NOTICE OF PROPOSED RULE MAKING

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1 NOTICE OF PROPOSED RULE MAKING Maintenance personnel licensing for small aircraft Issued for public consultation by CASA s Standards Division NPRM 1310SS September 2014 Project Number: SS 05/01

2 Audience This Notice of Proposed Rule Making (NPRM) will be of interest to: owners and registered operators of small aeroplanes and helicopters Part 145 of Civil Aviation Safety Regulation 1998 (CASR) Approved Maintenance Organisations (AMO) Regulation 30 of Civil Aviation Regulation 1988 (CAR) certificate of approval for aircraft maintenance and transport category aircraft certificates or approval holders Licensed Aircraft Maintenance Engineers (LAME) and others involved in aircraft maintenance personnel involved in design, certification and production of aircraft and aeronautical products. Amendment Amendment of Part 66 of CASR and its Manual of Standards (MOS). Key dates The Civil Aviation Safety Authority (CASA) is responsible under the Civil Aviation Act 1988 for, amongst other functions, developing and promulgating appropriate, clear and concise aviation safety standards. CASA must, where appropriate, consult with government, commercial, industrial, consumer and other relevant bodies and organisations in the performance of this function and the exercise of its powers. Civil Aviation Act 1988 Subsection 9(1)(c) and Section 16 This NPRM contains proposed amendments to existing regulations that may be pursued as a future regulatory change. No action will be taken until all responses and submissions have been considered. To ensure clear and relevant safety standards, we need the benefit of your knowledge as an aviator, aviation consumer and/or provider of related products and services. You can help by completing the NPRM Response Form and returning it to CASA by 21 November NPRM 1310SS Page 2

3 Foreword This NPRM is issued by CASA with a view to ensuring that Australian aviation safety requirements are current and appropriately address safety risks. CASA s policies require that the aviation safety regulations must: be necessary to address known or likely safety risks provide for the most efficient allocation of Industry and CASA resources be clear and concise where appropriate, be aligned with international standards and drafted in outcome based terms. The International Civil Aviation Organization's (ICAO) Air Navigation Services Training Procedures Doc 9868 now includes the concept of competency-based training and modularised licences as a recommended practice. The small aircraft licence (SAL) proposed by CASA includes these practices. The proposed expansions of Part 66 of CASR and the Part 66 MOS legislation would continue to use the Australian competency-based training system to deliver the training outcomes required for small aircraft licences and endorsements. The Part 66 licence system already provides for small aircraft licensing but uses exclusions to provide the required tailored outcomes. During consultation with industry, the very strong response was that the privileges of any future small aircraft licence needed to be expressed in a positive sense. The members of the Part 66 small aircraft maintenance licence working group agreed to a small aircraft licence structure, the detail of which is provided within this NPRM. The proposed small aircraft licence would be available to new applicants who have completed the relevant Certificate IV in Aeroskills (Mechatronics Training Course). CASA is not proposing to reissue existing B1.1, B1.2, B1.3, B1.4 and B2 category licences as small aircraft licences. Part 66 licences' current small aircraft maintenance certification and Certificate of Release to Service privileges would continue without any change. I would like to thank you for your interest in this proposal. I emphasise that no rule changes will be made until CASA has considered all NPRM responses and submissions received by the closing date. Grant Mazowita Acting Executive Manager Standards Division September 2014 NPRM 1310SS Page 3

4 Contents Reference material Acronyms and abbreviations References 6 2 Industry consultation Previous consultation Consultation on this NPRM 9 3 Proposed change Background considerations relevant to the AME small aircraft licence Key proposal Legislative drafting instructions 15 4 Implementation and review Implementation timeframes Transition and post-implementation reviews Licence transition requirements 18 Annex A NPRM Response Form A1 Annex B Summary of responses to DP 1215SS B1 Annex C List of elementary maintenance tasks C1 Annex D Proposed additional Appendix to the Part 66 MOS detailing competencies required for each small licence and licence endorsement D1 Annex E Samples of small aircraft maintenance licences E1 NPRM 1310SS Page 4

