Response 1038995049

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1. First name

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Patrick

2. Last name

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Bridge

Your feedback on proposal to change initial helicopter pilot licence training requirements (1714FS)

6. Do you support the proposal that allows an applicant to qualify for a CPL(H) with 105 hours of helicopter flight training?

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Yes
No
Please provide comments as to why you answered yes or no.
Flight training should predominantly be competency based. Historically, Australian industry has found that 105 hours to be appropriate for some students to meet the standards required to hold a CPL(H). Helicopter training in Australia is particularly expensive and for some individuals, the additional $30K of training is not warranted.

7. Do you support the proposal to conduct this training in an organisation approved under Part 141 of CASR?

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Yes
No
Please insert comments as to why you answered yes or no.
Regardless of whether the training is provided by a 141 or 142 organisation, the student needs to achieve the required standard which is independently assessed by the flight examiner. Restricting the 100/105 hour course to only 142 organisations would have significant financial implications on 141 companies. Many/most students are unable to complete an integrated course due to the need to work fulltime to fund the training.

8. Basic instrument flight training is an international licensing requirement for the PPL(H) and CPL(H). Do you support the removal of basic instrument flight training from RPL navigation endorsement, the PPL(H) and CPL(H) licensing standards in Part 61?

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Yes
No
Please provide comments as to why you answered yes or no.
I'm an advocate for some instrument flight training for PPL and CPL ratings. The training could be conducted effectively in a FW or using a low cost PC based flight simulator. I acknowledge that IF skills fade quickly and many small helicopters do not have an attitude indicator. Perhaps an analysis of helicopter accident statistics would determine the requirement (versus ICAO compliance).

9. Do you agree with the parameters below for the 105 hour course?

A minimum of 30 hours of flight training must be completed within the final three months of the course.
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Agree
Disagree
No more than two types of helicopter are used in the course.
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Agree
Disagree
At least 20 hours of training must be completed in each type of helicopter used in the course.
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Agree
Disagree
The first 15 hours of training must be completed in the same type of helicopter.
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Agree
Disagree
Please provide comments including any changes you recommend and why.
My answer is based on different types, meaning the old definition of type ie Bell 47 and Bell 206 being different types (noting they are both fall under SEH type rating)

If a student is particularly gifted, they should not be penalised for taking an instructional flight in a 3rd (or 4th) type. I have one student that currently has 15 hours on Bell 47, 10 hours R44 and 5 hours Bell 206. His 1st solo was delayed (to ~25 hour mark) as he has flown 3 different types, but by the time he gets to 105 hours, I believe he will be a more rounded CPL pilot. He will not be presented to the flight examiner unless he meets the standard on his primary type.

I'm not sure of the rational of limiting the types for the first 15 hours of training?

10. Do you agree with the licensing criteria in the proposal for the 105 hour CPL(H) as follows?

At least 105 hours of flight time as pilot of a helicopter.
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Agree
Disagree
At least 40 hours of dual flight time in a helicopter
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Agree
Disagree
At least 35 hours of flight time as pilot in command of a helicopter.
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Agree
Disagree
At least 25 hours of flight time as pilot in command of a helicopter other than cross-country flight time.
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Agree
Disagree
At least 10 hours of cross-country flight time as pilot in command of a helicopter.
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Agree
Disagree
Please provide comments on your response to this question including any changes you recommend and why.
The above seems reasonable, if not a little bit too prescriptive. Where possible, the hours requirement of Part 61.595 (1) and 61.615 (1) should be mirrored.

11. Do you have any final comments about this proposal? Please use the comment box or upload a file submission.

Final comments
No. However, CASA need to review the CPL requirements for Powered-Lift as the present proposal is not achievable by Australian industry without employing ex service personnel from US armed forces with V22 experience.