Wednesday, December 30, 2009

New Rules for Licensing and Operations

Well, if the White Paper is correct the new rules for licensing and operations will appear by the end of 2010. Here's a discussion of some of the proposed changes.

CASR Part 61 – Flight crew licensing
Recreational Pilot Licence to be introduced to replace passenger-carrying privileges for student pilots
This was also in the draft rules of 2002 (refer to Discussion Paper 0202FS). Back then the features of the RPL were:
day VFR only, max of 180 hp, 4 seats max
authorisation for cross-country flight in Class G airspace available as well as specific controlled airfields
Class 2 medical required although solo flying permitted not over populous areas for those without a Class 2 medical

It will be interesting to see how this turns out when the details are fleshed out. One guess is that the new RPL will be very similar to the current RAA Certificate.

In 2002 there were some changes to the list of design feature authorisations:
(i) tailwheel;
(ii) retractable undercarriage;
(iii) constant speed propeller;
(iv) piston engine;
(v) turbocharged or supercharged piston engine;
(vi) gas turbine engine;
(vii) pressurisation system;
(viii) FMS (Flight Management Systems);
(ix) Powered sailplanes (also for glider category);
(x) 3 axis control ultralight aeroplane;
(xi) weight shift control ultralight aeroplane.
Note: piston engine has been included for those pilots who may have done all their flying on turbine-powered aircraft.
Back in 2002 there were also some changes to operational authorisations including aerobatics. I've already commented on how the Australian Aerobatic Club blocked some of those beneficial changes at the time but the more recent CAAP on aerobatics partly recovered the situation. My guess is that we have lost any opportunity to tidy up aerobatics any further.
All flying training conducted for issue of a flight crew licence, rating or other authorisation to be conducted by persons holding an instructor rating who are authorised to instruct in that particular activity
Current grades of flight instructor rating to be replaced by a single instructor rating with endorsements to provide flight training in specific activities
Back in 2002 the proposal was as above but we had a lot more detail:
a) Flying training for the issue or periodic review of a pilot licence, rating or other authorisation, may only be conducted by the holder of a Flight Instructor rating.
b) Check pilots and other approved persons who currently conduct training under approvals from CASA will be required to hold instructor ratings.
c) An instructor will not have to be trained to give ab-initio instruction and the current 50 hour course will no longer be required.
d) The current grades of instructor rating will be replaced by authorisations attached to the rating to give instruction in specific activities.
h) Private pilots will be able to hold instructor ratings but may only instruct to the level of their own qualifications.
l) A ground instructor rating will be introduced for persons who wish to give ground instruction and do not a hold flight instructor rating.
o) For continued use of the rating, a biennial flight review or other method of maintaining competence will be required instead of a rating renewal test.
The 2002 proposal was a major shake-up of the instructor rating.
Compare a private pilot as an instructor with the existing RAA flight instructor rating - so perhaps that will be in the new rules too. (Take a look at the new Part 91 to see whether they can charge for it though) The whole package would enable an experienced pilot to come back as an instructor to impart his/her knowledge – whether it be in ab initio training or a specialised role such as tail-wheel, warbirds or aerobatics.
Now consider this in conjunction with the new rules for flying schools.

CASR Part 141 – Flight training operators
Key proposals include
Replaces the AOC requirement issued under the Civil Aviation Act 1988 for flight training schools with a flight training operating certificate (OC);
OC to be required for training for all pilot licences and ratings, including aircraft ratings; training for other authorisations can be provided without an OC

To an instructor who focusses on the design feature authorisations listed above and operational endorsements such as spinning and aerobatics will no longer need to operate through a flying school. Of course a sole trader has other issues to deal with such as legal liability, availability of aircraft and chasing up money from customers. Let's hope that vested interests don't kill this proposal too. This has the potential to reduce the cost of learning aerobatics on tailwheel aeroplanes.

CASR Part 91 – General operating and flight rules
The remainder of CASR Part 91, when implemented, will replace the various 1988 Civil Aviation Regulations (CARs) and Civil Aviation Orders (CAOs) that relate to general operating and flight rules and will be supported by a number of Advisory Circulars (ACs). It will form a complete set of operating rules for current ‘private’ operations, and will supplement the operating rules applicable to corporate/business, air experience, aerial work, and air transport operations.
The Part will primarily consolidate and retain most of the existing rules with little change. However, a small number of new rules have been included to further ICAO compliance and enhance aviation safety.
Key proposals include:
Strict control of Portable Electronic Devices (PEDs);
Requirement for the pilot to plan to arrive with a specified minimum amount of fuel;
Altered requirement for the carriage of Emergency Locator Transmitters (ELTs);
Changes to minimum operating heights to allow flight below 500ft.
The changes currently proposed fall far short of those proposed ten years ago which is good as I recall some silly onerous things back then. Let's hope they don't creep back in again. It seems that the new Part 91 will simply reflect the current situation but be much clearer.

In the past, vested interests apparently argued against many beneficial changes and stalled the process. Let's hope that the new draft rules provide benefit to the majority of individual pilots and therefore aviation as a whole. 2010 should be an interesting year but I wonder if CASA can really finish them within this timsescale.

Happy New Year.

Thursday, December 17, 2009

Aviation White Paper

From the Aviation White Paper:
“To maintain and improve the safety of Australia’s aviation industry the Government will: …........;
>> finalise the suites of CASA’s regulations on licensing and flight operations by the end of 2010“
It has been a long while since I've looked at the draft Parts 61 and 91 so just as a start have a look at where I was 6 years ago:

GENERAL
This page is an update on the status of the new Australian aviation regulations with particular reference to aerobatics.
The big event recently was the CASA FLOT2003 Conference held in Sydney in March, 2003.
First of all, some advice for those providing comments to CASA -
Read all the related documents before making your comment. Make your comments concise and to the point. The new regulations are structured differently - don't comment on just one aspect without taking the time to understand the framework and all related sections. If you like something - say so - otherwise just a handful of adverse comments can end up in it being changed to something that you don't like.

