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

As outlined in submissions previously, the current licencing system is complex, incomplete and has generally I believe not been well received by industry. It has been further complicated by recent changes including cancelling of AD's and inclusion into CAO's.

Provide maintenance regulations that are understandable and acceptable to all parties involved. I was not aware of major problems with the previous group licencing system apart from that it was supposedly a problem that they were not aligned with the EASA system? Regarding changes to schedule 6, I don't consider compliance to be onerous, perhaps others have different experience, I would be happy to listen to ideas about how it can be simplified even further without removing required information from log book entries etc. If there is a maintenance regulation system from another country that would work in Australia then it is a shame that we didn't adopt that system when the new licencing system was introduced. If we were to adopt the American system I am not convinced that this is the best system as my experience with the maintenance carried out on aircraft that have come into this country from the USA is that the maintenance standard and record keeping has been below the standard of what I would expect here in Australia.

I don't have enough knowledge or experience with the American system to give an educated opinion. I do hear complaints from within the American system. If it is clearer and simpler then obviously it would be of benefit

Can't comment on the system again due to lack of knowledge of the system. My experience with American maintained aircraft and maintenance organisations is that many of them don't seem to have the same standards of maintenance and record keeping that we would expect here in Australia.

I don't have a working knowledge of the New Zealand system. I believe they have stricter requirements for part traceability than what I have seen practiced here in Australia. This was introduced to help prevent the use of counterfeit parts. If it is a workable system then it could be suitable

Don't know.

Unsure.

Under the proposed EASA part ML the limitations of aircraft size and capacity i.e. no more than 4 seats in a helicopter for GA maintenance regulations means that an AS350 or B206 Longranger (or components which may be interchangeable between different models) would be maintained under a different set of rules to a Jetranger or R44 etc? I would be surprised if that is how the system would operate in Europe.

Unsure.

Learning a new system and meeting new requirements.

Under the current licencing system there is no licence outcome if you are working in a piston engine environment i.e. B1.2. I understand that the current diploma applies to B1.1 (turbine airplane). I attended a seminar when the new licencing system was introduced and it was not well received at that early stage, industry consultation and listening to feedback before introducing a new system might be a good idea. Perhaps it would have been better to retain the workable parts of the old system and make changes as necessary to meet new requirements. If we were to adopt a new system it would need to accommodate future changes without becoming overly complicated again. The manual of standards as an explanation of the licencing system is a convoluted and overly large document as is not practical due to this.