RAAus Ops Manual

[Admin]

Just curious...If you were in charge of rewriting the RAAus Ops Manual, what parts of it would you like to change if you were given the opportunity?...is there anything at all?

 

 

[turboplanner]

Yes, I'd make sure it referenced all the CASA regulations RAA pilots are required to comply with but never seem to be made aware of.

 

 

[Bill Hamilton]

Yes, I'd make sure it referenced all the CASA regulations RAA pilots are required to comply with but never seem to be made aware of.

Folks,

During training, you are made aware of the existence of the Civil Aviation Act 1988, and Regulations and Order, and all relevant apply, except the ones from which RAA is specifically exempt, and that is in the Ops. manual.

 

And--- they are all on the CASA web site, a big slog to work out what applies ---- but a necessary slog. The AIP is on the Airservices web site.

 

Get yourself an iPad, and an OzRunways subscription, and you will have made a big dent in the above, and almost all you need to carry with you.

 

Cheers,

 

Bill Hamilton

 

 

[Zibi]

First thing I'd change is the text on all the drawing in Rules of the air and Ground marshaling directions (sections 4.04 and 4.05)

 

I appreciate that someone draw all those pictures by hand, but it's really hard to make out whet the text on all those pictures says.

 

Pictures can stay but the text should be redone.

 

 

[shags_j]

Whilst that's all true Bill, wouldn't it be more advantageous for us to have a quick and easy reference to the CASA regs that we are required to abide by?

 

...

 

Meanwhile I will pull out my copy of the handbook and have a read through at what I think is missing:

 

however see my post on the Aviators Model Code of Conduct. There has to be a way to implement something like that in the handbook...

 

 

[turboplanner]

Folks,During training, you are made aware of the existence of the Civil Aviation Act 1988, and Regulations and Order, and all relevant apply, except the ones from which RAA is specifically exempt, and that is in the Ops. manual.

And--- they are all on the CASA web site, a big slog to work out what applies ---- but a necessary slog. The AIP is on the Airservices web site.

 

Get yourself an iPad, and an OzRunways subscription, and you will have made a big dent in the above, and almost all you need to carry with you.

 

Cheers,

 

Bill Hamilton

Well Billy,

 

Para 1 first 15 words

 

You could have fooled me, judging by the dozens of posts on here where people have asked questions, or admitted they were not aware they had to comply.

 

Para 2 Words 2 thru 8

 

And I've made a couple of attempts to read the Bible, but worn my attention span out each time.

 

The regulations could stay on the CASA site, that's not a problem, and I was an early advocate of living documents, but:

 

(a) we need a comprehensive search engine - for example complying with visual flight rules should be searchable by "cloud", "altitude", "distance" etc

 

In trying to answer posts here accurately, I've spent up to four hours looking for something I know, but can't demonstrate in writing.

 

(b) The CASA site needs to show current procedures only, but have a reference back to changes. For example, radio procedures have changed often, and quite subtely at times,

 

which is no problem for the CPL, Instructor, weekly flyer etc., but for the occasional pilot there's no simple way to be sure you are up to date on the latest twist, so we hear all

 

versions from the "Roger" of Biggles to the change made last week.

 

Line 4

 

Agree with the iPad and Ozrunways, but:

 

(a) Relying just on an electronic device is about as risky as putting in the exact amount of fuel for the flight segment of the trip. You are not allowing for Murphy's law,

 

not providing for redundancy. Ask any retailer what they did when the power went out at peak shopping time and see how they coped counting change and providing receipts,

 

checking prices etc.

 

(b) With strict liability hanging over our heads, we have to do more that make a dent in it, and so we should

 

In summary, my experience is that a number, and maybe many RAA pilots are not aware that they are required to comply with anything other than what they've been told during training, ie they are not aware to the CASA regulations.

