[Peetwo]

Part 43 back in the spotlight??

Via the Yaffa:

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CASR Part 43 not Straightforward: AMROBA
31 August 2021

Implementing simplified maintenance rules for the private and airwork categories won't be as easy as first thought according to the Aviation Maintenance Repair and Overhaul Business Association (AMROBA).

Then Deputy Prime Minister and Minister for Infrastructure and Transport Michael McCormack announced CASR Part 43 at Wagga Wagga in 2018, aimed at isolating aircraft in the private and airwork categories from the complex maintenance required for aircraft on passenger-carrying operations.

CASR Part 43 is designed to be an inspection-base system, with the primary anchor of safety being a periodic inspections to ensure the aircraft still complies with the original type certificate and any Airworthiness Directives (ADs). The rule-set is supposed to be based on the USA's Federal Aviation Regulation (FAR) Part 43, a move supported widely in the GA community.

Significantly, under Part 43, CASA would not require a maintenance organisation approval to do work on aircraft and components other than instruments and propellers. A new Inspection Authorisation (IA) would be introduced for individual engineers.

AMROBA Executive Director Ken Cannane supports the introduction of CASR Part 43, but points out it will require changes to other regulations to match how FAR Part 43 works.

"What has to be understood is that FAR Part 43 [rules] needs to be amended to fit into the whole CASR system as does CASR Part 66 need to be amended to accommodate the FAR Part 43 privileges of the licenced aircraft maintenance engineer(LAME) to fully comply with both ICAO Annex 1, Chapter 4 privileges," he told Australian Flying.

"This change is to revert to the previous privileges held by Australian LAMEs to certify an aircraft, or part of an aircraft, as airworthy after an authorised repair, modification or installation of an engine, accessory, instrument, and/or item of equipment.

"The current privilege is to certify maintenance and issue a release to service."

Cannane also says that changes would need to be made to Australia's Airports Act 1996 to enable FAR 43 clone legislation to function as designed.

"The other major issue is that the FAA system has both approved and unapproved specialised services that may include aircraft flight clubs, flight training, aircraft airframe and powerplant repair/maintenance, aircraft charter, air taxi, air ambulance, avionics, instrument or propeller services.

"However, the FAA requires the airport operator to have a licensing or permitting process in place that provides a level of regulation and compensation satisfactory to the airport. FAA AC/5190-7, Minimum Standards for Commercial Aeronautical Activities, has very specific safety standards that have to be implemented by business authorised by the airport operator."

Consultation on CASR Part 43 was open during the December 2018 – January 2019 period, which revealed an industry divided over the impact of simpler maintenance rules for private and airwork.

Several responses to the CASA Consultation Hub cited a loss of business income and a potential lowering of safety standards as obstacles to Part 43, whilst other submissions praise the initiative as delivering practicality and cost savings to a sector currently under significant burden.

CASA has completed the policy work on Part 43 and have sent it to the Office of Parliamentary Counsel (OPC) to draft the legislation, but as yet there is no timetable for that do be done.

Following OPC, the legislation will go back to a technical working group and public consultation to finalise it before implementation.

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MTF...P2 

[Peetwo]

AMROBA Newsletter - August 2021.

Via https://amroba.org.au/ :- Volume 18 Issue 8 (August 2021)



MTF...P2 

[Peetwo]

Breaking News: Future of Civil Aviation – 2021

Via AMROBA website: https://amroba.org.au/category/breaking-news/



Ref: https://amroba.org.au/wp-content/uploads...iation.pdf

MTF...P2 

PS - Via Skynews: 

PLEASE PM ScoMo..could we PLEASE extend the AUKUS alliance to include such matters as Civil Aviation...PRETTY PLEASE! 

[Peetwo]

Newsflash Addendum - 'You rushed me to a conclusion!' 

Via the AMROBA member email chain:

To all members.
 
We truly are in a mess with possible loss of further global recognition as CASA drops the ball in support the BASA with the USA.
 
With today’s government tripartite defence announcement it is important for government/CASA to regain the working relationship with the FAA.
 
Maybe the defence will change their European engineering alignment and shift back to a USA/British alignment.
 
Government must make moves to align the CASR Part 21 and get some CASA engineers FAA product certification trained so the BASA and Implementation Procedures, that gives Australian design and manufacturers access to the US civil aviation market, can benefit from access to this civil aviation market.
 
According to many in the industry that have tried this pathway, it is the lack of expertise in CASA that is holding our civil aviation manufactures back.
 
Regards...KC

Plus PDF link: https://auntypru.com/wp-content/uploads/...y-CASA.pdf

P2 Addendum: Referring to this from KC's 1st Newsflash - 

Part 2 already has Implementation Procedures between FAA & CASA that can be expanded.

To provide historical context, to the 2016 kicked goal by AMROBA, Senator Fawcett and the Reverend Forsyth, the following is from the JSCOT inquiry into Implementation Procedures for Airworthiness - USA 

1 Mr David Forsyth AM (PDF 319 KB) 

2 AMROBA (PDF 465 KB) 

3 Civil Aviation Safety Authority (PDF 243 KB) 

 
Hansard 2 May 2016: PDF Link 

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!

