nprm 1310ss - maintenance personnel licensing for small ... · maintenance personnel licensing for...

Issued for public consultation by

CASA’s Standards Division

NPRM 1310SS – September 2014

Project Number: SS 05/01

NOTICE OF PROPOSED

RULE MAKING

Maintenance personnel licensing for

small aircraft

MAINTENANCE PERSONNEL LICENSING FOR SMALL AIRCRAFT

NPRM 1310SS

Audience

This Notice of Proposed Rule Making (NPRM) will be of interest to:

owners and registered operators of small aeroplanes and helicopters

Part 145 of Civil Aviation Safety Regulation 1998 (CASR) Approved Maintenance

Organisations (AMO)

Regulation 30 of Civil Aviation Regulation 1988 (CAR) 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

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

products.

Amendment

Amendment of Part 66 of CASR and its Manual of Standards (MOS).

Key dates

The Civil Aviation Safety Authority (CASA) is responsible under the Civil Aviation Act 1988 for,

amongst other functions, developing and promulgating appropriate, clear and concise aviation

safety standards. CASA must, where appropriate, consult with government, commercial,

industrial, consumer and other relevant bodies and organisations in the performance of this

function and the exercise of its powers.

Civil Aviation Act 1988 Subsection 9(1)(c) and Section 16

This NPRM contains proposed amendments to existing regulations that may be pursued as a

future regulatory change.

No action will be taken until all responses and submissions have been considered. 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.

You can help by completing the NPRM Response Form and returning it to CASA by

21 November 2014.


NPRM 1310SS

Foreword

This NPRM is issued by CASA with a view to ensuring that Australian aviation safety

requirements are current and appropriately address safety risks. CASA’s policies require that the

aviation safety regulations must:

be necessary to address known or likely safety risks

provide for the most efficient allocation of Industry and CASA resources

be clear and concise

where appropriate, be aligned with international standards and drafted in outcome

based terms.

The International Civil Aviation Organization's (ICAO) Air Navigation Services Training

Procedures Doc 9868 now includes the concept of competency-based training and modularised

licences as a recommended practice. The small aircraft licence (SAL) proposed by CASA

includes these practices. The proposed expansions of Part 66 of CASR and the Part 66 MOS

legislation would continue to use the Australian competency-based training system to deliver the

training outcomes required for small aircraft licences and endorsements.

The Part 66 licence system already provides for small aircraft licensing but uses exclusions to

provide the required tailored outcomes. During consultation with industry, the very strong

response was that the privileges of any future small aircraft licence needed to be expressed in a

positive sense. The members of the Part 66 small aircraft maintenance licence working group

agreed to a small aircraft licence structure, the detail of which is provided within this NPRM.

The proposed small aircraft licence would be available to new applicants who have completed

the relevant Certificate IV in Aeroskills (Mechatronics Training Course). CASA is not proposing

to reissue existing B1.1, B1.2, B1.3, B1.4 and B2 category licences as small aircraft licences.

Part 66 licences' current small aircraft maintenance certification and Certificate of Release to

Service privileges would continue without any change.

I would like to thank you for your interest in this proposal. I emphasise that no rule changes will

be made until CASA has considered all NPRM responses and submissions received by the

closing date.

Grant Mazowita

Acting Executive Manager

Standards Division

September 2014


NPRM 1310SS

Contents

Reference material 5

1.1 Acronyms and abbreviations 5

1.2 References 6

2 Industry consultation 7

2.1 Previous consultation 7

2.2 Consultation on this NPRM 9

3 Proposed change 10

3.1 Background considerations relevant to the AME small aircraft licence 10

3.2 Key proposal 11

3.3 Legislative drafting instructions 15

4 Implementation and review 18

4.1 Implementation timeframes 18

4.2 Transition and post-implementation reviews 18

4.3 Licence transition requirements 18

Annex A NPRM Response Form A1

Annex B Summary of responses to DP 1215SS B1

Annex C List of elementary maintenance tasks C1

Annex D Proposed additional Appendix to the Part 66 MOS detailing

competencies required for each small licence and licence

endorsement D1

Annex E Samples of small aircraft maintenance licences E1


NPRM 1310SS

Reference material

1.1 Acronyms and abbreviations

The acronyms and abbreviations used in this NPRM are listed in the table below.

