maintenance personnel licensing for small aircraft · easa b3 scope does not meet the requirements...

Issued as part of the process of public consultation by

CASA’s Standards Branch

Document DP 1215SS – December 2012

PROJECT NUMBER: SS 05/01

DISCUSSION PAPER

Maintenance Personnel Licensing

for Small Aircraft

Part 66 Licensing of Maintenance Personnel for Small Aircraft

This DP will be of interest to:

Owners and registered operators of small aeroplanes and helicopters;

Part 145 of CASR 1998 approved maintenance organisations;

Regulation 30 of CAR 1988 certificate of approval for aircraft maintenance and Transport

Category aircraft certificates or approval holders;

Licensed Aircraft Maintenance Engineers (LAME) and others involved in aircraft

maintenance; and

Personnel involved in design, certification and production of aircraft and aeronautical

products.

Discussion Paper Maintenance Personnel

Licensing for Small Aircraft

Document DP 1215SS Page 1 of 14

Foreword

Background

The maintenance suite of Civil Aviation Safety Regulations 1998 (CASR) (Parts 42, 66, 145 and

147) came into effect on 27 June 2011. The application of these regulations to all sectors of

aviation operations is a process that has been sequenced to occur over several years. The current

applicability situation is that Part 42 (covering continuing airworthiness requirements) and Part

145 of CASR 1988 (covering approved maintenance organisations) apply only to the regular

public transport (RPT) sector. CASR Parts 66 and 147 are in place and being utilised with all

LAME licences now issued under Part 66 of CASR 1998 and the majority of LAME training now

provided under Part 147 of CASR 1998.

The current Civil Aviation Regulations 1988 (CAR 1988) maintenance regulations, covering

continuing airworthiness and maintenance requirements for the current charter, aerial work and

private sectors are being revised. The way in which the Part 66 AME licensing regime will be

applied to these sectors also needs to be reviewed/revised, in light of the responses received by

CASA as a result of the consultation conducted under Notice of Proposed Rule Making (NPRM)

0804MS - A proposal to modernise rules for the licensing of maintenance personnel for small

aircraft.

Context of this Discussion Paper

The new system for LAME licensing introduced by Part 66 of CASR 1998 commenced on 27

June 2011. The system is based on the A, B1, B2 and C categories and type ratings used by the

European Aviation Safety Agency (EASA).

NPRM 0804MS feedback and more recently the International Civil Aviation Organization

(ICAO) Approval of Amendment 1 to the Air Navigation Services Training Procedures Doc

9868 has resulted in the need for further consultation and analysis by the Civil Aviation Safety

Authority (CASA) with industry, before the legislation covering off the form of Part 66 licence

outcomes for small aircraft can be provided. ICAO has now issued the amended Air Navigation

Services Training Procedures Doc 9868 and it includes the concept of competency based training

and modularised licences as a recommended practice. In light of the feedback and changes to the

ICAO Training Document and Licensing Recommended Practice, CASA has decided to re-

commence consultation on the Part 66 licence outcome that may be provided for small aircraft

sectors. This Discussion Paper (DP) builds on the discussion initiated by NPRM 0804MS and the

introduction of Part 66 of CASR 1998 on 27 June 2011.

Discussion Paper Maintenance Programs

for Non RPT Aircraft


How you can help us

CASA is responsible under the Civil Aviation Act 1988, amongst other functions, for developing

and promulgating appropriate, clear and concise aviation safety standards. In the performance of

this function and the exercise of its powers, CASA must, where appropriate, consult with

government, commercial, industrial, consumer and other relevant bodies and organisations.

Paragraph 9(1)(c) and Section 16 of the Civil Aviation Act 1988

This DP presents information for wide public and industry consideration. To ensure clear and

relevant safety standards, we need the benefit of your knowledge as an aviator, aviation consumer

and/or provider of related products and services by completing the DP Response Form and

returning it to CASA by 1 March 2013.

