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

The CASA push for existing CAR 30 maintenance approval holders to embrace CASR Part 145 is ill informed and not widely understood by industry. Pilot maintenance without specific education in specific maintenance requirements, the importance of maintenance data, proper record keeping and certification for maintenance carried out is potentially dangerous. THE requirement to have a CASR 21M Engineering Order for absolutely any modification places an unreasonable burden on industry. When a modification can be carried out in accordance with approved data and the modification can be demonstrated to have no adverse affect on the aircraft or the existing aircraft systems, the FAA system of having a Form 337 prepared and certified by an Inspector is much more appropriate and affordable. Industry reality is that most Engineering orders are reverse engineered by the CASR 21M delegate AFTER the installation or modification has been put together by the LAME and the information, wiring diagrams and/or modification data has been supplied by the LAME to the CASR 21M Delegate. With the exception of generic installations or modifications on aircraft not previously modified, it makes no sense for someone in an office to try to fit the installation or modification into a non standard aircraft. In practice it often happens that the installation or modification is completed prior to the Engineering Order being completed. I would like to see a system where the person carrying out the modification would have the ability to choose whether they were prepared to complete and submit a Form 337, or if they considered the installation or modification too complex for their skill set they could choose to engage a tertiary educated CASR 21M Delegate and purchase an Engineering Order.

Licensing of younger AMEs. The jump from a Cert IV qualification in Aeroskills to a Diploma in Aeroskils is not widely understood at GA level. It is a huge burden for young AMEs who are typically aged between 22 and 30 years of age when they achieve their Cert IV and have many other life responsibilities and financial priorities. I would like to see a system where a Certificate IV holder could be considered a qualified mechanic and occupy a certifying position, and a LAME could occupy a more senior and supervisory position. More like the FAA system where an A & P Mechanic can carry out and certify for scheduled and minor maintenance, however an Inspector must carry out and certify for more complex maintenance, prepare and certify for Form 337s and carry out major repairs. Pilot maintenance without education in the basic requirements of maintenance, certification and record keeping is not responsible. CASA must take responsibility for this, and only CASA can fix it through education programs aimed at existing pilots, new pilots, and the pilot training organisations that all too often perpetuate falsehoods about pilot maintenance.

Please refer to comments in the preceding paragraphs about introducing a system where a LAME could design, document and certify for installations and modifications with reference to existing approved data where the installation or modification could be demonstrated to not adversely affect the existing aircraft systems. I have worked in the FAA system and find that the use of FAA Form 337's to be very effective.

The regulations are simpler and easier to understand. There is a smaller body of regulatory material.

CASA's willingness to budget for and carry out industry education. There is a lot of mis-information at all levels of industry about existing Australian regulations, as well as mis-information about what goes on in other countries. Whenever regulation changes it is essential that CASA undertake to fund and carry out continuous and effective education programs that ensure the new regulation is properly and fully understood by all persons who might be affected.

Airworthiness reviews are a really good idea. Allowing operators to access and use Minimum Equipment Lists approved in the country of certification is a really good idea. I understand that if an operator wants to modify a MEL that a Delegate's input and approval is appropriate, however I do not understand why Australian operators are told they are "not able to use the manufacturer produced and country of certification approved MEL".

CASA commitment to funding and carrying out education of industry personnel. It is imperative that CASA commit to a thorough and effective education program whenever there is regulatory change.

Unknown. Until the suite of regulations currently under development in Europe is published, it is inappropriate to surmise.

Unknown. Until the suite of regulations currently under development in Europe is published, it is inappropriate to surmise.

I have no experience with working in Canada or with the Canadian regulations.

I have no experience with working in Canada or with the Canadian regulations

Aircraft owner

I believe the FAA system has the most benefits overall. I believe we should consider and take points from the New Zealand regulations as they are our very close neighbour. My experience as an FAA Qualified Airframe and Powerplant mechanic demonstrates that the Australian, New Zealand and European system of splitting maintenance tasks into Airframe, Engine, Electrical, Instrument, and Radio categories is not necessary. Individual maintainers naturally gravitate into the areas where they are most comfortable and have the resources available as well as the areas where they are more naturally comfortable. The countries that do not focus on "categories" still have their specialist shops and the personnel employed by those specialist shops. The specialist shops must by necessity invest in the necessary specialist equipment and they will always require personnel who are specialist in their particular field. It is illogical to say that a maintainer who has the data, skills, and equipment can NOT certify for a particular maintenance task.

Limitations will be abuse of the system by personnel who do not respect the regulator or the regulatory system. Please also note that the abuse of the CASA system is not always deliberate, and can sometimes be that the person does not understand the complex regulation, or that they were unable to easily find the regulatory information that was applicable to their particular situation. A major limitation to the success of any regulatory change will be CASA's commitment to funding and carrying out a very thorough and complete education program aimed at all industry personnel who might be affected by the change.

A major limitation to the success of any regulatory change will be CASA's commitment to funding and carrying out a very thorough and complete education program aimed at all industry personnel who might be affected by the change.