Warning: long post may follow this warning – perhaps.
CASR_61. Why me?
"Crack on" is the word, "stop messing about and get into it". "But, but, it's out, gone, consigned to the tip; history" I protest. The grim faces around me say it all – we may yet be stuck with it. Longingly, with a sigh I glance at the neat pile of NZ, PNG and FAA rules; but needs must when the devil drives. And so it begins:- our casual stroll through the part 61 mind-field. Every journey has a starting point, some philosophy has it that a journey begins in the mind, a single thought - the decision to move in a direction. So, where does a Part 61 virgin begin such a journey? There are rumours and pub talk of 'advisory' material being available; so I decide to start there.
Innocently, I down load the quite easily found 'advisory' documents from the dreadful CASA web site, (which is worth a separate thread of its very own – Yuk). Warning- you will need the 'advisory' doc – HERE – to untangle my scribble. Enjoy.
With the 'explanatory' series safely filed, I begin. As I am due for an IR renewal, I start there. I note a modest 1/16 in the page counter and as the document is full of large colourful pictures (of no practical value whatsoever), I reckon, with a bit of luck, there will be about five pages of information most of which will be guff. One coffee job I think as I wade in.
Page 1: "Learn about new rules for instrument rating – in effect since September 01, 2014" says line one. My heart sinks, right there, however, as we are here to 'learn' anyway, as it were, I press on. Through the glaringly obvious pointless introductory piffle which says – if you want to operate under the IFR, then you need an instrument rating.
So one may assume that to conduct operations under the IFR, then a rating or licence must be held. Which is it? the sentence above reminds me of those instructions for assembling various items where the translation is grammatically literal:
Now I have always thought that the IR was to authorise flight in non visual conditions, using all the instruments. The implication in the drivel above is that you are limited in the instruments you use for flight. "Use the AH Bloggs" – Cant' skipper, not qualified on AH". Of course that's rubbish, but whoever wrote the guidance advice, clearly has only got a tentative hold on the subject matter. Here I am, page one, and already 'doubt' as to the value of the following information is creeping in. I am left to assume what it means to say. Now it seems we now must refer to Sub part 61 M for information. So begins the reading list and a glimmer of hope for clarity. (MTF).
So with a click – page 2 arrives:- more pointless pictures and night VFR first up.
Here again, questions left begging answers; can I as an IFR pilot conduct operations under the NVMC rules, is the NVMC rule set still valid; or, is it all now under the IFR – only at night. Perhaps it will be explained later. I stagger confused into the 'changes' paragraph, then this:-
Now read it again, and once again. OK, one instrument rating; but only valid sometimes, except if you are a PIFR, which is different again (we think). Six different 'aircraft endorsements' essentially means (as you read on) that there are, potentially (reality yet to be decided) potentially six separate IR to keep current. Your 747 command IR under CAR 217 (or similar) is still valid despite the fact that you failed a FPC in your mates Baron last week. You can quite legally saddle up the 747 and chuff off to LAX in the middle of a dark and stormy, but you cannot be trusted to nip up the way for lunch in the B58, unless you have 'demonstrated competency in the type (class). But you may, provided you have passed the flight test for the Metro do the odd moonlight run for the local freight company, but cannot take the C 172 IFR to the beach for a spot of fishing – unless your IR for the '172' class is valid. This of course may, or may not be the case if you operate a Cessna 510 single pilot or a Westwind multi crew. Which, stand alone is bad enough, but then add this:-
Why do they insist on multiples – its an ATPL singular or a MPL (singular) not ATPLs – I only have one off. Anyway, it looks like only those with the impossible to obtain ATPL may avoid holding 'multiple IR' ( I think). Which takes us into recency.
