Proposed amendments to Schedule 3 of Part 61 Manual of Standards to support implementation of the Flight Operations Regulations and to ensure it is fit for purpose- (CD 2110FS)

Closed 15 Nov 2021

Opened 1 Nov 2021

Feedback updated 14 Jan 2022

We asked

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.

You said

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.

We did

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.

 

Published responses

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

Overview

Part 91 of CASR and the associated flight operations rules, will introduce some change to what pilots and operators need to know or do during the application of the privileges of their authorisations. As a result, we propose to amend the Schedule 3 standards.

The proposed amendments will ensure:

  • harmonisation with the new Part 91 and associated flight operations rules
  • aeronautical knowledge content of Schedule 3 will be fit for purpose for developing syllabuses for courses of training, and content for the various FCL exams
  • CASA exam question bank will contain, and develop, contemporary and relevant questions appropriate for each subject, and deliver accurate knowledge deficiency reports.

Principal changes

The primary purpose of the review and amendment to Schedule 3 is to align content and vocabulary with Part 91 and associated flight operations rules.

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.

Previous consultations

Following extensive consultation with the aviation community from 2011, the general operating and flight rules package was published for public review as CD 1511OS - Part 91 of CASR and associated MOS for general operating and flight rules in August 2015. We published a further consultation draft of the proposed Part 91 of CASR and its associated Manual of Standards (MOS) for general operating and flight rules on our Consultation Hub in March 2018 with summary of consultation published in August 2018. Feedback on Part 91 of CASR from previous consultations in 2011 and 2015 was considered and incorporated into the 2018 consultation drafts.

A Flight Operations Regulations Implementation Technical Working Group (TWG) was established by the Aviation Safety Advisory Panel (ASAP) in June 2021.  The TWG has provided current, relevant technical expertise, feedback and recommendations to CASA (and ASAP, where relevant) on implementation activities for the benefit of industry.

The proposed changes to Part 61 MOS Schedule 3 are consequential to the implementation of the flight operations rules.

Why your views matter

We recognise the valuable contribution consultations make to the policy decision-making process and future regulatory change. We are consulting to ensure that the proposed amendments to Part 61 MOS, Schedule 3 accurately and practically reflect the new rule set and will work in practice as intended.

This consultation seeks feedback on the proposed amendments to Part 61 MOS, Schedule 3. Although Schedule 3 is most relevant to aspiring pilots, training organisations, course developers and examination writers, comments are sought from every sector of the community. This includes the general public, government agencies and all sectors of the aviation industry.

The survey below has been designed to give you the option to provide feedback on the policy topics applicable to you.

Your feedback will make a valuable contribution to our standards development and making process and help to inform any future regulatory change.  Comments should be submitted through the online response form.

Documents for review

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

  • Summary of proposed change on CD 2110FS, which provides background on the proposed standards
  • Consultation Draft – Schedule 3 Part 61 MOS - Aeronautical knowledge standards
  • MS Word copy of online consultation for ease of distribution and feedback within your organisation

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.

Comments on the CD 2110FS and the Consultation Draft – Schedule 3 Part 61 MOS - Aeronautical knowledge standards, should be submitted through the online response form.

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 the CASA 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 regulations.

All comments on the Consultation Draft - Schedule 3 Part 61 MOS - Aeronautical knowledge standards, will be considered. Relevant feedback that improves upon the proposed regulations and is consistent with the regulations and other CASA policy, will be incorporated into the final making. The feedback we receive from this consultation will also assist us in confirming adequate implementation and transition timeframes.

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 by the Flight Crew Licensing - Aeronautical Knowledge Exams consultative group over several months.

Post-implementation review

We will monitor and review the amended standards during the transition phase and on an ongoing basis.

Audiences

  • CASA Staff
  • Flight instructors and flight examiners
  • Flight training operators
  • Pilots
  • Sports aviation operators
  • Hot air balloon operators
  • Aviation Meteorology
  • Forecaster/Meteorological service provider
  • School/Education/Aviation Theory Provider
  • Self-administering Aviation Organisations
  • Parachuting sport aviation bodies
  • Pilots of parachuting aircraft
  • Balloon Instructors and flight examiners
  • Balloon Pilots
  • Balloon Sports aviation operators
  • Tethered gas balloon operators
  • Balloon AOC holders and applicants
  • Balloon pilots holding a CP(B)L
  • Sport and recreational balloon owners and pilots
  • Sport aviation bodies & prospective ASAOs
  • Gliding clubs
  • Aircraft owner/operator
  • Aerial work operator
  • Part 142 operators
  • Part 141 operators
  • Floatplane operators

Interests

  • Sport and recreational aviation
  • Human factors
  • Licensing
  • Operational standards
  • Flight training
  • Private operations
  • Self administration aviation activities
  • Sport and recreational ballooning
  • Training and checking systems
  • In-house training for CASA FOIs
  • Sport and recreational aviation - balloons
  • Safety promotion