Aerial Work

[facthunter]

At this time I would think it would be a negative. Our branch of aviation does not need to be complex as simplicity is safer. SAAA make jets (as an example) but the general aviation sector take care of the training. THEY (SAAA) want to do training. That will be costly but they have a point. That is, who out there in GA would have the expertise to train people on SOME of their (SAAA) aircraft. There has to be exemptions in this area. eg. Not all endorsements have to be done by commercial pilots. Nev

 

 

[aro]

I'm not convinced that CAR 206 defines private operations at all.

 

CAR 206 defines Commercial Purposes "For the purposes of subsection 27(9) of the Act". Subsection 27(9) deals with the purposes for which an AOC is required - not the requirement for a commercial license.

 

CAR 5.78 defines what a Private Pilot License allows you to do "to fly an aeroplane as pilot in command, or as co-pilot, while the aeroplane is engaged in a private operation" with the note:

 

"Paragraph (d) of subregulation 2(7) sets out the operations that are classed as private operations."

 

It appears to me that paragraph (d) of CAR subregulation 2(7) defines private operations, not CAR 206.

 

The assumption that private operations are operations that are not commercial seems incorrect. CAR 206 lists:

 

(ii) aerial spotting;

 

(iii) agricultural operations;

 

(iv) aerial photography;

 

as commercial operations.

 

Subregulation 2(7) paragraph (d) lists

 

(ii) aerial spotting where no remuneration is received by the pilot or the owner of the aircraft or by any person or organisation on whose behalf the spotting is conducted;

 

(iii) agricultural operations on land owned and occupied by the owner of the aircraft;

 

(iv) aerial photography where no remuneration is received by the pilot or the owner of the aircraft or by any person or organisation on whose behalf the photography is conducted;

 

as private operations.

 

This seems to say that e.g. agricultural operations on land owned and occupied by the owner of the aircraft are commercial operations that require an AOC, but can be performed with a private pilots license. It seems clear that an operation can be both commercial and private.

 

Subregulation 2(7) paragraph (d) also lists

 

(i) the personal transportation of the owner of the aircraft;

 

as a private operation, which seems to mean that transportation of the owner of the aircraft is definitely a private operation. There doesn't seem to be any restriction on what the owner does at the destination, except that CAR 206 says that carriage of goods property of the pilot, the owner or the hirer of the aircraft for the purposes of trade requires an AOC.

 

I don't know the definition of "goods for the purposes of trade", but it seems that it must be goods for sale, not just tools of trade. If CAR 206 includes tools of trade it would seem, for example, that a commercial pilot was forbidden from carrying a pilot's tools of trade without an AOC. Or if you assume a pilot is somehow exempt, what about a salesman carrying a mobile phone on a flying holiday? How far do you extend tools of trade? Do I need an AOC to check work email at my destination, if I carried my smartphone with me?

 

Whether this is how CASA interprets these regulations I don't know, but that is how I read them. Ultimately, it is CASA's interpretation that matters, until you are prepared to pay a lawyer to go to court and challenge them.

 

 

[aro]

Addendum: On the topic of the original question, if we want to be able to fly recreationally, and we think that our recreational flying should be less strictly regulated than commercial flying then I don't think it is desirable to allow commercial operations in RAA. If we allow commercial operations, it seems that regulation of RAA must be stricter than if only private operations are allowed.

 

 

[Dafydd Llewellyn]

From what I understand - and I don't claim to be any sort of guru here - if you use your RAA-reg. aircraft just to GO to a job, even if you don't carry so much as a Swiss Army knife - you have used it for a 'commercial purpose'. Presumably, coming home isn't a 'commercial purpose' - unless, perhaps, you return to your home airfield and then also do a paying job before actually going home.This is where it all gets silly, I feel. I want to be able, in the future when it's back in the air, to be able to do trips in my wee, simple, cheap but capable Jab. that have, in some small way, a 'commercial purpose'. I don't want to be a commercial gun for hire, and despite CASA's apparent interpretation that because there is a 'commercial purpose' for my flight I might be inclined to become a task-driven homicidal/suicidal maniac, I'm not going to breach any condition of the operational limits to do any such flights.

 

I also don't want to suddenly find out that my insurance cover is void because I have used the aircraft for a purpose other than 'recreational' aviation, as defined and limited.

