Part 61 - For Dummies.
#21

Dear Hitch.

I respectfully draw your attention to a posting – HERE – from P2.  Careful reading and consideration of the entire matter before Senior member Fice clearly demonstrates how Part 61 may be used wilfully, with malice and aforethought, by people who harbour bad intentions.  The entire, despicable, farcical stitch-up was conducted on the Skidmore watch.

We have seen CASA play the hard game before where facts and circumstance are woven into a twisted story, supported by the CASA version of the pilot's records.  All pure frog pooh.

It seems the estimable Fice has seen through this long standing bastardisation and told 'em in no uncertain terms – Stick it and don't come back.

Had 61 been used, this poor bugger could have ended up with a criminal record and no licence to speak of.   Will the Skidmore penchant for appeal to support his 'ground troops' make this fellah's life a misery again?  It's a good thing Wodger wasn't on the job, he really can frame 'em, blame 'em and end their careers.  

61 Rules - Yeah right. 
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#22

Tom, you are a legend. You make a short post but one with a poignant message. This matter has been finalised on Skidmores watch. This matter, along with others will now come under the watchful eye of the IOS. We will be watching, monitoring, sampling, examining and scrutinising any vindictive actions undertaken by Fort Fumble against any IOS member as 'payback'. If it happens, we will expose it. The IOS won't stand for bullying and neither will the Senators.

Mr Skidmore the honeymoon is over. Your probationary period is up. The moment any of your henchmen so much as break wind in close proximity to one of our previously persecuted aviation fraternity we are going to throw it into the spotlight. We will expose any bullying or payback to the Senate, social media, tendentious news bloggers and the like. We've had enough. Your organisation has been judged and found wanting. The IOS are loudly proclaiming 'no more'. If the new DAS is smart he will escalate the need to turf out the dross from CAsA and blood the place with new talent, starting at the top rung.

The ongoing and future actions of CAsA employees will now be attributed to Mr Skidmore personally. His 6 month period of grace is up. He is now fully accountable for all that takes place within sleepy hollow. No excuses, obsfucation or pledges of insanity or 'I didn't know because I was in Montreal' or 'I didn't know because that happenned before I started at CAsA' will be accepted. You are on notice!

Tick tock
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#23

"And thus I clothe my naked villany. etc.

Quote:Judas Iscariot was, according to the New Testament, one of the twelve original disciples of Jesus Christ, and son of Simon Iscariot. He is known for the kiss and betrayal of Jesus to the Sanhedrin for thirty silver coins.[1] His name is often invoked to accuse someone of betrayal. He is sometimes confused with Jude Thaddeus.  Though there are varied accounts of his death, the traditional version sees him as having hanged himself following the betrayal.

Aye, at least Judas, one of the great betrayers had the common decency to hang himself afterwards.  

The mindless, work shopped propaganda published in the Australian, by Creedy this morning, without even a comment from any of the alphabet groups, constitutes one of the greatest disappointments in my time on this planet.  It is a despicable, shameful web of spin, disinformation, deception and deceit.

Overt support for Part 61 betrays the Abbott government and makes a mockery of 'red-tape' reduction.

Overt support for Part 61 betrays the Senate inquiry and it's recommendations.

Overt support for Part 61 betrays the Rev. Forsyth and renders his report and industry stated position inutile.  

Overt support for Part 61 betrays the industry, completely, utterly and vindictively.

But, for me the real heartbreak is that 'we' all had such high hopes of Skidmore; seems to me he has willingly betrayed that trust, destroyed the faith and cynically, decimated the hopes for reform we placed in his care.  

Milord's, Ladies and Gentlemen, you are invited to witness, in your life time, the destruction of an industry, willfully executed by those sworn to the task.  

Only the Board or, perhaps the Senate can save parts of the industry now from a slow, painful end, but the gods know how little impact their collective efforts have had so far.

Aye:  Abandon hope all ye who enter here.   

MTF when I sort out hell's own furies and other assorted daemons.  I still cannot believe I read that article properly or that this industry is going to roll over and let it slide away. 

Selah – 
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#24

(05-21-2015, 11:43 AM)Gobbledock Wrote:  ...Mr Skidmore the honeymoon is over. Your probationary period is up. The moment any of your henchmen so much as break wind in close proximity to one of our previously persecuted aviation fraternity we are going to throw it into the spotlight. We will expose any bullying or payback to the Senate, social media, tendentious news bloggers and the like. We've had enough. Your organisation has been judged and found wanting. The IOS are loudly proclaiming 'no more'. If the new DAS is smart he will escalate the need to turf out the dross from CAsA and blood the place with new talent, starting at the top rung.  

The ongoing and future actions of CAsA employees will now be attributed to Mr Skidmore personally. His 6 month period of grace is up. He is now fully accountable for all that takes place within sleepy hollow. No excuses, obsfucation or pledges of insanity or 'I didn't know because I was in Montreal' or 'I didn't know because that happenned before I started at CAsA' will be accepted. You are on notice!

Tick tock

 Epitaph: Here lies the Skidmark of embuggerance.

{Comment: Nearly posted over you "K", thought the bollocks article from the Oz would raise your hackles - very disappointing indeed Undecided }

Gobbles you, old Tom & the Ferryman are truly soothsayer's of legend... Angel  Your posts above predicted this but I admit I still had my doubts... Huh

From this wet lettuce piece here from 'Steve (I love CASA) the regurgitator', it has become quite obvious that Skates has come under the hoodoo voodoo spell of the Grand Master of the Iron Ring & received his frontal lobotomy... Sad
 
Quote: "...Well may we say "God save the Queen", because nothing will save the Director of Aviation Safety..."

From the bottom of my linked post above..

..."more than 70" ...FCOL  [Image: huh.gif] ..

FFS!- How can any sane person (..at the back of the room) accept that 70 responses is in anyway representative of the industry??

Although still majorly in decline, last time I cared to look there were 34,000+ licensed pilots in Australia. Of that there is over 10k with fixed wing commercial licenses. Of those it would be fair to say approximately a third are represented by pilot unions AIPA & VIPA, both of which have a vested interest in promoting future pilot wannabes. Therefore, I would have thought what they think & believe matters, from my post #8:

Quote: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:

[Image: Part61-VIPA-1.jpg]
[Image: Part61-VIPA-2.jpg]

[Image: Part61-VIPA-3.jpg]
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.. Dodgy

And - I would add that the above- are more truly representative of a lot more individual pilots than those of '70' -  probably low time, piss ant instructors, with pathetic little gripes about the new Part 61 - FFS!

Ah yes but they're a pilot associations, so what would they know right? What about this, from REX ASRR submission, on a more general note in regards to regulatory reform, cost & in compliance with Government policy & the OBRP guidelines:

Quote:3. THE CASA REGULATORY REFORM PROGRAM

The regulatory reform program commenced with the introduction of the Civil Aviation
Act 1988 meaning that the process has been ongoing for more than 25 years. A key
part of the regulatory reform process is harmonisation with international regulations
which in most cases has not occurred.

An example of this is the recent NPRM 1213CS in relation to hardened cockpit doors,
in which the proposed CASR 90.810(2) does not concur with FAA policy ANM 01-
115-11 upon which the NPRM change proposal (3.4.2) was based...

