LOC-I in Australian General Aviation

Flight Safety Australia Magazine 2016

http://www.flightsafetyaustralia.com/2016/03/angle-attitude-stallspin-crashes-and-how-to-avoid-them/

“According to the Australian Transport Safety Bureau (ATSB), in 2014, the number of aircraft ‘control problems’ involving general aviation (GA) aircraft was the highest [it has been] in the last 10 years. This was significantly greater than the 10-year average; however, it was consistent with the general trend (since 2010) of increasing aircraft control occurrences in GA. Around 70 per cent of these occurrences involved aeroplanes and greater than 50 per cent involved aircraft conducting private/business/sports operations. There were 60 accidents—two fatal and six serious injury accidents—and four serious incidents. Of these occurrences, 22 were investigated by the ATSB. The most common control issues were loss of control, hard landings and wheels-up landings.

The United States’ ATSB equivalent, the National Transportation Safety Board (NTSB) notes an even stronger trend. According to the NTSB, in the past decade nearly 47 per cent of all fatal aircraft crashes involved ‘loss of control’. Of those cases, nearly 80 per cent were aerodynamic stalls, weighted heavily toward stalls in the early stages of a baulked landing (‘go-around’) of instrument missed approach. In fact, loss of control in flight (LOC-I) is involved in the greatest majority of fatal air crashes in all categories of aircraft operation that fall under the NTSB’s purview—recreational, general aviation, instructional flight, business flying, corporate (professional flight crew) operations and even commercial airline flights.

Whoever’s data you use, it’s clear that we need to know a lot more about stalls and spins, and how to avoid them.”

It is worth repeating that last statement – CASA's flagship aviation safety magazine stated that “we need to know a lot more about stalls and spins, and how to avoid them.”

FAA Most Wanted

https://www.ntsb.gov/safety/mwl/Pages/default.aspx

The FAA's most wanted issues are quite clear - prevention of loss of control in flight for GA is one of them and there is much activity in the USA to address this - education and technology including regulation (new FAR 23, pilot training).

https://safetycompass.wordpress.com/2018/05/14/roundtable-discussion-about-loss-of-control-in-flight-yields-some-important-ideas/ 

"Incorporate more realistic scenarios into flight training regarding stalls. Ensure pilots have the confidence to do stall recovery."

The FAA and NTSB are much more active than the ATSB and CASA! The flight training industry in the USA is also much more active than in Australia.

What the NTSB and FAA Do

Refer https://www.flyingmag.com/preventing-loss-control-with-training-technology?src=SOC&dom=fb

“Loss of aircraft control remains the No. 1 killer of general aviation pilots, according to the National Transportation Safety Board (NTSB). At an industry roundtable hosted by the NTSB at its Washington, D.C., headquarters in April, the hot topic was how better training and technology can help pilots do a better job of flying their airplanes safely. (For a complete video archive and transcript of the discussion, visit the NTSB.)

Several of the participants suggested that flight instructors generally need more experience with slow flight and stalls so that they can teach their students to quickly and confidently recognize and recover from these conditions.”

“The FAA Airplane Flying Handbook was updated in 2016, and the chapter on slow flight and stalls is now titled Maintaining Aircraft Control: Upset Prevention and Recovery Training. The FAA defines an upset as “an event that unintentionally exceeds the parameters normally experienced in flight or in training,” such as excessive pitch attitudes and/or bank angles, or “flying at airspeeds inappropriate for the conditions.”

The handbook suggests that to avoid upsets, pilots should receive upset recovery and prevention training, including slow flight, stalls, spins and unusual attitudes.”

Also refer http://www.boldmethod.com/learn-to-fly/regulations/the-faa-updated-their-guidance-on-flight-reviews-will-it-make-flying-safer/

“The FAA just released AC 61-98D to help beef up what pilots and instructors cover in their flight reviews. While it doesn't change the regulation and minimum training requirement of FAR 61.56, it does recommend where pilots should spend their time in the review, in an effort to lower accident rates.

Loss Of Control Is The Major Concern

According to the FAA, Loss Of Control (LOC) was the number one cause for GA fatalities from 2001 through 2010.”

From that AC 61-98D:

“Regardless of the pilot’s experience, the flight instructor should review at least those maneuvers considered critical to safe flight, such as:
• Takeoffs;
• Stabilized approaches to landings;
• Slow flight;
• Stall recognition, stalls, and stall recovery;
• Spin recognition and avoidance;
• Recovery from unusual attitudes; and
• Operating the aircraft by sole reference to instruments under actual or simulated conditions.”

It is worth repeating this item: “Spin recognition and avoidance”!

The FAA’s AC 61-67C Stall and Spin Awareness Training is also relevant on the subject of flight training for stalls:

“The flight training required by part 61 does not entail the actual practicing of spins for other than flight instructor-airplane and flight instructor-glider applicants, but emphasizes stall and spin avoidance. The most effective training method contained in Report No. FAA-RD-77-26 is the simulation of scenarios that can lead to inadvertent stalls by creating distractions while the student is practicing certain maneuvers. Stall demonstrations and practice, including maneuvering during slow flight and other maneuvers with distractions that can lead to inadvertent stalls, should be conducted at a sufficient altitude to enable recovery above 1,500 feet AGL in single-engine airplanes and 3,000 feet AGL in multiengine airplanes. The following training elements are based on Report No. FAA-RD-77-26:
a. Stall Avoidance Practice at Slow Airspeeds. ………
b. Power-On (Departure) Stall. ……
c. Engine Failure in a Climb Followed by a Gliding Turn. This demonstration will show the student how much altitude the airplane loses following a power failure after takeoff and during a turn back to the runway and why returning to the airport after losing an engine is not a recommended procedure. This can be performed using either a medium or steep bank in the turn, but emphasis should be given to stall avoidance. …….
d. Cross Controlled Stalls in Gliding Turns. Perform stalls in gliding turns to simulate turns from base to final. Perform the stalls from a properly coordinated turn, a slipping turn, and a skidding turn. Explain the difference between slipping and skidding turns. Explain the ball indicator position in each turn and the aircraft behavior in each of the stalls.
e. Power-Off (Approach-To-Landing) Stalls. ……
f. Stalls During Go-Arounds. …..
g. Elevator Trim Stall. (1) Have the student place the airplane in a landing approach configuration, in a trimmed descent. (2) After the descent is established, initiate a go-around by adding full power, holding only light elevator and right rudder pressure. (3) Allow the nose to pitch up and torque to swerve the airplane left. At the first indication of a stall, recover to a normal climbing pitch attitude. ………”

This is much more thorough than a typical training syllabus conforming to CASA’s Part 61 MOS.

Question

I don't see the ATSB and CASA putting adequate attention to LOC-I. Particularly disappointed to read about one such accident where the pilot had a history of handling the aeroplane such that a stall/spin was most likely YET the report guessed that the cause of the engine failure was carburettor icing and both CASA and ATSB promptly promoted the avoidance of carburettor icing and totally ignored what caused the fatalities - stall/spin. An engine failure should not result in death.

https://www.safepilots.org/library/contributed/White%20Paper_LearnToTurn_StowellWinburn_2016.pdf

Refer the 1944 book Stick and Rudder to ATSB/CASA reports in 2007 to the Flight Safety Magazine article of 2016 to now. The biggest single cause of fatal GA accidents is stall/spin from a turn. Why don't ATSB and CASA tackle LOC-I with the same fervour as in the USA?