 

So - the upshot of all of that is: if I want to be able to do the odd 'commercial' flight, such as delivering a part I have manufactured to a customer and installing it in her/his aircraft, even if it's just a damn cup-holder weighing 50 grammes that needs to be screwed to the door and signed off by an L2, I may have to consider putting the old girl back in VH-reg and taking out at the least an RPL I'm damned if I can see what qualitative difference there will be to my, or the general public's, safety resulting from that change - but I'd have to amortise the extra costs of operating a VH-reg aircraft vs. a self-maintained RAA-reg aircraft on the cost of that cup-holder. And the cup-holder will be almost certainly be screwed into an RAA aircraft identical in almost every respect to my own but with a different set of letters/numbers on it.

 

Al Capone was jailed for tax evasion. A prostitute can claim 'expenses' as long as she/he is determined to have properly declared all income and properly have claimed allowable 'expenses'. What the ATO decides is allowable has NO reflection on the legality of the source of the income / expenses - as long as they're justified by the ATO rules. An ATO decision on your income/outgo bottom-line position has NO relevance on a CASA decision on a breach/non breach of the safety regulations for which they are responsible. You can fly Jack the Ripper to and fro - as long as you do it within the rules.

No, CAR 206 defines what constitutes commercial operations. Therefore, if it isn't in CAR 206, it ain't a commercial operation. I used my Cherokee 140, on a PPL, to regularly fly between Sydney and Tamworth, for the purpose of oversighting the work East-West airlines were doing on the CSIRO F-27, VH-CAT, for which I was responsible. That usage is plainly for "going to the job" but it was not a defined commercial purpose. My employer did not pay for my usage of my own aircraft, so I was not earning money from the use of the aircraft per se. Yes, I claimed that flying against my tax - and never had a query. I don't think either CAR 206 or that aspect of the Tax laws has changed noticably since those days.

 

 

[Dafydd Llewellyn]

I'm not convinced that CAR 206 defines private operations at all.CAR 206 defines Commercial Purposes "For the purposes of subsection 27(9) of the Act". Subsection 27(9) deals with the purposes for which an AOC is required - not the requirement for a commercial license.

CAR 5.78 defines what a Private Pilot License allows you to do "to fly an aeroplane as pilot in command, or as co-pilot, while the aeroplane is engaged in a private operation" with the note:

 

"Paragraph (d) of subregulation 2(7) sets out the operations that are classed as private operations."

 

It appears to me that paragraph (d) of CAR subregulation 2(7) defines private operations, not CAR 206.

 

The assumption that private operations are operations that are not commercial seems incorrect. CAR 206 lists:

 

(ii) aerial spotting;

 

(iii) agricultural operations;

 

(iv) aerial photography;

 

as commercial operations.

 

Subregulation 2(7) paragraph (d) lists

 

(ii) aerial spotting where no remuneration is received by the pilot or the owner of the aircraft or by any person or organisation on whose behalf the spotting is conducted;

 

(iii) agricultural operations on land owned and occupied by the owner of the aircraft;

 

(iv) aerial photography where no remuneration is received by the pilot or the owner of the aircraft or by any person or organisation on whose behalf the photography is conducted;

 

as private operations.

 

This seems to say that e.g. agricultural operations on land owned and occupied by the owner of the aircraft are commercial operations that require an AOC, but can be performed with a private pilots license. It seems clear that an operation can be both commercial and private.

 

Subregulation 2(7) paragraph (d) also lists

 

(i) the personal transportation of the owner of the aircraft;

 

as a private operation, which seems to mean that transportation of the owner of the aircraft is definitely a private operation. There doesn't seem to be any restriction on what the owner does at the destination, except that CAR 206 says that carriage of goods property of the pilot, the owner or the hirer of the aircraft for the purposes of trade requires an AOC.

 

I don't know the definition of "goods for the purposes of trade", but it seems that it must be goods for sale, not just tools of trade. If CAR 206 includes tools of trade it would seem, for example, that a commercial pilot was forbidden from carrying a pilot's tools of trade without an AOC. Or if you assume a pilot is somehow exempt, what about a salesman carrying a mobile phone on a flying holiday? How far do you extend tools of trade? Do I need an AOC to check work email at my destination, if I carried my smartphone with me?

 

Whether this is how CASA interprets these regulations I don't know, but that is how I read them. Ultimately, it is CASA's interpretation that matters, until you are prepared to pay a lawyer to go to court and challenge them.

I think you are correct. There's a difference in the wording between CAR 206(i)(viii) and the later definition given in the reference in Oscar's initial post, which suggests they have softened their interpretation to allow tools of trade - but that may be yet to be tested in court.

