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Ralph Burnett contends that the creation of a LL ‘rating’ under Part 61 just confirms the regulator isn’t listening to anyone in the industry or reading the policy of the government of the day.

The industry wants simple rules which harmonise with major overseas aviation regulations. Government policy is for less red tape. Both want the industry to grow and be able to pay tax and employ people.

This rating we didn’t need just exemplifies the problem within the new CASR Part 61. The Aussie version of Part 61 runs for over 500 pages, with at least another 600 in the Manual-of-Standards, (MOS). The US FAA original has about 160 pages, while New Zealand has 110.

There are 39 ‘offences of strict liability’ in ours – none in theirs. Each one of these can cost a pilot 50 penalty points each worth $180 – $9,000 for offences such as not carrying your licence, or failing to adequately keep one’s logbook.

Is it any wonder that pilots are incensed by the regulators use of a heavy legal hand. There will never be co-operation between the regulator and industry while these punitive sections remain in the CASRs.

So, why complicate things? In the case of low level, where are the facts that show pilots are having accidents at low level because their training was inadequate? And, where are the facts to support a change to increase training of pilots insofar as reducing accidents?

Where are the facts to support a claim that Low Level instruction quality is the problem?


Is There a Problem?

Accidents at low level continue to happen, despite all the booklets and lectures given to pilots. The primary question is – as a proportion of hours flown, or pilots flying, or any other metric you’d like to coax out of the accident data – is the situation becoming worse? The next question is, rather obviously, if all the past preaching about unauthorised low level flying hasn’t changed the accident numbers, what might?

If the regulator ‘believes’ there is a problem, do they have any sensible solutions? Please explain how making a course-of-training into a full blown rating will help. This especially when the ‘rating’ itself goes no further than the previous CAO 29.10 course syllabus. Add to this our dismay when reading the MOS flight tolerances for low level and ag ops: +/- 100 ft in steep turns? Spare me.

Who inflicted this upon us? The MOS is a mishmash of throwaway instructions and offers no reliable guide to a structured course of training.

In summary, there is no safety case for a rating, and what has been written into the Part 61 LL section just doesn’t cut it.

Is There any Causal Factor?

I submit that most Low Level accidents are the result of simply human factors, over which neither the regulator, nor the instructor, has much control. As in any other group of humans undertaking a known high risk activity, there will be a proportion of alpha personalities who believe they either know better, or are more skilled than the rest of us. A more careful look into accidents grouped under the ‘low flying’ category shows that a high proportion of the pilots had never undergone training in low level. And, they probably never would have! That’s the nature of the personality trait. Exclude aggies here.

Yes, there will be some pilots who have had accidents when they have been doing their very best to avoid weather, or are landing in adverse conditions. This cohort are the ones who later seek out low level training because they appreciate that this will increase their toolbox of skills and knowledge – and perhaps save them from becoming a statistic.


First and foremost, all pilots should receive genuine low level exposure during their early training. It should be part of their skills toolbox in order that they can cope better with emergencies such as a forced landing plus/minus power.

Low level training would be much more acceptable were it to be categorised under flight activity endorsements. This would allow for it to not require an ATO/FE to test and recheck it at every flight review. The rating status just isn’t defensible because it doesn’t qualify the pilot for any other useful activity such as mustering – for this you need a further endorsement.

The flight activity endorsement has no renewal requirement other than 90 day, yet could be part of a flight review. Add to all of the above, were it to be a flight activity endorsement, then the price is more attractive and so we’d expect more pilots to undertake the training.

If the regulator and the industry were to promote low level training, then this will create a realistic understanding of the risks and benefits involved. Instead, all I hear is derogatory comments about ‘scud running’ and ‘cowboy flying’. This arrogant attitude. (usually from the ignorami), is part of the flying culture that both the industry and regulator need to modify.

Only when both adopt positive approaches to low level, will the accident rate be reduced. My contention is that it will help to create a more prudent approach to low flying, and it will save lives.

It might even awaken the cowboys to how little they know. To quote the well known Cheneyism: You don’t know what you don’t know. Which is certainly true of low level.

Over time, it will allow for both the industry and the regulator to better identify and even profile the recalcitrants.

Instructors should all have low level qualifications. A low level training endorsement seems about the level they should aim for by the time they reach Grade 1. Personally, I teach emergency sequences with the confidence that only low level experience can bring to the right hand seat.

I’ve been flying for more than a few decades, and I offer these proposals in the hope that our regulator and the industry agree. Less regulation and more training is my answer.

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