Tuesday, December 27, 2011

CASR Part 61 - Flight crew licensing

CASA has a new Consultation Draft - CASR Part 61 - Flight crew licensing with 3 Feb 2012 the closing date for comments.
When the first draft of Part 61 came out about ten years ago we also had a draft Advisory Circular 91-075 to read in conjunction with it to explain how it would work - as far as aerobatics is concerned. It is also important to read it in conjunction with the draft Part 91. This time we don't have a draft AC and I really fail to see how CASA would make their draft regs wrt aerobatics function practically.
Discussion points follow.
The first point about the new regs is that it is a two tier system replacing the existing three tier system i.e. there will be no CAO equivalent. The regs should define the essential requirements leaving the AC to describe a method of compliance - in the case of aerobatics I would expect that would also represent internal CASA policy therefore mandated as the way that delegates would operate. Perhaps there will be a Manual of Standards instead of ACs for some elements.
One of the big changes with Part 61 is the Recreational Pilot Licence with limited medical certification permitting aerobatics.
Other relevant (to aerobatics) changes relate to the administration of flight activity endorsements and a different structure for instructor ratings including provision for PPL instructors. A PPL is still unable to be pilot in command if he/she receives remuneration or if the operation requires an AOC so a PPL instructor rating is of very limited use or benefit.
61.1030 defines the flight activity endorsements:
■ spinning – upright, above 3,000 ft AGL
■ aerobatics, above 3,000 ft AGL
■ low level aerobatics – down to 1500 ft AGL
■ unlimited aerobatics – at any altitude
■ formation aerobatics – a new endorsement
Subpart 61.T is all about instructor ratings. Somewhat similar to what we have now but some significant changes in how they are structured. We'll have endorsements for spin training, aerobatics training, formation training and formation aerobatics training.
Let's start with the new formation aerobatics endorsement. Australia is already much more severely regulated wrt aerobatics and formation flying than the UK and the USA. The UK is about to get EASA rules for aerobatics (let's not mention EASA's contribution to the European economy) so is slowly catching up to our bureacracy.
Hopefully there's an appropriate consideration of the transition to this new rule so that instructors who currently hold aerobatic and formation training authorities and who also have formation aerobatic experience will be granted this formation aerobatic training endorsement. If not, how does an instructor get one? Remember that CASA does not recognise military aerobatic and formation aerobatic endorsements (hopefully they will fix that now too).
That might leave us with a handfull of instructors around the country who could provide this training, not a very big market for it so no-one is going to spend much money to obtain the training authority. I've already declined to be in an aeroplane to instruct some-one in formation aerobatics - been a while since I have done it and I don't like the idea of being either PIC or passenger in an aeroplane while some-one is getting up to speed. Much better that they get some ground training and coaching from me then progress from there - a big subject and a lot of effort but they'll find it hard to get an instructor in the aeroplane with them, in my opinion. I would work with some-one from the other aircraft in developing their skills - if I trust them, we have suitable aeroplanes, wear parachutes and work up to it etc.
Question is - what is the rationale for introducing this new requirement?
Now for the spinning endorsement. i.e. upright spins above 3,000 ft AGL.
CAAP 155-1 has the flight standard and underpinning knowledge requirements (see also the CASA Day VFR Syllabus) so all pretty clear there. The CAAP also has some good, although brief, guidance on different types and recovery techniques.
The instructor rating endorsement for spin training is different in the draft new regs as there is no mention of the current requirement for it to be specific to "those aeroplanes for which he or she has been certified as competent to give such instruction". This was in recognition of some quite important differences in spin characteristics and in recovery techniques between different types. Good to recognise that but to regulate to that detail is really unworkable.
The AC could easily expand on the CAAP by providing details on the groups of aircraft (those certified for intentional spinning) with some typical characteristics and the different recovery actions.
Need consideration of Limited Category aircraft as they are approved for aerobatic training operations however not certified so what is known about their spin behaviour? Experimental (homebuilt) aeroplanes can also have characteristics which are potentially dangerous if not known to the instructor but can they be used for spin training? With a newish certified aeroplane the information must be in the Flight Manual. Old ones such as the Tiger Moth get by with tribal knowledge.
No mention of the inverted spin endorsement at all! Let's move on to the basic aerobatic endorsement - above 3,000 ft. The existing endorsement is specified in the CAO and therefore in CAAP 155-1 however there was much discussion on this a decade ago when the previous draft Part 61 was floated.
Barrel roll, loop, slow roll, stall turn and roll off the top.
My recollection is that some years ago there used to be a note to the effect that unless some-one had an endorsement comprising all five manoeuvres then that person was restricted to just performing the manoeuvres listed in the endorsement. The current note states that "If a pilot is approved to carry out more than 1 of these manoeuvres, he or she may carry out combinations of those manoeuvres." A roll off the top is a combination manoeuvre which can therefore be performed if some-one doesn't have it listed but has the other four?
