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

Matters which arose during inspections associated with Schedule 8 maintenance, which I have adequate tooling, training and skill to rectify myself, which nonetheless required the involvement of LAMEs prior to the aircraft's return to service.

The unnecessary expense of having to involve LAMEs to perform trivial maintenance on an Experimental/Amateur-Built (E/AB) aircraft.

Adopt FAA regulations pursuant to continuing airworthiness of E/AB aircraft. In particular, FAA makes the aircraft operator responsible for airworthiness. An aircraft operator can inspect, service, repair or modify at their discretion, provided they don't depart from the terms of the aircraft's Certificate of Airworthiness, and provided that the aircraft remains capable of successfully undergoing a Condition Inspection carried out by an FAA approved A&P/IA once per year. Under that scheme, an E/AB aircraft operator can facilitate a repair or upgrade by assessing their competence and making a decision about whether they can accomplish it themselves using available training and documentation, or whether they need to contract it out.

I want to be responsible for the continuing airworthiness of my own E/AB aircraft. I know it better than anyone else. I have done more schedule 8 oil changes than any LAME, I've spent more time inspecting and finessing it than any LAME. I have undertaken basic airworthiness training in gliding, and the structure and operation of a a Vans RV isn't significantly different from a Krosno KR03A Puchatek or a LET Blanik other than the fact that it's easier. Since the builder of my aircraft died six years ago, I am confident that there is nobody else alive who knows my aircraft as well as I do, or who is as strongly incentivized to keep it in an excellent state of airworthiness. Under the FAA system's treatment of E/AB aircraft (which is not described in your summary, possibly because it's aimed at operators of certified aircraft), I could take on that responsibility. I'd be able to consult with a LAME, who would still need to do a condition inspection annually; but other line maintenance and minor rectification and repairs could be carried out by my own hands, perhaps under collaboration with my local SAAA chapter. For certificated aircraft: Most GA aircraft are designed to be maintained under the FAA system. Duplicating the FAA system in Australia would be a natural fit, enabling reasonably painless transition of methods, procedures, paperwork, spare parts, and so on. FAA regulated aircraft are operated at a higher standard of safety with lower injury and fatality rates. https://www.faa.gov/news/fact_sheets/news_story.cfm?newsId=21274 -- FAA produced a preliminary estimate of 0.84 fatalities per 100,000 GA hours in FY2017. https://www.atsb.gov.au/media/5773880/ar-2017-104_final.pdf -- ATSB records 21 fatalities in GA in 2016 across slightly less than 1.2 million GA hours (table 2, 2016 trend-estimated), yielding a fatality rate of 1.75 per 100,000 hours, approximately twice the FAA's fatality rate We can no doubt speculate over many reasons why pilots in a country with worse weather conditions, more hazardous terrain, and no practical limitation on night flight manage to fly the same aircraft approximately twice as safely as Australian pilots, with less prescriptive regulations. Regardless of the reason, we should be aspiring to be more like them, and less like us.

LAMEs and CASA inspectors would require training about the differences. E/AB aircraft logbook statements stipulating systems of maintenance may require modification. Certificates of Airworthiness may require reissuing with modified operational limitations pertaining to maintenance standards.

For a private aircraft operator, it's difficult to see how the summary described in this survey departs from the CASA status quo, other than the fact that Release to Service is conducted by log book endorsement rather than by issuance of a maintenance release.

EASA's current GA maintenance rules are a corrective measure to address the way that their previous GA maintenance rules almost drove the sector broke. Their program of re-regulation is also not yet complete. I don't believe CASA should be using an unproven scheme authored by a regulatory agency with a track record of GA destruction as the basis for its own modernized scheme, especially when FAA has a ready-made proven, flexible system we could adopt with minimal effort.

One attraction of the Canadian system is the Special Certificate of Airworthiness for Owner Maintenance, which enables privately operated light aircraft to transition to a regulatory scheme where owners of type certificate aircraft can be wholly responsible for the aircraft's continuing airworthiness. The Owner Maintenance certification allows owner-pilots, with regard to their type certificated aircraft, and without maintenance training, to: · Rebuild an airplane that is out of service · Overhaul the airplane · Install used unapproved parts · Be exempt from Airworthiness Directives (AD) · Modify the airplane · Install or replace any instruments or avionics · Sign the maintenance release for all maintenance performed · Maintain the airplane Transport Canada's regulations list several dozen aircraft types eligible for the scheme: http://www.tc.gc.ca/eng/civilaviation/regserv/cars/part5-standards-a507sh-1837.htm E/AB aircraft are effectively grandfathered in by being treated much like they would be under FAA rules. One of the benefits of the scheme is that FAA analysis has strongly suggested that Canadian owner-maintained aircraft suffer fewer airworthiness-related accidents than the rest of the Canadian GA fleet. https://www.faa.gov/about/office_org/headquarters_offices/avs/offices/air/directorates_field/small_airplanes/media/p23_reorg_arcfinal.pdf Appendix H attachment C, beginning on page 330, "Canadian Owner Maintenance Class: Safety Data and Accident Rates."

Regardless of the option chosen by CASA, my strong preference is that CASA consult heavily with the SAAA to determine a set of regulations which enable a non-builder owner of an E/AB aircraft to gain a cheap and straightforward authorization for maintenance which provides its holder with capabilities equivalent to those held by an FAA-regulated pilot who owns an E/AB aircraft. Note that I am not expecting that a non-builder pilot should receive a repairman certificate which enables issuance of maintenance releases. But it should be possible for a sensible, skilled and technically proficient owner to maintain their own E/AB aircraft within the boundaries stipulated by the Certificate of Airworthiness, logbook statement, and any requirements necessary to meet the requirements of an annual condition inspection. The FAA has demonstrated a decades-long track record of safe operation under such a scheme: The safety case has well and truly been made. There should be no reason why it can't work here too.