[Peetwo]

AMROBA September Newsletter - 

Via AMROBA: Volume 20 Issue 9 September 2023

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[Peetwo]

AMROBA October Newsletter & 'Breaking News'

Via AMROBA: Volume 20 Issue 10 October 2023









Via the AP email chains:

Shortage of LAMEs

Our latest Breaking News article “Aircraft Maintenance Personnel” article highlights the disconnect between CASR Parts 66/147 and the NVET system.

It highlights the brick wall between CASA and ASQA and why aviation regulations do not recognise Australia’s vocational training system.

To apply for an AME licence, the application should have achieved the applicable VET AQF qualification like all other trades in Australia. Why is aviation different? Because those drafting instructions to create regulations did not make the link.

When will aviation regulations address the “root cause(s)” for the shortage of LAMEs. CASA produced regulations have not provided a solution, only exacerbated the situation.

Root Cause 1:    Pre Parts 66/147, maintenance avionics and mechanical trade training had already changed from industry wide to sector specific at TAFEs providing airline/large aircraft training packages at major training campuses in the early 1990s. A demarcation issue within the airline had further reduced the mechanical trade training into mechanical systems and structures.

Do Parts 66/147 align with the VET avionic, mechanical and structures pathways?  NO

Training development is now politically sensitive because the unions are not part of the regulatory solution.

The non airline sectors, pre-Parts 66/147, had found that these main TAFE providers were not providing helicopter and piston aircraft training. These changes were recognised by CAA, at the time, who had stopped promulgating its “Guide to Become a LAME” that listed the Avionic and Mechanical trade training stream for the whole industry.  This was a guide for State Education Departments as it provided the syllabi for course development.

Root Cause 2.    Unlike the FAA, CASA is not funded to provide trade/licence training but have imposed on government funded RTOs, the Part 147 approval to provide aviation maintenance licencing training outside the Australia’s funded NVET system controlled by ASQA, the training regulator.

This has led to no career pathways in the NVET that match aviation maintenance sector needs.

The solution is to amend the aviation legislation to be compatible with the ASQA legislative/regulative requirements so aviation maintenance personnel can receive NVET AQF qualifications to hold CASA AME licences like other licence holders in other trades.  This is also inline with international standards. 

Whilst Australia languishes in the past, EASA has, 2023, once again amended their Parts 66/147.

EASA latest amendment:            Annex III (Part-66) and Annex IV (Part-147) to the CAW Regulation, introducing, among others, new training methods and teaching technologies and other improvements as part of the regular update of Part-147. In particular, amendments were introduced in order to:

• facilitate the type rating endorsement of aircraft when there are no organisations approved in accordance with Part-147 offering type training on that aircraft, maintaining the same level of safety and a level playing field;
  
• update the basic knowledge training syllabus in Part-66;
  
• enhance the efficiency of the ‘on-the-job training’ (OJT) required for the first type rating endorsement in the maintenance licence category;
  
• enhance the efficiency of the maintenance personnel training system with new training methods and new teaching technologies;
  
• improve and correct the elements that emerged with the implementation of the CAW Regulation.
  

 
We will continue to lobby to see if we can get action 

Ken Cannane

Executive Director
AMROBA
Phone: (02) 97592715
Mobile: 0408029329
www.amroba.org.au
Safety All Around.

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[Peetwo]

AMROBA November Newsletter

Via amroba.org.au : Volume 20 Issue 11 November 2023



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[Peetwo]

AMROBA XMAS WISHLIST 2024

Via amroba.org.au : https://amroba.org.au/wp-content/uploads...2023-4.pdf



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[Peetwo]

AMROBA 1st Newsletter for 2024 -

Reference:Volume-21-Issue-1-January-2024

Critical Shortage of Maintenance Personnel?

We start this year with the same critical shortage of Aircraft Maintenance Engineers (AME) and Licenced AMEs to service the Helicopter sector and General Aviation (GA) Aeroplane sector.

30 plus years and still no aircraft maintenance engineer vocational trade training courses for the helicopter or CASR Part 23 aeroplane sector’s mechanical trade streams. 

There is one vocational pathway for the Part 25 aeroplane trade stream that supports the airline’s three trades streams of avionics, mechanical and structures. The other sectors are supported by a two trade streams, avionics and mechanical.

After our first meeting with CASA this year, we now know that there will be no regulatory change to address the shortage of aircraft maintenance personnel and LAMEs, simply because CASA said “there will be no regulatory change”. So, we are stuck with the system that creates a shortage of personnel.

• The regulatory system is “broke”, the VET training system is also broken, but repairable.

The problem that fails to be recognised is there are three (3) separate AME mechanical training pathways in the non-airline sector but only one pathway that exists in the VET system.

The second problem is that CASA does not acknowledge VET qualifications.