AEROBATICS
I won't go into all the background information here. I've made my views and actions known on the internet for many years - search the Ozaeros Yahoo Group for more information. The relevant regulations are Parts 61 & 91 - you must read both together as they are inter-related. All the CASA information is at http://www.casa.gov.au/avreg/newrules/casr/index.htm
I, amongst others, put in a lot of effort towards the proposed new rules and Advisory Circular for aerobatics - the intent was to facilitate administration of aerobatics. It recognised that certain people in industry and certain members of the Australian Aerobatic Club (AAC) had the requisite skills and attitude such that administrative oversight by CASA could be streamlined.
The text below outlines the situation going into the CASA FLOT2003.
PART 61 FLIGHT CREW LICENSING Subpart P - Flight Activity & Maintenance Authorisations
"1.1.2 The following flight activity authorisations are specified in this Subpart -
d) Aerobatics
e) Aerobatics below 3000 ft AGL
f) Aerobatics below 1500 ft AGL
g) Formation aerobatics
h) Upright spin - specified type of aeroplane"
PART 91 GENERAL OPERATING AND FLIGHT RULES
91.075 Aerobatic Flight
"(3) The pilot in command of an aircraft must not perform aerobatic manoeuvres in the following circum stances without CASA's approval:
(a) below 3 000 feet AGL;
(b) in the vicinity of a public gathering or at an air display;
(c) at night."
The prior draft had 1500 feet as the minimum altitude "without CASA's approval". i.e. per the draft Part 61 above the initial endorsement would be to 3,000 ft. Down to 1500 ft was a separate endorsement (or authorisation, the new term) i.e. does not require CASA approval - built it does require authorisation from .... but .... "many" of those who commented on the Part 91 NPRM either did not read the associated material (the Advisory Circular and the Part 61 proposal) or wanted to torpedo the whole proposal for aerobatics and put administration of aerobatics back thirty years. Let's have a look at those comments.
Comment 22
"I am no medical expert however I don't understand how unconsciousness is a risk with negative G......... A former member of the Club; Dr Hilton Selvey has written to you regarding his experience and research in relation to general fitness and anti G straining techniques. We have not attached DR Selvey's comment to our own however we do respect his professional opinion and his experience in this field. Although we are not in a position to give an opinion in relation to medical and physiological effects of G on a pilot our experience with current pilots flying in Australia and the world for that matter is in definite conflict ...
Spin endorsement Paragraph 12 indicates that a spin endorsement is a legal prerequisite for aerobatic training. Further appendix 1 states that a pilot must not fly as pilot in command during spinning or aerobatic flight until he or she has been certified for spinning and aerobatic manoeuvres. This appears to be a new rule and has created much confusion within the club. I personally do not have a separate spin endorsement in my logbook and appendix 1 seems to imply that this is now mandatory..... This concludes the input from myself and the AAC at this point. Once again I would like to state our wholehearted support for this initiative...."
CASA Response "Reply pertains to the AC."
Comment 24 (at FLOT2003 a CASA officer stated that the AAC was one such response below!)
"Many respondents indicated that the minimum height for aerobatics should be initially set at 3000 feet and not 1500 feet as proposed in the regulation.
CASA Response "CASA agrees."
Disposition "Revised drafting instructions submitted to raise the height back to 3000 feet, as is the current requirement."
Comment 187 Guidelines for Aerobatics - Ref AC 91-077
"Many of my comments on earlier drafts have been incorporated. Some outstanding issues:
1. References the text in para 8 refers to data from NASA but there's no NASA reference listed. Kermode is quoted in para 12.2 but not listed.
4.1 utility category may be certified for limited acrobatic manoeuvres the utility category refers to design load factors and design airspeed there being no requirement to certify any acrobatic manoeuvres.
4.8 a pilot new to aerobatics should have a check up with an Aviation Medical Examiner prior to acrobatic training? Why? What do AMEs know on this subject?
9.1.9 effects of +0 can be counteracted by pulling the head down between the shoulders? I have never tried this in an aeroplane. In the safety of my own home I have attempted this but was unable to achieve that condition.
10.3 refers to G loadings between normal, utility and acrobatic categories. Consider a note that design airspeeds vary significantly too.
10.8 refers to limits, including maximum flick manoeuvre IAS. FAR 23 only refers to recommended entry speeds and that's what is typically in the AFM or POH. It is rare to have a maximum flick manoeuvres LAS it is usually a range of recommended entry speeds or just a single recommended entry speed. I certainly agree it should be treated as a limit....
Appendix 1. When this was drafted, two to three years ago, Appendix 1 was considered to be interim. Now that CASR 91 is being delayed while the other regulations are developed were at the point where Appendix 1 needs to be removed from this AC and issued as a separate AC as it relates to CASR 61 the draft itself identifies this intention on the very last page......e
Transition - I note the intent for an appropriate transition phase. Consideration needs to be given to transition to the new endorsements in terms of minimum heights. Existing aerobatic endorsements should remain valid for aerobatics above 3000 ft. Many of the low level acrobatic approvals have no expiry date. Will these remain valid?"
CASA Response
"(1) Referencing is reasonable given that this is an AC and not an academic paper.
(2) Definition of utility category points to the flight manual for definition of the aerobatic manoeuvres, which are permitted.
(3) A Designated Aeronautical Medical Examiner is trained to make a medical assessment of a pilot according the type of flying they may be undertaking and may be aware of factors that a General Practitioner may miss.
(4) Entry IAS is covered by the statement 'maximum flick manoeuvre IAS'.
(5) Appendix to be deleted and incorporated into Part 61."
Disposition "Change to AC carried out in line with the CASA response above."

