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

Response 692000541

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Bryant

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 only issue I have in reviewing the proposed standard is the number of hours. Previously, AngelFlight (for whom I've flown a few CSFs) required 300 hours. The raising to 400 hours adds over 30% more time required and will limit their pool of resources to carry out this important function. They had most, if not all, similar requirements as per your document. Also, they were authorised the pilot to identify themselves as an AngelFlight when making radio announcements on CTAF. I did not see mention of this in your proposal. While I was not paid for this service, my fuel was reimbursed, and I did not see acknowledgement of this in your document.