Dotting the i's and crossing the t's - Confused  

Not directly related to AMROBA but IMO the following article, from the JDA Journal blog, provides an excellent example of the importance of MROs, LAMEs, maintenance controllers etc. of keeping up with the often laborious paperwork associated with aircraft maintenance and airworthiness... Wink :
Quote:Paperwork Matters; be careful!!!

[Image: aircraft-maintenance-records-faa-matt-la...=775%2C368]
Posted By: Sandy Murdock August 17, 2017
Aircraft Maintenance Records
Failure to Assiduously Make Every Entry Could Kill Your Livelihood
[Image: aircraft-maintenance-records-cessna-faa-...=658%2C338]
  • “Paperwork is a pain in the a__.”
  • “All that time filling out records takes time away from the real work.”
  • “As long as I get it mostly right, it’s okay. Only the FAA cares about crossing “t’s” and they can’t tell the difference if I forgot to dot the “I”.
  • “I wait until the end of the day to fill out the records. Stopping in the middle of work makes it hard to get the engine out on time. Yea, after 8 hours on the floor, I’m tired and sometimes forget. Who cares?”
These are comments that can be heard in an MX hangar any day. An AMT or an IA or anyone who twists wrenches for a job. Unfortunately, those are not the sentiments of FAA PMIs, Safety Inspectors and others surveilling all types of aviation. While it may appear to the folks on the floor to be form over substance, there are good reasons why paperwork is sacrosanct.

[Image:]Circuit Judge Thapar, who wrote the opinion for the Sixth Circuit, Lawson v. Huerta, USCA 6th Cir., sided with the FAA:

The FAA is a stickler for record keeping.  Any time a mechanic works on an airplane or performs an annual inspection, FAA rules require him to make and certify accurate records of the work performed in the airplane’s maintenance logbook.  Whether the mechanic replaces an engine or simply tinkers with a gauge, the logbook must collect its due.

[Image: faa-logbook-aircraft-maintenance-records...=581%2C438]

The facts of this case involved an owner taking his Cessna to mechanic who holds an Aircraft Mechanic Certificate and Inspection Authorization for major alterations (installing a G-model engine and a 78-inch propeller). Instead Lawson installed a K-model and an 80-inch propeller. He signed
(1) inspected the Aircraft and deemed it airworthy;
(2) installed a G-model engine pursuant to the field approval and Cessna STC; and
(3) repaired the Aircraft’s lower firewall with parts from a plane of the same year and model.
(4) He also completed and certified two Form 337s reflecting the alterations he had made.  On Form 337(I)—the same one Moore approved—Lawson certified that he had installed a G-model engine and a 78-inch propeller.
(5)  On Form 337(II), Lawson certified that he replaced the lower firewall in compliance with the applicable Cessna manual.

[Image: faa-form-337-major-repair.jpg?resize=458%2C679]

The mechanic believed that the two engines were “the same”; so, it was opinion that the alteration was airworthy even though the approved Form 337 did not reflect the work which he did. Each of these entries, the Board determined, was intentionally false and thus a violation of FAA regulations.  See 14 C.F.R. § 43.12(a)(1) (prohibiting any person from “mak[ing] or caus[ing] to be made . . . [a]ny fraudulent or intentionally false entry in any record or report that is required to be made, kept, or used to show compliance with any requirement under this part”).

The Judge repeated the level of proof which the FAA must demonstrate to prove intentional falsification:

(1) made a false representation,
(2) in reference to a material fact,
(3) with knowledge of its falsity. Hart v. McLucas, 535 F.2d 516, 519 (9th Cir. 1976).

The FAA need not, however, prove that Lawson specifically intended to deceive or that someone relied upon his misrepresentation—those are elements of the distinct offense of fraud.  Cassis, 737 F.2d at 546 (“Fraud and intentional falsification are distinct concepts for purposes of this regulation.”).

The mechanic responded that on this evidence he is guilty, at most, of poor wording and carelessness—not intentional falsification.

Intent is not an easy matter to prove and the Respondent stated that his intentions were not to be fraudulent. Under settled law, the papers must be read to determine if any discrepancies were excusable “ambiguities” or “omission.”

The opinion reviewed the facts and found that Mr. Lawson fraudulently signed the documents. The concluding paragraph is most compelling:

The FAA and the NTSB have staked out a consistent position in their intentional falsification casesFor good reason, they are serious about enforcing compliance with their maintenance rules and preserving the integrity of their records-keeping system.  See Helms v. Cassis, 4 N.T.S.B. 555, 557 (1982) (“The maintenance of the integrity of the system of qualification for airman certification, which is vital to aviation safety and the public interest, depends directly on the cooperation of the participants and on the reliability and accuracy of the records and documents maintained and presented to demonstrate compliance.”), aff’d, 737 F.2d 545 (6th Cir. 1984).  Thus, the Board’s cases make clear that even a single incident of intentional falsification constitutes a “lack of qualification” and justifies revoking the violator’s credentials.  See, e.g., Adm’r v. McCarthney, 7 N.T.S.B. 670, at *2 (Dec. 28, 1990) (“[E]ven one intentional falsification compels the conclusion that the falsifier lacks the necessary care, judgment and responsibility required to hold any airman certificate.”); Olsen v. NTSB, 14 F.3d 471, 476 (9thCir. 1994) (concluding that one “intentionally false logbook entry regarding [an aircraft] tachometer” was “sufficient to justify the FAA’s revocation of [the mechanic’s] airframe and powerplant mechanic certificate”). Those who fail to comply with these rules do so at their own peril.  And where, as here, they openly flout them, revocation is hardly arbitrary or capricious.  It is to be expected.

Those are words, written by an impartial judge, which should make it clear to all that PAPERWORK MATTERS!

[Image: faa-logbook-entry.jpg?resize=646%2C487]

The judge’s explanation goes part way towards full comprehension of the FAA reliance on records.
  • First and foremost, there are not {nor have never been} enough inspectors to watch every AMT perform the work; consequently, the required forms are a surrogate for an inspector’s presence.
  • Second, in placing reliance on the certificate holders’ recording the critical steps, the FAA is depending on the honesty of the person signing. If the professional exercising that privilege is not able to accurately report the work performed, that trust is broken and the rights accorded by that certificate or authorization are invalidated.
  • Third, it is important to remember that “intent” can only be inferred. What you may think is nothing but mere sloppy entries or what you honestly believe is the “same” (as it well may be), the FAA can and may determine to be fraud and courts are likely to agree with the government.
It may be a “pain in the a__”. but the pain resulting from a failure to assiduously make every entry could kill your livelihood.
[Image: aircraft-maintenance-record-keeping-logb...=603%2C208]

MTF...P2 Tongue

KC with sense and sensibility - Rolleyes

I see that KC has taken the Miniscule's snub (of AOPA and AMROBA from the ASAP table - see HERE) firmly on the chin on quietly and got on with the business of advocating for his AMROBA membership... Wink

Via the AMROBA latest newsletter: Volume 14 Issue 8 (August 2017)

Quote:1. Engineering Regulatory Reform Restarting.

AMROBA met last week with CASA senior management. We left that meeting more confident, than we have in the past, CASA’s Executive, under Carmody’s leadership, is starting to understand that the Australian aviation engineering sectors must have a level playing field in the design, manufacturing & maintenance fields so our industry can create jobs and compete in global aviation markets.

So how do we prioritise? Every sector within our disciplines needs urgent change but some changes will happen later than others because more detailed discussions will be needed. It is not just adoption but the transition from where we are to where we need to be. That is, to fix the “design” and “manufacturing” issues.

Project 1. Amend CASR Part 21 Subpart J to fully adopt the EASA regulation, AMC & GM utilising the clarity of the FAA system of devolvement of regulatory functions to the approved design organisation.