 

 

[shags_j]

I remember some discussion on Aircraft Geeks about commercial pilots in the US recently being authorised to use electronic flight bags. They also said that CASA was still considering it. Just and FYI

 

 

[Akromaster]

I'd just like it to be written in a way that's easy to understand. Right now, it feels like I need a lawyer to interpret it for me.

 

Ak

 

 

[Admin]

These are great overview thoughts but what about other things like extra privileges etc you would like to see included in the Ops manual?

 

 

[shags_j]

Three letter Ian... C.. T.. A!

 

Just kidding. Can I say one thing. Reading the ops manual is hard frickin work.

 

 

[shags_j]

Also is the ops manual downloadable. I think mine is out of date.

 

Found it: http://old.raa.asn.au/opsmanual/

 

 

[Guest davidh10]

...however see my post on the Aviators Model Code of Conduct. There has to be a way to implement something like that in the handbook...

I looked at the MCC and don't believe a bunch of motherhood statements belong in an Operations Manual that is supposed to be precise and prescriptive. The real rules and regulations are hard enough to comprehend without mixing them up with stuff like the MCC contains.One of the changes I'd like to see in the Ops Manual is the removal of all the repetition. The same set of paragraphs get used over and over and over... While the law is so full of references that it drives us mad, there is a way to use references that is useful and while reading it you can mentally say "ok, the requirement is the same as for XX".

 

Folks,During training, you are made aware of the existence of the Civil Aviation Act 1988, and Regulations and Order, and all relevant apply, except the ones from which RAA is specifically exempt, and that is in the Ops. manual.

And--- they are all on the CASA web site, a big slog to work out what applies ---- but a necessary slog. The AIP is on the Airservices web site.

 

Get yourself an iPad, and an OzRunways subscription, and you will have made a big dent in the above, and almost all you need to carry with you.

 

Cheers,

 

Bill Hamilton

Bill;

While true, how many pilots actually go that next step to read the actual regulations. From my observations it is hard enough to get everyone to make correct radio calls and look at NOTAMS before they fly! I've also observed that there are quire a few forumites who will ask a question that was directly answered by a link in the post to which they responded, so there is evidence of a degree of laziness. It is trying to combat this lack of exploration that makes it desirable to reference the Acts, CAOs etc in the Ops Manual. In this, I have to agree with Turbo.

 

 

[farri]

Yes, I'd make sure it referenced all the CASA regulations RAA pilots are required to comply with but never seem to be made aware of.

Definately a step in the right direction!

 

Frank.

 

 

[Bill Hamilton]

Whilst that's all true Bill, wouldn't it be more advantageous for us to have a quick and easy reference to the CASA regs that we are required to abide by?.

Folks,

 

The bane of AOC operators is the "informal" CASA requirement to not only have references to the Act, Regs., etc in the company "accepted" Operations Manual, but to virtually paraphrase the whole shooting match and repeat it in the Ops. Manual in a form that "pilots" will understand. Of course, the problem here is whether the "paraphrased" version really means the same thing as the actual legislation.

 

Believe me, you don't want that to happen to the RAOz manual, otherwise it will seriously compromise the useable payload of your aircraft.

 

The "rules" are a huge slog, they are not written for you to understand them (unlike most of the rest of the world's aviation law) but, in the words of a former Head of Legal Counsel at CASA: " Aviation law is for lawyer and judges, for the safe conviction of pilots and engineers".

 

Nevertheless, you are struck with them, and you should devote the time and effort to working your way through them, and becoming familiar with what effects your operation ---- there is no easy alternative. In brief, you have to abide by ALL the rules, unless you are exempt, and the RAOz manual give you a good idea of which rules, from which you are exempt. The most important, from which you are not exempt, are the "Rules of the Air" ( to use the old fashioned name) --- the rules of navigation, and these are spread through the Act, Regulations, Orders and the AIP in a most inconvenient fashion, but ignorance, for any reason, is no excuse in law.

 

Australian air law is internationally renowned for being complex, convoluted and contradictory, and a fertile hunting ground for FOIs/AWIs/CASA investigators with attitude, and if you get caught up, for any reason, and don't have deep pockets, you are in real trouble.

