[Peetwo]

RAAA GA advocacy? - Too little, too late..   

Personally I don't think Carmody and the Iron Ring would do little more than roll over and fart when they read this Oz article from Mike Higgins CEO of the RAAA:

RAAA calls for CASA to consult
MIKE HIGGINS
The Regional Aviation Association of Australia is proud to be a strong supporter of general aviation in this country.

A strong GA sector is vital as we acknowledge that, in many cases, flight instructors, pilots and maintainers tend to move up into the regional airlines after gaining valuable experience in the smaller GA organisations.


As another recent example, the RAAA is a key and vocal member of the Civil Aviation Safety Authority technical working group on Civil Aviation Safety Regulations Part 43.

The proposed new Part 43 will be a much improved way of maintaining aircraft operating in the private and aerial work sectors (not the RAAA world directly).

Under the proposal, future compliance costs for existing maintenance providers will be substantially reduced by the removal of obligations to conduct internal audits and obtain CASA approval to expand or change the range of maintenance ser­vices they provide.

In a nutshell, the proposed rules are based on the GA safety standards found in the US. Therefore, we can expect the changes to maintain or raise existing levels of safety and concurrently increase productivity, as less time will need to be devoted to the soon-to-be-redundant CASA red tape that has not improved safety outcomes.

This is a great initiative for maintainers and aircraft operators based in regional, rural and remote Australia. Congratu­lations to CASA on this one.

On the other hand, the new CASR Part 135, which will affect every current charter operator in the country, is before the parliament without any reference to how this sector is to be maintained. Therefore, the Australian community (via their sitting members) is being asked to vote on a half-baked package.

How can one reasonably make such a momentous decision affecting every charter operator in the country when 50 per cent of the picture (maintenance requirements and therefore costs) are not yet available?

To make matters worse, there is a rumour within CASA that CASR parts 42 and 145 (currently applying to the largest aircraft operators and maintainers in the country) will be tweaked and pushed down on to current Civil Aviation Regulation 30 maintenance and charter organisations. This would be a disaster.

There is a way forward.

Sector risk profiles are collaborative meetings between CASA and experts in industry. The RAAA has been represented in almost every SRP undertaken to date. The RAAA is urging CASA to pause and conduct a SRP on the CAR 30 rules and organisations. A CAR 30 SRP would determine exactly what, if any, improvements might need to be made for current CAR 30 organisations to continue maintaining charter operators under the new Part 135.

Mike Higgins is chief executive of the Regional Aviation Association of Australia.

Update to the latest Fort Fumble clusterduck - 

Via the Yaffa:

Industry in the Dark over Part 135 Maintenance Rules
6 December 2018

General aviation advocates are concerned that the Civil Aviation Safety Authority (CASA) has sent the new CASR Part 135 to rulemaking without including any maintenance requirements.

Part 135 covers air transport operations for small aircraft, and effectively applies regulation for heavy Regular Public Transport (RPT) to charter operations.

With the announcement in July that CASA will develop new GA-specific rules, operators and maintenance engineers are waiting to see if these new, less onerous, regulations can be applied to Part 135 operations as they are in the USA.

According to Ken Cannane, Executive Director of the Aviation Maintenance Repair and Overhaul Business Association (AMROBA), sending Part 135 to rulemaking without any maintenance requirements has left the industry in the dark.

"When you go down the line of adopting one direction or the other, it has to be adopted in a total format," he told Australian Flying. "We're doing maintenance rules for general aviation, which interlink closely with the CASR Part 91 sub-part, which covers requirements of the USA.

"As for Part 135, CASA hasn't given any indication whether it's going to be the FAR sub-section of 135. Operators need to understand the maintenance requirements, not just maintenance people.

"[CASA] needs to bring it together into a single platform. I was under the assumption that Part 135 would include the maintenance requirements for a Part 135 operator!

"It's a foolish thing we've done. Years ago we included a sub-part in every part, so every operator knew what was going to be applied within that new regulation.

