Airspace in Australia

[Camel]

And even more ridiculous is when the Coffs Harbour tower controller goes to lunch the CTA becomes a CTAF and then RAA pilots can transit or land and even take off. For those who don't know when getting ATIS and it is broadcast as Zulu then the tower is closed.

 

 

[rhysmcc]

Rhys, I understand the differences and was just comparing, e.g., the safety of the VFR route over the top of Williamtown compared with the Ultralight Lane. Chalk and Cheese. There is a half-way CTA that would be transit rather than full on access.

And what exactly is the difference between transit or "half-way CTA" and normal "full on access" CTA?

Safety would be to transit coastal under a clearance from ATC who would provide you with tracking instructions to avoid arriving and departing aircraft that will be crossing your route (or rather you'd be crossing the arriving and departing paths).

 

Having experienced CTA for the first time a week or so back flying into Tamworth I achieved a new level of appreciation for how extra safe it is to have a professional maintaining separation rather than the very sub-standard "see & avoid".[/Quote]Remember VFR aircraft are not separated from other VFR aircraft, traffic information is provided however the PIC is still responsible for "see&avoid".

 

And even more ridiculous is when the Coffs Harbour tower controller goes to lunch the CTA becomes a CTAF and then RAA pilots can transit or land and even take off. For those who don't know when getting ATIS and it is broadcast as Zulu then the tower is closed.

Not really, as the whole idea of CTA is due to the higher density of aircraft rather then preventing access to a particular airport. When the Tower is closed, there is none or little RPT therefore less risk to the traveling public. The medical requirements would be the same reason, operating in higher traffic density airspace therefore the risk is greater to the traveling public if your heart kicks in.

 

[DonRamsay]

In the USA the Airline Pilots Union at the last possible minute put in an objection to the easing of medicals for non-commercial flying there. That bastard act went over like a lead balloon with lots of retired airline pilots who like to fly light stuff and not maintain a Class 1 medical.

 

The previous DAS McCormick was the person who trod all over RAAus ambitions for safer MTOW and CTA. He was ably backed up by Farquarson (Jabiru killer) and the AvMed director. Fortunately, all three have now been consigned to the dustbin of history.

 

 

[DonRamsay]

And what exactly is the difference between transit or "half-way CTA" and normal "full on access" CTA?Safety would be to transit coastal under a clearance from ATC who would provide you with tracking instructions to avoid arriving and departing aircraft that will be crossing your route (or rather you'd be crossing the arriving and departing paths).

Full CTA would be doing laps at Bankstown - partial is as you've described it - supervised transit.

 

 

[Camel]

Not really, as the whole idea of CTA is due to the higher then density of aircraft rather then preventing access to a particular airport. When the Tower is closed, there is none or little RPT therefore less risk to the traveling public. The medical requirements would be the same reason, operating in higher traffic density airspace therefore the risk is greater to the traveling public if your heart kicks in.

As I said earlier Port Macquarie is busier than Coffs Harbour and is a CTAF, has plenty of RPT and flight training.

 

Don't need a medical in CTAF so when he has lunch you don't need medical. I have a PPL with class C and D so I have the privilege but I feel transit is no big deal at certain locations for RAA with some training.

 

 

[DonRamsay]

I may be a bit out of touch here, but I am struggling to understand how CASA is even using the whole different medical standards argument as a justification for keeping RA-AUS pilots out of controlled airspace. My understanding is the argument is that they pose a greater danger to people on the ground due to the supposedly lower medical standard, but as aircraft fly over highly populated areas OCTA this whole line of argument just seems ridiculous.I suspect the main barrier is a lot of the GA (and CASA) community still look at RA as a lower form of aviation that can't be trusted doing "real flying". That will be the hardest part to overcome. If the RPL and pilot certificate a truly equivalent then it makes sense that RAA pilots should be able to get CTA/CTR endorsements as per the RPL. Making this actually happen will not be easy though.

To be fair, McCormick on taking office just said stop all moves for new privileges for RAAus. No argument or reasons that I'm aware of just stop it until he had a think about it all. But it stayed stopped for the whole of his time in office. It would not be hard to believe that he really wanted to see the back of RAAus and dreamed up the RPL to achieve that and to stop GA pilots moving to RA.

