The general aviation community has reacted with alarm to CASA proposals that would introduce stringent requirements for community service flights (CSF).
CSF flights are those where pilots volunteer their time and aircraft to save people needing medical treatment from long road trips to and from home.
These operations have traditionally been classified as private, but after two fatal accidents involving CSF aircraft, CASA is now seeking to tighten controls on the pilots and the operations.
"CASA is proposing the new requirements to support pilots who conduct community service flights and to enhance public confidence in the services," CASA CEO Shane Carmody said in his December CASA Briefing newsletter.
"The proposed requirements relate to pilot flight time experience, licensing and medicals, night operations and maintenance. In many cases pilots currently conducting community service flights will already meet the proposed requirements.
"However, CASA believes it is appropriate to formally set out these requirements as pilots carry out community service flights without the organisational structure and support provided by an air operator’s certificate."
The proposed new restrictions include:
- a landing in the previous 30 days on the aircraft type or aircraft class
- 10 hours time-on-type for VFR
- 20 hours time-on-type for IFR
- logbook entries to be identified as a CSF
- 400 hours total time for PPLs
- 250 hours in command
- 100 hours flight time for multi-engined aircraft
- No helicopter operations
- No night VFR
- No more than five passengers
- VFR flights must submit a flight plan, flight note or SARTIME to Airservices
- Pilots flying on a Basic Class 2 cannot do CSFs.
"The proposed conditions are necessary in an operation where there is no AOC or other structure to support the supervision and oversee the development of new and existing CSF pilots, or to ensure that maintenance standards appropriate to the nature of the operation have been satisfied," CASA states in the proposal.
Angel Flight CEO Marjorie Pagani told Australian Flying that the CASA proposals are bewildering.
"It does not make any sense at all, because CASA conceded it does not relate to accident causes or data," she said. "We and AOPA have called upon them to provide supportive risk analyses or any statistical data, and they have not.
"The FAA publishes only recommendations. I suggested to CASA they publish a CAAP but they ignored that. They have not consulted us or any aviation organisation on this."
CASA consulted on community service flights in 2014, suggesting initally that co-ordinating organisations like Angel Flight or Little Wings would need to be full approved self-administering organisations (ASAO) under CASR Part 149. The proposal met with no support from the aviation community and was scrapped the following year.
Pagani also believes that CASA may be over-stepping their mark by telling pilots and owners what they can and can't do with their aeroplanes.
"There is a broader question, and that is the proscribing of lawful conduct by properly licensed pilots and owners, by the stroke of an administrative pen.
"This will affect many pilots, both in terms of flying and maintenance. If they succeed in this without challenge, they will use the precedent as enabling them to impose any conditions on any pilot, or, if they choose, to shut down all of the community flight organisations."
CASA said today that CSFs and private flights were different in nature.
"A person flying as a private passenger in an aircraft is not expecting their flight to be similar to a RPT or charter flight," the spokesperson said.
"They usually have some social connection with and knowledge of the pilot and the flight is not usually conducted under the operational pressures that are often associated with a CSF.
"Whereas a CSF is arranged and coordinated by a third party, the passenger and pilot have no connection to one another and there are operational pressures that apply which do not apply to an ordinary private flight, for example the need to get to a specialist medical appointment that has possibly been scheduled months in advance."
CASA has confirmed the new proposals will not apply to FunFlight because those flights don't involve travel to or from medical treatment.