Draft AC 139.C-02 v1.0 - Aerodrome personnel

The revised Part 139 Manual of Standards (MOS) was made on 5 September 2019. The revised MOS introduces new roles of responsibility, and places further requirements on aerodrome operators to ensure appointed personnel have the appropriate competence through training, knowledge, qualifications and/or experience.

AC 139.C-02 'Aerodrome personnel' was drafted to assist aerodrome operators to:

• identify all roles and responsibilities required by the MOS
• understand the minimum level of training and assessment deemed necessary to ensure personnel appointed to carry out the required roles and responsibilities have the appropriate knowledge, qualifications and/or experience.

As past CASA surveillance activities identified a lack of understanding of other regulatory roles and responsibilities, the scope of this AC was expanded to include roles and responsibilities required under Part 99 of CASR - Drug and alcohol management plans and testing and Part 175 of CASR - Aeronautical information management.

Between 12 and 26 June 2020 aerodrome operators, consultants and internal CASA personnel, were invited to review the proposed guidance and provide comment. The consultation has closed and a summary of feedback is provided below.

Respondents

A total of 10 submissions were received—three from consultants and seven from aerodrome operators.

Seven respondents consented to their comments being made public, three requested their submission remain confidential. Of note, two respondents referred in support to another respondent's submission.

Summary of feedback

The following provides a summary of feedback received:

• Further clarity was requested about the appointment of an Accountable Manager.
• The introduction of PANS-Aerodromes raised concern, as there is no obligation under Part 139 to adopt procedural content described.
• The necessity for a qualified trainer and assessor was cited as an additional cost burden. The cost of recurrent training was also identified as a concern.
• Matters raised with respect to pilots operating airside, passenger supervision and the appointment of RV assessors who perform a specific function and who require specific assessment were not representative of the intent in which this information was provided.
• Personnel engaged to perform technical inspections was identified as being outside the scope of this AC.

All comments provided by industry have been carefully considered and incorporated into the AC where appropriate.

The AC was amended to make clear that the method to ensure personnel are competent is the prerogative of the aerodrome operator. Reference to a qualified trainer and assessor has been removed and it was reinforced that for a person to assess another's competency, that person would be required to have current or recent experience, and/or comparable relevant qualifications in the area of competency being assessed. The five year interval for recurrent training has been re-instated, with a recommended period of two years retained as best practice.

Additional guidance was provided to clarify competency requirements for contracted work safety officers (WSOs). As each aerodrome operating environment is unique, demonstrated competency extends beyond the holding of a training certificate, and there is an expectation that contracted WSOs should demonstrate knowledge and skill requirements specific to the aerodrome site in which they are performing their duties.

To support the appropriate appointment of an Accountable Manager guidance was expanded. The Accountable Manager should be a person at the highest level within the organisation who is responsible for the aerodrome certificate, and for aerodrome operations and developments. The appointee must also have the necessary knowledge and appropriate level of authority to fulfil the role.

The transitional period for existing certified and existing registered aerodromes does not extend to the appointment of personnel. Whilst there is a delay in the requirement to submit administrative documentation to CASA, an aerodrome operator is expected to have, on the date of commencement of the new rules:

• identified and assigned all roles and responsibilities that are required by the legislation
• ensured the suitability of those persons appointed.

CASA would like to thank industry for providing feedback and comments in support were appreciated.

AC139.C-02 has now been published on our website.

CASA will monitor the effectiveness of the new Part 139 of CASR and the MOS with a view for further revision if required based on industry feedback and safety outcomes. A post-implementation review is planned to occur after the end of the transition period being 13 November 2022.