[Kharon]

Say NO! to part 61.
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Lost count – tried for 100, but hey; who’s counting….
Lost count – tried for 100, but hey; who’s counting… .

[Peetwo]

Another day, another Tiger Team exemption -

7 January 2016


Aerial application rating and firefighting endorsement exemption

CASA has published a new exemption (CASA EX 226/15) to create a pathway for certain pilots who have significant experience in low-level aerial work operations (aerial mustering or aerial application) to qualify for a firefighting endorsement.

The exemption will allow a pilot who, before 1 September 2014, held an agricultural pilot rating (helicopter or aeroplane category) to conduct aerial firefighting operations whilst flying either a helicopter or aeroplane.

As a result of the exemption the following conditions will apply:

• the pilot of an aeroplane must have accumulated not less than 1000 hours of flight time conducting low-level operations
  
• the pilot of a helicopter must have accumulated not less than 300 hours of light time conducting low-level operations
  
• before conducting any firefighting operations, the pilot must undertake the relevant training and be assessed as competent to engage in firefighting operations
  
• the training and competency assessment must be conducted by the holder of an Air Operator’s Certificate (AOC) who has authorised the firefighting operations
  
• any firefighting operations must be conducted under the supervision of the operator (AOC holder) who has authorised the firefighting operations.
  
  

This exemption expires on 31 August 2016.

View the exemption on the ComLaw website.

At this rate Part 61 & it's many accompaniments will soon outgrow the Fuji Xerox box - UFB!



Say NO! to part 61.


MTF...P2

[Peetwo]

Another day, another Tiger Team deferral - FFS give it up OST you tosser, you can't make a silk purse out of a sow's ear:

5 February 2016


Flight instructor ratings for approved aerial mustering training pilots
Work is underway to ensure aerial mustering flight training and testing continues smoothly during the flight crew licensing regulations transition period.

To assist with this process, two instruments (CASA 289/14 and CASA 290/14) enable Civil Aviation Order (CAO) 29.10 approved training pilots to continue exercising their privileges during the Part 61 transition period (please note these instruments are currently due to expire on 31 August 2017, however CASA expects them to be extended for a further 12 months to 31 August 2018).

Under the flight crew licensing transitional arrangements, pilots who held CAO 29.10 approvals are taken to be flight instructors with a low-level rating training endorsement for the relevant category, and can continue exercising the privileges of the instructor rating until 31 August 2017 and until 31 August 2018 once the policies are extended.

While these pilots are not required to pass any examinations during the transition period, they do need to undertake instructor rating proficiency checks.

Eligible pilots can apply to have this authorisation included on their new Part 61 flight crew licence. You will simply need to provide the required evidence to CASA when you submit form 61-9TX (Recognition and transfer of CAR 5 qualifications under CASR Part 61 and CASR Part 202.261). You can access the form as a PDF, or via CASA Self Service.
Find out more about applying for your Part 61 flight crew licence.

If you have already converted to a Part 61 licence and want to request the addition of a flight instructor rating, you will need to complete form 61-9LR (Notification of licence document resolution) and submit it to CASA. You can access the form as a PDF, or via CASA Self Service.

 
Word of advice - sack OST's Tiger Team (& sack OST) they're a WOFTAM & Part 61 needs to be pulled next week soonest in joint sitting Parliament -  otherwise the ever suffering taxpayer & industry will be paying for this till the cows come home - FFS GA & red tape reduction now or else
MTF...P2   

[Gobbledock]

Ha ha;

"While these pilots are not required to pass any examinations during the transition period, they do need to undertake instructor rating proficiency checks".

Jeez Oscar, get your hand off it mate. Ag Phil and his boys will be fuming.

Ag pilots are some of the scruffiest bad ass blokes you will meet (some, not all), but they are some of the best bloody pilots you will ever meet. Skilled at fast and low flying, virtual acrobatics, flying into the sun, zipping through some of Australia's hottest areas where clear air turbulence reigns supreme, watching orange and pink sunsets as they park their machine for the night and slam a few coldies down their sweaty throats to get rid of the crop spray flavour.

These blokes and a few blokettes do not need some silver moustache wearing girly-man telling them how to suck eggs.

Instructor rating proficiency checks? They could teach you a thing or two Oliver, you and your other Kansas City faggots who are either not pilots or are pilots but used to flying your little plush machines complete with leather seats and a nice fragrance leaf donning the flight controls. Be gone with you, you bureaucratic peddler of pony pooh. Stick your deplorable, amateurish load of shite Part 61 where the sun don't shine.

Gobbles.....out

[Kharon]

A Sunday twiddle.
From a place where E does not equal MC, let alone get squared.

Time; a queer, quirky concept and highly subjective.  Not the Einstein version, but an individual concept of time, which can vary so much it defies science.  The amount of time a traffic light takes to change is in direct ratio to how much of a hurry you are in, when there’s a queue for the loo and you are busting: the relative ‘time’ can stretch to a concept of infinity; yet other routine matters of daily life can whiz by so fast, you scarcely notice the moments.  

Then there are the diverse forms of time; the politicians versions where decades pass before outdated infrastructure projects achieve their goals, where the passing of law can take years – or moments. Then there’s the time taken to have anything the politicians manage to produce blossom into fruition.  A strange dimension.

The politicians edicts must then enter an entirely new time dimension, that of the bureaucrat. In this realm time is such a malleable commodity it defies any science or logic known to mankind.

The ‘new’ regulations for aviation are yet another great mystery of the time continuum; they, more than perhaps any other perfectly reflect the parallel universes they must pass through before they end up sat on my desk wearing pencil marks, side notes, crumbs and coffee mug rings.  I look at this incredible pile of paper with the innocuous title ‘Part 61’ and wonder at it’s passage from conception to where the cat has parked, atop a nine inch high pile of A4.  To transmogrify the time spent in that passage of time into dollars and sense defies my best efforts.  The dollars I can roughly estimate, but of estimating the ‘sense’ and the reasons why this pile of paper is sat on my desk is totally and completely beyond my humble capacity for comprehension. Indeed, with my least jaundiced pair of rose tinted glasses I can find little worthy of the time and money spent in it’s production.

This abomination has now entered the time realm of the real world of aviation; where time and resources are measured on a different scale; a scale with some sense of urgency and an appreciation of cost.  When this thing was floating through the various stages of gestation, travelling on tax payer money at a bureaucratic leisurely pace, it was inert and therefore harmless.  Once pupped and weened the beast began it’s campaign for life in a vastly different world.  Once it became law and went live the bad habits it was raised with begin to show up; more time and more money needed to reform the beast.  The industry owners, quite rightly, have taken the thing back from whence it came and demanded that the breeder refund or reform the bastard of the litter.  So, provided the new owners can stand the cost and spare the time, more money, time and effort will be spent to ‘correct’ the errant mongrel.  Sensible folk with little time or money to waste would cut their losses, cut it’s throat, drop it down a deep hole and find another.  

But this is not the Australian way; the solution is to develop a new time dimension; that of ‘transition’, a kind of limbo state, where ‘tiger teams’ attempt correction and lawyers desperately try to avoid the conflicts while retaining absolute power without any responsibility.

It’s a royal buggers muddle; meanwhile back in real time, industry must rely on patience, forbearance and a low profile, hoping that they are not accidently breaching some strict liability clause, tucked away at the bottom of a paragraph, over the page which could, in the right circumstances, end their days of productive time.  

It is time to end this farce – OST insists that we must have a rule set; OK, adopt FAA or NZ rules and before they start screaming “it can’t be done” tell ‘em that “yes you can”.  Then use those as an interim (two, probably five years) transition period until the fools, sat on their ridiculous hats in Sleepy Hollow catch up with the rest of world.  Won’t take long, just another two or three decades.    

Aye well; that’s a Sunday load off; now I’ll go visit ET in the third dimension where time and motion are strictly controlled on a rational basis.

Warp speed thanks GD; lets get the cluck off planet and find some sanity.

“Those who can make you believe absurdities, can make you commit atrocities.”

Toot toot.

[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  

[Peetwo]

Part 61 - From the coalface

Oliver's reply a year ago to professional pilot & instructor Bob Molony:

UNCLASSIFIED

Dear Bob
 
Thank you for your email dated 22 April 2015 regarding the new flight crew licensing regulations.
 
You have raised a number of important and topical issues in your email. By now, you should have received a letter from me to all active pilots on this topic. In that letter, I acknowledge that CASA has to do better in implementing new regulations and I give my personal assurance that all comments, feedback and criticism will be looked at carefully and given full consideration.
 
I would like to advise that the topics you have spoken about in your email were also raised at the Flight crew licensing implementation forum that was held in Canberra on 17 December 2014.  Action has been taken on many of the topics that were raised and further work is underway to address other concerns and problems.
 
I understand you have spoken with Roger Crosthwaite, Manager Flight Crew Licensing Standards about your email and the issues you raised. He is very prepared to continue a dialogue with you on these and other matters. Also, I understand you have provided further advice to Roger on the topic of flight reviews and proficiency checks, especially for pilots such as yourself who are faced with a significant increase in the number of checks required by the new regulations. Your input on that and other topics is welcomed.
 
CASA is open to feedback and will listen carefully to issue raised. So thank you for writing to me.
 
Safe flying
 
 
Mark Skidmore AM
 
Director Aviation Safety
Civil Aviation Safety Authority
 
Ph: +61 (2) 6217 1001 

This was Bob's email to OST 22 April 2015:

The Director of Aviation Safety - Mark Skidmore AM

 
Cc The Hon Warren Truss MP, Minister for Infrastructure and Regional Development
      Mr Jeff Boyd Deputy Chair CASA Board
 
Dear Mark,
 
Firstly, Congratulations on being selected as Director of CASA and a big well done with your positive messages as published in the last few CASA Briefing Letters.
 
In keeping with the theme of the ANZAC Centenary this is “A Letter From The Front Line of Aviation” detailing the effects of the introduction of Part 61; I will keep this short as I know you are a very busy man.
 
