Aircraft Airworthiness & Sustainment Conference 2013
Opening Statement by John F. McCormick
Brisbane – 23 July 2013
Welcome to all.
CASA is pleased to once again be associated with and sponsor this year’s Aircraft Airworthiness & Sustainment Conference.
I congratulate the conference Chairman-Richard Gauntlett-on his resolution to continue to organise and host this important event in the current world climate of financial austerity, noting that the parent organisation in the United States cancelled their equivalent conference earlier this year - as a consequence of budget sequestration.
At this 'fourth' Aircraft Airworthiness and Sustainment Conference we are continuing our discussions and exchanges on the subject of optimising the management of Australia's ageing aircraft fleet - something that remains an increasingly significant challenge as time passes.
CASA's position on ageing aircraft
So what exactly is an ageing aircraft? There is no universal definition as such. At CASA, we take the view that all aircraft are ageing aircraft – beginning at the time of manufacture. The rate at which it ages will, however, depend on how that aircraft is:
- stored over its working life.
Thus chronological age is only one indicator of an ageing aircraft, certainly not the only. While there is nothing inherently wrong with an older aircraft-provided it has been properly operated, stored and maintained-the potential for the effects of maintenance neglect or operational mis-management to accumulate and manifest itself is more likely in an older aircraft.
Similarly, obsolescence should not necessarily be confused with the ageing process:
- a commercial aircraft is obsolete when it is no longer economically viable to keep it operational
- a military aircraft is obsolete when its capabilities are no longer competitive with potential adversaries/challengers.
In both cases, a change in the aircraft's role i.e. reassigning the aircraft to freight or training duties may realise some additional utility out of that ‘ageing aircraft’. In other cases there isn’t the availability of funding to replace the aircraft outright, and increasing sustainment costs are borne to keep the enterprise or capability alive.
These and other factors contribute to the wide-spread extension of aircraft lives beyond the manufacturer’s original expectations. Each aircraft and operational scenario is different, and therefore Australia has no plans to impose a universal life-limit on aircraft based on chronological age alone.
Regular Public Transport sector
CASA has no major concerns regarding ageing aircraft management at the ‘heavy metal’, higher end of the aviation spectrum. The maintenance programs developed for most large commercial aircraft in Australia have extensive involvement with the aircraft's manufacturer. This also extends to the incorporation of manufacturer sponsored ageing aircraft programs and initiatives.
In addition, the amount of resources allocated to the continuing airworthiness support of these aircraft by RPT operators is considered appropriate for continued safe operations.
There is also a welcome rejuvenation of many of Australia’s commercial fleets i.e. A380s, B787s and B737s fleet modernisations to name a few. The days of Australians flying overseas on B747s and B767s are coming to an end.
We must mindful that while many wouldn’t consider a brand new A380 or B787 to be ageing aircraft - how we operate and maintain these aircraft today will have a large impact on just how long the aircraft will remain commercially viable into the future.
General Aviation sector
On the other hand, the situation at the other end of the scale – General Aviation – is very different.
General Aviation has few of the resources and manufacturer’s support arrangements enjoyed by the ‘top end of the town’.
Many General Aviation aircraft:
- are being operated for decades beyond their notional design lives
- have modest or otherwise no manufacturer’s support arrangements
- do not have fatigue or usage profiles as guidance by which to manage them
- receive no more than a yearly/100 hourly inspection that is generic in nature.
The above scenario applies to some 10,000 aircraft of the 15,000 on the Australian Register. This represents a significant concern to CASA.
CASA’s efforts in education
While CASA will always continue to monitor commercial aviation closely – in terms of maintenance, focus will continue to increase on General Aviation sector. We continue to consider a range of initiatives as to how to optimise our oversight of the entire VH registered fleet - starting first and foremost with safety education.
Responsibility for the airworthiness of an aircraft rests with the aircraft’s Registered Operator – or owner – just as it does for a road-worthiness of a car or a sea-worthiness of a boat.
Getting Registered Operators to fully understand their responsibilities as well as the impacts of the ageing process on their aircraft has been a high priority for CASA. Further regulation in this area will be considered as an option only if education fails to positively impact the desired safety outcomes.
CASA’s education initiatives include the distribution of targeted information booklets on the subject of ageing aircraft to all Registered Operators, as well as a series of ageing aircraft educational seminars held around the country in Capital Cities and at Aero clubs over the last few years.
CASA has also developed a very informative e-learning course on the subject of ageing aircraft, which is available to anyone on the CASA web-site. The feedback to date on this initiative, some of which has come from international sources, has been very positive.
In addition, CASA is also trialling a web-based ageing aircraft management tool we refer to as the ‘prototype Matrix Tool’.
This tool provides the user with feedback as to the likelihood their aircraft may be subject to ageing related issues. To date, this tool has had:
- over 13,000 hits during its trial period – around 30 per day – which is very encouraging, considering there are 15,000 aircraft on the Australian Register today
- considerable overseas interest, including from the FAA.
CASA is currently considering whether to further develop this prototype tool into a production version – available permanently – at some stage in the near future.
I urge any aircraft owners who are interested in how this tool can help you better understand how your aircraft is ageing to attend tomorrow’s presentation and engage with my staff on the CASA stand.
Instructions for continuing airworthiness
CASA is also considering several options in regard to the minimum levels of maintenance that are appropriate for aircraft operated many decades beyond their intended use-by date.
As an aircraft ages, the nature and intrusiveness of scheduled inspections needs to increase-much the same as for a person’s medical visitations as one ages. However, there is much evidence to show us that this is not occurring in relation to the ageing aircraft fleet. Registered operators are encouraged to take a closer look at their maintenance inspection regime.
Having an increasingly ageing aircraft fleet, subject to a static and generic maintenance regime does not bode well for the long-term, particularly in the absence of manufacturer’s input i.e. Instructions for Continued Airworthiness – in many cases. Where such manufacturer’s input does exist, it should be incorporated wherever possible.
One example of manufacturer’s Instructions for Continued Airworthiness is Cessna and its Supplemental Inspection Documents or SIDs programs.
Cessna especially is to be commended for its efforts in recognising and supporting the continued airworthiness of many of its products well beyond the timeframes of operation for which those aircraft were originally envisaged.
The SIDs inspection and structural replacement programs are based on years of operational data and operator feedback – and address areas in various aircraft that, for a wide variety of reasons could be susceptible to ageing process – including the continued operation of an aircraft many decades beyond its initial design assumptions.
By way of example, New Zealand Civil Aviation Authority has last year mandated the incorporation of all Cessna SIDs where they exist. The results they have received to date from this policy decision show the decision to be fully justified from a safety perspective with many cases of otherwise unknown structural deterioration now uncovered and addressed.
The Cessna SIDs program is an example of a manufacturer actively involved in the ageing aircraft management process of its aircraft.
On that positive note, I thank you for the opportunity to once again open this important airworthiness conference.
The feedback I get from my people is that this is an excellent forum for the airing and exchange of ideas on how to better manage our respective aircraft and fleets. We pick-up some really good information here each year.
I trust everyone will make the most of the opportunity to maximise their knowledge and pursue worthwhile opportunities at this ‘Aircraft Airworthiness and Sustainment Conference 2013’ over the next 3 days.