Part 61 Solutions Taskforce Closure Report
The flight crew licensing regulations (Parts 61, 64, 141 and 142) which came into effect in September 2014 were subject to immense criticism from the aviation community. CASA was committed to addressing the concerns raised.
The Part 61 Solutions Taskforce was formed in November 2015 to deliver solutions to valid issues associated with the flight crew licensing regulations. The remit of the Taskforce was to ensure that known or likely safety risks continued to be addressed, that unnecessary costs were not imposed on the aviation community, and that the rules did not unnecessarily hinder participation or the potential for industry growth.
An industry advisory panel (IAP) - comprising representatives from a range of aviation industry sectors - was also formed to assist CASA prioritise the issues and provide input on proposed solutions.
The Taskforce was originally established with a nominal completion date of 30 June 2016, but with the acknowledgement that the final end date would be determined by the full delivery of solutions to critical items on the flight crew licensing regulations issues register.
Over 11 months, CASA has worked closely with IAP members to prioritise issues and find ways of making the transition to the new rules easier for the aviation community.
The Taskforce was a new way of working that CASA had not previously used. It represented a tangible example of the power of collaboration and cross-functional cooperation to achieve a common corporate objective.
The Taskforce's collaborative approach in the prioritisation of issues requiring resolution and the formulation, drafting and implementation of policy solutions made it significantly different to CASA's regulatory development consultation process. Feedback provided by IAP members highlighted that this strong focus on consultation and collaboration was a major factor in the Taskforce's success.
CASA was able to choose the right staff, at the right time, and bring them together into a single line of accountability reporting structure with clearly defined tasks, objectives and timelines which enabled the Taskforce to get the job done. The Taskforce was able to accelerate the work that was already underway to address the issues that had been raised by industry.
The Taskforce delivered on a large amount of work including: publication of guidance material for flying training organisations, reviewing the flight review and instrument proficiency check policies and developing a range of instruments and exemptions to allow the smooth continuation of operations until the regulations themselves can be amended.
The Taskforce received significant positive feedback from the aviation community on the Part 141 Sample Operations Manual, the Part 142 Sample Exposition, the instrument proficiency check changes and the sample competency based training and formatted syllabuses correctly mapped to the Part 61 Manual of Standards (MOS).
The permanent flight crew licensing regulation amendment package will be the final deliverable of the Taskforce. The regulations are expected to be amended in late 2016/early 2017. CASA’s formal industry consultation process will be used to communicate proposed amendments to the aviation community. Once the regulations have been amended the permissions and exemptions issued to deliver the interim solutions will be able to be revoked.
Key findings and recommendations
The Taskforce, within a short period of time, successfully delivered major solutions to assist the aviation community and CASA staff in the implementation and transition to CASR Parts 61, 64, 141 and 142. The outcomes can be attributed to the following:
- The Taskforce's strong focus on consultation and collaboration in the prioritisation of issues requiring resolution and the formulation, drafting and implementation of policy solutions.
- The commitment of the IAP to work with the Taskforce to resolve the issues and test the solutions.
- The Taskforce's model and methodology allowed a balanced representation of issues and concerns and a more thorough review and testing of solutions.
- The importance given to both the technical solutions and the human elements associated with the regulatory change.
- The Taskforce team structure, which was suitable for a multi-disciplinary environment, quickly built an agile and flexible environment.
- The single line of accountability approach allowed timely decisions to be made.
- The establishment of the Shared Services team provided a dedicated administrative support and allowed the technical teams to focus on addressing regulation and policy issues, and producing the technical material and content.
While the IAP considered the work of the Part 61 Solutions Taskforce highly successful, it held the view that the establishment of the Taskforce was a reactive approach and CASA should use the Taskforce model and apply it pro-actively when rolling out future regulatory change. The IAP felt, while the air transport regulations are 'settled', they should be reviewed; and its implementation plan appropriately consulted.
The IAP recommends:
- CASA consider more effective methods for its stakeholder engagement and consultation approach and work with the aviation community to find better ways to maximise the efficiency and effectiveness of consultations.
- More time should be taken to develop the regulations (including a consultation process). The focus should be on getting it right rather than meeting targeted deadlines.
- Make regulations achievable with the provision of clear pathways.
- Develop regulations in plain language or, at the very least, the provision of plain language explanatory and advisory material.
- Engage with the aviation community in the implementation planning for future regulatory change.
- Implementation programs should take into consideration the human factor ramifications.
- Engage CASA's Certificate Management Teams much earlier in the process.
- Leverage from established communication channels between CASA inspectors and the certificate holders and their key personnel.
Based on its experience and the lessons identified in the last 11 months, the Taskforce recommends the following methods of implementation for future regulatory changes:
- Conduct a review of CASA's stakeholder engagement approach during the regulation development and implementation phases.
- A model of collaboration and cross functional co-operation within CASA and with the aviation community.
- The establishment of suitable, flexible teams to work on preparation activities
- In consultation with the aviation community establish a clear delivery framework right from the beginning, including the methodology and implementation approach.
- Developing guidance material and acceptable means of compliance prior to implementation of regulations.
- The development of guidance, resources and tools as solutions packages and the provision of training for all affected CASA staff and the establishment of an inspector helpline prior to the implementation of the regulations.
- Adoption of similar online applications delivered by the Taskforce – an online forum to facilitate aviation community/CASA staff consultation; an enquiries management tool to track and monitor industry enquiries; a knowledge base tool to help CASA staff answer enquiries; an issues register and a continuous improvement process as part of both the development and implementation phases.
For ongoing work, the Taskforce recommends:
- Relevant CASA areas maintain, support and improve on solutions delivered by the Taskforce, including Part 141 Sample Operations Manual package and the Part 142 Sample Exposition package and the online tools.
- Continued training for CASA inspectors on outcome-based regulation and change management.
- The Flight Crew Licensing web content be improved to help industry and staff source information.
- Delivery of workshops to the aviation community on change management and outcome-based regulations.
- Conversion of the Part 141 and 142 assessor worksheets into more appropriate online forms.