[Peetwo]

Only one line worthy of note in the CASA fudge feast;-


* Major provider only. Second provider has had has nil accidents.

Interesting little side bar ain’t it  - and peculiar use of the English language.\

P2 OBS: Interesting point you make "K" when you consider a couple of bibs and bobs from the history of the attempted embuggerance of Angel Flight by Fort Fumble...

Ref: DP 1317 OS https://www.casa.gov.au/file/144061/down...n=VPWEGeMX

2.1 Preliminary consultation

On 25 August 2008, CASA met with representatives of Angel Flight Australia, a charity that coordinates non-emergency flights to assist rural Australians access city medical services. CASA briefed Angel Flight representatives about the proposed CASR operational regulations suite and sought their input. Future impact upon Angel Flight's established practice was discussed, as was CASA’s intent to consult publicly on how such flights might be regulated in future.

On 11 January 2014, CASA met with representatives of the Little Wings group, a charity that provides non-emergency air travel support for children with cancer, and their families. The representatives outlined their organisation's structure, procedures and plans. CASA outlined the consultation process and discussed in general terms, options that may be included in any consultation process.

Now let's FFWD to page 15...  

For this reason, CASA considers that a full AOC option is not required. Equally, CASA does not regard a continuation of the status quo (i.e. use of any aircraft, any pilot licence etc.) to be sound safety regulation.

Option 5—establishment of an ASAAO—is CASA's preferred method of meeting safety management goals within reasonable regulatory constraints. This option would allow the industry sector (community service flights) to address safety appropriately, once a self-administering organisation receives CASA approval.

 
And this is the response from Little Wings to the 18 December 2018 consultation paper - via HOLT:

Little Wings is supportive of any increase in the safety of flight operations in the community services flights area. We are also very aware and concerned about placing an additional financial burden on both volunteer flight crew and volunteer organisations assisting with the coordination of these flights. To this effect we note the following response to CASA’s recommendations: Medical Requirements Little Wings supports a minimum of a Class 2 medical certificate: Little Wings currently requires a Class 1 for all volunteer pilots. Aeronautical experience. One landing in 30 days: –. We currently operate to 90 days as required by current legislation. Little Wings understands the premise of this requirement but even though we feel that this could potentially impact our operations, we would be more supportive of a minimum of 60 days for one landing. Time on type: Little Wings is supportive of the time on type requirement. Our current requirements are minimum of 10 hours on type but on average most flight crew will fly 20 – 25 hours under supervision. Each CSF to be recorded in pilots logbook: Currently Little Wings records all flight and duty details for each pilots CSF flights. In regard to PPL pilots: Little Wings only uses CPL pilots so will not be affected by this section. Aircraft Operational Limitations. Little Wings supports all details outlined by CASA for Aircraft operational limitations. Aircraft certification and maintenance requirements. Little Wings supports the concept of increasing aircraft maintenance standards for CFS operations. Little Wings supports the aircraft being maintained under an approved system of maintenance or CASA schedule 5 with 100 hour or 12 monthly inspections whichever occurs first. Little Wings does not support the requirement for the engines to be required to be maintained to AD/ENG/4,AD/ENG/5. Little Wings believes this would create a significant financial burden with little to no safety increase, resulting in less opportunity to conduct flights.

 
Hmm...a bit smelly me thinks - 

Additional AQON:

Q/126 from QLD Liberal Senator Amanda Stoker:

Question on notice no. 126
Portfolio question number: 126
2018-19 Additional estimates
Rural and Regional Affairs and Transport Committee, Infrastructure, Regional
Development and Cities Portfolio

Senator Amanda Stoker: asked the Civil Aviation Safety Authority on 18 February
2019—

1. How does CASA respond to Angel Flight's claim that CASA has not consulted on
the new requirements for community service flights (CSFs) with them? What
response did CASA get from Angel Flight during its consultation process in January?
How does CASA see that the new conditions it has introduced will affect Angel
Flight operations and the thousands of rural and regional patients who rely on Angel
Flight services every year? How does CASA respond to Angel Flight's claim that the
new requirements will force up to 80% of its pilots to withdraw from volunteering for
them and affect their viability? How do you respond to claims the new requirements
are devoid of a safety case and devoid of a risk assessment to justify them? How will
the new requirements reduce the risk of fatal accidents for CSFs in future? What
changes has the US regulator, the FAA (Federal Aviation Administration) ,
introduced in response to similar issues the US has had with CSF safety? How has
Angel Flight responded to the FAA's changes, if any? What is the reasoning behind
CASA's decision to ban helicopters from flying for Angel Flight (despite there being
no prior accidents involving helicopters) ? How will this affect people in flooded rural
communities who may need help getting out to medical appointments when airfields
are flooded? When making regulatory changes, does CASA have regard to the impact
of those changes upon the willingness and availability of individuals to provide
volunteer flight services to isolated rural and regional Australians, and the
consequences for their access to health care? If the answer to question 10 is no, why
not?

