Post-implementation review of Part 66 - Continuing airworthiness - aircraft engineer licences and ratings (PIR 1703MS)

Closed 26 May 2017

Opened 21 Feb 2017

Feedback Updated 23 Oct 2017

We Asked

Since the commencement of Part 66 in June 2011, CASA has received valuable feedback from stakeholders—including Part 66 licence holders and training organisations—on the implications and effects of the legislation. Feedback has highlighted the opportunity to simplify and clarify some aspects of the legislation, and address anomalies, gaps and unintended consequences via conduct of a post implementation review (PIR) of Part 66 of the Civil Aviation Safety Regulations 1998 (CASR).

In support of the PIR, CASA invited submissions to the Post implementation review of Part 66 - Continuing airworthiness - aircraft engineer licences and ratings (PIR 1703MS) from 21 February 2017 to 26 May 2017.

The objective of this consultation was to provide an opportunity for the aircraft maintenance sector to comment on matters relating to aircraft maintenance engineer licences and ratings, covered by Part 66 of CASR, the Part 66 Manual of Standards (MOS) and associated advisory material. CASA asked industry to identify issues that they wanted the review team to address and ideas for possible solutions.

You Said

Respondents

CASA received a total of 70 submissions; 48 respondents consented to having their comments published on the CASA website.

Key feedback

Comments made in the submissions demonstrated that the majority of issues could be grouped into three main 'issues':

  1. Part 66 of CASR, the Part 66 MOS and associated advisory material:
    1. complexity of Part 66 regulations
    2. complexity of the Part 66 MOS
    3. the Part 66-related ACs and Part 66 AMC/GM document are not easily understood
    4. lack of true harmonisation with EASA (as originally intended)
    5. lack of clarity and understanding of the Part 66 regulations and Part 66 MOS
    6. continued use of two sets of regulations (Civil Aviation Regulations 1988 (CAR) and CASR)
  2. licence privileges:
    1. lack of understanding of privileges/limitations
    2. complexity of exclusions on licences
    3. maintaining licence currency (6 months in 24 month requirement)
    4. B1 licence privilege:
      1. understanding what is a 'simple test'
      2. understanding avionic line replaceable unit (LRU) privileges
  3. aeroskills training (that leads to grant of a Part 66 licence):
    1. structure of the training, including knowledge requirements (EASA modules/units of competency)
    2. training pathways
    3. cost of training
    4. type training too complex/difficult
    5. access to training by individuals in remote parts of the country
    6. RPL problems.

We Did

Future direction

CASA expects to establish a CASA/industry Part 66 PIR Working Group soon. The role of the working group will be to contribute relevant technical expertise and industry sector insight to:

  • the analysis and review of the identified issues
  • the development of proposed solutions
  • the formulation of recommendations for improvements to the Part 66 legislation and associated guidance material.

 

Published Responses

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

Overview

Part 66 of the Civil Aviation Safety Regulations 1998 (CASR) sets out the requirements for the application for, the granting of, and appropriate use of aircraft maintenance engineer licences and ratings. Part 66 was first introduced in June 2011 as part of the regulatory reform program and transitioned the aircraft maintenance licensing requirements from the Civil Aviation Regulations 1988 (CAR) to the CASR. The detailed standards for the issue of aircraft engineer licences, ratings and other requirements and privileges associated with the licence are included in Part 66 Manual of Standards (MOS), which is an essential part of Part 66 suite of legislation.

The Part 66 licensing system adopted A, B1, B2 and C licence categories and aircraft type ratings in line with the European Aviation Safety Agency (EASA) system. However, the licensing system did not provide for the EASA B3 licence category for small aircraft because it was considered too limited and unsuitable for the Australian aviation industry. The plan was to develop a small aircraft licensing system after the initial implementation of Part 66.

Since 2011, CASA—in collaboration with the Maintenance Standards Sub-Committee and the Small Aircraft Working Group—has developed a small aircraft licensing system based on the previous CAR 31 licence system that uses ‘group rating’ endorsements on a licence to identify the privilege for each licence. A separate four year (Certificate IV) training course was specifically developed under the Aeroskills training package to satisfy CASA’s requirements for the grant of a licence for small non-type rated aircraft—the majority of which are operated in the general aviation (GA) sector of the industry.

This small aircraft licensing system was to have commenced from 4 July 2016 with amendments made to the Part 66 MOS. However, just before the MOS amendment was due to commence some key industry stakeholders raised concerns about a number of aspects of the new licensing system. The main concerns related to inflexibility of training pathways impeding the career progression of maintenance personnel from small non-type rated aircraft to large type rated aircraft, and the ability of Part 147 maintenance training organisations (MTOs) and registered training organisations (RTOs) to deliver the training for the small aircraft licence. During discussions with stakeholders it became apparent that significant changes would have to be made to the small aircraft licensing system to address their concerns and to ensure the regulatory requirements and the structure of the training could work effectively together. Consequently, CASA and industry agreed to postpone the commencement of the small aircraft licencing system to allow for further assessment of the licensing framework. CASA also decided to carry out a comprehensive post-implementation review of Part 66 legislation.

Why We Are Consulting

Since the commencement of Part 66 in June 2011, CASA has received valuable feedback from stakeholders—including Part 66 licence holders and training organisations—on the implications and effects of the legislation. Feedback has highlighted the opportunity to simplify and clarify some aspects of the legislation, and address anomalies, gaps and unintended consequences. Primary issues identified to date include:

  • the licensing system could be structured to better support a small aircraft licence for the general aviation sector
  • complexity and difficulty in interpreting both the Part 66 of CASR and the Part 66 MOS
  • the CASA knowledge requirements and competency requirements needed for a licence outcome as specified in the Part 66 MOS are too onerous in many cases
  • poor alignment between the Aeroskills training and the licence outcome
  • inconsistent training delivery standards between RTOs and Part 147 MTOs
  • the training syllabus for a licence outcome differs to EASA’s syllabus
  • funding for vocational education and training is not consistent across state governments
  • the statement of privileges on a licence lacks clarity, particularly in relation to the use of exclusions
  • the licensing system is not fully harmonised with EASA’s Part 66 licensing system.

In support of the Part 66 post-implementation review, CASA invites you to provide submissions on issues you consider need addressing.

Audiences

  • Engineers

Interests

  • Airworthiness / maintenance