Project 2. Amend applicable provisions of CASR Part 21 to align with FAR changes made in 2009. Available on AMROBA’s website – under Manufacturing refer FAR Part 21 2009 amendments . FAA cost benefits $250 saving for every $1.00 spent implementing these changes.

CASR Part 21 was made in 1998, based on FAR Part 21, and is now no longer harmonised with FAR 21 and world standards. The above two projects do not need additional consultation, they need regulatory action so our regulatory system can once again align with global airworthiness and manufacturing standards; i.e. harmonisation. Adopting and implementing these changes will remove the variable interpretations from some CASA staff based on CASR Part 21 that is 18 years out of date...


This submission to CASA requires CEO Carmody to take control of CASA not, as we have witnessed in the past, the staff of CASA control the Executive. This is a small regulatory change compared to other reforms needed to align CASR Part 91 with FAR Part 91 or Part 61 with FAR Part 61...

Three cheers for that man KC... Smile

MTF...P2 Tongue

Breaking AMROBA news: 25/09/17

Quote:[Image: September-website.jpg]

Breaking News

Engineering Future
September 26, 2017 Ken Cannane
Engineering Future

Aviation Engineering Future Can Be Optimistic

Aviation engineering is a job creating industry that can be further grown if we realise that Australian aviation engineering is a domestic aviation market that is part of a regional aviation market that is part of an international aviation engineering market. Engineering: design, maintenance, manufacturing and training.

Though there are local dedicated engineering businesses supporting our local domestic market, it is impractical to have unique conditions that restrict involvement in the fast growing regional aviation market of the Asia/Pacific. This regional market will more than double in the next decade and will be reliant on design, maintenance, manufacturing and technical training disciplines from within the region and beyond. We need regional uniformity & streamline all industry/government practices and procedures so that unnecessary Australian red tape is removed so businesses can compete within Australia and are capable of providing engineering services to regional and global markets.

A core underpinning requirement is that our VET qualifications must have clarity in terminology and be acceptable within the Asia/Pacific region and also global aviation engineering markets.

There is concern within the engineering disciplines that fundamental changes, so businesses and individuals can participate in the local, regional and global aviation engineering markets, are taking far too long.

Removal of unique Australian terminology and practices and adoption of at least regional aviation terminology and practices is fundamental for business and individuals to participate in these markets.

Design: CASA has indicated that full adoption of the EASA design organisation regulatory requirements (EASA CS Part 21 Subpart J) will be fully adopted. This has high priority so Approved Design Organisations can become more involved regionally as well as domestically.

Manufacturing: CASA has indicated that full adoption of FAA manufacturing requirements (FAR Part 21, except for Subpart J and M) will be fully adopted. This also has high priority because of the effect it has on our manufacturing businesses. Aircraft, parts, ASTC, APMA & ATSO systems of current FAR Part 21 are different from the out-dated CASR Part 21.

Maintenance: CASA is consulting, but not yet committed, to adopting FAR Part 43 which is the only system that addresses the MRO and maintenance aspects of the CASA registered aircraft fleet. FAR Part 43 and associated FARs will modernise and unify maintenance requirements. Harmonisation has more benefits in our local and regional markets.

Training: This is another urgent field to unify. We employ Aircraft Maintenance Engineers but we have no national VET qualification titled “Aircraft Maintenance [and] Engineering”, the most common terminology used in the Asian region. There is an urgent need to change the VET “MEA Aerospace” terminology that will enable better recognition and acceptance within the Asia/Pacific Region. There is a current urgent “Case for Change” to fix the current lack of VET qualifications to support the CASR Part 66 B1.2 and B1.4 aircraft maintenance engineer licences. Underpinning VET qualifications to a system that was adopted from EASA needs a new VET training package system.

It is now the end of September 2017, and industry is now totally dependent on government, CASA and the Australian Industry Skill Committee and its Aerospace Industry Reference Committee to implement the identified changes (needed by government, CASA regulations, standards, procedures and NVET training qualifications) to enable our aviation businesses and individuals to not only participate in the local aviation engineering disciplines, but to be able to participate globally, especially in the Asia/Pacific region.

Some of these changes should have happened, in the opinion of businesses and individuals, over a decade ago when regulatory changes imposed many uniquely Australian conditions.

Aviation engineering is a global industry/market, any differences from international standards negatively affects participation in local, regional and global markets.

Ken Cannane 25/09/2017
Executive Director
Safety All Around.

& from this month's AMROBA Newsletter: Volume 14 Issue 9 (September 2017)

Quote:1. Engineering Jobs on Hold Waiting for Public Servants Action.

Aviation engineering (design, manufacturing & maintenance) need harmonisation by adoption with EASRs (design) and FARs (manufacturing & maintenance), plus international/regional government and/or CASA agreements to create jobs.

Instead of creating jobs now in the aviation engineering sectors, the regulatory and standards changes that are needed to harmonise globally, and will create jobs, are being painstakingly processed through an over-bureaucratic red tape system that keeps Australia lagging behind our progressive Asian neighbours. The more they delay changes to adopt EASA and FAA regulatory standards, the public servants will continue to create red tape for current requirements that are not in these proposed adopted regulatory systems. It is not only within CASA, but it also is within the education system.

Industry participants are witnessing a return to pre CASR days with the red tape continuing to be created. There are many businesses holding approvals from other NAAs so they can participate in the regional and global aviation markets. Others are working through a third party in a foreign country bypassing CASA as Australian approvals issued by CASA are not recognised in many countries.

Are we supporting, or, over regulating an industry to minimal involvement?

Engineering regulatory changes are fairly straight forward, but will public servants working for CASA/DIRD adopt the same practices of EASA or FAA? Looking at increasing documentation that has come out over the last few years, there is little confidence throughout the industry that adopting the EASR or FAR will be implemented by CASA in the same manner as EASA or FAA.

Many trying to participate in engineering sectors are continually frustrated at the differing approaches and direction regulatory reform has taken over the last two decades. The only direction that engineering sectors want CASA & government to take is to fulfil the international convention and adopt international standards. The signing of the BASA with the USA many years ago requires full adoption of, and continual harmonisation with, the FARs. The government did that in 1998 when CASR Parts 21-35 were made based on the FAR system. What government/CASA has failed to do is amend CASR Part 21 to adopt amendments made to FAR Part 21 since 1998.

CASA’s current management recognises the need for these changes but are dealing with a bureaucratic process that takes too long to bring about the change.

Industry sees CASA as part of a total government system, so when aviation regulatory change happens, it also expects CASA to coordinate the effects of these changes with other government departments and agencies. In the recent past this has not happened as well as it could have.

A very important outcome of adopting and maintaining the FAR manufacturing, STC, PMA & TSO system is the international recognition and agreements that CASA can, and must, attain to create jobs. International agreements is crucial for the continual growth of the engineering design and manufacturing sectors in Australia. This requires CASA to be skilled in negotiating technical agreements for the benefit of our engineering organisations.

Many current businesses involved in design and manufacturing are also involved in our defence industry design and manufacturing contracts so keeping harmonised with world’s best design and manufacturing regulatory systems is paramount for future contracts that result in Australian jobs.

The EASA design organisation and administrative requirements in EASR Part 21 Subpart J is urgent as it meets civil and defence requirements but must be adopted word for word and also the utilisation of AMC/GM.

CASA then needs to obtain technical agreements from as many Asia/Pacific nations as possible to open our design capability in the Asia/Pacific region. This will create jobs.

The FAA Part 21, excluding Subpart J and M, adoption will also require CASA to obtain, as a minimum, technical agreements with as many Asia/Pacific nations as possible to open our manufacturing capabilities in the Asia/Pacific Region. In addition, CASA has to also obtain recognition of the Part 21 approvals, Australia TC, STC, PMA, TSO, etc. with as many Asia/Pacific nations as possible. This will create jobs.

