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

Shortage of L.A.M.E's - This could be attributed to the ever changing, either perceived or real, path to becoming licenced in this industry. For over 20 years apprentices have been told they are going to be licenced through TAFE only to be let down at the end and instead have to complete Basic examinations. How many young and inspiring engineers have thrown the towel in and left the industry in frustration because of this?Industry requires a clearly defined path to becoming a L.A.M.E. Prescriptive regulation- This is a constant challenge for people in industry to interpret and apply. Audit after Audit of our CAR 30 organisation has demonstrated that even the people within CASA who's job it is to audit us against the regulations are unable to consistently interpret CASA regulation, resulting in audit findings being later "acquitted by CASA" after many hours wasted. Adopting a outcome based regulatory model would assist industry. Maintenance Authorities- Our CAR 30 maintains primarily Warbird Aircraft which are no longer supported by their manufacturer or in wide spread use. As a result type courses are no longer available for their airframes or engines. This results in us having to apply to CASA every two years for Maintenance authorities to certify for maintenance on these aircraft. This adds an unnecessary cost burden to our organisation when really after so many renewals it should just be added to our individual L.A.M.E licence. The implementation of CAO 104.0 looked to improve this system, but in reality just made an administrative nightmare shifting all responsibility back to the CAR 30 and the chief Engineer. This has not worked as is clearly demonstrated by the extremely low number of organisation in the nation holding a CASA CAO104 training delegation. CASA Part66 -Licence based on EASA model is confusing. The majority of engineers no longer can confidently define what they are licenced to sign for. Engineering Orders- The re write of CASA regulations around 21 subpart M has made it all but impossible for design engineers to approve modifications to aircraft or have imposed such stringent testing requirements that these modifications are cost prohibitive. This is in some instances to the detriment of safety. The same modifications can be incorporated into a FAA administered aircraft by submitting a Form 337 and approved by the FAA at little or no cost. Industry requires a simple cost effective means of approving minor modifications such the FAA form 337. Cost and inconvenience of obtaining and maintaining a CAR 30- The cost of obtaining a CAR 30 is prohibitive to businesses resulting in no new CAR 30's starting up. Engineers should be able to use the full scope of their licence without the need for a CAR 30. Lack of knowledge on behalf of CASA of Registered Operators responsibilities- CASA is chastising CAR 30's for not managing the Airworthiness of aircraft instead of the Registered operator who's responsibility it ultimately is.

Adopt a simple internationally accepted system such as the FARs

The main benefits of the United States model is it is a simple, proven and an outcome based system.

I don't see any reason why a US based system would have potential limitations if adopted in this country.

It is in harmony with Part 43 of the United States of America's Federal Aviation Regulations.

I don't see any reason why a NZ based system would have potential limitations if adopted in this country.

I don't see any real benefit of adopting a European based model

I don't see any real benefit of adopting a Canadian based model when we could adopted a United States based model

A potential limitation is the Canadian model is not a widely understood model. Where as if we base it on a US model, everyone understands the US model.

What ever model is taken to be the basis of Australia's future GA regulations I just ask we don't modify it unnecessarily. Surely it is possible to adopt another countries regulations in its entirety and move forward in a timely fashion to grow our industry.