Proposal to change initial helicopter pilot licence training requirements (NPRM 1714FS)

Closed 3 Dec 2017

Opened 20 Nov 2017

Contact

Regulatory Development and Implementation

131 757

regulatoryconsultation@casa.gov.au

Results updated 19 Feb 2018

 

Respondents

CASA received a total of 63 submissions. 31 respondents consented to having their comments published on the CASA website.

Key feedback and summary

The majority of respondents indicated strong support for the proposal to make available an option to qualify for a commercial pilot licence with helicopter category rating with 105 hours training in helicopters. There was also strong support for the proposal to remove the mandatory requirement of basic instrument flying for the grant of the recreational pilot licence navigation endorsement and the helicopter category rating for the private pilot and commercial pilot licences.

The common themes across the feedback were:

  • There were no safety concerns with the 105 hour proposal.
  • The time conducting basic instrument flying is better used for basic flying.
  • The alternative non-integrated 150 hour requirement is a significant cost burden.
  • The requirements for an integrated course of training are excessive.
  • Most helicopters used for training are not equipped for basic instrument flight training.
  • The old standards worked well.
  • A number of safety concerns relating to inexperienced pilots only having basic instrument flying experience.
  • The need to harmonise with international standards is not high since only a small number of pilots fly outside of Australia.

Detail of responses

With regard to the question about allowing an applicant to qualify for a CPL(H) with 105 hours of helicopter flight training, 62 of the 63 respondents supported the proposal.

61 respondents supported the proposal to include the 105 hour course as a Part 141 training activity.

55 respondents supported the proposal to remove of the basic instrument flight training from the RPL navigation endorsement, the PPL(H) and the CPL(H) licensing standards in Part 61.

Proposed course parameters

Regarding the proposed parameters for the course, support was as follows:

  • 60 respondents supported the proposal that a minimum of 30 hours of flight training must be completed within the final 3 months of the course. 1 respondent said the minimum hours to be completed in the last 3 months of the course should be at the discretion of the flight training operator.
  • 56 respondents supported the proposal that no more than 2 types of helicopters are used in the course. 1 respondent said experience flying more types of helicopters is beneficial while another respondent didn't understand the need for the limit.
  • 53 respondents supported the proposal that at least 20 hours of training must be completed in each type of helicopter used in the course. Several respondents rejected this proposal and the proposal limiting the number of types of helicopters used in the training to 2 types, indicating the limits are unnecessary. 1 respondent said completing training in the R22 followed by a conversion to an R44 would be beneficial and it would be unnecessary cost to have to fly 20 hours in the R44.
  • 55 respondents supported the proposal that the first 15 hours of training must be completed in the same type of helicopter.

Minimum aeronautical experience standards

Regarding the proposed minimum aeronautical experience standards an applicant must have to qualify for the CPL(H)

  • 61 respondents supported the proposal of a minimum of 105 hours of flight time as pilot of a helicopter.
  • 62 respondents supported the proposal of a minimum of 40 hours of dual flight time in a helicopter.
  • 49 respondents supported the proposal of a minimum of 35 hours of flight time as pilot in command of a helicopter. The feedback from the 13 respondents who disagreed with the proposal indicated support for reducing the total pilot in command time to between 25 and 30 hours. Some respondents suggested the time could be better spent covering more low flying, and learning additional skills. Several respondents said the time was excessive given the limited scope of flying that students could fly solo. Most respondents said the proposal to require10 hours pilot in command cross-country time was appropriate.
  • 51 respondents supported the proposal of a minimum of 25 hours of flight time as pilot in command of a helicopter other than cross-country flight time. The comments from the respondents that disagreed with the proposal were consistent with those made against the 35 hour proposal in paragraph (c).
  • 61 respondents supported the proposal of a minimum of 10 hours of cross-country flight time as pilot in command of a helicopter. One respondent said 10 hours was excessive and another respondent said the hours should not be prescribed and competency should be the standard.

Future direction

Overall, respondents have strongly supported the proposals. As a result, CASA will now undertake to implement changes to the licensing regulations that reflect the proposals. An amendment is required to Part 61 of CASR before 31 August 2018 when the transition regulations end. A stopgap measure would be to make legislative instruments that would give effect to the proposals.

Published responses

View submitted responses where consent has been given to publish the response.

Overview

Changes to the helicopter flight crew licensing regulations in Part 61 of the Civil Aviation Safety Regulations 1998 (CASR) are being proposed.

These changes include:

  • adding a 105 hour training course option for the commercial pilot licence with helicopter category rating – CPL(H),
  • this course would be conducted by an organisation with an approval under Part 141 of the CASR, and
  • removing the mandatory requirement for basic instrument flight training for the grant of the following:
    • recreational navigation endorsement
    • private pilot licence with helicopter category rating
    • commercial pilot licence with helicopter category rating.

The proposal has been developed following ongoing consultations between the Australian Helicopter Industry Association, helicopter flight training operators and CASA. Transition regulations which are consistent with this proposal, have been in place since the commencement of the flight crew licensing regulations in September 2014. The transition provisions continue until 31 August 2018.

Consequences of implementing the proposals

The proposal would allow continuation of practices which have been successfully employed by the Australian helicopter training industry. Implementing the changes would be relatively straightforward, as existing courses of training and licensing processes which are based on the old regulations, reflect what is being proposed. The proposal would need to be incorporated into Part 61 of CASR prior to expiry of the transitional provisions on 31 August 2018.

If accepted, the proposal would remove doubt over the continued use of the 105 hour CPL(H) course and the requirement for basic instrument flight training. This would help support and encourage operators to complete their Part 141 transition.

Details on the how the proposal would be implemented, such as managing changes to Operations Manuals, if required, will be provided once the proposal has been settled.

CASA is working with the helicopter flight training sector to provide a sample CPL(H) 105 hour course of training, that operators would be able to use once incorporated into their Operations Manual. An assessment of the course would not be required if it is implemented without amendment.

CPL(H) licences granted on the basis of the proposed standards would be issued with a note identifying its non-compliance with ICAO Annex 1 standards. This is no different from the current situation where licences are granted under the old licensing standards (according to the transition rules).

As is the case for licences issued under former Part 5 of CAR; pilots with non-compliant licences require the approval of a foreign State to operate an Australian aircraft in that State. In addition, a foreign State may impose additional training and testing requirements for conversion and might not validate the licence. These conditions also applied under the licensing system under Part 5 of the CAR Part 5.

The option of integrated training under Part 142 of CASR or a 150 hour course under Part 141 of CASR to achieve an ICAO Annex 1 compliant licence would remain available.

Why your views matter

 

CASA recognises the valuable contribution that community and industry consultation makes to the regulatory development process. This policy proposal  asks you to consider a range of proposed changes to initial helicopter pilot licence training requirements.

A copy of the proposal is provided below. You can read it on this screen using the scroll bar, or save it to your computer using the popup options.

Please read the document before providing your feedback in the online survey.

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What happens next

At the end of the response period for public comment, we will review each comment and submission received through the online response form. We will make all submissions publicly available on the CASA website unless a respondent requests that their submission remain confidential. Information about how we consult and how to make a confidential submission is available on the CASA website.

Audiences

  • Flight training operators

Interests

  • Licensing