Response 764180214

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Haynes

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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I do believe that pilots of CSF's should have PIFR or IFR qualifications but I don't believe it requires another burdensome 50 + page document from CASA to say so. The likes of Angel Flight, Care Flight etc. can easily put this in their criteria for pilots of CSF. A wordy unwieldy document will only discourage pilots from conducting these flights. Whereas adding PIFR or IFR will mean the pilot has taken the extra study, had more training and hopefully has a better understanding of conditions that may or may not be suitable for CSF. These are NOT medical emergency flights. If the pilot is not confident about the flight for any reason - weather, aeroplane, patient, etc. the CSF should be cancelled. (better to be late than dead on time) The users of CSF also have the right to refuse the flight and should be told to do so if they have any concerns. As the pilot if you think there is undue concern from a patient/passenger, reassure them there is no obligation to fly and advise them to arrange other means of transport.