[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.

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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...

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...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