Proposed Part 139 (aerodromes) transition strategy - (PP 1916AS)

Closed 2 Mar 2020

Opened 3 Feb 2020

Results updated 28 Jul 2020

As part of the post-implementation review of Part 139 of CASR - Aerodromes, a revised Part 139 of CASR was made in February 2019 and a revised Part 139 MOS was made in September 2019. The new rules commence in August 2020. This consultation asked people to consider, where new regulatory requirements were being introduced, a number of transition strategies to assist current certified and registered aerodrome operators, and applicants for new aerodromes, to transition to the new rules. The consultation has now closed, and a summary of the feedback is provided below.


Published responses

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


In order to facilitate a smooth transition for aerodrome operators to the new rule set, the Civil Aviation Safety Authority (CASA) has given a great deal of consideration to providing reasonable timelines and balance in terms of meeting the new regulatory requirements, while avoiding undue burden on existing aerodrome operators. Our objective is to ensure aerodromes can continue to operate while transition activities are undertaken.

We are proposing delaying some of the new regulatory requirements during the transition period, to allow additional time for industry to prepare and comply with significant changes. We also intend to bring forward some of the visual aid requirements of chapter eight in relation to aerodrome markings, markers, signs etc and chapter nine in relation to the use of inset runway lights. Additionally, consideration has been given to grandfathering new aerodromes or aerodrome facilities under development, against the current rules where construction will not be complete by 13 August 2020. Aerodrome facilities or new aerodromes under construction or approved before 6 September 2019, or where building or funding approval has been sought before 6 September 2019, will be assessed against the existing Part 139 Manual of Standards (MOS).

The resultant policy will then be enacted through the Part 139 Aerodromes – Consequential, Application, Transitional and Savings provisions (CATS) regulations, which will support the revised  Part 139 of the Civil Aviation Safety Regulations 1998 (CASR) for aerodromes and the Part 139 MOS.

The policy proposal for the Part 139 transitional strategy is divided into three key implementation phases for the revised Part 139 Ruleset:

  • before commencement
  • during transition
  • post transition.

 Main transition strategies  

  • Bring forward commencement date to 13 August 2020 to align with the Aeronautical Information Publication (AIP) publication date.The current commencement date is 22 August 2020.
  • Bring forward Part 139 MOS chapter eight and chapter nine (in relation to use of inset runway lights) to commence as soon as the CATS regulations are made.
  • Application of grandfathering provisions for active infrastructure projects and funding applications prior to commencement in certain circumstances.
  • Deem all certified and registered aerodromes to be certified from 13 August 2020.
  • Delay the requirement for an aerodrome manual for certified aerodromes until six months after commencement of the new rules.
  • Delay the requirement for an aerodrome manual for registered aerodromes until 18 months after commencement of the new rules.
  • Delay new requirements for safety management systems (SMS), risk management plans, aerodrome emergency plans and exercises plus aerodrome technical inspections for 12 or 24 months.

Why your views matter

A revised Part 139 of CASR (aerodromes) was made in February 2019 and a revised Part 139 MOS was made in September 2019. The revised rules commence in August 2020. 

We are consulting to ensure that the proposed policy to transition aerodrome operators into the new Part 139 of CASR requirements, is clearly articulated and will work in practice and as it is intended.

The Part 139 of CASR prescribes the requirements for regulated aerodromes typically used in air transport operations as well as: 

  • obstacles and hazards
  • radio communications facilities at aerodromes.

In order to support a smooth transition for aerodrome operators, a series of Consequential, Application, Transitional and Savings (CATS) provisions are also required as part of a broader Part 139 transitional strategy.

Previous consultations

Full consultation on the proposed changes to Part 139 of CASR and Part 139 MOS culminated in endorsement from the Part 139 Technical Working Group (TWG), under the Aviation Safety Advisory Panel (ASAP) in October 2018. The resultant Part 139 Regulation and MOS amendment aligns with that TWG endorsement.

This Part 139 transitional strategy will support the revised Part 139 of CASR and Part 139 MOS and in no way changes the policy endorsed by ASAP TWG in the October 2018 meeting.  

Documents for review

A copy of the Part 139 transitional strategy is provided below in the ‘Related’ section. Please read through this document and then provide your feedback against each transitional policy proposal in the online survey. You will also find 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.

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 regulatory amendment, 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 register and review each submission received through the online response form. All submissions will be made publicly available on the Consultation Hub, unless you request your submission remain confidential. All comments on the draft Part 139 transitional strategy policy proposal will be considered. Relevant feedback that improves upon the proposed policy, will be incorporated into the final Part 139 Aerodromes Consequential, Application, Transitional and Savings regulations. We will also publish a Summary of Consultation which summarises the feedback received, outlines any intended changes and details our plans for the regulation/standard

We will publish a Summary of Consultation which summarises the feedback received, and the action we plan to take regarding that feedback.

CASA has set a tentative date of April 2020 to make the proposed aerodrome CATS regulations, some of which will come into effect before the proposed new 13 August 2020 commencement date. The feedback we receive from this consultation will also assist CASA in developing adequate implementation and transition timeframes.


  • CASA Staff
  • Aerodrome operator
  • Pilots
  • Air traffic service providers
  • Part 173 Certified/Authorised Instrument Flight Procedure Designer Aerodrome
  • Part 175 of CASR Aeronautical information service providers
  • Aviation Meteorology
  • Certified aerodrome owner/operator
  • Registered aerodrome owner/operator
  • Unregulated aerodrome owner/operator


  • Airspace and infrastructure
  • Safety management systems