[Peetwo]

Evidence: CASA holding back industry innovation & investment-

Ref Senate Estimates thread:

Ps Having developed a recent interest in the Joint Parliamentary committee for treaties - see HERE &..

...I was pleased to note that the membership in this parliament of JSCOT also included Senator Sterle.

I also noted with interest certain lapsed inquiries from the 44th Parliament were carried across and reinitiated for inquiry - see top 2 & No. 6 HERE.

Pps Due to the very relevant content the No.6 reinitiated inquiry will be taken as being actively monitored by PAIN and all previous records, submissions, Hansard etc. plus any updates will appear on the AMROBA thread...

This was the ToR & link for the No.6 JSCOT inquiry:

New  Implementation Procedures for Airworthiness - USA
        Status: Current
        Date Referred: 12 September 2016

Track Inquiry                

Now if you go to the submission, you will see (at this stage) there is only one submission from AMROBA:

1 AMROBA (PDF 90 KB) 

Committee Secretary
Joint Standing Committee on Treaties
PO Box 6021
Parliament House
Canberra ACT 2600

The Bilateral Aviation Safety Agreement (BASA) between Australia and the United States has been fairly restrictive for Australian aviation businesses to trade with the United States of America. Australian manufactured aviation products approved by the Civil Aviation Safety Authority (CASA) are available to be sold now. The only thing that is holding our industry back is this international agreement and CASA/FAA [Federal Aviation Administration] Implementation Procedures. The CASA/FAA Implementation Procedures cannot be signed until the BASA has Parliamentary approval. It needs to approved this year.

Over the last couple of years, industry has been requesting these changes to this Agreement so Australian manufactured aviation products can be sold in the USA.

The FAA required analysis and assessment of the CASA approval process has been completed and sample manufactured products have been accepted by the FAA.

Australian manufacturers are concerned that administrative delays in getting these changes to the BASA can be stalled in Parliament if the amended document sits for the 20 day period. This could delay the approval by the FAA of amendments to the Implementation Procedures between CASA and the FAA.

Australian manufacturers have CASA approved products ready to market in the USA. CASA and the FAA have agreed to amend "Implementation Procedures" and can be signed this year if the BASA is expidited through parliament so it does not have to tabled for the standard 20 days.

CASA staff are with the FAA next week.

The Minister of Innovation, Mr Wyatt Roy is fully aware of one such product and has promised support.

Regards

Ken Cannane

Executive Director

AMROBA

www.amroba.org.au

Safety All Around.

Treaties tabled on 2 February 2016

Submission 1

 
However prior to end of the last Parliament there was one public hearing that was particularly interesting...

Here is the Hansard where Senator Fawcett once again made the CASA executive trough dwellers, look quite frankly like deer in the headlights, inept & completely out of touch with reality   (P2 - Also note the part in bold from MP Whiteley):

Joint Standing Committee on Treaties

02/05/2016
Treaties tabled on 2 February and 2 March 2016

BALA, Ms Nisha, Section Head, International Relations, Civil Aviation Safety Authority
HUTTON, Ms Carolyn, Branch Manager Government and International Relations, Stakeholder Engagement Group, Civil Aviation Safety Authority
NIKOLIC, Mr Peter, Manager Initial Airworthiness, Standards Division, Civil Aviation Safety Authority
WALKER, Mr Robert, Stakeholder Engagement Group Manager, Civil Aviation Safety Authority
WEEKS, Mr Roger, Acting Executive Manager, Standards Division, Civil Aviation Safety Authority
Committee met at 11:16

Agreement on the Promotion of Aviation Safety between the Government of Australia and the Government of the United States of America

CHAIR ( Mr Hartsuyker ): I now declare open this public hearing. The Joint Standing Committee on Treaties will take evidence on the amendments to the implementation procedures for airworthiness under the Agreement on the Promotion of Aviation Safety between the Government of Australia and the Government of the United States of America.

I welcome representatives from the Civil Aviation Safety Authority. Although the committee does not require you to give evidence under oath, I should advise you that this hearing is a legal proceeding of the parliament and warrants the same respect as proceedings of the House and the Senate. The giving of false or misleading evidence is a serious matter and may be regarded as a contempt of the parliament. If you nominate to take questions on notice could you please ensure that your written response to questions reaches the committee secretariat within seven working days of your receipt of the transcript of today's proceedings. Do you wish to make some introductory remarks?

Mr Walker : Yes, we would, Chair. Thank you for the opportunity to make some opening remarks around the amendments that are being considered here today. Under article 7 of the Agreement on the Promotion of Aviation Safety between the Government of Australia and the Government of the United States of America, more commonly known as the Bilateral Aviation Safety Agreement or BASA, it is proposed to bring into force a number of amendments to the Implementation Procedures for Airworthiness, or the IPA. The BASA is a bilateral technical cooperation agreement that provides the overall framework for cooperation on aviation safety. It also provides for the development of treaty level implementation procedures, or IPs, on specific areas of aviation safety oversight. This agreement was signed in June 2005 and the first and currently only set of IPAs, the Implementation Procedures of Airworthinesss, was signed in May 2006 and entered into force on 28 November 2006.

The agreement and the IPA facilitate mutual acceptance of approvals, evaluations and monitoring associated with civil aviation products, personnel and facilities. These proposed amendments will provide significant benefits to Australia manufacturers of aeronautical parts and appliances by enabling them to export Australian certified aeronautical parts directly into the United States. The benefits will extend to owners and operators of transport category aircraft, normal category helicopters and transport category helicopters as well. The proposed amendments will remove a limitation related to the state of design so that the United States Federal Aviation Administration, the FAA, will accept Australia's Civil Aviation Safety Authority's supplemental type certificates for those small aeroplanes where the United States is not the state of design. Australian parts and appliances—which include any instrument, mechanism, equipment, part, apparatus, appurtenance or accessory, including communication equipment, that is used or intended to be used in operating or controlling an aircraft in flight, is installed in or attached to the aircraft and is not part of the airframe, the engine or propeller—will no longer have to undergo additional often duplicated manufacturing certification by American authorities when exporting to the United States.

The original IPA established the working processes for recognition of a range of aviation safety certification approvals issued by CASA and the FAA. Following negotiations with the US FAA, amendments to the IPA were signed by representatives of the Australian government and the government of the United States in Washington on 7 May 2010. These amendments extend FAA recognition to CASA's Australian parts-manufacturing approval processes, addressing an imbalance in the IPA where Australian regulation already recognised and accepted US manufactured and FAA aviation parts. The approval of this amendment will provide significant financial benefits to the design and manufacturing sectors of the Australian aviation industry. This will open one of the biggest aviation markets in the world to Australia and will allow for export of Australian designs and products without any additional commitments for Australia. The proposed amendment IPA will replace the current IPA, and no change is required to the BASA. No financial costs to the Australia government are anticipated in the implementation of the proposed amendment IPA and no new legislation is required to give it effect.

I thank the committee for the opportunity to make this opening remarks. We welcome any questions from the committee.

CHAIR: I have two questions. Firstly, what is the size of the market that is likely to be opened up for Australian producers as a result of these changes? Secondly, what are the likely savings in relation to the reduction of the need for validation?

Mr Walker : Obviously the US aviation market is one of the largest in the world. The way the market currently runs is that Australian certification that is done here in Australia has to be revalidated before parts or aircraft can be exported to the US. The real value of these changes is that a lot of the expense that is involved in doing that is going to be taken out of the equation. I will refer to my colleagues for some of the specifics around the actual money saved, but it goes without saying that it is about the range of what is on offer here. These changes will provide opportunities for the larger regular passage of transport operators like Qantas and Virgin when they reach end of lease for aircraft frames et cetera and want to sell those frames back into the US right through to the smaller operators, particularly parts manufacturers here in Australia. There are some great opportunities for some of the smaller aerospace sector operators. In terms of the quantum, it is one of the biggest markets in the world. In terms of the money that can be saved—and I might refer to my colleagues here as well—we are talking about millions of dollars of savings to individual operators.

Mr Weeks : Chair, just to give some sense of differentiation in the size of the two markets, within Australia we have about 15,000 aircraft on our civil register. In the United States there are in excess of 207,000 aircraft. So the potential for our manufacturers to access that market is obviously a significantly greater quantum than what they would have access to here domestically. In relation to the costs it is difficult, because this is a potential opportunity. But we know that, for example, if one of our major carriers was wanting to undertake a refit or refresh of their cabin, at the moment they would have to engage a United States firm to do the certification processes and our own, and it can be in the vicinity of millions of dollars of additional cost to duplicate that certification. That would be removed under this arrangement.

Senator FAWCETT: I want to take you to a couple of points. One is just a question of clarification. My understanding is that CASA STCs for part 25, 27 and 29 aircraft are limited. So where Australia is the designer of the aircraft or where the US is the designer of a small aircraft essentially we can provide STCs for anything, but as soon as we get into the commercial field and the RPT type aircraft my understanding from my notes here is that it is limited. Can you expand on what that means? It appears to limit or put barriers in the way of the most lucrative part of the American market.

Mr Nikolic : Regarding the way this was negotiated, when we approached the FAA for the first time with the wish to expand our scope they requested that we provide them with evidence of our competency—CASA as well as industry. We provided a number of STCs in different categories to demonstrate that competency. They reviewed that and they based their limitation and scope on the basis of what we could demonstrate at the moment as a level of competency, so on those bases they could simply accept those approvals without any further validation. Regarding the way the amendment is structured, we have two tiers of STCs. The first tier will be the one that will be automatically accepted, which means that they will administratively just accept the application and will issue their validated certificate without actually checking anything. The second tier is anything else.

When it comes to anything else, basically that is open to any STC and then it will come to a negotiation between the FAA and CASA as to how deep they need to dig into that more complex STC that they deem outside that initial scope.

