[Peetwo]

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

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

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

1. All NAAs Provide/Control AME Licencing Examinations

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

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


2. Trans-Tasman Mutual Recognition Agreement.

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

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

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

Access to the TTMRA Guide here.

3. General Aviation can safely grow by adopting FARs.

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

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

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

MTF...P2