My background: I have been an ATO since 1991, I served twenty years in the RAAF and my fifty years of flying comes up in a few months. My day to day is Chief Pilot, GA instructing and testing, ferrying, (I have operated in 31 different countries), and mentoring new pilots, particularly in their first turbo prop or jet aircraft. My CAR 5 licence is attached; I also hold FAA and CASA PNG ATP licences.
 
As an ATO I operate on the “Front Line” of aviation, and therefore deal daily with the ramifications of the introduction of Part 61; please read this as this is what is happening out there, this is not my opinion but what I see and hear:-
 
Confusion, anger, distrust of CASA, a loss of respect for CASA, no willingness to engage with the rules and regulations. The end result is a big reduction in SAFETY, plus the attendant increase in costs. We had a system that worked well, (our safety record is a testament to that), so we spent a lot of time and money to change it to a system that has multiple problems.
 
Safety is best achieved when the regulator and the industry have respect, trust, and an open and cordial relationship, supported by logical and readable rules. All this was lost when Part 61 was imposed on the aviation industry, with CASA producing NO evidence of an identifiable safety benefit, indeed Part 61 has reduced safety and trashed CASA’s standing in aviation, both in Australia and overseas. The combination of Parts 61/141/142 has caused confusion in the training sector, with many organisations now unable to correctly map their training syllabus, and identify their responsibilities and limitations. The introduction of the 61/141/142 trifecta has imposed a workload and costs that are simply beyond the physical and financial capability of many organisations to comply with.
 
The average pilot believes they were misled in respect of the promise of a four year transition period, and “what you do today you will be able to do after the 1st September 2014”; this statement from the then Director, (see attached), was simply wrong, and many pilots have suffered a significant loss in privileges/income as a result, and for many, the costs of complying have increased enormously (another broken promise).  If you use me as an example Part 61 requires that I do five biennial flight reviews, three of them annually, and five Instrument Proficiency Checks annually, to be able to do what I used to do with one Flight Review and one Instrument Rating Renewal.  Clearly this is not affordable in both time and money, and the people I mentor, especially in jets and turbo prop aircraft will be left to fend for themselves, once again safety takes a back seat.  There are many other pilots in a similar position to mine, Part 61 will remove our collective experience and leave Australian aviation with an experience hole. Training of new pilots in the entry level turbo prop and jet sectors is now much more expensive, with many fewer pilots now able to progress into these areas. A change in the Flight Review requirements and Type classifications has caused these consequential devastating results, where no safety risk existed.
 
I could write pages of examples but that probably won’t help, the fact is that Part 61, both the manner of the introduction, and the content, has been a disaster of CASA’s making; indeed as one pilot put it to me “this was an act of corporate arrogance and ineptitude never seen in aviation before, and is the biggest threat to safety and an orderly industry that we have experienced; introducing Part 61 with all the licencing rules in one place was a sound idea, but CASA spent ten to fifteen years and  many millions of dollars, and then got it wrong. The place needs a clean out.  There was no fact based safety case presented and all this wasted time and money has managed to produce is increased costs, a reduced level of safety, and a pilot cohort who have disengaged from the regulator.
 
The audience aren’t listening anymore, and most have tuned out completely; safety has been compromised, costs have increased; and we all need to get this fixed.
 
Having highlighted the problem, it is incumbent on me to suggest a fix. Ideally a return to the status quo pre 1Sep 2014.  If that is not palatable or possible then we need an Instrument that declares there is a four year changeover period and that what rules and regulations applied before 1st September 2014 will apply to at least 31August 2018; Part 61 will run parallel with the “old rules” but will not have precedence.; the end result will have a “no detriment” guarantee. This will calm the confusion and allow an orderly transition process to be initiated. I know there may be legal obstacles to this but the safety implications must take precedence. Delay is not an option, the confusion, anger, distrust and loss of respect for CASA is increasing exponentially. The rush for dispensations, band-aid fixes and heads in the sand, needs to be stopped. Red Tape is out of control, despite the Prime Minister stating that his Government is going to remove unnecessary red tape, and costs of compliance are increasing rapidly. 
 
I am happy to talk to you and co-operate in any reasonable way to help solve the problem.  I am not a “CASA Basher” and have always prided myself on embracing change and progress, but this mess is awful, and needs fixing; please listen to this message from the outside, and not the message from those who inflicted this harmful legislation on a trusting industry.
 
Further to the above; teaching requires good communication, it is not possible for CASA to effectively communicate the rules and regulations to an audience of pilots, when the rules are written in a different language, legalese.  Any requirement to continue this practice is adversely affecting safety! By all means have a lawyer’s version, but please communicate with pilots in plain English.
 
Yours Sincerely
 
Robert (Bob) Molony
0412174562

The following is what followed in the to & fro correspondence between Bob & CASA (former exec manager Roger Crosthwaite:

Hello Roger,

 
Thank you for your phone call last week; you asked for some specifics from me so here we go. (Just some simple ones to start with.) I accept your statement that there is no intent in Part 61 to stop people doing what they were doing, but it appears that in some cases this is the unfortunate, if mis-intended, outcome.
 
1 Can I continue to do C525 and BE350 “endorsements”, now type ratings?
 
I believe I can do these ratings; I have done many of these before Part 61; both of these aircraft were in CAO 40.1.0 App 1A, Part 1 Class ratings. I was authorised to conduct the C525 and BE300 (King Air 350), endorsement prior to 1 September 2014 by virtue of being a Gr 1 Multi Engine Flight Instructor with the appropriate experience, and therefore I am still entitled to conduct the same (flight activity) post 1 September in accordance with CASR 202.263(1).
 
On a different subject;
 
(a)    I think the BE350 should be in the MEA Class as the practical differences between the BE90/200/350 are slight, indeed the differences change more with the year model and FMS fitted, than whether it is a 90, 200 or 350.
(b)    The requirement to use the BE200 sim in Melbourne for BE200 training is only appropriate if the aircraft the applicant is going to use is represented by the simulator. For aircraft fitted with sophisticated FMS/auto-pilot (ProlIne 21, Garmin 1000 etc) the simulator is a negative learning environment and causes confusion.
 
2 Having looked at my licence, do you have a work around for the multiple IPC and FR requirements; for a lot of pilots this is a huge problem which didn’t exist before Part 61. The way it reads now a lot of experience is going to be lost forever if this is not fixed, and a loss of experience eventually leads to a reduction in safety.
Rodger, I enjoyed our short discussion, but we need answers and solutions; instruments and dispensations: the training industry is really struggling with the changes, and we can’t afford to get bogged down in semantics, I know many who can’t cope with the changes and uncertainty, and have given up.
 
Regards

Bob Molony

---

 Sent: Tuesday, 5 May 2015 8:02 AM
UNCLASSIFIED

Thanks Bob

I will respond to your earlier email shortly,.

Regards

Roger 

---

 Thanks Roger,

Re my email of 28th April (attached)
Can you please confirm that my interpretation re the C525 training is correct.
Cheers

 Bob Molony

---

 Sent: Monday, 4 May 2015 10:24 AM  

UNCLASSIFIED

Good morning Bob

Thanks for this email.

I did receive your email of 28 April, thanks. I’ll be putting your input into the discussion which I am looking forward to progressing.

Best regards

Roger

---

Roger, 

This is part of an email I received over the weekend.  I am sending this as it might give you a sense of the feeling out there 
“Spoke with an operator in  xxxxxx yesterday and he said that if someone would lead the charge, he would shut down his 20 aircraft and lay off all his staff if needs be to get CASA to wake up to themselves.  We can’t continue on this way.”

 Can you please confirm that you received my email dated 28tApril.

 Regards 

Bob Molony

---

 Sent: Friday, 8 May 2015 1:14 PM 

 UNCLASSIFIED

Good morning Bob 

Thanks for your email below.
I can assure you we are working through several areas to overcome problems that have arisen with respect to the implementation of the new flight crew licensing regulations.

With respect to your question below about your entitlement to conduct type rating and aircraft class rating flight training and flight tests for those ratings.

In principle, a pilot holding a current grade 1 aeroplane instructor rating with multi-engine aeroplane training approval was authorised under CAR Part 5 to conduct the training for aircraft type and class endorsements, in accordance with CAO 40.1.7.  The transition regulations authorise that pilot to continue with those privileges.
Our approach is to grant the Part 61 type rating training endorsement to instructors who provide evidence that they had conducted CAR Part 5 type specific endorsement training under CAR Part 5 prior to 1 September 2014. This avoids the complex administrative process of granting type rating training endorsements and applying limitations on those endorsements or the rating to reflect the CAR Part 5 limitation.  

 We are also concerned about the recognition of these training authorisations by foreign regulators when they are considering converting an Australian licence. It would be inappropriate in many cases for pilots to be awarded a training endorsement when they were never trained and authorised to conduct that training in the Australian system. I note this is more likely to be so in the airline environment.

 With regard to your other questions, we will respond shortly. However, your points are noted and are being considered along with other similar feedback we have received.

 Best regards
Roger

 

---

  Hello Roger, 

I have left this for a while as I know you are very busy, however I now need to progress this to conducting a C525 rating.

Do I need an exemption to sign Form 61-3CT Section 2 Person under 61.235(5), or are we following your suggestion below regarding Part 61 type training endorsement.

 Cheers

Bob Molony

---

Hello Roger,

 I have a lot of work (and income), waiting for a resolution to the below question, which is now nearly three months old.
I am a patient man, and I have a good sense of humour, BUT!!!!!!!!!!!!!!!
Gents, this is but one of the many many problems CASA, through Part 61, has created for the industry, it is your responsibility to fix the problems you created, in a timely manner please.
While you are fixing this can you please confirm that it is ok for me to do a flight review overseas, for someone with a CASA licence and a VH registered aircraft.

 Regards 

Bob Molony  

---

  UNCLASSIFIED

Good afternoon Bob

To conduct flight training for the grant of an aircraft type rating: 
1.  the person conducting the flight training must hold a Part 61 instructor rating and the appropriate type rating training endorsement. 


2. a person holding a conversion training approval under CAR Part 5 (CAR 5.21 approval) is taken to hold a Part 61 flight instructor rating and the type rating training endorsement specified on the CAR 5.21 approval. 