What we achieved with that first tier, which is acceptance, is that we managed to cover probably 80 to 90 per cent of the work that is currently being done in Australia, especially when it comes to part 25 and potentially part 29 transport category fixed wing and rotary wing aircraft. The acceptance will be related to cabin refurbishments, which is the main thing for airlines. Every 3 to 5 years they refresh the cabin to be more competitive. It will also cover automatic acceptance for emergency medical outfits, which is what is mainly done by our design organisations to equip new helicopters for state emergency services and so on. These are probably the most lucrative areas that currently could be exported to the US and other countries. From the savings point of view, what Qantas and Virgin told us is that each of these STCs when contracted in the US would cost between $2 million and $4 or $5 million. They do probably between three and five projects every year. So there are significant savings there. Also, there is the potential for further development of the manufacturing sector in that particular area. It is potentially undeveloped for the reason that in the past that work was mainly outsourced to the US. That is a big—

Senator FAWCETT: Under the current assessment of this limitation where does that leave, for example, the firm down at Moorabbin that under APMA approvals used to manufacture landing gear struts for Metroliners? They had a very large market in the United States. Where do they stand under this new interpretation of limitations?

Mr Nikolic : If they specifically work on landing gear or for part 25 aircraft they would probably need to go to a slightly higher level of review by the FAA. However, up to this point they did not have any option. They could not enter that market at all with the Australian—

Senator FAWCETT: They have been in the market for five or six years.

Mr Nikolic : Only if they have the FAA approvals. If they have an FAA approval, which means they would need to contract an FAA design organisation, and they have an overarching FAA production approval holder who would take them as a supplier, then they could access that market. With this particular arrangement they would be able to contract an Australian design organisation, get a CASA approved STC and then under their own production approval they would be able to export that. So the option is there. How deep the FAA would seek to go into validation of that STC is a matter of negotiation.

Senator FAWCETT: My next question goes to CASA's capacity to support industry. The feedback that I got extensively a couple of years back when we were doing the Forsyth review was that for people who want to export parts or services into foreign markets time to market was critical. Someone would identify, they would put up a request for tender, people would tender but then they had to deliver within a pretty quick time frame. The feedback that I got consistently was that for anything that was delegated under the old CAR 35 system, where an engineer would sign off on CASA's behalf, that tended to work well but, wherever CASA needed to have its people look at things, capacity constraints—and sometimes it was possibly linked to a shortage of people within CASA with the relative experience—meant that what an independent engineer could sign off within a week was taking up to a year. I think the worst case I came across was nearly two years for CASA to sign off, which meant that it was impossible for them to meet market demands. Where is CASA at at the moment in having the capacity to work with industry and get timely turnarounds so that they can take advantage of this?

Mr Weeks : Senator, that is a difficult question. Because industry is aware that this is likely to occur, we have certainly seen an increase in the number of applications for things like STCs. The branch is working on those applications as we speak. I think it is up around 40 or so. Each STC does take variable time to assess, depending on the complexity of the product that is being applied for. I am confident that with the staff we have we are prioritising the STCs that require the approval. But it is variable, unfortunately.

Senator FAWCETT: That is not quite my question, though. My question is: are you adequately resourced? If the government's agenda is to encourage innovation and agile activity by industry to export and if a regulatory clearance is part of the system that they have to negotiate, then if you are already under-resourced in your ability to respond in a timely manner—which is what I have been hearing from industry—if the demand goes up because of agreements like this it is just going to make the situation worse. My question is: are you currently adequately resourced? Industry is telling me the answer is no, so I am interested in your perspective. And either what would you need to do to be adequately resourced internally or do you have planning in place to look at how you can delegate engineering authority to third parties to whom CASA has said, 'We accept your degree of competence and you can sign on CASA's behalf'?

Mr Weeks : Senator, in broad terms—and I will ask Mr Nikolic to provide some greater detail—it would be fair to say that if we received a significant increase in applications that would place pressure on us. In the current process I think we have a reasonable degree of being able to handle that, but Mr Nikolic will give more detail on that.

Senator FAWCETT: Just before Mr Nikolic starts, the third part of that question was around delegating to third parties. You have done that in the past. That appears to have contracted somewhat. What is CASA's current view? Do you have plans to reimplement some of those delegated options?

Mr Weeks : Yes. Mr Nikolic will provide more detail, but we have moved away from the CAR 35 process into the CASR part 21 approved design organisation process. There are some things for which at the moment CASA only issues the approvals, but there are also a wide range of approvals that are delegated or given to a part 21 design organisation. Mr Nikolic will—

Senator FAWCETT: Again, sorry just before we go to that I want to talk at the strategic level initially. Again the feedback I have had from industry is that there are frequently people with more expertise in industry than CASA has been able to employ and retain, which leads to deep frustration in industry when there are capacity constraints at CASA. Why are you not looking for an opportunity to outsource the maximum extent possible, as opposed to retaining a range of functions within CASA, if industry can demonstrate that they actually have more capacity and demonstrated competence?

Mr Weeks : That is a good point and that is the model of part 21—to the maximum extent possible have the experts and industry undertake those types of design and approval processes. In terms of our obligations as a regulator, there are some things that we will obviously need to continue to be involved in.

Mr WHITELEY: Can you give a percentage break up of those two differentials? What do you retain for whatever reasons you retain? You said you retain some and you are acknowledging that you already do outsource some, so what bits?

Mr Nikolic : The percentage is difficult to give because all these tasks are random. They do not come in a scheduled manner. However, from a strategic perspective I can say that all minor modifications and minor repairs are already delegated 100 per cent to industry and with major modifications and major repairs there are two options. One is that industry would come to CASA and request that they approve, in which case we would be looking at what the actual request is and in many cases delegate that to industry, and in some cases, if it is a very complex task, we would probably do a partial delegation to industry and partially keep it in CASA. This is the setup that has been in place since CAR 35 days, so it has not changed.

We also looked into strategically delegating more to industry and for that purpose a regulation was put in place two years ago, which is known as subpart 21J approved design organisations. That particular regulation allows an approval to industry, to an approved design organisation, that basically will have almost all the options and approval powers as CASA. There are certain areas where industry would literally have everything except the issuing of the final certificate, which is kept for CASA. So that is already in place.

Senator FAWCETT: My concern comes from a recent visit I made of a firm which for many years has been one of Australia's leading aviation providers that modifies aircraft and does things with delegated authority. Now for the things that are not structural, not external to the aircraft, not impacting at all on the safety of the aircraft—and purely for domestic use, not for export—CASA are insisting on sending staff to look at frames and brackets that are being fitted inside the aircraft. So if you are resource constrained already I question why for something this company has done without issue, safety breach or anything for years CASA is now all of a sudden delaying the process considerably by insisting people come out and check step by step the installation of essentially some frames and brackets for equipment to go on the back of an aircraft. It strikes me that there is a mismatch there between what you are telling us and what is actually happening on the ground. I am just trying to understand why. There are always two sides to a story. I went for a visit and asked some questions and this is what I heard. I would like to hear CASA's perspective.

Mr Nikolic : Without getting into the detail of what firm that is—and it is difficult to talk hypothetically without a specific example—I would assume that we are talking about certain conformity inspections that are done by CASA. We are in the process of making arrangements to be able to delegate those as well. That has not been done up till recently.

Senator FAWCETT: Can I say: in the past—

CHAIR: We are running out of time, Senator. Can I just ask that you write to us and provide further information along those lines, and detail where you are at. You get the thrust of where Senator Fawcett is coming from.

Senator FAWCETT: Chair, can I just ask one must question?

CHAIR: Very quickly.

Senator FAWCETT: You can take it on notice if you need to. Does this agreement—and it strikes me that you are doing some restructuring to facilitate this agreement with the FAA—still provide local companies the option to say, 'We don't want to export. This is purely a modification. We would like to do it under an engineering order'—as they have done in the past? Or are they now required to go through this process? It strikes me that, if somebody has no intention to export, and if they are aware of all the limitations of doing it domestically and having to take it back to the FAA baseline, can they still do that? Or is that commercial impost an unintended consequence of this agreement?

Mr Nikolic : They can still do it using the existing systems. We are currently going through a post-implementation review of the Part 21. We are trying to find other solutions for general aviation apart from the approved design of implementation of 21J. We have a significant group of industry advisers in a working group that work with us. We are trying to find a workable, sensible solution so that not necessarily everyone needs to be a 21J-approved design organisation, and not necessarily everyone needs to have an overhead cost of a design organisation. So we are working on that, as well.

CHAIR: Deputy Chair?

Mr KELVIN THOMSON: In the interest of time, Chair, I will let that opportunity pass.

CHAIR: Mr Whiteley?

Mr WHITELEY: No, I will leave it. It was a very good line of questioning, I have to say. There are a number of obvious questions that could be followed up. I think we should wait. There is an obvious theme within the Senator's line of questioning that, I think, should be taken very seriously. The general perception is that the organisation is nowhere near as efficient or as best practice or as industry standard—whatever the words are—as it should be. My only query would be is that, at the moment, with the current level of applications, you are resource okay. But I think I heard you say that, if it goes up, which we believe it will, you probably would not be. My only question would be, and you might want to address it in your letter, is: right now, are you at industry standard? Are you as efficient through the approval process and the certification process as it would be if a third-party independent contractor was used? I would be interested to hear that.

CHAIR: Senator Fawcett, we do have a couple of minutes left if you have a final question.

Senator FAWCETT: You rushed me to a conclusion!

CHAIR: Sorry, but I thought the Deputy Chair had some questions which he wished to ask. I apologise for that. Being almost 11.45 am, we will bring it to a conclusion. Thank you for attending and for giving evidence today. If the committee has any further questions, the committee's secretariat may seek further comment from you at a later date.

MTF...P2

[Peetwo]

Latest AMROBA newsletter & Aviation Week article:  Volume 13 Issue 9 (September 0916)

From Chapter 1 of AMROBA's newsletter, I get a distinct sense of frustration and fatigue from the normally unflappable, constantly effervescent and positive KC -



However there is no denying KC still has the passion and understanding, with freely given advice to the Government, for possible reformation of aviation safety administration (CASA) that would/could see a positive impact on the current dire predicament of the industry - if only the Minister would listen...

