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BRISBANE AERO ENGINEERS PTY LTD
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Please accept this email as a response to your current consultation process on Part 66 licensing.
FYI I looked through the survey & then could not find anything that then really suited my need to offer any such feedback here, other than this broad approach here.
As in my opinion ever since such changes were made to such licensing, we have seen a further decline in the amount of people obtaining such licenses & so the industry is in a sheer crisis in this regard & I do really fear of what level of support will be offered in this industry moving forward unless some drastic changes are made & some drastic levels of support from government is then also offered in this area.
As the number of AME’s that leave this industry in sheer frustration with not being able to be duly licensed after say 6-8 years is alarming. As they then need to get some qualifications behind them all & so they can also earn some reasonable levels of income & so on & so no wonder they then all do leave..
Or when one looks at the number of people that have then also gone through such RTO over the years to say achieve an initial Cert IV & then where are they all now?
Other industries receive a lot more support from government to help boost numbers, but what levels of support does general aviation receive in this regard, zilch & just a more erroneous process with a less beneficial outcome.
As how can we have or support a licensing process that then doesn’t improve an outcome of producing more qualified people or does not align with other countries either…. So we now need to start again I believe as this Part 66 has not worked at all & the focus has to be on greatly retaining people within this industry & offering them a more concise & easier pathway to achieve such required end results.
As the concerning proposed part 43 maintenance regulations are being made way less erroneous than what is pre-existing under say CAR30 or Part 145 but then the associated licensing system is now way too erroneous. So how is that all really going to work or how can we have two opposite trains of thought here?
As currently many colleagues are looking at trying to attract qualified maintenance people from overseas, but again our CASA system & requirements make such a process way too hard for most people to then bother with.
We have also been under constant & ongoing regulatory changes for over 20 years now & so with such a process being so drawn out, again no wonder either no one really knows where they are currently at, or no wonder people coming into this industry then get a taste of what they are then in for & then again walk away, as it is all way too dysfunctional for them to all bother investing their time & money into. As anyone all simply needs a clear & defined pathway of where they are heading & how too also get there & again current that is not being provided here is it…
Or even with NDT, today one does a respective course & then sits & passes the associated exam & then they need to achieve 4-500 hours of supervised time before they are then duly qualified. All of which is unobtainable for most people or companies to then ever achieve & so on top of LAME’s becoming an extinct creature, so will respective NDT personnel & I believe that this sector of our industry is in a larger state of crisis than any other sector is & also as a result of CASA also walking away from oversighting such NDT & letting the Aust NDT sector control it all.
Or where are all the required Level III NDT oversight people then also going to come from when you look at the current low number of Level III people that the greater majority of them are also all past retirement age!
Again industry needs urgent support & the associated transport minster needs to take charge of all this & urgently….
Plus CASA also has to stop being such a reactive regulator & start being a proactive one & it also needs to become way more engaged with industry as well.
Then finally please also take note of Ken Cannane comments from AMROBA below here as well:-
Our regulatory system is based on the policy of government and inaction by CASA.
AMROBA has carried out a comparison between CASA Part 66 and EASR Part 66 and have come to the conclusion that our licencing system just cannot work.
1. Obviously needs new government policies and management to reform and modernise.
2. Must bring Australia’s regulatory system up to the global standards previously adopted from EASA and/or FAA.
Why is CASA still applying a dated EASR Part 66 system that EASA stated didn’t work and have amended it a few times to make it work for other than the airlines.
What is the policy in CASA to adopt a foreign regulatory system but never keep the CASR aligned with amendments with the foreign regulatory system.
Especially when the originating Regulator admits it is to correct errors in the previous system.
Why does CASA try to make a system work that EASA recognised did not work for all aviation, especially GA?
They have done this with both Parts 21 & 66/147.
Regulatory News CASR Part66 dated
EASR Part 66 has continually evolved in Europe but not in Australia.
• Firstly, EASA added the B3 licence up to 2000kg aeroplanes to address a GA issue. Need to adopt.
• EASA then added the “Group” ratings to address the sectors of aviation just like CAR31 group rating system. Need to adopt.
• EASA then added a B2L so the avionics had a system licence to match non airline operations. Need to adopt.
Australia’s AME licensing system is decades behind the originator’s (EASA) system.
• Same management policy as has been applied to CASR Part 21.
Australia’s Part21 “Certification Procedures for Products and Articles” is decades behind the originator’s (FAA) system.
• Time for new management and policies
CASA personnel must be living in the past whist industry continues to modernise.
A previous CASA CEO stated they would urgently re-align CASR Part 21.
We are still waiting.
When will we get a statement saying CASA will urgently re-align with EASR Part 66.
