Discussion Paper
Maintenance Personnel Licensing for
Small Aircraft
Annex A
Consolidated Summary of Comments/Responses received to
NPRM 0804MS – A Proposal to Modernise Rules for the
Licensing of Maintenance Personnel for Small Aircraft
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Discussion Paper
Maintenance Personnel Licensing for
Small Aircraft
Consolidated Summary of Comments/Responses received to
NPRM 0804MS – A Proposal to Modernise Rules for the
Licensing of Maintenance Personnel for Small Aircraft
Addition of a small aircraft licence category in CASR Part 66
(as foreshadowed in NPRM 0804MS)
There were a total of 105 responses received to the NPRM 0804MS. CASA thanks all those who
contributed their time and thought in providing comment. Similar comments have been
consolidated. The responses were taken into consideration in the development of this DP. The
responses were made up as follows:
Acceptable without change
2
Acceptable but could be improved with some changes
0
Not acceptable but would be acceptable if some changes were made
6
Not acceptable under any circumstances
87
No opinion
10
Consolidated Summary of Comments
Comment 1 – General
If we want to adopt a foreign system, the FAA is more akin to our needs. However, as Australian
needs are unique, why do we need to adopt other agencies’ processes? Our current safety record
is second to none – please let it remain that way.
Comment 2 – General
Lowering age from 21 to 18 for B3/B4 licence is unacceptable and will compromise safety. No
18yr old is responsible at that age to hold such a responsibility. Lowering experience level from 4
years to 3 for issue of B3/B4 licence (4 years is an absolute minimum) is unacceptable.
Comment 3 – General
The B4 is not proposed for EASA – it is a new Australian invention we would be the only
country in the world to use it. The entire proposal is career inhibiting and a restrictive
methodology introducing a two tiered system not conducive to transition between employers.
Comment 4 – General
Avionics installed on GA aircraft is in many cases becoming more complex than in the Airlines
and any skill level short of complete understanding of the integration will lead to maintenance
errors. For this reason the B3/B4 is simply impractical. E.g. unlike the “avionics suites” installed
in airlines, a modern Garmin unit can interface to practically every known system manufactured
by another party. Understanding this integration is crucial for assuring airworthiness and simply
beyond the scope of a simple B3/B4 licence scheme.
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Maintenance Personnel Licensing for
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Comment 5 – General
CASA has not explained the reasons behind changing the current system. Why do we need to be
the same as the EU? Why change the current system that is based on aircraft safety, to one that is
based on economics?
Comment 6 – General
I do not believe that an 18 year old with 3 years of experience in training has the maturity or
experience to be responsible for releasing aircraft for flight. I feel that this situation could lead to
employers pressuring teenagers to release aircraft which are not airworthy. I urge you to
reconsider this proposal in the interests of flight safety in Australia.
Comment 7 – General
Avionics is not so different from the engine category in that it can be fitted to many different
airframes. There is room for a group 20 avionics rating (additional to the existing groups 1 thru
12) but it must be technically based on the avionic manufacturer’s suite. E.g Garmin G1000,
Rockwell Collins Proline 2, 4, 21 and Honeywell Apex types of avionics suites are fitted to many
different airframes.
Comment 8 – General
No mail out to Licensed Aircraft Engineers has occurred. There are potentially several thousand
LAMEs that have not been made aware of the proposed changes.
Comment 9 – General
A stronger explanation of what “Aerial work” is when compared to “General Aviation” and what
the differences are in respect to maintenance requirements should be provided. The ALAEA
considers aerial work as part of GA and not a separate industry.
Comment 10 – General
There must be an explanation of why a realignment of the licence structure is actually necessary.
No details of current “problems” have been noted in the NPRM with corresponding proposals to
correct these problems.
Comment 11 – General
Schedule 8 is a group of competencies to ensure pilots carry out basic maintenance tasks safely
and legally and should be technically formulated to meet required training standards for the issue
to a pilot as an MA attached to their licence, which should require them to meet ALL of the
competencies for the issue thereof and as such should not be included in the proposed Part 66
licensing.
Comment 12 – General
At present the aircraft trade course teaches both the fixed wing and rotary wing aspects of the
trade and also the piston and jet theory, so why is CASA proposing that an apprentice must
choose to concentrate on only half of these during their apprenticeship?
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Comment 13 – General
My view on licensing is that the current system works well and already caters for the various
types of airframe, be it wood, fabric, metal, composite etc and has provision for new development
and technology to be covered under existing licence groups.
Comment 14 – General
There is no safety basis to assume that persons working and certifying small aircraft as proposed
under the new rules should be any less mature and experienced to those working on groups
19/20/21/22 classified aircraft.
