Very encouraging news P2 and Carmody should be congratulated........but??

'Scuse me for being sceptical.
So many times we have heard things like this from CAsA, every one gets excited, then the heavy hand of the iron ring descends and the whole project fizzles out or gets delayed into the next century, costs the taxpayer a few hundred million, and what we end up with barely resembles what we hoped for.

Maybe this time....but I'm not holding my breath.

Well done Ken; Bravo. We should add a ‘good work’ and well done for Carmody, then just hope it’s not too little, too late. How good would it be to have lean, clean, functional maintenance organisations back on aerodromes? But to do what – exactly’ servicing a thriving industry perhaps? Oh, but wait a moment – there ain’t one. That has been decimated by the horrendous cost of compliance, the ever present threat of jail or fiscal penalty and of course the amount of time it takes to get anything done – provided the paper- work has not been lost; or, returned not correctly completed.

Carmody is in a position very much like a minister – the ‘go’ decision is made and the instructions issued to those who are to execute the orders. This is great in principal, ‘make it happen’ is the edict – but who is going to make the changes?

Well in the CASA case – it’s the same sad, sorry bunch of misfits who buggered it all up in the first place; those who took forever to do it and cost us a bomb in the doing; while the industry quietly turned it’s toes up.

It’s great – ‘in principal’ Mr Carmody and thank you. Now, could you please explain who is going to do the rewrite, how long it will take and approximately the total forecast cost of the whole thing – from the beginning of the balls up, to the repairs being complete?

Get some professional help mate – you’ll need it to see this job done.

Toot toot.

It occurs to me that there is a much simpler, cheaper, quicker answer to the whole conundrum.

CAsA attempt to write a sensible, comprehensive, workable rule set that complies with the "Safety"
imperative but still allow an industry to survive and grow has failed miserably, cost the Australian people
hundreds of millions of dollars and in the process decimated a once thriving GA industry. Ultimately it will compromise our airline industry as well, we already see that in the export of our heavy maintenance to foreign climes.

The legacy of their failure will go on costing the Australian people into the future in the ticket price everyone who buys an airline ticket pays. The loss to the economy is already apparent and it will grow worse, anything to do with aviation is captured within the CAsA straightjacket. As businesses close, providers contract into monopolies, charges go up and the whole process becomes a self licking stamp to oblivion.

I absolutely reject CAsA's notion that US style regulations cannot be implemented in Australia. They did it in New Zealand a democracy not unlike our own with dramatic results, all it takes is the will.

Its so disappointing to read todays Australian just how close Dick Smith came to fixing the fundamental flaw in the ACT.

Without that reform is improbable.

New Zealand gave us a prime example of what can happen for a few million dollars and a couple of years, their success should be CAsA's shame.


Via the AMROBA website:

[Image: March-2018.jpg]Breaking News 
Australian General Aviation Alliance Growing
April 3, 2018 Ken Cannane

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MTF...P2 Tongue

AMROBA newsletter - Volume 15 Issue 3 (March 2018)

KC etc. backs Dick Smith and AGAA is ramping up... Wink

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MTF...P2 Cool


Skytek Engineering is the latest aviation business to have its airport lease jacked up to an unreasonable level by the grubby money hungry Cairns airport. The JP Morgan/Hastings owned money printing machine is again trying to squeeze out GA businesses. The airport has a long legacy of shitting on GA particularly over the last 5 years, firstly under the Scottish tight ass CEO Kevin Brown, and now under the young poofter CEO Norris Carter. They shut the cross runway and have then repetitively raised leases in an effort to force operators out of the place. It’s a fucking disgrace.

An article was posted in today’s Cairns Post but there is no use posting the link as the article is paywalled by the shit Rag. So instead I’ve posted a link to the company below;

F#ck you Cairns airport.

AMROBA: Viva la Revolución - Part III

References: Viva la Revolución - Part II & Let the viva la revolución begin & While the cat is away the mice will play

Via AMROBA 'Breaking News':

Quote:[Image: April-BN-800x445.jpg]Breaking News 
April 20, 2018 Ken Cannane
Nobody Cares

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MTF...P2 Cool

AMROBA newsletter: Volume 15 Issue 5 (May 2018)

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Excellent update KC -  Wink

MTF...P2  Tongue

AMROBA newsletterVolume 15 Issue 6 (June)


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MTF...P2  Cool

AMROBA Newsletter: Volume 15 Issue 8 August — 2018


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Quote:3. Political and Bureaucracy Support is Essential

Most aviation industry associations have come to realise to obtain a fair aviation regulatory system we need political support like never before. This is needed when sustainable growth of an industry is not the aim of the current regulatory system. Aviation would not have grown unless past regulators listened to the ambitions and proposals of our aviation pioneers and created a regulatory system so their proposals became reality.

