CASA Consultation Hub

This consultation asked industry to provide feedback on the draft advisory circular (AC) on the commissioning of aerodrome lighting systems.

Commissioning is a final check of a new, upgraded or replaced aerodrome lighting system prior to being made available for operational use at night or in low visibility conditions. It is designed to ensure that the installed system is complete, compliant, and useable.

The revision of this AC was triggered by the revision of Part 139 (Aerodromes) Manual of Standards (MOS) 2019.

The consultation has now closed, and a summary of the feedback is provided below.

A total of 13 responses were received from five qualified flight checkers, 3 aerodrome managers, 3 lighting supplier/consultants and 2 air navigation service provider personnel.

Of the respondents, 12 consented to their submissions being made public.

Summary of feedback

In addition to some relatively minor editorial and typographical matters raised, the main actionable subjects that were identified included:

• ground check procedures and documentation requirements (including coordination with air traffic control which has been partially addressed)
• qualified flight checker approvals
• optional lighting during flight check.

There were some comments on important matters that could not be addressed within the scope of this AC. The reasons why include:

• requirement established by Part 139 MOS
• more applicable to the lighting planning and design phases
• insufficient data to support a change at this stage.

Respondents who made submissions on these topics are encouraged to raise these issues in appropriate consultative forums ahead of future amendments to the Part 139 MOS.

Each comment was reviewed and, where actionable, incorporated in the text of the AC. All comments were greatly appreciated as the resulting AC is a better product for it.

With respect to the 3 areas of actionable comment, the following summarises the actions taken.

The development of the ground check procedure details and the addition of a checklist template addressed several comments. Firstly, it is a direct response to those who identified a disparity in the guidance provided on flight checks as compared to ground checks and the lack of guidance for documenting ground checks. Other comments addressed in these changes include ensuring technical PAL specifications are met and lighting activation and control by third parties is checked.

The requirements for and approval of qualified flight checkers has been changed considering comments received and changes to flight operations regulations. Firstly, a qualified flight checker no longer needs to be a pilot. The flight safety aspects that appeared in the previous AC are now covered by Part 91 of CASR. As such, the qualified flight checker role is now focused on lighting standards and performance.

In the previous AC, there were some non-runway lights included in the flight check procedures. While it is not a MOS 139 requirement to check these lights, it was decided to retain the guidance material on checking them, if the aerodrome operator wished to have it done. A section on the aerodrome operator establishing a scope for the flight check has been added and the word optional has been added to the relevant sections of the AC and the checklist.

This consultation provided details of miscellaneous amendments, including the addition of some new aircraft type ratings, CASA is proposing to make to the Part 66 Manual of Standards (MOS). The consultation period has now closed. A summary of feedback is provided below.

About this consultation

Participants in this survey were asked to provide their feedback on a small number of proposed minor amendments to the Part 66 MOS. A total of 14 responses were received to the consultation survey. Of the 14 respondents, nine of these identified themselves as licensed aircraft maintenance engineers (LAMEs), two identified as CAR 30 approved maintenance organisations, a further two respondents identified as falling into the 'other' category, with the remaining respondent identified as falling into a 'licensing' category. In addition, nine of the 14 respondents have given permission for their submission to be published by CASA.

Of the total of number of responses received:

• One respondent's comments were unrelated to the topics of this amendment.
• Two respondent's comments were general in nature relating to aircraft type ratings, but not targeted towards any specific amendment.
• One respondent's comment suggested grouping one of the variants of the Cessna 525 aircraft together with similar variants under the one type rating endorsement.
• Seven respondents expressed their support of the proposed amendments.
• The remaining three respondents disagreed with the amendment related to the Category C licence academic qualification pathway.

Summary of feedback

More general comments received in support of the proposed amendments stated the amendments made perfect sense and were appropriate. One comment in support of the academic qualification pathway for a Category C licence agreed that if an applicant who already has obtained the basic knowledge applicable for a Category B1 or B2 licence, he/she should not need to be re-examined on this knowledge when applying for a Category C licence.

