Ticked
Maintenance records and logbook requirements
Ticked
Modifications and repairs
Ticked
Other
(please specify)
Prohibitive Cost of data, Simplification of Log Book Entries, Engineering orders for minor modifications & repairs. (ie Placards,radio fittings, routine minor welding repairs).
2. What kind of issues and/or challenges are you currently experiencing in regard to general aviation, and how have they impacted you?
Comments
(a) Data - In many cases the maintenance data for most General Aviation aircraft has not changed for many years and we are required to maintain expensive subscriptions for the older aircraft for no reason. Your normal reporting procedures (ie AD's, SB's & Letters) provide all relevant maintenance ans service information changes.
CASA could provide a complete online manual service for the common GA aircraft.
(b) Engineering Orders - It appears that the EO system has gone overboard in the requirement of the provision of orders to carry minor and routine repair work where the repair will not be a safety issue.
(c) The regulatory authority 's overreaction to perceived maintenance problem and the issue of an AD followed soon after by and amendment to Ad after industry backlash, demonstrates the authorities inability to investigate the issue properly.
This overact ion has been extremely costly to owners and the maintenance industry. For instance (AD/GEN 87, SIDS). This now forces owners not to take action on Ad's until the last minute in case of change.
The SId's program although beneficial will be detrimental to safety if the required repeat inspections are adhere to due to the damage caused in removing and rep[lacing bolts, fittings and fasteners if they have been removed previously.
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
(a) Issue of Maintenance releases - The requirement for the Chief Engineer to issue MR's.
Allow a LAME with both Airframe and Engine licenses to be able to issue the Aircraft Maintenance Releases on aircraft less than 5700 kg.
(b) Investigate the American System for log book entries.
(c) Simplify the use of AC43 for maintenance/repairs.
(d) The need to investigate ways of allowing competent personnel in specialist areas (i.e. welding & electronics "plug & play") to be able to obtain accreditation for minor repairs and fixes with out the need for the onerous costs associated with the current approval 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.
(a) Simplification & a reduction in cost.
(b) Less paperwork.
(c) Flexibility of operation.
b) What could be some potential limitations if Australia adopted the United States’ model for regulating general aviation maintenance? Please detail.
(a) Reduction in maintenance standards.
(b) Lack of control of maintenance.
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.
(a) Simplification & a reduction in cost.
(b) Less paperwork.
(c) Flexibility of operation.
b) What could be some potential limitations if Australia adopted the New Zealand model for regulating general aviation maintenance? Please detail.
(a) Reduction in maintenance standards.
(b) Lack of control of maintenance.
3. Europe
a) What would you see as the main benefits in adopting the European model for regulating general aviation maintenance? Please detail.
Little if any benefit.
b) What could be some potential limitations if Australia adopted the European model for regulating general aviation maintenance? Please detail.
Appears to be little improvement on our existing systems.
4. Canada
a) What would you see as the main benefits in adopting the Canadian model for regulating general aviation maintenance? Please detail.
(a) the reporting annually would provide a one stop record center for each aircraft and will allow for a simplified log book system.
(b) The status of all aircraft would be known.
b) What could be some potential limitations if Australia adopted the Canadian model for regulating general aviation maintenance? Please detail.
(a) There is an opportunity for the reporting system to be over engineer placing a greater burden on paperwork.
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
Simplification of the maintenance advise system would be greatly improve the research and review of log books. For example we have AD's, Country of Origin AD's, Cao's
Service Letters, Service Bulletins & Sid's and in many cases these inspections are double ups requiring the same inspection in different documents.
With all these documents there is a greater risk of an important safety item being missed.
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)