With the above Hansard Senator Fawcett so clearly exposes the CASA cohorts as being severely recalcitrant and inept in the matters before the Joint Standing Committee on Treaties ie

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

Now FFWD to KC's supplemental newsflash:

Issue: Why is CASA risking the loss of this important international agreement by not mirror imaging the FAR certification standards and processes so CASA issued STCs are accepted by the FAA?

Why is this government to government technical agreement being jeopardised by CASA not implementing FAR acceptable procedures, processes and standards to support Australian civil aviation product manufacturers access to the biggest aviation market in the world, the USA?

The process has gone backwards with the past couple of CEOs of CASA.

Fact: Australia has only one Bilateral Aviation Safety Agreement (BASA) that includes a process where CASA issued Australian Supplemental Type Certificates can be accepted by the USA regulator, the FAA. i.e. the BASA with the USA.

This international agreement and implementation procedures have been approved by Parliament but being ignored by CASA product certification personnel.

P2 comment: FFS! - Given the evidence provided, in the now 5 year passage of Hansard, it is obvious that there has been zero progress or inclination by CASA to adopt/adhere to any of the fundamental principles signed up to and placed into law by the Federal parliament with the amended treaty of 2016...

Finally consider the prophetic in summary evidence provided by the Rev David Forsyth...  
 

In my opinion, this Treaty Amendment has the potential to significantly improve opportunities for Australian aviation manufacture and design. As noted in the questioning at the Committee hearing, in particular by Senator Fawcett, and by the nature of the follow up questions to CASA, realising the potential benefits depends on CASA’s ability to provide approvals in a timely manner. CASA does not have a good track record in this area as evidenced by industry submissions to the ASRR, and more recently by submissions to the CASA Industry Stakeholder survey. To fully realise the potential benefits of the Amendment, CASA will need to significantly increase the use of industry delegations, improve its relationship with industry to increase trust and thus information exchange, and automatically approve STCs, modifications, licences, and other approvals from the FAA and EASA.

Hmm...now what exactly has changed??

(BJ you seriously need to fix this..  )    

MTF...P2 

[Peetwo]

AMROBA September Newsletter.

Sorry KC but I almost missed this...

Via AMROBA: Volume 18 Issue 9 (September 2021)

1. Can Australian Civil Aviation System Change?

3 years ago, AMROBA took on the challenge to get the fundamental legislation changed so our civil aviation system enables global recognition of government certificates (e.g. the Authorised Release Certificate) and manufacturing and maintenance products and services recognised in their own right globally, especially with North America for manufacturing and the Asia Pacific region for maintenance services (where we should be participating). Since the new Deputy Prime Minister was appointed we have seen a change in attitude by his office, his portfolio Department and CASA’s CEO. There are positive signs.

2. What if the FARs were adopted? – NZ or the PNG version based on NZ?

What if the US system was adopted for all but the international airlines? If full adoption, the non-airline sector and the non-turbine powered helicopter sector. What would be the future if the FAA FBO system was adopted in Australia. No AOC or AMO for general aviation, including aerialwork. How will CASA provide regulatory oversight that is covered by the FAA’s Airports Division, not Flight Standards. Will CASA promulgate the FAA standards for non-approved FBOs or will it stick with a more stringent approach or will they adopt the NZ/PNG system?

It would be a massive change that would need a massive education program.

3. FAR FBO Adoption Consequences.

Whenever a foreign country’s aviation regulatory system, or part of that system is adopted, it is an obligation on government to ensure it is amended to work within other Australian legislation, federal and State.

4. Would adopting the FARs remove Chicago Convention Annexes Differences.

This has been an on-going debate within CASA and its predecessors for a couple of decades to no avail. AMROBA does not believe this is a decision that should be made by CASA. This is a political decision the DPM must make to meet the aspirations of the aviation participants. AMROBA and all of GA have voted for FAR alignment while Airlines have opted for the EASA system. Charter operators and supporting AMOs have also shown support for the FAR based system. The ultimate political policy should be adoption of the Treaty (Convention) Standards and Recommended Practices as close as practical when adopting the FAR system.

5. Using on-line module eBook training adopted.

Members are taking up the offer for Emperious eBook discussed in the last months Newsletter. This simply means an AME can either self-study to pass the CASA modular or participate in an AQF IV trade course and use the eBook to assist in sitting CASA examination.

(A one coffee read well worth the time -  )

MTF...P2 

[Peetwo]

AMROBA Newsletter and KC call to act on the Acts -   

Via the AP email chains:

AUSTRALIA’S AVIATION SYSTEM

Works if Policy is Turned into Reality

Page 1 of 5

July 2021

The primary problem in Australia’s aviation Acts is they do not list the Annexes that government has administratively made the responsibility of a number of Departments and Agencies. The public and foreign countries look at the Acts of Parliament for this detail. Unless you know where to look on the Department’s website, it is generally not known. Each Department/Agency should have the Annexes they are responsible for inserted in their Acts.

To be part of the Global Aviation Market, adoption or exceedance of the Acts, with no lower difference should be government policy..

