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

Regulations that are not clear and concise. Two people can read the same paragraph two very different ways so the regulation comes down to interpretation. CASA insists on keeping Airworthiness directives that do not relate to anything released by the OEM or in the case of American aircraft the FAA yet all new Airworthiness directives come from the country of manufacture. Standards required of an AMO depend on the size of the facility and number of people employed there. Why should the standard be any different if the same aircraft are maintained in different workshops surely the standard of housekeeping , maintenance control, certification requirements and spare part control should be the same. Training engineers has reached a point with Part 147 where apprentices need to complete five years away for at least three months a year with another two hours a day everyday at work. This to give us at completion a licensed engineer who is in most areas of a lower standard than those who completed there apprenticeship under the old system.

Recent communications with CASA regarding an AMOC for an AD had three different CASA reps quoting us back the AD. Finally when a CASA rep realized we could read a blanket refusal from Canberra to provide any assistance without the permission of the OEM. The OEM was consulted and cannot give permission for the relevant data to be viewed because as far as they are concerned it does not exist. It would seem that the CASA reps on the ground who are generally very helpful are hamstrung by the system and people they work for. My suggestion is to have all of CASA dedicated to helping the industry remain compliant.

I like most people in the industry do not have time to read how four other countries manage their GA industry. We had a system in Australia which worked very well for a number of years then we tried to copy another system (not working so well). If the recommendation from CASA was for our AMO to write our own exposition so it related directly to how we do things then surely CASA could take its own advice in this area and modify the current system so it more reflects how we manage GA in Australia rather than copying some other system.