 

The experience in the USA for 10 years of LSA has given the lie to the argument that you need the fitness of an Olympic athlete to be a safe pilot. And we all know the original thinking behind setting ridiculously high medical standards in the first place was to ration the demand for flying jobs during WWII.

 

 

[Nobody]

In many ways the best outcome would be:

 

1) CASA to ease the restrictions on the drivers licence medical so that it can be what it should have been.

 

2) RAAus to allow people with an RPL to fly an RAAus aircraft without holding a RPC.

 

That way it would save people from having to have 2 licences and people could have access to controlled airspace.

 

 

[rhysmcc]

Full CTA would be doing laps at Bankstown - partial is as you've described it - supervised transit.

Well that could be done. To do laps (Ccts) at Bankstown you'll need a controlled aerodrome endorsement. To transit say Coffs at 1500 for example you'd need a controlled airspace endorsement (CTA). that's how it works with the RPL.

 

In many ways the best outcome would be:1) CASA to ease the restrictions on the drivers licence medical so that it can be what it should have been.

 

2) RAAus to allow people with an RPL to fly an RAAus aircraft without holding a RPC.

 

That way it would save people from having to have 2 licences and people could have access to controlled airspace.

That should be our goal, you'd need still to be a member and follow the new Ops Manual but phase out the RPC once the drivers licence medical is fixed (ie same waiver as now or note from the doc).

 

 

[Ada Elle]

Or, why not offer CTA training, testing and endorsement to the few in RAAus that would find it useful. As you would know, to convert to an RPL is not a trivial or inexpensive exercise. Then, of course, there is the Clayton's Drivers Licence medical that was invented by the mostly despised AvMed nutters. A Class II would be my only option and that is also a very expensive and time consuming exercise and prove nothing other than some more bureaucrats have a steady job producing nothing of value.

Who would do the CTA training, testing, and endorsement?

 

A bare minimum RPL should run at <$1k (2.5 hours of dual flight time + AFR). If you fly a type which is VH-registrable there are no familiarisation costs. The trips to CTA for endorsement purposes may be fairly expensive, depending on where you are.

 

Basically, I don't see how RAAus training, by equivalently qualified instructors (ie CPLs, ideally CPLs who teach CPLs) would be much cheaper than getting an RPL.

 

As for the medical issue: I think that the private drivers license medical standard is potentially too lax, especially in CTA where you might be causing millions of dollars of delays by calling a medical mayday in certain spots. I also know that I've advised patients not to drive, and they have driven anyhow.

 

I think what we need is a DAME administered third class medical, with clear standards.

 

 

[ricky m]

Maybe it will go like the uk? caa (uk cassa equivalent) oversee licenses,BMAA(British microlight association) over see airworthiness ... The uk nppl (m) microlight (3axis and wieght shift) allows flight though controlled airspace matz etc.with basic medical.. If u are clear and precise on the request on the radio....ur cleared through the zone:) simples lol....but nppl is uk only (no jar priviliges) hence i now how nppl.rpc (raa aus)and rpl (casa). plus 3 radio liciences (yes 3... One for caa uk... One endorsment for rpc... And one for rpl, to get the cassa one i had to take an english language test..lmao.. yet the sylibuss is pretty much the same for all. ohhh well

 

 

[shags_j]

First: coffs doesn't close for lunch.

 

Second:just as a matter of practicality i will be converting to rpl as soon as possible solely due to cta access. If Raaus can't deliver t this then i have no choice. I know this isn't the fault of the board ( they have tried) but i will have no choice for cta access. In a lot of cases ( mine included) a limited transit access isn't enough.

 

 

[rhysmcc]

First: coffs doesn't close for lunch.Second:just as a matter of practicality i will be converting to rpl as soon as possible solely due to cta access. If Raaus can't deliver t this then i have no choice. I know this isn't the fault of the board ( they have tried) but i will have no choice for cta access. In a lot of cases ( mine included) a limited transit access isn't enough.

Agreed, I think the way forward would be to remove the requirement for a RPC (ie allow RPL PPL), keep the RPC until CASA improve the medical requirements (remove), membership of RA-AUS still applies as requirement.

 

I wonder what savings could be made by RA-Aus if they could cut back on the number of certificates they administer? Thus passed onto the members.

