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

I am a charter operator, and private owner and for over 50 years, have been involved in hands on maintenance with my aircraft and built two aircraft one of which I still own. Consequently I witness on a very regular basis the frustrations suffered by my LAME's in attempting to stay ahead of the ongoing avalanche of regulatory change in the aircraft maintenance areas of general aviation. Of particular concern is the failure by CASA to address the ever more critical situation of shortage of LAMES due to lack of training facilities and suitable curiculums. The industry has been attempting to have this appalling situation reversed for years with little if any resonance from the regulator. The height of hypocracy is amply demonstrated in the paragraph "Benefits of basing the regulations on an existing model" last sentence, quote. "For example, in the United States there have been general aviation regulations in place for over 50 years. Why reinvent the wheel?" This has got to be one of the most understated facts that CASA have ever come up with. The industry in Australia has been maintaining GA aircraft for longer than that and have been trying to convince CASA of this very fact for just about as long.

My LAME currently employs an engineer who has been working with him for around 25 years on a very broad cross section of GA aircraft. He is an extremely capable and knowledgeable person and I would trust my ife on his ability to maintain any GA aircraft. However because he is not licenced, he is not able to sign off on the simplest of rectifications or repairs such as can be carried out by a pilot like changing a tyre. There must be a means found in which such persons can by virtue of their experience, perform some form of practical "in hangar/ on the job" test under the auspices of an independant LAME or other approved person to demonstrate an adequate knowledge to enable the ability to exercise greater responsibilities and gain access in turn to a higher salary. It has the added bonus of alleviating considerably, the load being born by the Chief Engineer in having to double up on inspections and the paperwork. Why in the current environment, would a young person contemplating an apprenticeship take up Aviation maintenance with the associated risks complexity and an uncertain training regime, when he could start with his local Toyota or other automotive dealer earning higher salary and still having a very desirable and practical qualification on completion.

The overall simplicty of the model. However, I believe that in exploring differences between the US and Australian models, there must be some practical mechanism to utilise the best of both systems to end up with a superior arrangement.

It would be very difficult for an engineering business that services both Charter/Air transport aircraft and other GA operators to compete with someone who is able to carry out "under tree maintenance" when, in relation to the Charter maintenance side of the business, (which may well be of a significantly lower proportion), he must carry all the extra paperwork, have calibrations of equipment/tools etc and numerous other items and requirements that usually come at significant cost. Some middle ground should be found here where there is a requirement for proper licencing which prevents, fly by night operators but simplifies the overall requirements for GA maintenance.

It is difficult to see why GA maintenance should come under two separate Rules similar to the US system. Maintenance is maintenance in whatever form, It should be able to be formulated under one ruling. The NZ system has no equivalent to the Australian schedule 5, and requires all aircraft to be maintained to the manufacturers requirements. This typically adds very significant cost increases in maintenance requirements for no perceivable safety benefit. The Schedule 5 maintenance has been safely in use in Australia for many years. Manufacturer's maintenance schedules typically appear to be more complex with significant allowance for their fear of litigation proceedings.

Comments in relation to Australia's Schedule 5 as above clarify. Otherwise the NZ system has elements which could easily be assimilated and be beneficial.

The approach by EASA is very refreshing, particularly coming from a committee of differing countries and their thinking toward aviation and particularly GA. The GA roadmap contains what appear to be a series of simplification of GA aircraft operational rules across the board. There is insufficient details on which to make a hard and fast decision, but if the intentions behind the rhetoric are real, there is very real potential to apply the intentions to any amendment policies considered.

I am not sufficiently conversant with EASA regulations to make an informed statement in this regard.

It would seem on the surface that the Canadian model appears in some ways to be the most complex of the models presented, which is surprising considering the number af GA aircraft utilised in that country. I do not have sufficient understanding of the Canadian regulations to make an informed statement. However there may well be elements that would sit well within the proposal for change.

No comment here.

The intention to visit the regulatory and other areas of maintenance of GA aircraft in Australia is to be applauded. It is long overdue, and the current regulations must bear some responsibility for the decline of GA in the last decade or so. It is difficult to believe, that with genuine resolve from CASA, and significant input from the Maintenance Industry, a world standard set of simplified maintenance regulations cannot be attained. The opportunity to compare each aspect of regulations from the sampled countries one by one and come up with the simplest method of addressing safety and cost concerns with each has the potential for significant reform. Within reason the KISS principle should be the default position at all times. I believe an industry forum with CASA, could in the space of a week, cover the bulk of the work necessary to get the basics in place. A couple of months for general industry input for a final draft should enable the amended legislation in place within 6 months (Not allowing for delays in the Attorney General's legal area.)

I am the owner manager of a small Charter business, formerly owned an Aerial Application business. Have built and fly my own aircraft privately. Been actively involved in my aircraft maintenance (no licences) although some past authorisations for over 50 years.