Response 172468298

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THOMPSON

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Royal Federation of Aero Clubs Australia

Feedback on the proposed amendment to Part 61 MOS spin avoidance and stall recovery training

1. Do you agree that once in force, the Part 61 MOS amendments will reflect the change in policy as set out in AC 61-16 v1.0?

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There is strong opinion from a majority of RFACA members that spin training should be retained.

2. Do you agree that once in force, the Part 61 MOS amendments will not create unintended consequences?

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It is the opinion of the majority of RFACA members that the removal of spin training will lead to an increase in stall/spin accidents.

General comments

Do you have any additional comments about the proposed policy?

Comments
In May 2019 RFACA conducted a survey regarding stall/spin training.
In response to a request from the CASA Acting Manager Flight Crew Licensing Standards, the Royal Federation of Aero Clubs (RFACA) undertook to canvas member and other flight training organisations with the intention of gathering input relating to the conduct of incipient spin and spin training and the aircraft types used to conduct this training. Attention was focussed on this issue following the release of the ATSB final report into the Diamond DA40 accident in Queensland in September 2017.

The RFACA was not able to ascertain the number of training providers who do not have suitable aircraft to conduct incipient spin training nor the number of operators who conduct this training in aircraft not approved or certified for spin training.

The RFACA membership holds the view that:

• The requirement for incipient spin training should be retained, that wing drop stall is not sufficient due to differing recovery technique
• CASA should provide a definition of incipient spin as it relates to the MOS training standards
• Spin training should be mandated for flight instructors conducting ab-initio through to CPL training and competency in these manoeuvres should be demonstrated at least in every instructor proficiency check or internal standardisation check.
• Aircraft used for the conduct of incipient spin training should be certified or approved for spin training

Overview of Responses
Many of the responses received were very detailed. All the respondents are past or present Chief Flying Instructors, Heads of Operations, Flight Examiners or ATO’s and between them represent many thousands of hours of flight training and testing experience.
The respondent organisations ranged from operators of large academy type training colleges through to small schools conducting principally private pilot training and included specialist aerobatic schools.

Not surprisingly the range of opinions regarding incipient spin training and testing for PPL and CPL varied widely. There was consistent comment regarding the definition of “incipient spin” being ambiguous and not clearly defined by CASA.

Additionally, many considered that instructor’s understanding of stalling and spinning was poor, and it was suggested that instructors should undertake recurrent training in stalls and spins on a regular basis (possibly each time they undertake the instructor proficiency check and/or with the mandated internal proficiency check).

Further information obtained by the ATSB from the Diamond company regarding the application of any control input that could lead to a spin has led to at least one operator seeking additional clarification from the manufacturer as to what is permissible in that aircraft. Other spin accidents in new aircraft such as the Bristell were also identified.

Many schools have access to spin capable aircraft but there are some that do not. Most of the new training aeroplanes being purchased by operators are not approved for spinning. Larger training organisations appear to be investing heavily in new glass cockpit “plastic” type aeroplane which are used for training future airline pilots. Nearly all these aircraft are not spin approved.

Responses Summary
The key points in each response have been provided below and the respondents been de-identified.
Contributor 1: Spin training and or incipient spin training should be retained as part of the PPL/CPL syllabus. This is a serious element of pilot training. If an operator cannot get access to spin capable or at least utility cat aircraft with well qualified Instructors then in my opinion they should not have P141/142 approval. Some pilots appear startled during approach configuration and turning stalls. I think we have to be careful not to dumb the training down even more than what it is today.
Contributor 2: Incipient spin recognition and recovery training should be mandatory. Aircraft that are not certified for spinning, should not be used for incipient spin training. The question that needs to be asked is, should a flight school be conducting pilot training if it does not have the resources that allow for the training of this important element?
Contributor 3: Flying schools should be required to have spin capable aeroplanes and ensure that their instructors are competent to teach these sequences. CASA should consider including a basic Acrobatic course in the instructor rating syllabus. Examiners must be more rigorous when testing instructors to ensure they can perform the stall and incipient spin to a satisfactory level of competency.
Contributor 4: As with other regulators, CASA should provide a clear definition of incipient spin. ICAO Annex 1 refers to spin avoidance - we must regard spin avoidance as a necessity for PPL/CPL and spin recovery as part of instructor training as essential. Stalling with a wing drop (whether induced or otherwise) has, for many years been widely regarded as an incipient spin and would certainly qualify as spin-avoidance training. There would be a significant cost impact on operators in obtaining/accessing spin capable aircraft.
Contributor 5: Definition of incipient spin requires clear guidance from CASA. Different recovery technique from a wing drop stall and a spin. Does the expense of obtaining a spin approved aeroplane offset the risk of sending pilots into industry who have never experienced spins or their recovery? We are opposed to requirement for spin approved aeroplanes for CPL training or testing. Wing drop sufficient.

Contributor 6: Fully endorses the response from Contributor 5 above.

Contributor 7: Definition of incipient spin not clear, CASA varies from other authorities.

Contributor 8: Every school should have access to a spinnable aeroplane and a suitably qualified instructor. Poor instructor knowledge and understanding of stalls and spins.

Contributor 9: RFACA should not oppose any proposal by CASA to align with international practice.

Contributor 10: Incipient spin definition not clear. Spinning not necessary for PPL and CPL. All DA40 stalls to be conducted wings level pending clarification from Diamond re incipient spin entry. We are conducting advanced stalling in the DA20 which is spin capable. Suggest spin refresher training for all instructors when undertaking a proficiency check for their instructor rating.

Contributor 11: Incipient spin definition not clear. MOS reference Aircraft Rating Standards, A5 Aeroplane advanced manoeuvres range of variables, manoeuvres performed within operating limits of aeroplane.

Contributor 12: Incipient spin not appropriate for some aeroplanes. Cirrus has spins prohibited, but has the split wing which gives aileron control in the stall and is very difficult to induce a wing drop without pro spin control inputs.