 

 

[Roundsounds]

As mentioned earlier, CTA privileges are already provided to RAAus students under an exemption at the old GAAP airports (now modified Class D). Gliding Australia (formerly the GFA) enjoy Class C and D access, their pilots operate on the same basis as RAAus- a certificate issued by their RAAO and a self assessed medical. Camden is a good example of this.

 

A properly prepared submission to CASA, highlighting the discriminatory application of restrictions to airspace use, should see at least Class D access.

 

I know an individual has already raised this with CASA resulting in it being referred to their legal office for consideration, but a lone voice is unlikely to make any ground. This would need a higher profile push to succeed.

 

 

[K-man]

A bare minimum RPL should run at <$1k (2.5 hours of dual flight time + AFR). If you fly a type which is VH-registrable there are no familiarisation costs. The trips to CTA for endorsement purposes may be fairly expensive, depending on where you are.

I would suggest this synopsis is optimistic. Bearing in mind, very few people are going to want an RPL without CTA and CTX endorsement. I fly an aircraft that is VH registrable but that doesn't mean there are any available in flying schools that are registered VH. That means flying an unfamiliar aircraft, that might be similar in characteristics although double the weight, into and out of controlled airspace and controlled airports. I would suggest that two hours is closer to the minimum there just learning to fly the aircraft competently. Then you have two hours of instrument flying. For the flight test you have to demonstrate that you can safely fly into controlled airspace without the help of the examiner so in my case I flew into and out of Moorabbin (class D) numerous times and Essendon (class C) once, with an instructor, getting taxi clearance etc. From memory, that was about 2.5 hours alone. Flight review, another 1.5 hours with flight into and out of two controlled airports and being cleared from tower airspace to controlled airspace and requesting altitude change. That is eight hours and I can't see anyone getting away with much less unless there are corners being cut. If that happens and standards aren't being enforced then the RPL will have the same criticism heaped on it that we have now with our RPC.

 

Basically, I don't see how RAAus training, by equivalently qualified instructors (ie CPLs, ideally CPLs who teach CPLs) would be much cheaper than getting an RPL.

Well, for starters, we could do it in our own aircraft which is the same aircraft we will be flying into and out of controlled airports and airspace anyway. Apart from that, normally RA aircraft are cheaper to hire than GA aircraft and there is no familiarisation. I reckon I would have saved well over $1k if I had been able to fly my own aircraft throughout the conversion.

 

As for the medical issue: I think that the private drivers license medical standard is potentially too lax, especially in CTA where you might be causing millions of dollars of delays by calling a medical mayday in certain spots. I also know that I've advised patients not to drive, and they have driven anyhow.I think what we need is a DAME administered third class medical, with clear standards.

I don't understand what in the 'driver's licence medical' is lax. The same things will disqualify you for the RPL medical as the class 2. As to the medical maydays ... just how often does that occur and why would having a different medical make any difference? A class 2 medical doesn't prevent heart attack or stroke. If I recall correctly that is an issue in the U.S. presently where they are looking at reducing the medical requirements. My wife's last DAME medical was nearly twice the price of mine and I thought the cost of my RPL medical was exhorbitant.

 

 

[K-man]

As mentioned earlier, CTA privileges are already provided to RAAus students under an exemption at the old GAAP airports (now modified Class D). Gliding Australia (formerly the GFA) enjoy Class C and D access, their pilots operate on the same basis as RAAus- a certificate issued by their RAAO and a self assessed medical. Camden is a good example of this.A properly prepared submission to CASA, highlighting the discriminatory application of restrictions to airspace use, should see at least Class D access.

I know an individual has already raised this with CASA resulting in it being referred to their legal office for consideration, but a lone voice is unlikely to make any ground. This would need a higher profile push to succeed.

Agreed. And just where is the logic that a student is deemed safe to fly in that environment but once they are given their flying certificate they are no longer deemed competent to fly there? Apart from that, the difference in flying class D and class C is minuscule. Like many areas, this is another example of politics getting in the way of common sense.

 

 

[Camel]

First: coffs doesn't close for lunch.Second:just as a matter of practicality i will be converting to rpl as soon as possible solely due to cta access. If Raaus can't deliver t this then i have no choice. I know this isn't the fault of the board ( they have tried) but i will have no choice for cta access. In a lot of cases ( mine included) a limited transit access isn't enough.

Coffs use to close for lunch on weekends, has it changed ?