...The Office of Best Practice Regulation (OBPR), in the Department of Prime Minister
and Cabinet, has published a handbook of guidelines [Dept of Finance and
Deregulation, July 2013] for Australian Government agencies involved in regulatory
reform. Any agency that introduces new rules that may have a regulatory impact on
business must first produce a RIS as part of the regulatory process. The OBPR must
be notified and the agency is required to publish an Annual Regulatory Plan. It
appears that CASA does not comply with any of these OBPR mandatory guidelines.
Rex has not received a RIS for all NPRMs. One was received for the new CAO 48.1
which Rex found to be inadequate and against which it made a submission. Rex did
not receive a reply.

CASA does refer to an Annual Regulatory Plan on its website but essential
information is lacking. The OBPR handbook under ‘Expected Timetable’ says:

This field should include information about the estimated timetable for
major stages and milestones in the development of planned regulation
such as:
• when reviews are scheduled to commence and conclude;
• when public consultation will commence and how long the public
consultation period will be;
• when policy approval is to be sought; and
• when it is proposed to introduce regulation into the Parliament.


CASA does not comply with these provisions and often the first indication to industry
of a new rule is the sudden arrival of a DP or NPRM with an inadequate deadline.
CASA should provide information in relation to its regulatory reform projects that
complies with the OBPR guidance. Such information would allow industry to plan for
when new regulations will take effect, and also to consider responses to requests for
submissions in advance...

But for a full unadulterated reference on the true effect to industry of the Part 61 abomination, you simply can't go past the ProAviation submission , example:

Quote:61.370   Provision of photograph

(1)           The holder of a flight crew licence commits an offence if:

(a)          the holder exercises the privileges of the licence after the end of 10 years beginning:

(i)            when the licence was granted; or

(ii)          if the holder holds more than one flight crew licence—when the holder’s most recent licence was granted; and

(b)          the holder has not, before the exercise of the privileges, given CASA a photograph of the holder:

(i)           showing the holder’s full face and his or her head and shoulders; and

(ii)          taken not earlier than 6 months before the end of the period mentioned in paragraph (a).

Penalty: 50 penalty units.

An offence against this regulation is an offence of strict liability.


Comment: CASA doesn’t provide photo identification on the pilot licences it issues, so despite the gravity implied by the specified maximum available penalty, it is unclear (a) what impact non-compliance would have had on ensuring the safety of air navigation, and (b) what on earth motivated the legislative drafters to solicit such priceless “gifts” under threat of a 50-unit (currently $5,500) fine?

To be fair, following industry ridicule this regulation was repealed shortly after it was published; however it does appear to reflect on the training, guidance and motivations of people tasked with writing the regulations, and it is only one of thousands of examples of compulsive over-regulation. It also appears to represent an unnecessary breach of privacy to store data of this kind when there is no apparent “safety of air navigation” benefit while doubtless at least the equivalent of one employee would be required for management and storage. Let’s say at least $150,000 a year including on costs.

I could go on but what is the point, the Skates booking (see Ferryman post above) on the Styx River crossing has apparently been booked & paid for and we all know there are no refunds - oh ye Gods here we go again.. Sad   

MTF...P2 Confused

Ps Kharon:  "..I still cannot believe I read that article properly or that this industry is going to roll over and let it slide away..."

IMO the following post from Gobbles off "the noble Art - Embuggerancesays it all really:

Quote:The problem in all of this is ourselves. You see the problem is not one of civil disobedience, it's one of civil obedience. We accept the ridiculous rules, laws and regulations thrust upon us and we comply implicitly. We allow these unworkable, generally unsafe and unfair frameworks to enter our lives and we sit back and accept it with hardly any pissing or moaning. Our lives, income, careers, health, sanity and futures get f#cked up by horse pooh like Part 61 yet what do we do? We comply implicitly. Like a lapdog waiting for a command from its Master we sit back and we accept whatever we are given. We are conditioned to 'accept', not to question. We are conditioned to obey, not disobey. We are conditioned to receive, not give. We act like an aviation community that has been muted by some dark insidious force. Yes we suffer from CASS - Civil Aviation Stockholm Syndrome. We have been bullied, threatened, cajoled and tricked into absolute submission, and most of us don't even know it.

So again I raise the hypothesis that the problem is us, not them, and that our insistence on civil obedience rather than civil disobedience is the root cause of the decline in our once glorious industry.

"Safe mind control games for all"


  
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#25

From CASA Estimates session today, Senator Sterle had a lengthy inquisition of Skidmore and his EM numb-nut Crosthwaite on certain areas of a constituent's concern with Part61... Shy

As Hansard will take sometime to be released here is the video footage for your enjoyment (or not... Confused ):

   



From that it would appear that Skidmore will not be visiting the skip anytime soon and the "IRP" could drag on for another two decades - or until the GA industry is well & truly dead, buried & cremated... Confused

MTF...P2 Undecided  
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#26

Exemption upon exemption; repair on repair, cock up, counter cock-up and 2200 pages of pages of gobbledegook.   MoS to be manipulated, process to be adjusted, it just goes on and on, ad nauseum ad tedium (add vomitus).  Would someone explain how, in few short months the abomination is going to be fixed.  Tick, Cross and Wait could not, if you set fire to it, rang a bell and threw a bucket of water over him find his arse, let alone unscramble this mess.  In ten years time, a new bunch of Senators are going to be sat there, shaking their heads and wondering how, in the seven hells we ended up with such a mess of exemption, corruption and criminal charges against industry.  

There should be no need whatsoever for any form of exemption; not against standards or licensing.  Not after two decades.  Now, industry, realising rape is inevitable is determined to lay back and enjoy it; thinking only of the privileges bestowed by becoming one the exclusive, exempted hand picked crew to receive the CASA 'treatment'.  (Spell check – Lobotomy).
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#27

(05-29-2015, 07:36 AM)kharon Wrote:  Exemption upon exemption; repair on repair, cock up, counter cock-up and 2200 pages of pages of gobbledegook.   MoS to be manipulated, process to be adjusted, it just goes on and on, ad nauseum ad tedium (add vomitus).  Would someone explain how, in few short months the abomination is going to be fixed.  Tick, Cross and Wait could not, if you set fire to it, rang a bell and threw a bucket of water over him find his arse, let alone unscramble this mess.  In ten years time, a new bunch of Senators are going to be sat there, shaking their heads and wondering how, in the seven hells we ended up with such a mess of exemption, corruption and criminal charges against industry.  

There should be no need whatsoever for any form of exemption; not against standards or licensing.  Not after two decades.  Now, industry, realising rape is inevitable is determined to lay back and enjoy it; thinking only of the privileges bestowed by becoming one the exclusive, exempted hand picked crew to receive the CASA 'treatment'.  (Spell check – Lobotomy).

Skidmore's double entendre

Visiting this month's Skidmore missive is just as frustrating as watching that pathetic little weasel Wodger (in the above video... Wink ) squirm, snigger, spin & poonce around while totally bullshitting about the Part 61 "post implementation review" maybe...just maybe to be completed within the 'calendar year'...FFS! Angry  

How many times have we heard that before??- And this from yet another one of the former Angry Man's fleabag Wodger Wabbit's... Dodgy    

But I diverge back to the Skidmore monthly missive:

Quote:In reviewing the development and implementation of the licensing suite I can see a number of improvements we can make in our processes. The first is to do more work up front before the regulations are made. This may involve testing the regulatory proposals in a practical way with the aviation community or running a pilot program to ensure implementation plans are optimal. At all stages we need a better dialogue with the aviation community to allow us to communicate, consult meaningfully and to listen carefully to all constructive feedback. Most importantly, CASA needs to put more effort into educating and training our own people about the new regulations and their implementation so we can give clear and consistent advice to the aviation community.
    