While on MROs, cost of compliance & overbearing, nonsensical, regulatory redtape; the following via Aviation Week was brought to my attention by Baldwin Aviation (TY 4 that.. ):

Costs Of Compliance Uncertainty
Sep 20, 2016 Christian Klein | Inside MRO

[/url]Maintenance professionals tell us that regulatory burden is the biggest, most consistent threat to repair station profitability. Poorly crafted rules, inconsistent enforcement and government policies that don’t align with business realities make compliance certainty problematic.

Reducing burdens by managing regulatory obligations are part of ARSA’s core. One way we accomplish the objective is by catching misguided policy before it becomes a burdensome obligation. A case in point is the “new” parts documentation requirement in change 5 (and now 6) to the US-EU Maintenance Annex Guidance (MAG).
 
The MAG change required an [url=http://awin.aviationweek.com/OrganizationProfiles.aspx?orgId=31159]FAA Form 8130-3 from the production approval holder (PAH) to accompany all new parts installed by U.S. repair stations on articles that may be exported to the EU. Unfortunately, under then-existing FAA rules, the agency (not the manufacturer) had to issue the form, usually through a PAH’s designee.

That created a regulatory Catch-22: In order to serve European customers, many US repair stations would be legally obligated to possess parts documentation that US manufacturers could not issue without FAA designees. The designees were (and still are) in short supply, particularly considering the hundreds of thousands of parts that would need the EASA-required documentation.

Recognizing the threat to aviation maintenance efficiency and profitability, ARSA led a coalition that pressed the FAA and EASA to resolve the problem and has since kept pressure on the agencies to make workable solutions. 

How much money, time and frustration this effort spared repair stations is immeasurable. What is measurable is industry participation. In the MAG mess, private businesses stood alongside the association, demonstrated the reality of aviation maintenance concerns and translated on-paper burden into out-of-pocket dollars lost.

While that member support is imperative, there’s no doubt that every certificate holder is just as frustrated by their regulatory burden whether or not they support ARSA or A4A or GAMA or any of the aviation industry’s “alphabet soup groups.”  

Christian A. Klein is executive vice president of the Aeronautical Repair Station Association and a managing member of Obadal, Filler, MacLeod & Klein, the law firm that manages ARSA

Sounds very similar to the situation we have with the previous mentioned and ongoing Treaties Inquiry - Implementation Procedures for Airworthiness - USA . And perhaps highlights the enormous costs expected to be absorbed by industry because of non-harmonisation of rules & regulations, by what is a huge global industry...


MTF...P2

[Gobbledock]

Interesting and succinct thoughts, as usual, from KC.

But what he hints at when it comes to the CAsA 'structure' is very true - Skiddy embarked on 20 months worth of confusion. And uncertainty. Not long after he started he advised that there would be a restructure. Finally it came about after much uncertainty and he punted some, made others redundant, announced fluffy working groups like 'tiger teams', made others reapply for their jobs, then he left the place without department heads and executive managers. Even today there is much uncertainty, many structural gaps, confusion, a misalignment of roles and responsibilities and what can only be described as a rudderless ship. It's like he came in with the wrecking ball and smashed it all down and has walked away leaving the rubble littered everywhere and no reconstruction plans.

Yes, 20 months and millions of dollars only for him to bail right as the ship takes on copious amounts of water. Then he tells us that 'his job is done, and it's time to move on'. WTF??

We, the IOS could go on and on about this for decades to come, but here is the rub; Australian aviation is the client. While all the above mentioned pony pooh takes place, the industry suffers, and suffers badly. We saw an example with the trucking debacle some months ago, what happens when a bad call is made - chaos!!!CAsA and the Guv'mint need to realise that it's NOT about them, it's about the industry. And the industry is hurting, hurting badly. It's about time the Bureaucrats woke up to that reality. But yet again here we are, 28 years down the track and what has changed? Hmmmm, an agency name change, $300m pissed away on a failed 28 year reform program, an ailing industry, a rudderless ship, and a Frankenstein that has quite simply become an unrecognisable object.

Nup, someone needs to grab their thermos, duck whistle and 12 gauge shotgun - put one shot into the head of the beast, leave the rotting carcas on the riverbank to scare away the other vermin and start again, holos bolos.

Grab the dogs 'K', apparently they are hungry and some important work needs to done

[Peetwo]

Latest 'breaking news' from KC & the AMROBA clan -   

Good to see KC has not put the cue in the rack just yet - actually on the contrary... :

Breaking News 
Government Restricting Trade
October 8, 2016 Ken Cannane
government-trade-restrictions

MTF...P2

[Kharon]

This is within Ken's ambit.  Probably would have skipped the Camit thread on UP, except I always enjoy ‘Aussie Bob’s” posts; I was not disappointed :-

I can speculate
________________________________________

I have no idea why Camit folded but I can speculate ....

First there was the OH&S bullshite that cripples workers and costs heaps in productivity.

Then there was the insurance you blokes seem to love so much. Public liability shite springs to mind but also include workers comp that pays vast sums to idiots who cannot take responsibility for themselves and costs way more than it should.

On top of that there was the general fear that liability may become an issue anyway - thanks to insurance companies and fearmongers, the latter of which are becoming all too common in Australia.

Then there was pressure on the bottom line from their clients, forever wanting a cheaper product.

Then CASA came knocking and wanted compliance with regulations that either didn't exist or where they did, no one could understand them.

Finally the Aussie grubs in grubment land came along and waved the legislation book. Again no one could understand what was written in it.

Then finally the banks in a time of almost zero interest rates insisted on charging exorbitant interest and got away with it because no one wants to take them on.

Just speculation. I must be bored.

[Peetwo]

KC & AMROBA clan latest newsletter: Volume 13 Issue 10 (October 1016)

1. Specialist or Specialised Maintenance?

Correctly worded regulations and standards are clear and concise, i.e. understandable. Sadly, what has been produced over the last decade has raised more confusion than clarity and one of the main reasons is the failure to adopt and use international terminology and definitions. Instead, we have poorly worded regulations and standards very unique to Australia. Internationally, maintenance not covered by the AME, can be classified as specialised maintenance, not specialist maintenance.


2. What is a "Certificate of Release to Service" (CRS)?

Does a "certificate of release to service" give the impression that the aircraft is airworthy and serviceable or is it, as EASA states, simply a release from maintenance?

AMROBA looks very closely at what CASA states is a "certificate of release to service" and how others will interpret this improper terminology.

EASA states clearly in their documentation that their CRS does not mean the aircraft is airworthy and/or serviceable, this will not be the interpretation of our Courts or even members of a Senate Committee. The words "certificate of release to service" will be interpreted as the aircraft is airworthy and serviceable to return to service.


3. The effect of bad terminology on the AME skills.

One reason why the aviation regulatory system relating to AME skilling and licencing is not easy to understand is because it fails to adopt international standards promulgated under the Convention and comply with Government Guidelines.

Instead of harmonising with EASR Parts M, 66 & 147, CASA changed the meaning of EASR wording in the CASRs so they applied a unique system, with different LAME privileges that impacts on international harmonisation.


4. Government Guidelines & Convention Article 37.

One reason why the aviation regulatory system is not easy to understand is because it fails to meet international standards promulgated under the Convention and comply with Government Guidelines. A close review of the government guidelines and Article 37 of the Convention could see a very different regulatory language being applied to the aviation system where regulations would be very minimal & standards adopted.

MTF...P2  

[Peetwo]

KC on DDDD's GA review -

Via Oz Flying:

Ken Cannane, Executive Director of the Aviation Maintenance Repair and Overhaul Business Association (AMROBA). (Steve Hitchen)

GA Study must produce Action: AMROBA
8 November 2016

The general aviation study announced late last month will achieve little unless it results in positive action according to Ken Cannane, Executive Director of the Aviation Maintenance Repair and Overhaul Business Association (AMROBA).

"A new GA study will not achieve much unless the outcome is a government action plan to implement changes for GA that everyone, except public servants, know is needed," Cannane told Australian Flying.

"If the GA study is collating the findings and recommendations of previous reviews and proposing this action plan for government endorsement, it may have success."

One of the outcomes AMROBA is looking for is for the study to recommend regulatory harmony between CASA and the Federal Aviation Administration (FAA) in the USA.

"Developing unique regulatory standards must be replaced with adoption of the ICAO minimum standards as implemented by the FAA for GA.

"This aligns with the vision and approach taken by NZ and Australia in the early 1990s – if it had been completed we would have at least had common Australasian GA aviation requirements.

"Adoption will enable GA growth, especially in rural Australia and manufacturing."

The purpose of the study, as stated by the Department of Infrastructure and Transport, is to examine:

• current GA trends
  
• areas of growth and decline
  
• key economic, demographic and regulator factors
  
• challenges facing GA
  
• opportunities for the GA industry to respond.
  

According to the department, the GA study will "provide a comprehensive overview of the GA industry and assist in identifying potential actions for both the GA industry and Government to consider."

Read more at http://www.australianflying.com.au/lates...DF4ZWQ8.99

MTF...P2

[Peetwo]

KC treaty win ; & further reform frustrations.

Excerpt from Mount NCN post:

JSCT recommends BASA treaty amendments be ratified -

Yesterday the Joint Standing Treaties Committee tabled Report 166 which reviewed...

..Amendment 1 to Revision 1 of the Implementation Procedures for Airworthiness covering Design Approval, Production Activities, Export Airworthiness Approval, Post Design Approval Activities, and Technical Assistance between Authorities under the Agreement on the Promotion of Aviation Safety and Addendum to the Implementation Procedures for Airworthiness between the Government of Australia and the Government of the United States of America...

The following committee conclusion & recommendation was made:

Conclusion
2.47 The Committee supports the ratification of the treaty actions.

