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

Response 522184449

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Personal information

2. Last name

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Carter

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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yes
Ticked some change/s required (please specify below)
no (please specify below)
not applicable
Comments
For AOC or Opspec on an International Flight it is required to be certified ICAO Annex 6 Part 1 Chp 6.1.2. Certified ICAO Doc 8335 Chp 4.4. Who can certify the copy. Is this covered in CASR Part 119/121/135?

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
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no (please specify below)
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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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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)

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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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no (please specify below)
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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)
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Equipment

1. This proposal relaxes oxygen requirements for non-air transport operations. (Division 30.9 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 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)
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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)
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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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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 )

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

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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yes
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Comments
CASR 91.200(5) refer to Part 91 MOS. Part 91 MOS Part 4.01 is marked - Reserved. The MOS must support the Regulation if it is mentioned or it is superfluous to the Regulation.

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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no (please specify below)
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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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yes
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Comments
CASR 91.655(e) - Would mean that only aircraft capable of closed port (pressure) refueling would be permitted to conduct hot refueling. This would have an adverse effect on the helicopter and Aerial Application industry as the majority have open port refueling systems. The impact for the HEMS industry, is that most country airfields do not have pressure refueling and precludes drum stock refueling. The cost to upgrade to closed port is expensive and as previously stated precludes country and airfields and drum refueling (used most often in natural disaster). The risk could be reduced to ALARP by the Operations Manual or Exposition stating the maximum quantity that can on board for during hot refueling, which limits the possibility of overflowing the fuel tanks. This proposal is not in line with FAA SAFO 10020. CASR 91.125 does not cover the requirements of ICAO Annex 6 Part 1 Chp 6. Carriage of AOC & Opspec. Is this to be covered in CASR Part 119/121/135? As an Inspector currently conducting SAFA checks in a foreign country this is considered a finding .

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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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
CASR 91.655
Priority 2
CASR 91.125