Ken Cannane
Executive Director
AMROBA
FYI I looked through the survey & then could not find anything that then really suited my need to offer any such feedback here, other than this broad approach here.
As in my opinion ever since such changes were made to such licensing, we have seen a further decline in the amount of people obtaining such licenses & so the industry is in a sheer crisis in this regard & I do really fear of what level of support will be offered in this industry moving forward unless some drastic changes are made & some drastic levels of support from government is then also offered in this area.
As the number of AME’s that leave this industry in sheer frustration with not being able to be duly licensed after say 6-8 years is alarming. As they then need to get some qualifications behind them all & so they can also earn some reasonable levels of income & so on & so no wonder they then all do leave..
Or when one looks at the number of people that have then also gone through such RTO over the years to say achieve an initial Cert IV & then where are they all now?
Other industries receive a lot more support from government to help boost numbers, but what levels of support does general aviation receive in this regard, zilch & just a more erroneous process with a less beneficial outcome.
As how can we have or support a licensing process that then doesn’t improve an outcome of producing more qualified people or does not align with other countries either…. So we now need to start again I believe as this Part 66 has not worked at all & the focus has to be on greatly retaining people within this industry & offering them a more concise & easier pathway to achieve such required end results.
As the concerning proposed part 43 maintenance regulations are being made way less erroneous than what is pre-existing under say CAR30 or Part 145 but then the associated licensing system is now way too erroneous. So how is that all really going to work or how can we have two opposite trains of thought here?
As currently many colleagues are looking at trying to attract qualified maintenance people from overseas, but again our CASA system & requirements make such a process way too hard for most people to then bother with.
We have also been under constant & ongoing regulatory changes for over 20 years now & so with such a process being so drawn out, again no wonder either no one really knows where they are currently at, or no wonder people coming into this industry then get a taste of what they are then in for & then again walk away, as it is all way too dysfunctional for them to all bother investing their time & money into. As anyone all simply needs a clear & defined pathway of where they are heading & how too also get there & again current that is not being provided here is it…
Or even with NDT, today one does a respective course & then sits & passes the associated exam & then they need to achieve 4-500 hours of supervised time before they are then duly qualified. All of which is unobtainable for most people or companies to then ever achieve & so on top of LAME’s becoming an extinct creature, so will respective NDT personnel & I believe that this sector of our industry is in a larger state of crisis than any other sector is & also as a result of CASA also walking away from oversighting such NDT & letting the Aust NDT sector control it all.
Or where are all the required Level III NDT oversight people then also going to come from when you look at the current low number of Level III people that the greater majority of them are also all past retirement age!
Again industry needs urgent support & the associated transport minster needs to take charge of all this & urgently….
Plus CASA also has to stop being such a reactive regulator & start being a proactive one & it also needs to become way more engaged with industry as well.
Then finally please also take note of Ken Cannane comments from AMROBA below here as well:-
Our regulatory system is based on the policy of government and inaction by CASA.
AMROBA has carried out a comparison between CASA Part 66 and EASR Part 66 and have come to the conclusion that our licencing system just cannot work.
1. Obviously needs new government policies and management to reform and modernise.
2. Must bring Australia’s regulatory system up to the global standards previously adopted from EASA and/or FAA.
Why is CASA still applying a dated EASR Part 66 system that EASA stated didn’t work and have amended it a few times to make it work for other than the airlines.
What is the policy in CASA to adopt a foreign regulatory system but never keep the CASR aligned with amendments with the foreign regulatory system.
Especially when the originating Regulator admits it is to correct errors in the previous system.
Why does CASA try to make a system work that EASA recognised did not work for all aviation, especially GA?
They have done this with both Parts 21 & 66/147.
Regulatory News CASR Part66 dated
EASR Part 66 has continually evolved in Europe but not in Australia.
• Firstly, EASA added the B3 licence up to 2000kg aeroplanes to address a GA issue. Need to adopt.
• EASA then added the “Group” ratings to address the sectors of aviation just like CAR31 group rating system. Need to adopt.
• EASA then added a B2L so the avionics had a system licence to match non airline operations. Need to adopt.
Australia’s AME licensing system is decades behind the originator’s (EASA) system.
• Same management policy as has been applied to CASR Part 21.
Australia’s Part21 “Certification Procedures for Products and Articles” is decades behind the originator’s (FAA) system.
• Time for new management and policies
CASA personnel must be living in the past whist industry continues to modernise.
A previous CASA CEO stated they would urgently re-align CASR Part 21.
We are still waiting.
When will we get a statement saying CASA will urgently re-align with EASR Part 66.
Ken Cannane
Executive Director
AMROBA