Pilkington's Views on Regulations Related to Aerobatics
Well, the intent here is to limit my views to those new regulations which apply to aerobatics however they will stretch to some related issues. Let's start with that incredible Comment #24.
Comment 24
"Many respondents indicated that the minimum height for aerobatics should be initially set at 3000 feet and not 1500 feet as proposed in the regulation.
CASA Response "CASA agrees."
As the 2002 version of draft 91.075 did not propose that the minimum height for aerobatics be initially set at anything other than 3000 ft I'm surprised at this comment. The 2002 draft 91.075 simply stated that aerobatics below 1500 ft required CASA approval.
The draft AC 91.075(0) has been available for review in its current form since September, 2001. Appendix 1, Para 3.3 is quite clear on the subject of initial approvals for aerobatics:
"Pilots may be certified as safe to conduct all the primary aerobatic manoeuvres above a minimum height of 1500 feet, but must not be cleared for aerobatic manoeuvres below their individual spin recovery certification. A minimum height of 3000 feet is recommended for most initial approvals."
Para 2.3 also refers to limitations for inexperienced pilots. The AC also outlines requirements for aerobatic flight instructors, training and the provision of an Operations Manual which would detail the conduct of aerobatic training. This is the mechanism by which CASA would control the process for training and issue of approvals for aerobatics down to 3000 ft; and down to 1500 ft.
The significance of the height in 91.075 relates to CASA approval - it sets the level at which CASA itself must issue the approval to perform aerobatics as distinct from an authorization from a authorised flight instructor (or other person). The 2002 draft 91.075 proposed 1500 feet as the limit below which CASA would directly issue approvals to perform aerobatics. Approval to conduct aerobatics at all requires an authorization and I refer to the draft for Part 61. An authorization to conduct aerobatics below 3000 ft (down to 1500 ft) is a separate authorization from that for aerobatics (above 3000 ft). This information on the intent of authorisations related to aerobatics has been publicly available since March 2002.
This proposal was widely discussed between CASA and industry some years ago. I am disappointed that CASA has lost that corporate knowledge of the development of the proposal. I am surprised that those who commented did not (apparently) adequately read the Advisory Circular nor the Part 61 Discussion Paper which clearly confirmed that the initial minimum height for aerobatic authorizations remains 3000 ft.

On the subject of physiological effects which was the subject of Comment #22 and #187. I recommend consideration of this work from the USN: http://www.nomi.med.navy.mil/NAMI/GTIP.PPT It provides a useful update to the material of the draft AC (which was derived from FAA AC - 61-67) - consider the comments there which support the views of Dr Hilton Selvey over the older work reflected in the draft AC 91.075(0).
From discussion with Dr David Newman late last year - he would be willing to act as a consultant to CASA on these issues. For those who don't know Dr Newman: MB, BS, DAvMed, PhD, MRAeS and Director- Aerospace Physiology Laboratory, RMIT. He is also on the Committee of the Aviation Medical Society of Australia and New Zealand. http://www.amsanz.org/Australia/home.html
Also, despite CASA comments in the SOR, I find nothing regarding the effects of G in the DAME's Handbook at http://www.casa.gov.au/manuals/htm/dame/dame.htm

PART 61 FLIGHT CREW LICENSING Subpart P - Flight Activity & Maintenance Authorisations
"1.1.2 The following flight activity authorisations are specified in this Subpart -
d) Aerobatics
e) Aerobatics below 3000 ft AGL
f) Aerobatics below 1500 ft AGL
g) Formation aerobatics
h) Upright spin - specified type of aeroplane"
I generally support the above - the following notes are more specific on each line item.
In particular, I agree with d), e) and f). This provides a consistent and reasonable process for authorisation of aerobatics throughout the three regimes - above 3000 ft, down to 1500 ft and below 1500 ft. I note that NZ has implemented similar regulations and these should be reviewed for consideration to assist in drafting Part 61 here. http://www.caa.govt.nz/ Their 91.701 relates to our 91.075 but goes further in spelling out the same three regimes - above 3000 ft, 3000 to 1500 ft and below 1500 ft. Their Part 61, Subpart L relates to aerobatics and has similar provisions to that of the draft AC 91.075(0) Appendix 1.
I note that Appendix 1 of draft AC 91.075(0) is to be removed from that AC and be incorporated in Part 61. I support that Appendix 1 in general however it requires substantial improvement as follows. My comments assume that it is retained as an Advisory Circular.
- refer to paras 3.1 and 3.3. For operations below 3000 ft, the authorisation should combine aerobatics and spinning. Part 61 draft does not provide for separate spin authorisations below 3000 ft. Apart from being the current situation, the rationale is that any spinning conducted below 3000 is either quite limited, being part of a competition sequence, or highly specialised, being part of a display, so the overall competence of conducting that operation with provision for identification and correction of departures from the planned sequence is the important issue.
- para 3.4. Using 150 kts as the boundary of a performance range is inappropriate - in fact, using airspeed as the sole parameter is inappropriate. Classification of types into conventional GA types, warbirds and jets would be more appropriate.
- sections 4 and 5 were drafted to reflect current practice and need to be edited to conform to the draft Part 61 terminology
- para 4.5 consequently must be altered to delete the CASA action, except where an authorised person is not available
- para 4.5 - I recommend that aerobatic approvals down to 1500 ft be permanent and that lower levels be renewable every two years. i.e. ongoing competence at the 1500 ft level is relatively easy to maintain or regain - note that the draft approval letter specifies the currency requirements.
- Annex A, the form of the test. The application form requires editing to conform to the draft Part 61 terminology. That form specifies a log book endorsement of 10 manoeuvres contrary to para 2.7 of Appendix 1. The flight test should comprise the applicants normal sequence plus demonstration of recovery from a vertical climb, before a tail-slide, rather than the list of manoeuvres currently provided. Para 3.3 must be amended to reflect that change. Note that para 4.5 provides for any restrictions appropriate from consideration of the scope of the test. For approvals down to 1500 ft I recommend a guideline that the Australian Aerobatic Club's Sportsman Competition Sequence (current or recent) be the test sequence.
On the subject of transition to the new regulations, I recommend that existing aerobatic approvals should be carried over to the new system with the same height limitations. I note however, that any permanent low level approvals should have a termination date consistent with the renewal period defined in that draft AC 91.075(0) Appendix 1. Pilots who have significant experience at formation aerobatics until now should be granted a formation aerobatic authorization based on providing evidence of that experience to CASA.
For the author of Comment # 22 who does not have a spin endorsement - it needs to be done - the existing requirement for a spin endorsement separate from an aerobatic endorsement has been around for a very long time. The recent addition of a separate inverted spin endorsement has been around for about ten years.
http://www.casa.gov.au/download/orders/cao40/4000.pdf gives details of the spin and aerobatic endorsements - note that a spin endorsement is a prerequisite to an aerobatic endorsement.
On the subject of the upright spin authorization, paragraph h), there is some merit in limiting the authorization to specific types. This is currently the case for instructor training authorizations but is a new requirement for pilot authorizations. The current upright spin endorsement is not limited to any particular type. We must first consider the case for its introduction. I am unaware of any safety issue related to specific types. Certainly, there is a variety of different spin and recovery characteristics however different aircraft types have many other features which can equally be considered as safety issues. The issue of different spin characteristics should be addressed by the following actions:
1. improved education on spinning by an Advisory Circular
2. a limitation on any spin authorisation if the training is conducted on a type which cannot fully demonstrate a "standard" spin eg the Airtourer
The relevant USA Advisory Circular is AC 61-67C Stall and Spin Awareness Training http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular/AC61-67C.pdf
I envisage an Australian AC having different scope than the USA AC as the purpose is different - being more specific to spin training, excluding the stall awareness information and including information on various spin and recovery characteristics which may be encountered.
Finally, CASA omitted the authorisation required for inverted spinning.

