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DP Response Form Ageing Aircraft Management Plan Document DP 1205CS

Details:

Name: Clinton Garth Bartlett

ARN: 066036

Association: Cessna Pilot’s Association of Australia.

Responding: Association

Involvement: Member Representative and Technical Support

Consultation: Satisfied

Consent: I consent to have my name published as a respondent to this DP

Date: 7th November 2012

Specific Key Options/Issues:

Option 1 – Do nothing: No further research, oversight or management of the ageing aircraft fleet. This would produce minimal further opportunity to identify and address ageing related catastrophic events before they occur This is not an acceptable option

Option 2 – Matrix Tool: Further develop the prototype Matrix Tool into a production version, permanently available on the CASA website to enable Registered Operators to more accurately establish the likelihood that their aircraft may be suffering from the negative impacts of ageing. This option is acceptable with consideration to the following:

  1. This Matrix Tool is interesting to see the effects of various factors on the likelihood that an aircraft might be suffering from the negative impacts of aging. It was particularly interesting to do after the e-learning training on aging aircraft – as consolidation.
  2. The Matrix Tool has limitations beyond the above. To consider all relevant factors, it would need to be vastly more complex in structure – possibly making it unwieldy. More importantly it is limited by the lack of records/knowledge we have of aircraft over such a long period of time. There are no records kept in logbooks of how an aircraft has been stored, or even where it has been operated.

Option 3 – E-Learning: Further promote and encourage the use of the recently developed Ageing Aircraft Awareness E-Learning course to improve Registered Operator’s knowledge. This would better equip Registered Operators to manage their aircraft in relation to ageing aircraft issues. This option is acceptable with consideration to the following:

  1. Yes this is a good option as part of a solution. E-learning is convenient. It appears to be pitched appropriately at private Registered Operators: not too complex, yet enough detail to feel you have learnt something useful and it was worthwhile doing.
  2. The e-learning better equips the private Registered Operators to discuss the issue with their LAME and other pilots/groups – in effect to further promote the issue and generate open and free ‘discussion’.
  3. The main issue will be how this (and presumably other e-learning courses) will be promoted? How will the operators be ‘encouraged’?

Option 4 – Type Clubs: Further encourage the participation or formation of Type Clubs where members are able to collectively share their knowledge and experience in the support of their ageing aircraft. This might include the ability to amortise any costs associated with the development of CAR 42 approved SoMs, or CASR 21M developed STCs, repairs or technical substitution lists etc. to best support their ageing aircraft type. Agree with this option with consideration of the fact that type clubs vary considerably:

  1. The aim of the clubs may be – social – technical – representative – educational – or various combinations.
  2. The structure and leadership of the clubs varies in terms of willingness / ability / relevant knowledge / paid / voluntary.
  3. Funds available may vary considerably. Not all clubs are equal. The issue would be how to handle such different clubs under one umbrella.

Option 5 – Professional Development: Further develop and deliver professional development training to LAMEs and APs to ensure enhanced SoM outcomes that genuinely address all aspects of the ageing process in the Australian Operating and maintenance environment Agree with this option with consideration of the following

1. Despite professional accreditation/licensing, not all LAMEs are equal

2. Option 5 goes hand in hand with Option 3. It makes easier the conversation between the Operator and the LAME and thus potentially relieves the commercial pressures per above.

General

With regards to Cessna aircraft, Cessna has now issued SIDs programs covering the whole of its fleet. These Special Inspection Documents specifically address the issues of aging and commence when the aircraft are 5 years old. For all new aircraft, these inspections are an integral part of the respective Continued Airworthiness Programs. Our membership who have had the SID program done report that they have found each of these SIDs to be relevant and appropriate to the respective function. Most feel comfortable that Cessna has implemented a sensible but conscientious program for ageing aircraft. There is always discussion within the membership with regards to the inconsistency of differing LAME’s views and also the inconsistency of interpretation of the applicability of Schedule 5 vs the manufacturer’s system of maintenance.