AVIATION MAINTENANCE REPAIR & OVERHAUL BUSINESS ASSOCIATION, INC

AMROBA®inc ADVOCATE OF THE AVIATION MRO INDUSTRY

Newsletter Date 17/1/2012 Inquiry Needed?! Volume 9, Issue 1

Irrespective to what many in government believe, politicians, are very good at making press re- most people that are trying to eke out a living in leases and producing reports and documents aviation believe it is time for an inquiry to iden- that highlight what everyone that works in tify the impediments that restrict the growth aviation is totally aware of today — over of the non airline segments of aviation. regulation of a mode of transport. x Pilot shortages It has been recognised for decades that legis- x LAME shortages lation and enforcement do not contribute to x MRO businesses global competitiveness safety or growth. There has been no growth in x International recognition— private aviation for a couple of decades. design/maintenance Since 1992, the use of aircraft as a form of x Diminishing skills private transport has dramatically declined. x Security Geographically, Australia should have one of x Over regulation the best private and charter (air taxi) systems x Micro-management in the world. x Compliance versus safety ‘Impediments’ to the use of aircraft for pri- x “Island Australia” mentality vate and charter (air taxi) is the restrictive After all of the ‘inquiries’ and ‘reviews’ that this regulatory regime that has been applied by industry has been subjected to in the last 20 plus government. years, why are so many in aviation once again It is not just CAR/CASR/CAOs but all the other (continuing) demanding another inquiry. rules that continue to be made so government The simple answer is that findings and recom- looks like it is addressing concerns raised by mendations of past inquiries have never eventu- “whoever”. ated in the eyes of participants in the industry. Whether it is noise and security, aviation itself Talk to government and they will tell you that comes out second in considerations. It is in they have implemented the recommendations — times of natural emergencies that aviation however, what is understood as the “intent” of proves its worth over and over again. the recommendations by industry participants is Aviation adds to the economies of regional obviously very different to what government sees Australia not just by airline growth but it is the ‘intent’ of the recommendations. should be benefiting from the growth in utilisa- What has changed over the last couple of decades tion of private and charter (air taxi) opera- has seen a shift from the ‘rule of law’ concept to tions. ‘rule by the regulator’. This has seen an increas- Red tape is the biggest negative aspect to ing amount of documentation being created. aviation — so many have started in aviation In order for ‘regulated’ businesses to be able to with great enthusiasm to succeed but continual fund investment it is essential that potential lend- fights with local, State and Federal govern- ers and investors have confidence that the regula- ment red tape, continues to dampen those in- tory regime will treat them fairly and give them volved. Younger investors continue to be disil- adequate opportunity to recover costs and earn a lusioned with aviation. reasonable rate of return. Aviation is a form of transport—all levels of This confidence can be easily eroded if the regula- government should be working to remove im- tory regime is seen as taking arbitrary or unrea- pediments to aviation instead of continually sonable decisions. Perhaps more importantly, the adding red tape. increasing complexity of legislation not only multi- There is a need for an inquiry to identify & plies the demand for increasingly specialised legal remove impediments to the growth of interpretation, but it decreases access to our rules aviation as a form of transport before the for ordinary citizens. charter industry is permanently damaged. Government and its agencies, as well as most

