Policy proposal - Continuing airworthiness management and maintenance for future air transport operations - (PP 1915SS)

Closed 22 Dec 2019

Opened 22 Nov 2019


CASA is seeking your feedback on a policy proposal to complete continuing airworthiness regulation reform for the current charter sector, and to support the transition of regular public transport (RPT) and charter operations into the future air transport flight operations regulations, commencing March 2021.

Proposed policy changes

The proposal primarily sets out continuing airworthiness management and maintenance policies for operators, maintenance providers and people providing continuing airworthiness management services in the current charter sector. In the future, these operations will fall under ‘air transport’ and will transition into the new CASR Parts 121, 135 and 133—depending on the class (aeroplane vs helicopter) and size (weight and passenger capacity) of the aircraft. The proposed policies also have some effects for other aircraft that will transition into the future air transport sectors.

While the status quo will remain for most of the proposed policies, some adjustments are proposed to ensure compatibility with the new risk-based framework of the flight operations regulations. This includes proportionate requirements of continuing airworthiness across the new air transport sectors.

Areas of policy change are:

  • continuing airworthiness management
  • who may carry out maintenance
  • maintenance performance rules
  • approved maintenance organisations.

Please see Policy Proposal PP 1915SS for further information. This proposed policy is framed in terms of the new flight operations classifications. 

The implementation of these proposed changes will have a commencement date independent of the flight operations regulations. The date is yet to be determined and CASA will ensure industry has sufficient time to transition. 

Regulations to be amended

The proposed changes will supersede the requirements in Parts 4, 4A and 4B of CAR that currently apply to aircraft engaged in charter operations.

Related issues

In response to industry feedback, CASA has commissioned an independent risk review of the passenger limits of Parts 135 and 121 of CASR.

In consultation with industry we will assess the outcomes of that review to determine any impact on the policies proposed in this consultation.

Transition from current rules to the new flight operations regulations will have consequential effects on the continuing airworthiness and maintenance sectors. We are developing transitional measures scheduled to be published for consultation in the coming months. These measures will prioritise safety and take commercial issues into consideration. 

Register for industry briefing sessions

We are hosting continuing airworthiness and maintenance industry briefing sessions at a range of locations across Australia (2-17 December 2019) to support this consultation.  

Book your place by 28 November 2019. 

More Information

In June 2013, aircraft engaged in regular public transport (RPT) operations were transitioned to a new set of continuing airworthiness legislation comprising Parts 42 and 145 of the Civil Aviation Safety Regulations 1998 (CASR) and their associated Manuals of Standards (MOS).

Aircraft engaged in charter operation remain subject to the continuing airworthiness requirements of Parts 4, 4A and 4B of the Civil Aviation Regulations 1988 (CAR) and the relevant Civil Aviation Orders (CAOs). The CARs are a set of unique Australian regulations that are outdated, inefficient and overly complex. They rely on numerous legislative instruments and advisory materials for proper operation and interpretation. The CARs are gradually being replaced by a more contemporary, proportionate requirements in the CASRs.

On commencement of the new flight operations regulations in March 2021, existing RPT and charter operations, will transition into new air transport operations classifications under Parts 121, 133 or 135 of CASR, based on the class (aeroplane vs helicopter) and size (weight and/or passenger capacity) of the aircraft.

There are three stages in the reformation of continuing airworthiness legislation for the transition of current RPT and charter operations into future air transport operations under Parts 121, 133 and 135 of the CASR.

  • Stage 1 - development of the detailed policies for the new legislation. We are working with industry towards development of a practical outcome. Ongoing consultation throughout 2019 via the CASA Consultation Hub, the Technical Working Group (TWG) and Sector Risk Profile workshops. Finalisation of policy target expected December 2019.
  • Stage 2 - development of the legislation that enacts the policies established in Stage 1 and development of advisory materials. Development completion target date expected June 2020.
  • Stage 3 - implementation of the legislation. Consultation on finalisation of legislation and implementation schedule with relevant stakeholders, with consideration given to commencement of the new flight operations regulations..

