CAO 100.5
Dick,
By less prescriptive I guess you are referring to the NZ allowance for acceptable means of compliance and the following exemption from Canada:
"(b) The annual calibration requirement of (a) does not apply to an aircraft operating under an air operator certificate, or to any large or turbine-powered pressurized aircraft, where:
(i) the aircraft is equipped with two independent stabilized magnetic direction indicators in addition to the non-stabilized direct reading magnetic direction indicator; and"
(ii) a procedure for monitoring and recording the performance of the magnetic direction-indicators is detailed in the flight training unit's, or in the air operator's approved maintenance control manual approved pursuant to CAR 406 and CAR 706 respectively."
I fail to see how this is less prescriptive than the exemption requirements of CAO100.5:
"exempted aircraft:
means an aircraft with an approved system of maintenance
(SOM) under regulation 42M of CAR 1988, or with a maintenance schedule under regulation 41 of CAR 1988, but only if the SOM or the schedule incorporates instructions for the continuing airworthiness of instruments and instrument systems fitted to the aircraft that would otherwise be subject to the additional maintenance requirements set out in clauses 2 to 6 of this Appendix."
Do I work for CASA? NO.
Have I ever worked for CASA? NO.
Can you say the same?
Surely a well supported industry petition (there are plenty of people here who would submit) with evidence (costs you are claiming) to have the wording a CAO100.5 amended to require the checks at the first Maintenance Release issue after the date of expiry (much like weight and balance checks) would be a more valuable use of your considerable financial and political clout than complaining on a public forum.
This would ensure the checks were only done during times when a LAME(and in the case of helicopters a pilot) was required anyway and a safety case should not be too hard to build for this.