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

Response 482058474

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Personal information

Last name?

Last name (Required)
Denyer

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
Ticked Maintenance organisation requirements
Ticked Independent licensed aircraft maintenance engineer (LAME) privileges
Ticked Generic inspection schedule
Ticked Maintenance certifications
Maintenance release
Pilot maintenance
Ticked Maintenance records and logbook requirements
Ticked Modifications and repairs
Other

2. What kind of issues and/or challenges are you currently experiencing in regard to general aviation, and how have they impacted you?

Comments
CASA does not understand their own rules and regulations. There are so many "grey" areas that the rules and regulations are not clear, for example sample the status of manufacturer's service bulletins. The Part 147 Training system is also a disaster, I can not justify employing any apprectices under the current system. The part 66 licensing system is a disaster. Regulation of Non destructive testing is a shambles.

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
This is an unrealistic question to ask as it is so broad in it framing. To provide a sensible answer require hours of my time, but my basic points would be: - move aware from EASA and adopt the FAA requirements - change from "approved data" to "methods techniques and practices acceptable to the administrator" as per the FAA system.

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.
On the surface it sound much better that our current regulations but I am not an expert on the FAA regulations and their practical implications. Again this is an unrealistic question to ask in a survey such as this. Many, many hours of study and work are required to provide a sensible answer to this question.
b) What could be some potential limitations if Australia adopted the United States’ model for regulating general aviation maintenance? Please detail.
Again this is an unrealistic question to ask in a survey such as this. Many, many hours of study and work are required to provide a sensible answer to this question.

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.
Again this is an unrealistic question to ask in a survey such as this. Many, many hours of study and work are required to provide a sensible answer to this question.
b) What could be some potential limitations if Australia adopted the New Zealand model for regulating general aviation maintenance? Please detail.
Again this is an unrealistic question to ask in a survey such as this. Many, many hours of study and work are required to provide a sensible answer to this question.

3. Europe

a) What would you see as the main benefits in adopting the European model for regulating general aviation maintenance? Please detail.
Again this is an unrealistic question to ask in a survey such as this. Many, many hours of study and work are required to provide a sensible answer to this question.
b) What could be some potential limitations if Australia adopted the European model for regulating general aviation maintenance? Please detail.
Again this is an unrealistic question to ask in a survey such as this. Many, many hours of study and work are required to provide a sensible answer to this question.

4. Canada

a) What would you see as the main benefits in adopting the Canadian model for regulating general aviation maintenance? Please detail.
Again this is an unrealistic question to ask in a survey such as this. Many, many hours of study and work are required to provide a sensible answer to this question.
b) What could be some potential limitations if Australia adopted the Canadian model for regulating general aviation maintenance? Please detail.
Again this is an unrealistic question to ask in a survey such as this. Many, many hours of study and work are required to provide a sensible answer to this question.

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
This is not consultation. I first became aware of of the consultation today 22nd August, and the period closes on the 28th August. Excuse my scepticism, but after being involved in the GA Industry for nearly 30 years, and investing many, many hours attending and contributing to previous iterations of CASA thought bubbles on regulatory reform, only to either have nothing change, or to end up with more complicated systems and more red tape. There is a huge mis-match between what CASA expects of maintenance organizations and individuals working in the industry and CASA's own performance.

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)
Recreational pilot/private pilot
Maintenance authority
Aircraft design/engineering/building
Ticked 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)