FCOL this bloke just doesn't get it - someone bring me a bucket... Confused . 
{Comment: Passing strange that the release of the - weasel worded - Skidmore missive just so happens to be a day after Estimates... Huh  Yeah right like that is a coincidence Dodgy }  

Anyway the following is the Hitch version of the Skates missive with the excuse: CASA has Scope for Improvement: Skidmore - FFS do you reckon??

Quote:29 May 2015

CASA Director of Aviation Safety Mark Skidmore had admitted the regulator could improve the way in implements new regulations.

In his CASA Briefing Newsletter for May 2015, Skidmore explained that complexity and implementation were two areas the regulator could look at doing better.

"I fully accept CASA can make improvements in both the way regulations are developed and implemented," Skidmore said. "We do start with the intention to make new regulations as clear as possible, using plain language without unnecessary complexities. We most certainly do not set out to write regulatory requirements that are hard to understand.

"But like many good intentions our goal can get lost during the journey and, for a range of reasons, the result can sometimes be regulations that are more complex than desired."
One of the things impacting the complex nature of regulation is the government requirement for legislation to comply with the federal drafting style, which by its nature tends to result in lengthy, more complex regulations. Clearly, Skidmore feels hamstrung by this.

"In short, it is not always easy or even possible to create ‘simple’ regulations. But having said that, it is CASA’s job to strive towards the goal of clarity, coherence and precision using plain and easy to understand language."

Skidmore has also admitted that the way CASA has implemented new regulations in the past could so with some improvement.

"The first is to do more work up front before the regulations are made," he said. "This may involve testing the regulatory proposals in a practical way with the aviation community or running a pilot program to ensure implementation plans are optimal.

"At all stages we need a better dialogue with the aviation community to allow us to communicate, consult meaningfully and to listen carefully to all constructive feedback.

Most importantly, CASA needs to put more effort into educating and training our own people about the new regulations and their implementation so we can give clear and consistent advice to the aviation community."

See it is someone else's fault... Sad
 

And this was Hitch's comment on the above in his weekly wrap -

Quote:It seems to me that CASA is telling us gently that we can forget one of the Forsyth recommendations: plain-English regulations. In his CASA Briefing Newsletter for May, Mark Skidmore points out that they would like to get complexity out of the CASRs, but the government drafting style is getting in the way. I have no doubt he's right. The legislative drafting style is unwieldy, legalese gobbledygook designed to be interpreted by only legal minds, not the general public to which they apply. The incongruity is that the style actually impedes aviation safety rather than promote it because the average person has no idea what many regulations actually say. In 2010, US president Barack Obama signed an act that forced US regulations to be written in plain English. It's way over due that we had something similar happen here, even if it's only for aviation safety regulations.

No further comment.... Sad
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#28

The cautionary tale of Oliver Skidmore-Twist.

Post Implementation Review my arse.  Watch and listen to the Cross, tick and Wait waffle on while Skidmore looking about as comfortable as a Christian in a lions den (which he was) supports the piffle.  Skidmore is not a stupid man, but he's not street smart.  Isolated by a privileged very sheltered background; he brings to mind the  Dickens character, Oliver Twist. Clueless, in a big bad world, where Fagin and his boys fool him every time and our boy ain't even met big, bad Bill Sykes yet.  An orphan with just about enough nouse to realise they are pulling his chain, he just don't know who, why or which way.  If you know the tale (not the dreadful musical) you'll be aware of what happened to poor orphan Oliver when he asked for more.  

I challenged Hitch to take Part 61 away and read the wretched thing; then write an operations manual for a mixed fleet, do the costing and make it work.  I'll challenge Skidmore to do the same. Then, having done what any half decent Chief pilot could do, examine the 'law' for the hang-mans nooses, those which can and will be used, as and when pleases, by any CASA bully boy on a mission of destruction.  Skidmore needs to do this, then perhaps he can elevate his understanding level beyond that of a private pilot.  He won't do it of course; he could not start with a blank sheet of paper and develop a 'compliant' (acceptable/ approved) manual suite, bull it through the CASA version of compliance and get an operation 'up and running'. He wouldn't know where to start, let alone how to finish.  But to be an effective director he needs to be able to do this, as this is what he, under the control of the Casamites, is expecting industry to do.   (Grim chuckle), maybe Wodger could teach him to cut, paste, tick and flick. 

The next item which attracted howls of Bollocks was the pleading for more 'feed back' again, just  like ducking Oliver bloody Twist – more, more, more.  Industry should robustly respond – Go away. Bugger off and do your ducking homework.  READ the submissions to the Forsyth review, then READ the Forsyth review, then READ the responses to that review; then READ the stated government policy on drafting legislation.   To save some time READ the NZ or PNG part 61 or even the FAA part 61.  But FFS READ something based on practical, workable, comprehensive law and stop playing for more time; it's a dead horse, no point to flogging the poor beast.

Here's some tips for any aspiring Part 61 proponent.  When you have satisfactorily' completed all the above tasks, then come back and swan about as 'director', visiting 'selected' tame operators; maybe then the little light will come on.  But until you have, you are just another expensive dumb arse with NFI, keeping the seat warm until we can find some one with real life experience and balls to produce the demanded changes.  Running with the hares and hunting with the hounds can only end one way.  Pick a side, neutrals just get mown down in a no prisoners contest.  

Item next – This BOLLOCKS about the way the Commonwealth draft the regulations, now it's the drafters fault.  NO IT IS NOT.   More home work.  You could save some of your time and our money by READING the responses to Forsyth: all there (lots of).  They are, for the most part from industry experts, in black white and mostly plain English, who must work with the rubbish Tick, Cross and Waite are foisting on industry.  But to put your name on the duplicitous, scurrilous statement, blaming the drafters of legislation for the CASA inbred duck cluster shames you and insults industry. 

Even Damocles and his wee sword could not cut through the Gordian knot CASA has tied  around the package of dross, the pony-pooh referred to as CASR Part 61.  If you haven't got the brains to cut through it; then have the balls to bin it.  

Aye much to learn has young master Oliver Skidmore, for he is but a babe; lost, cold and very alone in the deep, dark woods of Sleepy Hollow.  

Quote:"Turn him to any cause of policy,
The Gordian Knot of it he will unloose,
Familiar as his garter"

No, no steam, just over it.  It was fine for Nero to fiddle, he wasn't the poor bastard trying to piss on the flames, was he?
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#29

On a lighter note, is Cross-tick-white and P. Boyd attending the same surgery and having plastic surgery done by the same 'ugly surgeon'? One would swear these two are one and the same. Twins perhaps?
And FFS, somebody please wake up the worlds oldest A380 pilot, at one stage I thought the Carboard cutout had died, there was so little movement!! Maybe the roids were playing having with him.....

