Revitalising General Aviation
REVITALISING GENERAL AVIATION
CREATING CAREER PATHWAYS
General aviation depends on modernising the current legislative, regulative and specific standards as they have done in the United States. The FAA modernisation program is continuing and is leaving Australia’s general aviation industry struggling to operate efficiently under a system that is archaic, to say the least.
The concept that the EASA engineering system is better than the FAA system in engineering, maintenance, manufacturing and AME licencing is a fallacy. We need the USA BASA so that CASA Type Certificates and STCs can obtain a FAA TC and/or STC. It is the FAA TC/STC that will enable access to the global aviation market more than the CASA TC/STC. The CASA STC holds little acceptance worldwide.
Let me make a prediction – 2017 will see a lot of engineering, maintenance, manufacturing & licencing issues addressed.
The May 25th Infrastructure/CASA Executive meeting with industry associations was constructive from AMROBA’s perspective. At least we now have people within CASA that will listen and make decisions that support harmonisation – if we base our issues on an ICAO Standard or Recommended Practice (SARP), then we can also convince minor changes to these SARPs to meet Australia’s geographical condition. Minor changes to meet where our businesses are located, etc. to provide career paths in the aviation industry, especially in rural Australia.
The people I am currently dealing within CASA are positively responsive.
To fix all the problems will take time, so we have to look at, and prioritise, the many issues confronting general aviation. Licencing, airworthiness, maintenance, design, manufacturing, inspection standards, etc.
After this meeting, the road back to a thriving industry depends on the changes that we can get out of CASA by the end of this year. AMROBA has spent, and is spending, some time in identifying and prioritising the changes and CASA is not putting up roadblocks.
Regulatory Reform/Development Past Failure to Future Success
In recent months the jobs debate is shifting toward something that could actually help: regulatory reform. The shift in strategy by government is a welcome move considering the incredible regulatory burden faced by our members and others in aviation. Reduce the burden and jobs will be created.
What a different regulatory system we would have had if government was concerned with the creation of jobs and career paths as well as maintaining safety. No amount of regulations will succeed unless people do the right thing – reduce the regulations and rely on individuals with the right attitude and aptitude to create improvements to safety.
How to Create Career Paths
Researching past history to find what worked and what didn’t should be the main aim at this stage of regulatory review. Pilot/LAME career paths that enabled entry into aviation anywhere in Australia opened up a career pathway to employment with major airlines. These career pathways must be created once again.
This means looking back at what worked best under the ANR/ANO era; the change to CAR/CAO era and what worked and what didn’t work. The next stage is to look at the CAR/CAO system to CASR/MoS and see what worked and what didn’t. What worked and now doesn’t work has to be reversed to get the career paths working again.
Australia is not USA, Canada, Europe, Asia or NZ. It is different geographically and lacks many services throughout rural Australia. General aviation was prosperous, efficient and safe prior to regulatory change that came with the creation of CAA.
Since then, GA has been opposing changes that has lost jobs, especially those systems from another country and the move away performance based requirements, to prescriptive requirements. Regulatory systems based on performance based requirements have worked very safely in GA under the previous regulatory system and are now globally being adopted.
1. Pilot shortage
- This started about mid 1990s but nobody looked at the regulatory change that created a completely different training environment; an environment that has seen reduced participation because the entry points were reduced. A system that made it harder and more costly for young people to become a pilot. This was the change from ANR/ANO to CAR/CAO change. Change from an individual licence system to organisation approval.
- This change virtually shut down the avenues for young people, mainly rural, from learning to fly. The ANR system had an independent flight instructor licence, just like the FAA independent flight instructors. This independent flight instructor licence attracted many young people into flying.
- Aviation was seen as a career path, especially for rural Australia, because many independent flight instructors were available to start the career path of many country students. A most cost effective system. Removing it from the VH regulated system but allowing it in the non-VH regime reduced the number of applicants/year seeking an aviation career pathway.
- The loss of these independent flight instructor licences also resulted in a reduction of flight training schools because the new entry level was now via a flying school holding an AOC. The number of flying schools reduced post the change from ANR/ANOs to CAR/CAOs. A regulatory change failure.
- Like the USA, these independent flight instructors introduced about 70% of the pilots into aviation as PPLs. By removing this avenue to flying, CASA then devolved this aspect to the non VH industry without a parallel pathway thus removing an ability to provide a cost effective system training in type certificated aircraft.
- This is one of the major reason why private aviation started to decline, it really had nothing to do with “other economic pressures”. This is an excuse by those that won’t admit changes can have unseen negative effects that should be rectified.
