Industry Queries CAA Airworthiness Standards

To some extent the feelings within industry have also been stoked by the high relative cost of putting the Airbus A320, the 747-400 and the 737-300 on the register while aircraft such as the Mohawk 298 (Lloyd Aviation) and the Beech 1900 (Hawker Pacific) have met with what is considered by many to be an unduly lengthy, complex and technically unjustified certification process.

The Mohawk situation is perhaps a classic example of why many aviation firms within Australia wonder why they ever bothered to get into the business at all.

Lloyd Aviation of Adelaide required an aircraft of larger capacity than their existing Bandeirantes. After examining the limited range of options, they settled on four Mohawk 298s that were being used by the then Pan American commuter operator, Ransome Airlines, in the north east sector of the USA.

The Mohawk 298 is essentially a re-engined (Pratt & Whitney Canada PT6A-45) version of the Aerospatiale Nord 262 which first flew back in 1962. Some 11O examples were built, nine of which were converted to Mohawk 298 standards during the mid seventies by the Fred Frakes organisation in the USA. The Nord 262 originally was certificated under CAR 4(8) and later FAR Part 298 (Federal Aviation Regulation), the origin of the actual designation of the converted aircraft and the same standard that the FH-227 and Fokker F-27 are certificated to in the USA.

The Mowhawks looked like the answer to Lloyd Aviation’s dreams, a 26 seat pressurised commuter that could comfortably cruise at up to 200mph and at around $Sm for the four aircraft with spares, even the bank manager had reason to smile.

Lloyds had little doubt as to the structural or operational qualities of the aircraft as they had been flying without incident in the USA for more than ten years, while the actual Nord 262 design had almost a quarter century of flying operations backing its design integrity. Hence, in accordance with normal operating procedures, senior representatives qf the company discussed the acquisition of the Mohawks with the CM’s (then DofA but hereinafter referred to as CM) senior Airworthiness people in Canberra. Lloyds tell us that there appeared to be no problems with bringing in the aircraft and placing it on the Australian register. So, confident that this was the answer to their needs, Lloyd Aviation proceeded with the acquisition of the four Mohawks Australia’s airlines and the major General Aviation aircraft distributors are beginning to publicly query the often unique certification standards applied to Australian registered transport aircraft.

Qantas and Ansett have both issued lengthy submissions to both the Industries Assistance Commission inquiry into the travel and tourism industries and the Air Safety Regulatory Panel (ASAP) set up by the then Aviation Minister, Mr Peter Morris to rewrite, update and streamline the Australian aviation regulatory environment. The IAC will issue the results of its report during 1989 while the initial draft of the ASAP was due to be handed to the present Minister for Aviation as we closed for press.

To a large extent the move to actively query, or at least try and get the CM to publicly justify its often unique certification standards, stems from increasing industry frustration at not being able to get aircraft certificated without a costly and time consuming certification process which to many is likened to “merely reinventing the wheel” of an already certificated US Federal Aviation Agency transport aircraft.

To some extent the feelings within industry have also been stoked by the high relative cost of putting the Airbus A320, the 747-400 and the 737-300 on the register while aircraft such as the Mohawk 298 (Lloyd Aviation) and the Beech 1900 (Hawker Pacific) have met with what is considered by many to be an unduly lengthy, complex and technically unjustified certification process.

The Mohawk situation is perhaps a classic example of why many aviation firms within Australia wonder why they ever bothered to get into the business at all.

Lloyd Aviation of Adelaide required an aircraft of larger capacity than their existing Bandeirantes. After examining the limited range of options, they settled on four Mohawk 298s that were being used by the then Pan American commuter operator, Ransome Airlines, in the north east sector of the USA.

The Mohawk 298 is essentially a re-engined (Pratt & Whitney Canada PT6A-45) version of the Aerospatiale Nord 262 which first flew back in 1962. Some 11O examples were built, nine of which were converted to Mohawk 298 standards during the mid seventies by the Fred Frakes organisation in the USA. The Nord 262 originally was certificated under CAR 4(8) and later FAR Part 298 (Federal Aviation Regulation), the origin of the actual designation of the converted aircraft and the same standard that the FH-227 and Fokker F-27 are certificated to in the USA.

The Mowhawks looked like the answer to Lloyd Aviation’s dreams, a 26 seat pressurised commuter that could comfortably cruise at up to 200mph and at around $Sm for the four aircraft with spares, even the bank manager had reason to smile.