5 Reference material 1.1 Acronyms and abbreviations The acronyms and abbreviations used in this NPRM are listed in the table below. Acronym / abbreviation AAAA ACARS ADF ADS-B ALAEA AME Description Aerial Agricultural Association of Australia Aircraft Communication Addressing and Reporting System Automatic Direction Finder Automatic Dependent Surveillance - Broadcast Australian Licenced Aircraft Engineers Association Aircraft Maintenance Engineer AMO Approved Maintenance Organisation (CASR Part 145) AMROBA ATAE Aviation Maintenance Repair and Overhaul Business Association Aviation Training for Aviation Engineers CAR Civil Aviation Regulations (1988) CASA Civil Aviation Safety Authority CASR Civil Aviation Safety Regulations (1998) CBT CRS CVR DME DP FDR FMS ICAO ILS INS IRS LAME LRU MOS MTO Competency-based Training Certificate of Release to Service Cockpit Voice Recorder Distance Measuring Equipment Discussion Paper Flight Data Recorder Flight Management System International Civil Aviation Organization Instrument Landing System Inertial Navigation System Inertial Reference System Licensed Aircraft Maintenance Engineer Line Replaceable Unit (avionic) Manual of Standards Maintenance Training Organisation NPRM 1310SS Page 5

6 Acronym / abbreviation MTOW NFRM NPRM Rad Alt SAL Sat Nav Sel Cal SOE SOR TCAS UHF VHF VOR Description Maximum Take Off Weight Notice of Final Rule Making Notice of Proposed Rule Making Radio Altimeter Small Aircraft Licence Satellite Navigation Selective Calling (radio system) Schedule of Experience Summary of Response Terrain Collision Avoidance System Ultra High Frequency Very High Frequency VHF Omnidirectional Range 1.2 References Regulations Regulations are available on the ComLaw website Part 66 of CASR Continuing airworthiness aircraft engineer licences and ratings. Part 145 of CASR Continuing airworthiness Part 145 approved maintenance organisations. Part 66 Manual of Standards. Part 145 Manual of Standards. Standards International Civil Aviation Organization's (ICAO) Air Navigation Services Training Procedures Doc Consultation document DP 1215SS Maintenance Personnel Licensing for Small Aircraft. Available online at NPRM 0804MS A Proposal to Modernise Rules for the Licensing of Maintenance Personnel for Small Aircraft. NPRM 1310SS Page 6

7 2 Industry consultation 2.1 Previous consultation NPRM 0804MS - A proposal to modernise rules for the licensing of maintenance personnel for small aircraft The way in which the Part 66 Aircraft Maintenance Engineer (AME) licensing regime is applied to the current charter, aerial work and private sectors is being reviewed/revised, in light of the responses received by CASA as a result of the consultation conducted under NPRM 0804MS. NPRM 0804MS feedback and more recently ICAO's approval of Amendment 1 to the Air Navigation Services Training Procedures Doc 9868, resulted in the need for further consultation and analysis by CASA with industry, before the legislation covering off the form of Part 66 licence outcomes for small aircraft could be provided Discussion paper In December 2012, CASA released Discussion Paper (DP) 1215SS for public comment. In total, forty two respondents submitted comments to the DP. The following CASA and industry representatives consented to having their names published: Industry Representative Jim Charlesworth Boyd Park Alan Jupp John Beveridge Scott Gurner Timothy Derbyshire Graeme Wheeler Graeme Bell Dennis Wisbey Marj Davis-Gillespe Darren Lydeamore Karl Jelinek Michael Rutledge Stephen Re Robert Nieuwenhoven Ken Cannane Organisation ACMA, AvServe, MAF Avionpro Pty Ltd PlaneTorque Australia Pty Ltd Aero Enterprise Aircraft Electrical Services Pty Ltd Australian Centre for Mission Aviation Aymstyle Pty Ltd Australian Piper Society Aero Service Royal Federation of Aero Clubs of Australia MAF international Tuna City Aviation Heliflite ALAEA Sunshine Coast Helicopter Rescue Service AMROBA NPRM 1310SS Page 7

