Proposed safety standard - Community service flights (CD 1814OS)

Response 438948855

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Schneider

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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You have not spelled out why this increase in regulation is needed. You would need to convince me that a problem, supported by evidence actually exists. Have there been mishaps or accidents that can be directly traced to lack of pilot judgement due to inexperience, flying night VFR instead of IFR etc. I do not support more regulation and consequent increase in compliance burden just to 'make aviation safer'. Increase in regulation often does the opposite, particularly when it restricts and inevitably makes this kind of charitable contribution a thing of the past. On these grounds, I strongly oppose this proposal.