Well it's all good news, 90 days and ninety nights between prescriptions (unless you operate single pilot) which is, regrettably different again. We shall get to the SP rules in due course – I hope. The following requirement for an Instrument Proficiency Check (IPC) is deceptively simple; 24 months for 'type' rated aircraft unless you operate a type rated aircraft single pilot, then it's 12 months between IPC – cool you say. Not so, what if you work for a mixed fleet operator; or operate free lance; or, even fly a Dash for a day job and do the odd charter for your old boss in a Citation. Your freedom to operate 'independently' has just been further and severely restricted and the fiscal burden on someone increased. So, the Virgin 738 pilot with no desire to do any other flying is out of jail, on a 217 cake walk and in no trouble whatsoever. None of the single fleet operators are, except when 142 or 141 creeps in, then it will be off overseas for training and checking – at great expense which will be off-loaded onto the passenger ticket price. Aye well, it will suit some, but it's a clumsy, micro management system which achieves very little in the way of improved risk mitigation and gives the 'authority' more room to meddle, should they decide to. But I digress.
The navigation system blurb is simply a waste of words, stating the obvious while illustrating nothing. Click:- Page 3:
Don't you just love it –the simple elegance, ease of operation, flexible, rational and of course completely safe now that an instrument rating is no longer a thing which allows flight in instrument conditions'. Now it's flight in IMC but only in a specific airframe, you see an instrument approach in a light jet is very, very different to one conducted in a high performance single. I expect the clouds are different or something. Are we not mixing our ability to operate an aircraft in IMC with the ability to operate the aircraft itself. This part takes us into the first of many junctions where several 'disciplines' are melded into one conglomerate. A place where the alchemist attempts to turn apples into oranges and ends up with a raspberry, gaining little in the way of risk mitigation for great expense and trouble.
I quite like the notion of redefining the 'type' of instrument approach, don't you. I mean the 'old' definitions – precision approach (with vertical guidance) an 'non-precision (without vertical guidance) were just so clumsy. Lord spare me. Then we discover that using a pointer to determine if you are on (or off) track is so vastly different to using a course deviation 'bar' it requires yet another, separate, expensive 'endorsement'. Monday you fly old 'Charlie' with a fixed card pointer VOR; Tuesday it's 'Delta' with a new fangled CDI – of course you need a separate 'endorsement' you silly boy; vast are the differences.
Click page 4:- Self explanatory, written for intellectually challenged water melons explaining that obviously these changes are operational required for 'safety. Not risk mitigation you understand, but safety. Read on.
Click page 5: Aye, well the picture is great and I feel so much better educated now that it has been explained 'properly', we in the kindergarten have greatly benefited from this information.
Click page 6:- Circling approach : a simple no changes would have saved some ink. VOR does not qualify for ADF, OK we can live with that. Enter the Mos and the IAP 2 and IAP 3 units of competency within schedule 2. NFI what they are, but no doubt we shall discover that later in the piece. (not today).
2D and 3D - Six seems to be a favourite number, now we have identified , but not qualified something which has never been done before, Non precision and precision approach paths (but with and without those terribly tricky pointer things).
Click page 7:- Highly illuminating graphics, a table which needs some assistance with the English language and those damned tricky indicator whatchmacallums, and a note
The crystal clear resolution of lingering doubt may be contained within that epistle. May the force be with you, maybe, if it's Tuesday or maybe Wednesday – Maybe I don't know. May I ask a grown up. Who writes this rubbish?
Click page 8:- Oh, I know, I know, that's an aircraft right? however, maybe.
Click page 9:- Here we have the 'Wendy' and 'Don' show, which is a bad example of the FAQ system which never quite works, does it.
Click page 10:- another aircraft piccy over the top of some fairly interesting implications; I read on holding my breath.
Click page 11:- The 'Irene' and 'Patrick' show; Irene seems to be OK, but poor old Patrick, cut his throat instead of brushing his teeth, so confused and confounded was he. This so much safer than a once a year check of 'instrument flight proficiency', more fun too and look at those costs spiralling out of control. Stellar stuff.
Click page 12:- The sanity page, industry responsible 217 system saves the day. The short answer to escape the bull-pooh preceding. N.B. When the responsibility is firmly on the operators shoulders; Poof suddenly it' s all too easy. What's that – no 217 well it's off to the local flight school for you mate; what do you mean there ain't one? Oh, too hard to meet the new requirements eh; well NZ is closer than the US of A, try there.
