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Part 61 - For Dummies.
#76
(07-05-2016, 11:46 AM)Peetwo Wrote: AMROBA v Skidmore Part 61 - UDB!  Confused

The following is the history/& short insight into the ever evolving cancerous growth that is Part 61 which still threatens the sustainability of an industry that continues to be embuggered with regulatory red tape by a seemingly uncontrollable bureaucracy - Angry :    

Quote:CASR Part 61 - Flight crew licensing - History

Consultation updates in 2016
AC 61-05 v1.0 - Night VFR rating
This AC has been published.
12 Apr 2016
Draft AC 61-05 v1.0 - Night VFR rating
All comments should be sent to the project leader, Damien Fing by close of business 29 February 2016.
15 Feb 2016

Consultation updates in 2015
FS 99/02 - CASR Part 61: Flight crew licensing
This project is now closed
Refer to the project closure notes for further information.
13 May 2015

Consultation updates in 2014
Project FS 14/25 - Post-implementation review of the Flight Crew Licensing regulations - Part 61
Project approved.
3 Dec 2014
Project FS 03/01 - Periodic review and ongoing amendments to include endorsements for new types and models introduced to Australia
This project is now closed
Refer to the project closure notes for further information.
3 Dec 2014
Civil Aviation Order (Flight Crew Licensing) Repeal and Amendment Instrument 2014 (No. 1)
Civil Aviation Order made.
27 Aug 2014
Civil Aviation Legislation Amendment (Flight Crew Licensing) Regulation 2014
Regulation made.
21 Aug 2014
Draft AC 61-08 v1 - Teaching and assessing non-technical skills for single pilot operations
All comments should be sent to the Project Leader, Roger Crosthwaite by close of business 31 July 2014.
16 Jul 2014
Project OS 14/12 - Performance Based Navigation and Reduced Vertical Separation Minima regulatory review.
Project approved.
2 May 2014

Consultation updates in 2013
Civil Aviation Legislation Amendment (Flight Crew Licensing and Other Matters) Regulation 2013
Regulation made.
12 Dec 2013
Civil Aviation Legislation Amendment (Flight Crew Licensing Suite) Regulation 2013
Regulation made.
21 Nov 2013
Consultation Draft for proposed amendments to the Flight Crew Licensing Suite
All comments should be submitted via the Project Leader, Mike Juelg by close of business Friday 25 October 2013.
4 Oct 2013
Consultation Draft for Part 61 Manual of Standards (MOS)
All comments should be submitted to the Project Leader via mos61@casa.gov.au by close of business 2 August 2013.
5 Jun 2013
Civil Aviation Legislation Amendment Regulation 2013 (No 1)
Regulation made.
14 Feb 2013

Consultation updates in 2011
Consultation Draft - CASR Part 61 - Flight crew licensing
Comments on this consultation draft are to be submitted via the online form by close of business 3 February 2012.
17 Nov 2011

Consultation updates in 2009
Project FS 06/02 - Multi-Crew Pilot Licensing (MPL)
This project is now closed.
6 Feb 2009

Consultation updates in 2007
Multi-crew Pilot Licence (MPL) Project team provided with Draft CAR 5 amendment

15 Aug 2007

Consultation updates in 2006
Project FS 06/02 titled Multi-crew Pilot Licence (MPL)
New multi-crew pilot licence project has been registered.
29 May 2006

Consultation updates in 2004
Industry consultation briefings cancelled
The Part 61 and 141 MOS consultation briefings scheduled for 23 August through to 15 September have been cancelled.
19 Aug 2004

Consultation updates in 2003
NPRM 0309FS - Flight Crew Licensing
NPRM 0309FS - Flight Crew Licensing, associated Annexes and Draft MOS Part 61 have been published. Your comments are invited by 29 September 2003.
18 Jul 2003
Project FS 03/01 - Periodic review and ongoing amendments to include endorsements for new types and models introduced to Australia
Project opened.
10 Jun 2003

Consultation updates in 2000
DP 0005FS - Flight Crew Licensing Structure
DP 0005FS - Flight Crew Licensing Structure, CASR Part 61 is available for public comment. Comments close 29 January 2001.
30 Nov 2000

