[Peetwo]

First ANON submission - 

6 Name Withheld (PDF 292 KB) 

3. The immediate and long-term social and economic impacts of CASA decisions on small

businesses, agricultural operations and individuals across regional, rural and remote Australia

The following comment apply only to the impacts on individuals; there are no comments on the
impacts on small businesses and agricultural operations.

Legislative Instrument CASA 09/19 — Civil Aviation (Community Service Flights — Conditions on Flight
Crew Licences) Instrument 2019 has directly increased the maintenance costs, convenience and
satisfaction of volunteering to assist community service flight organisations.

In my own case, my aircraft maintenance costs of have increased by about 30 % annually. Because
my aircraft is used occasionally for community service flights and typically logs 120 – 150 hours per
year, it is now required to have a periodic inspection after 100 hours rather than 12 months. The 
aircraft did not suffer from any maintenance related safety defects during the man years it was
maintained under its previous, CASA approved, system of maintenance and there is no evidence that
the aircraft will be safer under the new inspection regime. 

The same Instrument imposes very inconvenient restrictions on a pilot’s ability to determine who can
travel as a passenger on a community service flight. For example, a pilot is now prohibited from
taking a spouse, another family member or a friend as a passenger unless that person is a member
of the flight crew. As with the maintenance regulation, CASA is unable to demonstrate any safety
benefit from this restriction and it is more likely that an additional passenger, even a non-pilot, will
enhance safety.

It is universally recognised that community services flights are vital for Australians living in regional,
rural and remote locations so anything that reduces the availability of these services without a
demonstrated safety benefit creates a significant disadvantage for those rural residents who rely on
the services.

What can be done – Legislative Instrument CASA 09/2019 should be withdrawn and CASA should be
directed to collaborate with organisations providing community service flights to develop mutually
acceptable voluntary codes of practice...

MTF...P2