We sought industry feedback between 17 and 31 August 2022 on proposed changes to the privileges of the Grade 1 training endorsement.

Industry had previously told us that parts of the flight training and testing scheme are not working as efficiently as intended. Not all of the privileges of the Grade 1 Flight Instructor Rating under the old scheme were transferred to the Part 61 Grade 1 training endorsement and this has diminished the incentive for flight instructors to seek a Grade 1 training endorsement.

We proposed changing the rules to allow some Grade 1 training endorsement holders to conduct:

• flight training for a Grade 2 training endorsement, design feature training endorsement, flight activity training endorsements and low-level training endorsements
• assessments (flight tests) and grant of nominated ratings and training endorsements.

About this consultation

We received 43 responses, mostly from flight instructors and flight examiners, pilots and flight training operators.

The consultation survey asked respondents “Do you have any comments about the proposed instrument?”. Twenty-nine responses were clearly in support of the proposed instrument. Ten responses implied support for the objectives of the policy, while either suggesting changes to the technical detail of the instrument, proposing changes that are out of scope of the instrument, or posing questions on the operation of the instrument.

Common themes from the free text responses included opinions that the new rules will:

• encourage more uptake of Grade 1 training endorsements and support the retention of experienced instructors in the flight training industry
• streamline the pathway for Grade 1 training endorsement holders to attain flight examiner ratings
• provide better flexibility and efficiency, and reduce barriers and burdens for flight training operators
• improve access to training and assessment (flight test) activities for nominated authorisations
• maintain aviation safety as the additional privileges are within scope of ability of Grade 1 training endorsement holders.

Four responses did not support the proposed instrument. These free text responses included comment that the instrument could:

• decrease the level of skill within the industry, and lead to reduced aviation safety or increased risk
• permit Grade 1 training endorsement holders to conduct activities that they are not competent to conduct, and for which flight training operators are unable to adequately prepare the Grade 1 training endorsement holders to conduct
• lead to conflict between the motivations of flight training operators and the required independence of assessment activities conducted by Grade 1 training endorsement holders
• create two standards for assessments.

Summary of feedback

Common themes, issues and suggestions raised in responses included:

Conduct of assessment (flight test)

Seven respondents made comments relating to the proposal to allow relevant Grade 1 training endorsement holders to conduct nominated assessments (flight test) and grant authorisations. The comments related to:

• Grade 1 training endorsement holders conducting assessment (flight test) activities without a significant amount of experience conducting training for the authorisation, and suggest that minimum training and experience requirements be included
• concern that CASA may be overestimating the industry’s current capabilities to safely conduct assessment (flight test) activities
• ongoing oversight from CASA
• potential conflict between the motivations of flight training operators and the required independence of Grade 1 training endorsement holders who conduct assessment (flight test) activities
• indemnity insurance under CAAP ADMIN-1 that will not apply to Grade 1 training endorsement holders who conduct assessment (flight test) activities.

We recognise that the Grade 1 training endorsement holders who can make use of the instrument are experienced in training pilots and/or other instructors. Assessment of competency is a fundamental capability of all instructors, and as such these instructors have demonstrated their ability to assess trainees undergoing training at least at the basic level. What they have not covered in their training is the administration aspects of conducting flight tests and granting authorisations. While we acknowledge the possibility of a Grade 1 training endorsement holder conducting an assessment (flight test) for a training endorsement which the Grade 1 training endorsement holder themselves recently attained, it should be noted that the core competency of the Grade 1 training endorsement includes the ability to assess trainee competency. Grade 1 training endorsement holders will need to comply with the general competency rule in regulation 61.385 of CASR and ensure they are competent to conduct the activity in an aircraft.

We will review how the proposed instrument has worked before amending Part 61 of CASR, to further consider whether the assessment for the grant of the additional training endorsements needs to be a flight test. This would mean that Grade 1 training endorsement holders would be permitted to assess and grant the endorsements without conducting a flight test, as for flight activity and design feature endorsements and indemnity will therefore not be extended to Grade 1 training endorsement holders.

Further expansion of Grade 1 training endorsement privileges

Four responses suggested that the proposal does not adequately address problems experienced by the rotary sector conducting training for specialised activities typically associated with the low-level, aerial application or night VFR ratings and endorsements, and should be extended. These responses suggested that:

• Grade 1 training endorsement holders should be able to conduct assessment (flight test) for the grant of the aerial application rating (day) and aerial application rating (night) training endorsements
• Grade 1 training endorsement holders with either a low-level training endorsement or a night VFR training endorsement should be permitted to conduct flight tests for a low-level rating or night VFR rating (as relevant)

• experienced pilots should not need a Grade 1 training endorsement to train, assess and sign off for activities such as low-level, aerial application, firefighting, sling and winch operations.

CASA is developing an alternative pathway for the training, assessment and grant of nominated 'specialised pilot endorsements' as part of its GA Workplan: Improving pilot licensing rules | Civil Aviation Safety Authority (casa.gov.au). The generic term specialised pilot endorsements has been used by CASA to refer to the aerial mustering, sling operations, winch and rappelling operations, and firefighting endorsements to the low-level or aerial application rating (as relevant). CASA expects that this project will provide benefit for operators and pilots who conduct some of the specialised activities mentioned above. The focus of the alternative approach is to facilitate the training, assessment, and grant of nominated low-level or aerial application endorsements to experienced pilots, rather than to facilitate the training, assessment and grant of nominated training endorsements to other instructors.

We expect to make a draft instrument for the alternative 'specialised pilot endorsements' pathway available for consultation in the near future and will seek feedback to determine if that instrument will address the problems and proposals mentioned above.

Noting these factors, we intend to proceed with the proposals as drafted.

Questions posed by respondents regarding how the instrument will work

Seven respondents also asked questions on how the instrument will work. These questions (edited for length and consistency) and CASA's responses are presented in Table 1 below.

Table 1: Respondent questions and CASA responses

The consultation demonstrated broad support for the proposed instrument and the changed privileges of the Grade 1 training endorsement. Minor changes will likely be made to improve the clarity of the instrument. However, any changes will not impact the intended effect of the instrument or the underpinning policy.

The instrument will be in place by the end of September 2022.