Lloyds had little doubt as to the structural or operational qualities of the aircraft as they had been flying without incident in the USA for more than ten years, while the actual Nord 262 design had almost a quarter century of flying operations backing its design integrity. Hence, in accordance with normal operating procedures, senior representatives qf the company discussed the acquisition of the Mohawks with the CM’s (then DofA but hereinafter referred to as CM) senior Airworthiness people in Canberra. Lloyds tell us that there appeared to be no problems with bringing in the aircraft and placing it on the Australian register. So, confident that this was the answer to their needs, Lloyd Aviation proceeded with the acquisition of the four Mohawks the only four Nord 262 type aircraft in the entire world that are subjected to this requirement.

So much for Lloyd Aviation and their ill-fated Mohawk.

Almost as frustrating, time consuming and fiscally even more unrewarding is the sad saga of the Beechcraft 1900 and Hazelton Airlines.

Following a tour of Australia during early 1987 by the Beech 1900, where the type was enthusiastically endorsed by all who flew it (refer p. 118 May 87 AA) local agents, Hawker Pacific set down to the task of logging that first and vitally important local order. It was good news for Hawkers that their first client also happened to be one of Australia’s most respected and longest established aviation personalities, Max Hazelton. Max wanted the new, pressurised 19 passenger aircraft to link his newly won rural NSW routes with a high speed, enhanced comfort service to Sydney.

So Hawkers ordered their first 1900 and also later additionally committed to two more due to the strong local interest the type was generating. Initial discussions with the CM progressed well and their appeared little difficulty in getting the type certificated under SFAR 41C just as it was in the USA, where incidentally over 100 were already flying in daily service.

However, as history would have it, that was not to be the case and this ‘mini airliner’ was, like so many before it, to feel the full sting of the verdict of non acceptance by our airworthiness authorities.

The 1900 arrived in Australia on the 4th July 1988 following a period of CAA evaluation in the USA. Prior to this, both the CM and Hawkers estimated that the time taken locally to obtain CofA would be no more than one month, allowing Hazelton Airlines to place the type into revenue service by September at the latest.

Hazeltons of course had to fight to win their new routes, they had to actively gain the confidence and endorsement of the regional communities and their councilors that they were promising to serve with a higher standard of aircraft type than was previously the case. If they couldn’t do this, then the routes could well go to another commuter. Thus, when Hazeltons endured the delays that followed, they also had to endure a loss of face within these populace as by and large the local mayors and remote communities tended not to believe all that was being told them about the certification problems at the hands of the CAA. In short, it was too incredible for them to believe.

This episode also did little to reassure the community in general that this new commuter was really the fine aircraft that it was originally purported to be. The fact that it was basically an improved commuter version of the long established King Air and made by one of the most respected GA manufacturers in the world had at least helped fly the flag a little higher. In fact for those with a penchant for numbers, since the first King Air entered service a quarter century ago some 4,000 have been built. During the first half of 1988 it took 82% of world market share for this category of aircraft and is by far the largest selling turboprop ever built. More than 50% of all turboprops are King Airs while since 1964 when the first King Air 90 entered service, more than 2,500 engineering changes have been incorporated to further improve the design.

During the protracted certification process (US FAA certification was awarded in November 1983 with over 100 1900s presently in service), the CAA required an improved structural capability to withstand birdstrike on the wing leading edges, dual controls on the trim tabs (a major redesign according to Hawkers that Beech weren’t scheduled to do till 1990), lighting on the emergency exits and changes to their design to allow external operation and an annunciator panel for the stall warning system. Of these, the uprated wing leading edge birdstrike requirement presented the biggest problem as Beech weren’t physically able to accommodate this extensive mod for at least another year.

Coincidentally, the vitally necessary, and indeed very lengthy, datapack on this was dispatched to the CAA by courier during early October only to be ‘lost’ within the bowels of the CM for over a month when finally it was discovered to have been there all along! Throughout this period, the CAA denied having ever received it, much to the frustration of all concerned on the private enterprise end of the queue. However, after much teeth grinding on the relatively insoluble birdstrike requirement, the CAA simply dropped this requirement and accepted the American data- a month’s plus delay for nothing!

However, the story doesn’t end here. While undergoing flight test in the USA, the CM test pilot performed an engine procedure which caused considerable damage to the expensive turboprop engines. According to both Hawkers and Max Hazelton: a Beech pilot, a CAA pilot and a Hawker Pacific pilot were aboard the test aircraft. The CAA pilot wished to undertake a test which the Hawker Pacific pilot objected to on the grounds of the likely damage that would ensue to the engines as a result of this test. The Beech pilot apparently reluctantly agreed at the CAA pilot’s insistence and the Hawker Pacific pilot duly elected to leave the aircraft as he was concerned for his personal safety owing to some of the practices previously being undertaken in the name of flight testing.

