Readers Airworthiness Letters Response

I should like to congratulate Jim Thorn and the Australian Aviation magazine for the article on Australian certification procedures in the January 1989 edition of the magazine.

Despite the best intentions of the CAA staff, the present procedures and regulations for the certification of new aircraft types into Australia have become outdated and no longer applicable in the light of international aviation standards.

The Australian aviation market represents approximately one percent of the total free world market. Most aviation manufacturers design their aircraft to meet North American or European standards which represent by far their greatest market potential.

We believe that the professional integrity of both the FAA and the UK CAA authorities is at least as good as that of our own CAA in Australia. Since general operating conditions in Europe and North America are more demanding due to their higher traffic densities and more extreme weather conditions, we cannot see any reason why aircraft certified by the US FAA or the UK CAA should not be easily certified for use in Australia.

The difficulties encountered in bringing new aircraft types into Australia is actively discouraging the introduction of modern and safer aircraft and at the same time, is encouraging the extended use of older aircraft types with lower safety standards due to their outdated technology. Aviation in Australia is expanding at unprecedented rates due to the prevailing economic conditions and forthcoming deregulation. It is also becoming increasingly international, especially for corporate users.

There is an urgent need to review the certification procedures in Australia and to develop a far greater standardisation in the requirements for Australian certification with those of the US and UK aviation regulatory authorities.

I congratulate Jim Thorn for raising this subject for public debate and look forward to cooperating with the CAA in reviewing the existing procedures to see what improvements should be made.

C Ryland Managing Director Hawker Pacific Pty Ltd Condell Park 2200

Dear Sir

Qantas read with interest the feature article in the January issue of your magazine calling for the CAA to streamline its certification procedures.

For many years Qantas has expressed concern over various aspects of the Australian aviation safety regulatory process, particularly when related to regular public transport operations. These include issues such as more consultation within the industry on regulation changes, international agreement on first-of type certification standards and aircraft operational requirements.

Qantas recently publicised its views on these issues in our General Manager Operations’ paper to the Royal Aeronautical Society’s Aerospace 88 Symposium. Our objective was to promote informed debate on matters which have concerned the major Australian airlines for many years. We hope that your readers will also bring further constructive criticism to this debate. For our part, Qantas will continue to press for reform with future submissions to the Task Force which was set up by the previous Minister Peter Morris to undertake a complete review of the Aviation Safety Regulatory process.

There are several matters raised in your article which invite our further public comment and we take up your invitation to include these in your March issue. Firstly, earlier this year the then DoTC released an advisory publication on first-of-type aircraft introduction procedures. Release of this publication was certainly timely. As a reference document it is most informative as it provides a comprehensive description of the current Australian certification philosophy arid associated procedures.

However the airline industry noted with concern the publication’s official restriction on an operator’s direct involvement during the certification process. We believe that the depth of expertise and experience available within the major airlines on airworthiness matters, and in particular the knowledge of the detailed specification of the aircraft being evaluated, make significant contributions to the certification process.

Our experience with our most recent certification programmes for the 767-238 and stretched fuselage 767-338 is that these have been conducted in a spirit of cooperation with Qantas being fully involved during the process.

Planning for introduction of our new 747-438 aircraft is well underway including the programme for validating the basic FAA certification against the CAA’s defined airworthiness standard.

Secondly, Qantas is concerned at the high cost of Australian certification. The manufacturer’s commitment is to deliver an aircraft with an Export Certificate of Airworthiness issued by its own regulatory authority. However extra costs are incurred by the manufacturer in the preparation of additional engineering data, and in conducting additional flight testing to show compliance with Australian requirements. These costs for compliance to a standard other than the basic certification standard are passed on to the airline. Your article refers to a CAA perception that “this cosJJs overplayed by the airlines”. Provision for such costs are negotiated at the contract stage and clearly identified within post-contract documentation and final aircraft pricing.

