Since the introduction of Part 66 of CASR, CASA has received submissions from industry stakeholders indicating that the Part 66 licence pathways are too inflexible, particularly in relation to pathways for initial licence issue in comparison to the previous CAR 31 licensing system
The “all or nothing” approach of Part 66 has been cited as a stumbling block for individuals, who either don’t have a strong interest in one of the aspects of a full Part 66 licence or who are unable to accumulate the necessary practical maintenance experience for all the required systems. The issue also affects people who hold foreign licences and are seeking to convert their foreign licence to an Australian licence.
These industry submissions generally suggest that a progressive, modular licensing structure should be developed to facilitate earlier and more achievable licensing outcomes with improved flexibility for licence applicants and businesses.
CASA has committed, through its GA Workplan, to consider more progressive, less onerous maintenance licence pathways tailored for light aircraft.
About this consultation
CASA published DP 2218MS to outline considerations and possible options for AME licence pathways that would provide a more flexible and achievable licensing outcome, particularly in relation to initial licensing outcomes.
This consultation asked people to provide comment on DP 2218MS and the suggested changes to the Part 66 licence structure, that would address both industry submissions and the GA workplan objectives.
CASA received 60 responses to the discussion paper, 46 of which were from licensed aircraft maintenance engineers, 10 from aircraft owner/operators, 11 from CAR 30 approval holders, 8 from Part 145 approved maintenance organisations and two from Part 147 maintenance training providers.
3 CASA officers also provided comments.
39 respondents gave permission to publish their responses.
Summary of feedback
Of the 60 respondents, 38 supported the proposals as published, and 6 respondents were opposed to the concepts.
Of the remaining 14 respondents, the proposals were generally acceptable however some changes were proposed.
Key themes and issues
Modular licensing pathways would be beneficial
Most respondents clearly supported the intent to provide a more flexible, modular licensing framework.
Use of exclusions
A majority of respondents supported the use of exclusions. Four respondents opposed exclusions on the grounds that exclusions are confusing.
Seven respondents called for expanded use of the full range of exclusions, to maximise flexibility and licensing outcomes. In particular, reference was made to providing for a licence to be obtained without needing practical experience on systems that are not accessible or not applicable to a person's employment, such as air conditioning, pressurisation and retractable undercarriage.
The proposal in the DP is framed around the use of exclusions, in the first instance, in order to expedite delivery of the intended benefits and outcomes. However, CASA acknowledges that some industry stakeholders do not agree with the use of exclusions in any context.
Exclusions were designed to transition between CAR 31 and Part 66 licences. Exclusions do have the potential to be used as a useful and beneficial mechanism to facilitate licensing outcomes, particularly in cases where a licence applicant cannot achieve the necessary experience in particular systems. This is a common situation in regional areas. Expanded use of exclusions also has potential application in acceptance of foreign licences with different scope.
Any ongoing use of exclusions will need to be carefully considered, particularly in relation to the associated training requirements, administrative implementation arrangements and clear understanding of licence scope and privileges.
Whether we need a phase 2 positive description
A small number of respondents opposed a second phase to develop a positive description of modular licensing, on the basis that it would only further add to confusion.
It is acknowledged that the desired practical outcomes of a modular licensing system can be achieved using exclusions and a positive description of privileges is not essential. CASA intends to continue to focus on expediting the desired modular licensing outcomes via exclusions and will consider a positive privilege arrangement as a possible future extension, after a settling-in period using exclusions.
Propellers separate from powerplants
The majority of respondents did not comment on this subject. Two respondents specifically opposed separating propellers from power plants. An equal number of respondents specifically expressed support for the concept.
An objective of this initiative is to increase flexibility and improve licensing outcomes for industry. Providing propellers as an option, rather than a requirement, is consistent with this objective. It is also noted that a propeller qualification would be an unnecessary and potentially unwelcome burden for LAMEs who work in a helicopter-only environment.
Following discussions with the TWG, and with the aim of expediting delivery of core modular licensing outcomes, CASA will develop a proposal that retains propellers as a requirement for piston engine aeroplane licences but not helicopters. This approach can be reviewed in later phases of this initiative, if necessary.
Practical experience period should be longer
Some respondents suggested that the minimum practical experience proposed in the discussion paper is insufficient.
CASA notes that this proposal is intended to facilitate licensing outcomes. It is understood that a modular approach to licensing will naturally reduce the training and practical experience requirements and timeframes. Experience should be specific to the required licence outcome and proportional to the proposed licence scope. In cases where the licence scope is reduced, relative to the current arrangements, it is considered reasonable to proportionately reduce the experience. In all cases, the proposal would ensure at least 1 year practical experience, which is consistent with recommendations set out in ICAO Annex 1.
Following discussions with the TWG, and in order to expedite core modular licensing outcomes, CASA will develop a legislative proposal that does not change the current experience requirements stated in the Part 66 MOS. CASA will consider proportionate adjustments to the experience requirements in the second phase of this initiative.
Physics should be mandatory for all licences
Several respondents commented that physics should be a required theoretical module for all licences.
Omission of physics module 2 in the discussion paper was a typographical error.
Physics is a relevant knowledge element for all licences and is an element of the ICAO licensing standards.
Electrical should be mandatory for all licences
Several respondents commented that electrical should be a required theoretical module for all licences.
An objective of this initiative is to increase flexibility and improve licensing outcomes for industry. Providing electrical as an option, rather than a requirement, is consistent with this objective. It is also noted that an airframe only licence would be a useful practical outcome, particularly for small, simple GA aircraft.
CASA will consider this issue further and will work with the TWG to develop a flexible and practical legislative proposal.
CAR 31 basic examination credits should be recognised
Several respondents suggested that credits obtained under the old CAR 31 licensing arrangements should be recognised.
This concern is outside the scope of this paper. However, CASA has a process in place for mapping CAR 31 examination credits for RPL purposes. We will consider a review of procedures in this area.
Recognition of expired CAR 31 licences
CASA has received feedback during this consultation suggesting that we should consider applying the same approach that is used for recognition of foreign licences to recognition of expired CAR 31 licences.
CASA agrees that this is desirable and will consider options to achieve this outcome.
Use of CAR 31 summary of experience (in place of the journal/log of industrial experience)
Several commenters requested CASA accept the old CAR 31 summary of experience in lieu of the new journal/log of industrial experience developed for the Part 66 self-study system.
This concern is outside the scope of this paper. However, CASA will review its procedures in this area.
The proposed CAR 31-based model vs other options (EASA B3)
Respondents generally indicated strong support for a CAR 31-like structure.
No respondents supported adoption of the EASA B3 or B2L licence arrangements. Respondents who mentioned EASA were generally critical of the EASA licensing structure.
In order to expedite core modular licensing outcomes, CASA will develop a legislative proposal that does not specifically adopt the EASA B3 and B2L structure. CASA will consider this issue in more detail in the second phase of this initiative.
Overall, respondents have strongly supported the proposals and encourage CASA to expedite the delivery of more flexible licensing outcomes.
CASA will therefore proceed with this initiative, using the input provided to develop a more detailed policy, legislation and implementation package.
