Response 441332243

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Personal information

2. Last name

Last name (Required)
Ewart

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

If yes, please specify the name of your organisation
Honourable company of Air Pilots Australian Region

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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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)

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Ticked yes
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no (please specify below)
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Comments
I commend CASA for introducing this regulation in recognition of the fast moving electronic flight bag landscape.

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
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no (please specify below)
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Comments
Once again I commend CASA from removing the prescription and authorizing the responsibility of the Pilot in Command to be sufficient.

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
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Comments
Finally a recognition that there is a broader definition required and that the issue of fitness for flight should be the only consideration.

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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Ticked yes
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Comments
A sensible interpretation of rules that have been more than adequate in other jurisdictions.

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
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Comments
Absolute clarity in regulation is vital in this area and the wording here addresses that concern very well.

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)
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Comments
With this area moving so fast some flexibility is absolutely required and by including the absolute discretion of the pilot in command and this very well written.

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
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Comments
The prescription previously applied in previous regulation was potentially in conflict with the use of such devices as EFBs this addresses that by once again being pragmatic around where and what these devices should be used.

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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Comments
Again the removal of prescription I assume through an analysis of risk profile is to be commended as the previous iterations made strict compliance almost impossible for some operations.

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
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Comments
Absolute clarity and consolidation of disparate rules makes this a very sensible rule.

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
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Comments
Once again a simplification of disparate rules very well received.

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
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Comments
Absolutely this is one of the most encouraging rules yet. This brings Australia into line with overseas best practice and is very well received.

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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Comments
This is as it should be along the lines of the AR type approvals exemptions should be necessary in this day and age and they should be approvals for certain operations subject to specific conditions being met.

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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Ticked yes
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Comments
Though I have no experience in this area it would appear to meet the intent.

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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Comments
Absolutely support this it goes some way to standardizing both compliance processes and training requirements. Given that in the majority of cases a NVFR operation will upgrade to an IFR from an individual perspective it will make transition to such much more seamless. The application of such a rule should improve flexibility subject to the provisions of this rule.

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
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Comments
Tying this into a single interpretation makes it absolutely clear of the intent.

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
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Comments
Makes this clear.

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
Alignment with ICAO is a very good thing and also improves the understanding of the requirements.

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
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Comments
Simplifying this part of the regulations should reduce the administrative burden on both CASA and industry.

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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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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Comments
This is a great step forward and should provide a benchmark for all future regulation reform. The rules are both pragmatic and easy to read which should make compliance much simpler for industry.

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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Comments
A single source of all such rules is a fantastic outcome and indicates real regulation reform.

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)
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Ticked no
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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
Approach bans a great step forward that will only enhance safety.
Priority 2
A single point reference for all such matters in easy to read format
Priority 3
PED policy and flexibility that reflects the reality of this technology