I put that question to Greg Hood, CEO ATSB, at the RAeS Hargrave Lecture and Dinner on 13/6/18 and he agreed that the history of accidents in the last twelve months supported the need to take more action.

DJP’s OPINION

I posted these notes on 7th June, prior to the Moorabbin accident:

http://aerobaticsaustralia.net/?p=165

A change in the emphasis and guidance by CASA could have a marked effect on the skills and awareness of all GA pilots:

1. In RPL and PPL tests plus CPL tests in single engine aircraft only, examiners should require the incipient spin entry and recovery (mandatory for the test) to be from a turn. After all, CASR 61.195 already requires all pilots to have been trained and assessed as competent in these exercises prior to the test.

2. The above action will result in more emphasis being placed on LOC-I skills and awareness training by flight training schools.

3. The same emphasis on LOC-I should be placed on Aeroplane Flight Reviews – again, the requirement is already in the regulations so only requires guidance when the existing CAAP 5.81-1 is rewritten as an Advisory Circular.

4. These actions would require improved stall/spin awareness training and ongoing refresher training for many instructors.

CASA's flagship aviation safety magazine stated in 2016 that “we need to know a lot more about stalls and spins, and how to avoid them.”

Contest Categories

The trouble with being on holiday is that there is too much spare time which occasionally leads to cogitation. Today it is the aerobatic contest categories.

For a long while, contest entry level was Sportsman then Intermediate, Advanced and Unlimited. This mirrored the IAC as, in Australia, we initially followed the IAC rules. I can remember typing up (i.e. on a small manual typewriter so it was many years ago) the first set of rules for the AAC tailored for us. Only Unlimited was in the realm of CIVA back then. We used to use the IAC Known sequences for many years.

CIVA has progressively expanded its scope to now include Intermediate / Yak 52 and Advanced – all with a distinctively European flavour as each country gets one vote. As CIVA swings in favour of the aeroplane types prevalent there the IAC sensibly continues to do it the way that suits their many members in the USA and the airplane types used there.

For a while CIVA tried to limit the performance of aircraft types in their lower categories but has long discarded that philosophy. Meanwhile the IAC sensibly maintains its policies of access to various categories with appropriate airplane types readily available.

As the capability of newer aircraft improved we saw the resulting category creep particularly in Advanced and Unlimited.

Sportsman was considered too hard to start with so Graduate was born. That was too hard for a few so we have Entry category. How many people have seen a pilot compete in Entry? Personally, I have only ever seen one such flight in a T-28.

Every now and then I hear talk of another special category for RV pilots.

We now have CIVA Intermediate and AAC Intermediate. Talk of an Intermediate category without snap rolls for Decathlons.

We have many Yak 52s in Australia and we occasionally see one at a contest. I have seen one fly Intermediate prior to that category flying the Yak 52 sequence. I have seen one accomplished Yak 52 pilot attempt to practice the Yak 52 / Intermediate Known but was unable to do it competitively so withdrew to Sportsman. Hardly seems sensible to have a Yak 52 sequence with no Yak 52 competitors.

How many competitors at a typical aerobatic contest? My estimation is that everyone will come home with a trophy.

