[Kharon]

To all flying schools, flight examiners and testing officers

RE:  Important information to get the fastest processing result for applications/notifications

The introduction of CASR Part 61, 64, 141 and 142 did impact on PAC’s service delivery.  We acknowledge that there were difficulties for industry, as well as for us, in coming to terms with the requirements of the new regulations.  We know it has been frustrating for industry and applicants and we do appreciate your understanding and patience.  However, we are now significantly picking up the pace on our processing.  During the last 5 months we have identified a number of common issues with the applications/notifications we receive and offer the following points to assist you with the process, which will lead to reducing the time it takes to return a licence.

For the issue of a CPL/MPL, in accordance with CASR 61.245(3)(b), the flight test must not be conducted by the same person (HOFO/CFI) who has certified in writing that the applicant has met the requirements of CASR 61.235. Please ensure for these flight tests that the flight examiner did not also certify the applicant was suitable.  This requirement ONLY applies to a flight test for commercial or multi-crew pilot licence.

If the training provider is a Part 141 organisation, the person certifying under 61.235(5) must either be the operator’s head of operations or a person named in the Part 141 operator’s operation manual as responsible for the flight training to which the flight test relates.
If the training provider is undertaking Part 142 activities, the person certifying under 61.235(5) must be the operator’s head of operations (CFI).

You must ensure on notification forms, particularly form 61-2I, that the applicant does not inadvertently complete and sign the declaration for the Person under CASR 61.235(5).  We are receiving applications where this has occurred.  The Flight Examiner has then conducted the flight test.  This is not acceptable, and the application/notification will be returned and the applicant’s record will not be updated at this time.

For applications for licences, please ask the applicant’s permission to include the training provider’s contact details in Section C:  Applicant Declaration of the form and enter a contact name and email address.  This will enable PAC to return an incomplete application to the training provider at the same time it is returned to the applicant.  This will greatly speed up the time taken to address any issues with the application and ensure the applicant gets their licence as quickly as possible.  We are bound by the Privacy Act and we cannot return an application to a third party without permission, even though we understand many flying schools complete much of the form on behalf of the applicant.

Please ensure you read all forms carefully and that you and the applicant complete all sections of the form.  Remember, you do NOT have to submit KDRs with licence applications any more.
When conducting flight tests and submitting notifications to CASA (issue of operational ratings, class/type ratings, proficiency checks etc), you must complete and send the appropriate notification form to CASA – not just the flight test page. 

Please be aware that an aeronautical radio operator certificate (AROC) is NOT a replacement for a flight radio operator licence (FROL).  The requirements for a FROL, previously issued under CAR 5, are embedded in the training for the licence.  Therefore this application for an AROC is not required as part of any licence application, including for an RPL.

If you are conducting flight tests for the conversion of an overseas licence, please be aware that the conversion of an overseas flight crew licence is a two-part process.  The applicant will submit Form 61-4A to CASA, who will verify the licence and assess the application.  CASA will send a letter to the applicant advising them that CASA is satisfied they hold overseas permissions that CASA will recognise and advising them to complete exams before contacting a 141 or 142 organisation to organise a flight test for the licence and, if applicable, operational ratings.  The applicant should then complete exams and take evidence of successfully passing the exams and the letter from CASA to the Flying School.  The Flying School will assess the applicant’s competency and if they are satisfied they have met all the competencies, the organisation will book a flight test.  On completion of a successful flight test, the Flying School will submit Form 61-4B to notify CASA of the result.  These two forms should NOT be submitted at the same time.

For licence applications, we would appreciate it if you could let applicants know they can pay online.  Online payments are available from the CASA website.  This will increase our efficiency in processing applications.

Please use the following links for further information that we believe is pertinent to you.  Your students or candidates for flight tests would also  benefit from this information and we would appreciate your assistance in ensuring they are aware of these links.
Aircraft ratings (overview)

http://www.casa.gov.au/scripts/nc.dll?WC...=PC_101936

Aircraft ratings
http://www.casa.gov.au/scripts/nc.dll?WC...=PC_101931

Class-rated aircraft that require training and a flight review - includes list of aircraft types
http://www.casa.gov.au/scripts/nc.dll?WC...=PC_102048

An alternative to a class rating flight review — includes list of aircraft types
http://www.casa.gov.au/scripts/nc.dll?WC...=PC_102049

Aircraft type ratings (overview)
http://www.casa.gov.au/scripts/nc.dll?WC...=PC_101935

Guide to type-rated aeroplanes — includes list of ratings
http://www.casa.gov.au/scripts/nc.dll?WC...=PC_102026

A guide to type-rated helicopters — includes list of ratings
http://www.casa.gov.au/scripts/nc.dll?WC...=PC_102046
Flight reviews
http://www.casa.gov.au/scripts/nc.dll?WC...=PC_101937

Proficiency checks
http://www.casa.gov.au/scripts/nc.dll?WC...=PC_101938

New look pilot licences from 1 September 2014
http://www.casa.gov.au/scripts/nc.dll?WC...=PC_102135

Flight crew licensing - frequently asked questions
http://www.casa.gov.au/scripts/nc.dll?WC...=PC_102186

Flight Crew Licensing – Part 61
http://www.casa.gov.au/scripts/nc.dll?WC...=PC_101440

Flight Examiner Handbook
http://www.casa.gov.au/scripts/nc.dll?WC...=PC_102160

Flight crew licensing entry guide
http://www.casa.gov.au/scripts/nc.dll?WC...=PC_102094

CAR Part 5 Licence Instruction Guide
http://www.casa.gov.au/scripts/nc.dll?WC...=PC_102094

We are continuing to review our forms and processes to ensure we can make improvements that will assist industry and allow PAC to reduce service delivery timeframes.

