Friday, 21st December 2018
Mr Shane Carmody
Director of Aviation Safety, CASA
GPO BOX 2005
Canberra ACT 2601, Australia
Mr Michael McCormack MP
Deputy Prime Minister
Minister for Infrastructure and Transport
PO Box 6022, House of Representatives
CANBERRA ACT 2600, Australia
Dr Jane Thompson
RRAT Committee Secretary
PO BOX 6100
CANBERRA ACT 2600, Australia.
Call to withdraw proposed changes to Community Service Flights CD 1814OS
The Aircraft Owners and Pilots Association of Australia calls on CASA to immediately withdraw it’s proposed changes to Community Service Flights, as published in your discussion paper CD1814OS. Should the changes proposed by CASA be implemented, they will entirely undermine the viability of Community Service Flights nationwide and will leave thousands of sick and disadvantaged Australians without essential transport for medical needs. The proposed changes will preclude qualified pilots and aircraft owners by unnecessarily increasing the regulatory and cost burdens, further contributing to general aviation industry decline.
Throughout this past year, you have loudly espoused your commitment to a just-culture stating that CASA bases aviation safety outcomes on evidence-based risk assessment and takes a pragmatic and proportionate approach towards safety-outcomes. In view of this, any proposed changes to Community Service Flights should be based on the assessment of direct evidence and risk, not the subjective speculation by the regulator towards a possible perceived risk.
Your discussion paper (CD1814OS) published on 18th December 2018, fails to provide any statistical or accident data to support CASA’s proposed changes. AOPA Australia is only aware of two charity flight accidents spanning the past 16 years, of which we note the following important facts;
Accident 1: Occurred in 2011, PPL holder, approx. 1,000 hours experience, flying Night VFR, had owned the accident aircraft for many years. ATSB attributes the accident to a failure of the PIC to maintain lowest safe altitude of which the result was a CFIT event.
Accident 2: Occurred in 2017, PPL holder, approx. 1,000 hours experience, flying VFR, had owned the aircraft for several years. Whilst the final accident report has not yet been delivered, the preliminary report identifies that the pilot departed in inclement weather that precluded the ability to maintain VFR, resulting in inadvertent IFR and subsequent loss of control.
Whilst these two accidents were tragic, they did not reflect a failure of regulatory aviation safety standards, but rather were attributed to a failure in pilot decision making in the cockpit. This highlights a need for better pilot education and support services, along with peer mentoring – not a need for greater regulation by CASA.
Based on the factual accident information;
- Both pilots (Accident 1 and 2) were experienced PPL holders with approx 1,000 hours in command;
- Neither accident reflects a substandard approach to existing minimum experience requirements;
- CASA’s proposal to increase minimum experience requirements from 250 to 400 hours would not have prevented the two historical accidents from occurring.
- Both pilots were current in their respective aircraft and had conducted regular charity flights;
- Neither accident reflects a substandard approach to existing pilot currency requirements;
- CASA’s proposal to change pilot currency from 90 days to 30 days would not have prevented the two historical accidents from occurring.
- Neither aircraft suffered a partial or full engine failure, or any other aircraft maintenance related event;
- Neither accident reflects a substandard approach to existing aircraft maintenance requirements;
- CASA’s proposal to require AD/ENG/4 will preclude a significant number of private aircraft from participating in Community Service Flights, by requiring them to maintain aircraft engines to commercial charter industry standards. For example, the cost to overhaul a Beechcraft Bonanza A36 engine (IO-550) to comply with AD/ENG/4 can be as high as $85,000 AUD.
In all three points above, CASA’s proposed changes;
- Would not have stopped or prevented the two historical accidents from occurring;
- Do not address the relevant safety need, which is pilot support, education and awareness;
- Will result in increasing regulatory burden and costs to participating aircraft owners and pilots;
- Will result in reducing Community Service Flight capabilities nationwide;
- Will leave thousands of persons throughout regional Australia without essential transport;
- Will contribute to general aviation industry decline.
None of the changes proposed by CASA appear to be responsive to any relevant safety factors. Rather, they present as a knee-jerk reaction to a perceived requirement for the regulator to be seen to be taking action.
Furthermore, AOPA Australia is deeply concerned that CASA have moved to introduce these unnecessary changes during a Christmas holiday break when few aircraft owners and pilots can respond and at a time when Parliament has risen and won’t return until February 2019. It would appear that CASA has been very selective in its timing, seeking to avoid political interference and/or scrutiny, which is both inappropriate and unfortunate.
We also make clear that we do not believe that CASA has adequately consulted with the industry or the major charities regarding these unnecessary changes. We call on CASA to immediately withdraw CD1814OS and ask that the regulator establish a working group with representatives of each of the charities affected along with a representative of the Aircraft Owners and Pilots Association of Australia.
In 2017 the AOPA Australia met with Rob Walker, Industry Stakeholder Manager for CASA and extended an offer to help develop and deliver appropriate pilot education and support services for those conducting Community Service Flights focused on decision making in the cockpit. Whilst our offer was not taken up, we remain ready and willing to assist.
Thank you for your time and we would appreciate your direct response.
Aircraft Owners and Pilots Association of Australia (AOPA Australia)
Hangar 600, Prentice Street, Bankstown Airport NSW 2200 Australia.
PO BOX 26, Georges Hall NSW 2198 Australia.