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

40 years in GA as an AME and LAME. The list is too extensive to put here. the biggest GA stuff up from CASA in the past 20 years has been the removal of the CAR 31 licence for GA maintenance.

the constant pressure from owners/operators/maintenance organisation owners to degrade maintenance standards and for non compliance with regulatory requirements. this is also experienced in the financial cost of pay for maintenance staff and materials. maintenance staff are paid poorly in GA and as a result it is extremely difficult to attract intelligent and motivated personnel to apprenticeships in GA maintenance. the lack of GA experience within CASA. most of the CASA AWI's are coming from an Airline or Military background and do not comprehend how GA operates. there is displayed and arrogance and air of superiority by some CASA staff in particular regional offices at CASA. this is well known in the industry. a lack of training from the industry of apprentices and Engineers both in theory and practical skills. this is the result of compression of the trades into 2 streams as Mechanical & Avionics which can be completed in between 3 to 4 years. these 2 streams were previously 5 trades as separate trades, (engine, airframe, electrical, instrument, radio), delivered over 4 or 5 years each in the past. there is NO way that anyone can be competent to the level previously achieved if 3 of these trades are incorporated into one trade stream of Mechanical (Eng, Airf, Elec) or Avionics (Elec, Inst, Rad) and delivered over 3 to 4 years of practical and theory training. before any movement fwd can be achieved in my mind a certain amount of going back to proven methods needs to be undertaken by the industry and CASA alike.

remove the EASA style system from GA in Australia. it works fine for the airline side of the industry but is extremely restrictive, expensive and carries too much administrative non revenue positive burden. return to a positive Engineer licence such as what we had in CAR 31 which stated what you can do and not what you cannot do. this will remove a huge amount of confusion for the industry and simplify things for LAME's in GA. keep the training syllabus the same for GA and Airlines for the licence theory content for portability. the GA licence is NOT an inferior licence to the airline engineer licence. set a standard that ALL GA maintenance organisations must adhere to for facility, documentation, personnel etc and enforce it uniformly across the industry. this will only be possible if there is a common standard established within CASA and published for all.

it is easier to detail what is NOT a benefit which are; Not a benefit to remove the need for maintenance organisation approval. Not a benefit to go back to blanket generic vague Maintenance Schedule (App D of FAR 43). Not a benefit to have A&P and IA separation in the AME Licence. Not a benefit to go back to the old days of the under the gum tree maintenance by out of the car boot LAME issuing a MR/CRS. alignment with the FAA system has always been the best way to go for GA in Australia as the vast majority of aircraft are type certified in the USA and our neighbors are aligned with them, NZ, Canada. the USA GA market is the biggest in the world and why wouldn't we align with them as we get most of our parts and aircraft from them in the GA sector. Bi lateral acceptance between FAA and CASA is most important for all across the board in aviation in Australia and yet it has been neglected for too long.

See (a) above. if aligned with the FAA system the CASA Reg's would still need to be tailored to our specific needs in Australia.

This looks very much like the FAA system. The training restriction for Pilot Approved maintenance is a positive thing. See above response 1(a) for generic similarities. CAA NZ have already done a large amount of the ground work that CASA can draw on. However, the development of these propose new rules need to be tailored to foster the Australian GA industry and NOT be a blanket reproduction of the FAA or the NZ system but should use these as a broad base template.

See 1(a), (b) responses above for similarity to FAA system.

NONE as far as I can see.

Having worked and certified in Europe and holding an EASA 66 AME Licence I am aware of the very small scale of the GA industry in Europe. EASA are only now after more than 18 years developing maintenance rules that fit for their GA industry which is demonstrably vastly smaller and different to the Australian GA industry. CASA has shown in the past 18 to 20 years of EASA style regulations in the maintenance realm that it does not work in this country for GA. the instigation of the CASR 66 AME Licence in place of the CAR 31 AME licence for GA has been a complete disaster and CASA to date have failed in all attempts to reinstate the old CAR 31 licence ratings and system in spite of constant requests from the GA industry.

NONE.

Removal of certification by a LAME for "Elementary maintenance tasks" is not good. Where is the need for a maintenance organisation for Annual/100 hry CRS/MR issue?

The reinstatement of the old CAR 31 AME Licence needs to be carried out ASAP. This will reinstate a confident statement of what a GA LAME CAN certify for and it is in line with the ICAO preferred building block modular licence. CASA needs to set a published minimum standard for GA maintenance organisations and also a basic manual for such an organisation as a template for standardization. CASA needs to have more GA trained and experienced QUAILTY LAME's recruited into a GA specific AWI group so ALL GA maintenance organisations can be on a level playing field. Compliance with the regulations needs to have less administrative burden on the GA industry and not more which has been the trend in the last 20 years. We do not need nor do we want to go back to the old days of gum tree maintenance out of the boot of a car for CRS/MR issue because there is already too much non compliance going on from maintenance and operations already based unfortunately on the desire to reduce costs. This process will most likely be seen by the industry as another CASA process that will take much time and money and result in another half baked result because the "Brains" in CASA will not listen to the industry as it has not in the past when abolishing systems that worked very well in GA. This was my initial thought when I saw this consultation notification. However I then thought that if i like most others treat this like another lost cause and say nothing then only the ill informed and lobby groups pushing their narrow issues will be heard. The brick wall that is CASA is covered in blood from the heads that we have bashed against it for years.