Yours sincerely

Mark Taylor
Manager PAC

Got that - piece of cake -  Right  

[thorn bird]

"We acknowledge that there were difficulties for industry, as well as for us, in coming to terms with the requirements of the new regulations. We know it has been frustrating for industry and applicants and we do appreciate your understanding and patience".

Then from the April Missive.......

"Tell us how to cut regulatory red tape
People across the aviation community are being asked to contribute to efforts to reduce regulatory red tape. CASA is committed to the Federal Government’s deregulation agenda which aims to reduce unnecessary red tape costs on individuals, businesses and community organisations. The agenda applies to any mandatory obligations imposed by legislation, regulations or quasi-regulations. This includes statutory instruments, standards, codes of practice, or any other aspect of regulator behaviour that has a measurable cost burden on business or individuals. Costs imposed by new regulations must be offset, although not necessarily in the same area. It has been a long standing CASA policy to ensure safety regulations are necessary, risk based and cost effective, with no unnecessary cost burdens imposed on the aviation community. The Government’s deregulation agenda puts additional emphasis on CASA’s policy. Everyone in aviation is invited to make constructive suggestions on cutting red tape by sending ideas and comments to a dedicated email address. Suggestions can be made about removing unnecessary regulations, modifying inefficient regulations or simplifying CASA’s processes and procedures.
Send your red tape reduction ideas to: deregulation@casa.gov.au."

Sorry CAsA, ran out of patience a LONG LONG time ago.....just sent your Email to deregulation@casa.gov.au.

Red tape Reduction Idea:

"ADOPT NEW ZEALAND REGULATIONS"

Anyone got anything to add to that? Feel free to include it!

[thorn bird]

Under Part 61, what are the recent experience requirements for conducting instrument approaches?
The table to the right shows pilot recent experience requirements for different types of approach. Each one can be done in an aircraft, or a flight simulation training device approved for the purpose.

Approach type Pilot recent experience requirement
General Must have conducted at least three instrument approach operations within the previous 90 days
Aircraft category Must have conducted at least one instrument approach operation in an aircraft of the same category (such as aeroplane, helicopter etc) within the previous 90 days
2D approach Must have conducted at least one 2D instrument approach operation within the previous 90 days
3D approach Must have conducted at least one 3D instrument approach operation within the previous 90 days
Azimuth guidance Must have conducted at least one 2D instrument approach operation using azimuth guidance within the previous 90 days
Course deviation indicator Must have conducted at least one instrument approach operation using a course deviation indicator (CDI) within the previous 90 days

So why confuse the hell out of everyone with the Star Wars crap. What was wrong with calling them NDB,VOR,ILS,DME,GPS??? and why persist with this confusing costly recency crap designed to catch everyone out when nobody else does?

[P7_TOM]

Dick Smith is leading from the front again – ADS again, which led to CASA comment again, which brings out the Casamites; all quite amusing.  

Pinched this from the UP – LS - always worth reading:

Folks,

The bigger problem with Part 61/141/142 is complying at all, at any cost, and the ongoing costs of keeping licenses current under the "new system" is horrifying.

CASA must be forced to comply with its own manuals and mandatory Government policy, including genuine cost/benefit analysis at the beginning -- and this need amendment to S.9A of the Civil Aviation Act 1988 to make it really stick. By the time you get to a RIS it is too late.

Tootle pip!

We hear there is to be a letter despatched (if not posted already) to all FOI stating categorically, it is not industry's fault that 61 is becoming a national disaster and 'we' are to get assistance rather than show cause for non compliance.  The alarming thing is that 'the letter' seems to indicate that 61, as writ, is here to stay – Gods help us.

The top floor, full dress meeting, scheduled for this week is one small window for change.  Let us all pray, to whatever pagan gods amuse best, that with the imminent departure of a very large obstacle to 61 being thrown out, good sense and reason will prevail.  Just ring NZ borrow theirs; Nigeria would help; PNG would help; Fiji would help.  Hells bells, my Grandmamma could write a better rule set than the pathetic crew who cobbled the existing ego fantasy, promising the world and delivering an atlas.  

Breathless with anticipation the crowd awaits Terry's departure.  Amen to that....

[Peetwo]

Dick Smith is leading from the front again – ADS again, which led to CASA comment again, which brings out the Casamites; all quite amusing.  

Pinched this from the UP – LS - always worth reading:

Folks,

The bigger problem with Part 61/141/142 is complying at all, at any cost, and the ongoing costs of keeping licenses current under the "new system" is horrifying.

CASA must be forced to comply with its own manuals and mandatory Government policy, including genuine cost/benefit analysis at the beginning -- and this need amendment to S.9A of the Civil Aviation Act 1988 to make it really stick. By the time you get to a RIS it is too late.

Tootle pip!

We hear there is to be a letter despatched (if not posted already) to all FOI stating categorically, it is not industry's fault that 61 is becoming a national disaster and 'we' are to get assistance rather than show cause for non compliance.  The alarming thing is that 'the letter' seems to indicate that 61, as writ, is here to stay – Gods help us.

The top floor, full dress meeting, scheduled for this week is one small window for change.  Let us all pray, to whatever pagan gods amuse best, that with the imminent departure of a very large obstacle to 61 being thrown out, good sense and reason will prevail.  Just ring NZ borrow theirs; Nigeria would help; PNG would help; Fiji would help.  Hells bells, my Grandmamma could write a better rule set than the pathetic crew who cobbled the existing ego fantasy, promising the world and delivering an atlas.  

Breathless with anticipation the crowd awaits Terry's departure.  Amen to that....

 
From the Australian Aviation today...

CASA seeking feedback on Part 61

May 5, 2015 by Jordan Chong Leave a Comment
Civil Aviation Safety Authority boss Mark Skidmore has written to pilots seeking their feedback on the implementation of the new Part 61 regulations.

