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

Thanks for this opportunity. I have followed closely the recent tragic air accidents of several CSF. My views are formed as a result of what I have personally observed at airfields where I have seen CSF ops, on ATSB information, news media reporting and some informal information via aviation colleagues with some inside knowledge. I have witnessed what I consider to be dangerous flight operations and poor decision making with zero or low planning for flights with members of the public who have no idea of the danger they are placing themselves in. There is a responsibility to the public to maintain better standards as they typically have no idea of the skill or qualifications of the pilot who is operating their flight. Often you will read in the media, following a fatal accident, that the pilot "was experienced" as related by their family or friends.. then you learn that the pilot has held a licence for 2 years and has just 200 hours TT. Carrying pax who are not your friends is a huge change for the average PPL. All previous flights are with family or friends who understand if the flight does not go ahead. They have your interest at heart, they have self interest and finally most do not want to fly "for fun" on a day of poor weather. Thus there is no pressure on the pilot. If he says no due weather his family will agree 200%! Thus the change to what is essentially a commercial ops situation where there is an expectation that you will get the passengers to their destination is a very large change. They have turned down the road option, if the aircraft can't get them there they will likely miss their appointment. Loading passengers always takes longer than expected, getting fuel in unfamiliar airfields takes longer. The passengers arrive and are heaver than what they said and have more "stuff" to bring along. Last light cut off times get pushed out...In marginal VMC this is huge pressure for a typical PPL. Most private pilots are not equiped to handle these (new) pressures. They certainly are not trained in the skills of managing people and saying "NO". My view is the proposed changes are not enough, though they are on the right track. Two issues: A; total time as PIC is an issue, plus B; time in last 90 days. The proposal suggests 250 hours PIC and 1 landing in last 30 days (and only 10 hours on type). Both of my issues essentially relate to Human Factors and the PIC decision making. A: I believe that 250 hours PIC/400 hours TT is too low. Community confidence in these flights is vital. 250 PIC hours is too low to handle the pressure and decision making. Many older pilots who are attracted to do CSF meet this requirement even though they fly just 30 hours/year. I believe that an increase to 500 hours min time as PIC will only marginally reduce the potential pool of volunteer pilots, but this will increase safety significantly. If a PPL get to 500 hours then they are better equiped to manage carrying non aviation pax in a higher pressure environment than that they normally carry (friend/family). Managing non aviation strangers with medical needs and often in less then perfect weather is an order of magnitude of difference from typical private ops with family when you choose to fly in perfect VFR weather, and have the option to change or cancel the flight if the weather deteriorates - and your family understands that. Saying no to strangers who need to get to medical treatment is hard. This is "gethomeitis" x 10. B: My view is currency is vital. We want these pilots to be current, that means you want pilots who fly 100 hours/year or more. The requirement of just 1 landing in last 30 days is too low. I suggest a minimum of 5 hours PIC time in last 30 days AND 20 hours in last 90 days is what should be minimum. If CSF pilots are not doing 20 hours in the last 3 months then they are not current to handle the stress and pressure to get these vulnerable strangers to far away airports in less than perfect weather. Alternatively you could have a variation of these numbers - but along these lines based on about 100 hours/year. If they are not flying 100 hours per yer they should not be CSF pilots carrying this high pressure payload. Interestingly the 1 landing in 30 days is not really the issue - the danger I see is not whether a pilot has the physical "stick n rudder" skills - (which 1 landing in the last month implies) but whether the pilot has the right mindset maturity and decision making currency to make the right decisions early to avoid getting themselves into marginal VMC or other boxed in corner. This is human factors - not physical skills. "Decision making currency" is more important than the number of circuits you have done currency. Decision making currency will help ensure that prior planning, contingency planning, physical currency, and ability to say "no" are all done when needed in a timely fashion. The issue is not that you can actually fly an aircraft on a beautiful VFR day. It is what and when you make decisions about carrying passengers who have a huge vested interest in getting to their destination in marginal weather or poor light. Can you make a decision that will greatly disappoint the passengers early enough for everyone to be safe??