Response 121966764

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Personal information

2. Last name

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Badger

Carriage of documents

1. This proposal introduces new journey log requirements for international flights. (section 3.01 and 3.02 of the Part 91 MOS)

Please select one item
yes
some change/s required (please specify below)
no (please specify below)
Ticked not applicable

2. This proposal explicitly permits the carriage of documents electronically. (regulation 91.113 of CASR)

Please select one item
Ticked yes
some change/s required (please specify below)
no (please specify below)
not applicable

Firearms

1. This proposal removes the need for CASA approval for someone to carry firearms on aircraft - for flights not regulated for this purpose under the Aviation Transport Security Act 2004. (regulation 91.130 of CASR)

Please select one item
yes
some change/s required (please specify below)
Ticked no (please specify below)
not applicable
Comments
To restricting and introduces probability of CASA. punishing those who make paper mistakes, rather than working with the industry in a sensible way.

Crew members

1. This proposal creates a broader requirement for fitness for duty and removes the prescriptive eight-hour rule for alcohol consumption. (regulation 91.215 of CASR)

Please select one item
yes
some change/s required (please specify below)
Ticked no (please specify below)
not applicable
Comments
Places more power in an already dictatorial and persecutive CASA beauracracy.

2. This proposal broadens the requirement for cabin crew, to include non-air transport flights carrying 20 or more passengers. (regulation 91.1460 of CASR)

Please select one item
yes
some change/s required (please specify below)
Ticked no (please specify below)
not applicable
Comments
Terrible rule that takes away from responsibility of passengers and crew to operate safely. Placing a cabin crewman in the fuselage is another form of multiple layers of safety that are meant to add to total safety capacity. If Australia is to be world competitive you can’t have beaurecrats dictating rules for rules sake. Enforced passenger education is better for all.

3. This proposal broadens the requirement for passengers to comply with cabin crew safety instructions. (regulation 91.790 of CASR)

Please select one item
yes
Ticked some change/s required (please specify below)
no (please specify below)
not applicable
Comments
Oblique at best! Lay it out in terms that crew and passengers can relate to. Too much CASA gobbledegook!

Portable Electronic Devices (PEDs)

1. This proposal removes the prescriptive list of permitted portable electronic devices (PEDs) on flights. (regulation 91.145 of CASR)

Please select one item
yes
some change/s required (please specify below)
Ticked no (please specify below)
not applicable
Comments
Blame the PIC for not enforcing ridiculously worded CASA directives. CASA vs those in control of aircraft, that’s the usual recipe. Wake up!

2. This proposal restricts crew members from operating PEDs where that would be distracting to the performance of their duties. (regulation 91.150 of CASR)

Please select one item
yes
some change/s required (please specify below)
Ticked no (please specify below)
not applicable
Comments
Allows CASA to prosecute for the most mundane or trivial breach. Eg, MSG alert may appear on nav screen, time for CASA to get all heavy handed and ground the crew and probably the operator as well. Has happened before so will happen again.

Equipment

1. This proposal relaxes oxygen requirements for non-air transport operations. (Division 30.9 of the Part 91 MOS)

Please select one item
yes
Ticked some change/s required (please specify below)
no (please specify below)
not applicable
Comments
Wow, a loosening of restrictions to bring us in line with the rest of the world! Unbelievable, I wonder what the real aim is?

2. This proposal expands a requirement to preserve flight recordings (and recorders) after an immediately reportable matter while reducing the amount of time these need to be retained. (regulation 91.724 of CASR)

Please select one item
Ticked yes
some change/s required (please specify below)
no (please specify below)
not applicable

3. This proposal consolidates all the rules for the Minimum Equipment List (MEL) in one place and expands who can approve the MEL. (regulation 91.1680 to 91.1705 of CASR and sections 33.01 to 33.09 of the Part 91 MOS)

Please select one item
yes
Ticked some change/s required (please specify below)
no (please specify below)
not applicable
Comments
Need to mandate the response time from CASA if they are to be notified of changes. Usually takes weeks/ months to seek permission for anything from CASA so they can’t be relied upon to act in the interest of passengers nor industry. Well and good to write a legal right to seek changes but how long do you have to wait for a decent reply or decision.

