You tell the FAA which regs you want banished

[avcanada]

What an interesting idea.

The FAA allows the public to write in with the three regs they feel should be banished and why. They then review the issues against the FAA's regulatory agenda and consider banishment or change with the regs.

What a great use of the system. I guess the deadline for the comments is May 25th and that in the past they have received more than 1250 comments.

I would like to start a similar topic below. What three regs would you change or banish in Canada and why?

Only three now

[CD]

US DOT - Review of Existing Regulations - Request for Comments

Request for Comments
As part of its ongoing plan for periodic regulatory reviews, the FAA is requesting the public identify three regulations, in priority order, that it believes we should amend or eliminate. To avoid duplication of effort, we ask the public to direct any comments concerning 14 CFR parts 125 and 135 to the address included in the February 3, 2003, notice announcing that special review (68 FR 5488). Also, readers should note that this is the first periodic regulatory review that specifically includes 14 CFR Chapter III, the regulations governing commercial space transportation. In earlier review cycles, the FAA requested comments only on 14 CFR Chapter I.

Our goal is to identify regulations that impose undue regulatory burden; are no longer necessary; or overlay, duplicate, or conflict with other Federal regulations. In order to focus on areas of greatest interest, and to effectively manage agency resources, the FAA asks that commenters responding to this notice limit their input to three issues they consider most urgent, and to list them in priority order.

The FAA will review the issues addressed by the commenters against its regulatory agenda and rulemaking program efforts and adjust its egulatory priorities consistent with its statutory responsibilities. At the end of this process, the FAA will publish a summary and general disposition of comments and indicate, where appropriate, how we will adjust our regulatory priorities.

Also, we request the public provide any specific suggestions where rules could be developed as performance based rather than prescriptive, and any specific plain-language that might be used, and provide suggested language on how those rules should be written.

[CD]

Here are my three nominations...

Air Canada Public Participation Act
This must be one of the most archaic and restrictive pieces of legislation out there. It should be scrapped in favour of allowing Air Canada to compete on a equal basis with all other operators in Canada.

605.26(1)(b)
I find it bizarre that it is still permitted to have unrestrained, lap-held infants on board aircraft. This provision should be deleted and the use of child restraint systems made mandatory for infants.

605.31
Can anyone tell me how much oxygen I really need to carry? Anyone? Bueller? Here are some of the problems:
1. Confusion Over the Use of Tables
2. Excessive Oxygen Requirements for Passengers and Crew Members
3. Conflicting Requirements for Passengers of Aircraft Operating Above 13,000 Feet
4. Excessive Oxygen Requirements for Aircraft Operating Below 25,000 Feet
I know that proposals were already presented to address this regulation - I hope they'll actually fix the problems.

[Panama Jack]

Wow, it really is an election year in the United States.

[Panama Jack]

605.26(1)(b)
I find it bizarre that it is still permitted to have unrestrained, lap-held infants on board aircraft. This provision should be deleted and the use of child restraint systems made mandatory for infants.

I remember a discussion a few years ago regarding this very issue. If the matter is that lap-held infants are not adequately protected in the event of an accident, you are correct and they would be better off in approved child restraint seats.

However, we need to consider aviation as one as the modes of transportation. Occupying another seat means that the parents will need to purchase that seat. When the economics get involved, the family may opt to drive rather than fly since the cost of purchasing another seat may be prohibitive. What is the safety record driving versus flying? I think they did a statistical study in the USA on this, and deemed that more children who would have otherwise flown would be killed in automobile accidents than could have been killed in airline accidents.

[hz2p]

I just love statistics. Here's a statistic for you: Did you know that a man with his feet in the stove, and his head in the freezer, is ON AVERAGE comfortable?

Statistics is the astrology of Mathematics. You can get any answer you want.

Back on topic - even if CD is a Transport Canada Evil Empire Headquarters Stormtrooper (TCEEHS - (tm)) I've got to agree with him on the child seat thing.

My only problem with the child seat business is the boneheaded airline employees of dubious sexual orientation ... a few years ago, I was boarding an airliner, kids and child seats in tow. But because the (new) child seats didn't have the right sticker, the boneheaded airline employee of dubious sexual orientation wouldn't let me carry on board and use the child seats. He wanted me to throw out my child seats - abandon them outside the door of the aircraft, and not let the kids use the child seats I had brought along. Naturally, it was Air Canada. I really, really don't like flying Air Canada. I'd rather have all my teeth removed without the benefit of anaesthetic. It would be less painful.

[A.W.]

qqq

[Panama Jack]

I just love statistics. Here's a statistic for you: Did you know that a man with his feet in the stove, and his head in the freezer, is ON AVERAGE comfortable?

I heard that stat before, couldn't remember it though . . . thanks for quoting it.