3. a person holding a CAR Part 5 grade 1 flight instructor rating is taken to hold a Part 61 instructor rating and grade 1 training endorsement. If the person also held multi-engine training approval then they would also be taken to hold the class rating training endorsement for multi-engine aeroplanes. CAO 40.1.7 extended the privileges of the rating to giving training for the grant of an aircraft endorsement if the instructor met particular requirements such as experience on type. 

4.to conduct type rating flight training under the old system,

If the pilot was conducting conversion training under the CAR 5.21 approval, then the conditions on the approval would dictate which types of aircraft he or she could train in, and any organisation limitations such as conducting the training only for pilots of a particular operator.

1. 1. If the pilot was conducting aircraft endorsement training under a flight instructor rating, then the training needed to be done under an AOC holder.
      
      
2. CASA approach has been to recognise pilots who have been conducting aircraft endorsement training prior to 1 September 2015 under one of the above authorisations and grant the pilot the type rating training endorsement.
   
3. Flight training for the grant of a type rating must be conducted under the authority of Part 141 or Part 142 – notwithstanding the provisions of the transition regulations and the two legislative instruments that authorise operators to conduct the training https://www.casa.gov.au/standard-page/flight-crew-licensing-legislative-instruments-0#r2
   
4. If the training is a Part 141 activity, then CASA can authorise a person to conduct the training under a regulation 141.035 approval.
   
5. If the training is a Part 142 activity, then CASA can authorise a person to conduct the training in a flight simulation training device under a regulation 142.040 approval – note this option is not available if the training is conducted in an aircraft as the operator must hold an AOC.
   
   To conduct a flight test for a type rating:
   
   The person conducting the flight test must be the holder of a flight examiner rating and the applicable type rating flight test endorsement.
   The holder of a CAR Part 5 delegation is taken to be a flight examiner and may continue conducting the flight tests authorised by their delegation. In addition, they may conduct the flight tests listed in the 61.040 approval  - https://www.casa.gov.au/standard-page/flight-crew-licensing-legislative-instruments-0#r2
   That instrument details which flight tests may be conducted based on the authorisations the delegate holds. 
   With respect to your case.
   I understand you satisfy the requirements for conducting the type rating flight training in aircraft.
   I am not sure whether the training you are doing is under a Part 141 or Part 142 authority (noting the options above).
   For the flight test, the requirement for the recommendation under subregulation 61.235 (4), you can complete that section and conduct the flight test – as long as you can satisfy one of the provisions in 61.235 (5), (6) or (7). 
   CASA is currently working on a proposal for the Metro, Merlin, Kingair 350/1900 to be included in the scope of Part 141 and that would enable a regulation 141.035 approval to be granted.  That work is with our Legal Services Division. 
   I trust that deals with you type rating training questions. 
   With respect to the second subject in your 28 April email:
   Including the BE350 in the multi-engine aeroplane class rating. Your advice is noted and I will make sure it is considered as part of the post implementation review.
   Using the BE200 simulator in Melbourne.  I am handing that question to the Flying Standards Branch team for them to address.  There are definite views on this about the positive and negative training aspects.
   I apologise for any gaps in advice and the time taken to fully address your questions.  Follow up questions on these topics should be directed to Flight Crew Licensing (Industry Permissions Division) for licensing and Flying Standards Branch (Operations) for matters of flight testing, approvals to conduct the training and the simulator issue.
   Best regards
   Roger 
   Roger Crosthwaite
   Manager Flight Crew Licensing Standards
   Standards Division
   CIVIL AVIATION SAFETY AUTHORITY | www.casa.gov.au
   T 02 6217 1017   | F 02 6217 1691   | M 0400 834 774
   Safe Skies For All
   

[*]

Clear as mud??


Well okay a year on and with Oliver's Tiger Team now in the mix, any guesses to how this seemingly cordial to & fro bollocks with the regulator might have ended up??

Here is a couple of clues..

From: Bob Molony
Sent: Tuesday, 3 May 2016 3:58 PM
To: byron.bailey@hotmail.com
Cc: dick@dsi.com.au
Subject: Part 61 and Friday's meeting in Tamworth

 
Byron,
 
How are you, all well I hope.  I enjoy reading your thoughts in the Australian.
 
Unfortunately I will be in PNG on Friday, however I have attached some of the correspondence that I have exchanged with CASA over the past year or so, and a copy of the Regulation Impact Statement provided by CASA to the Government.
 
Dick has seen much of this before.
 
Some points from me are:
 
1 Read the Part 61 Regulation Impact Statement, in particular the last sentence of the conclusion; one can only surmise that the drafters and signatory were incompetent or dishonest – The Authority duped the Government into agreeing to the legislation.
 
2 The legislation is so poorly written that one must question the credentials of the drafters and the adverse effect of the legal input.
 
3 The introduction was so amateurish as to be laughable, indeed most in CASA were caught by surprise that it was actually released. Where was the change management team of experts??
 
4 Why was this deemed such an important project, it has cost a fortune, raped GA and reduced safety. It has also badly damaged the relationship between CASA and the industry.
 
5 The cost to the average GA organisation is in the order of $100,000; many have closed, businesses have been ruined, families torn apart through divorce and or losing their home.  Indeed Projet has forgone $200,000 of jet training business because of the laughable type rating changes.
 
6 There will be no resolution until CASA advertises all related positions and hires some decent people with broad industry experience. I believe the Director will be worn down by the System if he is not given a clean slate.
 
7 I am not a lawyer, but I believe CASA’s demonstrated incompetence would not withstand a class action from, in particular, GA operators who are all substantially out of pocket and have had their business model trashed; all this for no reason other than some in CASA had a thought bubble.
 
Keep me in the loop please.
 
Cheers

Bob Molony

[*]
MTF...P2

[Peetwo]

Latest from Part 61 Tiger Team

11 May 2016


More guidance for on the way for flying training organisations

CASA is currently working to produce a package of guidance material to help Part 142 flying training organisations transition to new rules by August 2018. This follows the recent release of similar guidance for Part 141 operators.

Part 142 of the Civil Aviation Safety Regulations covers the rules relating to structured flying training activities that lead to the issue of multi-crew pilot, air transport pilot and flight engineer licences. It also provides the regulatory framework for flight training for complex aircraft type ratings and multi-crew cooperation, and for contracted flight crew recurrent training and checking.

Under the regulations, flying training organisations who want to be authorised under Part 142 need to develop and maintain a safety management system, a training management system and an exposition, as well as nominate a safety manager.  To help operators meet these requirements, CASA will be publishing a series of guidance documents and tools including a sample exposition, technical assessor’s handbook and worksheet and information sheets.

The sample exposition will suit organisations that want to address the requirements in a single document, rather than as a suite of documents. It will include a sample training management system, internal training and checking system, safety management system gap analysis template and implementation plan.

The Part 142 sample exposition will be based on a fictitious operator (‘Sample Aviation Pty Ltd’) who already conducts Part 141 activities and has developed an operations manual using the Part 141 Sample Operations Manual as a guide. Sample Aviation has grown and expanded its business, and now needs to develop a Part 142 exposition. Sample Aviation will be operating a number of single engine aircraft and a twin engine aircraft, and staff numbers have increased to approximately 15 employees.  In addition to their Part 141 training, Sample Aviation will be offering full-time integrated training to a commercial pilot licence standard.

The sample exposition will serve as an easy-to-tailor template for operators who are conducting similar activities to the Sample Aviation profile, and will also provide a useful starting point for those who undertake more complex operations. The new material is expected to be available in mid-2016.

Part 141 guidance package nearing completion

CASA is also in the process of wrapping up the suite of materials available for Part 141 operators, with a sample syllabus just released for non-integrated helicopter commercial pilot licence training and a sample syllabus for the helicopter private pilot licence also recently published. These syllabuses may be used by flight training organisations who are transitioning to Part 141, or new entrants who commence training to the Part 61 Manual of Standards. Find out more and access the syllabuses.

The Part 141 guidance package includes a sample operations manual and guide, technical assessor’s handbook and worksheet, instructions for CASA staff on conducting assessments, sample flying training syllabuses and an information sheet. The package will be complete once the sample syllabus for the aeroplane commercial pilot licence has been finalised.

5 May 2016
Part 61 Solutions Taskforce update: Top five

The Part 61 Solutions Taskforce is continuing to address issues associated with the flight crew licensing suite of regulations. While a great deal of work is underway the work listed below represents the more significant updates and activities for the Taskforce this fortnight.

1. New sample syllabus for flying training organisations

A new sample syllabus has been finalised and will be published on the CASA website for use by flying training organisations who conduct non-integrated training for the commercial pilot licence (helicopters).  A sample syllabus for the commercial pilot licence (aeroplanes) is also being developed and will be available in the coming weeks.

2. Flight reviews for aircraft ratings and instrument proficiency checks

The Taskforce is continuing to work on proposed exemptions to reduce the number of flight reviews and instrument proficiency checks that some pilots are required to complete under Part 61. A major part of this work involves preparing and publishing advisory information, with details about how to administer the changed arrangements such as entering details on pilot licences and completing and submitting notification forms. This guidance material is currently being developed.  The draft exemptions will soon be made available to the Industry Advisory Panel and the Flight Crew Licensing Sub-Committee for feedback. 

3. Part 142 guidance package under development

The Taskforce is working to produce a package of guidance material designed to help Part 142 flying training organisations transition to new rules by August 2018. CASA will be communicating with the aviation community to advise that the package is under development, and what sort of operator it will be suitable for.
 
4. Flight crew licence tests

The policy relating to authorisations that require flight tests (and therefore flight examiners) is currently being reviewed. The Taskforce is also reviewing the policy relating to flight crew licence test profiles.

5. Night vision imaging system rating and endorsement exemption

A solution is being prepared that will address an issue with the night vision imaging system (NVIS) experience requirements in Part 61. The solution is dealing with the Part 61 requirement to have 20 hours of flight time at night as pilot in command for the grade 1 and grade 2 NVIS endorsements. Instead of the flight time being pilot in command, credit will be given to dual, pilot in command under supervision (PICUS) and solo night flight time. Provision will also be made for time in approved flight simulators. The consultation proposal document will be circulated shortly for staff and industry feedback

Hitch courtesy Oz Flying..

