Ticked
Maintenance records and logbook requirements
Ticked
Modifications and repairs
Other
2. What kind of issues and/or challenges are you currently experiencing in regard to general aviation, and how have they impacted you?
Comments
As an aircraft owner, the administrative cost to make quite minor changes (the dreaded Engineering Order) is far to high and offers no value. Example: our older analogue ADF failed & we (the owners) decided to replace it. As we were putting in a newer model - same panel slot, similar weight, similar antenna, we had to get an EO, which added substantially to the cost. There was certainly no value to us or the maintenance organisation out of the EO, but CASA made a nice profit for a fee for no service (sounds familar - see Banks!). Sure, if we were putting a different wing on, an EO might make some sense.
Similar costly EOs have been needed for other minor non-airframe changes. Removing this unnecessary bureaucracy would be a good start.
Then there are the uncertainties that arise about whether a SIDS like activity for our aircraft type will or will not be introduced, the ADS-B debacle and so on.
CASA needs to understand that imposing ever increasing costs on dubious safety grounds (empty skies are safe skies perhaps??) is one of the things driving GA out of business.
3. Can you think of any opportunities that would improve our regulatory system for general aviation maintenance? For example, ways to reduce costs and red tape while maintaining a high safety standard. Please provide detail.
Comments
Yes, limit EOs to situations that have a genuine need such as a major redesign or change to the airframe, not simple internal upgrades that do not change the structure of the aircraft.
Not going years ahead of the US when bringing in nex technology - ADS-B offers advantages, but why on earth go ahead of the US and impose much higher costs because we're the bleeding edge?
Listen to GA, not just the military and airlines. Our perspectives and needs are very different. And listen doesn't mean proforma 'consultation' then ignore everthing that's been said.
Only impose a cost when there is a clear value proposition for the cost on the payee and not just because you can.
Benefits and limitations of international models
1. United States – FAA
a) What would you see as the main benefits in adopting the United States’ model for regulating general aviation maintenance? Please detail.
We'd be working in harmony with the leading GA country and the place many aircraft and engines are made. They seem to have things covered.
b) What could be some potential limitations if Australia adopted the United States’ model for regulating general aviation maintenance? Please detail.
None I am aware of.
2. New Zealand – CAA
a) What would you see as the main benefits in adopting the New Zealand model for regulating general aviation maintenance? Please detail.
A better approach than in Australia, but why not get even closer to the US approach?
b) What could be some potential limitations if Australia adopted the New Zealand model for regulating general aviation maintenance? Please detail.
Not as good as US model.
3. Europe
a) What would you see as the main benefits in adopting the European model for regulating general aviation maintenance? Please detail.
None.
b) What could be some potential limitations if Australia adopted the European model for regulating general aviation maintenance? Please detail.
Europe has little GA as we know it; much closer to the recreational aircraft approach. When you visit Europe and inquire about flying light aircraft the costs are huge as are the constraints. Let's not make things worse!!
4. Canada
a) What would you see as the main benefits in adopting the Canadian model for regulating general aviation maintenance? Please detail.
Seems similar to US, so why not use US model?
b) What could be some potential limitations if Australia adopted the Canadian model for regulating general aviation maintenance? Please detail.
Not as good as US?
International regulations
Have you worked in general aviation maintenance under the rules of any of the international models mentioned in this consultation (i.e. United States, New Zealand, Europe or Canada)?
Have you worked in general aviation maintenance under the rules of any of the international models mentioned in this consultation?
Please select one item
(Required)
Yes
Ticked
No
Final Comments
Do you have any further comments or feedback?
Comments
This looks to be a good start to consultation. Keep it up.
Final question to assist analysis
Which of the following best describes your current primary role in the aviation sector? (please select one)
Please select one item
(Required)
Aerial work
Ticked
Private flying
Business aviation
Sport aviation (including self-administered organisations)
Flight training (including recreational, private and commercial pilot training organisations, and multi-crew training organisations)