Without doubt, this all changed when CAA was created for many reasons.

However, when all of the general aviation associations met in Wagga it removed the perception built up within the political and bureaucracy that there were differences in opinions and separate GA associations had different opinions on the directions for GA. That perception was nurtured by questionable government consultation processes used to divide sectors of the aviation industry by selective consultation.

Since Wagga, many politicians, government departments and even some within CASA have come to accept that the industry has one aim, to remove impediments to enhancing safety and the growth of GA.

The USA system is by far the largest GA system in the world and has a safety record second to none. So why would you not adopt the system for Australia with a less populated country but similar in size.

Entry pathways into aviation must be multiple as provided in the EASA and FAA systems.

Maybe the Wagga Summit got this message across to the political and bureaucracy at last. CASA must provide as many pathways as possible to allow new participants to enter in to our aviation world. There has to be a real stop to restricting pathways and freedom of choice.

Fighting for Your Freedom to Fly has never been truer than at this moment.


Good to see KC & the AMROBA band have not backed away one iota from the good fight -  Wink

MTF...P2  Cool

Value of GA recognised by EASA -  Rolleyes  

Courtesy of Dr K, via twitter:

Dr K I Kourousis
@K_Kourousis Follows you
Senior Lecturer (Associate Professor), Aeronautical Engineer CEng | University of Limerick - School of Engineering
Limerick, Ireland

Quote:Dr K I Kourousis‏ @K_Kourousis 

Some of EASA's international peers should just become EASA members to solve similar issues they have with proportionate and safe regulation of GA. Look at the example of the Australian CASA, still struggling to solve this for quite a long time.



The future of GA - safer, simpler, more affordable

Related Content
EASA’s Annual Safety Conference ‘A Vision for the Future of General Aviation’ (6-7 Nov 2018 in Vienna/Austria) on safer, simpler and more affordable flying introduces the new era of innovation and sharing of airspace, flights in General Aviation
The conference will launch a new European GA strategy focusing on safer, simpler and more affordable flying, with panels on innovation, safe and more affordable aircraft as well as the sharing of flights but also airspace.

H55 Founder & Executive Chairman André Borschberg, who holds the world record for the highest solar-powered flights as well as the longest solo flight in an airplane of any kind, will attend as a keynote speaker and panellist.

A substantial range of European GA manufacturers, developers of hybrid and solar-powered aircraft but also of air taxis and other UAV, cost-sharing platforms as well as GA associations and policy representatives will participate in this key conference on the future of European General Aviation which takes place in Vienna coinciding with Austria’s presidency of the Council of the EU.

In 2014 the Rome Conference on General Aviation marked the onset of improved cooperation with GA community which led to notable and successful results

EASA first reached out directly to the European GA community at its first conference on General Aviation which took place 4 years ago in Rome. The Rome Conference led to an engaging GA strategy and greatly improved cooperation and communication between EASA and the European GA community.

After considerable progress has been made in the past years to strengthen GA, such as simpler and lighter rules for declared training organisationsballoon operations, introduction of standard changes and repairs and the re-written CS-23 rules, the 2018 Annual Safety Conference will look towards the future of GA. The new European GA strategy is taking off with the recently adopted update of the aviation safety rules for Europe, also known as the Basic Regulation  which provides additional flexibility for regulating GA.

Have a look at the conference agenda and sign up for the EASA 2018 Annual Safety Conference A Vision for the Future of General Aviation! We welcome you to participate and help shape the future of GA!

Good to see that the EASA understand the value of having a strong and vibrant GA industry... Wink - meanwhile in Dunceunda land... Dodgy 

 Timeline of Australian aviation safety regulatory embuggerance - 1988 till ???? 