Recommendation 1

2.48 The Committee supports the following two treaty actions and recommends that binding treaty action be taken:
§ Amendment 1 of Revision 1 of the Implementation Procedures for Airworthiness between the Government of Australia and the Government of the United States of America; and
§ the Addendum to the Implementation Procedures for Airworthiness between the Government of Australia and the Government of the United States of America.

 However this committee review & report also contained some fairly damning observations of CASA's inadequacies, inefficiencies, lack of expertise in being able to effectively administer and oversight industry. There was also a subtle inference that, despite the ASRR recommendations, there was still a long way to go before CASA is once again trusted and respected by industry...

Problem: --------3. (C/NF) While the team recognized improvements on previous shortcomings and commended many areas, there remain a few shortcomings, principally a shortage of properly-trained inspectors and excessive delegation of regulatory functions to carriers.

---

Examples from 2008 ICAO USOAP report: ..CASA’s Human Resources Management Branch has recently established a training policy that makes a commitment to provide initial, on-the-job, recurrent and specialized training to its staff in the area of airworthiness. However, no training programmes have been developed detailing the type of training to be provided to technical staff in each position, including periodic training plans. In general, the training provided to technical staff is insufficient to address the competency requirements for all the technical tasks...

---

...CASA’s Human Resources Management Branch has been developing a Competency Based Training (CBT) programme for all CASA staff and some courses that underpin this programme have been delivered. However, the existing technical training matrix does not address all the specific training needs of the Airworthiness Engineering Branch (AEB) and its technical staff. In addition, final review and approval of the CBT programme is still pending. Managers of the AEB identify and provide training to their technical staff, including the staff of the field offices, on a yearly basis. However, some specific training has not been provided (i.e. training on human factors) and while on-the-job training is provided, it has not been documented...

It also clear from the committee's OBS that the CASA of today has stubbornly refused to address the concerns of the 2008 ICAO/FAA USOAP audit team:

Resourcing and demand

2.38 During the public hearing on 2 May, CASA noted that the industry, being aware of the impending changes, had been making increasing numbers of applications for STCs. At the time of the public hearing, CASA stated that it had about 40 applications pending.40

2.39 Concern has been expressed that CASA is not adequately resourced to handle its current workload with regard to applications for STCs:

… it often takes CASA a long time to approve complex STCs and similar modifications. The fundamental reason is that in a small aviation manufacturing country like Australia, CASA cannot hope to attract and retain the calibre and quantity of people required to fulfil the task required. Nor can it afford to do so. These limitations apply equally across the spectrum of CASA’s activities. The problem is exacerbated by the lack of trust between CASA and industry as noted in the ASRR (Aviation Safety Regulation Review), which denies CASA assistance from industry to acquire at least some of the required knowledge.41

2.40 The Committee discussed with CASA witnesses whether the agency has the resources it needs to assess the pending applications in a timely manner. Asked for the specific number of STC applications outstanding for various periods, CASA supplied the following details:

• as at 30 April 2016: 18 STC applications outstanding;
  
• as at 30 June 2016: 21 STC applications outstanding; and
  
• as at 15 September 2016: 23 STC applications outstanding.42
  
  

2.41 The CASA witnesses argued that the time taken to assess each STC application varied based on the complexity of the application:43

All STC applications are usually assessed and accepted with a response provided to the applicant within 2 to 3 business days. It should be noted that this process relates to the administrative assessment of the application form and initial supporting documentation. Once the STC application is accepted the STC process begins and the time spent on each application will depend on the complexity of the modification, required involvement of CASA officers and the quality of documentation provided by the applicant.44

2.42 In general terms, CASA indicated that at present it has sufficient resources to deal with the additional applications for STCs, but that if the number of applications increased in future, CASA may experience some resource pressure.45

2.43 Under Part 21-J01 v1.0 of the Regulations, CASA has the ability to approve organisations and people to carry out certification work on its behalf.46 According to CASA:

…the model of part 21 – to the maximum extent possible have experts and industry undertake those types of design and approval processes. In terms of our obligations as a regulator, there are some things that we will obviously need to continue to be involved in.47

2.44 In terms of the degree of work done on certification by approved organisations, CASA indicated the about 100 per cent of certifications for minor modifications and minor repairs is done by approved organisations. For more complex work, the certification work would be delegated on a case by case basis to either approved organisations or to CASA itself.48However, there is concern that CASA has not been adequately utilising this avenue for approvals and has been reducing the use of delegations, contributing to the time taken to obtain approvals.49Asked to quantify the number of approved design organisations, CASA said that two organisations have been approved, one is finalising its assessment, one is in the middle of its assessment and three are at the beginning of the process.50

2.45 CASA also advised that as a result of a review of Part 21–J01 of the Regulations, CASA was working with industry advisers to find a workable alternative for general aviation design approvals.51

2.46 The Committee notes that, given the degree of interest from Australian design bureau and manufacturers in obtaining relevant STCs, it will be important for CASA to ensure the STC process proceeds as smoothly and quickly as possible.

   

From AMROBA's latest newsletter: Volume 13 Issue 11 (Nov 2016)

1. The Ugly Truth Regarding Maintenance Training.

Incompetence is the only answer to why the maintenance training and licencing is in such a mess and almost unworkable. The previous CASA project managers never spoke with other governments departments and agencies. There was no understanding of the role of the AME/AMT, who work in base maintenance and component shops, let alone understand the role of the ICAO Annex 1, Chapter 4 licence privileges. The Education Department recently confirmed no restrictions on course duration. EASR Parts 66 & 147, implemented properly, can lower costs.

Australian aviation legislation/regulations have been out of step globally since 1990. The ICAO requirements for a LAME is important to adopt and the scope of the licence needs to be documented.

Why are we not harmonised with ICAO, EASA and NZ?

The reason is CASA, who thought they were experts, did not adopt EASRs properly or work with the rest of government. The damage they have done will take a major rethink to correct. Many of our members insinuate that it was deliberately done to damage GA. Considering the inputs they had during the consultation period, it always raised industry concerns how they developed the regulations.

CASA did not adopt provisions from EASRs that are a major reason for the unique LAME rating system applied to the licence. With a small change to EASR 66.A.5, Aircraft Groups, the original CAO 100.90 Series “Groups” could have been retained. For those that are old enough, EASA is similar to the original Group ratings use by DCA before the CAO 100.90 series Group ratings. CASA reintroduced a system from the past that did not work well for GA.

66.A.5 Aircraft groups
For the purpose of ratings on aircraft maintenance licences, aircraft shall be classified in the following groups:

1. Group 1: complex motor-powered aircraft as well as multiple engine helicopters, aeroplanes with maximum certified operating altitude exceeding FL290, aircraft equipped with fly-by-wire systems and other aircraft requiring an aircraft type rating when defined so by the Agency.
2. Group 2: aircraft other than those in Group 1 belonging to the following subgroups:
— sub-group 2a: single turbo-propeller engine aeroplanes
— sub-group 2b: single turbine engine helicopters
— sub-group 2c: single piston engine helicopters.
3. Group 3: piston engine aeroplanes other than those in Group 1.

We need to adopt with reference to original CAO group ratings. The following unused EASR clarifies LAME privileges

EASR 66.A.20 Privileges

(a) The following privileges shall apply:

1. A category A aircraft maintenance licence permits the holder to issue certificates of release to service following minor scheduled line maintenance and simple defect rectification within the limits of tasks specifically endorsed on the certification authorisation referred to in point 145.A.35 of Annex II (Part-145). The certification privileges shall be restricted to work that the licence holder has personally performed in the maintenance organisation that issued the certification authorisation.
2. A category B1 aircraft maintenance licence shall permit the holder to issue certificates of release to service and to act as B1 support staff following:
— maintenance performed on aircraft structure, powerplant and mechanical and electrical systems,
— work on avionic systems requiring only simple tests to prove their serviceability and not requiring troubleshooting.
Category B1 includes the corresponding A subcategory

Other provisions of EASR Part 66 also need to be adopted that will enable self-study plus examination plus experience to obtain a licence and or rating. In addition, to obtain a licence, the use of on-line providers is growing in Europe. Tradespersons from allied trades can also be smoothly introduced into aviation maintenance with a more cost effective system.

For a decade or more, MSA, the now defunct industry skill council, (has been replaced by a new SSO to support the Industry Reference Committee responsible for developing training packages) has mislead the industry in stating the training had to be crammed into the same training hours that existed 2 decades back. Basically 1200 to 1500 training hours, depending on which State; these hours include competency assessment.

The Department of Education has informed us, at a meeting in Canberra on the 23rd November that they have never had a limitation on course duration. Like NZ, the course duration has to be promulgated by CASA. This will correct one problem. It will enable harmonisation of training packages. Under the Trans-Tasman Mutual Recognition Agreement, we should be harmonising as close as possible with education qualifications.

Job skill requirements must be provided by the education system to CASA standards.

One step forward and two steps back -


MTF...P2

[Peetwo]

KC & AMROBA final newsletter for 2016: Volume 13 Issue 12 (December 2016)

There are only two topics at the end of this year that summarises our view of Australia’s aviation situation and future.

1. Lack of political support for jobs in General Aviation

The real reason general aviation, i.e. aviation sectors other than the major airlines, cannot achieve its growth potential and add to the Australian economy is the lack of political support in this country for an industry that could create many jobs and careers, especially for rural Australia.

The government defines general aviation as: "General aviation commonly refers to that part of the aviation industry that engages in activity other than commercial air transport activity. This may include small charter operators, aeromedical operators, agricultural aviation businesses, aviation-based fire-fighting services, training and aerial work such as aerial photography and surveying. It also includes private, business, recreational and sports aviation activity."

These are all operational sectors that ignores the ICAO Classification of Activities that also lists: "Airport Services, Air Navigation Services, Civil Aviation Manufacturing, Aviation Training, Maintenance and Overhaul, Regulatory Functions (e.g. Design Activities) and Other Activities" that are common to both Commercial Air Transport and General Aviation.