 

Many of you will have seen news clips of Campbell Newman at COAG this week, showing over a 1000 pages of legislation, that is the Carbon Tax legislation ---- have I got news for him ---- try the aviation legislation for size, by number of pages or word count, we are the world leader by a large multiple ---- which means we should have the world's best air safety record, doesn't it. Sadly, we are are far from having the best record, so what purpose does much of this ever increasing load of air law have to do with safety --- the inescapable answer is: "Not Much". One example, that, thankfully doesn't apply to RAOz aircraft are the new rules for aircraft maintenance ---- the Australia "rules" to qualify parts and components as not being bogus, is bigger alone, than the whole FAA regulation on aircraft maintenance, FAR Part 43.

 

That nobody really knows what the aviation law really means, results in the law meaning what some CASA functionary thinks it means, and very few people will have the financial means to dispute the many and varied interpretation of the law.

 

This is what is, increasingly, becoming known as "Rule by Law", which is a very different thing to "Rule of Law". You will find some very interesting stuff on the following web site <http://www.ruleoflawaustralia.com.au/Home.aspx>

 

Also well worth a few moments of your time: <http://www.ruleoflawaustralia.com.au/downloads/G0010NoBold.doc>. If this link doesn't work, look up the speech/paper by Robin Speed on 20 Nov. 2009, or cut and paste them into a new tab on your browser.

 

Cheers, (or should that be laments)

 

Bill Hamilton

 

 

[frank marriott]

A big part of the question is the different "opinions" one sees this forum [or a group of pilots anywhere for that matter]

 

If you look at a section and try to reason what the intent of particular legislation is and confirm your understanding with an "informed opinion" I find you will not be far wrong.

 

Trying to find a hole to allow you to do something that was not "intended" is generally where guestionable opinions result.

 

You can argue what is an "informed opinion" but I will not go there as that is a personal opinion of the seeker - I am sure the guist of what I have said is clear enough?

 

FrankM

 

 

[Robert]

Also is the ops manual downloadable. I think mine is out of date.Found it: http://old.raa.asn.au/opsmanual/

It would also be great to be able to download the complete manual as one doc no only in sections

 

 

[Guest davidh10]

Folks,The bane of AOC operators is ...

While I cannot help agreeing; Even CASA provide the "VFR Guide", which is a very useful reference and means of revising or looking up various aspects of the rules. It also contains references to the appropriate piece of legislation, for the same reason you have mentioned about interpretation in AOC manuals. The VFRG is not the law, but is still a useful document. CASA must think so too or they wouldn't publish it. Just a pity it isn't available in hard copy any more.

The reality is that most pilots won't read through the actual law, but only study texts, other's opinions (such as here) and hopefully, the VFRG. So given that tomes of actual legislation fails to make pilots safer, making it easier for them to learn what is required must be a benefit.

 

Nobody reads the road legislation. We all rely on the learners manual in the newsagent bookstand!

 

Perhaps it is a matter of differing objectives. The VFRG is easily understandable and accessible, so has a good chance of being read and understood. Thus it could be said that having it leads to increased safety, whereas, as you have said, the objective of the law is to prosecute.

 

 

[Bill Hamilton]

Nobody reads the road legislation.

 

True, but the road rules are not enforced like the aviation rules, either.Nor are they as complex and extensive.

 

There is not something like 9000 pages of mandatory requirements to "maintain" your private motor car (see GA aircraft)

 

When was the last time you were ticketed for parking, and told to produce your "up to date UBD", your car service log, sprung for having a can of oil with the luggage (dangerous goods) and your license and log book very carefully scrutinised, and your license (certificate) will be in your pocket of course, in your flight bag is not good enough --- and so on.

 

For most pilots, a ramp check can be a rather grueling experience, and depending on the approach of the inspector, it is amazingly easy to accumulate a rather big total, both in $$$ and points terms.