Acronym / abbreviation Description

AAAA Aerial Agricultural Association of Australia

ACARS Aircraft Communication Addressing and Reporting System

ADF Automatic Direction Finder

ADS-B Automatic Dependent Surveillance - Broadcast

ALAEA Australian Licenced Aircraft Engineers Association

AME Aircraft Maintenance Engineer

AMO Approved Maintenance Organisation (CASR Part 145)

AMROBA Aviation Maintenance Repair and Overhaul Business Association

ATAE Aviation Training for Aviation Engineers

CAR Civil Aviation Regulations (1988)

CASA Civil Aviation Safety Authority

CASR Civil Aviation Safety Regulations (1998)

CBT Competency-based Training

CRS Certificate of Release to Service

CVR Cockpit Voice Recorder

DME Distance Measuring Equipment

DP Discussion Paper

FDR Flight Data Recorder

FMS Flight Management System

ICAO International Civil Aviation Organization

ILS Instrument Landing System

INS Inertial Navigation System

IRS Inertial Reference System

LAME Licensed Aircraft Maintenance Engineer

LRU Line Replaceable Unit (avionic)

MOS Manual of Standards

MTO Maintenance Training Organisation


NPRM 1310SS

Acronym / abbreviation Description

MTOW Maximum Take Off Weight

NFRM Notice of Final Rule Making

NPRM Notice of Proposed Rule Making

Rad Alt Radio Altimeter

SAL Small Aircraft Licence

Sat Nav Satellite Navigation

Sel Cal Selective Calling (radio system)

SOE Schedule of Experience

SOR Summary of Response

TCAS Terrain Collision Avoidance System

UHF Ultra High Frequency

VHF Very High Frequency

VOR VHF Omnidirectional Range

1.2 References

Regulations

Regulations are available on the ComLaw website http://www.comlaw.gov.au/Home

Part 66 of CASR— Continuing airworthiness – aircraft engineer licences and ratings.

Part 145 of CASR— Continuing airworthiness – Part 145 approved maintenance organisations.

Part 66 Manual of Standards.

Part 145 Manual of Standards.

Standards

International Civil Aviation Organization's (ICAO) Air Navigation Services Training Procedures

Doc 9868.

Consultation document

DP 1215SS—Maintenance Personnel Licensing for Small Aircraft. Available online at http://www.casa.gov.au/scripts/nc.dll?WCMS:STANDARD::pc=PC_101292

NPRM 0804MS—A Proposal to Modernise Rules for the Licensing of Maintenance Personnel for

Small Aircraft.

http://www.comlaw.gov.au/Home

http://www.casa.gov.au/scripts/nc.dll?WCMS:STANDARD::pc=PC_101292


NPRM 1310SS

2 Industry consultation

2.1 Previous consultation

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

personnel for small aircraft

The way in which the Part 66 Aircraft Maintenance Engineer (AME) licensing regime is applied

to the current charter, aerial work and private sectors is being reviewed/revised, in light of the

responses received by CASA as a result of the consultation conducted under NPRM 0804MS.

NPRM 0804MS feedback and more recently ICAO's approval of Amendment 1 to the Air

Navigation Services Training Procedures Doc 9868, resulted in the need for further consultation

and analysis by CASA with industry, before the legislation covering off the form of Part 66

licence outcomes for small aircraft could be provided.

