Considerable expense and monitoring involved in operating an approved Maint Org.Customer base needs to be protected to remain viable in G.A.environment.
Maint Org LAME to have same privileges as independant LAME ,Simplify documentation/certification of installations where item manufacturer provides instructions .
2. What kind of issues and/or challenges are you currently experiencing in regard to general aviation, and how have they impacted you?
Comments
I am seeing a severe decline in GA activity,partially due to aging GA pilots not being replaced,the limited availability and cost of instruction in country areas with flying schools having to operate with much higher reporting requirements than in the past.
Small country flying schools that trained so many pilots in the past are no longer able to operate under the current requirements,although RA Aus schools appear to be able to.
Cessna SID programs which I support have resulted in numbers of aicraft,particularly the light twins grounded because the owners have not elected to go ahead.
Other areas of concern are the dramatic increases of parts,particularly Textron Cessna and the high cost of Data.
Severe shortage of LAMEs
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
While CASA is looking to improve the regulatory system to save costs in the GA Industry by possibly basing new regs on the FARS or another system,an assessment of how real savings to the aircraft owner/operator can and are going to be achieved should be carried out.
A change to the regs will necessitate all MOQMs to be rewritten /updated.
As I understand in the American System the equivalent private and aerial work aircraft maintenance requirements are such that the manufacturers requirements are not mandated.Some examples are the Cessna SID program and in a Beechcraft forum a Baron owner stated that his wing bolts had not been removed for 34 years while another was 25 years.Here we have an Australian Air Worthiness Directive requiring the removal every 5 years and renewal after 15 years (an AMOC can be applied for to save the 5 yearly removals)
Also in the American System for private and aerial work aircraft engine field overhauls and bulk strips can be carried out,obviously this would be a great cost saving.
These are just a few examples but demonstrate some of the areas that the Industry and CASA need to address.
Although The FARs may have been in existance for 50 years so has Schedule 5
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.
(continued)I believe that there is a very strong argument that the Australian piston engined charter fleet has operated and is still to this day operating safely while benefiting from the real cost savings afforded by schedule 5 and this should be retained.
Another area of concern is to simplfy Aworthiness Directive and inspection requirements ,country of manufacture,unique Australian ADs,hidden Australian ADs ie CAOs,AWBs,SIDs etc.
b) What could be some potential limitations if Australia adopted the United States’ model for regulating general aviation maintenance? Please detail.
duplicate inspections not required,
inferior M/R and log book entries/records
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.
none
b) What could be some potential limitations if Australia adopted the New Zealand model for regulating general aviation maintenance? Please detail.
N/A
3. Europe
a) What would you see as the main benefits in adopting the European model for regulating general aviation maintenance? Please detail.
NONE
b) What could be some potential limitations if Australia adopted the European model for regulating general aviation maintenance? Please detail.
N/A
4. Canada
a) What would you see as the main benefits in adopting the Canadian model for regulating general aviation maintenance? Please detail.
NONE
b) What could be some potential limitations if Australia adopted the Canadian model for regulating general aviation maintenance? Please detail.
N/A
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 have worked in the General Aviation field since 1969,obtained a private pilot license in 1973 and a LAME license in1975,both of which are still current. I have operated my own maintenance buisiness in rural South Australia since 1987. Over a period of years there has been an ever growing decline in the activity and presence of General Aviation and I believe significant measures are needed to be taken by the regulator to assist its survival,particularly in rural areas.
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
Sport aviation (including self-administered organisations)
Flight training (including recreational, private and commercial pilot training organisations, and multi-crew training organisations)