Consultation updates in 1999
FS 99/02 - CASR Part 61: Flight crew licensing

Part 61 legislative instruments:
Quote:Part 61 is contained within Volume II of the CASR (see link below), from page 101 to 423 i.e. 322 pages:

CASR Volume 2 : 675 pages
r 45.005-92.205



Part 61 Manual of Standards Instrument 2014 is 664 pages contained within 4 Volumes, see links and page count below:

Volume 1 : 74 pages

Volume 2 : 254 pages  

Volume 3 : 228 pages

Volume 4 : 108 pages
                                              
Kharon - "..Part 61 now has so many necessary exemptions as to render it farcical, it is no longer a law, but a crippled vehicle which the owners must keep repairing to salve their egos..."  

For reference - HERE - is the link for all the work done and in progress initiated by Oliver's Part 61 Tiger Team. Within that there is an additional link - HERE - which takes you to a page of 'legislative instruments' that have been introduced since the original Part 61 first became law on 01 September 2014.

Now in reference to the "K" post here is the latest list of exemptions put in place to address the shortcomings and industry imposts identified so far within the Bible sized CASA Part 61... Dodgy :
Quote:Exemptions

 Simply staggering when you consider that the above only includes the 'exemptions' so far and none of the additional pages of related amendments that also require more & more legislative instruments to be generated and tabled in parliament. The Attorney General's department must have a separate section totally devoted to handling CASA generated legislative instruments - UDB! Dodgy

Update: Part 61 taskforce extension - WTF?    Undecided  

Caution: The following material may cause rapidly developing side effects. For example extreme nausea, manic depression, fits of rage and/or Part 61 induced PTSD... Confused

Funny coincidence but yesterday Skidmores's Wodger WAP & the NFI Tiger Team released the following update to the latest Part 61 news page:
Quote:5 July 2016

Part 61 Solutions Taskforce extended to address remaining priority issues

CASA’s Part 61 Solutions Taskforce has been extended until 30 September 2016 so that additional guidance material can be produced for the aviation community and remaining priority issues can be resolved.

The Taskforce was formed in November 2015 to deliver solutions to valid issues associated with the flight crew licensing regulations (Parts 61, 64, 141 and 142). The remit of the Taskforce was to ensure that known or likely safety risks continued to be effectively addressed, that unnecessary costs were not imposed on the aviation community, and that the rules did not unnecessarily hinder participation or the potential for industry growth.

An Industry Advisory Panel – comprising representatives from a range of aviation industry sectors – was also formed to test CASA’s proposed solutions and provide input on proposals.

The Taskforce was originally established with a nominal completion date of 30 June 2016, but with the acknowledgement that the final end date would be determined by the full delivery of solutions to critical items on the flight crew licensing regulations issues register.

In its seven and half months of operation, the Taskforce has worked to deliver an extensive range of solutions and materials. To date these include instruments and exemptions that:
  • extended the deadline for flight training organisations to transition to new rules
  • introduced more flexible ways for pilots to meet multi-crew cooperation (MCC) training requirements, and clarified the standards for MCC training in aeroplanes
  • relaxed some air transport pilot licence (ATPL) requirements
  • provided a pathway for aerial agriculture rating holders to conduct firefighting operations
  • provided clarity for the mustering sector on who can teach an examine mustering endorsements
  • provided relief for pilots who operate single-pilot turbojets
  • changed the instrument rating and ATPL flight test standards
  • changed the commercial pilot licence and ATPL aeronautical knowledge examinations window from two to three years for people who passed
  • relaxed the requirements and provided alternative ways for pilots to meet flight review and instrument proficiency check requirements.
View the full list of flight crew licensing instruments and exemptions.

In addition, the Taskforce has produced a range of guidance material designed to make it easier for industry to transition to new rules. This has included a Part 141 Sample Operations Manual, new syllabuses to help flight training organisations develop their courses, and a range of new information sheets designed to provide more accessible overviews of transition and regulatory requirements.