Consequently, the engines were run up to max takeoff power and the fuel flows were simultaneously switched to ‘off’. The immediate result is that the turbine shroud shrinks and contracts onto the blade tips themselves- the consequent resulting damage doesn’t have to be technically described to be understood! As Max Hazelton appropriately summed up, “Commonsense went out the window a long time ago. Our airworthiness people just won’t believe the data that the world’s largest regulatory body certifies, it’s incredible”.

What is not incredible was that Max simply could not wait any longer and on the 7th November reluctantly informed Hawker Pacific that he would have to cancel his order. The cost of this category of aircraft and is by far the largest selling turboprop ever built. More than 50% of all turboprops are King Airs while since 1964 when the first King Air 90 entered service, more than 2,500 engineering changes have been incorporated to further improve the design.

During the protracted certification process (US FAA certification was awarded in November 1983 with over 100 1900s presently in service), the CAA required an improved structural capability to withstand birdstrike on the wing leading edges, dual controls on the trim tabs (a major redesign according to Hawkers that Beech weren’t scheduled to do till 1990), lighting on the emergency exits and changes to their design to allow external operation and an annunciator panel for the stall warning system. Of these, the uprated wing leading edge birdstrike requirement presented the biggest problem as Beech weren’t physically able to accommodate this extensive mod for at least another year.

Coincidentally, the vitally necessary, and indeed very lengthy, datapack on this was dispatched to the CAA by courier during early October only to be ‘lost’ within the bowels of the CM for over a month when finally it was discovered to have been there all along! Throughout this period, the CAA denied having ever received it, much to the frustration of all concerned on the private enterprise end of the queue. However, after much teeth grinding on the relatively insoluble birdstrike requirement, the CAA simply dropped this requirement and accepted the American data- a month’s plus delay for nothing!

However, the story doesn’t end here. While undergoing flight test in the USA, the CM test pilot performed an engine procedure which caused considerable damage to the expensive turboprop engines. According to both Hawkers and Max Hazelton: a Beech pilot, a CAA pilot and a Hawker Pacific pilot were aboard the test aircraft. The CAA pilot wished to undertake a test which the Hawker Pacific pilot objected to on the grounds of the likely damage that would ensue to the engines as a result of this test. The Beech pilot apparently reluctantly agreed at the CAA pilot’s insistence and the Hawker Pacific pilot duly elected to leave the aircraft as he was concerned for his personal safety owing to some of the practices previously being undertaken in the name of flight testing.

Consequently, the engines were run up to max takeoff power and the fuel flows were simultaneously switched to ‘off’. The immediate result is that the turbine shroud shrinks and contracts onto the blade tips themselves- the consequent resulting damage doesn’t have to be technically described to be understood! As Max Hazelton appropriately summed up, “Commonsense went out the window a long time ago. Our airworthiness people just won’t believe the data that the world’s largest regulatory body certifies, it’s incredible”.

What is not incredible was that Max simply could not wait any longer and on the 7th November reluctantly informed Hawker Pacific that he would have to cancel his order. The cost of this be actually incorporated into the design at manufacture rather than having to be added on later as expensive modifications to the basic design.

However, back in 1980 when the issue of larger commuters ra!sed its ugly head, the then Department of Transport flatly reIected any bending of the 5,700kg limit and refused to accept SFAR 41 at that time. The result was that one major aviation company of the time, Stillwell Aviation, was unable to market the Metro Ill. On the surface that might not sound much but in those days the Metro II was the number one aircraft in the rapidly emerging commuter class in Australia and many operators were clamouring to move up to the faster and more capable Metro Ill version. Stillwells calculated at the time that they would beable to sell at least 15 Mertro Ill aircraft within three years.

However, this was not to be as the entire issue of SFAR 41 became a near religious cause of the then DoT. In fact it was only after the bad publicity received over this, and other matters relating to the DoT via Dick Smith’s book “Two Years In The Aviation Hall of Doom” that the department finally wavered and gradually adopted the gist of the revised American SFAR 41C regulations with special amendments for our unique performance and birdstrike factors. It was these latter provisions though which almost make the aircraft unmarketable in Australia so while looking like they had changed their original ruling, the then department had in fact really only made what in real terms was a cosmetic gesture to defray some of the heat it was getting from all quarters of the industry and much of the media.