Part 61 Subpart L proposes significant changes to instructor ratings, which I support. Again, to fully understand the proposal it is essential to read the draft Part 141 on Flight Training. To refer to the example that was quoted at a Workshop at the FLOT2003 conference: a 20,000 hour experienced pilot would add a lot of value to the training environment - he/she would need to add competencies in instruction plus appropriate standardisation requirements - but there's no reason why he/she should be regarded as an inexperienced instructor. The current system of instructor does not recognise, in fact discriminates against, the ideal learning situation of experienced operational pilots returning to become instructors.
Specifically, the typical profile of instructors often excludes specialist skills such as advanced, or low level aerobatics, which is sometimes best serviced by sport pilots having the appropriate skills, attitude and competence in that specialist area combined with instructional and assessment skills.
I note the proposal presented at the FLOT2003 Conference by Roger Weeks, CFI of the RACWA. He proposed the retention of the existing grades and the introduction of a fourth grade for specialist instructors. That does nothing to remove the discrimination against that nominal 20,000 operational pilot returning to the training environment. This proposal also offers requirements for flight training authorisations which are relevant so let's consider them here, along with the CASA proposal. I have a concern with a specification of number of hours, spinning for example - its not like night flying where its either night or its not. Is it actual hours of performing spins or simply hours of flying with the sole intent of performing spins? The performance of the aircraft has a big effect on the outcome with the latter definition. We need to consider that an hour on a flight with the sole intention of spinning in a low performance aeroplane achieves very much less than an hour in a higher performance aeroplane.
Weeks proposes that tail-wheel training would require a minimum of 5 hours PIC on tail-wheels (after the basic tail-wheel authorisation) plus 2 hours of instructor flight training. CASA proposes 20 hours PIC with nil additional instructor training. I'd combine the two requirements - 20 hours PIC plus 2 hours of instructor training. Tail-wheel operations requires a new set of habits - my insurance company told me that one of the significant factors in tail-wheel accidents was inexperienced instructors.
Weeks proposes that training for aerobatics above 3000 ft would require a minimum of 5 hours PIC in aerobatic flying (beyond the basic aerobatic authorisation) plus 2 hours of instructor flight training. CASA proposes 20 hours PIC in aerobatics plus 5 hours specific instructor training. Refer the draft Appendix 1 to AC 91.075(0) which does not have the 5 hours instructor training. I support Weeks proposal in this case.
Spinning training would require the basic spinning authorisation plus 2 hours of instructor flight training in spinning. CASA proposes 5 hours of spinning plus 3 hours of specific instructor training. I support the Weeks proposal - along with the training authorisation being type specific.
For training in aerobatics below 3000 ft and down to 1500 ft, CASA proposes that the instructor simply hold the relevant authorisation. i.e. as per the current requirement. I support this.
For training in aerobatics below 1500 ft, CASA proposes that the instructor simply hold the relevant authorisation. i.e. as per the current requirement. I recommend specific instructor training - ground training only to develop advanced knowledge of the relevant subjects and assessment of pilot attitude.

OTHER REGULATIONS
If I was involved full-time in the flying side of the industry I'd be taking a close look at all of the new regulations presented at the CASA FLOT2003 Conference. For example:
91.150 Parking or stopping of aircraft
"(2) The person responsible for parking an aircraft must ensure that it is secured so as to ensure ..."
Looks OK doesn't it - but it was a lot different in the previous draft!
91.335 Documents to be carried
As an instructor I can take a student on an aerobatic training flight to the eastern boundary of the Moorabbin training area with the usual aircraft and pilot documentation on board only BUT if I do a similar flight myself as a private operation I must take a swag of maps (its within 20 nm of the edge of the VTC so I need the VNC as well) plus the complete ERSA.
At the FLOT2003 conference our group recommended that much of this be deleted from the regulation and incorporated in an Advisory Circular.
91.580 Aircraft equipment and instrument visibility and accessibility
"(1) The operator of an aircraft must ensure that navigation instruments that are required for use by its pilots are arranged soa s to permit the pilot to see the indications readily from ..."
Given the wide range of opinions between pilots does CASA provide a certificate of compliance against this regulation when the navigation instruments are fitted? If installation is approved per Reg 35 or TC or STC - does that provide evidence that this requirement is met?
91.585 Aircraft lighting requirements
"(1) The operator and the pilot in command of an aircraft on a flight in poor light conditions ... must ensure that the aircraft is fitted with, and display, lighting equipment as follows:
(a) lighting to illuminate instruments and equipment essential to safe operation ...
(b) cockpit lighting for general illumination of equipment, and for study of checklists and flight documents;
(c) cabin lighting sufficient for all passengers to find harness connections ...
(d) navigation lights;
(e) an anti-collision light;
(f) at least 1 landing light;
(h) a fully-functional electric .. torch ..."
91.590 Anti-collision and navigation lights
"(1) The pilot in command of an aircraft fitted with red anti-collision lights must ensure that the lights are displayed before its engine is, or engines are, started ....
(4) It is a defence ... that ... the safety of aircraft was not affected ....
(6) An offence against subregulation (1), (2) or (3) is an offence of strict liability."
The subject of "strict liability" was a controversial subject at the FLOT2003 conference and there's sure to be plenty of comment elsewhere. Enough to say here that its not a defence that the anti-collision lights are unserviceable (referring to 91.590) - if they are fitted then there's a penalty of 25 units if they are not turned on and working. Referring to 91.585 - if you don't have all that equipment then you must not fly in "poor light conditions" - quite a reasonable airmanship philosophy but as a regulation I'd like to see "poor light" defined (can't be a single definition as the requirement covers visibility both internal and external to the aeroplane) - does this mean that an aeroplane certified for day VFR cannot fly in some day VFR conditions? Perhaps all of this would be better in an Advisory Circular.