Consistent with the feedback from industry and the TWG, CASA will seek to expedite the delivery of the core beneficial outcomes of this proposal. To achieve this, CASA will develop a legislative proposal that will facilitate modular licensing outcomes using exclusions. This approach will also provide more flexible pathways in other cases, including Australian trainees, that cannot access certain systems to gain practical experience, as well as recognition of foreign licences and defence authorisations. In order to expedite these outcomes, the status quo will be maintained on some requirements, such as minimum experience requirements and propeller exclusions. These requirements will be considered in more detail in later phases of this initiative after the core outcomes are achieved.
We sought industry feedback between 1 and 16 December 2022 on the proposal to establish a tailored system for training, assessment, grant and exercise of aerial mustering endorsements.
Previously, industry had told us that the flight training and testing scheme for aerial mustering endorsements was not working as efficiently as intended. In many respects, the intended approach to flight training has not materialised for mustering pilots. This is believed to be one of the reasons for the limited availability of suitably qualified flight instructors, examiners and flight training operators to conduct training and assessment for aerial mustering endorsements and consequently impacts on the availability of suitably qualified pilots to conduct mustering operations.
We proposed changing the rules to establish a tailored alternate system for training, assessment, grant and exercise of aerial mustering endorsements.
Note: The existing Part 61 and Part 141 flight training scheme remains available for training, assessment, grant and exercise of aerial mustering endorsements.
The proposal addressed:
About this consultation
We received 22 responses, the majority from flight instructors and flight examiners, pilots, flight training operators and Part 138 operators.
The consultation survey asked respondents “Do you have any comments about the proposed instrument?”. Nineteen of the 22 responses provided feedback on this question. Four responses were clearly in support of the proposed instrument. Twelve responses implied support for the objectives of the policy, while either suggesting changes to the technical detail of the instrument, making comment on the mustering sector generally, or posing questions on the operation of the instrument.
Common themes from the free text responses included opinions that the new rules will:
Three responses did not support the proposed instrument. These free text responses included comment that the instrument:
Summary of feedback
Common themes, issues and suggestions raised in responses included:
Focus on safety culture
Two respondents emphasised the importance of the mustering sector—and the pilots and operators operating in that sector—adopting and maintaining a safe flying culture.
One of these respondents indicated:
Conversely, another respondent commented:
"Some of the most unsavoury habits that exist in the helicopter industry exist within the mustering community."
They also noted:
We recognise and emphasise the importance of pilots and operators conducting mustering adopting and maintaining a strong safety culture. The proposal is intended to emphasise operational responsibility and to build on safety requirements such as safety systems and operational manuals required under Part 138 of CASR. Part 138 operators who intend to conduct training and facilitate the assessment and grant of endorsements will need to develop a training syllabus and have it approved by CASA. CASA needs to be satisfied that the operator can safely and adequately deliver the training and that the operator has suitable staff to conduct the training.
Specific technical requirements
Eight responses made comment or reference to the specific technical requirements proposed in the instrument (for example, the prerequisites for trainee pilots). These responses made quite varying suggestions, including:
Prerequisites for trainee pilots
Training and assessment
Recurrent checks
Trainer requirements
Questions posed by respondents regarding how the instrument will work.
Three respondents also asked questions regarding how the instrument will work. These questions (edited for length and consistency) and CASA's responses are at Table 1.
Table 1: Respondent questions and CASA responses
|
Question |
CASA response |
|
Can Part 141 operators that currently provide training for aerial mustering endorsements still provide that training once the instrument is in effect?
|
Yes. The proposed instrument is an alternative pathway to gain an aerial mustering endorsement. Part 141 operators who conduct training for aerial mustering endorsements can continue to deliver that training as usual. |
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Is it intended that a pilot who receives an endorsement under this instrument could immediately conduct unsupervised aerial mustering operations under Part 138? Or will the requirements in the Part 138 MOS section 17.02 continue to apply? |
The Part 138 MOS outlines operational standards for Part 138 operations, including mustering. Within the Part 138 MOS there are additional requirements concerning pilots conducting unsupervised mustering operations beyond the scope of the proposal. It is intended that a trainee pilot would still be subject to the requirements in the Part 138 MOS at the completion of training conducted under the proposal. This means that trainee pilots may be required to gain additional experience, as they would if they were to gain an aerial mustering endorsement through the existing Part 61 pathway. However, we will consider whether amendments to the Part 138 MOS are required. |
|
Will a flight test be required for the grant of an aerial mustering endorsement through the proposed instrument? |
Yes. The training culminates in a flight test, however this will be conducted by the trainer appointed by the Part 138 operator that has conducted the mustering training. Further consideration of the flight test requirement would be included in the review and subsequent amendment to the regulations. The proposed flight test requirement is to keep this interim solution as streamlined with the current rules as possible and to minimise the differences from a licensing administration perspective. |
Considering the highly variable suggestions mentioned above, we intend to proceed with the proposed requirements. We will review how the instrument is operating once it is in effect by continuing to engage with the mustering sector, and we will complete a policy review before making any changes to CASR to incorporate the effect of the proposed instrument.
Next steps
The consultation indicated support for the proposed instrument and the proposed alternative pathway for the training, assessment and grant of aerial mustering endorsements. Minor changes will likely be made to improve the clarity of the instrument. However, any changes will not impact the intended effect of the instrument or the underpinning policy.
The instrument will be in place by the end of January 2023.
We sought industry feedback between 17 and 31 August 2022 on proposed changes to the privileges of the Grade 1 training endorsement.
Industry had previously told us that parts of the flight training and testing scheme are not working as efficiently as intended. Not all of the privileges of the Grade 1 Flight Instructor Rating under the old scheme were transferred to the Part 61 Grade 1 training endorsement and this has diminished the incentive for flight instructors to seek a Grade 1 training endorsement.
We proposed changing the rules to allow some Grade 1 training endorsement holders to conduct:
About this consultation
We received 43 responses, mostly from flight instructors and flight examiners, pilots and flight training operators.
The consultation survey asked respondents “Do you have any comments about the proposed instrument?”. Twenty-nine responses were clearly in support of the proposed instrument. Ten responses implied support for the objectives of the policy, while either suggesting changes to the technical detail of the instrument, proposing changes that are out of scope of the instrument, or posing questions on the operation of the instrument.
Common themes from the free text responses included opinions that the new rules will:
Four responses did not support the proposed instrument. These free text responses included comment that the instrument could:
Summary of feedback
Common themes, issues and suggestions raised in responses included:
Conduct of assessment (flight test)
Seven respondents made comments relating to the proposal to allow relevant Grade 1 training endorsement holders to conduct nominated assessments (flight test) and grant authorisations. The comments related to:
We recognise that the Grade 1 training endorsement holders who can make use of the instrument are experienced in training pilots and/or other instructors. Assessment of competency is a fundamental capability of all instructors, and as such these instructors have demonstrated their ability to assess trainees undergoing training at least at the basic level. What they have not covered in their training is the administration aspects of conducting flight tests and granting authorisations. While we acknowledge the possibility of a Grade 1 training endorsement holder conducting an assessment (flight test) for a training endorsement which the Grade 1 training endorsement holder themselves recently attained, it should be noted that the core competency of the Grade 1 training endorsement includes the ability to assess trainee competency. Grade 1 training endorsement holders will need to comply with the general competency rule in regulation 61.385 of CASR and ensure they are competent to conduct the activity in an aircraft.
