Response 684224400

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Personal information

2. Last name

Last name (Required)
collins

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
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)

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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)

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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)

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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)

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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)

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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)

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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)

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yes
Ticked some change/s required (please specify below)
no (please specify below)
not applicable
Comments
For private operations it should be up to pilot in command if they wish to execute an approach. They might be able to be visual even if RVR reports look unfavourable. I think this is the current regulation.

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
yes
Ticked some change/s required (please specify below)
no (please specify below)
not applicable
Comments
For Private operations up to the Pilot in command to decide if operations are safe.

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
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)

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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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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)

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yes
Ticked some change/s required (please specify below)
no (please specify below)
not applicable
Comments
Suggest make compulsory altitude 5000 AMSL to give more flexibility.

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
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
yes
Ticked 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?

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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?

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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?

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Ticked yes (please specify below)
some change/s required (please specify below)
no
not applicable
Comments
This is a bit off topic but can you please consider: 1) In the CPL flight test as at 2018 with GPS in aircraft, on tablets and phones can candidates that hold a command instrument rating navigate as they see fit (i.e. if they want they do not need to navigate visually). Note. I cannot remember any recent accidents reported (within the last 10 years) with pilots (In VMC) not finding their destination and thus causing an accident. So therefore candidates with IFR ratings it is really a waste of time having to spend time going back doing visual navigation when after getting the CPL they will most likely never use it again. I cannot think it would make any difference to the safety of any operations after they receive their CPL. 2) Consider single engine aircraft with ballistic parachutes to do IFR charter. With the assumption that it would be a safe as a typical light twin engine aircraft. This would not apply to long over water flights. 3) For proposed changes to medicals where a GP can confirm one is up to the standard to drive a car. The current proposal is to only allow the pilot (say in private ops) to fly VFR. Can this be extended to IFR ops as well. Can not really see any difference as if the pilot became incapacitated then the out come would be the same whether in out of the clouds. As regarding colliding with other aircraft ATC would see if they were (a) not responding to ATC calls (b) deviating from their assigned flight path and would then vector any conflicting aircraft out the way. Even with the current Class 1 and Class 2 medicals it is possible and has happened when IFR Single Pilots have become incapacitated and have never see an accident report where they have collided with another aircraft. However there are plenty of aircraft in air collisions with both pilots with no medical issues.

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
New proposed medical for private ops to allow for IFR
Priority 2
Change CPL test to allow IFR pilots to navigate as they see fit
Priority 3
Allow IFR charter in single engine aircraft with ballistic parachutes