Ultralights
7th Dec 2004, 06:26
his email requires your undivided but brief attention.
CASA have proposed a massive list of regulations (see below) as a collective "Engineering Suite" under an NPRM. It is essential that you reply to NPRM0407MS because these regulations represent a serious threat to you ability to fly without unnecessary cost or restriction. Absolutely no justification has been advanced for these new rules, and their associated costs and restrictions, let alone any Costs/Benefits justification. They are not the answer to any safety problem.
you can cut, paste and print the response below and fax or post it to CASA or use it to fill in the CASA online response form. CASA details are:
Fax: 1800 653 897
Post: (no stamp required in Australia)
Reply Paid 2005
Regulatory Documentation Coordinator
CASA Standards Administration & Support Branch
Canberra ACT 2601, Australia
Online: http://rrp.casa.gov.au/respond
What is wrong with the suite?
These proposed rules, individually and collectively, will greatly increase costs, decrease availability of maintenance services, and put many LAMEs out of business. These proposed rules, if ever enacted, will constructively ground a significant proportion of the GA fleet.
They are Australian unique, complex, convoluted, in some areas unworkable at any cost.
Without reason, this rules package is very different to US/Canadian/NZ practice, and introduces some very severe limitations on current and long standing proven practices and procedures. There is simply nothing about Australian aviation that demands vastly increased maintenance costs, compared to the US, NZ or Canada.
The list of shortcomings is very long, but just for starters:
This proposal does not comply with:
(1) Current CASA directives for simple outcome based, safety justified regulation.
(2) Government regulation making policy generally, and;
(3) Government Aviation Policy, or;
(4) Productivity Commission, Office of Regulation Review, mandatory guidelines, and;
(5) Does not harmonise with ICAO, FAA, NZ or generally accepted practices.
The following organizations have already rejected the proposals outright, or have registered very strong reservations or objections;
(1) AOPA, and;
(2) AMROBA, the Australian Maintenance, Repair, and Overhaul Business Association, covering the people who probably maintain your aircraft, and;
(3) SAAA, the Sports Aircraft Association of Australia, and;
(4) AAAA, the Aerial Agriculture Association of Australia, and;
(5) RAAA, the Regional Aviation Association of Australia, and;
(6) Qantas Airways Ltd., and Virgin Blue, and;
(7) Several of the most significant Regional airlines, and;
(8) HAA, the Helicopter Association of Australia.
DESPITE THE ABOVE, WE NEED YOUR RESPONSE, FROM THE GRASSROOTS OF AVIATION.
JUST A VERY FEW OF THE MANY OBJECTIONABLE THINGS THAT IMPACT YOU, AS AN AIRCRAFT OWNER OF PILOT;
(1) With Part 61, constructively eliminates pilot maintenance of Private aircraft, something we have been doing without problems since the Wright brothers.
(2) Severely restricts the repair and overhaul your LAME can do in the course of maintenance. It is not even clear that you or a LAME can change a tyre in the field. The cost implication on these new restrictions are frightening.
(3) The rules are designed for CASA micro management and control of large workshops, the cost burden on the many little companies who maintain the bulk of the GA fleet will be impossible to sustain.
(4) Re-introduces all sorts of impossible paperwork problems for spare parts and overhaul of parts and components. The cost implications are really scary.
(5) Re-introduces the problem of whether you can even clean your windscreen, without "approved data", and similar silly nonsense that was rife several years ago.
(6) Will result in what is now legitimate maintenance becoming illegal, driving maintenance underground, hardly good for air safety.
What is our response?
Please forward your response to CASA by 10 December 2004 by one of the following means:
Online (preferred method):
rrp.casa.gov.au/respond
Fax:
To: Regulatory Documentation Coordinator
1800 653 897 (free call) or international +612 6217 1691 Post (no stamp required in Australia):
Reply Paid 2005
Regulatory Documentation Coordinator
CASA Standards Administration & Support Branch
Canberra ACT 2601, Australia
E-mail (use the response format in this NPRM):
[email protected]
Key Change Proposals (refer to NPRM Section 3) CASA invites you to advise your opinion, or otherwise for the key proposals contained in this NPRM by indicating your preference and commenting below:
The regulations have been restructured in a number of places and the provisions have moved in some cases from one Part to another (Although there was no change in technical content)
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
This proposal is completely unacceptable in it's present form, it
produces an entirely Australian unique set of maintenance rules,
complex, convoluted and contradictory, with unknown but very
substantial cost increases, for no safety benefit.
