[Peetwo]

Root of all regs Part 91 - Up for IOS comment??

Via Oz Flying: 

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CASR Part 91 contains the general operating rules for aircraft. (Steve Hitchen)

CASA calls for Part 91 Feedback
28 March 2018

The Civil Aviation Safety Authority (CASA) has opened consultation on the new drafts of CASR Part 91 and the Manual of Standards (MOS).

Part 91 covers the general operating and flight rules for aircraft, and is the foundation regulation that governs all aircraft operations.

The aim of the new part is to consolidate over 100 other documents into just two.

"Primarily, the existing rules will be retained and consolidated," CASA has stated. "However, there are a small number of new rules which are designed to enhance operational flexibility, enhance safety and increase compliance with International Civil Aviation Organization standards."

In opening the consultation, CASA has also acknowledged that CASR are complex and are not easy to read.

"We understand that our rules can be difficult to read," CASA says, "and our Aviation Safety Advisory Panel has told us we have more work to do to ensure clarity and simplicity. CASA will continue to look at ways to make the rules easier to read and understand before they are introduced."

The draft of CASR part 91 is over 100 pages long.

Feedback can be given via the CASA Consultation Hub before 29 April 2018.

Read more at http://www.australianflying.com.au/lates...G5866zk.99

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Some comments so far, via the PAIN email chain:

Via Stan: Always good for a laugh -  work creation in progress!!!!!
 

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Proposed new general and operating flight rules - have your say

CASA is seeking your feedback on new draft regulations relating to general operating and flight rules which will form the foundation for all aviation operations.

The draft rules are Part 91 of the Civil Aviation Safety Regulations 1998 (CASR) and its associated manual of standards (MOS). They replace more than one hundred documents—such as regulations, orders, supporting instruments and exemptions—combining them into just two documents.
Primarily, the existing rules will be retained and consolidated. However, there are a small number of new rules which are designed to enhance operational flexibility, enhance safety and increase compliance with International Civil Aviation Organization standards.

We are seeking feedback on the proposed changes through our Consultation Hub.

We understand that our rules can be difficult to read, and our Aviation Safety Advisory Panel has told us we have more work to do to ensure clarity and simplicity. CASA will continue to look at ways to make the rules easier to read and understand before they are introduced. But for now, we’ve tried to make it easier for you to have your say by highlighting the key issues that have changed.

The consultation will ask you questions on the proposed changes to Part 91 and MOS, but you don’t have to read the drafts in full. Each question will include the relevant section of the rules. Also, you can comment on as many or as few of these changes as you like, as well as provide general comments.

The consultation closes on 29 April 2018.

Want to know more? Register for our special webinar on proposed changes to the general operating and flight rules on 5 April, 6-7pm AEST.

Visit the CASA website.

Got a specific question? Email flightopsregs@casa.gov.au.

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&..

Folks,

I have already had a look at some of the sections, in my opinion the "consultation requests" are quite misleading, and designed for one answer.

For example, the proposal to legislate an "approach ban".

There is no evidence that the long standing (and actually reasonable) "rules" should change, the change reasons are theoretical, not based on Australian experience, and given our doubtful to non-existent met information, will be very limiting, particularly if an AWIS has to be accepted as a valid report. --- particular almost non-existent low cloud being reported as 8/8 at low levels.

That is just one example.

Cheers,

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...Thank you for your insights. For one, I see yet another of the never ending series, consultation ad nauseam;  I see with jaundiced eye. 


But it must be done even though usually a waste of time except we can use the information to cite as further proof of a make work salary factory that will never be finished rewriting the rules. 

Take the NZ or USA rules and be done with it? Not on your Nellie mate, would show to the world what a sick joke, the slow destruction of GA by Can’tberra, literally an out of control bureaucracy.

Out of control? An occasional Statement of Expectations written by CASA and Departmental minions mouthed dutifully by one of a continuous line of do nothing Ministers. CASA the independent Commonwealth body, supposedly governed by a Board that is noted for it’s invisibility. Board expenses alone? ...half a $million? probably much more?  A drop in the bucket.!

Sandy

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And from the related UP thread...

Flying Ted - CASA Part 91 Survey

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Has anyone completed the recent CASA survey? I noticed you can only give feedback if you are prepared to provide your personal details which I found somewhat odd.

There doesn't seem to be any option to find out what the questions are before you hand your details.

https://consultation.casa.gov.au/reg.../consultation/

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thorn bird - Given the requirement to name yourself, and given CAsA's history of retaliatory action against anyone who criticises them, it would be brave person who answered truthfully, if they considered the draft was anything else but perfect.
which maybe proves the old bureaucratic rule, "never call an enquiry unless you know the result"and certainly will skew the result of their inquiry.

But a quick skim through it I thought on the surface it didn't seem too bad, although there are a lot of hangman nooses in it along with a lot of 50 penalty points for very minor offences. More detailed scrutiny is required me-thinks.
What I would dearly like to know is how much of our money they pissed up against the wall producing it.

Will it actually improve safety in any way? Would simply adopting the US or NZ rules saved us a heap of money? would adopting those rule sets produced a better outcome? Are we getting bang for our buck?

Leave it to you guys to debate.

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LeadSled -

Quote:

----- on the surface it didn't seem too bad, although there are a lot of hangman nooses in it along with a lot of 50 penalty points for very minor offences
Thorn Bird,
That about sums it up, in my view there is huge scope for CASA to make life even more miserable.

Just for the hell of it, I took a squizz at Part 135, that is the doozy, as far as I can see it will put light charter out of business, such is the increase in paperwork. Airfield requirements will be one hell of a problem. It is not even clear to me that I can even still use a single engine piston at all, due forced landing field requirements.

One matter on which CASA HAS NOT consulted is on 135.135, passenger lists, strict liability 50pp.

The gender of each passenger must be recorded. I trust CASA will consult widely, including with the Australian Human Right Commission, to agree a definition of an an acceptable way for the operator/pilot to determine gender to the satisfaction of CASA.

The LBTIQUASSGF community will be watching.

Tootle pip!!

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thorn bird -  "definition of and an acceptable way for the operator/pilot to determine gender to the satisfaction of CASA."

Thats an easy one Leadie,

How do you sex a chromosome?

Take down its genes.

I believe on Quaintasses application form they ask for your gender identity
there is a box on the list for not assigned.

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LeadSled -

Quote:

I believe on Quaintasses application form they ask for your gender identity there is a box on the list for not assigned.

Thornbird,

On some CBA application forms, it has a list of six or so, the last one is "Prefer not to answer", how would you handle that for CASA at ~$10,800 a time, seeing as it is fully approved by the AHRC.

As harmonisation is all the go these days, CASA could harmonise with Transport Canada, which, as directed by overarching national legislation, has to recognise (as I recall) 23 genders, and in the best of CASA tradition, getting it wrong is a criminal offense.

Tootle pip!!

MTF...P2