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

Obtaining additional helicopter type ratings to be added to existing LAME licensing as CASA fail to recognise most over seas training organisations

CASAs reluctance to recognise overseas training organisations for specific engine or airframe type rating training CASA. Then unable to offer us any alternative jeans to comp,y It hinders our company expansion due to insufficient qualified LAMEs to perform Return to service

CASA. Should recognise over seas providers who offer type rating courses, without the need for CASA staff to be sent on courses to 'asses' at industry expense P147 is too onerous and most Australian providers cannot continue to provide courses There are means of conducting 'in house' engine /airframe courses, we were able to conduct in house Honeywell T55-08D engine course BUT with much push back from certain CASA staff - luckily we had support of one very good CASA expert Mick English plus the upport of our local AWI but it was a battle and should Not have been

The FAA system is by far the best model for GA We have multiple FAA A&P mechanics on our staff as well as FAA P145 and 12 FAA N registered helicopters The FAA system allows us far more flexibility in our business for growth and introducing new aircraft types The nature of our business means we MUST be able to operate outside of Australia and FAA allows that -,the CASA LAME hinders it. The FAA system aligns best with OEMs The FAA systems allows more flexibility for the role and duties of A&P holders The FAA system does not have the road blocks we are experiencing with CASA, which has become worse with introduction of P66. Obtaining engineering licence through CASA system is NOT currently working In house training

As stated above, we are FAA P145 and have FAA A&P mechanics and we do not find the FAA system as limiting in any way compared to CASA

We also operate P2 registered helicopters and fixed wing (PNG) and we hold a PNG P145, as well as PNG LAMEs The PNG system is based on and an approved version of the NZ system We find the PNG system excellent and would have no problem working within the NZ and or PNG system

Compared to CASA, minimal if any limitations which would impact

We also own and operate a complete EASA P145 system in our company based in French New Caledonia. The EASA system is Devasting to GA and should NOT be considered in any form I was part of the original CASA review for GA B3 license system about 15 years ago. It was not adopted but our P66 is very aligned with EASA and is a major factor in why P66 is such a mess The EASA (European) system has effectively destroyed GA operations in Europe

The cost and bureaucracy of operating the EASA system is devastating to GA particularly smaller operators It is the SOLE reason the mid tier GA operators, Cessna 400 series twins, Piper twins and other light but older style piston powered aircraft are no longer in operation throughout Europe Spain went from having around 30 helicopter operators down to about 5 Large operators due to the expense and difficulty of operating under the EASA system. I am actively involved in Helicopter operations throughout the World and don't know of any operator who says the EASA system is good!

Better than CASA but not as good or flexible as FAA/NZ/PNG

Would have issues similar to CASA

I have outlined the pros and cons in previous page FAA first preference PNG second preference NZ third preference Canada fourth

Previously answered FAA great PNG/Nz Very Good EASA dissasterous and Negative impact for GA Canada is workable

CASA. Needs to listen and take action in consultation with industry. Unfortunately- regardless of the results of this survey, there are still staff within CASA who are resisting logical change to allow different outcomes

Owner, chief pilot, LAME of large Helicopter and aeroplane company