Flight training and flight tests for specialised endorsements (CD 2304FS)

We sought feedback between 17 and 30 April 2023 on the proposal to establish a tailored system for training, assessment, grant and exercise of "specialised endorsements" including the sling, winch and rappelling operations and firefighting endorsements.

We had previously been told that the flight training and testing scheme for these specialised endorsements was not working as efficiently as intended. This is believed to be one of the reasons for the limited availability of suitably qualified flight instructors, examiners and flight training operators to conduct training and assessment for specialised endorsements and consequently impacts the availability of suitably qualified pilots to conduct specialised operations.

In many respects, the intended approach to flight training in which the requirements for conducting lower risk activity authorisations were meant to require less rigorous training and testing compared to the higher risk activities has not materialised for these pilots and an alternative approach to better facilitate training and assessment for these endorsements may be possible.

We proposed changing the rules to establish a tailored alternate system for training, assessment, grant and exercise of specialised endorsements.

Note: The existing Part 61 and Part 141 flight training scheme remains available for training, assessment, grant and exercise of these specialised endorsements.

The proposal addressed:

• entry criteria and prerequisites for new pilots seeking a specialised endorsement
• training and assessment requirements for the grant of specialised endorsements
• supervision requirements following completion of training, assessment and grant of endorsement
• maintenance of competency following grant of endorsement
• entry criteria and prerequisites for persons conducting training specialised endorsements for Part 138 or Part 137 operators
• maintenance of competency for persons conducting training and flight tests for specialised endorsements
• requirements for Part 138 or Part 137 operators who elect to conduct the training and facilitate the assessment and grant of specialised endorsements.

About this consultation

We received 13 responses, the majority from pilots, Part 138 or 137 operators, flight instructors and flight examiners and flight training operators.

The consultation survey asked respondents “Do you have any comments about the proposed instrument?.” Six responses were clearly in support of the proposed instrument. Five responses implied support for the objectives of the policy, while either suggesting changes to the technical detail of the instrument or posing questions on the operation of the instrument.

Common themes from the free text responses included opinions that:

• training and testing for these endorsements should be facilitated in industry due to the limited access to instructors and examiners
• industry is better served by training, testing and checking for these endorsements being conducted by those using them regularly in industry
• the new rules will allow operators to more easily move new pilots into specialised roles without incurring prohibitive costs associated with accessing limited training providers
• the new rules should explain what needs to be included in the practical flight training, to ensure that trainees have exposure to a wide range of scenarios and environments.

Two responses did not support the proposed instrument. These free text responses included comment that the instrument:

• would be detrimental to aviation safety by lowering the quality of pilot produced
• would not improve aviation safety because the 'train-the-trainer' course would not be sufficient to impart adequate instructional skill and techniques to the trainer. Additionally, operators would be conducting the training on an irregular or seasonal basis and so the trainer would have no ability to improve their instructional skills or the quality of the training course
• would be detrimental to aviation safety because trainers would not be competent to conduct emergency procedures training. These procedures would be ignored and so pilots who receive an endorsement using this pathway will not be trained in how to manage potential emergency situations
• is over complicated and unnecessary because the current system is working
• will not help with the shortages of instructors and should not be allowed as an alternative to the current instructor and examiner system.

We recognise and emphasise the importance of pilots and operators conducting sling, winch or rappelling or firefighting operations implementing and maintaining a strong safety culture. The proposal emphasises operational responsibility and builds on safety requirements such as safety systems, training and checking systems and operational manuals required under Parts 138 and 137 of CASR.

Operators who intend to conduct training and facilitate the assessment and grant of a specialised endorsement will need to develop a training syllabus and have it approved by CASA. CASA must be satisfied that the operator can safely and adequately deliver the training and that the operator has suitable staff to conduct the training. Continuous improvement is necessary in any training course, whether it is delivered by a flight training operator or a commercial operator through this pathway.

In addition, the 'train-the-trainer' course requirements prescribe the minimum amount of training required. The training provider and instructor delivering the training to the trainer pilot must be satisfied that the trainer pilot is competent to deliver training.

Trainer pilots under this proposal must be sufficiently experienced and are expected to be knowledgeable and skilled in managing emergency procedures. Ensuring trainees are competent in emergency and non-normal procedures is an operational responsibility and should also be addressed in the operator's ongoing proficiency checking.