I would like to thank you in advance for taking time to consider and respond to this DP.

Peter Boyd

Executive Manager

Standards Division

5 December 2012




Contents

Acronyms ....................................................................................................................... 4

Discussion ...................................................................................................................... 5

1. Objective .................................................................................................................. 5

2. The Consultation Process ...................................................................................... 5

What CASA does with your comments ..................................................................... 5

3. Considerations relevant to the small aircraft LAME Licence .............................. 5

3.1 Part 66 of CASR 1998 Licensing Structure .................................................. 5

3.2 The Small Aircraft LAME licence .................................................................. 6

3.3 CASA decision to delay introduction of the B3/B4 licence ............................ 6

3.4 Small aircraft licence .................................................................................... 7

4. Benefits of the small aircraft Licence ................................................................. 10

5. Licence prerequisites ........................................................................................... 11

6. Privileges of a B1/B2 licence ............................................................................... 11

7. Proposal ................................................................................................................ 12

8. Benefits and impact of changes .......................................................................... 12

9. The Next Steps ...................................................................................................... 12

DP Response Form ...................................................................................................... 13

YOU CAN RESPOND ONLINE OR BY FAX, POST OR E-MAIL

An online response form is offered as an alternative to the printed form in this DP and is the preferred method of submitting comments to CASA. If you are connected to the Internet, access the online form by clicking on this website address: casa.gov.au/newrules/ors, or if you are working from a paper copy of this document, type that address into your web browser.

Annex A – Consolidated Summary of Comments/Responses received to NPRM 0804MS – A Proposal to Modernise Rules for the Licensing of Maintenance Personnel for Small Aircraft ...................................................................................... A1

http://casa.gov.au/SCRIPTS/NC.DLL?WCMS:STANDARD::pc=PC_100540




Acronyms

CASA Civil Aviation Safety Authority

CAR Civil Aviation Regulations 1988

CASR Civil Aviation Safety Regulations 1998

DP Discussion Paper

EASA European Aviation Safety Agency

FAA Federal Aviation Administration (USA)

FAR Federal Aviation Regulation (USA)

ICAO International Civil Aviation Organization

LAME Licensed Aircraft Maintenance Engineer

MTO Maintenance Training Organisation

NPA Notices of Proposed Amendments (EASA)

NFRM Notice of Final Rulemaking

NPRM Notice of Proposed Rule Making

PTO Passenger Transport Operations

RPT Regular Public Transport

SARPs Standards and Recommended Practices of the ICAO Annexes

SCC Standards Consultative Committee

STC Supplemental Type Certificate




Discussion

1. Objective

1.1 The objective of this DP is to seek feedback from the aviation community in deciding the

structure of a modularised Part 66 licence for certification of small aircraft maintenance and the

training requirements (knowledge, skills and related competencies) that underpin this structure.

2. The Consultation Process

2.1 Publication of this DP constitutes a continuation of the normal process of public/industry

consultation on the licensing proposal for the small aircraft sectors. NPRM 0804MS and the

responses to it, would normally have led directly to issue of a Notice of Final Rulemaking

(NFRM). In light of the changes to the ICAO Standards and Recommended Practices (SARPs)

and the extensive feedback received from the publication of NPRM 0804MS, CASA has decided

to re-consider the previous work that led to the issue of NPRM 0804MS and the responses

received to it. A summary of the responses received to NPRM 0804MS and taken into

consideration is provided at Annex A of this DP.

2.2 Once responses to this DP have been received, they will be consolidated and considered

by CASA. The outcome expected from these processes can be expected to be the issue of a

NPRM of the amendments required to Part 66 of CASR 1998 and the Part 66 Manual of

Standards (MOS) to introduce a modular small aircraft licence structure.

2.3 If an NPRM is developed and CASA decides to make a rule change, the responses to the

NPRM will be published with the proposed final rule in the form of a NFRM concurrent with the

making of the final rule.

