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Whilst I can see the need for some type of regulation(s) in regard to CFS flights these should be formulated taking into consideration the accident "history" of such flights over the last (say) 10 years and looking at the primary cause of these accidents.
Whilst CASA is a regulatory body and as such uses a punitive response to a breach of regulations such an approach in an attempt to regulate CSFs is an inappropriate model to be adopted.
A self regulated approach by organisations conducting such flights should be based on CASA recommendations rather than regulations is a more appropriate model to be adopted.
It would be appropriate if these recommendations were not effective and adopted in principal by organisations conducting such flights, further action would be considered. These recommendations MUST come in consultation and be the prime basis of input from organisations conducting CRF and not what CASA perceives as regulations that will improve the safety of such flights.
Finally, the persons conducting these flights do so on a voluntary basis and provide a valuable cost effective service to the community especially in country areas. "Over" regulating such services will result in their demise and eventually disappearance. This has been amply demonstrated in general aviation!