CASR Part 61 - Flight crew licensing

CASA has a new Consultation Draft - CASR Part 61 - Flight crew licensing with 3 Feb 2012 the closing date for comments.
When the first draft of Part 61 came out about ten years ago we also had a draft Advisory Circular 91-075 to read in conjunction with it to explain how it would work - as far as aerobatics is concerned. It is also important to read it in conjunction with the draft Part 91. This time we don't have a draft AC and I really fail to see how CASA would make their draft regs wrt aerobatics function practically.
Discussion points follow.
The first point about the new regs is that it is a two tier system replacing the existing three tier system i.e. there will be no CAO equivalent. The regs should define the essential requirements leaving the AC to describe a method of compliance - in the case of aerobatics I would expect that would also represent internal CASA policy therefore mandated as the way that delegates would operate. Perhaps there will be a Manual of Standards instead of ACs for some elements.
One of the big changes with Part 61 is the Recreational Pilot Licence with limited medical certification permitting aerobatics.
Other relevant (to aerobatics) changes relate to the administration of flight activity endorsements and a different structure for instructor ratings including provision for PPL instructors. A PPL is still unable to be pilot in command if he/she receives remuneration or if the operation requires an AOC so a PPL instructor rating is of very limited use or benefit.
61.1030 defines the flight activity endorsements:
■ spinning – upright, above 3,000 ft AGL
■ aerobatics, above 3,000 ft AGL
■ low level aerobatics – down to 1500 ft AGL
■ unlimited aerobatics – at any altitude
■ formation aerobatics – a new endorsement
Subpart 61.T is all about instructor ratings. Somewhat similar to what we have now but some significant changes in how they are structured. We'll have endorsements for spin training, aerobatics training, formation training and formation aerobatics training.
Let's start with the new formation aerobatics endorsement. Australia is already much more severely regulated wrt aerobatics and formation flying than the UK and the USA. The UK is about to get EASA rules for aerobatics (let's not mention EASA's contribution to the European economy) so is slowly catching up to our bureacracy.
Hopefully there's an appropriate consideration of the transition to this new rule so that instructors who currently hold aerobatic and formation training authorities and who also have formation aerobatic experience will be granted this formation aerobatic training endorsement. If not, how does an instructor get one? Remember that CASA does not recognise military aerobatic and formation aerobatic endorsements (hopefully they will fix that now too).
That might leave us with a handfull of instructors around the country who could provide this training, not a very big market for it so no-one is going to spend much money to obtain the training authority. I've already declined to be in an aeroplane to instruct some-one in formation aerobatics - been a while since I have done it and I don't like the idea of being either PIC or passenger in an aeroplane while some-one is getting up to speed. Much better that they get some ground training and coaching from me then progress from there - a big subject and a lot of effort but they'll find it hard to get an instructor in the aeroplane with them, in my opinion. I would work with some-one from the other aircraft in developing their skills - if I trust them, we have suitable aeroplanes, wear parachutes and work up to it etc.
Question is - what is the rationale for introducing this new requirement?
Now for the spinning endorsement. i.e. upright spins above 3,000 ft AGL.
CAAP 155-1 has the flight standard and underpinning knowledge requirements (see also the CASA Day VFR Syllabus) so all pretty clear there. The CAAP also has some good, although brief, guidance on different types and recovery techniques.
The instructor rating endorsement for spin training is different in the draft new regs as there is no mention of the current requirement for it to be specific to "those aeroplanes for which he or she has been certified as competent to give such instruction". This was in recognition of some quite important differences in spin characteristics and in recovery techniques between different types. Good to recognise that but to regulate to that detail is really unworkable.
The AC could easily expand on the CAAP by providing details on the groups of aircraft (those certified for intentional spinning) with some typical characteristics and the different recovery actions.
Need consideration of Limited Category aircraft as they are approved for aerobatic training operations however not certified so what is known about their spin behaviour? Experimental (homebuilt) aeroplanes can also have characteristics which are potentially dangerous if not known to the instructor but can they be used for spin training? With a newish certified aeroplane the information must be in the Flight Manual. Old ones such as the Tiger Moth get by with tribal knowledge.
No mention of the inverted spin endorsement at all! Let's move on to the basic aerobatic endorsement - above 3,000 ft. The existing endorsement is specified in the CAO and therefore in CAAP 155-1 however there was much discussion on this a decade ago when the previous draft Part 61 was floated.
Barrel roll, loop, slow roll, stall turn and roll off the top.
My recollection is that some years ago there used to be a note to the effect that unless some-one had an endorsement comprising all five manoeuvres then that person was restricted to just performing the manoeuvres listed in the endorsement. The current note states that "If a pilot is approved to carry out more than 1 of these manoeuvres, he or she may carry out combinations of those manoeuvres." A roll off the top is a combination manoeuvre which can therefore be performed if some-one doesn't have it listed but has the other four?
I find the roll off the top useful as a definite additional skill is required. No reason to mandate it though. Some instructors teach half Cubans instead of the Immelmann (roll off the top).
Quite a few instructors give an aileron roll endorsement rather than slow roll which is quite fair in my opinion especially if learning in a Cessna Aerobat. I find that those pilots work their way around to doing passable slow rolls with a bit of practice (if they wish to develop the technique so) with no danger to themselves.
There are some who believe that snap (or flick) roll should be included as a basic manoeuvre. If mandated that would rule out some commonly used aerobatic trainers.
Regardless of whether an instructor conforms exactly to CASA's aerobatic endoesement or not, most instructors will include recoveries from extreme unusual attitudes or failed aerobatic manoeuvres. In my opinion that is the most important element of an aerobatic course yet is not specified in the CAO and gets limited acknowledgement in the CAAP.
I am sure that there will be much discussion on this. One may very well ask what happens in other comparable countries.
Low level aerobatics down to 1500 ft AGL.
The current regulations state that aerobatics may not be performed below 3,000 ft AGL without CASA permission. Hence the basic aerobatic endorsement restricts people to aerobatics above 3,000 ft. Same with spinning. (What about a stall in a normal category aircraft?) To perform aerobatics below 3,000 ft and above 1500 ft currently one must go to a CASA delegate, do the test described in the CAAP and, if successful, come away with that permission from CASA. Worth mentioning that the test officer will probably ask the reason for wanting to do aerobatics below 3,000 ft.
Nowhere in the new rules does it mandate a minimum altitude of 3,000 ft nor any other altitude. It is now intended to be controlled by individual pilot authorisations. The basic aerobatic endorsement and the spin endorsement will come with a limitation of above 3,000 ft AGL. (I say again, what about a stall in a normal category aircraft - what will be the minimum height for that?)
No mention of a spin endorsement below 3,000 ft AGL.
The draft Part 61 has no mention of who can authorise aerobatics down to 1500 ft AGL.
Currently a low level aerobatic approval may be limited to a period of two years or, perhaps after being renewed, may be permanent.
Aerobatics below 1,500 ft AGL is even more vague in the draft Part 61. We don't need much detail in the reg as the activity is fairly limited and tailored to individuals. The draft uses the term "unlimited" which will conflict with the same term used as a specific aerobatic competition category.
Currently it follows the same process as for aerobatics down to 1500 ft AGL with fewer delegates authorised at lower altitudes and keener CASA interest at lower altitudes. Additionally, there is another rule somewhere that flight below 500 ft requires specific CASA approval so aerobatics below that height is also subject to that additional approval with respect to location and date.
Competition pilots typically work progressively through the categories and lower altitudes with reviews and checks along the way to getting the next lower altitude approval by CASA or a delegate.
The regulatory reform program has been a long time coming and there are some good things in Part 61 so it would be good to implement it in my lifetime. It really needs to be implemented in conjunction with Part 91 which needs much more work after the draft earlier this year. I would expect a reasonable transition period with suitable arrangements for new authorisations granted on the basis of existing authorisations. CAAP 155-1 Aerobatics needs to be rewritten as an Advisory Circular which will require much thought and effort from where we are now. We should not make the Part 61 regulation any more prescriptive or detailed than it need be but rather manage aerobatic activities by the AC. Much easier to change the AC in future than the regulation. I know that people will say that an AC is advisory and it is true that the words will say that it is only one means of compliance with the regulations and therefore possible to do things contrary to the AC. To ensure that the AC is followed the individual authorisations and delegations must specify the AC as a mandatory condition - unless some-one has arranged a variation with CASA.
The draft Part 61 therefore needs some minor changes to ensure no misunderstanding of the essential requirement. Let's consider those first and then consider the content of the AC.
The USA has a minimum height of 1500 ft for aerobatics below which an FAA waiver is required. UK has no minimum height specified. Seems strange to me that CASA intends leaving it to industry and sport associations to manage entirely without retaining the hook as they do now by requiring CASA approval below a specified height (currently 3,000 ft). Consider some-one who receives an authorisation from their mate to conduct aerobatics down to "ground up" on a permanent basis. With the proposed reg that would remain in effect for life even if the person doesn't exercise it for, say, 50 years then one day decides to have a go at a ripe old age. Perhaps CASA doesn't want to retain the administrative burden of keeping records of all the low level permissions.