What CASA does with your comments

2.4 CASA registers each comment and submission received but will not individually

acknowledge a response unless specifically requested. The name of every contributor and a

summary of their comments will be published with any subsequent consultation documents

(including an NPRM if issued) unless a respondent specifically asks CASA not to.

3. Considerations relevant to the small aircraft LAME

Licence

3.1 Part 66 of CASR 1998 Licensing Structure

3.1.1 All Aircraft Engineer Licences are now issued under Part 66 of CASR 1998 with one or

more of the following categories and subcategories:

Category A:

° A1 – turbine engined aeroplanes

° A2 – piston engined aeroplanes

° A3 – turbine engined helicopters

° A4 – piston engined helicopters




Category B1:

° B1.1 – turbine engined aeroplanes

° B1.2 – piston engined aeroplanes

° B1.3 – turbine engined helicopter

° B1.4 – piston engined helicopters

Category B2 - aircraft (aeroplanes and helicopters)

Category C - large aircraft in a base maintenance activity

3.1.2 Part 66 of CASR 1998 licences were issued with exclusions in order to match the new

licences to the limits of previous licence scopes provided under regulation 31 of CAR 1988. In

order to minimise further change, the concept now proposed would be to use licences issued as a

subset of the B1/B2 category and sub category licence structure now in place in Australia and as

presented directly above.

3.2 The Small Aircraft LAME licence

3.2.1 A joint CASA/Industry team was formed in 2007 to produce the concept for the small

aircraft LAME licence. The team commenced their work by compiling an industry priorities list

to steer the workings of the team. In 2009 the culmination of the joint CASA/Industry’s small

aircraft work was the issue of NPRM 0804MS and a recommended structure for a small aircraft

maintenance licence. The NPRM contained three options for small aircraft licencing, each of

which was modular and allowed the proposed licence privilege to be built up over time. The

options considered are briefly described below.

Option 1 was the preferred option and provided for small aircraft licences that delineated

between the primarily mechanical (B3) and primarily avionic (B4) categories. There were

to be subcategories and extension ratings for each licence. Column 1 of Table 1 below

contains detail of the Option 1 licences and ratings.

Option 2 provided for a single licence category combined with a mixture of subcategories

and extensions. There was to be no distinction between mechanical and avionics licence

holders.

Option 3 was also comprised of B3 and B4 licences but provided for more crossover of

mechanical and avionics subcategories and extensions

3.2.2 The deliberations and decisions of that team and the licence options of NPRM 0804MS

form the background thinking of this DP.

3.3 CASA decision to delay introduction of the B3/B4 licence

3.3.1 Before finalising the small aircraft licence proposals CASA decided to review EASA’s

small aircraft proposals and transition of Regulation 31 of CAR 1988 licences into Part 66 of the

CASR 1998 licences. The issue of the Commission Regulation (EU) No 1149/2011 – on the 21

October 2011, allowed CASA to review the final form of the EASA B3 licence.




3.3.2 The EASA B3 licence is limited in its aircraft application, i.e. licence scope pertains to:

“Applicable to Piston-engine non-pressurized aeroplanes of 2000 Kg MTOM and below”. The

EASA B3 scope does not meet the requirements determined as necessary for a small aircraft

licence previously by the joint CASA/Industry team and will not be adopted for small aircraft

licensing in Australia.

3.4 Small aircraft licence

3.4.1 Having introduced the Part 66 licencing system in 2011 CASA was in a position to review

that system against the NPRM 0804MS proposals and response comments. ICAO had also issued

the amended Air Navigation Services Training Procedures Doc 9868, which included

competency based training and modularised licences as a recommended practice, which meant

CASA could include provision of modular licences in the review.

3.4.2 The review showed that Option 1 from NPRM0804, the preferred (by CASA and

industry) licence concept, can be achieved by a basic Part 66 licence that can be built up with

extra modules gained as the licence holder attends further competency based training and the

related competence is achieved over time.

