CASA part66 licensing issues
I am a Licensed Aircraft Maintenance Engineer and a private pilot. I would like to raise some concerns I have with the new Part 66 way of licensing aircraft maintenance engineers. I believe this change will in time lead to much high aircraft maintenance cost for GA aircraft owners.
A B1 engineer qualified under the new arrangements will not be able to certify for any instrument maintenance or a radio system periodic inspection on a VFR aircraft. Instead of your local GA maintenance facility being able to do all the maintenance on your VFR aircraft (Excluding Radio Installs and AD/RAD/47 etc). They will not even be able to do a 100hrly on your most basic Cessna 172 without getting in a B2 LAME to certify for the Radio and Instrument Periodic Inspection. As you can imagine this extra cost of having a B2 LAME to complete the inspection will make any remote maintenance shop very expensive. My workplace is only 1.5 hours from the closest B2 LAME, but paying for them to travel out every time we do a 100hrly would be very expensive. (Currently we have no other option if the aircraft is IFR)
Another issue is the way the new Part 66 licence severely limits a LAME in advancing his skills. Under CAR31 an AME can sit exams in his own time whilst working full time and when he has passed the required exam(s) he can then submit his experience. This is a relatively inexpensive and simple process. And allows a LAME to accrue additional licenses and privileges throughout his/her career. The Part 66 license currently doesn’t allow an engineer to gain a basic license and then build on it over time gradually adding things like a Radio license, turbo’s, air conditioning, hydraulics and pressurisation to name a few.
I think that for the sake of the continuation of GA we need to keep the CAR31 licensing structure indefinitely, with some improvements. A CAR31 Group 1 Airframe license came with the following additional privileges:
It covered all Electrical and Instrument maintenance on VFR aircraft and Radio Periodic Inspections on VFR aircraft.
However it didn’t include any privileges for multi-axis auto-pilots or remote indicating compasses. The implications being that a B2 LAME has to sign off the annual inspection on an RV6 with altitude hold, or a VH registered Sportstar with an Aspen. The privileges need to be expanded to cover a periodic inspection on those systems. Another improvement would be to allow an Airframe LAME to carry out the RAD47 transponder checks on VFR aircraft after receiving the appropriate training and having the correct equipment.
I would go so far as to say, there is no reason a CAR31 airframe LAME shouldn’t be able to certify for the above maintenance on a Private IFR aircraft. The only difference is the category that the aircraft is flying in. What is more important than who is doing the maintenance is what is being done? I.e. for IFR aircraft, I believe all the instrument lifed components should be up to speed with the manufactures recommendations. Vac pumps, hoses, plenums, and standby pumps should all be done as per the manufacturer. Not always done unfortunately.