Answer —
1. Angel Flight was alerted to the general content of proposed minimum safety
standards for community service flights on 28 November 2018, prior to the proposed
standards being released for public consultation. The consultation process was
conducted over six weeks, from 18 December 2018 to 31 January 2019. #1 Over 220
responses were received, including 115 from people who said they were pilots who
had flown community service flights. Both community service flights (CSFs)
providers made submissions as part of this process.
#1 So they gave a AF a heads up and then decided to run the consultation period over the Xmas/New Year holidays 4 days before they were shut for business for 2 weeks? - Fair and reasonable consultation my ASS...
2. At a meeting between the Civil Aviation Safety Authority (CASA) and Angel
Flight on 18 January 2019, Angel Flight verbally indicated that they opposed all of
the proposed minimum safety standards. At the meeting CASA requested that Angel
Flight formally respond to the consultation process indicating whether any of the
proposed changes would be acceptable in part or in full. A formal response to the
consultation was received from Angel Flight on 24 January 2019, which included
permission for CASA to publish the response. The response is available at
www.consultation.casa.gov.au.

3&4 CASA considers that the new minimum standards will improve the safety of
community service flights #2 without having an adverse impact on the majority of the
flights organised by Angel Flight. Information provided by Angel Flight about the
demographics of the volunteer pilots who conduct flights they organise to the
Australian Transport Safety Bureau (ATSB) in 2013 indicated that most would
significantly exceed the new minimum experience requirements:

• average Pilot-in-Command hours were about 2400 – the new minimum standard is
250
• 64 per cent of pilots held an instrument rating – now required for flights at night
• 39 per cent held a commercial pilot licence or higher – exempt from the total hour
requirement.The maintenance requirement may require the operator of an aircraft
maintained in the private category to conduct an additional periodic inspection
slightly earlier than normally required for private category aircraft if they fly more
100 hours before 12 months has elapsed since the last inspection. The 100 hours is
double the private aircraft annual average utilisation of 50 hours per year and is only
exceeded by a relatively small proportion of the aircraft fleet that is only used for
private purposes.
#2 Note the complete dodge of the intent of the QON? 

5. CASA statistical analysis and rationale for the key provisions of the instrument are
included in responses to Committee Question Numbers 127 and 128.

6. The new minimum safety standards are intended to reduce the likelihood of further
fatal accidents involving community service flights. CASA reviews the findings of
investigations conducted by the ATSB and also considers what pro-active steps can
be taken based on available information and consistent with a responsible application
of the precautionary principle. ps apparently only when it suits them - see HERE.

Most community service flights are conducted by a single pilot in a small aircraft,
flying long distances from regional and remote towns to the cities, carrying people
with serious medical conditions. This places significant responsibility and sometimes
considerable pressure on the pilot.

The new standards require minimum experience levels for pilots and a requirement to
have recently flown an aircraft of a similar type. Aircraft that fly more than double the
average hours of a private aircraft in a year are required to have a maintenance
inspection.

Under the new standards, community service flights can no longer be conducted
under the night visual flight rules. Night flights must be conducted under the
instrument flight rules. The fatal accident in Victoria involving a flight organised by
Angel Flight occurred after sunset, within a few minutes of last light and in poor
weather. #3  

7. In 2007 and 2008 the USA had 4 fatal charitable medical flight fatal accidents. In
2010, after investigation of these fatal accidents the National Transportation Safety
Board released a number of safety recommendations. In 2013 the Federal Aviation
Administration (FAA) introduced a Policy Clarification on Charitable Medical Flights
in 2013. Around this time the charitable medical flight organisations also established
additional minimum requirements.

The FAA Notice of Policy specifies the kinds of conditions that can and will be
imposed in any given case on the exemptions under which charitable medical flights
are conducted, and the exemptions themselves specify the particular conditions
applying in each instance.

The exemptions given by the FAA allow private pilots conducting charitable medical
flights to be reimbursed for their fuel and related costs without turning their activities
into a commercial operation (an operation for hire and reward). Australian private
pilots conducting community service flights are similarly treated.#4

8. Most organisations providing community service flights in the USA have
voluntarily imposed minimum safety standards. A review of US Angel Flight
organisations indicates that six out of seven organisations have minimum
requirements that meet or exceed the new standard introduced by CASA.