2.1.2 Discussion paper

In December 2012, CASA released Discussion Paper (DP) 1215SS for public comment. In total,

forty two respondents submitted comments to the DP. The following CASA and industry

representatives consented to having their names published:

Industry

Representative Organisation

Jim Charlesworth ACMA, AvServe, MAF

Boyd Park Avionpro Pty Ltd

Alan Jupp PlaneTorque Australia Pty Ltd

John Beveridge Aero Enterprise

Scott Gurner Aircraft Electrical Services Pty Ltd

Timothy Derbyshire Australian Centre for Mission Aviation

Graeme Wheeler Aymstyle Pty Ltd

Graeme Bell Australian Piper Society

Dennis Wisbey Aero Service

Marj Davis-Gillespe Royal Federation of Aero Clubs of Australia

Darren Lydeamore MAF international

Karl Jelinek Tuna City Aviation

Michael Rutledge Heliflite

Stephen Re ALAEA

Robert Nieuwenhoven Sunshine Coast Helicopter Rescue Service

Ken Cannane AMROBA


NPRM 1310SS

Individuals

Roger Pape

Peter Dwyer Private LAME

Laureen Bridges Technical Writer

Paul Cousins

A summary of the responses received and CASA's disposition to those comments is provided at

Annex B of this NPRM.

2.1.3 Small aircraft maintenance licence working group

Given the strong objections raised by industry to the original NPRM 0804MS proposal for a small

aircraft licence, CASA formed a small aircraft maintenance licence working group comprised of

industry and CASA personnel. The working group met on two occasions – 17 December 2013

and 26 February 2014 – with the main outcome of those meetings being an agreed small aircraft

licence structure (see Figure 1). The working group’s members are listed below.

Industry

Representative Organisation

Phil Hurst Aerial Agricultural Association of Australia

Péter Marosszéky Aerospace Developments Pty Ltd

Bruce Baxter Aircraft Electronics Association

Steve Re ALAEA

Ken Cannane AMROBA

Adam Roy ATAE

Laurence Beraldo ATAE

Rod Elliott Hawker Pacific

Brian Cobb Manufacturing Skills Australia

Les Watts Manufacturing Skills Australia Consultant

CASA

Representative Role

Nicholas Ward Project Sponsor representative, CASA Standards Division

Mike Broom Project Leader, CASA Standards Division

Mick McGill Standards Officer, CASA Standards Division

Sam Palaskonis Section Head CASA Maintenance Personnel Licensing

Rupert Symonds Maintenance Specialist (Avionics), Maintenance Personnel Licensing


NPRM 1310SS

2.2 Consultation on this NPRM

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

consultation on the licensing proposal for the small aircraft sector.

CASA registers and reviews each comment and submission received, but will not individually

acknowledge a response unless specifically requested to do so. A summary of the comments

provided in each submission will be published without attribution in a Summary of Responses

(SOR), typically provided as an Annex to the subsequent Notice of Final Rule Making (NFRM). If

consent is provided, the contributor’s name will additionally be published as a List of

Respondents, typically provided in the subsequent NFRM.

At the end of the response period for public comment, all submissions will be analysed,

evaluated and considered. Subsequent to the closing date for comments, an NFRM (including a

SOR) will be prepared and published in conjunction with the making of the Final Rule.


NPRM 1310SS

3 Proposed change

3.1 Background considerations relevant to the AME small aircraft

licence

3.1.1 Existing licensing structure under Part 66 of CASR

Aircraft engineer licences are now issued under Part 66 of CASR 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 Small aircraft licence—policies relevant to design

In developing the proposed small aircraft licence structure (as illustrated in Figure 1 below), the

small aircraft maintenance licence working group sought to design a licence that would:

be structured the same way as the current Part 66 B1 and B2 licence categories

be modular in its structure—progressively building licence privileges up

be consistent with ICAO Annex 1 – Personnel Licensing and the Air Navigation

Services Training Procedures Doc 9868 amendments, which include competency-

based training (CBT) and modularised licences as a recommended practice

be underpinned by CBT—delivered by Part 147 Maintenance Training Organisations

(MTOs)

provide a positive statement of licence privileges rather than the use of

exclusions/limitations

be limited to small aircraft1

be aligned to the previous CAR 31 licence lower group system where applicable with

some merging of groups

be available after two years, and with scope to certify for the pilot maintenance

schedule and small aircraft maintenance activities (similar to the line maintenance

activities available to category A licence holders).

