Proposed amendment to Part 66 Manual of Standards aircraft engineer licensing training - (CD 1908SS)

Closed 27 Sep 2019

Opened 30 Aug 2019

Results Updated 19 Feb 2020

From 30 August to 27 September 2019, CASA invited comment on a set of proposed amendments that would introduce a new ‘self-study’ training and examination pathway that would lead to the grant of a Part 66 aircraft engineer licence. 

The summary of consultation below outlines the comments provided by respondents to the consultation and provides CASA’s response to the issues raised.

One hundred and twenty-nine (129) submissions were received with 81 respondents consenting to having their comments published.  Where permission has been granted, individual responses are available below.

As a result, CASA will proceed with the development of the detailed policies and administrative systems required for introduction of the new self-study pathway.

On completion of this work, in the first half of 2020, CASA will seek additional feedback from industry on the detailed policies and requirements through a second round of consultation with the Part 66 Technical Working Group and the aviation industry.


Published Responses

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


We are proposing to amend the Part 66 Manual of Standards (MOS) to introduce a new ‘self-study’ training and examination pathway that leads to the grant of a Part 66 aircraft engineer licence.

The proposed new pathway is an alternative to the current requirement to undertake licence category training via a Part 147 Maintenance Training Organisation. It will be similar to the CASA Basics examinations/Schedule of Experience scheme that existed under the previous CAR 31 licensing system.

The Part 66 licensing system introduced in June 2011, transitioned aircraft maintenance licensing requirements from the Civil Aviation Regulations 1988 (CAR), to the Civil Aviation Safety Regulations 1998 (CASR). It adopted A, B1, B2 and C licence categories and aircraft type ratings in line with the European Aviation Safety Agency (EASA) system.

Since Part 66 came into effect, CASA has conducted a comprehensive post-implementation review (PIR) of all Part 66 legislation and has received valuable feedback from key stakeholders, including Part 66 licence holders and training organisations, on the implications and effects of the aircraft maintenance licensing rules. The feedback has highlighted the opportunity to simplify and clarify some aspects of the legislation, address anomalies, gaps and unintended consequences.

The ASAP appointed a Technical Working Group to review and address the specific issues identified in feedback received to the Part 66 PIR.

One of the primary issues identified by the PIR and discussed by the TWG was concern over industry's limited access to licence category training, examination and assessment for a Part 66 licence.

To address this issue and to more closely align Part 66 to EASA Part 66, we propose to introduce a new training pathway to obtain a Part 66 maintenance engineer licence. The new pathway would provide industry a self-study option, as an alternative to the existing Part 147 MTO requirements, under which a person may be granted a licence by:

  • passing theory exams administered by CASA based on the 17 Part 66 basic knowledge modules contained in the MOS (the syllabus could be self-studied from CASA recognised EASA Part 66 textbooks)
  • submitting to CASA a log demonstrating they have achieved the required practical maintenance experience on operating aircraft specific to the category of licence being applied for.

This proposal also includes the following:

  • Seven miscellaneous amendments (items 46 to 52) unrelated to this proposal, that add new aircraft type ratings to the list of type ratings in Appendix IX of the Part 66 MOS. For administrative purposes, they are being consulted as part of the one instrument.
  • A number of additional amendments to the Part 66 MOS to simplify current language to more closely align Part 66 to EASA Part 66, and to provide clarity to other provisions within the MOS.

Why We Are Consulting

We are consulting on the proposed self-study training and examination option, to ensure the proposed amendments are clearly articulated and will work in practice as they are intended. Your feedback will help inform our policy decision-making process and any future regulatory change. 

Further details regarding the proposed set of amendments to the Part 66 MOS can be found in the Summary of Proposed Change on CD 1908SS under the ‘Related’ section of this consultation. Comments on the CD 1908SS should be submitted through the online response form.

Documents for review

  1. Summary of proposed change on CD 1908SS
  2. Consultation draft — Part 66 Manual of Standards Amendment Instrument 2019 (No. 1)
  3. Compilation draft — Part 66 MOS, incorporating the proposed amendments into the relevant sections of the MOS

The questionnaire has been designed to give you the option of either providing feedback on the proposal in its entirety or to provide feedback on the individual amendments throughout the Part 66 MOS.

General comments and file upload option

There is a general comments box at the end of the questionnaire, in which you can insert any additional comments relating to the regulatory amendment, which you may not have already addressed.

Note: We are no longer able to offer the option to upload files due to the potential risk of malware.

Using an iPad

If you are using an iPad to complete the survey you will be asked to 'download the relevant PDF'. Depending on the software you have on your iPad you may need to download the free viewer to review the single document PDF files. Where a file is a 'multi-file or portfolio PDF you will need to source the Adobe free view - available from iTunes.

What happens next

Once the consultation has closed, we will register and review each submission received through the online response form. We will make all submissions publicly available on the Consultation Hub, unless you request your submission remain confidential. We will also publish a Summary of Consultation which summarises the feedback received.


  • CASA Staff
  • Engineers
  • Part 147 of CASR Maintenance training organisations


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