AMROBA.

AMROBA September Newsletter Rolleyes

Via AMROBA: Volume 20 Issue 9 September 2023

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AMROBA October Newsletter & 'Breaking News'

Via AMROBA: Volume 20 Issue 10 October 2023

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Via the AP email chains:

Quote:Shortage of LAMEs

Our latest Breaking News article “Aircraft Maintenance Personnel” article highlights the disconnect between CASR Parts 66/147 and the NVET system.

It highlights the brick wall between CASA and ASQA and why aviation regulations do not recognise Australia’s vocational training system.

To apply for an AME licence, the application should have achieved the applicable VET AQF qualification like all other trades in Australia. Why is aviation different? Because those drafting instructions to create regulations did not make the link.

When will aviation regulations address the “root cause(s)” for the shortage of LAMEs. CASA produced regulations have not provided a solution, only exacerbated the situation.

Root Cause 1:    Pre Parts 66/147, maintenance avionics and mechanical trade training had already changed from industry wide to sector specific at TAFEs providing airline/large aircraft training packages at major training campuses in the early 1990s. A demarcation issue within the airline had further reduced the mechanical trade training into mechanical systems and structures.

Do Parts 66/147 align with the VET avionic, mechanical and structures pathways?  NO

Training development is now politically sensitive because the unions are not part of the regulatory solution.

The non airline sectors, pre-Parts 66/147, had found that these main TAFE providers were not providing helicopter and piston aircraft training. These changes were recognised by CAA, at the time, who had stopped promulgating its “Guide to Become a LAME” that listed the Avionic and Mechanical trade training stream for the whole industry.  This was a guide for State Education Departments as it provided the syllabi for course development.

Root Cause 2.    Unlike the FAA, CASA is not funded to provide trade/licence training but have imposed on government funded RTOs, the Part 147 approval to provide aviation maintenance licencing training outside the Australia’s funded NVET system controlled by ASQA, the training regulator.

This has led to no career pathways in the NVET that match aviation maintenance sector needs.

The solution is to amend the aviation legislation to be compatible with the ASQA legislative/regulative requirements so aviation maintenance personnel can receive NVET AQF qualifications to hold CASA AME licences like other licence holders in other trades.  This is also inline with international standards. 

Whilst Australia languishes in the past, EASA has, 2023, once again amended their Parts 66/147.

EASA latest amendment:            Annex III (Part-66) and Annex IV (Part-147) to the CAW Regulation, introducing, among others, new training methods and teaching technologies and other improvements as part of the regular update of Part-147. In particular, amendments were introduced in order to:
  • facilitate the type rating endorsement of aircraft when there are no organisations approved in accordance with Part-147 offering type training on that aircraft, maintaining the same level of safety and a level playing field;
  • update the basic knowledge training syllabus in Part-66;
  • enhance the efficiency of the ‘on-the-job training’ (OJT) required for the first type rating endorsement in the maintenance licence category;
  • enhance the efficiency of the maintenance personnel training system with new training methods and new teaching technologies;
  • improve and correct the elements that emerged with the implementation of the CAW Regulation.
 
We will continue to lobby to see if we can get action 

Ken Cannane

Executive Director
AMROBA
Phone: (02) 97592715
Mobile: 0408029329
www.amroba.org.au
Safety All Around.


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AMROBA November Newsletter

Via amroba.org.auVolume 20 Issue 11 November 2023

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AMROBA XMAS WISHLIST 2024

Via amroba.org.au : https://amroba.org.au/wp-content/uploads...2023-4.pdf

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AMROBA 1st Newsletter for 2024 - Rolleyes

Reference:Volume-21-Issue-1-January-2024

Quote:
Critical Shortage of Maintenance Personnel?

We start this year with the same critical shortage of Aircraft Maintenance Engineers (AME) and Licenced AMEs to service the Helicopter sector and General Aviation (GA) Aeroplane sector.

30 plus years and still no aircraft maintenance engineer vocational trade training courses for the helicopter or CASR Part 23 aeroplane sector’s mechanical trade streams. 

There is one vocational pathway for the Part 25 aeroplane trade stream that supports the airline’s three trades streams of avionics, mechanical and structures. The other sectors are supported by a two trade streams, avionics and mechanical.

After our first meeting with CASA this year, we now know that there will be no regulatory change to address the shortage of aircraft maintenance personnel and LAMEs, simply because CASA said “there will be no regulatory change”. So, we are stuck with the system that creates a shortage of personnel.

• The regulatory system is “broke”, the VET training system is also broken, but repairable.

The problem that fails to be recognised is there are three (3) separate AME mechanical training pathways in the non-airline sector but only one pathway that exists in the VET system.

The second problem is that CASA does not acknowledge VET qualifications.

Regulatory Systems - worldwide

Regulatory systems worldwide are more harmonised today, than at any other time in my 60 plus years of participating in civil aviation. In every system there is basically the same maintenance concepts as included in CAR/CASRs requiring the person signing a maintenance release to meet the standards of Annex 1, Chapter 4 and Annex 8, Chapter 6.6.6. Their licenced AMEs, however named, all certify the aircraft as airworthy at completion of work. We should be no different. The maintenance and aircraft records required to be kept are closely aligned. The maintenance and aircraft records that approved AMOs need to keep are very closely globally aligned.

Our fleets are not so different, and their safety records are as good as, or better, than Australia.