Thus aircraft like the Dornier 228-200 series, the King Air 300, the Beech 1900 and of course the Metro Ill all remained well outside the reach of local operators for many years.

The bottom line for Stillwells of course was that it totally lost the market position that it had worked so hard to develop during the late sixties with the popular Metro II. The result of this was that when the recession of ’81/82 came, the firm really only had one family of aircraft (Learjet) to market and consequently was finally taken over in financial disarray to become Pacific Aviation.

So why mention all of this now ancient history? After all, isn’t it as one CM executive suggested, merely digging up old graves? In our opinion we think it relevant in respect of the simple fact that more than eight years have passed since the ‘dreaded’ Metro Ill first entered service in the USA. In that time it is perhaps worth noting that at the end of 1988 there had been 163 Metro Ills delivered out of a total Metro fleet of some 420 aircraft produced over an 18 year history. In 1987 the Metro Ill accounted for the greatest number of flight hours than any other commuter type in the US. In 1987 the fleet logged an impressive 237,608 cumulative hours, nearly 10% of all third level flight hours in the world’s busiest air transport environment. It performed in snow, in gales and through tropical heat and midwest dust storms without any airworthiness problems.

On this basis, we asked the CAA if any Metro Ill had indeed suffered an accident due to an airworthiness problem during the past 8 years. The answer, of course, is that there hasn’t been which just goes to show that perhaps the Americans in the late seventies weren’t so wrong after all. Mind you, from our personal experience, to get anybody involved in the senior levels of the CM’s Airworthiness Branch to admit that appears to be an impossible task and one that even today carries over to the sad saga of the Beech 1900.

The bureaucrats naturally are entitled to their opinions though so are some of those who lost their jobs when Stillwells were forced into massive retrenchments in 1982. To them they saw their livelihoods shattered on the basis of an unfair and illogical edict by a government bureaucracy which neither cared the slightest for the fate of the industry nor had ever remotely considered the real time implications of their actions. The fact that the Metro Ill featured more powerful, and at the time the option of far more reliable engines (PT6 vs Garrett TPE731s), expanded fire protection, additional electrical system redundancy, improved field performance and engine out capability (the areas where the majority of major accidents occur) and met the stringent Australian accelerate/stop requirements was meaningless. To the department of the time, it was nothing less than an accident waiting to happen even though some 85% of accidents are as a direct result of human factors (BASI data) while for 1985 the US National Transportation Safety Board quoted that pilot error was the cause of 95% of commuter airline accidents.

The Metro Ill, and its cousins, only real failure was that it simply had a max takeoff weight slightly greater than 5,700kg – and that to the department was then, and is apparently still now, beyond forgiveness.

But it isn’t just the smaller GA operators and manufacturers who have had to endure this trial by fire over the years. The major airlines also have a litany of complaints regarding elements of how their heavy transport aircraft are certificated for the Australian register.

So much so that Ansett and Qantas have for the first time ever launched relatively public campaigns against areas of our often unique standards. As mentioned previously their vehicles for change are the Industries Assistance Commission into the Travel and Tourism Industries and the Air Safety Regulatory Review that was initiated by the then Aviation Minister, Mr Peter Morris, back in 1987. Their submissions call for a streamlining of the overall certification procedure, which they claim, presently costs them heavily in both technical, manpower and fiscal terms to bring an airliner onto the register that has already been fully flight tested and certificated by the world’s most experienced aviation nation, the United States.

The airlines also point to the fact that apart from the odd placard or sign, there are very few meaningful mods necessary to make the airliner safe for Australians to fly in. The bottom line, they claim, is that if year in and year out there are virtually no real problem areas uncovered by our unique standards, then why bother with this time and dollar consuming exercise in the first place?

Ansett’s IAC submission argues that “Despite certification processes applied by overseas regulatory authorities of high standing (eg: UK’s CM, USA’s FM) Australian authorities insist on certifying new aircraft, simulators and overseas airports from a zero base. This causes costs and delays that are unnecessary. It would not be inconsistent with Australia’s interests for regard to be required to be had to determinations of these authorities as part of the Australian certification process. Alternatively, there may be scope for delegating to airlines a degree of responsibility in this area”.

