Response 374710242

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Stubbs

Introduction of proposed safety standard - community service flights

The proposal introduces minimum CSF pilot experience, licensing and medical requirements, requirement of flights at night to be conducted using instrument procedures instead of visual procedures and requires slightly enhanced aircraft maintenance requirements, in line with other operations within Australia involving similar participants.

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The conditions proposed seem generally reasonable. Paragraph 10 (b) of the instrument consultation draft is however confusing. It reads: (b) the aeroplane has undergone a maintenance release inspection at the earlier of 100 flight hours or 12 months before the date of the flight. I presume this intended to mean that an inspection must have been performed within the last 12 months AND within the last 100 flight hours, but it actually says an inspection must have been performed at the earlier of two precise instances which makes no sense. The requirement to have had an inspection within the last 12 months is already in the CARs as far as I am aware so should not need to be repeated here. Therefore a condition that the aircraft must have a current maintenance release issued no more than 100 hours before the flight would make more sense.