Part 61, which was introduced in September 2014, has caused consternation among sectors of the aviation industry which has prompted CASA to make adjustments to how these new suite of regulations for ratings, licences and endorsements are being implemented.

Speaking to reporters during a conference call on Tuesday, Skidmore said CASA had already received about 10 emails from pilots since the letter was posted on April 23, offering suggestions or questions on topics such as ratings and endorsements, suggestions for medical tests and flight reviews and the format of the licence, among other topics.

Skidmore, who started as Director of Aviation Safety in January, acknowledged CASA had not implemented Part 61 “as well as we should have”.

While he believed the regulator was coming to grips with the major concerns out there in the community, more feedback was needed.

“Communication is definitely one of the things we need to work on to make sure that people can clearly understand what it is we are trying to achieve with Part 61,” Skidmore said.

“We have to be consistent in our approach to the aviation community so we don’t confuse them so we can make sure we are providing good, relevant consistent information out to people. I will continue to drive that.

“I don’t know what I don’t know, hence the letter to say we are working on this, we are getting good information but we would like to know more. If you’ve got something let us know.”

In the letter, the Director of Aviation Safety said some of the changes to Part 61 already made were related to check pilots conducting proficiency checks, low level ratings and aerial mustering training and flight testing, fire fighting operations, aerial application proficiency checks and R22 and R44 helicopter ratings.



CASA Director of Aviation Safety Mark Skidmore AM (CASA)

It also said about 10,600 new Part 61 licences have been issued since September 2014, with the transition period running until September 2018.

The Part 61 manual available on the CASA website is published in four volumes and runs to more than 600 pages.

CASA manager for flightcrew licensing standards Roger Crosthwaite said the document needed to be large given it covered a such a large array of ratings, licenses and endorsements.

There were plans, however, to make the information more accessible for industry participants, with better presentation and enabling scenario-based searches.

“I am very hopeful that we will have a more electronic version where people go on and say I want to get the standards for the PPL helicopter and the system will provide those, draw them together, under a knowledge base to present the standards,” Crosthwaite said.

The move to introduce Part 61 came before Skidmore’s joined CASA and was during a period where the industry and the regulator experienced an at-times difficult working relationship, which was highlighted in the Aviation Safety Regulatory Review.

Moreover, some in the industry warned CASA at the time of the difficulties Part 61 would cause.

Skidmore said although he was unable to change what happened in the past, he was committed to rebuild some of the trust that was lost in recent times by learning from what had happened and making sure “we don’t do it again”.

Part of that will be cultural change “both on my side for CASA and externally for the community to understand and to trust us”.

“Cultural change takes five to seven years,” Skidmore said.

“In a year or two, you will start to see it actually going. I will be looking for that.”
CASA’s letter to pilots can be read here.

This bit..

"..The Part 61 manual available on the CASA website is published in four volumes and runs to more than 600 pages.



CASA manager for flight-crew licensing standards Roger Crosthwaite said the document needed to be large given it covered a such a large array of ratings, licenses and endorsements.."

FFS this Wodger needs to be given a reality check I reckon...here we go the NZ Part 61  (err...79 pages??).

On 2nd thoughts forget it, if this Wodger hasn't realised by now that statements like that are absolute bollocks and an insult to the intelligence of the average IOS member...well God help him at the next Estimates..

MTF...P2   

Breathless with anticipation the crowd awaits Terry’s departure.



To-morrow, and to-morrow, and to-morrow,
Creeps in this petty pace from day to day,
To the last syllable of recorded time;
And all our yesterdays have lighted fools
The way to dusty death. Out, out, brief candle!
Life’s but a walking shadow, a poor player,
That struts and frets his hour upon the stage,
And then is heard no more.
It is a tale Told by an idiot, full of sound and fury,
Signifying nothing.

- See more at: http://auntypru.com/#sthash.t894Zsqu.dpuf

[Kharon]

61 ways to flog a dead horse.

Unless there is a very real wake up call to the bored issued this week 'we' are going to be stuck, forever with the bastard, retarded mutant of Part 61.  Not only is the rule set hopelessly esoteric, academically flawed, operationally complex, unnecessarily convoluted, totally impractical, it is legally unsound – from industry point of view.  There simply is no protection; each and every paragraph may be turned into a large stick, used to beat the hapless victim insensible. 

The rest of the world get by with less than 100 pages of clear, sensible, sane requirements; that list is long.  These countries do not make a 'safety issue' of what is, essentially an administrative matter.  Administrative in as much as there is system, which must be complied with – such NZ has, for an example.  What is not in the NZ/FAA rule is some pseudo academic (writ by the village idiot on an ego trip) definition of 'standards' defining not only how to put your pen back in your shirt pocket, but the penalty for not doing it according to prescription; or how to place your feet on the rudder; or how to best do asymmetric circuits, at night.  My own favourite – a note excusing you from doing an engine out overshoot in a single engine aircraft: don't laugh, not until you have read through this 600 page monstrosity.

Perhaps a nicely polite letter to the bored and the DAS informing them that the rule set is unacceptable, unworkable; and, industry refuses to tolerate the impost, the legal risks, the incredible amounts of paper required or the implications contained with 600 pages of wishful thinking.  The short version, if you prefer – stick where the sun don't shine.

Toot toot.

Well, everyone's buggering about, playing nice and remembering the pogroms of McComic era. Sod that – tell 'em - it's a ducking crock; loud long and often.  Steam by pass valve – opening.   FFS – JUST BIN THE BLOODY THING.  You know you want to.....


Whistles up dogs; ambles off, cursing fluently, colourfully, robustly and with feeling. 

[Kharon]

Shamelessly lifted from the UP boards.

There are some who can distil a sound argument into common sense.  The inestimable "Creampuff" continues to provide a balanced point of view.  Pearls cast before swine mostly, but I admire his wit, tenacity and logic.  Shamelessly lifted from the UP boards, from the thread – HERE - :- Creamy – on song.

