[Peetwo]

Real world vs Fort Fumble fantasy land - 

The following is cribbed off social media, courtesy of Ben Wyndham AOPA Director and owner/operator of Airspeed Aviation :

Ben Wyndham

CASA's new Parts 119/121/135 Is going to destroy the small business sector of the Aviation industry. The Charter sector services all the small towns the big airlines don't.
Grab the latest issue of Australian Flying magazine for our view on new legislation delivering a massive increase in compliance costs that will wipe out a $1bn industry, decimate rural health and other public  services, all for zero improvement in safety.

IMO in one page BW nails down the real regulatory issues currently embuggering the small to medium size Charter and low capacity RPT operators...

Also note that on BW's LinkedIn page that there was an excellent comment, from another industry expert in his field, one Dan Parsons:

Dan Parsons - Airport Operations, Safety & Regulations Nerd

Hi Ben,

I can see in the article you have some concerns regarding the impact on Part 139 on small charter operators. Under the existing rules, there are obligations on aerodromes based on aircraft seating capacity regardless of whether RPT or charter. Under the current proposed amendments, CASA seems to moving away from treating RPT and Charter as the same thing. It looks to me like charter-only (eg mining) aerodromes in the future will be allowed to operate any sized aircraft with no specific aerodrome regulations.

I have to admit that I am probably on the other side of this argument to you (the aerodrome safety argument; not the general regulatory argument). I see distinctions between the charter and RPT, on safety grounds, as erroneous.

And I also don't see the obligations on the aerodrome operator (not the aircraft operator) as difficult. You just need someone on the ground to check the runway and surrounds before you land. CASA has never mandated a training standard or a syllabus or set licensing standards for this task. It just needs to meet the requirements of the aerodrome.

Anyway, as you continue to do the best for your sector, if you need any help on the 139 stuff, send me a message.

Cheers,

Dan

Dan of course once did a stint for the Big R-regulator CASA and therefore has a unique insight of how the aviation safety bureaucracy works...  

Hmm...wonder what Dan's take is on the bollocks HVH led ATSB YMEN DFO topcover report...   Ref: http://www.auntypru.com/forum/thread-10-...ml#pid9374

Also as an addendum to the Ben Wyndham Oz Flying 'Short Final' piece, Sandy forwarded the following email correspondence for general consumption:

Dear Sarah and friends, Members of Parliament,


The website ’Oziflyer’ offers pilot licence training in the USA for Australians as an economic alternative in spite of the unfavourable exchange rate, travel, accommodation and licence conversion costs.

This is where we have arrived at with our unique, very expensive and highly prescriptive aviation regulatory regime, its an unworkable regime. To make matters worse our regulations have been migrated inappropriately to the criminal code, and framed as strict liability. 

The present accelerating decline of General Aviation (GA) can only be arrested if Parliament decides to reform our aviation administration by harmonising with the successful rules of the USA Federal Aviation Agency. The need for change is urgent because the latest tranche of CASA  rules are making GA unsustainable. 

In the last thirty years we have lost hundreds of flying schools, charter operators and maintenance businesses throughout Australia. However myself, and many experienced colleagues, consider that there is still sufficient talent remaining to reform GA. This will serve to grow jobs, businesses and services, particularly crucial to regional Australia, and reverse the trend to importing airline pilots. 

Changing to a modern US styled regulatory regime will not only enhance our competitiveness, but will increase safety of flight through the adoption of proven career pathways leading to having talented and experienced personnel in key positions. 

Today’s market oriented society works competitively, there has to be incentive, GA must be made more accessible if we wish to stem the losses and turn around towards growth. Integrating with the US, easily the world’s aviation leader, will also make parts manufacturing and technical training, as well as pilot training, far more attractive on the world stage, and turns our low dollar value into a big export advantage. 

Kind Regards,

Sandy 

   
From the Ozi Flyer website: 

Don't waste time and money on your way to become a pilot!

FAA Certified instructors will accompany you all the way from your preparations in Australia until you obtain your FAA license in the United States and then help you convert it to an Australian license (CASA), all in half of the expenses you spent in Australia and in one-tenth of the time. A lifetime experience of endless landscapes, sights, adventures with top of line facilities, aircraft's and instructors only possible in the US!

We will accompany you in every step of the the way until you achieve your flying goals - this is what we do!

& for a cost comparison:

US vs AUS

CASA CONVERSION REQUIREMENTS  

15.6 Overseas Licence Conversion – Examination Requirements Candidates holding an overseas licence (not examination credits) from a country that is an ICAO Contracting State must, in all cases hold an ARN, and satisfy the specified prerequisites and have their qualifications assessed by a Flight Crew Licensing before attempting to sit the relevant theory examinations:

• For PPL(A) conversion, they must: − Hold a valid PPL(A) from an ICAO Contracting State without any restrictions; and − Meet the requirements for issue of an Australian PPL(A) based on overseas licence and experience.
• For CPL(A) conversion examination they must: − Hold a valid CPL(A) or ATPL(A) from an ICAO Contracting State without any restrictions; and − Meet the requirements for issue of an Australian CPL(A) based on overseas licence and experience; and − Pass the CPLA Overseas Conversion (aeroplane) (COSA) and CPL Human Factors (CHUF) examinations. Notes 1 & 2 Flight Crew Licensing Manual Version 10.0 - July 2017 Civil Aviation Safety Authority D17/261845 Uncontrolled when printed Page 122 of 159
• Instrument Rating Examination (IREX), they must: − Hold a valid pilot licence from an ICAO Contracting State without any restrictions; and − Have been approved by FCL to sit IREX. Note 1: In accordance with CASR 61.275, CASA must be satisfied that the overseas flight crew licence and/or ratings are at least equivalent to the Australian licence with that aircraft category rating. D17/261845 Uncontrolled when printed Page 123 of 159 An instrument rating is optional for any other licence, in which case this may be completed either as part of their licence conversion process or added at a later date. Where an applicant requires an instrument rating, they are required to pass the CASA IREX exam followed by the instrument rating flight test. To complete the instrument rating flight test, the applicant must hold either:

• An Australian licence (PPL or higher); or
• A Certificate of Validation (CoV).
• For ATPL(A) conversion examination they must: − Hold a valid ATPL(A) from an ICAO Contracting State without any restrictions; and − Meet the requirements for issue of an Australian ATPL(A) based on overseas licence and experience; and − Pass the ATPL Human Factors (AHUF) exam and the ATPL Overseas conversion (AOSA) examination Notes 1 & 2 and − Pass the CASA Instrument Rating Examination (IREX), if not previously passed.

Note: A pass in the IREX examination and an instrument rating flight test are required before the issue of an ATPL(A). Flight Crew Licensing Manual Version 10.0 - July 2017 Civil Aviation Safety Authority.

MTF...P2