We will review how the proposed instrument has worked before amending Part 61 of CASR, to further consider whether the assessment for the grant of the additional training endorsements needs to be a flight test. This would mean that Grade 1 training endorsement holders would be permitted to assess and grant the endorsements without conducting a flight test, as for flight activity and design feature endorsements and indemnity will therefore not be extended to Grade 1 training endorsement holders.
Further expansion of Grade 1 training endorsement privileges
Four responses suggested that the proposal does not adequately address problems experienced by the rotary sector conducting training for specialised activities typically associated with the low-level, aerial application or night VFR ratings and endorsements, and should be extended. These responses suggested that:
CASA is developing an alternative pathway for the training, assessment and grant of nominated 'specialised pilot endorsements' as part of its GA Workplan: Improving pilot licensing rules | Civil Aviation Safety Authority (casa.gov.au). The generic term specialised pilot endorsements has been used by CASA to refer to the aerial mustering, sling operations, winch and rappelling operations, and firefighting endorsements to the low-level or aerial application rating (as relevant). CASA expects that this project will provide benefit for operators and pilots who conduct some of the specialised activities mentioned above. The focus of the alternative approach is to facilitate the training, assessment, and grant of nominated low-level or aerial application endorsements to experienced pilots, rather than to facilitate the training, assessment and grant of nominated training endorsements to other instructors.
We expect to make a draft instrument for the alternative 'specialised pilot endorsements' pathway available for consultation in the near future and will seek feedback to determine if that instrument will address the problems and proposals mentioned above.
Noting these factors, we intend to proceed with the proposals as drafted.
Questions posed by respondents regarding how the instrument will work
Seven respondents also asked questions on how the instrument will work. These questions (edited for length and consistency) and CASA's responses are presented in Table 1 below.
Table 1: Respondent questions and CASA responses
|
Question |
CASA response |
|
Will there be a specific form and applicable e-learning module link created for those who meet the necessary prerequisites? |
Yes. Grade 1 training endorsement holders who seek to conduct assessments (flight tests) under the instrument will need to use a form to apply for access to the e-learning modules. This form will be made available on the CASA website upon commencement of the instrument. |
|
Why do Grade 1 training endorsement holders need to complete the e-learning modules? |
Training for the Grade 1 training endorsement currently does not address administrative matters and other matters to ensure consistency in assessments across industry. During the e-learning modules, Grade 1 training endorsement holders will also be required to develop workbooks to facilitate their conduct of assessments (flight tests) and will be able to view sample workbooks produced by CASA. |
|
Will you need to complete the e-learning modules for each type of assessment (flight test) you want to conduct? |
No. A Grade 1 training endorsement holder only needs to complete the e-learning modules once. |
|
Will the Grade 1 training endorsement holders conducting assessments (flight tests) need to complete an instructor proficiency check with a flight examiner? |
Yes. A Grade 1 training endorsement holder must have successfully completed an instructor proficiency check conducted by a flight examiner within the previous 24 months before conducting an assessment (flight test). |
|
Will the grant of an additional training endorsement be taken to satisfy an instructor proficiency check? |
For an instructor (the trainee) who successfully completes an assessment (flight test) conducted by a Grade 1 training endorsement holder under the instrument, the grant of the additional training endorsement will satisfy the trainee’s instructor proficiency check. A Grade 1 training endorsement holder conducting assessments (flight tests) must have successfully completed an instructor proficiency check conducted by a flight examiner within the previous 24 months before conducting an assessment (flight test). This means that the grant of an additional training endorsement to a Grade 1 training endorsement holder following an assessment (flight test) conducted by another Grade 1 training endorsement holder will not 'reset' their instructor proficiency check for the purposes of the instrument. |
|
Can a Grade 1 training endorsement holder who conducts training for the Grade 2 training endorsement also grant the Grade 2 training endorsement? |
No. A Grade 1 training endorsement holder is only permitted to conduct training for the Grade 2 training endorsement. The flight test for the grant of the Grade 2 training endorsement must be completed by an appropriately qualified flight examiner. |
|
Will Grade 1 training endorsement holders who also hold a flight examiner rating and who become authorised to conduct assessments (flight tests) under the instrument be able to have those approvals added to their flight examiner rating? |
No. The privileges allowed under the instrument are privileges of the Grade 1 training endorsement, rather than the flight examiner rating. The instrument provides a temporary pathway while it is determined if flight tests are required for these types of competency assessments. |
|
If the Grade 1 training endorsement holder conducting the flight test must be approved to conduct flight training for the same kind of authorisation by a flight training operator, does this mean responsibility for the conduct of the flight test and grant of the authorisation falls on the flight training operator? |
No. The conduct of flight tests is not a Part 141 or Part 142 flight training activity. Although a Grade 1 training endorsement holder must be authorised to conduct the training by a flight training operator, responsibility for the assessment and grant will lie with the Grade 1 training endorsement holder. This will reflect the likely future state whereby the relevant authorisations can be granted by instructors without a flight test (as flight activity and design feature endorsements are currently granted by instructors). |
|
Can both Part 141 and 142 flight training operators use Grade 1 training endorsement holders to conduct activities authorised by the instrument? |
Yes. The instrument is not intended to be limited to Part 141 flight training operators. Generally, operators conducting training for training endorsements are Part 141 flight training operators. We will ensure the instrument refers to both Part 141 and 142 flight training operators. |
The consultation demonstrated broad support for the proposed instrument and the changed privileges of the Grade 1 training endorsement. Minor changes will likely be made to improve the clarity of the instrument. However, any changes will not impact the intended effect of the instrument or the underpinning policy.
The instrument will be in place by the end of September 2022.
We asked industry to provide feedback on the draft Mangalore Aeronautical Study conducted by CASA’s Office of Airspace Regulation (OAR). This aeronautical study assessed the airspace within 25 nautical miles (NM) of Mangalore from the surface to 8,500 feet (FT) above mean sea level (AMSL).
We sought feedback to understand industry and community issues, observations or positions regarding the information contained in the draft report.
The consultation was open from 13 July to 11 August 2022. We received 28 responses (21 via the survey, and 7 via email) from membership-based organisations (such as Civil Air, Recreational Aviation Australia and the Australian Airline Pilots' Association) as well as pilots from sporting, recreational and general aviation backgrounds. Fifteen respondents consented to having their comments published. Read what people had to say in the ‘Published responses’ section on this page.
Overall, responses were generally supportive of the draft aeronautical study.
The feedback validated the issues of frequency congestion and use of non-standard phraseology. Various aviation groups expressed an interest in presenting information at aviation seminars to help improve education.
There were some comments on topics outside the scope of the aeronautical study, including:
Each comment was reviewed and, where actionable, incorporated into the final report. All comments were greatly appreciated. Where consent has been given to publish a response, these have been included in the final version of the study.
The recommendations in the draft report have not changed.