The Wisdom of Asia

Malaysia Airlines’ MAS Aerospace Engineering A decade back many of our members had work (MASAE) unit aims to be the world’s number one contracts in India-Asia/Pacific regions—today maintenance, repair and overhaul they are wondering why Asian governments (MRO) service provider in terms of utilised man- work extremely hard to support their businesses hours within two to three years. (7th Oct 2011) to compete globally and the Australian govern- 1400 new aircraft should have entered global ment appears to make laws that restrict our service by the completion of 2011. Asia Pacific MRO businesses. dominated the order book in 2010, with 29%. Why won’t Asian governments accept the Aus- China alone nabs 10%. Engines represent 46%of tralian ‘Authorised Release Certificate’ that our all MRO services. (IATA/TeamSAI) MRO industry uses to release components back By 2021, the Asia Pacific MRO market will into service. Asian’s accept EASA, FAA, TC and be $21.1 billion of the $69 billion global even NZ Certificates but not ours? market (30%), with China representing AMROBA has raised this issue with CASA and the $7.2 billion. It counts 30% of Asia Pacific Minister — our governments do not, unlike their and 10% of the global MRO market. Asian counterparts, seem to understand that The biggest region for growth in aviation MRO they must remove ‘unique’ Australia require- business will be in the India-Asia Pacific region. ments so that our members can compete with their Asian MRO industries. Malaysia DCA will replace the British Civil Avia- tion Regulations and update DCA practices to be Instead of aligning with EASA/FAA, it is crucial on par with those enforced by the European that the government concentrates on aligning Aviation Safety Authority (EASA). As such, DCA within this region without the additional costs of policies and procedures with regards to regula- individual organisations gaining approvals from tions, certification, approval and examinations each country in this local region. will be replaced by EASA standards. Asia has isolated Australia from access to their Even the United Arab Emirates Civil Aircraft aviation markets simply because we create Regulation CAR Part V Chapter 4—Part M is a unique bureaucratic driven aviation regulations. direct adoption of the EASA Part M instead of our Every State Government should be demanding unique requirements created by CASA directions the Federal Government adopt the EASA mainte- to the AGs. nance regulations without change so their State In the 1980s, governments were determined to aviation MRO businesses can grow and compete remove unique Australian regulatory require- in the India & Asia Pacific region. ments to enable Australian aviation to compete Australia did it with CASR Part 21 when it copied globally—the current maintenance regulations the FAR Part 21 to the advantage of small manu- are so different from our Asian neighbours that it facturers so it is time for change to benefit MRO is very unlikely that ‘harmonisation’ will ever businesses. happen in Australia. Australia is well placed in the India/Asia Pacific It is obvious that the current government will region to provide aircraft component mainte- not direct ‘harmonisation by adoption’ which we nance to the growing aviation industry in this have advocated for some time. region. The Asian countries with their “business” wisdom AMROBA would like to see government set up a adopted the EASA regulations so why can’t we? team to negotiate aviation agreements with our Asian countries, with their centuries of business Asian and Pacific neighbours so that there is acumen, realised that to compete in the global freedom to compete in these markets. aviation market you do not restrict your own Europe and North America have trading zones industry by enforcing unique local requirements but we have not seen government working to set on your own industry. Singapore, Malaysia, Hong up an aviation zone in the India/Asia Pacific re- Kong, etc were quick to “adopt” EASA require- gion. ments even to adopting EASA personnel training Most of the problems confronting the Australian standards. small MRO industry is the free trade arrange- Asia Pacific is also predicted as the biggest re- ments in Australian aviation legislation. The gion for aviation growth but it will be restricted problem is that it is one way, inwards not out- by the lack of skilled workers and pilots. wards. If Australia had a government with the same Or is it that our costs are prohibitive in the business acumen as in Asia, it would stop mak- global aviation market, especially the local re- ing unique laws that continue to restrict our gion. The India Asia Pacific Region are educating businesses access to the Asia Pacific region. their resources but with a lower wage structure, they are very competitive.

