Discussion paper on Part 66 modular licensing framework for aircraft maintenance engineers (DP 2218MS)

Since the introduction of Part 66 of CASR, CASA has received submissions from industry stakeholders indicating that the Part 66 licence pathways are too inflexible, particularly in relation to pathways for initial licence issue in comparison to the previous CAR 31 licensing system

The “all or nothing” approach of Part 66 has been cited as a stumbling block for individuals, who either don’t have a strong interest in one of the aspects of a full Part 66 licence or who are unable to accumulate the necessary practical maintenance experience for all the required systems. The issue also affects people who hold foreign licences and are seeking to convert their foreign licence to an Australian licence.

These industry submissions generally suggest that a progressive, modular licensing structure should be developed to facilitate earlier and more achievable licensing outcomes with improved flexibility for licence applicants and businesses.

CASA has committed, through its GA Workplan, to consider more progressive, less onerous maintenance licence pathways tailored for light aircraft.

About this consultation

CASA published DP 2218MS to outline considerations and possible options for AME licence pathways that would provide a more flexible and achievable licensing outcome, particularly in relation to initial licensing outcomes.

This consultation asked people to provide comment on DP 2218MS and the suggested changes to the Part 66 licence structure, that would address both industry submissions and the GA workplan objectives.

CASA received 60 responses to the discussion paper, 46 of which were from licensed aircraft maintenance engineers, 10 from aircraft owner/operators, 11 from CAR 30 approval holders, 8 from Part 145 approved maintenance organisations and two from Part 147 maintenance training providers.

3 CASA officers also provided comments.

39 respondents gave permission to publish their responses.

Summary of feedback

Of the 60 respondents, 38 supported the proposals as published, and 6 respondents were opposed to the concepts.

Of the remaining 14 respondents, the proposals were generally acceptable however some changes were proposed.

Key themes and issues

Modular licensing pathways would be beneficial

Most respondents clearly supported the intent to provide a more flexible, modular licensing framework.

Use of exclusions

A majority of respondents supported the use of exclusions. Four respondents opposed exclusions on the grounds that exclusions are confusing.

Seven respondents called for expanded use of the full range of exclusions, to maximise flexibility and licensing outcomes. In particular, reference was made to providing for a licence to be obtained without needing practical experience on systems that are not accessible or not applicable to a person's employment, such as air conditioning, pressurisation and retractable undercarriage.

The proposal in the DP is framed around the use of exclusions, in the first instance, in order to expedite delivery of the intended benefits and outcomes. However, CASA acknowledges that some industry stakeholders do not agree with the use of exclusions in any context.

Exclusions were designed to transition between CAR 31 and Part 66 licences. Exclusions do have the potential to be used as a useful and beneficial mechanism to facilitate licensing outcomes, particularly in cases where a licence applicant cannot achieve the necessary experience in particular systems. This is a common situation in regional areas. Expanded use of exclusions also has potential application in acceptance of foreign licences with different scope.

Any ongoing use of exclusions will need to be carefully considered, particularly in relation to the associated training requirements, administrative implementation arrangements and clear understanding of licence scope and privileges.

Whether we need a phase 2 positive description

A small number of respondents opposed a second phase to develop a positive description of modular licensing, on the basis that it would only further add to confusion.

It is acknowledged that the desired practical outcomes of a modular licensing system can be achieved using exclusions and a positive description of privileges is not essential. CASA intends to continue to focus on expediting the desired modular licensing outcomes via exclusions and will consider a positive privilege arrangement as a possible future extension, after a settling-in period using exclusions.

Propellers separate from powerplants

The majority of respondents did not comment on this subject. Two respondents specifically opposed separating propellers from power plants. An equal number of respondents specifically expressed support for the concept.

An objective of this initiative is to increase flexibility and improve licensing outcomes for industry. Providing propellers as an option, rather than a requirement, is consistent with this objective. It is also noted that a propeller qualification would be an unnecessary and potentially unwelcome burden for LAMEs who work in a helicopter-only environment.

