This workshop allowed operators to discuss some of the complexities they have experienced with the regulations including awareness of available exemptions and approvals. For example, there is an exemption available that alleviates some of the recency issues operators raised with having to meet the night recency requirements in all their aeroplanes.
What can operators do?
Industry can subscribe to the relevant CASA communications, to receive timely notification and awareness of exemptions and the guidance material relating to them.
What is CASA doing or has already delivered?
We are considering the development of a plain English guide outlining the approvals and exemptions available to specific sectors. For example, this could take the form of a summary of relevant exemptions and approvals presented in plain English at the beginning of the applicable Advisory Circular.
We have recently updated its policy regarding the removal of seats exceeding the Maximum Operational Passenger Seating Configuration (MOPSC). Instead of requiring physical removal, operators may now block off these extra seats or clearly mark them with signage. This could include notices such as 'do not sit here' or an equivalent when you operate the aircraft with a MOPSC lower than the total number of installed seats.
This change enables operators using aircraft that exceed the Part 135 seat limit (and would otherwise require compliance with Part 121) to reduce the MOPSC and operate under Part 135 when necessary for operational flexibility. Operators would need to document procedures for each operational context in their exposition.