As an example of the relatively high cost that the airlines have to pay to get an airliner onto the Australian register take the case of the 737-300. Ansett and Australian airlines teamed on this mutual benefit exercise but the bottom line, according to Ansett General Manager, Mr Graeme McMahon, was just over $1m. And when asked what mods were recommended from this exhaustive series of tests by the CAA, the Ansett verdict was ‘none’. Similarly, Qantas has budgeted a cool $1m to get the 747-400 certificated and paid $400,000 on certification costs for the 767-300 and a further $210,000 on the smaller 767-200 for which they were able to use much of the baseline Ansett 767 data.

The CM meanwhile questions these amounts as they say that the direct cost attributable to it is usually well under $200,000. However the remainder, according to the airlines, is made up in flying time costs (6 to 8 flight hours in a 747-400 doesn’t come cheaply!) and engineering data analysis costs with the time taken using the manufacturers resources and manpower being eventually attributed to the end user.

When certificating a first of type aircraft the end user must pay for the following. Business Class international travel for the CM team from Australia to the relevant factory, usually Europe or the USA. Direct salary costs of all officers from time of departure till time of return excepting weekends, etc. On-costs of 63% of direct salary costs. Per diem allowances and cost of accommodation and any outfit allowances where applicable.

According to the airlines and major importers we spoke to, the size of the team varies between 1 and 7 depending on what type of aircraft is involved, the degree of its relative technical complexity and whether or not it is a first of type (FOT). It appears an average visit for a medium sized aircraft takes around 1o days though not all the CM team are there for the duration as not everybody is required for the full period. As an example, on the Falcon 900, a team of 3 were involved with no real mods being required on the aircraft. Hawker Pacific quote the travel and accommodation costs alone at more than $30,000 without factoring in the time and cost of their own specialist personnel.

Apart from SFAR 41 type aircraft, from what this magazine could gather, there were very few real mods required on any of the FAR 25 airliner class aircraft brought into Australia this past decade. We consequently requested a list of aircraft from the CM with the mods effected on each to make them safe for Australians to fly in (as against elsewhere in the world). The list of mods was not available due to what the CAA quoted as time and cost constraints. From our contacts with the airlines, distributors and manufacturers we could find very few real mods that were required to meet local CM requirements despite the previously mentioned costs endured by airline and distributor alike. As one industry spokesman stated “We don’t mind cost recovery if it is valid and required, though if we have to continually fund exercises in futility, then that is hardly fair. The CM is now said to be optimised on a new criterion of corporate efficiency and industry now has to fund it 100%, thus why can’t industry in return at least have more say in the often adversarial area of certification standards. Why, for instance, can’t the CM be a little more accountable for its actions and decisions just as we in private enterprise are? People there continually make arbitrary decisions with no logical technical or operational gain and yet at the same time they are also beyond accountability for their actions – that is wrong. ”

However, a new factor has crept into the certification process which hits directly at the often stated aims of the new style CAA’s attempts to establish a greater rapport with the end user and seek greater consultation with the industry’s consultation on crucial matters. Put basically, the CM has now officially prohibited the end user from being actively involved in the direct certification process between the manufacturer and the CM itself. Thus Ansett has to a large extent been excluded from being intimately involved with the complex task of certifying the A320. Ansett engineering people are dismayed at this move, which the CM claims is at the behest of the manufacturers, yet neither Ansett nor Qantas could find this sentiment from either Airbus or Boeing.

As any aviation observer knows, there are numerous purpose designed and often unique requirements adopted in a new airliner type for each individual operator. A different galley system, for instance, might also require an additional or changed power source. If the end user is deliberately excluded from this process then there is a good chance that ultimately safety will eventually be prejudiced by such an exclusion.

The above then makes it difficult to comprehend exactly what the CAA’s own publicity brochure means when it states; “The Authority’s aim is to improve the service offered to the aviation industry so the industry can reduce its costs, operate more efficiently and offer a better service to its customers. The CAA will be more accountable in everything it does because it is largely self funded and responsible to a commercially oriented Board with objectives of reducing the costs of infrastructure and services to the aviation industry”.

CM Chief Executive Officer, Mr Collin Freeland in our September 1988 edition (p. 109) also contributed the following noteworthy statement – “I hope to move fairly early to have an advisory committee on the regulatory side set up. I would hope to see a committee with primarily industry representation, say eight industry people and two people from the CM sitting on a committee where if we have day to day problems in the administration of the regulations – that is somewhere those problems can be brought to with a group of technical experts that can sit down and advise on that. If there are changes to be made to the day to day regulations or the way we administer them, we could go to that committee for advice and get their views reasonably quickly”. Perhaps the group’s first mission, when it is operational, will be to address the above situation of deliberate exclusion of industry from the end process of certification of their aircraft!