1 Small aircraft are aeroplanes with a Maximum Take-Off Weight (MTOW) of not more than 5,700kg and

single engine helicopters or small aircraft with a turbine (type rated) engine or large aircraft designated by CASA as a small aircraft.


NPRM 1310SS

3.2 Key proposal

CASA proposes to introduce a modularised aircraft maintenance engineer licence structure for

use on small aircraft, like the existing B1 and B2 licence structure of Part 66 of CASR. Typically,

small aircraft are not type rated, so they can have their maintenance certified and the aircraft

CRS issued by the holder of an appropriate category B1 or B2 licence. The new small aircraft

licences would work in a similar way.

For aircraft equipped with a specific turbine engine(s) powerplant, a turbine engine type rating(s)

would be required on the relevant sub category of B1 licence. The addition of a powerplant

endorsement would require a LAME to first gain the relevant underpinning competencies for

turbine engines.

The CBT for the small aircraft licence would be delivered by CASA-approved and oversighted

Part 147 MTOs using the MEA11 Aeroskills Training Package, a nationally endorsed set of

competency standards and qualifications under the Australian Government's Australian

Qualifications Framework - the national policy for regulated qualifications in Australian education

and training.

Upon successful completion of the small aircraft licence training package i.e. Mechatronics, the

Part 147 MTO report of the training outcome could be supplied to CASA with a licence

application for issue of a small aircraft licence.

A licence document can contain more than one licence e.g. the CASA licence document issued

under Part 66 could be annotated with A1, B1.1 and B2 licences as well as a small aircraft

licence. The small aircraft licences could be the first licence annotated on the CASA licence

document or a subsequent annotation.

The proposed small aircraft licence would use a positive statement of licence privileges, rather

than the use of exclusions/limitations. The small aircraft maintenance licence working group's

agreed licence structure (Figure 1), forms the basis of the proposal presented in this NPRM.

3.2.1 Small aircraft licences – scope of licence privilege

Five small aircraft licences are being proposed: B.1.1, B1.2, B1.3, B1.4 and B2; limited to small

aircraft. The form of annotation, by way of example, could be along the lines of: B1.1SAL or

B2SAL, to differentiate the small aircraft licences from the current licences.

The small aircraft licences would not be rated with type rated aircraft types but the B1.1SAL and

B1.3 SAL could be endorsed with turbine engine endorsements. If a B1.1SAL, B1.3SAL or

B2SAL licence holder wanted to provide maintenance certifications or certificates of release to

service for type rated aircraft types – thus requiring the relevant aircraft type rating – then

additional competency training and assessment by a Part 147 MTO would be required. After

gaining the relevant bridging competence the B1.1SAL, B1.3SAL and B2SAL could apply to

CASA for the relevant B1.1, B1.3 or B2 licence.

The scope of licence privilege for each of the B1.1SAL, B1.2SAL, B1.3SAL and B1.4SAL has

been designed around the level of competence that can be delivered in the first two years of

training of the Mechatronics Training Course. Competence for the following is expected:

avionics LRU

single generator electrics; distribution, lighting, batteries, electrical subsystems

metal airframe


NPRM 1310SS

elementary maintenance tasks.

Note: Although the privilege to certify for elementary maintenance is an included privilege for all category B1 licences, this privilege will be represented on the licence as a licence endorsement.

Like the B1 small aircraft licence, the scope of privilege for the category B2 small aircraft licence

relates to the expected competence gained by the two year mark of Mechatronics training. The

B2 small aircraft licence would have scope for:

avionics LRU

instrument systems – indication and data (including data loggers and software updates)

instruments systems within mechanical, powerplant and structural systems

navigation systems

radio systems – Com 1 VHF/UHF/Audio/ELT/cabin intercom data

electrical system (lighting, batteries, electrical subsystems)

electrical system – single generator (generation and distribution).