I refer to the Director of Aviation Safety’s letter dated 30 April 2015, inviting feedback on the new flight crew licensing suite of regulations.

As a preliminary point I note that the many stated aims of the new regulations have, over the years, included: 

- “safety through simplicity” 
- “harmonisation”
- “a less prescriptive, outcomes-based safety regime”, and
- “no exemptions” (because they would no longer be necessary in a simple, harmonised, outcomes-based safety regime). 

The new regulations achieve none of those aims. In fact, they achieve the opposite.

The Dreamliner was promised but the Spruce Goose has been delivered. The people who paid and waited for the Dreamliner are now not only stuck with the Spruce Goose, but are expected to take seriously the suggestion that this monstrosity can be “continuously improved” into an even better Dreamliner, this side of hell freezing over. 

I invite CASA to identify one provision of the new flight crew licensing regulations that has demonstrably caused an improvement in safety compared with the pre-existing regulations, at no cost or at a cost commensurate with the improvement.

I note that a person required to keep a personal logbook commits a criminal offence if the person does not retain the logbook, unaltered, for seven years after the last entry was made in the logbook: CASR 61.355. I invite CASA to describe one realistic scenario in which the throwing of a pilot’s logbook into the bin, 6 or so years after the pilot’s last flight as crew, would cause any material safety risk. Just one realistic scenario. (Hell, even an unrealistic scenario might shed some light on what’s going on in the head of whoever decided that making this a crime would contribute to safety.)

I note the exquisite genius of the confusion created by the convoluted complexity of the meaning of “flight time” in Part 61 of CASR compared with the definition of “flight time” in the 1988 Regulations. In the 1988 regulations, the duration of a flight starts when an aircraft first moves under its own power for the purpose of taking off. That definition in itself causes some chronically-unresolved issues. E.g. the PIC can’t give binding directions to PAX during ‘push-back’, because 309A is linked to the definition of ‘flight time’ in the 1988 regulations.

But now we also have Part 61, in which the duration of a flight starts from the moment an aircraft begins moving, whether or not under its own power, in preparation for flight. Does that mean I log PIC time from the moment I tow my aircraft out of the hangar in preparation for flight? If so, I’ve just increased my aeronautical experience by about 25%, by all the hangar door closing, head scratching, nervous weeing and paperwork I do before turning the key. Am I therefore 25% safer? 

Of course, it’s not possible to understand what all of the new regulations mean, without knowing about and understanding the effect of the myriad of exemptions that may variously negate, alter or extend the effect of the regulations. Given that I realised, about 10 years ago, that almost nothing in the ever-growing piles of regulations and manuals and exemptions made much practical difference to the safe conduct of flying activities, I doubt whether I’ll ever be inclined to gain that understanding, or that my safety will be compromised by not doing so. 

Importantly, I realise that many in CASA are among us poor passengers stuck on the Spruce Goose. Although lots of people blame CASA for the design of the Spruce Goose, I realise that CASA has neither the resources nor the competence to design a safety regulatory regime and, to the limited extent that CASA has come up with good design ideas, changes have often been dictated by people outside CASA - the government equivalent of the marketing gurus and the bean counters and the legal department, all of whom have irreconcilable demands and won’t be on the test flight. 

But problems are difficult to solve unless there’s an understanding and genuine acknowledgement of the real extent of the problem.

The problem here is that the new regulations are a monstrosity, and no amount of continuous improvement is going to change that. 

CASA needs to genuinely acknowledge and confront that problem, or it will continue to be part of and blamed for it.

Bravo CP, Choc frog quality, Tim Tam logic,  thank you.

[Peetwo]

Apparently on the UP Lefty made a point of highlighting that "K" had copied the Creamy post - thank you Lefty for the free promo...

Off the CP post (above) - IMO the following should be quoted by any IOS member considering responding/providing feedback to the Skates Part 61 correspondence:     

I refer to the Director of Aviation Safety’s letter dated 30 April 2015, inviting feedback on the new flight crew licensing suite of regulations.

As a preliminary point I note that the many stated aims of the new regulations have, over the years, included:

- “safety through simplicity”
- “harmonisation”
- “a less prescriptive, outcomes-based safety regime”, and
- “no exemptions” (because they would no longer be necessary in a simple, harmonised, outcomes-based safety regime).

The new regulations achieve none of those aims. In fact, they achieve the opposite.

The problem here is that the new regulations are a monstrosity, and no amount of continuous improvement is going to change that.

CASA needs to genuinely acknowledge and confront that problem, or it will continue to be part of and blamed for it.

However I (like "K" above) find it concerning that Skidmore needs any further feedback on the Part 61 monstrosity. He already has a very readable file reference in the form of the ASRR submissions page that should provide ample clues on industry objections to Part 61...

Here is a couple of links to some of the submissions that take issue with Part 61: AIPA VIPA AAFI REX RAAA 

Of those five IMO the VIPA submission encapsulates most of the still outstanding issues with Part 61 and also questions why we aren't standardised to either the FAA or EASA Part 61 regs:

 
Key to the Tim Tam cupboard for VIPA I reckon...

However it would appear that Skates is still choosing to ignore much of the excellent contributions from associations and organisations that put considerable time and effort into their ASRR submissions...

From off today's Oz article -  Mark Skidmore: CASA to fix bungled flight crew rules:

“We need feedback from individuals about what is working well and what is not.’’


Initial feedback looked at ­issues ranging from ratings and endorsements, the licence format, the need for air transport pilots ­licence flight tests and confusion about the transition for private pilot’s licence.

Officials said the dozen emails received by Tuesday were constructive and dealing with the ­issues. In a phone hook-up with reporters this week, Mr Skidmore said how long it took to address the Part 61 issues would depend on the feedback he received from the letter.