I find the roll off the top useful as a definite additional skill is required. No reason to mandate it though. Some instructors teach half Cubans instead of the Immelmann (roll off the top).
Quite a few instructors give an aileron roll endorsement rather than slow roll which is quite fair in my opinion especially if learning in a Cessna Aerobat. I find that those pilots work their way around to doing passable slow rolls with a bit of practice (if they wish to develop the technique so) with no danger to themselves.
There are some who believe that snap (or flick) roll should be included as a basic manoeuvre. If mandated that would rule out some commonly used aerobatic trainers.
Regardless of whether an instructor conforms exactly to CASA's aerobatic endoesement or not, most instructors will include recoveries from extreme unusual attitudes or failed aerobatic manoeuvres. In my opinion that is the most important element of an aerobatic course yet is not specified in the CAO and gets limited acknowledgement in the CAAP.
I am sure that there will be much discussion on this. One may very well ask what happens in other comparable countries.
Low level aerobatics down to 1500 ft AGL.
The current regulations state that aerobatics may not be performed below 3,000 ft AGL without CASA permission. Hence the basic aerobatic endorsement restricts people to aerobatics above 3,000 ft. Same with spinning. (What about a stall in a normal category aircraft?) To perform aerobatics below 3,000 ft and above 1500 ft currently one must go to a CASA delegate, do the test described in the CAAP and, if successful, come away with that permission from CASA. Worth mentioning that the test officer will probably ask the reason for wanting to do aerobatics below 3,000 ft.
Nowhere in the new rules does it mandate a minimum altitude of 3,000 ft nor any other altitude. It is now intended to be controlled by individual pilot authorisations. The basic aerobatic endorsement and the spin endorsement will come with a limitation of above 3,000 ft AGL. (I say again, what about a stall in a normal category aircraft - what will be the minimum height for that?)
No mention of a spin endorsement below 3,000 ft AGL.
The draft Part 61 has no mention of who can authorise aerobatics down to 1500 ft AGL.
Currently a low level aerobatic approval may be limited to a period of two years or, perhaps after being renewed, may be permanent.
Aerobatics below 1,500 ft AGL is even more vague in the draft Part 61. We don't need much detail in the reg as the activity is fairly limited and tailored to individuals. The draft uses the term "unlimited" which will conflict with the same term used as a specific aerobatic competition category.
Currently it follows the same process as for aerobatics down to 1500 ft AGL with fewer delegates authorised at lower altitudes and keener CASA interest at lower altitudes. Additionally, there is another rule somewhere that flight below 500 ft requires specific CASA approval so aerobatics below that height is also subject to that additional approval with respect to location and date.
Competition pilots typically work progressively through the categories and lower altitudes with reviews and checks along the way to getting the next lower altitude approval by CASA or a delegate.
The regulatory reform program has been a long time coming and there are some good things in Part 61 so it would be good to implement it in my lifetime. It really needs to be implemented in conjunction with Part 91 which needs much more work after the draft earlier this year. I would expect a reasonable transition period with suitable arrangements for new authorisations granted on the basis of existing authorisations. CAAP 155-1 Aerobatics needs to be rewritten as an Advisory Circular which will require much thought and effort from where we are now. We should not make the Part 61 regulation any more prescriptive or detailed than it need be but rather manage aerobatic activities by the AC. Much easier to change the AC in future than the regulation. I know that people will say that an AC is advisory and it is true that the words will say that it is only one means of compliance with the regulations and therefore possible to do things contrary to the AC. To ensure that the AC is followed the individual authorisations and delegations must specify the AC as a mandatory condition - unless some-one has arranged a variation with CASA.
The draft Part 61 therefore needs some minor changes to ensure no misunderstanding of the essential requirement. Let's consider those first and then consider the content of the AC.
The USA has a minimum height of 1500 ft for aerobatics below which an FAA waiver is required. UK has no minimum height specified. Seems strange to me that CASA intends leaving it to industry and sport associations to manage entirely without retaining the hook as they do now by requiring CASA approval below a specified height (currently 3,000 ft). Consider some-one who receives an authorisation from their mate to conduct aerobatics down to "ground up" on a permanent basis. With the proposed reg that would remain in effect for life even if the person doesn't exercise it for, say, 50 years then one day decides to have a go at a ripe old age. Perhaps CASA doesn't want to retain the administrative burden of keeping records of all the low level permissions.
Seems to me that CASA should stay involved for aerobatics below 1500 ft to the extent of keeping records of such approvals and having the ability to cancel any if justified. There aren't that many that it is much of a burden. Above 1500 ft is of lesser concern to safety. i.e. I believe the existing rule of a specified minimum height for aerobatics, without CASA approval, should be retained and that height should be 1500 ft. That would be in Part 91.
