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

Represented CASA globally as Head of Maintenance & Personnel Industry experience totals over 60 years ED of AMROBA representing design, maintenance, manufacturing and personnel for over a decade Industry auditor and advisor

Industry is stuck in between three different regulatory system, none of which are harmonised globally. The costs of over regulation and red tape is doing major damage to industry. Many businesses have already succumbed to the current system that lacks definition between CASA functions and requirements and the responsibilities of industry participants. The move to adopt the FAR system for GA that industry has demanded since mid-1990s is still the aim of AMROBA and its members. AMROBA has provided many comparison documents to CASA that demonstrates the FAR system will lower costs to GA but improve safety by adopting enhanced safety standards.

FAR Part 43 has enhanced safety standards applied to inspections and maintenance. This also impacts on the additional knowledge/skill to be held by maintenance personnel. 1. Immediate adoption of EASR Part 147 Appendix into the Part 147 MoS will enable the Aerospace IRC to develop training programs focused on the Part 66 modules during 2019. Should have happened a decade ago. 2. Introduction of a CASR Part 145 aligned with FAR Part 145 ASAP and to consider a Part145 (light) or (domestic) for aviation excluding maintenance for major domestic/airlines support EASR requirements. 3. FARs associated with general aviation should be adopted wit minimum changes so costs can be lowered and safety enhanced. 4. Introduction of the EASR Part 66 B3 licence and the EASA Sport aircraft licence. 5. Adopt the FAR Inspection Authorisation into GA to meet and use the ICAO Annex 1 Chapter 4 LAME privilege to certify a/c as airworthy post major repairs/modifications.

1. Enhanced maintenance certification standards - same as pre 1990 in CAR/CAOs 2. Adoption of ICAO maintenance release post maintenance - no period on M/R. 3. FAA FBO includes no FAA approval in GA - may need reviewing in Australia. FAR Part 145 is compulsory for propeller/engine overhaul and Part 121 operators. 4. Performance based regulations for performing maintenance and inspections. 5. Harmonisation with FARs make the US manufacturers manuals and documentation are also aligned with the FAR requirements. 6. Maintenance records will have commonality with incoming records and harmonised improving export potential. 7. A fully compatible EASR Part 66 licence system is compatible with the FAR system. 8. NZ and the Pacific also use a FAR based system AMROBA has made detailed submission defining the differences over many years.

The biggest limitation will be the ability of CASA field staff to realise the changes that the performance based FARs for GA would regulatory implement. Trained CASA staff will be essential to enabled the safer maintenance regulations to be adopted. The only area that needs to be determined is how CASA would implement the FBO system mentioned in Part 43. Adopting a strict Part 145 for Part 121 operators as required in the FARs would mean many GA CAR 30 AMOs being regulatory written out of the system. AMROBA does not see this as a safe approach but a Part 145 light/domestic, based on FAR Part 145 addressing CAR 30 basic standards is possible with consultation. CASA needs the support of AMROBA and other associations when adopting and transitioning to a FAR based system

NZ adopted their version of the FAR maintenance requirements but did not address the successful non-FAA approved maintenance organisations in the USA. Harmonisation, by adopting the FAR system, has great potential for a single aviation market in general aviation including maintenance regulations. The FAR system is the Pacific region most popular regulations.

The NZ regulations, as amended by PNG, are excellent for commercial aviation but do not support the CAR 30 AMO system prevalent in GA. Their rules work in a small country that is basically on State of Australia. Australia is larger and needs recognition of approved AMOs but this can be done by utilising the same system once used where requirements to be met were stated in Appendices to CAOs, These should be basis of a CASR Part 145 light/domestic.

The European model would remove many CASA approved support AMOs if fully adopted. In addition, much of GA is covered by Member States legislation and AME licencing. It will be many years before EASA increases its coverage of all of GA. The biggest market is within the Pacific that includes the USA & Canada. The maintenance regulations of EASA has not yet matured to address GA.

Basically the EASA approach would have more negative impact on GA. They are still discussing maintenance standards for NAA controlled aircraft. They are also discussing the introduction of AME licencing for >1000Kg and under >200Kg aircraft that the FAA implemented many years ago under their "repairman certificate" system.

The Canadian system is fairly harmonised with the FAA system and will in the future, restructure into the FAR numbering system. The Canadian model is the closest to the CAR /MOS standard used by CASA. They have some better and more compatible provisions to practices in our GA. 1. The Canadian's have an excellent owner-maintenance system that would work in Australia that should be adopted. 2. The Regulations/Standards should be the model structure CASR/MoS should be modelled on. Has some restrictions when compared to the FARs for GA.

One of the benefits with the Canadian system is that the regulator sets the standards for GA pilot licences even if when the sport aviation sectors are devolved regulatory functions to issue Canadian Authority licence to sport aviation pilots. To adopt the Canadian system is possible but would face a large workload to transfer into the FAR Part format.

Worked within the USA for around sis months and also spent time at Boeing as an airline representative. Later spent time whilst employed by CASA reviewing regulatory systems from around the world when managing CASA regulatory reform. As an airline EM, I negotiated maintenance of Australian aircraft in foreign countries. As ED of AMROBA have been involved in many members of-shore maintenance discussions.

Both Canada and the USA have proven safe general aviation regulations that are concise and have clarity, including performance based requirements. The advantage of the FAA regulations in GA is that US aircraft/component manufacturers do not always specify in their documentation material the requirements of the FARs. They simply state the requirements of the FARs take precedent over the material in their documentation. The FARs fill the gap in their manuals.

Understanding how non-FAA approved maintenance FBOs work takes time to understand and a restriction to adopting without consideration. The Canadian system is acceptable to both EASA and FAA but they have indicated that they will be adopting the FAR numbering system in the future. Why working for 6 months in the UK a few years back, observation of the EASA system worked well for the airline system, but many GA aircraft are FAA registered even some being used in flying training. Those maintaining GA aircraft would opt for the FAR system they used to maintain the FAR registered aircraft.

AMROBA has pledged its support for a FAR based GA system with minimum changes. AMROBA, if the FAR system is adopted, would also support CASA implementation and transition programs post implementation. This approach is well overdue.

Business association representing design, maintenance, manufacturing and training of technical personnel.