9. Based on the information available to CASA, helicopters have rarely been used for
CSFs in Australia. During public consultation of the proposed standards, only one
respondent indicated that they had used a helicopter for a community service flight
and that respondent also owned and used an aeroplane. Due to very limited use, they
were not provided for in the instrument rather than intentionally being banned.
However, after further consideration, an amendment is being prepared that would
allow the use of helicopters.

10. CASA takes such matters into account as part of its public consultation processes,
including that conducted for CSF. Feedback was received during consultation from
115 people who said they were a pilot who had flown a community service flight. A
number of changes were made to the original proposal based on feedback received.
CASA has also developed a concise fact sheet for pilots considering volunteering
aimed at making it easier to understand the new requirements and encourage
participation of pilots.

11. N/A

#3 & #4 Again the real White Elephant in the room makes an appearance i.e 24+ year NVFR identified safety issue - see HERE . It is interesting to note the USA/NTSB references would appear to have been plucked directly from the 2011 ATSB report

Hmm...wonder why, the patron Saint of Oz Aviation Safety, St Carmody and his Iron Ring cadre completely missed referencing this part of that ATSB report - 

United States occurrences

Safety Alert In March 2013 the United States (US) National Transportation Safety Board (NTSB) issued Safety Alert SA-020 Reduced Visual References Require Vigilance. This alert highlighted that about two thirds of US general aviation accidents in reduced visibility weather conditions are fatal, and typically involve pilot disorientation or controlled flight into terrain. The NTSB observed that even in visual conditions, the combination of flight at night with limited ground lighting and therefore ground references could be problematic. A number of common accident scenarios in conditions with limited ground reference were provided in the alert and strategies for pilots to manage that risk were suggested. Of note in the context of the accident near Horsham on 15 August 2011, the NTSB highlighted that: Remote areas with limited ground lighting provide limited visual references [sic] cues for pilots, which can be disorienting… and that pilots should: Consider following instrument procedures if you are rated or avoiding areas with limited ground lighting (such as remote or mountainous areas) if you are not...

  
Gotta wonder why CASA are suddenly having an epiphany on certain selective ATSB reports six years after the report was made public and 9 years after the NTSB safety recommendations were available to be disseminated by the rest of the world?? 

Q/128 from Sic'em Rex:

Question on notice no. 128

Portfolio question number: 128
2018-19 Additional estimates
Rural and Regional Affairs and Transport Committee, Infrastructure, Regional
Development and Cities Portfolio