2. The Role of CASA is not really defined in Legislation

One of the major points that the Aviation Safety Regulatory Review identified was the Civil Aviation Safety Authority was functioning very different from its 10 counterparts that have a place on the ICAO Council. Member States listed in the Council’s Part 1 – States of chief importance in air transport are: Australia, Brazil, Canada, China, France, Germany, Italy, Japan, Russian Federation, United Kingdom and the United States.

The commonality of the other members enabling Act, regulations, i.e. standards, that are aligned with the ICAO promulgated international standards and the international standards promulgated by the Federal Aviation Administration of the USA is very high, except for Australia.

After 30 years, Australian requirements have not been harmonised with these world leading aviation countries.

MTF...P2

[Peetwo]

KC & AMROBA 1st newsletter 2017 -

Volume 14 Issue 1 (January 2017)

1. 2017 is the Time to Make GA Great Again.

CASA may have an acting Chief Executive Officer/Director of Aviation Safety but that does not appear, at this moment, to be stopping the orderly regulatory and procedural changes required. Early indications is Acting CEO Shane Carmody is taking charge and making decisions so things can happen. Reducing the number of committees (talkfests) should be a priority. We need "Action Teams" directed to achieve an outcome, determined by CASA/Industry & not by individual team members. International harmonisation by adoption of the least costly performance based system is a priority.

The reduction in red tape is more likely to occur in harmonising with the FAR system than the bureaucratic EASR system. E.g. the FAR system provides for multiple authorisations under one certificate – refer FAR Part 121 air carrier certificate.

---

2. Aviation Safety Is Based On "Trust".

Australian general aviation, including aerialwork operators, engineering: design, maintenance and manufacturing, is being constrained by over-regulation that delivers low participation, low utilisation of non-airline aircraft and over burdening requirements that are written in a style that works against safety.

If industry is regulatory treated as felonious, as ‘strict liability’ requirements infers, then ‘trust’ cannot be attained between CASA and industry participants.

Safety requires trust – without trust, safety is not fully achieved

---

3. Transition CASR Part 66 To EASR Part 66 To Meet GA Needs.

Without doubt, CASR Part 66 did not adopt EASR Part 66 to the detriment of the GA industry. The uncertainty that this experiment has done to the GA industry demonstrated that drafters did not understand the role of the LAME. Correcting CASR Part 66 by further harmonising with EASR Part 66 and adopting FAR Part 43 to clarify responsibilities will be part of the fix required.

Because CASR Part 66 intermixed into the trade training system, Australia basic skill training has suffered.

---

4. Avionic & Mechanical Group Ratings Required This Year.

The reason for "group" ratings is based on gaining experience in GA. It is not about the basic practical training that should be the same for all AMEs, and it is not about the knowledge that the AME has that can be tested by CASA "avionic or mechanical" examination. Whether CASA or a contracted organisation provides the examinations, is an administrative responsibility of CASA.

Experience has been ignored under CASR Part 66 but well explained under EASR Part 66.

MTF...P2

[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.)

---

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.

---

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'...

[Peetwo]

*NEWSBREAK* - Good news story for Oz aerospace/aviation industry - 

Yesterday our Ambassador to the US tweeted:

Joe Hockey‏@JoeHockey

AUS-US trade set to soar to greater heights w signing of agmt on streamlined approval processes for #aviation products in DC today @FAANews

 

Here is a background reference post from the Mount NCN thread:

JSCT recommends BASA treaty amendments be ratified -

Yesterday the Joint Standing Treaties Committee tabled Report 166 which reviewed...

..Amendment 1 to Revision 1 of the Implementation Procedures for Airworthiness covering Design Approval, Production Activities, Export Airworthiness Approval, Post Design Approval Activities, and Technical Assistance between Authorities under the Agreement on the Promotion of Aviation Safety and Addendum to the Implementation Procedures for Airworthiness between the Government of Australia and the Government of the United States of America...

The following committee conclusion & recommendation was made:

Conclusion
2.47 The Committee supports the ratification of the treaty actions.

Recommendation 1

2.48 The Committee supports the following two treaty actions and recommends that binding treaty action be taken:
§ Amendment 1 of Revision 1 of the Implementation Procedures for Airworthiness between the Government of Australia and the Government of the United States of America; and
§ the Addendum to the Implementation Procedures for Airworthiness between the Government of Australia and the Government of the United States of America.

 However this committee review & report also contained some fairly damning observations of CASA's inadequacies, inefficiencies, lack of expertise in being able to effectively administer and oversight industry. There was also a subtle inference that, despite the ASRR recommendations, there was still a long way to go before CASA is once again trusted and respected by industry...

Problem: --------3. (C/NF) While the team recognized improvements on previous shortcomings and commended many areas, there remain a few shortcomings, principally a shortage of properly-trained inspectors and excessive delegation of regulatory functions to carriers.

---

Examples from 2008 ICAO USOAP report: ..CASA’s Human Resources Management Branch has recently established a training policy that makes a commitment to provide initial, on-the-job, recurrent and specialized training to its staff in the area of airworthiness. However, no training programmes have been developed detailing the type of training to be provided to technical staff in each position, including periodic training plans. In general, the training provided to technical staff is insufficient to address the competency requirements for all the technical tasks...

---

...CASA’s Human Resources Management Branch has been developing a Competency Based Training (CBT) programme for all CASA staff and some courses that underpin this programme have been delivered. However, the existing technical training matrix does not address all the specific training needs of the Airworthiness Engineering Branch (AEB) and its technical staff. In addition, final review and approval of the CBT programme is still pending. Managers of the AEB identify and provide training to their technical staff, including the staff of the field offices, on a yearly basis. However, some specific training has not been provided (i.e. training on human factors) and while on-the-job training is provided, it has not been documented...

It also clear from the committee's OBS that the CASA of today has stubbornly refused to address the concerns of the 2008 ICAO/FAA USOAP audit team:

Resourcing and demand

2.38 During the public hearing on 2 May, CASA noted that the industry, being aware of the impending changes, had been making increasing numbers of applications for STCs. At the time of the public hearing, CASA stated that it had about 40 applications pending.40

2.39 Concern has been expressed that CASA is not adequately resourced to handle its current workload with regard to applications for STCs:

… it often takes CASA a long time to approve complex STCs and similar modifications. The fundamental reason is that in a small aviation manufacturing country like Australia, CASA cannot hope to attract and retain the calibre and quantity of people required to fulfil the task required. Nor can it afford to do so. These limitations apply equally across the spectrum of CASA’s activities. The problem is exacerbated by the lack of trust between CASA and industry as noted in the ASRR (Aviation Safety Regulation Review), which denies CASA assistance from industry to acquire at least some of the required knowledge.41

2.40 The Committee discussed with CASA witnesses whether the agency has the resources it needs to assess the pending applications in a timely manner. Asked for the specific number of STC applications outstanding for various periods, CASA supplied the following details:

• as at 30 April 2016: 18 STC applications outstanding;
  
• as at 30 June 2016: 21 STC applications outstanding; and
  
• as at 15 September 2016: 23 STC applications outstanding.42
  
  

2.41 The CASA witnesses argued that the time taken to assess each STC application varied based on the complexity of the application:43

All STC applications are usually assessed and accepted with a response provided to the applicant within 2 to 3 business days. It should be noted that this process relates to the administrative assessment of the application form and initial supporting documentation. Once the STC application is accepted the STC process begins and the time spent on each application will depend on the complexity of the modification, required involvement of CASA officers and the quality of documentation provided by the applicant.44

2.42 In general terms, CASA indicated that at present it has sufficient resources to deal with the additional applications for STCs, but that if the number of applications increased in future, CASA may experience some resource pressure.45

2.43 Under Part 21-J01 v1.0 of the Regulations, CASA has the ability to approve organisations and people to carry out certification work on its behalf.46 According to CASA:

…the model of part 21 – to the maximum extent possible have experts and industry undertake those types of design and approval processes. In terms of our obligations as a regulator, there are some things that we will obviously need to continue to be involved in.47

2.44 In terms of the degree of work done on certification by approved organisations, CASA indicated the about 100 per cent of certifications for minor modifications and minor repairs is done by approved organisations. For more complex work, the certification work would be delegated on a case by case basis to either approved organisations or to CASA itself.48However, there is concern that CASA has not been adequately utilising this avenue for approvals and has been reducing the use of delegations, contributing to the time taken to obtain approvals.49Asked to quantify the number of approved design organisations, CASA said that two organisations have been approved, one is finalising its assessment, one is in the middle of its assessment and three are at the beginning of the process.50

2.45 CASA also advised that as a result of a review of Part 21–J01 of the Regulations, CASA was working with industry advisers to find a workable alternative for general aviation design approvals.51

2.46 The Committee notes that, given the degree of interest from Australian design bureau and manufacturers in obtaining relevant STCs, it will be important for CASA to ensure the STC process proceeds as smoothly and quickly as possible.

   

The real positive implications for industry and economic benefits for the nation, of the signing  of the amendment to the US BASA agreement are best summarised by AMROBA in their latest newsletter... :

1. US Bilateral Aviation Safety Agreement Update.

Recognition: Many thanks should be given to Mr Myles Tomkins, CEO of Airwork Helicopters, Caboolture, Qld who’s STC was used as the trial STC during negotiations with the FAA. Some product certification processes not done by CASA had to be processed by the FAA to obtain FAA approval.

By the time this is published, the latest amendment to the USA BASA’s Implementation Procedures (IP) will have been signed and Australian holders of CASA issued STCs will have obtained a process to obtain a FAA issued STC based on the process included in the latest amendment to the IP. This is a major boost for CASA approved organisations that have excellent entrepreneurial and innovation skills to design new products and product improvements. There is now an agreed process where an Australian STC holder can request CASA to submit their CASA STC to the FAA for acceptance and issue of a FAA STC. Up till now, having a CASA issued STC did not open foreign aviation markets but obtaining a FAA STC changes the marketing capabilities for Australian STC holders.

This is probably the biggest change since the BAA was renegotiated as a BASA and CASR Part 21 was aligned with FAR Part 21. This change opens foreign markets to Australian designed and manufactured products...