3.4.3 Table 1 below provides detail of a small aircraft LAME licence (Option One) expressed in

subcategory/category B1 and B2 format. Column two of the table provides an explanation of the

licence privileges that would be granted by the licence endorsement listed in column three of the

table.

Table 1 - The NPRM 0804MS preference for the small aircraft LAME licence (Option One) expressed in subcategory/category B1 and B2 format.

B3 Licence Proposed in

NPRM 0804MS

Licence Scope Proposed by this Discussion Paper

Proposed Part 66 Licence Descriptor

Basic Aeroplane Single-engine piston powered aeroplane with fixed pitch propeller, fixed undercarriage and simple electrical and avionics systems. This subcategory provides licence coverage for 80% of the Australian small aircraft fleet.

A licence in this subcategory confers Certificate of Release to Service (CRS) privileges for the mechanical, structural and powerplant systems with limited CRS privileges in respect of electrical and avionics systems.

B1.2 Basic Aeroplane licence.




B3 Licence Proposed in

NPRM 0804MS

Licence Scope Proposed by this Discussion Paper

Proposed Part 66 Licence Descriptor

Advanced Aeroplane

Aeroplanes with retractable undercarriage, variable pitch propeller(s) that may be piston powered or turbopropeller powered, with simple or complex electrical and avionics systems.

A licence in this subcategory confers CRS privileges for the mechanical, structural and powerplant systems with limited CRS privileges in respect of electrical and avionics systems.

B1.1 & B1.2 Advanced aeroplane licence.

An engine type rating may be required if the aircraft is turbine powered and listed in AC 66-2.

Basic Helicopter Single-engine piston powered helicopter with non-boosted rotor controls and simple electrical and avionics systems.

A licence in this subcategory confers CRS privileges for mechanical, structural and powerplant systems with limited CRS privileges in respect of electrical and avionics systems.

B1.4 Basic Helicopter licence.

Advanced Helicopter

A helicopter with powered rotor controls which may be piston or turbo shaft powered, with simple or complex electrical and avionics systems.

A licence in this subcategory confers CRS privileges for the mechanical, structural and powerplant systems with limited CRS privileges in respect of electrical and avionics systems.

B1.3; B1.4 Advanced Helicopter licence.

An engine type rating may be required if the aircraft is turbine powered.

Piston engine Includes CRS for all piston engine types fitted to small aircraft.

B1.2; B1.4 Piston engine licence

Turbine engine All non type rated turbine engines and type rated turbine engines (subject to training and endorsement) fitted to small aircraft. A licence in this subcategory confers CRS privileges for all non type rated turbine engines fitted to small aircraft.

B1.1; B1.3 Turbine engine licence

An engine type rating may be required if the aircraft is turbine powered.




B1 Licence – Module/Rating Options

Licence option Description Module/Rating

Hydraulics Hydraulic Systems

Retractable undercarriage

Retractable undercarriage systems

Wood/Fabric Wood and fabric

Composite Repairs Composite Repairs

Environmental Aircon/Pressurisation/Oxygen Environmental Systems

Pneumatics Pneumatic systems

Structures Structural systems

Propellers and Governors

Propellers and governing systems

Supercharging Supercharging systems

FADEC FADEC systems

B2 Licence Options

Advanced NAV/COM, INSTR

A licence in this subcategory confers CRS privileges for HF, Integrated Audio, GPS, NAV, IFE, FDR, CVR, ADC, Remote Compass, Advanced INSTR; and basic avionics systems.

B2 Advanced Navigation, Communication, instrument licence

Advanced Electrical

Multi-source DC, and AC systems. A licence in this subcategory confers CRS privileges for:

AC and multi-source DC electrical power generation and distribution systems, and

simple and single source electrical generation and distribution systems.