Seems to me that CASA should stay involved for aerobatics below 1500 ft to the extent of keeping records of such approvals and having the ability to cancel any if justified. There aren't that many that it is much of a burden. Above 1500 ft is of lesser concern to safety. i.e. I believe the existing rule of a specified minimum height for aerobatics, without CASA approval, should be retained and that height should be 1500 ft. That would be in Part 91.
It certainly doesn't mean that anyone with an aerobatic endorsement and spin endorsement can operate down to 1500 ft. The approvals mentioned above for those endorsements would be limited to operations above 3,000 ft AGL.
The requirement for an inverted spin endorsement has been with us for less than ten years and is not in the draft Part 61.
Before we go any further let's consider some case studies and discuss what the objectives of mandating any particular endorsement (and therefore training) in the regulation may be. These are real situations, not made up, The current rules mandate identical training and endorsements for all three.
First is M, who bought his lovely 7ECA Citabria before he got his GFPT. He just wanted to do casual Sunday afternoon aerobatics on a nice day every now and then. The Citabria pretty much behaves per "the book" as an aeroplane. The standard spin training is appropriate. Do the right thing and the aeroplane responds. Do the wrong thing and you can get into trouble. No inverted system and it tosses oil onto the airframe with any negative g so we'd rather do ballistic aileron rolls to keep a little positive g ratehr than competition style slow rolls. Similar thought with the roll off the top. I don't like doing snap rolls in a Citabria so M won't do them. The aerobatic endorsement per the current regs however is not too far off what I would recommend for M to be safe.
Next is S who also bought an aeroplane before he gained his GFPT. He got an Airtourer. Spin recovery is pretty much intuitive (for some-one who meets the stated GFPT standard for stalls). Quite a robust aeroplane with very high margins for airspeed above normal operating speeds. S is a pretty switched on guy and wouldn't do aerobatics without having received appropriate training. But to achieve the same level of safety as M I can imagine some-one saying to him: buy Stan Tilley's book on doing aerobatics in the Airtourer, go up high and have a go. That is perfectly legal in the USA and people do it.
The final case study is J who also has yet to complete his GFPT and has just purchased a Pitts Special. My recommendation on the minimum scope of training is totally different to the above. Same objectives as S and M - just wants to do the occasional loop and roll, certainly doesn't want to exploit the full potential of that aeroplane. He will never intentionally perform an inverted spin so doesn't need the endorsement. He will need extensive training in advanced spinning - upright, inverted, steep, flat, accelerated. Cross-over spins. Slow rolls are easy. Stall turns - so easily goes wrong with a violent entry to an inverted flat spin. Similar issue with the roll off the top. Snapping off the top of a loop is just too easy. I wouldn't give anyone a "check-out" in an aeroplane like that without extensive training in advanced spinning and aerobatics.
Back to the questions:
•what should be mandated in the regulation as an aerobatic endorsement?
•is an inverted spin endorsement required?
The Canadian Air Regulations apparently state that to conduct Aerobatics with a passenger, one of the following must be met, Pilot must be a holder of an aerobatic instructor rating OR have completed a 10 hour course and have their pilot logbook signed off, OR have completed 20 hours of solo aerobatic practice and have completed 1 hour of either solo or dual practice in the last 6 months.
It is worthwhile considering what is about to happen in the UK. Currently virtually no regulatory involvement in aerobatics at all but they are about to be included in the new EASA regs. Not totally inclusive as they will only apply to "EASA aeroplanes".
"FCL.800 Aerobatic rating
(a) Holders of a pilot licence for aeroplanes, TMG or sailplanes shall only undertake aerobatic flights when they hold the appropriate rating.
(b) Applicants for an aerobatic rating shall have completed:
(1) at least 40 hours of flight time or, in the case of sailplanes, 120 launches as PIC in the appropriate aircraft category, completed after the issue of the licence;
(2) a training course at an ATO, including:
(i) theoretical knowledge instruction appropriate for the rating;
(ii) at least 5 hours or 20 flights of aerobatic instruction in the appropriate aircraft category.
(c) The privileges of the aerobatic rating shall be limited to the aircraft category in which the flight instruction was completed. The privileges will be extended to another category of aircraft if the pilot holds a licence for that aircraft category and has successfully completed at least 3 dual training flights covering the full aerobatic training syllabus in that category of aircraft."
This new EASA aerobatic rating is likely to feature in CASA considerations as they seem enamoured of EASA regs as best practice worldwide - not that I've seen evidence of that in practice for GA operations.
I'm not sure what will be required in such a five hour course however the 2008 draft EASA training was:
Aerobatic Rating – Theoretical knowledge and flying training
1. The aim of the aerobatic training is to qualify licence holders to perform aerobatic manoeuvres.
2. The approved training organisation should issue a certificate of satisfactory completion of the instruction for the purpose of licence endorsement.
THEORETICAL KNOWLEDGE
3. The theoretical knowledge syllabus should cover the revision and/or explanation of:
3.1. Human factors and body limitation – spatial disorientation – airsickness – body stress and g forces, positive and negative – effects of grey and black out
3.2. Technical subjects – legislation affecting aerobatic flying to include environmental and noise subjects – principles of aerodynamics to include slow flight, stalls and spins, flat and inverted – general airframe and engine limitations
3.3. Limitations applicable to the specific aircraft category (and type) – airspeed limitations (aeroplane, helicopter, touring motor glider, sailplane – as applicable) – symmetric load factors (type related as applicable) – rolling g’s (type related – as applicable)
3.4. Aerobatic manoeuvres and recovery – entry parameters – planning systems and sequencing of manoeuvres – rolling manoeuvres – over the top manoeuvres – combination manoeuvres – entry and recovery from developed spins, flat, accelerated and inverted
3.5. Emergency procedures – recovery from unusual attitudes – drills to include use of parachutes and aircraft abandonment
FLYING TRAINING
4. The exercises of the aerobatic flying training syllabus should be repeated as necessary until the applicant achieves a safe and competent standard. The training should be tailored to the category of aircraft and limited to the permitted manoeuvres of that type of aircraft. The exercises should comprise at least the following practical training items (if permitted):
4.1. Aerobatic manoeuvres – Chandelle – Lazy Eight – Aileron Roll – Barrel Roll – Rudder Roll – Loop and inverted loop – Immelmann – Split S
4.2. Confidence manoeuvres and recoveries – slow flights and stalls – steep turns – side slips – engine restart in flight (if applicable) – spins and recovery – recovery from spiral dives – recovery from unusual attitudes
I should mention New Zealand sometime. They started their regulatory reform program at about the same time as Australia and largely completed it a very long time ago. They have an aerobatic rating so it is more bureaucratic than our flight activity endorsement however it all seems quite sensible.
“a current aerobatic flight rating authorises the holder to conduct aerobatic manoeuvres within the following limitations: (1) at a height not less than 3000 feet above the surface while carrying a passenger: (2) at a height not less than 1500 feet above the surface while not carrying a passenger: (3) at a height less than 1500 feet above the surface while not carrying a passenger when authorised by the holder of an aviation recreation organisation certificate issued in accordance with Part 149, if the certificate authorises the holder to organise aviation events.”
They require a competency check every two years.
“The flight training course should provide an introduction to the basic aerobatic manoeuvres with an emphasis on their safe and accurate execution.
The flight training course should consist of dual instruction, solo practice and consolidation.
The flight training course should cover in practice all the elements of the ground course. Particular attention should be given to engine management, the aerodynamic and loading affects of aerobatic flight on the aircraft, disorientation effects on the pilot, and the elemental need for safety,particularly recovery from unusual attitudes, the management of energy, height above the ground and situational awareness.
The course ought to be flexible enough to cater for aircraft of different performance and capabilities.
Advanced turns (more than 60-degrees of bank angle)
Spinning
Loops
Rolls
Stall turns
Combinations - eg Half cubans, half reverse cubans, and rolls off the top.
Emergencies and recovery from unusual attitudes.
It may include:
Snap rolls or other manoeuvres at the discretion of the instructor, and dependent on pilot aptitude and aircraft integrity.”
We could do a lot worse than becoming a state of NZ and adopting their aviation regulations.
Anyway, let's try for the minimum change to the draft Part 61 as we don't want to hold it up too much and let's try to make it somewhat consistent with the way we do things now however let's make it a bit more flexible.
1. CASA should retain (in Part 91) a requirement that aerobatics below 1500 ft AGL is not permitted without permission by CASA. The current requirement is 3000 ft AGL. The 1500 ft AGL requirement is identical to the USA and retains increased control over very low level aerobatics. Permissions below 1500 ft AGL may be limited as they are now – refer the CAAP. Per the draft Part 61, aerobatics below 3000 ft AGL down to 1500 ft AGL is a flight activity statement so provided by a log book entry.
2. The requirement for a formation aerobatic endorsement must be deleted as it is not workable and I see no reason to introduce it.
3. I expect the spin (upright) endorsement to be supported by training and knowledge requirements as it is now by the Day VFR Syllabus.
4. I support the deletion of the inverted spin endorsement as I could so no reason for its introduction in the '90s.
5. The basic aerobatic endorsement should be defined to include loop, aileron roll, stall turn and unusual attitude recoveries (failed attempts at these three manoeuvres).
6. Unlimited aerobatics flight activity is deleted as it becomes a permission from CASA or a delegate as currently.
A new Advisory Circular will be required and this should be based on the current CAAP 155-1 with the following changes consistent with the draft Part 61 if it is changed per my recommendations above.
1. CASA delegates will be required to issue permissions for aerobatics below 1500 ft AGL. Instructors who hold low level aerobatic permissions to 1500 ft AGL and authorised persons should be able to issue permissions to perform aerobatics (including spins) down to 1500 ft AGL.
2. The AC should include guidance on the content of aerobatic training which will depend on the capability and performance of the type in which the training is done.

