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I do not support the proposed changes.
There should be no reason that CSF's require any additional burden beyond holding an appropriate license. Any increase in the experience required to conduct such flights will reduce the number of pilots able to conduct such flights which will have a negative effect on the CSF organisations and the important work they do.
Additionally such increase in requirements on pilots and maintainers will add an additional cost burden to an already struggling sector. This will further reduce the number of active pilots as the cost increases and only reduce safety as pilots fly less.
CSF organisations themselves already have minimum requirements beyond holding an appropriate license. Whilst these are not as comprehensive as the proposed changes, they have been established by the CSF organisations as adequate to mitigate the risks they perceive.
The information provided does not provide any details on the safety assessment conducted, the existing risk and the subsequent residual risk if the changes were implemented, let alone the cost to the industry.