Speech to Royal Federation of Aero Clubs of Australia Flying Training Conference
It is a pleasure to accept the invitation from Marj Davis to speak to the Royal Federation of Aero Clubs of Australia Flying Training Conference.
I would like to reflect back on the submission from RFACA into the National Aviation Policy statement process where the RFACA said that its policies included:
- a commitment to aviation safety
- a commitment to the provision of high quality Flying Training, and
- a commitment to finalising the Regulatory Reform Program in the earliest time frame thus ensuring enormous safety and efficiency benefits to the industry.
These policies align closely with CASA's policies and initiatives, and I would like to cover each of these today.
We see flying training as very much the cornerstone of much of aviation, and a key element in the long term safety performance of the industry. Education and training is, of course, what this conference is all about and it has been one of your reasons for existence for aero clubs for nearly 100 years.
Fostering the development of correct behaviours and attitudes and adequate skills and knowledge that are acquired during flight training form the basis for how pilots eventually operate safely.
The training provided by aero clubs has long been at the forefront of aviation training in Australia.
Aero clubs are particularly well equipped to support training by promoting and reinforcing the development of a strong safety culture, a core element for a competent and professional pilot.
We see flying training very much as a continuum, which might start in a Cessna but could finish in an A380 - in other words, we've got to get the basics right. Flying is a manipulative skill that requires good hand/eye coordination and good ab initio flying training is fundamental to setting a pilot up for life.
To support this training we have introduced practical guidance material to ensure the competent training and assessment of Australian pilots. Competency based training and assessment is the best way for pilots to achieve the specified standards for licences, ratings and endorsements.
The aim of the guidance material is to help people using the competency based training and assessment system to better understand and apply the concepts of the system.
But the outcome we want to see from training - by far the most important outcome - is safety.
Australia is a global leader in aviation safety and has an aviation safety record second to none. Trends from data produced by the Australian Transport Safety Bureau show that aviation in Australia is only getting safer.
However we can not be complacent when it comes to aviation safety.
CASA can always improve in how it supports the aviation industry achieve the best safety outcomes and a key goal for CASA is improved safety through improved flying training & testing standards
To continue to improve flying training and CASA's oversight, CASA established a Flying Standards Branch which is responsible for practical pilot proficiency standards, oversighting of Approved Testing Officers (ATOs) and assisting the flying training sector. The Flying Standards Branch also includes the Flight Testing and Training Office (FTTO). Several initiatives and programs are in place or under development, including:
A Professional Development Program for ATOs - This is a compulsory program for ATOs conducted on a two year cycle. The key objective of these programs is to improve safety through improved standards and standardisation of:
- assessment of pass/fail standards;
- Conduct and sequence of flight tests; and
- Expected behaviours of ATOs as delegates of CASA.
We have published the Approved Testing Officer Manual (ATOM) – This manual provides practical flight testing guidance to ATOs. The manual supports the standardisation of flight test conduct as an intrinsic element in improving the safety of aviation through the consistent assessment of applicants pursuing flying qualifications.
The FTTO has commenced conducting the majority of initial issue flight instructor rating tests. The fail rate was initially around 57 per cent. After 12 months the fail rate had dropped to 35 per cent and now sits at approximately 22 per cent.
We have also developed the Flight Test Notification System (FTNS) which has been in place for some time now. The FTNS was introduced to provide a national standardised system for general aviation ATOs to notify CASA prior to the conduct of a flight test (a legislative requirement). The FTNS permits data capture and analysis capability to track pass/fail results, common fail items and performance of ATOs and flying training organisations. This data can be used to provide feedback to industry and target CASA education programs. This will provide CASA with the ability to monitor pilot proficiency standards and ATO/ check Pilot activity rates in the air transport sector.
Within CASA, one of the my key aims is to ensure that we are regulator that is focused on our safety related functions and responsibilities under the Civil Aviation Act and on ensuring the aviation industry is aware of its own obligations to maintain the highest standards of aviation safety.
However, I am acutely aware of the industry’s need for a predictable and consistent regulator.
One of the key initiatives to support this is for us is to improve the training of our own staff.
I am well aware that CASA in the past had not had the focus on technical training for its own staff that it should have had. It is now a priority for us, with a range of new programs to enhance staff capability in areas such as leadership, regulatory skills and technical expertise.
We have created a dedicated Safety Education and Promotion Division who have put in place comprehensive initial, on-the-job, recurrent and specialist training programs for our technical staff and support staff.
This includes continuous monitoring and access to professional development and evaluation.
The Safety Education and Promotion Division also use a range of professional communications and marketing techniques to develop and deliver safety promotion campaigns.
These campaigns result in the dissemination of safety information and promotional materials to the aviation community, via the most effective and timely communication methods and channels.