AMROBA fully encourages CASA current management to make the changes required, but we are also aware that the process to make change is so slow, industry has to continue to work within an ageing system that continually is applied differently by continually changing CASA middle managers and staff.

Patience is needed because CASA has lacked stability and their regulatory experience has been depleted.

2. International Recognition of NVET Qualifications.

CASR Part 66, when introduced, should have meant a complete review of the national VET qualifications. When the Asia/Pacific region adopted the EASA Part 66 Aircraft Maintenance Engineer Licencing system, their education qualifications were totally remodelled to match the adopted separate licences.

The Asian nations adopted EASR Part 66 and they also created education qualifications, e.g. "Aircraft Maintenance [&] Engineering" that underpins the issue of the mainly Part 66 B1.1/3 and B2 licencing system throughout the Asia/Pacific nations. The ‘field of study’ is "Aircraft Maintenance & Engineering".

Though Asian countries still have slight differences in education qualifications, Australia is the odd country using ageing terminology that is not recognisable within this region and globally. As one Asian engineering executive stated, Australia has had "aircraft maintenance engineers" for years but support it with training packaged as "MEA Aeroskills" instead of VET qualifications titled "Aircraft Maintenance Engineering".

Asia/Pacific nations’ aviation MRO representatives are appealing for more harmonised "education qualifications" to enable the movement of qualified people within the region.

In particular, the needs of workshop maintenance personnel VET qualifications need to be harmonised. New Zealand education qualifications are more specific and support various occupations in maintenance support organisations.

If CASAs PIR adopts the EASR Part 66 properly then the basis for an AME licence is passing the applicable module examinations that make up the modules for one of the five Part 66 AME licences. In addition, the only other regulatory aspect is the experience requirements. Acceptance of a VET qualification enables a reduction in experience requirements. Having a VET qualification based on a 75% examination pass mark may underpin the licencing requirements but doesn’t support the other occupations in the MRO industry.

However, most businesses prefer employees to hold an education qualification under the VET system.

WH&S/OH&S requirements sets training and qualifications applicable to occupations.

It became clear at the recent Indonesian MRO conference that foreign education systems had been, or are being, developed to meet the many occupations within the aviation MRO industry.

AMROBA has made a submission to the Aerospace Industry Reference Committee to adopt the most common title of VET qualifications in the Asia/Pacific region. Change MEA Aeroskills to AQF diplomas/certificates in Aircraft Maintenance and Engineering.

It is time to have education qualification documents that actually describes the field of study applicable to the occupations in the MRO industry just like so many other countries.

Diploma/Certificate in Aircraft Maintenance & Engineering identifying the field of study just makes practical common-sense.

Clarifying such a qualification with the occupation (licence and non-licence occupations).

Component maintenance organisations requiring VET qualifications have been ignored for far too long. Many component workshops need deeper knowledge than what a LAME needs to maintain components on-wing so there is an urgent need to identify those occupations and specify the specific skills needed for the occupations. Australia does not need to start from nothing, it only needs to adopt the New Zealand VET system diploma and certificates that has already identified in their VET qualifications required for the occupations in the aircraft maintenance sector.

Education qualifications are generally defined in terms of the package or mix of competencies or learning outcomes required to meet an occupational job role.

Aviation, for some past reason, has never been made so employers can interpret what the person actually has been educated to what standards.

3. Do Politicians Understand How Jobs Can Be Created In GA?

Adopt the best regulations and practices from countries like the USA that have a comparable GA spread.

After five decades of being involved in the aviation MRO industry, it is sad to see this industry being segmented by regulatory imposed compartmentalised sectors. Segmenting has never worked to increase participation or jobs in this industry.

There was once a "principle" applied by government/CASA requiring a "parallel pathway" for CASA registered aircraft and non CASA registered aircraft operating under Self Administration Organisations.

What is missing from the general aviation system is the FAA "independent flight instructor" that Australia had a version of pre the creation of the CAA in 1988. Pilot shortages were recognised in the mid 1990s.

Since the creation of CAA, industry stability and core fundamental regulations and standards have been in continual state of change. In addition, political direction has continually changed since the parliamentary review in the late 1980s.

Asian politicians, on the other hand, are aware that aviation is a job creating industry if the right regulatory system is adopted. EASA concentrates on airline sectors whereas the FAA is a system covering all sectors of aviation.

At the recent Indonesian MRO conference, three government ministers spoke of their support and growth in aviation.

Most politicians are supportive of aviation but do not become involved because of the fear of safety being compromised.

If the FAA system for general aviation was adopted, then independent flight instructors, a fixed based operator system and the need for a LAME with the FAA Inspection Authorisation responsibilities, same as New Zealand, would see growth over time as independent flight instructors become available.

Many past independent flight instructors were retired airline pilots.

The capability for growth and job creation is available if the world best general aviation safety system is adopted.

Growth in the engineering disciplines of design, maintenance, manufacturing and training are waiting the adoption of the best international standards for safety and economics.

Political support is crucial to grow any industry in the current economic and environmental society applied by social media and politicians. Most country members of governments have always shown support for aviation. However, as international experience has been depleted in CASA, the replacements with less experience are risk adverse instead of risk management that experienced public servants provided.

The economic reform that started in the late 1980s has been replaced by unique requirements that no longer apply in the major countries like North America and Europe.

MTF...P2 Cool

TAFE SA debacle stings trainee Ginger beers -  Confused

Via the Oz:

Quote:Aircraft engineers must redo subjects at TAFE SA after training bungle
  • Michael Owen
  • The Australian
  • 12:00AM October 5, 2017
Aircraft maintenance engineers who since May have had parts of their licences suspended after an air safety regulator audit exposed a serious TAFE SA training bungle that risked the lives of air travellers have been told they must redo key course modules.
Letters to those affected said the Civil Aviation Safety Autho­rity, in co-operation with TAFE SA, had completed a review of training assessment records and supporting documentation.

In many cases, “training assessment standards ... have not been completed”, letters say, and some conditions on licences will remain suspended “until the training and/or assessment deficiencies have been rectified”.

“Your failure to meet the required standards for the issue of that licence raises potentially significant aviation safety concerns,” a letter from the head of CASA’s licensing team, Craig Johnson, says.

“On the basis of the records provided by TAFE SA, CASA is unable to be satisfied that you have received adequate levels of training and undergone appropriate assessments to demonstrate that you are competent to safely exercise all the privileges conferred (by the licence).

“CASA is not attributing any fault or blame on your part. TAFE SA ... did not ensure that the ­applicable training assessment standards were satisfied in ­accordance with the relevant syllabus and the applicable legislative requirements.”

Among affected modules of the course taught at TAFE SA’s Parafield Airport campus are electronic instrument systems; electrical fundamentals; maintenance practices; and aeroplane and helicopter aerodynamics, structures and systems.

TAFE SA has offered, free of charge, retraining with an “allocated lecturer” or with another CASA-accredited training provider. As revealed by The Weekend Australian on September 2, about 90 aircraft maintenance engineers, whose jobs are to ensure planes and helicopters are safe to fly, were caught up in the scandal.

Those affected include a small number of Qantas engineers and others employed by CHC Helicopter, the largest commercial helicopter operator in Australia.

A CASA spokesman yesterday said issues with training assessments and outcomes varied on a case-by-case basis. “Different ­requirements for different ­students,” the spokesman said.

TAFE SA executive director of education Brian Rungie yesterday said its status as a maintenance training organisation was being returned on a staged basis, and it could now again conduct CASA exams and make recommendations on the issuing of ­licences.

“We expect CASA to have ­assessed all information and ­respond in the near future regarding the return of the full MTO ­status,” Mr Rungie said.

South Australian Deputy Opposition Leader Vickie Chapman said the scandal was unacceptable. “This is not about greasing a bicycle chain. This is about keeping planes in the sky,” she said.