"If you follow the FAR system, it does have a separate sub-part in every FAR operational rule which lays out the maintenance rules for that standard of operation."

Inquiries to CASA about which maintenance regime will be applied have not yielded any answers, which Cananne believes is not helpful to companies operating under Part 135 in the future.

"All they've said is 'we'll look at it after we get the maintenance rules in based on the FAR system for general aviation'," Cannane says. "It's a never-never situation that leaves people not knowing in which direction they're trying to head. Operators really should know now!"

Other charter operators have told Australian Flying before of fears that Part 135 will apply maintenance rules applicable to heavy RPT, which is likely to come with a greater cost impost than the new GA rules being developed.

In the USA, FAR Part 135 enables aircraft to be maintained using the general aviation rules. It is yet to be seen if CASA will allow that given they have defined all passenger-carrying operations out of GA and into CASR 135.

According to a CASA spokesperson, the maintenance rules have not been included because CASR 135 differs from FAR 135 in that the Australia regulation is operational and therefore doesn't include maintenance.

"The airworthiness/maintenance elements of the program have been split up according to the current operational classifications RPT/charter/aerial work/private," the spokesperson said. "We covered RPT back in 2010 with CASR Parts 42 and 145. Maintenance for charter, aerial work and private is still under CAR.

"The remainder of the airworthiness reg reform program (charter, aerial work and private) has been split into two projects, one to cover the private and aerial work sectors, and a second to cover charter."

Read more at http://www.australianflying.com.au/lates...Tv7hTyG.99

And in response to RAAA's Mike Higgins article above, via Linkedin:

Shannon Wells
Managing Director, Airlines of Tasmania (Par Avion)
They really looking at 42 for 135 ops ?

Ben Wyndham
Owner/Director/Chief Pilot at Airspeed Aviation
Shannon Wells we could call it a HAAMC?

Ben Wyndham
Owner/Director/Chief Pilot at Airspeed Aviation
Are we all agreed then that the Civil Aviation Safety Authority are making a monumental hash of this and are actually putting business, jobs, and lives at risk by their legislative jihad on GA?

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Ben Wyndham
Owner/Director/Chief Pilot at Airspeed Aviation
Mike Higgins the proposed Part 43 policy released today makes it clear that CAR 30 will be phased out and Part 135 operators will be pushed up to Part 145 maintenance.
It may not be too late yet, but you cannot say that CASA aren't making an enormous hash of this.

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Ben Wyndham
Owner/Director/Chief Pilot at Airspeed Aviation
Great to see some support for CHTR from the RAAA and the RPT Sector Mike Higgins ?

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Ben Wyndham
Owner/Director/Chief Pilot at Airspeed Aviation
I have been out getting quotes.
CAMO will cost me $50,000 pa
Contract safety manager $36,000 pa
Maint bills will go up 35-50% if our CAR30s have to go CASR 145.
CASA's answer is "well if you're the last man standing you will be able to charge more".
Family GA businesses are about to become history. 
It may not be too late yet, but you cannot say that CASA aren't making an enormous hash of this.

Stuart Burns
Airfreight & Corporate Aircraft Charter Specialist
Is it a monumental hash Ben, or a calculated destruction of the industry that carries a great part of the Australian economy through providing the regional and remote regions with essential services? Anyone who lives or works outside of a capital city needs to be very concerned.

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Paul Carey
Managing Director | Avtrac Pty Ltd | Avtrac WA Pty Ltd | Avdocs - CASA Delegate
Organisations like ours at Avtrac have the added burden of multiple CAMO approvals for our Operators (massive duplication) instead of allowing an Independent CAMO like EASA regulations.

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Stuart Burns
Airfreight & Corporate Aircraft Charter Specialist
Cheers Mike, the damage CASA is doing to SME aviation operators through mismanaged regulatory reform is criminal.

&.. from Wellsy:

Finally for those FB followers, yesterday AOPA Australia's Ben Morgan and AMROBA's Ken Cannane convened a video conference discussion on Part 43 General Aviation Maintenance Regulation reforms: 

 

MTF...P2