Regulatory Systems - worldwide

Regulatory systems worldwide are more harmonised today, than at any other time in my 60 plus years of participating in civil aviation. In every system there is basically the same maintenance concepts as included in CAR/CASRs requiring the person signing a maintenance release to meet the standards of Annex 1, Chapter 4 and Annex 8, Chapter 6.6.6. Their licenced AMEs, however named, all certify the aircraft as airworthy at completion of work. We should be no different. The maintenance and aircraft records required to be kept are closely aligned. The maintenance and aircraft records that approved AMOs need to keep are very closely globally aligned.

Our fleets are not so different, and their safety records are as good as, or better, than Australia.

Foreign LAMEs: To provide our employers with qualified staff that the Australian training system doesn’t produce, a fast-track system of recognising foreign LAMEs is required so current maintenance organisations can service the non-airline aircraft fleet and the industry maintainer experience is maintained.

CASA’s modular self-study pathway, pass CASA Part 66 module examinations is the only way to address this issue in the short term.  In house on-the-job training will add costs to operating a business. As maintenance employers state, the bureaucracy has caused the problem but have taken no action to correct the shortage of maintenance personnel they created for over 2 decades.  Part 21 realignment with FAR Part 21.

In addition, getting engineering fields of design, manufacture and maintenance harmonised globally is not even being contemplated. Aviation engineering/maintenance is not unique to Australia; it is a global industry with global standards that all other mature safe nations are or have implemented.

CASA told industry harmonisation would happen years ago post a CASA/FAA bilateral agreement meeting. They stated they would realign CASR Part 21 with FAR Part 21 applauded by industry. 

Same action as last year and years before, no action.

Regulatory Reform. If done correctly, the results should return civil aviation, especially the non-airline sectors, to the participation rates pre the creation of CARs/CASRs. However, how many more regimes of government and CASA will come and go before Regulatory Reform, originally direct by Parliament in the late 1990s, is completed? 

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[Sandy Reith]

Commonsense and detail reform measures falling on the deaf ears of a failed regulator.

The failure goes back to the design of the administration of an important arm of government back in 1988 by effectively deleting aviation out of Departmental and Ministerial control.

Unfortunately the Parliament overlooked the important Westminster democratic principle of Ministerial responsibility being an essential ingredient of government. The idea that government is responsive to the electorate and responsible for its governance. Think of a Department and its Minister as being as close as possible to the consequences of its actions and accountable through the ballot box. Imperfect system but the best devised and refined over hundreds of years.

The independent corporation of CASA is in law an entity that can be sued. Unlike a Department of government. This means that this entity is inclined to proceed independently to protect itself, and human nature as it is may well increase its importance leading to high salaries, fees for service for new permissions and so on. Sorry to say but CASA exhibits all such elements in spades.

All of us in the aviation community should be lobbying for aviation to be administered by a Department of Government.

[Peetwo]

Courtesy KC AMROBA CEO: Regulatory Forecast - Engineering Dreamtime

Via the AP emails:

To all members, 

Irrespective which way you look at engineering regulatory reform projects they are parked in CASA’s dreamtime. 

Only project that we have prioritised is finding a fast track recognition of foreign LAMEs to address the critical shortage of LAMEs. 

As project managers, CASA engineering are non-achievers.
Past projects have reduced industry participation, not increased the participation in aviation. 

It is definitely an art to have a regulatory reform project that cannot be completed within the life of one parliament, or, at worse, two parliaments.

To think that regulatory reform engineering projects started with the creation of the CAA and are still in progress.

We started, early 1980s, doing reform in conjunction with NZ; CASA (new DAS) changed direction mid-1980s.

NZ completed their reforms and CAA/CASA continues (every new DAS) changing directions.

Projects now parked in dreamtime.

The Parts that have been implemented (partially adopted) have issues and need to be amended. 

Maybe the next regime of government, Board or CASA will champion engineering reform projects.
At least the last regime recognised they had to realign Part 21 with FAR Part 21. 

Under these major issues are a raft of smaller projects that don’t happen. 

Is participation and safety improving in each of these silos that CASA has created?
 
Regards


 

Plus:



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[Peetwo]

KC member email and latest AMROBA Newsletter. -

Via AMROBA:

To all members,

Link to CASA Authorised Persons: copy to your desktop:

https://www.casa.gov.au/search-centre/ai...tes?page=0 

Have attached Latest Newsletter.

In this issue we raise the same issue that the ICAO 2023/24 audit found.

ICAO stated Australia “could more fully realise the benefits of closer alignment with ICAO’s standards and practices (SARPs)”

There is also ICAO – Government “corrective acion plans” that have been agreed with ICAO.

Why won’t those “corrective action plans” be made public? 

1/ We provide an example how government lodge a difference with Annex 1, Chapter 4 that is very misleading to other nations.

a) By not adopting and implementing these SARPs, we are being held in the past.
b) We cannot understand why government/CASA cannot look to the future.
c) Adopting and implementing ICAO SARPs is the first step to modernisation.

