Commissioning of aerodrome lighting systems – Draft AC 139.C-11 v1.0

Closed 23 Nov 2021

Opened 9 Nov 2021

Feedback updated 21 Dec 2021

We asked

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.

You said

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.

We did

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.

Published responses

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


Aerodrome lighting provides visual guidance for pilots when approaching, landing and operating at an aerodrome at night or in reduced visibility conditions.

Before commissioning any aerodrome lighting system, an aerodrome operator must ensure they complete a series of checks to meet the requirements contained in the Part 139 (Aerodromes) Manual of Standards (MOS).

A new aerodrome lighting system must not be made available for use until it has been commissioned. The replacement or upgrade to an existing commissioned lighting system must also be commissioned before being made available for use.

In certain circumstances, CASA may direct the completion of a ground and/or flight check of an already commissioned aerodrome lighting system. These circumstances include a substantial change to the system or through an adverse performance report from a pilot or aircraft operator.

The aerodrome operator is responsible for providing written evidence to CASA of the commissioning process and for ensuring that all required check reports are obtained prior to requesting a Notice to Airmen (NOTAM) or updating the AIP.


This purpose of Advisory Circular (AC) 139.C-11 v1.0 is to provide general information and advice on the requirements and method of commissioning various aerodrome lighting systems. For those systems that require a flight check as part of the commissioning process, advice on how to  conduct the flight check is also provided.


This AC will be of interest to:

  • aerodrome owners/operators
  • persons conducting ground checks of aerodrome lighting systems
  • persons conducting flight checks of aerodrome lighting systems.

Draft AC 139.C-11 v1.0 will replace AC 139-04(0) - Commissioning of aerodrome lighting systems.

Why your views matter

CASA recognises the valuable contribution that community and industry consultation makes to the regulatory development process. For this reason, we are seeking feedback on whether the draft AC is fit for purpose and provides adequate guidance on:

  • requirements and method of commissioning various aerodrome lighting systems
  • the conduct of the flight check when required as part of the commissioning process.

A copy of the draft AC 139.C-11 v1.0, is provided below as well as appearing on the Feedback page of the survey.

Please read the AC document before providing your feedback.

Note: The MS Word document is not to be used as an emailed submission, unless there are extenuating circumstances and this form of submission has been agreed to by the consultation project lead.

What happens next

At the end of the response period for public comment, we will review each comment and submission received. We will make all submissions publicly available on our website, unless you request your submission remain confidential. We will also publish a Summary of Consultation which summarises the feedback received, outlines any intended changes and details our plans for the AC.


  • Certified aerodrome owner/operator
  • Aerodrome owner/operators
  • CASA aerodrome inspector
  • Aerodrome industry consultant


  • Airspace and infrastructure
  • Operational standards