It certainly doesn't mean that anyone with an aerobatic endorsement and spin endorsement can operate down to 1500 ft. The approvals mentioned above for those endorsements would be limited to operations above 3,000 ft AGL.
The requirement for an inverted spin endorsement has been with us for less than ten years and is not in the draft Part 61.
Before we go any further let's consider some case studies and discuss what the objectives of mandating any particular endorsement (and therefore training) in the regulation may be. These are real situations, not made up, The current rules mandate identical training and endorsements for all three.
First is M, who bought his lovely 7ECA Citabria before he got his GFPT. He just wanted to do casual Sunday afternoon aerobatics on a nice day every now and then. The Citabria pretty much behaves per "the book" as an aeroplane. The standard spin training is appropriate. Do the right thing and the aeroplane responds. Do the wrong thing and you can get into trouble. No inverted system and it tosses oil onto the airframe with any negative g so we'd rather do ballistic aileron rolls to keep a little positive g ratehr than competition style slow rolls. Similar thought with the roll off the top. I don't like doing snap rolls in a Citabria so M won't do them. The aerobatic endorsement per the current regs however is not too far off what I would recommend for M to be safe.
Next is S who also bought an aeroplane before he gained his GFPT. He got an Airtourer. Spin recovery is pretty much intuitive (for some-one who meets the stated GFPT standard for stalls). Quite a robust aeroplane with very high margins for airspeed above normal operating speeds. S is a pretty switched on guy and wouldn't do aerobatics without having received appropriate training. But to achieve the same level of safety as M I can imagine some-one saying to him: buy Stan Tilley's book on doing aerobatics in the Airtourer, go up high and have a go. That is perfectly legal in the USA and people do it.
The final case study is J who also has yet to complete his GFPT and has just purchased a Pitts Special. My recommendation on the minimum scope of training is totally different to the above. Same objectives as S and M - just wants to do the occasional loop and roll, certainly doesn't want to exploit the full potential of that aeroplane. He will never intentionally perform an inverted spin so doesn't need the endorsement. He will need extensive training in advanced spinning - upright, inverted, steep, flat, accelerated. Cross-over spins. Slow rolls are easy. Stall turns - so easily goes wrong with a violent entry to an inverted flat spin. Similar issue with the roll off the top. Snapping off the top of a loop is just too easy. I wouldn't give anyone a "check-out" in an aeroplane like that without extensive training in advanced spinning and aerobatics.
Back to the questions:
•what should be mandated in the regulation as an aerobatic endorsement?
•is an inverted spin endorsement required?
The Canadian Air Regulations apparently state that to conduct Aerobatics with a passenger, one of the following must be met, Pilot must be a holder of an aerobatic instructor rating OR have completed a 10 hour course and have their pilot logbook signed off, OR have completed 20 hours of solo aerobatic practice and have completed 1 hour of either solo or dual practice in the last 6 months.
It is worthwhile considering what is about to happen in the UK. Currently virtually no regulatory involvement in aerobatics at all but they are about to be included in the new EASA regs. Not totally inclusive as they will only apply to "EASA aeroplanes".
"FCL.800 Aerobatic rating
(a) Holders of a pilot licence for aeroplanes, TMG or sailplanes shall only undertake aerobatic flights when they hold the appropriate rating.
(b) Applicants for an aerobatic rating shall have completed:
(1) at least 40 hours of flight time or, in the case of sailplanes, 120 launches as PIC in the appropriate aircraft category, completed after the issue of the licence;
(2) a training course at an ATO, including:
(i) theoretical knowledge instruction appropriate for the rating;
(ii) at least 5 hours or 20 flights of aerobatic instruction in the appropriate aircraft category.
(c) The privileges of the aerobatic rating shall be limited to the aircraft category in which the flight instruction was completed. The privileges will be extended to another category of aircraft if the pilot holds a licence for that aircraft category and has successfully completed at least 3 dual training flights covering the full aerobatic training syllabus in that category of aircraft."
This new EASA aerobatic rating is likely to feature in CASA considerations as they seem enamoured of EASA regs as best practice worldwide - not that I've seen evidence of that in practice for GA operations.
I'm not sure what will be required in such a five hour course however the 2008 draft EASA training was:
Aerobatic Rating – Theoretical knowledge and flying training
1. The aim of the aerobatic training is to qualify licence holders to perform aerobatic manoeuvres.
2. The approved training organisation should issue a certificate of satisfactory completion of the instruction for the purpose of licence endorsement.