The administrative provision necessary to issue and manage certificates and licences have been amended and included into the respective Parts 66, 144, 145, 147 and 183
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
In Part 43, the concepts of scope and coverage for licence and certificate holders has been reduced to simply scope and that scope forms a standard in the MOS with an associated clarification of the demarcation between work on an aircraft and work on aeronautical products
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
In Part 43, who can carry out, supervise, coordinate and return to service maintenance has been restructured into Tables that incorporate information from previous regulations
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
Part 43 has been reduced in detail with the removal of the list of preventive and supplementary maintenance, the removal of the detail of what may be major repairs and modifications from regulation and the removal of the technical detail of the Altimeter and Transponder test specifications from the regulations
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
The number of licence categories in Part 66 has been reduced with the removal of the lighter-than air to an AMS-4 certificate
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
Part 66 introduces line extension ratings to cover certain aspects of maintenance a licence holder may be qualified to do in the line maintenance environment
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
An "Aircraft Metal Structures" rating has been introduced to cover the repair of aircraft metal structures
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
The original proposal in NPRM 0113MS for an "Aircraft Taxiing" rating has been withdrawn
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [ ] not acceptable under any circumstances
Comments:
In Part 66, the scope of the AMS-2 certificate was revised and split into the new AMS-2 and a new AMS-5 certificate
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
The original proposal in NPRM 0113MS allowing an AMPA to issue an AMS-1 or AMS-3 certificate has been withdrawn
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
Subpart 91.M is now used as the core set of maintenance regulations for all types of operation and as a result the registered operator requirements and the requirements for AMPs, maintenance records, role equipment maintenance and engine on condition checking programs have been incorporated into Subpart 91.M
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [ ] not acceptable under any circumstances
Comments:
The complete set of Minimum Equipment List (MEL) requirements have been taken from the various Subparts and placed in a new Subpart V to Part 91
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
To be consistent with the operational regulations Part 121B has been replaced by Part 135 and Part 133 has been divided into Part 133A for air transport operations and Part 133B for aerial work operations. (Note there is no Subpart 133B.M)
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [X] not acceptable but would be acceptable if changes were made [ ] not acceptable under any circumstances
Comments:
See AMROBA COMMENTS
Continued over next post........
Certain maintenance support requirements, weight and balance provisions and air operator certificate (AOC) holder related provisions have been included in the Subparts 121.M, 133A.M and 135.M
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
In Parts 144, 145, 147 and 183, the provisions for certificates to remain valid for three years has been removed in favour of perpetual certificates
[ ] proposal is acceptable without change [X] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [ ] not acceptable under any circumstances
Comments:
In Part 144, the provision of classes of activity and associated ratings has been removed in favour of a general description of distribution activities
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
The requirement for a safety management system (SMS) has been removed from Parts 144 and 145
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [ ] not acceptable under any circumstances
Comments:
Unique provisions for foreign (overseas) maintenance organisations and maintenance training organisations have been deleted from Parts 145 and 147
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
Part 147 introduces a requirement for competency assessor to be an authorised person (AMPA) and authorisation will continue to be required for examiners of non-accredited courses (the previous Examiner Authority) and for assessors of PCT trainees
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
In Part 183, the classes of authorised representative have been reduce to AAR and AMPA with the removal of the AER, DAME, and DAO
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
In Part 183, a provision to allow the delegation of functions in Part 21 to a class of AAR has been introduced
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [ ] not acceptable under any circumstances
Comments:
In Part 43, the reservation of the provision excluding certain experimental and amateur built aircraft from the provisions of Part 43
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
The above aircraft have to be excluded entirely from Part 43, as
per the FAA Part 43, as has been explained to CASA at length.
Otherwise it will result in the grounding of all Experimental
including amateur built, and Limited Category, directly contrary
to long established Government policy and existing legislation.
In Part 43, the removal of the reference to coordination in what constitutes certification for maintenance
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
In Part 145, the removal of the relief for one-person organisations in documenting their management system
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
General and Specific Comments
Your response to the draft regulations for Maintenance and Maintenance Personnel Having read the draft regulations for Maintenance and Maintenance Personnel (NPRM Annex A) are there specific issues that you wish to see addressed? Please indicate by specifying the relevant Regulation Number, any change to that Regulation you believe will add value to the draft regulations, and a short explanation of your reason for proposing the change.