Take-off and landing

1. This proposal introduces an approach ban for Instrument Flight Rules (IFR) flights under certain circumstances. (section 17.07 of the Part 91 MOS)

Please select one item
yes
some change/s required (please specify below)
no (please specify below)
Ticked not applicable

2. This proposal changes the existing low visibility take off and approach exemptions to an approval. (regulation 91.425 of CASR)

Please select one item
yes
some change/s required (please specify below)
no (please specify below)
Ticked not applicable

Flight requirements

1. This proposal extends the ability for pilots not operating under an AOC or other certificate to use night vision imaging systems (NVIS) under certain conditions. (section 5.02 of the Part 91 MOS )

Please select one item
yes
some change/s required (please specify below)
no (please specify below)
Ticked not applicable

2. This proposal introduces the ability for night Visual Flight Rules (VFR) flights to use IFR lowest safe altitudes. (regulation 91.395 of CASR)

Please select one item
yes
some change/s required (please specify below)
no (please specify below)
Ticked not applicable

3. This proposal introduces a requirement to comply with Air Defence Identification Zones (ADIZ) procedures. (regulation 91.362 of CASR)

Please select one item
yes
some change/s required (please specify below)
no (please specify below)
Ticked not applicable

4. This proposal creates a requirement to comply with aircraft interception procedures. (section 20.05 of the Part 91 MOS)

Please select one item
yes
some change/s required (please specify below)
no (please specify below)
Ticked not applicable

5. This proposal reduces the altitude above which a VFR aircraft must (where practicable) use VFR cruising levels from 5000 ft to 3000 ft AMSL (above mean sea level). (section 13.04 of the Part 91 MOS)

Please select one item
yes
Ticked some change/s required (please specify below)
no (please specify below)
not applicable
Comments
Opens probability of CASA going wild on compliance. Who governs CASA’s appetite to persecute at will. When they are bored or have government looking in the go for misdeameanors to make it look like they are doing something.

Animals

1. This proposal significantly simplifies the rules for the carriage of animals in the aircraft cabin. (regulation 91.200 of CASR)

Please select one item
Ticked yes
some change/s required (please specify below)
no (please specify below)
not applicable

Emergency simulation restrictions

1. This proposal restricts the simulation of certain emergencies, predominantly, in Instrument Meteorological Conditions (IMC) or at night. (regulation 91.570 to 91.610 of CASR)

Please select one item
yes
some change/s required (please specify below)
Ticked no (please specify below)
not applicable

General response

1. Are the proposed changes to the general operating flight rules appropriate and can they be complied with by industry without undue burden?

Please select one item
yes
Ticked some change/s required (please specify below)
no (please specify below)
not applicable
Comments
Inflated and bloated as usual. What else would you expect from CASA.

2. One of the aims was to primarily consolidate the current rules and carry over existing regulatory requirements. If you exclude the changes listed in the Summary of Proposed Changes, has this been achieved?

Please select one item
yes
Ticked some change/s required (please specify below)
no (please specify below)
not applicable
Comments
To beauracratic and too much arse covering. Let the industry regulate rather than the bloated CASA machine that is hell bent in banning aircraft from the skies of the most navigatable country on earth.

3. Are there any significant aviation safety risks which have not been addressed in the Part 91 of CASR draft regulations and MOS?

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Ticked yes (please specify below)
some change/s required (please specify below)
no
not applicable
Comments
The greatest distraction to pilots and operators in Australia today is CASA. They are an out of touch, overbearing, fat, lazy, and unaccountable, and are an outright danger to all engaged in aviation in Australia today. I say this with experience in SE Asia and Africa. We need a regulator who wants aviation, rather than one who wants aviation banned.

Your priorities

1. When you reflect on the feedback you have provided throughout this consultation, what are the three matters you consider most important?

Priority 1
The dangers that CASA causes
Priority 2
The retribution that I will receive from CASA for speaking what everyone thinks
Priority 3
I only have 20 yrs of flying left so I am trying to protect aviation for the young pilots, young operators and our passenger customers.