The move from Act, regulations and orders supported with guidance material has escalated into a more complex system than original direction of Act, Regulations & advisory material.

Besides remnants of the original system we are now implementing Act, CASRs, Manuals of Standards (tabled in Parliament) that refer to AMCs/GMs), Acceptable Means of Compliance, Guidance Material, Advisory Circulars, Instruments, etc. etc.

A totally confusing regulatory system – the FAR system is supported by industry and was the basis of new regulations but we now have a mixture of FAA & EASA system, totally confusing.

ICAO statement in many Annexes regarding primary legislation. E.g.

Primary aviation legislation Annex 19 Appendix

1 1.1 The State shall promulgate a comprehensive and effective aviation law, consistent with the size and complexity of the State’s aviation activity and with the requirements contained in the Convention on International Civil Aviation, [includes Annexes] that enables the State to regulate civil aviation and enforce regulations through the relevant authorities or agencies established for that purpose.

1.1.2 The aviation law shall provide personnel performing safety oversight functions access to the aircraft, operations, facilities, personnel and associated records, as applicable, of service providers



CAA/CASA developing regulations has seen constant failure ever since the CAA was established in 1988. Controversial regulations cause Inquiry after Inquiry.

Industry has been in constant change by revolving CASA CEOs that has costs millions to industry participation with ever changing directions of CASA CEOs.

The basic concept of being as uniform as possible with the Convention and Annexes seems to be a low priority with all CEOs since CEO Bruce Byron..

The US FARs, promulgated by Bills of Parliament in the US, were the model used by all past Departments and civil aviation Agencies up till CEO Bruce Byron. All GA industry have continually voted to support for alignment with the FAR system to meet Convention Annexes.

Though the responsibilities under the Convention were split between new and old Departments and Agencies, these Departments and Agencies have never been given the responsibilities that have been publicly displayed on the Department’s website for years.

Time for these Departments and Agencies to take responsibility – change the Acts, see below.

And from AMROBA's website the latest newsletter: https://amroba.org.au/wp-content/uploads...r-2021.pdf



MTF...P2 

[Peetwo]

KC & AMROBA - back to work in 2022. 

Via the AP email chains:

To all members

Hope all are well and looking forward to a return to normal as borders are down, hopefully stay down, except for WA.

An election year is a bad year for positive Act/Regulation changes but it is a year of expectations with the RRAT due to bring down its report prior to the election.

But I am a bit more positive than I was at the start of last year.

The future is now based on the Minister’s directions, the Department’s review of Acts  and CASA’s alignment with NZ/FAA system for GA.

The EASA airline system does not work in Australian GA, we need to re-align with the FAA.

We need to get trade training back into the maintenance sectors, trade standards that comply with the ICAO AME training manual.

If the Government & Opposition do not realise by now that the Acts & Regulations, and the silo divisions it has created in general aviation, is what is holding back aviation in Australia.

We need a government vision of growth and international participation by those employed by our members in aviation “Activities”.

There are two (2) aspects of aviation – one is OPERATIONS, the other is ACTIVITIES that include design, maintenance, manufacture and maintenance training.

Sadly, ever since they created CAA/CASA the focus has been on ‘operations’.

Unless the Minister changes the “Statement of Expectations” to the CASA Board, not much will change pre the election.

This is discussed in the Newsletter

The first positive is the Government’s review of the Airports Act.

2022 January Newsletter

Minister and Department may be getting on track, still not sure of CASA.

Regards

Next, via https://amroba.org.au/ :

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MTF...P2 

[Sandy Reith]

AMROBA has put the case for reform time and again, backed up with all the rational imperatives from its experience and extensive knowledge. Much do be attributed to the tireless Ken Cannane with his wealth of knowledge.

Unfortunately, having just read Minister Barnaby Joyce’s latest offering hot off the press, his wishy washy motherhood Statement of Expectations (SOE) to CASA and its Board, great disappointment is realised.

I believe there’s a huge sigh of relief in the salary factory of Aviation Hearse, and the whole of Can’tberra‘s Public Sector (no ‘Service’ exists these days) will be smiling and relaxed for the Bureaucratalia Day holiday. As the Government’s barely disguised electioneering and continuous prime time TV ads for Australia Day keep repeating, that for some “it’s raw.” How true for the likes of Glen Buckley and the whole of General Aviation.

[Peetwo]

KC (AMROBA) take on SoE - 

Via the AP email chains and https://amroba.org.au/ :

To all members,

AMROBA can proudly take some credit for the text that is included in DPM Barnaby Joyce’s latest Statement of Expectations and its Explanatory Statement.

Our lobbying has paid off but it is the start to getting back on track.

This is the best SOE/ES that I have witnessed from a DPM – it at last addresses the issues confronting the engineering and general aviation sectors.

Latest Breaking News – Minister’s SOE & ES

There will always be knockers of any SOE but the more you read this, the more it creates the pathway back.

The only impediment is CASA staff, can Pip Spence change the regulatory oversight philosophy they have.

Barnaby’s staff need to be congratulated as they have focused on the issues.

It was also done in consultation with CASA & the Department, so their support, at the Executive level, is apparent.

