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Hargreaves Holdings Pty Ltd
Feedback on the proposed policy amendments to Part 101 MOS registration, accreditation and transitional provisions.
Question 1 - Do you agree that the Part 101 MOS amendments reflect the change in policy as set out in the summary of proposed change and will work as intended?
Please select one item
Ticked
I agree
I do not agree (please specify why below)
Question 2 - Do you agree that the Part 101 MOS amendments will not result in unintended consequences?
Please select one item
I agree
Ticked
I do not agree (please specify why below)
Comments
The Safety Risk Analysis contained within the Summary of Proposed Change states that "the delayed commencement of paragraph 2.30 (2) (c) regarding RePL training instructor qualifications will not adversely affect aviation safety".
The requirement, in paragraph 2.30 (2) (c) of Division 2.7 of the Part 101 Manual of Standards, that a RePL instructor hold a pilot instructor rating, a Certificate IV in Training and Assessment, a tertiary level qualification in teaching, or a certificate of successful completion of a training program in the principles of instruction, is, in our opinion, a sensible requirement and one which will improve the quality of RePL training courses, and the knowledge, competence and confidence of new RePL holders.
The RPAS industry has, and continues to see, new RePL holders who enter their roles without the appropriate levels of knowledge to ensure compliance with CASR Part 101, and to ensure aviation safety. As CASA has acknowledged, this stems from a number of RePL training organisations rushing members of the public who are new to aviation through sub-standard courses without appropriate time or detail spent teaching material essential to aviation safety.
The Part 101 MoS has taken significant steps towards improving the RePL course structure, curriculum and quality of RePL training organisations.
We do not agree that a further 18-month delay to the introduction of a requirement for RePL instructors to hold a teaching or training qualification will not adversely affect aviation safety.
If the delay to the introduction of these standards for RePL Instructors will not adversely affect aviation safety as the Summary of Proposed Changes states, then there can be no safety-based foundation for their introduction in the first place.
The Part 101 Manual of Standards was made on 9 April 2019. RePL training organisations have already had 18 months during which they could have ensured that their instructors hold the requisite qualification. Notwithstanding the impacts of COVID-19, it has remained possible to complete VET qualifications such as the CertIV TAE.
A further 18-month delay to the introduction of these requirements will impact the quality of training provided to some RePL candidates and inevitably will have a negative impact on aviation safety.
We do not support a three-year delayed start to these requirements and suggest that the existing commencement date should remain.