We are now actioning the recommendations we are accountable for:
Recommendation 1
CASA Aviation Safety Advisors should conduct a safety seminar at Mangalore and surrounding aerodromes with an agenda that focusses on awareness and safety for operations within the vicinity of a non-controlled aerodrome and the importance of precise and concise radio calls.
Status: In progress
In September 2022 we started our latest AvSafety seminars for pilots with the topic “Non-Controlled Aerodromes: Manage Your Risks”. These free seminars are being held at locations across Australia for 12 months including regional centres near Mangalore.
We also launched a broader national pilot safety campaign in mid-August. The ‘Your safety is in your hands’ campaign is built around 4 key safety topics. Operating around non-controlled aerodromes was the first topic and activities. We engaged pilots via a range of channels including podcast, investigative panel video and webinars. Resources continue to be available on our pilot safety hub.
Recommendation 2
En Route Supplement Australia (ERSA) entries at Mangalore, Ballarat, Latrobe Valley and Busselton be amended to remove or clarify the requirements for the addition of 1,000 FT to prescribed altitudes during practice instrument approach procedures.
Status: Completed
The ERSA was updated and effective from 8 September 2022.
Feedback outside the scope of the study has been provided to CASA Executive Management for consideration.
The OAR will continue to monitor the airspace around Mangalore at regular intervals.
We asked people to provide feedback on a proposal that would extend the period within which terminal instrument flight procedures (TIFPs) are revalidated by CASA from 3 to 5 years. The consultation has now closed, and a summary of the feedback is provided below.
About this consultation
From 8 July 2022, CASA consulted on a proposal to amend paragraph 6.1.4.2 of the Part 173 Manual of Standards (MOS) that requires all TIFPs to be revalidated by CASA at intervals not exceeding 3 years. In line with ICAO Annex 11 and PANS-OPS Volume II, the proposal was to amend the MOS provision so that all TIFPs are revalidated at intervals not exceeding 5 years.
The consultation closed on 22 July 2022 and there were 14 responses. Respondents included 2 unknown/unspecified respondents, 1 air operator, 1 aerodrome industry consultant, 1 aircraft owner, 1 pilot, 1 air traffic controller, and 7 Part 173 certified flight procedure design organisations. Eleven respondents consented to having their comments published and 3 requested their submissions be kept confidential.
The consultation survey asked respondents whether they agree with and support the proposed amendment that all TIFPs are revalidated at intervals not exceeding 5 years.
All the respondents agreed that it is a good idea to align this regulatory amendment to existing ICAO Standards and Recommended Practices (SARPS). The respondents were in favour of the proposed change and overall supported the proposal.
Summary of feedback
Proposal – Amend the flight revalidation interval standards in section 6.1.4 of the Part 173 MOS
Responses were positive and constructive. Generally, respondents were in favour of the proposed change and supported the extension of the flight revalidation interval from the current not exceeding 3 years to not exceeding 5 years to align with ICAO SARPS. Most respondents agreed that the proposed change would reduce the cost of compliance for the industry without affecting safety.
One respondent provided no feedback on this proposed amendment.
Another respondent, although supporting the alignment with ICAO SARPS, felt by changing the time interval from three to five years would allow for hazards to go unchecked for longer.
CASA's response
Paragraph 6.1.5.1 of the Part 173 MOS states:
Before the effective publication date of a TIFP, the certified designer must forward to the aerodrome operator for which a procedure has been designed, diagrams and obstacle data sufficient to enable the aerodrome operator to fulfil obligations to report and monitor obstacles in the vicinity of an aerodrome as required under Part 139 of CASR.
There are no differences in obstacle monitoring and reporting regimes as obstacle restrictions and limitations are required by Chapter 7 of the Part 139 MOS.
Chapter 7 of the Part 139 MOS relates to obstacle restrictions and limitations. It requires an aerodrome operator to monitor the manoeuvring area of, and the airspace around, an aerodrome; maintain them free from obstacles in accordance with the Part 139 MOS; and report new or changed critical obstacles to the certified procedure designer.
Under section 7.03 of the Part 139 MOS, an aerodrome operator must establish and monitor the obstacle limitation surfaces (OLS). OLS means a series of planes, associated with each runway at an aerodrome, that defines the desirable limits to which objects or structures may project into the airspace around the aerodrome so that aircraft operations at the aerodrome may be conducted safely applicable to the aerodrome, and, as far as possible, ensures that the OLS within the aerodrome boundary is maintained clear of obstacles.
Under subsection 7.20 (3) of the Part 139 MOS the aerodrome operator must inform the certified designer of a TIFP at the aerodrome of the following:
(a) any change in the status of an existing critical obstacle;
(b) any proposed development that is to be higher than the critical obstacles within the area depicted by the designer;
(c) any new object or structure that is higher than the critical obstacles within the area depicted by the designer.
Therefore, CASA has assessed that extending the intervals at which CASA must conduct a flight revalidation of a TIFP does not impose any new obligations on TIFP design organisations, aerodrome operators or airspace users.
Overall, the respondents were in favour of the proposed change and strongly supported the proposal. CASA will now undertake to implement the changes in the Part 173 MOS.
CASA is also currently undertaking a complete Post Implementation Review of the Part 173 MOS (Project AS 04/02 - CASR PART 173 - Review of CASR Part 173 Manual of Standards (MOS) - Instrument Flight Procedure Design) and will further update the existing Part 173 MOS as a result of more discussions with industry.
We asked industry to provide feedback on the draft Airspace Review of Ballina conducted by CASA’s Office of Airspace Regulation (OAR). This aeronautical study assessed the airspace within the vicinity of Ballina from the surface to 8,500 feet above mean sea level.
The consultation was open from 16 June until 17 July 2022.
We sought feedback from airspace users via a survey, drawing on the contents of the airspace review. The review had identified 3 areas of concern:
To address these concerns and improve safety, the review proposed 9 recommendations. They represent a graduated approach to reducing airspace risk at Ballina, intending to build up to a controlled aerodrome service with an associated control zone and control area steps.
We received 148 submissions via the survey and email.
Responses were received from a variety of airspace users. Most were from airlines, aerial work operators, flight training, air transport licence holders, commercial licence holders, private/recreational pilots, sports aviation pilots and air navigation service provider staff.
The reduction of airspace risk was widely supported. There was virtually no opposition to the importance of airspace safety and strong support to improve safety in and around Ballina.
There were some differences in opinion regarding the appropriateness, timing and phased implementation of the recommended measures.
There were a small number of remarks regarding the cost associated with the recommendations. Some preferred more cost-effective solutions such as the existing SFIS services. The primary concern among the general aviation community was the balance between retaining the current level of access and amenity while deriving the safety dividend.
There were some concerns about airspace efficiency and that controlled airspace constraints may reduce capacity at times. Some expressed the view that the introduction of ATS reduces the efficiency of the airspace due to the separation standards applied to aircraft operating in the area compared to uncontrolled airspace. Some users had concerns about potential delays in obtaining clearances to operate in their usual volumes of airspace.
A common theme was interim solutions should be ICAO-compliant and form part of the enduring solution. Any interim measure should not have to be wound back as subsequent measures are phased in.