The Taskforce is currently finalising similar guidance for Part 142 flying training organisations, including a Part 142 Sample Exposition and supporting material. The Taskforce is also developing a range of other guidance for the aviation community such as the Flight Examiner Rating Course and Flight Examiner Handbook update.

Industry Advisory Panel members last met as a group on Friday, 1 July, to take stock of progress so far and negotiate on the next set of priorities for the Taskforce. The Panel has agreed to continue in its current form until the Taskforce winds down in 30 September, with future arrangements to be determined after that date.

Over the coming months, CASA will continue engaging with the aviation community to resolve remaining issues, including those relating to flight reviews, mustering, the multi-engine helicopter class, flight instructor training endorsements, flight tests, aerial agriculture, azimuth guidance and the ATPL flight test. Revisions to the Part 61 Manual of Standards are also being finalised.

It is anticipated that a Notice of Proposed Rule Making for the amendments to the flight crew licensing regulations will be released by the end of 2016. The amendments are designed to give permanent effect to the interim solutions that have been delivered to the aviation community via exemptions and other instruments of approval. CASA will continue to publish fortnightly updates to keep the aviation community up to date with the work of the Taskforce.

Please someone? anyone? NX perhaps? - please, please bring some sanity to Skidmore's CASA nut house - FFS! Angry



MTF...P2 Tongue
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#77
Can someone ask NX to enquire at the next estimates how much so far has been spent just by CAsA alone
implementing Part 61. Then ask him if CAsA could provide estimates expressed as a percentage of turnover how much Part 61 is going to cost the industry?
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#78
Pre BRB warm up.

On any project you can expect ‘hiccups’; the art form is to be able to manage those nasty, hidden little gremlins which can, and do, pop up.  Even the best laid schemes of mice and men etc.  There is an engineering adage which has withstood, for a couple of centuries, the test of time. “ Man proposes; God disposes”.  Now my TOM built ‘heavy things’, things that mattered, things that were conceived then examined, then tested and examined, things that went through an acute process of research, design, finance before being tested again.  Eventually, when all possible cock-ups, down to the colour of the floor covering (and the cost) had been examined, critiqued, tested and costed the final plans were laid – even then – there were progress meetings and ‘accountability’ sessions.  As I said, these were not tin sheds, but important, expensive, engineering projects.  A lot, and I do mean a lot of care was taken before the first nail in the site office door was knocked in.

Heh heh, (quiet chuckle) got a little “K” syndrome for a while  there; it’s easy to run on – I digress.  To the point old fool.  Well, part 61 should never, not ever, have become a major capital expenditure program. My TOM built and commissioned a major oil refinery in Siberia for much less money.  Sure there were duck ups, delays, misunderstandings and some bloody awful concrete pours – but despite all that job done – on time and ‘just’ within budget.  Part 61 is a project out of control and beyond existing skill levels.  It has become an embarrassment to those who failed, miserably, not only to do their homework and budget; but it was created, designed and approved by someone with NFI.  The design was never ‘tested’ or the construct even examined in any form of ‘critical manner.  It is a pipe dream, one that should never have got off the drawing board, for no sane board of directors or investors would ever have approved such an amateur lash up – not in a million.

Now, CASA are forced into a risible position; the law can only work under an increasing amount of exemption and endless ‘amendment’.  The system is cumbersome, legally un-safe, inefficient in terms of time and money – and there is no end in sight.  The impact has industry reeling simply because the project was a wishful thinking exercise. This rule set was  drafted by those with absolutely no concept and less experience of running a flying business.  It reads like a first time around the block effort of a new chief pilot with little or no idea of the real world and how it wags.  

Now the ‘authority’ is too ashamed, em-bare-assed and scared silly about the repercussions from above, that it is forced to persist with and defend this ridiculous wet dream of a rule set.  Weeks needs to walk, Skidmore and anyone who else who has joined in the creation and defence of the existing mess should either resign; or, man up. Admit it’s the biggest crock to ever come down the pike and start again; preferably with a sensible rule set as a template.