AMROBA, other industry advocate groups and many stakeholders should be applauded for their tenacious efforts in pushing for this reform to the US BASA agreement. There should also be a show of gratitude for Senator Fawcett, in support of the Joint Standing Committee for Treaties, for his efforts in bringing attention and understanding to the many historical issues/problems and roadblocks previously involved in the complex treaty process.

Now although this a major coup for Aussie aerospace manufacturing and airworthiness/maintenance (MRO) organisations; KC & AMROBA did not pass up the opportunity to provide a much bigger industry message to government... :

Government should immediately take action to give “powers” to CASA to “harmonise” CASA’s certification processes, e.g. noise certification, and CASA to update their processes to comply with the FAA process.

Nevertheless, during the process of implementing this “recognition” process, it was obvious that CASA had strayed from “harmonisation” with the FAR system. CASA, administratively adopted changes and resurrected original processes implemented during the adoption of FAR Part 21 as CASR Part 21.

AMROBA would hope that common sense prevails and CASA accepts the FAA processes completely and streamline their certification processes to remove any differences with the FAA so the FAA gains full confidence in CASA’s ability to certify aircraft and products in the same manner as the FAA.

Many members holding other NAA organisation approvals encourage CASA to seriously look at harmonisation with the FAR system for engineering: design, manufacturing and maintenance, as the FAR performance based requirements are ‘business’ related and the most recently updated.

This amendment is a step in the right direction, now CASA has to resurrect talks with FAA regarding maintenance harmonisation. CASR Part 145 is in need of PIR as much as CASR Part 66 & 147. A new Part 43, based on FAR Part 43 is the answer.

The Byron concept to align with EASRs has been a failure – there is no sign of industry expansion or international recognition with a change that was not supported by the majority of the MRO industry.

The FAA took over a decade to finalise their FAR Part 145 and it is now the most modern Part 145 in the world that should be the model that CASA must use, if we are to survive, and grow, in the next 40 plus years.

The BASA/IP with the USA, has great potential for engineering (design, manufacturing & maintenance) if CASA dedicates to “harmonise “the CAR/CASR system” with the applicable FAR system that provides for the continuing airworthiness of FAR certified aircraft & products. The intent is Australia will apply the same standards to FAA products.

      - Listen up miniscule Chester & PM Malcolm...


MTF...P2  

[Peetwo]

Update to previous good news post (above) -

Quote from AMROBA newsletter:

"...Many thanks should be given to Mr Myles Tomkins, CEO of Airwork Helicopters, Caboolture, Qld who’s STC was used as the trial STC during negotiations with the FAA. Some product certification processes not done by CASA had to be processed by the FAA to obtain FAA approval..."    

The knock on effect as reported in Oz Aviation :

Airwork Helicopters obtains FAA supplemental type certificate for composite tail rotor blades
March 24, 2017 by australianaviation.com.au Airwork Helicopters chief executive Myles Tomkins and the CASA approved advanced composite Bell 206 tail rotor blades. (Airwork Helicopters)

Composite tail rotor blades made by Caboolture’s Airwork Helicopters has received a Supplemental Type Certificate (STC) from the US Federal Aviation Administration (FAA).
Airwork is the first company to have received an FAA STC.

The Kevlar and carbon fibre rotor blades for the Bell 206 series of helicopters received the FAA’s approval on March 22 2017.

Airwork founder and chief executive Myles Tomkins has said previously the composite tail rotor blades were quieter, had twice the life of the standard Bell 206 tail rotor blades and had a 30 per cent cost advantage.

They also offered a higher margin of safety due to their increased strength and higher thrust for an equivalent power setting.

In May 2015, Airwork obtained a Supplemental Type Certificate (STC) and Australian Parts Manufacturing Approval (APMA) from the Civil Aviation Safety Authority (CASA) to manufacture the composite tail rotor blades, following four years of development.

MTF...P2  


Ps I note that our miniscule for NFI is now trying to jump on the coattails of a very good news story for industry:

Australia gains easier access to US aviation market
Media Release
DC068/2017
24 March 2017


Australia’s aviation industry now has easier and cheaper access to the lucrative United States aviation market.

This follows the signing of amendments to the bilateral aviation agreement between Australia and the United States.

Federal Minister for Infrastructure and Transport Darren Chester said the amendments would be a significant benefit to Australian aviation parts and products designers and manufacturers.

Mr Chester said the changes would also benefit Australian companies and individuals who export aircraft and aircraft products to the United States.

“There are more than 40 Australian aviation design organisations and more than 80 aviation production organisations that will have lower costs and less red tape when exporting to the US market,” Mr Chester said.

“A range of Australian design and manufacturing approvals will now be accepted in the US without the need for additional and sometimes costly work.

“People and organisations wanting to sell their aircraft into the US should have fewer regulatory hurdles to contend with.

“These amendments save money and streamline regulatory requirements without in any way compromising safety standards.

“I know that many large and small aviation organisations have been eagerly awaiting these changes so they can make greater inroads into the huge US aviation market.”

The amendments have been made to the Implementation Procedures on Airworthiness made under the Bilateral Aviation Safety Agreement between Australian and the United States.

 
Bet he didn't have a clue about this historical good news development before yesterday, yet here he is trying to take some credit - despicable really:

Pps Passing strange 6D mentions this in regards to the dreaded "A" word (aviation), yet he is still not trying to garner favour for his recently released legislative instrument SOE to the CASA Board - see 6D's attempt at humouring the IOS.

[Peetwo]

Update to previous good news post (above) -

Quote from AMROBA newsletter:

"...Many thanks should be given to Mr Myles Tomkins, CEO of Airwork Helicopters, Caboolture, Qld who’s STC was used as the trial STC during negotiations with the FAA. Some product certification processes not done by CASA had to be processed by the FAA to obtain FAA approval..."    

The knock on effect as reported in Oz Aviation :

Airwork Helicopters obtains FAA supplemental type certificate for composite tail rotor blades
March 24, 2017 by australianaviation.com.au Airwork Helicopters chief executive Myles Tomkins and the CASA approved advanced composite Bell 206 tail rotor blades. (Airwork Helicopters)

Pps Passing strange 6D mentions this in regards to the dreaded "A" word (aviation), yet he is still not trying to garner favour for his recently released legislative instrument SOE to the CASA Board - see 6D's attempt at humouring the IOS.

Update to the update -

Via the Oz today:

Blade runner leads way to US

Developing a better tail rotor blade for the Bell 206 helicopter has been Myles Tomkins’s passion for seven years.

Developing a better tail rotor blade for the Bell 206 helicopter has been Myles Tomkins’s ­passion for the past seven years, and last week he achieved his dream by becoming the first ­Australian supplier to crack the US helicopter parts market.

Mr Tomkins, who began his aviation career as a helicopter muster pilot 40 years ago, has ­developed a composite rotor blade for the Bell 206 that has now won approval to be sold as an aftermarket part in the US.

It’s a big win for Mr Tomkins, and Australia’s aviation parts ­industry more broadly, and it came with no less than a bilateral agreement between the Australian and US governments to allow access to the US market.

As Transport Minister Darren Chester said, the signing of amendments to the bilateral ­aviation agreement between Australia and the US last week would make access to the US aviation market easier and cheaper.

“There are more than 40 ­Australian aviation design organisations and more than 80 ­aviation production organisations that will have lower costs and less red tape when exporting to the US market,” Mr Chester said. “A range of Australian design and manufacturing approvals will now be accepted in the US without the need for additional and sometimes costly work.

“People and organisations wanting to sell their aircraft into the US should have fewer regulatory hurdles to contend with. These amendments save money and streamline regulatory requirements without in any way compromising safety standards.’’

The amendments have been made to the Implementation ­Procedures on Airworthiness made under the Bilateral Aviation Safety Agreement between Australian and the US.

And the first cab off the rank is Tomkins’s Airwork Helicopters, which employs 16 people in the town of Caboolture. Coinciding with the amendments, he secured a Supplemental Type Certificate, which allows his composite blades to be sold in the US.

Mr Tomkins has spent more than $1 million developing the blades and securing the STC, and had to obtain permission from CASA to make the blades. He says the STC allowed helicopters to “bolt on new parts, like going to Supercheap Auto”.

And one of the parts that can bolt on is his composite blades. He says the US market is vast, with about 7000 Bell 206s in the air. And his blades are 25 per cent cheaper.
The win has prompted him to look at other products to sell into the US. “Now that we have proved we can do it, we are starting to look at other carbon fibre products.’’

The kevlar and carbon fibre blades also offer twice the life over the standard tail rotor blades. The blades also offer a higher margin of safety because of their increased strength and higher thrust for an equivalent power setting, as well as a very substantial noise reduction.

This could allow helicopter operators that fly in and around noise-sensitive environments such as national parks and built-up areas.

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[Kharon]

Baby's first steps.

Oz - “It’s a big win for Mr Tomkins, and Australia’s aviation parts ¬industry more broadly, and it came with no less than a bilateral agreement between the Australian and US governments to allow access to the US market.”

What I know about the complexities of international, bilateral trade agreements could be put on the back of a postage stamp, with room for the address. So however and by whoever it was done deserve thanks and a well done. Bravo.

“There are more than 40 ¬Australian aviation design organisations and more than 80 ¬aviation production organisations that will have lower costs and less red tape when exporting to the US market,” Mr Chester said.

Better and better, the whole thing a gift for Australian aviation development. Been a long time coming and a ‘no doubt’ win for pragmatism, common sense and those who have worked tirelessly to make it happen. Bravo. The competition will be fierce and some may not succeed but at least there is now a chance to compete in a bigger market, win loose or draw.

I realise it took a lot of time, trouble, energy and money to arrive at the point where, with a stroke of a pen, a whole new world of opportunity was opened up; but the benefit to the nation and an industry provided by the simple signing of a name to the agreement must be realised. Imagine if the whole aviation industry was granted regulatory changes of the same calibre and the difference that would make. Progress and reform in one small but happy area brought about by a stroke of the ministerial pen. “Please Sir, may we have some more”. You do see the difference for the better, don’t you?

