Response 225334038

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Personal information

2. Last name

Last name (Required)
McNally

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

If yes, please specify the name of your organisation
Capiteq Pty Limited

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

Please select one item
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)

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

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

Please select one item
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)

Please select one item
yes
Ticked some change/s required (please specify below)
no (please specify below)
not applicable
Comments
Part 1 of this clause puts the onus on the pilot in command to determine the suitability of a PED for use by passengers in flight. This is clearly not practicable on commercial aircraft with more than a few seats, and when cabin crew are carried. With the common carriage of PED's this needs to be resolved another way as crew cannot ascertain the safety of the device (with the exception of requiring 'flight mode' to be active). Part 2 of the clause is acceptable.

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
Ticked some change/s required (please specify below)
no (please specify below)
not applicable
Comments
Crew member duties include various legal and company requirements, some of which are not critical, nor a matter of safety. This clause is too broad in the use of 'duties' and should be constrained to not using a PED for non-essential or unrelated activities during critical phases of flight under normal or abnormal operations.

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

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
some change/s required (please specify below)
Ticked no (please specify below)
not applicable
Comments
The proposal does not make it easier to comply nor does it increase our flexibility in the way we approve changes to the MEL.

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
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)

Please select one item
Ticked yes
some change/s required (please specify below)
no (please specify below)
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
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)

Please select one item
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)

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

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
yes
Ticked some change/s required (please specify below)
no (please specify below)
not applicable
Comments
Agree in principle, however it may be impractical for the pilot in command to approve each animal coming on board in larger aircraft and commercial operations. An operator should be able to meet this requirement through internal processes involving ground crew and/or cabin crew. PIC can be advised of the animal and has discretion to not carry an animal (rather than having to give approval for each animal).

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

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

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

Please select one item
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
Instructions by cabin crew
Priority 2
Use of PED by passengers when advised by crew not to use
Priority 3
MEL approvals by CAMO