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MTF...P2
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More engineers and clear rules are goals
The Australian-25 Feb 2019
Australia’s aircraft maintenance industry is at a crossroads of staffing and regulatory challenges, industry stakeholders have warned.
On one hand there is the looming global shortage of aircraft maintenance engineers that is most acute in the Asia-Pacific region.
On the other, there is the challenge of disharmonious regulation for aircraft maintenance that exists throughout the world.
Those issues, and others affecting the industry, will be tackled at the International Asia-Pacific MRO (maintenance, repair and overhaul) Conference at Avalon 2019 on Thursday.
Organised by executive director of the Aviation Maintenance, Repair and Overhaul Business Association, Ken Cannane, the conference will feature 10 presentations from industry stakeholders including Boeing and Airbus and the Civil Aviation Safety Authority and Qantas.
“Work has gone offshore as far as the airlines are concerned but we’re progressively doing things in the regulation space, to make Australia more competitive in the region,” Cannane says. “People have started to realise it is one big industry, and there needs to be a harmonious approach from one country to the next.”
He says that under the current “prescriptive approach”, it is possible for one company working on an aircraft to have to comply with up to seven regulatory systems.
“Some changes to regulations were made about a decade ago, but they did little to remove some of the provisions that were time-consuming and did nothing for safety. It was just old sort of stuff,” Cannane says. “Now they’re looking at proper reviews and harmonising [regulations] in the Asia-Pacific.”
Cannane says the potential for growth in the aircraft-maintenance sector, with an estimated global worth of $84 billion, is enormous given the expansion of the aviation industry.
Boeing’s industry outlook for the next 20 years has forecast another 754,000 aviation technicians will be needed worldwide, with more than a third of that demand coming from the Asia-Pacific.
Associate professor Anne Junor of the University of NSW Business School says the emerging global shortage of qualified and licensed aircraft maintenance engineers is particularly acute in this region.
“In Australia, the shortage is adversely affecting the general aviation and regional aviation sectors, on which regional and rural Australia depends,” Junor says.
“The short is largely a legacy of the offshoring of maintenance work that started in earnest in 2006 and progressively resulted in a decline in apprentice intakes.” Junor describes the situation as a “national tragedy”.
“We are rapidly losing the window of opportunity whereby Australia has had the opportunity to build maintenance training as a significant part of Australia’s education industry, helping meet future skills in the region,” she says.
Adding to that challenge, is that Australian licences for maintenance engineers are not recognised everywhere overseas following a botched attempt to align the nation’s training with that in Europe.
Adjunct professor Ian Hampson, of Macquarie University’s Centre for Workforce Futures, says that has been a “body blow to Australian training and licensing”.
Junor says it would be terrible to see the aviation industry go the same way as expertise in the country’s automotive industry following car-plant shutdowns.
“Australia is highly dependent on air transport and we cannot afford to see the loss of aviation skills,” Junor says.
Hampson says aircraft maintenance engineers will always be needed in Australia because of its geography.
“There are some planes we have to maintain here because we can’t fly them to Singapore [as a maintenance hub], they simply don’t have the range,” he says. “Aircraft used by the Royal Flying Doctor Service, rescue helicopters and police rescue — geography won’t allow those aircraft to be maintained overseas.”
Cannane says the education sector is responding to the demand for aircraft-maintenance engineers, with more emphasis on vocational education and training in schools.
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Quote:High flying career tied up in red tape
- Denise Dion
Tom Burn is an award winning, high-flying apprentice, training for a career for which the Australian government recognises there is a national skills shortage but getting into a TAFE course closer than seven hours drive is proving impossible.
After being named school-based apprentice of the year for the Illawarra and South East NSW region in 2018, being a finalist at the prestigious 2018 NSW Training Awards in September and attending the Honeywell Engineering Summer School, Tom was offered a position with Merimbula Aircraft Maintenance as an apprentice aircraft maintenance engineer.
One week after the HSC exams had finished Tom started his four-year apprenticeship with the aim of getting his certificate IV in aero skills, mechancial.
Not surprisingly training facilities for this course are sparsely located being either a four-hour drive to Sale or a seven-hour drive to Padstow, south west Sydney.
Rex Koerbin of Merimbula Aircraft Maintenance said he wanted to send Tom to Sale because not only was it a shorter drive, accommodation for the block release courses of two to three weeks each would be cheaper. Sale also helps to co-ordinate accommodation for students, something Padstow does not undertake.
Mr Koerbin said that over the years he had trained four apprentices and they had attended Padstow and Sale.
"It is just logical to do the training at Sale; it's closer and the school is actually next to the airfield," he said.
