Proposed amendments to Part 66 MOS – addition of new type rated aircraft and additional miscellaneous amendments - (CD 2111MS)
Feedback updated 14 Dec 2021
We asked
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.
You said
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.
We did
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.
Published responses
View submitted responses where consent has been given to publish the response.
Overview
Part 66 of the Civil Aviation Safety Regulations 1998 (CASR) sets out the requirements for, the application for, the granting of, and the appropriate use of aircraft maintenance engineer licences and ratings. The detailed standards for the issue of aircraft engineer licences, ratings, other requirements (including training requirements) and privileges associated with the licence, are included in the Part 66 Manual of Standards (MOS).
On occasion throughout each calendar year, we make miscellaneous and editorial amendments to the Part 66 MOS. These amendments do not substantially alter existing regulatory arrangements.
This consultation seeks feedback on the amendments we are proposing to make to the Part 66 MOS. These amendments include:
- clarification on the basic knowledge and competency requirements for applicants who are applying for a Category C licence
- updates to type rating information including the addition of new aircraft types and new type certificate holders 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 2021 (No.2) would make the following changes.
Section 66.A.25 amendments
Section 66.A.25 sets out the basic knowledge and competency requirements for a person who applies for a category or subcategory of licence, or for a person who applies for the addition of a category or subcategory to an existing licence.
The proposed amendment would update section 66.A.25 – Basic knowledge and competency requirements, to clarify the basic knowledge requirements for grant of a Category C licence, to a person (an applicant) who:
- holds an existing B1 or B2 licence, or
- does not hold an existing B1 or B2 licence, or
- holds an academic degree mentioned in subparagraph 66.A.25 (h)1.
Note: The basic knowledge requirements for a Category C licence are the same as that for a Category B1 or B2 licence.
This clarification would prevent an applicant for a Category C licence (who currently holds an existing B1 or B2 licence, or who holds an academic degree qualification referred to in subparagraph (h)1) from having to be re-examined on basic knowledge already satisfied via issue of their B1 or B2 licence, or by completion of their technical degree.
Appendix IX amendments
Appendix IX of the Part 66 MOS specifies the aircraft types and type rating endorsements for various categories of aircraft engineer licences, that CASA has designated as requiring specific type training by aircraft engineers.
This amendment updates, at the request of individual aircraft operators and maintainers, the list of aircraft type ratings and rating endorsements in Appendix IX by the addition, variation and substitution of items. The commencement of operations of those aircraft concerned is currently pending and therefore the addition of these new aircraft types to the lists in Appendix IX are required.
Impact on industry
For aircraft that CASA has 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. Therefore, these amendments are considered to have a positive impact on industry and those 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 only enhance aviation safety.
Previous consultations
The amendments of the Part 66 Manual of Standards Amendment Instrument 2021 (No.2) that propose to add new aircraft type certificate (TC) holders and new aircraft type ratings are being made at the request of individual aircraft operators and maintainers, who will shortly commence operations and maintenance of those aircraft being added to the Part 66 MOS. The amendments that will add new aircraft type ratings, were consulted with the Part 66 Technical Working Group (TWG) at their most recent meeting held on 16 September 2021. No feedback to these proposed amendments were received by CASA.
As is often the case when drafting any Part 66 MOS Amendment Instrument, CASA's Legal, International and Regulatory Affairs (LIRA), Advisory and Drafting section, use the opportunity to make other minor editorial adjustments/corrections. For these types of editorial changes, which do not substantially alter existing regulatory arrangements, they are included for feedback purposes during the public consultation period required under legislation for any amendment made to a Manual of Standards. As such, these additional editorial amendments were not previously consulted with the Part 66 TWG.
Why your views matter
CASA recognises the valuable contribution that consultations make to the ongoing development and improvement of legislation, such as to a Manual of Standards. We are consulting to ensure that the proposed amendments are clearly articulated and understood by industry and will work in practice and as they are intended.
Comments are sought from every sector of the community. This includes the general public, government agencies and all sectors of the aviation industry, whether as an aviator, aviation consumer and/or provider of related products and services.
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 2111MS, which provides background on the proposed changes to the Part 66 Manual of Standards (MOS)
- Consultation Draft – Part 66 Manual of Standards Amendment Instrument 2021 (No.2)
- 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 2111MS 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 MOS.
All comments 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 CASA policy, will be incorporated into the final amendment.
Audiences
- CASA Staff
- 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
- Licensing
- Airworthiness/maintenance (CAR 30 and CASR Part 145 maintenance orgs)
- Aircraft engineer licensing
Share
Share on Twitter Share on Facebook