Saturday, November 14, 2009

Draft Maintenance Regulations

CASA's new draft maintenance regulations are available for comment until 18th December.
http://www.casa.gov.au/scripts/nc.dll?WCMS:STANDARD::pc=PC_93516

A few years ago I was in Canberra for a presentation by CASA near the start of this project. The intent was to base it on EASA with local improvements for “world's best pratice” etc. The principle was to have outcome based regulations rather than prescriptive regulations.

My little experience with EASA is that they are very bureacratic and only make general aviation more difficult. My quick look at CASA's draft regulations indicate that they have failed to make them outcome based – they are very prescriptive and will introduce more bureaucracy and expense to us.

A few examples.

I can currently do the second inspection of the control system on an aircraft (mine in particular) after maintenance. The new regulation would make it very difficult for me to do that.

We currently have a maintenance release with a requirement for a daily inspection to be certified. The draft requirement is for a technical log with the pre-flight inspection to be signed by the pilot.

Take a look here to see how NZ does it.
http://www.caa.govt.nz/Advisory_Circulars/ac91-6.pdf Reasonably sensible in my opinion – it is a daily system, not a lot different than what we currently do and provides for a variety of means to comply.

However, the CASA requirement is "pilot in command of an aircraft for a flight must ensure that the information about the flight is recorded in the flight technical log for the aircraft (unless CASA has approved another means of recording the information)." No longer a record at the end of the day's flying. Take a look at the NZ AC again to see what you can expect when CASA fills in the details with their AC. Remember, that will be required after each and every flight.

Read that rule above in conjunction with a new requirement for the pre-flight inspection, if required by the aircraft's flight manual. The Decathlon and Laser manuals, for example, are quite specific on the pre-flight check – not an issue as it includes the usual things that a pilot would do anyway. Do you think that CASA will expect that it be certified in the new technical log or not? I didn't see a requirement for a daily inspection anywhere in these draft regulations.
Consider how you operate your aircraft, say, at an aerobatic contest or practice weekend with several flights back to back.
More unnecessary paperwork and more time wasted.

The requirement for fitting a fabricated part – only if it has been made by the approved maintenance organisation doing work on the aeroplane. A simple part such as the special canopy bolt for the Pitts – the maintenance organisation had to contract the work to a specialised machining company but it seems that is no longer acceptable. The alternative is to buy the original factory part or a get that other company to get that bolt approved as a PMA'd part.

Replace a few screws on your aeroplane. Make sure that they are accompanied by evidence that they conform to the specification and are eligible to be fitted to the aircraft. Much more prescriuptive than the current reegulations I believe.

It seems that these draft regulations require more scrutiny by those people who will pay more as a result. i.e. everyone should take a look and respond to CASA. Why can't we do things the way they are done in the USA? I thought that was the original intent of regulatory reform twenty years ago. Last time I asked that of CASA in a meeting in Canberra I was told that the FAA would like to change their regulations in the same way. Guess what – the American aviation community wouldn't let them. The Australian way is to ignore drafts and simpy whinge when the new requirements are imposed on us - it is time that we changed our approach to CASA.

Tuesday, November 10, 2009

Spin Placard

New spin placard, well not really new as it has been in FAR 23 for many years but only newly certified airplanes will have it. Worth noting as it emphasizes a limitation on the number of turns in a spin based on what was tested.
[(d) For acrobatic category airplanes and utility category airplanes approved for spinning, there must be a placard in clear view of the pilot--
(1) Listing the control action for recovery from spinning maneuvers; and
(2) Stating that recovery must be initiated when spiral characteristics appear, or after not more than six turns or not more than any greater number of turns for which the airplane has been certificated.]
Aerobatic category airplanes are normally tested to 6 turns and with a comprehensive spin matrix of configurations and modes so your favourite video on Youtube doesn't count for much. i.e. the recommended maximum number of turns in a spin is 6 (there are physiological effects on the pilot which also support that same limit).

Friday, November 6, 2009

Sport Aerobatics Magazine - safety articles

There have been some interesting articles in Sport Aerobatics magazine this year.

One in the October issue that I have just received: “Making Safer Takeoffs”

“... The overabundance of horsepower and the ability to climb out at an obscene angle is a great way to demonstrate one of the highest-performance maneuvers of the entire flight. … As aerobatic airplanes have become more powerful over the years, excess horsepower has seduced many aerobatic pilots into flight profiles that will not tolerate an engine failure. …
let's say you are at 300 feet above ground level (AGL) after takeoff and the engine quits cold … Your airspeed is 90 mph … and your climb angle is 30 degrees. Wait about two seconds, because that's your typical reaction time in spite of what you might think … As you shove the stick full forward, the airspeed will continue to drop back … Now you are sinking and stalling … Now look at your energy state. You have no airspeed to work with, and you are going down rapidly … You need a descent angle of about 30 degrees to start building airspeed … You're going through 150 feet now with the ground coming up fast … Either way you are out of options and you will hit the ground at more than 20 g's, plenty hard enough to ….

Get some altitude someday and try it...even when pulling the engine back to idle power, you will be in for a surprising altitude loss, but nothing compared to a surprise engine failure. … Recognise a steep climbout for what it is: a deviation from established safe procedures. … Observers may then recognise you as one who really does know how to handle a high-performance airplane.”