It even sets some pertinent timeframes that, as an ex-senior regulator, will impose pressure to complete.

Atkinson, Binskin, Spence consulted, so there is now no impediment in the way for returning to sensible practical safety regulations.

We now have a government agency responsible for oversight of airport developments – a massive responsibility that CASA did not have before.

International recognition and mutual bilateral agreements of Australian designed products – a return to an international office within CASA?

Read our latest Breaking News that has links directly to the Minister’s Statement of Expectations and Explanatory Statement.

Regards

Plus:

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MTF...P2 

[Peetwo]

AMROBA newsletter; Part 43 & Air Taxi regulation concern - 

Via AMROBA: Volume 19 Issue 2 (February 2022) 

And via the AP email chains:

To all members

With so much talk about regarding Air Taxi services by Drones and other new ideas it is a wonder why CASA won’t adopt the term “Air Taxi” like the FAA.

Association News 3-22 covers this subject and lists FAA, Canada & Australia (2004) figure of Air Taxi involvement

There is almost a fixation within CASA to not get with the future and accept globally accepted terms.

We know this won’t happen until Sect 98 of the Civil Aviation Act is amended to adopt the words from the Air Navigation Act that developed the regulations up to the creation of the CAA/CASA.

Civil Aviation Act Section 98 – Amend to include Air Navigation Act Section 26

“(b) for the purpose of carrying out and giving effect to the Chicago Convention, as amended by the Protocols referred to in subsection 3A(2), any Annex to the Convention relating to international standards and recommended practices (being an Annex adopted in accordance with the Convention) and the Air Transit Agreement”.

Only the government can fix

Regards

Finally courtesy of Oz Flying, via the Yaffa:

AMTC 4 Proposal to decrease Safety: AMROBA

11 March 2022

The Aviation Maintenance Repair and Overhaul Business Association (AMROBA) says that CASA's Part 43 proposal for an Aircraft Maintenance Technician Certificate will decrease aviation safety. 

The AMTC 4 concept applies only to maintenance on Light Sport Aircraft (LSA) as is based on the USA's Repairman Certificate model. It enables people without a Part 66 licence to do maintenance provided they have completed a 120-hour course of instruction.

CASR 43 will cover maintenance of general aviation aircraft operated in only the private and air work categories, which includes CASA-registered LSAs.

An AMTC 4 would be permited to:

• approve and return to service an aircraft that has been issued a special airworthiness certificate in the LSA category after performing or inspecting maintenance including the annual and the 100-hour inspection, do preventive maintenance and modifications not considered a major repair or modification on a product produced under a CASA approval
  
• perform the annual condition inspection on LSAs that have been issued an experimental certificate
  
• only perform maintenance, preventive maintenance, and a modification on an LSA that is in the same class for which the holder has completed the training.
  

AMROBA CEO Ken Cannane told Australian Flying today that the flaw in the AMTC 4 proposal is that the proper training for the qualification has not been put in place.

"We believe safety will decrease unless you get the skill training properly built into the Australian Vocational Education Training (VET) system, so people can get the proper training by the proper establishments," Cannane said.

"They're just going to adopt these positions and put in place what they see as the training standards, yet there is no-one to provide the training at this current moment.

"There's no confidence in the industry that they can get this right and get the education system on board with that training."
Cannane believes that CASA is repeating a mistake made when the EASA-based CASR Part 66 was introduced covering continuing airworthiness engineer licences.

"We're trying to make sure that all training is done under the VET system, but CASA, just as they did with Part 66, have not met with the education department and brought about the VET courses to cover this type of training."

AMROBA will not support CASA's Part 43 proposal as presented, although they have recommended the FAA Part 43 provided it is adopted directly from the FAA, including the training requirements and inspection authorities.

Cannane said that CASA was trying to create an administrative mess by adopting part of the EASA and part of the FAA standards, despite EASA setting down licencing authorisations in their Part 66 to cover the sort of maintenance envisaged by the AMTC 4 proposal.

"We're ending up with a complete mess in the system because we're adopting figuratively the legislation of Part 43, but not the administrative supports behind it to do the education. We've got Part 66, which has all the licences in there to cover  those types of aircraft, yet they won't adopt those parts.

"So we've got a situation with a half-adopted Part 66 and they're implementing a system out of the United States without all the education systems in place to support it.

"That, to us, only puts more people in the field that actually are lower skilled, and from our point of view it all seems to be about writing something of low cost for these types of aircraft.

"There seems to be no safety approach."

CASA is expected to release the draft proposals for CASR Part 43 in the first half of this year.

MTF...P2 

[Peetwo]

KC on a mission?? - 

Ref:

AMROBA newsletter; Part 43 & Air Taxi regulation concern - 

Via AMROBA: Volume 19 Issue 2 (February 2022) 

And via the AP email chains:

To all members

With so much talk about regarding Air Taxi services by Drones and other new ideas it is a wonder why CASA won’t adopt the term “Air Taxi” like the FAA.

Association News 3-22 covers this subject and lists FAA, Canada & Australia (2004) figure of Air Taxi involvement

There is almost a fixation within CASA to not get with the future and accept globally accepted terms.