One respondent expressed a view that a particular variant of the Cessna 525 aircraft (i.e., the Cessna 525C - CJ4) should be included in the proposed amended type rating endorsement for the Cessna 525 which will include the 525, 525A, 525B variants.

Three respondents took exception to the current Part 66 policy to qualify for a Category C licence, via an academic qualification training pathway.

Based on the comments received and the miscellaneous and minor nature of the topics covered by the amendments, CASA will proceed with the proposed amendments as presented.

This consultation sought feedback on the proposed amendments to Part 61 MOS, Schedule 3 to ensure that they accurately and practically reflect the new rule set and they will work in practice as intended.

The consultation was open to industry from 1 Nov 2021 to 15 Nov 2021. It has now closed, and a summary of the feedback is provided below.

CASA thanks all respondents for their constructive feedback.

About this consultation

The new CASR Flight Operations Regulations came into effect on 2 December 2021. To harmonise with these changes, amendments are required for the Part 61 Manual of Standards (MOS) Schedule 3, Aeronautical knowledge standards.

The primary purpose of the amendments to Schedule 3 is to align content and vocabulary with Part 91 and the associated flight operations rules; however, concurrent amendments include:

• editorial changes to make elements associated with the helicopter units more relevant to that aircraft category
• improvements to support Schedule 2 practical competencies and underpinning knowledge currently examined for the issue of licences, ratings and endorsements
• action words added to many of the schedule’s unit elements which articulate the level to which the knowledge in the standard must be demonstrated on completion of a course of training, essential for the document to be regarded as an authoritative competency standard
• correction of grammar and formatting errors.

The consultation asked respondents if they agreed that:

• the proposed changes harmonise Schedule 3 units with the new flight operations rules
• the editorial changes make units associated with the helicopter category more relevant to that aircraft
• the action words added to several Schedule 3 unit elements accurately state the level to which the knowledge in the standard must be demonstrated on completion of a course of training
• Schedule 3 is fit for purpose.

A free text field was provided for any general comments regarding the proposed amendments and any potential impact the changes may have on a respondents' operations and was not covered in the consultation.

There were 5 respondents to the consultation. Two represented flying training organisations, 2 were provided by flying instructors, and one was a pilot. Two respondents provided a written submission and one consented to having their response made public. Four of the respondents requested their submissions be kept confidential.

Summary of feedback

Of the 5 respondents, all their responses supported the proposed amendments.

All agreed that the changes harmonise Schedule 3 units with the new flight operations rules, and that the action words added to several Schedule 3 unit elements accurately state the level to which the knowledge in the standard must be demonstrated on completion of a course of training.

While 3 respondents indicated they were undecided or that the helicopter category was not their area of expertise, two agreed that the editorial changes make units associated with the helicopter category more relevant to that aircraft.

Three respondents agreed that Schedule 3 aeronautical knowledge standards amended as proposed were fit for purpose, one indicated they were undecided or that it was not their area of expertise, and one agreed, but with changes.

Written feedback was provided by 2 respondents which provided several editorial corrections and recommendations for the Schedule 3 amendments which will be considered for incorporation into the amendment when made.

In addition to the feedback particular to Schedule 3, recommendations were also made to correct a spelling error in Schedule 2, clarify the aeronautical knowledge content of the RPL Navigation endorsement in Schedule 1, Appendix G.8 (Examination code RPLN in Schedule 4 Appendix 1), and to improve the Table of Contents hyperlinks within the version of the Part 61 MOS and other Manuals of Standards available on the Federal Register of Legislation website. Some of these recommendations are already being actioned in the present tranche of amendments, and all will be given careful consideration in the next amendment cycle.

Overall, respondents strongly supported the proposals. As a result, CASA will now undertake to implement changes to licensing examinations consistent with the proposed amendments.

While the Schedule 3 amendment should come into effect with the flight operations regulations, transition will be defined by the rate at which new exam questions are seeded into the flight crew licence exam suite.  A phased approach is proposed to occur over several months.