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Safety Advisory Notice issued to: Civil Aviation Safety Authority

Recommendation details
Output No: SAN19990011
Date issued: 23 March 1999
Safety action status: Closed
Background:

SUBJECT - THE PROPOSED AUSTRALIAN PRIVATE PILOT INSTRUMENT RATING


SAFETY DEFICIENCY

The Notice of Proposed Rule Making (NPRM9804PL) for the Australian Private Pilot Instrument Rating (APPIR) does not address some of the key elements required to fly in accordance with night visual flight rules (VFR) using the privileges of that rating. In addition, the proposal does not provide sufficient detail to adequately address some of the key safety issues fundamental to the rating and upon which BASI can make appropriate comment.


FACTUAL INFORMATION

Flight at night in accordance with night-VFR procedures using the privileges of the APPIR

NPRM 9804PL, issued on 4 January 1999, proposes the development of an instrument rating that is valid for private operations in Australia - the APPIR. The APPIR will permit holders who have undertaken the night endorsement on the APPIR rating to fly at night in accordance with night-VFR procedures. The proposed requirements for a night endorsement, as outlined in the NPRM, are a demonstrated competence in travelling from a runway to lowest safe altitude (LSALT), and from LSALT to a runway at night using instrument flight rules (IFR) procedures. The NPRM contains no requirements to include training or demonstration of competence in navigating by visual means at night, nor does it include training or demonstration of competency in operating at an airfield remote from other lighting at night.


Content of the NPRM for the APPIR

The NPRM has described the outline of the proposed APPIR; however, it has not detailed:

(a) the competencies that will be required to be fulfilled for the issue of the APPIR, and for each of the separate endorsements that may be attached to the APPIR;

(b) the aeronautical knowledge that will be required of a pilot before undertaking a flight test for the APPIR, and for each of the separate endorsements that may be attached to the APPIR; and

(c) the guidance that the Civil Aviation Safety Authority will provide on pilot recency, operational and alternate planning, flight in icing and in the vicinity of thunderstorms, coping with social and family pressures, and the risks associated with attempting procedures for which a pilot has not demonstrated a competency.

The Civil Aviation Safety Authority has stated that this information will be promulgated in the future as guidance material.


ANALYSIS

Whilst the night endorsement of the APPIR is intended to permit a pilot to fly in accordance with night-VFR procedures, this endorsement does not address two key elements that are necessary for safe VFR flight at night:

(1) Navigation by visual means at night. The competencies required for this element of night-VFR flight are different to those required for navigation by solely using flight instruments at night; and

(2) Operations at airfields remote from other lighting at night. The competencies required for this element of night-VFR flight are different to those required to operate at airfields that are not remote from other lighting at night.

Completeness of the NPRM for the APPIR

Although a number of critical safety issues are referred to, and are fundamental to the NPRM, little or no detail is provided in this proposal. Whilst it is understood that the Civil Aviation Safety Authority is moving towards less prescriptive legislation, it is important that the details of the proposal that may have a direct impact on safety should form part of the proposal. It is the Bureau's opinion that when all the competencies, aeronautical knowledge requirements and advisory information referred to in the NPRM, are promulgated, the Bureau will be in a position to provide a comprehensive response, if necessary, in relation to any other perceived safety deficiencies arising from the proposed APPIR.

Output text

The Civil Aviation Safety Authority should note the safety deficiency identified in this document, and take appropriate action.

Initial response
Date issued: 22 April 1999
Response from: Civil Aviation Safety Authority
Response text:

The Safety Deficiencies you have identified in the above Notice have been noted and will be rectified in the final proposal.

The requirements for night endorsement will include the competency to navigate "at night by visual reference both with and without the assistance of radio navigation aids" as is currently specified in CAO 40.2.2 Appendix 1 paragraph 2.1 (d).

Likewise "competency in operating at an airfield remote from other lighting at night (CAO 40.2.2 Appendix 1 para 1.3(b)) will be required for the night endorsement. However what constitutes "remote from other lighting" is not presently defined in CAO 40.2.2. Taking off or landing towards an isolated town might provide substantial external visual reference even though the airfield may otherwise be deemed "remote from other lighting". The issue is to be addressed further.

The "competencies that will be required to be fulfilled for the issue of the APPIR, and for each of the separate endorsements that may be attached to the APPIR" will be articulated in the final documentation. At the time the Summary of Responses was prepared it was considered adequate to state the requirements in general terms such as the standard of proficiency for aircraft handling, track keeping, altitude holding, and flight management are the same as for CIR holders conducting the same activity" (para 2(e) on page 6 of the Summary) and "aircraft handling skills will be those listed on the Command Instrument Rating flight test report form" (Summary, page 7, "Competency standards").

Similarly the aeronautical knowledge items will be articulated in detail in the final proposal documents. The advisory material is to be developed during further consultation with the industry. It is understood that the acceptability of the final proposal is dependent on the content of these documents.

 
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Last update 01 April 2011