We sought feedback between 17 and 30 April 2023 on the proposal to establish a tailored system for training, assessment, grant and exercise of "specialised endorsements" including the sling, winch and rappelling operations and firefighting endorsements.
We had previously been told that the flight training and testing scheme for these specialised endorsements was not working as efficiently as intended. 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 specialised endorsements and consequently impacts the availability of suitably qualified pilots to conduct specialised operations.
In many respects, the intended approach to flight training in which the requirements for conducting lower risk activity authorisations were meant to require less rigorous training and testing compared to the higher risk activities has not materialised for these pilots and an alternative approach to better facilitate training and assessment for these endorsements may be possible.
We proposed changing the rules to establish a tailored alternate system for training, assessment, grant and exercise of specialised endorsements.
Note: The existing Part 61 and Part 141 flight training scheme remains available for training, assessment, grant and exercise of these specialised endorsements.
The proposal addressed:
About this consultation
We received 13 responses, the majority from pilots, Part 138 or 137 operators, flight instructors and flight examiners and flight training operators.
The consultation survey asked respondents “Do you have any comments about the proposed instrument?.” Six responses were clearly in support of the proposed instrument. Five responses implied support for the objectives of the policy, while either suggesting changes to the technical detail of the instrument or posing questions on the operation of the instrument.
Common themes from the free text responses included opinions that:
Two responses did not support the proposed instrument. These free text responses included comment that the instrument:
We recognise and emphasise the importance of pilots and operators conducting sling, winch or rappelling or firefighting operations implementing and maintaining a strong safety culture. The proposal emphasises operational responsibility and builds on safety requirements such as safety systems, training and checking systems and operational manuals required under Parts 138 and 137 of CASR.
Operators who intend to conduct training and facilitate the assessment and grant of a specialised endorsement will need to develop a training syllabus and have it approved by CASA. CASA must be satisfied that the operator can safely and adequately deliver the training and that the operator has suitable staff to conduct the training. Continuous improvement is necessary in any training course, whether it is delivered by a flight training operator or a commercial operator through this pathway.
In addition, the 'train-the-trainer' course requirements prescribe the minimum amount of training required. The training provider and instructor delivering the training to the trainer pilot must be satisfied that the trainer pilot is competent to deliver training.
Trainer pilots under this proposal must be sufficiently experienced and are expected to be knowledgeable and skilled in managing emergency procedures. Ensuring trainees are competent in emergency and non-normal procedures is an operational responsibility and should also be addressed in the operator's ongoing proficiency checking.
Summary of feedback
Common themes, issues and suggestions raised in responses included:
Specific technical requirements
Six 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 that:
Prerequisites for trainee pilots
Training and assessment
The instrument does not include detail of what is involved in a firefighting operation and we understand that this may create ambiguity. For clarity, the 'firefighting operations' contemplated in the instrument involve activities which require the firefighting endorsement to conduct. In essence, this involves applying or dispensing water or fire retardant from below 500 ft AGL for fire suppression. There are various methods of applying or dispensing the firefighting material, including buckets and tanks.
Air attack supervisor activities that involve slow left turns at around 500 ft AGL, as mentioned in the comments above, are not 'firefighting operations' contemplated in the instrument, and do not require a firefighting endorsement to conduct - only a low-level rating with the relevant category low-level endorsement is required.
The training for the endorsement under the instrument must involve training to the competency standards and in the activities permitted by the firefighting endorsement (applying or dispensing water or fire retardant from below 500 ft AGL for fire suppression) rather than simply air attack supervisory services. We will clarify this in the final instrument.
The intent was to enable operators to consider what is involved in a sling or winch or rappelling operation for their unique operational circumstances, rather than defining or explaining what a 'sling operation' and 'winch or rappelling operation' involves. We will consider whether it is necessary to also define 'sling operation' and 'winch or rappelling operation' in the final instrument.
In addition, training in firefighting operations refers to simulated or mock firefighting operations, rather than actual firefighting activities. We will clarify this in the final instrument.
Recurrent checks
Trainer requirements
We have considered the comments made above, though CASA intends to proceed with the requirements in the original proposal. We will review the operation of the policy following commencement by continuing to engage with relevant sectors, and we will complete a policy review before making any changes to incorporate the effect of the proposed instrument into CASR.
Questions posed by respondents regarding how the instrument will work
Four 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 |
Who can conduct the annual operator proficiency check? |
The instrument does not prescribe recurrent checking; instead, existing operator proficiency check requirements in Parts 137 and 138 are expected to be met. The person conducting these checks should be the same person as currently permitted or required to conduct the checks under Parts 137 or 138 of CASR. |
How will the requirement for a winch and rappelling operations endorsement trainee to have 100 hours PIC on type assist junior first officers in multi-engine roles gain a winch and rappelling operations endorsement after being hired? |
Trainees for winch and rappelling operations endorsements are not required to have 100 hours PIC on type. Under the draft instrument, they are required to have at least 100 hours PIC of a helicopter. |
Will it be an option to use an Industry Flight Examiner Rating Courses (IFERC) instead of the FERC e-learning modules required in the instrument? |
No. There is currently only one approved IFERC. IFERCs are set up for people who want to become flight examiners and are therefore tailored to examiner competencies. The e-learning FERC modules prescribed in the instrument are intended to provide trainers with knowledge around conducting a test and administrative requirements for tests. Completion of the e-learning FERC modules also provides CASA with visibility of people who can conduct the training and testing under the instrument. |
Can a flight instructor with the relevant training endorsement complete the FERC requirements and be able to operate under the instrument? |
Yes, so long as they meet the trainer prerequisites prescribed in the instrument (e.g. aeronautical and operational experience, be employed or engaged by a relevant operator). |
How many instructors meet the criteria prescribed for the instructors delivering the 'train-the-trainer' course? Is it possible this instrument may shift the problem of the lack of qualified specialised endorsement instructors to a lack of qualified instructors that can conduct the 'trainer' training? |
There is a moderate amount of instructors who meet the prescribed criteria to conduct the train-the-trainer course, approximately: 150 for sling, 70 for winch and rappelling, 75 for helicopter firefighting and 5 for aeroplane firefighting.
We expect the instrument will make it easier for pilots to access training and testing for specialised endorsements and will not merely shift the problem. |
The consultation indicated support for the proposed instrument and the proposed alternative pathway for the training, assessment and grant of specialised 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 mid-June 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:
You told us practical barriers to the efficient conduct of flight training and entry control assessment for these specialised 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 late-May 2023.
Opportunity to comment
Your feedback will help us make sure the proposed requirements are suitable, 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 CASR (Part 61, Part 137, Part 138, and Part 141 of CASR) to incorporate the provisions of the final instrument.
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