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PIR 1703MS – Post-implementation review of Part 66 - Continuing airworthiness - aircraft engineer licences and ratings
Part 66 of the Civil Aviation Safety Regulations 1998 (CASR) sets out the requirements for the application for, the granting of, and appropriate use of aircraft maintenance engineer licences and ratings. Part 66 was first introduced in June 2011 as part of the regulatory reform program and transitioned the aircraft maintenance licensing requirements from the Civil Aviation Regulations 1988 (CAR) to the CASR. The detailed standards for the issue of aircraft engineer licences, ratings and other requirements and privileges associated with the licence are included in Part 66 Manual of Standards (MOS), which is an essential part of Part 66 suite of legislation.
The Part 66 licensing system adopted A, B1, B2 and C licence categories and aircraft type ratings in line with the European Aviation Safety Agency (EASA) system. However, the licensing system did not provide for the EASA B3 licence category for small aircraft because it was considered too limited and unsuitable for the Australian aviation industry. The plan was to develop a small aircraft licensing system after the initial implementation of Part 66.
Since 2011, CASA—in collaboration with the Maintenance Standards Sub-Committee and the Small Aircraft Working Group—has developed a small aircraft licensing system based on the previous CAR 31 licence system that uses ‘group rating’ endorsements on a licence to identify the privilege for each licence. A separate four year (Certificate IV) training course was specifically developed under the Aeroskills training package to satisfy CASA’s requirements for the grant of a licence for small non-type rated aircraft—the majority of which are operated in the general aviation (GA) sector of the industry.
This small aircraft licensing system was to have commenced from 4 July 2016 with amendments made to the Part 66 MOS. However, just before the MOS amendment was due to commence some key industry stakeholders raised concerns about a number of aspects of the new licensing system. The main concerns related to inflexibility of training pathways impeding the career progression of maintenance personnel from small non-type rated aircraft to large type rated aircraft, and the ability of Part 147 maintenance training organisations (MTOs) and registered training organisations (RTOs) to deliver the training for the small aircraft licence. During discussions with stakeholders it became apparent that significant changes would have to be made to the small aircraft licensing system to address their concerns and to ensure the regulatory requirements and the structure of the training could work effectively together. Consequently, CASA and industry agreed to postpone the commencement of the small aircraft licencing system to allow for further assessment of the licensing framework.
CASA decided to carry out a comprehensive post-implementation review of Part 66 legislation.
Issues identified so far
Since the commencement of Part 66 in June 2011, CASA has received valuable feedback from stakeholders—including Part 66 licence holders and training organisations—on the implications and effects of the legislation. Feedback has highlighted the opportunity to simplify and clarify some aspects of the legislation, and address anomalies, gaps and unintended consequences. Primary issues identified to date include:
- the licensing system could be structured to better support a small aircraft licence for the general aviation sector
- complexity and difficulty in interpreting both the Part 66 of CASR and the Part 66 MOS
- the CASA knowledge requirements and competency requirements needed for a licence outcome as specified in the Part 66 MOS are too onerous in many cases
- poor alignment between the Aeroskills training and the licence outcome
- inconsistent training delivery standards between RTOs and Part 147 MTOs
- the training syllabus for a licence outcome differs to EASA’s syllabus
- funding for vocational education and training is not consistent across state governments
- the statement of privileges on a licence lacks clarity, particularly in relation to the use of exclusions
- the licensing system is not fully harmonised with EASA’s Part 66 licensing system.
Objective of the post-implementation review
The objective of this post implementation review project is to carry out a comprehensive review of Part 66 of CASR, the Part 66 MOS and associated advisory material to achieve the following outcomes:
- reduce the complexity of the legislation
- fix any anomalies in the legislation and address unintended consequences
- remove ambiguities and generally streamline the legislation
- ensure that the legislation is optimised to support the required competency outcomes
- ensure that the legislation maintains compliance with ICAO standards
- a more progressive licensing system that includes a small aircraft licence
- a more efficient set of training competency units for the complete licensing system in conjunction with the Aerospace Education and Training Industry Reference Committee
- improve the way privileges are stated on licences to provide clarity.
The review will be carried out in collaboration with industry.
CASA seeks your input
In support of the Part 66 post-implementation review, CASA invites you to provide submissions on issues you consider need addressing.
If you are any of the following, Part 66 legislation currently affects you directly or indirectly:
- apprentice or tradesperson in aircraft maintenance engineering (AME)
- Part 66 licensed aircraft maintenance engineer (LAME)
- CASR Part 145 approved maintenance organisations (AMO)
- CASR Part 147 maintenance training organisations (MTO)
- CAR 30 Certificate of Approval holder
- registered training organisation (RTO) offering Aeroskills training
- CASA airworthiness inspector or other staff who deal with Part 66 matters.
In your submission, please reference the specific items of legislation (if applicable) and briefly describe how it affects you and what you consider to be a potential solution. Even if the issues that affect you have already been identified above, we still urge you to submit details of how and to what extent those issues affect you, and what you consider to be the most effective solution.
How to respond
Please submit your response to CASA as a Word or PDF file using the online response form. Submissions close 26 May 2017.
Summary of consultation
CASA published PIR 1703MS - Post-implementation review of Part 66 - Continuing airworthiness - aircraft engineer licences and ratings on the CASA website from 21 February to 26 May 2017.
CASA received a total of 70 submissions; 48 respondents consented to having their comments published on the CASA website.
For further information about the Part 66 post implementation review, please email firstname.lastname@example.org.
If you would like to make a submission to the Part 66 post-implementation review, you must lodge it using the online response form. Email submissions will not be accepted.