Aerobatic Contest Rules Discussion Notes

Just some discussion notes about the Australian Aerobatic Club's Regulations (current version March 2010). The Contest Director is responsible for "conducting the contest in accordance with AAC ... Regulations" (I won't include CIVA rules in this discussion). They'll never be perfect but they should be continually reviewed and amended as appropriate to reflect how we want to run contests. i.e. we expect the Contest Director to follow the rules at the time. 4.3 REASONS FOR DISQUALIFICATION "b) Technical Devices - the use of technical devices for the purpose of coaching during a competition flight is prohibited." Seems to me that some people use video cameras on board the aircraft during a competition flight so are they cheating or not? 4.4 ETHICS "Abuse of any contest official or other contestant is grounds for disqualification from the contest." From the introduction, the AAC "acts through the Australian Sport Aviation Confederation" which has an anti-doping policy covering all sport aviation members from 1 January 2009. "This Anti-Doping Policy shall apply to each Participant in the activities of ASAC or any of its Member organisations by virtue of the Participant's membership, accreditation, or participation in ASAC, its Members, or their activities or Events." So, it seems to me that this policy applies to AAC events. In addition, "All members of ASAC member organisations have a duty to uphold the good name of ASAC and the air sports community. They must not tolerate harassment, discrimination or abuse, physical or mental, on other members of that community or of society as a whole." It seems to me that the ASAC code of ethics applies to the AAC and its members. If the Contest Director is responsible for conducting the contest in accordance with AAC Regulations so a participant is right to expect that to be done - the Contest Director may have a valid reason to do otherwise however I would not expect a Contest Director to simply bully contestants into actions contrary to the rules. 4.6 PILOT BRIEFING "k) It is recommended that, when possible. a "warm up" flight for the judges and contestants be flown in Known and Unknown programmes by a pilot who is a non-competing pilot. Such pilot shall fly the low altitude line(s)." I have rarely seen a warm up flight, certainly not in recent memory so if this is not going to be done the rule should be removed. Note also rule 3.17 a) whereby "All competitors will be allowed one training flight for familiarisation with the local conditions over the performance zone." There has been much discussion on this point over the years, often in the context of familiarity with the contest venue providing undue advantage. The related rule 3.17 d) forbidding other practice flights is also relevant as such flights were argued to also provide additional undue advantage (notwithstanding that some competitors arrive at the contest site far ahead of the contest to practice with no restrictions). This warm-up pilot flies the low altitude limits, not the first competitor. Having the first competitor fly the low altitude lines is njot provided for under any rule and would seem to be contrary to the spirit of the rules forbidding extra practice thereby gaining additional familiarisation. 4.14 TIME LIMITATIONS "a) A time limit of 15 minutes will apply for ..... Graduate, Sportsman and Intermediate Programmes. This will deem to start when the competitor is called into the Performance Zone ...". Aerobatic aircraft have vastly different climb performance. Some will get from take-off to altitude in less than a minute. Others may take 10 minutes. The same discrepancy is displayed with the time between the safety check manoeuvres and commencement of the sequence. The same discrepancy will show up for any break. To be fair, each competitor should have available the same amount of time in the performance zone. Total time should be allocated to aircraft of varying performance to allow equal participation in the contest. i.e. either reduce the time limit for high performance aircraft or increase it for lower performance aircraft. Three categories of performance would seem to be workable. Also, the variable start of timing is clearly not fair. Some pilots are called into the box from the holding area, some from take-off and some upon completion of flying the lower limits for the judges. In a very high performance aircraft the different applications may not matter however in a low performance aircraft the different applications are very significant. The commencement of timing should be clarified so that low performance aircraft are not unduly penalised.

Your Street

From the Sunday Herald-Sun newspaper on The Basin, just down the road from us:
" Local councils are filled with petty bureaucrats obsessed with over-regulating the lives of suburban residents."

Reminds me of the tree saga. We called the council tree expert as we were worried about one tree. He said that was OK but identified two others that should be removed - that was 10 years ago and all are still doing well. At the same time we mentioned a dead tree next to the road just at the front of our place. They weren't interested in removing it. Electricity company sent me a letter demanding removal as it was near the power lines and unsafe - I told them to talk to council. It was indeed unsafe - it came down on the road one night, fortunately no-one was injured.
The there was the spa pool fence. I rang the council and was told that I needed a permit for the fence around my portable spa pool. I filled in the form and sent the money. Got a phone call from them a few days later asking why I did that! This other guy said that I didn't need a permit and refunded my money. However, he did say that the fence would need to be inspected to make sure it was safe. "If I don't need a permit how do you know the fence is going to be there to inspect" .. "Well, we know now so we want to inspect it."
The Herald-Sun moved on to the subject of "Preachers stop in their tracks":
"There's a sign at Anita Elkington's front door that tells bible-bashers in two short words what they can do with their gospel message. ... As the wife of a retired policeman she is riled by injustice. ... and can't understand why young ratbags gain pleasure from mindless vandalism .. glass bus shelters are often smashed .. Why do the dickheads keep putting glass back in the bus shelters anyway when they know they're going to get smashed again."

Too Dumb To Fly

Editorial in the Sept-Oct issue of AOPA's magazine, Australian Pilot.
"A group of us was standing around the other day discussing the death of a fellow pilot in a crash. The newspaper story on the accident which took the pilot's life (and that of his passenger), told the usual story about what a great bloke he had been and how he had died "doing what he loved."
We all made the appropriate noises about how terrible the whole thing was for the man's family, especially for the family of the passenger who died.
Then one member of our group muttered that the crash had not come as a surprise to him and that he would never have flown with the pilot. "He was an accident waiting to happen, that bloke," he said.
Others mumbled their agreement, obviously reluctant to speak of the dead.
I hadn't knowm the pilot and so pressed them for more information. Gradually, the members of the group who had known the dead pilot, admitted more and more information about him.
They told me he had been warned several times by other pilots about his dangerous flying behaviour, that he'd been warned not to try to do aerobatic flying in an aircraft not suitable for it, and warned not to do seat-of-your-pants flying with a passenger on board if he was not qualified to do so.
Despite the warning, he had continued to fly that way, obviously supremely confident of his own ability. He got away with it every time too, until that last time.
The dead pilot had received the same rigourous training as we all have, so common sense suggests merely insisting on more training would not have been a solution to preventing this accident.
The problem turned out to be in his mind, not in his hands.
...
Maybe the only way to bring down the road toll and to weed out dangerous pilots is to prevent people with bad attitudes from getting behind the wheel in the first place."