 

 

[AVOCET]

It's beginning to sound to me that these laws were written by a bunch of Pharisees ,& to keep themselves employed by arguing the interpretation thereof ,

 

If there not clear enough for the average pilot to understand ( for which they were ultimately written ) after 17 years of flying I've probably got enough black marks to put me away for life ! But I really don't think they care that much .

 

I remember when the amateur home built rules came out , I really think they where penned to stop joe blow from setting up shop and building lots of kits to flog to the general public , it didn't stop some people from offering builder assistance to folk and that in general was a good thing and that stopped a lot of crap examples from getting into the air ,or being totally rejected buy the inspection process ,

 

And after all ,the AUF was keen to get as many aircraft flying to boost their numbers ,

 

I think it worked out well .

 

I guess my point might be that some of these rules are their to stop some people from taking it to far , like trying to set up for example , starting a fleet of U/L freight planes ect . But really folk going about their own buisiness & minding their own buissines ,don't really show up on their radar all that much , and the odd ramp check is casa's way of reminding us all ,who's in charge , and that ,when all's said and done:, as the saying goes , there's more said than done!

 

Mike.

 

 

[Oscar]

Our branch of aviation does not need to be complex as simplicity is safer.

I'm sorry, but that is in itself an overly simplistic statement. A piece of stick on a bolt that drags on the road is simpler than an ABS braking system. Which system would you want to know is on a vehicle that collects your 16-year old to go to a party on a wet night down a lousy, but 100 kph limited, road driven by a friend who has just gained her/his licence?

 

What simple IS - is easier to administer, of less cost, more readily maintainable etc.

 

The offset is - to maintain an equitable level of safety, the operational regime becomes limited to the capability of the equipment. If you fly in a plastic chair attached by wires to a Hills Hoist with half an acre of fabric that can only flutter to earth with the maximum possible impact of a butterfly farting - then you don't need the protection of an impact-absorbing seat. If you want to cruise at 120 kts, the potential landing impact at VSo might well break your spine if you get it a bit wrong, in that same simple seat.

 

The laws of physics aren't influenced by matters of simplicity or complexity. A billycart is simple - but it you hit a brick wall at 40 kph in a billycart, you are NOT safer than if you hit that brick wall in a car with seat-belts, crumple-zones and airbags.

 

Simple IS safe - if the parameters of operation of 'simple' are kept to what is 'safe' relevant to that level of simplicity. 95.10 aircraft are simple; 24-reg aircaft are not. What capability you want, rather dictates the level of 'simplicity' that will deliver a roughly equivalent level of safety. I think the question may well be: what level of capability do we want RAA aircraft to have? At the upper end, RAA-registered aircraft offer a very decent level of capability. That is now far removed from the days of aircraft when the AUF was created.

 

Should RAA go back to a 'simpler' regime? - it's an option.

 

 

[aro]

I think you are correct. There's a difference in the wording between CAR 206(i)(viii) and the later definition given in the reference in Oscar's initial post, which suggests they have softened their interpretation to allow tools of trade - but that may be yet to be tested in court.

I don't think CAR 206 was ever intended to include tools of trade. If it does, the qualification "being the property of the pilot, the owner or the hirer of the aircraft" seems bizarre, because it means taking borrowed tools is OK, but not your own.

 

It seems more logical to interpret the intended meaning to be you can't e.g. use your aircraft to import crays from King Island for sale without an AOC. The qualification is still a bit odd however, because it seems to mean that you can't take something to someone and sell it to them, but you can deliver it after they have purchased it and ownership has transferred to them - it is no longer "property of the pilot, the owner or the hirer of the aircraft".

 

 

[frank marriott]

This argument has been around for many years, only is was PPL V CPL , AUF was never mentioned.

 

Make up your own mind what the reg states, and if you are familiar with reading law then don't miss para (ix) - It gives the definition a pretty wide scope.

 

Test it if you think you can beat it by all means, personally whilst using the privileges of an RAA certificate I will not be going anywhere near it.

 

P.S. I have other licences quals but whilst operating my RAA registered aircraft on a RAA certificate then my legal rights are the same as anyone else (save CTA access and even that is limited to the particular aircraft / configuration)

 

To change the definition is a CASA thing, not RAA - just my opinion but opinions were asked for, even if they are not supportive of what is being suggested.