We know this won’t happen until Sect 98 of the Civil Aviation Act is amended to adopt the words from the Air Navigation Act that developed the regulations up to the creation of the CAA/CASA.

Civil Aviation Act Section 98 – Amend to include Air Navigation Act Section 26

“(b) for the purpose of carrying out and giving effect to the Chicago Convention, as amended by the Protocols referred to in subsection 3A(2), any Annex to the Convention relating to international standards and recommended practices (being an Annex adopted in accordance with the Convention) and the Air Transit Agreement”.

Only the government can fix

Regards

Via the AP email chains yesterday...

To all members.

What does it take to get Government/Infrastructure/CASA to adopt requirements from another legal system without ‘CASAerising’ the regulations so they fail to adopt the other legal system and its benefits. CASA failed to exactly adopt EASR Parts 42/66/147/145 and now CASA is proposing to once again fail to adopt FAR Part 43 and associated FAR provisions. When will CASA stop bastardising adopted aviation regulations and harmonise? 

The Federal Government’s House Standing Committee on Legal and Constitutional Affairs, Chapter 2, Basis and mechanisms for the harmonisation of Legal Systems provides all the reasons and justifications that supports adoption of aviation regulations, not ‘CASAerising’ regulations of an adopted legal system for aviation.

How hard is it to adopt FAR Part 43 and associated FAR provisions following the Government’s own guidance above. When adopting, other CASR Parts have to be amended to include the FAR Part 43 associated FAR provisions. To make the foreign adopted regulation work as intended, CASA also has to adopt supporting documents promulgated by the regulator, like FAA ‘Orders’ and ‘ACs’ associated with FAR Part 43. The FAA is quite happy for CASA to top & tail their Orders and ACs.

Maybe we should simply have a regulation accepting all FAA Orders & ACs and require any referral to the Administrator/FAA to read refer to CASA.

Why does CASA change the terminology (e.g. Repairman) of the foreign regulations it states they are adopting so they create confusion to Australia and foreign countries with their unique CASA twists made to foreign adopted regulations that actually adds costs and lessens harmonisation with the aviation markets, including the biggest market, the USA? 

Many members have approvals from foreign Authorities and enjoy their interpretations of their regulations, not CASA’s unique interpretations.

The original adoption of FAR Part 21 demonstrated how simple it was to adopt another legal system regulations BUT they must stay harmonised, that is the biggest on-going challenge to CASA’s staff. When an adopted legal system regulations are adopted, they need to be remain harmonised by automatically adopting amendments of the foreign regulations.  Those major aviation countries mainly change their own regulations to clarify the intent and CASA should follow and adopt.

We know and have witnessed the changes made to FAR Part 21 and EASR Parts 42/66/147/145 by their regulators but sadly they have  not been made to CASR Parts 21/42/66/147/145.

Have our members lost the chance to have harmonised regulations with the FARs & EASRs under this CASA management?

If that is the case, the Board will never meet the government expectations to have Australian aviation designs and manufactured products accepted by other nations starting with the USA, Canada, UK, NZ and other Asia Pacific Region nations.

Regards

Plus: ref - https://auntypru.com/wp-content/uploads/...Skills.pdf

Aircraft Maintenance Personnel Skills
CASA Adds New Part 43 Personnel

It is now apparent that CASA is ushering in a maintenance personnel skill future that could provide a divided skill base to support the maintenance sectors of civil aviation.

There is no evidence of CASA harmonising globally with maintenance personnel skills and licencing – factors that will probably affect future global maintenance agreements.

We now have part Europe, part USA and unique Australian:
• CASR Part 66 licencing system – applicable to CASR & CAR (EASA). +
• Part 43 proposed aircraft maintenance technicians/inspection authorisation system.
• Self-Administration Organisation approved maintenance personnel.

Adding the FAA Repairman system to the Australian European based licencing system is supported but at no time was the EASA Part 66 “L” maintenance certificate system consulted as an alternative approach. This is the norm for CASA consultation, they make up their own mind and then consult (tell) on its implementation. This is a reversal of CASA AME licencing policy to move away from EASA back to the FAA system.

The FAA Repairman and EASA “L” maintenance certificate systems cover the same sectors of maintenance and both are linked back into their respective licencing regulations; EASR Part 66 and FAR Part 65. This is not clear in CASA’s proposal. Will the FAA Repairman regulations be added to the CASR Part 66?

AMROBA supports the adoption of the FAR Repairman system because the utilisation under the FAR system will match the Australian GA/Sports sectors but it must include adopting FAR Part 65 Repairman requirements into the CASR Part 66 AME licencing system. CASA has opted to intermix these systems and AMROBA does not see this intermix causing any confusion or restriction on implementation if it includes Part 65. provisions

MTF...P2 

[Peetwo]

AMROBA March Newsletter: Volume 19 Issue 3 March (2022)

2022 – INTERNATIONALISATION

Time has run out, government must change the process to internationalise Australia’s civil
aviation engineering disciplines of design, maintenance and manufacturing to open the Australian
civil aviation engineering fields to compete in the global aviation markets in their own right.

