Proposed amendments to Part 66 MOS – Modular licensing and new aircraft type ratings - (CD 2408MS)

This consultation provided details of amendments CASA is proposing to make to the Part 66 Manual of Standards (MOS). The consultation has now closed, and a summary of the feedback is provided below.

About this consultation

This consultation survey asked respondents to provide their feedback/comments on a number of proposed amendments to the Part 66 MOS that included:

• adjusting the stand-down periods after a failed Part 66 module exam to assist a candidate’s progression towards attaining a licence
• relocation of Table 5 – Units of competency required for a category or subcategory of modular licence, in Appendix C of the Part 66 acceptable means of compliance/guidance material (AMC/GM) that identifies the units of competency (UOC) required for a modular licence into the Part 66 MOS
• minor changes to some modular licence amendments made in December 2023, to support relocation of the modular licence UOC table and to correct some unintended inaccuracies
• repeal of the expired provisions in the Part 66 MOS that enabled use of the CAR 31 CASA Basics and SOE licensing scheme, to obtain various equivalent Part 66 licence outcomes
• updates to type rating information to add new aircraft types to the type rated aircraft listings in Appendix IX of the Part 66 MOS.

A total of 55 responses were received to the consultation survey. Of the 55 respondents, 32 identified themselves as a licensed aircraft maintenance engineer (LAME), 18 identified as an approved maintenance organisation (CASR Part 145 AMO, or CAR 30 approval holder), 6 identified as an approved maintenance training organisation (CASR Part 147 MTO), with 23 respondents identifying as an aircraft maintenance engineer (AME).

Of the total number of respondents who made written submissions, 40 consented to having their responses/submissions made public, with 15 respondents requesting their responses/submissions to remain confidential.

Of the total number of responses received:

• thirty-nine respondents comments were in relation to the proposed adjustments to the stand-down periods after a failed Part 66 module exam
• fourteen respondents suggested further adjustments to the proposed amendments to the stand-down periods after a failed Part 66 module exam, or an alignment to the stand-down periods applied to pilot exams
• forty-one respondents expressed their support of the proposed amendments
• four respondent's comments were unrelated to the details of these amendments
• four respondents provided no comments.

Summary of feedback

Most comments received were in relation to the proposed adjustments to the stand-down periods after a failed Part 66 module exam, with the majority of respondents expressing their support of the proposal.

One respondent commented that the amendment would have a positive effect on those working towards a Part 66 licence, while another applauded CASA for reviewing and amending these waiting periods.

Other comments from respondents suggested the proposed changes don't go far enough and that CASA should consider further 'scaled' reductions in these stand-down periods. For example, one respondent suggested that in the event of an unsuccessful exam result, a student/candidate should have:

• 70 - 75% – ability to re-sit an exam the following day
• 60 - 70% – a stand-down period of 1 month
• 50 - 60% – a stand-down period of 3 months
• 50%> – a stand-down period of 6 months.

Furthermore, to boost a candidate's chance of success on their 3rd attempt of an exam, the respondent suggested a requirement for re-training prior to taking the exam.

Some respondents commented that there should be no stand-down periods at all after a failed Part 66 module exam, to align with pilot exam requirements, or other variations on the theme that if an applicant was close to the pass mark, then the applicant should be allowed to resit the exam the next day.

Other respondents offered various suggestions on this topic including that CASA should enable open book exams and permit subject exams, where a student could sit an exam at the end of each subject within a module, rather than at the end of a complete module.

Regarding feedback on the other proposed changes, most respondents expressed their support of the proposals. In addition, some respondents also identified a few minor errors to existing information, which CASA will address in the final published version of the Part 66 MOS.

Based on the comments received, the majority of which were supportive of the proposed changes, CASA will proceed with the proposed amendments to the Part 66 MOS, with some changes as described below.

CASA will adjust the proposed stand-down periods to incorporate a combination of the industry suggestions to provide further relief for applicants. Specifically, CASA will remove the stand-down period (currently 90 days) for a first failed sitting of a module exam; this would apply for each module. Any subsequent failed attempts, would incur stand-down periods as consulted, i.e. a second failed attempt would incur a stand-down of 30 days (down from 90 days), and a third failed attempt would incur a stand-down of 6 months (down from 12 months) and reset the stand-down cycle. CASA considers this an appropriate arrangement that balances the need to maintain the necessary high standard of knowledge and skills required to be a LAME, with appropriate improvements that reduce timeframes and minimise disincentives for prospective LAMEs in a way that would not have an adverse effect on LAME knowledge and skills standards.

In relation to comments suggesting that the Part 66 module exams should be subject to the same arrangements as the Part 61 pilot licensing exams, CASA notes that the Part 61 rules include additional requirements, such as a 2 year sliding period within which all exams must be completed successfully, stand down periods that commence after 3 failed attempts, and that an applicant who has 4 failed attempts must provide a submission to CASA before they are permitted to attempt the exam again. Considering all these requirements, CASA does not propose to adopt the Part 61 pilot licensing exam arrangements for Part 66 LAME licensing exams.

Due to updates being required to CASA's exam provider's online examination booking system to accommodate the proposed adjustments to the stand-down periods after a failed Part 66 module exam, CASA advises there will be a delayed commencement date for the revised stand-down periods. CASA will set the commencement provisions such that the revised stand-down arrangements can be made available to industry as soon as the necessary implementation arrangements are in place.

The other amendments, including the type rating updates, will commence after making and registration of the MOS amendment.