Response 527516347

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Personal information

Last name?

Last name (Required)
Higgins

Do your views officially represent those of an organisation?

If yes, please specify the name of the organisation.
RAAA

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
Maintenance organisation requirements
Independent licensed aircraft maintenance engineer (LAME) privileges
Ticked Generic inspection schedule
Maintenance certifications
Maintenance release
Pilot maintenance
Maintenance records and logbook requirements
Modifications and repairs
Other
(please specify)
CAR 42B needs to be removed. Review the number of major defect reports received over many years by CASA, where aircraft have been maintained under Schedule 5. Examine the likelihood that these defects would have been found and dealt with in a more timely manner, if the aircraft were to be inspected and maintained under CAR 42 A or CAR 42C. Additionally, retain the CAR 30 system for private operations and allow for independent LAMEs. Allow experienced LAMEs (yet to be defined) to approve minor repairs, modifications, using a scaled philosophy of MITCOM and FITCOM.

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

Comments
Inappropriate maintenance instructions leading to decreasing reliability and aircraft availability. The eventual cost of repair compared to preventative maintenance costs. There is an increasing number of MROs citing increasing red tape for closing, particularly in rural and remote locations.

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
Remove CAR 42B. Retain CAR 42A or CAR 42C Alternatively, adopt the tried and proven FARs. These have been refined over the years by the FAA who are charged with the oversight of the airworthiness of the vast majority of the US manufactured aircraft types we operate in Australia. However, please don't create another unique Australian hybrid. Adopt the FARS, but don't adapt them!

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.
Review provides summary of FAA system that is basically correct. The FAR rules in Part 43 are all the scattered regulations, instruments, CAOs and other means used by CASA to state who and what is to be done. The Operations FAR parts detail when an approved AMO is required. The FAR fixed based maintenance organisations are our approved CAR 30 GA maintenance organisation. Unless you want GA maintenance to collapse by deleting AMOs, we should adopt the FARs maintenance and maintain a CAR 30 GA aspects only AMOs Adoption of the FAR based regulations, including introducing the Inspection Authorisation is highly beneficial to GA. The FAR terminology is compatible with flight and technical documents promulgated by US manufacturers.

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.
New Zealand adopted the FAR system when CASA’s predecessors were doing the same. However, they did not implement the USA Fixed Based Operator system because they, like Australia, don’t have Federal control over aerodrome to specify the standards that the FBO system has in the USA. Adopting USA system, including the FBO system, is preferable to NZ with an end result of having harmonised regulatory system

3. Europe

a) What would you see as the main benefits in adopting the European model for regulating general aviation maintenance? Please detail.
Should be totally rejected. They are still coming to terms with GA as most GA aircraft are still controlled under each member state of the EU. Their first attempt devastated their own industry. Too far behind the USA system.

4. Canada

a) What would you see as the main benefits in adopting the Canadian model for regulating general aviation maintenance? Please detail.
The Canadian system is highly supported as its structure has standards as applied under the CASRs. However, like the CARs, are not in the FAR format. Bureaucracy costs to convert would prevent recommending. However, the GA concepts are fully supported o Owner maintenance o Canadian Pilot licencing and standards for all levels of GA. o Approval and delegation of licencing functions to approved GA associations The rest is just individual inputs Adoption of the FAR system will improve safety and reduce costs but also needs the FAR operational regulations for GA to complete the efficiency of the maintenance regulations.

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 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
Maintenance organisation
Maintenance training organisation
Ticked Licensed aircraft maintenance engineer
Aircraft maintenance engineer
Consultant & other professional services
Chief engineer
Government organisation
Safety manager
CASA officer
Other (Specify)