We Asked, You Said, We Did

Below are some of the issues we have recently consulted on and their outcomes.

We Asked

CASA published DP1618OS—Maintenance of limited category aircraft. Proposed Subpart 132.M of CASR—on the CASA website from 1-19 September 2017. The objectives of the DP were to provide owners, operators and maintainers of limited category aircraft with the opportunity to provide feedback on potential ways of regulating maintenance of limited category aircraft. Three options were proposed:

  • Continuing to have maintenance of limited category aircraft governed by the current rules.
  • Moving the maintenance requirements for limited category aircraft to Part 42 of CASR.
  • Having a dedicated Subpart 132.M of CASR dealing with maintenance of limited category aircraft.

CASA also consulted with stakeholders on 28 February 2017 at a public meeting held at the Stamford Plaza Hotel in Sydney.

You Said

22 online responses were received from industry participants in relation to the three proposed options. Of the 22 respondents, 17 provided their permission to publish their responses. The responses against the three options were as follows.

 

Option 1 - retain the present regulatory structure

No response                                        4

Unacceptable                                      10

Acceptable with change                      6

Acceptable without change                 2

 

Option 2 - incorporate the limited category aircraft maintenance rules into Part 42 of CASR

No response                                        4

Unacceptable                                      9

Acceptable with change                      8

Acceptable without change                 1

 

Option 3 - create a standalone maintenance Subpart 132.M of CASR

No response                                        0

Unacceptable                                      4

Acceptable with change                      10

Acceptable without change                 8

 

Outcome of consultation meeting held at Stamford Plaza Hotel 28th February 2017

18 industry participants provided unanimous support to proceed with development of a Subpart 132.M of CASR. Of these 18 participants, 9 stated by way of caveat that they would need to see the full policy detail before giving unqualified support to the proposal.

The support provided by industry participants at this meeting reflects the responses CASA received online.

 

Key feedback and policy changes

Predominantly, the feedback indicated that the development of a Subpart 132.M of CASR was the preferred option but respondents wanted to see further detail.

We Did

A detailed policy paper will be prepared and published on CASA's Consultation Hub.

Responses to the policy draft will be analysed and regulations will be drafted to give effect to the agreed policies.

We Asked

In August 2017, we surveyed readers of Flight Safety Australia (FSA) magazine about their preferences for delivery and frequency of FSA, which since 2012, has been delivered electronically, via an app for tablets, and the flightsafetyaustralia.com website. We wanted to assess reader’s preferences before making any changes to the magazine’s content and how it’s delivered.

You Said

Our readers said they felt the balance was about right in the coverage of aviation safety issues but would like to see more close calls and accident reports. They also said they wanted aviation safety information more often from the current bi-monthly app and news stories most days.

We Did

From January we are going to increase the frequency of articles including close calls and accident reports, with new stories every week and a monthly edition to download as well as topical news stories published daily on the news site.

We Asked

Since the commencement of Part 66 in June 2011, CASA has received valuable feedback from stakeholders—including Part 66 licence holders and training organisations—on the implications and effects of the legislation. Feedback has highlighted the opportunity to simplify and clarify some aspects of the legislation, and address anomalies, gaps and unintended consequences via conduct of a post implementation review (PIR) of Part 66 of the Civil Aviation Safety Regulations 1998 (CASR).

In support of the PIR, CASA invited submissions to the Post implementation review of Part 66 - Continuing airworthiness - aircraft engineer licences and ratings (PIR 1703MS) from 21 February 2017 to 26 May 2017.

The objective of this consultation was to provide an opportunity for the aircraft maintenance sector to comment on matters relating to aircraft maintenance engineer licences and ratings, covered by Part 66 of CASR, the Part 66 Manual of Standards (MOS) and associated advisory material. CASA asked industry to identify issues that they wanted the review team to address and ideas for possible solutions.

You Said

Respondents

CASA received a total of 70 submissions; 48 respondents consented to having their comments published on the CASA website.

Key feedback

Comments made in the submissions demonstrated that the majority of issues could be grouped into three main 'issues':

  1. Part 66 of CASR, the Part 66 MOS and associated advisory material:
    1. complexity of Part 66 regulations
    2. complexity of the Part 66 MOS
    3. the Part 66-related ACs and Part 66 AMC/GM document are not easily understood
    4. lack of true harmonisation with EASA (as originally intended)
    5. lack of clarity and understanding of the Part 66 regulations and Part 66 MOS
    6. continued use of two sets of regulations (Civil Aviation Regulations 1988 (CAR) and CASR)
  2. licence privileges:
    1. lack of understanding of privileges/limitations
    2. complexity of exclusions on licences
    3. maintaining licence currency (6 months in 24 month requirement)
    4. B1 licence privilege:
      1. understanding what is a 'simple test'
      2. understanding avionic line replaceable unit (LRU) privileges
  3. aeroskills training (that leads to grant of a Part 66 licence):
    1. structure of the training, including knowledge requirements (EASA modules/units of competency)
    2. training pathways
    3. cost of training
    4. type training too complex/difficult
    5. access to training by individuals in remote parts of the country
    6. RPL problems.

We Did

Future direction

CASA expects to establish a CASA/industry Part 66 PIR Working Group soon. The role of the working group will be to contribute relevant technical expertise and industry sector insight to:

  • the analysis and review of the identified issues
  • the development of proposed solutions
  • the formulation of recommendations for improvements to the Part 66 legislation and associated guidance material.