MTF...P2  Cool

KC pitches for EASA maintenance regs Rolleyes  

Well this follows on quite nicely from the previous post... Wink

Via the Yaffa:

[Image: ken_cannane_amroba.jpg]

AMROBA urges CASA to adopt New EASA Rules
20 September 2018

Ken Cannane, Executive Director of the Aviation Maintenance Repair and Overhaul Business Association (AMROBA), has recommended CASA adopt the new European Aviation Safety Agency (EASA) maintenance rules.

EASA laid down new Part 66/147 rules in August, and Cannane believes Australia would benefit from copying the new regulations.

"EASA has just promulgated its latest revision to Part 66/147 and it is now more compatible to our industry," Cannane said in an AMROBA communique on Monday.

"When CASA partially adapted the EASA parts 66/147 over a decade ago, its impact has been well documented. The CASR Part 66 Review recognised that it was a major concern to the MRO industry.

"[EASA Part 66] is workable in Australia and needs to be adopted now so the Aerospace IRC can develop appropriate training packages for each licence. It has created a B2 light and split some of the modules to support a GA B3 and 'L' licences. New B3 and 'L' AME licences will work in Australia.

"For those old enough to remember the AME licencing system pre CASA Canberra HO days, they will recognise what was covered under licence ratings and airworthiness authorities.
"AMROBA has recommended that this revision of the EASA Parts 66/147 be adopted as part of the CASR Part 66 review."

CASR Part 66 was scheduled to be implemented in July 2016, but was postponed due to unresolved issues and unintended consequences of the rules surrounding small aircraft maintenance engineers.

A post-implementation review revealed the industry thought the new CASR was too complex, confusing and simply didn't work, with many calling for a return to the older CAR 31 rules.
In July this year, CASA agreed to draft maintenance rules specifically for general aviation, a path that has drawn applause from the GA community at large.

"AMROBA supports CASA's direction in the engineering fields," Cannane said this week.
"We just need it to come to fruition for the benefit of the industry overall."


Hmm...Dr K will be pleased - MTF...P2 Tongue

AMROBA Newsletter - Volume 15 Issue 9 (October 2018)

Via AMROBA... Wink 

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Hmm...a few more issues in that lot to add to the miniscule 8G McDo'Naught's TICK..TOCK aviation safety bucket list... Dodgy  

MTF...P2  Tongue

KC & AMROBA scathing of CASA's reg reform of Part 66/147 -  Dodgy


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 Part 66 Implementation Failure

Quote:This is an object case study in how to fail when implementing regulatory change.
CASR Part 66/147 was introduced in 2010 based on 17 European regulated maintenance personnel training modules that CASA never attained vocational government support to implement.

Employers are supposed to employ aircraft maintenance engineers (AME) qualified with the applicable trade modules plus module 10 for AME licences without type ratings...

...Implementing part 66 is an inter-governmental issue and the responsibility is on CASA to obtain other government departments and agencies, like the Department of Education, to support for the implementation of CASA regulatory standards.

The biggest drawback was when CASA regulatory adopted parts of a foreign system but not crucial regulatory provisions like listing predicated regulatory course hours and theoretical and practical split as aviation regulatory standards. Until the EASA course duration is promulgated by CASA, the appropriate government funding will not be allocated in Australia. 18 years after implementing, CASA still haven’t promulgated the EASR Part 147 course hours...

...EASA has made considerable changes to EASR Part 66/147 to address the shortfall of their regulatory standards and licencing for general aviation. Without doubt, CASA should fully adopt these standards, including the amended Course Duration to cover GA licencing.

This enables CASA to meet their obligations under the Civil Aviation Act to promulgate clear and concise aviation standards...

...The current training packages are not providing aviation businesses with the standard for skills or qualifications to meet what is required in the maintenance repair overall (MRO) system. They are not compatible with the skills required by legislation and they are not being packaged in the legislative required modular system based on international standards.

From an employer and employee point of view, CASA and government have not implemented the VET training requirements that they introduced in 2010.

How can CASA and government continue to back a system that they introduced without the support of the VET system, comparable to Europe, needed to properly implement it?...

MTF...P2  Cool

Via Oz Flying today:

Quote:[Image: ga_maintenance_2.jpg]

Industry Feedback shows Preference for US Maintenance Rules
24 October 2018

Feedback to CASA's proposal to adopt international maintenance regulations for small general aviation aircraft has shown overwhelming support for the USA's Federal Aviation Regulations (FAR).