Qantas are also fighting back and a recent speech by Capt Alan Terrell, General Manager Operations of Qantas to the Royal Aeronautical Society’s Aerospace ’88 symposium in Sydney last October fairly accurately sums up our national carrier’s feelings on the matter of Australian certification standards.

“Differences in regulatory attitudes may also be attributable to the amount and type of lobbying of special interest groups. For example, the Australian CM is the only regulatory body in the world to require the adoption of ICAO revised standards for takeoff performance to existing aircraft designs. ” stated Capt Terrell.

(This is known in Australia as Amendment 62 to ANO 101. 6 and is the accelerate/stop requirement mentioned earlier in this article. Essentially it factors in a 2 second reaction period at V1 prior to brake initiation in the event of a rejected takeoff. This equates roughly to 400ft in a 747 and compares with the US and internationally used reaction time of . 3 of a second. Australia also incorporates a line up requirement which also serves to shorten already marginal strips and is particularly demanding when merged together with the accelerate/stop requirements)

“The ICAO standards were intended to be applied to new aircraft designs which could be optimised for the new rules, not existing ones, and this was the approach adopted by all other countries. In Australia, the rules penalised all aircraft coming on to the register from 1981 under first of type certification. This issue was the subject of considerable lobbying by the Australian Federation of Air Pilots (AFAP) in the late 1970s and the need for change to the rules was not supported by historical evidence”, stated Capt Terrell.

On direct matters on airworthiness certification adversely affecting Qantas, Capt Terrell went on to say, “ICAO exists as a forum for standardising world aeronautical practices. The complexity of national variants to ICAO both in terms of certification and operation of aircraft is such that it places severe administrative demands on both airlines and the authorities and causes economic loss to the airlines involved. Everyone accepts that aviation safety is essential, but there needs to be a more universally agreed approach to the issues involved”.

“The implementation of the Bosch Committee Report on Aviation cost recovery means that the operators are required to pay for the services imposed upon them by the CM. Since the user is footing the bill, he has the right to demand that regulatory requirements, particularly those unique to Australia, be publicly justified in terms of the safety benefits to the travelling public”, stated Capt Terrell.

Australian Aviation also sought the opinions of the aviation experienced members of the CAA Board to ascertain their opinion on the present state of play within the Airworthiness Branch. What surprised us was that these gentlemen also, by and large, held similar views to that of industry. Dick Smith, long time a thorn in the side of the department and now ironically (and thankfully) a CAA Board member perhaps was the most vocal. Stated Dick, “Now is the time to investigate the amount of money being spent on certifying aircraft specifically to the Australian standards when that money and those highly skilled resources could perhaps be better spent in improving surveillance. The maintenance of our own unique standards may well improve safety by some small degree over a period of time but it has to be asked whether or not this money, and these resources, would not contribute more to safety if they were employed in monitoring and checking on the safety standards actually being employed at the work face”. Though, in view of their naturally sensitive positions, the other board members preferred not to be quoted directly they did agree with the general thrust of Dick’s argument.

And this may well be the bottom line for even the CM. At time of going to press the CM was grossly short of skilled surveyors and engineers due largely to the inequities of the CM employment provisions. At November 1988, they were down 23 positions in the crucial engineer and surveyor areas and were set to lose many more in the coming months as the airlines freely offered pay packages up to $15,000 more per annum than that able to be offered by the CM. The problem is that while the Federal Government told the CM it had a new and commercially attuned corporate structure, it did not remove it from the restrictive guidelines of the Public Service Act, hence it cannot perform in real terms in a manner similar to that of the FAG, Qantas and more recently Australian Airlines. This is not the CM’s fault but one of government and one that needs to be corrected very quickly if the CM is going to be of real long-term benefit to the industry it is tasked to serve.

So what is the opinion of the CM itself?

As one would imagine, the senior officers of the Airworthiness Branch do not agree with the above sentiments. Despite the fact that every industry person we spoke with, every airline, even members of their own Board and quite a few non-airworthiness-related employees of the CM itself agreed that there was clearly room for change, the senior officers we spoke with did not even acknowledge that a problem existed in the first place. It was just another case of industry whinging like it always does.

