Multi-engine helicopter ratings (CD 2209FS)

We sought industry feedback over the 2-week period 21 June – 4 July 2022 on proposed changes to multi-engine helicopter ratings.

Industry had previously told us that our current approach of requiring a type rating for each multi-engine helicopter limits access to qualified flight instructors, flight examiners, and flight training operators for some multi-engine helicopters. The issue is compounded by the very small number of these types of helicopters in Australia and it has led to increased costs and time to access training and assessment.

We proposed changing the rules to create a class-like system as the first step in introducing a new multi-engine helicopter class rating.

About this consultation

We received 20 responses, mostly from pilots, flight instructors and flight examiners. Three responses were submitted on behalf of flight training operators and commercial operators. Three responses did not provide any comments.

The consultation survey asked respondents “Do you have any comments about the proposed instrument?”. Nine responses were clearly in support of the proposed instrument.

Common themes from the free text responses included opinions that new rules will:

• reduce barriers and regulatory burdens for commercial operators, and make it easier for small operators to make the switch to multi-engine helicopters
• reduce costs for operators, including those who operate multiple types of helicopters
• make it easier for pilots to become authorised to operate multi-engine helicopters across multiple types, thereby increasing the number of qualified aircrew in general aviation
• improve safety by encouraging the use of appropriate multi-engine aircraft for aviation activities
• support the ongoing improvement of the competency-based regulatory framework.

Seven responses implied support for the objectives of the policy, while suggesting changes to the technical detail of the instrument. Four responses provided comments that identified minor errors in the instrument, posed questions on the operation of the instrument or proposed changes that are out of scope of the instrument.

Four responses did not support the proposed instrument. These free text responses included comment that the proposed instrument:

• does not go far enough and the parameters of the 'class' should be expanded
• goes too far, and type ratings should be retained while providing for a streamlined pathway to attain subsequent type ratings.

Summary of feedback

Common themes, issues and suggestions raised in responses included:

Comments on the 'complexity' of aircraft nominated to be in the 'class'

Four responses commented that the use of the term 'less-complex multi-engine helicopters' was inappropriate. These respondents noted that the multi-engine helicopters included in the Prescription of Type Ratings Excluded from CASR Part 142 Flight Training (Edition 6) Instrument 2018 did not reflect the characterisation of a 'less-complex helicopter'. CASA acknowledges that characterisation is broad and open to interpretation. However, since assigning these single-pilot types to be Part 141 flight training activities CASA has not identified any negative safety impacts. It is the link between the complexity of the training (organisational systems) and the operation of the aircraft, especially for multi-crew operations, that is significant and the rationale for assigning multi-crew type rating training to Part 142 of CASR.

Noting that there were no comments on the appropriateness of the training being under Part 141 of CASR for helicopters included in the system, CASA intends to proceed on the basis that existing training activities in these helicopters can be maintained with minimal impact.

Proposed significant or beyond-scope changes

Multiple respondents also proposed significant changes to the proposed multi-engine class or suggested other changes beyond the scope of the policy. These suggestions included:

• expanding the multi-engine class rating to encompass any multi-engine helicopter below 5700 kg MTOW, and to still prescribe type ratings for any multi-engine helicopter 5700 kg MTOW or above or for multi-crew certified multi-engine helicopters
• retaining the existing type rating system, but creating an alternative streamlined pathway to facilitate instructors and examiners to gain multiple type-specific training or testing endorsements
• permitting instructors and examiners who hold any type-specific training or testing endorsement for any multi-engine helicopter type to conduct training or testing (as relevant) for the multi-engine helicopters prescribed in the class.

CASA notes these responses are significant or beyond the scope of change therefore they will be brought forward in future policy considerations prior to including the class rating in the regulations.

Errors in Schedule 1 of the proposed instrument

Two errors in the schedule of prescribed helicopters were identified and will be corrected prior to commencement of the instrument. These were:

• Schedule 1 incorrectly refers to SK76(SP). The correct type rating is “SK76”
• Schedule 1 does not include the BK 117 D-3. This will be added to the same cell as the BK 117 D-2.

The consultation showed there is broad support for the proposed instrument and the establishment of a multi-engine helicopter class rating. Minor changes will be made to correct identified errors in Schedule 1 of the instrument. Minor changes will likely also be made to improve the clarity of the instrument and to prevent any unintended consequences. However, any changes will not impact the intended effect of the instrument or the underpinning policy.

The instrument will be in place by 15 August 2022.