CASA Consultation on proposed GA Regulations (Registrations for Info sessions close tomorrow 5 December)

Your industry urgently needs your attention and input.

In August this year CASA commenced a round of Consultation in relation to maintenance regulations for General Aviation 

The consultation process so far has been essentially to steer the ultimate decision towards adopting a system for General Aviation based on the US FAA FAR Part 43.

We understand that CASA will be putting forward a proposed model with a very tight timeframe for implementation based on that system. It has been proposed that the legislative draft will be out for consultation in the first quarter of next year and the scheme implemented by 2020.

Quite often CASA consultation flies under the radar for many people, however this is one that we feel needs the LAME community to scrutinise very carefully because it contains some big conceptual changes that will impact on LAMEs, particularly working in the broad non-RPT sector and their employers.  

In a very short summary of some of the changes the proposal basically removes the requirement for a maintenance organisation approval for maintenance on aircraft operations covering GA and Aerial work. This covers flying training, mustering, firefighting and emergency service operations, search and rescue, aerial surveying and photography, towing, and private flying. It doesn’t cover charter aircraft.

Aircraft maintenance will be signed off by a LAME under their licence and they will no longer be signing on behalf of an organisation.

LAMEs would not be required to obtain type ratings to carry out maintenance of type rated aircraft under this proposed CASR.
If a type rated aircraft is being maintained under the new regulations, a LAME who does not hold the relevant aircraft type rating may carry out maintenance of the aircraft provided that the maintenance is within the scope of their licence, and any maintenance task that the LAME carries out is a basic privilege of their licence, or a task for which they have established competency by having: previously performed the task, been trained in the task by an appropriately qualified person, or satisfactorily performed the task under the supervision of another LAME who meets one of these requirements.

Because no organisation approvals will be required procedures manuals, quality systems, internal audits or CASA approval to vary locations or scope of work (additional aircraft or components) will no longer be required either.

A maintenance organisation approval (presumably under Part 145) will be required for instruments and repairs of propellers, but not engines. Engines may be overhauled and tested by a LAME.

Organisations maintaining charter aircraft (regardless of size or number of engines) will be required to maintain a CAR 30 approval until regulation reform has been undertaken,  but given CASA statements that a multi-tier regulation approach is not on the table it seems to be a given that they will need to obtain a Part 145 approval even if charter is a very small part of their work. 

The proposal introduces an Inspection Authorisation (IA) for Annual inspection of aircraft for compliance with type certification basis and mandatory maintenance requirements, also, conformity inspection of major modifications and repairs as well as supervision of progressive inspection schedules.

The IA will be held by an individual, a B1 licence and 3 years experience are prerequisites. As is the case in the US the will be an initial exam and ongoing currency requirements
Only an IA or a Part 145 AMO can will be able to release an aircraft after an annual inspection.

To fully understand the ramifications of this proposal there needs to be careful consideration of the differences between the Australian and US FAA regulatory systems and that the proposal appears to be  simply adopting one of the FARs in isolation. These are things that CASA needs to fully explain to the industry. In order to maintain and enhance the current levels of safety and compliance CASA needs to explain how this is achieved in the US and how it will be achieved here.

It wouldn’t be accurate to say that General Aviation maintenance in the US is conducted with no organisational oversight as has been proposed by CASA for Australia.

This is simply too big a change to be introduced with limited explanation in an accelerated timeframe.

We fear that if this is rushed through there could be serious safety consequences and force many small businesses to the wall.

CASA is conducting a series of public briefings commencing next week in major centres starting with;

10 December – Morrabin    
11 December – Bankstown and Parafield
12 December – Archerfield and Jandakot
13 December – Darwin and Cairns

Registrations for these events close tomorrow (5 December)

We urge you to consider attending one of these events to have the opportunity to listen and ask your own questions about the proposals. We would also expect that a policy document will be released for review before next week and we recommend that you review it.