Summary of feedback

Common themes, issues and suggestions raised in responses included:

Specific technical requirements

Six responses made comment or reference to the specific technical requirements proposed in the instrument (for example, the prerequisites for trainee pilots). These responses made quite varying suggestions, including that:

Prerequisites for trainee pilots

• the trainee prerequisites should be consistent for each specialised endorsement and require 200 hours PIC experience for the relevant category.

Training and assessment

• for the sling operations endorsement, 10 hours of training would be more suitable. If training and testing for the sling endorsement, then the fire rating could be conducted in house by a quick check ride
• Part 142 flight training operators should have an avenue to conduct the training and testing, in addition to Part 141 flight training operators
• the firefighting endorsements should be attached to the low-level rating rather than the aerial application rating. This would be better for this instrument because the 'trainers' operating under the instrument would only be issuing an endorsement without the need to issue any new rating
• for the firefighting endorsement, most beginner firefighting pilots begin with flying an AAS (air attack supervisor) platform which principally involves doing slow left-hand orbits at around 500 ft. The 5-hour dual flight time requirement is unnecessary for this, and 1 mock fire flying session of at least 1 hour flight time with strong correlation to a briefing/theory session following a syllabus would be more appropriate
• for the firefighting endorsement, the requirement for the training to include at least 5 firefighting operations, conducted during a minimum of 3 flights serves no purpose and is virtually impractical to achieve because if it is a mock firefighting session then one is enough especially if the operation can involve as little as flying slow left-hand orbits. If it means a real firefighting operation, then that is truly impossible.

The instrument does not include detail of what is involved in a firefighting operation and we understand that this may create ambiguity. For clarity, the 'firefighting operations' contemplated in the instrument involve activities which require the firefighting endorsement to conduct. In essence, this involves applying or dispensing water or fire retardant from below 500 ft AGL for fire suppression. There are various methods of applying or dispensing the firefighting material, including buckets and tanks.

Air attack supervisor activities that involve slow left turns at around 500 ft AGL, as mentioned in the comments above, are not 'firefighting operations' contemplated in the instrument, and do not require a firefighting endorsement to conduct - only a low-level rating with the relevant category low-level endorsement is required.

The training for the endorsement under the instrument must involve training to the competency standards and in the activities permitted by the firefighting endorsement (applying or dispensing water or fire retardant from below 500 ft AGL for fire suppression) rather than simply air attack supervisory services. We will clarify this in the final instrument.

The intent was to enable operators to consider what is involved in a sling or winch or rappelling operation for their unique operational circumstances, rather than defining or explaining what a 'sling operation' and 'winch or rappelling operation' involves. We will consider whether it is necessary to also define 'sling operation' and 'winch or rappelling operation' in the final instrument.

In addition, training in firefighting operations refers to simulated or mock firefighting operations, rather than actual firefighting activities. We will clarify this in the final instrument.

Recurrent checks

• annual checks should be required for pilots with less than 20 hours actual fireground experience; for pilots with over 20 hours fireground experience, a check should only be required if the pilot has not completed any fire work in the last 18 months.

Trainer requirements

• the trainer pilot requirements for the specialised endorsements should be consistent, with 1000 hours PIC on relevant category, 100 cycles (for sling and winching), and 100 hours experience for firefighting. The 2 years' experience requirement does not ensure competency or experience
• an instructor with an operational endorsement should be able to conduct training for that endorsement
• Grade 1 training endorsement holders with the relevant training endorsement should be able to conduct the flight test.

We have considered the comments made above, though CASA intends to proceed with the requirements in the original proposal. We will review the operation of the policy following commencement by continuing to engage with relevant sectors, and we will complete a policy review before making any changes to incorporate the effect of the proposed instrument into CASR.

Questions posed by respondents regarding how the instrument will work

Four respondents also asked questions regarding how the instrument will work. These questions (edited for length and consistency) and CASA's responses are at Table 1.

Table 1: Respondent questions and CASA responses

The consultation indicated support for the proposed instrument and the proposed alternative pathway for the training, assessment and grant of specialised endorsements. Minor changes will likely be made to improve the clarity of the instrument. However, any changes will not impact the intended effect of the instrument or the underpinning policy.

The instrument will be in place by mid-June 2023.