8 Individuals Roger Pape Peter Dwyer Laureen Bridges Private LAME Technical Writer Paul Cousins A summary of the responses received and CASA's disposition to those comments is provided at Annex B of this NPRM Small aircraft maintenance licence working group Given the strong objections raised by industry to the original NPRM 0804MS proposal for a small aircraft licence, CASA formed a small aircraft maintenance licence working group comprised of industry and CASA personnel. The working group met on two occasions 17 December 2013 and 26 February 2014 with the main outcome of those meetings being an agreed small aircraft licence structure (see Figure 1). The working group s members are listed below. Industry Representative Phil Hurst Péter Marosszéky Bruce Baxter Steve Re Ken Cannane Adam Roy Laurence Beraldo Rod Elliott Brian Cobb Les Watts Organisation Aerial Agricultural Association of Australia Aerospace Developments Pty Ltd Aircraft Electronics Association ALAEA AMROBA ATAE ATAE Hawker Pacific Manufacturing Skills Australia Manufacturing Skills Australia Consultant CASA Representative Nicholas Ward Mike Broom Mick McGill Sam Palaskonis Rupert Symonds Role Project Sponsor representative, CASA Standards Division Project Leader, CASA Standards Division Standards Officer, CASA Standards Division Section Head CASA Maintenance Personnel Licensing Maintenance Specialist (Avionics), Maintenance Personnel Licensing NPRM 1310SS Page 8

9 2.2 Consultation on this NPRM Publication of this NPRM constitutes a continuation of the normal process of public/industry consultation on the licensing proposal for the small aircraft sector. CASA registers and reviews each comment and submission received, but will not individually acknowledge a response unless specifically requested to do so. A summary of the comments provided in each submission will be published without attribution in a Summary of Responses (SOR), typically provided as an Annex to the subsequent Notice of Final Rule Making (NFRM). If consent is provided, the contributor s name will additionally be published as a List of Respondents, typically provided in the subsequent NFRM. At the end of the response period for public comment, all submissions will be analysed, evaluated and considered. Subsequent to the closing date for comments, an NFRM (including a SOR) will be prepared and published in conjunction with the making of the Final Rule. NPRM 1310SS Page 9

10 3 Proposed change 3.1 Background considerations relevant to the AME small aircraft licence Existing licensing structure under Part 66 of CASR Aircraft engineer licences are now issued under Part 66 of CASR with one or more of the following categories and subcategories: Category A: A1 turbine engined aeroplanes A2 piston engined aeroplanes A3 turbine engined helicopters A4 piston engined helicopters Category B1: B1.1 turbine engined aeroplanes B1.2 piston engined aeroplanes B1.3 turbine engined helicopter B1.4 piston engined helicopters Category B2 - aircraft (aeroplanes and helicopters) Category C - large aircraft in a base maintenance activity Small aircraft licence policies relevant to design In developing the proposed small aircraft licence structure (as illustrated in Figure 1 below), the small aircraft maintenance licence working group sought to design a licence that would: be structured the same way as the current Part 66 B1 and B2 licence categories be modular in its structure progressively building licence privileges up be consistent with ICAO Annex 1 Personnel Licensing and the Air Navigation Services Training Procedures Doc 9868 amendments, which include competencybased training (CBT) and modularised licences as a recommended practice be underpinned by CBT delivered by Part 147 Maintenance Training Organisations (MTOs) provide a positive statement of licence privileges rather than the use of exclusions/limitations be limited to small aircraft 1 be aligned to the previous CAR 31 licence lower group system where applicable with some merging of groups be available after two years, and with scope to certify for the pilot maintenance schedule and small aircraft maintenance activities (similar to the line maintenance activities available to category A licence holders). 1 Small aircraft are aeroplanes with a Maximum Take-Off Weight (MTOW) of not more than 5,700kg and single engine helicopters or small aircraft with a turbine (type rated) engine or large aircraft designated by CASA as a small aircraft. NPRM 1310SS Page 10