 

Sure, it doesn't happen very often, but when it does, you suddenly realise just how detailed and prescriptive aviation regulation actually is, you really should have enough of a grasp of it to comply with the "Rules of the Air", but also to stay out of compliance trouble.

 

Right now, on another bulletin board, there is a discussion as to how close an aircraft in Class G airspace can fly to a control area boundary, for something that should be clear cut, the interpretations of "the rules" vary very considerably. There is not even agreement amongst those who have a detailed and up to date knowledge of "the rules".

 

Just study guides left over from training are not nearly good enough, for a start, they don't have an amendment service. You really should know about the existence of, and have a good working knowledge of all the rules that apply to you and your operation.

 

When (increasingly, not if) you get ramped, ignorance of the law is not only not an excuse, but another black mark ---- leading to the "not a fit and proper person ----" charge.

 

So what should you carry with you ? Even that is not all that east to answer, but there are a few checklists around, anybody got one to post here?? What should you have on board, if you are ramp checked, as many were at NatFly.

 

Cheers,

 

 

[turboplanner]

I would agree with your last two posts Bill.

 

I'm one who reads, or tries to read ALL the road legislation, because I have to design vehicles which fully comply, but amazingly, after decades of familiarity and study, I still find little amendments and variations in some parts of Australia.

 

The basic problem is that each new Act is usually in addition to what's on the statute books. If politicians were required to delete all the old laws on a subject before introducing new ones, we'd have a more manageable situation.

 

If you give some thought to the quality of politicians judged by the latest escapades of the Speaker of The House of Representatives, you won't be waiting for this to happen.

 

However, even with the volume of legislation we have, it is a very simple matter to come up with a Thesaurus type reference index, and place all the legislation on the one Federal Website.

 

Then we can do a global search which will take us to the subject matter.

 

That still leaves us divided into two groups - those who will spend a little time reading it, and those who want a 30 second answer.

 

The second group you can't help, but the first group is large enough that the majority of pilots will become safer.

 

Under the present system we've had some queries on here where I've been reasonably sure of the answer, but spent up to four hours searching and still haven't found the applicable document/paragraph.

 

 

[frank marriott]

Bill and TB

 

I agree with your statements as such BUT I find the lack of knowledge of SOME newly qualified pilots under the RAA rules leaves a lot to be desired.

 

I have no problem with the layed down content of what is required for an unresticted RAA licence.

 

The problem as I see it is that there is still some schools that are still teaching to the old rules of not above 500ft/5000ft /now 10000ft resulting in a "QUALIFIED pilot" getting into something like an LSA which many outperform the C172 or Warrier type and believing they have the necessary knowledge to operate legally .

 

I do not want to be blasted by the likes of Mots and others like him who I see as teaching to the relevant standards but there is a void in some schools.

 

It is great to to read some posts of students doing their Xcountry endorcement where they have to navigate around restricted areas and CTA obviously doing what is necessary/required.

 

My opinion - the days of drifter/thruster type licnces where the pilot only flys locally have gone [legally]. [Frank before you get upset I am not having a go at drifter pilots - only the knowledge base that SOME have]

 

I have found many RAA pilots that have little or no knowledge of ERCs, flight service areas [i acknowledge the term is out of date but you can get what I mean] .

 

I accept I will get blasted from some on this forum but what I am trying to say is that if a pilot has not been infomed of the various rules it does not make him/her a lesser person but just not aware of the many other rules.

 

FrankM

 

 

[turboplanner]

What leads to what you are on about Frank is the convoluted state of our regulations. Make them simpler and more accessible and instructors will be up to date, students will be up to date, and we all will be a lot safer.

 

 

[frank marriott]

TB

 

No arguement from me - just my observations [right or wrong]

 

FrankM

 

 

[Bill Hamilton]

"BUT I find the lack of knowledge of SOME newly qualified pilots under the RAA rules leaves a lot to be desired."