B2 Advanced Electrical licence




B2 Module/Rating Options

Limited Electrical and Avionics privileges

A licence which includes this phrase confers the following additional CRS privileges:

single source DC electrical generating and distribution systems,

electrical and instrument aspects of mechanical systems,

pressure and suction based flight instruments,

avionics LRU not requiring specialist testing equipment,

repairs to avionics interwiring and antenna leads, and

replacement of damaged or defective antennae.

Limited Electrical and avionics systems.

Flight guidance A licence in this subcategory confers CRS privileges for EFIS and FMS.

Flight guidance Systems.

Pulse A licence in this subcategory confers CRS privileges for all airborne radar systems including:

Radar,

Doppler,

Radalt,

DME,

Traffic,

TCAS, and

TAWS.

Navigation systems (pulse radio systems).

Schedule 8 This is a generic title covering pilot maintenance privileges which would be available to after approximately 2 years. A licence in this subcategory would confer CRS privileges for those maintenance activities listed by CASA in a schedule of approved pilot maintenance activities.

Pilot Maintenance Schedule.

4. Benefits of the small aircraft Licence

4.1 The joint CASA/Industry small aircraft working group described the principal benefits of

the licence outcome described in Section 3.4 above as providing:

a clear delineation between mechanical and avionics categories;

an appropriate balance between complexity and flexibility;

a small aircraft licences aligned with the structure of B1 and B2 licence categories;

simplified applicability and endorsement rules for licence extensions; and

analogous to current industry employment practice.




4.2 The original proposal in NPRM 0804MS has now been even more aligned with the B1

and B2 categories of Part 66. Propellers, Wood Structures and Fabric Coverings were already

optional competencies for the B1 category licence and this concept could be even further

expanded by the Option 1 proposals of this DP.

4.3 The use of conditions/limitations on the Part 66 licences may allow even greater

flexibility in the exact makeup of the module/ratings for the B1 and B2 i.e. more module/rating

options than those contemplated by the joint CASA/Industry small aircraft working group

modules. Such opportunities for additional module/ratings/flexibility would be explored at a

technical level when the Aeroskills Training Package is adjusted to provide for the modular B1

and B2 licences for small aircraft.

4.4 The new modular licence for small aircraft will be ICAO compliant and would include

category A privileges and competencies for the pilot maintenance schedule at the two year mark.

5. Licence prerequisites

5.1 Licence prerequisites for the basic licence ratings for B1 or B2 would remain as per the

proposal in NPRM 0804MS - A proposal to modernise rules for the licensing of maintenance

personnel for small aircraft. In order to qualify for an initial B1 or B2 licence, an applicant will

be required to demonstrate that he or she:

is at least 18 years of age at the time of making the application;

has been assessed by a CASR Part 147 Maintenance Training Organisation as meeting the

applicable competency requirements including the required underpinning knowledge

modules;

has attained 3 years aviation maintenance experience (inclusive of training); and

possesses the necessary English language skills.

5.2 For the category A privilege for the pilot maintenance schedule, all of the above would be

relevant except that the candidate would need to have attained two years aviation maintenance

experience (inclusive of training).

6. Privileges of a B1/B2 licence

6.1 The privilege of a Part 66 licence with exclusions is certifying for maintenance and/or

issuing a CRS for small aircraft within the licence scope held.

6.2 Small aircraft are aeroplanes with a Maximum Take Off Weight of 5700 kg or less; and

single engine helicopters.

6.3 Turbine engines require type ratings on the relevant sub category of B1 licence. The

addition of a powerplant type rating requires the LAME to first gain the relevant underpinning

competencies for turbine engines.

6.4 Typically, small aircraft are not type rated and can have their systems maintenance

certified and the aircraft CRS issued by the holder of an appropriate Category B1 or B2 licence.




7. Proposal

7.1 The key proposal is the introduction of modularised maintenance certification licence

structure for use on small aircraft using the existing A, B1 and B2 licence structure as per the

existing Part 66 of CASR 1998.