As an Australian apprentice, undertaking an Australia-wide recognised certificate for a national skills shortage career, Mr Koerbin didn't see a problem sending an apprentice to another state, particularly as he had done so previously.
But not this time, it seems.
Mr Koerbin was told that the Victorian training organisation, Federation Training, had not re-registered with the NSW Smart and Skilled initiative and therefore wasn't legible for funding to cover a NSW apprentice.
However Mr Koerbin wasn't told about the issues until quite late on and then had to start looking at the only other option, Padstow.
Quote:This trade is recognised as being in dire need in Australia, it shouldn't be this hard.
Rex Koerbin, Merimbula Aircraft Maintenance
"It looks like Tom's got no choice but to attend Padstow but when we enquired we were told the course had started in March.
"This trade is recognised as being in dire need in Australia, it shouldn't be this hard," Mr Koerbin said.
READ: Education: it really shouldn't be this hard
He was then told that there was a correspondence course starting in May.
"But apprentices need to be in a facility with workshops because the skills learnt at school then add on to what is being taught on the job. You don't get the same level of education through a correspondence course," Mr Koerbin said.
"Apprentice plumbers go to Canberra, so there's not a problem with cross border arrangements there. What on earth is going on, why is this so hard and why is there so much red tape," he added.
Quote:Apprentice plumbers go to Canberra, so there's not a problem with cross border arrangements there.
Rex Koerbin, Merimbula Aircraft Maintenance
In meantime Tom is waiting to see whether he can get exemptions from his two-year school-based apprenticeship at Merimbula Engineering when he was at Eden Marine High School and join the Padstow TAFE.
Asked about his apprenticeship Tom said he was loving it.
"It's going really well. I was looking forward to going to Sale, it would be much better than travelling to Sydney," he said.
Federation Training has been asked why the organisation has not re-registered with the NSW government Smart and Skilled initiative.
A spokesman for Federation Training said the Institute was well aware of the situation and the challenges of RTO (Regional Training Organisations) registration across state borders.
"We will be working co-operatively with our NSW colleagues and state education department officials to determine what can be done in situations like this," the spokesman said.
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Breaking News
CAR 30 AMOs Threaten by Reform
CAR 30 Threat to Survival
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Quote:What’s Different Since the EightiesFor those that were in businesses in the 1980s, they must be wondering what is different to the aviation legal framework that was so harshly criticized in findings post a number of 1980s government reviews. The current legal framework, if subjected to the same review by the same government enquiries, would most likely end up with the same findings today.
The Civil Aviation Act that set up the CAA to create a legal framework of Act, Regulations and Aviation Safety Standards was supposed to reduce the multiple requirements with ‘hidden’ quasi-regulations specified in regulatory exemptions, instruments, policy statements, procedures, etc. All the things that the government’s Best Practice Guidelines identify to eradicate. It was why the CAA proposed a two-level system, Act & Regulations, supported by advisory material, like FAA Advisory Circulars. Today is no different to pre-CAA days.
OECD: “Develop a consistent policy covering the role and functions of regulatory agencies in order to provide greater confidence that regulatory decisions are made on an objective, impartial and consistent basis, without conflict of interest, bias or improper influence.”
Quote:Aircraft Owners and Pilots Association Australia
AOPA AUSTRALIA MEETS WITH QLD LNP SENATOR SUSAN MCDONALD
Many thanks to Queensland LNP Senator Susan McDonald for the opportunity to meet today at Parliament House. Attending the meeting was AOPA Australia Executive Director Benjamin Morgan, ALAEA Technical Manager Steve Re, and AMROBA Executive Director Ken Cannane.
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Quote:Contents
1. Recovery will be hard
Aviation will not be as it was for quite some time. Many of the older aviation experienced generation will not be around when it does recover. The path to recovery will have its effect on those experienced aviators who remain to assist the recovery. Recover we will, but it might be with new operators and organisations.
2. Safety, Innovation & Business Growth.
Properly written principle-based regulations and devolvement of powers for business to self-assess and grow is extremely important. By all means, cost effectively control the entry of a business into an aviation sector, but post that period, the growth of the business is the responsibility of the business and its accountable manager.
Quote:Contents
1. ‘Entitled’ – Deregulation - Devolvement.
No matter which way you look at it, aviation has been badly served by the current government
guidelines for regulatory development. “The aviation industry has the overall responsibility for
maintenance of safe regular and efficient operations for aviation personnel training and for the
manufacture and maintenance of aircraft and aviation equipment.” ICAO Safety Oversight Manual.
An acceptable regulatory system should provide clarity that an individual or operator or organisation
is entitled to their authorisation if they meet the promulgated regulatory standards without the need
to ‘satisfy’ CASA.