The new regulation proposal was announced at the Australian General Aviation Alliance (AGAA) summit in Wagga Wagga last July by Deputy Prime Minister Michael McCormack, and is intended to simplify maintenance rules for small aircraft involved in private, airwork and non-passenger charter operations.

According to CASA data released yesterday, 78% of respondents to the proposal preferred the FARs over New Zealand, Canadian or European regulations.

"All respondents identified issues with the existing regulations and indicated support for change to a simpler, more understandable, set of rules," CASA has said.

"Of the 63 industry respondents who indicated a preference for an international rule set, 49 respondents (78%) preferred the United States' regulations and seven respondents (11%) stated a preference for the New Zealand regulations (which are broadly based on the American approach).

"Twenty-one respondents (28%) also outlined concerns with aircraft engineer licenses and rating."

Feedback came from a large cross-section of the GA community, including private operators, AOC holders, engineers, associations and type groups.

"Industry is stuck in between three different regulatory system[s], none of which are harmonised globally," said Ken Cannane, Executive Director of Aircraft Maintenance Repair and Overhaul Business Association (AMROBA).

"The costs of over regulation and red tape is doing major damage to industry. Many businesses have already succumbed to the current system that lacks definition between CASA functions and requirements and the responsibilities of industry participants.

"The move to adopt the FAR system for GA that industry has demanded since mid-1990s is still the aim of AMROBA and its members. AMROBA has provided many comparison documents to CASA that demonstrates the FAR system will lower costs to GA but improve safety by adopting enhanced safety standards."

Howard Hobbs, President of the Australian Mooney Pilots Association (AMPA), said that following the US system would clarify the responsibiliy of aircraft owners when it came to maintenance requirements.

"Adopting FAA regulations for private GA aircraft in Australia would eliminate much of the confusion that currently exists around what maintenance is, and is not, mandatory under Australian regulations," Hobbs said.

"Under FAA regulations, it is clear that owners are required to maintain their aircraft in accordance with the type certificate and the flight manual (the version that applied when the aircraft came into service) and to carry out any ADs applicable to that aircraft. Private owners in the USA are not required to other manufacturer recommendations unless they become subject to an AD."

Whilst generally supporting the FAR system, Mike Higgins from the Regional Aviation Association noted that simply adopting the FARs could spell the end of the Approved Maintenance Organisation (AMO) in Australia.

"The FAR rules in Part 43 are all the scattered regulations, instruments, CAOs and other means used by CASA to state who and what is to be done. The Operations FAR parts detail when an approved AMO is required. The FAR fixed-based maintenance organisations are our approved CAR 30 GA maintenance organisation.

"Unless you want GA maintenance to collapse by deleting AMOs, we should adopt the FARs maintenance and maintain a CAR 30 GA aspects-only AMOs.

"Adoption of the FAR based regulations, including introducing the Inspection Authorisation is highly beneficial to GA. The FAR terminology is compatible with flight and technical documents promulgated by US manufacturers."

CASA will now hand the feedback over to a Technical Working Group appointed by the Aviation Safety Advisory Panel (ASAP) to firm up a new policy.

More information including some published feedback is on the CASA consultation hub.


MTF...P2  Cool

KC calls for parliamentary solution to SATS regulatory embuggeranceWink   

Following on from this part of AMROBA's latest newletter: (ref: )

Quote:2. Do We Have a Government Small Aircraft Transport (SAT) Policy?

Before the review era started in the 1980s, Australia had a small aircraft transport system. Today, the EU is further ahead with their SAT system which we once had.

“general and business aviation complements regular air transport performed by commercial airlines and thus provides specific social and economic benefits such as increasing the mobility of citizens, the productivity of businesses and regional cohesion”.
** European Parliament Resolution of 3 Feb 2009 on an Agenda for Sustainable Future in General and Business Aviation.

Quote: “EU 2009: SATS aims at the segment of the transport market that is not served by scheduled air transport or high-speed trains, which today results in a substantial need for road travel for short to medium distances, to answer the specific needs of. business and other users. --- The small aircraft transport mode can fill a gap, which exists between Surface Transport and regular mass Air Transport.” Unquote.