Costs borne by the CAA are also recovered from the airline. In the past these have been associated with visits to the manufacturers. However with the Authority’s new 100% cost recovery policy such costs will escalate to include its own airworthiness staff review of design substantiation data already accepted by the manufacturer’s own regulatory authority.

Finally, Qantas acknowledges the dedication of the CAA’s airworthiness staff, and appreciates the difficulties the CAA has experienced in recent years in building up strength and expertise in this area since relocating to Canberra. We note however that the CAA believes our constructive criticism of the existing regulatory process to be a “disservice to the Australian public”. We would like to assure the· public that the airline industry has an ol:>vious interest in safety. We meet this obligation through our own measures of self regulation to better the minimum standards set by the Authority.

Our call for much needed reform in the regulatory process we believe is in line with the Authority’s new role of being more publicly accountable for the services it provides to industry.

W Bourke Manager of Aeronautical Engineering Qantas Airways Ltd Mascot 2020

Caa Response Delayed. . .

The management of the CAA has deferred comment at this time on our feature on present CAA airworthiness procedures and standards preferring instead to leave this to their Board, which they appreciate may have differing views on the subject than is held currently within the Authority itself. Consequently the CAA’s Deputy Chief Executive, Allan Rainbird, has advised us that this will be considered at the Board’s February meeting. Providing the Board can meet our normal editorial deadline for the May edition, then we look forward to printing their response in that issue. If the deadline cannot be met then, both parties have agreed that the reply itself would be too dated to proceed with in a later edition.

Dear Sir

Jim Thorn is to be congratulated on his story on the CAA certification procedures as reported in the last edition of Australian Aviation. The major airline companies are not the only ones that have to suffer unjust charges and poor service. General aviation also gets its fair share.

Whilst we in the industry receive relatively good service from the operational area of the CAA, the administrative area leaves much to be desired. The basic problem that the CAA administration suffers is common to many areas of the public sector, that is, that they do not have to give reasonable service to their clients, as they have a totally captive market.

No amount of rhetoric by the CAA management that the CAA is to be run on private enterprise lines will change this basic fact. It is impossible to model any Government Department on private industry lines, as there Is no real accountability. By accountability we mean there is no downside for lack of performance. In the real world of private enterprise, lack of service or charging excessively for services means lack of sales and therefore less income. The next step is quite obviously lack of employment for a firm’s employees, and insolvency for their employer.

Our experience with the CAA is that many of the administrative people have no real idea of the needs and requirements of their clients, in our case the general aviation area. If they did, they would not take 3 to 4 to en_ter additional aircraft types onto air service licences such as they do at this time. Not only can this mean a valuable aircraft may sit around idle for this period of time, but we then have to pay a totally exorbitant amount to have a few words added to a licence. How anyone can possibly justify a light twin to an operator’s air charter Is beyond belief. Such charges and service would not be tolerated in the private sector.

Another example of bureaucracy out of control is the ‘sharing’ of the landing charges applicable to general aviation at capital city aerodromes by two separate departments. (the CAA and the FAC). Each authority has own infrastructure to collect half of the landing charge each. Twice the amount of overhead to collect the same amount of money that was once collected by only one of these departments.

They even have different collection policies.

The CAA insists that accounts under $50 in value be remitted quarterly, whilst the FAG remits all accounts monthly regardless of the amount. Imagine the headaches the CAA gives to firms renting out aircraft in trying to reconcile a landing charge statement for the recovery of landing fees from aircraft renters up to four months after the fee may have been incurred.

When we pointed out this fact to the Avcharge Centre last year and requested monthly billing to alleviate this problem, we were told in no uncertain terms that our request was not possible as it would be uneconomic to provide this requirement.

Once again, both organisations have no consideration, or more importantly, no understanding of the requirements or the needs of their customer. We in the private sector of general aviation do not want any special consideration from the CAA, only efficient, prompt service at a reasonable, justifiable cost delivered in a courteous manner. As a board member of the CAA, Dick Smith would understand the need and desirability for these requirements, and we only hope some of what he has that made him so successful in his own business brushes off onto the department he represents.