Toot toot.

[Peetwo]

AMROBA latest newsletter - Volume 14 - Issue 4

1. GA Future Depends on More Pilots.

The government’s 457 Visa decision places more pressure to adopt the FAA cost-effective pilot training system.

Grow more pilots. The most significant thing we can do is to increase the number of active pilots. More pilots means more customers, which means more airplanes and more avionics and more gas and more parts. It also means lowered cost through economies of scale. Bigger markets equal smaller prices. A big lowly populated country needs flexibility in pilot training.

Embrace the innovators. GA is a conservative industry, entrenched in old, out-of-date practices and burdened by overwhelming regulation. We still see an industry that think the best way to train a new pilot is in an airplane twice the age of their average student. In a culture where toddlers are often using iPads and video games that have more computing power than the flight management systems on many aircraft, it is going to be very hard to entice potential pilots with 1940’s technology.

2. Why do Aviation Regulations Reverse the Onus of Proof?

When I started in aviation the burden of proof, when “safety” was jeopardised, rested with the regulator to prove by identifying an unsafe practice then finding the non-compliance or breach of the Act, Regulations or Order requirement. Justifying that “safety” had been jeopardised in the “opinion of the Inspector” was only upheld in AAT if the Inspector had the expertise to convince the courts – not always easy. What we now need is a Minister to direct that there should be no reverse onus of proof in the Act and Regulations (something that was once "normal legislative form") or that "strict liability" shall not be used where any measure of pilot/LAME decision making is involved, because it violates the definition of "strict liability" in the Criminal Code.

3. CASR Part 66 underpinning standards must be high priority.

CASR Part 66 should be identifying licences that meet Annex 1 (international standards) and the licence, however called, that do not meet Annex 1. One of the most important issues confronting maintenance is coming to terms whether we have a ‘recognised’ trade within the NVET system or whether we have a mixed trade/profession because of the application of the EASA knowledge based AME licencing system. There are three parts to the skilling of our workforce that are combined so that all parts suffer.

Practical trade skills underpin the ability of the workforce but these skills vary whether you work in an airline system that does not need some skills or an aircraft/component overhaul sector that needs all the practical skills to do repairs, modifications, etc.

International AME knowledge requirements for the avionic and mechanical maintenance should be separated from the current practical competency based training and treated more as ‘profession’ training that can be tested by examination. Basically what CASA Basic Examinations did in the past!

Licensing knowledge is a step above the AME practical/knowledge as identified by the ICAO AME training Manual. One of the real issues confronting the maintenance training is the underpinning skills/knowledge that a person needs when entering the aviation industry.

KC on 457 issues...

Reference post off the Alphabets thread:

RAAA on disbandment of 457 visas -

By RAAA CEO Mike Higgins, via the Oz: 

Unintended consequences of 457 visa changes could ground airlines

REX have invested heavily in a pilot training school. Picture: Grahame Hutchison.

• Mike Higgins
  
• The Australian
  
• 12:00AM April 28, 2017
  

Update: REX on 457 visa disbandment.

Via the ABC online...

457 visas: Airlines warn loss of foreign pilots could 'tear apart' fabric of regional communities

By Gavin Coote
Posted Fri at 5:48pmFri 28 Apr 2017, 5:48pm


Photo: Regional Express is warning the scrapping of the 457 visa may force it to axe some services. (Graham Tidy: Reuters)

Regional aviation operators are warning that a decision to axe the 457 temporary working visa could spell the end for some air services in regional Australia.

The Federal Government is introducing a new temporary skilled visa program, reducing the number of eligible occupations.

Under the changes, pilots would no longer be eligible.

Regional Express (REX) said it relied heavily on the 457 visa to attract experienced captains due to a drainage of Australian pilots going to work at bigger carriers domestically and abroad.

Chief operating officer Neville Howell said it could have dire consequences for regional Australia.

"On the thinner routes, some of the marginal routes that we're operating, it could very well mean that we have to cease those operations or indeed reduce the frequency," Mr Howell said.

"That has all sorts of implications to the people in those remote communities."
Mr Howell would not say which routes could be potentially scrapped.

"I don't want to start hypothesising and jumping to conclusions in terms of which routes in particular, but suffice to say on some of the runs where we're not getting a great deal of passengers we would have to look at that first of all," he said.

"The other runs like, for example Orange and Griffith and so forth, those numbers are fine. But it is the thinner routes where our passenger uptake is not particularly good."

Call for immediate moratorium

Mr Howell said the Government needed to place an immediate moratorium on the changes until a well-considered replacement list of occupations was drawn up.
"If indeed changes need to be made, okay. But to just completely cut the legs off without consultation it doesn't make a great deal of sense," he said.

"It will undoubtedly tear apart the socio-economic fabric of many of the smaller regional cities that are heavily reliant on our services for medical, educational and business links.

"It's mindless policy-making. There is a shortage of that skilled labour."

In March, REX grounded six of its aircraft after a plane travelling from Albury to Sydney lost one of its propellers mid-air.

Why the 457 visa is going


After two decades and tens of thousands of visas, the 457 visa category has been abolished. But what was it and why does this matter?

The Regional Aviation Association of Australia echoed REX's concerns, saying Northern Territory operator Chartair had already grounded three of its largest aircraft because of a shortage of captains.

But its CEO, Mike Higgins, stopped short of backing calls for a moratorium.

"What we're saying is that we're happy to work with the Government to do a review," Mr Higgins said.

"We feel that while there are some professions that are exempt, for example real estate agents, hairdressers and so forth, it's breathtaking that captains and aircraft engineers who are in dire shortage have been excluded.

"It's going to cause a great harm. We're very hopeful that we can sit down and have a sensible discussion about the way forward, particularly with experienced captains."

& from KC, via AMROBA... :

1. GA Future Depends on More Pilots.

The government’s 457 Visa decision places more pressure to adopt the FAA cost-effective pilot training system. Pilot training just cannot provide the number of pilots commercially needed. There has always been poaching by larger operators but today, Australia does not have the capability to provide or attract enough pilots. Without the 457, industry will suffer.

CASA managed regulatory reform has failed to produce jobs in aviation, especially by removing the flexibility of learning to fly.

Grow more pilots. The most significant thing we can do is to increase the number of active pilots. More pilots means more customers, which means more airplanes and more avionics and more gas and more parts. It also means lowered cost through economies of scale. Bigger markets equal smaller prices. A big lowly populated country needs flexibility in pilot training.

Ans. Adopt FAR Part 61 independent flight instructor system.

Embrace the innovators. GA is a conservative industry, entrenched in old, out-of-date practices and burdened by overwhelming regulation. We still see an industry that think the best way to train a new pilot is in an airplane twice the age of their average student. In a culture where toddlers are often using iPads and video games that have more computing power than the flight management systems on many aircraft, it is going to be very hard to entice potential pilots with 1940’s technology.

Ans. Computerised distant learning to meet international knowledge training standards.

Be willing to change. The current pilot population and industry infrastructure must be willing to adapt to the times. This means changing attitudes and behaviours, especially government public servants. We must embrace our communities, support our airports, open our hangar doors and fence gates. We must share expenses, share ownership, share responsibility, and continue to create a culture of safety first.

Add to these points the following:

Provide training for the future. Australia has one of the best climates and huge open airspace that should be accommodating major aviation international training industry for pilots, engineering, and maintenance for the Indo/Asia/Pacific region. Update training to meet the needs means adopting cost effective international training standards. Australian pilot, engineering and maintenance global training providers should be registered with ICAO.

Streamline training. With the current use of IPads from a young age, new students should be able to download the full ‘knowledge’ elements of maintenance training when the person starts training. This system should also enable on-line examinations. Only the practical elements need direct student/trainer involvement.

International equivalent licence and certificates. Pilot and AME licences should be based on meeting these international training standards and their licences should state they meet the Convention Annex 1 standards. This is the first step to once again having Australian LAME’s being accepted internationally. Academic qualifications that meet the Annex minimum standards. This also complies with Article 37 of the Convention.

Domestic only licences and certificates. The Convention places an obligation on Australia to adopt international training standards for personnel (Article 37) BUT the Convention also provides provisions (Articles 39 & 40) for ‘licences’ for personnel that do not meet the international standards AS LONG AS the ‘licence is endorsed as not meeting the international standards. This is the international standard that is used for the maintenance authority system that should be classified as a limited licence.

These Articles are what CASA and its predecessors also used to issue limited, experimental etc. certificates to aircraft.

These provisions means CASA can promulgate applicable personnel standards to maintain aircraft that do not meet an international type certification standard, like recreational and ex-military aircraft, to operate within Australian airspace. The Convention also enables such aircraft to fly to another country if that country gives permission.

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[Peetwo]

AMROBA latest newsletter -   : Volume 14 Issue 5 May — 2017


Via the AMROBA website:

1. Aircraft “Inspection” – By Who and to What Standards?

Is it time that the aviation regulatory system identified “aircraft inspection” separately from other maintenance actions as it is done in the FARs? CASA’s ageing aircraft concerns raised this as a major issue and various condition reports that AMROBA is aware of, and we know CASA also sees these reports, is clearly identifying a worsening trend instead of an improvement.

If we have a worsening trend then we have the wrong regulatory environment that is not ensuring airworthiness standards and practices are being applied at the coal face. Everyone has complained about skills & training since the introduction of CASR Part 66 but no corrective reaction yet from CASA. Does this mean that CASA believes the regulatory environment is not the “causal” problem?

The Civil Aviation Act (20AB (2)) clearly states that a person must be permitted by or under the regulations to do maintenance. Who is permitted to do aircraft inspections? What skills/qualifications should they have? We are aware of aircraft registered operators “authorising” persons that are not licenced and do not have AME trade qualifications to work on VH registered type certificated aircraft.