11 3.2 Key proposal CASA proposes to introduce a modularised aircraft maintenance engineer licence structure for use on small aircraft, like the existing B1 and B2 licence structure of Part 66 of CASR. Typically, small aircraft are not type rated, so they can have their maintenance certified and the aircraft CRS issued by the holder of an appropriate category B1 or B2 licence. The new small aircraft licences would work in a similar way. For aircraft equipped with a specific turbine engine(s) powerplant, a turbine engine type rating(s) would be required on the relevant sub category of B1 licence. The addition of a powerplant endorsement would require a LAME to first gain the relevant underpinning competencies for turbine engines. The CBT for the small aircraft licence would be delivered by CASA-approved and oversighted Part 147 MTOs using the MEA11 Aeroskills Training Package, a nationally endorsed set of competency standards and qualifications under the Australian Government's Australian Qualifications Framework - the national policy for regulated qualifications in Australian education and training. Upon successful completion of the small aircraft licence training package i.e. Mechatronics, the Part 147 MTO report of the training outcome could be supplied to CASA with a licence application for issue of a small aircraft licence. A licence document can contain more than one licence e.g. the CASA licence document issued under Part 66 could be annotated with A1, B1.1 and B2 licences as well as a small aircraft licence. The small aircraft licences could be the first licence annotated on the CASA licence document or a subsequent annotation. The proposed small aircraft licence would use a positive statement of licence privileges, rather than the use of exclusions/limitations. The small aircraft maintenance licence working group's agreed licence structure (Figure 1), forms the basis of the proposal presented in this NPRM Small aircraft licences scope of licence privilege Five small aircraft licences are being proposed: B.1.1, B1.2, B1.3, B1.4 and B2; limited to small aircraft. The form of annotation, by way of example, could be along the lines of: B1.1SAL or B2SAL, to differentiate the small aircraft licences from the current licences. The small aircraft licences would not be rated with type rated aircraft types but the B1.1SAL and B1.3 SAL could be endorsed with turbine engine endorsements. If a B1.1SAL, B1.3SAL or B2SAL licence holder wanted to provide maintenance certifications or certificates of release to service for type rated aircraft types thus requiring the relevant aircraft type rating then additional competency training and assessment by a Part 147 MTO would be required. After gaining the relevant bridging competence the B1.1SAL, B1.3SAL and B2SAL could apply to CASA for the relevant B1.1, B1.3 or B2 licence. The scope of licence privilege for each of the B1.1SAL, B1.2SAL, B1.3SAL and B1.4SAL has been designed around the level of competence that can be delivered in the first two years of training of the Mechatronics Training Course. Competence for the following is expected: avionics LRU single generator electrics; distribution, lighting, batteries, electrical subsystems metal airframe NPRM 1310SS Page 11

12 elementary maintenance tasks. Note: Although the privilege to certify for elementary maintenance is an included privilege for all category B1 licences, this privilege will be represented on the licence as a licence endorsement. Like the B1 small aircraft licence, the scope of privilege for the category B2 small aircraft licence relates to the expected competence gained by the two year mark of Mechatronics training. The B2 small aircraft licence would have scope for: avionics LRU instrument systems indication and data (including data loggers and software updates) instruments systems within mechanical, powerplant and structural systems navigation systems radio systems Com 1 VHF/UHF/Audio/ELT/cabin intercom data electrical system (lighting, batteries, electrical subsystems) electrical system single generator (generation and distribution) Elementary maintenance Elementary maintenance is maintenance similar to the current category A licence line maintenance tasks and those maintenance tasks that may be carried out by a pilot as prescribed under Schedule 8 of CAR Elementary maintenance is an automatic endorsement on all subcategory B1 small aircraft licences and an option for the category B2 small aircraft licence. The B2 trainee could apply for the elementary maintenance endorsement if they had gained the required practical experience relevant to the competency unit contained in the B2 small aircraft licence elementary maintenance skill set. Elementary maintenance skill sets have been developed for both the B1 and B2 small aircraft licence pathways to define the units of competency that need to be attained from the Mechatronics training in order to qualify for the grant by CASA of a B1 or B2 small aircraft maintenance licence endorsed with certification privileges for completion of elementary maintenance. Upon completion of the elementary maintenance skill sets and after gaining 2 years of practical experience on aircraft, an individual would qualify to apply to CASA for the issue of a category B1 or B2 small aircraft licence effectively allowing for an initial licence to be obtained after two years with certification privileges for the elementary maintenance tasks listed in Annex C and some basic licence scope Licence prerequisites In order to qualify for a small aircraft B1 or B2 licence under the proposed regulation, an applicant would be required to demonstrate that he or she: is at least 18 years of age at the time of making the application has been assessed by the relevant Part 147 MTO and their Part 145 AMO as meeting the applicable competency requirements, including the required underpinning knowledge modules has attained two years aviation maintenance experience (inclusive of training) possesses the necessary English language skills required by CASA for the issue of a licence under regulation of CASR. NPRM 1310SS Page 12

