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

Response 587798549

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Personal information

Last name?

Last name (Required)
Re

Do your views officially represent those of an organisation?

If yes, please specify the name of the organisation.
Australian Licenced Aircraft Engineers Association

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
Maintenance certifications
Maintenance release
Pilot maintenance
Maintenance records and logbook requirements
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
Generally licencing and access to training. Both Category and Type training for recategorized aircraft following Part 66 introduction.

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 single regulatory suite would be a start. The incorporation into Part 145 of CAR 30 organisations would alleviate this. However the Standards that GA orgs are expected to achieve need to be clearly identifiable and not contain unnecessary regulatory red tape. Think - "outcome based" wording to describe what they need to do. i.e. Have required resources for the scope of work being undertaken. Clear Guidance Material and AMC's would assist the process.

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.
I would like to see a clear table outlining where the shortcomings are with the current Australian system and how each of these could be overcome by introducing the FAA Part 43
b) What could be some potential limitations if Australia adopted the United States’ model for regulating general aviation maintenance? Please detail.
I would like to see a clear table outlining where the shortcomings are with the current FAA Part 43 and how each of these could be overcome in introduced into the Australian system.

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.
As per comment for the FAA system
b) What could be some potential limitations if Australia adopted the New Zealand model for regulating general aviation maintenance? Please detail.
As per comment for the FAA system

3. Europe

a) What would you see as the main benefits in adopting the European model for regulating general aviation maintenance? Please detail.
As per comment for the FAA system
b) What could be some potential limitations if Australia adopted the European model for regulating general aviation maintenance? Please detail.
As per comment for the FAA system

4. Canada

a) What would you see as the main benefits in adopting the Canadian model for regulating general aviation maintenance? Please detail.
As per comment for the FAA system
b) What could be some potential limitations if Australia adopted the Canadian model for regulating general aviation maintenance? Please detail.
As per comment for the FAA system

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
With respect to the alternative regulatory approaches from the US, Canada, NZ and EASA it is important to recognize that each jurisdiction has different AME Licencing provisions. It is the owners responsibility to identify and ensure all of the requirement maintenance has been carried out on their aircraft. They attempt to do this by devolving theses tasks to maintenance orgs, but ultimately it doesn't remove their obligations. The concept of the Annual Airworthiness Review is one worth visiting (be it 12 monthly or at another suitable interval) with a goal of identifying the required maintenance for the aircraft. The annual review would be required to be signed off by a person qualified to do so. That person could be a LAME with an authorization to do so - similar to the IA in the FAA system, or it could be another qualified person. Based on the outcome of the Annual Review the maintenance is then acquitted by the appropriate organisation/LAME. This is essentially no different to what actually happens today, however it ensures the maintenance planning for the aircraft is documented. On the subject of independent LAME's privileges extending to complete aircraft maintenance - this could only be supported if it can be demonstrated there is a system in place to assess or provide oversight to ensure the Ind. LAME has access to the required resources and support for the scope for the work they are undertaking - including the retention of maintenance records. I note other documents relating to the information required to be recorded on maintenance documentation and suggested improvements - our comment is any work done on the aircraft needs to be recorded - parts used and their release details etc. These records should be maintained for an extended time and kept safe. The current timeframe is too short.

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