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.