This will create jobs that the real potential of this engineering industry can add to the workforce.

When we once again have over 1500 directly supervised flight training facilities and over 1000
directly supervised maintenance organisations we will know that we have succeeded in
implementing (adopted) safety regulations and practices that also enable internationalisation.

We Trained Hard. . . . . .

but it seemed that every time we were beginning to form into teams we would be
reorganised. I was to learn later in life that we tend to meet any new situation by
reorganising; and a wonderful method it can be for creating the illusion of progress while
producing confusion, inefficiency and demoralisation.” - PETRONIUS: 65 A.D.

1. Face the Facts – CARs/CASRs have collapsed civil aviation in Australia.

CAA/CASA does not have any vision for a safe and viable civil aviation non-airline industry.
AMROBA does, see item 2.

Civil Aviation Regulations and now Civil Aviation Safety Regulations are strangling the industry.
Government Acts and Regulations developed since the decision to make CAA/CASA an
independent government agency has created government jobs & destroyed civil jobs. 

2. The Big Engineering Picture - Internationalisation

Government may not have an understanding of where the civil aviation engineering fields in
Australia want to be in the near future but AMROBA and its members do. Internationalisation of
our engineering products and services in their own rights. Internationalisation needs adoption of
the FAR non-airline regulatory system by Australia and reduce red tape by 50%. 

3. Aviation Safety – How Engineering Skills Keep it Safe

Civil aviation engineering is not dissimilar to other forms of transport and the safety culture that
has been imbedded over the last 100 odd years is not dependent on legislation and regulations that
mostly add red tape that does not value add to safety. 

4. Training – Bring Back Trade Training Career Pathways

Federal Education must be made responsible to provide trade training based on the ICAO AME
trade training system. CASA collapsed the AME trade training in Australia when it took over the
NVET trade training organisations and replaced with licencing knowledge training under Part 147.

Solution: Make the Federal Education Department responsible under the Annex to provide trade
training at non Part 147 trade training schools based on ICAO AME training standards. These ICAO
training standards were the basis of our trade training system well before Part 66/147.

MTF...P2 

[Wombat]

In a former life circa 1995 I worked for Government in the industry assistance area. I was privileged to work with about several Australian ultra high quality metal working companies on a variety of projects. The Australian dollar was around 70 cents or less.

Airbus, Boeing, Pratt and Whitney, GE and Lockheed could not get enough machined product made by these guys - engine parts like rings, housings, etc. airframe parts like ribs machined from solid in inconel, hastelloy, steel, aluminium, titanium, etc. Military and civil. Many of these guys were "around Melbourne".

Some of their work was mindbogglingly exquisite - like a CF6 bearing housing that started as a five kilo Inconel forging and ended up as a few hundred grams of tracery with about 50 thou walls accurate to tenths of the proverbial gnats. GE couldn't work out how they did it. Inconel is a bastard to machine, but a bright Australian found the secret. There were dozens and dozens of cases like this - from the manufacture of tiny helicoil inserts to double cut plunge grinding of turbine blade roots.

They couldn't keep up with demand and were making so much money some owners were buying new Ferraris each year, nothing vulgar like Mercedes.

The fly in the ointment was that none of these companies had any Australian aviation accreditation beyond ISO 9000 that was internationally recognised. That meant that all of them were constrained to be what were called "Third tier" suppliers because nothing they produced could be certified by themselves for aircraft use. All their product was certified by either their first or second tier customers - our Australian companies couldn't capture the true value of their product because there was no Australian equivalent certification and being approved by EASA of the FAA was too expensive and difficult to arrange remotely. Neither could they move up the value chain and bid for larger sub assemblies.

* The Inconel bearing housing machining was particularly difficult because the final wall sections were so thin that clamping the workpiece to avoid distortion  during machining was a huge problem. The Australian solution was simple, elegant and cheap. GE was driven mad trying to find out how it was done. They eventually forced disclosure of this trade secret by legal subterfuge.

P2 - Chocfrog to you Wombat...solid gold post, keep them coming mate - 

ps KC sends his regards...

[Peetwo]

KC on Part 21 realignment and future BASAs - 

Via emails:

To all members.

CASA has a major hurdle to learn how to adopt foreign regulations as was done when CASA adopted FAR Part 21.
CASR Part 21 is way out step with FAR Part 21 that no longer supports the BASA with the United States.

AMROBA has applied the same principles to making CASR Part 21 to Realign CASR Part 21 with FAR Part 21 – we don’t suggest that no additional work will be required to change the numbering system to meet Australian regulatory numbering standards and fine tune with a government personnel review. This is also a task for legislative drafters.

We have also suggested that CASA Engineering management be trained by the FAA in Part 21 certification procedure for products and articles.

AMROBA has added some unique Australian Part 21 requirements – e.g. Limited (ex-military) category aircraft, amateur-built under a ABAA, intermediate category, etc.

We also adjusted Subpart J to align with EASA CS 21, subpart J.

If you are in the design and manufacturing sectors you should review.

The FAA used a 12 months post making the Part for industry to update – this was mainly so quality systems could be implemented.
Many Australian companies already include a quality system and may need little adjustment.