Click page 13: - Here we meet 'Connie' happily taking her ATR into scheduled all weather services, but can't fly the Comanche for nuts. What's wrong with this picture? either the CAR 217 is 'ticking and flicking' or the outside examiner is too tough; or, you nut it out for a Sunday puzzle. There are six fatal assumptions made for Connie. Hint? well in either event CASA will not be responsible.
Click page 14:- Flight school commercial – ignore.
Click page 15:- I will stop here and find another coffee. Tomorrow we may venture into the tangled world of the MoS and the regulation as writ. There is a list of rules provided on page 16, but first we meet the MoS. I love this these bits:-
FCOL if I believe I am fit, and by extension, deemed capable of assessing this as fact, then I may dispense with my medical examiner. The reason we have independent assessment is because ?
I mean seriously who of sound mind would make such statement; probably some one who has self assessed and determined competency.
Enough – coffee and perhaps a nice lie down.
Toot toot;
Whistles up dogs and buggers off, far from the study, to where water murmurs over rock, the air is clear, sanity prevails and part 61 is on hold, for a little while.
CASR_61. Why me?
Quote:The difficulty lies not so much in developing new ideas as in escaping from old ones.
John Maynard Keynes.
"Crack on" is the word, "stop messing about and get into it". "But, but, it's out, gone, consigned to the tip; history" I protest. The grim faces around me say it all – we may yet be stuck with it. Longingly, with a sigh I glance at the neat pile of NZ, PNG and FAA rules; but needs must when the devil drives. And so it begins:- our casual stroll through the part 61 mind-field. Every journey has a starting point, some philosophy has it that a journey begins in the mind, a single thought - the decision to move in a direction. So, where does a Part 61 virgin begin such a journey? There are rumours and pub talk of 'advisory' material being available; so I decide to start there.
Innocently, I down load the quite easily found 'advisory' documents from the dreadful CASA web site, (which is worth a separate thread of its very own – Yuk). Warning- you will need the 'advisory' doc – HERE – to untangle my scribble. Enjoy.
With the 'explanatory' series safely filed, I begin. As I am due for an IR renewal, I start there. I note a modest 1/16 in the page counter and as the document is full of large colourful pictures (of no practical value whatsoever), I reckon, with a bit of luck, there will be about five pages of information most of which will be guff. One coffee job I think as I wade in.
Page 1: "Learn about new rules for instrument rating – in effect since September 01, 2014" says line one. My heart sinks, right there, however, as we are here to 'learn' anyway, as it were, I press on. Through the glaringly obvious pointless introductory piffle which says – if you want to operate under the IFR, then you need an instrument rating.
Quote:.....Pilots who hold any of the following Part 61 licences and ratings are authorised to conduct an IFR operation.
So one may assume that to conduct operations under the IFR, then a rating or licence must be held. Which is it? the sentence above reminds me of those instructions for assembling various items where the translation is grammatically literal:
Quote:....However, instrument-rated pilots are limited on the IFR operations they may conduct, depending on the instrument endorsements they hold.
Now I have always thought that the IR was to authorise flight in non visual conditions, using all the instruments. The implication in the drivel above is that you are limited in the instruments you use for flight. "Use the AH Bloggs" – Cant' skipper, not qualified on AH". Of course that's rubbish, but whoever wrote the guidance advice, clearly has only got a tentative hold on the subject matter. Here I am, page one, and already 'doubt' as to the value of the following information is creeping in. I am left to assume what it means to say. Now it seems we now must refer to Sub part 61 M for information. So begins the reading list and a glimmer of hope for clarity. (MTF).
So with a click – page 2 arrives:- more pointless pictures and night VFR first up.
Here again, questions left begging answers; can I as an IFR pilot conduct operations under the NVMC rules, is the NVMC rule set still valid; or, is it all now under the IFR – only at night. Perhaps it will be explained later. I stagger confused into the 'changes' paragraph, then this:-
Quote:....Under Part 61 there is one instrument rating, six different aircraft endorsements and two instrument approach operation endorsements (read on for more information— note that this doesn’t include the private IFR rating).