Part 61? Print it out on soft paper and place it in your toilets.
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#30

By way of comparison.
NZ AOC for a part 135 operator eight weeks and 15 to 20K from start to finish.
Australia, similar aircraft, 18 months and so far over 150K and still no light at the end of the tunnel.
NZ to include a type on an AOC 4 to 6 weeks and 6 to 8K.
Australia, similar aircraft, a year and around 100K.
Part 61 OZ style, if you can work out how to comply with it added costs around 25% to overheads. Part 135 to come.
CAO 48, if you can work out how to comply with it, add another 10% to your overheads.
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#31

Hopework for Oliver.

For today's lesson we are firstly going to examine recognising Pony-Pooh when it's presented as fact.  In the example below it is possible to identify several excellent examples of the word weasels art.   

Quote: Wrote:"I fully accept CASA can make improvements in both the way regulations are developed and implemented," Skidmore said."We do start with the intention to make new regulations as clear as possible, using plain language without unnecessary complexities. We most certainly do not set out to write regulatory requirements that are hard to understand.

"But like many good intentions our goal can get lost during the journey and, for a range of reasons, the result can sometimes be regulations that are more complex than desired."

One of the things impacting the complex nature of regulation is the government requirement for legislation to comply with the federal drafting style, which by its nature tends to result in lengthy, more complex regulations. Clearly, Skidmore feels hamstrung by this.

"In short, it is not always easy or even possible to create ‘simple’ regulations. But having said that, it is CASA’s job to strive towards the goal of clarity, coherence and precision using plain and easy to understand language."

Skidmore has also admitted that the way CASA has implemented new regulations in the past could so with some improvement.

"The first is to do more work up front before the regulations are made," he said. "This may involve testing the regulatory proposals in a practical way with the aviation community or running a pilot program to ensure implementation plans are optimal.

I have highlighted some of the more obvious 'bollocks' statements, now, can you find the rest?

Well done, you have correctly identified nearly every part of the deceptive example, but remember, that was an easy one to get you started.  Before we move onto lesson two it is necessary that you gain an idea of 'Non Bollocks'.  This is essential as (a) facts may be gleaned to assist with bollocks decimation; and (b) 'Facts' can be used to confound the forces of stupidity and darkness; let us visit the library – HERE -.

Your reading list, for today – AAAA; AIPA and AMROBA; will give you a working knowledge across a wide spectrum, showing how  'professional' industry associations see the problems and their suggested remedies for dealing with the amateurish clap trap the sheltered workshops produce.  

Now here's your play lunch and some quotes to read on the bus to the library: of you go:-

Quote: Wrote:And do not blame the A-Gs or the Office of Parliamentary Counsel, or alleged Government legislative policy, what we have got is exactly what CASA intended, with the full support of the previous Minister Albo.

What is entirely inexplicable is Minister Truss continuing with Albo's policies, even when they are 180 degrees removed from the policies pursued by Truss when he was last the Minister, including, but not limited to airspace and airports policy, and regulatory development policy as reflected in Policy Doc. 1/20

Quote: Wrote:That rational risk management is not popular in CASA  is an understatement. If the "rules development" rules of the Productivity Commission/Office of Best Practice Regulation/various recommendations of the Australian  Law Reform Commission, Attorney-General's Department etc. were followed, a good proportion of CASA "rules" would never see the light of day.

Quote: Wrote:The CASA attitude to risk management and cost/benefit is best seen the Airspace Act 2007.  The first "Minister's Airspace Policy Statement" is a model of how  airspace and airspace designation should  be• managed.  In contrast, the second such statement is shorn of all rational meaning, "risk management" goes missing, and "safe" becomes  the criteria, in words very similar to S.9(A) of the Civil Aviation Act 1988.

Quote: Wrote:In short, the almost immovable "CASA Culture" rejects rational risk management and the cost/benefit justification  of regulation. Without amendment to the Act that will not change.

Without  amendments to the Act, a number of your recommendations cannot  be enshrined in law, and we cannot afford to continue  with vastly different  interpretations of the Act ( particularly when the "hard core" of CASA prefer the most narrow, extreme and prescriptive interpretations) with each change of CEO/DAS of CASA.

That rational risk management is not popular in CASA is an understatement. If the "rules development" rules of the Productivity Commission/Office of Best Practice Regulation/various recommendations of the Australian Law Reform Commission, Attorney-General's Department etc. were followed, a good proportion of CASA ''rules" would never see the light of day.

If you can manage those lessons for today, tomorrow we can move on to some of the more interesting, devious bollocks and how to counter them; remember, young Oliver, the longest journey starts with the first step forward.  

Toot toot.
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#32

I just had an epiphany!!
No sorry darling the Viagra lite didn't work!!
My darling wife, who being a rather senior person in the health industry has carved a swath of mayhem through the health Bureaucracy telling it like it is...ie get knotted, I'm for patients NOT bureaucrats!!
The thought occurred to me that amongst the members of the IOS there must be many like me.
Them that are enraged by what CAsA are doing to our industry, but are immune to threats and intimidation because basically we don't give a sh.t!
Now, take a bunch of IOS, who don't give a sh.t, embed them into CAsA where "All sins are forgiven" where you become an instant expert!! Oh my god!! I cannot imagine how much mayhem they could cause!!. what could CAsA do??.."YOUR FIRED"!!..."I don't give a sh.t", "but your fired".."SO??"..."but but...your fired"..."Mate, there is a union you know, there is fair work, there is unfair dismissal etc etc.have you in court!! Besides, I DONT GIVE A SH.T"

"I dream a dream." (les miserable) or "Everything is nice" (willy wonker)
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#33

The first directive from the DAS, always remembering that talk is cheap; it costs money to buy whiskey.  FWIW from CASA – HERE - or the AP library - HERE -.  Worth a moment or two over a coffee.
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#34

Warning: long post may follow this warning – perhaps.

CASR_61.  Why me?

Quote:The difficulty lies not so much in developing new ideas as in escaping from old ones.
John Maynard Keynes.

"Crack on" is the word, "stop messing about and get into it".   "But, but, it's out, gone, consigned to the tip; history" I protest.  The grim faces around me say it all – we may yet be stuck with it.   Longingly, with a sigh I glance at the neat pile of NZ, PNG and FAA rules; but needs must when the devil drives.  And so it begins:- our casual stroll through the part 61 mind-field.  Every journey has a starting point, some philosophy has it that a journey begins in the mind, a single thought - the decision to move in a direction.  So, where does a Part 61 virgin begin such a journey?  There are rumours and pub talk of 'advisory' material being available; so I decide to start there.   

Innocently, I down load the quite easily found 'advisory' documents from the dreadful CASA web site, (which is worth a separate thread of its very own – Yuk).  Warning- you will need the 'advisory' doc – HERE – to untangle my scribble.  Enjoy.

With the 'explanatory' series safely filed, I begin.  As I am due for an IR renewal, I start there.  I note a modest 1/16 in the page counter and as the document is full of large colourful pictures (of no practical value whatsoever), I reckon, with a bit of luck, there will be about five pages of information most of which will be guff.  One coffee job I think as I wade in.

Page 1: "Learn about new rules for instrument rating – in effect since September 01, 2014" says line one.  My heart sinks, right there, however, as we are here to 'learn' anyway, as it were, I press on.  Through the glaringly obvious pointless introductory piffle which says – if you want to operate under the IFR, then you need an instrument rating. 

Quote:.....Pilots who hold any of the following Part 61 licences and ratings are authorised to conduct an IFR operation.

