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CASA Consultation Paper (760 kg) Published.


walrus

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CASA have published the paper on the MTOW increase proposal. Generally, people are for it. However the devil may be in the detail in regard to maintenance and medical standards. We will have to wait and see.

 

If I was cynical, I'd be concerned that there is an element of 'divide and rule' in CASA's thinking because the proposal as it stands, disadvantages associations other than RAA. It could perhaps be wondered if the weight increase is a "present' to RAA for swallowing the self management bait.

 

https://consultation.casa.gov.au/regulatory-program/dp-1912ss/results/socondp1912ss.pdf

 

 

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  • 2 weeks later...

SAAA have today published their response to the consultation paper. It is obvious that RAAus has severely pissed off the people at SAAA. They have come up with a well detailed reasoning that RAAus is not trying to improve safety, but only wants to have a monopoly.

 

While RAAus has a lower medical requirement and also a monopoly, with CASA not approving any other body to run sport aviation, SAAA is saying that there will be no safety benefit, but RAAus will get an even greater cash flow. All at the expense of pilots who have had better training.

 

I won't post the response as I am not sure it was intended for non members, but you may be able to find it on the SAAA web site. As usual it is a well thought document, unlike some I have seen from AOPA.

 

 

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Well I went through the document and thought really there is a lot of sour grapes in it coming from the SAAA. They of course do have valid points about competition etc but I really think they are pissed off at not being allowed to gain Part 149...this seems pretty large in the document....I wonder what the submission would be if they were granted Part 149 approval.

 

Of course AOPA and SAAA have the double standards on the medical on the hit list and that is a valid point too. Its a long read the whole document and they repeat themselves many times on the same issues.

 

I think in the end you have to jump through the hoops to comply if you want to be able to fly what you want no matter what class it is.

 

As a matter of full disclosure I am a member of RAA and AOPA and SAAA

 

 

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Double standards is what I see as part of it. Why do I have to have a medical certificate while a mate does not? Exact same aircraft. Surely the aircraft is safe to fly without one, or it is not? RAAus have proven beyond a shadow of a doubt that it is safe, and everyone knows it to be true. (Thanks RAAus members.) Double standards clearly at work. And for what?

 

SAAA participated in many CASA part 149 briefings and at no stage were advised "why are you even here - it won't be available for you." Whether we wanted to go part 149, or not, is a different question that one day would have been put to the membership to decide. Not now, door slammed shut.

 

SAAA member (only).

 

 

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All at the expense of pilots who have had better training.

 

What constitutes "better training"? Consider Dad 'n' Dave learning to fly. 

 

Dad goes the RAAus route and learns to fly in a Foxbat. Dave goes the other way, learning on a C172/PA28. They both go to the same flying school, which trains under both environments. The airport is a metropolitan Secondary. Both only want to fly Day VMC.

 

At the completion of their training, Dad has an RAAus pilot certificate and can fly anywhere in Australia, except in controlled airspace. Dave can do the same, but can enter controlled airspace. Dad can only take one passenger, while Dave, without endorsements to more complex aircraft, can take three passengers.

 

How is Dave a better trained pilot than his Dad?

 

 

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What constitutes "better training"? Consider Dad 'n' Dave learning to fly. 

 

Dad goes the RAAus route and learns to fly in a Foxbat. Dave goes the other way, learning on a C172/PA28. They both go to the same flying school, which trains under both environments. The airport is a metropolitan Secondary. Both only want to fly Day VMC.

 

At the completion of their training, Dad has an RAAus pilot certificate and can fly anywhere in Australia, except in controlled airspace. Dave can do the same, but can enter controlled airspace. Dad can only take one passenger, while Dave, without endorsements to more complex aircraft, can take three passengers.

 

How is Dave a better trained pilot than his Dad?

 

If that is happening CASA need to step in and sort it out.

 

The PPL syllabus is a lot different to the PC syllabus, and so is the training. 

 

 

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There's extra training for the CTA which is not compulsory and  different hours for some sections. Hard to justify ANY difference in standard, Nev

 

Each time we discuss this it's distilled down to one liners and brush offs. It's time each prospective pilot does his/her own research thoroughly based on ALL of the wirtten information, otherwise you might just as wells say "get someone to teach you the controls and forget about the rest" For example flight planning has started to come back in since 2013, but people here are still telling others it doesn't exist any more, so we get fuel exhaustions, and we get people not going directly to NAIPS for weather, with serious consequences.

 

 

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 Why do you quote ME and then write that stuff? You misinterpret all I say..  Most times.  I'm not even going to try to unpick all that.  I've never been an advocate of dumbing down anything. Both groups are trained (or should be) to a standard which must be adequate for their particular operations.  All times quoted are minimums on both syllabus's. I think the RAAus one is a bit optimistic in the nav section but it's still to a standard at the end of the day. Nev

 

 

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  • 2 weeks later...

It will be interesting to see what standard's are adopted if this come to fruition.

 

 https://www.avweb.com/ownership/lsa-weight-limit-increasing-to-3600-pounds-updated/

 

Am I correct in saying that USA has no RAA type organisation, all aircraft are FAA registered? 

 

 

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What constitutes "better training"? Consider Dad 'n' Dave learning to fly. 

 

Dad goes the RAAus route and learns to fly in a Foxbat. Dave goes the other way, learning on a C172/PA28. They both go to the same flying school, which trains under both environments. The airport is a metropolitan Secondary. Both only want to fly Day VMC.