It was revealed last week that TAFE SA had failed an Australian Skills Quality Authority accreditation in all 16 courses randomly selected for an audit, affecting 2500 students.
MTF...P2  Cool

"I can feel a lawyer coming on....I can feel a lawyer coming on."

Is it any wonder young people today are reluctant to get involved in Aviation.

One wonders if this whole debacle could not have been handled with a simple oral test. Then again there's probably nobody in CAsA competent enough to administer it. So Sad.

Dunno Thorny; not ‘plugged in’ to engineering training – but I wonder if the ‘accelerated’ sections were something like “This is a spanner, spanners come in several flavours, there’s your open ended, flat version, the ring spanner with it’s cute little goose neck to get into awkward spaces, then there’s you ‘socket’ spanner with all these little attachments to make life easy and speedy”.  These are very different tools to the ‘screwdriver’ etc.

I’d reckon most blokes who wanted to be a LAME would probably have a half decent, basic tool kit before they signed on – and – probably knew exactly how to use ‘em, having fixed motor bikes, out board engines, the lawnmower, Mum's washing machine and ‘the Commodore’ over the weekend.

I could understand the angst if say the ‘lock wiring’ element had been skipped through; or the torqueing of cylinder head bolts had been omitted; but CASA have been very coy in releasing ‘the audit’ results. I, for one would like to know what all the fuss is about – perhaps it’s the OH&S part, which warns you of a wet floor and leaves stupid little cones about the place to fall over – rather than just clean up the spill - who knows. But, for this much fuss the audit should be made public; just so we can see why.

My toolkit weighs in at just under 400 Kg all up, excluding machinery, that would fill in a happy day for the lads and lasses at ‘tech’, some of it is older than 150 years in service. Wonder what they’d make of some of the wheel wrights tools or; carriage makers gear; or the old school blacksmiths bits and bobs; great fun, useful and still functioning.

Oz flying reviews Part 66 clusterduck feedback - Confused

Via the Yaffa... Wink

[Image: Ken_Cannane.jpg]Ken Cannane, Executive Director of the Aviation Maintenance Repair and Overhaul Business Association (AMROBA). (Steve Hitchen)

Part 66 Feedback exposes Regulatory Flaws
12 October 2017

Post-implementation feedback on CASR Part 66 (maintenance licences and ratings) appears to expose a raft of flaws that stand to threaten the viability of the maintenance, repair and overhaul (MRO) industry.

Part 66 was originally designed for airline maintenance systems, but was extended to cover general aviation and charter organisations, which was seen by the GA MRO industry as over-burdening operators and engineers.

The consultation, which was part of a post-implementation review, was open from 21 February to 26 May this year and garnered 70 submissions, of which 48 were able to be made public.

The feedback summary is repetitive with its use of the words "complexity", "lack of understanding" and "lack of clarity". It also highlights to CASA and the education authorities failures with the aviation engineering training system.

Respected Wagga engineer Mark Wallace was scathing in his submission.

"I struggle to contain and put down on paper the issues raised with the submission required to cover this. The amount of discussion, heartburn, disappointment, anger, frustration and other emotions that have covered the issues raised can barely be contained.

"The unintended consequences of the licensing system as it stands because of the mixing of the old CAR 31 licence to a full Part 66 licence means that some people can sign for some of the aeroplane, some people can sign for different bits of the aeroplane, but all must consult their licences to discover whether they can sign for all of the aeroplane.

"Some of this was obvious and to be expected on the implementation of any new system, but we are 7 years down the road and appear to be worse off now than ever before under the old system."

LAME Peter Dwyer has been working on GA aircraft for 39 years, giving significant credibiity to his feedback.

"It is a fact that the industry did not want the CAR 31 system abolished in the first place which was made plainly clear to CASA well before it was thrown out with the bath water and the CASR Part 66 licence implemented," he stressed in his submission.

"All attempts to date by CASA to meet the needs of the industry for small aircraft licencing has fallen into the gutter due to the lack of attention to what has been explained to CASA by the industry.

"It is overwhelmingly acknowledged by the industry that a 'small' aircraft is not limited to the C172 model of complexity and that it involves a vast array of aircraft and systems previously covered by the CAR 31 licence system and that the reinstatement of the CAR 31 licence system is the most appropriate and workable that is out there."

Ken Cannane, Executive Director of the Aviation Maintenance Repair and Overhaul Business Association (AMROBA) said the feedback sent a clear message to CASA.

"The majority of comments are telling us that Part 66 just doesn't work and we need to resurrect the old system," he told Australian Flying.

"Most of the comments come from general aviation, because that's where it doesn't work. As far as the airlines are concerned, Part 66 works because it was made to cover them, but then expanded to cover all the other [general aviation] licences.

"If CASA had just stuck to the airlines, then Part 66 would have worked OK."
Despite the volume of feedback and consistency of calls to revert to CAR 31, Cannane believes the consultation is unlikely to bring about meaningful change.

"My optimism about this going anywhere is pretty low," he said. "We're going back to committees and talk-fests. We've been consulting for 20 years and it's time decisions were made and directions given, and I think everyone in the industry feels that way.

"We've got an industry out there in general aviation that is really struggling, and its diminishing. We've gone backwards in general aviation every time we've had a regulatory change since the 1990s."

CASA says it will now form a technical working group for the post-implementation project for Part 66, drawing members from the recently-established experts register.
The summary and published feedback are all on the CASA website.


Oh dear Mr Carmody & 6D AGAD - TICK TOCK indeed! Undecided

MTF...P2 Cool

KC & 'Blind Freddy' -  Rolleyes

[Image: Ken_Cannane.jpg]Ken Cannane, Executive Director of the Aviation Maintenance Repair and Overhaul Business Association (AMROBA). (Steve Hitchen)

Latest from KC & the AMROBA band via:

Quote:1. Government’s Purpose of Regulatory Reform.

When will aviation have proper regulatory reform meeting the PM’s policy?

Department of Prime Minister: "The challenge for any government is to deliver effective and efficient regulation and regulatory frameworks that impose the least necessary burden on businesses, community organisations and individuals in delivering economic and social outcomes.

Recent changes to the Australian Government regulatory policy and governance arrangements will improve regulatory quality and support its focus on regulatory reforms to directly enhance innovation, competition, productivity and economic growth. Efforts to reduce compliance burden will continue to be a focus of the Government’s regulatory policy.

From late 2013, the Australian Government put in place a reformed approach to managing regulation to reduce the cost of complying with Australian Government rules and regulation. It also put in place arrangements to foster significant change in regulatory practice across the Australian Public Service.

From 1 July 2016 the Government is strengthening the focus of its Regulatory Reform Agenda to pursue regulatory reforms that remove barriers to competition, innovation and growth; building on the ongoing commitment to cut red tape, improve regulator performance, and strengthen Regulatory Impact Analysis processes.

Through the strengthened Agenda, the Government will continue to minimise the cost of complying with Australian Government regulations while also working to remove unnecessary regulatory barriers to productivity, innovation and growth."

Government Regulatory Reform Major Topics

1. Impose the least necessary burden in delivering economic outcomes.

2. Directly enhance innovation, competition, productivity, and economic growth.

3. Reduce the cost of compliance.

4. Foster significant change in regulatory practice.

5. Remove barriers to competition, innovation and growth.

6. Ongoing commitment to cut red tape.

CASA Regulatory Development (Not Reform)

1. Has increased the regulatory burden without delivering economic outcomes.

2. Restricted innovation, competition, productivity and economic growth.

3. Increased the cost of compliance.

4. Increased cost with significant change in practices.

5. Created barriers to growth.

6. Committed to increasing red tape and regulatory requirements.

Without doubt, all industry has seen produced under this policy is the opposite to the PM Regulatory Reform policy clearly stated on the website of the PM.

Obviously, those within CASA do not see themselves as part of government unlike the FAA reforms being carried out under President Trump’s direction.