Findings & recommendations
- The change from ANR/ANO to CAR/CAO moved all training into aerialwork and the CAA Executive then determined all aerialwork operations required an AOC – big error. Not only did this affect the livelihood of many aerialwork operators, it also meant many jobs associated with aerialwork operating under a “licence” system suddenly had increased costs that closed them down in the early 1990s. Hundreds of jobs were lost.
- Many rural students realised that obtaining flight training from mostly independent flight instructors was the entry to a career in aviation. They would then do further training, usually at an approved flight school, to obtain qualifications to find employment in commercial aviation with many being picked up by airlines whenever they expanded.
- It was commonly stated that 70% of airline pilots came from rural Australia in that period, as did many maintenance engineers who also obtained employment with airlines. Rural Australians had a career path into aviation.
- Recommendation: Reintroduce the independent flight instructor rating based on the FAA system to create aviation career pathways and jobs, especially in rural Australia.
2. LAME Shortage
- This is an issue that has been made complex because regulatory changes, pre the creation of the CAA, introduced a decline to LAMEs remaining in the industry. CASA no longer has a database that identifies how many LAMEs are still in aviation.
- Currently aviation maintenance is not seen by students, leaving secondary education, as a career pathway. Similarities to the loss of the independent flight instructor, many maintenance careers were lost with the change from ANR/ANO to CAR/CAO.
- Pre the CAA, post the shift of the Authority’s HO to Canberra, the new CASA HO management in Canberra did not understand why CASA promulgated the AME syllabi based on the ICAO AME training manual. It was the national standard.
- Once the ICAO AME syllabi was repealed, different States, different RTOs developed separate AME training standards based on the Education Department’s training packages. Many RTOs training courses became specific for the larger employer. International harmonisation in skills and knowledge declined.
- Many employees from an allied industry trade, simply self-studied, passed “Basic Examinations” and obtained a licence after gaining sufficient experience. This is the same as the EASA system today.
- The Education training packages do not address all of the international training standards for an AME and LAME specific responsibilities.
- Another issue is that RTO training outputs no longer provided an AME with employable skills across the industry. Hundreds have been knowledge trained without obtaining employment in the industry. Many GA employees could not obtain piston engine or rotorcraft training.
- Regulatory changes have not clarified the LAME ICAO privileges and responsibilities; nor did they retain the international responsibility even though many have been trained but are unemployable as they do not have the skills.
- Training in Australia, with employment from remote areas to the major cities, clearly demonstrates that requiring all training to be formal training has impacted negatively on the whole industry.
- The introduction of a perpetual licence also introduced the FAA problem with A&P mechanic certificate holders. EASA, for just this reason, has a 5 year notification system so that they know who is still in the industry.
Findings & recommendations
- Continual changes over many years has slowly declined the skills below the international training standards promulgated by ICAO.
- Continual additional requirements being added to a trade training system without any expansion of the training course has resulted in lower skills.
- All aviation employer associations and operators have identified skill deficiencies that are preventing efficient operations, this was emphasised at the Federal Minister’s Aviation Industry Consultative Council earlier this year.
- JAA/EASA used the ICAO standards to develop new standards for licencing NOT training for AMEs. Australia has a decline in skills caused by moving away from the ICAO international trade training standards.
- FAA/EASA changes to the normal category aircraft certification standard will mean a wider skill set will be required. This will enable CASA to promulgate the international training standards to underpin the 5 licence categories adopted from EASR Part 66. The CASR Part 23 future 19 seat, 5820 Kgs normal category limitation now allows alignment of the AME licencing categories with aircraft certification categories.
- The international “privileges” of a LAME must be clarified in regulations & standards and supported by (hopefully) an on-line diploma course. Additional skills identified in the ICAO training manual should be the basis of a Chief Engineer course for new LAMEs.
- What worked in the past was the Authority’s stated responsibilities of the LAME as follows: “…includes certification of safety for flight of an aircraft; certification of documents for issue or renewal of a Certificate of Airworthiness; approval of subsequent flight test; certification for the issue of a maintenance release; certification of work carried out under regular maintenance schedules; certification after replacement of components; rectification of defects; and maintenance inspections.” In addition “must ensure that he had adequately supervised the work that established airworthiness standards have been maintained and the resulting condition is satisfactory in all aspects “
- ”Aircraft maintenance engineers are authorised by [CASA] to exercise stated privileges and accept responsibilities directly related to airworthiness. These LAMEs act on behalf of the [CASA] in ensuring that established and approved airworthiness standards are continuously maintained during the operation of every aircraft. The exercise of the privileges of a LAME is an individual responsibility of major importance based on proven ability and knowledge by examination.”