He said this included making sure CASA staff were educated about the changes so that they clearly understood what the authority was attempting to achieve with Part 61.

Asked about criticism of CASA’s failure to respond to industry warnings before the changes were implemented, he noted this had occurred before he was appointed. “I can’t correct the past,’’ he said. “All I can do is try and correct the future and learn from it and hopefully make sure we don’t do it again.

“But at the same time what I’m trying to do now is … get the information — here’s my letter to ­people to say tell us what you think is not right and let us have a look at it and try to correct it.’’

    
“We need feedback from individuals about what is working well and what is not.’’

He wants to hear from individuals - but that's bollocks there are literally thousands of individuals who are members of associations like VIPA, AIPA, RAAA, AMROBA or the AAFI who feel more comfortable (safety in numbers) being affiliated with presumably many other like-minded people and have their views voiced by their association rather than individually...FFS..

Hmmm...I'm beginning to wonder whether Skidmore is just killing time and is merely another benchwarmer marking time till the industry becomes yet again impatient & splintered through individual self-interest & self-preservation.

Time & patience is fast running out Skates ..tick...tick...tick...tick



MTF..P2

[Gobbledock]

I have two comments to make as follows;

a) Lookleft is a washed out f#ckwit. He has spent so much time with his pin head stuck up corporate assholes that his moustache is permanently stained crimson yellow. And,

b) Dear Mr Skidmore, Part 61 as it stands is an absolute load of shit. You and your wordsmiths such as Aleck, combined with a conglomerate of pilot has-beens and the massive volume of written excreta do not know shit from clay, let alone what works correctly in the flying side of the aviation industry which includes flight schools, commercial operations, GA, helicopters, overall fixed wing and rotary operations and Ag. By default, you, as DAS are presiding over one of the worst, most ridiculous, absolutley crap implementations since the Liberal party was born.
Sir, please extract your head from the sand and flush Part 61 down the shitter immediately. Then could you please contact your NZ counterparts who, unlike CAsA seem to have an actual understanding of what is required, and they also listen and consult with industry, an industry which quite frankly knows more about flying than either you or your minions who have spent half their life protected by a government pay packet.

Warm regards
Gobbles

[P7_TOM]

"K" - I have copied your post to the 61 thread, says pretty much exactly my response to the GD. Saves me restating what the world knows - the only question remaining is - Is Skidmore playing for time while industry fights his fight for him?  If so, then I agree with the Gobbledock; prevarication and hiding behind the front line is not what you would expect from a 'leader of men'.  A crafty Crat, perhaps - but this is a borderline cop out.  Wonder what the Rev Forsyth thinks of it all: probably unprintable.     

Bollocks – quote - un quote.

But he agreed it was sometimes difficult for the industry to accept change.

Completely absurd, unmitigated BOLLOCKS.   Scrap the bastard AUSTRALIAN part 61 – Bring in a slightly modified FAA/NZ part 61 and watch how fast the industry embrace change and how hard it will work to make the change seamless.  The speed will blow your socks off.  

Quote:
“We need feedback from individuals about what is working well and what is not.’’

“But at the same time what I’m trying to do now is … get the information — here’s my letter to people to say tell us what you think is not right and let us have a look at it and try to correct it.’’

Mr Skidmore also revealed he was looking at reinvigorating the Standards Consultative Council as one way of improving the regulatory process.

“That’s nice when you can see that starting to happen, so I’ll be looking for that and I know you guys will judge me on it,’’ he said.

Mr Skidmore took the unusual step last month of writing to all pilots about Part 61 seeking feedback on the rules.

“We need feedback from individuals about what is working well and what is not.’’

More Bollocks – Take weekend off and READ the ducking thing; then try to make it work; start with a humble single engine 'charter' operation; work through to a mixed multi engine aircraft IFR fleet; take a stroll on the RPT/ FIFO heavier operation then, just for fun try a flight school. Then take a week away and visit those operations (not the CAsA selected ones, that's too easy). When you have gained some insight into 'running' an operation – from the coal face; sit down again and try to make Part 61 'work'.  Perhaps, when at least a vague understanding of how civil aviation is managed has been gained; the charge to bin this appalling travesty will be led from the front; by a DAS.  One who has at least faint comprehension of reality, rather than the current mush being spoon fed by those who have made a complete hash of the current 'rule set'.

Study of Part 61 as opposed to having tea, biscuits and endless 'chats' with the vested interest society will, or should, shock the DAS into coming to grips with doing his job; as it should be; not the way of bunch of highly skilled word weasels want it done; but the way industry demands he do it.  If he is not prepared to do it properly, he should bugger off back to whichever sheltered workshop spawned him and learn to knit.  

Mate, the skip is out of the back door, turn right walk ten paces, lift the lid and just drop the Part 61 abomination in there, close the lid.  Then I'll put the kettle on and we can have a look at the rest of worlds, ICAO compliant, best practice rule set.  Lets see if we can loose 500 pages of mindless, amateurish dribble.  

Feed back – Bollocks.... Dodgy .....Listen, the same vicious, vengeful casamites who terrified and beat the industry into silence are still doing their jobs.  Tel me how FFS do you expect to get 'honest' feed back?, from those who have businesses and jobs to protect.    

FCOFL - Toot ducking toot, toot, toot....  .

There, I feel better now.

Me too sunshine, me too... ..

[Gobbledock]

Someone should tell Skates that there are plenty of people wiling to 'talk'. He should also be informed and educated as to what his troops have done in the past to industry participants when they speak up.

[Kharon]

Australian Flying – Platitudes aplenty.

Mostly, I don't mind Hitch, but I'm calling BOLLOCKS on this half assed, badly informed, opinionated, pandering paragraph.  Aye platitudes for all, but of analysis, nary a word.  
 