13 3.2.4 Privileges of the small aircraft B1/B2 licence The privilege of the Part 66 small aircraft licence would allow the holder to certify for maintenance and/or issue a Certificate of Release to Service (CRS) for small aircraft covered by the scope of the licence held. The Part 66 licence would allow the holder of such licences to work independently, or within a Part 145 or regulation 30 of CAR 1988 maintenance organisation. When used to provide maintenance for aircraft covered by CAR 1988, the privilege would be to carry out maintenance on a small class A and B aircraft and to provide for certifications of completion of that maintenance. A sample of each Part 66 small aircraft licence and some possible endorsements for each licence category (as illustrated in Figure 1 below) is provided by Annex E Benefits and impact of changes The proposed licence structure would provide maximum small aircraft coverage within the initial licence scope aligned to the Certificate IV in Aeroskills (Mechatronics) qualification. Under the proposed changes, apprentices and employers would benefit from the increased flexibility in training this proposed licence structure would provide, allowing for a wide range of training options that would cover the varying maintenance requirements of the employer, while further developing the knowledge and skills basis of apprentices. The training received by apprentices would be relevant to the industry sector in which they are employed, allowing better targeting of skills development. The availability of the pilot maintenance schedule privileges after approximately two years would benefit employers of eligible employees. Other benefits and outcomes of the proposed small aircraft licences and endorsements would be: an appropriate balance between complexity and flexibility of the licence the possibility commence use of the initial small aircraft licence at the two year mark competencies that are delivered in the four year Mechatronics Aeroskills training package thus keeping within the government's current four year funding model removal of the need for the five year duration for the "Diploma of Aeroskills" qualification training outcomes for the B1.2, B1.4 and B2 licences thus mitigating industry's concern that employers have to provide a year s funding (to cover the extra year of training - not currently funded by government - required by Diploma level training compared to Certificate IV training) a clear delineation between mechanical and avionics licence categories and electrical privileges in both B1 and B2 licence categories small aircraft licences aligned with the current Part 66 licence structure for the B1.1, B1.2, B1.3, B1.4 and B2 licence categories merging of aircraft systems with close affiliations into single endorsements where the same skill sets can be applied to each of the aircraft systems e.g. radio systems - primary and secondary radar: ADS-B, Rad Alt, DME, Transponder and TCAS is a single endorsement providing certification privileges for those aircraft systems common to the majority of aircraft that would be worked on in an aircraft maintenance organisation e.g. avionics line replaceable units (LRU) and electrical system (lighting, batteries, subsystems) NPRM 1310SS Page 13

14 B1SAL licences providing certification privileges for elementary maintenance covering pilot maintenance and other maintenance tasks (similar to category A licence line maintenance tasks) and an option to gain certification privileges for elementary maintenance on the B2SAL licence optional endorsements for particular aircraft systems that may be difficult to obtain if an aircraft fitted with those systems is not available to demonstrate competence e.g. electrical system multi generator systems assessment of competency by the Part 147 MTO assessor and Part 145 AMO provides the initial permission to carry out maintenance, as recorded on the relevant CASA application for a small aircraft licence and/or endorsement licence and endorsement issue can occur upon successful completion of training for the relevant competencies training outcomes provided under the Australian Qualification Framework CBT regime an ICAO compliant licence. NPRM 1310SS Page 14

15 Figure 1 - The small aircraft maintenance licence working group s proposed licence structure licences and endorsements 3.3 Legislative drafting instructions Part 66 of CASR This section contains indicative terminology that may not be utilised in the final form of the legislation. After consideration of feedback received in response to this NPRM, CASA intends to provide legislative drafting instructions to give effect to the following requirements of Part 66 of CASR: NPRM 1310SS Page 15

16 a requirement for a small aircraft licence is a subcategory B1.1, B1.2, B1.3, B1.4 or category B2 licence limited to small aircraft that a small aircraft licence is an aircraft engineer licence the use of exclusions for expression of privilege and removal of exclusions for addition of privileges, will not be utilised aircraft type training also relates to a type rated engine for a small aircraft licence the Part 66 MOS may specify (in addition to the existing Part 66 MOS specifications): small aircraft licence endorsements aircraft systems and subsets of systems that are included in the scope of a small aircraft licence or endorsement the privileges that a LAME whose licence is endorsed with a small aircraft endorsement may exercise the elementary maintenance tasks that are included in the scope of the elementary maintenance endorsement for a small aircraft licence type rated engine endorsements the additional competencies (knowledge and practical) required to remove a small aircraft limitation from a subcategory B1.1, B1.3 or B2 licence the required units of competency for endorsements on a small aircraft licence the sequence of training required to receive a small aircraft licence and endorsements that a specified small aircraft licence endorsement is one for which a Part 145 organisation may authorise a competent small aircraft licence holder to provide maintenance certifications for Part 66 MOS CASA intends to provide legislative drafting instructions to give effect to the following requirements of the Part 66 MOS. As the Part 66 MOS would include mention of the small aircraft licence and its endorsements wherever required, the following sections of the MOS would require rework: 66.A.1 Aircraft engineer licence 66.A.20 Privileges (relating to small aircraft endorsements) and a related listing of elementary maintenance see Annex C 66.A.25 Basic knowledge and competency requirements (for small aircraft licences) 66.A.30 Basic practical experience requirements (for small aircraft licences) 66.A.45 Type/task training and ratings to include the small aircraft turbine engine endorsement theory training requirements 66.A.50 Aircraft type practical training to include the small aircraft turbine engine endorsement training requirements 66.A.55 On the Job aircraft type training to include the small aircraft turbine engine endorsement training requirements 66.A.70 Limitations to explain what the limitation limited to small aircraft means for a subcategory B1.1 or B1.3 or category B2 licences Appendices Appendix I CASA knowledge syllabus NPRM 1310SS Page 16