So one may assume that to conduct operations under the IFR, then a rating or licence must be held.  Which is it? the sentence above reminds me of those instructions for assembling various items where the translation is grammatically literal:  

Quote:....However, instrument-rated pilots are limited on the IFR operations they may conduct, depending on the instrument endorsements they hold.

Now I have always thought that the IR was to authorise flight in non visual conditions, using all the instruments.  The implication in the drivel above is that you are limited in the instruments you use for flight.  "Use the AH Bloggs" – Cant' skipper, not qualified on AH".  Of course that's rubbish, but whoever wrote the guidance advice, clearly has only got a tentative hold on the subject matter.  Here I am, page one, and already 'doubt' as to the value of the following information is creeping in.   I am left to assume what it means to say.   Now it seems we now must refer to Sub part 61 M for information.  So begins the reading list and a glimmer of hope for clarity. (MTF).

So with a click – page 2 arrives:- more pointless pictures and night VFR first up.

Here again, questions left begging answers; can I as an IFR pilot conduct operations under the NVMC rules, is the NVMC rule set still valid; or, is it all now under the IFR – only at night.  Perhaps it will be explained later.  I stagger confused into the 'changes' paragraph, then this:-

Quote:....Under Part 61 there is one instrument rating, six different aircraft endorsements and two instrument approach operation endorsements (read on for more information— note that this doesn’t include the private IFR rating).

Now read it again, and once again.  OK, one instrument rating; but only valid sometimes, except if you are a PIFR, which is different again (we think).  Six different 'aircraft endorsements' essentially means (as you read on) that there are, potentially (reality yet to be decided) potentially six separate IR to keep current.  Your 747 command IR under CAR 217 (or similar) is still valid despite the fact that you failed a FPC in your mates Baron last week.  You can quite legally saddle up the 747 and chuff off to LAX in the middle of a dark and stormy, but you cannot be trusted to nip up the way for lunch in the B58, unless you have 'demonstrated competency in the type (class).  But you may, provided you have passed the flight test for the Metro do the odd moonlight run for the local freight company, but cannot take the C 172 IFR to the beach for a spot of fishing – unless your IR for the '172' class is valid.  This of course may, or may not be the case if you operate a Cessna 510 single pilot or a Westwind multi crew.   Which, stand alone is bad enough, but then add this:-

Quote:...Holders of ATPL(A)s and MPLs don’t need to hold a separate instrument rating.

Why do they insist on multiples – its an ATPL singular or a MPL (singular) not ATPLs – I only have one off.  Anyway, it looks like only those with the impossible to obtain ATPL may avoid holding 'multiple IR' ( I think).  Which takes us into recency.

Well it's all good news, 90 days and ninety nights between prescriptions (unless you operate single pilot) which is, regrettably different again.  We shall get to the SP rules in due course – I hope.   The following requirement for an Instrument Proficiency Check (IPC) is deceptively simple; 24 months for 'type' rated aircraft unless you operate a type rated aircraft single pilot, then it's 12 months between IPC – cool you say.  Not so, what if you work for a mixed fleet operator; or operate free lance; or, even fly a Dash for a day job and do the odd charter for your old boss in a Citation.   Your freedom to operate 'independently' has just been further and severely restricted and the fiscal burden on someone increased.  So, the Virgin 738 pilot with no desire to do any other flying is out of jail, on a 217 cake walk and in no trouble whatsoever.  None of the single fleet operators are, except when 142 or 141 creeps in, then it will be off overseas for training and checking – at great expense which will be off-loaded onto the passenger ticket price.  Aye well, it will suit some, but it's a clumsy, micro management system which achieves very little in the way of improved risk mitigation and gives the 'authority' more room to meddle, should they decide to.  But I digress.

The navigation system blurb is simply a waste of words, stating the obvious while illustrating nothing.   Click:- Page 3:

Quote:...To conduct an IFR operation a pilot must hold the applicable instrument rating aircraft endorsements. They are:
›› single-engine aeroplane (SEA) instrument endorsement
›› multi-engine aeroplane (MEA) instrument endorsement (covers single and multi-engine aeroplanes).

›› single-engine helicopter (SEH) instrument endorsement
›› multi-engine helicopter (MEH) instrument endorsement (covers single and multi-engine helicopters)

›› powered-lift aircraft instrument endorsement

›› gyroplane instrument endorsement

›› airship instrument endorsement.

Don't you just love it –the simple elegance, ease of operation, flexible, rational and of course completely safe now that an instrument rating is no longer a thing which allows flight in instrument conditions'.  Now it's flight in IMC but only in a specific airframe, you see an instrument approach in a light jet is very, very different to one conducted in a high performance single.  I expect the clouds are different or something.   Are we not mixing our ability to operate an aircraft in IMC with the ability to operate the aircraft itself.  This part takes us into the first of many junctions where several 'disciplines' are melded into one conglomerate.  A place where the alchemist attempts to turn apples into oranges and ends up with a raspberry, gaining little in the way of risk mitigation for great expense and trouble.   

I quite like the notion of redefining the 'type' of instrument approach, don't you.  I mean the 'old' definitions – precision approach (with vertical guidance) an 'non-precision (without vertical guidance) were just so clumsy.  Lord spare me. Then we discover that using a pointer to determine if you are on (or off) track is so vastly different to using a course deviation 'bar' it requires yet another, separate, expensive 'endorsement'.  Monday you fly old 'Charlie' with a fixed card pointer VOR; Tuesday it's 'Delta' with a new fangled CDI – of course you need a separate 'endorsement' you silly boy; vast are the differences.  

Quote:...To conduct an instrument approach operation, a pilot must have the applicable instrument approach endorsement. They are:
›› IAP 2D instrument endorsement
›› IAP 3D instrument endorsement.

Click page 4:- Self explanatory, written for intellectually challenged water melons explaining that obviously these changes are operational required for 'safety.  Not risk mitigation you understand, but safety.  Read on.

Click page 5: Aye, well the picture is great and I feel so much better educated now that it has been explained 'properly', we in the kindergarten have greatly benefited from this information.

Click page 6:- Circling approach : a simple no changes would have saved some ink.   VOR does not qualify for ADF, OK we can live with that.  Enter the Mos and the IAP 2 and IAP 3 units of competency within schedule 2.  NFI what they are, but no doubt we shall discover that later in the piece.  (not today).

2D and 3D - Six seems to be a favourite number, now we have identified , but not qualified something which has never been done before, Non precision and precision approach paths (but with and without those terribly tricky pointer things).

Click page 7:- Highly illuminating graphics, a table which needs some assistance with the English language and those damned tricky indicator whatchmacallums, and a note

Quote:..Note: a 3D approach operation does not satisfy a recent experience requirement for a 2D operation, but may satisfy a CDI or azimuth guidance recent experience requirement.

The crystal clear resolution of lingering doubt may be contained within that epistle.  May the force be with you, maybe, if it's Tuesday or maybe Wednesday – Maybe I don't know.  May I ask a grown up. Who writes this rubbish? 

Click page 8:- Oh, I know, I know, that's an aircraft right? however, maybe.

Click page 9:- Here we have the 'Wendy' and 'Don' show, which is a bad example of the FAQ system which never quite works, does it.

Click page 10:- another aircraft piccy over the top of some fairly interesting implications; I read on holding my breath.