CASA also has dedicated and experienced Air Safety Advisors and we are continuing to roll out the program of very popular and effective Aviation Safety seminars for pilots. These seminars are held in regional centres and cover topics such as airmanship, situational awareness, operations at non-towered aerodromes, fuel management and the responsibilities of the pilot in command.
CASA generally holds the seminars in conjunction with local aero and flying clubs, although other venues are used where necessary. Feedback from pilots about the seminars is very positive.
CASA runs around 100 seminars a year for pilots in regional centres across Australia, and I encourage everyone to attend.
I am pleased to say CASA has been making significant progress in the regulatory reform program.
We have established a taskforce between CASA and the Attorney General’s Department which comprises CASA staff who develop and instruct on our regulatory policies and legal drafters from the Office of Legislative Drafting and Publishing (OLDP) who turn these policies into legislation.
Finalising and implementing the outstanding CASR suites involves a huge amount of work and considerable resources for CASA and the OLDP.
We are also aware that it can be a challenge for industry having to review and comment on our consultation documents and draft regulations.
In addition to drafting the legal text of the new regulations, we also have to ensure that we publish adequate advisory and guidance material, supported by training and education materials, for both industry and CASA staff.
Since 2009 we have made a number of key advances in the regulatory reform program including:
- CASR Parts 42, 66, 145 and 147.
- CASR Part 21 M
- CAR 166 & 166A
- MOS Part 172
- CASR 22-35, and
- CAO 82.5 and 82.3
CASA's priorities in regulatory development include:
Part 91 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 requirements of Part 91 form the basis for safe aviation operations (which are not repeated in other operations parts) so all pilots will need to become familiar with the Part 91 regulations.
It also prescribes the basic requirements for aircraft emergency equipment, weight and balance and radio and navigation equipment carriage.
Key points in Part 91 include:
- Making minimum height rules requiring aircraft to be flown at such a height that would enable a forced landing without undue hazard.
- New provision for fitness of crew members for duty.
- Performance and flight crew training requirements for larger helicopters.
- Incorporating new a new requirement for 'risk' briefing of passengers before boarding non-air transport flights.
- Adding requirements for in-flight fuel management.
Part 119 relates to the issuing of Air Operators Certificates to Australian air operators.
- Part 119 will provide a single standard for regular public transport and charter operations and require identification of key personnel as defined in the Civil Aviation Act.
- Establishment of a Safety Manager.
- Making the CEO accountable for the safety system and regulatory compliance.
- Requirement to develop and maintain a Safety Management System.
- Requirement to provide for crew training and checking (or arrange for Part 142 Training and Checking organisation to carry out the function).
Part 121 will set the minimum acceptable standards applicable to larger aeroplanes (over ten seats) that are conducting passenger or cargo transport operations, regardless of whether charter or regular public transport operations are involved.
Part 121 will consolidate into one CASR Part the regulatory requirements that will apply in addition to, or in substitution for, the general operating and flight rules prescribed in Part 91 when using larger aeroplanes for air transport operations.
The Part will replace all affected CARs and CAOs.
It will largely cover the same regulatory areas as now, but with a few additions,, mostly to give effect to ICAOs Annex 6 Part 1 SARPS.
Key Points that will be in the consultation draft include:
- More comprehensive provisions for fuel carriage requirements and alternate aerodrome requirements with respect to operations outside Australia.
- Another change will be for flight and cabin crew members to be subjected to more comprehensive training and checking requirements.
Part 129 will prescribe the requirements for foreign operators operating foreign registered aircraft to, within or from Australian territory on air transport operations that are not regulated domestic flights.
Key Points that will be in the consultation draft include:
- Implement a standard that mandates a common crew member language and that requires flight crew members to be able to communicate with air traffic control in English.
- Use of Operational Specifications as a schedule to the Air Operators Certificate.
- Refinement of maintenance and airworthiness requirements applicable to aircraft operated by Part 129 operators.
Australia is one of several nations that issues Air Operators Certificates to foreign operators and Part 129 will harmonise with other overseas regulations where appropriate.
Part 133 applies to the operation of a rotorcraft for an Australian air transport operation.
The proposed regulations will introduce a single standard for air transport operations, whether unscheduled or scheduled.
The applicability and standards of Part 133 are aligned closely to Australia's obligations as a member State of ICAO and to CASA's hierarchy of priorities within the Classification of Civil Aviation Activities Policy for rotorcraft.
Key points that will be in the consultation draft include:
- Link requirements under VFR at night to be more directly to the requirements for IFR operations.
- Safety-based outcomes for overwater flights: establish procedures, training and recency.
- Rotorcraft performance standards based on ICAO requirements.
The proposed regulations will set the minimum acceptable standards applicable to small aeroplanes (9 seats and below) that are conducting Australian air transport operations.
They will set in place a common level of safety for operators who are authorised to provide 'Air transport operations' - an amalgamation of current charter and regular public transport operations and standards - in order to carry passengers in small aeroplanes.
