Proposed Part 101 MOS – Chief RePL Instructor assessment fee - (SPC 2319US)

Summary of consultation on SPC 2319US - Proposed Part 101 MOS - Chief RePL Instructor assessment fee

The Civil Aviation (Fees) Regulations 1995 are the regulations for charging all of CASA's cost recovery activities. For this proposed fee item, 24.12  ties the service fee to the granting of an approval under a Manual of Standards (MOS), in this case under proposed paragraphs 2.29A (2)(c) and (4)(c) of the Part 101 MOS.

The regulatory fees are either a fixed amount or have been set at an hourly rate to reflect the cost of CASA's personnel or systems that are required to deliver the services or activities.

CASA engaged broadly with industry for feedback on the proposed $623 Chief RePL Instructor assessment fee. Notification of the consultation was published in the CASA Briefing newsletter, on social media, and the CASA website. A total of 83 industry stakeholders accessed the consultation CASA's Consultation Hub while the consultation was open, from 6 December 2023 to18 January 2024.

This consultation has now closed, and a summary of the feedback is provided below.

About this consultation

The aim of this consultation was to provide operators and industry an opportunity to raise any concerns regarding the proposed regulatory fee. This consultation has facilitated CASA to understand the potential impact that this proposed fee may have on an individual or their operation.

CASA received 14 responses. Nine respondents consented to having their feedback published, while the remaining requested their submissions remain confidential. The responses represented a broad cross section of the remotely piloted community including RePL training organisations (4), Remotely Piloted Aircraft Operator's Certificate (ReOC) holders (3), RePL pilots/instructors (5) and Commercial Pilot Licence and RPA accreditation holders (2). Five respondents stated that they were representing their organisation, while nine were personal views on the proposed fee.

CASA appreciates the contributions made by respondents and acknowledges that their feedback has been beneficial to the consultation process.

There were 83 industry stakeholders who accessed the consultation on CASA's consultation Hub. Of those stakeholders, 17% provided responses.

Of the 14 respondents, 6 supported the proposed fees, one respondent was neutral, and 5 respondents opposed the concept  of fees. Concerns raised included existing charges for ReOC holder renewals, the time needed to undertake the task to process a Chief RePL Instructor assessment, and whether there was a yearly charge to be imposed. These concerns will be addressed in further consultation documentation. Two other respondents disagreed with the fees but did not state their reasons.

The Australian Government’s overarching cost recovery policy is that, where appropriate, non-government recipients of specific government activities should be charged some or all the costs of those activities.

The proposed fees were developed in accordance with the Government Cost Recovery Policy and guidelines. The cost estimates were mapped with a subject matter expert and are the direct cost for a proficient officer to assess a Chief RePL Instructor. Included in this costing is an indirect overhead for system usage and corporate costs. To allow for better industry certainty, it was deemed appropriate to charge a fixed fee.

For existing RePL training organisations that wish to nominate a CRI from the proposed commencement date of the proposed introduction of the CRI position, CASA will be waiving fees for a twelve-month period from the commencement date.

Next steps

As the related CRI application and volume data becomes available, we will review and address assumptions on the fees—this is consistent with the Australian Government Charging Framework. Based on the feedback received from the Technical Working Group (TWG) and industry, the fees do not pose any significant concerns.