[Peetwo]

Part 43 the next Part 61 regulatory behemoth?

Ref the 20/20 thread:

Submission 65 - ALAEA

Via the RRAT inquiry webpages: 

Australian Licensed Aircraft Engineers Assocation (PDF 5585 KB)

Via the Yaffa:

 

ALAEA speaks out against GA Maintenance Rules
21 October 2021

The Australian Licenced Aircraft Engineers Association (ALAEA) has leveled heavy criticism of the proposed CASR Part 43 maintenance regulations.

In a submission to the Senate Standing Committee on Rural and Regional Affairs and Transport (RRAT) inquiry into the general aviation industry, the ALAEA has said that Part 43 creates confusion as most of the proposed requirements are currently covered by other standards.

CASR Part 43 was promised by then Deputy Prime Minister and Minister for Infrastructure and Transport Michael McCormack at gathering of general aviation associations at Wagga Wagga in July 2018.

The submission comes after ALAEA Technical Manager Stephen Re testified before the committee via video link in September.

"Part 43 has been proposed to cover not only the maintenance requirements of the aircraft (i.e., what must be done and when) but also the requirements of organisations maintaining the aircraft, as well as the training and licencing of engineers," the submission states.

"These requirements are already catered for in both the CAR and CASRs Part 42 (continuing airworthiness), Part 66 (engineer licencing), Car 30 and Part 145 (approved maintenance organisations).

"As it stands the introduction of the proposed Part 43 will create multiple levels of standards and training for engineers who are essentially working on the same aircraft but in different operations classifications and will remove the requirements for qualifications for important specialist skills such as aircraft welding, composite repairs and non-destructive testing."

The ALAEA aired concerns that there was already parallel and overlapping regulation with the CASRs and the older CARs still operating side-by-side, which they say creates confusion.

"Ideally aircraft airworthiness, approved maintenance organisations, engineer licencing, and maintenance training should be found in the CASR’s only. They are Parts 42 (continuing airworthiness), 145 (approved organisations) 66 (licencing) and 147 (training) supported by a Manual of Standards (MOS) and the appropriate supporting Guidance Material and Acceptable Means of Compliance (AMC and GM).

"Clear and concise regulation should not need any additional material to explain its purpose or how to comply."

With some maintenance regulations still to be completed, the ALAEA is concerned that developing Part 43 has drawn resources away from what it sees as more important projects.

"It is our view that Part 43 has reached outside of the areas it needed to address and has absorbed valuable scant resources in the process (both CASA’s and Industry)," the submission states.

"The intent of Part 43 could have been achieved with better and faster results by amending the current airworthiness regulations in the CASR.

"For example, an amendment to Part 145 to define and simplify the three distinct levels of standards required to maintain large RPT aircraft, charter aircraft and lower risk GA aircraft could be achieved very quickly if the appropriate resources were allocated for consultation and drafting."

In August this year the Aviation Maintenance Repair and Overhaul Business Association (AMROBA) came out in support of CASR Part 43, but warned implementation would not be straightforward and required modification to other regulations.

Plus from this week's LMH: http://www.australianflying.com.au/the-l...tober-2021

...I am starting to wonder if CASR Part 43 actually has legs. Announced a bit out of the blue in 2018, the regulation covers maintenance for GA aeroplanes operated only in the private and airwork categories. It is supposed to make things simpler, but the ALAEA believes it will just make matters worse and AMROBA has pointed out all the other regs that will have to change to get CASR Part 43 to work the way FAR Part 43 does. The great danger is that Part 43 may be come the new Part 61, i.e., implemented without a true understanding of the way the industry operates and in need of serious review the day after it was signed into law. If you turn to page 18 of the November-December issue of Australian Flying, you will find an article entitled The State of the Unity. It outlines the many rifts that exist within GA and the issues that divide, and Part 43 is listed as one of them. Although Part 43 was intially greeted with applause, it seems there are people within GA that are now going through buyer's remorse. But Part 43 is not the heart of the matter. The problem is much greater: CASA's maintenance regulation regime is confusing and a touch non-sensical. The ALAEA submission to the senate has some excellent examples that a comedy writer would not dare include in a script but for CASA make perfect sense. CASA's working groups need to have a look at maintenance regimes holistically and ask if this really is the world's best practice...

MTF...P2