 

Frank,

 

Not at all surprising, because I have ceased to be surprised at the lack of often quite basic knowledge in interviewing professional pilots for various purposes, either recruitment or audits.

 

When I find an instructor who has never done a full stalling sequence all the way through training, and has never does more than a very tentative approach to the stall, has never done spins and recovery, let alone aerobatics, and transfers his or her fear of more than the most basic maneuvers to the student, is it any wonder we have a standards problem. Look at the handling problems revealed in recent ATSB reports of airline incidents.

 

Our whole approach to the issue in Australia, is the heart of the problem ---- rather than teach an understanding of what the rules are (or should be) for, the conduct of our operations at the least achievable risk, in training the emphasis is on a style of rote learning to pass a style of examination which doesn't really examine knowledge, and after this hoop of fire is left behind, the attitude is very much "I've passed that exam, now I can forget it" ----. and forget it "they" do. One of my favorite general questions is to ask a candidate how they assess VFR conditions --- and I get a recitation of the table in the AIP ---- so I ask the question again in terms of;"OK, that's the numbers, but the question I asked is how do you assess VFR --- how do you apply the numbers??

 

By contrast, in US, Canada or the UK, source material is all plain text, not the underlying regulations, because the form of the regulations and style of instruction is all practical application of the "rules", not being able to effectively regurgitate actual legislation to answer (I'm talking GA here) very trickily worded multi-choice questions. There is nothing wrong with multi-choice questions as such, but what we do here departs a long, long way from the proper application of the educational theory that underpins multi-choice questions as a method of examination. When the "right" ( or least wrong) answer is only differentiated by the punctuation within the question, that is not a fair and reasonable question.

 

That we generally write rules in the negative doesn't help in easy understanding, I have seen many "show cause" letters from CASA that illustrate that CASA people have as much difficulty with the aviation law as she is writ, as the guys in the industry.

 

We started out re-writing the rules in 1996, plain language, written in the positive, have a look at Part 21, contrast it with the bulk of regulation.

 

By 1998, we had drafts of Part 91, General Operating and Flight Rules, which were even shorter than FAA Part 91, plus a whole lot more ---- but it all fell by the wayside, as Minister's and CASA senior management changed ---- we still haven't got a Part 91, but the latest draft is a real problem, just in size alone. And that is not the only problem, compared to the 1998 draft Part 91 that was almost ready for making.

 

I simply don't know if it will ever change in Australia, too many efforts have died along the way. Right now there is huge criticism of of (pick your own number) a 20+ year "regulatory reform program", but it has never been one continuous program, but multiple failed programs, as Ministers change, CASA senior management changes, and the influence of "industry" versus "bureaucracy" wax's and wanes. Most of the industry is pre-occupied just with survival, there is little enthusiasm for the idea of real reform, to catch up with what NZ did years ago, Canada more recently. The old Canadian rules were easy to work with, compared to Australia, the new Canadian rules are even easier, and arguably easier to work with than NZ.

 

Sadly, it is not just aviation that is, in Australia, over burdened with "rules", but what is the general public reaction every time there is some kind of kerfuffle?? --- "They should pass a rule against it" ---- and the pollies oblige.

 

How do we change the Australian psyche that sees more rules as the answer to almost every problem??? If "rules" were the answer, shouldn't we have a rule simply making human factors errors a criminal offence, with mandatory custodial sentences for breaches??

 

After all, ultimately 100% of aircraft accidents are human factors accidents ---- to quote Dan Maurino, long time ICAO safety guru, and co-author, with Professor James Reason, of the most important and influential books on aviation safety yet written.

 

Cheers,

 

 

[frank marriott]

Fair comment

 

 

[M61A1]

"BUT I find the lack of knowledge of SOME newly qualified pilots under the RAA rules leaves a lot to be desired."Frank,

 

Not at all surprising, because I have ceased to be surprised at the lack of often quite basic knowledge in interviewing professional pilots for various purposes, either recruitment or audits.

