CASA part66 licensing issues
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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.
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.
Join Date: Aug 2011
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Transitional nightmare!
A very valid argument to be made here RooDog and a debate that is had around the smoko table at least weekly!
Currently I am stuck smack bang in the middle, I have amassed more than enough SOE over the years and have done a few CAR31 airframe/engine basics, I have seen each end of the argument, working in both Part145 MRO's and CAR30 GA shops. Personally I love GA and that is where I wish to stay, unfortunately at the moment nobody can give me a clear answer on what is the clearest pathway to take in regards to attaining a license outcome due to the fact I am not pursuing a type rated license.
Our regulator cannot give me a clear and definitive answer on the best course of action and continually recommend I RPL a diploma of aviation with a Part147 trainer but still cannot tell me what class/type of license I will attain. Certain 147's will not even offer advice until you agree to foot the 2K RPL fee.
There has been rumours of a new (B3) small aircraft license, which apparently will give the holder the same entitlements as the old system - one can only hope.
In the meantime, I have decided to finish all my basics for 1/2/5/6/10/19 AF and 1/2/3 + PT6 engine.
With the extension until 2019, this seems to Be the most economical and straight forward decision. The way I see it, if I have full SOE and all exams completed, they have to issue me with some form of license!
In my view GA wasn't broken, why try to fix it!
Cheers.
Currently I am stuck smack bang in the middle, I have amassed more than enough SOE over the years and have done a few CAR31 airframe/engine basics, I have seen each end of the argument, working in both Part145 MRO's and CAR30 GA shops. Personally I love GA and that is where I wish to stay, unfortunately at the moment nobody can give me a clear answer on what is the clearest pathway to take in regards to attaining a license outcome due to the fact I am not pursuing a type rated license.
Our regulator cannot give me a clear and definitive answer on the best course of action and continually recommend I RPL a diploma of aviation with a Part147 trainer but still cannot tell me what class/type of license I will attain. Certain 147's will not even offer advice until you agree to foot the 2K RPL fee.
There has been rumours of a new (B3) small aircraft license, which apparently will give the holder the same entitlements as the old system - one can only hope.
In the meantime, I have decided to finish all my basics for 1/2/5/6/10/19 AF and 1/2/3 + PT6 engine.
With the extension until 2019, this seems to Be the most economical and straight forward decision. The way I see it, if I have full SOE and all exams completed, they have to issue me with some form of license!
In my view GA wasn't broken, why try to fix it!
Cheers.
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blah blah blah , we talk and no one listens . Owners don't give a rats because they just see a bill, they know its going to be high , and don't see the process behind it.
Go where the smart money is and get that B2. Be like me and become the full bunch of Banana's . Might as well profiteer off that broken system
Go where the smart money is and get that B2. Be like me and become the full bunch of Banana's . Might as well profiteer off that broken system
We certainly were sold short on Part 66. The selling point rammed home was that if you could do it before you would be able to do it in future. Absolute bull**** from the CASA spin doctors.
https://www.casa.gov.au/standard-pag...stions-answers
Q. As a B1 LAME (on an VFR aircraft) what are my avionics and electrical privileges?
Licence maintenance certification privileges are those established by paragraph 66.A.20 and Table 1 of the Part 66 MOS. The transitional privileges mentioned in section 66.A.21 of the Part 66 MOS are only available to those LAME's converted from or qualifying under the previous regulation 31 of the CAR 1988 system. The transitional privileges do not include the avionics repairs and nor does 66.A.20 and Table 1 of the Part 66 MOS. For a B1 licence holder the transitional privileges are:
Rating held or qualified for was an engine category Group 1 or 2 rating, or an airframe category Group 1, 2 or 19 rating. Maintenance certifications and issue of certificates of release to service in relation to any of the following kinds of maintenance to which that licence or rating applied or would have applied: on aircraft approved only for V.F.R. operations: for aircraft general instruments (excluding RMI, inertial navigation and multi-axis autopilots), all instrument system maintenance; and for aircraft radio systems, periodic inspections;
Licence held or qualified for was an engine or airframe category rated licence. Maintenance certifications and issue certificates of release to service in relation to daily or manufacturers’ equivalent inspection; and check of the condition of security of attachment of wiring, plumbing, parts and appliances; and maintenance of instrument, or electrical, parts and appliances forming part of the powerplant, mechanical or structural systems, where the maintenance is limited to external mechanical adjustments to facilitate correct operation of powerplant or mechanical or structural systems; or is limited to replacement of instrument, or electrical, parts and appliances, connected by simple twist or terminal connectors. Excludes instrument or electrical parts and appliances, where maintenance involves functional tests and adjustments requiring the use of external specialised test equipment.
https://www.casa.gov.au/standard-pag...stions-answers
Q. As a B1 LAME (on an VFR aircraft) what are my avionics and electrical privileges?
Licence maintenance certification privileges are those established by paragraph 66.A.20 and Table 1 of the Part 66 MOS. The transitional privileges mentioned in section 66.A.21 of the Part 66 MOS are only available to those LAME's converted from or qualifying under the previous regulation 31 of the CAR 1988 system. The transitional privileges do not include the avionics repairs and nor does 66.A.20 and Table 1 of the Part 66 MOS. For a B1 licence holder the transitional privileges are:
Rating held or qualified for was an engine category Group 1 or 2 rating, or an airframe category Group 1, 2 or 19 rating. Maintenance certifications and issue of certificates of release to service in relation to any of the following kinds of maintenance to which that licence or rating applied or would have applied: on aircraft approved only for V.F.R. operations: for aircraft general instruments (excluding RMI, inertial navigation and multi-axis autopilots), all instrument system maintenance; and for aircraft radio systems, periodic inspections;
Licence held or qualified for was an engine or airframe category rated licence. Maintenance certifications and issue certificates of release to service in relation to daily or manufacturers’ equivalent inspection; and check of the condition of security of attachment of wiring, plumbing, parts and appliances; and maintenance of instrument, or electrical, parts and appliances forming part of the powerplant, mechanical or structural systems, where the maintenance is limited to external mechanical adjustments to facilitate correct operation of powerplant or mechanical or structural systems; or is limited to replacement of instrument, or electrical, parts and appliances, connected by simple twist or terminal connectors. Excludes instrument or electrical parts and appliances, where maintenance involves functional tests and adjustments requiring the use of external specialised test equipment.