Even ‘Blind Freddy’ can see that adopting the USA aviation system would meet the PM’s policy for all six major topics listed above.

Surely CASA would have provided a plan to meet these government initiatives that would remove the unique and unnecessary regulations and red tape that is restricting this industry, especially General Aviation, from achieving its full potential.



MTF...P2 Tongue

AMROBA latest newsletter: Volume 14 Issue 11 (November 2017)

After the snub that KC received at the hands of Chester, one has to admire if nothing else the stoicism and ability of KC to steadfastly remain on message - makes you wonder if he knows something that we don't because buggered if I'd be putting up with the spin'n'bulldust platitudes and time delaying tactics of this miniscule to date... Dodgy

Quote:1. Safety is the responsibility of industry.

The Civil Aviation Act states in Section 9(2) that:-

"CASA also has the following safety-related functions:

(a) encouraging a greater acceptance by the aviation industry of its obligation to maintain high standards of aviation safety,"

When you have a willing industry, why would you not adopt and implement performance based regulations that includes delegated authority as has been incorporated in the modernised FARs?

Refer our recent Breaking News - see: Further TAAAF update & AMROBA latest newsflash - where comparisons with the FAA’s modernised FAR Part 21, including consequential amendments to FAR Parts 45, 43, 91 & other operating regulations that provided significant savings to the industry. The FAA devolved many of their regulatory services to industry recognising the technical and organisational expertise that now exists in industry. Also reduced the FAA overall costs but enhanced safety.

2. Regulatory Reform Scorecards Ups & Downs.

As most reviews look at either the airline or sport aviation, it is time that GA private, small operators and GA charter be put under review. These are the sectors that have stagnated and/or reduced since regulatory reform started in 1990. The government’s policy states: "Our vision for aviation in Australia is to help the industry grow in an environment that is safe, competitive and productive."

A regulatory environment that is ‘safe, competitive and productive’ exists for GA in the USA but not Australia. Adopting the FARs for the non-airline sectors would help the industry to grow in an environment that is also safer than current regulatory standards.

Do we have general aviation private and small operators’ participation that we had in 1990 before reform started? The answer is NO. So the vision to help the industry to grow has been a bureaucratic regulatory reform failure.

3. GA Private & Commercial Aircraft Ops?

To get jobs and growth back into aviation, the aviation regulatory system needs major changes to recognise the difference between private and commercial use of aircraft to make a living.

Private operations not only includes private owners but aerialwork operations and associated maintenance services as well. All of these

operational and maintenance sectors have been swamped with regulatory requirement more akin to airline operations.

Maintenance organisations should be those that are approved to maintain airline operations to those that require no approval from CASA to maintain other aircraft. An organisation not requiring formal approval should still be required to register with CASA if they do aircraft maintenance.

Aero clubs, business aircraft owners, aerialwork operators and individual owners should be able to directly employ an appropriately rated LAME to maintain their own aircraft on condition they provide all the data, equipment and tooling to perform the maintenance.

A CASA registered AMO that complies with all the FAA FBO/SASO standards should be considered – similar to the past approval meeting CAO requirements.
MTF...P2 Cool

KC last 2017 newsletter - Looking back to go forward.

Quote:The future - In the rear view mirror.

[Image: new-years-cards-fireworks-sydney-opera-h...277230.jpg]

I did not, not intentionally, mean to start a new year by looking backwards; but before doing anything on the road, you normally at least glance in the rear view mirror.

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At last NY’s day :-SBG #1 - .1/.1./.17. -" for example the Australian aviation industry, where, clearly, it is to everyone’s advantage to make things ‘better’. Did that happen in 2016? Of course not. Could it have happened in 2016? It bloody well should have – alas. Australian aviation enters the new year still burdened by the same troubles; the same unresolved issues, the same deft deflection of meaningful reform, the same denial that there are serious problems. Mind you, as the industry shrinks, real reform and good management become of less concern to the people who not only created the aberration, but have the power to fix it". Amazing.

In what seems to be an already common theme - in AMROBA's last newsletter for 2017 - Volume 14 Issue 12 (December 2017) - KC takes a good hard look in the rear view mirror and in his usual indefatigable way nails the real issues and provides (free of charge) real solutions... Wink

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TICK..TOCK Barnaby... Dodgy

MTF...P2 Cool

Breaking news AMROBA - 01 Jan '18.

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Quote:[Image: Jan-2018.jpg]

Breaking News 

Government Responsibility & 3 Tier Delusion

January 1, 2018 Ken Cannane

Three Tier Delusion Gov Responsibility

Government Must Take Responsibility for Regulatory Restricting Aviation Growth

The only reform that can be relied on.

CAA/CASA replacement of Executives every time a new CEO is appointed.

"… the end of June 2007 we had new executives in all our senior management positions. There is no one in a senior management position now who was in that position when I arrived at CASA in December 2003" (Bruce Byron 2006/07 Annual Report)

Governments (CAA/CASA), since 1988 continue to develop regulations and red tape that have decreased individual and organisation participation and the utilisation of CASA registered aircraft.

If industry does not comply with these over prescriptive requirements they face enforcement action but CASA itself has not complied with paragraph 9(1)© of the Civil Aviation Act since 1995. When will government take enforcement action and direct CASA to meet their obligation to promulgate "Aviation Safety Standards"? This is the third tier referred to in the ASRR.

Quote:9 CASA’s functions

(1) CASA has the function of conducting the safety regulation of the following, in accordance with this Act and the regulations:

by means that include the following:

© developing and promulgating appropriate, clear and concise aviation safety standards;

CASA has not promulgated one "aviation safety standard" under Sec (9)(1)©.
What is an Aviation Safety Standard? The Act Interpretations state:

"aviation safety standards" means standards relating to the following:

(a) the flight crews engaged in operations of aircraft;

(b) the design, construction, maintenance, operation and use of aircraft and related equipment;

© the planning, construction, establishment, operation and use of aerodromes;

(d) the establishment and use of airspace;

(e) the planning, construction, establishment, maintenance, operation and use of:

(i) services and facilities of the kind covered by paragraph 8(1)(a) of the Air Services Act 1995; and

(iii) services of the kind referred to in paragraph 6(1)(b) of the Australian Maritime Safety Authority Act 1990 to the extent that those services use aircraft;

and any construction associated with those facilities or services;

(f) the personnel engaged in:

(i) the maintenance of aircraft and related equipment; or

(ii) anything referred to in paragraph © or (e).

CASA’s past General Counsel (1995 to 2006) made the following statement as a private citizen to a Senate Inquiry into the Administration of CASA after he left CASA.


Under paragraph 9(1)(c ) the Civil Aviation Act 1988 CASA is required to conduct safety regulation by means that include:

"© developing and promulgating appropriate, clear and concise aviation safety standards".

CASA’s discharge of this responsibility during the past 5 years has been an abject failure"

Since 1995, CASA was required to develop and promulgate aviation safety standards but CASA has abrogated this responsibility. If they had promulgated internationally harmonised "aviation safety standards" based on ICAO/FAR then the regulatory reform would have been completed within 2 years.

Only government can hold CASA accountable to comply with the Act.

Ken R Cannane


Safety All Around.
MTF...P2 Tongue

The following is IMO a good fit for the AMROBA thread.

Via the Oz today:

Rhys Jones: Lifetime of work making aircraft safer

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Rhys Jones with a model of the F/A-18 Hornet Picture: David Caird

   The Australian
   12:00AM January 26, 2018
   Aviation Editor

It was the roof blowing open mid-flight on Aloha Airlines Flight 243 in 1988 that showed the importance of the field Rhys Jones has dedicated decades to — the structural mechanics of aircraft and repairing corrosion.

The professor of mechanical and aerospace engineering at Monash University has today been awarded a Companion of the Order of Australia (AC) for his work, which saw him spend 16 years at the Aeronautical Research Laboratory at Victoria’s Fisherman’s Bend, a key hub for Australian aviation that was part of the then Defence Science and Technology Organisation.