3.2.2 Elementary maintenance

Elementary maintenance is maintenance similar to the current category A licence line

maintenance tasks and those maintenance tasks that may be carried out by a pilot as prescribed

under Schedule 8 of CAR 1988.

Elementary maintenance is an automatic endorsement on all subcategory B1 small aircraft

licences and an option for the category B2 small aircraft licence. The B2 trainee could apply for

the elementary maintenance endorsement if they had gained the required practical experience

relevant to the competency unit contained in the B2 small aircraft licence ‘elementary

maintenance skill set’.

Elementary maintenance skill sets have been developed for both the B1 and B2 small aircraft

licence pathways to define the units of competency that need to be attained from the

Mechatronics training in order to qualify for the grant by CASA of a B1 or B2 small aircraft

maintenance licence endorsed with certification privileges for completion of elementary

maintenance.

Upon completion of the elementary maintenance skill sets and after gaining 2 years of practical

experience on aircraft, an individual would qualify to apply to CASA for the issue of a category

B1 or B2 small aircraft licence effectively allowing for an initial licence to be obtained after two

years with certification privileges for the elementary maintenance tasks listed in Annex C and

some basic licence scope.

3.2.3 Licence prerequisites

In order to qualify for a small aircraft B1 or B2 licence under the proposed regulation, an

applicant would 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 the relevant Part 147 MTO and their Part 145 AMO as meeting

the applicable competency requirements, including the required underpinning

knowledge modules

has attained two years aviation maintenance experience (inclusive of training)

possesses the necessary English language skills required by CASA for the issue of a

licence under regulation 66.025 of CASR.


NPRM 1310SS

3.2.4 Privileges of the small aircraft B1/B2 licence

The privilege of the Part 66 small aircraft licence would allow the holder to certify for

maintenance and/or issue a Certificate of Release to Service (CRS) for small aircraft covered by

the scope of the licence held. The Part 66 licence would allow the holder of such licences to

work independently, or within a Part 145 or regulation 30 of CAR 1988 maintenance

organisation.

When used to provide maintenance for aircraft covered by CAR 1988, the privilege would be to

carry out maintenance on a small class A and B aircraft and to provide for certifications of

completion of that maintenance. A sample of each Part 66 small aircraft licence and some

possible endorsements for each licence category (as illustrated in Figure 1 below) is provided by

Annex E.

3.2.5 Benefits and impact of changes

The proposed licence structure would provide maximum small aircraft coverage within the initial

licence scope aligned to the Certificate IV in Aeroskills (Mechatronics) qualification. Under the

proposed changes, apprentices and employers would benefit from the increased flexibility in

training this proposed licence structure would provide, allowing for a wide range of training

options that would cover the varying maintenance requirements of the employer, while further

developing the knowledge and skills basis of apprentices.

The training received by apprentices would be relevant to the industry sector in which they are

employed, allowing better targeting of skills development. The availability of the pilot

maintenance schedule privileges after approximately two years would benefit employers of

eligible employees. Other benefits and outcomes of the proposed small aircraft licences and

endorsements would be:

an appropriate balance between complexity and flexibility of the licence

the possibility commence use of the initial small aircraft licence at the two year mark

competencies that are delivered in the four year Mechatronics Aeroskills training

package – thus keeping within the government's current four year funding model

removal of the need for the five year duration for the "Diploma of Aeroskills" qualification

training outcomes for the B1.2, B1.4 and B2 licences – thus mitigating industry's

concern that employers have to provide a year’s funding (to cover the extra year of

training - not currently funded by government - required by Diploma level training

compared to Certificate IV training)

a clear delineation between mechanical and avionics licence categories and electrical

privileges in both B1 and B2 licence categories

small aircraft licences aligned with the current Part 66 licence structure for the B1.1,