 

Don't you work for Airservices as a Controller ? If so you should be helping get transit privileges for RAA as RAA is about the members and being able to fly affordably, oh that's right you want full access and don't seem to want to improve things, look after yourself eh ! I have a PPL and I would like to see transit for RPC holders as I want to improve the situation and remove the danger of getting around. If you want full access you need a PPL or RPL and that's it, very simple and it won't come cheap. I spent plenty and spent lots of time studying, I'm saddened by those who are in it for themselves as I could easily not worry about transit rights as I'm OK !

 

Board members do it for nothing to help others !

 

Most RAA FTF don't earn big bucks, they like sharing the knowledge and joy !

 

RAA was about sharing aviation and being affordable !

 

I have taken people flying that would possibly never get that opportunity including camp quality kids, disabled and that has brought me joy.

 

 

[frank marriott]

What happened to the RPC holder conducting a private flight with pax (and the FTF for authorising it) when he/she ran out of fuel at Archerfield. Nothing publically. Is this a common occurrence or just this FTF? Insurance?

 

 

[rhysmcc]

Agreed. And just where is the logic that a student is deemed safe to fly in that environment but once they are given their flying certificate they are no longer deemed competent to fly there? Apart from that, the difference in flying class D and class C is minuscule. Like many areas, this is another example of politics getting in the way of common sense.

I think the argument is the student is operating under the supervision of a qualified instructor (Not sure if they need a PPL or CTA endorsement) is why it's considered "safe" during training but no after (personally I don't agree and RA-AUS should issue these people CTA).

 

Coffs use to close for lunch on weekends, has it changed ?Don't you work for Airservices as a Controller ? If so you should be helping get transit privileges for RAA as RAA is about the members and being able to fly affordably, oh that's right you want full access and don't seem to want to improve things, look after yourself eh ! I have a PPL and I would like to see transit for RPC holders as I want to improve the situation and remove the danger of getting around. If you want full access you need a PPL or RPL and that's it, very simple and it won't come cheap. I spent plenty and spent lots of time studying, I'm saddened by those who are in it for themselves as I could easily not worry about transit rights as I'm OK !

Board members do it for nothing to help others !

 

Most RAA FTF don't earn big bucks, they like sharing the knowledge and joy !

 

RAA was about sharing aviation and being affordable !

 

I have taken people flying that would possibly never get that opportunity including camp quality kids, disabled and that has brought me joy.

If by transit access you mean CTA endorsement then yes, I would support such a push. If you mean access to "VFR Routes Only" then I would actually oppose such a move and as mentioned before would not be seen on providing such a clearance when requested due the additional restrictions that would place on me (i.e. not being able to track aircraft out of the route to avoid arriving/departing aircraft).

 

 

[ian00798]

Coffs use to close for lunch on weekends, has it changed ?Don't you work for Airservices as a Controller ? If so you should be helping get transit privileges for RAA as RAA is about the members and being able to fly affordably, oh that's right you want full access and don't seem to want to improve things, look after yourself eh ! I have a PPL and I would like to see transit for RPC holders as I want to improve the situation and remove the danger of getting around. If you want full access you need a PPL or RPL and that's it, very simple and it won't come cheap. I spent plenty and spent lots of time studying, I'm saddened by those who are in it for themselves as I could easily not worry about transit rights as I'm OK !

Board members do it for nothing to help others !

 

Most RAA FTF don't earn big bucks, they like sharing the knowledge and joy !

 

RAA was about sharing aviation and being affordable !

 

I have taken people flying that would possibly never get that opportunity including camp quality kids, disabled and that has brought me joy.

Shags knows Coffs quite well, so if he says it doesn't close for lunch, then I would take that as fact.

 

I think that was a bit personal and harsh, nowhere in shags message did I see him indicate that he is only caring for himself, or that he doesn't support RAA having CTA access, merely that he wants to use CTA and under the current rule set he can only do that with an RPL. from the controllers perspective, we don't care whether the aircraft we are clearing has a CH call sign, RA call sign or an airline call sign, all we want to know is that pilot can comply with the procedures of CTA. Rather than a narrow Lane of entry, I believe it's safer to give a full CTA endorsement which should be feasible for a pilot certificate. If you study thoroughly using all the resources, ie AIP, CASA on track etc then getting a CTA endorsement won't take long, after all it's competency based, whether it takes 2 hours to show competency or 10 is up to you and how much work you want to put in. VFR lanes can be quite troublesome, just look at Bankstown and victor one, especially when you add weather and poor visibility into the mix.

