CASA released their policy paper on general aviation maintenance last Friday and followed it up this week with seminars held at several locations around the country.
Known as CASR Part 43, the idea of the new regulation is to make it easier to maintain GA aircraft that are used in non-passenger-carrying operations. That covers largely training, airwork and private operations. Traditional GA tasks that do carry fare-paying passenger such as charter and joyflights have been reclassified into CASR Part 135, which is likely to have more stringent maintenance requirements when they are announced next year.
After consultation that revealed most people in GA prefered the new regulations to be based on Federal Aviation Regulation (FAR) part 43 from the USA, CASA says it has shaped the new rules in accordance with FARs, with some differences.
According to a CASA spokesperson, Part 43 will not create a lot of change, but will remove complexity.
Among the major changes to aircraft maintenance under CASR Part 43 are:
- Registered Operators (RO) will be responsible for all aspects of maintenance
- Maintenance organisation approvals won't be needed
- Annual or progressive inspections will form a large part of airworthiness management
- Maintenance Release (Form 918) will be replaced with a Release to Service
- CASA Schedule 5 will be replaced with FAR 43 Appendix D
- Procedures Manual, quality systems and internal audits no longer required
- CASA approvals to vary location and scope of work no longer needed
CASA believes these measures will lower entry costs to the industry because approval fees will be phased out, there will be no need for major investment in facilities, no need to write a manual and no need for an independent quality system. Expansion costs are also expected to be lower because CASA won't be charging fees to expand the scope of the operation.
Part 43 will also see an Inspection Authorisation (IA) introduced in Australia. This is a new type of approval for an individual person with the purpose of conducting annual inspections, supervision of progressive inspection schedules and checking that major modifications and repairs conform with the regulations and published data.
The mandatory maintenance for aircraft under CASR Part 43 are expected to be:
- Airworthiness limitations (AWL) approved by the National Aviation Authority (NAA) at the country of manufacture
- Airworthiness Directives (AD)
- CASA directives
- Instructions for Continuing Airworthiness (ICA)
ICAs not mandated by CASA or the state-of-design NAA won't be mandatory under the proposed new policy.
However, Approved Maintenance Organisations (AMO) represented at seminars at Moorabbin and Bankstown raised several concerns about the new policy, including the fear that new-entry independent LAMEs will have a competitive advantage over existing companies that have invested in their approvals, the inability for CASR 43 companies to work on charter and joyflight aircraft and the concern that ROs will be able to give direction to LAMEs.
AMROBA Executive Director Ken Cannane said he thought the CASA presenters didn't properly address the issues raised during the seminars.
"The problem is the CASA presenters do not understand the minute details of the FARs to alleviate points raised," he told Australian Flying.
"They never raised the issue of the 'repairman certificate” for the experimental and LSA owner/operators.This will be very attractive to this sector.
"Basically, the independent LAME performing engine overhauls does not exist in the USA because they all have registered businesses because of liability responsibilities."
AMROBA is urging potential Part 135 operators to demand the adoption of FAR Part 135, Subpart J, which Cannane believes is most cost effective and harmonises with the FAR maintenance rules for GA and airwork.