Following discussions with the TWG, and with the aim of expediting delivery of core modular licensing outcomes, CASA will develop a proposal that retains propellers as a requirement for piston engine aeroplane licences but not helicopters. This approach can be reviewed in later phases of this initiative, if necessary.

Practical experience period should be longer

Some respondents suggested that the minimum practical experience proposed in the discussion paper is insufficient.

CASA notes that this proposal is intended to facilitate licensing outcomes. It is understood that a modular approach to licensing will naturally reduce the training and practical experience requirements and timeframes. Experience should be specific to the required licence outcome and proportional to the proposed licence scope. In cases where the licence scope is reduced, relative to the current arrangements, it is considered reasonable to proportionately reduce the experience. In all cases, the proposal would ensure at least 1 year practical experience, which is consistent with recommendations set out in ICAO Annex 1.

Following discussions with the TWG, and in order to expedite core modular licensing outcomes, CASA will develop a legislative proposal that does not change the current experience requirements stated in the Part 66 MOS. CASA will consider proportionate adjustments to the experience requirements in the second phase of this initiative.

Physics should be mandatory for all licences

Several respondents commented that physics should be a required theoretical module for all licences.

Omission of physics module 2 in the discussion paper was a typographical error.

Physics is a relevant knowledge element for all licences and is an element of the ICAO licensing standards.

Electrical should be mandatory for all licences

Several respondents commented that electrical should be a required theoretical module for all licences.

An objective of this initiative is to increase flexibility and improve licensing outcomes for industry. Providing electrical as an option, rather than a requirement, is consistent with this objective. It is also noted that an airframe only licence would be a useful practical outcome, particularly for small, simple GA aircraft. 

CASA will consider this issue further and will work with the TWG to develop a flexible and practical legislative proposal.

CAR 31 basic examination credits should be recognised

Several respondents suggested that credits obtained under the old CAR 31 licensing arrangements should be recognised.

This concern is outside the scope of this paper. However, CASA has a process in place for mapping CAR 31 examination credits for RPL purposes.  We will consider a review of procedures in this area.

Recognition of expired CAR 31 licences

CASA has received feedback during this consultation suggesting that we should consider applying the same approach that is used for recognition of foreign licences to recognition of expired CAR 31 licences.

CASA agrees that this is desirable and will consider options to achieve this outcome.

Use of CAR 31 summary of experience (in place of the journal/log of industrial experience)

Several commenters requested CASA accept the old CAR 31 summary of experience in lieu of the new journal/log of industrial experience developed for the Part 66 self-study system.

This concern is outside the scope of this paper. However, CASA will review its procedures in this area.

The proposed CAR 31-based model vs other options (EASA B3)

Respondents generally indicated strong support for a CAR 31-like structure.

No respondents supported adoption of the EASA B3 or B2L licence arrangements. Respondents who mentioned EASA were generally critical of the EASA licensing structure.

In order to expedite core modular licensing outcomes, CASA will develop a legislative proposal that does not specifically adopt the EASA B3 and B2L structure. CASA will consider this issue in more detail in the second phase of this initiative.

Overall, respondents have strongly supported the proposals and encourage CASA to expedite the delivery of more flexible licensing outcomes.  

CASA will therefore proceed with this initiative, using the input provided to develop a more detailed policy, legislation and implementation package.

Consistent with the feedback from industry and the TWG, CASA will seek to expedite the delivery of the core beneficial outcomes of this proposal. To achieve this, CASA will develop a legislative proposal that will facilitate modular licensing outcomes using exclusions. This approach will also provide more flexible pathways in other cases, including Australian trainees, that cannot access certain systems to gain practical experience, as well as recognition of foreign licences and defence authorisations. In order to expedite these outcomes, the status quo will be maintained on some requirements, such as minimum experience requirements and propeller exclusions. These requirements will be considered in more detail in later phases of this initiative after the core outcomes are achieved.