Cadets in training at RMIT Point Cook. (Steve Hitchen)

New Part 61 due before Year End

A complete amendment to CASR Part 61 - Licencing is currently being re-written as is expected to be issued before the end of 2016.

The amendments will incorporate a large raft of exemptions CASA has developed to get around unworkable parts of the original CASR.

Since being signed into law in late 2014 by former Acting Director of Aviation Safety Terry Farquharson, Part 61 has earned the ire of the training industry because it contained new requirements that were either overly-stringent or simply impossible to comply with.

CASA has dealt with the ongoing problem of Part 61 by issuing exemptions. So far, 18 exemptions are in force, with another six to be released in the coming weeks. Those still in the works are:

• Exemption against requirement to have a valid flight review for each aircraft rating
  
• Exemption against requirement to have a valid Instrument Proficiency Check for aircraft type ratings
  
• Night vision imaging system – exemption against requirement to have 20 hours of flight time at night as pilot in command of a helicopter
  
• Aeronautical knowledge examination for CPL and ATPL – exemption against requirement to pass all subjects within two years
  
• Exemption against requirement for multi-crew training where a helicopter is certified single-pilot but is operated with two pilots for the purposes of CAO 20.18 and CAO 95.7.3
  
• Instructor rating training endorsements – exemption against certain requirements for the grant of endorsements
  

As well as exemptions, CASA has also issued approvals to correct problem with aerial firefighting training, instructor rating training endorsments and aerial application proficiency checks for helicopter pilots.

CASA Chairman Jeff Boyd recently declared CASR Part 61 "a mess" and promised more exemptions to schools and operators that require them.

A complete list of existing exemptions to Part 61 is available on the CASA website.

Read more at http://www.australianflying.com.au/lates...gR5iuFl.99

MTF...P2

[Peetwo]

Tiger team ramps up with election distraction??

Most of the bureaucracy in Can'tberra are having a holiday while the elongated (yawn ) election campaign continues...   However old Skidmark's bollocks Part 61 Tiger team,  faithfully led by WOFTAM NFI Wodger Week-as-piss, are ramping up the changes & exemptions week by week, hour by painful hour...

Here's the latest from Tiger Team central...

30 May 2016

Part 61 Solutions Taskforce update: Top 5

The Part 61 Solutions Taskforce is continuing to address issues associated with the flight crew licensing suite of regulations. While a great deal of work is underway, the update below represents the more significant activities and priorities for the Taskforce this fortnight.

1. Changes to instrument rating and air transport pilot licence (ATPL) flight test standards
Changes are being made to the flight test standards for instrument ratings and aeroplane and helicopter ATPLs. The changes are being made to address an issue arising from the Airservices Australia Navigation Rationalisation Project and the associated decommissioning of 181 navigation aids on 26 May 2016. The related flight test standards will be amended in Schedule 5 of the Part 61 Manual of Standards and the Flight Examiner Handbook.

2. Flight instructor rating project
The Taskforce is finalising a proposal for basic instrument flight training, which would remove the requirement to hold a night visual flight rules (VFR) rating training endorsement or an instrument rating training endorsement. This initiative will overcome constraints which are being experienced by some instructors and some flight training operators. A second proposal is being prepared which would allow Part 141 operators who are not instructor schools to conduct training for the grant of some training endorsements. Work is advancing well on updating advisory circulars and producing a detailed Grade 3 training endorsement training course.

3. Night vision imaging system exemption
An exemption from the 20 hours of pilot in command flight time at night in helicopters for the grant of night vision imaging system (NVIS) ratings and endorsements is being finalised, and should be made and registered within two weeks. The exemption only affects a small number of pilots and helicopter operators.

4. Firefighting training endorsement
The Taskforce has been working with industry on a proposal to allow certain operators to conduct flight training for the grant of firefighting endorsements. The approval will be under regulation 141.305 and should be ready for registration within three weeks.

5. Flight review and instrument proficiency check proposals
The Taskforce is finalising these proposals following extended consultation.

Implementation activities are being managed to ensure processes are in place to support the changes, and to ensure advice about the changes is communicated effectively throughout the aviation community.
View a full list of Taskforce activities.

25 May 2016
Changes to instrument rating and ATPL flight test standards

Changes are being made to the flight test standards for instrument ratings and aeroplane and helicopter air transport pilot licences (ATPLs). The changes are being made to address an issue arising from the Airservices Australia Navigation Rationalisation Project when, on 26 May 2016, 181 navigation aids will be decommissioned.

The related flight test standards will be amended in Schedule 5 of the Part 61 Manual of Standards. In particular, changes will be made to Appendices K.1 – ATPL(A), K.2 – ATPL(H) and M.1 – instrument rating.

The amendment will remove the requirement for applicants to demonstrate competency conducting an instrument approach operation using azimuth guidance. This change is necessary as many non-directional beacons (NDBs) won’t be available and many aircraft are not equipped to display data on an azimuth guidance indicator, other than an automatic direction finder (ADF).

Pilots are reminded of the 90 day recent experience rule contained in subregulation 61.870(6) for conducting instrument approaches using azimuth guidance. They should also be aware of the general rule contained in subregulation 61.860(5) for conducting an instrument approach operation using a particular kind of procedure such as an NDB. Together, these rules make sure pilots are competent using azimuth guidance indicators and conducting NDB approach procedures.

CASA expects the amendment to the Part 61 Manual of Standards will be made before 26 May.

Visit the Airservices Australia website to find out more about the navigation rationalisation project.

   
UFB!
MTF...P2

[Kharon]

1 in 60.

That’s the USA and NZ averaged page count in relation to the Australian Part 61; one page of theirs to 60 of ours, approximately.  The NZ version runs to 80 pages which is still a whopping 37.5 (+/-) to one.  The Wallabies would love to see a score line like that.

Now the cost to produce P61 must have be in the same ratio.  Had the rule made a improvement to industry operations; or, streamlined entry; or, removed some of the fiscal burden; or, relieved the pressures of strict liability and criminal persecution; or, improved safety in any way; then we could all say Bravo, money well spent.  Regrettably, this is demonstrably not the case. 

Not only has none of the above happened, but the legal nightmare the rule has provided is becoming more and more tangled as change after change, alteration after alteration, amendment after amendment, exemption upon exemption flow out of the ‘tiger team’ (Yuk) think tank.  It’s a duck up of epic proportions and the gods alone know the true cost.

Not throwing good money after bad is an old maxim, it got old because it has stood the test of time and experience. Yet here we are, all sitting around groaning every time the village idiot, the one with the thesaurus-in-arse problem, spews evermore complex, inane rubbish into the P61 sewer.  Someone should tell Skidmore these are NOT law writers, they are barely qualified flight instructors with inflated ego's and bladder problems. 

It has been an incredibly expensive exercise to produce this aberration; it is costing a mint to amend it ‘on the run’; it will continue to cost industry time, money and heartache to deal with the consequences and yet the farce continues.  Estimates of between 3 and $400,000,000 have, thus far been thrown into the regulatory reform bucket over 25 years.  It will take another two decades and as much money again to rectify and reform the new suite.

WTF are the government thinking; if anything at all?  The FAA or CAA (80 page) part 61 regulations, could with minor alteration be made effective in a heartbeat (E-MC2) the savings enormous, the platform stable and at least one rule set would be intelligible.

It is crystal clear that neither Skidmore, Weeks, the tiger team (yuk), the minister nor even the parliament care a jot about the incredible waste of money to make this unbelievable cripple of an aviation law, nor the huge sums it will take to rectify.  But hey, WTF it’s only tax payer dollars; and what’s a Billion dollars over 50 years to produce a simple rule for licencing pilots, just peanuts; ain’t it?

The biggest load of legal nonsense, operational Bollocks and CASA stupidity ever produced, managed by an idiot, supported by fools and paid for by the mug public.  Stellar.

Toot (over it) toot.

[thorn bird]

K, you beat me to it! the finger was poised over the return key, your musings however were far more eloquent than anything I could write.

From a purely Philosophical prospective, CASA is a government wholly owned independent business unit, it has a board of directors, a CEO and many deputy managers, department heads etc etc, all the trappings of a commercial  corporation.

We, the industry, are allegedly their "Customers".

We pay fees CASA charge for the services they attempt to provide and this generates income enabling CASA to create make believe profit and loss accounts and balance sheets just like a real corporation, any profits paid as a dividend to the government.

All this sounds fine and beaut, but is it reality?

Some bright young thing within CASA, with a lot of letters after their name, had an epiphany and thought it would be really really cool, to call us "stakeholders", much more modern and hip than the word "customer".

"Customer" implies choice, that is if we are dissatisfied with the product or service we are purchasing we can complain or even take our custom elsewhere. The inconvenient truth however is CASA is a monopoly, a government decreed monopoly, which means there is no choice, we must endure incompetent service with no right of appeal.

"Stakeholder" that wonderful weasel word. It implies that the industry has some stake in its future and in its governance. Sadly it does not, its future lays in the hands of a clique of ex military and lawyer bureaucrats, people who have lived their whole working life in the fantasy land of the department of defence and the public service, they have no understanding or experience of running a business, in their world money grows on trees, you do not question you do as you are told.

Completely ignored is the reality that their incompetence ultimately will lead to their own downfall. When the industry is finished so is their reason for existence.

In the real corporate world accountability rules.
A monumental duck up like Part 61 would trigger an investigation, those responsible held to account and shown the door.

No doubt the "product" so completely defective would be withdrawn, throwing good money after bad is never a good idea.

Yet in CASA's unreal world the perpetrators of this travesty get promoted then tasked with trying to put ever more lipstick on a pig.

When will CASA accept that all the lipstick in the world will not make a pig anything but a pig?

CASA's product is so flawed it is beyond redemption nobody with a modicum of financial nous would continue to invest huge amounts of money in trying to fix the unfixable. CASA despite the industries objections continues with this abomination, the same authors of the original, tasked with attempting to fix their brain child, absorbing more and more of the industries money on a folly.