Timing of the measures is a critical consideration. Many stakeholders favoured the earliest practical adoption of the measures. There were no comments seeking to delay the initiatives among the vast majority that support the measures, notwithstanding that some respondents preferred the status quo.
Based on the responses received, no changes were made to the recommendations in the draft report however the proposed milestones were revised.
The timelines and milestones for implementing the recommendations will be finalised through further engagement with stakeholders.
Read the full report on the CASA website.
We sought industry feedback over the 2-week period 21 June – 4 July 2022 on proposed changes to multi-engine helicopter ratings.
Industry had previously told us that our current approach of requiring a type rating for each multi-engine helicopter limits access to qualified flight instructors, flight examiners, and flight training operators for some multi-engine helicopters. The issue is compounded by the very small number of these types of helicopters in Australia and it has led to increased costs and time to access training and assessment.
We proposed changing the rules to create a class-like system as the first step in introducing a new multi-engine helicopter class rating.
About this consultation
We received 20 responses, mostly from pilots, flight instructors and flight examiners. Three responses were submitted on behalf of flight training operators and commercial operators. Three responses did not provide any comments.
The consultation survey asked respondents “Do you have any comments about the proposed instrument?”. Nine responses were clearly in support of the proposed instrument.
Common themes from the free text responses included opinions that new rules will:
Seven responses implied support for the objectives of the policy, while suggesting changes to the technical detail of the instrument. Four responses provided comments that identified minor errors in the instrument, posed questions on the operation of the instrument or proposed changes that are out of scope of the instrument.
Four responses did not support the proposed instrument. These free text responses included comment that the proposed instrument:
Summary of feedback
Common themes, issues and suggestions raised in responses included:
Comments on the 'complexity' of aircraft nominated to be in the 'class'
Four responses commented that the use of the term 'less-complex multi-engine helicopters' was inappropriate. These respondents noted that the multi-engine helicopters included in the Prescription of Type Ratings Excluded from CASR Part 142 Flight Training (Edition 6) Instrument 2018 did not reflect the characterisation of a 'less-complex helicopter'. CASA acknowledges that characterisation is broad and open to interpretation. However, since assigning these single-pilot types to be Part 141 flight training activities CASA has not identified any negative safety impacts. It is the link between the complexity of the training (organisational systems) and the operation of the aircraft, especially for multi-crew operations, that is significant and the rationale for assigning multi-crew type rating training to Part 142 of CASR.
Noting that there were no comments on the appropriateness of the training being under Part 141 of CASR for helicopters included in the system, CASA intends to proceed on the basis that existing training activities in these helicopters can be maintained with minimal impact.
Proposed significant or beyond-scope changes
Multiple respondents also proposed significant changes to the proposed multi-engine class or suggested other changes beyond the scope of the policy. These suggestions included:
CASA notes these responses are significant or beyond the scope of change therefore they will be brought forward in future policy considerations prior to including the class rating in the regulations.
Errors in Schedule 1 of the proposed instrument
Two errors in the schedule of prescribed helicopters were identified and will be corrected prior to commencement of the instrument. These were:
The consultation showed there is broad support for the proposed instrument and the establishment of a multi-engine helicopter class rating. Minor changes will be made to correct identified errors in Schedule 1 of the instrument. Minor changes will likely also be made to improve the clarity of the instrument and to prevent any unintended consequences. However, any changes will not impact the intended effect of the instrument or the underpinning policy.
The instrument will be in place by 15 August 2022.
This consultation asked industry to provide feedback on the draft advisory circular (AC) on heliport design and operation. The issue of this AC, in concert with AC 91-29, replaces CAAP 92-2(2) and CAAP 92-4(0) and represents a comprehensive adoption of the international standards and recommended practices contained in Annex 14 Volume II. A heliport is a helicopter landing site (HLS) that is designed, constructed and operated in accordance with the specifications outlined in the AC. Heliports are typically dedicated helicopter operating areas supporting air transport operations, medical patient transport and offshore oil and gas operations.
The consultation has now closed, and a summary of the feedback is provided below.
A total of 6 responses were received with 1 each from a heliport owner/operator, a certified aerodrome operator, and a planning authority as well as 3 heliport consultants/designers.
Of the respondents who made written submissions, 1 consented to having them made public and 5 requested their submissions be confidential.
Summary of feedback
In addition to some relatively minor editorial and typographical matters raised, the main actionable subjects that were identified included:
There were some comments on important matters that could not be addressed within the scope of this AC development. They include:
Also, there was a comment regarding need for this document, and another, to address the potential lack of adoption by industry of the specifications. While these comments are noted, it is necessary for CASA to incorporate these specifications within our regulatory suite to give it effect within Australia. As they remain guidance, different sectors and industry bodies that have developed and/or adopted different specification (including more prescriptive models) are able to consider these specifications within their broader environment and with respect to their risk appetite.
All comments were appreciated and, as result of the feedback, the AC is a better document. Each comment was reviewed and, where feasible, incorporated into the AC.
With respect to the 5 areas of comments the following summarises changes with the AC:
About this consultation
We sought industry feedback between 5 and 20 May 2022 on Plume rise assessment - draft Advisory Circular 139.E-02 v1.0. The consultation proposed amendments to the current Advisory Circular (AC). The key amendment proposed was the incorporation of the MITRE Exhaust Plume Analyzer as a tool to determine the probability of an aircraft experiencing turbulence near a plume rise.
It was also proposed that the AC was amended to clarify CASA's role in the assessment process and that Land Use Planning Authorities (LUPAs) are the decision maker on applications from proponents that include a plume rise.
Stakeholders were asked whether the proposed changes provide adequate guidance on how to obtain advice from CASA and CASA's process for assessing plume rises.
Most responses received were from aircraft operators, with 3 respondents identifying as consultants on plume rise assessments and 2 as representing airport operators.
Summary of feedback
We received 35 responses to this consultation. Thirty-four respondents supported the proposal, with 9 of these respondents recommending changes of a relatively minor nature to the proposal.
One respondent opposed the proposal and cited a 2006 US FAA paper. However, in 2015, after further study, the US FAA concluded that plumes in the vicinity of airports could create hazards to aircraft in critical flight phases that would be incompatible with airport operations. The proposed AC is based on the 2015 US FAA position.
The common issues, questions or suggestions were around the ability of CASA to:
Overall, the majority of respondents supported the proposal.
The principal change is the adoption of the MITRE EPA as the tool that will support the delivery of an aircraft-type specific assessment of the probability of encountering turbulence near a plume rise. Some comments were based on an assumption that CASA has a decision-making role in relation to proposals involving a plume rise. The draft AC was therefore amended to clarify that the role of CASA in the assessment process does not extend to decision making on applications as this is the role for the relevant LUPA.
We have amended the AC to reflect comments provided by respondents and published AC 139.E-02v1.0.
We asked industry to provide feedback on the proposal to add an additional step in the Launceston controlled airspace (CTA) in line with a recommendation made during the 2021 Supplementary Review: Aircraft containment Launceston. The proposal introduces a step from 30 DME to 36 DME with a lower limit of 6,500 feet (FT) above mean sea level (AMSL) in the northern area of Launceston CTA.