- Recommendation: The avionic and mechanical trade training, meeting ICAO international AME trade training standards, must be resurrected.
- Recommendation: The international “privileges” of a LAME must be included in a training package separate from the trade training levels.
- Recommendation: The regulatory system and advisory material must provide the LAME with clear guidance of the international privileges to certify the aircraft as airworthy and coordinate maintenance and issue a maintenance release.
Note: Requirements must separate trade training from LAME responsibilities. CASA and the Education Department responsibilities must be separated.
3. Design, manufacturing harmonisation
- This is another area that a proper review of what worked in the past needs to be analysed and the benefits implemented into the current highly prescriptive red tape system.
- Under the ANR/ANO system, Australia had a highly successful design and manufacturing industry that adopted the world’s best total quality system that applied high quality control and assurance systems.
- Manufacturers and design organisations in that era were not much different to the recent FAA regulatory modernisation changes that have been applied. Recent FAA changes further emphasis why our process must speed up reform. Unlike Australia where politician stay away from aviation, the US Senate Commerce Committee, April 4, made the following changes under the Reauthorisation Act.
- FAA Reauthorisation Aircraft Certification Reform
Sec. 2221. Aircraft Certification Performance Objectives and Metrics.
This section would direct the FAA, in collaboration with the SOCAC, to establish performance objectives and to apply and track performance metrics for both the FAA and the aviation industry related to aircraft certification. The performance objective for aircraft certification would ensure that progress is being made in eliminating delays, increasing accountability, and achieving full utilization of delegation authority while maintaining leadership of the United States in international aviation.
Sec. 2222. Organization Designation Authorizations.
This section would amend existing law by requiring that, when overseeing an Organization Designation Authorization (ODA) holder, the FAA must require a procedures manual that addresses all procedures and limitations regarding the ODA’s functions and ensure that such functions are delegated fully to the ODA (unless the FAA determines there is a safety or public interest reason not to delegate functions). This section would also establish a centralized ODA policy office within the FAA’s Office of Aviation Safety to oversee and ensure the consistency of audit functions under the ODA program across the FAA.
Sec. 2223. ODA Review.
This section would establish a multidisciplinary expert review panel consisting of members appointed by the FAA to conduct both a survey of ODA holders and applicants and an assessment of the FAA’s processes and procedures to obtain feedback on the FAA’s efforts involving the ODA program and make recommendations to improve the FAA’s ODA-related activities. Within six months of the panel convening, the panel would submit a report to the FAA and relevant congressional committees on the assessment and recommendations.
Sec. 2224. Type Certification Resolution Process.
This section would amend existing law by requiring the FAA to establish a type certification resolution process, in which the certificate applicant and the FAA would establish for each project specific certification milestones and timeframes for those milestones. If the milestones are not met within the specific timeframe, the relevant milestone(s) would be automatically escalated to the appropriate management levels of both the applicant and the FAA and be resolved within a specific period of time.
Sec. 2225. Safety Enhancing Technologies for Small General Aviation Airplanes.
This section would require, within 180 days, the FAA to establish and begin implementation of a risk based policy that expedites the installation of safety enhancing technologies for small general aviation aircraft, and establish a more streamlined process so that the safety benefits of such technologies for small general aviation aircraft can be realized.
Sec. 2226. Streamlining Certification of Small General Aviation Airplanes.
This section would require the FAA to issue a final rule required by the Small Airplane Revitalization Act of 2013 by December 31, 2016.
- The FAA devolution of functions is being pushed politically to “improve safety and cost effectiveness of the industry and to free up FAA technical staff to concentrate on “regulatory oversight”.
- Recommendation: As soon as possible, make regulatory and standards changes to adopt an internationally harmonisation engineering and manufacturing system based primarily on the modernisation of FAR Parts 21 and 183.
4. Inactive Aircraft
In 2013, BITRE identified that 3200 aircraft, for one reason or another flew zero hours during 2013. AMROBA estimates that during 2015/2016 that zero flight time figure would almost be double.
The lack of flying affects the MRO and design industry. The ramification on lower utilisation of the GA fleet has been an issue for a long time.
Nearly 40% of those that reported stated repair/maintenance/restoration – so 60% of those reporting zero hours gave other excuses for not flying. It is these other reasons that are of concern.
Summary: CASA has a challenge. Either harmonise with the most cost effective system for engineering and manufacturing industry by removing any differences to the FAR system or risk the BASA with the US by adopting the EAA system for engineering and manufacture. In addition, the maintenance requirements need urgent changes to remove invoked red tape and regulations that has caused rising criticisms of current requirements.
2017 must see improvement so general aviation can shake the restrictive, prescriptive, red tape shackles.