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