Discussion paper - Maintenance of limited category aircraft (DP 1618OS)

Closed 15 Sep 2017

Opened 4 Jul 2017

Feedback updated 12 Dec 2017

We asked

CASA published DP1618OS—Maintenance of limited category aircraft. Proposed Subpart 132.M of CASR—on the CASA website from 1-19 September 2017. The objectives of the DP were to provide owners, operators and maintainers of limited category aircraft with the opportunity to provide feedback on potential ways of regulating maintenance of limited category aircraft. Three options were proposed:

  • Continuing to have maintenance of limited category aircraft governed by the current rules.
  • Moving the maintenance requirements for limited category aircraft to Part 42 of CASR.
  • Having a dedicated Subpart 132.M of CASR dealing with maintenance of limited category aircraft.

CASA also consulted with stakeholders on 28 February 2017 at a public meeting held at the Stamford Plaza Hotel in Sydney.

You said

22 online responses were received from industry participants in relation to the three proposed options. Of the 22 respondents, 17 provided their permission to publish their responses. The responses against the three options were as follows.


Option 1 - retain the present regulatory structure

No response                                        4

Unacceptable                                      10

Acceptable with change                      6

Acceptable without change                 2


Option 2 - incorporate the limited category aircraft maintenance rules into Part 42 of CASR

No response                                        4

Unacceptable                                      9

Acceptable with change                      8

Acceptable without change                 1


Option 3 - create a standalone maintenance Subpart 132.M of CASR

No response                                        0

Unacceptable                                      4

Acceptable with change                      10

Acceptable without change                 8


Outcome of consultation meeting held at Stamford Plaza Hotel 28th February 2017

18 industry participants provided unanimous support to proceed with development of a Subpart 132.M of CASR. Of these 18 participants, 9 stated by way of caveat that they would need to see the full policy detail before giving unqualified support to the proposal.

The support provided by industry participants at this meeting reflects the responses CASA received online.


Key feedback and policy changes

Predominantly, the feedback indicated that the development of a Subpart 132.M of CASR was the preferred option but respondents wanted to see further detail.

We did

A detailed policy paper will be prepared and published on CASA's Consultation Hub.

Responses to the policy draft will be analysed and regulations will be drafted to give effect to the agreed policies.

Published responses

View submitted responses where consent has been given to publish the response.


Maintenance of limited category aircraft is regulated under Parts 4 and 4A of the Civil Aviation Regulations 1988 (CAR) in conjunction with Civil Aviation Orders (CAOs) and a number of legislative instruments. In time, all Australian aircraft will be transitioned to the Civil Aviation Safety Regulations 1998 (CASR) under the regulatory reform program. On completion of the transition, the CAR will be repealed.

If no change is made to the regulations dealing with maintenance of limited category aircraft, these aircraft would remain subject to existing provisions of CAR until such time as the CAR is repealed. At that time limited category aircraft would come under relevant CASR Parts dealing with maintenance of a wide range of general aviation aircraft.

Why your views matter

CASA recognises the valuable contribution that industry consultation makes to the regulatory development process and issues this discussion paper as the first stage in moving towards a unified set of regulations for limited category aircraft. The discussion paper sets out three options for consideration and invites industry to help identify their preferred option for future regulation of maintenance for limited category aircraft.

Please read the related discussion paper before responding to the online survey.

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What happens next

When we have reviewed all feedback we will publish a summary of consultation, which will summarise the feedback received and detail our plans for future policy and consultation on this subject.


  • Air operators
  • Airworthiness organisations
  • Engineers


  • Airworthiness / maintenance
  • Limited category aircraft