Response 983409422

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Personal information

2. Last name

Last name (Required)
robinson

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

If yes, please specify the name of your organisation
AOG Services Pty Ltd CAR30 mtc Org airvraft owner and operator

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

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
yes
Ticked some change/s required (please specify below)
no (please specify below)
not applicable
Comments
Wy written consent required.? If the pilot in command so approves the carriage of the firearm then it should be approved. In many instances the ability to approve in writing if at a remote location may nit be possible.

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
some change/s required (please specify below)
Ticked no (please specify below)
not applicable
Comments
How can anyone make an decision about if the person is impaired enough to be a hazard. So being a little bit stoned and being able t operate a plane is Ok but being too stoned isn't??

3. This proposal broadens the requirement for passengers to comply with cabin crew safety instructions. (regulation 91.790 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
yes
some change/s required (please specify below)
Ticked no (please specify below)
not applicable
Comments
No How can a pilot determine the device is a hazard or not. lets face it On most RPT the passengers don't even see the pilot any more, so why make him responsible for it.

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
Whilst it seems reasonable the pilot wont play video games during flight, this is too broad, what if he texts a fiend for a weather update on the destination ahead. and he answers a non related question as well.

Equipment

1. This proposal relaxes oxygen requirements for non-air transport operations. (Division 30.9 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
The requirement for short durations need to be addressed. Eg parachute ops where pilot climbs to FL 15. and then decends in a short time frame, normally less than 10 minutes. The fact the reg is silent on this leaves it open to interpretation by a CASA FOI. This is already proven to be recipe for disaster. The regs need to clear and straight forward.

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
yes
some change/s required (please specify below)
no (please specify below)
Ticked 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
yes
some change/s required (please specify below)
no (please specify below)
Ticked 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
yes
some change/s required (please specify below)
no (please specify below)
Ticked 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
yes
some change/s required (please specify below)
Ticked no (please specify below)
not applicable
Comments
If the pilot makes a honest and unintentional error he has committed an offence. This needs to be changed to intentionally enters and to provide mitigating circumstances, duress , weather etc.

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
some change/s required (please specify below)
Ticked no (please specify below)
not applicable
Comments
Given limited radar coverage in Australia and the incomplete cove age of ADSB pilots need greater flexibility to lower levels to avoid cloud and terrain.

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

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
Ticked 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
yes
Ticked 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?

Comments
Yes But this is probably not the forum for it

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
simplicity of rules
Priority 2
practical usgae in real flight situations
Priority 3
interpretation of the rules by indidual CASA opfficers who often see things diffeently to the pilot or operator