Response 824043559

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Personal information

Last name?

(Required)
Simms

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
Maintenance organisation requirements
Independent licensed aircraft maintenance engineer (LAME) privileges
Generic inspection schedule
Maintenance certifications
Maintenance release
Pilot maintenance
Maintenance records and logbook requirements
Modifications and repairs
Other
(please specify)
The current CAR 30 requirements are a one size fits all, but the transition to part 145 is too large a step for most organisations.
The current schedule 6 is confusing and contradictory.
The current maintenance release does not encourage recording defects
CAO 100.5 does allow some latitude

2. What kind of issues and/or challenges are you currently experiencing in regard to general aviation, and how have they impacted you?

Comments
Concerns regarding the transition to Part 145 and the complexity particularly of the CASA technical assessors worksheet.

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
If the Aerial Work limits were broadened somewhat it would reduce the number of companies having to comply with the charter(transport) requirements.

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.
A simple and effective maintenance system
b) What could be some potential limitations if Australia adopted the United States’ model for regulating general aviation maintenance? Please detail.
NONE

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.
The New Zealand regs are consistent and are relatively easy to implement and maintain.
b) What could be some potential limitations if Australia adopted the New Zealand model for regulating general aviation maintenance? Please detail.
NONE

3. Europe

a) What would you see as the main benefits in adopting the European model for regulating general aviation maintenance? Please detail.
Not many benefits if any.
b) What could be some potential limitations if Australia adopted the European model for regulating general aviation maintenance? Please detail.
Over prescriptive rules based on a GA which is totally different in operation to Australia, New Zealand, the US & Canada.

4. Canada

a) What would you see as the main benefits in adopting the Canadian model for regulating general aviation maintenance? Please detail.
A practical approach based on GA operations similar to Australia
b) What could be some potential limitations if Australia adopted the Canadian model for regulating general aviation maintenance? Please detail.
NONE

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)?

Please select one item
(Required)
Yes
No

Experience with international regulations

1. You have identified as having experience working under the general aviation maintenance rules of one or more of the international models mentioned in this consultation. Please select from the list below, those regulations to which your experience applies.

Please select all that apply
Europe
Canada
United States
New Zealand

2. What kind of role did/do you have? (You may select more than one role if applicable)

Please select all that apply
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
Other (Specify)

3. Based on your experience working with international regulations, what do you consider to be the benefits of the maintenance regulations for general aviation in that country? Please detail.

Comments
Much simpler, easy to implement and maintain.

4. Based on your working experience in international regulations, what do you consider to be the limitations of the maintenance regulations for general aviation in that country? Please detail.

Comments
Nil, all of countries other than EASA have very clear unambiguous rules (not overcomplicated)

Final Comments

Do you have any further comments or feedback?

Comments
Given a choice I would say the New Zealand regulations would be the best fit for Australia.

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
Other (Specify)