We are currently in Stage 1. The current continuing airworthiness legislation in the CAR and CAOs will be available to existing charter operators until the completion of Stage 3.

Why your views matter

We recognise the valuable contribution community and industry consultations make to the policy decision-making process and future regulatory change. For this reason, we asked the Aviation Safety Advisory Panel (ASAP) to appoint a Technical Working Group (TWG). This group has met twice since its establishment in August 2019, to assist in the reformation and development of this policy. The policy proposed in this consultation document has been endorsed by the TWG. We are now seeking your feedback Please take this opportunity to provide your views on the policy proposal.

The survey has been designed to give you the option to provide feedback on the survey in its entirety or to provide feedback on the policy topics applicable to you. Comments on the PP 1915SS should only be submitted through the online response form.

Documents for review

A copy of the Summary of proposed policy PP 1915SS and other documents related to this consultation are provided below in the ‘Related’ section. This includes a downloadable MS Word copy of this consultation for ease of distribution and feedback within your organisation.

Note: The word document and PDF are not to be used as an emailed submission, unless there are extenuating circumstances and this form of submission has been agreed to by the consultation project lead.

Policy proposal PP 1915SS, is accompanied by three annexes that provide detail on policy specific to that subject matter. These are:

  • Annex A - Continuing airworthiness policies for air transport operation under Part 121 of CASR
  • Annex B - Continuing airworthiness policies for air transport operation under Parts 133 and 135 of CASR
  • Annex C - Maintenance organisation policies for organisations that provide maintenance for aircraft in air transport operation under Parts 133 and 135 of CASR

Please read the Policy proposal – PP 1915SS consultation document and accompanying annexes before providing your feedback in the online survey.

General comments and file upload option

There is a general comments box at the end of the consultation, into which you can place your comments on matters related to the proposed policy, which have not already been addressed in the consultation.

Note: CASA can no longer offer the option to upload files because of the potential risk of malware.

Information about how we consult and how to make a confidential submission is available on the CASA website.

 To be notified of any future consultations, you can subscribe to our consultation and rulemaking mailing list .

Using an iPad

If you are using an iPad to complete the survey you will be asked to 'download the relevant PDF'. Depending on the software you have on your iPad you may need to download the free viewer to review the single document PDF files. Where a file is a 'multi-file or portfolio PDF you will need to source the Adobe free view - available from iTunes.

What happens next

Once the consultation has closed, we will review each submission. All submissions will be made publicly available on the Consultation Hub, unless you request your submission remain confidential. Once all submissions have been considered, we will publish a Summary of Consultation which summarises the feedback received, and the action we plan to take regarding that feedback. Relevant feedback that improves upon the proposed regulations and is consistent with the regulations and other CASA policy, will be incorporated into the final ruling.

After all comments have been considered and the policies refined accordingly, we will finalise the policy proposal in consultation with the TWG and ASAP, and then commence the legislative drafting process. The draft legislation will be consulted in 2020 to ensure the policies have been accurately captured. We are working towards finalising the policies for the future continuing airworthiness requirements by March 2020. This will give certainty to affected parties one year prior to commencement of the new flight operations regulations.

Implementation and transition

Commencement and transition details will be determined and settled in consultation with industry after the policies have been finalised and at the completion of Stage 1.

The next stage (Stage 2) will be the development of legislation based on the agreed policy and the replacement of associated Civil Aviation Advisory Publications (CAAPs) with guidance material (GM), acceptable means of compliance (AMC) and advisory circulars (AC) as needed.

We are committed to transition strategies that minimise disruption to industry and will work in collaboration with the TWG and consultation with the wider industry accordingly.


  • CASA Staff
  • Air operators
  • Airworthiness organisations
  • Engineers
  • Pilots


  • Airworthiness / maintenance