Well Boys and Girls, the tip of the great southern ice berg has arrived at a bank account near you. Roll up, roll up. Pay your money and get a servicing – a good one.
When CASA closed their Jandakot office we had to pay for FOIs' time to drive from Perth. Now all the useful licensing stuff is done in Canberra and it's even worse, don't get me started on what a great "efficiency drive" that was.
So ask your MPs where Julia's fuel excise is going, including the new 5c a litre that we got on 1 July but of course aren't allowed to call Carbon Tax, the excise that was supposed to be gone when we got Location Specific Charges but is now higher than ever, is it going towards the regulator or just into the big black hole?.
bilbert - Exactly. The last consultation was never acknowledged. No summary of responses. This last consultation will be ignored as well.
AMROBA, Ken K and a few others tried very hard, very hard indeed to prevent the current stew of maintenance regulations becoming law. Probably could have if the 'industry apathy' syndrome could have been disabled.
There is a raft of this type of law coming your way, right now. It is a user pays system.
We have paid in blood and money for a remodelled, reformed regulation suite.
We will pay further in terms of reduced profit against operating costs because of the revised regulations.
We will pay again through increased administrative cost to support the money making end of the operation.
We will pay again for legal opinion to ensure notional compliance, where possible, with the regulation.
We will pay again through the Tribunal and Courts to defend against varying legal opinion.
This Financially irresponsible, legally incompetent and morally bankrupt system cannot, any longer be allowed to dictate or manage the industry it is paid to serve.
The longer you leave it, the more it smells. Do something Now !!
Ken K is not the saviour you make out. In the late 90s he was the project lead in CASA for what we have today. Although not totally responsible his fingerprints are all over what came down the pipe.
He spat the dummy and had a 180 degree change and decided the outdated FAA regs were the way to go (the same regs the yanks are trying to reform themselves). He and a very small group of cronies that then formed AMROBA fought hard against the CASA reforms being led for a while by Joe Tully and later by Hondo Gratton (who both did a good job within the bounds of their responsibility).
Unfortunately the squeaky wheel got the grease (Ken's endless letters to Ministers and politicians) and CASA once it got the airline structure sorted lost interest in pursuing what was being referred to as the B3 licencing system, as well as other reforms, before they had been fully worked through.
As a result GA missed out on some pretty good ideas because it all got to hard for CASA. Hence we have a half arsed reform that GA needs to deal with today.... a lot of the blame sits with Ken K!
Last edited by hiwaytohell; 1st Aug 2012 at 23:20.
Apart from the cost element of this, how would an already under resourced regulator cope with this huge increase in work load.
Your C210 needs a stop hole drilled which would take 5 minutes but the EO to support it is in the pile with the other 140,000 others that need to be processed. How long will that take?
We all know what will happen. There will be a massive increase in "illegal" maintenance.
Make any laws or regulations too onerous and some will be even more disposed to finding ways to circumvent them, or will just plain ignore them. I have long weighed up the cost of compliance (in non-aviation matters I hasten to add) against the likely fine if I get caught. 99.9% of the time it has worked, and on the .1% of other occasions I have quite cheerfully paid the fine, knowing that I am ahead. Every one who exceeds the speed limit is doing exactly this. Example: A tree is a nuisance, maybe a fire hazard. But if you apply to have it cut down, the authority says it is protected. Better not to ask, because if you now go ahead and cut it down, a nasty judge could send you to jail (stupidity being a jailable offence). However, if you don't ask, and do cut it down there's a good chance no-one will give a rat's. Worse case, some greeny dobs you in. So - even with a fine - problem solved, the tree is next winter's firewood now. You win all round. Go go ahead - stop drill that crack, fit that non-OEM part, splice that wire. Just don't ask if it's OK and don't mention it anywhere. In keeping your aeroplane airworthy you may be committing an offence, but what are the chances of CASA actually determining when or how the work was done if the defect has clearly been attended to? The 'S' in CASA does not mean 'safety' but 'short-sighted'. Or maybe good old 'stupid'?
See Instrument 515, and please all note there is no differentiation between "minor" and "major" repairs.
Instrument 515 is far more restrictive than it predecessors.
The article by Phelan is correct, those of you who seem to believe otherwise fall into two categories:
(1) Wishful thinkers, or
(2) You haven't read what Instrument 515 and Part 21M actually say, as opposed to what you think they say.
As for trying to blame Cannane and an industry association for what the present management has done to maintenance regulations is a bit rich, the "EASA rule" never had a GA set of rules, it's CASA that has discontinued the rules development for small aircraft, in favour, once again, of "one size fits all" -----
We are already seeing some horrendous costs, compared to the old system ---- in the order of ten times +, for a simple EO and Special Flight Permit (ferry permit) to move an aircraft for a minor repair.
I love the suggestion made elsewhere here to invoke the trans Tasman agreement. Re-register every GA commercial aircraft in NZ, get NZ pilot ticket , NZ AOC, NZ maintenance approval etc and render CASA completely irrelevant. A bit of legwork to set it up, but ultimately not a bad idea. Another tack( which I once used) if you are sourcing an aircraft from the USA: Have a Yank citizen remain the nominal owner and you can fly it here for as long as you like. Maybe only good for private operation, but that could be a sizable proportion of the GA fleet taken out of CASA control. The nominal ownership thing can be done with some binding clause that allows you to purchase it at any time for a dollar.
The instrument is valid for a year and is an exemption.
This is simply a rotten and corrupt way to regulate anything.
Coupled with the CASA /ATSB MOU this implies that the full spectrum of aviation activity by anyone can be criminalised at any time by the application of the regs as interpreted by the CASA member at the time.
The ONLY logical outcome from the perspective of a private pilot is to avoid any and all contact, with any official from CASA, ASA and ATSB.
That means: Minimal radio calls, turning off transponders, non attendence at any aviation event that attracts CASA, for example, the Birdsville races and non reporting of any maintenance or flight related safety issue, let alone any incident reports, since under the MOU, ATSB can cause CASA to initiate an investigation.
....And as we have seen, CASA can always find an excuse to cancel a licence.
To put that another way, I have been "involved" in Three of what I would call "Incidents" by my personal standards. If CASA wanted my scalp for some reason, each of them is an offence under one or other of the catch all provisions - with strict liability.
It matters not Blackie, it is an exemption, NOT A PERMISSION.
This is the simple problem with the entire cluster**** that is aviation regulation in Australia - everything is prohibited but certain acts may be exempt from this blanket prohibition.
Look no further than CASA's use of the definition of "Regular public transport" over the years to shut down a variety of charter operations...at the same time as turning a blind eye to the "Yield management" practices - cancelling scheduled flights, of Qantas and Jetstar (and perhaps Virgin too for all I know).
GOOD GRIEF