We sought feedback to understand industry and community issues, observations or positions about the information contained in the proposal.
The consultation was open from 11 April to 12 May 2022. We received 27 responses via the Consultation Hub. Respondents included pilots of passenger transport operations, sport aviation operators and representatives of user groups. Eleven respondents consented to having their comments published, however only nine made comment.
Overall, responses were generally supportive of the draft proposal however others identified potential restrictions to existing operations resulting from the lowering of the CTA. The feedback validated the issues of high cockpit workload while maintaining airspace containment applicable to the required standards, particularly on descent into Launceston.
There were some comments on matters outside the scope of the proposal including that SIDs, STARs and RNP approaches should be implemented.
Each comment was reviewed and, where actionable, the Office of Airspace Regulation (OAR) undertook additional consultations for clarification purposes. All comments were greatly appreciated. Where consent has been given to publish the response, these have been included.
An airspace change proposal was submitted and approved by the OAR to introduce a new step from 30 DME to 36 DME in Launceston CTA with a lower limit of 7,500 FT AMSL. The change is expected to become effective 15 June 2023.
We asked people to provide feedback on proposed amendments to the Part 42 MOS to include Japan as a recognised country for the purposes of aeronautical product maintenance. We also asked for feedback on a draft Advisory Circular (AC) which provides guidance to Approved Maintenance Organisations (AMOs) seeking approval under the Technical Arrangements on Aviation Maintenance (TA-M) between CASA and JCAB. The consultation has now closed, and a summary of the feedback is provided below.
About this consultation
Prior to the consultation, CASA entered into a TA-M with JCAB limited to maintenance of aeronautical products. The consultation survey asked respondents whether they currently conducted maintenance of Japanese aeronautical products and whether the TA-M with JCAB would have an impact on their business.
Respondents were also asked to provide input on whether the draft AC provided suitable guidance and was fit for purpose.
In total, there were 2 respondents to the consultation. Both requested their submissions remain confidential.
The responses received were from an aircraft operator and approved maintenance organisation, and an approved maintenance organisation.
Summary of feedback
One respondent requested the Note to section 7.2 of the proposed MOS amendment be changed to clearly state that only aeronautical products from Japanese AMOs approved under the TA-M were acceptable. Both respondents provided feedback on the draft AC highlighting areas for improvement including clearly describing the scope of the TA-M in the 'Purpose' section, documentation for acceptance on new products from Japan and the requirements for maintenance record keeping.
Overall, respondents saw the TA-M as positive and generally did not object to the Part 42 MOS amendment. As a result, we will now undertake to make improvements to the proposed Part 42 MOS amendment and the draft AC.
From 8 March to 19 April 2022, we sought feedback on the draft Remotely Piloted Aircraft Systems (RPAS) and Advanced Air Mobility (AAM) Strategic Regulatory Roadmap. The consultation asked industry if our approach to aviation safety regulations for drones and AAM over the next 10 years and beyond had been captured.
This consultation has now closed, and a summary of feedback is provided below.
About this consultation
On 6 May 2021, the Department of Infrastructure, Transport, Regional Development and Communications released the National Emerging Aviation Technologies (NEAT) Policy Statement.
This statement tasked CASA with producing a safety regulatory roadmap RPAS and AAM.
CASA developed the initial roadmap with industry experts between July 2021 and January 2022 by setting up a technical working group under the Aviation Safety Advisory Panel.
We received 109 responses to the consultation:
We thank respondents for their contributions and feedback.
Summary of feedback
Responses were positive and constructive. The feedback we received revealed some common themes, including:
We considered all feedback and will incorporate changes and further clarify content in the final roadmap.
To address the above themes, we intend to report on and review this roadmap regularly. A short section will be included in the final published version of the roadmap outlining this intent.
We also note that the development of new technologies will likely outpace our regulatory change processes. However, we will look to use tools such as regulatory sandboxes and digital enablement to help keep up with the progression of technology in support of future regulatory processes.
The requirements for emergency services operations was considered under various use cases during the development of the roadmap. To make sure consultation feedback is reflected, we have changed the ‘operations’ section to clarify our intention to consider ways for improving approval processes for RPAS and AAM use in emergency service operations.
In response to the feedback regarding the sports and recreational community, extra activities will be added to the final roadmap to better address the needs of this sector.
We have added changes and expansions to the roadmap to better clarify the original meaning and intent. We also added recreational accreditation to the roadmap, noting its deferment from 2022 to 2023.
Next steps
The RPAS and AAM Strategic Regulatory Roadmap will be published by the end of June 2022.
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?".
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:
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:
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:
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.
From to 23 March to 13 April 2022 we sought feedback on the Proposed amendments to CAO 95.55 - Removal of the 45 knot stall speed limit for certain sport and recreation aeroplanes. The consultation asked if the removal of the 45-knot stall speed limit for lightweight aeroplanes would, in relation to the operation of these aeroplanes under Approved Self-administering Aviation Organisation (ASAO) administration, maintain an acceptable level of aviation safety.
About this consultation
CAO 95.55 was amended in December 2021 to support the commencement of the new flight operations regulations. Added to the scope of the CAO were lightweight aeroplanes that can have a maximum take-off weight (MTOW) of 760 kg and a maximum stall speed of 45 knots. Consultation to increase the MTOW to 760 kg recognised there was further consultation to conduct in relation to the 45 knot stall speed. That was the purpose of this consultation.
Sport and recreation aeroplanes that are the subject of CAO 95.55 are grouped into ultralight aeroplanes, light sport aircraft and lightweight aeroplanes. These groupings are based on the aeroplane's maximum take-off weight (MTOW) and the airworthiness standards to which the aeroplane has been designed, including its landing configuration stall speed.
The focus of this consultation was on the safety aspects of removing the stall speed limitation from the definition of lightweight aeroplane.
The aim of the proposed changes to CAO 95.55 is to provide greater flexibility to the sport and recreation flying sector, as it will provide for a wider range of aircraft that can now be utilised, some which had been previously excluded.
In total, there were 134 respondents to the consultation. Responses came from various groups (some respondents said they were associated with more than one group); 87 identified as being sport and recreational aircraft owners or operators, 87 identified as a pilot of sport and recreational aircraft, 65 identified as a Part 61 licenced pilot, 27 identified as being a sport and recreational aviation maintainer or organisation, 2 identified as a maintenance engineer or a CAR 30 approval holder, 15 identified as being a flight school (sport and recreational aircraft - other than gliders), 2 identified as being gliding clubs and 2 identified as being a sport aviation body or as a prospective ASAO. Of the submissions, 95 consented to allow their responses to be published and 39 requested their submissions to be confidential.
Summary of feedback
Most responses (80%) agreed that the proposed change to the light aeroplane definition would maintain an acceptable level of aviation safety in relation to the operation of lightweight aeroplanes under ASAO administration.