Another in May, the annual safety issue: “Why it's important to follow briefed contest operating procedures”

“ … Pilots taking off were briefed to fly an upwind leg followed by a right turn into the holding area when clear of the runway. They were instructed not to perform “zooming” (an extended ground effect followed by a steep rapid climb) takeoffs. …. The incident pilot taking off performed a zooming takeoff during which he performed a sharp steep-banked 90 degree right turn at approximately mid-field. … The collision courses of the two aircraft were visible to most people at the contest …

As aerobatic pilots, we are amongst the pinnacle of skilled aviators. As an organisation of aerobatic pilots, our goal should be to always conduct ourselves in a manner that is an example for and the envy of other vaiators. Where there is an aerobatic contest, there should be pilots marvelling at the decorum of our well oiled machine. That is not possible unless everyone practices the superior judgement that sets a superior pilot apart from a pilot with merely superior skills.

The primary goal of contest organizers is to send everyone home in the same number of pieces that they showed up in, namely one. ...”

I wonder how many aerobatic pilots even bother to read them or take any notice?

Friday, October 2, 2009

Regulatory Review Program

I just have to agree with this editorial:

"We can’t pinpoint the exact date, but readers keep reminding us that it’s 21 years this September since CASA launched its regulatory review program (RRP) to upgrade our dismally concocted, confused, contradictory and contaminated regulatory structure. The program set sail with the seemingly modest goal of introducing clear and concise regulations that were fewer, simpler, more enforceable, more appropriate, and in harmony with the rule structures of other nations.

And there was lots of industry consultation. Since the program began in 1988, we’ve had four PMs, at least as many aviation-responsible ministers, four CASA directors, and by now something well over $200 million in ongoing costs. CASA’s legal department has grown, shrunk, and is now growing again, but the sheltered regulatory review workshop proudly sails on through dark, uncharted waters, seemingly still attached by a long mooring line to its point of departure.

Every few years we’re told that the task is almost ended, but the end seems no closer. Depending on who you listen to the villains include lack of consultation, excessive consultation, lack of direction, political interference, political disinterest, management and organisation structure changes, bureaucratic intervention, and bureaucratic inertia. The program however continues to set new records.

We’re told that the US FAR Part 43 is something like 20 pages, and the NZ equivalent where they use the same size A5 paper, runs to about 32 pages. Our sources say our FAR Part 42, the equivalent, is running to 162 A4 pages, which would probably be somewhere between 250 and 300 A5 pages. One observer notes that at least this week our harmonisation seems to be leaning towards the FAA, because recent press releases and CEO comments are now spelling harmonisation with a Z.

High safety standards indeed!

Congratulations"
From http://www.aviationadvertiser.com.au/2009/09/twenty-one-this-month/

Tuesday, September 22, 2009

Aerobatic Contest Rules

Last year I developed some rule change proposals for discussion and I believe that some-one submitted them so time to compare those with the last round of rule changes.

Rule #1.8 still has liability insurance at $1M. That doesn't cover much damage if you think about it. They'll go after the event organisers for the rest (the event insurance policy excludes aircraft accidents). Also, insurance policies have contests as a general exclusion so perhaps the aircraft's policy isn't even valid. Personally, I would not get involved with running a contest with that approach to risk management.

Rule #2.2 still does not clarify the responsibilities and authority of a safety pilot. Furthermore it allows a member of the AAC with a low level permission to be a safety pilot. The current conditions on permissions per the CAAP would seem to be contrary to this. There is nothing in the assessment for an individual's low level permission which considers riding along as safety pilot – whatever that is as there is still no definition for it.

Also, despite some categories being permitted to have a safety pilot, rule #2.3 i) still requires a contestant to hold an appropriate low level permisison. i.e. if a pilot doesn't have a low level permission then it prevents participation in the contest per rule #2.3. i.e. what is the purpose of a safety pilot?

Rule #3.8 still does not allow for special cases of competitors arriving late. Even if the contest jury and the other competitors agree it still can't happen.

Rule #4.15 Height Limitations
Well, Intermediate was changed but still an issue with Sportsman and Graduate.
Graduate and Sportsman pilots are expected to have a Low Level Permission to 1500 ft. The current rule 4.16 provides for disqualification if judged to fly below 1500 ft. The other categories have a buffer of 1-200 ft where a points penalty is awarded. The proposal will provide for that same buffer to Graduate and Sportsman. Such a buffer recognises that judgement of height is not absolute.
The effect will be increased safety which is the objective of the disqualification rule. With a specified higher limit, pilots will be obliged to fly higher per the rules rather than consider 1500 ft to be the lower limit. A higher margin of safety will result. Most pilots in these categories already use an effective lower height limit of about 1700 ft to ensure that they are not disqualified as a result of inaccuracy of judgement.

Rule #4.16 relates to the above.
There is a clear statement in the rule “An infringement of the lower disqualification level must be agreed by at least a two-thirds majority of the Judges” which is ignored – people in Graduate and Sportsman are being disqualified on a simple majority rather than a two-thirds majority as required.

Rule #4.17. The Aerobatic Performance Zone, was not changed.
The CASA rules relating to the deadline applies only to aerobatics flown below 1500 ft so is not applicable to Sportsman or Graduate. The location of the Zone itself per the general rules for conduct of aerobatics should be adequate for the categories flown above 1500 ft.

An approximate tolerance is specified for measurement of distance for the location of the judges. Some judges have been observed to be located as close as approx 100 meters from the edge of the Zone and, as a result, penalised pilots for flying too close to the judges. Pilots fly in the defined Zone and expect the judges to be located per the rules. This rule change would make it clearer to the judges how far from the edge of the Zone they should be located.

Rule #5.4
The rule for on the maximum number of figures for a Sportsman Free was changed from “same as current compulsory” to “12”.

Rule 5.1 refers to Sportsman Programme 2 as primarily the Free Programme. Rule 5.4 also refers to it as the Free Programme and notes that a competitor has the option of reflying the Known instead of the Free. I.e. the norm has become flying the Known twice whereas the clear intent of the rule is to fly the Known and a Free.

The original rule was the same as is proposed. i.e. no limit on the number of figures. The IAC has been running successfully with this rule for many years. When the rule was changed the rationale was that it was not fair to allow a Free with more figures than the Known however this simply entrenches the wrong approach of flying the Known twice. The approach should be to encourage competitors to fly a Free sequence as intended by the rules. The 2009 rule change did encourage a very few to fly a Free programme but it has not gone far enough.

