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Project FS 06/01 - Provide for student pilots to fly solo without holding a student pilot licence

Topic code: 
Flight Crew licensing
Project status: 


Student pilots under training are not permitted under the Civil Aviation Regulations to fly solo without holding a Student Pilot Licence (SPL) and CASA cannot issue an SPL under the Aviation Transport Security Regulations (2005) until a full security check has been completed (this does not apply to applicants who are under 18). The aviation community is disadvantaged by the considerable delays being experienced in issuing SPLs due to the processing of security checks, and concern has been expressed about the adverse effect on the flying training industry.

Delays associated with processing of security checks typically add 3 to 4 weeks to the time required to process and issue an SPL. In recent times, the delay has been much longer due to factors such as the security requirements for the Commonwealth Games.

The inability to fly solo severely hampers a student pilot's training programme, particularly students undergoing full time training, because students normally fly solo after only about 10 hours of dual flight training and further progress is normally dependent on practice in solo flying. Early consolidation training is essential. Students mainly affected are those on full time training courses, many of whom are from overseas, with limited time to complete their training. Overseas students represent a valuable export market to Australia.

This project sets out to amend Civil Aviation Regulation (1988) 5.03 to allow student pilots to fly solo without holding a student pilot licence. In practical terms, this could mean a pilot could continue flying training for approximately 4 weeks and up to the GFPT (general flying progress test) stage which is commonly around 20 hours of flight time. There would be exceptions where a student can reach GFPT in a shorter timeframe. Conditions could be applied to limit the scope of such operations that minimise the exposure to risks that would otherwise be mitigated by ensuring a pilot had a full security check prior to flying solo.

CASA considers the proposed change would not present a significant additional risk to security as a pilot can already learn to fly an equivalent type of aircraft under the recreational aircraft scheme or by obtaining a certificate of validation (based on an overseas licence where no security check has been completed).

CAR 5.03 already gives permission to persons to fly an aircraft without holding a pilot licence in certain circumstances, and CASA proposes adding a further paragraph (d) that would now include student pilots under the existing provisions. The proposed amendment would take the following form (subject to legal drafting by the Attorney General's Office of Legislative Drafting and Publishing):

CAR 1988 5.03

the person:

(i) is undertaking a solo training flight within the student pilot area limit
[Purpose/intent: Without this, there is no relief from having to hold a student pilot licence; it is the crux of the proposal and gives sufficient scope for students to carry on training but confined to the local training area]; and

(ii) the flight has been authorised by an authorised flight instructor
[Purpose/intent: This involves the flying school in deciding who should have access to the aircraft; it mirrors the authorisation requirement for student pilots]; and

(iii) the person has submitted an application for the issue of a student pilot licence, including an application for a security status check, to CASA
[Purpose/intent: This ensures the licence application and security checking process has been initiated; to be read with subparagraph (v)]; and

(iv) the person holds a Class 1 or Class 2 medical certificate
[Purpose/intent: This covers the medical certification requirements for student pilots - ensures an equivalent level of safety is established]; and

(v) has written notification from CASA to make solo flights
[Purpose/intent: This ensures CASA has received the application and has used its processes to get the application to the AFP for a security check; this would be in the form of a notification letter produced at the time the application is received by CASA].

Rules affected

CAR 5.03 - May a person perform a duty essential to the operation of an aircraft without a licence?

Project management

Project Leader: Roger Crosthwaite

Project Sponsor: Greg Hood

Standards Consultative Committee (SCC)

Standards Consultative Committee


Title Details Date
Consultation updates in 2008
Project FS 06/01 Project closed.

The Office of Transport Security are not currently prepared to consider regulation change to allow student pilots to fly solo without a licence and background security check.
23 Oct 2008
Consultation updates in 2006
Project FS 06/01 - Provide for student pilots to fly solo without holding a student pilot licence New rulechange projects has been registered. 3 Mar 2006