• Out goes Class I, II & III items
  
• All manufacturers , PAH, PMA, ATSO meet one quality system standards
  
• More responsibilities on industry designers and manufacturers.
  
• No Fabrication system – included in manufacturing quality system.
  
• Linked FAR provisions that need adopting also added to rear of Part 21
  
• Noise Part needs adopting so CASA certifications can be accepted globally.
  
• Continuing airworthiness items in FAR Part 26 need to be included in CASR Part 90.
  
• Note – EASA also has a CS 26 with continuing airworthiness items – Part 90 must stay globally aligned.
  

What we do with this proposal if supported by members is give it to government and its department to see if we can get this regulatory change started so we can at least have a regulatory system for Australian manufacturer products and articles for sale globally.

The Department and Foreign Affairs, possibly Department of Trade will all be involved in obtaining BAAs with other countries hopefully, based on this realigned Part 21

Please feel free to pass it on to non-members

Regards

---

Ref: https://amroba.org.au/wp-content/uploads...ticles.pdf

MTF...P2 

[Peetwo]

KC on keeping the Iron Ring honest - 

Via the AP email chain: 

To all members,

Your Board is having a VC with CASA CEO tomorrow at 1400.

When you look at all the issues that we have it makes one wonder
if this CASA regime has the capacity to understand just how their
excessive regulations, red tape and lack of clarity has damaged
this industry. A once booming industry with more global
recognition than it has today is no longer an industry of choice
for the youth of Australia. It has massive shortages of skilled
LAMEs.

1. Before the CAA was created (1988), Australia was one of
most Chicago Convention compliant countries in the world with a
healthy general aviation sector. Australia doesn't even keep pace
with changes to the Annexes to the Convention that affect general
aviation, maintenance, design and manufacturing.

a. CASA is not globally focused as the Statement of
Expectations directs CASA to get recognition of CASA approved
manufacturers requires, etc.

2. In the late 80s many AMOs that were trying to expand into
foreign markets asked government to take action so CASA
certificates, including the Form 1, were recognised in their own
right by other nations. This is now in the Statement of
Expectations provided to the Board of CASA.

3. In the early 90s small businesses such as the directly
supervised flying schools and maintenance organisations were
written out of the regulations thus collapsing general aviation.
They exist in the FAA system and their general aviation is still
booming. Our previous system was based on the FAA system and ICAO
standards.

4. In the late 90s AMOs and unions asked CASA to accept NVET
qualifications, plus experience, to obtain a licence. This has not
been achieved.

a. Was the decision to partially adopt EASR Parts 66/147 the
right one. Without doubt, GA would have been better off with CAR
31 or the FAA A&P(IA)/repairman system.

b. The barriers to obtain a licence today are far more
restrictive in Australia than in the EU or US systems.

5. In the early 20s many manufacturers were looking at having
their designs and products (include a/c) accepted in their own
rights by other nations.

a. This is what was expected post the adoption of FAR Part 21
in 1998 as CASR Part 21.

b. No longer harmonised with FAR Part 21 and have less global
recognition of designs/manufactured products/maintenance
capabilities.

You can see that the system is simply too restrictive and prevents
individuals and small businesses from existing.

It is no wonder why industry wants Australia's civil aviation
system to be based on the FARs.

If the airlines want the EASA system then maybe we need a hybrid
of EASRs for major Airlines and FARs for the rest.

From my experience developing regulations in CASA, CASA can
encapsulate both the FARs and selected parts of EASRs into CASRs
fairly easily if you understand the Convention Annexes' Standards
and Recommended Practices really well.

It doesn't and shouldn't take thirty years to complete this task
either.

Regards

And from this little get together yesterday ...

Aircraft Owners and Pilots Association Australia

AOPA AUSTRALIA TO HOST MEETING WITH CASA BOARD & EXECUTIVE REPRESENTATIVES, BANKSTOWN AIRPORT
The Aircraft Owners and Pilots Association of Australia will host a meeting with CASA Board and Executive representatives and AOPA Australia Board and Executive representatives on Monday 16th May, at our Bankstown Airport office.

Key topics AOPA Australia will be seeking to discuss:

- Pilot Medical Certification Reform
- Independent Flight Instructors
- Part 43 Maintenance Regulation Reform
- Part 135 Charter Industry Regulation

Attending representatives include:

- Benjamin Morgan, AOPA Australia CEO
- Shawn Kelly, AOPA Australia President
- Ken Cannane, AOPA Australia Director

- Mark Binskin, CASA Board Chair
- Pip Spence, CASA Director of Aviation Safety
- Rob Walker, Executive Manager Regulatory Oversight
- Chris Monahan, Executive Manager National Operations Standards
- Andreas Marcelja, Acting Executive Manager Stakeholder
- Matt Di Toro, Executive Officer



Sandy's comment:

Sandy Reith

The 3rd word down on the illustrated hi-vis yellow jacket should read Suffocation, not Safety.

