Proposed amendments to Part 172 regulations and standards for air traffic service providers – (PP 2207AS)

Closes 8 Jul 2022

Opened 9 Jun 2022


Part 172 of the Civil Aviation Safety Regulations 1998 (CASR) was one of the first CASR Parts introduced in 2003. Part 172 deals with the provision of air traffic services (ATS).

CASA is carrying out a post-implementation review (PIR) of Part 172 of the CASR and its Manual of Standards (MOS). While CASA has amended the MOS from time to time to address specific matters, this is the first comprehensive review of both the Regulation and the MOS.

The structure of Part 172 allows the standards for ATS to be specified either in the MOS or by direct reference to certain International Civil Aviation Organization (ICAO) documents (Annex 11 and Doc. 4444). One of the first steps in the PIR was to do a comparative check of the regulation, the MOS and the relevant ICAO documents. This revealed significant duplication (same standard mentioned simultaneously in different sources), but critically - no regulatory standards for managing air traffic controller fatigue. The review also found that Part 172 is inconsistent with current CASA policy with regard to managerial and organisational arrangements for aviation service providers. 

Proposed changes to regulations and standards

CASA is proposing to amend Part 172 of CASR to:

  • introduce requirements and associated provisions covering the management of air traffic controller fatigue
  • modify the existing change management requirements to require CASA approval for significant changes
  • align the existing management structure requirements with other CASR Parts by setting requirements for an accountable manager and key personnel
  • change the naming convention for key documents from ‘operations manual’ to ‘exposition’
  • simplify the existing hierarchical structure for the various standards to which an ATS provider must comply
  • empower CASA to specify matters that must be accounted for when an ATS provider determines it has enough staff to provide the air traffic services covered by its approval
  • rearrange the layout (the order of regulations) of Part 172 to match the layout of new CASR Parts.

CASA is also proposing to amend the Part 172 MOS to:

  • omit more than half of the standards in the current MOS because they replicate existing ICAO standards or are a defining technique (a way to apply a standard, but not a standard)
  • introduce standards for a fatigue risk management system (FRMS) as the initial and only method for ATS providers to meet the proposed Part 172 of CASR requirement for ATS providers to have a system for managing fatigue
  • redraft, restructure or refresh all remaining standards within the MOS in accordance with discussion and feedback between CASA and a Technical Working Group (TWG). 

Previous consultations

Prior to the release of this policy proposal, CASA consulted internally and externally via a TWG, consisting of representatives from CASA, Airservices Australia and Civil Air (the air traffic controllers’ association).

The TWG met 19 times since its establishment in late 2019. The advice and feedback from the TWG greatly assisted CASA to develop this policy proposal, which – CASA believes – covers essential changes and improvements to Part 172 and the MOS.

Other consultation activities

Three separate consultation activities are taking place under Project AS 14/23:

  1. A fast-tracked amendment to the Part 172 MOS aimed at ensuring the standards in the MOS support the use of digital tower/remote tower services for the provision of aerodrome control services.
  2. A consultation process to address matters concerning independent visual approach (IVA) to parallel runways.
  3. The proposals in this consultation, which will deal with the remaining outcomes of the PIR.

Why your views matter

We recognise the importance and value of community and industry consultation in policy decision-making and regulatory change. We are consulting to ensure that the proposed changes are appropriate, practical and will work as intended.

Comments are sought from every sector of the community. This includes the general public, government agencies and all sectors of the aviation industry.

Documents for review

All documents related to this policy proposal in the ‘Related’ section at the bottom of the page. This includes an MS Word copy of the online survey to make it easy for you to peruse or coordinate feedback within your organisation.

This consultation includes:

  • Policy Proposal (PP) 2207AS - provides a detailed background and explanation of the proposed changes
  • For information only – Annex A to PP 2207AS – Concept for fatigue management standards for the Part 172 MOS
  • For information only – Annex B to PP 2207AS - Extract of ICAO Annex 11 (15th Ed) - Fatigue management
  • Annex C to PP 2207AS - Spreadsheet analysis of proposed changes to Part 172 Manual of Standards
  • Annex D to PP 2207AS - Tabular comparison – Part 172 MOS Ch 1-9 – Current vs proposed
  • Annex E to PP 2207AS - Tabular comparison – Part 172 MOS Ch 10-14 – Current vs proposed
  • MS Word copy of online consultation - Proposed amendments to Part 172 regulations and standards for Air Traffic Services – (PP 2207AS)

Please submit your feedback through the Consultation Hub using the survey provided. If you are unable to provide feedback this way, please contact us for advice through

It is important that you read the Policy Proposal document (PP 2207AS) before providing your feedback.

What happens next

At the end of the response period for public comment, we will review each comment and submission. We will make all submissions publicly available on the CASA website, unless you request your submission remains confidential. We will also publish a summary of consultation which summarises the feedback received and outlines the next steps.

All comments on the PP 2207AS will be considered. Relevant feedback that improves upon the proposed regulations and is consistent with the regulations and other CASA policy, will be incorporated into drafting instructions for the final rules.

Once legal drafting has been completed, we will again consult with industry. This is expected to take place during the second half of 2022.

CASA proposes a transition period of 1 year from the date of commencement of the final changes to ensure that industry has sufficient time to adapt to the new requirements. Timeframes may change depending on the date the draft rules are signed, registered and implemented by CASA.

Give Us Your Views


  • CASA Staff
  • Aerodrome operators
  • Pilots
  • Sports aviation operators
  • Hot air balloon operators
  • Air traffic controller/s
  • Amateur/kit-built aircraft owners and builders
  • Self-administering Aviation Organisations
  • Parachute operators
  • Air traffic service provider/s


  • Drones / unmanned aircraft systems
  • Airspace and infrastructure
  • Air travel
  • Fatigue management
  • Human factors
  • Safety management systems
  • Operational standards
  • Flight training
  • Private operations
  • Self administration aviation activities
  • Sport and recreational aviation - balloons