History
Whilst engaged as a company pilot for an organisation, the company owners decided to donate aircraft hours to a charitable organisation. Having come from a charter/aeromedical background, I found the manner and methods by which the organisation understood the aviation environment and management of passengers to be understandably, very poor. I initiated the use the existing Operations Manual as a template for the design of a mini-manual for the organisation to follow. This incorporated 20.11, general instructional material and other aspects of the safety management system. It was received well but relied still, on the extreme diligence of the pilot particularly, to oversee the safety of passengers around aircraft and at airports generally. I found the conduct of some flights akin to that of a commercial IFR charter.
Feedback
Generally speaking, I don't believe in further regulation and would strongly recommend looking to the FAA for guidance in this matter. The US has a widely active, buoyant and enthusiastic community service GA sector and the FAA has likely dealt with many of these issues.
There is an aviation risk, no doubt about that. There is also wider risk here too, of lives, quality of life and community welfare to be balanced with that concern. A lack of funding and available alternatives means these passengers (many of them children) are without transportation except for the generous donation of time and equipment by these pilots and owners who are effectively subsidising the government's lack of support for people in need.
CASA has not provided any data on the size of the sector here, nor of the occurrences which have precipitated such a review. Are occurrences in excess of the average GA accident/incident rates in Australia? I'd suggest you publish the data so as respondents we too, can identify the issues.
Whilst I am reluctant to see further regulation, I would suggest that the organisations themselves, stipulate the minimums that are required, in a manner similar to that which some air charter consumers also stipulate.
I would suggest...
For CSFs
PPL(A) Class 2 medical.
VFR day only or IFR day/night - both meeting recency.
Minimum 250 hours total experience, 10 hours on type SE/20 hours ME.
Flight review is current - especially aircraft owners!
VH registered, FAR-23 aircraft, current maintenance release.
Suggest further, that the organisations provide a merit system and more actively recognise donors/pilots on their CSF experience/missions.
The other risk is that of legislating this sector out of existence, which really will destroy lives.
This is a matter for the organisations to determine the manner and standard by which their passengers should be transported and with advice, setting the criteria.
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