2. Regulatory Impact Statement
One would think that creating jobs would be the major priority of every government post COVIG-19
and they would be taking actions that have held back growth. The core of the problem is that there has
never been a priority of governments to create jobs as the number one priority. They talk the talk but
don’t walk the walk. If they did they would make legislation to reduce paperwork, simplify government
forms, etc. The Government’s Guides for Better Regulation includes a check list that has to be addressed
but nowhere in the check list is the department/agency recommending changes to regulations. Do they
have to tell government how many jobs the change will create? Should not that be the number one
check needed? Jobs.
Quote:Dear Ed
With all the cuts to QANTAS announced today because of the big reduction in passenger numbers, it’s time to review staffing levels and salaries of government departments and agencies involved in aviation, a commensurate cut!
Do we really need all those ‘fat cats’ at the top in CASA and the ATSB (on enormous salaries) to be there, or are they a protected species? And what about all those air traffic controllers sitting around waiting for a plane? The only exceptions to the rule are the specialist firefighters who need to be there, regardless.
Quote:Dear Dan,
On February 19th four experienced pilots were killed in a mid air collision near Mangalore.
This is not the first time that aircraft have had avoidable accidents due to our poorly managed, outdated, inadequate and improperly designed airspace, prerogative of the ‘independent‘ AirServices Australia With the CV induced absence of airline traffic now is the time to make real improvements in our airspace management.
The whole aviation industry including General Aviation (GA) has been hard hit by the various measures to keep Australians safe from a rampant corona virus.
Now, more than ever, it is imperative that Government brings in some urgent reforms for GA which it can accomplish with little or no expense. Reforms that are so obvious it should not be difficult to order the agencies to action those measures that can help to regrow GA, apart from making our airspace safer for GA and airline traffic alike.
Having written and spoken with you on several occasions about the opportunities that exist to grow jobs and businesses in GA, I feel that there’s got to be the understanding that action is required. The Prime Minister talks about reducing red tape. Government could act now to put life back into GA and reverse the over regulated decline of this important industry.
Car driver medicals for all private pilots, the same successful standard that has been In place now for some thirty years in the Australian low weight aircraft category (and similarly private flyers USA). This is a hugely anomalous area of splitting GA that has induced thousands of private pilots to the low weight category and distorted the whole industry.
Relief from the Aviation Security Identification Card, a biennial $300 police check which to our knowledge has never been subjected to any cost benefit analysis. This is a measure that was brought about by the ‘911’ attacks but there is no similar ID imposition in the USA. This is an expensive impost that is resented greatly throughout GA because we can see that it has little or no value. Moreover for those of us that have been flying professionally, or privately, for up to fifty years or more it is disgraceful that we are treated like potential terrorists. Pending a proper analysis, Government should immediately increase the validity period in line with a timeline and or licence category.
Flying training is the backbone of all aviation, we have lost hundreds of flying schools due extreme, unnecessary and hugely expensive CASA requirements. Independent instructors as the successful USA model will allow a resurgence of training especially, important for country centres to re-establish their flying schools.
Airports, including those made over to local governments, are under threat of closure and inappropriate development in many places. Private airfields like Tyabb and Drouin in Victoria are being hounded by Councils, Central Coast airport in NSW also under attack and they need support
If there was ever a time for Government to make some necessary changes and assist the aviation community it is right now. Plain commonsense with leadership must prevail if Government is to have credibility with the aviation community.
Lastly we will not be satisfied to wait on yet another Parliamentary (Senate) inquiry when the last one, Forsyth 2014, has had no appreciable effect, in reality GA is in steeper decline.
Please make representations on my behalf to Minister Michael McCormack and the Prime Minister.
Regards,
Sandy
Quote:..It is of note that CASA approached this matter with a change management mindset, attempting to achieve a consensus from the regulated parties. The management of change, as a systematic
approach/methodology to enable change at an individual and organisation level [9], has also been
promoted by CASA for safety management purposes in the wider aviation industry [10]. Past CASA
attempts to impose regulations or dictate mandatory actions did not have the expected result, as
compliance was found to be problematic. An extensive industry consultation process was employed
for this purpose during 2018−2019 [11]. Tailoring of maintenance regulations (framework, oversight,
and practice) for the GA aircraft was a topic on the industry’s “wish list” from this consultation. This
finding has also confirmed the feedback collected by CASA from their previous interaction with the
GA sector.