3. The theoretical knowledge syllabus should cover the revision and/or explanation of:
3.1. Human factors and body limitation – spatial disorientation – airsickness – body stress and g forces, positive and negative – effects of grey and black out
3.2. Technical subjects – legislation affecting aerobatic flying to include environmental and noise subjects – principles of aerodynamics to include slow flight, stalls and spins, flat and inverted – general airframe and engine limitations
3.3. Limitations applicable to the specific aircraft category (and type) – airspeed limitations (aeroplane, helicopter, touring motor glider, sailplane – as applicable) – symmetric load factors (type related as applicable) – rolling g’s (type related – as applicable)
3.4. Aerobatic manoeuvres and recovery – entry parameters – planning systems and sequencing of manoeuvres – rolling manoeuvres – over the top manoeuvres – combination manoeuvres – entry and recovery from developed spins, flat, accelerated and inverted
3.5. Emergency procedures – recovery from unusual attitudes – drills to include use of parachutes and aircraft abandonment
4. The exercises of the aerobatic flying training syllabus should be repeated as necessary until the applicant achieves a safe and competent standard. The training should be tailored to the category of aircraft and limited to the permitted manoeuvres of that type of aircraft. The exercises should comprise at least the following practical training items (if permitted):
4.1. Aerobatic manoeuvres – Chandelle – Lazy Eight – Aileron Roll – Barrel Roll – Rudder Roll – Loop and inverted loop – Immelmann – Split S
4.2. Confidence manoeuvres and recoveries – slow flights and stalls – steep turns – side slips – engine restart in flight (if applicable) – spins and recovery – recovery from spiral dives – recovery from unusual attitudes
I should mention New Zealand sometime. They started their regulatory reform program at about the same time as Australia and largely completed it a very long time ago. They have an aerobatic rating so it is more bureaucratic than our flight activity endorsement however it all seems quite sensible.
“a current aerobatic flight rating authorises the holder to conduct aerobatic manoeuvres within the following limitations: (1) at a height not less than 3000 feet above the surface while carrying a passenger: (2) at a height not less than 1500 feet above the surface while not carrying a passenger: (3) at a height less than 1500 feet above the surface while not carrying a passenger when authorised by the holder of an aviation recreation organisation certificate issued in accordance with Part 149, if the certificate authorises the holder to organise aviation events.”
They require a competency check every two years.
“The flight training course should provide an introduction to the basic aerobatic manoeuvres with an emphasis on their safe and accurate execution.
The flight training course should consist of dual instruction, solo practice and consolidation.
The flight training course should cover in practice all the elements of the ground course. Particular attention should be given to engine management, the aerodynamic and loading affects of aerobatic flight on the aircraft, disorientation effects on the pilot, and the elemental need for safety,particularly recovery from unusual attitudes, the management of energy, height above the ground and situational awareness.
The course ought to be flexible enough to cater for aircraft of different performance and capabilities.
Advanced turns (more than 60-degrees of bank angle)
Stall turns
Combinations - eg Half cubans, half reverse cubans, and rolls off the top.
Emergencies and recovery from unusual attitudes.
It may include:
Snap rolls or other manoeuvres at the discretion of the instructor, and dependent on pilot aptitude and aircraft integrity.”
We could do a lot worse than becoming a state of NZ and adopting their aviation regulations.
Anyway, let's try for the minimum change to the draft Part 61 as we don't want to hold it up too much and let's try to make it somewhat consistent with the way we do things now however let's make it a bit more flexible.
1. CASA should retain (in Part 91) a requirement that aerobatics below 1500 ft AGL is not permitted without permission by CASA. The current requirement is 3000 ft AGL. The 1500 ft AGL requirement is identical to the USA and retains increased control over very low level aerobatics. Permissions below 1500 ft AGL may be limited as they are now – refer the CAAP. Per the draft Part 61, aerobatics below 3000 ft AGL down to 1500 ft AGL is a flight activity statement so provided by a log book entry.
2. The requirement for a formation aerobatic endorsement must be deleted as it is not workable and I see no reason to introduce it.
3. I expect the spin (upright) endorsement to be supported by training and knowledge requirements as it is now by the Day VFR Syllabus.
4. I support the deletion of the inverted spin endorsement as I could so no reason for its introduction in the '90s.
5. The basic aerobatic endorsement should be defined to include loop, aileron roll, stall turn and unusual attitude recoveries (failed attempts at these three manoeuvres).
6. Unlimited aerobatics flight activity is deleted as it becomes a permission from CASA or a delegate as currently.
A new Advisory Circular will be required and this should be based on the current CAAP 155-1 with the following changes consistent with the draft Part 61 if it is changed per my recommendations above.
1. CASA delegates will be required to issue permissions for aerobatics below 1500 ft AGL. Instructors who hold low level aerobatic permissions to 1500 ft AGL and authorised persons should be able to issue permissions to perform aerobatics (including spins) down to 1500 ft AGL.
2. The AC should include guidance on the content of aerobatic training which will depend on the capability and performance of the type in which the training is done.

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