His original studies in the 1960s and 70s were in mathematics at Adelaide University, and amid all the talk of a “STEM revolution” he has some sharp thoughts on the value of the discipline today.

“Too many engineers are not taking their mathematics seriously enough,” Professor Jones says, noting how important it is to aerospace engineering. “If Australian engineers are going to be able to compete with the rest of the world, they have to have the strongest understanding of their discipline possible because we are not the cheapest — we’ve got a small local market. You’ve got to be able to innovate or die ... to understand the theory you’ve got to have really good mathematics.”

During his time with the Defence Science and Technology Organisation he helped on work done in the US to develop technology to deal with ageing aircraft, at a time when the sector was still reeling from the Aloha incident, the causes of which included fatigue damage.

In the early 1990s, he took a post at Monash University but says he always had “one foot” in work around the defence sector.

His interest in aircraft has lasted and he went on to pioneer work on civil and military planes aimed at dealing with the issues around corrosion and cracking. His work is aimed at ensuring “continued airworthiness and if you have an aeroplane with problems, how to ensure you can fix it”.

Professor Jones worked with private sector company RUAG Australia and the US Navy on a “cold spray” technique to repair aircraft that is now used on Australia’s navy helicopters and to other aircraft. One of his papers was chosen to be in a top 10 collection for the century to 2007, published by the Defence Science and Technology Organisation.

& Sandy's response:


Well done Trent for making one bright spot in General Aviation and offering some suggestions for growth. I share your concerns about subsidies, a much better solution is to stop subsidising CASA with it’s plethora of unnecessary permissions that attract enormous fees and to revisit the ‘one off’ increase fuel levy imposed by Albanese that was planned to raise $89.9 over 4 yrs for ‘special safety programs’ in 2012. Truss simply rolled that one on, so much for sunset clauses and last I heard was this was over $127 million extra collected from our aviation industry. 

As a former GA owner operator across 50 yrs and sadly having watched the half destruction of a very productive and necessary GA industry, I can attest to the extraordinary over regulation, supposed update of all the rules started 30 years ago and still not finished, and causing job losses and large numbers of flying schools closing. 

One additional reform that could make GA far more sustainable would be availability of freehold on airports. Airports should be like roads, public on the airside with private property on the landside. This would allow the business security that is necessary for banks to lend and investors to become involved. 

All we need is a commonsense Minister who will take control away from the dysfunctional independent regulator CASA. Alex in the Rises

MTF...P2  Tongue

First AMROBA newsletter for 2018: Volume 15 Issue 1 (January 2018)

Quote:1. Need to provide ‘regulatory inspections standards’.

Many aircraft manufacturers provide definitions of the various levels of aircraft inspections standards. However, most countries have minimum regulatory inspection standards promulgated in regulations to address the older aircraft that do not specify the inspection standards.

FAR 43.15 requires the inspection to determine the aircraft, or part of the aircraft meets all applicable airworthiness requirements and, if the aircraft is under a system of maintenance, to do in accordance with the procedures and system specified in the SoM.
Current maintenance personnel are used to terms like routine and detailed inspections and many manufacturers provide a definition of the difference. This too is based on more FAR Part 43 minimum standards.

2. FAA Reauthorisation Bills.

CASA does not have the same political scrutiny that the FAA is put under by their parliament transport committees. The USA Parliament has House Committees review the FAA performance and technical issues confronting the industry just about every two years before presenting a Bill that reauthorises the FAA for a further period.
The contents of these Reauthorization Bills make interesting reading. For instance, the 2013 Reauthorisation Bill amended their Act re CDPOs.

(a) In General.--Section 44704 (e) is amended to read as follows:

``(e) Design and Production Organization Certificates.--``(1) <<NOTE: Effective date.>> Issuance.--Beginning January 1, 2013, the Administrator may issue a certificate to a design organization, production organization, or design and production organization to authorize the organization to certify compliance of aircraft, aircraft engines, propellers, and appliances with the requirements and minimum standards prescribed under section 44701(a). An organization holding a certificate issued under this subsection shall be known as a certified design and production organization (in this subsection referred to as a `CDPO').

Remember, it was the 2016 reauthorisation bill that eliminated the current 3rd class medical requirement within 180 days of enactment. It would allow any pilot with a valid driver’s license to carry up to five passengers in aircraft weighing up to 6000 pounds, on flights below 14,000′ MSL and at speeds below 250 knots.

3. Maintenance records - deferred defects.

When the registered operator or the RO’s pilot delivers the aircraft to a maintenance organisation there is usually a discussion that is had with the RO or the pilot on what maintenance is to be carried out. This complies with the regulations as the customer has to authorise the maintenance organisation to perform maintenance and what maintenance is to be carried out.

How often during those conversations does the RO or pilot raise issues that have not been documented in the maintenance records but will require servicing or maintenance?
However, as a maintenance organisation are we doing the right thing by writing up these defects that the pilot had not listed on the maintenance release or an approved alternative maintenance release and/or log book system? These are not defects identified during maintenance.

Also it would appear that KC & AMROBA are mobilising for a GA battle Royale...  Confused

Proposed General Meeting – Tamworth NSW

Many issues are confronting the on-going viability of general aviation and more may be introduced.

We need members and associates to meet and professionally discuss our future.
  •  Regulatory Reform & Red Tape Reduction associated with harmonisation.
  •  Replace Regulatory Development with Regulatory Economic Reform?
  •  Is CASA the problem or is it the Act that directs their modus operandi?
  •  Do we adopt a modified version of the USA FBO system for GA?
  •  Where are the future AME/LAMEs coming from? Will they have the expertise for the future?
  •  How do we attain higher utilisation of VH registered aircraft?
  •  Reducing costs to maintain a viable safe aviation industry.
  •  Encouraging the use of aircraft as a normal form of transport.
Location: Tamworth because the DPM resides in Tamworth. Most agree we need to invite the DPM to attend. It was also suggested to enable GA members and friends to privately fly in, stay a night and return home the next day.

If Tamworth is seen as difficult to get to, where else should it be held to improve attendances?

Duration: Two days has been suggested so that day one could identify all the issues, identify what action should be taken and by whom. Day two could include other GA associations’ executive representatives to discuss proposed actions.

Invitees: Many suggest that CASA senior management should be invited to pm day one to be part of the discussion. Others clearly reject this approach. Voice your opinion.

Should aviation media be invited and at what time? All through the meeting as we have done in the past?

Good to see KC & AMROBA are not prepared to let CASA and the aviation safety bureaucracy continue to destroy the Australian GA industry without a fight - Wink
Time for the rest of the Alphabets to get on-board me thinks.. Rolleyes

MTF...P2 Cool

Caution Will Robinson…

In principal the ‘meeting’ is a great idea. But: it will need some speakers, in particular holders of Air Operator Certificates who are unafraid of rocking their own boat. There are probably about a dozen left who can and, more importantly – will, speak up. No need to guild the lily; just tell it as it really is. This is fraught with peril and would require some encouragement, there is always the next audit around the corner.

Then there are the respected few who are an absolute ‘must-have’. Folk like the Rev Forsyth for example, Phil Hurst for another, Mike Smith another, Greg Vaughan another; Dick Smith another. There are a few out there; calm, sane experts with credibility and nowhere near ‘silly’.

Personally, I would invite to attend, but not to speak, the ‘Alphabet’ top dogs. Too many are suspicious of their ‘agenda’, however laudable it may be. They have taken a position and have a rice bowl to protect; their members are precious to them and their very livelihood depends on ensuring the very best for ‘their own kind’. QED – many times and they will dance with the devil.

I (personally) would not let CASA within a bulls roar of the place. They need to be presented a ‘manifesto’ – along the lines of the Magna Carta.

