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

As an aircraft owners and operators, We have difficulty in understanding CASA’s recent tendency to create additional maintenance requirements for private GA aircraft that, in most cases are uniquely Australian, with little or no data to substantiate the need for the regulations or to demonstrate that the regulations will be effective. In the past decade, CASA has mandated Cessna SIDs and have indicated that they are considering mandating similar supplemental inspections for other aircraft types. There are also projects that would require engines and propellers in private GA aircraft be overhauled based on manufacturers’ recommended time limits of 12 years for engines (Project CS 12/04) and typically 6-7 years for propellers (Amendment 3 to AD/PROP/1). In all of these cases, there has been no proper analysis of the cost, the risk or the benefit. The Australian maintenance regulations contain many other requirements that are unique to Australia (e.g. CAO100.5 requirement to drain fuel tanks and refill to check panel gauges, maintenance releases, etc.). The differences between Australian and FAA regulations often impose additional unnecessary costs of private GA owners. For many years, Australian GA maintenance regulations did not include the distinction that has long existed in FAA regulations between major and minor modifications. The consequence was that, under Australian regulations, expensive Engineering Orders (EOs) were required to authorise trivial work. Often the EO cost much more than the work. In 2015, CASA published an Advisory Circular (AC 21-12) that introduced this distinction but many LAMEs are unaware of it and still insist on EOs for work that is clearly a minor modification. These additional maintenance requirements create additional costs without any demonstrable safety benefit. Clearly Australian Regulations when compared to FAA Regulations, impose additional unnecessary costs to private GA owners in Australia.

There are about 9,000 single engine fixed wing GA aircraft in Australia, of which about a quarter reported nil flying hour in the 2015 BITRE survey, so the active fleet is now around 6,500. There are about 1,800 fixed wing GA aircraft in New Zealand, 28,000 in Europe and 155,000 in the USA. The vast majority of the worldwide GA aircraft fleet was built in the USA and resides there. The USA aircraft maintenance regulatory system was designed around maintaining such aircraft and was the blueprint for the development of maintenance systems in other countries, including Australia. There is no evidence that GA aircraft safety is any better in Australia than in the USA despite the many uniquely Australian regulations that apply here. Given this background, it is self-evident that Australia should align its GA maintenance regulations with those of the USA. Rather than modify the Australian regulations to create marginal improvements it would be better to simply incorporate by reference into Australian law the relevant regulations that apply to maintaining private GA aircraft in the USA. Changes to USA maintenance regulations should then apply automatically to Australian private GA aircraft. To do otherwise, will perpetuate the current system where Australian GA maintenance regulations differ in many confusing respects from USA regulations. It is a waste of public money for CASA to attempt to maintain a body of law that applies specifically to the maintenance of only 6,500 aircraft when there is a viable alternative that would cost virtually nothing. Since the risk posed to the general public from private GA operations is very low, CASA should scale down its GA maintenance regulatory functions and concentrate its resources on protecting the fare paying public.

Adopting FAA regulations for private GA aircraft in Australia would eliminate much of the confusion that currently exists around what maintenance is, and is not, mandatory under Australian regulations. Under FAA regulations, it is clear that owners are required to maintain their aircraft in accordance with the type certificate and the flight manual (the version that applied when the aircraft came into service) and to carry out any ADs applicable to that aircraft. Private owners in the USA are not required to other manufacturer recommendations unless they become subject to an AD. The current Australian regulations have confused this by making some manufacturer recommendations (e.g. Cessna SIDS) mandatory. Other Australian regulations (e.g. AD PROP/1) create uniquely Australian requirements for propeller overhauls that differ from the manufacturer recommendations. Furthermore, the FAA regulations are much clearer, far more concise and more easily understood by owners and maintenance organisations than current CASA regulations

The main limitation of adopting the FAA regulations would be the need to explain the changes to CASA staff and to Australian LAMEs. This cost is more than offset by eliminating the many sources of confusion that exist for LAMEs (and indeed CASA staff!) in the Australian regulations. It would be important that Australia does not “cherry pick” only parts of the FAA regulations as this would perpetuate a uniquely Australian set of regulations.

The New Zealand regulations appear to be based closely on the FAA regulations.

As the vast majority of the worldwide GA aircraft fleet was built in the USA and resides there, and the USA aircraft maintenance regulatory system was designed around maintaining such aircraft it is self-evident that Australia should align its GA maintenance regulations with those of the USA. There is no evidence that GA aircraft safety is any better in Australia or New Zealand than in the USA.

There is no apparent benefit from adopting the European regulations

Personal experience with European regulations in other, non-aviation fields has shown that their regulations are complex and difficult to understand. Furthermore, the GA industry there is small relative to the USA. The comments in relation to New Zealand regulations also apply here.

The comments in relation to New Zealand regulations also apply here.

The comments in relation to New Zealand regulations also apply here.

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The FAA have a comprehensive and coherent set of maintenance regulations that are actively maintained and applied by the vast majority of GA aircraft in the world.

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We should avoid attempting to convert the FAA regulations into the Australia drafting style as this would immediately lose the benefits of clarity, brevity and ease of understanding of the FAA regulations. Rather, the FAA regulations should be incorporated simply by reference