2/ EASA introduced a GA aircraft maintenance organisation a few years ago, EASA Part CAO.

a) A Combined Airworthiness Organisation can be approved for:
b) Non passenger, non complex aircraft maintenance
c) Also perform the EASA “airworthiness review” – GA annual inspection does the same.
d) Also issue “permit to fly” so you can approve a customer’s aircraft to fly to your organisation for mainenanc.

Note: EASA has extended these functions to EASR Part 145 AMOs and CAMOs

3/ The shortage of LAMEs could be reduced if CASA adopted the EASA Part 66 B3 & B2L AME licences.

a) EASA introduced to ease entry into licencing especially for GA.
b) A B3, according to EASA, can attain a licence in half the classroom training hours as a B1.2. 

So why are we stuck in the past and not adopting the other half of CASR Part 66 AME licences. 

We have a bureaucracy that has not kept pace with the global industry changes or the SARPs? 

No wonder the industry is struggling instead of booming. 

Ken Cannane

Executive Director

AMROBA

Phone: (02) 97592715

Mobile: 0408029329

www.amroba.org.au

Safety All Around.

Newsletter:







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[Peetwo]

KC wrap on Manufacturing Forum - 

Via AP emails:

To all members, 

I attended this Forum early last week to find out what the government’s new “Made in Australia” policy, presented by Senator O’Connor, was about and what manufacturing industries, we are part of manufacturing, and unions are doing to attract and retain employees with such a shortage of potential employees available. See attached review.

The purpose of this forum was to find solutions to Australia’s staffing levels in the manufacturing sectors.

Civil aviation is competing with construction, food trades, new technologies, and many other manufacturing sectors for a limited number of available personnel.  Without doubt, a short-term foreign LAME recognition process is needed.

Many of these sectors have implemented changes or are in the process of implementing changes to modernise their sectors.

Two major points became obvious from the presentations and discussions.

1. School career advisors do not advise school leavers to take up trades. In fact, it was stated by apprentices presenting at the Forum that they knew nothing of the jobs available in trades when they left school.
   
2. “Relevance” of the trade training and the also relevance of licences were high in the discussions.
   

These points were repeated by many sectors that stated they have been reviewing the relevance of the training and licences available.

Those that have done this stated it has helped in their attraction & retention of staff.

These are basically the issues raised by the civil aviation maintenance sector for more than a decade.

Licencing Examples

The current CASR Part 66 licences are not relevant to the non-airline sectors.

• The EU abandoned the current CASR Part 66 licences because it was not relevant to their industry.
  
• CAR 31 group ratings were more relevant to the Australian civil aviation industry, except for airlines.
  
• A modular avionic licence like the EASR Part 66 B2L is more relevant than just a B2.
  

Training Examples.

1. AME rotorcraft training course has not been available for decades.
   
2. AME small aeroplane training course has not been available for decades.
   

The “relevance” of training and licences was raised by both employer groups and unions.

AMROBA recognises that MISA who organised this Forum, are currently working on these missing courses.

There was a lot of common ground between employers and unions in successful industry sectors.

There is much that can be learnt from this Forum, especially how other licencing authorities are reviewing their licences for relevance and the training sectors are reviewing the  relevance of the training as related to the job.

It is no longer applicable for licencing authorities and training providers to determine what is taught and the type of licence.

It is important that the training and licences are relevant to the jobs created by employers.

Those that are attracting and retaining staff have had complete cooperation between trade training, employers, and licencing.

It starts with the employers’ job needs, the ability of the training sector to provide relevant training to basic trade level to meet job needs, relevant licencing at that level and the provision of training electives that trades person can acess to expand the scope of trade capabilities without licence changes. The scope of the licence is based on additional VET training/qualifications.

This is similar to the EASA B2L approach.

In industry sectors not suffering from shortages, the cooperation between employer groups, ASQA, VET course developers , providers and Licencing Authorities have been cohesive.

AMROBA has produced training course curriculum for the large aeroplane, small aeroplane and helicopter pathways based on the modules 11A, 11B and 12. We have also developed on for the B2L based on the EASR modules that CASA must adopt.

Refer Training News on our website. 

Ken Cannane

Executive Director

AMROBA

Phone: (02) 97592715

Mobile: 0408029329

www.amroba.org.au

Safety All Around.

---

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[Peetwo]

KC member email & AMROBA latest Newsletter - 

When I left industry and joined the Department, pre-CAA/CASA days, the Department had an internationally accepted airworthiness training school in Melbourne. It had even trained some of our Asian neighbours’ regulators’ airworthiness staff.

Basically 12 weeks training to convert maintenance supervisors/managers into regulators understanding the intent of ICAO SARPs and advisory material.

This hasn’t been available to the current employees of department and agencies like CASA. This type of training is now available from ICAO for regulators. Many of our Asian neighbours have ensured their staff, especially those involved with regulatory development, have participated in these ICAO training courses.

Our members must have “qualified” and “licenced” staff to run a business, why shouldn’t the government ensure the public service employees involved with aviation regulatory development have appropriate qualifications from ICAO?