[wallypilot]

With the child restraint system, you can have a system that still allows the infant to sit in the lap of the parent. I have seen it on airlines in Europe. I think that is what should be made mandatory, not a whole separate seat occupied by the infant. Plus, once airborne and in cruise, many airlines have these great cot-cribs that attach to the bulkhead and have straps over top of the crib-enclosure to keep the baby relatively secure in the event of turbulence. I have not seen any of these items on AC.

As for Regs to change, the reg that stipulates ATPL requirements should be enhanced for better clarity. It seems there is a lot of variability in the acceptance of dual night time counting towards the 100 total night. The regs should be changed to explicitly reflect the exact requirements, including stating that Dual time is not to be counted. I know some inspectors have accepted it, while others, have correctly not allowed it.

[Panama Jack]

I understand that the child restraint system you talk about in Europe has not been approved in North America because it does not protect the infant and puts at risk the adult in the seat (infant will be crushed to death in the event of the deceleration forces that are normally tested in this realm).

While we are at the point of clarifying definititions (I agree 100%), a clarification of "instrument time," as the disagreements testify in another on-going thread, would be appropriate.

[CD]

JAR-OPS 1.320 and 1.730 outline, among other things, the transportation of infants and children. The provisions allow multiple occupancy of aircraft passenger seats. Accordingly, infants (< 2 years) are properly transported on an adult's lap. JAR OPS 1.730 further regulates that an operator is only allowed to operate an aircraft if he or she provides an additional loop belt or other restraint device for each infant.
*
For the transportation of infants on an adult's lap, the adult is restrained with a pelvic belt, and the infant is fixed on the adult's lap with an additional loop belt.
*
In a suddenly occurring deceleration in the longitudinal aircraft axis, the adult and the infant show a pronounced jack-knife effect. The upper torso and the lower extremities of the infant as well as of the adult sitting behind the infant fold up in a forward direction, with the loop belt restraining the infant. Finally, the loop belt drives into the infant's abdomen and only stops at his or her vertebral spine. From the technical point of view, the infant acts like an energy absorption element for the adult; the crash loads acting on the adult are thus reduced, and the infant fixed with the loop belt thus suffers most serious up to fatal injuries.

Examination on the Enhancement of Cabin Safety for Infants

[Donald]

Our goal is to identify regulations that impose undue regulatory burden; are no longer necessary; or overlay, duplicate, or conflict with other Federal regulations.

So basically, the Feds want the citizens to do their work for them?!?

In seriousness, I would like to see right seat time counted towards an ATPL equally with instructing time.

[Panama Jack]

OK, so I stand corrected on the injuries to the adult. Still, not good for lil' Johnny.

[Louis]

A definition of "built-up area" would be nice, as the thread I started in the Questions area prompted many different answers, and no definite one.

I also agree with what Panama Jack said, a definition of instrument time would also be quite useful.

[JACKASS]

It is easier to beg forgivness then ask permistion

as far as the built up area, clarity is the one thing that you want to avoid

the child seat could simply be avoided by hanging the child in the seat from the roof of the aircraft (airlines need to install hooks) or build a seat into the overhead luggage compartment that could be used in the place of two carry on bags.

As far as the ATPL requirements ease back on the specifics. I knew a king air FO with 3000 hours without an ATPL, he got the job at 250hours and never got his 100hours night pic, he finally had to rent an aircraft for sixty hours just to get it

[sakism]

(4) Experience

An applicant shall have met the training requirements for the issue of a Commercial Pilot Licence - Aeroplane that is not restricted to daylight flying and completed a minimum of 1500 hours total flight time of which a minimum of 900 hours shall have been completed in aeroplanes. The total flight time shall include a minimum of:
(amended 2000/09/01; previous version)

(a) 250 hours pilot-in-command flight time in aeroplanes which shall include where applicable, a maximum of 100 hours pilot-in-command under supervision flight time completed in accordance with Section 421.11. The pilot-in-command and/or pilot-in-command under supervision flight time shall include a minimum of 100 hours cross-country flight time of which a minimum of 25 hours shall have been by night;

(b) 100 hours night flight time as pilot-in-command or as co-pilot of which a minimum of 30 hours shall have been acquired in aeroplanes;

(c) 200 hours cross-country flight time as co-pilot in an aeroplane required to be operated with a co-pilot or, 100 additional hours cross-country flight time as pilot-in-command which may have been part of the 250 hours pilot-in-command flight time specified above; and

(d) 75 hours instrument flight time of which a maximum of 25 hours may have been acquired in approved instrument ground trainers and a maximum of 35 hours may have been acquired in helicopters. Instrument ground time shall not be applied toward the total 1500 hour flight time requirement.




Maybe that King Air FO should have read the CARS and saved himself a lot of money.