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Project MS 13/15 - Exemption from 145.A.30 (k) 2. Ii) & (ii) 9(B) of Part 145 MOS requirement
Project closed 19 July 2013.
The objectives of this project have been transferred to and are being addressed in Project MS 12/37.
Current transitional conversions of CAR 30 to Part 145 AMO approvals have raised the issue of approved maintenance organisations being obligated to type train LAME to a greater scope than local Nation Aviation Authority (NAA) requirements. CASA did not intend to legislate a more expansive scope of aircraft type training than that required by the local NAA but the current form of the MOS provision does not articulate that standard clearly enough.
The current provision of the Part 145 MOS that deals with using a licence holder from another NAA where the licence is held:
- Is an airframe and Powerplant (A&P) licence (or the like); and
- Is not type rated (as the basic licence relies on company authorisations post aircraft type training for particular types of aircraft);
- Requires that a licence holder gains the equivalent of CASA B1 or B2 aircraft type training for a particular type rated aircraft type.
CASA intends to amend the provision 145.a.30 (k) 2. II) & (ii) (B) of the Part 145 MOS so that the applicable type training standard required is that of the NAA in the geographic location of the A&P licence holder - rather than the current B1 or B2 type training (CASA0 requirement.
In anticipation of the proposed amendment, CASA has decided to provide Part 145 AMOs with an exemption against the current training standard. The exemption would be to the extent of the proposed amendment to the Part 145 MOS.
Legislative change action is required to correct the issue as the current Part 145 MOS legislative obligation is to require that licence holder gains the equivalent of CASA B1 and B2 aircraft type rating.
This is a compliance issue in the Part 145 AMO approvals may be held up as overseas line stations cannot quickly source aircraft type training that covers the CASA requirement rather than the local NAA requirement.
The consequence of no-action is delays to conversion of existing CAR 30 approvals to Part 145 AMO approvals.
The objective is to provide regulatory relief, by way of exemption, in anticipation of an equivalent Part 145 MOS amendment.
The current regulatory policy in place is contained within 145.A.30 (k) 2. (i) & (ii) (B) of Part 145 MOS.
The Part 45 AMC/GM document and the AEB assessors handbook will be amended in concert with the eventual Part 145 MOS amendment.
CASR Part 145
This project was approved by: Peter Boyd, Executive Manager Standards Division on 5 June 2013.