For the rest of the respondents, who either disagreed or agreed to the proposed amendments with changes, the common themes across their feedback were:
Theme 1 - Pilots - scope of aircraft, pilot competencies and medical
Feedback in support of the proposal but with changes mentioned the following benefits:
Feedback opposed to the proposal mentioned the following concerns:
Theme 2 - Aircraft - certification and maintenance
Feedback in relation to certification mentioned the following issues:
Theme 3 - Administrative oversight by ASAOs
Feedback in relation to administrative oversight highlighted the issue of pilot competency and the role of the ASAO, with the following mentioned:
CASA's responses
While there were a few responses which disagreed with the proposed amendments, overall they were generally accepted. CASA is satisfied that because the change applies only in relation to lightweight aeroplanes for which a certificate of airworthiness is in force and not to light sport aircraft or ultralight aeroplanes, most of the safety concerns identified by the submissions are acceptable and can be managed within the existing CAO 95.55 framework.
For lightweight aeroplanes, CASA agrees with the responses regarding the need for pilot training to include a broader range of skills. CASA supports greater pilot and organisational responsibility for general competency in relation to the operation of heavier, faster, and more complex aircraft. CASA agrees that, with the expanded availability of appropriate training types, the competency standards for pilots of these aircraft should encompass training not possible in the LSA/ultralight group, including the training of instructors in the demonstration of stalls, spin avoidance, and recovery techniques in lightweight aeroplanes to pilot certificate holders where appropriate for the type.
CASA also observes that this expanded capability is likely to have a flow-on safety benefit to the sector as more pilots will gain exposure to these kinds of manoeuvres and handling considerations. This was identified as one of the benefits of the earlier proposal to raise the MTOW for light weight aeroplanes covered by ASAOs.
CASA is dedicated to assisting ASAOs to build capacity and capability in delivering outcome-based flight training and the further promotion of a safety culture within the recreational sector. Mechanisms to address these issues have been drafted for the proposed Part 103 Manual of Standards.
In relation to aircraft certification, CASA notes that the removal of the 45 knot stall speed limit for lightweight aeroplanes has no impact on the certification status of the aeroplane. Any lightweight aeroplane to which a certification standard that includes a stall speed limit applies, would be constrained by that limit. For example, if an aeroplane is certificated to JAR-VLA/CS-VLA, the 45 knot stall speed would remain as a certification limit for the aeroplane. For lightweight aeroplanes which are not certificated (amateur-built aeroplanes) the stall speed is determined during the aeroplane's flight testing and is dependent on the aeroplanes design and construction.
Next steps
CASA thanks the many highly qualified people and organisations contributing their time and thought to this consultation and acknowledges the feedback as beneficial to the effectiveness of the consultation process.
Based on industry feedback, CASA will proceed with amending CAO 95.55. The amendment will include:
In addition, CASA will investigate the development and promulgation of further educational tools to assist ASAOs further enhance their competency standards, flying training and safety culture.
From 15 February to 1 March 2022 we sought feedback on draft advisory circular (AC) 61-09 - Competency-based training and assessment for flight crew. The consultation asked if the AC contained sufficient explanation for the implementation of competency-based training and assessment (CBTA) and recognition of prior learning (RoPL) in the flight crew training environment.
This consultation has now closed, and a summary of feedback is provided below.
About this consultation
Prior to this consultation, there has been inconsistent awareness and implementation of CBTA systems and the use of RoPL for Australian aviation training. While CBTA training concepts are not new in vocational education and training environments, they may not yet have been completely introduced and accepted in a flight crew training setting. This consultation enquired into the understanding and experience of CBTA and RoPL, asking respondents if the AC provided a sufficient explanation of the concepts, and an opinion of its success if and when implemented.
In total, there were 10 respondents to the consultation. Responses came from various groups (some respondents were part of more than one group); 4 flight training operators, 5 flight instructors, 5 flight examiners, 1 CASA inspector and 1 trainee. Of the submissions, 5 consented to allow their responses to be published and 4 requested their submissions be confidential.
Summary of feedback
The majority of responses agreed with the amount and relevance of the information within the AC, although various responses requested clarification or additional guidance.
Common themes across the feedback were:
There were few responses which disagreed with the AC contents which confirms the information is generally accepted.
CASA accepts CBTA training methods are varied and broad in many environments. CASA recognises the challenges faced by many training organisations to implement or transform their current training methods to a CBTA framework, while keeping up with industry standards.
CASA agrees with the responses regarding some difficulties in interpreting information on the RoPL Candidate Application (Annex A). Minor amendments will be made to improve this sample form. Similarly, amendments will be made to the AC to include information that may have originally been omitted.
CASA is dedicated to assisting training operators with a smooth, simple transition to, and maintenance of CBTA methods.
Next steps
CASA thanks the many highly qualified people and organisations contributing their time and thought to this consultation and acknowledges the feedback as beneficial to the effectiveness of the consultation process.
Relevant stakeholders will be notified of the AC, a Notice to Instructors circulated and a proposal to develop further education and training on CBTA and RoPL.
Based on industry feedback, CASA will proceed with the publishing of AC 61-09 and will undertake the following activities:
Between 15 December 2021 and 21 February 2022, we invited public comment on proposed amendments to the drone rules following a regulatory post-implementation review (PIR) of Part 101 of CASR and its MOS.
The aim of the PIR is to recognise what:
In addition to Part 101 of CASR and its MOS, CASA also administers several legal instruments in the form of:
The proposed amendments seek to streamline these instruments to create a set of regulations and standards, with built-in flexibility, and provide clarity and consistency for industry.
We asked you to comment on:
Supporting documentation and links were:
We received 255 responses to the consultation:
We thank respondents for their contributions and acknowledge their feedback is beneficial.
Responses to the consultation were positive. Most respondents agreed to the proposed changes, or agreed with changes and specified those suggested changes.
We considered all feedback provided and incorporated or further clarified the proposed amendments.
The amendments to the Part 101 MOS and CASA55/20 reflect CASAs intent to continue to streamline these instruments to create a set of regulations and standards, with built-in flexibility, and provide clarity and consistency for industry.
Further amendments to CASR Part 101 and its MOS will be made throughout 2022.
Since May 2021, CASA and Airservices Australia have been conducting an automated airspace authorisation trial in Adelaide, Canberra and Perth.
The trial allows operators who hold a remotely piloted aircraft operator’s certificate (ReOC), or those who operate under one with a remote pilot licence (RePL), to quickly and easily apply to fly within 5.5 km (3NM) of a controlled airport.
Between 10 December 2021 and 28 January 2022, we invited public comment on the trial from those who had taken part, those who would like to take part and those who hadn’t heard of the trial.
We asked 22 questions about the trial and how it has been used and received by operators.
We received 446 responses to the consultation:
Remote pilot licence (RePL): 244
Remote operator's certificate (ReOC): 168
Excluded category RPA (sub-2 kg or 2-25 kg over my own land): 11
Micro RPA (250 g or less) for commercial or business use: 6
‘Other’ or ‘recreational’: 17
We thank respondents for their contributions and acknowledge their feedback is beneficial.
Responses to the survey were positive. The feedback from respondents revealed some common themes including:
While many respondents hadn’t taken part in the trial due to various reasons, there was an overwhelming consensus (98%) that the trial should continue and other airports be added.
From the respondents who had taken part in the trial, 80% said it was fairly easy or easy to apply for authorisation and more than 55% have been able to take on more work.