B1.2, B1.3, B1.4 and B2 licence categories

merging of aircraft systems with close affiliations into single endorsements where the

same skill sets can be applied to each of the aircraft systems e.g. radio systems -

primary and secondary radar: ADS-B, Rad Alt, DME, Transponder and TCAS is a single

endorsement

providing certification privileges for those aircraft systems common to the majority of

aircraft that would be worked on in an aircraft maintenance organisation e.g. avionics

line replaceable units (LRU) and electrical system (lighting, batteries, subsystems)


NPRM 1310SS

B1SAL licences providing certification privileges for elementary maintenance – covering

pilot maintenance and other maintenance tasks (similar to category A licence line

maintenance tasks) and an option to gain certification privileges for elementary

maintenance on the B2SAL licence

optional endorsements for particular aircraft systems that may be difficult to obtain if an

aircraft fitted with those systems is not available to demonstrate competence e.g.

electrical system multi generator systems

assessment of competency by the Part 147 MTO assessor and Part 145 AMO provides

the initial permission to carry out maintenance, as recorded on the relevant CASA

application for a small aircraft licence and/or endorsement

licence and endorsement issue can occur upon successful completion of training for the

relevant competencies

training outcomes provided under the Australian Qualification Framework CBT regime

an ICAO compliant licence.


NPRM 1310SS

Figure 1 - The small aircraft maintenance licence working group’s proposed licence structure –

licences and endorsements

3.3 Legislative drafting instructions

3.3.1 Part 66 of CASR

This section contains indicative terminology that may not be utilised in the final form of the

legislation. After consideration of feedback received in response to this NPRM, CASA intends to

provide legislative drafting instructions to give effect to the following requirements of Part 66 of

CASR:


NPRM 1310SS

a requirement for a small aircraft licence is a subcategory B1.1, B1.2, B1.3, B1.4 or

category B2 licence limited to small aircraft

that a small aircraft licence is an aircraft engineer licence

the use of exclusions for expression of privilege and removal of exclusions for addition

of privileges, will not be utilised

aircraft type training also relates to a type rated engine for a small aircraft licence

the Part 66 MOS may specify (in addition to the existing Part 66 MOS specifications):

small aircraft licence endorsements

aircraft systems and subsets of systems that are included in the scope of a small

aircraft licence or endorsement

the privileges that a LAME whose licence is endorsed with a small aircraft

endorsement may exercise

the elementary maintenance tasks that are included in the scope of the elementary

maintenance endorsement for a small aircraft licence

type rated engine endorsements

the additional competencies (knowledge and practical) required to remove a small

aircraft limitation from a subcategory B1.1, B1.3 or B2 licence

the required units of competency for endorsements on a small aircraft licence

the sequence of training required to receive a small aircraft licence and

endorsements

that a specified small aircraft licence endorsement is one for which a Part 145

organisation may authorise a competent small aircraft licence holder to provide

maintenance certifications for.

3.3.2 Part 66 MOS

CASA intends to provide legislative drafting instructions to give effect to the following

requirements of the Part 66 MOS. As the Part 66 MOS would include mention of the small

aircraft licence and its endorsements wherever required, the following sections of the MOS

would require rework:

66.A.1 – Aircraft engineer licence

66.A.20 – Privileges (relating to small aircraft endorsements) and a related listing of

elementary maintenance – see Annex C

66.A.25 – Basic knowledge and competency requirements (for small aircraft licences)

66.A.30 – Basic practical experience requirements (for small aircraft licences)