A limit on the number of figures for Sportsman category figues is unduly restrictive. It is very difficult to develop a Sportsman Free. The result is a strong discouragement to the development of Free sequences which is contrary to the overall rules. All competitors have the option of developing a Free sequence so this proposal retains fairness for all. (Perhaps the AAC could offer a default Free as well as a Known).

Recent competitions are noted for high scoring Sportsman flights. This rule change will provide more of a challenge with no increase in difficulty so contribute to more successful contests. The challenge comes from the additional preparation needed to develop and practice a Free. In the IAC, all acknowledge that a Free should be flown by competitors at National level.

Monday, June 22, 2009

Error Management Roadshow

I was fortunate to be able to attend this seminar by Tony Kern today.

I believe that CASA has done something extremely significant by organising this. Unfortunately, only a small proportion of pilots and engineers are able to attend. Even more unfortunately, only pilots and engineers knew about it - everyone in this country should undergo the general version of this and it must become part of secondary education.

"Internationally recognised error management expert, Tony Kern will be presenting practically–focused seminars nationwide. The full-day seminars will cover:
background to human error: physiology and psychology
violation and error-producing conditions & countermeasures for LAMEs & pilots
developing a personal safety management system (PSMS) to integrate seamlessly with organisational safety management systems
flight discipline & compliance: the cornerstone of professionalism practical error management – tips & strategies for individuals.

Each seminar participant will also receive:
Blue Threat Fieldbook – tailored to Australian conditions, so that you can track your own errors & develop personal countermeasures
A year’s free subscription to online assessment tools"
http://www.convergentperformance.com/gwoe/default.asp

See also: http://www.hikoudo.com/index.html

Friday, May 15, 2009

Downwind Loop

There was plenty of free time at the National Championships at Parkes so I filled in some time by knocking up some proposed Known Sequences for Sportsman and Intermediate. There wasn't a lot of time to submit them so grabbed some Knowns from the IAC and BAeA and set to work. I have just heard that I was severely criticised for putting a downwind loop in one of those sequences. I was also told that one of the persons who criticised me actually had a downwind loop in his proposal. Furthermore, neither of my sequences had a downwind loop.

Loopy!

Monday, May 11, 2009

The Best Aerobatic Display

I've watched very many memorable aerobatic displays over the years. As a kid I used to go to the RAAF Laverton displays; only much later did I meet the pilot of many of the displays I'd been watching and had an opportunity to work with Gil. Then there was Aub, who taught me aerobatics, and his displays in the Cessna Aerobat. A year in the UK in the '70s gave me the opportunity to see the Rothmans Team plus Barry and Neil. Then living in the USA (pilots' paradise) there was Greg, Patty, Sean and Bob. At local displays: Chris and Pip. Back in the eighties there was the Philips World Aerobatic Challenge with Geoff, Frank, Kermit and Eric. Can't forget Xavier or Yurgis. Who have I forgotten?

I won't venture into any judgement on their relative abilities. All memorable displays.

Not taking anything away from the skills that these people have demonstrated but last March, at Redcliffe in Queensland, I saw a display and just had to comment to the pilot afterwards that it was the best aerobatic display that I had ever seen. Let's consider it against the competition criteria for the Unlimited Four Minute Freestyle Programme.

Technical Merit (160K)

“Use of Many Different Areas of the Flight Envelope – 40K”
Yep, full marks.

“Exploitation of Aerodynamic Controls and Gyroscopic Forces – 40K”
Nil gyroscopic manoeuvres but then again people used to say that to do a nice lomcevak all you need is a Pitts and a heavy hand. I wouldn't take many points off for that consideration.

“The Clarity of the Execution of Individual Manoeuvre Elements – 40K”
Yep, full marks.

“The Combination of Manoeuvre Elements in a Wide Variety of Figures Flown on Different Axis and Flightpaths – 40K”
Slight downgrade as one manoeuvre was a cloverleaf with the associated repetition – however that earned more points below.

Artistic Impression (160K)

“The Pleasing and Continuous Flow of Figures – 40K”
Full marks.

Contrasting Periods of Dynamic and Graceful Manoeuvres – 40K
Full marks.

Presenting Individual Figures in Their Best Orientation – 40K
Full marks.

Placing Individual Figures in Their Optimum Position – 40K
Full marks.

Positioning (80K)

Symmetry – 40K
Perfect.

The Performance Zone – 40K
Just perfect.

All of those I mentioned above would score very high against this criteria but this flight I saw recently stands out. Just plain first class.

Bob Tait in a 7GCAA Citabria.

Sunday, March 22, 2009

Pitts & Decathlon Update

My last blog at http://davidjpilkington.blogspot.com/ was about preparation for the National Aerobatic Championships at Easter. I've also sent some emails to a few people to start discussion about the logistics of getting there. Taking a Pitts or Decathlon with two people doesn't leave a lot of room to take luggage plus some useful stuff for the aeroplane. As usual, diddly squat response to my emails so I'll proceed with my own plans to suit myself – perhaps I'll even drive up with my wife (if the Airtourer option doesn't work out) and see what options I have for flying when I get to Parkes.
My Decathlon, JIR, probably won't be going but that's another option for my wife and myself. If it does go it will, of course, be available for others to fly at the standard rate at Moorabbin. However, it would be good to get our “new” Pitts S-2A, MCR, there instead.
Oxford's Pitts, SZE, will definitely be there with Rob and David taking it up. I expect that a standard Decathlon, probably ITG, will also be going up.
At this stage I'm not sure Gerry's Super Decathlon from Brisbane nor Jock's Super Decathlon from Lilydale. Hopefully both of them will make it.
So, there are plenty of aeroplanes for people to fly at Parkes. Closing date for entries was over a week ago and I see people still trying to organise entries and time off work etc. I wonder why entries had to close a month before the event.
I have just received the invitation to the Civic Reception at Parkes however 5 pm on the Thursday may not work for me. Practice takes priority over cocktail parties but the way things are going I'll be lucky to arrive by then. Incidentally, the invitation doesn't say cocktail party so maybe it is a just us standing there while people make lots of speeches. Arriving on Thursday should give me one practice flight in the box on Friday before the contest starts. I see that the rules state that each competitor shall be allowed one training flight in the box. My view is that each pilot is allowed only one flight in the box – one argument put for the Nationals to be held at Parkes is that the contest should not be at anyone's “home base” so that no-one has an advantage by being more familiar with the box. So, why allow people to practice there for a week or so before the contest?
Finally, a note about daily inspections and pre-flight checks of the aeroplane. It seems that some people are unaware of the responsibility associated with signing the maintenance release to certify that they have inspected the aeroplane per the required checklist and that it is serviceable. A couple of weeks ago I observed that all tyres on JIR looked a little low but I didn't have a pump with me and I wasn't going flying so I thought that it would be picked up by the next pilot. I returned a week later after it had done several flights and the tyres were obviously still low. The tailwheel in particular had an obvious deflection which meant that it was only 10 psi. I wonder how many pilots know what the pressure should be? If not, you are unable to conduct the daily inspection! If not, you are putting yourself at risk by not conducting an adequate pre-flight check. I've seen what happens if the tailwheel tyre runs off the rim.
I hope to see you all at Parkes next month.