Tony Kern's excellent book, Darker Shades of Blue: The Rogue Pilot, deals with the same subject in much more detail. Hey, isn't that a Decathlon on the cover? Could he be writing about us?

I've been promoting peer reviews per CASA's Aerobatics CAAP 155-1 for some time. I've had some vocal opposition on the basis that "we already do that" - nope, read the above editorial again - that is what you are doing and it rarely works. Peer reviews have one important difference which makes all the difference - the pilots asks people that he respects for opinions on his safety. If he doesn't ask, then that's fine with me, it is not compulsory but it doesn't take much time or effort and it doesn't cost anything. If he does ask then he should be given a truthful response not just a "feel good" stamp of approval.

A few years ago, one of my friends rang me to say he saw a flying instructor barrel roll a Warrior and asked for my advice - "tell the owner of the flying school" - but he didn't. The flying school eventually sacked him for other reasons. He didn't last long at the next flying school either. Some of the aeroplanes he has damaged over the years are known about. I wonder how many pilots were impressed by his feats of derring-do and will repeat them in future.
We must not tolerate people like that - they need to find a different career.

An Instructor's Obligation by Rick Durden:
"I've been to visit that little room where I put the memories of friends and acquaintances now dead. (It's a blunt, hard, cold word. We won't use euphemisms; they are dead.) There is a special corner in that room for those, fortunately few, who have died in airplanes. In that corner, there is a dark nook for two special pilots. They are special because I was certain they were going to kill themselves in airplanes and, even though I was a flight instructor, I either didn't or couldn't do anything about it. Despite the fact it has been over a year since the second one died, it is still a painful journey to go into that nook, because I cannot help but have the nagging feeling that I could have done more to prevent their deaths. I know the journey is one that more than a few experienced flight instructors take from time to time, usually only very late at night, and when they are alone. They agonize over what more they could have done to prevent a death.
They are the instructors who have a little deeper lines in their faces and who become very quiet from time to time.
.......
Over the years I have come to believe firmly that flight instructors have a duty to aviation. On those rare times that the experienced instructor gets to know or flies with someone who is close to that instructor's personal line on the pilot spectrum, I believe the instructor has an obligation to raise the issue with the pilot. We instructors may lose a friend or two. We may upset a pilot or four, but to not step up and try to reach the person is to shirk the responsibility we instructors so clearly have.Sometimes instruction is not fun. At those times the measly $40 per hour I charge isn't even close to being enough.
I'm not going home yet.
I just hope I will not be putting a third friend in that little nook in that room in the back of my mind."

Low Level Aerobatic Peer Reviews

Just been reading some articles at Avweb.
The first, "Lucky or Good"
http://www.avweb.com/news/probablecause/probable_cause_62_lucky_or_good_198053-1.html
"There's something about the typical experienced-pilot's personality that is antithetical to safety. I'm not an expert in analyzing personalities -- though I know what I like -- but it seems the very traits that make someone a "good stick" also make that same skilled pilot a safety risk."
and the other, "We Worry About the Wrong Things and It's Killing Us"
http://www.avweb.com/news/pilotlounge/pilots_lounge_122_we_worry_about_the_wrong_things_196933-1.html
"My friend just can't figure out why we Americans so blithely accept the true risks we face while continuing to smoke, over-eat, not wear seatbelts and not raise heck about hospital procedures, yet we get ourselves all in a twitter over the low risk items and take all sorts of expensive and often-redundant precautions that would be better spent on the high-risk stuff.
I didn't have an answer for my friend, but it caused me to look at the same question as applied to flying. While the fatality numbers for general aviation, just under 500 in 2006 -- far less than the number who die each year falling in bathtubs -- are very low, they have to be compared with the very small number of people who get into general aviation airplanes in the first place. With that in mind, our accident rate is far worse than the airlines and somewhat worse than automobiles, about the same as for motorcycles. Therefore, it's worth evaluating: Do we pilots worry about how to deal with the actual risks we face? As an aside, do we flight instructors teach students (and pilots in for recurrent training) how to identify and avoid doing stupid, high-risk things in airplanes?"
I was reminded of a discussion paper that I wrote for one of the aerobatic clubs about a year ago. There was some discussion. Some said that peer reviews are not needed as "we already tell people". Nope, you might tell some-one if they experience a sudden loss of judgement and does something silly but then they already know it themselves.
Some wanted peer reviews as a condition of permanent low level permissions. Nope, then we'll just have people chasing to get the peer review stamps in their book just before contest registration - if that, why would a contest registrar be looking for it? No-one else will be chasing it up so they won't happen.
If people don't do peer reviews for the right reasons then they won't be effective.
That discussion paper has gone nowhere so I thought that I'd share it with you here. I have seen that a few aerobatic pilots are practicing it. At one contest recently, peer reviews were apparently mentioned at the briefing and offered the assistance of a stamp. Unfortunately not many pilots know what a peer review actually was.