 

May Newsletter 2024 is available on the AMROBA website.

The Red Tape Army

To industry, the government’s Red Tape Agenda is a fallacy.

Ask anyone in the engineering fields of design, manufacture, maintenance and maintenance training, red tape has reduced in the last decade or two and the answer will be” NO.  The Institute of Public Affairs confirms this is a fact.n

In aviation, you cannot blame the flexibility in the Convention Annexes that enables a safe but cost effective FAR system to exist.

This applies across most indusrtry sectors but must be completed for the engineering disciplines.
 

AMO Red Tape

CASR Part 21 has not kept pace with change that has meant Australia has a system not harmonised with any other nation.

Re-harmonisation with FAR Part 21 was promised by the last CEO/DAS of CASA post a FAA/CASA bilateral meeting but still no action.
 

GA Red Tape Reduction

What a waste of money the government commttees, reports, workplans and all other workplans that each regime of CAA/CASA has consulted, developed and promulgated over the last forty years.

There are hundreds of recommendation from all these talkfests but basically no action.

Ever since the decision was made in 1992 by the then Department & CAA to harmonise with the FARs, each new regime makes different decisions.

Do those in charge realise that this Part 21 links to Part 43 to Part 91 and many other FAR provisions that also need adopting.

The CAA staff involved in the 1990s were topping and tailing each FAA ACs as was done when it was made.

This reduces drastically the amount of time it takes to adopt and implement a foreign regulation.

Civil Aviation Safety Regulations 1998 - Reg 1.003

Harmonisation with FARs

(1)  These Regulations contain provisions based on the FARs.

(2)  An object of these Regulations is to harmonise certain parts of Australia's aviation safety law with the FARs.

(3)  The words ' Source FARs' below a regulation indicate that the regulation is based on the section of the FARs, as in force on 1 January 1997, stated after the words and, if the section number is followed by the word 'modified', the word indicates that the FARs section has been modified for the regulation.

Example:

21.013   Eligibility

Any person is eligible to apply to CASA for a type certificate or type acceptance certificate.

Source FARs section 21.13 modified.

The words set out below the regulation in this example indicate that the regulation is based on section   21.13 of the FARs as in force on 1   January 1997 and that the FARs section has been modified for the regulation.

(4) If a word or expression is used in both a regulation and the FARs section on which the regulation is based, the meaning of the word or expression in the FARs section may be taken into account in interpreting the word or expression in the regulation, unless the contrary intention appears.

Since November 2020, Annex 6, Parts 1, 2, and 3 have provided the flexibility that the FAR system provides.

Why are we wasting time converting foreign regulation into complicated unique Australian regulations?

Major cause: Government and agencies employees are not qualified or skilled to develop regulations compliant with the safe SARPs promulgated by ICAO.

Until government provides qualified (ICAO training courses) regulators to return Australia to a highly compliant SARPs in accordance with Aricle 37 of the Convention, this continual regulatory change will continue for many years. 

Only government can correct the red tape that has been applied and removal of differences to the ICAO SARPs. 

Ken Cannane

Executive Director

AMROBA

Phone: (02) 97592715

Mobile: 0408029329

www.amroba.org.au

Safety All Around.

Plus: 

• Volume 21 Issue 5 May 2024
  

MTF...P2 

[Peetwo]

KC member email & AMROBA latest Newsletter - 

When I left industry and joined the Department, pre-CAA/CASA days, the Department had an internationally accepted airworthiness training school in Melbourne. It had even trained some of our Asian neighbours’ regulators’ airworthiness staff.

Basically 12 weeks training to convert maintenance supervisors/managers into regulators understanding the intent of ICAO SARPs and advisory material.

This hasn’t been available to the current employees of department and agencies like CASA. This type of training is now available from ICAO for regulators. Many of our Asian neighbours have ensured their staff, especially those involved with regulatory development, have participated in these ICAO training courses.

Our members must have “qualified” and “licenced” staff to run a business, why shouldn’t the government ensure the public service employees involved with aviation regulatory development have appropriate qualifications from ICAO?

 

May Newsletter 2024 is available on the AMROBA website.

The Red Tape Army

To industry, the government’s Red Tape Agenda is a fallacy.

Ask anyone in the engineering fields of design, manufacture, maintenance and maintenance training, red tape has reduced in the last decade or two and the answer will be” NO.  The Institute of Public Affairs confirms this is a fact.n

In aviation, you cannot blame the flexibility in the Convention Annexes that enables a safe but cost effective FAR system to exist.

This applies across most indusrtry sectors but must be completed for the engineering disciplines.
 

AMO Red Tape

CASR Part 21 has not kept pace with change that has meant Australia has a system not harmonised with any other nation.

Re-harmonisation with FAR Part 21 was promised by the last CEO/DAS of CASA post a FAA/CASA bilateral meeting but still no action.
 

