[Peetwo]

Addendum - Oz Flying catching up - 

Reference previous:

Via the AP email chains:

AMROBA has sent the attached rejection of CASR Part 43 to CASA’s CEO Pip Spence and the Senate’s Regulatory Review Committee.

rrat.sen@aph.gov.au.

Pip.Spence@casa.gov.au

Your Help Is Required to Stop this Part.

It is available as breaking news.

This is a proposal that just cannot be made. It is proposed to be an opt out system that is not supported by the majority of CASA field office AWIs let alone any of our members. Everyone that has contacted me want it stopped. 

CASA is proposing to send it to Parliament within months. 

AMROBA was advised that this FAR based Part will not have FAA ACs top & tailed to support it but unique Australian advisory circulars not yet written.  It also adopts ICAO Aircraft Maintenance Technicians terminology that is same as LAME but they have applied it to US Repairmen referenced in FAR Part 65 Subpart E repaiman that is not being added to CASR Part 66. Not adopting FAR standards. 

Disharmonised, disjointed regulatory framework from a regulator that has obviously lost the vision for Australia to comply with ICAO SARPs for the benefits of our members. 

The real text of the Part has not been circulated for comment.

• No training has been provided to CASA field staff, let alone industry.
  
• There has been no benefits for industry identified that we are aware of.
  

CASR Part 43/42 should be merged into one Part underpinning all aircraft maintenance as FAR Part 43 does in the USA FAR system.

All we can ascertain from what CASA has produced is more red tape, bureaucracy and costs that are not benefits for industry. 

Why is CASA continually creating silos in the maintenance sectors? The rest of the world has a Part 43 based on FAR Part 43 if adopting FARs.

Urgent: We need your help.

AMROBA needs all its members to also write to Pip Spence rejecting this proposal.

We also need members to urge other AMOs and industry participants to write and reject this Part 43 proposal.

As one insider stated to me “it will be a disaster worse that the introduction of flight crew licencing.”

Even the latest ICAO audit findings suggested Australia should be adopting the SARPs for the “benefits” of industry participants. 

This Part must be totally rejected and it will rely on as many as possible writing to CASA registering their rejection. 

As many individuals and organisations must also make submissions rejecting this proposal. 

The current regulatory reform process is not fit for purpose. 


Thank you 

Ken Cannane

Executive Director

AMROBA

Phone: (02) 97592715

Mobile: 0408029329

www.amroba.org.au

Safety All Around.

Via Oz Flying:

AMROBA withdraws Support for CASR Part 43

29 May 2024



The Aviation Maintenance Repair and Overhaul Business Association (AMROBA) this week withdrew its support for the proposed CASR Part 43 regulations.

CASR Part 43 covers maintenance of general aviation aircraft used in private and aerial work operations, designed to simplify and remove some regulatory burden.

However, in a letter sent to CASA CEO Pip Spence on 27 May, AMROBA withdrew its support, saying the legislation will "further divide and devastate the aircraft maintenance sector."

Signed by AMROBA Executive Director Ken Cannane, the letter states that CASA's proposal is at odds with FAR Part 43, on which the Australian regulations are theoretically based.

"How CASA now intends to apply CASR Part 43 in Australia is nothing like how FAR Part 43 is applied in the USA," Cannane said.

"CASR Part 43, as originally proposed based on FAR Part 43, covered all maintenance requirements (i.e. what must be done, recorded and by whom) for all maintenance on aircraft and aircraft components from individuals to organisations, approved or not.

"However, since then CASA introduced a CASR Part 42 that now applies different maintenance requirements for commercial passenger operations."

Cannane also said the the Part 43 proposal would create multiple levels of standards and training requirements for maintenance personnel despite working on similar aircraft flying in the same airspace, suggesting a solution that would see CASRs 42 and 43 merged.

"Unfortunately, CASR Part 42 and 43 must be merged into one Australian Part – preferably Part 43 to keep the regulatory structure based on the FAR system as originally politically and department/agency/industry supported ...

"The immediate and long-term effect that this change will have on our members will result in some current CAR 30 organisations closing their doors and others simply become more frustrated with an already disjointed red-tape focused regulatory system.

"This means CASA is implementing uniquely Australian regulations and requirements based partially on European and USA aviation regulatory maintenance requirements."

Cannane, who has been in the aviation sector for several decades including a stint within the regulator, said that he had never experienced regulatory issues to this extent in the past.

"In my 60 + years in aviation, this is the most disjointed, disharmonised, uniquely Australian, set of aviation regulations ever been proposed," he said in the letter.

"It continues to add red tape and confusion to regulatory maintenance requirements [with] no benefits for members.

"The regulatory reform process is no longer fit for purpose."

MTF...P2