When CASA issued CAAP 155-1, Aerobatics, in January 2007 they introduced the concept of peer reviews which has largely been ignored by the aerobatic community since then. We know that CASA has been reconsidering their policy on low level aerobatics so should the club take the initiative to improve safety for aerobatic pilots before CASA imposes any restrictions?
If you consider the details of any accidents, not just those involving aerobatics, do you think that an effective regime of peer reviews would have eliminated any of them? Or even just one – would that make it worthwhile for all to undertake peer reviews?
How safe is a novice safety pilot in a competition? What do they know of their responsibilities and required capability?
Many organisations offer Pilot Proficiency Programs for their members – should the aerobatic club undertake a similar program for the benefit of its members?
This discussion paper is prepared for use by the aerobatic club in consideration of the recent history of a large number of tragic accidents involving low level aerobatics and the potential for CASA to revise their policy with a possible adverse effect on the operations of club members.
BACKGROUND
Some years ago, CASA developed two new draft regulations, Parts 61 and 91, which included some new rules relating to aerobatics.
PART 61 FLIGHT CREW LICENSING Subpart P - Flight Activity & Maintenance Authorisations
"1.1.2 The following flight activity authorisations are specified in this Subpart -
    d) Aerobatics
    e) Aerobatics below 3000 ft AGL
    f) Aerobatics below 1500 ft AGL"
i.e. rules relating to aerobatics were to be split into three different categories as above. Basic aerobatic endorsements would be above 3000 ft as now. Aerobatics down to 1500 ft would be administered by industry i.e. appropriate instructors and others (via the aerobatic club) would have the authority to make logbook entries permitting pilots to do aerobatics down to 1500 ft. Aerobatics below 1500 ft would continue to be administered by CASA.
There was a draft Advisory Circular which had been developed by CASA in broad consultation with industry.
PART 91 GENERAL OPERATING AND FLIGHT RULES
91.075 Aerobatic Flight
"(3) The pilot in command of an aircraft must not perform aerobatic manoeuvres in the following circum stances without CASA's approval:
    (a) below 1500 feet AGL;
    (b) in the vicinity of a public gathering or at an air display;
    (c) at night."
To enable the provisions of Part 61, this rule in Part 91 above had to be altered for it to read 1500 ft instead of 3000 ft.
The aerobatic club objected to this change – they wanted to retain 3000 ft as the minimum height for aerobatics thus requiring a specific delegation for CASA for any aerobatics below 3000 ft. So, as CASA staff had changed, being unware of the broad industry consultation they took the aerobatic club's view and put 3000 ft into the draft regulation. I learnt a lesson there – even though many of us had contributed to the draft AC and rule development none of us respodned to the NPRM – we need to have responded and said it was good. CASA only got negative comments.
The draft AC 91.075(0) has been available for review in its current form since September, 2001. Appendix 1, Para 3.3 is quite clear on the subject of initial approvals for aerobatics:
"Pilots may be certified as safe to conduct all the primary aerobatic manoeuvres above a minimum height of 1500 feet, but must not be cleared for aerobatic manoeuvres below their individual spin recovery certification. A minimum height of 3000 feet is recommended for most initial approvals."
Para 2.3 also refers to limitations for inexperienced pilots. The AC also outlines requirements for aerobatic flight instructors, training and the provision of an Operations Manual which would detail the conduct of aerobatic training. This is the mechanism by which CASA would control the process for training and issue of approvals for aerobatics down to 3000 ft; and down to 1500 ft.
I went to the CASA FLOT2003 conference in Sydney specifically to have that draft changed back to the original 1500 ft and succeeded in that. But, who would've thought that the aerobatic club would oppose the new rules which were aimed at facilitating our sport. The aerobatic club purported to represent its members yet did not tell its members what it intended to do – these days it is so easy to communicate with members with email or online forums!
Six years later the regulatory reform programme (not just aerobatics) has gone nowhere so I wouldn't rely on any changes to the rules in my lifetime. i.e. we must work within the existing CAR 155 and, probably, the existing CAO 40.0.
OTHER COUNTRIES
UK
Aerobatics in the UK is not regulated in that there is no minimum height specified for aerobatics and aerobatic training is not required – there is no aerobatic endorsement (it is likely to be required soon with the new EASA rules).
http://www.caa.co.uk/docs/33/cap393.pdf page 291
The AOPA has an aerobatic training syllabus and a certificate which is generally accepted as the standard.
http://www.aopa.co.uk/scripts/course_a.php
The British Aerobatic Association and the Tiger club have standards to be demonstrated prior to their members performing at low level at their events.
Display pilots require a CAA authorisation http://www.caa.co.uk/docs/33/cap403.pdf
USA
The USA does not require aerobatic training and has no aerobatic endorsement.
http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/0/74a345ccf8eb48a6862569d900744be1/$FILE/ATTNUI98/ac91-48.pdf
Minimum height for aerobatics is 1500 ft however the IAC has gained a waiver for its members whereby they may practice and compete to competition levels without any further approval subject to that flying being within an area approved by the FAA for low level aerobatics.
http://www.iac.org/
Display flying is largely administered by ICAS with annual renewals of low level waivers which are issed by the FAA. ICAS has a detailed manual.
http://www.airshows.aero/
Canada
From some brief research, Canada has a tighter regulatory regime than Australia.
CASA POLICY - THE CAAP
Back in the '70s low level concessions were renewed annually – testing was by CASA (more correctly CASA's predecessor) or aerobatic club members approved by CASA. CASA also approved aerobatic club members to conduct low level aerobatic coaching.
Flying Operations Instruction No 13-2 Issue 2 about '93 brought some significant changes:
A low level approval will remain current while the pilot holds a valid licence.
AAC members may be approved to conduct aerobatics down to 330ft.
The AAC may nominate members for approval for the testing of AAC members for the issue of low level approvals. So far so good, but to gain approval from the CAA as a low level tester the pilot must undergo a flight test with an examiner of airmen. This flight test must be repeated annually except that it may be conducted biannually in the case of a pilot who has competed at Unlimited level at our Nationals or who has competed in a World aerobatic contest during the preceding year.

Appendix 1 contained the knowledge requirements for low level aerobatics which largely remain today.
The came another policy with durations of two years for low level aerobatic approvals and limitations on aircraft power.
CAAP 155-1 was developed with broad industry involvement and introduced the provision for CASA delegates to issue low level aerobatic permissions. It was issued in January 2007.
http://www.casa.gov.au/download/CAAPs/ops/155_1.pdf
It contained some excellent information, some of which was based on USA AC's but most was developed locally.
It introduced new guidance for threat and error management.
It introduced the recommendation for annual peer reviews.
It introduced new guidelines for low level aerobatic permissions:
It included a low level aerobatic test form with additional guidance on the conduct of the test.
It contained guidance on conditions of low level aerobatic permissions:
“6.15 Conditions On Permissions
6.15.1 A delegate cannot cancel a permission once it is issued. Therefore a delegate needs to carefully consider whether there is a need to issue the permission with conditions. Delegates may issue a low-level aerobatics permission with any conditions they believe necessary in the interests of safety. For the guidance of delegates, it is considered that the following conditions are applicable to all low level permissions to provide an acceptable level of safety:
(1) Other than one-off permissions, the permission can be issued for an indefinite period, but a delegate may include an expiry date if he or she considers this necessary in the interests of safety.
(2) A limitation to single-engine aeroplanes up to 800 hp or to a particular aircraft type or types.
(3) A height limitation specifying a minimum level for the conduct of aerobatics. Delegates may specify any height limitation they believe necessary in the interests of safety, but the following height limitations would probably cover most circumstances:
• Not below 1500' AGL;
• Not below 1000' AGL;
• Not below 500' AGL; or
• Unlimited.

Note: There is no requirement for pilots to hold a permission at each higher level before being issued one at a lower level, although some form of progression would be the normal expectation. The delegate may issue a
permission with any height limitation that is based on safety considerations.”

The sample permission letter includes the following conditions:
“1 The minimum heights and distances to maintain separation from any group of persons must be
those specified for spectators in Civil Aviation Order (CAO) 29.4.
2. Subject to clause 3, the approved person must not conduct flight manoeuvres below the
minimum heights specified under regulation 157 of CAR 1988.
3. If the approved person is permitted under this instrument to conduct flight manoeuvres below
500 feet, the flight may only be conducted over a location approved by the appropriate CASA
office as suitable for the conduct of those manoeuvres.
4. Passengers must not be carried during manoeuvres below 1500 ft, nor during any acrobatic
demonstration, display or competition.
5. The approved person is not allowed to conduct an acrobatic flight over public gatherings.
6. The approved person must not conduct acrobatic manoeuvres within or over:
(a) any location where acrobatic manoeuvres are likely to be a hazard to the navigation of
other aircraft;
(b) any location known or likely to be noise sensitive;
(c) an area where an aircraft malfunction would endanger the lives of persons.”

Most importantly, a delegate cannot withdraw or cancel a low level aerobatic permission.
Issues for the Aerobatic Club
As the club purports to represent its members and to have an interest in the safety of its members it should take a proactive approach in considering the recent history of accidents and what it should do to improve the future safety of aerobatic pilots.