 

 

[Oscar]

The qualification is still a bit odd however, because it seems to mean that you can't take something to someone and sell it to them, but you can deliver it after they have purchased it and ownership has transferred to them - it is no longer "property of the pilot, the owner or the hirer of the aircraft".

I suspect you'd need a Court ruling on whether 'delivering' in that case was a part of the commercial transaction, or just a gratuitous act on your part because you happened to be flying past and dropped in on by... Every way you look at it it gets more and more convoluted, and the answer appears to be either: 'never do anything with your aircraft that has a commercial implication', OR get the 'commercial' use parameters defined and abide by them. The first path is the simpler and more easily achieved, I completely accept. That appears so far to be the will of members, and if a majority consensus, then the RAA Board should concentrate on achieving that objective.

 

However, I really, really suggest that members consider the adage 'be careful what you wish for, lest you get it.' The simple life will have a cost, just as the more complex one does. How much do you want to be able to do vs. how much complication are you prepared to tolerate?

 

And, as an aside: is there a way forward that is more sophisticated than just one size fits all?

 

 

[Downunder]

I'm all FOR restricted commercial ops.

 

"24" reg only.

 

Not over built up areas.

 

Not for transporting passengers, meaning having an observer or someone helping with the task is OK. Not paying to go from A to B.

 

The owner of the aircraft going some where for their work is fine. Taking someone else for their work is not.

 

I called up the Agricultural Dept a few years ago to ask about dog baiting. They contracted a company with a twin engine A/C based at a regional centre.

 

Surely a RAA aircraft could do the same thing. Be based on remote strips in the work area with ground support and be far more cost effective?

 

Each bait needs to be recorded and logged with a GPS. A lower and slower RAA aircraft could deliver far more accurately and at lower costs meaning more baits on the ground.

 

Shark/beach patrols in RAA aircraft? Why not. Govt currently contracting choppers to do the job at $$$ per hour.

 

Feral animal culling? Again Low and slow wins. All at a reasonably cheap costs.

 

All of this gives some justification to the RAA movement. To be seen as contributing to society is a good thing for everyone.

 

 

[aro]

This argument has been around for many years, only is was PPL V CPL , AUF was never mentioned.Make up your own mind what the reg states, and if you are familiar with reading law then don't miss para (ix) - It gives the definition a pretty wide scope.

 

Test it if you think you can beat it by all means, personally whilst using the privileges of an RAA certificate I will not be going anywhere near it.

On the face of it, PPL vs CPL doesn't seem to refer to CAR 206. PPL vs CPL refers to CAR 2(7)(d) which defines private operations. CAR 2(7)(d) also has a clause "(viii) any other activity of a kind substantially similar to any of those specified in subparagraphs (i) to (vi) (inclusive);" (are private operations) which seems to be as wide a scope as your para (ix).

 

However activities included in CAR 2(7)(d) also seem to be defined as commercial in CAR 206 therefore requiring an AOC. I'm not sure how RAA interact with AOCs - presumably there is an exemption from CAR 206 somewhere (or perhaps CAA 27(2) specifying the requirement for an AOC) at least for flying training purposes.

 

Also, I don't know how private operations included in CAR 206 e.g. certain agricultural operations work in relation to AOCs. I suspect someone must have an AOC, but the pilot isn't required to have a CPL. There may not be anything similar in RAA, which might effectively prohibit operations included in CAR 206 in a roundabout way. However, I have heard of ultralights being used for agricultural work, so perhaps it is possible if someone has an AOC...

 

 

[Aerochute Kev]

I'm all FOR restricted commercial ops."24" reg only.

Not over built up areas.

 

Not for transporting passengers, meaning having an observer or someone helping with the task is OK. Not paying to go from A to B.

 

The owner of the aircraft going some where for their work is fine. Taking someone else for their work is not.

 

I called up the Agricultural Dept a few years ago to ask about dog baiting. They contracted a company with a twin engine A/C based at a regional centre.

 

Surely a RAA aircraft could do the same thing. Be based on remote strips in the work area with ground support and be far more cost effective?

 

Each bait needs to be recorded and logged with a GPS. A lower and slower RAA aircraft could deliver far more accurately and at lower costs meaning more baits on the ground.

 

Shark/beach patrols in RAA aircraft? Why not. Govt currently contracting choppers to do the job at $$$ per hour.

 

Feral animal culling? Again Low and slow wins. All at a reasonably cheap costs.

 

All of this gives some justification to the RAA movement. To be seen as contributing to society is a good thing for everyone.