Hitch - There was, I believe, a noticeable absence of the spleen-venting rants the regulator is so often subjected to. The problem with rants is, even though the base sentiment is valid, it has to be set aside. Emotive language and finger-pointing does nothing to add power to an argument, and actually obliterates the logic so the reader often doesn't get the point. I'm going to take the lack of brickbat flinging as a sign that the aviation community is now willing to do its part in bringing real change to aviation safety regulation.

WRONG:- and it won't be Hitch or his readers who have to plough their way through the unbelievable mess.  I wonder when we will see a Part 61 analysis from Hitch, there's a challenge.  Instead of writing trite little articles, let him take Part 61 home this weekend and do us an in depth review for next week; present it as the 'without a Hitch' solution.  
 
Hitch - I can't see how much more feed back Skidmore needs; this is just another 'consultation' ploy, a play for time.  The 600 page monstrosity referred to as Part 61 has 500 more pages than any other sane regulator publishes.  That's just for starters, it would take a crew of qualified lawyers a twelvemonth to untangle the language, extricate the hidden hangman's nooses and boil it all down to a point where 61 could even start to be framed in compliance with the current government recommendations.  Strict liability is risible as are the allusions to 'criminality'.  Part 61 is not good law but the pet policy of a control freak with a box ticking fetish.
 
Why should the industry be asked to sort out yet another CASA debacle; free of charge. The solution is simple; bin the Australian Part 61, revert to old system while the NZ part 61 is 'tweeked' to suit.  The Act can be changed during that period. Why waste time trying to make a sows ear into a silk purse.  Within the same time period it will take industry to sort out CASA's mess, wait for a response, wait for the changes (if any) to be effected; we can have a sane, sensible rule set in place which industry can 'safely' work with.  

No one who has tried to make 61 work has ever said "Whoa, this is great", not anyone who has read it that is.  RTFT Hitch, then get back to us..Remember it cost a fortune to mount this 600 page garbage pile and they want industry to tell 'em what's wrong, for free.  Strewth.

Long string of expletives - deleted.

[P7_TOM]

On behalf of an absent associate, for your consideration:-

Folks,

I would remind everybody that Part 61 plus MOS plus Advisory Documents plus CASA policy/interpretative/training documents now runs to 2200 pages and growing, not the 600 pages below. The total of pages that is legislative is about 1700.

The inconsistencies, conflicts etc. are simply impossible to manage, without a wholesale re-write on a basis that complies with the Government policy for red tape reduction.

Only now are people in the aviation community waking up to the real costs of this monster.

I cannot afford to do the multiple reviews now required, (about 6) to do what I did with one biennial flight review before last September.

In a recent Flying article, the Australian v. NZ requirements for a review were in stark contrast, and the Australian cost greatly underestimated the total, if you include multi-engine or IFR/PIFR.

Under Part 61, the PIFR has been completely changed, it is now little different to a CIR, I guess we will go back to the old figures of UCFIT (uncontrolled flight into terrain).

The whole point of the PIFR has been lost.

Cheers,

[Kharon]

Hitch and the hornets nest, a cautionary tale.

From fearless Phelan, a short but succinct response.

Hitch, Would you mind skimming through the attached document and identifying any spleen-venting rants so I can tidy it up a bit?

Cheers, PP

The puff piece from 'Hitch' has brought those who made submissions, took time to study and have diligently tried to find some glimmer of sanity in garbage heap 61, out swinging.  'We' did after all pay, dearly, for abomination #61 and, rightfully feel entitled to some value for money.   

It's bad enough that Skidmore is bluffing and throwing up a pony-pooh dust storm, claiming to be 'desperate' for 'feedback', which is unmitigated Bollocks.  We expect a mouthpiece like Creedy to murmur sweet nothings; but I would have expected better from a 'writer' who represents some of those who will be worst hit when the hammer falls.  

Perhaps Hitch and his ilk (maybe even Skidmore) should read the ProAv submission – HERE - . Virus and spam free from the Aunty Pru library.

Part 61 is not good law but the pet policy of a control freak with a box ticking fetish. 

Toot toot. 

A taste of truth and sanity; from Phelan.

Executive Summary.


This submission concludes that a pervading “culture” exists within the Civil Aviation Safety Authority that has degraded relations between the regulator and most industry sectors to a point where it is impacting negatively on air safety in ways that we illustrate by reference to examples. 

It is submitted that this culture has developed, evolved and progressively expanded and consolidated since CASA was established in July 1995 and first designated as an independent statutory authority. We believe several symptoms of the existence of this culture can be identified in the examples we cite, and that it is manifested by the interaction between CASA departments which our examples illustrate. 

It is acknowledged that a number of quality employees remain employed by CASA, although their numbers are reducing and their capability to influence the way the regulator carries out its functions has been so limited that numerous key figures have voluntarily left the organisation. 
A majority of the aviation stakeholders we have consulted observe that the embedded anti-reform culture still exists and thrives within the organisation. They point out that it has already survived several high-level enquiries; and that events have proven that no reform can be effective unless those influences are identified and permanently negated.
 
CASA has operated, and continues to operate under the notion that to be legal is to be safe. Nothing could be further from the truth, particularly when the industry is forced to operate under flawed and ambiguous legislation while separate offices; and at times different officials in the same office, make differing decisions when applied to different operators requesting identical approvals. 

We consider the situations we detail demonstrate that solutions cannot be developed and recommended without significant amendment to the Civil Aviation Act and Regulations.

[Peetwo]

Australian Flying – Platitudes aplenty.

Mostly, I don't mind Hitch, but I'm calling BOLLOCKS on this half assed, badly informed, opinionated, pandering paragraph.  Aye platitudes for all, but of analysis, nary a word.  
 

