.
10 Jun 2003Consultation updates in 2000
DP 0005FS – Flight Crew Licensing Structure
DP 0005FS – Flight Crew Licensing Structure, CASR Part 61 is available for public comment. Comments close 29 January 2001.
30 Nov 2000Consultation updates in 1999
FS 99/02 – CASR Part 61: Flight crew licensingPart 61 legislative instruments:
Quote:Part 61 is contained within Volume II of the CASR (see link below), from page 101 to 423 i.e. 322 pages:
CASR Volume 2 : 675 pages
r 45.005-92.205
Part 61 Manual of Standards Instrument 2014 is 664 pages contained within 4 Volumes, see links and page count below:
Kharon – “..Part 61 now has so many necessary exemptions as to render it farcical, it is no longer a law, but a crippled vehicle which the owners must keep repairing to salve their egos…”
For reference – HERE – is the link for all the work done and in progress initiated by Oliver’s Part 61 Tiger Team. Within that there is an additional link – HERE – which takes you to a page of ‘legislative instruments’ that have been introduced since the original Part 61 first became law on 01 September 2014.
Now in reference to the “K” post here is the latest list of exemptions put in place to address the shortcomings and industry imposts identified so far within the Bible sized CASA Part 61… :
Quote:Exemptions
- Exemption – instrument proficiency checks for aircraft pilot type ratings (CASA EX93/16)
- Exemption – CASR Part 61 aircraft flight reviews (CASA EX97/16)
- Exemption – CASR Part 61 aeronautical knowledge examinations and two year completion period: CASA EX86/16
- Exemption – aeronautical experience for an NVIS rating or endorsement: CASA EX77/16
- Exemption – single-pilot turbojet aeroplane specific instrument proficiency check exemption: CASA EX41/16
- Exemption – from completion of an approved training course in multi-crew cooperation: CASA EX225/15
- Exemption – against ATPL flight test requirements: CASA EX222/15
- Exemption – Grade 3, 2 or 1 training endorsement (aeroplane) flight test: CASA EX219/15
- Exemption – from the flight instructor rating flight test: CASA EX218/15
- Exemption – from the pilot instructor rating aeronautical knowledge examination (PIRC): CASA EX215/15
- Exemption – from the spinning flight activity endorsement (FAE): CASA EX214/15
- Exemption – English language proficiency assessments: CASA EX146/15
- Exemption – logging of time in flight for co-pilots on single-pilot certificated aircraft: CASA EX116/15
- Exemption – Parts 141 and 142 – CASA approval of kinds of aircraft: CASA EX126/15
- Exemption – from certain low-level rating requirements: CASA 92/15
- Exemption – dual flight checks before solo flights by student pilots: CASA EX 78/15
- Exemption – aeronautical experience requirements for grant of commercial pilot licences – aeroplane category: CASA EX22/15
- Exemption – aerial application proficiency check and operator proficiency check (head of flight operations) – aeroplanes: CASA EX162/14
- Exemption – flight examiner rating for holders of CAO 82.0 check pilot approvals: CASA EX140/14
- Exemption – foreign cadet pilots taking flight test for a commercial pilot licence – class 1 medical certificate (replacement exemption September 2015): CASA EX156/15
- Exemption – aerial application rating and firefighting endorsement (replacement exemption August 2015)
- Exemption – of certain Cobham Aviation Services’ pilots from low-level rating requirement: CASA EX 130/14
Simply staggering when you consider that the above only includes the ‘exemptions’ so far and none of the additional pages of related amendments that also require more & more legislative instruments to be generated and tabled in parliament. The Attorney General’s department must have a separate section totally devoted to handling CASA generated legislative instruments – UDB!
MTF…P2 😉