66.A.45 – Type/task training and ratings – to include the small aircraft turbine engine

endorsement theory training requirements

66.A.50 – Aircraft type practical training – to include the small aircraft turbine engine

endorsement training requirements

66.A.55 – On the Job aircraft type training – to include the small aircraft turbine engine

endorsement training requirements

66.A.70 – Limitations – to explain what the limitation ‘limited to small aircraft’ means for

a subcategory B1.1 or B1.3 or category B2 licences

Appendices

Appendix I – CASA knowledge syllabus


NPRM 1310SS

Appendix III – Type training and assessment standards

New Appendix that lists the elementary maintenance tasks the holder of a small

aircraft licence endorsed for elementary maintenance may certify for

Note: the list of elementary maintenance tasks are detailed in Annex C

New Appendix that details the units of competency required for a category or

subcategory of small aircraft licence

Note: the list of competencies that would lead to the issue of a small aircraft licence

or endorsement are detailed in Annex D.

3.3.3 Consequential amendments to Parts 145 and 147 of CASR and MOS

CASA intends to provide consequential legislative drafting instructions to give effect to the

following requirements of Parts 145 and 147 of CASR, and their respective MOS Parts.

Introduction of a new scheme that would lead to a permission for an individual to provide

maintenance certifications upon being assessed by the Part 145 AMO and 147 MTO as

competent for the pre-requisite competencies for a particular small aircraft licence or

endorsement. The AMO and MTO assessors would sign off on the competencies on the same

form the licence applicant would submit to CASA when seeking the issue of the small aircraft

licence or endorsement.

Like the permissible maintenance scheme, the duration of the permission granted to an

individual by the AMO would be six months, during which time the applicant could expect to

have been issued their licence or endorsement by CASA.


NPRM 1310SS

4 Implementation and review

4.1 Implementation timeframes

The Mechatronics competency training package, sequence of training delivery and the related

licence flexibility are subject to further deliberations. CASA and the small aircraft maintenance

licence working group (as per paragraph 2.1.3) may reform to discuss any further finessing of

the small aircraft maintenance licence proposals. Readers are invited to provide their

submissions either directly to CASA or via their representatives on the working group.

CASA will take feedback from this NPRM to determine whether the proposal described remains

the preferred industry solution for a Part 66 licence for small aircraft. Following consideration of

responses to this NPRM, CASA will seek amendment to Part 66 and the relevant areas of Parts

145 and 147 of CASR and the Part 66 MOS.

A preliminary date for the proposed rulemaking is December 2014, with the regulations

becoming effective on 26 June 2015. These dates may change depending on when the draft

rules are signed, registered and set to commence.

4.2 Transition and post-implementation reviews

CASA will monitor and review the new rules on an ongoing basis during the transition phase.

Thereafter, following the commencement of the rules, CASA will conduct post-implementation

monitoring and reviews during the implementation of the small aircraft licences.

4.3 Licence transition requirements

This proposed small aircraft licensing system was designed to deliver the training outcomes

required that are applicable to small aircraft, with the privileges expressed in a positive sense on

the licence without the use of exclusions.

The Part 66 licence system already provides for small aircraft licensing but uses exclusions to

provide the required tailored outcomes. CASA will not be transitioning existing Part 66 licences

into the new small aircraft licence system.

CASA will grant small aircraft licences and endorsements upon completion of the relevant

competencies of the Mechatronics course delivered within the Aeroskills Training Package

provided by a CASR Part 147 MTO.

CASA will seek to provide a regulation that allows CASA to continue to accept licence

applications for a small aircraft licence where a person qualifies for what were termed lower

group ratings under the previous CAR 31 CASA basics examinations and schedule of

experience (SOE) requirements for small aircraft for a period of a further 4 years, allowing for the

continued use of the CASA basics to gain a small aircraft licence until June 2019.

Additional information is available from:

Michael McGill

CASR Part 66 Project Leader

Post (no stamp required in Australia)

Reply Paid 2005

Airworthiness and Engineering Standards Branch

Civil Aviation Safety Authority

Canberra ACT 2601, Australia

Email

[email protected]

Telephone

Australia 02 6217 1423 or

131 757 (for the cost of a local call)

International +61 2 6217 1423

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