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

We have in been instrumental in providing Part 145 expositions to a number of organizations maintaining aircraft from both RPT and GA environments. During this process we have encountered significant confusion as to the differing organizational requirements from within industry and CASA itself.

As above.

The wait time for assessment/editing and approval of MOE (all while accruing costs) is a significant burden to new entrants. Initial startup costs could be reduced by the production of a "standard exposition" which meets all of the AMC/GM for the new rules - published by CASA and freely available. This would provide new organizations with a known standard to implement before commencement. Organizations accepting the manual as written could expect a reduced assessment time (focused on the initial audit/key personnel) thus commencing productive operations faster. Changes to the organization over time could then be added to the standard manual via the change procedure. An attempt to achieve this was created via the MAAT tool however the MAAT tool is still reliant on individual operators (who are not technical writers) to produce the relevant procedures and consequently still requires a lengthy assessment process and often produces a manual which is less than user friendly.

Independent engineers ability to certify for light aircraft, reduced burden of holding 145/repair station requirements.

No model for A&P / IA split of privileges in the Australian Part 66/training requirements. Complexity of some aircraft in Airwork category probably beyond the scope of independent LAME.

Private aircraft maintained by LAME without company approval.

Pilot maintenance - training requirements would need to be specified. Who can do the training? How long is it valid for?

Unknown at this stage..presumably it will integrate well into the Part 145/66 system. CS-STAN system of standard repairs appears to have good intentions.

The European model is incomplete, and untested. Part ML will continue to evolve after implementation as Part 66 and 145. This will create an ongoing regulatory change for CASA & the Australian industry.

All regulations under one heading - simplifies compliance and regulation searches. LAME maintenance of non-commercial aircraft.

Annual report to be sent to regulator - more info required on what is in the report, who completes this and what the regulator does with it.

Given that charter will soon be integrated into air transport and the reality that the majority of LAME's and MOE's cannot survive without servicing the charter industry it is likely that the majority of MOE's in existence today will need to obtain approval to conduct air transport level maintenance if the level at which 145 approval is required is defined by operational category of the aircraft. It needs to be considered weather the risk of maintenance related accident with the current charter fleet justify the increased burden this will placed on industry. One possible solution would be to define the split between 145/GA by aircraft certification category: With Transport and Commuter Aircraft requiring 145 and all other categories requiring GA maintenance - given that the certification category is the defining factor in many maintenance decisions the risk based nature of certification rules this would provide a truly risk based divide. Whichever set of rules is chosen there must be allowance for higher level MOE's to maintain lower level aircraft and pathways for transition for LAME's from one sector to another must be clear and simple.

In addition to consulting I am a GA LAME.