 

At the completion of their training, Dad has an RAAus pilot certificate and can fly anywhere in Australia, except in controlled airspace. Dave can do the same, but can enter controlled airspace. Dad can only take one passenger, while Dave, without endorsements to more complex aircraft, can take three passengers.

 

How is Dave a better trained pilot than his Dad?

 

Because Dave has  more than double the hours, ( if he does it in minimum time and most Dave equivalents on average three times the hours) plus under hood time, way more complex exams so he’s done way more study so a good chance he  knows more, built into his training is  more navigation and law and more human factors to a much larger order of magnitude than Dads.

 

 

then there’s the much debated things he probably doesn’t need but is forced to pay for  -  forced whether he really requires it or not to have had a much complex medical. Had a complex security clearance that Dad probably doesn’t have. 

 

 

but then you are choosing to exemplify a very specific pilot. The scenario you outline is not the scenario that most RAAUS pilots use. They mostly use country or regional training schools outside and away from CTA and don’t get similar training  by virtue of their being at same flying schools that teach both. And of course there is no requirement to and hard to believe they would ( on economic grounds) teach both to the same standard. 

Whereas all GA licences have to include all of the above stuff. 

your example is almost an argument for taking away the RAAus version - better stay quiet in that. 

 

 

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It will be interesting to see what standard's are adopted if this come to fruition.

 

 https://www.avweb.com/ownership/lsa-weight-limit-increasing-to-3600-pounds-updated/

 

Am I correct in saying that USA has no RAA type organisation, all aircraft are FAA registered? 

 

More or less but not quite. 

They do have a category of extremely ultra light weight - part 103?  I forget the weight but it’s something like only a couple of hundred pounds empty weight. That category requires no pilots licence, no registration I think but is pretty heavily restricted - if my memory is correct (and may not be) it’s limited to only a few hundred feet altitude, single seat  only in environs of departure point etc etc. 

 

basically the really old ultralight rag and stick  type stuff. 

 

 

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It will be interesting to see what standard's are adopted if this come to fruition.

 

 https://www.avweb.com/ownership/lsa-weight-limit-increasing-to-3600-pounds-updated/

 

Am I correct in saying that USA has no RAA type organisation, all aircraft are FAA registered? 

 

While I agree it might be interesting there’s No point even bringing up USA standards etc here. It just muddies the water.

 

Sorry It’s a real peeve I have.

 I get so many bright eyed potentials coming to talk to me about getting into experimental Category aviation and they’ve been googling stuff and quote all sorts of US situations  and regs and they have often made plans based upon rules that don’t apply here. 

 

and when I tell them that it’s actually nothing like it here and much more restrictive they get deflated. 

 

 

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Well I went through the document and thought really there is a lot of sour grapes in it coming from the SAAA. They of course do have valid points about competition etc but I really think they are pissed off at not being allowed to gain Part 149...this seems pretty large in the document....I wonder what the submission would be if they were granted Part 149 approval.

 

Of course AOPA and SAAA have the double standards on the medical on the hit list and that is a valid point too. Its a long read the whole document and they repeat themselves many times on the same issues.

 

I think in the end you have to jump through the hoops to comply if you want to be able to fly what you want no matter what class it is.

 

As a matter of full disclosure I am a member of RAA and AOPA and SAAA

 

SAAA didn’t   “not get”  Part 149. 

SAAA actively chose not to pursue it. 

I was one of the many who actively didn’t want it. And the SAAA  wisely took notice of the membership and chose to stay right away from it. 

 

 

You have to understand that Part 149 takes a system that was

 

 “Pilots+their Representative body  - In battle together against - the regulator. “

 

and turns it into 

 

“pilots - in battle against - their Representative and the Regulator together”

 

Part 149 effectively turns RAAUS into a branch of  the regulator with penalties if they are deemed to not be acting as such. 

 

On top of this

 

Part 149 is in large part about training and aircraft Registration,  airworthiness and  maintenance stuff. 

SAAA does not and has no intention of becoming involved in these. These are all directly CASA related things to the SAAA member.

 

 

So Part 149 was, apart from the initial looking at it to see if it suited, never a serious benefit to SAAA or its members. 

 

 

if you remove your mistaken idea of the sour grapes about Part 149 you are left only with. ......  all the valid points about double standards with GA /SAAA pilots being discriminated against so a private company can maintain their monopoly. 

 

 

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I just read the SAAA document again and I think its sour grapes...I would post the relevent text here but not sure if its the right thing to do but page 4 point 5 is a pretty damning statement...we spent 10 years trying to sort this out and now they exclude us...basically it is saying in the document...infact its in the header for point 5

 

 

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 If we don't HANG together we will surely HANG separately. Australian  sport and rec. aviation should always remember this. Nev

 

I don't think anyone's going to be hanging' comments closed in September; whoever commented by then is in the ongoing process. Commenting on their comments is what it is.

 

 

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There was an alternative to RAAus trying to start up several years ago, but CASA keeps putting things in the way of them getting approval.

 

Last time I talked to them if I remember correctly they were considering legal action gains CASA.

 

We could certainly do with some competition forRAAus.

 

 

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I just read the SAAA document again and I think its sour grapes...I would post the relevent text here but not sure if its the right thing to do but page 4 point 5 is a pretty damning statement...we spent 10 years trying to sort this out and now they exclude us...basically it is saying in the document...infact its in the header for point 5

 

Hello Kyle,

 

I will not or say too much -- however go and discover how the Glider Federation was treated after advice was given.

 

You will see "adverse treatments demonstrated" for want of a better descriptive term, remember they acted on advice.

 

KP

 

 

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