GA Red Tape Reduction

What a waste of money the government commttees, reports, workplans and all other workplans that each regime of CAA/CASA has consulted, developed and promulgated over the last forty years.

There are hundreds of recommendation from all these talkfests but basically no action.

Ever since the decision was made in 1992 by the then Department & CAA to harmonise with the FARs, each new regime makes different decisions.

Do those in charge realise that this Part 21 links to Part 43 to Part 91 and many other FAR provisions that also need adopting.

The CAA staff involved in the 1990s were topping and tailing each FAA ACs as was done when it was made.

This reduces drastically the amount of time it takes to adopt and implement a foreign regulation.

Civil Aviation Safety Regulations 1998 - Reg 1.003

Harmonisation with FARs

(1)  These Regulations contain provisions based on the FARs.

(2)  An object of these Regulations is to harmonise certain parts of Australia's aviation safety law with the FARs.

(3)  The words ' Source FARs' below a regulation indicate that the regulation is based on the section of the FARs, as in force on 1 January 1997, stated after the words and, if the section number is followed by the word 'modified', the word indicates that the FARs section has been modified for the regulation.

Example:

21.013   Eligibility

Any person is eligible to apply to CASA for a type certificate or type acceptance certificate.

Source FARs section 21.13 modified.

The words set out below the regulation in this example indicate that the regulation is based on section   21.13 of the FARs as in force on 1   January 1997 and that the FARs section has been modified for the regulation.

(4) If a word or expression is used in both a regulation and the FARs section on which the regulation is based, the meaning of the word or expression in the FARs section may be taken into account in interpreting the word or expression in the regulation, unless the contrary intention appears.

Since November 2020, Annex 6, Parts 1, 2, and 3 have provided the flexibility that the FAR system provides.

Why are we wasting time converting foreign regulation into complicated unique Australian regulations?

Major cause: Government and agencies employees are not qualified or skilled to develop regulations compliant with the safe SARPs promulgated by ICAO.

Until government provides qualified (ICAO training courses) regulators to return Australia to a highly compliant SARPs in accordance with Aricle 37 of the Convention, this continual regulatory change will continue for many years. 

Only government can correct the red tape that has been applied and removal of differences to the ICAO SARPs. 

Ken Cannane

Executive Director

AMROBA

Phone: (02) 97592715

Mobile: 0408029329

www.amroba.org.au

Safety All Around.

Plus: 

• Volume 21 Issue 5 May 2024
  

MTF...P2 

Addendum: Volume 21 Issue 5 May 2024 Addendum

[Peetwo]

AMROBA Breaking News; & June Newsletter - 

Via amroba.org.au : 



Part 43 Piston Engine Overhaul - Piston Engine Failure Accidents Coming Back – 23-6-24




Plus: Volume 21 Issue 6 June 2024 













Also maintenance related, I note that our WOFTAM miniscule Dicky King recently announced (with absolutely zero fanfare - ) that she has appointed a new CASA Board member: https://minister.infrastructure.gov.au/c...casa-board

Mr Verkerk is an experienced and highly skilled former senior executive in the aviation industry, including at Qantas, with professional qualifications in aeronautical engineering.

He has a strong understanding of the aviation regulatory environment, gained over 40 years as an aviation engineer of heavy passenger aircraft.

Mr Verkerk’s wealth of experience will enable him to provide in-depth insight into aviation engineering and maintenance, an identified capability gap on the current board...

---

&..from his profile:

Adrian has more than 30 years of experience in high capacity airline operations, mostly in senior executive Engineering and Maintenance roles.

Prior to that, he spent 10 years working in technical support and systems design functions supporting a wide range of military aircraft and engine types.

During his career, Adrian has held several key regulatory posts in the airline industry, including Head of Aircraft Airworthiness and Maintenance Control (HAAMC) and Continuous Airworthiness Manager (CAM). He was the Accountable Manager for the first Approved Design Organisation under the current CASR Part 21J regulations.

He has provided leadership for the implementation of formal safety management systems in engineering organisations and driven transformation programs focused on digitalisation, fuel efficiency, optimised maintenance strategies, cabin configuration and flight path planning.

Adrian has served on a number of international airline industry bodies including the Technical Committee of the Association of Asia Pacific Airlines (AAPA) and vice chair of the International Air Transport Association (IATA) Engineering and Maintenance Group.

He is keenly interested in implementing strategies to attract and retain talent to grow the aviation sector.

Adrian holds a Bachelor of Aeronautical Engineering from the University of Sydney and is a Fellow of the Royal Aeronautical Society.

Hmm...any thoughts KC??

MTF...P2

PS: Passing strange how the CASA Board page lists Verkerk as being appointed on the 16th May, however the Dicky King MR announcement was published more than 2 weeks later??

[Peetwo]

AMROBA Mid Year Review 

Courtesy KC, via the AP emails:

Are our members and other industry participants wasting their time inputting to CASA Proposals? 

