Proposed instrument (CASA EX32/22) – Cessna Aircraft (Cessna Supplemental Inspection Documents Requirements) Exemption 2022

Closed 17 Apr 2022

Opened 4 Apr 2022

Feedback updated 2 May 2022

We asked

We sought industry feedback over  the 2-week period 4-17 April 2022.

We are proposing to exempt operators and maintainers of Cessna aircraft in the broader private and aerial work sectors from the requirements to carry out Cessna Supplemental Inspection Documents (SIDs).

Cessna SIDS are significant documents for managing continued airworthiness of ageing Cessna aircraft. The new instrument provides flexibility for registered operators of aircraft in the private and aerial work sectors to consider relevant SIDs and take appropriate action to maintain their aircraft. We encourage operators to continue to apply SIDs but recognise not all SIDs are necessary in all cases.

About this consultation

We received 30 responses. Most responses received were from aircraft owners/operators, pilots, maintainers and maintenance organisations. Three responses represented the view of type club, flying school or aero club. One response from design engineer Part 21.M and 1 response from IOA holder/CASA delegate. Four responses provided no comments for the free text question of "How will the proposed instrument work in practice?".

You said

The consultation survey asked respondents their views on "How the proposed instrument will work in practice".

Fourteen responses were clearly in favour of the proposed exemption instrument. In the free text these were voiced as a blend of:

  • a welcome common-sense approach, excellent initiative
  • the CASA mandate for SIDs should never have happened in the first place
  • the cost of full SID compliance had been way too much for most aircraft owners/operators.

Ten responses indicated they are not in favour of the proposed instrument. Extracting from the free text responses these can be aggregated as a blend of:

  • the proposal is unsafe and will cause accidents 
  • a dislike that CASA will now exempt from SIDs compliance
  • there will be a risk to safety by exempting from mandatory compliance.

Four responses provided no comments for the free text question and two responses provided comments that were unable to be as assessed as in favour or not in favour. Therefore, these six we are not able to gauge their submission as 'for' or 'against' the proposed exemption instrument.

Summary of feedback

The majority of respondents who commented were in favour of exempting private and aerial work operators from the current CASA mandate for Cessna SIDs compliance.

Comments were mixed, with the majority favouring the change but others raising concerns about safety and others observing it was 'too little, too late' or 'about time'.

Respondents also raised several important issues and concerns.

The common issues, questions or suggestions were:

  • There has been a huge cost to aircraft owners in complying with SIDs due to the CASA mandate and now you are doing a complete turnaround and providing exemption. Will the industry be reimbursed? Too little help, too late.
  • Higher risk operations like low level aerial work where aircraft fatigue can be a significant factor should not be exempt from complying with SIDs.
  • Under the previously issued Instrument even the twin-engine Cessna aircraft had been relieved from compliance with the 'ATA32' tasks for landing gear but now aircraft in air transport operations that are twin-engine will not gain exemption from those landing gear SIDs inspections.
  • At least four respondents indicated that they severely dislike the way that whole SIDs issue has been handled by CASA since 2014.

We did

Next steps

The consultation showed that there is the majority who are in favour of CASA relaxing the compliance rules around Cessna SID compliance for private and aerial work operations. Therefore, the exemption will be issued as consulted and will be in place by the end of April 2022.

This policy will bring forward corresponding outcomes from the proposed general aviation maintenance regulations (Part 43 of CASR). It brings us into line with global practices and only the specific SIDs elements required by an airworthiness directive will be mandatory.

Under Part 43 of CASR aircraft will be inspected at regular intervals and if action is needed, we will require it to be taken.

Published responses

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

Overview

We are proposing to exempt operators and maintainers of Cessna aircraft in the broader private and aerial work sectors from the requirements to carry out Cessna Supplemental Inspection Documents (SIDs).

The exemption will be in place by the end of April 2022.

This will bring forward corresponding outcomes from the proposed general aviation maintenance regulations (Part 43).  It brings us into line with global practices and only the specific SIDs elements required by an airworthiness directive will be mandatory. 

Under Part 43, aircraft will be inspected at regular intervals and if action is needed, we will require it to be taken.

The proposed instrument would also maintain the intent of the previous instrument (CASA EX67/21) for aircraft in the non-scheduled air transport sector (previously charter) – originally issued as a targeted relief measure for specific SIDs.

SIDS are significant documents for managing continued airworthiness of ageing Cessna aircraft. The new instrument provides flexibility for registered operators of aircraft in the private and aerial work sectors to consider relevant SIDs and take appropriate action to maintain their aircraft. We encourage operators to continue to apply SIDs but recognise not all SIDs are necessary in all cases. 

Opportunity to comment

If you would like to provide comment on the advanced copy of the proposed instrument CASA EX32/22 – Cessna Aircraft (Cessna Supplemental Inspection Documents Requirements) Exemption 2022 you can do so through the online response form.

We want to ensure that it and the additional guidance provided in AWB 02-048 Issue 8: Compliance with Cessna Supplemental Inspection Documents clearly articulates who the instrument will apply to and how it will work in practice. 

Documents for review

All relevant documentation are attached in the ‘related’ section at the bottom of the page.  

What happens next

At the end of the response period, we will:

  • review comments received
  • make all responses publicly available on the Consultation Hub (unless you request your submission remain confidential). 
  • publish a Summary of Consultation which summarises the feedback received, outlines any intended changes and next steps.

All comments received on the proposed instrument will be considered. Relevant feedback that improves upon the proposed instrumentsand amendments to the AWB will be incorporated into the final instrument and AWB.

Audiences

  • CASA Staff
  • Airworthiness organisations
  • Engineers
  • Aircraft owner/operator
  • Part 145 of CASR approved maintenance organisations (AMO)
  • Regulation 30 of CAR maintenance organisations (CAR 30)
  • Licensed aircraft maintenance engineers (LAME)
  • Aircraft maintenance engineers (AME)
  • Aerial work operator
  • Part 142 operators
  • Part 141 operators
  • Aerial work operator (Part 138)

Interests

  • Airworthiness/maintenance (CAR 30 and CASR Part 145 maintenance orgs)