Proposed changes to the general operating and flight rules - Part 91 of CASR (NPRM CD 1511OS-2)

Response 166064654

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Personal information

2. Last name

Last name (Required)
Cleary

5. If yes, please specify the name of your organisation.

If yes, please specify the name of your organisation
The illawarra Flyers

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)

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yes
some change/s required (please specify below)
no (please specify below)
Ticked not applicable
Comments
This proposal is not applicable to our group

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

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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)

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Ticked yes
some change/s required (please specify below)
no (please specify below)
not applicable

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)

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Ticked yes
some change/s required (please specify below)
no (please specify below)
not applicable

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)

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yes
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no (please specify below)
Ticked not applicable

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

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Ticked yes
some change/s required (please specify below)
no (please specify below)
not applicable

Portable Electronic Devices (PEDs)

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

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Ticked yes
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no (please specify below)
not applicable

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)

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Ticked yes
some change/s required (please specify below)
no (please specify below)
not applicable

Equipment

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

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Ticked yes
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no (please specify below)
not applicable

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)

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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)

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Ticked yes
some change/s required (please specify below)
no (please specify below)
not applicable

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)

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Ticked yes
some change/s required (please specify below)
no (please specify below)
not applicable

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

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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 )

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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)

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Ticked yes
some change/s required (please specify below)
no (please specify below)
not applicable

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

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Ticked yes
some change/s required (please specify below)
no (please specify below)
not applicable

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

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Ticked yes
some change/s required (please specify below)
no (please specify below)
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)

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Ticked yes
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Comments
This proposal generated the most discussion within our group, but when compared to the existing CAR reg 173, we see this change as an improvement. We do however question why you see the need to double the penalty points associated with this new reg compared with CAR 173

Animals

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

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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)

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Ticked yes
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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?

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Ticked yes
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no (please specify below)
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Comments
We have been quite impressed with the obvious homework done by CASA on this Part prior to releasing it for consultation. The webinar was a good idea and was well presented There has been a significant dose of common sense applied to all the proposed changes and there are no apparent hidden agendas. The difference between the implementation of this Part and part 61 is so huge it is difficult to believe the work has been done by the same organisation. The quality of the work on this Part is such that we decided that we should 'just get on with it'. Well done 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?

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Ticked yes
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no (please specify below)
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Comments
Following are a couple of minor 'typo' type matters for consideration: MOS MDA definition - change the word 'attitude' to 'altitude' MOS Table 2.03 (4) does not show the criteria for Class G VMC Page 51 - Add definition for IRCC MOS 13.01 (Last IFR should be VFR) (2) For the definition in regulation 91.365 of specified VFR cruising level for a track, section 13.04 prescribes the cruising level for an aircraft in an IFR flight on the track. 25.02 (7) Listening watch (7) For the purpose of making required reports and broadcasts, the PIC of an aircraft in an operation below 5 000 ft in Class G airspace: (a) must maintain a listening watch on the area VHF; and (b) if necessary for the safety of the operation — must maintain a listening watch on frequencies other than the area VHF. Please compare with table 30.80 (1) where there is no requirement to carry a radio below 5000 feet except in a CTAFR area. IFR aircraft should be required to carry 2 radios or a radio capable of monitoring a second frequency, so they can monitor CTAF frequency on arrival to improve their situational awareness, as well as communicate on the area frequency. MOS Table 30.06 (2) requires magnetic heading equipment as follows; The system must be: (a) a direct reading magnetic compass; or (b) a remote indicating compass and a standby direct reading magnetic compass. It would seem more than appropriate in this day and age to add a (c) that allows some combination of 2 or more remote indicating compasses without the need for a direct reading magnetic compass? MOS page 146 - Fig 30.64 TAS RA actually shows Snowy RA

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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yes (please specify below)
some change/s required (please specify below)
Ticked no
not applicable

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
Education
Priority 2
Education
Priority 3
Education