Proposal to develop a tailored set of maintenance regulations for general aviation - (DP 1809SS)

No problem with maintenance records and Logbook requirements what we have works well when used properly.

The regulations are far to complex and spread out thru CAR, CASR, CAO, MOS, AWB, exemptions, etc etc. it takes far too long to try to find information and then there is so much contradicting info thru out the various documents that it is often impossible or difficult to find a definitive answer, sometimes even asking CASA for answers results in several different opinions. LAME licensing - the current system of LAME licensing is a shambles for General aviation. it is too complex, restrictive, hard to understand, expensive and there is no clear path for apprentices and employers to follow. the process is far to driven by the training organisations where there is no real competition, and prices for courses is too high. The old CAR 31 system worked perfectly well for General aviation, the licence system was clear and could be obtained incrementally as your experience and requirements changed. for example a LAME could gain and extra privilege by studying and passing a CASA exam ( which was standard across the country unlike now) the cost of which was a few text books and an exam sitting say $150 then you gained the experience working under supervision and you got a license. the new system you have to go to an approved training organization to have an exclusion removed which involves several weeks of training at a cost of $1000s plus lost income , accommodation, meals etc etc. the cost and time is prohibitive for small GA organisations and individuals. Please retain the CASA exam system.

go Back to the CAR 31 licencing system for general aviation small aircraft, stop writing ridiculously long and complex requirements. if your going to adopt another countries system then adopt it in its entirety, don't change it, which usually results in a system that doesn't work properly because the changes havn't been thought thru properly.

Tried and tested system that has been used for 50 years. if it works in the USA one of, if not the biggest GA fleet in the world then it should work here.

How to join it up with the EASA based system that has been partly introduced here to provide a pathway for AME and LAMEs to transition from GA to Airline operations

Again a tested system that has been shown to work over a period of time

How to join it up with the EASA based system that has been partly introduced here to provide a pathway for AME and LAMEs to transition from GA to Airline operations

I cant see any advantage

Problem is that it is really just a concept it is in its very early stages and it hasn't been tried or tested for many years

can't see any advantage

How to join it up with the EASA based system that has been partly introduced here to provide a pathway for AME and LAMEs to transition from GA to Airline operations

additional time to comment on a project of this size and complexity would be useful. My main issue with what we have now is the complexity and cost of the current regulations. LAME licensing is just too complex and expensive for small GA operators and individuals. The old CASA exam and licensing system worked well and provided a clear path to obtaining a license the biggest mistake i see has been to hand this over to Private operators, which has only increased the cost by many thousands of dollars and increased the time it takes to obtain a license. Many good LAMEs i have known and worked with have come from other than aviation backgrounds, the transition is now so complex and expensive that it is simply not feasible to do.