[Peetwo]

Part 61 Tiger Team update - more exemptions??

Off CASA's new formatted website:

Licensing regulations: Latest news


17 March 2016

Instrument proficiency checks for single-pilot turbojet aeroplanes

As a result of discussions with the aviation community and further consideration of the equivalent requirements in the US under FAR 61.58 a new exemption (CASA EX41/16) has been published to relax the type specific instrument proficiency check (IPC) requirements for single-pilot turbojet aeroplanes from 12 months to 24 months. 
There is, however, still a requirement for the pilot to have completed an instrument proficiency check (IPC) in a single-pilot turbojet aeroplane covered by any type rating within the previous 12 months.

Prior to the introduction of Part 61, pilots conducting IFR operations as pilot-in-command were required to complete an instrument rating renewal in an aircraft covered by the instrument rating. For example, to operate a multi-engine aeroplane under the IFR, the pilot was required to have a current command (multi-engine aeroplane) grade of instrument rating. No type-specific renewals were required except where they needed to meet operational requirements. The rating authorised the holder to conduct a flight under the IFR in any multi-engine or single-engine aeroplane. The same principle applied to helicopters.

Part 61 introduced new requirements for pilots operating type-rated aircraft under the IFR. Those requirements meant:

• a pilot must have completed, within the previous 24 months, an IPC conducted in an aircraft covered by the type rating  and
  
• for single-pilot turbojet aeroplanes, a pilot must have completed, within the previous 12 months, an IPC in an aircraft covered by the type rating.
  
  

The additional requirement for single-pilot turbojet aeroplanes was based on the safety concerns associated with operating complex, high performance aeroplanes under the IFR.

Scenario
Stan is the holder of an instrument rating with a multi-engine aeroplane instrument endorsement as well as the IAP2D and IAP3D endorsements.  He has a C525(SP) type rating and regularly flies C525-CJ and C525A –CJ2 Citation Jets single pilot. As well, he has a EA500(SP) type rating and flies an Eclipse 500. Stan regularly flies each aircraft single-pilot under the IFR and plans to continue doing so.

The Rule:  to exercise the privileges of an aircraft type rating under the IFR, Stan must have a current instrument proficiency check (IPC) for the aircraft type rating.  If the aircraft is a single-pilot turbojet aeroplane, then the IPC must have been done within the previous 12 months; otherwise within the previous 24 months. The IPC must be done in an aircraft that is covered by the type rating.

For the C525(SP) type rating, he can do the IPC in either Citation Jet. If later on, he does the differences training and flies the C525-CJ1+, he could do the IPC in that aircraft too – they all count as being an IPC for the C525(SP) type rating.

Before the exemption: Since Stan was flying both types of Citation Jets and the Eclipse 500 single-pilot IFR, prior to the exemption he was required to successfully complete an IPC for the C525(SP) and the EA500(SP) type ratings within the previous 12 months. That meant Stan needed to successfully complete two single-pilot turbojet IPCs each year.

After the exemption: The exemption means Stan doesn’t need to successfully complete an IPC for the C525(SP) and EA500(SP) type ratings every 12 months.  However, he will need to successfully complete an IPC in one of the single-pilot turbojet aeroplanes covered by the type ratings every 12 months.  Like all other type rated aircraft, Stan will need to successfully complete an IPC for each type rating —for example, the C525(SP) and the EA500(SP)— every 24 months.

Stan would be able to continue to operate the Citation Jets and the Eclipse if he alternates his annual IPCs between the two type ratings. 
View the exemption.

Clear as mud??   Ok moving on I happened to notice on the UP that the AHIA have apparently made some progress on the Part61 ATPL(H) debacle:

AHIA and CASA meet to work on ATPL(H)


Helicopters Australasia. February 2016.

The troubled ATPL changes have been stalled for almost two years with only a handful of helicopter pilots being able to obtain an ATPL(H). Ray Cronin and CASA staff recently developed a flight test for the ATPL(H) which met the needs of the regulator and industry. It had been suggested a flight test should be less than two hours in a multi-engine helicopter.

The findings of their original work has been referred to the Part 61 Solutions Taskforce for implementation. The ATPL(H) flight test requirement is a controversial change to the Flight Crew Licensing legislation.

However, a recent incident where an ATPL(H) candidate was allegedly required to do flight test of almost four hours in a ME helicopter and a substantial ground test at great cost to the applicant, showed the proposed changes had been ignored. Thus an urgent need to bring this issue out into the open for public debate and rectification of the unworkable legislation.

Many issues need to be resolved, one stumbling block is the almost unachievable Multi-Crew Coordination Training qualification and the new flight test standards associated with the issue of an ATPL(H).

The significance of the work being done by Ray and CASA peers cannot be understated.

The current ATPL(H) shortages are best explained using data from CASA annual reports. In five years prior to Part 61 finally being introduced, number of ATPL(H) increased from 671 to 855 an increase of 184 or an average annual increase of 37. However, when the annual loss rate due to retirements, etc., is considered, a loss rate of 9% per annum must be met by new ATPL(H) graduates. (Plus fleet current growth of 2.5%).

The FISCAL year ending June 2014 showed 845 ATPL(H) and 124 graduates. An increase of 14% - a marked jump from the previous year, when 78 new licences were issued.

But the introduction of Part 61 showed the true nature of the problem, when after nine months of Part 61 transition prior to June 2015, ATPL(H) numbers had only increased by ten to 855. The issue of new licences dropped dramatically to only 44.

New ATPL(H) licences issued were 75% less when compared to last non-Part 61 FISCAL year.

What are predictions for June 2016?

Even ‘Blind Neddy’ could see at June 2015, we needed 98 graduates to replace the normal loss rate of 9% plus demands of the fleet growing at 2.5%. But only 44 were able to get past obstacles now in place due to the new Part 61! This creates a shortfall of 54. (Q. Are overseas aircrew with 457 visas a short-term solution, as proposed in a past CASA newsletter?)

Assuming the number of ATPL(H) licenses remains static at 855 this generates a demand for 98 plus the shortfall of 54 or around 150 graduates.

Unconfirmed reports suggest we may have only produced less than a dozen graduates; if true means a requirement (backlog) of say, 120 to 130 new ATPL(H) licenses exists.

Does it really matter? Many operators will state the problem has been exaggerated because most Australian heavy helicopter companies are owned by international corporations. The down turn in oil & gas extraction contracts means a surplus of qualified ATPL(H) holders able to fill our empty PIC seats using 457 visas.

Who suffers the most? But the real casualties are the training organisations providing theory, simulator, flying and staff training for the new Part 142 schools who have transitioned from the ‘old system’.

And the MCC quagmire? At present MCC legislation requires expensive Boeing 737 simulators, for helicopter pilot training. CRM professionals doubt any benefit of placing a helicopter pilot into a non-helicopter simulator; when after all the MCC course is focused on CRM factors - not the operation of a complex device.

In days of old, CRM facilitators would place chairs in a room to represent the layout of the operator’s helicopter; and verbally provide the CRM exercises to the students which were aligned to their typical mission profile. Now we see MCC courses costing $5,000 to $10,000 plus a flight test could cost probably $10,000 and a CASA FOI for several days.

Ray and his CASA associates are to be congratulated on progress to date and we all hope they are allowed to clean up other unworkable rules holding back our industry. More later ..........

AHIA

 
Hmm..."two steps forward, one step back"..comes to mind - wouldn't it be easier just to scrap the reg & start over?? Nah that'd be too bloody sensible
MTF...P2