 

You raise some very valid points about the sharing of knowledge and the joy of flight, and I would love to see more of that. Just remember, there is no need to slag off others who also share the same passion for flying.

 

 

[Ada Elle]

I would suggest this synopsis is optimistic. Bearing in mind, very few people are going to want an RPL without CTA and CTX endorsement. I fly an aircraft that is VH registrable but that doesn't mean there are any available in flying schools that are registered VH. That means flying an unfamiliar aircraft, that might be similar in characteristics although double the weight, into and out of controlled airspace and controlled airports. I would suggest that two hours is closer to the minimum there just learning to fly the aircraft competently. Then you have two hours of instrument flying. For the flight test you have to demonstrate that you can safely fly into controlled airspace without the help of the examiner so in my case I flew into and out of Moorabbin (class D) numerous times and Essendon (class C) once, with an instructor, getting taxi clearance etc. From memory, that was about 2.5 hours alone. Flight review, another 1.5 hours with flight into and out of two controlled airports and being cleared from tower airspace to controlled airspace and requesting altitude change. That is eight hours and I can't see anyone getting away with much less unless there are corners being cut. If that happens and standards aren't being enforced then the RPL will have the same criticism heaped on it that we have now with our RPC.Well, for starters, we could do it in our own aircraft which is the same aircraft we will be flying into and out of controlled airports and airspace anyway. Apart from that, normally RA aircraft are cheaper to hire than GA aircraft and there is no familiarisation. I reckon I would have saved well over $1k if I had been able to fly my own aircraft throughout the conversion.

Is there a problem, in a dual RA/GA school, with doing the training portions of the RPL in your own aircraft? (other than the actual instrument flight portions)

 

Secondly, there shouldn't be a flight test for the RPL.

 

Thirdly, you don't necessarily need to go into controlled airspace on the flight review. The flight review may test navigation etc, but nothing stops you from getting your controlled airspace endorsement after flight review. An instructor needs to sign that you have received training on form 61-1RE.

 

Fourthly, most schools charge a lot more for training in your own aircraft than for training in one of theirs. At the GA school I've been training at (which has a PiperSport) I wouldn't be able to hire an aircraft and ask to be trained in it cheaper than training in the PiperSport.

 

So, without taking any shortcuts, you could (in Sydney):

 

- have 1 hour in a sim

 

- fly for 1.5 hours in a VH registered Jabiru, Foxbat, or PiperSport (available at YSBK/YSCN)

 

- fly for 1.5 hours in an AFR

 

- then go to a combined RA/GA school and ask to do CTA/CTX in your own aircraft (say at YMND).

 

I don't understand what in the 'driver's licence medical' is lax. The same things will disqualify you for the RPL medical as the class 2. As to the medical maydays ... just how often does that occur and why would having a different medical make any difference? A class 2 medical doesn't prevent heart attack or stroke. If I recall correctly that is an issue in the U.S. presently where they are looking at reducing the medical requirements. My wife's last DAME medical was nearly twice the price of mine and I thought the cost of my RPL medical was exhorbitant.

Not RPL medical. The drivers license standard for RAAus/GFA/etc.

 

Under the drivers license standard, you're allowed to drive two weeks after a heart attack. The CASA standard is six months.

 

A long time ago I looked after a flight instructor with a broken toe. He asked me how long to be grounded for. At this stage I had very little experience with aviation, so I said for him to ask his DAME; the DAME called me, and we agreed upon 'until it was healed', which is usually 4 weeks. That's twice as long, for a broken toe, as someone who has had a heart attack in the RAA system.

 

Why is the cost of a DAME medical exorbitant? You're asking a highly trained professional to use their professional judgment.

 

 

[rhysmcc]

I'd need to read the regs again but I'd doubt you could go do CTA/CTX training in your own (RA-AUS) aircraft. I know you can't complete a (CASA) AFR in a RA-AUS registered aircraft, i'd bet the same restriction on a CASA Flight instructor providing training in other then a registered aircraft (as far as Part 61 is concerned).