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Safest year since 1945—IATA

Accidents and fatalities decreased globally last year, x loss of in-flight control; except in Russia, according to IATA. x ground damage; and It was the best year (so far) for air safety since IATA x in-flight damage, began recording accidents and incidents. Asia Pacific Annual Report: For the Asia Pacific region, The first 11 months of 2011 was the safest period to safety performance continues to improve overall. How- travel by plane since 1945, according to the Interna- ever, the region did experience one major accident, tional Air Transport Association (IATA). with the loss of a Boeing 747 freighter in South Korea. "As of the end of November, global safety performance Overall however, the safety performance trends of Asia (for Western-built jets) is at the best level recorded, Pacific based airlines continue to improve. Smaller Asia and is 49 percent better than the same time last year," Pacific based operators have seen dramatic improve- said Gunther Matschnigg, senior vice president for ments in safety performance over the past decade, safety, operations and infrastructure for IATA. bringing them closer to established international safety performance benchmarks. This makes 2011 the safest year for air travel since the International Civil Aviation Organization began collect- The European Union maintains its stance as a self- ing data in 1945. IATA has calculated and published appointed guardian of global safety performance stan- global airline safety records based on ICAO data since dards, imposing sanctions in the form of an operational 2000. ban against States and airlines around the world, even for airlines that do not fly to Europe. The number of fatal accidents fell to 22 from 23 last year. The number of passenger and crew fatalities also The EU operational ban now includes all carriers certi- declined, down to 486 compared to last year's 786 fied in 20 states, accounting for a total of 273 known deaths. air carriers. Other governments have expressed objec- tions to the extra-territorial impact of such actions by Globally, the accident rate was 2.16 per million take- the EU, with accusations that the whole process is not offs in the first 11 months of 2011 and across all re- transparent, and may be subject to political manipula- gions accident rates have fallen except in the Common- tion. Others have voiced doubts about the validity of wealth of Independent States (CIS) region -- comprised the process, noting that most fatal accidents have in- of Russia and former Soviet republics. volved carriers from States that are not subject to the The accident rate in the CIS region increased from 7.15 operating ban. per million take-offs in 2010 to 11.07 per million take- Air travel is the safest form of transportation, and in- offs this year. dustry remains committed to further continuous im- In North America, accident rates fell to 1.18 per million provements in safety performance. Safety is always from 1.51 in 2010. In the Asia-Pacific region, the rate our number one priority, regardless of any other chal- fell to 1.39 from 2.51, and for Europe the figure fell to lenges confronting the industry. Public trust depends 1.39 from 1.59.” on this unshakeable commitment. According to an IATA study conducted in 2010, there is Further improvements in safety performance can no particularly common type of plane accident that only be achieved through collaborative efforts occurs. amongst regulatory agencies, the aviation indus- try and other safety stakeholders. The airline in- The five most common types of accidents are: dustry has been able to register another excep- x runway excursions when the jet goes off the tionally good year for safety in 2011, further im- runway; proving on the excellent safety performance of x a gear-up landing or a gear collapse; 2010 and earlier years.

New Aircraft Types

Tecnam P2012 Traveller operators will have the option is also planning to fly the 11-seat, high-wing of utilising both MOGAS and AVGAS, thus enabling the piston-powered commuter twin in the first quarter of Tecnam P2012 Traveller to provide air services to as 2012. The P2012 Traveller, the aircraft is being devel- many locations as possible. Its Lycoming TEO-540 twin oped with input from US commuter airline , engines ensure safe and reliable operations, be they which hopes to begin replacing its fleet of 67 aging over long water legs or rough terrain, with a fuel system 402s and Piper Navajos with the new model. featuring two fuel tanks integral with the wing box with The fixed-gear aircraft will cost around $2 million. a capacity of 600 litres (159 US gal), burning less than 114 litres per hour (30 US gph) at a cruise speed of 160 knots. Tecnam’s reputation for innovation and styling is also very evident in the cabin environment too. Taking into account the latest studies, seat pitch has been set at a very comfortable 32 inches. Individual vent outlets are provided for each passenger and there is a heating sys- tem that has been designed to warm the cabin uni- formly. There are two very spacious baggage compart- ments allowing 1000 litres (70.6 cu ft) of space