Ken Cannane so brilliantly provided the solution and the timeline, a couple of years and a couple of million, against another 20 years in purgatory and another half billion dollars.

Australia's "never ending story"? No the industry will be long gone

[Peetwo]

The sheer mendacity of Part 61 continues -


In one of the clearest examples of Skidmore's obstinacy & arrogance the Part 61 Tiger team perseveres with more amendments and exemptions to the more than 2000 page Australian version of part 61 ( via Oz Aviation today) :

CASA postpones changes to flight testing regulations


June 21, 2016 by australianaviation.com.au 

Australia’s Civil Aviation Safety Authority (CASA) has postponed changes to the regulation of Approved Testing Officers (ATO) in response to community feedback.

As a result, ATOs have another year to surrender their delegation and obtain a Flight Examiner Rating (FER).

“In response to the concerns expressed by members of the industry about the insurance-related implications of this change, CASA has decided to extend the expiration date of current ATOs for a further year – from 30 June 2016 to 30 June 2017,” CASA said in a statement on Tuesday.

“This means that ATOs who have not yet surrendered their delegation and obtained a FER under Part 61 of the Civil Aviation Safety Regulations 1998 (CASR) in its place do not need to do so immediately, and may continue to perform their functions as ATOs for a further year.

“It also means that the indemnity protection offered to all CASA delegates and authorised persons, as set out in Civil Aviation Advisory Publication (CAAP) Admin-1, will continue to apply to ATOs until 30 June 2017.”

For those who have already surrendered their ATO delegation and obtained a FER, CASA was proposing a legislative amendment to retain their status as an ATO until June 30 2017.

CASA noted on its website that many who had already transitioned from having an ATO delegation to a FER would have made arrangements to obtain their own insurance coverage.

However, the legislative amendment would include the indemnity protection that having an ATO delegation provided.

“Until that change can be made flight examiner rating holders are not covered by the CAAP Admin-1 indemnity,” CASA said.

“Please note that until the legislation has been amended, FER holders who were previously ATOs are not now ATOs (delegates), and the benefit of CAAP Admin-1 indemnity protection has not yet been extended to these people.

“CASA will ensure that affected former ATOs who now hold FERs are advised when the legislation is amended, and what further action may need to be taken so they can obtain the retrospective benefit of CAAP Admin-1 protection.”

More details are available on the CASA website

Errr...no comment -
MTF..P2

[Peetwo]

The sheer mendacity of Part 61 continues -


In one of the clearest examples of Skidmore's obstinacy & arrogance the Part 61 Tiger team perseveres with more amendments and exemptions to the more than 2000 page Australian version of part 61 ( via Oz Aviation today) :

CASA postpones changes to flight testing regulations


June 21, 2016 by australianaviation.com.au 

While the Pollies are otherwise distracted Oliver Skidmore-twist's beloved Tiger Team, led by former C(N)FI Wodger Week-as-piss, continues to add another couple of exemptions  and more than a dozen pages to the totally indecipherable and shambolic Part 61...

Flight reviews

Under Part 61, pilots need to have a valid flight review for each aircraft rating. That means pilots flying a class-rated aircraft need to have a valid flight review for that class rating and, if the same pilot flies a type-rated aircraft, they need to have a separate flight review for that pilot type rating. The flight review exemption (CASA EX97/16) simplifies the flight review requirements and, for some pilots, reduces the number of flight reviews they need to complete. Pilots only need to complete a flight review that was conducted in an aircraft of the same category within the previous two years. If it is a multi-engine aircraft, the flight review must have been done in a multi-engine aircraft of the same category. The flight review rules already recognise other activities that pilots complete such as flight tests, proficiency checks and certain training, all of which satisfy the flight review requirements. The same rules apply under the exemption.

Flight reviews for the low-level, private IFR and night VFR operational ratings remain unchanged.

A flight review that includes training - and CASA strongly encourages pilots to include training in their flight review - must be conducted under a Part 141 or Part 142 operator as applicable.

The information sheet below (Changes to aircraft rating flight review requirements - July 2016) provides more details.

Instrument proficiency checks

Under Part 61, to exercise the privileges of an instrument rating, pilots need to have completed an instrument proficiency check (IPC) in the previous 12 months (regulation 61.880). To exercise the privileges of a pilot type rating under the instrument flight rules (IFR), pilots need to have completed an IPC in an aircraft covered by the pilot type rating in the previous 24 months (regulation 61.805). For type-rated single-pilot turbojet aeroplanes, the IPC needs to have been done in an aircraft covered by the type rating as a single-pilot operation in the previous 12 months.

The exemption (CASA EX93/16) doesn’t change the annual instrument rating IPC requirement. Pilots still have to complete an annual IPC that was conducted in an aircraft of the same category, and to fly a multi-engine aircraft under the IFR, the IPC must have been done in a multi-engine aircraft of the same category.

However, under the exemption, instead of having a valid IPC for a pilot type rating, pilots only need to have completed an IPC in the previous 24 months that is relevant to the aircraft being flown. There are three safety criteria: whether the aircraft is type-rated, whether it is multi-crew certificated, and whether it is a turbojet aeroplane to be flown single-pilot.

The information sheet below (Changes to instrument proficiency checks - July 2016) provides more details, including tables to help you determine the best aircraft to take your IPC in. 

No changes to Part 61 licences or forms

The licence entries required to be made by flight instructors and flight examiners on a Part 61 flight crew licensing document will not change as a result of the new flight review and instrument proficiency check requirements.

Consequently, pilots do not need to apply for a new licence as a result of these changes. Any authorisations that appeared on your licence before the changes were introduced will remain valid.

Approved testing officers, flight examiners and flight instructors should refer to the current CASR Part 61 Licence Instruction Guide for detailed information on how to make entries.

Resources and guidance

We have developed guidance material to explain the changes at a glance, and have also updated existing documents to reflect the changes.

• Information sheet: Changes to instrument proficiency checks - July 2016 (new)
  
• Information sheet: Changes to aircraft rating flight review requirements - July 2016 (new)
  
• Licensing information sheets (updated)
  
• CASR Part 61 Licence Instruction Guide
  

 
While on Part 61, heard a rumour that a certain Alphabet Soup industry advocate (initials KC ) has a first DRAFT of an amended Part 61 that is currently doing the BRB rounds. Apparently it is already receiving much critical acclaim - yeah I know just a rumour, back in my box...



MTF...P2

[Kharon]

A new years resolution- broken.

There are 134 pages of the AMROBA Part 61, which is an excellent start as it is well within the reading, comprehension and absorbance levels of most.  Moreover, it frames the ASRR opinion. - HERE -

The following converts FAR Part 61 into high level CASR Part 61 and all the detail promulgated in Sec 9(1)(c ) Aviation Safety Standards as per the ASRR Report.

Only had time for a quick skip through; but, I have downloaded the text and will study it further.  It may not appeal to the pedantic, there are some rough patches and occasional ‘clumsy’ adaptations- however, in the main, it makes a whole lot more sense than the heavily patched up existing monster CASA keep trying to fix.

It is high time 61 was put out of it’s misery.  As it stand now it’s almost nugatory anyway.  Seriously, how can we have allowed a thing like that to exist, even more of a mystery is the collective minds that drafted it; what a tangled mess that must be: I digress.  Part 61 now has so many necessary exemptions as to render it farcical, it is no longer a law, but a crippled vehicle which the owners must keep repairing to salve their egos.  

OST bleats on about it be a ‘complex’ situation and how we could not possibly understand the delicacy and deep legal tenets involved; there is also the huge, insurmountable problem of English ‘law’ v American 'law' to consider. Etc. Then there’s ‘constitutional’ matters to ponder.

BOLLOCKS – the ducking Act is ‘unconstitutional’: this is a known fact; the other known fact is no one could afford to test that in court and so it stands as a testament to the base intent of those who manipulated it, to suit.  Bit like the ‘airports’ imbroglio, where fast and loose interpretations allowed the current travesties to persist.

AMROBA’s Part 61 could be fine tuned, in short order by a couple of half smart legal types; hells bells I’d bet someone like Creampuff could knock it into shape between first and second coffee on a Sunday morning before doing the Times crossword.

It’s a risible notion that a ‘law’ can only be made to work by a constant stream of exemption to that law; how can that be ‘safely’ enforced.  I’d pay to watch a trial where someone not exempt was prosecuted while others, who are ‘exempt’ continued on their merry way.

Will I stop there? I think so, I’m never quite sure if I’ll break out in hysterical laughter or start tearing the limbs off fluffy toys whenever I touch on 61. So, kettle on, breathe and endit.

Toot toot.

[Peetwo]

AMROBA v Skidmore Part 61 - UDB!  