 

 

[jetjr]

What about homebuilt experimentals under RAA being prevented from CTA, yet same homebuilt aircraft under VH is OK

 

DAME has next to nil impact on medical now, its a series of online questions, requirements are above and beyond normal acceptable limits for many things

 

Theres a many thousands training required, $17K maybe? To qualify. Most medicals require multiple requests for info and records

 

Two DAME I know really arent interested, too much time and problems and their advice is ignored anyway

 

 

[shags_j]

Coffs use to close for lunch on weekends, has it changed ?Don't you work for Airservices as a Controller ? If so you should be helping get transit privileges for RAA as RAA is about the members and being able to fly affordably, oh that's right you want full access and don't seem to want to improve things, look after yourself eh ! I have a PPL and I would like to see transit for RPC holders as I want to improve the situation and remove the danger of getting around. If you want full access you need a PPL or RPL and that's it, very simple and it won't come cheap. I spent plenty and spent lots of time studying, I'm saddened by those who are in it for themselves as I could easily not worry about transit rights as I'm OK !

Board members do it for nothing to help others !

 

Most RAA FTF don't earn big bucks, they like sharing the knowledge and joy !

 

RAA was about sharing aviation and being affordable !

 

I have taken people flying that would possibly never get that opportunity including camp quality kids, disabled and that has brought me joy.

Woah Settle Petal.

 

I am ATC but nothing I have said here (other than Coffs not closing for lunch anymore) has anything to do with my job. Like Ian said, I don't care if I am clearing something with numbers or a VH reg.

 

I also as I said support RAAus having CTA Privilege. But how long can I wait for that. I wish I were in a position to assist in getting these endorsements through but I have neither the knowledge or skills to assist the board in this and I really do wish them well in their quest for these privileges.

 

I am speaking from my own requirements on what I want to practice. My choice: get an RPL and fly from an aerodrome 15 mins from my house, or, maintain my RAAus, travel over an hour to Caboolture and if I want to go somewhere, plan around all CTA. Yes for me I am definitely better off changing to an RPL. Maybe I will maintain my RPC so I can fly tecnams etc. but for the moment I don't think that's for me.

 

My role as a controller doesn't put me in a position to negotiate with anyone on RPC access to CTA. I put in a good word for RAAus pilots any chance I get and always keep a positive attitude towards RAAus. So I'm not sure what else I can do to help RAAus get CTA access.

 

 

[Ada Elle]

I'd need to read the regs again but I'd doubt you could go do CTA/CTX training in your own (RA-AUS) aircraft. I know you can't complete a (CASA) AFR in a RA-AUS registered aircraft, i'd bet the same restriction on a CASA Flight instructor providing training in other then a registered aircraft (as far as Part 61 is concerned).

61.195 and 61.495 don't say this.

 

Said person would have to be both an RA/GA instructor, of course, but:

 

- what stops you from receiving instruction for an RPL Nav Endorsement in an RAA aircraft?

 

- what is different between the Nav endorsement and controlled airspace?

 

 

[Roundsounds]

So, without taking any shortcuts, you could (in Sydney):

- have 1 hour in a sim

 

- fly for 1.5 hours in a VH registered Jabiru, Foxbat, or PiperSport (available at YSBK/YSCN)

 

- fly for 1.5 hours in an AFR

 

- then go to a combined RA/GA school and ask to do CTA/CTX in your own aircraft (say at YMND).

This certainly would be an adequate work around, but why is a workaround needed?

I hold a CPLA, Grade 1 Flight Instructor Rating and CFI / ATO privileges. To set up a Part 141 flight training organisation I would spend 18 months and around $15K, whereas an RAAus FTF - 4 weeks and less than $500 would see me up and running. I could train RAAus pilots and issue their RPC at a Class D aerodrome, subject to obtaining a CASA exemption. Having gained their RPC they can no longer operate from the Class D aerodrome. However, if the same pilot obtains an ASIC, RAMPC or Class 2 medical, applies for and obtains an RPL from CASA I can do a flight review with the very same pilot I just trained and tested for an RPC, endorse them for Class D operations and off they go in the same RAAus registered aircraft they gained their RPC in! Across the paddock at Camden there are glider pilots, with cross country and passenger carrying privileges operating motorised gliders without holding any CASA issued medical or licence and no Class D airspace endorsement.

 

Where is the safety related case for applying different standards to two similar RAAOs? Maybe Part 149 will address this?