7.2 The Part 66 licence would allow the holder of such licences to work independently, or

within a Part 145 of CASR 1998 or regulation 30 of CAR 1988 maintenance organisation.

8. Benefits and impact of changes

8.1 The licence structure will provide maximum industry sector coverage within the initial

licence scope.

8.2 Apprentices will benefit from increased flexibility allowing a wide range of training

options.

8.3 Training will be relevant to the industry sector in which the apprentice is employed

allowing better targeting of skills development.

8.4 Employers will benefit from the licence structure flexibility which allows an initial

licence to be obtained after two years.

8.5 The availability of pilot maintenance schedule privileges after approximately two years

will benefit employers of eligible employees.

8.6 Licence issue will occur upon successful completion of training for the relevant modular

licence. This will benefit apprentices and employers as it works with the Australian Qualification

Framework competency based training regime.

9. The Next Steps

9.1 CASA will take feedback from this DP to determine whether the proposal described in

this DP remains the preferred industry solution for a Part 66 of CASR 1998 licence for small

aircraft.




DP Response Form

Maintenance Personnel Licensing for Small Aircraft

Please complete your response by 1 March 2013 and return it by one of the following means:

Online (preferred method*) casa.gov.au/newrules/ors

Fax 1800 653 897 (free call in Australia)

Post (no stamp required in Australia) CASA’s Standards Development Branch

Reply Paid 2005, Canberra ACT 2601, Australia

E-mail (use the response format in this DP)

[email protected]

* A web-based online response form is offered as an alternative to the printed form in this DP. Online submission is the preferred method of sending your comments to CASA. If you are connected to the Internet, type casa.gov.au/newrules/ors into your web browser and follow the links for this DP.

Your Details

Your name: ______________________________________ ARN* (if known): __________________

Organisation: ____________________________________ ARN* (if known): __________________

* Aviation Reference Number, usually your CASA-issued licence or certificate number

Address: ____________________________________________________________________________

_____________________________________________________________________________

Your telephone number (optional): …………….……….… (to enable the Project Manager to contact you as necessary)

Do you consent to have your name published as a respondent to this DP? YES [ ] NO [ ]

Signed: ………………………………………….. Date: ………………….…

How are you responding to this questionnaire/proposal, i.e. whose views are represented in your response?

Private

individual

Aviation Industry

body/association

Staff

association/union

Government

agency/authority/

department/council

Aviation

business

owner/service

provider

Other

Please advise your main involvement in aviation:

Passenger/

public consumer

of aviation

services

Air crew for

passenger-carrying

activities

Air crew for

non-passenger-

carrying

activities

Ground support

for passenger-

carrying activities

Ground support

for non-passenger

carrying activities

Other (specify

below*, e.g.

parachutist)

* Details: ____________________________________________________________________________

Are you satisfied with CASA’s consultation on this issue?

Very satisfied Satisfied No opinion Dissatisfied Very Dissatisfied

http://rrp.casa.gov.au/respond




General and Specific Comments

CASA invites you to advise your comments on the subject matter of this DP by completing the

following section or directly via the CASA website.

CASA is proposing to deliver the preferred small aircraft LAME licence option of the NPRM

0804MS A proposal to modernise rules for the licensing of maintenance personnel for small

aircraft; using the existing A, B1 and B2 licence structure as per the existing Part 66 of CASR

1998. Please provide your comment on the proposal.

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Thank you

Your response ensures balanced consideration by CASA of the interests of the aviation

community and consumers.

Additional information is available from:

Mike Broom Project Leader

Post (no stamp required) Reply Paid 2005

Standards Development Branch

Civil Aviation Safety Authority

Canberra ACT 2601, Australia

E-mail [email protected]

Telephone 02 6217 1107 or 131 757 (for the cost of a local call)

International +612 6217 1107

Fax 02 6217 1691

International +612 6217 1691

maintenance personnel licensing for small aircraft · easa b3 scope does not meet the requirements...

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