Click page 11:- The 'Irene' and 'Patrick' show; Irene seems to be OK, but poor old Patrick, cut his throat instead of brushing his teeth, so confused and confounded was he. This so much safer than a once a year check of 'instrument flight proficiency', more fun too and look at those costs spiralling out of control.  Stellar stuff.

Click page 12:- The sanity page, industry responsible 217 system saves the day.  The short answer to escape the bull-pooh preceding. N.B.  When the responsibility is firmly on the operators shoulders; Poof suddenly it' s all too easy.  What's that – no 217 well it's off to the local flight school for you mate; what do you mean there ain't one? Oh, too hard to meet the new requirements eh; well NZ is closer than the US of A, try there. 

Click page 13: - Here we meet 'Connie' happily taking her ATR into scheduled all weather services, but can't fly the Comanche for nuts.  What's wrong with this picture? either the CAR 217 is 'ticking and flicking' or the outside examiner is too tough; or, you nut it out for a Sunday puzzle.  There are six fatal assumptions made for Connie.  Hint? well in either event CASA will not be responsible.

Click page 14:-  Flight school commercial – ignore.

Click page 15:- I will stop here and find another coffee.  Tomorrow we may venture into the tangled world of the MoS and the regulation as writ.  There is a list of rules provided on page 16, but first we meet the MoS.  I love this these bits:-

Quote:Before commencing a flight, pilots must ask themselves ‘Am I capable of conducting the operation safely?’

This is the equivalent of the medical ‘fitness to fly’ question, but relates to the technical and operational aspects of flying. It means pilots need to be sure they are fit to fly in all respects.


FCOL if I believe I am fit, and by extension, deemed capable of assessing this as fact, then I may dispense with my medical examiner.  The reason we have independent assessment is because ?


Quote:The first is to ensure that all pilots consider whether they are competent to conduct a flight. This is about good practice.

Ultimately, responsibility for ensuring you are competent to operate an aircraft safely rests with you, the pilot.

I mean seriously who of sound mind would make such statement; probably some one who has self assessed and determined competency.  

Enough – coffee and perhaps a nice lie down.  

Toot toot; 

Whistles up dogs and buggers off, far from the study, to where water murmurs over rock, the air is clear, sanity prevails and part 61 is on hold, for a little while.    
Reply
#35

Well captain, you cant say I didn't warn you!!

ECT(electro convulsive therapy) is recommended after a Part 61 brain scramble.
Opens all the files in the brain apparently,then throws everything in the air where it must be meticulously gathered up and re-filed.
I'm told it un-jams the neurons thus permitting rational thought processes to be reestablished.
Very little in the way of side effects from the process.
Took a while to accept that this strange woman in the house was my wife, and an irrational focus on trying to identify the bloody sadist who dreamed up Part 61 and what I'd like to do the Bastard, Oh and you tend to drool in your beer for a while.

Of course the serious aspect to all this is just what its going to cost the industry?

Is there any hope that GA can survive it all?

The adversities facing the industry would seem insurmountable when you think about the massive chunks of money being ripped from it by all the various major and minor parasites that have grown up to feed off it, and some of the ill considered actions of our government and their failure to envisage the consequences.

Disaster number one. privatization of our airports.

Flogging public infrastructure to big banks and property sharks was always going to end in tears.

Neither party got involved with any interest in aviation.

So today our primary airports have become the biggest tax dodge in history.
Our gateways embarrassingly voted some of the worst in the world and our secondary's slowly being chewed to death in the interest of lining property sharks pockets. 

Shopping centres and industrial parks are more profitable than promoting the industry the airports allegedly exist for and hey with the minister asleep at the wheel they can be built without interference from pesky environmentalists, building codes and planning officials.

Exorbitant rents, unrealistic lease terms all contribute to the GA industries demise, added to which the unofficial "Excise" on fuel imposed by some airport owners, where they demand a cut for every litre of fuel sold at their airports further drives up the cost to industry. The cost of fuel at one capital city secondary airport is almost the same as an airport in the middle of the outback.

Fuel should be a major consideration as its the lifeblood of the industry, by the end of the year the temporary levee to provide CAsA with an extra $90 mil will have raked in over $400 mil, Jeez that maybe could have funded ADSB in every aircraft in Australia, which is what they want. They just dint want to pay for it, no worries get the industry to pay.

No idea why, the yanks seem to get buy without it just fine, but then what would they know?
I heard a rumour that they are pushing ADSB requirements out to 2025, allegedly because there's new technology coming along that will make ADSB redundant.
At the end of the day all ADSB has done and will do is rip another few hundred million out of the industry, for no apparent benefit.

Disaster number two our world class regulator.

Its failure to consider "Affordable Safety" or what constitutes "Competent" management.

We hear from them that its not their fault, they just do the governments bidding.

But hang on!! they are supposed to be the "experts"

What we never hear from them is any consideration given for the regulatory mess we are in.

Did they do a study and make any recommendations to the government?

How did we end up with the "Act"?

Did anyone in CAsA give consideration to the likely outcomes if it was written the way it was?

Was consideration given to the result of moving our regulations into the criminal code? which resulted in our regulations being written in legalize instead of plane language and ultimately will make criminals out of every pilot in Australia.

Was consideration given to the likely consequence of stepping away from FAA rules, where almost all our aircraft come from and who have produced a rule set that results in the safest aviation environment in the world?

What cost our unique maintenance reg's?

What cost our unique Part 61 Reg's?

What cost our unique Part 41, 42?

I don't see any evidence anywhere of any serious study by CAsA of the "economics" of the industry.
But they continually meddle, where they are not entitled, into commercial decisions of aviation companies.  
To do aviation business in Australia there must be a reserved seat on the board for CAsA and they have veto rights.

Disaster number four Apathy.

That is not just a failure of the government but also a failure of the industry.
Forgivable perhaps from the industries point of view, when your clinging on by your finger nails in survival mode continuously it aint easy to focus on the big picture.
Unforgivable from the governments point of view, they are elected to represent the interests of ALL Australians. To have sat idly by and ignored what has happened is unforgivable and very short sighted.

Look across the Tasman to see what aviation in Australia could have become.
Reply
#36

Guide Dogs required - apply within.

Had the walk and the dogs good company not done the trick, dinner and good company with it certainly restored my battered brain.  The dreaded ‘pointers’ discussion ended up with some of the funniest anecdotes I have ever heard being told.  Quite restored and refreshed I decided today I would examine the modest 8 page ‘Guide to type rated aeroplanes’.  You will need -THIS - to follow my rambles

Now this topic is of particular interest as one of the very best things CASA ever did was to bring in the ‘blanket’ cover on single engine aircraft as it provides a benchmark against which risk and accident rates may be measured.  In short, the move has been a success and I am hoping that the philosophy will be applied, in so far as is practical, to multi engine aircraft.  

Click page 1:- More decorative pictures demonstrating the approved method of turning on a switch, then the flatulence begins, the vexed question answered – “Who should read this .etc.”   Tension rises in the houseboat study, the dogs casualy stretch and head out.  I enjoy learning, happy to read stuff but I ducking hate been patronised.  No matter, breathe in, exhale and continue.

Quote:[specified] single-pilot certificated aeroplanes that have performance, complexity or handling characteristics that (warrant pilots completing a type-specific training course).
 