Hitch - There was, I believe, a noticeable absence of the spleen-venting rants the regulator is so often subjected to. The problem with rants is, even though the base sentiment is valid, it has to be set aside. Emotive language and finger-pointing does nothing to add power to an argument, and actually obliterates the logic so the reader often doesn't get the point. I'm going to take the lack of brickbat flinging as a sign that the aviation community is now willing to do its part in bringing real change to aviation safety regulation.

WRONG:- and it won't be Hitch or his readers who have to plough their way through the unbelievable mess.  I wonder when we will see a Part 61 analysis from Hitch, there's a challenge.  Instead of writing trite little articles, let him take Part 61 home this weekend and do us an in depth review for next week; present it as the 'without a Hitch' solution.  
 
Hitch - I can't see how much more feed back Skidmore needs; this is just another 'consultation' ploy, a play for time.  The 600 page monstrosity referred to as Part 61 has 500 more pages than any other sane regulator publishes.  That's just for starters, it would take a crew of qualified lawyers a twelvemonth to untangle the language, extricate the hidden hangman's nooses and boil it all down to a point where 61 could even start to be framed in compliance with the current government recommendations.  Strict liability is risible as are the allusions to 'criminality'.  Part 61 is not good law but the pet policy of a control freak with a box ticking fetish.
 
Why should the industry be asked to sort out yet another CASA debacle; free of charge. The solution is simple; bin the Australian Part 61, revert to old system while the NZ part 61 is 'tweeked' to suit.  The Act can be changed during that period. Why waste time trying to make a sows ear into a silk purse.  Within the same time period it will take industry to sort out CASA's mess, wait for a response, wait for the changes (if any) to be effected; we can have a sane, sensible rule set in place which industry can 'safely' work with.  

No one who has tried to make 61 work has ever said "Whoa, this is great", not anyone who has read it that is.  RTFT Hitch, then get back to us..Remember it cost a fortune to mount this 600 page garbage pile and they want industry to tell 'em what's wrong, for free.  Strewth.

Long string of expletives - deleted.

Well, well..look who the Ferryman dragged out of the woodwork for public comment...

Brian J Hannan PAIN_NET • 18 hours ago


As retired VP of AOPA and having a long history of hard negotiating with CASA and some wins for GA I am disappointed to read the above
comment.

I based my crossed swords with CASA and AsA on facts, data and evidence and I read into the Hitch comment that is what he suggests as appropriate - "constructive and logical".

Yes, we all know Part 61 is overweight and illogical. Accordingly Industry should point that out to Skates, together with recommended solutions. Not buried in emotive claptrap.
I write occasionally for AF and have had many debates with Hitch
where we don't agree. This time I don't disagree with what he wrote.

Seems to be some confusion in the above comments about the role
of a reporter versus that of Industry and the various alphabet organisations in regards to fixing Part 61.

Again we are fighting among ourselves, wasting time to the detriment of fixing CASA. Sad, let's not waste further energy on such negativity.

Brian Hannan   

I agree with Hannan's last about fighting amongst ourselves but IMO that is not what this is about. It is about calling bollocks on bad law that quite simply should be scrapped.

It is fanciful that people (mainly CASAmites) continue to believe certain parts of this monstrosity could be salvaged/modified to suit. Usually these believers come from a certain select industry minority and do not realise that by trying to negotiate individually with CASA LSD (Iron Ring) that they are allowing CASA to again "Divide & Conquer", in this case industry dissent on Part61.

No the IOS majority needs to keep singing loud & clear BIN IT Skidmore ASAP...

Hitch, Would you mind skimming through the attached document and identifying any spleen-venting rants so I can tidy it up a bit?

Cheers, PP 
  

Love it PP -   Bit of light reading in that submission..
MTF..P2   

[Gobbledock]

That's quite amusing commentary coming from Herr Hannan. If ever there was a spewer of emotive claptrap it would be he!!

[P7_TOM]

Reading between the lines.

The "Hitch" article containing 'the' paragraph which has angered so many needs to seen in context and in light of past experience.  Before becoming embroiled in history; perhaps we should consider what it is 'industry' is actually being asked to provide feed back on.

CASA insists it is above the law, a law unto itself, divorced from the industry it serves.  CASA has spent, we hear, in excess of AUD $230,000,000 dollars over nearly a quarter century producing reformed regulation; Part 61 is one of those reformed parts.  CASA insists that it is a world class organisation and only CASA has the expertise to draft and implement these new regulations. They tell us so and more at every opportunity.  This mark you, despite many reports and recommendations pointing out, in no uncertain terms that CASA is a moribund, failed organisation, which now, suddenly 'seeks feed back' and reassuring hugs from industry.  An industry it has ruthlessly exploited, bullied, abused, swindled and denigrated.  An industry who's advice it has consistently and arrogantly ignored now seeks assistance to understand not only what is wrong with 'their' Part 61 but how to fix it. This after writing the wretched thing and having spent (or wasted) an incredible sum to produce the perverted, preferred CASA version of Creampuffs Frankenstein monster.

Now industry is being asked to not only accept this flawed regulatory suite as is; but to willingly assist the people who created it, despite all previous advice.  Had CASA taken a look at the FAA or NZ CAA part 61, they had a template on which they could have built a sound foundation. What we have is a 600 page regulation supported by a further 1000 odd pages detailing how we should tie our boot laces.  Error upon error, flaw upon flaw and enough holes to drive a horse and cart through.

Being asked to repair and live with a flawed regulation is unacceptable, just the cost of the flawed product, stand alone, makes it a ridiculous proposition.  But being asked to stand still while each individual alphabet group is picked off with platitudes, compromise, exemptions and 'special' approvals, as a mark of favour is the ultimate insult.  This is history repeating.

Hitch calls for 'compromise' and 'understanding – I call for a revised regulation, on a par with the worlds best.  No more, no less; it is what we paid for.

