Proposed charges for GA maintenance rules regulatory services – (CD 2317MS)

We sought feedback between 24 October 2023 to 6 November 2023 on the proposed amendments to the Civil Aviation (Fees) Regulations1995 to include the Part 43 of CASR fees schedule.

The regulatory fees are either a fixed amount or have been set at hourly rate to reflect the cost of CASA's personnel or systems that are required to deliver the services or activities.  

This consultation has now closed, and a summary of the feedback is provided below.

About this consultation

The consultation was to provide operators and industry an opportunity to raise any concerns regarding the proposed regulatory fees. This consultation will help us understand the potential impact that these proposed fees may have on an individual or their operation.

We received 17 responses. Fourteen respondents consented to having their feedback published, while the remaining requested their submissions remain confidential. The responses represented a broad cross section of the aviation community including Licensed Aircraft Maintenance Engineer (11), CAR 30 approval holders (8), and pilots (8).

Summary of feedback

We appreciate the contributions made by respondents and acknowledges that their feedback has been beneficial to the consultation process.

There were 7,483 stakeholders consulted with a total of 0.2% responses received from Industry.

Of the 17 respondents, 2 supported the proposed fees, 3 respondents were undecided, with 12 respondents opposed to the concept with concerns ranging from impact of increased costs on smaller organisations, disadvantages to industry for example, struggle to attract new entrants prepared to work towards licenced level. Of note, from the 12 respondents, 5 responses were out of scope and concerns raised were of technical policy matters.

The proposed fees were developed in accordance with the Government Cost Recovery Policy and guidelines. The cost estimates were mapped with a subject matter expert (SME) for a proficient officer and were treated as a direct cost to undertake the activity. It was deemed appropriate to charge a fixed fee, if possible, to give Industry certainty of CASA fees. Regarding the mapping of times for an issuance of AMTC 3 and 4 the allocation of effort was variable, and the decision was that this was to remain at the hourly rate of $160. 

The costing for a renewal or variation of an Inspection Authorisation (IA) is $13 more expensive than an initial due to the required level of delegation sign off.

We will be waiving fees for existing CAR holders that wish to transition to an AMTC 1 and 2 or IA for a three-year period from the go-live date of Part 43 of CASR.

We appreciate the comments provided by the respondents to this consultation. We will review and refine any assumptions on the fees as the data becomes available which is consistent with the Australian Government Charging Framework. Based on the feedback received from the Part 43 Technical Working Group and industry the fees did not pose any major concern.