Project CS 13/27
Project CS 13/27 - Review the requirements for the calibration for certain aircraft instruments when the aircraft is operating under the Visual Flight Rules
Issue
Civil Aviation Regulations (1988) (CAR) 39 (Class A aircraft) and 41 (Class B aircraft) require that all aircraft components from time to time included in or fitted to the aircraft, are maintained. Those regulations go further and prohibit operation of that aircraft unless there is a maintenance program that includes instructions for all those components included in, or fitted to, the aircraft.
Three Airworthiness Directives (ADs) were published to address the needs of certain instruments to ensure consistent standards were being applied:
- AD/INST/8 applicable to aircraft operating under the Visual Flight Rules (VFR),
- AD/INST/9 applicable to aircraft operating under the Instrument Flight Rules (IFR) and
- AD/RAD/43 applicable to any aircraft fitted with a transponder and altitude encoding equipment and operating under either the VFR or IFR.
A review of appropriateness of using airworthiness directives for maintenance directions resulted in Civil Aviation Order (CAO) 100.5 being amended to include Paragraph 11, Additional maintenance requirements, which has replaced the three ADs. It is important to note that Schedule 5 of the CAR does not provide any testing parameters needed when performing scheduled maintenance on these instruments and systems.
CAO 100.5 requires that all aircraft, with some exemptions, operating in Australian airspace are to have specific maintenance tasks completed on the aircraft's pitot static system, including altimeter and airspeed indicator every 2 years and the fuel quantity indicating system every 4 years. Exempted aircraft are those aircraft which have an existing approved maintenance program that includes these specific requirements.
CAR 39 and 41 make no distinction as to the nature of operations the aircraft is to be used for. To allow aircraft operating under the Visual Flight Rules to be excluded from the requirement to regularly maintain certain aircraft instruments and systems would require CAR 39 and 41 to be amended or that provision included in the proposed CASR Part 91.
Concerns have been raised by some members of the aviation industry that the current universal requirements to regularly calibrate certain aircraft instruments and systems are an unnecessary cost impost on some sections of the aviation industry in Australia and are unwarranted.
By not requiring a section of the Australian fleet to perform regular maintenance on certain equipment when they are potentially operating in the same airspace as aircraft being maintained may increase the risk of loss of separation.
A Discussion Paper will be prepared and released to determine the extent of the concern regarding the costs of these maintenance actions for aircraft operating under the VFR and the associated risks. This may lead to further consultation linked to regulatory changes.
Project objective
To release a Discussion Paper to present the issues and, following review of responses, determine if further action is warranted.
Rules affected
CAR 39, CAR 41, CASR 91, CAO 100.5
Status
This project was approved by: Peter Boyd on 22 October 2013.
Project management
Project Leader/s: Charles Lenarcic
Project Sponsor/s: Peter Boyd, Executive Manager Standards Division
Standards Officer/s: Mick McGill
Project Priority
Medium