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

When our aircraft was being restored I was required to get Engineering certification to fit a wooden propeller to the aircraft. This was despite the aircraft having left the factory in 1946 with a wooden propeller fitted and having only ever operated with a wooden propeller. The issue seemed to be lack of type knowledge within CASA, The aircraft had been registered in Australia continuously since 1947.

No specific issues being experienced apart from the general decline in GA activity and its impact upon the viability of both training and maintenance organisations.

The stated objective with GA maintenance requirements of adopting appropriate international standards may help to cut costs by releasing resources within CASA for use in other areas. It may also simplify documentation and maintenance process relating to aircraft built in the region whose standards are adopted by Australia.

We would have a set of standards that are broadly similar to the US and New Zealand, which would provide a much larger population of users who can provide input to the regulation development process. The requirements would be relevant for a large segment of the Australian GA aircraft population that was originally manufactured in the US, meaning that US manufacturers would be able to respond easily to Australian maintenance requirement queries. Individual LAME's could perform a broader range of work subject to appropriate certification.

The elimination of the MR as an operational document could be a retrograde step. At present it is a valuable means for a pilot to determine if an aircraft is airworthy and is operating within minimum maintenance requirements. This is particularly important where the pilot is renting an aircraft from a flying school where maintenance logbooks will generally not be available.

We would have a set of standards that are broadly similar to the US and New Zealand, which would provide a much larger population of users who can provide input to the regulation development process. Individual LAME's could perform a broader range of work subject to appropriate certification.

The elimination of the MR as an operational document could be a retrograde step. At present it is a valuable means for a pilot to determine if an aircraft is airworthy and is operating within minimum maintenance requirements. This is particularly important where the pilot is renting an aircraft from a flying school where maintenance logbooks will generally not be available (as these are often held by the maintenance organisation, which may be remote from the operating airfield). If authorised pilot maintenance tasks are to remain similar to the current Schedule 8 tasks, adoption of the New Zealand requirement for LAME training of pilots may lead to a large amount of LAME time being taken up during the implementation phase training people for tasks that are relatively simple. The NZ provisions requiring operator authorisation for pilot maintenance to be undertaken, whilst good in principle, may lead to some operational complications if a pilot is flying in a remote area and needs to repair a punctured tyre or replace a faulty spark plug. The current Australian requirement set out in paragraph 2.5 of CAAP 42ZC-1(2) would seem a more appropriate approach.

Hard to see a benefit from the information currently being provided. The current regulations relating to light aircraft are not yet fully developed and appear to be in a state of flux. The rule making framework is fairly loosely defined and over time the development of new regulations will probably suffer due to the need to cater for multiple independent member states with different vested interests.

The regulatory framework will be slow to evolve due to the nature of European Community law making process. The aircraft categories do not seem to match the current Australian 5700kg cut-off point, which may lead to complications in re-certifying existing LAME's and their maintenance operations. Given the light aircraft population in Australia, the US or NZ regulations may be more appropriate as they will be more readily understood by the majority of aircraft manufacturers, making interaction between manufacturers and LAME's or owners much more simple.

The model has a similar simplicity to the US and NZ models. Adopting the Canadian model would lighten the burden on CASA to develop new regulations. The regulatory model would have a wider audience to source feed back from as it covers two countries.

The Canadian Annual Airworthiness report appears to be overly-bureaucratic and does not provide the pilot of the aircraft with readily accessible airworthiness assurance (unlike the current Australian MR document)

No