The one thing that is certain: red tape and costs will increase unchecked due to government imposed changes. 

If you look back on what has been promulgated over the last decade, the results of change supports the fact that industry  inputs have not stopped:

• The shortage of maintenance personnel over last 20 years: 
  

1. Virtually no all-of-government (DEWR/MISA) cooperation developing:
   

• B1.3/4 AME trade and licensing NVET courses and qualifications for CASA licencing;
  
• B1.2 AME trade and licensing NVET courses and qualifications for CASA licencing;
  
• Below 760 Kg basic aeroplane NVET trade course and qualification for RAAus licencing ;
  
• Numerous bridging NVET courses between each course; and
  
• Specific product standalone NVET courses and qualifications.
  

 

• Part 43, from full support for  FAR part 43 adoption to CASR Part 43 total rejection.
  

1. Complete failure to adopt the FAR because drafters lack understanding of FAR.
   

• CASA Project team have not done FAR Part 43 training with the FAA.
  

 

• Training of CASA personnel in how to give effect to Conventions Annexes SARPs has not happened.
  

1. ICAO provides Regulator Training which ICAO Council Part 1 members and others utilise.
   
2. Managing Compliance with ICAO SARPs – 5 day course for CASA managers, especially project managers.
   

• This is fundamental training for all department/agency staff involved with regulatory reform should complete;
  
• We have brought this to CASA management notice before.
  

• ICAO audit finding 2023/24:-  industry is being denied the benefits of compliance with the SARPs 
  

How many decades of reform do we suffer until someone wakes up to the fact that regulations should be simply adopting the text of the Annexes based on the FAR regulatory structure.

What a waste of millions of dollars over the decades because the personnel in the public service have not undergone ICAO provided training that other NAA staff regularly attend. 

Recommendation:  Government introduce a trading program with ICAO to provide Department/CASA staff with the right qualifications to manage the Chicago Convention obligations and compliance with the Convention’s Annexes’ SARPs.

• Specifically, ICAO Provided training: Managing Compliance with ICAO SARPs must be compulsory training if Australia is to obtain civil aviation trading safety agreements that will enable CASA issued Australian certificates of approvals of design, manufacture, maintenance, technical training and the government’s Authorised Release Certificate to be accepted by other ICAO member nations in their own right.
  
• That should be  the aim of engineering  regulatory reform: a regulatory system that enables both global and domestic safe trade of products and services.
  

 

Ken Cannane

Executive Director

AMROBA

Phone: (02) 97592715

Mobile: 0408029329

www.amroba.org.au

Safety All Around.

AMROBA Mid Year Review.pdf Size: 395.53 KB  Downloads: 1

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[Peetwo]

AMROBA Newsletter July 2024

Via amroba.org: Volume 21 Issue 7 July 2024







MTF...P2 

[Kharon]

Make work projects.

The first two paragraphs in the AMROBA  newsletter _ HERE _ shine a light on two very fundamental question. Why the need for 'complexity' and re-work of existing regulation; and, what does this achieve? Can the benefits of CASA make work be demonstrated?

'Safety' is the catchall used to justify the endless, ever more restrictive, complex, legally binding way of saying the same thing. But, take a look at any of the  video from a Senate Estimates session. Count the  heads at the table and behind; average the salaries, then multiply that number the attendees.  Big number, huge and they all have 'jobs' to do. However, in the real world, once 'a job' is done; the tools are packed away, the floors swept and the actors exit - stage left. But not within the protected realms of user pay-us 'public service'.

The base regulation philosophy lends itself to endless 'twerking' and 'tweaking'. The relentless re working and, some would say 'working around the ICAO / Chicago tenets takes time and cost money. Is there even a need to have 'unique' Australian regulations and the rest of the guff foisted – eventually – onto the fare paying public? Cost v benefit analysis of the additional 'paper work' and oversight of that paperwork and the endless 'wriggle room' copious amounts of expensive shelf ware could tell a different story.

The AMROBA stated position is based in law, logic and long experience in the training, qualifying and surveillance of 'aircraft maintenance and engineering standards' presented by qualified, expert opinion. So why is there cohort of people madly rewriting that which has been accepted world wide as a gold standard.?

Has CASA simply become a 'make work' haven, one of small, disjointed little empires crewed by jobsworths? A collective made up of parcel pushers who manage to avoid all semblance of real responsibility feeding a network which achieves little but self protection? Fair questions – IMO – but I can't see 'the' Minister wanting to upset that cozy little kitchen clutch by asking 'embarrassing' questions, let alone awkward ones, without getting anywhere near the pointed ones, which, if asked would see a major change to the basic way CASA do business.

Full marks to AMROBA for tenacity and daring to ask the right questions and providing the way to repair the damage and expense; which, for no tangible, demonstrable gain CASA not (demonstrably)  provided in any way shape or form to the 'efficiency' or 'safety' of the aviation industry. The costs horrific – benefits non.

Toot – toot.