Now read it again, and once again. OK, one instrument rating; but only valid sometimes, except if you are a PIFR, which is different again (we think). Six different 'aircraft endorsements' essentially means (as you read on) that there are, potentially (reality yet to be decided) potentially six separate IR to keep current. Your 747 command IR under CAR 217 (or similar) is still valid despite the fact that you failed a FPC in your mates Baron last week. You can quite legally saddle up the 747 and chuff off to LAX in the middle of a dark and stormy, but you cannot be trusted to nip up the way for lunch in the B58, unless you have 'demonstrated competency in the type (class). But you may, provided you have passed the flight test for the Metro do the odd moonlight run for the local freight company, but cannot take the C 172 IFR to the beach for a spot of fishing – unless your IR for the '172' class is valid. This of course may, or may not be the case if you operate a Cessna 510 single pilot or a Westwind multi crew. Which, stand alone is bad enough, but then add this:-
Quote:...Holders of ATPL(A)s and MPLs don’t need to hold a separate instrument rating.
Why do they insist on multiples – its an ATPL singular or a MPL (singular) not ATPLs – I only have one off. Anyway, it looks like only those with the impossible to obtain ATPL may avoid holding 'multiple IR' ( I think). Which takes us into recency.
Well it's all good news, 90 days and ninety nights between prescriptions (unless you operate single pilot) which is, regrettably different again. We shall get to the SP rules in due course – I hope. The following requirement for an Instrument Proficiency Check (IPC) is deceptively simple; 24 months for 'type' rated aircraft unless you operate a type rated aircraft single pilot, then it's 12 months between IPC – cool you say. Not so, what if you work for a mixed fleet operator; or operate free lance; or, even fly a Dash for a day job and do the odd charter for your old boss in a Citation. Your freedom to operate 'independently' has just been further and severely restricted and the fiscal burden on someone increased. So, the Virgin 738 pilot with no desire to do any other flying is out of jail, on a 217 cake walk and in no trouble whatsoever. None of the single fleet operators are, except when 142 or 141 creeps in, then it will be off overseas for training and checking – at great expense which will be off-loaded onto the passenger ticket price. Aye well, it will suit some, but it's a clumsy, micro management system which achieves very little in the way of improved risk mitigation and gives the 'authority' more room to meddle, should they decide to. But I digress.
The navigation system blurb is simply a waste of words, stating the obvious while illustrating nothing. Click:- Page 3:
Quote:...To conduct an IFR operation a pilot must hold the applicable instrument rating aircraft endorsements. They are:
›› single-engine aeroplane (SEA) instrument endorsement
›› multi-engine aeroplane (MEA) instrument endorsement (covers single and multi-engine aeroplanes).
›› single-engine helicopter (SEH) instrument endorsement
›› multi-engine helicopter (MEH) instrument endorsement (covers single and multi-engine helicopters)
›› powered-lift aircraft instrument endorsement
›› gyroplane instrument endorsement
›› airship instrument endorsement.
Don't you just love it –the simple elegance, ease of operation, flexible, rational and of course completely safe now that an instrument rating is no longer a thing which allows flight in instrument conditions'. Now it's flight in IMC but only in a specific airframe, you see an instrument approach in a light jet is very, very different to one conducted in a high performance single. I expect the clouds are different or something. Are we not mixing our ability to operate an aircraft in IMC with the ability to operate the aircraft itself. This part takes us into the first of many junctions where several 'disciplines' are melded into one conglomerate. A place where the alchemist attempts to turn apples into oranges and ends up with a raspberry, gaining little in the way of risk mitigation for great expense and trouble.
I quite like the notion of redefining the 'type' of instrument approach, don't you. I mean the 'old' definitions – precision approach (with vertical guidance) an 'non-precision (without vertical guidance) were just so clumsy. Lord spare me. Then we discover that using a pointer to determine if you are on (or off) track is so vastly different to using a course deviation 'bar' it requires yet another, separate, expensive 'endorsement'. Monday you fly old 'Charlie' with a fixed card pointer VOR; Tuesday it's 'Delta' with a new fangled CDI – of course you need a separate 'endorsement' you silly boy; vast are the differences.
