Response 679791910

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Personal information

2. Last name

Last name (Required)
Pilkington

Carriage of documents

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

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
Ticked yes
some change/s required (please specify below)
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)

Please select one item
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)

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
yes
some change/s required (please specify below)
Ticked no (please specify below)
not applicable
Comments
1. Procedures if fuel reaches specified amounts - undue burden for a typical training flight in an aerobatic aircraft "the pilot calculates that any change to the existing clearance to that aerodrome may result in landing with less than the final reserve fuel" - will assume what "any change"might mean so will make that call every time inbound to Moorabbin. 2. Altimeter setting procedures - undue burden for low level aerobatic pilots who generally set the altimeter at zero (or -100 ft) for flight above the aerodrome. 3. Definition of aerobatics does not conform to ICAO and is therefore different from that used by USA FAA (your explanation in CAAP 155-1 is incorrect) and EASA etc. Undue burden on instructors teaching stalls per Part 61 MOS etc. 4. MOS 30.21 anti-collision lights and 30.22 navigation lights - undue burden for day VFR for an aircraft certified to FAR 23 at an earlier date when such lights were only required for operation at night. Some of these types are still in production with nil options for fitment of lights and nil current approval for installation at significant expense. 5. MOS takeoff weight and landing weight - undue burden and safety for aircraft types (still in production) approved to earlier certification standards (even early FAR 23) - specifically the 8KCAB as one example eg no approved data in the flight manual and if there is any data from the manufacturer it requires unsafe speeds (eg approach just above the stall speed, way below 1.3 Vs) and unable to be achieved by a pilot of average piloting skills which only became a requirement at a much later amendment of FAR 23. There is no other data approved for the purpose!

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
Ticked yes (please specify below)
some change/s required (please specify below)
no
not applicable
Comments
You have still not completed Part 61 rectifications and issue of guidance material.

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
definition of aerobatics does not conform to ICAO
Priority 2
anti-collision and navigation lights required for day VFR aircraft certified to earlier FAR 23
Priority 3
takeoff and landing distance requirements for aircraft certified to earlier FAR 23