The common level of safety will apply irrespective of whether an operation is scheduled or non-scheduled as described by ICAO in Part I of Annex 6.
Key points that will be in the consultation draft include:
- More comprehensive provisions for fuel carriage requirements.
- Take-off alternates within 60 minutes to align with ICAO requirement.
- Operations beyond 25nm to have safe forced landing area when over water.
- Aircraft under IFR with 6 or more passengers to have TAWS (B).
- Training and checking requirements in line with complexity of operation.
The proposed regulations will be a re-establishment of the requirement for a dedicated set of operational regulations for rotorcraft aerial work operations.
The Part will bring together requirements affecting aerial work operations that apply in addition to or in substitution for those required under Part 91 and will also establish the general standards for aerial work for both rotorcraft and aeroplanes.
Key points that will be in the consultation draft include:
- It will establish a modernised aerial work classification and certification basis.
- Operators will be required to have an appropriate training and checking system to conduct the training and checking programs called up by the operating rules.
- All flight crew, safety critical ground support personnel and task specialist crew members will be required to be trained and checked to an appropriate level for the complexity of the operation.
- Allowance for the carriage of passengers in certain aerial work operations.
- A significant upgrade of specific aerial work operational regulations based on the measurable risks of the operations.
- Requirement for an active safety risk management process to be in place for operations conducted.
Part 61 will prescribe the requirements and standards for the issue of flight crew licences, ratings and other authorisations, including those issued to pilots and flight engineers.
It will also include the privileges, limitations and conditions on such authorisations, and include rules for the logging of flight time.
This will bring flight crew licensing requirements in line with ICAO SARPs.
It will also set pilot licences to be a single licence for each of recreational, private, commercial and airline transport with the provision to have one or more aircraft category ratings attached (as per the US system).
Part 61 will include flight engineers and other flight crew essential to the operation of the aircraft.
CASR Part 64 will prescribe the requirements for the licensing of ground operations personnel including the privileges, limitations and conditions on such provisions.
The aim of Part 64 is to create licensing standards that both conform to ICAO Annex 1 requirements and best international practice, but provide more flexible and streamlined arrangements without compromising safety.
Part 64 is designed to consolidate the existing rules governing the licensing of ground operations personnel into the CASR style and format.
Part 141 will specify requirements and standards for flight training, including those relating to training facilities, aircraft, procedures, management systems, standards/manuals, and personnel/safety operations for training relating to recreational, private and commercial pilot flight training, other than integrated training.
Part 141 will address training for the grant of recreational, private and commercial licences and other single pilot flight crew qualifications (will not extend to integrated training).
It will also address training conducted both in aircraft and in flight simulation training devices
Part 141 will also:
- Have requirement to develop and implement a Safety Management System.
- Simplified administrative and organisational requirements for operators conducting flight training for grant of recreational, private and commercial licences.
- Require an authorisation in place of an Air Operators Certificate.
CASR Part 142 will prescribe the organisational and administrative framework for issuing Part 142 authorisations for operators to conduct integrated flight training for a Private or Commercial pilot licences and other licences, and ratings required for multi-crew flight operations in addition to contracted recurrent training and checking.
Part 142 will require an Air Operators Certificate for authorised activities conducted in aircraft or an authorisation for activities conducted in flight simulation training devices.
It will also regulate integrated training courses for the grant of a Private or Commercial pilot licence and simplify the administrative and organisational requirements for operators conducting flight training for the grant of private, commercial and other licences required for multi-crew operations.
Key points in Part 142 include:
- Requirement to develop and implement a Safety Management System.
- Requirement for an Air Operators Certificate for authorised activities conducted in aircraft or an Authorisation for activities conducted in flight simulation training devices.
- Simplified administrative and organisational requirements for operators conducting flight training for grant of recreational, private, commercial and other licences for multi-crew operations.
- Regulates integrated training courses for the grant of a Private or Commercial pilot licence, flight training for a qualifications specified in CASR Part 61 that authorise a person to conduct multi-crew operations, including associated ratings and endorsements, flight training for the grant of a transport category aircraft type rating.
It is important to note that making the regulations is only the first step. There are also considerable implementation issues for both CASA and the industry to ensure that these regulations are put in place safely and effectively.
To that end, I have appointed a senior executive to construct and oversight the planning of the regulatory implementation program, working closely with the Executive Managers and those critical projects that impact on the delivery of the regulations implementation.
While implementing these regulations, CASA must continue on its day to day work, which includes a continuing focus on
- Standardisation, consistency and efficiency,
- building the skills of CASA staff,
- Delivery of regulatory services, and
- Ongoing surveillance of the aviation industry.
However, I am confident that we can and will successfully implement these new regulations and continue to improve aviation safety.
It is always a great pleasure to address the aero club movement and I would like to wish everyone a safe and successful conference and championship.