Quote:...To conduct an instrument approach operation, a pilot must have the applicable instrument approach endorsement. They are:
›› IAP 2D instrument endorsement
›› IAP 3D instrument endorsement.
Click page 4:- Self explanatory, written for intellectually challenged water melons explaining that obviously these changes are operational required for 'safety. Not risk mitigation you understand, but safety. Read on.
Click page 5: Aye, well the picture is great and I feel so much better educated now that it has been explained 'properly', we in the kindergarten have greatly benefited from this information.
Click page 6:- Circling approach : a simple no changes would have saved some ink. VOR does not qualify for ADF, OK we can live with that. Enter the Mos and the IAP 2 and IAP 3 units of competency within schedule 2. NFI what they are, but no doubt we shall discover that later in the piece. (not today).
2D and 3D - Six seems to be a favourite number, now we have identified , but not qualified something which has never been done before, Non precision and precision approach paths (but with and without those terribly tricky pointer things).
Click page 7:- Highly illuminating graphics, a table which needs some assistance with the English language and those damned tricky indicator whatchmacallums, and a note
Quote:..Note: a 3D approach operation does not satisfy a recent experience requirement for a 2D operation, but may satisfy a CDI or azimuth guidance recent experience requirement.
The crystal clear resolution of lingering doubt may be contained within that epistle. May the force be with you, maybe, if it's Tuesday or maybe Wednesday – Maybe I don't know. May I ask a grown up. Who writes this rubbish?
Click page 8:- Oh, I know, I know, that's an aircraft right? however, maybe.
Click page 9:- Here we have the 'Wendy' and 'Don' show, which is a bad example of the FAQ system which never quite works, does it.
Click page 10:- another aircraft piccy over the top of some fairly interesting implications; I read on holding my breath.
Click page 11:- The 'Irene' and 'Patrick' show; Irene seems to be OK, but poor old Patrick, cut his throat instead of brushing his teeth, so confused and confounded was he. This so much safer than a once a year check of 'instrument flight proficiency', more fun too and look at those costs spiralling out of control. Stellar stuff.
Click page 12:- The sanity page, industry responsible 217 system saves the day. The short answer to escape the bull-pooh preceding. N.B. When the responsibility is firmly on the operators shoulders; Poof suddenly it' s all too easy. What's that – no 217 well it's off to the local flight school for you mate; what do you mean there ain't one? Oh, too hard to meet the new requirements eh; well NZ is closer than the US of A, try there.
Click page 13: - Here we meet 'Connie' happily taking her ATR into scheduled all weather services, but can't fly the Comanche for nuts. What's wrong with this picture? either the CAR 217 is 'ticking and flicking' or the outside examiner is too tough; or, you nut it out for a Sunday puzzle. There are six fatal assumptions made for Connie. Hint? well in either event CASA will not be responsible.
Click page 14:- Flight school commercial – ignore.
Click page 15:- I will stop here and find another coffee. Tomorrow we may venture into the tangled world of the MoS and the regulation as writ. There is a list of rules provided on page 16, but first we meet the MoS. I love this these bits:-
Quote:Before commencing a flight, pilots must ask themselves ‘Am I capable of conducting the operation safely?’
This is the equivalent of the medical ‘fitness to fly’ question, but relates to the technical and operational aspects of flying. It means pilots need to be sure they are fit to fly in all respects.
FCOL if I believe I am fit, and by extension, deemed capable of assessing this as fact, then I may dispense with my medical examiner. The reason we have independent assessment is because ?
Quote:The first is to ensure that all pilots consider whether they are competent to conduct a flight. This is about good practice.
Ultimately, responsibility for ensuring you are competent to operate an aircraft safely rests with you, the pilot.
I mean seriously who of sound mind would make such statement; probably some one who has self assessed and determined competency.
Enough – coffee and perhaps a nice lie down.
Toot toot;
Whistles up dogs and buggers off, far from the study, to where water murmurs over rock, the air is clear, sanity prevails and part 61 is on hold, for a little while.