Response 93834857

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Costick

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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My comment is to leave matters exactly as they are, no legislative changes are required. There has already been a public consultation in this matter in 2014 which stated the desire was then that no legislative changes are required, what has happened in the four years since to change the matter. Has any incident occurred in Australia since then, or indeed ever, to warrant further legislation? I have know of none. What is the difference with a CSF made for medical purposes and say a flight taken for the another reason. For example if a private pilot with a basic class 2 medical helps a friend out by picking them up from an airfield to take them and their partner to Melbourne to go to the theatre, and gives them a lift back a day or so later, and no money changes hands then this is an allowable activity, even under the proposed changes. If the same friend is picked up from the same airfield needed to go to hospital in Melbourne to receive some kind of treatment, then this would be disallowed under the new rules. Even more ridiculous if the 'patient' received medical treatment while on board the aircraft the proposed regulations would not apply, so take a medically prescribed paracetamol on the flight and anyone can fly you anywhere! So what is the benefit to anyone involved of the proposed changes? Clearly the answer is that there is no benefit. This is legislation for its own sake, a purley bureaucratic exercise and my feedback again is is to leave matters exactly as they are, no legislative changes are required.