Explanatory Statement
Civil Aviation Safety Regulations 1998
Part 66 Manual of Standards Amendment Instrument 2025
Purpose
The purpose of the Part 66 Manual of Standards Amendment Instrument 2025 (the instrument) is to add some new aircraft types, and new aircraft type rating endorsements into Appendix IX of the Part 66 Manual of Standards (the Part 66 MOS) and to remove from that Appendix some incorrect commercial designations for some specified aircraft types. The instrument also makes some minor editorial amendments to some other Part 66 MOS provisions.
Legislation
Under section 9 of the Civil Aviation Act 1988 (the Act), CASA has the function of conducting the safety regulation of a range of matters, including, under paragraph 9(1)(c), developing and promulgating appropriate, clear and concise aviation safety standards.
Section 98 of the Act empowers the Governor-General to make regulations for the Act and in the interests of the safety of air navigation. Relevantly, the Governor-General has made the Civil Aviation Safety Regulations 1998 (CASR). Under subsection 98(5A) of the Act, the regulations may empower CASA to issue instruments in relation to, among other matters, the maintenance and airworthiness of aircraft.
Part 66 of CASR, Continuing airworthiness—aircraft engineer licences and ratings, deals with various categories and types of aircraft engineer licences (AELs) and ratings granted by CASA for:
- the performance of maintenance certification for maintenance carried out on aircraft
- issuing certificates of release to service for aircraft in relation to maintenance carried out on aircraft.
For subsection 98(5A) of the Act, regulation 66.015 of CASR empowers CASA to issue a Manual of Standards for Part 66 of CASR, prescribing matters required or permitted to be prescribed by the Part 66 MOS or necessary or convenient to be prescribed for carrying out or giving effect to Part 66. In particular, paragraph 66.015(2)(e) provides that the Part 66 MOS may specify that a specified aircraft type is a type rated aircraft type for an AEL.
Section 66.A.4 of the Part 66 MOS deals with certain type rated aircraft types and endorsements. Paragraph (a) of section 66.A.4 provides that an aircraft type specified in a cell in column 2 of a table in Appendix IX, with a type certificate (TC) holder (if any) mentioned in the corresponding cell in column 1, and a commercial designation (if any) mentioned in the corresponding cell in column 3, is specified as a type rated aircraft type for an AEL in Category B1, B2 or C. Paragraph (b) provides that, subject to paragraph (d), for an aircraft type specified in a cell in column 2 of a table in Appendix IX, an AEL in Category B1, B2 or C may be endorsed with the type rating endorsement mentioned in the corresponding cell in column 4. (Paragraph (d) deals with the legal effect of Notes in a cell in column 4.)
Section 66.A.45 of the Part 66 MOS deals with type/task training and ratings. Under paragraph 66.A.45 (h), an approved maintenance organisation (AMO) in accordance with section 145.A.37 of the Part 145 MOS, or a certificate of approval (COA) holder in accordance with Civil Aviation Order 104.0 (Certificates of approval — application, grant and conditions) (a CAR 30 organisation), may:
- for an aircraft type mentioned in column 2 of Table 2 in Appendix IX — deliver aircraft type training for a category or subcategory of licence for the aircraft, or a system or subsystem of the aircraft type; or
- for an aircraft type mentioned in column 2 of Table 2 in Appendix IX — arrange for the manufacturer of the aircraft or its engine to provide training and assessment.
Under subsection 33(3) of the Acts Interpretation Act 1901, where an Act confers a power to make, grant or issue any instrument of a legislative or administrative character (including rules, regulations or by-laws), the power shall be construed as including a power exercisable in the like manner and subject to the like conditions (if any) to repeal, rescind, revoke, amend, or vary any such instrument.
Background
The amendments that update the type rated aircraft types and type rating endorsements in the tables in Appendix IX of the Part 66 MOS have been made at the request of some aviation industry operators and maintainers who will shortly commence operations or maintenance work on these new aircraft types.
Maintenance training organisations (MTOs) generally deliver the type training required under the Part 66 MOS for licensed aircraft maintenance engineers (LAMEs) to obtain the type rating endorsements necessary to maintain type rated aircraft. However, the Part 66 MOS provides for Part 145 organisations and persons who have obtained a COA under regulation 30 of the Civil Aviation Regulations 1988 (CAR 30 organisations) to deliver type training and assessment or arrange for the manufacturer (of the aircraft or engine) to provide type training and assessment, if necessary. CASA understands that some of the new aircraft being added may have training provided for, or arranged by, such AMOs.
Overview of instrument
The instrument amends the Part 66 MOS in accordance with subsection 33(3) of the Acts Interpretation Act 1901.
The amendments made by Schedule 1 to the instrument amend the Part 66 MOS to add the following new aircraft types for the following TC holders into the applicable tables in Appendix IX:
- the UH-60L aircraft type, together with a related change to the type rating endorsement information, for PICKERING AVIATION
- the GVIII-G700 as a new aircraft type, together with a new type rating endorsement, for GULFSTREAM AEROSPACE CORPORATION
- the PC-12/47G aircraft type for PILATUS AIRCRAFT.
The instrument also removes from 2 tables in Appendix IX a reference to an incorrect commercial designation for some specified aircraft types. Some additional minor editorial changes are also made to some MOS provisions. These include changing a note so that it correctly refers to the documents mentioned in the related provision and changing a column heading of a table in Appendix IX so that it correctly refers to the kind of aircraft (helicopters) to which it relates.
All the amendments will commence on the day after registration of the instrument.