 

When I find an instructor who has never done a full stalling sequence all the way through training, and has never does more than a very tentative approach to the stall, has never done spins and recovery, let alone aerobatics, and transfers his or her fear of more than the most basic maneuvers to the student, is it any wonder we have a standards problem. Look at the handling problems revealed in recent ATSB reports of airline incidents.

 

Our whole approach to the issue in Australia, is the heart of the problem ---- rather than teach an understanding of what the rules are (or should be) for, the conduct of our operations at the least achievable risk, in training the emphasis is on a style of rote learning to pass a style of examination which doesn't really examine knowledge, and after this hoop of fire is left behind, the attitude is very much "I've passed that exam, now I can forget it" ----. and forget it "they" do. One of my favorite general questions is to ask a candidate how they assess VFR conditions --- and I get a recitation of the table in the AIP ---- so I ask the question again in terms of;"OK, that's the numbers, but the question I asked is how do you assess VFR --- how do you apply the numbers??

 

By contrast, in US, Canada or the UK, source material is all plain text, not the underlying regulations, because the form of the regulations and style of instruction is all practical application of the "rules", not being able to effectively regurgitate actual legislation to answer (I'm talking GA here) very trickily worded multi-choice questions. There is nothing wrong with multi-choice questions as such, but what we do here departs a long, long way from the proper application of the educational theory that underpins multi-choice questions as a method of examination. When the "right" ( or least wrong) answer is only differentiated by the punctuation within the question, that is not a fair and reasonable question.

 

That we generally write rules in the negative doesn't help in easy understanding, I have seen many "show cause" letters from CASA that illustrate that CASA people have as much difficulty with the aviation law as she is writ, as the guys in the industry.

 

We started out re-writing the rules in 1996, plain language, written in the positive, have a look at Part 21, contrast it with the bulk of regulation.

 

By 1998, we had drafts of Part 91, General Operating and Flight Rules, which were even shorter than FAA Part 91, plus a whole lot more ---- but it all fell by the wayside, as Minister's and CASA senior management changed ---- we still haven't got a Part 91, but the latest draft is a real problem, just in size alone. And that is not the only problem, compared to the 1998 draft Part 91 that was almost ready for making.

 

I simply don't know if it will ever change in Australia, too many efforts have died along the way. Right now there is huge criticism of of (pick your own number) a 20+ year "regulatory reform program", but it has never been one continuous program, but multiple failed programs, as Ministers change, CASA senior management changes, and the influence of "industry" versus "bureaucracy" wax's and wanes. Most of the industry is pre-occupied just with survival, there is little enthusiasm for the idea of real reform, to catch up with what NZ did years ago, Canada more recently. The old Canadian rules were easy to work with, compared to Australia, the new Canadian rules are even easier, and arguably easier to work with than NZ.

 

Sadly, it is not just aviation that is, in Australia, over burdened with "rules", but what is the general public reaction every time there is some kind of kerfuffle?? --- "They should pass a rule against it" ---- and the pollies oblige.

 

How do we change the Australian psyche that sees more rules as the answer to almost every problem??? If "rules" were the answer, shouldn't we have a rule simply making human factors errors a criminal offence, with mandatory custodial sentences for breaches??

 

After all, ultimately 100% of aircraft accidents are human factors accidents ---- to quote Dan Maurino, long time ICAO safety guru, and co-author, with Professor James Reason, of the most important and influential books on aviation safety yet written.

 

Cheers,

I would have to agree. I work for a large company maintaining aircraft, and pretty much all of the documented errors are related to not following the "process". Frequently the "process" is convoluted and contradictory, and so when the get a non-conformance, then they go and add yet another process to try and ensure that you carry out all the correct processes. Predictably, the more complex the process, the more errors are made.

I frequently find myself in utter dismay with the nightly "current affairs" type programs that show someone who has got themselves in a world of hurt, then wants legislation passed, then has the presenter asking "are we doing enough to stop this happening", when clearly there is no-one to blame but themselves.