Did some aerial baiting a few years ago with WA Ag Dept. Have to be licensed to handle the baits and as with most Gov't depts, staff only allowed to fly in twins, for safety reasons as the aerial baiting is usually remote areas.

WA beach patrols used to be carried out by a Perth aero club but now by chopper as well. Big $$$$

 

 

[frank marriott]

"as your para (ix)."

 

Not mine, just the way I read it.

 

If you honestly believe you can justify your take on the reg as it strands, go for it, no skin off my nose. One way of getting a court ruling on the definition as well.

 

 

[djpacro]

From Dec when the new Part 61 regs come in it will be easier to discuss when a CPL is required. Perhaps one year the new Part 91 etc will make the other part of the discussion easier too.

 

 

[Chocolate]

"However, I have heard of ultralights being used for agricultural work, so perhaps it is possible if someone has an AOC..."

 

yes i have heard of it too. aerial mustering, dropping dog baits. they have no AOC, no nav training, no VHF, no PPL, no CPL, no nuthing! and are being paid for the work. (and they have an accident history thats a true worry.) AOC - IMHO really not necessary for the work involved and far too costly for them to get. Nav training - no excuse - should have it IMHO. VHF - no excuse IMHO- to at least tell all the rest of us where and what height! PPL / CPL - not necessary for the type of work involved IMHO but a very uneven playing field a the moment for those that went and did the right thing by the legislation and got the CPL. Being paid?... well the CPL with VH cannot compete on price. It s a bit of a legislative mess really.

 

 

[poteroo]

RAAus is already more than knee deep in digested grass with CASA. After all the organisations' demonstrated failures to successfully conduct the activities that it contracted with CASA - it's hardly the time to be seeking to expand. RAAus hasn't delivered on its' contract. Clearly, the RAAus Board needs to look to its' own housekeeping before all else.

 

We need to be more focussed on what we are able to do - and that's flying training,( and remember that in GA, training is an aerial work activity and requires an AOC). RAAus needs to ensure that it fits into the system as the 'ab initio' provider of training - feeding seamlessly into the new RPL.

 

If we don't grasp this opportunity - then SAAA will! One major plank of the SAAA's earlier proposals was to provide ab initio training up to what was then to be called the LAPL, (now the RPL). Nothing currently mentioned, but now that they are an RAAO, they meet the criteria as described in the Part 61 most recent docs. Nothing then to stop them becoming direct 'competition' for RAAus FTF's.

 

happy days,

 

 

[facthunter]

SAAA don't have the MASS of numbers we do. (or HAD). Australia is the same size to cover for anyone who operates. While competition is a good thing, being divided when the whole group is not very large is not productive. ALL "non commercial" groups have a lot in common. When you serve the public for reward there MUST be more surveillance/control. Keep the case for US being free of unnecessary/excess control. It's our strong point of differentiation. Nev

 

 

[Dafydd Llewellyn]

RAAus is already more than knee deep in digested grass with CASA. After all the organisations' demonstrated failures to successfully conduct the activities that it contracted with CASA - it's hardly the time to be seeking to expand. RAAus hasn't delivered on its' contract. Clearly, the RAAus Board needs to look to its' own housekeeping before all else.We need to be more focussed on what we are able to do - and that's flying training,( and remember that in GA, training is an aerial work activity and requires an AOC). RAAus needs to ensure that it fits into the system as the 'ab initio' provider of training - feeding seamlessly into the new RPL.

 

If we don't grasp this opportunity - then SAAA will! One major plank of the SAAA's earlier proposals was to provide ab initio training up to what was then to be called the LAPL, (now the RPL). Nothing currently mentioned, but now that they are an RAAO, they meet the criteria as described in the Part 61 most recent docs. Nothing then to stop them becoming direct 'competition' for RAAus FTF's.

 

happy days,

Yes, indeed. No argument. However, it seems to me that a clear statement by RAAus as to exactly what one can and cannot do UNDER THE EXISTING REGULATIONS in regard to operations that are on the fringe between private and aerial work, would hardly be viewed as an attempt to expand - it is, rather, another aspect of tidying-up the current mess. Expansion would entail pursuing an amendment to CAR 206(i)(viii) - and that's a political agenda that, obviously, RAA should not be embarking on until it has been seen for some time to have its house in order. However, there is no reason for people not to consider it as an option for the future.