Comment 15 – General
There is currently no requirement for a person to hold an aircraft trade qualification prior to
obtaining an AME licence. This would be an ideal opportunity to correct this and to enhance the
skill and quality level of Australian LAMEs.
Comment 16 – General
The reasons for change as noted in section 3.3 of the NPRM are totally without foundation or
substance. The existing system has served well for decades and requires no more than minor
refinement, at most.
Comment 17 – General
To be consistent with the Chicago Convention as required by the Act, the licence structure should
be based on Annex 1 and not EASA or other NAA licence structures. Application of Annex 1 to
this proposal would provide a proper licence structure similar to what is being proposed in
Option 1.
Comment 18 – General
The proposal must get away from the current Schedule 6 concept where the LAME has to certify
for completion of maintenance tasks and stages of maintenance – that is a qualified AME’s
responsibility.
Comment 19 – General
The licensing system, as it stands now, works. What is needed is proper apprentice training in the
TAFEs. The practical side has been taken out of the college training and needs to be put back in.
Reports from apprentices indicate that the TAFE exam system is a waste of time. Sort the TAFEs
out, get them training AMEs properly, and use the CASA exam system during the apprenticeship.
Comment 20 – General
The proposed licence system is a bad idea for anyone other than the AMOs. It will make it harder
for LAMEs to move around and it will keep the wages down. You will not be making it easier
nor more enticing for young people to enter the industry and there will be a good number of
disgruntled senior LAMEs who may decide to take an early retirement.
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Comment 21 – General
The proposed system will provide the ability to specifically tailor training and licensing to a
given situation. While this initially sounds like desirable it is very restrictive for both organisation
and individual. It will mean the individual will have to get more training and apply for more
endorsements as requirements change or if the individual moves on. Who will pay for this – both
money and time?
Comment 22 – General
To implement what CASA wants would considerably increase the cost of becoming licensed to
the individual or AMO. It is hard enough to entice people into, or stay in this industry as it is with
the low pay to high responsibility of the job to comparative trades. How will increasing the cost
help bring new blood into an industry with an aging workforce?
Comment 23 – General
The existing licence structure is fine the way it is. Why do we need a 2 stroke rating? FADEC
shouldn’t require a further rating. CRS after annual inspection can be broadened within the
current structure. The current group1 rating (AF) seems to cover more than the proposed
subcategories plus extensions.
Comment 24 – General
The training/experience and AME requirements proposed seem to fall short of the mark. As I
read it, upon completion of part of certificate IV plus two years’ work experience an 18yr old can
have CRS responsibilities.
Comment 25 – General
Retain the existing licence plus ratings. Expand CRS privileges to all group 1 A/F licence
holders. CRS for all aircraft under the group 1 would be a good cost-saving for smaller AMOs.
Comment 26 – General
I find it incredible that CASA is proposing reducing the safety of general aviation (GA) by
reducing the time and age requirements for LAMEs and allowing a 3rd yr apprentice to certify for
aircraft. I totally disagree with the de-skilling of aircraft maintenance and feel it is attempting to
reduce expenses at a great risk to the flying public. I feel CASA would be well advised to
consider the ALAEAs comments to this proposal. This is an opportunity to ensure that safety and
quality workmanship prevails in GA.
Comment 27 – General
We need a licensing and airworthiness system that is recognised by say the US, Canada and New
Zealand as being totally interchangeable and reciprocal with their ICAO compliant licences.
Surely by now you must realise how counterproductive this ‘extension’ system is? Our training
systems should remain only upgraded and modernised, but still cover grouping and cross
categories – TAFE.
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Comment 28 – General
Other States have enshrined the ICAO recommended licensing system in law, e.g. US, Canada
and NZ. Australia is obligated to provide a licensing system that equates to those global NAA
licences today in force.
Comment 29 – General
The proposal is confusing to say the least because of the conflict between who can perform the
work and who can certify for the work. We are building greater divide between all sectors of the
industry and the role or usage of an aircraft is irrelevant to a licensing situation. I really don’t
think the SCC filled with operators really understands the issues at all.
Comment 30 – General
The proposed scopes of B3 and B4 ratings are confused. It would be better to incorporate the
current licence structures in to the new format.
Comment 31 – General
By reducing licence requirements and privileges to reduce training time you are effectively
“dumbing down” overall engineering quality. This will result in a poorer standard of
maintenance. This is unacceptable.
Comment 32 – General
B3/B4 licences won’t be recognised internationally – structures and powerplants are separate
fields of engineering. Don’t assimilate them, as maintenance standards will fall. These are
unacceptable.
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