Bugger, look at the clock – best get moving to the BRB.  Darts is a ‘friendly’ tonight, no set agenda and I do owe the lad a couple for making UP watch voluntary – maybe I’ll play him for them; unless he goes for double or square.  Risk assessment warns against such folly.

There now, that’s my well spent two bob’s worth.
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#79
Buying a Rolls Royce?

What’s the old saying about expensive machinery, something like if you have to ask the cost, you can’t afford it.  Well, it’s about time we started to ask the monetary cost of Part 61, because I’m pretty certain we can’t afford it.

I’ve no idea what each ‘exemption’ and ‘instrument’ costs from whoa to go; but each disallowable document must pass through many hands before it is published, so the cost in man hours alone must be impressive.  Look over there; a ‘Tiger Team Member’ all spruce and raring to go arrives at one of the special desks, fresh Latte, play lunch, sharp pencil and new rubber in the ‘kit bag’.  In strolls OST and dumps a pile of paper on the desk “sort that out for me” says he.

Well, the TTM is not dismayed or overawed by this already expensive pile of paper. Indeed, although the cost of producing the original was massive it’s just another pile of work to unravel, rework, draft exemption to and send down the line; off he goes in fine style.  First task, decide what it all means – the purpose of the rule part, the mystery of language, the conundrum of intent and the heady maze of legal speak.  With the consummate ease of a master crossword fanatic TTM wrestles the beast and after may phone calls to legal, hours and hours on Google, a dim picture of what it is, emerges from the mists.  End day one.  Day two is spent refining the image to an acceptable standard which leads to scheduling a meeting day three.  The long meeting involves several others and takes a while, because although none could understand the thing in the first place, they all must be consulted now that TTM has got some idea of what it was all about. Eventually, the meeting is over, high fives all around; TTM has a go ahead to work the exemption.  Well after three days of work, the TTM needs a break; so day four is toast, which takes TTM to day five and the all day gabfest ‘progress’ meeting.  Welcome to the week end.

Eventually, by the end of the next week, TTM has drafted ‘the instrument’ for consideration by ‘other’ departments – after the weekend.

TTM’s draft spends the next week on various desks and by the Friday gabfest, covered in red pencil and traces of McDonalds sauce the tattered original is centre stage.  The resolution is carried and the draft is on it’s way to be typed up and printed for the ‘big-wigs’ gabfest.  Of course the top table boys are busy; so our instrument, now a tidy package must wait it’s turn. Towards the end of the week, the rubber stamp is used and our ‘instrument’ goes into the system, legal vet it, operations vet it; even the tea lady gets a peep, just to make sure all’s well.  Next stop, parliament.  Oh yes, this is now a disallowable document and it must be seen at least to go through the entire process before emerging for publication and distribution. How many hours of work, for how many people are involved there?

It’s said many hands make light work; that may be true, however I just wonder why so many hands are needed.  Had the ducking rule been done properly, the first time, we would not have needed so many for the repair and patch up job.  Of course the reversal process will need as much time, money and effort as the temporary patch up; then there is the cost of redrafting 61 all over again.  Work for a lifetime, right there. Don’t forget, we’d spent a squillion manufacturing this cripple, before they set about repairing and patching.  It may not be the best rule set in history, but it’s up there with one the most expensive.  Only CASA could duck it up so completely, then try to patch it up and flog off as an exemplar. Gods spare us.

Why? Well you can’t expect CASA to admit the rule is a complete and utter disaster and start again. Measure twice, cut once and be cussed less, should be tattooed, in mirror writing, on every TTM forehead, as a reminder of folly.

Toot toot.
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#80
Hot off the CASA PR spin cycle - Dodgy


Quote:Part 61 Solutions Taskforce Closure Report

Executive summary

Background

The flight crew licensing regulations (Parts 61, 64, 141 and 142) which came into effect in September 2014 were subject to immense criticism from the aviation community. CASA was committed to addressing the concerns raised.

The Part 61 Solutions Taskforce was formed in November 2015 to deliver solutions to valid issues associated with the flight crew licensing regulations. The remit of the Taskforce was to ensure that known or likely safety risks continued to be addressed, that unnecessary costs were not imposed on the aviation community, and that the rules did not unnecessarily hinder participation or the potential for industry growth.

