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

Part 145 - Attempt to obtain. Excessive MOS requirements over and above CAR 30. Financially non-viable expansion of business due:- (a) Diminishing client base of private & GA owners & pilots. (b) Over regulation in training area means young persons are not encouraged. (c) Slow implementation of Drivers Licence type medicals for private pilots. (d) Delegated RA A rules more attractive ( Medicals & Maintenance privileges ). (e) Maintenance of CAR 30 standards for a small maintenance organisation vs RAA (f) Ability to train LAME's mostly in house and to allow self study. TAFE system is inadequate. (g) Approved Data - Interpretation by CASA of what is. Recognition of foreign NAA advisory data for minor modifications-avionics and equipment installations. (h) Continuing change to the Regulations affecting GA that is still not completed after 20 years. Short reviews of new law by CASA and the associated implementation of requirements by the CASA expanded bureaucracy.

We should adapt rules from NAA other than EASA as our base line. and cut out the present process. GA is having rules applied that are more suitable to RPT operations. It has to be simplified. Fix the aviation medical situation. Remove the excessive regulation on training organisations so that Aero Clubs can reform. Audit procedure:- Sadly the audit processes used being followed are so inadequate and incompetent that they result in noted discrepancies invoking in huge costs to organisations an operators and maintenance organisations way out of kilter to their importance. During audits, the Civil Aviation Act gives far too much power to individuals within CASA. It needs to be modified to restrict that power possessed by incompetent and inexperienced auditors and demand that the auditors give equal consideration to the positive as well as the negative in their reports. The penalties for failure to comply with CAR 1988 & CASR rules currently "snowball" and can add up very significantly where a discrepancy is discovered at an audit of a facility, or operation. At the moment it results in a CASA lawyers picnic. CASA have to remove this one sided legal burden. It is stifling business. The GA AME Licensing system should revert to the pre Part 66 rules which seems to be solely for the purposes of the airlines. What a cost it is. We should have a system of LAME's with Inspection Authorizations. Aircraft Certification: CASR Part 21.Recognize FAA AC 43-13-2B as approved data and introduce a form similar to the FAA 337 Form for embodiment of modifications and approval of data used.

Its a long established system with little unnecessary change. Based on my experience with American operators , mechanics and maintenance organisations, the systems work well. Many of our CASR requirements are " based on the FAR" We would gain a much more practical system with respect to changes of type design, modifications and licensing of mechanics to include an Inspection Authorisation for experienced A&P Mechanic ( Conducted by CASA)

Their A&P Certificate differs greatly from our Part 66. It may not be well accepted by current LAME's. The employer /aircraft operator decides if an A&P person is sufficiently qualified to undertake tasks. We would continue to build Australian manuals of standards that tend to make adopted rules unworkable and inappropriate. The Legal frame work will be an issue.

Cost of replicating the regulations of a close neighbor. Valid since 1995. The removal of failure to comply penalty items that accompany each and every operating and maintenance regulation. ( a total negative) An easily followed system in two parts as shown but Parts 21 ,66 & 145 needs to be read also . It is much more practical than our System

Very few

I do not see any. They have a huge budget and bureaucracy. Would cost a lot. Most of their Standards are based on the FAR.

More delays in obtaining a satisfactory outcome. Relatively low GA base

Not a lot. Quite a complex set of regulations.

Time & cost

CASA Authorised Person CASR Part 21

FAA Regulations: Accessible & understood by Australian aviation engineering professionals. Very accessible . Annual costs to Private Operators kept low by Annual IA review and return to service procedures. Commercial operators are subject to costs & Audits associated with FAA Repair Stations. IA's have a 2 yearly review. Responsibility for maintenance planning is the aircraft operators in all cases. No Maintenance Release. NZ Regulations; Based on the FAA rules and very similar. Very easily understood and concise. European EASA. Similar to the FAA but hard to access information due system complexity The GA private aircraft parts are still being developed. Canadian : A Mix of Canadian historical, FAA & EASA rules. Many parts with a different numbering system.

USA: The A&P Mechanics rating NZ: Nil Europe: Final rules - probable complexity. Low activity levels of GA . Canada: Complexity of rules parts identifications

I found that this review was very difficult. I have been on it for 5 hours. I tried to save it normally on my laptop and it only saved the blank. There is no simple Save. You have to go back to the e-mail account & reopen. To me it is very obvious that CASA will be difficult to move. So in the current political situation who knows. I have been in business for 30 years and a LAME for 51. I have issued countless certificates if airworthiness and weighed aircraft. Yesterday I talked to a major regional Queensland maintenance organisation and in the last two weeks one in South Australia. We all want to see a better performance by CASA in the areas that I have brought up. The rules that you implement have to be clear and tested. Thank you for the opportunity