17 Appendix III Type training and assessment standards New Appendix that lists the elementary maintenance tasks the holder of a small aircraft licence endorsed for elementary maintenance may certify for Note: the list of elementary maintenance tasks are detailed in Annex C New Appendix that details the units of competency required for a category or subcategory of small aircraft licence Note: the list of competencies that would lead to the issue of a small aircraft licence or endorsement are detailed in Annex D Consequential amendments to Parts 145 and 147 of CASR and MOS CASA intends to provide consequential legislative drafting instructions to give effect to the following requirements of Parts 145 and 147 of CASR, and their respective MOS Parts. Introduction of a new scheme that would lead to a permission for an individual to provide maintenance certifications upon being assessed by the Part 145 AMO and 147 MTO as competent for the pre-requisite competencies for a particular small aircraft licence or endorsement. The AMO and MTO assessors would sign off on the competencies on the same form the licence applicant would submit to CASA when seeking the issue of the small aircraft licence or endorsement. Like the permissible maintenance scheme, the duration of the permission granted to an individual by the AMO would be six months, during which time the applicant could expect to have been issued their licence or endorsement by CASA. NPRM 1310SS Page 17

18 4 Implementation and review 4.1 Implementation timeframes The Mechatronics competency training package, sequence of training delivery and the related licence flexibility are subject to further deliberations. CASA and the small aircraft maintenance licence working group (as per paragraph 2.1.3) may reform to discuss any further finessing of the small aircraft maintenance licence proposals. Readers are invited to provide their submissions either directly to CASA or via their representatives on the working group. CASA will take feedback from this NPRM to determine whether the proposal described remains the preferred industry solution for a Part 66 licence for small aircraft. Following consideration of responses to this NPRM, CASA will seek amendment to Part 66 and the relevant areas of Parts 145 and 147 of CASR and the Part 66 MOS. A preliminary date for the proposed rulemaking is December 2014, with the regulations becoming effective on 26 June These dates may change depending on when the draft rules are signed, registered and set to commence. 4.2 Transition and post-implementation reviews CASA will monitor and review the new rules on an ongoing basis during the transition phase. Thereafter, following the commencement of the rules, CASA will conduct post-implementation monitoring and reviews during the implementation of the small aircraft licences. 4.3 Licence transition requirements This proposed small aircraft licensing system was designed to deliver the training outcomes required that are applicable to small aircraft, with the privileges expressed in a positive sense on the licence without the use of exclusions. The Part 66 licence system already provides for small aircraft licensing but uses exclusions to provide the required tailored outcomes. CASA will not be transitioning existing Part 66 licences into the new small aircraft licence system. CASA will grant small aircraft licences and endorsements upon completion of the relevant competencies of the Mechatronics course delivered within the Aeroskills Training Package provided by a CASR Part 147 MTO. CASA will seek to provide a regulation that allows CASA to continue to accept licence applications for a small aircraft licence where a person qualifies for what were termed lower group ratings under the previous CAR 31 CASA basics examinations and schedule of experience (SOE) requirements for small aircraft for a period of a further 4 years, allowing for the continued use of the CASA basics to gain a small aircraft licence until June NPRM 1310SS Page 18

19 Additional information is available from: Michael McGill CASR Part 66 Project Leader Post (no stamp required in Australia) Reply Paid 2005 Airworthiness and Engineering Standards Branch Civil Aviation Safety Authority Canberra ACT 2601, Australia Telephone Australia or (for the cost of a local call) International

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