The last MoS ramble.
Back to the grindstone, as I tried to explain in #45, part 61 is a conglomeration of theory, arbitrary judgement and what in someone’s mind, is the only way to manage ‘the subject’. It seems to me that somewhere between a clean simple start point and the unbelievable mess remaining at the end point, the ‘philosophy’ became corrupted. Whether this is by design, accident or malice aforethought is not within our remit for the exercise. One thing is certain, there is a definite under lying intent to distance the authority from any or all responsibility for anything.
If you start with a blank sheet of paper it’s probably best to define the ‘philosophy’ then outline the framework of the rule you are intending to make; then define the ‘goals’ i.e. work backwards from the end point.
For example, there are some conflicts and awkward areas existing within the ‘old’ rule set which need to be removed. This cannot be done by ‘re-phrasing’ and using the ‘old’ as the foundation of the new. Take CAO 40 for example it’s mess, to define with certainty how a ‘type’ rating or endorsement is to be issued is a long, complex, tedious process. How then to eliminate this problematic area; then you must look at recent experience – on type – and decide how best to ensure that the potential for accident is reduced. Look, you could sit all day with a team of ‘industry experts’ and hammer out the problem areas and within another day of hard work come up with a ‘cunning’ plan which would plug up the holes, but not create an expensive headache for the industry during transition. It’s not rocket science and there are some good models to use as a start point.
Part 61 is about ‘pilot licencing’ - how to obtain a licence from student through to ATPL. Once a basic licence is held, then come the add on parts. Aircraft, ratings, specialist roles etc. A couple of us started with a white board and sketched out the ‘family tree’ a road map if you will, from day one when you walk into a flight school to when you qualify with whichever licence and rating it was you set out to achieve. Then we placed the old ‘gates’ and junctions on the pathways to be followed. When you overlay those pathways with Part 61 MoS requirements; there are dead ends, double backs and one way roads which cannot be simply worked around.
In short, the best way forward, using part 61 is to define each element and treat it as a ‘module’. Say an Instrument rating – you need to start in the first ‘Schedule’ and pick your way through to the final applicable schedule and ‘cherry pick’ the bits which apply. I can tell you it’s a tedious, time consuming, confusing task. But, with patience and persistence you can emerge at the end of the tunnel with enough data to draft a COM section, dedicated to IR. The wheels only really come off when you operate a ‘mixed’ fleet; or you want to fly a variety of aircraft. It’s then the realisation of huge expense and a totally buggered up system emerges. In the old system ‘on type recent experience’ was used to mitigate risk but your IR ‘recent experience’ covered the instrument flying element. It was a flexible, practical, if not perfect solution for risk mitigation. Accident statistics completely support the ‘old’ system and the statistics from the US of A show that the even more ‘relaxed’ approach of the FAA has no detrimental effect. So why Australia has taken some very expensive, convoluted measures to reinvent the wheel and come up with a square version is a mystery. If you can make the effort, try to develop a ‘module’ from the MoS to suit your individual needs, you will be surprised, but not pleasantly. While you are ‘at it’ look carefully to see where, when and how your personal responsibility and that of whoever ‘signs’ you out lays. I intend to leave ‘reading and comprehending’ the MoS there for now. The next area to tackle is the ‘practical’ competency areas which are truly dreadful.
I do apologise for the rambling, but I believe it is essential that before you elect to qualify for anything – under part 61, you come to grips with the underlying ‘philosophy’ and aberrations within. Just to understand the ‘language’ used is a challenge, but if we are to be stuck with it, as it stands, you need to do the homework.
MTF when I have finished with the ‘competency’ tables – if I can stop laughing long enough to draft a sensible post.
Toot toot.
Back to the grindstone, as I tried to explain in #45, part 61 is a conglomeration of theory, arbitrary judgement and what in someone’s mind, is the only way to manage ‘the subject’. It seems to me that somewhere between a clean simple start point and the unbelievable mess remaining at the end point, the ‘philosophy’ became corrupted. Whether this is by design, accident or malice aforethought is not within our remit for the exercise. One thing is certain, there is a definite under lying intent to distance the authority from any or all responsibility for anything.
If you start with a blank sheet of paper it’s probably best to define the ‘philosophy’ then outline the framework of the rule you are intending to make; then define the ‘goals’ i.e. work backwards from the end point.
For example, there are some conflicts and awkward areas existing within the ‘old’ rule set which need to be removed. This cannot be done by ‘re-phrasing’ and using the ‘old’ as the foundation of the new. Take CAO 40 for example it’s mess, to define with certainty how a ‘type’ rating or endorsement is to be issued is a long, complex, tedious process. How then to eliminate this problematic area; then you must look at recent experience – on type – and decide how best to ensure that the potential for accident is reduced. Look, you could sit all day with a team of ‘industry experts’ and hammer out the problem areas and within another day of hard work come up with a ‘cunning’ plan which would plug up the holes, but not create an expensive headache for the industry during transition. It’s not rocket science and there are some good models to use as a start point.
Part 61 is about ‘pilot licencing’ - how to obtain a licence from student through to ATPL. Once a basic licence is held, then come the add on parts. Aircraft, ratings, specialist roles etc. A couple of us started with a white board and sketched out the ‘family tree’ a road map if you will, from day one when you walk into a flight school to when you qualify with whichever licence and rating it was you set out to achieve. Then we placed the old ‘gates’ and junctions on the pathways to be followed. When you overlay those pathways with Part 61 MoS requirements; there are dead ends, double backs and one way roads which cannot be simply worked around.
In short, the best way forward, using part 61 is to define each element and treat it as a ‘module’. Say an Instrument rating – you need to start in the first ‘Schedule’ and pick your way through to the final applicable schedule and ‘cherry pick’ the bits which apply. I can tell you it’s a tedious, time consuming, confusing task. But, with patience and persistence you can emerge at the end of the tunnel with enough data to draft a COM section, dedicated to IR. The wheels only really come off when you operate a ‘mixed’ fleet; or you want to fly a variety of aircraft. It’s then the realisation of huge expense and a totally buggered up system emerges. In the old system ‘on type recent experience’ was used to mitigate risk but your IR ‘recent experience’ covered the instrument flying element. It was a flexible, practical, if not perfect solution for risk mitigation. Accident statistics completely support the ‘old’ system and the statistics from the US of A show that the even more ‘relaxed’ approach of the FAA has no detrimental effect. So why Australia has taken some very expensive, convoluted measures to reinvent the wheel and come up with a square version is a mystery. If you can make the effort, try to develop a ‘module’ from the MoS to suit your individual needs, you will be surprised, but not pleasantly. While you are ‘at it’ look carefully to see where, when and how your personal responsibility and that of whoever ‘signs’ you out lays. I intend to leave ‘reading and comprehending’ the MoS there for now. The next area to tackle is the ‘practical’ competency areas which are truly dreadful.
I do apologise for the rambling, but I believe it is essential that before you elect to qualify for anything – under part 61, you come to grips with the underlying ‘philosophy’ and aberrations within. Just to understand the ‘language’ used is a challenge, but if we are to be stuck with it, as it stands, you need to do the homework.
MTF when I have finished with the ‘competency’ tables – if I can stop laughing long enough to draft a sensible post.
Toot toot.