No matter what, the present hierarchy would not want to see our present standards altered, let alone take the New Zealand example and accept the US FM standards as their own. We then asked whether or not air safety had been prejudiced in New Zealand as a result of following the same airworthiness standards as the world’s largest producer and operator of aircraft. Like trying to get somebody to say that perhaps in retrospect, the much maligned Metro Ill was perhaps not quite the dog it was painted back in 1981, to get anyone to come up with a specific example of why it was less safe to fly in New Zealand (the bottom line, after all) than Australia in airworthiness terms was something that we were unable to achieve. As there is no real difference technically between aircraft flown by both nations (such as the 767-200 and 747-200 of Qantas and Air New Zealand) we wonder why it is that the Australian operator must be the one with the protracted and expensive standards with no perceived tangible benefit to operator or passenger alike.

Over the decades of course the then department did provide the nexus of change in a number of beneficial areas as regards ongoing safety. Following the tragic Viscount mid air breakup over Botany Bay in the mid fifties, it was made mandatory for all airline aircraft to be equipped with suitable weather radar. Stall warning devices were added and improved at the then department’s behest as was the important areas of the Cockpit Voice Recorder (CVR) and the Flight Data Recorder (FDR). Other mods were the installation of a reserve power source for the artificial horizon.

Such mods emanated from Australia at a time when civil aviation was still relatively young in technical terms compared with where we are today. Today, it might be fairly asked if the opportunity still exists to invent and perfect systems of such great import as those listed previously. In other words, while our own unique standards were perhaps technically relevant twenty or thirty years ago, are they really relevant today given (a) the small number of meaningful changes that the CM physically demands on FAR 25 aircraft, and (b) the high cost and intensity of scant CM resources that this “reinvention of the wheel” nowadays requires.

In defence of its present policy though the CM presents some interesting background data.

For instance, with the Australian certification of the Casa 212, a design defect was identified which meant that the aircraft did not meet the design requirements in that flutter would occur after the failure of a single element in the control system. This led to retrofit modification of all Australian Casa 212 aircraft and was duly incorporated in new production aircraft in Spain. The matter was one of non-compliance with the basic FM design standard. The Australian considerations being undertaken after the FM certification. The Australian assessment of the Casa 212 aircraft in Spain in 1981 also resulted in an Australian request to fit an artificial stall warning system. This was not required by other Authorities until 1987 when the FM mandated fitment following two fatal accidents to US registered C. 212 aircraft.

The fatigue investigation carried out in Spain also enabled retirement lives to be promulgated in Australia significantly greater than that type certified by Spain and the US and 20 other countries. For example, wing life increased from 15,000 hours to 16,700, the tailplane from 15,000 to 18,200 and fin from 5,000 to 32,300 hours. A significant DOC saving. The Airworthiness Branch has always been very strong in this area of fatigue analysis and as an example contributed greatly to the early identification and response to the Section 41 airframe fatigue problems affecting older model 747s.

During the Australian certification of the Lear 55 business jet, it was discovered that the external surfaces, in particular the pressure cabin skin, were subject to a sanding process in order to eliminate irregularities before painting. The CM considered that this sanding process compromised the fatigue and damage tolerance characteristics of the aircraft. At the time the FM was not aware of this highly improper and potentially dangerous treatment. Corrective action was immediately taken. by both the manufacturer and the FAA.

The Swearingen Merlin and Beech King Air are examples of many medium sized turbine powered aircraft which were designed to FAA rules which did not include a wing fatigue requirement. Australian airworthiness overseas assessment of these aircraft led to the introduction of retirement lives and to locally developed inspection techniques which have now been made mandatory by the FAA.

Potential control run fouling was discovered by the CAA team during certification of another small turboprop airliner – the British Jetstream 31. Action to correct this has now been taken worldwide.

A special requirement was also imposed on landing gear fatigue for a passenger helicopter (the Sikorsky S76) by an Australian team; this was subsequently the subject of the US Notice of Proposed Rulemaking (NPRM) and is now a formal FAA design requirement.

The CAA team investigating the BAe 146 also determined that the design had been to an earlier standard no longer accepted in the USA and Australia. As a result, there was inadequate pressure relief in the cargo hold liner portion of the pressure hull which, in the event of a door failure, may very well have led to control jams and loss of the aircraft. This has since been corrected worldwide. It was also discovered that the birdstrike testing was overly conservative and the applicable speed was capable of being raised. This could be of benefit to an operator.

Whilst the above does give some backing to the CAA’s case for a unique Australian based certification requirement the bottom line will inevitably be whether or not the vast cost and utilisation of decreasing physical resources will allow Australia the luxury of such a facility – particularly when it is patently obvious that the only element of the·aviation environment that actively supports its continuance is the bureaucracy itself.