Eventually, CASA decided to introduce a new set of maintenance regulations that mirrored the
United States (US) Federal Aviation Administration (FAA) rules for GA aircraft, with these outlined
in CASA’s consultation accompanying documents [11]. The FAA rules’ approach was by far the
preferred industry choice, recording a 78% acceptance rate [11]. The decision to follow the FAA
regulations for GA aircraft is not consistent with the CASA’s overall regulatory structure and
philosophy, as the Australian Civil Aviation Safety Regulations (CASRs) largely follow/mirror the
European Aviation Safety Agency (EASA) rules. This triggers questions on the underlying reasons
that provoke this type of change as well as what challenges may manifest as part of transitional
effects...
Quote:Conclusion of phase 1 of my investigation
On 23 June 2020 this Office sent a concluded view to CASA as follows:
Quote:The entry into force of the 1 September 2014 compilation of the Civil Aviation Regulations 1988 (CAR) removed the former CAR 206(1)(a)(vi) related to flying training organisations (FTO) from CAR 206.Please note that this is the Ombudsman’s opinion and CASA may disagree with it, or parts of it.
CASA’s ruling Franchise AOC Arrangements (the Ruling) issued on 21 February 2006 refers explicitly to its application to commercial operations conducted for CAR 206 purposes. CAR 206(1)(a)(vi) referred to flying training, other than conversion training or training carried out under an experimental certificate.
With CAR 206(1)(a)(vi) removed from the CAR, I note CASA’s view that the policy objectives reflected in the Ruling have remained applicable to the conduct of FTO activities under the post August 2014 regulatory regime, irrespective of the explicit reference to CAR 206.
The Ruling was not amended to reflect that legislative change from 1 September 2014 meaning that the CAR and the Ruling were no longer aligned in material ways.
Conceptually, I accept CASA's view that the Ruling may reflect broader policy considerations.
Nevertheless in my concluded view there was an administrative deficiency due to an absence of a direct relationship between the activity being regulated and the policy said to regulate it. This gave rise to ambiguity and uncertainty with the potential to cause detriment to those relying on the accuracy of the regime or, conversely, prevent detriment from occurring.
In the circumstances, it is my concluded view that CASA should have made a concurrent amendment to its Ruling at the entry into force of the 1 September 2014 compilation of the CAR because of the practical effect of the change to those relying on the regulatory regime.
Thank you for your advice that CASA will amend the Ruling to confirm the intent of the breadth its application.
Quote:Government Working Against Aviation Growth.
Nothing major will come from the current Senate Inquiry until the government re-writes the Civil
Aviation Act, and maybe one or two other Acts, so that all aviation businesses can survive. The
concept of the Civil Aviation Act is very limiting for aviation growth and job creation.
The US Aviation Act, on the other hand, is based on promoting safety by prescribing minimum
regulations and standards for all aspects of design, manufacture, maintenance and operation.
Compare that to Section 20 of the Act that basically states you cannot do anything unless it is
prescribed in Regulations. Section 9 backs this up by stating CASA is responsible for “developing
and promulgating appropriate, clear and concise aviation safety standards.”
In the US, if there is no minimum regulation/standard, then you can do it.
In NZ, the Minister may from time to time make rules for the implementation of New Zealand’s
obligations under the Convention. They adopted the US approach of “minimum” rules for safety.
In Australia, you basically cannot do anything in aviation unless there is a regulation/standard.
This approach stifles innovation & jobs. The current regulatory direction supports big against
small with requirement/red tape far beyond even ICAO standards and recommended practices.
There can be no innovation or real growth unless the US or NZ regulatory system is adopted.
Contents
1. We Need a NEW Act
Ever since the Civil Aviation Act was made, the decline in aviation has continued. The mindset
of government in applying the current provisions of the Act and Minister’s directions to the
Board is not providing Australia with an equivalent aviation system as the USA, Canada &
NZ with a similar aviation industry. The whole basis of Australia in ratifying the Chicago
Convention was to adopt the international standards and recommended practice as
promulgated as Annexes to the Convention. The USA, with a vast country has a General
Aviation Air Transport (GAAT) system that suits Australia’s rural needs. The European
GAAT is still being developed – adopt FARs.
The US system is designed to promote safety by setting minimum standards that enables and
encourages industry participants to use innovative differences that actually improves
aviation safety. The Australian system simply has participants following the regulatory
standards promulgated.
2. Aviation Going Backwards
The aviation industry outside big business has virtually given up inputting to any regulatory
reform as consultation has no effect on the outcome. CASA will do what CASA wants even
though the industry says the opposite. If you attend a consultation then you must support
CASA. The outcomes since 1988, is more big business but much lower small and medium
businesses participation, let alone private participation with VH registered aircraft. It is not
just CASA culture, it is government’s lack of support for aviation at airports around
Australia. The Minister does not stop commercial non-aviation project submitted by airport
owners.
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