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

Response 620695165

Back to Response listing

Personal information

2. Last name

Last name (Required)
Becker

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

If yes, please specify the name of your organisation
N/A

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
yes
Ticked some change/s required (please specify below)
no (please specify below)
not applicable
Comments
A pilot when they are tired or under the lasting effects of alcohol cannot not accurately judge their "ability to safely perform the duty". When you are tired it's hard to notice you are tired, that is why fatigue is so insidious. It would be better to have a flat rule for example must blow a zero blood alcohol level at any point.

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
yes
Ticked some change/s required (please specify below)
no (please specify below)
not applicable
Comments
How is this going to be enforced? As an example: When I cabin crew asks a passenger to NOT consume their own alcohol and they do it anyway how does that passenger get reprimanded for it?

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
If the PIC doesn't specify when PED's can be used then when can they be used? Just whenever they like until the PIC says otherwise? A rule maybe, PED's may not be used between the boarding gate and the aircraft (enforced now) and then may only be used when the seat belt sign is switched off? This will enable passengers to actually pay attention to the safety demo which is so vitally important.

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
Portable electronic devices I assume are personnel PED's? Maybe iPad's are used DURING flight as EFB's and as devices for payment by passengers during the service of food and drink. So should be specified as a personal PED's shall not be used during flight etc etc.

Equipment

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

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
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)

Please select one item
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)

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
Ticked some change/s required (please specify below)
no (please specify below)
not applicable
Comments
All flights above a certain flight level must be IFR? Pretty impossible to navigate in sight of ground or water at FL275?

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
Ticked yes
some change/s required (please specify below)
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
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
Fatigue for FCM
Priority 2
PED as a distraction