Via KC (legend -   ) https://amroba.org.au/ :

MTF...P2 

[Peetwo]

Su_Spence puts proposed Part 43 up for consultation?? - 

Ref: https://consultation.casa.gov.au/regulat...rial-work/

Overview

The general aviation (GA) industry has been asking for some years for less complex maintenance rules that reduce costs. We are moving to deliver on that this year as part of our GA workplan.

This includes finalising Part 43 of the Civil Aviation Safety Regulations (CASR) 1998 governing aircraft in private and aerial work operations.

Much work and consultation has already gone into this process, including input from a technical working group, online consultation, industry seminars and publication of over 20 information sheets on our website.

The aim was to base the new ruleset on existing overseas regulations, and we asked industry which of the several overseas regimes were appropriate. Almost 80% nominated the US Federal Aviation Regulations.

We took that advice, and we believe the result, Part 43, will simplify compliance, provide business opportunities, and reduce red tape for private and aerial work operators.

We are now seeking your feedback to ensure the final policy (consulted earlier) has been accurately reflected in the regulation, Manual of Standards (MOS), and associated advisory materials. All the details for the final policy are in the Policy Decision Summary in December 2020 linked below.

We understand that regulations can be difficult to read, so we’ve made it easier for you to have your say by publishing a draft Plain English Guide to Part 43. It is based on the regulation and MOS and is a great place to start. It explains how the agreed policy will work in practice.

And via the Yaffa:

CASA opens Consultation on GA Maintenance

19 May 2022



CASA today opened consultation on CASR Part 43 dealing with maintenance rules for GA aircraft operated in the private, airwork and limited categories.

CASR Part 43 has been developed to simplify maintenance rules and distance them from those applied to commercial and charter operations. CASA has said the new ruleset will be largely based on the USA's FAR 43.

"Part 43 will apply to maintenance of aircraft engaged in private and aerial work operations and limited category aircraft," CASA has stated. "This includes aircraft engaged in flight training, mustering, firefighting and emergency service operations, search and rescue, aerial surveying and photography, towing, and private flying.

"Part 43 will provide additional flexibility for the general aviation sector in various areas but does not change the rules that apply for aircraft used for air transport operations. Aircraft that are occasionally used in non-scheduled air transport will continue to be maintained by either a Civil Aviation Regulation (CAR) 30 approval holder or a Part 145 approved maintenance organisation, regardless of other general aviation uses."

According to CASA, the major changes that Part 43 will bring in are:

• maintenance organisation approval will not be required for carrying out maintenance of aircraft, engines, or components other than repairs to instruments, major repairs or modifications to propellers and specified maintenance of aircraft certificated in the transport category. Note: Aircraft maintenance technician certificates (AMTC) will be an available alternative to maintenance organisation approvals for maintenance of propellers and instruments, subject to conditions set out in the MOS
  
• a new individual authorisation - Inspection Authorisation (IA)
  
• CAR 30 approval holders will have the option of:
  
  • taking up a Part 43 AMTC authorisation, or
    
  • continuing to do business under the licence privileges of licensed aircraft maintenance engineers, or
    
  • transitioning to a future maintenance regime under the air transport continuing airworthiness (ATCA) maintenance rules Note: The ATCA maintenance rules are unrelated to Part 43 and are being developed under a separate CASA/industry project
    
• annual or progressive inspections will form an essential component in the management of airworthiness of an aircraft.
  

Although 80% of the GA community provided feedback to CASA called for Part 43 to reflect the FARs, the Aviation Maintenance Repair and Overhaul Business Association (AMROBA) has pointed out that for CASR 43 to work as the US system does, changes to other CASRs will be needed.

CASA is planning two face-to-face information sessions and one on-line session in the next three weeks to engage with the GA community on the proposed new rules.

Consultation on CASR Part 43 is set to close on 19 June with a view to implementing the new rules in September.
More information is on the CASA consultation hub.

MTF...P2 

[Peetwo]

AMROBA Newsletter - May 2022

Via AMROBA: Volume 19 Issue 5 May 2022

 

MTF...P2 

[Sandy Reith]

CASA, even with a new CEO being receiving around twice the Prime Minister’s pay, 17 May to 30 June ‘21 $253,089 CASA annual report, cannot move to correct the glaring mistakes made around the maintenance rules, let alone redress the unthinkable injustice perpetrated against Glen Buckley. In twelve months only one reform of note credited to Ms. Spence, removal of the Cessna SIDs that should never have been mandated in the first place. Otherwise only talk about obvious reforms that the General Aviation industry needs to halt the inexorable decline into what GA is becoming; just a rump shadow of its former self.

This is just sad, an extraordinary failure of public policy, a blight on us as a Nation and foolhardy in the extreme to decimate our aviation maintenance training and the whole of the GA industry. Especially considering the vital potential capabilities as a valuable elements of National security. Quite apart from the lost jobs, businesses and services that only GA can provide.

[Peetwo]

AMROBA Newsletter - June 2022

Via amroba.org.au...

https://amroba.org.au/wp-content/uploads...e-2022.pdf

MTF...P2 

[Peetwo]

AMROBA Newsletter - July 2022

Via https://amroba.org.au/ :

• Volume 19 Issue 7 July 2022
  

MTF...P2