The Regional Aviation Association of Australia (RAAA) has written to CASA Director of Aviation Safety Pip Spence urging more training exclusions on engineer licences and postpone a proposal to introduce modular licences for GA maintenance engineers.
In the letter dated 1 February 2023, RAAA CEO Steve Campbell encouraged CASA to consider issuing maintenance licences with a complete list of exclusions for skill areas not attained, saying the proposed list was "watered down".
The letter was in response to CASA's discussion paper on CASR Part 66, which called for feedback on several proposals including issuing maintenance licences with exclusions and modular licences, both of which the RAAA has rejected as written.
"The RAAA supports the proposal to utilise 'exclusions' on LAME licences to the full extent as outlined in our response," the letter states.
"We are concerned of the number of items that have been left off the list for exclusions which we believe will limit the effectiveness of these changes, especially for the general aviation sector ...
"In its current form the RAAA could not support this watered-down list of exclusions as it will not have the impact in the short term which is desperately needed."
According to the RAAA, the modular licence proposal would have some merit given that it echoed the structure of pre-Part 66 training, but would not deliver reforms fast enough.
"The ‘modular licence with subsets’ concept is reminiscent of our previous CAR 31 licence whereby we could breakdown the licencing system into five (5) categories, namely airframe and engine (now grouped as B1) and electrical, instrument and radio (now grouped as B2).
"To achieve this, legislative change is required which from experience will take time and will be resource intensive."
CASA proposed introducing reforms in two stages: Stage 1, licences with exclusions, and Stage 2 modular licences. The RAAA letter and submission to the DP point out that the two may function the same way if implemented.
"Issuing an Aircraft Engineer Licence with exclusions achieves a similar outcome to a modular licence in that a licence that is not a ‘full licence’; however, can be implemented with little change to the Part 66 Manual of Standards and therefore expediently."
The RAAA also believes the modular licence concept could be delayed and resources directed to fixing other issues with Part 66.
In October last year, the RAAA released its own seven-point plan to fix problems with training maintenance engineers in Australia, which stressed the importance of making sure reforms can be done quickly rather than via the proposed aviation white paper and legislative change.
Feedback to the Part 66 discussion paper can be submitted via the CASA consultation hub, which will be open until 12 February.