Regulation No. Change(s) that you Explanation
consider appropriate
(please suggest change)
See in detail the comments by AMROBA
Your response to the draft Manuals of Standards (MOS) Parts 43, 66, 121.M, 133A.M, 135.M, 145, 147 and 183 Having read the relevant draft Manuals of Standards (MOS) (NPRM Annex B) are there specific issues that you wish to see addressed? Please indicate by specifying the relevant MOS Number, Section Number, any change to that Section you believe will add value to the draft MOS, and a short explanation of your reason for proposing the change.
Section No. Change(s) that you consider Explanation
appropriate
(please suggest change)
The whole issue of Manuals of Standards must be reconsidered in
light of the re-statement of long standing Government policy and
the Directive 16 of the Director of Aviation Safety, Mr. Bruce
Byron, published on 24 November 2004
Any Additional Comments
"This proposal is completely unacceptable in it\'s present form,
it produces an entirely Australian unique set of maintenance
rules, complex, convoluted and contradictory, with unknown but
very substantial cost increases, for no safety benefit.
It must be completely re written to comply with the Government
aviation policy and the announcements of Bruce Byron on 24
November 2004"
Completely unjustified new restrictions on who, when, where and
how maintenance can be done are proposed, with unknown increased
costs, for no safety benefit, let alone costs and benefits
justified changes.
Accountability for spare parts as proposed is unworkable, let
alone the costs associated, without any safety justification.
There is NO SAFETY PROBLEM to which this is the answer.
I am not going to even attempt to cite individual rules that
should be changed, the whole framework is non-compliant, and this
must be corrected first.
If you are really a masochist, here are the links that make up
all the parts of the "Engineering Suite", they simply will not
work. The package, with literally thousands of pages of
Regulation and Manuals of Standards, is internally contradictory,
quite apart from all the other unacceptable features.
I will guarantee that no more than a handful of us have gone
through all or most of it, AOPA has no doubt that this is what is
intended. Make it so huge, most people will just not bother.
Rules affected: proposed CASR Parts 43, 66, 144, 145, 147, 183 and Subparts 91.M (incorporating previously proposed 136.M and 137.M), 121.M, 133A.M, and 135.M.
Document no.: NPRM 0407MS which comprises Introduction, Proposal (20K ) Annex A Proposed legislative changes (1.28MB ) Annex B Proposed Manuals of Standards (207K )
·
CASA have proposed a massive list of regulations (see below) as a collective "Engineering Suite" under an NPRM. It is essential that you reply to NPRM0407MS because these regulations represent a serious threat to you ability to fly without unnecessary cost or restriction. Absolutely no justification has been advanced for these new rules, and their associated costs and restrictions, let alone any Costs/Benefits justification. They are not the answer to any safety problem.
you can cut, paste and print the response below and fax or post it to CASA or use it to fill in the CASA online response form. CASA details are:
Fax: 1800 653 897
Post: (no stamp required in Australia)
Reply Paid 2005
Regulatory Documentation Coordinator
CASA Standards Administration & Support Branch
Canberra ACT 2601, Australia
Online: http://rrp.casa.gov.au/respond
What is wrong with the suite?
These proposed rules, individually and collectively, will greatly increase costs, decrease availability of maintenance services, and put many LAMEs out of business. These proposed rules, if ever enacted, will constructively ground a significant proportion of the GA fleet.
They are Australian unique, complex, convoluted, in some areas unworkable at any cost.
Without reason, this rules package is very different to US/Canadian/NZ practice, and introduces some very severe limitations on current and long standing proven practices and procedures. There is simply nothing about Australian aviation that demands vastly increased maintenance costs, compared to the US, NZ or Canada.
The list of shortcomings is very long, but just for starters:
This proposal does not comply with:
(1) Current CASA directives for simple outcome based, safety justified regulation.
(2) Government regulation making policy generally, and;
(3) Government Aviation Policy, or;
(4) Productivity Commission, Office of Regulation Review, mandatory guidelines, and;
(5) Does not harmonise with ICAO, FAA, NZ or generally accepted practices.
The following organizations have already rejected the proposals outright, or have registered very strong reservations or objections;
(1) AOPA, and;
(2) AMROBA, the Australian Maintenance, Repair, and Overhaul Business Association, covering the people who probably maintain your aircraft, and;
(3) SAAA, the Sports Aircraft Association of Australia, and;
(4) AAAA, the Aerial Agriculture Association of Australia, and;
(5) RAAA, the Regional Aviation Association of Australia, and;
(6) Qantas Airways Ltd., and Virgin Blue, and;
(7) Several of the most significant Regional airlines, and;
(8) HAA, the Helicopter Association of Australia.