Tuesday, February 24, 2009

2009 Nationals

Well, I just managed to get to the Victorian Aerobatic Championships with our “new” 1974 model Pitts S-2A. VH-MCR was formerly N20MC and was imported to Australia at the end of 2008. We did quite a bit of work on it including rebuilding much of firewall forward and tarting up the paintwork. It flew for the first time in Australia on 18/2/09 and took a few flights to get the rigging just right. I arrived at Tocumwal on Thursday, the day before the contest started so my first contest flight was also my first aerobatics in MCR as well as my first sequence in a Pitts for some time. Consequently I stayed high which, combined with the smoke from the bushfires, displeased the judges. Pitot-static problems aggravated the situation and resulted in some breaks, unnecessary in retrospect.

After the contest a formation sortie with Rob in the other S-2A from Moorabbin, VH-SZE. You should see the photos from this in a future issue of the AOPA magazine. Then departed for Moorabbin with Rob and Bart in SZE. SZE is definitely a few knots faster which is not surprising given the old wing with frise ailerons plus the big beacon on MCR.

Apart from the distraction of the Avalon Airshow in March there's plenty of time to prepare for the Nationals. My Free sequence needs a little bit more development. I've been using OLAN which is excellent for my requirements. Beats me if I'm going to pay for Microsoft Visio etc just to make up one sequence every 5 years or so. The California Freestyle guidelines are still valid even though they were developed over 20 years ago. Alan Cassidy's book, Better Aerobatics, also has some useful guidance on developing free sequences (buy his Aresti software if you're an up and coming pilot as you'll use it a lot as you progress to Advanced category).

The most important part of the preparation will be practice, ideally with critiquing from the ground by some-one with a tape recorder. I don't need some-one telling me what to do over the radio – I want detailed refinements to be considered in depth when I get back on the ground. Perhaps a weekend training camp at either Kyneton or Tocumwal near the end of March.
Practice of the Known and my final Free sequence is obviously going to be a big part of it so too will be performances of a number of Unknown sequences. The IAC has a made some Unknowns from 2008 public so there is plenty of raw material there.

Most serious competition pilots practice solidly just prior to the Nationals but it is important not to overdo it. The question is where? Rules state that “All competitors will be allowed one training flight for familiarisation with the local conditions over the performance zone“. I've always taken that to mean that no practice at the contest venue is permitted prior to official practice at which one flight is permitted. That is consistent with those people who want the Nationals at a site which is not used for practice throughout the year. On the other hand there are some who turn up at the venue two weeks prior to the contest and practice solidly – sort of makes a mockery of any policy not to allow pilots to become familiar with the Aerobatic Performance Zone at the contest site. Regardless, I see that the contest officials condone practice prior to official practice on Friday. My plan is to arrive on Wednesday to get two serious practice flights in. All practice flights mirror the competition scenario, beginning with the pre-flight walk through the sequence and ending with the three wing dips.

Finally, base will be the Comfort Inn Parkes International.

Wednesday, January 21, 2009

Looking at 2009

I've been on holidays here on the surfcoast at Torquay so plenty of time to relax and ponder.

Earlier I had anounced my new year resolution:
To lay low! The intent is to become less involved in organisations in which I've been active in recent years; fewer emails on the few lists that I've posted on; fewer meetings and committees. i.e. to slow down.

That should make some time available for other things and near the top of my list is more flying. 2008 was the first time that I competed in all but one aerobatic contest in Australia. The one I missed was the aerobatic event at the Australian Light Aircraft Championships - they don't allow professionals so I'm not eligible. Victorian Championships in February, Nationals in April, Queensland in June and New South Wales in October. Perhaps this year there will be a contest in Western Australia - plenty of help available from some of us if need be. The Avalon Airshow is in there somewhere but I'm not interested in seeing a succession of grey, noisy jets but its a convenient place to catch up with many friends on the trade days.

Contests means practice and critiquing. The Australian Aerobatic Club Victorian Chapter organises occasional training camps (I'll miss the one next weekend as I'll still be at the beach) and maybe there's a need for some of us to put in some additional effort. I'll be available to help coach pilots in preparation for all the contests, including ALAC which is in W.A. in March.

I'm now operating from Lilydale on Sundays as well as Moorabbin on Saturdays which means a lot more work in teaching tailwheel, aerobatics and spinning. And the world certainly needs more of that last one. I continue to be amazed at the lack of knowledge and incorrect information amongst pilots. An experienced PPL who put the Decathlon into a flat spin while attempting a straight power-off stall. Another with a spin and aerobatic endorsement but who hadn't done any for some time was recovering from our spins by simply centralising the rudder. The one who didn't really understand what a spin was. Finally, the myriad of online forums where people pontificate on how to recover from spins and too often the wrong information is being presented. I've been accused of pontificating online too (hey - you don't have to read it) and I never present anything other than some basic info plus appropriate references. Rich Stowell's new book on Stall/Spin Awareness.

There are some other flying activities which interest me so perhaps more of that later. Also a couple of engineering projects which I'm unable to say much about at this stage.

Looking forward to an interesting 2009.

DJP