G Gamage Canberra ACT

Dear Sir,

Thank you for the probing article on the CAA’s airworthiness procedures inthe January issue.

My reason for being critically interested in this subject is that I was one of the many people who were retrenched by Stillwell back in the early eighties. While it might be taking it a bit far to suggest that the inability to sell the Metro Ill locally was the primary cause of the company’s problems at that time but it is certainly no exaggeration to say that the loss of their number one product certainly made a bad situation critical.

It is thus with extreme disappointment to find that today another similar aircraft, the Beech 1900, is being subjected to the 1dent1cal concrete minded ideology that scuttled the Metro Ill in Australia more than half a decade ago. Considering that in hindsight the Metro has to date been flying comm \ercially for nearly 20 years and that there are now over 170 Metro Ills in daily operation with an excellent (hke 100%) airworthiness record then you would have thought that the senior officers of the CAA’s airworthiness division would have perhaps considered the remote prospect that they had over reacted back in 1981. The debacle with the similarly placed Beech 1900 regrettably shows that absolutely nothing has changed within the Department or whatever tt chooses to call itself this month.

Retraction and Apology

In an article concerning CAA Certification Procedures published in the January/ February 1989 edition of Australian Aviation reference was made to a flight test of a 1900in the USA by the CAA test pilot.

Australian Aviation acknowledges that the references were factually incorrect in that:

1. The CAA test pilot did not perform the engine procedures referred to;

2. The CAA test pilot did not undertake any test to which the Hawker Pacific pilot raised any objection whatsoever.

Australian Aviation withdraws any inference suggesting a lack of expertise and professionalism or the adoption of unsafe or damaging procedures on the part of the test pilot. Australian Aviation apologies to the CAA test pilot for any embarrassment that may have been caused.

I left the industry for a time in disgust at the high-handed approach taken by many senior Departmental officials and the multitude of nonsensical decisions often taken in the much abused name of ‘safety’. Only in recent times have I returned to GA as the industry is now critically short of people in my trade. Ironically one of the first things I encounter back at Bankstown is the Beech 1900 having its engines repaired following its CAA flight test and ferry from the USA. I believe also as I write this that the aircraft is still not anywhere near certification! Maybe you can verify these points for me as many readers must also be wondering what has occurred since the article was originally written.

Somebody more philosophical than I once said that ‘the more things change, the more they stay the same’ – perhaps this is also the CAA’s corporate motto as it regrettably appears to suit them ideally.

Name & address withheld

(In reply to your specific request, yes both PT6 engines on the 1900 had to be stripped down and repaired following the arrival of the aircraft in Australia. At presstime the 1900 had still not achieved its Australian CofA. Ed)

Dear Sir

I feel compelled to respond to your excellent article in the January/February edition regarding CAA Certification Procedures. As a LAME with some 17 years experience, I have dealt with the CAA as both a manager and at the shop floor level.

Within the past few years I have been fortunate to attend overseas the Initial Certification of both the first Canadair Challenger 601 and Cessna Citation ‘3 business jets for Australian use.

I felt that in both cases the only difficulty involved in certifying the aircraft was literally forcing the manufacturers into presenting the aircraft and its paperwork in a manner acceptable to the CAA. There seems to be a total lack of both coordination and understanding between the manufacturers and the CAA at Canberra level, and this may not be entirely due to the fault of either party.

In both cases, when I arrived with local CAA Surveyors I found that considerable coordination by us was required to push the procedure to a satisfactory result. This should not be the case following a visit by the Canberra Certification Team who I feel should brief the manufacturer on our total requirements more thoroughly. The manufacturers must also take far more interest in learning our procedures 1f they wish to sell aircraft in Australia.

Let’s face it, regulations all over the world are different and often written in legal terms and are thus open to ambiguity. Canberra should run regular courses for interested parties to attend to learn and understand our requirements more thoroughly. I am sure they wouldn’t mind paying for the courses as they would be far cheaper than some of the latehour, expensive modifications I have seen in attempts to achieve certification.

T Punton Oyster Bay 2225