[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