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Quote: USA: 2005. The challenge is to create a new mode of transport by wider use of small aircraft using local and regional airports, enabling access to more communities in less time. The SATS concept of operations uses small aircraft for business and personal transportation, for ondemand, point-to-point travel between smaller regional, reliever, general aviation and other landing facilities, including heliports. The SATS architecture contemplates near-all-weather access to any landing facilities in the U.S. SATS would leverage Internet communications technologies for travel planning and scheduling, which would also minimize user uncertainty regarding destination services. Unquote.

Where is Australia’s politically supported Small Aircraft Transport System?

The SATS RIS includes the 10 compliance cost categories: education, enforcement, notification, permission, procedural, publication and documentation, purchase cost, record keeping, delay and other. The cost categories, except ‘purchase cost’ and ‘delay cost’, are labour activity based internal costs. ‘Delay costs’ are the expenses and loss of income incurred as a result of an application or approval delay and can be in the form of labour or non-labour related costs.

EU continued: “A possible visionary European (Australian) Transport System should be based on an environmentally sustainable, cost efficient, safe, seamless and co-modal passenger friendly system aiming to ensure mobility and cohesion for the European citizens while enabling economic growth. More people and greater economic affluence mean more mobility and more transport. Some studies suggest that the number of cars in the world will increase from around 700 million today to more than 3 billion in 2050, creating serious sustainability problems unless there is a transition towards lower and zero-emission vehicles and a different concept of mobility is introduced in an environmentally friendly way.”

Communication from the European Commission.

A sustainable future for transport: towards an integrated, technology-led and user-friendly system. Brussels, 17 June 2009.  

I note the following from off Oz Flying yesterday:

Quote:[Image: ken_cannane_amroba.jpg]

AMROBA calls for Parliamentary Resolution
8 November 2018

Ken Cannane, Executive Director of the Aviation Maintenance Repair and Overhaul Business Association (AMROBA) yesterday called for a parliamentary resolution to support regulatory change in aviation.

Following up on similar initiatives in the US congress and the European parliament, Cannane said he believed a resolution in federal parliament in Australia was needed to encourage growth in general aviation.

"Australia aviation, outside the mass transport systems of the airlines, need a vision of the future that benefits all," Cannane said.

"In 2004 the US House passed a Bill supporting the small aircraft transport system (SATS) and in 2009, the EU parliament passed a resolution to support a similar SATS."

SATS includes the use of private aircraft for personal transport under FAR Parts 91 and 135 and EU PART OPS, as well as all levels of commercial uses except the mass transport system.

The EU resolution, passed in February 2009, said in part: “general (includes private flights) and business aviation complements regular air transport performed by commercial airlines and thus provides specific social and economic benefits such as increasing the mobility of citizens, the productivity of businesses and regional cohesion.”

"Since adopting the EU Resolution, design, manufacture, maintenance, private, business and light commercial operations are growing in the EU," Cannane said.

"We need a parliamentary resolution to guide regulatory development."

AMROBA is a member of the Australian General Aviation Alliance (AGAA) and has encouraged other AGAA members to adopt a parliamentary resolution as part of the alliance agenda.

Gotta hand it to KC, not only does he support his arguments and ideas for change/reform with well documented facts and international examples but his timing in the current political climate, leading up to an election, is impeccable - as usual the choc frog is in the mail KC... Wink  

MTF...P2  Tongue

AMROBA submission to 'Oversight of CASA' Senate Inquiry Wink

Via the RRAT 'Other Committee Activities' webpage:

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  1. Attachment -  Relevant USA Aviation Act requirements (PDF 314KB)

  2. Attachment - Civil Aviation Act, section 98 (PDF 247 KB)

MTF...P2  Cool

KC continued push for proper Govt policy for GA industry. 

Oz Flying rehashed an AMROBA October Newsletter article written by none other than Ken Cannane... Wink :
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An Industry in Transition
5 December 2018

– Ken Cannane
It is of great credit to the participants of general aviation that safety levels have been sustained during continual transition to an unknown future not yet defined by governments, or the public service, that are still debating what is "general aviation".

Since the 1992 Productivity Commission's Intrastate Aviation paper, aviation, in particular general aviation, has been in transition. But transition to what?

Aviation, especially general aviation, has been unsympathetically treated by governments for decades and some changes that have been imposed on aviation were not based on survival or growth of the VH general aviation industry. You only have to look at how public service interprets recommendations from multiple reports that have been created over the last 30 years to understand the outcome we have today.

