[Peetwo]

2nd & 3rd ANON submission - 

From GA Inquiry webpage, via APH website: https://www.aph.gov.au/Parliamentary_Bus...ubmissions

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7 Name Withheld (PDF 66 KB) 

Recommendations:
1. All flight/theory schools are required to become Registered Training Organisations under ASQA
and deliver the syllabus consistent the relevant qualification.
2. PPL and CPL theory be examined by the flight school not by CASA.
3. The lock out period for exams be abolished.

CASA have set rules that all examinations, for the CPL subjects, must be completed within two (2)
years. Additional rules exist that should an exam be failed more than three (3) times, a lockout period
of three (3) months applies. In 2016 I passed four (4) of the seven (7) exams and two (2) failures, one
which was locked out for the three (3) month period. In 2018 during email correspondence below, it
was confirmed that my passes would expire but failures would remain;

(see submission)


Lockout periods are contrary to the principles of education and a practice not undertaken by any other
vocational or tertiary institution. How is this fair and encourage or promote learning?

It is accepted that decisions made by CASA are “reviewable” through an internal appeals process and
then through the Administrative Appeals Process. This is costly and may takes a significant time. For
the internal review, CASA charge a fee. Where I intended to appeal several questions in an exam,
which were not relevant to helicopter operations, I was advised the appeal would cost $1,120.00 with
no expectations of success leaving the AAT the next step.

In its current form, one person in charge of the exams is the judge, the jury and the sentencing authority.
The theory syllabus required and exams at both Private and Commercial level for both fixed and rotary
wing are grossly out if date and there seems no interest by CASA to make any improvements when
they are fully aware of the issues. I have spoken to the CASA CEO on two (2) occasions where he
acknowledged ‘an issue’ with no discernible outcome.

How are the CASA examination officers required to demonstrate currency in the subjects they’re setting
examinations for? I would suggest they haven’t been in the general aviation world for many years if at
all.

The permitted materials for the examinations are also not conducive to learning. CASA restrict the
number of tags that can be placed into textbooks, dividers and the what type of materials are allowed.
For example, students may self-print the regulations but not the ERSA or AIP and must purchase from
Air Services.

The costs of the theory element are rising with no common-sense reasoning. It is not surprising why
people undertake their commercial licence in USA and return to just complete the two (2) conversion
exams and a flight test.

4. CASAs power to overrule to require additional non-essential medical tests be removed.
5. The CASA part 5 project be advanced with defined timeframes set and delivered.

8 Name Withheld (PDF 133 KB) 

SUBMISSION ON CASA’S IMPACT ON AUSTRALIA’S GENERAL AVIATION INDUSTRY

This submission relates to the implementation and application of the Civil Aviation Safety Regulations
(CASR) Part 61 and the direct impact on myself as a helicopter pilot and the observations of how it has
impacted my peers.

The implementation of CASR Part 61 has had a significant financial and detrimental career impact to
me. To understand the extent of the impact allow me provide a summary of my aviation experience
to date. I am a commercial helicopter pilot, completing my training in 2010, I hold a CPL(H) and frozen
ATPL(H) with approximately 1,500 hours total time. I hold the following ratings and endorsements:

• Instructor rating (Grade 2 TE, Design Feature TE)
• Low level rating (sling endorsement)
• NVFR(H) rating

I have completed 300+ hours low level, 40+ hours sling, 200+ hours instructing and 400 hours gas
turbine engine.

I completed my instructor rating post CASR Part 61 implementation, which means that for every
endorsement or rating that I wish to instruct I now need to complete a syllabus of training with an
appropriately endorsed instructor, followed by a flight test with a flight examiner who holds instructor
examiner privileges. Under the “old” Civil Aviation Regulation (CAR) Part 5 licencing, I would be
approved to instruct any rating or endorsement that I myself held, without the need for these
additional training costs. What does this mean for me? Quite simply, a substantially increased and
crippling financial burden.

To understand the magnitude of this new financial burden, below I have provided a summary and
breakdown of the costs that I am now faced with that were not previously applicable:

I recently undertook an upgrade of my instructor rating to progress from Grade 3 instructor to Grade
2 instructor. I was required to complete a 3 hour course of training followed by a flight test. At the
same time, I also completed a Design Feature (DF) training endorsement to allow me to teach Gas
Turbine Engines (GTE). Fortunately, I was able to use the DF test sequence to also count as my Grade
2 upgrade test. A summary of these incurred costs are detailed below:

(see submission)


I am now also enrolled to complete further training to allow me to conduct training for additional
ratings and endorsements as follows:

(see submission)

As you can see, I am now required to invest an additional $14,220 to be able to instruct sequences
that under the former CAR 5 licencing system I would have been authorised to instruct without any
additional financial strain.

When we undertake our instructor rating, a large component of course is learning how to teach,
regardless of the flight sequence. Therefore, I suggest that we are appropriately trained already to
teach any sequence that we ourselves hold a rating or endorsement for.

I accept that change is part of life and I encourage making the aviation industry safer. However, my
question is, where is the safety case to support the implementation of these new industry and
individual crippling training requirements? Where are the accident statistics that support the need for
additional training to be able to instruct for each individual rating or endorsement?

What I have found is that the public is often under the false perception that as pilots we are attractively
remunerated and can/should bear the additional training cost. I can assure you that it is not the case.

The award rate for a helicopter pilot at present is approximately $55,000 plus superannuation. There
is no provision for any additional salary loading for holding an instructor rating as a helicopter pilot.
This is an extremely low wage when you consider the investment of circa $100,000 I have made to get
to this level of training.

As a Grade 2 instructor, I am paid a full time equivalent salary of $62,500 plus superannuation. From
this before tax salary, I am now required to find an additional $14,220 after tax to be able to instruct
additional ratings and endorsements, while also paying the bills to support a family.

I have anecdotal evidence to suggest that helicopter pilots are less likely to pursue a career instructing
as the cost to be able to conduct fundamental training is beyond their means. This is likely to have
long term negative consequences on the future of the helicopter industry with a likely shortage of
appropriately qualified instructors to train the next generation of pilots.

Please note this submission is based on my experience and observations of the helicopter industry
only and I make no assertions or assumptions on the impacts to the fixed wind sector.

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MTF...P2