Proposed amendments to Part 66 MOS – addition of new aircraft type ratings (CD 2306MS)

Closed 29 May 2023

Opened 1 May 2023

Feedback updated 8 Jun 2023

We asked

This consultation provided details of amendments we are proposing to make to the lists of type rated aircraft in Appendix IX of the Part 66 Manual of Standards (MOS). The consultation has now closed, and a summary of the feedback is provided below.

About this consultation

This consultation survey asked respondents to provide their feedback on a small number of proposed amendments that will update existing type rating information and add new aircraft types and a new type certificate holder to the aircraft type ratings lists in Appendix IX of the Part 66 MOS. A total of 15 responses were received to the consultation survey. Of the 15 respondents, 12 identified themselves as licensed aircraft maintenance engineers (LAMEs), one identified as an aircraft owner/operator, one as a professional organisation representing LAMEs, 3 identified as a CAR 30 approval holder, a further 4 respondents identified as a Part 145 AMO and 2 identified as CASA employees.  

You said

Of the total number of responses received:

  • One respondent's comments were unrelated to the details of these amendments.
  • Five respondent's comments were general in nature relating to aircraft type ratings, but not targeted towards any specific amendment.
  • Nine respondents expressed their support of the proposed amendments.

Summary of feedback

General comments received in support of the proposed amendments stated the amendments would increase the safety of maintenance carried out on these aircraft due to the engineer needing to undertake training on the specific aircraft type. One respondent commented that any extra training required by an engineer is a good thing and that whilst experience is essential, as retirement approaches for the "old school" engineers, it is essential to continue to raise the bar on skills and training for the younger generation. One respondent commented that there were limited training courses for some earlier Airbus helicopter MBB-BK 117 variants, while another respondent suggested CASA conduct a review of some of the other existing type rated aircraft which were not type rated under the previous CAR 31 licensing scheme.

We did

Based on the comments received, the majority of which were supportive of the proposed changes, we will proceed with the proposed amendments as presented.

We acknowledge the comments describing issues with certain aspects of the Part 66 type rating requirements. These issues will be considered as part of our GA Workplan.

Published responses

View submitted responses where consent has been given to publish the response.

Overview

We are seeking your feedback on amendments we are proposing to make to the Part 66 Manual of Standards (MOS) to ensure it is fit for purpose.

These amendments include updates to type rating information and the addition of new aircraft types and a new type certificate holder to the aircraft type ratings lists in Appendix IX of the MOS. 

Purpose and scope of proposed amendments

The proposed Part 66 Manual of Standards Amendment Instrument 2023 (No. X) would enable the following changes to:

  • add a new type certificate (TC) holder – AIRBUS CANADA LIMITED PARNERSHIP, and new aircraft types, to the list of TC holders and their aircraft type ratings currently listed in Appendix IX, Table 1.
  • update the aircraft type rating information in Appendix IX, Table 1 currently listed for the following type certificate (TC) holders:
      • CESSNA AIRCRAFT COMPANY
      • EMBRAER
      • GULFSTREAM AEROSPACE LP (GALP), c/o Israel Aircraft Industries
  • update the aircraft type rating information in Appendix IX, Table 2, Part 2 currently listed for type certificate (TC) holder – AIRBUS HELICOPTERS DEUTSCHLAND GmbH
  • update the aircraft type rating information in Appendix IX, Table 5 currently listed for type certificate (TC) holder – AIRBUS HELICOPTERS DEUTSCHLAND GmbH.

Appendix IX amendments

Appendix IX of the Part 66 MOS outlines the aircraft types and type rating endorsements for various categories of aircraft engineer licences that we have designated as requiring specific type training by aircraft engineers.

A request from individual aircraft operators and maintainers has preempted the amendment instrument to update the list of aircraft type ratings and rating endorsements in Appendix IX. The commencement of operations of the aircraft outlined above is currently pending until the new aircraft types have been added to the lists in Appendix IX.

Impact on industry

For aircraft that have been designated in the Part 66 MOS as requiring a type rating, specific aircraft type training is required by aircraft engineers prior to them being able to certify for maintenance performed on these aircraft.

These amendments are considered to have a positive safety effect on industry and affected parties, in that they require individuals - who will maintain and certify for maintenance performed on these aircraft - to undertake aircraft specific type training, which in turn will enhance aviation safety.

Previous consultations

As the changes included in the Part 66 Manual of Standards Amendment Instrument 2023 (No. X) only affect the operators and maintainers who made the request to CASA, the Part 66 Technical Working Group are generally not consulted prior to opening the 28 day standard public consultation period - required under legislation for any amendment made to a MOS.

Why your views matter

Your feedback will help us make sure the proposed requirements are suitable, the final legislation is clear and will work as intended.

Please submit your comments using the survey link on this page.

If you are unable to provide feedback via the survey link, please email regulatoryconsultation@casa.gov.au for advice. 

Documents for review

All documents related to this consultation are attached in the ‘Related’ section at the bottom of the overview page. They are:

  • Summary of proposed change on CD 2306MS, which provides background on the proposed changes to the Part 66 Manual of Standards (MOS)
  • Consultation draft – Part 66 Manual of Standards Amendment Instrument 2023 (No. X)
  • MS Word copy of online consultation for ease of distribution and feedback within your organisation. 

What happens next

At the end of the response period, we will:

  • review all comments received
  • make responses publicly available on the consultation hub (unless you request your submission remain confidential)
  • publish a Summary of Consultation which summarises the feedback received and outlines any intended changes and next steps for the Part 66 MOS.

All comments received on the proposed amendments will be considered. Relevant feedback that improves upon the proposed amendments and is consistent with the Part 66 MOS and other related policy, will be incorporated into the final amendment.

Audiences

  • CASA Staff
  • Air operators
  • Airworthiness organisations
  • Part 147 of CASR Maintenance training organisations
  • Part 145 of CASR approved maintenance organisations (AMO)
  • Regulation 30 of CAR maintenance organisations (CAR 30)
  • Licensed aircraft maintenance engineers (LAME)
  • Aircraft maintenance engineers (AME)

Interests

  • Airworthiness / maintenance
  • Licensing
  • Airworthiness/maintenance (CAR 30 and CASR Part 145 maintenance orgs)
  • Aircraft engineer licensing