None of the reports generated by federal and state parliaments supported a blueprint that describes where and how general aviation participates and grows in the future. The political answers were, and are, competition and direct cost recovery from participants.

Like roads, airports are a means of transport servicing communities commercially and privately. Without airports, communities tend to wither and stagnate.

The significance of "Aviation" was officially removed from the federal department's title in 1987 when the departments of Transport, Aviation and Communication amalgamated to form the Department of Transport and Communications.

Creating an agency (CAA) in 1988 moved aviation outside political influence, but this also meant a loss of a previously politically-supported general aviation industry: design, manufacturing, maintenance, private and commercial operators.

The August 1990 Federal Budget announced that the $73 million contributed towards safety regulation would be phased out in favour of the costs being met by the aviation industry.

A list of the changes over the last 20 years demonstrates the instability of the governance.
No industry can grow when there is so much change in governance and administrative directions – all effect the capability of small and private businesses and individuals. What are the benefits to the community and the small private and commercial industry?

It is hard to imagine the future when there is no vision promulgated and politically supported. The biggest single problem with the government's Guide to Better Regulation is that the Regulatory Impact Statement [RIS] is based on there being a government policy.
If there is no policy for a future safe and viable general aviation industry, then all the RIS is creating is an undocumented policy problem to be changed.

The government's Guide to Better Regulation provides what was once an approach taken by the Authority and before the decision to include European provisions. "Light touch regulation" is defined as: As a policy maker, you can choose to be less prescriptive and give discretion to regulated parties on how they can act. Principles-based regulation allows for maximum flexibility among affected groups as to how they achieve compliance.

When politicians eventually support a future for general aviation, private and business aviation including design, manufacturing and education, then making regulatory changes to reduce regulation and red tape to support that vision would make sense.

Ken Cannane is the Executive Director of the Aviation Maintenance Repair and Overhaul Business Association (AMROBA). This article first appeared in the AMROBA newsletter of October 2018 and is reproduced here with permission.


MTF...P2  Cool

KC urges CASA to adopt FAR 135 maintenance rules Wink

Via the Yaffa:

Quote:[Image: ga_maintenance_3.jpg]

AMROBA urges US Rules for Part 135 Maintenance
11 December 2018

Ken Cannane, Executive Director of the Aviation Maintenance Repair and Overhaul Business Association (AMROBA), has urged CASA to adopt the US maintenance rules for passenger-carrying operations in small aircraft.

According to Cannane, the rules laid out in FAR 135 Subpart J have the capability to revitalise the general aviation sector. Under the US rules, operators of small passenger-carrying aircraft have the option of three approved maintenance organisations:
  • Part 135 maintenance organisation (the operator's own AOC)
  • Fixed-base Operator who has CASR Part 43 approval
  • Part 145 Approved Maintenance Organisation.

"With CASA moving to FARs for GA maintenance, it would seem natural that FAR Part 135 maintenance aspects for commercial operations should be adopted," Cannane believes. "It would address commercial charter operations in Australia.

"Like FAR Part 121, it is based on the Part 135 operator performing its own maintenance under the AOC but then provides provisions for contract maintenance."

CASA has released for rulemaking the CASR Part 135 rules on operations for passenger-carrying operations in small aircraft, but done so without any reference to what maintenance regulations will apply.

On Friday, CASA also published the policy paper for CASR Part 43 GA maintenance rules, which specifically exclude passenger-carrying operations such as charter and joy flights, but apply to aircraft on airwork and private operations.

"CASA has proposed the biggest change to GA maintenance since the creation of CAA/CASA," Cannane stresses, "so why not adopt the FAR 135 principles that enables the 135 operators to maintain their own aircraft under their Part 135 authorisation?

"FAR Part 135, Subpart J adoption is a radical change for a sector that is struggling and made save the sector. Subpart J would reduce red tape and improve an operator’s aircraft reliability.

"Employing their own maintenance staff means they are available and on call to address deficiencies that some pilots may not record until aircraft are scheduled for maintenance."
According to CASA, the maintenance rules for CASR Part 135 have yet to be determined.

MTF...P2  Tongue

AMROBA's last newsletter for 2018. 

For the final AMROBA newsletter for 2018 there is a definite positivity going on -  Wink 

Ref: Volume 15 - Issue 12: 

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MTF next year...P2  Tongue

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