But at the end of the shift – you still have to convince a basically uninterested politician to tangle with CASA and make some radical changes. That politician must be persuaded that ‘the Act’ as it stands is unconstitutional; that CASA is an escaped lunatic and that the blood is not on his hands.

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Take more than a man who wants to slaughter a couple of ‘illegal’ dogs when the country is infested with ‘illegals; and, 457 visa folk taking jobs away from locals to get it done right. But have your meeting – the last one really did a lot of good; didn’t it? “No” you say– well, I wonder why ever not.

But then, I often wonder why our ‘real’ experts hesitate to step up to the crease. Then I realize that experts know what a lost cause is and when to abandon ship. Most of the aviation ‘guru’s have walked away from ‘reform’ – that must give you hint.

ATSB and CASA must be disbanded; the Kiwi’s did it very neatly and have never looked back. They reformed the regulator; then the regulations and have set an enviable bench mark for sanity, economy and a way forward ever since. Can anyone see CASA agreeing to that?

FWIW, I’d steal the devil’s own lunch if KC asked me to, I’ll also help with the meeting – but, will I hold my breathe in anticipation of real change? Of course not.

My glass is empty – this is unpardonable; inexcusable – so, best get off my beam ends and amble over to fridge – this happens when one is home alone.

A General Aviation meeting, a ‘Tamworth Mark 11,’ would be a valuable exercise in several ways.
Firstly and obviously to create publicity for the ongoing plight of GA in particular and to generate political awareness without which reform is impossible. Impossible because the present model of regulatory governance for aviation has shown itself incapable of providing a workable or efficient environment for the GA industry. Thirty years into the rules rewrite (still not finished), several hundred $millions wasted and the last tranche of rules from 2014 are proving disastrous particularly for flying training. The transition to the new flying training rules is probably nearly complete, how many flying schools are left is a matter for conjecture because CASA does not count the numbers for comparison with years past. However the numbers remaining will be a tiny fraction compared to thirty years ago when CASA was remodeled into the independent Commonwealth corporate of today.

Secondly it behoves all of us to share and refine our thoughts on what is wrong and to reach some consensus on the method of reform. To this end it is clear that only by a change to the Act can reform occur. In the variety of diverse opinions about specifics, one would be hard pressed to obtain clause by clause complete agreement. Therefore the focus must be on the necessity for legislative change by demonstrating that the current trajectory is one of failure.
CASA should not be invited, CASA is irrelevant to the political changes that are required.
A Sydney meeting would have more media coverage and is a more reachable destination for the majority, especially those from interstate.

A two day seminar type meeting would have various sessions for all involved but the main publicity would be from high profile keynote speakers in the plenary session followed by question time.

There should be at least one speaker to debunk the myth that to fly is a government given privilege. We need to throw off in ourselves the outworn notion that we are always beholden to the Crown in the final analysis.

The rule of law works when it allows our legitimate pursuits not impinging greatly on the rights and freedoms of others.

For GA simple rules would work. No one baulks at the road rules and in principle it will be no different for GA.

Airline and commercial flying will always be more systematic and more stringently rules based to international standards.

AMROBA is to be congratulated for its consistent work towards achieving rational, workable and internationally acceptable standards for aviation in Australia.

KC asks a fair QON? Rolleyes  

Via the AMROBA website:

Quote:[Image: BN-1-2-18.jpg]Breaking News 
Does Government Want GA?
February 12, 2018February 12, 2018 Ken Cannane
Does Government Want General Aviation

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Standing by for the AQON? Big Grin

MTF...P2 Tongue

Ps   “With more than 5000 airports around the United States, our national network of general aviation aircraft and airports help businesses and communities to stay connected and compete in an increasingly global economy. General aviation enables businesses to access plants and customers anywhere in the country in a timely fashion, deliver goods and services to far-off markets, and conduct many meetings in different locations in a single day. These aircraft not only help communities to stay competitive, but as studies show, they actually increase shareholder value.

General aviation manufacturing is one of the few manufacturing industries that contributes to the balance of trade.

In addition to highlighting the economic benefits of the industry, the survey highlights the value of general aviation to communities around the nation in the terms of supporting agriculture, medical care, blood and organ transport, law enforcement, postal service, disaster relief, and access to many remote and rural parts of our country.”
- Following on from that quote I noted this related extraordinary AOPA article... Wink

Quote:Credit where due
Progress leads AOPA to withdraw FAA complaint against Waukegan AirportProgress leads AOPA to withdraw FAA complaint against Waukegan Airport
January 31, 2018 By Joe Kildea

In August 2017, AOPA filed three Part 13 complaints with the FAA over egregious fixed-base operator fees at three airports, one of which was Waukegan National Airport just outside Chicago. But following recent improvements, AOPA has withdrawn the complaint against Waukegan, acknowledging the steps taken by the airport to make it more accessible and friendlier to pilots.

[Image: 0131_waukegan.jpg?la=en&hash=A2A7D83B7A9...86BC25D115]
Photo courtesy of Waukegan National Airport.

“Grant Farrell from the Waukegan Port District and Skip Goss, the airport manager, understand the value of general aviation and importance of competition. We thank them for listening to our concerns and taking proactive steps to meet federal grant obligations and improve access,” said AOPA President and CEO Mark Baker.[Image: ri?ph=3031bd758b4456f88ef71857ffbba1ff27...TRxWUJQRjE]

The decision was announced in a Jan. 30 letter from AOPA General Counsel Ken Mead to the Illinois Department of Transportation and the FAA citing the airport management’s “concerted and transparent actions to improve the accessibility of the airport to transient users by offering alternative ramp parking and facilitating lower fuel prices.”

AOPA’s complaint alleged that Signature Flight Support, the only FBO at Waukegan, was using its monopoly position to force aircraft operators to buy unreasonably priced fuel and pay fees for services that were neither requested nor utilized.

In response, the airport announced in December that it would offer free tiedowns for transient aircraft and a pedestrian gate to access the ramp so pilots and passengers are not forced to go through the FBO. The FBO also reduced the price of self-service avgas from almost $6 a gallon to $4.81. A survey of websites shows avgas off the truck at Signature remains at $6.60.

According to the letter, “The alternative parking area, including wide promotion of its existence, will improve competition at the airport, better ensure the reasonableness of prices and fees for aeronautical services, and protect reasonable airport access.”

The letter notes that Waukegan’s steps match guidance the FAA issued in December to help airport sponsors understand their responsibility in assuring reasonable and non-discriminatory pricing at airports that receive federal funds.

“This is just the sort of response we are hoping for,” Baker said. “Our preference is that airport sponsors and FBOs themselves seek ways to give pilots choices when an FBO has a monopoly. We hope other locations can see Waukegan as a model. In the meantime, we will continue to press other locations to be more transparent with their fee structures and to provide pilots with choices when it comes to which services they choose to use at an airport.”

To learn more about the FBO fees issue and AOPA’s efforts to protect general aviation access, watch this recorded AOPA webinar. Baker and others working on the issue discuss the FAA guidance, how egregious FBO fees affect airport access, and what airports can do to ensure they meet FAA grant obligations.


AMROBA Newsletter - Volume 15 Issue 2 (February 2018)

1. Governments have no general aviation policy.

We are comfortable stating this having read the BITRE GA Survey. To enable a viable safe general aviation industry to grow and provide jobs throughout Australia, the past regulatory changes additional costs that imposed across aviation sectors need to be totally reviewed. Participants know that, but governments imposed costs far exceed such costs in other countries.

Laurie Brereton was the last Federal Minister that was pushing for economic reform. Prior to the formation of the CAA, the Department was more conscious of making decisions that affected the viability of this sector. Aviation businesses all operate to a very small profit margin.

It is no longer viable for general aviation in many sectors, it is why 35% of the registered aircraft fly zero hours each year. The number of aircraft for sale has never been as high as private aircraft owners abandon a once viable industry.