And pay for it we have, paid and waited many a long year for it and IMO industry deserves the very best, not this ridiculous school boy attempt at writing 'law'.   Industry cannot and must not be fobbed off with a repaired, patched, legally unsound, operationally ludicrous regulation which was useless in the first place.  A regulatory suite with which compliance will cost a small fortune. Not to mention that placing Part 61 in the hands of some officers is like giving a homicidal maniac a large axe and the keys to the sheltered workshop.

Repeating history is visible from the 24 years of failed, flawed reform accepted as routine by an industry scared of its own shadow, happy to accept whatever rubbish the peerless CASA dole out, as and when pleases.  Only to find ways to 'satisfy' the regulator while trying desperately to find a 'work-around' solution to the lunacy.   The rub is when the sound a fury has all died down, nothing, absolutely SFA will have changed, except more risk of being accidentally in breach, criminally prosecuted and deemed unfit, because the date on your flight plan was wrong; or some inutile twerp decides your radio call was not 'as per the book'.   Cooperation with CASA has always been a one way street; their way, straight to hell; or an accident, or a life of abject slavery to the almighty exemption, issued by 'your' mate in the office up the road. Only in Australia would this third class, shabby treatment be accepted.   

I'll second the BOLLOCKS motion.  Hell, I'd even donate a skip for the garbage.

[Kharon]

CASR Part 61 : start 1999 – ended 2015.  That's what – 16 years at 100 pages per annum, to produce an ineffective, incomprehensible bastard version of a rule set which began life as a jolly good idea,  Bravo.   Using the same formula a practical, sensible version, similar to the NZ rule set, with a modest less than 100 pages total should have taken, even at CASA speed, about a year to produce.  So WTF has happened during the lost years and what do 'we' have to see for the investment? 

Three things which, IMO demand serious answers : (i) the dollar cost of those 15 additional years; (ii) the almost unworkable, legally dangerous nature of the presented 'regulation'; (iii) that Australian industry is prepared to invest further time, effort and money in rectifying this monstrosity.   

The why, who, when and how of this aberration have me wondering if perhaps it's me that the village which lost it's idiot is looking for.  Because one of us is barking.  To start with a relatively straightforward, sane idea for simplifying and modernising a rule set and to finish up with the anathema* as presented, then to meekly accept it, and then happily volunteering to assist in rectifying the wretched thing; all point to insanity.

Woof woof.  



* ("something dedicated to evil and thus accursed").

[Peetwo]

CASR Part 61 : start 1999 – ended 2015.  That's what – 16 years at 100 pages per annum, to produce an ineffective, incomprehensible bastard version of a rule set which began life as a jolly good idea,  Bravo.   Using the same formula a practical, sensible version, similar to the NZ rule set, with a modest less than 100 pages total should have taken, even at CASA speed, about a year to produce.  So WTF has happened during the lost years and what do 'we' have to see for the investment? 

Three things which, IMO demand serious answers : (i) the dollar cost of those 15 additional years; (ii) the almost unworkable, legally dangerous nature of the presented 'regulation'; (iii) that Australian industry is prepared to invest further time, effort and money in rectifying this monstrosity.   

The why, who, when and how of this aberration have me wondering if perhaps it's me that the village which lost it's idiot is looking for.  Because one of us is barking.  To start with a relatively straightforward, sane idea for simplifying and modernising a rule set and to finish up with the anathema* as presented, then to meekly accept it, and then happily volunteering to assist in rectifying the wretched thing; all point to insanity.

Woof woof.  



* ("something dedicated to evil and thus accursed").

The Einstein quote is absolutely spot on...

This was what Hitch had to say in his weekly wrap in a further response to the "K" motion to bin the bloody thing...

CASA tells me they have received 61 e-mails of feedback in response to the Part 61 letter DAS Mark Skidmore sent out. Further, all but about two of those have contained valuable input that they can work with. There is a feeling in the industry that CASA has been told enough and calling for more feedback is just stalling for time. There is some merit to that argument, but I think that for the first time we have people in Canberra who are listening, and it's good for us all that fresh feedback has been called for. That way we have a chance of getting our message through en clair rather that having the new board be presented with old feedback that has been compromised after being processed by the CASA bureaucracy.

  However that was before the announcement that Jeff Boyd as the new Chair of the CASA Board had completely sunk in...  
 

 LS: ...I would remind everybody that Part 61 plus MOS plus Advisory Documents plus CASA policy/interpretative/training documents now runs to 2200 pages and growing, not the 600 pages below. The total of pages that is legislative is about 1700.


The inconsistencies, conflicts etc. are simply impossible to manage, without a wholesale re-write on a basis that complies with the Government policy for red tape reduction.

Only now are people in the aviation community waking up to the real costs of this monster...

Most industry stakeholders would be aware that Boyd as Chair of the RAAA was very vocal in his opposition for Part 61 in its present 2200 page bastardised form and apparently has already indicated a strong inclination to 2nd the Ferryman motion...   

There is also a rumour doing the rounds that Skates had indeed been nobbled by the Iron Ring but now with the threat of becoming the first DAS/CEO to be given the bullet by the board - & inside of his 1st year - he maybe changing his tune...

Yeah I reckon there will be much MTF...P2     

[Kharon]

Full steam, Minnie – Pour it all ON.

Mate if they don't know why, after 16 ducking years of 'consultation' frigging about with 'it'; there is no practical or intrinsic value in telling the silly sods who wrote it what's wrong.  If they had the first blind clue, in the beginning, they would never have ended up defending and rectifying the useless pile of paper. 

 It's wrong, academically, legally, operationally, financially and morally.  

What part of that does Skidmore need explaining, again and again and again.  

BIN IT – WRITE OFF the HUGE loss; hire some PROFESSIONAL people to knock out a modified NZ style 61 (there are some parts of that which could be lived without) and FFS stop PONCING about with it.

More coal, keep it coming.