Proposed amendment to allow access to the Obstacle Restriction Area (ORA) of an Aerodrome - (CD 2410AS)
Feedback updated 3 Dec 2024
We asked
This consultation asked industry to assess and comment on proposed amendments to the Part 139 Manual of Standards (MOS) associated with operations in the Obstacle Restricted Area (ORA) of an aerodrome.
The consultation was open from 5-19 September 2024 and a summary of the feedback is provided below.
About this consultation
Prior to the consultation, several areas of concern had been identified and communicated to CASA regarding the Part 139 MOS and associated with activities within the ORA.
There are key safety and maintenance activities that need to occur frequently within the ORA, particularly the Runway Strip. The Part 139 MOS unintentionally restricts these activities by requiring written approval by CASA.
The issues identified caused consequential administrative and economic burden to certified aerodromes with an instrument runway. These were subsequently corrected through this proposed amendment.
The consultation survey asked respondents whether they agreed with the proposed variations to the Part 139 MOS applicable to operations within the ORA, and to advise of any issues that they may have identified with the proposed changes.
You said
In total, there were 26 responses to the consultation. Thirteen respondents identified as aerodromes, 1 as ATC/AFIS, 8 as AROs and 10 as 'other'.
Of the respondents who made a written submission, 18 consented to having them made public and 8 requested their submissions be confidential.
Summary of feedback
The majority of the comments by the respondents supported the change and reduction in regulatory burden.
Two of the respondents queried some elements of the proposed changes, however also supported the proposal.
Overall, the common theme was one of support for the proposed changes and amendment to the Part 139 MOS.
We did
Overall, respondents strongly supported the proposed changes. As a result, CASA will now implement changes to the Part 139 MOS including removal of the requirement to seek approvals or exemptions for certain activities.
The amended Part 139 MOS is likely to be in force before the end of 2024.
Published responses
View submitted responses where consent has been given to publish the response.
Overview
We’d like your feedback on proposed changes to the Part 139 Manual of Standards (MOS) relating to access to the Obstacle Restriction Area (ORA) of an aerodrome. There are key safety and maintenance activities that need to occur frequently within the ORA, particularly the Runway Strip. The Part 139 MOS unintentionally restricts these activities by requiring written approval by CASA.
Following a review of the detail in the Part 139 MOS, we are proposing significant changes to subsection 6.21 (3) of the Part 139 MOS that would allow certain types of activities to be conducted within the ORA at controlled and non-controlled aerodromes.
Clear restrictions and directions are provided in the proposed revised subsection 6.21 (3) of the Part 139 MOS (refer to the Related documents below).
By removing the requirement to seek approvals or exemptions for certain activities, the changes will:
- reduce administrative burden and cost to industry
- reduce delays to operations
- provide enhanced efficiencies for aerodrome staff.
For further detail on the proposed changes please read the summary of proposed change on CD 2410AS.
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
All documents related to this consultation are attached in the ‘Related’ section at the bottom of the overview page. They are:
- SPC on CD 2410AS – this document is the summary of the proposals in the draft instrument
- Consultation Draft – Part 139 Manual of Standards Amendment Instrument 2024 (No. 2)
- MS Word copy of online consultation on CD 2410AS, for ease of distribution and feedback within your organisation.
What happens next
At the end of the response period, we will:
- review all comments received
- make responses publicly available on the consultation hub (unless you request your submission remain confidential)
- publish a Summary of Consultation which summarises the feedback received and outlines any intended changes and next steps.
All comments received on the proposed instrument will be considered. Relevant feedback that improves upon the proposed instrument will be incorporated into the final instrument.
Audiences
- Aerodrome operator
- Certified aerodrome owner/operator
- Aerodrome owner/operators
- Aerodrome industry consultant
Interests
- Safety management systems
- Aerodrome Reporting Officer Training
- Aerodromes
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