Read More

2. AME Licencing Has a Pathway to Reform.

The Education Department’s Aerospace Industry Reference Committee has mapped a way to at last implement a training system that will provide the "qualification" to match each AME licence.

The only issue is for CASA to promulgate the EASR Part 147 course duration/mix in the CASR Part 147. It is a catch 22 situation. CASA has no idea of understanding the politics between government departments and agencies. EASA promulgated course duration/mix for one reason: so each EU State would fund the training.

Until CASA promulgates, the States won’t receive the Federal education funding and will remain the same inadequate funding as in the past. You would expect CASA would like to show other NAAs that our course hours/mix is harmonised with theirs.

Read more

3. Are Aircraft Registration Databases Dependable?

If you read the GA Survey report, it makes you question the viability of aircraft and other aviation registers used statistically in Australia. CASA’s aircraft and LAME registers are unreliable.

How many aircraft that are on other sport organisations registers actually fly each year?

We already know the AME licencing register is unreliable as many of the LAMEs on the register are no longer working in this industry. The result of a perpetual licence with no validation period.

Aircraft registers are exactly the same. The GA Survey identified that 30% of the aircraft on CASA’s Aircraft Register flew zero hours.

Ever since the "major" notification form was repealed in the 1900s, the validity of the aircraft on the register is questionable.

Both databases can be corrected by CASA re-introducing validation provisions into the appropriate regulations. In this modern electronic world it can be quite simply done. CASA needs to know that the certificate of airworthiness remains valid. If the CofA is not valid then CASA should suspend the certificate until it is notified by a maintenance release being issued.

For aircraft, the person signing the maintenance release would electronically enter aircraft registration, TTIS and AMO/LAME number into a CASA dedicated portal.

For the LAME, adopt the EASR 5 year validation provision. Re-introduce the LAME notification form from the past that included LAME declaration of employment history.

Read More

MTF...P2 Cool

SA TAFE saga continues - Dodgy

Via the Adelaide Advertiser:

TAFE SA crisis inquiry: Training flaws worst uncovered by aviation watchdog CASA

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Civil Aviation Safety Authority revealed it carried out surveillance on TAFE’s training at Parafield

Sheradyn Holderhead, Federal Political Editor, The Advertiser
March 1, 2018 8:18pm

SERIOUS flaws in TAFE SA’s aviation training are among the worst ever uncovered by the industry watchdog, evidence to a high-level inquiry reveals.

New details of the failings which led to TAFE suspending training are laid bare as part of a Senate inquiry despite it being derailed by political point scoring.

But the only recommendation made by the Labor-controlled committee in the final report on the ongoing crisis was to establish a comprehensive review of Australia’s vocational education sector — a policy the Federal Opposition announced last week.

Federal Education Minister Simon Birmingham accused Labor of producing a “whitewashed report on the TAFE debacle”, which prompted the Coalition and Greens members of the committee to write a dissenting report.

[Image: 6d64308b3abf4f622bba26b1f88a1abd?width=316]
Federal Education Minister Simon Birmingham

In written evidence to the inquiry, the Civil Aviation Safety Authority (CASA) revealed it carried out surveillance on TAFE’s training at Parafield, after receiving information from the industry that it had conducted training at locations which were not approved by the watchdog.

“CASA subsequently conducted a surveillance activity on location at the Parafield Campus of TAFE SA, during which 18 serious and nine less serious noncompliances to regulatory requirements were identified,” the written evidence revealed.

In response to whether CASA had encountered similar serious issues with other TAFEs, the response was “no”.

“CASA does observe noncompliance but typically these are in a defined category such as record keeping, and not across a broad range of categories as was the case with TAFE SA,” the CASA evidence stated. In November, TAFE had the suspension lifted and all necessary conditions were removed, which allowed the institution to start operating at full aviation training capability.

The committee report, written by Victorian Labor Senator Gavin Marshall, labelled the inquiry an “unnecessary political exercise and a blatant attempt by the Coalition Government to damage the South Australian Labor Government”. But the report did note that the concerns about TAFE SA were symptomatic of a “broader crisis” in vocational education.

The dissenting report by Coalition and Greens Senators stated it was “disappointing” state and federal Labor “sought to frustrate the operation of this inquiry”. The inquiry was stalled and the only hearing was in Sydney.

Senator Birmingham said many questions still remained unanswered.

SA Education Minister Susan Close said TAFE SA was one of only five nationally accredited providers of Aircraft Maintenance Engineering Training in Australia.

“At no time were any safety concerns raised,” she said.

MTF...P2  Cool

Part 145 revisited by Carmody Capers & his inept minions - Confused

From the MRO Network, via Aviation Week...[Image: wink.gif]

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Australia Considers Changes to Maintenance Regulations

The new structure is more logically organized and provides what the authority describes as a “living set of aviation safety standards.”
Crystal.Maguire | Mar 07, 2018

Printed headline: CASA Part 145

In an effort to further simplify and harmonize its regulatory structure with international standards, Australia’s Civil Aviation Safety Authority (CASA) is considering changes to Civil Aviation Safety Regulation (CASR) Part 145. The post-implementation review will look at the regulation governing approved maintenance organizations and the associated guidance material.

Part 145 was introduced in 2011, as part of CASA’s regulatory restructuring, which aimed to harmonize CASA regulations with the European Aviation Safety Agency (EASA). Part 145 was updated and migrated along with three other maintenance rules applicable to regular public transport: aircraft and aeronautical products (Part 42), engineer licenses and ratings (Part 66) and training organizations (Part 147).

[Image: MRSAFETY_1_CASR.jpg]

Earlier versions of the maintenance provisions were housed in the Civil Aviation Regulations, a system the authority said was out of date, incapable of keeping pace with international developments and hard to use. The new CASR structure—originally created in 1998—is more logically organized and provides what the authority describes as a “living set of aviation safety standards that evolve as the aviation industry further matures and grows.”

CASA executed a post-implementation review of Part 66 in May 2016 (Inside MRO June 2017, p. MRO6); comments were solicited through February 2017. The goal of that project is to simplify and integrate small aircraft licensing into the overall CASR system. CASA received 70 industry comments in response to its request for feedback. In general, commenters asked for simplification, further international harmonization and a less complex system for license exclusions.

CASA has since committed to establishing a Part 66 industry working group to develop solutions and ultimately provide recommended changes to the rule.

The latest regulatory revisit—targeted at maintenance organizations—also kicked off with an opportunity for industry to provide feedback on “errors, omissions, gaps, unintended consequences or implementation issues” that have arisen since the rule’s 2011 promulgation. Industry was asked to provide comment on “key issues” for the agency to address during its review and to suggest any interim measures that might provide temporary relief pending formal rulemaking.

Initial CASA-identified issues that will be considered in the Part 145 review are bundled into three overall themes: specialist maintenance, complexity and international harmonization.

The comment period for the Part 145 post-implementation review closed on Feb. 16. There is no published time line for subsequent activities.

"...In an effort to further simplify and harmonize its regulatory structure with international standards, Australia’s Civil Aviation Safety Authority (CASA) is considering changes to Civil Aviation Safety Regulation (CASR) Part 145...

...The new CASR structure—originally created in 1998—is more logically organized and provides what the authority describes as a “living set of aviation safety standards that evolve as the aviation industry further matures and grows.”

Err... 30+ years and half a billion dollars later - what a load of bollocks... [Image: dodgy.gif]

MTF...P2 [Image: cool.gif]

KC pays accolades to Carmody on Part 21 - Rolleyes

Via AMROBA... Wink :

Quote:[Image: BN-March.png]Breaking News
CASA CASR Part 21 Realignment Project
March 13, 2018 - Ken Cannane
CASA’s Part 21 Realignment

[Image: CASA-Part-21.jpg] the worm turning - Finally?  Shy

MTF...P2  Cool

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