The following is the history/& short insight into the ever evolving cancerous growth that is Part 61 which still threatens the sustainability of an industry that continues to be embuggered with regulatory red tape by a seemingly uncontrollable bureaucracy - :    

CASR Part 61 - Flight crew licensing - History

Consultation updates in 2016
AC 61-05 v1.0 - Night VFR rating
This AC has been published.
12 Apr 2016
Draft AC 61-05 v1.0 - Night VFR rating
All comments should be sent to the project leader, Damien Fing by close of business 29 February 2016.
15 Feb 2016

Consultation updates in 2015
FS 99/02 - CASR Part 61: Flight crew licensing
This project is now closed
Refer to the project closure notes for further information.
13 May 2015

Consultation updates in 2014
Project FS 14/25 - Post-implementation review of the Flight Crew Licensing regulations - Part 61
Project approved.
3 Dec 2014
Project FS 03/01 - Periodic review and ongoing amendments to include endorsements for new types and models introduced to Australia
This project is now closed
Refer to the project closure notes for further information.
3 Dec 2014
Civil Aviation Order (Flight Crew Licensing) Repeal and Amendment Instrument 2014 (No. 1)
Civil Aviation Order made.
27 Aug 2014
Civil Aviation Legislation Amendment (Flight Crew Licensing) Regulation 2014
Regulation made.
21 Aug 2014
Draft AC 61-08 v1 - Teaching and assessing non-technical skills for single pilot operations
All comments should be sent to the Project Leader, Roger Crosthwaite by close of business 31 July 2014.
16 Jul 2014
Project OS 14/12 - Performance Based Navigation and Reduced Vertical Separation Minima regulatory review.
Project approved.
2 May 2014

Consultation updates in 2013
Civil Aviation Legislation Amendment (Flight Crew Licensing and Other Matters) Regulation 2013
Regulation made.
12 Dec 2013
Civil Aviation Legislation Amendment (Flight Crew Licensing Suite) Regulation 2013
Regulation made.
21 Nov 2013
Consultation Draft for proposed amendments to the Flight Crew Licensing Suite
All comments should be submitted via the Project Leader, Mike Juelg by close of business Friday 25 October 2013.
4 Oct 2013
Consultation Draft for Part 61 Manual of Standards (MOS)
All comments should be submitted to the Project Leader via mos61@casa.gov.au by close of business 2 August 2013.
5 Jun 2013
Civil Aviation Legislation Amendment Regulation 2013 (No 1)
Regulation made.
14 Feb 2013

Consultation updates in 2011
Consultation Draft - CASR Part 61 - Flight crew licensing
Comments on this consultation draft are to be submitted via the online form by close of business 3 February 2012.
17 Nov 2011

Consultation updates in 2009
Project FS 06/02 - Multi-Crew Pilot Licensing (MPL)
This project is now closed.
6 Feb 2009

Consultation updates in 2007
Multi-crew Pilot Licence (MPL) Project team provided with Draft CAR 5 amendment

15 Aug 2007

Consultation updates in 2006
Project FS 06/02 titled Multi-crew Pilot Licence (MPL)
New multi-crew pilot licence project has been registered.
29 May 2006

Consultation updates in 2004
Industry consultation briefings cancelled
The Part 61 and 141 MOS consultation briefings scheduled for 23 August through to 15 September have been cancelled.
19 Aug 2004

Consultation updates in 2003
NPRM 0309FS - Flight Crew Licensing
NPRM 0309FS - Flight Crew Licensing, associated Annexes and Draft MOS Part 61 have been published. Your comments are invited by 29 September 2003.
18 Jul 2003
Project FS 03/01 - Periodic review and ongoing amendments to include endorsements for new types and models introduced to Australia
Project opened.
10 Jun 2003

Consultation updates in 2000
DP 0005FS - Flight Crew Licensing Structure
DP 0005FS - Flight Crew Licensing Structure, CASR Part 61 is available for public comment. Comments close 29 January 2001.
30 Nov 2000

Consultation updates in 1999
FS 99/02 - CASR Part 61: Flight crew licensing

Part 61 legislative instruments:

Part 61 is contained within Volume II of the CASR (see link below), from page 101 to 423 i.e. 322 pages:

CASR Volume 2 : 675 pages
r 45.005-92.205

---

Part 61 Manual of Standards Instrument 2014 is 664 pages contained within 4 Volumes, see links and page count below:

Volume 1 : 74 pages

Volume 2 : 254 pages  

Volume 3 : 228 pages

Volume 4 : 108 pages                                              

Kharon - "..Part 61 now has so many necessary exemptions as to render it farcical, it is no longer a law, but a crippled vehicle which the owners must keep repairing to salve their egos..."  

For reference - HERE - is the link for all the work done and in progress initiated by Oliver's Part 61 Tiger Team. Within that there is an additional link - HERE - which takes you to a page of 'legislative instruments' that have been introduced since the original Part 61 first became law on 01 September 2014.

Now in reference to the "K" post here is the latest list of exemptions put in place to address the shortcomings and industry imposts identified so far within the Bible sized CASA Part 61... :

Exemptions

• Exemption - instrument proficiency checks for aircraft pilot type ratings (CASA EX93/16)
  
• Exemption - CASR Part 61 aircraft flight reviews (CASA EX97/16)
  
• Exemption - CASR Part 61 aeronautical knowledge examinations and two year completion period: CASA EX86/16
  
• Exemption - aeronautical experience for an NVIS rating or endorsement: CASA EX77/16
  
• Exemption - single-pilot turbojet aeroplane specific instrument proficiency check exemption: CASA EX41/16 
  
• Exemption - from completion of an approved training course in multi-crew cooperation: CASA EX225/15
  
• Exemption - against ATPL flight test requirements: CASA EX222/15
  
• Exemption - Grade 3, 2 or 1 training endorsement (aeroplane) flight test: CASA EX219/15
  
• Exemption - from the flight instructor rating flight test: CASA EX218/15
  
• Exemption - from the pilot instructor rating aeronautical knowledge examination (PIRC): CASA EX215/15
  
• Exemption - from the spinning flight activity endorsement (FAE): CASA EX214/15
  
• Exemption - English language proficiency assessments: CASA EX146/15
  
• Exemption - logging of time in flight for co-pilots on single-pilot certificated aircraft: CASA EX116/15
  
• Exemption - Parts 141 and 142 - CASA approval of kinds of aircraft: CASA EX126/15
  
• Exemption - from certain low-level rating requirements: CASA 92/15
  
• Exemption - dual flight checks before solo flights by student pilots: CASA EX 78/15
  
• Exemption - aeronautical experience requirements for grant of commercial pilot licences - aeroplane category: CASA EX22/15
  
• Exemption - aerial application proficiency check and operator proficiency check (head of flight operations) - aeroplanes: CASA EX162/14
  
• Exemption - flight examiner rating for holders of CAO 82.0 check pilot approvals: CASA EX140/14
  
• Exemption - foreign cadet pilots taking flight test for a commercial pilot licence - class 1 medical certificate (replacement exemption September 2015): CASA EX156/15
  
• Exemption - aerial application rating and firefighting endorsement (replacement exemption August 2015)
  
• Exemption - of certain Cobham Aviation Services’ pilots from low-level rating requirement: CASA EX 130/14
  

 Simply staggering when you consider that the above only includes the 'exemptions' so far and none of the additional pages of related amendments that also require more & more legislative instruments to be generated and tabled in parliament. The Attorney General's department must have a separate section totally devoted to handling CASA generated legislative instruments - UDB!



MTF...P2

[Peetwo]

AMROBA v Skidmore Part 61 - UDB!  

The following is the history/& short insight into the ever evolving cancerous growth that is Part 61 which still threatens the sustainability of an industry that continues to be embuggered with regulatory red tape by a seemingly uncontrollable bureaucracy - :    

CASR Part 61 - Flight crew licensing - History

Consultation updates in 2016
AC 61-05 v1.0 - Night VFR rating
This AC has been published.
12 Apr 2016
Draft AC 61-05 v1.0 - Night VFR rating
All comments should be sent to the project leader, Damien Fing by close of business 29 February 2016.
15 Feb 2016

Consultation updates in 2015
FS 99/02 - CASR Part 61: Flight crew licensing
This project is now closed
Refer to the project closure notes for further information.
13 May 2015

Consultation updates in 2014
Project FS 14/25 - Post-implementation review of the Flight Crew Licensing regulations - Part 61
Project approved.
3 Dec 2014
Project FS 03/01 - Periodic review and ongoing amendments to include endorsements for new types and models introduced to Australia
This project is now closed
Refer to the project closure notes for further information.
3 Dec 2014
Civil Aviation Order (Flight Crew Licensing) Repeal and Amendment Instrument 2014 (No. 1)
Civil Aviation Order made.
27 Aug 2014
Civil Aviation Legislation Amendment (Flight Crew Licensing) Regulation 2014
Regulation made.
21 Aug 2014
Draft AC 61-08 v1 - Teaching and assessing non-technical skills for single pilot operations
All comments should be sent to the Project Leader, Roger Crosthwaite by close of business 31 July 2014.
16 Jul 2014
Project OS 14/12 - Performance Based Navigation and Reduced Vertical Separation Minima regulatory review.
Project approved.
2 May 2014

Consultation updates in 2013
Civil Aviation Legislation Amendment (Flight Crew Licensing and Other Matters) Regulation 2013
Regulation made.
12 Dec 2013
Civil Aviation Legislation Amendment (Flight Crew Licensing Suite) Regulation 2013
Regulation made.
21 Nov 2013
Consultation Draft for proposed amendments to the Flight Crew Licensing Suite
All comments should be submitted via the Project Leader, Mike Juelg by close of business Friday 25 October 2013.
4 Oct 2013
Consultation Draft for Part 61 Manual of Standards (MOS)
All comments should be submitted to the Project Leader via mos61@casa.gov.au by close of business 2 August 2013.
5 Jun 2013
Civil Aviation Legislation Amendment Regulation 2013 (No 1)
Regulation made.
14 Feb 2013

Consultation updates in 2011
Consultation Draft - CASR Part 61 - Flight crew licensing
Comments on this consultation draft are to be submitted via the online form by close of business 3 February 2012.
17 Nov 2011

Consultation updates in 2009
Project FS 06/02 - Multi-Crew Pilot Licensing (MPL)
This project is now closed.
6 Feb 2009

Consultation updates in 2007
Multi-crew Pilot Licence (MPL) Project team provided with Draft CAR 5 amendment

15 Aug 2007

Consultation updates in 2006
Project FS 06/02 titled Multi-crew Pilot Licence (MPL)
New multi-crew pilot licence project has been registered.
29 May 2006

Consultation updates in 2004
Industry consultation briefings cancelled
The Part 61 and 141 MOS consultation briefings scheduled for 23 August through to 15 September have been cancelled.
19 Aug 2004

Consultation updates in 2003
NPRM 0309FS - Flight Crew Licensing
NPRM 0309FS - Flight Crew Licensing, associated Annexes and Draft MOS Part 61 have been published. Your comments are invited by 29 September 2003.
18 Jul 2003
Project FS 03/01 - Periodic review and ongoing amendments to include endorsements for new types and models introduced to Australia
Project opened.
10 Jun 2003

Consultation updates in 2000
DP 0005FS - Flight Crew Licensing Structure
DP 0005FS - Flight Crew Licensing Structure, CASR Part 61 is available for public comment. Comments close 29 January 2001.
30 Nov 2000

Consultation updates in 1999
FS 99/02 - CASR Part 61: Flight crew licensing

Part 61 legislative instruments:

Part 61 is contained within Volume II of the CASR (see link below), from page 101 to 423 i.e. 322 pages:

CASR Volume 2 : 675 pages
r 45.005-92.205

---

Part 61 Manual of Standards Instrument 2014 is 664 pages contained within 4 Volumes, see links and page count below:

Volume 1 : 74 pages

Volume 2 : 254 pages  

Volume 3 : 228 pages

Volume 4 : 108 pages                                              

Kharon - "..Part 61 now has so many necessary exemptions as to render it farcical, it is no longer a law, but a crippled vehicle which the owners must keep repairing to salve their egos..."  

