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

Response 956999584

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Personal information

Last name?

Last name (Required)
Morris

Do your views officially represent those of an organisation?

If yes, please specify the name of the organisation.
Jandair PTY LTD

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
Ticked Modifications and repairs
Other
(please specify)
The new requirement for those major modifications which have been previously certified under CAR 35 for other similar aircraft, to be covered by an STC, ids causing significant difficulties for some operators.

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
Remove the requirement for Part 21 approval for minor modifications such as fitting a different radio IAW RIDS or adding a USB socket .

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.
FAA rules make minor modification paperwork simpler
b) What could be some potential limitations if Australia adopted the United States’ model for regulating general aviation maintenance? Please detail.
The introduction of a lower class of licence ( ie. A&P) adds another level of complexity and is unnecessary. Our system where any work can be carried out by an appropriately qualified LAME is clearly better.

2. New Zealand – CAA

b) What could be some potential limitations if Australia adopted the New Zealand model for regulating general aviation maintenance? Please detail.
1 Adventure Flight aircraft maintenance is adequately covered in the new Part 132M regulations. 2. Inspection Authorisation: As with the FAA rules, the addition of another level of licence is unnecessary and adds complexity. Our existing LAME privilege/coverage is appropriate. Introduction of lower liccence categories is a degradation of standards.

4. Canada

b) What could be some potential limitations if Australia adopted the Canadian model for regulating general aviation maintenance? Please detail.
1. An annual report is a waste of time, serves no useful purpose as it is "after the event" an therefore not proactive. 2. Elementary maintenance tasks should either b e carried out under the equivalent of our Schedule 8 by a LAME trained pilot or certified by a LAME.

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)?

Have you worked in general aviation maintenance under the rules of any of the international models mentioned in this consultation?
Please select one item
(Required)
Yes
Ticked No

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
Ticked 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)