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

The time (hours) has no bearing on the competence of an individual candidate. The discussion to increase the course to become ICAO compliant(1) and of combating CFIT due inadvertent? IMC flying(2) of a VFR pilot is not beneficial. (1)An industry of upcoming Australian pilots should not have to suffer exhaustive costs to have a license recognised in another country if they never intend to go there to fly (this represents approximately 93% of my current students of over 55 students active) (2) teaching someone basic instruments skills in my opinion would supply a higher risk to the HF and decision making process about flying into weather or into night. More time and effort has to be placed on the decision to fly, plan and maintain VMC/light in all stages of VFR piloting and the risks involve with pushing through these legal requirement. I also think the high costs to upgrade aircraft and the ability for some candidates to become competent in basic instrument is detrimental and will crush the viability of helicopter flight training in Australia. FAA schools pay very JNR flight instructors wages based on hours they fly only! no fly no pay! 3 days of weather, no pay. Our employment laws support our employees by having set minimum wages and support stability in a job. With the heavier costs in the flight training sector it will be very difficult to maintain permanent jobs as student candidates will be discouraged by the increased costs. The integrated course is also an unviable option as most candidates work during training to maintain cash flow to support them during training. I currently have 0 students out of 55 that have capacity to fly fulltime for x months to obtain a license under an integrated syllabus.

Becuase I am the holder of a 141 and currently have a course approved under the old CAR 5 which is succesfully training the majority of my candidates. Candidtaes follow the same syllabus however we still have to find a common standard from the MOS. Some progress quicker then others however the course is still based on a minimum 105 hours. 105 hours to complete the license is not common but does happen and competent students should be rewarded for adapting higher levels of skill,airmanship and general cometence.

see above

As per CAR 5 requiremnts that should not have changed and is a logical sysetm to work with which provides less disruption and more continuity in training on types.

I think the general solo flight time is too high and provisions for more dual consolidation is more benificial. The differnce between somone having 15 hours general handling solo and 25 hours does and will not make a more cometent pilot at the student level.

1/3 of a 105 course is dedicated to solo flight this is too much in my opinion and provisions to reduce this to 1/4 is beneficial. Dual consolidation is often squeezed into the latter portions of a license to finess a student pre-test some might.Often financial prssures dont allow for time above the 105 and hence a softer skilled candidate is put up for testing with the "give it a crack you might get lucky" attitude! (I have seen this in recent times as a flight examiner) More consolidation dual embedded throughout would solidfy the core handling skills to a greater competency then solo consolidation.

I think although CASA has gone through the paces to streamline our sector to match that of other nations the 105 hour course work for our Australian industry. Saftey is not compromised by having a 105 hour course because standards still have to be met. The viability of a flight school is compromised and the implementation of a greater course would crush the Australian training industry and we would lose those potential candidates to cheaper FAA based trainings schools abroad.