[Sandy Reith]

The CASA make work trajectory has no deviation, but perhaps increased acceleration, in the last 10 or 15 years.

Reforms of substance cannot occur without political will power and this is the missing element because there’s no concerted effort by the GA industry to provide to Members of Parliament a cogent and consistent manifesto. To win the respect of the Parliament will require a level of sophistication in messaging that’s completely lacking at present.

[Peetwo]

AMROBA BREAKING NEWS -

Via amroba.org:





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[Peetwo]

AMROBA - September Newsletter

Via the AP emails:

To all Members

We are currently having issues with our website preventing links to work.

They apparently did an update that wiped out the links and are currently trying to fix.

I have attached the Newsletter, and a document referred to in a Newsletter article.

In the Newsletter we discuss:

1. The Basic Levels of employee to management in all maintenance businesses. Because you cannot inspect in safety, the skills of the basic persons is important. Where are all these employees? Both CASA and the Education system do not provide the clarity to attract employees.
   
2. The purchase of aircraft for private use is declining. With new technologies, Regional and Urban Air Mobility appearing, it is the on-going costs that restrict growth. Are Australian airports Hospitable to private aviation, UAMs, RAMs?
   
3. Global Recognition of our ARCs – our possible export products.When CASR part 21 was made in 1998, industry and CASA were working to agreements with the FAA, Canada and others. The intention was technical agreements with reciprocal recognition of airworthiness documentation by other nations. Sadly, we have been left behind – refer attached article on reciprocal arrangements between EASA, Canada and FAA.
   

Obviously, governments are not supportive an aviation engineering having export capabilities.

Ken Cannane

Executive Director
AMROBA
Phone: (02) 97592715
Mobile: 0408029329
www.amroba.org.au
Safety All Around.

Links: https://auntypru.com/wp-content/uploads/...r-2024.pdf & https://auntypru.com/wp-content/uploads/...d-EASA.pdf

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[Peetwo]

Latest Breaking News.- Reciprocal Acceptance.by Foreign NAAs.

Whilst the rest of the world continues to harmonise and sign more “Reciprocal Acceptance Technical Agreements” between the civil aviation regulators of different countries, Australia totally ignores these Reciprocal Acceptance Technical Agreements that accepts Australian civil aviation manufactured products and maintenance services. Refer Reciprocal Acceptance Breaking News article on the website.
 
In the late 1990s, post an EU/FAA Bilateral Meeting, it was clear to all NAAs that to participate outside your sovereign borders then each nation would require “Reciprocal Acceptance Technical Agreement” with other NAAs to accept the government document:

• Authorised Release Certificate Form 1.
  

This government document has to be ACCEPTED by the NAA of a foreign nation so Australian designed, manufactured or maintained aeronautical product can be sold and/or be used in that nation.

This has been known for 26 years but these “TECHNICAL AGREEMENTS” between NAAs just haven’t eventuated.



What is the use of this document if it is not accepted by other NAAs like the FAA, TCCA & EASA in it own right?

 
Other Government Documents not Acceted by other NAAs

Without access to the global civil aviation engineering market, Australian civil aviation engineering is wasting resources developing products and repair schemes.

CASA approved documents have no reciprocal acceptance.

• Australian Parts Manufacturing Approvals (APMA),
  
• Supplementary Type Certificates(ASTC) and
  
• Technical Standard Orders (ATSO)
  

have little recognition from foreign NAAs .
 
Design, manufacturing and maintenance organisation certificates issued by CASA have less recognition from foreign NAAs.
 
Early in 2000s, CASA had handshake agreements with the US FAA Associate Administrator, Canada TCCA Director of Certification & Maintenance to apply reciprocal acceptance based on what was in place between the US & Canada at that time. 26 years later and we still have no “Reciprocal Acceptance Technical Agreements of Australian government aviation documents.
 
UNTIL CASA AND OTHER NAAs HAVE SIGNED RECIPROCAL ACCEPTANCES, THEN AUSTRALIAN BUSINESSES ARE LIMITED.
 
CASA developed civil aviation regulations prevent international recognition.

They are based on FAR Part 21 1998 revision.

FAR Part 21 today is very different, it was amended to harmonise more with EU, Canada, and Brazil.
All of these nations are more compliant with ICAO Annexes SARPs.



Australian red tape far exceeds that of the Reciprocal Acceptance Nations in the referred article.
 
Only CASA can make the regulatory changes required to harmonise and to attain Reciprocal Acceptance Technical Agreements.
 
Obviously we don’t have governments that support harmonisation and opening global trade to Australian design, manufacturers and maintenance businesses.
 
I bet you can find many government/public services releases stating how Australian civil aviation is doing so good and internationally accepted.
 
The proof is when we are trading globally in our own rights we will see growth.
 
Ken Cannane
Executive Director
AMROBA
Phone: (02) 97592715
Mobile: 0408029329
www.amroba.org.au
Safety All Around.
 


