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

Lack of consistency and understanding of what maintenance is required vs recommended, difference in interpretation between CASA and maintenance organisations. Implementation of SIDS for Cessna fleet for private operations - has had a major effect on cost of compliance, viability of continued ownership of Cessna aircraft and detrimental effect on re-sale values.

As an aircraft owner, CASA's stance that the manufacturer's data is what is to be followed drives costs upwards and does not demonstrably improve safety (although it may reduce CASA's perceived liability). Manufacturers are in the business of selling parts, not ensuring safe operations. A more 'common sense' approach to maintenance, with greater embracing of careful and timely on-condition assessment of components where applicable, has not been demonstrated to be less safe than adherence to manufacturers' schedules in other countries (particularly the USA), and it is certainly more cost-effective. I sold my Cessna twin (operated privately) due to the high cost of ongoing compliance with SIDS. The inspections never found any serious flaws with the airframe or components, yet the costly, frequent, invasive and potential error-inducing inspections had to continue.

Abolish the requirement to comply with manufacturers' data and stick to the rule that actions are mandated for private operators only by Airworthiness Directives or 'Limitations for airworthiness' in the maintenance manual. Try wherever possible to avoid 'unique' knee-jerk Australian ADs - they are rarely required (if there has not been a problem in the vastly larger US fleet requiring ADs the need probably does not exist), and the flip-flopping of 'required' action as we saw with Beech control cable ADs (circa 2011) and the recent cable replacement / inspection AD changes are infuriating and costly to owners. Greater consideration should be given to the cost of compliance with a rule or directive and weighed up against the real or expected safety benefit before expensive actions are enforced. The nature and magnitude of the safety risk problem should be modelled and presented to industry in all cases as an argument for any proposed action. In general, a move towards the US FAA regulations would go a considerable way towards reducing cost and red tape.

It is simpler, compliance should be cheaper and it is based on a far greater case-history and experience of airframes and years in service than we have here in Australia. It should be seen as the exemplar. Compliance with the US model's rules would be easier for owner-operators Costs for maintenance organisations would hopefully decrease and this would reduce trickle-down costs It would enable light GA aircraft maintenance to be provided in regional areas where it can currently be difficult for owners to access. Provision for an 'A&P' type qualification would make access to routine maintenance easier, quicker and cheaper and provide a pathway for technically-minded owners to undertake simple maintenance tasks.

None that I can foresee

They are similar to the US rules, so would be as listed above

None

None. Unless driving general aviation to near extinction is the goal of the exercise, I would not aim to replicate anything that EASA has done. General aviation in Europe is on life-support and the situation probably irreversible. Changing the rules after the industry has been extinguished doesn't fix anything other than the regulator's image.

EASA no longer has a real GA industry to maintain or regulate, having overseen its demise. It will be hard to assess the impact of their revised rules, because the residual fleet and its activity is so small.

It certainly seems simpler than the current Australian requirements, but do we really need 'annual reports' and the like? I don't see any benefits and advantages over the US or NZ rules

Again a reliance on adhering to 'manufacturer's recommendations'. This drives cost and leads to over-intervention in the majority of cases. The manufacturers are in the business of selling replacement parts and limiting their liability, not necessarily ensuring safety.