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

Maintenance organisation requirements as set out in theRegs are to complex and often not understood especially by CASA AWI's that have little or no knowledge or experience of General Aviation in the first place. Schedule 5 in general is a disaster and is it is treated in industry as inspection requirements which are open to various interpretations. It is in fact a check list and should be used as such. It should only be used when an aircraft has no other or an insufficient manufacturer's maintenance program. All helicopters are maintained to their manufacturer's programs and I believe that all fixed wing aircraft should be also. CASA should mandate that all new aircraft brought into the country after a certain date should be maintained to the manufacturer's program's. An independent, appropriately licensed engineer should be able to carry out ALL maintenance on a Private aircraft operated in VMC under the VFR and certify for that maintenance for and on behalf of the owner.

Stupidity in the regulations causing inconsistancies because the Part 66 requirements were written to what the airlines wanted. EG I can certify for maintenance on an Autopilot System between Periodic Inspections yet I can't certify for the same system in the same aircraft at a periodic inspection. My company then has to fly in an Instrument Rated LAME at $1500.00 per day to carry out this inspection and certify for it. With the increasing use of electrical/electronic control devices, pumps, actuators and instrumentation the current B1 and B2 licenses should be combined such that the new GA engineer receives the equivalent of the old Groups 1 and 2 electrical and groups 1, 5, 6 and 10 instruments as well as the appropriate B1 Rating. Avionics (Radio's, RADAR etc can then be a separate rating)

Simplify the regulations. Harmonise the regulations with the associated guidance material. In fact if a regulation is written in such a convoluted manner that guidance material is required to interpret it then it is a very poorly written regulation and was most likely only written to keep somebody employed. finish the introduction of the new rules. This century if possible. Better training of CASA AWI's so that they all have the same interpretation of the regulations. Overhaul the CASA website so that it actually works in an intuitive and user friendly way. EG Find the CASA DAMP on-line training for Pilots now find the same for engineers. Increase AvSafety seminars for engineers.

The benefits would be many although I am aware that some of the FAA regulations are open to abuse because they don't have a time limit on them. EG- EXPERIMENTAL - Aircraft can be operated in this category indefinitely

We don't have Part 43 Part 42 would have to be scrapped. This would be a great thing as nobody else has a Part 42 and our Part 42 doesn't line up with any body else's Part 43. It is impossible to align Australia's Part 42 and the CAR's /CASR's to align with anything to meet the requirements of Part 43. i have tried and I have had Airworthiness people from PNG, Vanuatu and Fiji try to do so without success. This has cost my employer dearly in lost work on a couple of instances. On other occasions I have worked with the overseas people to assure them that between our CAR 30 approval and stte and federal government regulations coupled with company policies and procedures to issue us approval to be a Part 145 supplier to an overseas operator.

Harmonisation with the rest of the South West Pacific Region. I have had an FAA Airworthiness Surveyor tell me that "NZ got it right" during conversation in Samoa

Introduction of the IA qualification initially although I'm sure experienced LAME's (Chief Engineers/ Responsible Managers) could be interviewed by an AWI and issued with an IA based on previous experience.

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Simple, appropriate and easily applied and harmonised between countries. I have worked under the local adoption of the NZ regs in PNG, Solomon Islands and Vanuatu

They wanted all maintenance done to Part 145 without the IA and ability for an engineer to sign the CRS for a private aircraft. Not that there were many private aircraft in those countries. The added costs of Part 145 in GA was blamed for the almost complete cessation of Private Ops in PNG.

CASA et al needs to stop hindering not only General Aviation but all other aspects of aviation and aircraft operation and development in this country. CASA is almost as risk averse as NASA and look what that did to them.