For reference - HERE - is the link for all the work done and in progress initiated by Oliver's Part 61 Tiger Team. Within that there is an additional link - HERE - which takes you to a page of 'legislative instruments' that have been introduced since the original Part 61 first became law on 01 September 2014.

Now in reference to the "K" post here is the latest list of exemptions put in place to address the shortcomings and industry imposts identified so far within the Bible sized CASA Part 61... :

Exemptions

• Exemption - instrument proficiency checks for aircraft pilot type ratings (CASA EX93/16)
  
• Exemption - CASR Part 61 aircraft flight reviews (CASA EX97/16)
  
• Exemption - CASR Part 61 aeronautical knowledge examinations and two year completion period: CASA EX86/16
  
• Exemption - aeronautical experience for an NVIS rating or endorsement: CASA EX77/16
  
• Exemption - single-pilot turbojet aeroplane specific instrument proficiency check exemption: CASA EX41/16 
  
• Exemption - from completion of an approved training course in multi-crew cooperation: CASA EX225/15
  
• Exemption - against ATPL flight test requirements: CASA EX222/15
  
• Exemption - Grade 3, 2 or 1 training endorsement (aeroplane) flight test: CASA EX219/15
  
• Exemption - from the flight instructor rating flight test: CASA EX218/15
  
• Exemption - from the pilot instructor rating aeronautical knowledge examination (PIRC): CASA EX215/15
  
• Exemption - from the spinning flight activity endorsement (FAE): CASA EX214/15
  
• Exemption - English language proficiency assessments: CASA EX146/15
  
• Exemption - logging of time in flight for co-pilots on single-pilot certificated aircraft: CASA EX116/15
  
• Exemption - Parts 141 and 142 - CASA approval of kinds of aircraft: CASA EX126/15
  
• Exemption - from certain low-level rating requirements: CASA 92/15
  
• Exemption - dual flight checks before solo flights by student pilots: CASA EX 78/15
  
• Exemption - aeronautical experience requirements for grant of commercial pilot licences - aeroplane category: CASA EX22/15
  
• Exemption - aerial application proficiency check and operator proficiency check (head of flight operations) - aeroplanes: CASA EX162/14
  
• Exemption - flight examiner rating for holders of CAO 82.0 check pilot approvals: CASA EX140/14
  
• Exemption - foreign cadet pilots taking flight test for a commercial pilot licence - class 1 medical certificate (replacement exemption September 2015): CASA EX156/15
  
• Exemption - aerial application rating and firefighting endorsement (replacement exemption August 2015)
  
• Exemption - of certain Cobham Aviation Services’ pilots from low-level rating requirement: CASA EX 130/14
  

 Simply staggering when you consider that the above only includes the 'exemptions' so far and none of the additional pages of related amendments that also require more & more legislative instruments to be generated and tabled in parliament. The Attorney General's department must have a separate section totally devoted to handling CASA generated legislative instruments - UDB!

Update: Part 61 taskforce extension - WTF?     

Caution: The following material may cause rapidly developing side effects. For example extreme nausea, manic depression, fits of rage and/or Part 61 induced PTSD...

Funny coincidence but yesterday Skidmores's Wodger WAP & the NFI Tiger Team released the following update to the latest Part 61 news page:

5 July 2016

Part 61 Solutions Taskforce extended to address remaining priority issues

CASA’s Part 61 Solutions Taskforce has been extended until 30 September 2016 so that additional guidance material can be produced for the aviation community and remaining priority issues can be resolved.

The Taskforce was formed in November 2015 to deliver solutions to valid issues associated with the flight crew licensing regulations (Parts 61, 64, 141 and 142). The remit of the Taskforce was to ensure that known or likely safety risks continued to be effectively addressed, that unnecessary costs were not imposed on the aviation community, and that the rules did not unnecessarily hinder participation or the potential for industry growth.

An Industry Advisory Panel – comprising representatives from a range of aviation industry sectors – was also formed to test CASA’s proposed solutions and provide input on proposals.

The Taskforce was originally established with a nominal completion date of 30 June 2016, but with the acknowledgement that the final end date would be determined by the full delivery of solutions to critical items on the flight crew licensing regulations issues register.

In its seven and half months of operation, the Taskforce has worked to deliver an extensive range of solutions and materials. To date these include instruments and exemptions that:

• extended the deadline for flight training organisations to transition to new rules
  
• introduced more flexible ways for pilots to meet multi-crew cooperation (MCC) training requirements, and clarified the standards for MCC training in aeroplanes
  
• relaxed some air transport pilot licence (ATPL) requirements
  
• provided a pathway for aerial agriculture rating holders to conduct firefighting operations
  
• provided clarity for the mustering sector on who can teach an examine mustering endorsements
  
• provided relief for pilots who operate single-pilot turbojets
  
• changed the instrument rating and ATPL flight test standards
  
• changed the commercial pilot licence and ATPL aeronautical knowledge examinations window from two to three years for people who passed
  
• relaxed the requirements and provided alternative ways for pilots to meet flight review and instrument proficiency check requirements.
  

View the full list of flight crew licensing instruments and exemptions.

In addition, the Taskforce has produced a range of guidance material designed to make it easier for industry to transition to new rules. This has included a Part 141 Sample Operations Manual, new syllabuses to help flight training organisations develop their courses, and a range of new information sheets designed to provide more accessible overviews of transition and regulatory requirements.

The Taskforce is currently finalising similar guidance for Part 142 flying training organisations, including a Part 142 Sample Exposition and supporting material. The Taskforce is also developing a range of other guidance for the aviation community such as the Flight Examiner Rating Course and Flight Examiner Handbook update.

Industry Advisory Panel members last met as a group on Friday, 1 July, to take stock of progress so far and negotiate on the next set of priorities for the Taskforce. The Panel has agreed to continue in its current form until the Taskforce winds down in 30 September, with future arrangements to be determined after that date.

Over the coming months, CASA will continue engaging with the aviation community to resolve remaining issues, including those relating to flight reviews, mustering, the multi-engine helicopter class, flight instructor training endorsements, flight tests, aerial agriculture, azimuth guidance and the ATPL flight test. Revisions to the Part 61 Manual of Standards are also being finalised.

It is anticipated that a Notice of Proposed Rule Making for the amendments to the flight crew licensing regulations will be released by the end of 2016. The amendments are designed to give permanent effect to the interim solutions that have been delivered to the aviation community via exemptions and other instruments of approval. CASA will continue to publish fortnightly updates to keep the aviation community up to date with the work of the Taskforce.

Please someone? anyone? NX perhaps? - please, please bring some sanity to Skidmore's CASA nut house - FFS!



MTF...P2

[thorn bird]

Can someone ask NX to enquire at the next estimates how much so far has been spent just by CAsA alone
implementing Part 61. Then ask him if CAsA could provide estimates expressed as a percentage of turnover how much Part 61 is going to cost the industry?

[P7_TOM]

Pre BRB warm up.

On any project you can expect ‘hiccups’; the art form is to be able to manage those nasty, hidden little gremlins which can, and do, pop up.  Even the best laid schemes of mice and men etc.  There is an engineering adage which has withstood, for a couple of centuries, the test of time. “ Man proposes; God disposes”.  Now my TOM built ‘heavy things’, things that mattered, things that were conceived then examined, then tested and examined, things that went through an acute process of research, design, finance before being tested again.  Eventually, when all possible cock-ups, down to the colour of the floor covering (and the cost) had been examined, critiqued, tested and costed the final plans were laid – even then – there were progress meetings and ‘accountability’ sessions.  As I said, these were not tin sheds, but important, expensive, engineering projects.  A lot, and I do mean a lot of care was taken before the first nail in the site office door was knocked in.

Heh heh, (quiet chuckle) got a little “K” syndrome for a while  there; it’s easy to run on – I digress.  To the point old fool.  Well, part 61 should never, not ever, have become a major capital expenditure program. My TOM built and commissioned a major oil refinery in Siberia for much less money.  Sure there were duck ups, delays, misunderstandings and some bloody awful concrete pours – but despite all that job done – on time and ‘just’ within budget.  Part 61 is a project out of control and beyond existing skill levels.  It has become an embarrassment to those who failed, miserably, not only to do their homework and budget; but it was created, designed and approved by someone with NFI.  The design was never ‘tested’ or the construct even examined in any form of ‘critical manner.  It is a pipe dream, one that should never have got off the drawing board, for no sane board of directors or investors would ever have approved such an amateur lash up – not in a million.

Now, CASA are forced into a risible position; the law can only work under an increasing amount of exemption and endless ‘amendment’.  The system is cumbersome, legally un-safe, inefficient in terms of time and money – and there is no end in sight.  The impact has industry reeling simply because the project was a wishful thinking exercise. This rule set was  drafted by those with absolutely no concept and less experience of running a flying business.  It reads like a first time around the block effort of a new chief pilot with little or no idea of the real world and how it wags.  

Now the ‘authority’ is too ashamed, em-bare-assed and scared silly about the repercussions from above, that it is forced to persist with and defend this ridiculous wet dream of a rule set.  Weeks needs to walk, Skidmore and anyone who else who has joined in the creation and defence of the existing mess should either resign; or, man up. Admit it’s the biggest crock to ever come down the pike and start again; preferably with a sensible rule set as a template.

Bugger, look at the clock – best get moving to the BRB.  Darts is a ‘friendly’ tonight, no set agenda and I do owe the lad a couple for making UP watch voluntary – maybe I’ll play him for them; unless he goes for double or square.  Risk assessment warns against such folly.

