Response 968872238

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Personal information

2. Last name

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Gregory

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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yes
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no (please specify below)
not applicable
Comments
If they are the international standards then they are what they are. Hardly something to consult on..

2. This proposal explicitly permits the carriage of documents electronically. (regulation 91.113 of CASR)

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yes
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Comments
Duplication of law. The electronic records act covers this. Stop replicating, not yr job and adding to load.

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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yes
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Comments
I have nooo idea. Your document contains references to another document which references another. Too wordy and beaurocratic, worse than reading about a reasonable person in an insurance policy. So who CAN carry firearms without approval? Police? Station owners? I am none the wise after reading that novel.

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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yes
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Comments
Your rule does not ensure anything. It provides a vehicle to slap someone over the knuckles with. A person commits an offence if they likely to become unfit? How the hell are you to determine that you will become unwell.

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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yes
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Comments
Hard to link an extra person to safety. How does this enhance safety?

3. This proposal broadens the requirement for passengers to comply with cabin crew safety instructions. (regulation 91.790 of CASR)

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yes
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Comments
Again, it does squat to enhance safety. It’s a vehicle to persecute if someone doesn’t do what they’re told. Just call them a delegate of the PIC instead of making some words seemingly linking to the safety banner.

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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yes
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Comments
You’re holding the pic responsible if joe blogs turns on. a phone down the back? I though studies were clear that they did not interfere with equipment. If this is the case, just make it pilots discretion, get rid of the ‘fault lies’ Redacted text. Gees guys, is that all you think about? Finger pointing? You’re not enhancing anything by taking this approach.

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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yes
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Comments
Cmon. Serious? You want a rule for this? If someone isn’t paying attention when they should be there’s enough to kick them with already.

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
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no (please specify below)
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Comments
Still very beaurocratic to read. I can’t comment on international standards, I can get the intent, not required for sky divers.

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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yes
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Comments
Why does it take you a page to write what can be said in two lines? Scrap the lot and put your aim in as law.

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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yes
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Comments
I have no idea. I would have to wade through it all a couple of times to see if it would make it simpler.. It’s not simpler to read.

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
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Comments
By all means advise the PIC that electronics show it to be below minima but do not take that decision from us. If you think we’re busting minima there’s other vehicles you can use. Stop writing bloody rules for everything you can think of. Cmon guys, move forward don’t bog down.

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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yes
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Comments
Hard to see anything as ‘reducing red tape’ when it starts off with ‘PIC contravenes when’.... Lost me before you even had me. What’s the Aim if CASA again?

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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yes
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Comments
Why is it that your default is ‘must not’ unless some conditions are met... I’d like to see CASAs default as ‘can’!!! How about ‘PIC can do this prividing....’. Might improve your brand by changing your approach to the industry that is the reason for your existence.

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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yes
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no (please specify below)
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Comments
Make it read the same as IFR. Why not if RNP2 just leave it at 5nm bubble. Again you start with ‘must not’ stance.

3. This proposal introduces a requirement to comply with Air Defence Identification Zones (ADIZ) procedures. (regulation 91.362 of CASR)

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yes
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Comments
I thought it was pretty clear already. A policy is not going to change behaviour if that’s what has triggered this change.

4. This proposal creates a requirement to comply with aircraft interception procedures. (section 20.05 of the Part 91 MOS)

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yes
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Comments
Again, it was pretty damn clear. Let me guess, something happened a couple of times lately and you think a rule rewrite will stop the trend? Would love to know the drivers of particular changes.

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
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Comments
Cmon. Ditch this one entirely. Go back to allowing a B050 cruising lvl.

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
This is your version of significantly simplifying it? No way should an assistance dog be refused access. What does the guide dog association have to say about this? Have you sought their expert views on animal behaviour? Poor, again, what has driven this change has not been revealed.

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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yes
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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
Majority aren’t even needed in my view. You’ve provided no drivers for these changes and what you’ve proposed has only faint links to the aims you’ve stated. Changes to laws will only get you compliance while you are after. After all of this time and name changes I can’t believe you only have a hammer and you see everything as a nail. Perhaps the question is ‘What’s in it for you to continue this behaviour?’

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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yes
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Comments
Consolidate? God no. You still have to turn your mind side ways to read it and attempt to assimilate it to see the application of it.

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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no
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Comments
Safety risks will not be addressed by regulation! It will however, provided a framework to slap someone with. Time to move forward guys. Get some behavioural people on board to replace your legal and policy based minds.

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
CASAs approach to ‘consultations’
Priority 2
Stance is ‘prohibited’ unless conditions are met
Priority 3
What were drivers behind this? You’re saying trust us, these are the issues? The safety committee sure as hell doesn’t represent me, I’ve never heard of anyone other than Virgin and Qantas.