Foreign LAMEs: To provide our employers with qualified staff that the Australian training system doesn’t produce, a fast-track system of recognising foreign LAMEs is required so current maintenance organisations can service the non-airline aircraft fleet and the industry maintainer experience is maintained.

CASA’s modular self-study pathway, pass CASA Part 66 module examinations is the only way to address this issue in the short term.  In house on-the-job training will add costs to operating a business. As maintenance employers state, the bureaucracy has caused the problem but have taken no action to correct the shortage of maintenance personnel they created for over 2 decades.  Part 21 realignment with FAR Part 21.

In addition, getting engineering fields of design, manufacture and maintenance harmonised globally is not even being contemplated. Aviation engineering/maintenance is not unique to Australia; it is a global industry with global standards that all other mature safe nations are or have implemented.

CASA told industry harmonisation would happen years ago post a CASA/FAA bilateral agreement meeting. They stated they would realign CASR Part 21 with FAR Part 21 applauded by industry. 

Same action as last year and years before, no action.

Regulatory Reform. If done correctly, the results should return civil aviation, especially the non-airline sectors, to the participation rates pre the creation of CARs/CASRs. However, how many more regimes of government and CASA will come and go before Regulatory Reform, originally direct by Parliament in the late 1990s, is completed? 

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Commonsense and detail reform measures falling on the deaf ears of a failed regulator.

The failure goes back to the design of the administration of an important arm of government back in 1988 by effectively deleting aviation out of Departmental and Ministerial control.

Unfortunately the Parliament overlooked the important Westminster democratic principle of Ministerial responsibility being an essential ingredient of government. The idea that government is responsive to the electorate and responsible for its governance. Think of a Department and its Minister as being as close as possible to the consequences of its actions and accountable through the ballot box. Imperfect system but the best devised and refined over hundreds of years.

The independent corporation of CASA is in law an entity that can be sued. Unlike a Department of government. This means that this entity is inclined to proceed independently to protect itself, and human nature as it is may well increase its importance leading to high salaries, fees for service for new permissions and so on. Sorry to say but CASA exhibits all such elements in spades.

All of us in the aviation community should be lobbying for aviation to be administered by a Department of Government. [Image: attachment.php?aid=439]


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Courtesy KC AMROBA CEO: Regulatory Forecast - Engineering Dreamtime

Via the AP emails:

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To all members, 

Irrespective which way you look at engineering regulatory reform projects they are parked in CASA’s dreamtime. 

Only project that we have prioritised is finding a fast track recognition of foreign LAMEs to address the critical shortage of LAMEs. 

As project managers, CASA engineering are non-achievers.
Past projects have reduced industry participation, not increased the participation in aviation. 

It is definitely an art to have a regulatory reform project that cannot be completed within the life of one parliament, or, at worse, two parliaments.

To think that regulatory reform engineering projects started with the creation of the CAA and are still in progress.

We started, early 1980s, doing reform in conjunction with NZ; CASA (new DAS) changed direction mid-1980s.

NZ completed their reforms and CAA/CASA continues (every new DAS) changing directions.

Projects now parked in dreamtime.

The Parts that have been implemented (partially adopted) have issues and need to be amended. 

Maybe the next regime of government, Board or CASA will champion engineering reform projects.
At least the last regime recognised they had to realign Part 21 with FAR Part 21. 

Under these major issues are a raft of smaller projects that don’t happen. 

Is participation and safety improving in each of these silos that CASA has created?
 
Regards

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Plus:

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KC member email and latest AMROBA Newsletter. - Wink

Via AMROBA:

Quote:To all members,

Link to CASA Authorised Persons: copy to your desktop:

https://www.casa.gov.au/search-centre/ai...tes?page=0 

Have attached Latest Newsletter.

In this issue we raise the same issue that the ICAO 2023/24 audit found.

ICAO stated Australia “could more fully realise the benefits of closer alignment with ICAO’s standards and practices (SARPs)”

There is also ICAO – Government “corrective acion plans” that have been agreed with ICAO.

Why won’t those “corrective action plans” be made public? 

1/ We provide an example how government lodge a difference with Annex 1, Chapter 4 that is very misleading to other nations.

a) By not adopting and implementing these SARPs, we are being held in the past.
b) We cannot understand why government/CASA cannot look to the future.
c) Adopting and implementing ICAO SARPs is the first step to modernisation.

2/ EASA introduced a GA aircraft maintenance organisation a few years ago, EASA Part CAO.

a) A Combined Airworthiness Organisation can be approved for:
b) Non passenger, non complex aircraft maintenance
c) Also perform the EASA “airworthiness review” – GA annual inspection does the same.
d) Also issue “permit to fly” so you can approve a customer’s aircraft to fly to your organisation for mainenanc.

Note: EASA has extended these functions to EASR Part 145 AMOs and CAMOs

3/ The shortage of LAMEs could be reduced if CASA adopted the EASA Part 66 B3 & B2L AME licences.

a) EASA introduced to ease entry into licencing especially for GA.
b) A B3, according to EASA, can attain a licence in half the classroom training hours as a B1.2. 

So why are we stuck in the past and not adopting the other half of CASR Part 66 AME licences. 

We have a bureaucracy that has not kept pace with the global industry changes or the SARPs? 

No wonder the industry is struggling instead of booming. 

Ken Cannane

Executive Director

AMROBA

Phone: (02) 97592715

Mobile: 0408029329

www.amroba.org.au

Safety All Around.

Newsletter:

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