2. Cable Inspection AD Review

Many operators have changed their flight control cables so they won’t be happy with CASA if it cancels/amends the AD that should never have been published. AMROBA Newsletter Vol. 11, Issue 3, (March 2014) available on the website, raised the approved cable inspection maintenance standard that should be applied in GA. As FAA AC 43-13-1 states, cable tensions need to be relieved to perform inspections correctly.

This means every annual inspection maintenance records would require ‘independent’ inspections to rig and functional check flight control systems that had been inspected. As pointed out in the 2014 Newsletter, CASA’s “standard” specified in CAAP 43B-1 still has not been “harmonised” with international standards so why do CASA expect things to change?

Extending the life of cables past a manufacturer/regulator “recommended” replacement time, places the responsibility on the inspector LAME to determine, in the same manner as extending engines or any other component with a “recommended maintenance/overhaul” period, to be safe to proceed beyond the recommended period. Is it wise to make such decisions?

3. Aerospace and Aviation working together

Both the aerospace and aviation industry are working together identifying the skills needs for the future. There is a common concern that the skills need to improve to provide a workforce for the future. It is clear that too much has been placed on the past and not will be the future. Australia should be a powerhouse in the India/Asia/Pacific Region providing aerospace and aviation higher education and vocational training to all in this region.

However, both the aerospace and aviation industries are concerned that the education capability within this country is not taking advantage of the growth within the Indo/Asia/Pacific Region. Aircraft, and many components, require the same hand skills in maintenance and manufacturing but both sectors have identified the lack of skills that are an outcome of the national vocational education training system. Training must return to being based on the minimum international standards. It is interesting to note in the ICAO AME Training Manual that it states: “the standard of training recommended in this manual is intended to be sufficient for an individual to qualify for a licence”.

Typical informative, choccy frog quality, newsletter from true blue industry advocate KC -  

Also from the MRO/LAME/AME sector of the industry an excellent report from MROnetwork captured by thorny on Snippets thread:

   MIAT College Of Technology
Aircraft maintenance may face some regulatory challenges in 2017, especially from the EU.

MRO Regulatory Challenges Anticipated In 2017
Aircraft maintenance may face some regulatory challenges in 2017, especially from the EU.
Henry Canaday | Dec 23, 2016

 


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[Peetwo]

KC to CC: "There is a better way..!!??" 

KC latest free advice newsletter for Carmody: Volume 14 Issue 6 (June 2017)

AMROBA fully supports CASA’s consultation changes to bring to fruition regulatory reform.

1. All NAAs Provide/Control AME Licencing Examinations

We once had a comparable AME licencing system to what is provided by EASA, FAA, etc. The process should be simple. Most MRO workers complete an aviation trade training course, civil or military, or an allied trade, complete a workplace regulatory experience period, plus self-study, then sit and pass the NAA's applicable examinations. What industry wanted was the removal of duplication of RTO’s examinations and the CASA Basic Examinations. Like EASA, industry expected the NAA examinations to be provided/controlled by the RTO on behalf of CASA.

Basically, when the implementation of CASR Part 66 failed to adopt all provisions of EASR Part 66 and Part 147, CASA applied a completely different system in Australia.


2. Trans-Tasman Mutual Recognition Agreement.

Firstly, we need CASA to meet the intent of this agreement and keep impediments to mutual recognition to a minimum. The purpose of this agreement was to improve recognition of registered occupation (AME/LAME) between Australia & New Zealand. The fundamental purpose of mutual recognition is to promote economic integration and increased trade between participants by reducing regulatory impediments to the movement of goods and people in registered occupations across jurisdictions.

The simple fix to improve productivity and access in the Australasian market was to "harmonise" closely with the NZ maintenance and manufacturing personnel VET qualifications. This concept was abandoned by CASA during the 2000s when Byron focused CASA on the EASA regulations that provided harmonisation for Europeans, not Australasia.

"The TTMRA is built upon, and is a natural extension of, the MRA. It represents a deepening of the Australia-New Zealand Closer Economic Relations Trade Agreement (ANZCERTA). The impetus for the TTMRA came from government recognition that there were regulatory impediments to trade between New Zealand and Australia."

Access to the TTMRA Guide here.

3. General Aviation can safely grow by adopting FARs.

General aviation is a lot more than private owners. It is all operators, organisations and individuals outside the major airline system, including design, manufacturing and maintenance. Under the FAR system, all aircraft maintenance requirements are specified in FAR 91.409 and US manufactured aircraft maintenance manuals are compliant with these regulations. The system has worked extremely well for many decades.

FAR Part 91 is the core of the operational USA regulations and, if you believe the CASA Parts map, CASA sees it as the core to all the operation regulations in Australia. Instead of adopting the FAR Part 91, as supported by general aviation for the last two decades, minority sector representation have politically demanded that CASA provide sector regulatory provisions be produced prior to making the core regulation. This means that many provisions included in Part 91 are being duplicated in these separate Parts instead of adopting less confusing regulatory provisions from FAR Part 91.

The core regulations for GA is FAR Parts 91 and 43, including a ‘controlled" FBO system based on AC 150/5190-7 where FBO Specialised Service Organisations could be registered on a CASA database.

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[Peetwo]

KC & AMROBA dignifies ASAP snub -



Courtesy AMROBA :



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[Peetwo]

AMROBA July newsletter: Volume 14 Issue 7 (July 2017)[url=http://amroba.org.au/wp-content/uploads/2017/08/Volume-14-Issue-7.pdf][/url]

As usual the inestimable KC spells out in clear concise English the problems and the possible solutions for tackling the current regulator and regulatory impasse beleaguering the long suffering General Aviation industry:

1. General Aviation – Regulatory Operating in the Past.

Since the late 1980s, Australian GA has regressed, not progressed by modernising the regulatory system. Only the USA has general aviation sectors similar to ours. The FARs are a total GA system that the Pacific Region has adopted. Time is now crucial to stabilise, harmonise and reverse the current decline.

It makes no difference if you look at flight operations or the engineering fields of design, manufacturing and maintenance; general aviation is being regulated with outmoded philosophies when compared with the mature safe and proven USA system. Even the basic ICAO/FAA requirement to maintain aircraft as “airworthy” is not an Australian requirement. The most proven “performance-based” set of regulations that supports the safest and viable general aviation, is the FARs. Adoption must happen ASAP.

GA private operations, up to the FAR “Air Taxi” operations; GA manufacturing and even the adoption of a modified FAA FBO AMO system should also be implemented. Previous regulatory changes have not improved safety or created jobs; they have created an environment where jobs and participation are continually decreasing. It must be reversed so aviation can grow again.

If the GA aspects of the FARs were adopted, then representatives from other “operational” sectors would continue to lobby against FAR Part 91 as it would remove many regulatory imposts that have been implemented during the last decade or two by high profile lobbyists. It is time for government/CASA to start adopting the FARs for the benefit of general aviation that includes design, maintenance and manufacturing aspects. Adoption would also harmonise us in the Asia/Pacific Region.

Manufacturing: The Australian General Aviation Manufacturing Alliance (AGAMA) of businesses are being badly treated because the adoption of CASR Part 21 in 1998 imposed a fabrication inspection system that Australia had replaced with quality systems decades before. The FAA made major changes to Part 21 in 2009 to implement quality systems and CASR equivalent has not kept harmonised with the FAR.

GA Charter: Pre regulatory changes in the 1990s, the industry had a large number of small airlines (supplemental), GA small charter and individuals approved to provide pilot training that kept these sectors active and viable. When the FAR system was adopted, the FAA “Air Taxi” system was favoured by many. Irrespective, larger regional airlines will not support small GA Charter and/or Air Taxi but that should not prevent a cost effective safe system being implemented. The sad reality will be an over regulated system with airline type controls that will require high overheads that prevent small aircraft commercial operations.

Controlled FBO System: Pre regulatory economic reform/development, small AMOs existed without airline administrative requirements. In the US, the standards that are applied to FBO maintenance organisations are specified in an AC on condition the FBO employs FAA approved personnel who must comply with the applicable FAR Parts. Why not enable such operations in Australia as long as the FBO electronically registers on a CASA database and complies with CASA promulgated “standards” adopted from the FAA AC.

CASR Part 91 addresses the core of general aviation and CASA has failed to adopt FAR Part 91 as originally proposed to the aviation industry in the late 1990s. 20 years later and CASA has not finalised this most important regulatory operations Part that affects:

 private and professional pilots
 private and professional aircraft operators
 aircraft owners
 those who maintain, fuel and handle aircraft
 cabin crew
 loading personnel
 air display organisers
 air traffic services.

FAR Part 91 Applicability states:

(a) Except as provided in paragraphs (b), ©, (e), and (f) of this section and §§91.701 and 91.703, this part prescribes rules governing the operation of aircraft within the United States, including the waters within 3 nautical miles of the U.S. coast.
(b) Each person operating an aircraft in the airspace overlying the waters between 3 and 12 nautical miles from the coast of the United States must comply with §§91.1 through 91.21; §§91.101 through 91.143; §§91.151 through 91.159; §§91.167 through 91.193; §91.203; §91.205; §§91.209 through 91.217; §91.221, §91.225; §§91.303 through 91.319; §§91.323 through 91.327; §91.605; §91.609; §§91.703 through 91.715; and §91.903.
© This part applies to each person on board an aircraft being operated under this part, unless otherwise specified.
(d) This part also establishes requirements for operators to take actions to support the continued airworthiness of each airplane.
(e) This part does not apply to any aircraft or vehicle governed by part 103 of this chapter, or subparts B, C, or D of part 101 of this chapter.
(f) Except as provided in §§107.13, 107.27, 107.47, 107.57, and 107.59 of this chapter, this part does not apply to any aircraft governed by part 107 of this chapter.
Until the Government & CASA makes it policy to ADOPT FAR Part 91, GA will continue to suffer.

Of course, adoption would mean that many other Parts that have been made would need amending.

How KC manages to keep up such a gentlemanly, rational advocacy front in the face of extreme prejudice and disinterest from a self-serving minister and his minions, is quite remarkable really...


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