For the final word on the CAA’s position we quote directly from the Assistant GM Airworthiness; Mel Dunn. “I firmly believe the people that are highly critical of this (Australian certification) exercise are doing the Australian public in its broadest possible terms a disservice. They have a very qualified, expert, balanced and dedicated group of people in this airworthiness area. They are not out to screw the industry and anybody who perceives that undertaking a certification role is part of that exercise is making a terrible.

You Be The Judge: In the March edition of Australian Aviation we will allow the CAA a two page right of reply. The only requirement we have placed on them is that they naturally remain within the physical space requirements of a two page reply. We will also give readers the same opportunity and will feature two pages of your views on this important and controversial subject. However, we must have your letter by the 20th January and whilst all letters must be signed with full name and address, we will respect your right to privacy, if so required. Please send your response to The Editor, Australian Aviation, PO Box 105, Weston Creek, ACT, 2611 or fax it on (062) 88 2021

The Australian Aviation Viewpoint . . .

Writing this article has been one of the most difficult assignments of my 23 year career in commercial journalism. The reason being simply that I have never before come across reporting a subject where such a widespread body of experienced opinion held a view that was so patently contrary to that of the other.

This has consequently placed the magazine in a position where it is not difficult to be perceived as perhaps having a biased viewpoint if one should be, for instance, firmly on the side of the CAA. I can certainly understand that and consequently we have taken the liberty to specifically state where we stand on the issue so that nobody, on either side of the fence, may in future times misrepresent our position on this crucial matter. We have also gone out of our way to offer the CAA a right of reply in the next issue, we only hope they use it constructively as in this instance our 52,000 plus readers will be their judge.

Our policy is simply that while we believe that over the decades our own indigenous Airworthiness Branch has performed a number of viable actions in regards safety improvement aboard civil aircraft, we see less relevance in this regard in the years ahead as overall international design standards improve to levels unheard of in previous generations. This is all via the ability. to better pre-test systems, airframes and project fatigue data via computer engineering studies not even available in the seventies. To, for instance, accept the US FAA standards would to us seem quite plausible. This would greatly cut down on the friction, cost and associated problems that continually surface in such a counter productive and unnec(;lssary manner presently between the end user and the regulatory authority.

The CAA needs to open itself up to some lateral thinking. Just because things have been done the one way for many, many years does not make it right per se. Following the rule book to the letter is alright if the rule book is relevant. However, since the rule book was written, many things have changed and we think it is perhaps time to examine the basic rule book. Private enterprise companies, irrespective of their nature, have to be responsive and flexible in their long-term thinking-we don’t think it too much to expect the bureaucracy to operate under the same sensible guidelines.

To accept the certification standards of the largest producer and user of aircraft in the world would not seem to us to be such a retrograde step. After all, is a new US airline registered 747, 737, 767 or A300 any less safe to fly in than one in an Australian livery? New Zealand adopted this simple, highly popular system years ago and despite raising the question ad nauseam to the CAA we cannot see any downside to their system except perhaps that it employs less people in the certification process. We also appreciate that there is a move towards a truly international standard and our CAA is involved in discussions on this project, though our summation on this is that it will be mc1ny, many years before such a far-sighted document is fact.

We totally support the sending of a specialist CAA engineer or surveyor to the site of manufacture for the appropriate factory courses as required. Though the actual CAA costs in having people overseas is relatively small (though rising under the new CAA user pays guidelines) the real cost to the end user comes in satisfying the data base required only by the CAA. This is a cost that the CAA believes is being firmly overplayed by the airlines and quite frankly we would also like to see the airlines supplying a full cost breakdown to the CAA to better illustrate their own case in this regard. To date that has, according to the CAA, not occurred.

We also agree totally with Dick Smith’s sentiments in that we would like to se(;l these highly skilled and experienced CAA specialists taken off their “reinvention of the wheel” duties and put out in the field to greatly increase the degree of surveillance and monitoring that is the sharp end of aviation safety in Australia. ‘ Remember that as an Airworthiness Directive can be easily signed off by a certified maintenance organisation, additional surveillance and monitoring of standards in this regard is essential.

Deregulation is but a year and a half away. With it will come a veritable explosion in air travel within Australia at all levels. At present, and for the past two years, there has been an acute shortage of skilled aviation specialists at almost every level of the industry in Australia. When deregulation comes the situation will become even more severe as the present wave of new engineering apprentices, new pilots and such will not really become fully effective and experienced till the mid nineties. If there was ever a time when we need more CAA airworthiness people out in the field then this is it. That is our position loud and clear.

Jim Thorn November, 1988