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

Response 238823424

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Personal information

Last name?

Last name (Required)
FRANCIS

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)
The dreadful cost of LAME maintenance and certified parts. The high cost of insurance and fuel, however CASA cannot lower those costs for us.

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
Yes, since we cannot control the cost of fuel or insurance we can only control the cost of maintenance by allowing Owner Maintenance for private simple aircraft, and by selectively relaxing the need for certified aircraft to be only fitted with certified parts. A category of Owner/Maintainer can be created by drawing on the Amateur Built Experimental system and also parts of GFA and RAAus maintenance systems. None of the quoted overseas models allow such an innovation as far as I know.

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.
Absence of requirement for a certified maintenance workshop approval will lower costs, and encourage independent LAME in the regions. The rest is fairly conventional, but wont reduce private aircraft owner costs.
b) What could be some potential limitations if Australia adopted the United States’ model for regulating general aviation maintenance? Please detail.
I see no reason why a qualified LAME cannot conduct an annual inspection and issue a new MR, as at present.

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.
Absence of the need for a certified workshop for private aircraft maintenance will lower costs and foster independent LAME in small communities.
b) What could be some potential limitations if Australia adopted the New Zealand model for regulating general aviation maintenance? Please detail.
The remarks for the US system apply to NZ.

3. Europe

a) What would you see as the main benefits in adopting the European model for regulating general aviation maintenance? Please detail.
NIL
b) What could be some potential limitations if Australia adopted the European model for regulating general aviation maintenance? Please detail.
EASA has successfully suppresed GA in Europe. Under no circumstances should their appalling over-regulation be adopted.

4. Canada

a) What would you see as the main benefits in adopting the Canadian model for regulating general aviation maintenance? Please detail.
The best existing system by far. This is the only foreign system to look at.
b) What could be some potential limitations if Australia adopted the Canadian model for regulating general aviation maintenance? Please detail.
I see no reason for an annual report should be sent to the regulator annually. We need only to keep a record of the annual inspection and have it available for audit.Canada needs to allow owner maintenance, including issue of annual maintenance release.

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 wll be writing a personal submission to put some meat on the bones of my proposal for Owner Maintenance for private light aircraft. I am also a glider pilot, instructor and maintainer of fibreglass and aluminium gliders.

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
Ticked 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)
Other
Builder owner and maintainer of a RV7. Glider maintainer.