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[Peetwo]

AMROBA October Newsletter -

Via amroba.org:

To all members,

Our October Newsletter addresses:-

• ICAO’s Classification of Activities includes civil aviation manufacturing, Aviation Training, Maintenance and Overhaul and Regulatory Functions in addition to Operations activities.
  

CASA is Australia’s Regulatory Authority responsible for setting qualifications and training to meet the ICAO standards.

IMO – the International Maritime Organization– is the United Nations specialized agency with responsibility for the safety and security of shipping and the prevention of marine and atmospheric pollution by ships. IMO's work supports the UN SDGs.

• AMSA is Australia’s regulatory authority responsible for setting  to meet the IMO standards.
  
• The difference is that AMSA authorises the actual courses to attain a qualification to hold an AMSA licence/authorisation.
  

When compared, it is easy to see why the maritime system is stable and meets global standards – total reverse to civil aviation.

• ICAO’s minimum Classifications of Operations provides more pathways than our regulatory system.
  
• Why hasn’t Australia adopted the ICAO Commercial Air Transport “Air Taxi” system
  

ICAO Annex 6, Parts I, II & III details the  standards for approval and operations – in some cases, less onerous than Australia’s red tape systems.

• In some cases, an operator only has to meet the standards specified to provide the operations service. Less red tape than what is applied in Australia.
  

• Without doubt, the current system has resulted in a shortage of pilots, maintenance engineers, small businesses in both the engineering and operational sectors.
  

• When Flying Clubs were popular, we had many small businesses throughout the aviation system with much less red tape.
  

• We have harped on it for some time, full adoption of EASR Parts 66/147 A & B regulations would have removed the issues we have today.
  

Government needs to re-think the regulatory reform, from an engineering viewpoint, from an internal domestic system to a globally harmonised system with government to government nd CASA to other Nations Safety Regulator that enables Australian engineering businesses to participate globally.

This is a pipe dream at present because the government’s Authorised Release Certificate, Form 1, is not globally accepted.

The size of the industry is dependent on the regulatory system and the amount of red tape.

Ken Cannane
Executive Director
AMROBA
Phone: (02) 97592715
Mobile: 0408029329
www.amroba.org.au
Safety All Around.

On somewhat related matters but in another hemisphere, the FAA backs down on adopting (and therefore enforcing) the Moss Interpretation on maintenance supervision, via AvWeb:

FAA Puts Maintenance Supervision Guidance On Hold
Industry groups’ protest led to reconsidering the interpretation

Mark Phelps

Updated Oct 18, 2024 6:01 AM EDT

Image: ATS Apprentice Program

In a one-paragraph letter, the FAA legal team reported this week it is placing the so-called Moss Interpretation of maintenance supervision requirements on indefinite, but not permanent, hold. Industry groups and specifically Mike Busch of Savvy Aviation had protested that the interpretation would do irreparable harm to enabling apprenticeships and aircraft owner maintenance in general aviation maintenance.

Busch told AVweb today that the FAA had placed the interpretation on hold, and that he and industry advocacy groups have requested an FAA/Industry meeting before the FAA issues a clarification on the interpretation. Busch explained that the rule, as written, has been in place for 60 years and certificated maintenance personnel, Airframe & Powerplant (A&P) mechanics and those with Inspection Authorization (IA) status could use their judgment in supervising the work of apprentices and other non-rated individuals. He said that form of surveillance could range from simply inspecting the work after it is completed and signing it off in the logbook to direct in-person consultation on more demanding and critical procedures—and everything in between.

But under the language of the  Moss Interpretation, that discretion is removed and the apprentice must be under constant in-person supervision. He said that was not the intent of the original rule and would cripple the GA maintenance industry at a time when mechanics are sorely needed. At press time, Busch had not heard whether the request for an FAA/Industry meeting had been approved by the FAA.

When I queried KC about what all this meant he replied:
 

P2

Both were wrong in their interpretation.

“to the extent necessary” has been the most important part of the rule, always has in the US.

We sent an input to our counterpart, AARSA, to back their submission.

Ken

When I further queried what was AMROBA's input KC came back with the following...

P2

We inputted the following to ARSA based on the FAA proposal.
It is like CASA determining how much supervision is required.
It is up to the LAME and the supervised employee.
How long have you supervised him/her?
How well trained is the individual?
Apprentice to experienced AME?
 
Etc, etc,
 
Main sentence of our input.
 
Only the AMT can determine the amount of supervision required based on skills and experience of the person being supervised. If the FAA can prove there was insufficient supervision because the work was not performed correctly, then they could carry out enforcement. To assume the result before return to service is beyond the wording of the regulation that, in our opinion, allows the AMT to determine the amount of supervision required, not the FAA.

US Associations sent a combined letter to the FAA

US Association Submission re Supervision

Ken

KC perfectly highlights why it is so important for the Australian aviation industry to be engaged with our international counterparts to benefit trade and harmonisation of international safety standards IE the ICAO SARPs...

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