Senator Rex Patrick: asked the Civil Aviation Safety Authority on 22 February 2019
—
Senator PATRICK: You're going to table some statistics so that they can be reviewed
by people-I'm sure Angel Flight will have their interest in it, we'll have our interest in
it and so forth-that grounds your claim here in this committee that they are less safe. I
would like, as you're doing that, where there is some problem that has occurred in
your analysis, if you would perhaps annotate next to it and say, 'Our new regulation
would have prevented that from occurring.' Mr Carmody: As I've said, in the broadand
I understand that what you've requested- Senator PATRICK: So you're happy to
do that? Mr Carmody: this is about raising the threshold. I would prefer to ensure that
the Australian Transport Safety Bureau's accident investigation report, which would
be much more thorough than the work we do in this space, is out at the same time.
Senator PATRICK: But you've said you have done statistics. Mr Carmody: We've
done our statistics, but the issue of maintenance is less of a statistical issue, if I may.
Private aircraft fly approximately 50 hours a year-that's all. So there is a threshold that
says every 12 months you'll have your aircraft- Senator PATRICK: Hang on, that
average includes those like me, who don't fly very often, and those who are quite
experienced. Mr Carmody: Quite, but the BITRE standard says that private aircraft fly
an average of 50 hours a year. It's 50, isn't it? Mr Monahan: Yes. Mr Carmody: When
we consider these community service flight activities, we categorise them as private
activities, but they're on the cusp of commercial activities in the sense that the reality
is that people are receiving funding payment for them. So, in a technical sense, they're
on the cusp. We put them in the private category because we know that, and we also
know that the aircraft aren't operated that much. When you start to move into layers
above these private activities, there is more complexity and there are more
requirements. There is more maintenance and more training as you move up from the
private to the commercial, all the way up to regular public transport; we add more and
more layers. With the case of something like the 100-hour maintenance issue, we did
propose a much more stringent maintenance regime. We listened to what was said in
the feedback and we reduced that maintenance regime significantly in the final
instrument. Senator PATRICK: That's the equivalent of saying, 'We could have been
even worse, but we're not.' Mr Carmody: I suppose what I'm saying- Senator
PATRICK: I want to know: how does it make it safer? Mr Carmody: What I'm saying
is we consulted and we listened to people who said those maintenance requirements
would be too onerous. It makes it safer because it catches the out-riders. The people
who are caught above 100 hours are the ones I want to catch. The people who are
flying their aircraft for 300 hours are the ones I want to catch because they're using
their aircraft a lot more than the average. They are the ones-and there won't be very
many of them- Senator PATRICK: But they're going to be more experienced. Mr
Carmody: This is not about experience; your question is about maintenance. It's how
often the aircraft is used. So the 100 hours and the 12 months is pretty much standard.
Senator PATRICK: It's the same pilot, the same aircraft- ACTING CHAIR: I'm not
sure how the aircraft becomes less safe if I jump in as a community service passenger
versus someone who has just met Senator Patrick. Mr Carmody: What I'm saying is
it's statistically less safe because there are more accidents and incidents in that sector
brokered by people than there are in private flying. Senator PATRICK: You have to
ground that properly with evidence. Mr Carmody: Certainly. Senator PATRICK: Can
I just tell you the strategy that my party has done in terms of lodging a disallowance.
We have lodged a disallowance in the House. It's really just to send a signal so that
people can be prepared and present their case. I will do the same in the Senate when it
returns on 2 April. I don't want to disallow something, but you've got to make your
case. You are the safety authority. You are introducing a regulation that you say is
centred on safety. I can't quite see it as it stands. You have now basically said it comes
down to the statistics. You are concerned that Angel Flight have more incidents than
private pilots. Mr Carmody: Than private flying. Senator PATRICK: I want to see
those statistics and see how these regulations would have altered those statistics to get
them back to the place we are with normal pilots' licences. ... Senator PATRICK: let's
look at this again in six weeks time with your evidence on the table and with the
evidence of anyone else who wants to make a contribution. Mr Carmody: That's fine.
I understand everything you've said...

Answer —
The statistical basis underpinning the Civil Aviation Safety Authority’s (CASA)
decision is included in the response to Committee Question Number 127. The
intention of the instrument placing conditions on the licences of pilots undertaking
Community Service Flights (CSF) that the new minimum standards will improve the
safety of those flights without having an adverse impact on the majority of their
operations. It does this by including certain measures which are known to improve
safety outcomes. These include:

Aeronautical and recency experience requirements
• A number of provisions specify minimum experience including at least:

o 400 hours of flight time
o 250 hours as Pilot-in-Command
o 10 hours of flight under Visual Flight Rules
o 20 hours of flight under Instrument Flight Rules
o 25 hours as Pilot-in-Command of a multi-engine aeroplane

These measures are in keeping with international best practice and supported by
information used by similar national aviation authorities. From 400 hours total time,
the mishap rates for private pilots begin a steady decrease to the lowest rate at
approximately 2000 hours of total time. Recency and experience combined provide a
layered defence to enable pilots to manage more complex situations. The
requirements ensure that that no pilot conducts a CSF flight without a minimum of
experience in that type of aircraft or under those conditions.
• The provision for conducting a landing within 30 days on type reflects the fact that
landing related mishaps are the second largest category of mishaps globally. This
provision ensures that a pilot has recency in this critical phase of flight prior to
engaging in what CASA considers to be more demanding and complex CSF
operations.

Operational requirements
• Night visual flight rules (NVFR) were a factor in the first fatal accident involving an
Angel Flight pilot. The ban on NVFRs reflects the risks involved in this activity. Such
flights must occur under instrument flight rules.

Notification requirements
• At present, CSF are indistinguishable from private flights. The notification
requirements will provide important data to allow CASA to conduct data-driven
evaluations and decision making. It will also assist pilots in making accurate reporting
of their flight activity.

Maintenance
• These provision for maintenance at 100 hours or 12 months is an internationally
recognised preventative measure against the few aircraft that may fly well past 100
hours in 12 months. These maintenance requirements may require the operator of an
aircraft maintained in the private category to conduct an additional periodic inspection
slightly earlier than normally required for private category aircraft if they fly more
100 hours before 12 months has elapsed since the last inspection. The 100 hour figure
is double the annual average utilisation of 50 hours per year for private aircraft and is
only required by a relatively small proportion of the private fleet.

Hmmm....much, much MTF me thinks??...P2