We considered all feedback provided and have consulted with Airservices Australia.
The automated airspace authorisation trial will be extended for a further 6 months and additional airports are currently being considered.
In addition to the extension, we will consult with developers to address the identified enhancements to the trial platform and drone safety apps to improve the service.
We sought feedback on a proposed frequency split to ease congestion around Ballina, Lismore, Casino and Evans Head aerodromes. The consultation survey was open for 4 weeks, from 1 November to 26 November 2021.
About this consultation
We asked two primary questions:
Respondents were also asked for other suggestions or concerns with the airspace in the vicinity of Ballina, Lismore and Casino aerodromes.
We received 4 responses to the consultation. Three responses were from organisations, with one response from an individual.
Responses validated the issues of frequency congestion and over transmission of radio calls.
Responses were supportive of the proposal to allocate Lismore and Casino aerodromes a different CTAF to Ballina.
This consultation was a follow-up to a previous survey (9 June 2021 – 11 July 2011) that received 84 submissions asking for feedback regarding frequency congestion at Ballina, Lismore and Casino aerodromes.
We have listened to your feedback through this and previous industry consultations.
New radio frequencies are being introduced to ease congestion and increase safety around Ballina, Lismore, Casino and Evans Head aerodromes.
From 16 June 2022 the following Common Traffic Advisory Frequency (CTAF) will apply in these vicinities:
This consultation asked industry to provide feedback on the draft advisory circular (AC) on the commissioning of aerodrome lighting systems.
Commissioning is a final check of a new, upgraded or replaced aerodrome lighting system prior to being made available for operational use at night or in low visibility conditions. It is designed to ensure that the installed system is complete, compliant, and useable.
The revision of this AC was triggered by the revision of Part 139 (Aerodromes) Manual of Standards (MOS) 2019.
The consultation has now closed, and a summary of the feedback is provided below.
A total of 13 responses were received from five qualified flight checkers, 3 aerodrome managers, 3 lighting supplier/consultants and 2 air navigation service provider personnel.
Of the respondents, 12 consented to their submissions being made public.
Summary of feedback
In addition to some relatively minor editorial and typographical matters raised, the main actionable subjects that were identified included:
There were some comments on important matters that could not be addressed within the scope of this AC. The reasons why include:
Respondents who made submissions on these topics are encouraged to raise these issues in appropriate consultative forums ahead of future amendments to the Part 139 MOS.
Each comment was reviewed and, where actionable, incorporated in the text of the AC. All comments were greatly appreciated as the resulting AC is a better product for it.
With respect to the 3 areas of actionable comment, the following summarises the actions taken.
The development of the ground check procedure details and the addition of a checklist template addressed several comments. Firstly, it is a direct response to those who identified a disparity in the guidance provided on flight checks as compared to ground checks and the lack of guidance for documenting ground checks. Other comments addressed in these changes include ensuring technical PAL specifications are met and lighting activation and control by third parties is checked.
The requirements for and approval of qualified flight checkers has been changed considering comments received and changes to flight operations regulations. Firstly, a qualified flight checker no longer needs to be a pilot. The flight safety aspects that appeared in the previous AC are now covered by Part 91 of CASR. As such, the qualified flight checker role is now focused on lighting standards and performance.
In the previous AC, there were some non-runway lights included in the flight check procedures. While it is not a MOS 139 requirement to check these lights, it was decided to retain the guidance material on checking them, if the aerodrome operator wished to have it done. A section on the aerodrome operator establishing a scope for the flight check has been added and the word optional has been added to the relevant sections of the AC and the checklist.
Between 5 November and 18 November 2021, we invited public comment on proposed amendments to registration and accreditation requirements for drones.
According to CASA regulations, drones are defined by their intended use:
A summary of the proposed changes includes:
The consultation asked participants to review the proposed amendments and provide feedback to:
We received 159 responses from individuals or organisations, including:
We thank respondents for their contributions and acknowledge their feedback is beneficial.
Key feedback
Registration of each model aircraft
Proposed amendments to register each model aircraft used for sport or recreation were largely unsupported. While 11% agreed with the proposed amendments, more than 80% of respondents disagreed.
The consultation addressed the likely consequence that each model aircraft or drone used for sport or recreation would be subject to a separate registration levy in the future. At present, there is no levy for registering drones flown for sport or recreation. However, many respondents commented about the potential future cost. The Australian Government has not determined the cost recovery model for any proposed levy. The value of any proposed levy will be released in a Cost Recovery Implementation Statement (CRIS) on the CASA website. It will be open for public consultation before it is finalised, approved and published.
Some respondents were unaware that registration and accreditation requirements would not apply to owners and operators of model aircraft (drones) operating from approved model aircraft sites, managed by model aircraft associations.
Some respondents also asked for more information about the safety outcomes expected to be delivered by drone registration. Drone registration is a deterrent to poor safety behaviour as registered operators displaying unsafe behaviours can be personally identified and contacted. Further safety applications are expected in the future as technology evolves. The registration system will also provide wider public safety benefits for security, policing, privacy, and the environment (noise).
In addition, the requirement for accreditation and ongoing safety education makes sure every operator has demonstrated a sound understanding of the drone safety rules to protect themselves and others when flying their drone.
Clarifying the requirement for persons to be 16 years old to complete the operator accreditation
Comments from respondents indicated widespread confusion of the regulatory history and requirements for young people wishing to fly model aircraft (drones) for sport or recreation under the new scheme.
To summarise:
The proposal sought to amend the part 101 Manual of Standards (MOS) to align with subregulation 101.374E (2) which already explicitly states an applicant is eligible for an accreditation if the applicant is at least 16 years old. This is an administrative change. Despite this, the proposed amendment was supported by fewer than a quarter of respondents. More than two thirds of respondents disagreed with the proposal.
Removing registration requirements for certain aircraft test flights
The majority of respondents were either interested in, or operated, model aircraft. Given the commercial nature of the proposal to remove registration requirements for certain RPA test flights, more than a quarter of respondents declined to express an opinion on this question. About two-thirds of those who did, agreed with the proposal to remove registration requirements for certain RPA flown for test flights. Many respondents identified a potential for this exemption to be exploited. However, we are aware of this potential consequence and are developing mechanisms to prevent this.
Acknowledging that some of the measures are not popular, we will proceed with the proposed amendments as consulted.
We expect model aircraft registration and operator accreditation will open from 1 July 2022 and be required by 30 September 2022.
Accreditation will be free and valid for 3 years.
Registration will be valid for 1 year. The Australian Government has not determined the cost recovery model for any proposed levy. The value of any proposed levy will be released in a Cost Recovery Implementation Statement (CRIS) on the CASA website. It will be open for public consultation before it is finalised, approved and published.
Provisions for people under 16 who wish to fly model aircraft (drones), will include:
For the latest information on model aircraft registration and accreditation requirements, visit www.knowyourdrone.gov.au
We continue to work with model aircraft associations to identify new sites where their members can continue to operate, without the requirement for accreditation or registration.
CASA has mechanisms in place to reduce or eliminate the impact of registration costs in exceptional circumstances. For example, registered charitable organisations or public interest events.
CASA will also conduct a post-implementation review.