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

Response 138572750

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Personal information

Last name?

Last name (Required)
Gratton

Do your views officially represent those of an organisation?

If yes, please specify the name of the organisation.
GRATTON AVIATION SERVICES PTY LTD

Issues and opportunities

1. In regard to general aviation, have you experienced issues and/or challenges in any of the following areas? (Select all that apply).

Please select all that apply
Maintenance organisation requirements
Independent licensed aircraft maintenance engineer (LAME) privileges
Generic inspection schedule
Maintenance certifications
Maintenance release
Pilot maintenance
Maintenance records and logbook requirements
Modifications and repairs
Ticked Other
(please specify)
Concerned about overall costs of prescribed maintenance and the effects of this on GA and users.

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
The current regulations force maintenance organisations to be responsible for a/c airworthiness where this is correctly the responsibility of the a/c owner or operator. Australia should not perpetuate a unique system which, in our heavily litigious community , causes maintenance organisations (and therefore owner/operators) increased costs.

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.
A well proven system that places responsibility and oversight levels appropriately and provides the required degree of safety for GA Operations. The increased role and tasks of the independent maintainer would have considerable advantages.
b) What could be some potential limitations if Australia adopted the United States’ model for regulating general aviation maintenance? Please detail.
The US system works in an aviation community of massive scale compared to Australia. The applicability of this system to small workshops would have to be considered.

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 well proven system that places responsibility and oversight levels appropriately and provides the required degree of safety for GA Operations. Also a system that has been proven to work in a small scaled industry similar to Australia.

3. Europe

a) What would you see as the main benefits in adopting the European model for regulating general aviation maintenance? Please detail.
Alignment of existing Part 66 licensing to hopefully provide some movement between GA and airline maintainers, in either direction.
b) What could be some potential limitations if Australia adopted the European model for regulating general aviation maintenance? Please detail.
The system is not mature and is largely developmental, with the Europeans historically being very process and organisationally based.

4. Canada

a) What would you see as the main benefits in adopting the Canadian model for regulating general aviation maintenance? Please detail.
The increased powers of a LAME.

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
I believe the similarity between NZ and US Regs and the fact that NZ regs are proven to wok in a small industry and a similar legislative structure to Australia means that a high priority should be given to adoption of one of these, preferably NZ.

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
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)
Recreational pilot/private pilot
Maintenance authority
Aircraft design/engineering/building
Maintenance organisation
Maintenance training organisation
Licensed aircraft maintenance engineer
Aircraft maintenance engineer
Consultant & other professional services
Chief engineer
Government organisation
Safety manager
CASA officer
Other (Specify)