I wonder will there be a published matrix of just how the ‘complexity’ or ‘handling’ assessments are made? for it is a highly subjective topic. I don’t have a problem with the concept, but I would like to understand how the benchmarks are to be decided.  I have had the pleasure of operating two Mustang variants, both single pilot aircraft and about as different as two beasts could ever get.  Both certainly deserving of a specific ‘type’ course, so far so good; then we consider complexity and handling.  Both are truly lovely things to fly – in their own way, but the marked differences in ‘handling’ are found between start up and 500 feet; after that it’s up down, left, right, don't hit anything - as per.   So we can accept an ‘engineering’ school as a good and essential thing but then we must consider the ‘operational’ training.  Here is where we need to closely examine the methods by which CASA ‘approve’ a syllabus of training.  One of our aircraft here needs about 20 hours of pre flight briefing on how to fly the thing, systems management about 30 minutes; the other needs about 30 minutes of discussion on ‘flying’ it, but about 20 hours on ‘systems’ management.  It is in the area of how the ‘type training’ courses are structured that we should examine where our CASA ‘experts’ have set their benchmarks.   

The reason for raising this is I hoped to see some guidance for those who design, frame and execute training courses.  We shall see, as we add 61.055 and 60 to our reading list and note that we are to be provided detail on whether or not we need a rating and differences training within the Mark and model ‘group’.  Page 1 finishes as it starts, patronising yet uninformative (apart from the switch operation lesson).  

Click page 2:-  Not self explanatory then, the guide, is it?  Guidance on a guide emerges as the little warning bells tinkle softly.  Shades of the truly, really dreadful CAO 40.1 lurk in the dark corners, sneering.  You note the attractive young lady once again enforcing the approved method of operating a switch; yea verily shalt thou learn thy trade.  Invigorated – we press on.

Click page 3:- The useless FAQ style is employed to state the obvious which is buried,  hidden within the mangled pile of English, once you get past the if, and, but and maybe of it, you are still a way off comprehension.  I resist trying to work out what the boys pictured are up to.

Click page 4:- I just smile as I read the Boeing ‘cells’;  the table sort of works, in a left handed manner, but I doubt a Boeing operator would have it that complex; the differences certainly are not.  But we can live with a clumsy, high school standard ‘table’.

Click page 5:-Click page 6:-  Click page 7 – just an aircraft this time, clearly our button operation training is over.

Click page 8:- The plaintive though arrogant statement – “Do you want to no more – well do ya punk?” insinuates that the preceding pages should, if we weren’t as a thuck as pug pooh, have done the trick.  But for those of us, mildly bemused and uneducated as to the intricacies of the CASR 61 type rating imbroglio we can, as we must tackle the reading list provided.  For so far, apart from learning in very graphic manner how to operate a switch, I find very little value for money in the trite, little 'educational - 'explanatory' guide.  

Don’t you love the ‘Divisions’ now we also have to track them down in the huge pile of paper and work out what they are all about; can’t wait.   Fascinated by 61.205 ‘when training must not be conducted in an aircraft: there’s hope yet then. 

You can sum up the educational value and gain an insight into the mind that drafted this this ‘guide’ very easily.  Place your cursor in the centre the cockpit picture provided – read the pop up – ‘Airplane’s cockpit controls’.  There now I’ve learnt something – you have controls for the cockpit of your ‘airplane’.  Strewth, and here’s silly me all these years not knowing that.  

Aye well, patronised, no wiser, insulted by a perfectly serviceable language being mangled, I catch the welcome smell of fresh coffee and, with any luck, there may be a tasty treat from the bakery left over (if I can beat the dogs to the kitchen)… Wink ..  

Toot toot. 
Reply
#37

Class wars.

Whoever wrote and whoever was paid to produce these ‘information’ sheets aught, in all good conscience, give the money back.  The halfwit from CASA who approved these ‘sheets’ should be put back into the pencil sharpening cupboard.  Why? You ask – well simply for failing to understand the topics and the questions pilots and those manage and train pilots would ask. The FAQ ‘style’ of delivery is a very blunt instrument when phrased correctly; but in its mangled form it is, at best confusing. So, the FAQ - HERE - “If I hold a class rating” etc. is pointless. Particularly when the answer is conflicted – “except and exception”.  

So we begin page 1 of a tiny 4 page offering, and the first paragraph leads you straight down the garden path – ‘a flight crew qualification’ is it indeed? I would beg to differ.  Think about it – you hold a licence, to gain that you must have flown an aircraft at some stage, therefore you hold a flight crew qualification and may operate within the constraints of that licence at least one aircraft. What you need to know is can I operate another type under my licence.  Let’s keep it simple, you fly the 152 and have the hot’s for the Warrior parked next to it.  Can you just jump in and tool off for a couple of circuits. No sir, you cannot, well you can, but.  What is happening is that the affectionately named ‘Putt-putts’ have become the “But buts” 

Quote:…For some class-rated aircraft, you need to complete initial flight training and a flight review in that type of aircraft before you are authorised to conduct an operation in that type.

Click page 2:- Paints the picture using a little more contact with grim reality.  ‘Training – on type” and a ‘flight review’ on type imply what was in the old money an endorsement.  So we have a pointless complication of an ancient, time proven method of ensuring that the transition from a C 208 to a PC12 is done properly.  Even if the regulations failed to spell it out, a sane operator (and insurance company) would make sure that no harm came to their million dollar babies; so why the obfuscation? And why is the wheel being reinvented, at great expense?

Click page 3:- Multi engine and once again the questions are neatly avoided; if for example you work for an operator with King 90, 100 and 200 series on line.  Sensibly you have done the ground schools for each, completed your flight training program on each and have scraped a pass to go onto ICUS training, at the end of which you pass the proficiency required to clear you to independent line operations. Only now – each type requires a flight review – or does it?  So far we have less idea than the tow rag writing this informative guide does. 

Click page 4:- Rule 61.062 goes onto our reading list and with a sigh of relieve we leave this ‘information sheet’ behind..... Dodgy  


Fortified with a fresh coffee we open the ‘General Competency’ guide -  HERE – for pilots. Page 1:- Where we add 61.385 to our reading list and yet another pointless picture; don’t see too many long sleeve shirts on the flight deck do you and those stripes are brand spanking new.  I have previously mentioned these first paragraphs and flatly refuse to discuss them further (lest I bust something).  There used to be a short, round fellah worked for CASA who talked the way this crap is written, high blown hyperbole and big words used just out of syntax with the message, I wonder if our work experience child writing these sheets has found one on that blokes old speeches to ATO and saved a few minutes.  No more, I just can’t do it…thank the pagan gods there are only three more pages to wade through.

Click page 2:-What is the Manual of Standards (MoS)? they ask - bloody good question, I would also like to know which particular hell spawned it. 

Click page 3:- Click page 4.  Tilt, game over.  I cannot read anymore of this twaddle, not and retain at least a semblance of sanity and tranquillity for this day.... Cool  


Thankfully, the  - MoS  - 'guide'  shows only 4 pages as I drag it onto my screen from the depths.  Page 1 provides some interesting nuggets; like, it is a legislative instrument which makes it a very expensive toy, with sharp edges (talk to your local legal eagle).  It also provides a clue as to why Part 61 is such a mess.  IMO one of the main reasons for scrapping the entire thing is the failed attempt to roll the CAO and other legislative parts, instruments and exemptions into one 2200 page pie.  The prescriptive conflicts which existed before Part 61 reared it’s misbegotten head were not understood, never addressed and never resolved.  The ‘old’ system was a patchwork quilt made up of many small pieces and repaired with whatever was expedient or to hand, when repair was need.  Part 61 as it stands not only embraces those ‘conflicts’ but amplifies them.  The result is a truly awful hodgepodge pile of words which seeks to avoid and mute the existing problems, without addressing them – first.  `However, we shall persist with the charade.