Pilots are encouraged to consider accidents (not just aerobatic accidents) where a change in the way the pilot conducted his/her operations would've have avoided the accident. CAAP 155-1 offers a process for individuals to go to their peers to seek feedback on their own operations and potentially improve the way they do things from a safety point of view. Increased safety can only result from this very simple, but disciplined activity.
Peer Review Process
“The peer review process is intended to provide an independent assessment by a similarly qualified person or persons on the way the pilot conducts the activity and to identify any incorrect techniques or practices that the pilot may have developed over time. It is not intended to be a flight test for the renewal of the permission, but an opportunity for constructive discussion with other practitioners with a view to enhancing the safety of a pilot’s performance.”
As noted above, the provision for indefinite permissions carries some risks in that there is no further assessment and it is extremely difficult to take away a permission.
The peer review process should be promoted by all pilots within the club.
“7.28.3 The following is the recommended procedure for the peer review process:
• The pilot should have had sufficient recent practice and/or training to be able to conduct a sequence of low-level aerobatics safely;
• The pilot should brief the observer(s) on the sequence to be flown;
• The pilot should fly the sequence under observation, either from the ground or the aircraft down to the level of the permission, or the level to which the pilot intends to exercise the permission, if higher;
• After the flight, the pilot and the observer(s) should de-brief the sequence to identify ways in which performance and safety could be improved; and
• The review is entered in the pilot's logbook and signed by the pilot and by the observers as a record to indicate that the observation and discussion has taken place. It could include a disclaimer that the observer is not certifying the pilot's competence.
7.28.4 The observers would need to have proficiency in low-level aerobatics and preferably also in assessing low-level aerobatic performance. Suitable observers would be any one of the following:
• CAR 155 delegate; or
• At least two other low-level permission holders with similar permissions; or
• CASA Flying Operations Inspector (FOI).
7.28.5 During the debriefing process it is important to be objective in identifying items that were done well and those that could have been done better. Emphasis should be on providing input and advice on ways to improve safety and performance rather than on questioning an individual’s ability.
7.28.6 Signing-off as an observer for peer review should not be construed as certifying the competency of the pilot, but that the review has taken place and that any issues of concern have been brought to the pilot’s attention.
7.28.7 The object is not to assess the pilot as suitable or otherwise to continue to hold the permission, but in cases where continued operation by the pilot would constitute a serious risk to air safety there would be some moral responsibility for the participants to counsel the pilot and, if necessary, bring this to the attention of CASA.”

A sample form of the peer review logbook entry:
PEER REVIEW iaw CAAP 155-1 AEROBATICS Section 7.28.
I have observed a low level aerobatic sequence performed by ......................
and debriefed the pilot on opportunities to improve safety & performance.
Note: this is not a certification of competency.
Signed ................................  ARN ...............   Date ..............

The aerobatic club would be neglecting the safety of its members if it did not promote peer reviews as recommended by the CAAP. There may be other actions the aerobatic club could take to improve safety however this is one measure which has clearly been introduced by CASA and which has been ignored.
 
It is important not to let peer reviews become rubber stamping for mates. Should the aerobatic club accredit reviewers? Should the aerobatic club provide training and guidance material for reviewers? (This could include a checklist which the reviewer may chose to retain.)
 
The actual review is verbal at a debriefing session after a performance has been observed. Although the logbook entry records that the review was undertaken there is no statement of competency recorded. However, reviewers may like to keep records of debriefs for their own purposes (perhaps if they were asked by a coroner). Althought the CAAP refers to a debrief of a single performance the reviewer should be encouraged to bring up relevant matters of a broader nature.

i.e. the basic objective is to identify any hazardous attitudes and help the pilot to understand that so as to take appropriate action.

a. Antiauthority (don’t tell me!).
e.g.
I can join the circuit neater than that and save a couple of minutes, some-one will tell me if there is conflicting traffic.
That's not a zoom climb after take-off – my aeroplane can sustain a 60 deg climb angle, some-one will tell me if there is conflicting traffic.
45 minutes fuel reserves - its only going to be a 10 minute flight.
The spectators can't see me unless I'm really close to the fence during my display.

b. Impulsivity (do something quickly!)
e.g. I'm flying three Unknowns in this contest.
Miserable weather and no contest flying so I'll just do a display.

c. Invulnerability (it won’t happen to me).
e.g. All those things happen to other people because ….... but
engine failure at low level
spin just took a little longer to recover than usual
something went wrong with that lomcevak
there was nothing wrong with the aeroplane before the first flight of the day

d. Macho (I can do it).
e.g. Watch me on Utube – I can fly just as well as …......
Difficult unknown but I need to be down where the judges can see me.

e. Resignation (what’s the use?).
e.g. I need to do three monthly checks and a biannual flight review and low level aerobatic renewals so why do I need to do these peer reviews?

Some-one is likely to tell you if you nearly have an accident but then you might've scared yourself anyway. The thing is that the one that will get you will be something different, something that has been brewing for some time as a result of your display of one or more of those hazardous attitudes. No-one has enough lives to learn from their own mistakes – learn from the mistakes of others.
Safety Pilot
The following condition on low level approvals limits the qualifications of a safety pilot in competitions:
“Passengers must not be carried during manoeuvres below 1500 ft, nor during any acrobatic
demonstration, display or competition.”
The delegate may vary this however I note that there is absolutely nought in the test crtieria to assess a pilot's ability to sit in the passenger seat of an aeroplane and act as pilot in command while another pilot (who does not have a low level aerobatic permission) perform low level aerobatics, especially under the stress of a competition. How safe is a new safety pilot?
PILOT PROFICIENCY PROGRAM
Many other local organisations offer Pilot Proficiency Programmes for their members.
eg http://aviationsafety.org.au/files/ASR_GPPP_Course_Introduction_Whats_it_all_about.pdf
http://www.piper.org.au/prof.html
http://www.cessnapilotsassociationofaustralia.org.au/pilotproficiency.html
http://www.mooney.org.au/index.php/mooney-safety-ppp.html
http://www.comancheflyer.com.au/new/join.php
http://www.abs.org.au/uploads/Promo_Brochure.pdf
Perhaps it is easier to list the flying organisations which do not offer Pilot Proficiency Programs to its members?
Did you notice the insurance companies feature as sponsors or offer discounts on insurance for those who attend?
Should an Aerobatic PPP be developed as an improvement and alternative to the peer review process?
FAA AC 60-22, Aeronautical Decision Making is a good reference. Another good reference is the book "A Pilot's Guide to Safe Flying" by local author Sander Vandeth.

CONCLUSIONS
We know that CASA has been reconsidering their policy on low level aerobatics so should the club take the initiative to improve safety for aerobatic pilots before CASA imposes any restrictions?
If you consider the details of any accidents, not just those involving aerobatics, do you think that an effective regime of peer reviews would have eliminated any of them? Or even just one – would that make it worthwhile for all to undertake peer reviews?
How safe is a novice safety pilot in a competition? What do they know of their responsibilities and required capability?
Many organisations offer Pilot Proficiency Programs for their members – should the aerobatic club undertake a similar program for the benefit of its members?