An industry advisory panel (IAP) - comprising representatives from a range of aviation industry sectors - was also formed to assist CASA prioritise the issues and provide input on proposed solutions.

The Taskforce was originally established with a nominal completion date of 30 June 2016, but with the acknowledgement that the final end date would be determined by the full delivery of solutions to critical items on the flight crew licensing regulations issues register.

Key highlights

Over 11 months, CASA has worked closely with IAP members to prioritise issues and find ways of making the transition to the new rules easier for the aviation community.

The Taskforce was a new way of working that CASA had not previously used. It represented a tangible example of the power of collaboration and cross-functional cooperation to achieve a common corporate objective.

The Taskforce's collaborative approach in the prioritisation of issues requiring resolution and the formulation, drafting and implementation of policy solutions made it significantly different to CASA's regulatory development consultation process. Feedback provided by IAP members highlighted that this strong focus on consultation and collaboration was a major factor in the Taskforce's success.

CASA was able to choose the right staff, at the right time, and bring them together into a single line of accountability reporting structure with clearly defined tasks, objectives and timelines which enabled the Taskforce to get the job done. The Taskforce was able to accelerate the work that was already underway to address the issues that had been raised by industry.

The Taskforce delivered on a large amount of work including: publication of guidance material for flying training organisations, reviewing the flight review and instrument proficiency check policies and developing a range of instruments and exemptions to allow the smooth continuation of operations until the regulations themselves can be amended.
The Taskforce received significant positive feedback from the aviation community on the Part 141 Sample Operations Manual, the Part 142 Sample Exposition, the instrument proficiency check changes and the sample competency based training and formatted syllabuses correctly mapped to the Part 61 Manual of Standards (MOS).

The permanent flight crew licensing regulation amendment package will be the final deliverable of the Taskforce. The regulations are expected to be amended in late 2016/early 2017. CASA’s formal industry consultation process will be used to communicate proposed amendments to the aviation community. Once the regulations have been amended the permissions and exemptions issued to deliver the interim solutions will be able to be revoked.

Key findings and recommendations

The Taskforce, within a short period of time, successfully delivered major solutions to assist the aviation community and CASA staff in the implementation and transition to CASR Parts 61, 64, 141 and 142. The outcomes can be attributed to the following:
  • The Taskforce's strong focus on consultation and collaboration in the prioritisation of issues requiring resolution and the formulation, drafting and implementation of policy solutions.
  • The commitment of the IAP to work with the Taskforce to resolve the issues and test the solutions.
  • The Taskforce's model and methodology allowed a balanced representation of issues and concerns and a more thorough review and testing of solutions.
  • The importance given to both the technical solutions and the human elements associated with the regulatory change.
  • The Taskforce team structure, which was suitable for a multi-disciplinary environment, quickly built an agile and flexible environment.
  • The single line of accountability approach allowed timely decisions to be made.
  • The establishment of the Shared Services team provided a dedicated administrative support and allowed the technical teams to focus on addressing regulation and policy issues, and producing the technical material and content.
While the IAP considered the work of the Part 61 Solutions Taskforce highly successful, it held the view that the establishment of the Taskforce was a reactive approach and CASA should use the Taskforce model and apply it pro-actively when rolling out future regulatory change. The IAP felt, while the air transport regulations are 'settled', they should be reviewed; and its implementation plan appropriately consulted.

