[Peetwo]

AMROBA Newsletter - Volume 14 Issue 1 February — 2017

KC is back on deck ( ) and straight up firing a salvo that nails the bullseye...

Australia’s Obligations under the Chicago Convention.

How close does Australia comply with ICAO [Minimum] Standards prescribed in the Annexes to the Convention? You can see what differences government has notified to ICAO quite simply by clicking on the link:

http://www.airservicesaustralia.com/aip/...17-h24.pdf ,

and open any of the Annex links in the Appendix of AIP H24-17. What it demonstrates is little policy is given to eliminating differences as new regulations and standards are developed and made. Many of the differences are failure to adopt the ICAO international terminology by creating our own or adopting terminology from other countries regulatory system. However, there are many ‘missing’ differences such as Annex 6: "a) the aeroplane is maintained in an airworthy condition". There should be a concerted effort to harmonise with the ICAO standards and practices, including adopting its international definitions. It is time for government to get serious and stop wasting resources. Adopt and harmonise.

For example: Article 33. Recognition of certificates and licences states: Certificates of airworthiness and certificates of competency and licences issued or rendered valid by the contracting State in which the aircraft is registered, shall be recognized as valid by the other contracting States, provided that the requirements under which such certificates or licences were issued or rendered valid are equal to or above the minimum standards which may be established from time to time pursuant to this Convention. (Annex 1 licence standards may be closely followed for pilot licences but not the AME licences.)

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1. Airworthiness and Maintenance Control.

Reliability is the real reason why a commercial operator wants to control the airworthiness and maintenance of his/her aircraft so that it can return the best profit. Without looking at regulatory reasons for airworthiness and maintenance control, the operator is looking for maintaining the aircraft in a state of readiness to meet the need of the operator. The depth of monitoring and reviewing is dependent on the needs of the operator. For instance, if you are operating a tight schedule service that requires high hours per day, then a high level of monitoring is required to apply preventive measures to lower ground time.

There are many principles applied in airline operations all designed to get the maximum out of each component fitted to the aircraft. In these sectors, high level monitoring not only of engines and their components but also airframe and avionics systems are subject to the same monitoring process. Emergency services and charter operators are also benefitting from adapting monitoring and reviews of their aircraft’s maintenance programs a lot more than in the past.

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2. When "global standards" should be promulgated before regulations

What comes first, promulgation of a "standard" straight out of an Annex prior to developing a regulatory base to implement the standard or is the ICAO [minimum] standard "Australianised" so we continue with differences? For instance, Annex 1 states for a LAME: "4.2.2.3 A Contracting State shall prescribe the scope of the [ICAO] privileges of the licence holder in terms of the complexity of the tasks to which the certification relates." The scope of the [ICAO] privileges relates to the ICAO LAME certification privileges to sign "as airworthy" or "to sign the maintenance release".

This was partially described in CAO 100.90 series except it failed to mention "Scope of Certification Privileges". ICAO state in: 4.2.2.3.1 "Recommendation — Details of the LAME certification privileges should be endorsed on or attached to the licence, either directly or by reference to another document issued by the Contracting State."

Adopt and promulgate the standard and then develop the regulations and advisory material. This must be the way of the future.

Keep it coming KC and good pick up on the latest version of the uniquely Australian 'notified differences' to the ICAO SARPs...


MTF...

Ps Haven't had a chance to review the latest version -
http://www.airservicesaustralia.com/aip/current/sup/s17-h24.pdf - however I find it passing strange that in the last couple of years there has been regular instalments/amendments (every 6 months) to what was once over 4000 notified differences. Yet prior to the ASRR being released we were lucky to be compliant with the  ICAO AIP GEN 1.7 requirement for 3 year reviews of a signatory State's 'notified differences'...