AMROBA®inc Volume 9, Issue 1 Page 3

Working with CASA

The success of aviation, or any other The industry has to manage change move to enforcement actions industry, depends on the number of invoked by the change towards EASA UNLESS the industry participant entrepreneurs that are willing to in- structured rules. Already it has had a has demonstrated an unwillingness vest in the industry. negative effect within the non airline to comply with local directions. In addition, entrepreneurs need a MRO industry. Many of our members have very regulatory environment that is clear The failure to ‘adopt’ EASA rules has good rapport with their local CASA and practical so that they can get a created ‘unique’ requirements that are office and welcome CASA into their return for their investment. A good based on satisfying CASA instead of business. sign is the amount of aviation activity compliance with legislation. Currently, industry and CASA need in an area. Regulations, MoS compliance and to work closely together so that CASA, as our aviation regulator, has CASA guidance will need to improve industry remains compliant with an important role in creating the en- to provide a standard for industry to what is now a very confusing regu- vironment to attract growth in this meet. The future will be more about latory system. industry. On the flip side, each busi- “satisfying” CASA and history has Industry cannot keep up with the ness has an important role in creating shown that is why the demand for new rules, amendments, exemp- an environment that attracts entre- change was created in the first place. tions, instructions, policies and preneurs to this industry in the local One of the reason that confuses most administrative processes that now area. industry participants is the “apparent” apply. It is why many have walked A concern is the diminishing ‘charter’ failure of CASA to follow “due proc- away from the industry. and pilot training entrepreneurs. ess” when discussing compliance is- During any change period, espe- However, the largest concern is the sues. cially one as major as is happening low level of hours flown by non com- Too often, audits jump straight to now in aviation, CASA has to work mercial aircraft. “show cause” action instead of giving very closely with industry partici- Over the years some of our members the participant a chance to make pants so that they do not just move have had various experiences with changes without such confrontational on to another industry. the regulator. actions. Even CASA’s Enforcement The failure of industry to work with Manual list ways to achieve compli- CASA and vice-versus, has already ance. seen many depart this industry. These are: On the other hand, there is some x Assisting the industry to comply, evidence that CASA is starting to generally and on an individual work with their local industry to basis effectively educate them in the x Encouraging or exhorting compli- changes that they will have to make ance to continue in the industry. Pity the x Compelling compliance rules did not address costs. x Penalising and deterring non- What CASA has to do is work with compliance. entrepreneurs to increase pilot AVIATION The problem is that the CASA En- training and especially growth in MAINTENANCE forcement Manual then goes on to the charter sector. REPAIR & OVERHAUL discuss nothing but enforcement proc- Currently, the non airline industry BUSINESS esses. sectors have a very negative predic- ASSOCIATION, inc Our contention is that locally, actions tion for the future—can govern- to fix compliance issues should NOT ment and CASA turn that around?

The Aircraft Maintenance Engineers/Technician Creed

Worth Remembering IN DISCHARGING this trust, I regarding the ability of others who pledge myself never to undertake have worked on it to accomplish “UPON MY HONOR I swear that work or approve work which I feel to their work satisfactorily. ® I shall hold in sacred trust the rights be beyond the limits of my knowledge I REALIZE the grave Postal Address: and privileges conferred upon me as nor shall I allow any non qualified superior to persuade me to approve responsibility which is mine as a PO Box CP 443 a qualified aircraft maintenance aircraft or equipment as airworthy qualified aircraft maintenance Condell Park engineer/technician. Knowing full against my better judgment, nor shall engineer/technician, to exercise my NSW 2200 well that the safety and lives of I permit my judgment to be judgment on the airworthiness of Phone: 61 (0)2 9759 2715 others are dependent upon my skill influenced by money or other personal aircraft and equipment. I, Fax: 61 (0)2 9759 2025 and judgment, I shall never Email: knowingly subject others to risks gain, nor shall I pass as airworthy therefore, pledge unyielding adherence to these precepts for the [email protected] which I would not be willing to aircraft or equipment about which I [email protected] am in doubt either as a result of advancement of aviation and for Website: assume for myself, or for those dear direct inspection or uncertainty the dignity of my vocation.” www.amroba.org.au to me.

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