The IAP recommends:
  • CASA consider more effective methods for its stakeholder engagement and consultation approach and work with the aviation community to find better ways to maximise the efficiency and effectiveness of consultations.
  • More time should be taken to develop the regulations (including a consultation process). The focus should be on getting it right rather than meeting targeted deadlines.
  • Make regulations achievable with the provision of clear pathways.
  • Develop regulations in plain language or, at the very least, the provision of plain language explanatory and advisory material.
  • Engage with the aviation community in the implementation planning for future regulatory change.
  • Implementation programs should take into consideration the human factor ramifications.
  • Engage CASA's Certificate Management Teams much earlier in the process.
  • Leverage from established communication channels between CASA inspectors and the certificate holders and their key personnel.
Based on its experience and the lessons identified in the last 11 months, the Taskforce recommends the following methods of implementation for future regulatory changes:
  • Conduct a review of CASA's stakeholder engagement approach during the regulation development and implementation phases.
  • A model of collaboration and cross functional co-operation within CASA and with the aviation community.
  • The establishment of suitable, flexible teams to work on preparation activities
  • In consultation with the aviation community establish a clear delivery framework right from the beginning, including the methodology and implementation approach.
  • Developing guidance material and acceptable means of compliance prior to implementation of regulations.
  • The development of guidance, resources and tools as solutions packages and the provision of training for all affected CASA staff and the establishment of an inspector helpline prior to the implementation of the regulations.
  • Adoption of similar online applications delivered by the Taskforce – an online forum to facilitate aviation community/CASA staff consultation; an enquiries management tool to track and monitor industry enquiries; a knowledge base tool to help CASA staff answer enquiries; an issues register and a continuous improvement process as part of both the development and implementation phases.
For ongoing work, the Taskforce recommends:
  • Relevant CASA areas maintain, support and improve on solutions delivered by the Taskforce, including Part 141 Sample Operations Manual package and the Part 142 Sample Exposition package and the online tools.
  • Continued training for CASA inspectors on outcome-based regulation and change management.
  • The Flight Crew Licensing web content be improved to help industry and staff source information.
  • Delivery of workshops to the aviation community on change management and outcome-based regulations.
  • Conversion of the Part 141 and 142 assessor worksheets into more appropriate online forms.
OK so the Part 61 Tiger Team believe, besides a few minor administrative issues, that their job is done...  Huh

Please explain?





However I still fail to comprehend why it is that our regulatory authority CASA believe Australia is so fundamentally different to most 1st world ICAO signatory States, that we require such prescriptive OTT regulations for Flight Crew Licensing.

For the sake of regional harmonisation why isn't the now 23+yr firmly imbedded and regionally adopted CAANZ Part 61 - see HERE - an acceptable rule set for the Australian aviation industry... Huh


MTF...P2 Cool
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#81
"For the sake of regional harmonisation why isn't the now 23+yr firmly imbedded and regionally adopted CAANZ Part 61 - see HERE - an acceptable rule set for the Australian aviation industry... Huh"

Not enough pages P2
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#82
"Closure"report, reminds one of that condition sort by the recently bereaved. How appropriate for Aussie GA.

The one outstanding feature of the report is talk about outcome based regulation. Obviously we don't speak the same language because any objective view of our current super prescriptive strict liability criminal aviation law could not plausibly call it "outcome based regulation". Unless of course the desired outcome (unspecified) is the continued decline of GA in Australia.

The question must be put to Parliament how can it be that after 29 years and hundreds of millions of dollars the rewrite of the "regulations" is still not finished and GA is in steep decline?

The government corporate body style of governance (much vaunted independent umpire), ostensibly for efficiency and reduce costs to the public purse has failed. How is it that the CEOs of these bodies are paid more than their Ministers? Is it because Ministers have less responsibility? AusPost boss gets ten times more than the PM. Presumably Carmody is being paid well above Chester.


The system is truly broke and if it were possible to calculate the lost opportunity costs they would be way in excess of the monster direct costs of running our aviation regulators.
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#83
61 – Used for designed purposes.

Just a note, to those who rely on ‘their’ reading of Part 61 to keep their operation running. Read the Falcon Air story closely;or, better still, have a ‘chat’ with the operator. You have the right to remain hopeful – but Part 61 can and will be used against you – should the need arise. Be careful, be very, very careful; 61 is a legal minefield, laid under the trees which all have a cunningly concealed noose, waiting to trap the unwary.

There is a tested defense - HERE - still a valid precedent. No value in the AAT but in other 'courts' it would have gotten Falcon airborne and clear. Would have taken a little longer - but it would be very effective.


Just saying. That’s all.
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