DESPITE THE ABOVE, WE NEED YOUR RESPONSE, FROM THE GRASSROOTS OF AVIATION.
JUST A VERY FEW OF THE MANY OBJECTIONABLE THINGS THAT IMPACT YOU, AS AN AIRCRAFT OWNER OF PILOT;
(1) With Part 61, constructively eliminates pilot maintenance of Private aircraft, something we have been doing without problems since the Wright brothers.
(2) Severely restricts the repair and overhaul your LAME can do in the course of maintenance. It is not even clear that you or a LAME can change a tyre in the field. The cost implication on these new restrictions are frightening.
(3) The rules are designed for CASA micro management and control of large workshops, the cost burden on the many little companies who maintain the bulk of the GA fleet will be impossible to sustain.
(4) Re-introduces all sorts of impossible paperwork problems for spare parts and overhaul of parts and components. The cost implications are really scary.
(5) Re-introduces the problem of whether you can even clean your windscreen, without "approved data", and similar silly nonsense that was rife several years ago.
(6) Will result in what is now legitimate maintenance becoming illegal, driving maintenance underground, hardly good for air safety.
What is our response?
Please forward your response to CASA by 10 December 2004 by one of the following means:
Online (preferred method):
rrp.casa.gov.au/respond
Fax:
To: Regulatory Documentation Coordinator
1800 653 897 (free call) or international +612 6217 1691 Post (no stamp required in Australia):
Reply Paid 2005
Regulatory Documentation Coordinator
CASA Standards Administration & Support Branch
Canberra ACT 2601, Australia
E-mail (use the response format in this NPRM):
[email protected]
Key Change Proposals (refer to NPRM Section 3) CASA invites you to advise your opinion, or otherwise for the key proposals contained in this NPRM by indicating your preference and commenting below:
The regulations have been restructured in a number of places and the provisions have moved in some cases from one Part to another (Although there was no change in technical content)
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
This proposal is completely unacceptable in it's present form, it
produces an entirely Australian unique set of maintenance rules,
complex, convoluted and contradictory, with unknown but very
substantial cost increases, for no safety benefit.
The administrative provision necessary to issue and manage certificates and licences have been amended and included into the respective Parts 66, 144, 145, 147 and 183
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
In Part 43, the concepts of scope and coverage for licence and certificate holders has been reduced to simply scope and that scope forms a standard in the MOS with an associated clarification of the demarcation between work on an aircraft and work on aeronautical products
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
In Part 43, who can carry out, supervise, coordinate and return to service maintenance has been restructured into Tables that incorporate information from previous regulations
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
Part 43 has been reduced in detail with the removal of the list of preventive and supplementary maintenance, the removal of the detail of what may be major repairs and modifications from regulation and the removal of the technical detail of the Altimeter and Transponder test specifications from the regulations
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
The number of licence categories in Part 66 has been reduced with the removal of the lighter-than air to an AMS-4 certificate
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
Part 66 introduces line extension ratings to cover certain aspects of maintenance a licence holder may be qualified to do in the line maintenance environment
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
An "Aircraft Metal Structures" rating has been introduced to cover the repair of aircraft metal structures
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
The original proposal in NPRM 0113MS for an "Aircraft Taxiing" rating has been withdrawn
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [ ] not acceptable under any circumstances
Comments:
In Part 66, the scope of the AMS-2 certificate was revised and split into the new AMS-2 and a new AMS-5 certificate
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
The original proposal in NPRM 0113MS allowing an AMPA to issue an AMS-1 or AMS-3 certificate has been withdrawn
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
Subpart 91.M is now used as the core set of maintenance regulations for all types of operation and as a result the registered operator requirements and the requirements for AMPs, maintenance records, role equipment maintenance and engine on condition checking programs have been incorporated into Subpart 91.M
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [ ] not acceptable under any circumstances
Comments:
The complete set of Minimum Equipment List (MEL) requirements have been taken from the various Subparts and placed in a new Subpart V to Part 91
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
To be consistent with the operational regulations Part 121B has been replaced by Part 135 and Part 133 has been divided into Part 133A for air transport operations and Part 133B for aerial work operations. (Note there is no Subpart 133B.M)
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [X] not acceptable but would be acceptable if changes were made [ ] not acceptable under any circumstances
Comments:
See AMROBA COMMENTS
Continued over next post........