Click page 2:- introduces the dreaded schedules; which CASA happily acknowledge as ‘prescriptive’ and being contained within a legislative instrument makes it very difficult for anyone ‘responsible’ for anything to find a practical method of achieving a result without being trapped within an opportunity to use black letter law, should, for some reason that was desired by the ‘authority’ under a literal interpretation of a prescriptive ‘requirement’.   

Click page 3:- You can see the train wreck coming, but are powerless to prevent it; nightmarish stuff, bands aid over bull pooh, words to expunge sins and a legal minefield through which you must trustingly walk, blindfold.

Click page 4:- and some more for our required reading list.... Rolleyes


I have no idea the cost of producing these information sheets, non whatsoever; but someone should tell Skidmore to retrieve every single last copy and shred them, before the whole farcical waste of thousands of man hours and dollars is realised for the disgraceful waste it is.

Endit:- We are obliged now to tackle the MoS, but not today.  If the educational information package has not scared you off to NZ or PNG and you have struggled manfully thus far through the ‘guidance material’ , have choc frog and fresh coffee then download the MoS and have a tinker.  But do not be fooled by bland appearance and cosy, chatty feel good spin.  You are about to meet the stone cold killer employed by the regulator to do all the dirty work at the coal face, while they sip tea, munch biccies and wallow in the air conditioned safe haven created by the law of abrogated responsibility. You do realise that you – one way or another have paid for this torment to be inflicted, don’t you; also that apathy will ensure that your time in legal purgatory will be eternal.  

Selah. 
Reply
#38

Whoever wrote this garbage forgot the first lesson in 'bureaucratics 101'.

If at first you don't succeed, destroy all evidence that you tried.
Reply
#39

Lazy afternoon, it’s 61 or wash the car. 

I find myself with a couple of spare hours, too early for a beer, so I thought I’d start scratching about in the MoS, just a warm up round or two, before the bell.  You can, with some little trouble and should download the latest versions from the CASA web site.  Or, from HERE and HERE from the AP library.

Are you sitting comfortably, then I’ll begin.  Once upon a time the Part 61 Manual of Standards crept out of it’s shell and into daylight.   Our tale begins with the innocent enough Schedule 1A. Well, that’s an easy one – 13 solid pages of abbreviations.  ‘Dictionary’ implies pretensions of being a little high brow;

Quote:Early 16th century: from medieval Latin dictionarium (manuale) or dictionarius (liber) 'manual or book of words', from Latin diction.

Perhaps glossary would be a nicer description.  

Quote:An alphabetical list of words relating to a specific subject, text, or dialect, with explanations; a brief dictionary:

Volume 1 delves into the Terence Lindsay Farquharson “Instrument”; which for those of a legal bent is probably of some particular interest; however, for mere mortals, from this point on the MoS is live.  It is, for the most part comprehensible to the lay person until you reach Item 8 where you discover that the ‘units’ of competency have some legal clout, which takes you, without passing ‘Go’, into subjective interpretation land, where you’ll be hard pressed to get your $200 and stay out of goal.  The following is embedded in 8; only an example here, for examination purposes, there are more, however:-

Quote:….”[8.1] The units of competency for each of the following matters are as set out in the Appendix of a Section in Schedule 1 that is for the particular matter: etc.

Quote:….”[8.2] For an Appendix mentioned in subsection 8.1, each unit of competency mentioned in a cell in column 2 of the practical flight standards table in the Appendix (the unit of competency) has the unit code mentioned in the corresponding cell in column 1 (the unit code).”

Got that - No, try again and read carefully. 

8.1 The units of competency for (a) a flight crew licence with an aircraft category rating, a flight crew rating on a licence, or an endorsement on a rating; are matters are as set out in the (Appendix) of a (Section) in (Schedule 1) that is for the particular matter.  

You need to know where these things are – we shall in due course return to this bookmark. Just skip past 9 and 10 for the moment.  Before we trespass there we must try to understand 8, and it’s a long march toward understanding.  Patience Clarisse.  We must discover what a ‘Schedule’ is. 

So, Schedule 1 (Sked 1) all 61 pages of it, the index begins on page 14 finishing on 18, where are the first 13 pages? - however:-

Quote:N.B. ….The following Table of Contents and Index of Competency Unit codes are for guidance only and are not part of the Schedule.

We are seeking “(a) a flight crew licence with an aircraft category rating, a flight crew rating on a licence, or an endorsement on a rating”, which looks to be on page 14, “Section ‘L’ Aircraft ratings and endorsements” which resides on page 36 of this document.  A bold click and bingo; Appendix L.1. is for a single engine class rating; down to page 37 and we meet Appendix L.4. (L4. more properly) and we can see the Unit code (in its cell) and Unit of Competency (it too, in its cell).  So far so good, now we need to identify ‘what’ is involved in the code and competency, for there is not a blind clue in the agricultural style table presented.  We need the code; the keys to the kingdom, now, where did I leave them?  No matter, back to the top.  Nope, there is no additional help there, we must now cast about and see if any of the other schedules will assist.  Let me see:-

Schedule  2 – 254 pages total - in section 4 at page 110, we find Aircraft rating standards, click:-

If you skip back to Schedule 1 Appendix L4. You can see a ‘Unit code’ list – on the fifth line there is A1 – 'Control aeroplane on ground'.  Back to Sked 2, section 4 and ‘thar she blows’ A1 in all its hoary glory.  

Quote:1 Unit description 
This unit describes the skills and knowledge required to operate an aeroplane on the ground.

If you read 21.1 which expands A1.1 you may, without too much trouble see where the mind of the writer is located; and it is not on the flight line.  Take items (a) and (d).  Now when did having a look to see what was beneath the aircraft pre start ever become item last.  It is instinctive for a pilots to check as they walk toward the aircraft; and, during the daily inspection; it is also probably checked again after loading fuel and it probably a final check before the doors are closed.  Any ‘check pilot’ worthy of the name would have observed his ‘victim’ doing this type of checking before contemplating and engine start.  You may also notice that there is no mention – anywhere – of standard hand signals, the use and understanding of, for start, after start and ground manoeuvring.  This section appendix has not been put together by a competent, qualified pilot who understands how to conduct ‘training’ for a type rating.  This is not ‘competency’; this stuff belongs in part 101 of the pre first solo SOP blurb from any competent flight school, dished out day one, enforced and reinforced by competent instructor pilots.  

Quote:(h) correct handling techniques are applied to take into account wind from all 4 quadrants;
Damn straight – wind from all quadrants just about sums it up and the correct handling technique for this is to hit the bin, first time with this fraudulent document, or buy the beers.

MTF and lots of; but I need to explore a little further, without drafting notes as I read (plough) through the five separate pages I am currently cross referring to resolve the simple matter of a routine type rating (endorsement) exercise. 

Toot toot...... Smile   
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#40

Kharon old mate,

Are we there yet??

Sorry mate, couldn't resist it
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