There now, that’s my well spent two bob’s worth.

[Kharon]

Buying a Rolls Royce?

What’s the old saying about expensive machinery, something like if you have to ask the cost, you can’t afford it.  Well, it’s about time we started to ask the monetary cost of Part 61, because I’m pretty certain we can’t afford it.

I’ve no idea what each ‘exemption’ and ‘instrument’ costs from whoa to go; but each disallowable document must pass through many hands before it is published, so the cost in man hours alone must be impressive.  Look over there; a ‘Tiger Team Member’ all spruce and raring to go arrives at one of the special desks, fresh Latte, play lunch, sharp pencil and new rubber in the ‘kit bag’.  In strolls OST and dumps a pile of paper on the desk “sort that out for me” says he.

Well, the TTM is not dismayed or overawed by this already expensive pile of paper. Indeed, although the cost of producing the original was massive it’s just another pile of work to unravel, rework, draft exemption to and send down the line; off he goes in fine style.  First task, decide what it all means – the purpose of the rule part, the mystery of language, the conundrum of intent and the heady maze of legal speak.  With the consummate ease of a master crossword fanatic TTM wrestles the beast and after may phone calls to legal, hours and hours on Google, a dim picture of what it is, emerges from the mists.  End day one.  Day two is spent refining the image to an acceptable standard which leads to scheduling a meeting day three.  The long meeting involves several others and takes a while, because although none could understand the thing in the first place, they all must be consulted now that TTM has got some idea of what it was all about. Eventually, the meeting is over, high fives all around; TTM has a go ahead to work the exemption.  Well after three days of work, the TTM needs a break; so day four is toast, which takes TTM to day five and the all day gabfest ‘progress’ meeting.  Welcome to the week end.

Eventually, by the end of the next week, TTM has drafted ‘the instrument’ for consideration by ‘other’ departments – after the weekend.

TTM’s draft spends the next week on various desks and by the Friday gabfest, covered in red pencil and traces of McDonalds sauce the tattered original is centre stage.  The resolution is carried and the draft is on it’s way to be typed up and printed for the ‘big-wigs’ gabfest.  Of course the top table boys are busy; so our instrument, now a tidy package must wait it’s turn. Towards the end of the week, the rubber stamp is used and our ‘instrument’ goes into the system, legal vet it, operations vet it; even the tea lady gets a peep, just to make sure all’s well.  Next stop, parliament.  Oh yes, this is now a disallowable document and it must be seen at least to go through the entire process before emerging for publication and distribution. How many hours of work, for how many people are involved there?

It’s said many hands make light work; that may be true, however I just wonder why so many hands are needed.  Had the ducking rule been done properly, the first time, we would not have needed so many for the repair and patch up job.  Of course the reversal process will need as much time, money and effort as the temporary patch up; then there is the cost of redrafting 61 all over again.  Work for a lifetime, right there. Don’t forget, we’d spent a squillion manufacturing this cripple, before they set about repairing and patching.  It may not be the best rule set in history, but it’s up there with one the most expensive.  Only CASA could duck it up so completely, then try to patch it up and flog off as an exemplar. Gods spare us.

Why? Well you can’t expect CASA to admit the rule is a complete and utter disaster and start again. Measure twice, cut once and be cussed less, should be tattooed, in mirror writing, on every TTM forehead, as a reminder of folly.

Toot toot.

[Peetwo]

Hot off the CASA PR spin cycle -

Part 61 Solutions Taskforce Closure Report

Executive summary

Background

The flight crew licensing regulations (Parts 61, 64, 141 and 142) which came into effect in September 2014 were subject to immense criticism from the aviation community. CASA was committed to addressing the concerns raised.

The Part 61 Solutions Taskforce was formed in November 2015 to deliver solutions to valid issues associated with the flight crew licensing regulations. The remit of the Taskforce was to ensure that known or likely safety risks continued to be addressed, that unnecessary costs were not imposed on the aviation community, and that the rules did not unnecessarily hinder participation or the potential for industry growth.

An industry advisory panel (IAP) - comprising representatives from a range of aviation industry sectors - was also formed to assist CASA prioritise the issues and provide input on proposed solutions.

The Taskforce was originally established with a nominal completion date of 30 June 2016, but with the acknowledgement that the final end date would be determined by the full delivery of solutions to critical items on the flight crew licensing regulations issues register.

Key highlights

Over 11 months, CASA has worked closely with IAP members to prioritise issues and find ways of making the transition to the new rules easier for the aviation community.

The Taskforce was a new way of working that CASA had not previously used. It represented a tangible example of the power of collaboration and cross-functional cooperation to achieve a common corporate objective.

The Taskforce's collaborative approach in the prioritisation of issues requiring resolution and the formulation, drafting and implementation of policy solutions made it significantly different to CASA's regulatory development consultation process. Feedback provided by IAP members highlighted that this strong focus on consultation and collaboration was a major factor in the Taskforce's success.

CASA was able to choose the right staff, at the right time, and bring them together into a single line of accountability reporting structure with clearly defined tasks, objectives and timelines which enabled the Taskforce to get the job done. The Taskforce was able to accelerate the work that was already underway to address the issues that had been raised by industry.

The Taskforce delivered on a large amount of work including: publication of guidance material for flying training organisations, reviewing the flight review and instrument proficiency check policies and developing a range of instruments and exemptions to allow the smooth continuation of operations until the regulations themselves can be amended.
The Taskforce received significant positive feedback from the aviation community on the Part 141 Sample Operations Manual, the Part 142 Sample Exposition, the instrument proficiency check changes and the sample competency based training and formatted syllabuses correctly mapped to the Part 61 Manual of Standards (MOS).

The permanent flight crew licensing regulation amendment package will be the final deliverable of the Taskforce. The regulations are expected to be amended in late 2016/early 2017. CASA’s formal industry consultation process will be used to communicate proposed amendments to the aviation community. Once the regulations have been amended the permissions and exemptions issued to deliver the interim solutions will be able to be revoked.

Key findings and recommendations

The Taskforce, within a short period of time, successfully delivered major solutions to assist the aviation community and CASA staff in the implementation and transition to CASR Parts 61, 64, 141 and 142. The outcomes can be attributed to the following:

• The Taskforce's strong focus on consultation and collaboration in the prioritisation of issues requiring resolution and the formulation, drafting and implementation of policy solutions.
  
• The commitment of the IAP to work with the Taskforce to resolve the issues and test the solutions.
  
• The Taskforce's model and methodology allowed a balanced representation of issues and concerns and a more thorough review and testing of solutions.
  
• The importance given to both the technical solutions and the human elements associated with the regulatory change.
  
• The Taskforce team structure, which was suitable for a multi-disciplinary environment, quickly built an agile and flexible environment.
  
• The single line of accountability approach allowed timely decisions to be made.
  
• The establishment of the Shared Services team provided a dedicated administrative support and allowed the technical teams to focus on addressing regulation and policy issues, and producing the technical material and content.
  

While the IAP considered the work of the Part 61 Solutions Taskforce highly successful, it held the view that the establishment of the Taskforce was a reactive approach and CASA should use the Taskforce model and apply it pro-actively when rolling out future regulatory change. The IAP felt, while the air transport regulations are 'settled', they should be reviewed; and its implementation plan appropriately consulted.

The IAP recommends:

• CASA consider more effective methods for its stakeholder engagement and consultation approach and work with the aviation community to find better ways to maximise the efficiency and effectiveness of consultations.
  
• More time should be taken to develop the regulations (including a consultation process). The focus should be on getting it right rather than meeting targeted deadlines.
  
• Make regulations achievable with the provision of clear pathways.
  
• Develop regulations in plain language or, at the very least, the provision of plain language explanatory and advisory material.
  
• Engage with the aviation community in the implementation planning for future regulatory change.
  
• Implementation programs should take into consideration the human factor ramifications.
  
• Engage CASA's Certificate Management Teams much earlier in the process.
  
• Leverage from established communication channels between CASA inspectors and the certificate holders and their key personnel.
  

Based on its experience and the lessons identified in the last 11 months, the Taskforce recommends the following methods of implementation for future regulatory changes:

• Conduct a review of CASA's stakeholder engagement approach during the regulation development and implementation phases.
  
• A model of collaboration and cross functional co-operation within CASA and with the aviation community.
  
• The establishment of suitable, flexible teams to work on preparation activities
  
• In consultation with the aviation community establish a clear delivery framework right from the beginning, including the methodology and implementation approach.
  
• Developing guidance material and acceptable means of compliance prior to implementation of regulations.
  
• The development of guidance, resources and tools as solutions packages and the provision of training for all affected CASA staff and the establishment of an inspector helpline prior to the implementation of the regulations.
  
• Adoption of similar online applications delivered by the Taskforce – an online forum to facilitate aviation community/CASA staff consultation; an enquiries management tool to track and monitor industry enquiries; a knowledge base tool to help CASA staff answer enquiries; an issues register and a continuous improvement process as part of both the development and implementation phases.
  

For ongoing work, the Taskforce recommends:

• Relevant CASA areas maintain, support and improve on solutions delivered by the Taskforce, including Part 141 Sample Operations Manual package and the Part 142 Sample Exposition package and the online tools.
  
• Continued training for CASA inspectors on outcome-based regulation and change management.
  
• The Flight Crew Licensing web content be improved to help industry and staff source information.
  
• Delivery of workshops to the aviation community on change management and outcome-based regulations.
  
• Conversion of the Part 141 and 142 assessor worksheets into more appropriate online forms.
  

OK so the Part 61 Tiger Team believe, besides a few minor administrative issues, that their job is done... 

Please explain?

However I still fail to comprehend why it is that our regulatory authority CASA believe Australia is so fundamentally different to most 1st world ICAO signatory States, that we require such prescriptive OTT regulations for Flight Crew Licensing.

For the sake of regional harmonisation why isn't the now 23+yr firmly imbedded and regionally adopted CAANZ Part 61 - see HERE - an acceptable rule set for the Australian aviation industry...


MTF...P2