Certain maintenance support requirements, weight and balance provisions and air operator certificate (AOC) holder related provisions have been included in the Subparts 121.M, 133A.M and 135.M
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
In Parts 144, 145, 147 and 183, the provisions for certificates to remain valid for three years has been removed in favour of perpetual certificates
[ ] proposal is acceptable without change [X] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [ ] not acceptable under any circumstances
Comments:
In Part 144, the provision of classes of activity and associated ratings has been removed in favour of a general description of distribution activities
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
The requirement for a safety management system (SMS) has been removed from Parts 144 and 145
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [ ] not acceptable under any circumstances
Comments:
Unique provisions for foreign (overseas) maintenance organisations and maintenance training organisations have been deleted from Parts 145 and 147
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
Part 147 introduces a requirement for competency assessor to be an authorised person (AMPA) and authorisation will continue to be required for examiners of non-accredited courses (the previous Examiner Authority) and for assessors of PCT trainees
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
In Part 183, the classes of authorised representative have been reduce to AAR and AMPA with the removal of the AER, DAME, and DAO
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
In Part 183, a provision to allow the delegation of functions in Part 21 to a class of AAR has been introduced
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [ ] not acceptable under any circumstances
Comments:
In Part 43, the reservation of the provision excluding certain experimental and amateur built aircraft from the provisions of Part 43
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
The above aircraft have to be excluded entirely from Part 43, as
per the FAA Part 43, as has been explained to CASA at length.
Otherwise it will result in the grounding of all Experimental
including amateur built, and Limited Category, directly contrary
to long established Government policy and existing legislation.
In Part 43, the removal of the reference to coordination in what constitutes certification for maintenance
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
In Part 145, the removal of the relief for one-person organisations in documenting their management system
[ ] proposal is acceptable without change [ ] acceptable but would be improved if changes were made [ ] not acceptable but would be acceptable if changes were made [X] not acceptable under any circumstances
Comments:
General and Specific Comments
Your response to the draft regulations for Maintenance and Maintenance Personnel Having read the draft regulations for Maintenance and Maintenance Personnel (NPRM Annex A) are there specific issues that you wish to see addressed? Please indicate by specifying the relevant Regulation Number, any change to that Regulation you believe will add value to the draft regulations, and a short explanation of your reason for proposing the change.
Regulation No. Change(s) that you Explanation
consider appropriate
(please suggest change)
See in detail the comments by AMROBA
Your response to the draft Manuals of Standards (MOS) Parts 43, 66, 121.M, 133A.M, 135.M, 145, 147 and 183 Having read the relevant draft Manuals of Standards (MOS) (NPRM Annex B) are there specific issues that you wish to see addressed? Please indicate by specifying the relevant MOS Number, Section Number, any change to that Section you believe will add value to the draft MOS, and a short explanation of your reason for proposing the change.
Section No. Change(s) that you consider Explanation
appropriate
(please suggest change)
The whole issue of Manuals of Standards must be reconsidered in
light of the re-statement of long standing Government policy and
the Directive 16 of the Director of Aviation Safety, Mr. Bruce
Byron, published on 24 November 2004
Any Additional Comments
"This proposal is completely unacceptable in it\'s present form,
it produces an entirely Australian unique set of maintenance
rules, complex, convoluted and contradictory, with unknown but
very substantial cost increases, for no safety benefit.
It must be completely re written to comply with the Government
aviation policy and the announcements of Bruce Byron on 24
November 2004"
Completely unjustified new restrictions on who, when, where and
how maintenance can be done are proposed, with unknown increased
costs, for no safety benefit, let alone costs and benefits
justified changes.
Accountability for spare parts as proposed is unworkable, let
alone the costs associated, without any safety justification.
There is NO SAFETY PROBLEM to which this is the answer.
I am not going to even attempt to cite individual rules that
should be changed, the whole framework is non-compliant, and this
must be corrected first.
If you are really a masochist, here are the links that make up
all the parts of the "Engineering Suite", they simply will not
work. The package, with literally thousands of pages of
Regulation and Manuals of Standards, is internally contradictory,
quite apart from all the other unacceptable features.
I will guarantee that no more than a handful of us have gone
through all or most of it, AOPA has no doubt that this is what is
intended. Make it so huge, most people will just not bother.
Rules affected: proposed CASR Parts 43, 66, 144, 145, 147, 183 and Subparts 91.M (incorporating previously proposed 136.M and 137.M), 121.M, 133A.M, and 135.M.
Document no.: NPRM 0407MS which comprises Introduction, Proposal (20K ) Annex A Proposed legislative changes (1.28MB ) Annex B Proposed Manuals of Standards (207K )
·