We sought industry feedback between 1 and 16 December 2022 on the proposal to establish a tailored system for training, assessment, grant and exercise of aerial mustering endorsements.
Previously, industry had told us that the flight training and testing scheme for aerial mustering endorsements was not working as efficiently as intended. In many respects, the intended approach to flight training has not materialised for mustering pilots. This is believed to be one of the reasons for the limited availability of suitably qualified flight instructors, examiners and flight training operators to conduct training and assessment for aerial mustering endorsements and consequently impacts on the availability of suitably qualified pilots to conduct mustering operations.
We proposed changing the rules to establish a tailored alternate system for training, assessment, grant and exercise of aerial mustering endorsements.
Note: The existing Part 61 and Part 141 flight training scheme remains available for training, assessment, grant and exercise of aerial mustering endorsements.
The proposal addressed:
About this consultation
We received 22 responses, the majority from flight instructors and flight examiners, pilots, flight training operators and Part 138 operators.
The consultation survey asked respondents “Do you have any comments about the proposed instrument?”. Nineteen of the 22 responses provided feedback on this question. Four responses were clearly in support of the proposed instrument. Twelve responses implied support for the objectives of the policy, while either suggesting changes to the technical detail of the instrument, making comment on the mustering sector generally, or posing questions on the operation of the instrument.
Common themes from the free text responses included opinions that the new rules will:
Three responses did not support the proposed instrument. These free text responses included comment that the instrument:
Summary of feedback
Common themes, issues and suggestions raised in responses included:
Focus on safety culture
Two respondents emphasised the importance of the mustering sector—and the pilots and operators operating in that sector—adopting and maintaining a safe flying culture.
One of these respondents indicated:
Conversely, another respondent commented:
"Some of the most unsavoury habits that exist in the helicopter industry exist within the mustering community."
They also noted:
We recognise and emphasise the importance of pilots and operators conducting mustering adopting and maintaining a strong safety culture. The proposal is intended to emphasise operational responsibility and to build on safety requirements such as safety systems and operational manuals required under Part 138 of CASR. Part 138 operators who intend to conduct training and facilitate the assessment and grant of endorsements will need to develop a training syllabus and have it approved by CASA. CASA needs to be satisfied that the operator can safely and adequately deliver the training and that the operator has suitable staff to conduct the training.
Specific technical requirements
Eight responses made comment or reference to the specific technical requirements proposed in the instrument (for example, the prerequisites for trainee pilots). These responses made quite varying suggestions, including:
Prerequisites for trainee pilots
Training and assessment
Recurrent checks
Trainer requirements
Questions posed by respondents regarding how the instrument will work.
Three respondents also asked questions regarding how the instrument will work. These questions (edited for length and consistency) and CASA's responses are at Table 1.
Table 1: Respondent questions and CASA responses
Question |
CASA response |
Can Part 141 operators that currently provide training for aerial mustering endorsements still provide that training once the instrument is in effect?
|
Yes. The proposed instrument is an alternative pathway to gain an aerial mustering endorsement. Part 141 operators who conduct training for aerial mustering endorsements can continue to deliver that training as usual. |
Is it intended that a pilot who receives an endorsement under this instrument could immediately conduct unsupervised aerial mustering operations under Part 138? Or will the requirements in the Part 138 MOS section 17.02 continue to apply? |
The Part 138 MOS outlines operational standards for Part 138 operations, including mustering. Within the Part 138 MOS there are additional requirements concerning pilots conducting unsupervised mustering operations beyond the scope of the proposal. It is intended that a trainee pilot would still be subject to the requirements in the Part 138 MOS at the completion of training conducted under the proposal. This means that trainee pilots may be required to gain additional experience, as they would if they were to gain an aerial mustering endorsement through the existing Part 61 pathway. However, we will consider whether amendments to the Part 138 MOS are required. |
Will a flight test be required for the grant of an aerial mustering endorsement through the proposed instrument? |
Yes. The training culminates in a flight test, however this will be conducted by the trainer appointed by the Part 138 operator that has conducted the mustering training. Further consideration of the flight test requirement would be included in the review and subsequent amendment to the regulations. The proposed flight test requirement is to keep this interim solution as streamlined with the current rules as possible and to minimise the differences from a licensing administration perspective. |
Considering the highly variable suggestions mentioned above, we intend to proceed with the proposed requirements. We will review how the instrument is operating once it is in effect by continuing to engage with the mustering sector, and we will complete a policy review before making any changes to CASR to incorporate the effect of the proposed instrument.
Next steps
The consultation indicated support for the proposed instrument and the proposed alternative pathway for the training, assessment and grant of aerial mustering endorsements. 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 January 2023.
View submitted responses where consent has been given to publish the response.
We are seeking feedback on an instrument that will establish a tailored system for training, assessment, grant and exercise of aerial mustering endorsements.
You told us practical barriers to the efficient conduct of flight training and entry control assessment for aerial mustering endorsements have emerged since the flight crew licensing rules commenced in 2014.
The proposed instrument seeks to overcome these barriers by addressing:
The instrument will be in place by the end of December 2022.
We are also working to address other specialised pilot endorsements including sling operations, winch and rappelling operations and firefighting endorsements. We intend to publicly consult on these endorsements early in 2023.
Opportunity to comment
Your feedback will help us make sure the final instrument is clear and will work as intended.
Please submit your comments using the survey link on this page.
If you are unable to provide feedback via the survey link, please email regulatoryconsultation@casa.gov.au for advice.
Documents for review
Documents related to this consultation are attached in the ‘related’ section at the bottom of the page. These are:
What happens next
At the end of the response period, we will:
Feedback that improves the proposed instrument will be incorporated into the final instrument.
In due course, we will amend the flight crew licensing rules (Part 61 of CASR) to incorporate the provisions of the final instrument.
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