 

Yes, this is looking ahead; however an organisation such as RAAus needs to not only do its current task properly - which I believe has never been the case - but once that ground-floor has been reached, an organisation of this sort either progresses or dies. It cannot stand still and survive, in the long run.

 

 

[facthunter]

True . It has to have ongoing AIMS which are clear and public and subject to structured ( democratic and transparent) processes responsive to members wishes and be practically achievable.

 

Most of the discussion here has highlighted '

 

(1) The rules are hard to understand. (Always have been)

 

(2) The is a need for a working document that is available to the members that (Like the VFG) that covers ALL the issues an operator (That's US) needs to know. Even good Aviation specialist Lawyers argue over the CASR's etc as they did over the older ANO's) so how can the average plane driver be expected to know that he is compliant and not likely to fall foul of the system, despite best intentions, which is ( I remind you) one of strict liability, subject to fines, points loss and imprisonment. Nev

 

 

[aro]

If you honestly believe you can justify your take on the reg as it strands, go for it, no skin off my nose. One way of getting a court ruling on the definition as well.

I'm not trying to argue for commercial operations in RAA, I'm just trying to read and understand the regulations. A court ruling is one way to gain understanding I suppose, but not a terribly efficient one.

 

If I flew away for a weekend and was pinged for taking my laptop and mobile phone (tools of trade) and maybe even responding to an email or (horror) processing a sale while I was at my destination, I probably would challenge it in court.

 

CAR 206 is confusing regarding RAA. Can you provide a reference as to why it applies/does not apply to RAA aircraft? And if it does apply, why are RAA allowed to perform flying trainig without an AOC? I found a reference in CAO 95.55 exempting RAA from CAR 210 requiring an AOC to advertise commercial operations, but not section 27 of the Act, requiring an AOC for the actual flying operations.

 

The more I explore the regulations, the less they make sense, and the more convinced I am that aviation works on the basis that what everyone else does is allowed (until CASA decide something isn't!), anything else is forbidden.

 

 

[Dafydd Llewellyn]

I'm not trying to argue for commercial operations in RAA, I'm just trying to read and understand the regulations. A court ruling is one way to gain understanding I suppose, but not a terribly efficient one.If I flew away for a weekend and was pinged for taking my laptop and mobile phone (tools of trade) and maybe even responding to an email or (horror) processing a sale while I was at my destination, I probably would challenge it in court.

 

CAR 206 is confusing regarding RAA. Can you provide a reference as to why it applies/does not apply to RAA aircraft? And if it does apply, why are RAA allowed to perform flying trainig without an AOC? I found a reference in CAO 95.55 exempting RAA from CAR 210 requiring an AOC to advertise commercial operations, but not section 27 of the Act, requiring an AOC for the actual flying operations.

 

The more I explore the regulations, the less they make sense, and the more convinced I am that aviation works on the basis that what everyone else does is allowed (until CASA decide something isn't!), anything else is forbidden.

If an exemption to CAR 206 is not in CAO 95.55 (and there isn't one that I can see) then CAR 206 applies to RAA aircraft, just as it does to all other Australian aircraft.

 

 

[aro]

If an exemption to CAR 206 is not in CAO 95.55 (and there isn't one that I can see) then CAR 206 applies to RAA aircraft, just as it does to all other Australian aircraft.

I agree. So, do RAA training facilities require an AOC, and if not, why not? (CAR 206 defines which operations require an AOC.)

 

 

[facthunter]

That matter was negotiated (if my memory serves me correctly) Perhaps the definition of the FTF and its function covers it. Since individual GA pilots who are not working for a flying school can do (some ) endorsements, I can't see why there is much problem (structurally) with training being carried out under specified conditions by the RAAus. I'm not saying the situation we have is GOOD especially right now. There may be a move amongst all this to move to a more conforming structure. That in itself won't change much, by itself. Maybe that is why the SMS gets the problem down the line but can only be a part of a solution to quality assurance and standards creation and adherence. Nev

 

 

[Dafydd Llewellyn]

I agree. So, do RAA training facilities require an AOC, and if not, why not? (CAR 206 defines which operations require an AOC.)

I suspect, this follows from the exemption to Part 5 of the CARs (CAO 95.55. 3.1(a)). This is a rather curious exemption; it means RAA is NOT conducting flying training under the CARs, but under its Operations Manual. I suspect this will prevent RAA training organisations from being able to issue RPLs - if it does not, the gymnastics involved on CASA's part are something I await with bated breath . . .