CASA has assessed the impact that the amendments made by the instrument will have on aviation safety and is satisfied that they will have no adverse impact on aviation safety. The aircraft type ratings amendments will have a positive safety impact as they require LAMEs who will maintain and certify maintenance performed on the new type rated aircraft to undertake aircraft-specific type training.
Content of instrument
Section 1 names the instrument.
Section 2 provides that the instrument commences on the day after it is registered.
Section 3 provides that Schedule 1 amends the Part 66 Manual of Standards.
Schedule 1 sets out the amendments to be made to the Part 66 MOS that relate to aircraft type ratings and minor editorial matters.
The following references to items are to items in Schedule 1. All references to provisions are to provisions of the Part 66 MOS.
Item 1 omits the definition of Part 66 rating from paragraph 66.5 (b) (the definitions section of the Part 66 MOS) because it is no longer used in the Part 66 MOS.
Items 2 and 3 are minor grammatical corrections. Item 2 omits “type-rating” from paragraph 66.A.4 (b) and replaces it with the correct term “type rating”. Item 3 omits each mention of “years experience” in subparagraph 66.A.30 (a) 3 and replaces them with the term “years’ experience”.
Item 4 substitutes the note under paragraph 66.A.30 (aa) to correctly refer to the Basic Practical Experience Logbook, which is the Logbook mentioned in paragraph 66.A.30 (aa).
Item 5 is a minor technical amendment. It omits “subsection 66.A.4” from the provision reference at the top of Appendix IX and replaces it with “section 66.A.4”.
Item 6 inserts the aircraft type GVIII-G700 for the GULFSTREAM AEROSPACE Corporation TC holder into Table 1 of Appendix IX. The item also inserts a new type rating endorsement “Gulfstream GVIII (RRD BR730)” for the aircraft type.
Item 7 inserts the aircraft type PC-12/47G for the PILATUS AIRCRAFT TC holder into Table 1 of Appendix X. The relevant type rating endorsement will be “Pilatus PC-12 (PWC PT6)”.
Item 8 is a minor editorial correction. It omits “(aeroplanes)” from the heading to column 2 of Table 2 in Part 2 of Appendix IX and replaces it with “(helicopters)”, which are the aircraft referred to in the table.
Item 9 inserts the aircraft type UH-60L for the PICKERING AVIATION INC TC holder into Table 2 of Part 2 of Appendix IX. The item also removes the incorrect commercial designation information for specified aircraft types of the TC holder and makes a related change to the type rating endorsement information to refer to the UH-60L.
Item 10 removes the incorrect commercial designation “GE T700(CT7)”, for specified aircraft types of the TC holder SIKORSKY AIRCRAFT, from Table 2 of Part 2 of Appendix IX.
Item 11 makes the same amendment as item 9 in relation to the PICKERING AVIATION INC TC holder, but to Table 5 of Appendix IX.
Item 12 makes the same amendment as item 10 in relation to the TC holder SIKORSKY AIRCRAFT, but to Table 5 of Appendix IX.
Legislation Act 2003 (the LA)
Under paragraph 98(5AA)(a) of the Act, an instrument issued under subsection 98(5A) is a legislative instrument for the LA if it is expressed to apply in relation to a class of persons. The Part 66 MOS is a legislative instrument as it applies to a class of persons, being aircraft engineers.
Paragraph 10(1)(d) of the LA provides that an instrument will be a legislative instrument if it includes a provision that amends or repeals another legislative instrument. This instrument amends the Part 66 MOS and is, therefore, also a legislative instrument and subject to tabling and disallowance in the Parliament under sections 38 and 42 of the LA.
Sunsetting
Part 4 of Chapter 3 of the LA (the sunsetting provisions) does not apply to the instrument, because the instrument relates to aviation safety and is made under CASR (item 15 of the table in section 12 of the Legislation (Exemptions and Other Matters) Regulation 2015).
The instrument deals with aviation safety matters that, once identified, require a risk response or treatment plan. Generally speaking, item 15, when invoked, is necessary to ensure that, in the interests of aviation safety, a relevant instrument has enduring effect, certainty and clarity for aviation operators and organisations. That is the case for the MOS itself, which is an enduring piece of aviation safety legislation.
However, the instrument is an amending instrument and, therefore, will be automatically repealed under section 48A of the LA, which will happen before the sunsetting provisions would have repealed the instrument if they had applied.
Consultation
Public consultation was conducted from 3 October 2025 to 31 October 2025 on the amendments relating to aircraft type ratings and endorsements and the minor editorial changes to be made by Schedule 1 to the instrument. This consultation was conducted together with proposed amendments to the Part 66 MOS related to allowing LAMEs to use the self-study training pathway to remove exclusions from their AEL category or subcategories (the licence exclusion removal amendments).
CASA has decided to progress the amendments to be made by the instrument separately to the licence exclusion removal amendments. This is because the amendments to be made to CASR that underpin the licence exclusion removal amendments are now expected to be made in 2026, likely as part of a broader package of miscellaneous amendments.
CASA received 17 responses to the consultation conducted, with engagement from several stakeholder groups including LAMEs, approved MTOs and AMOs.
Most comments received were in relation to the proposed amendment to CASR and the Part 66 MOS that would allow LAMEs to use the self-study training pathway to remove exclusions from their Part 66 licence.
Of the total number of responses received, 11 respondents commented on the proposed aircraft type rating changes and minor editorial matters:
- 6 respondents expressed their support of the proposed amendments to the lists of type rated aircraft under Appendix IX of the Part 66 MOS
- 1 respondent commented that the proposed type rating changes did not affect the respondent
- 4 respondents did not provide any feedback on these proposed type rating changes.
CASA is satisfied that no further consultation is appropriate or reasonably practicable for this instrument for section 17 of the LA.
Sector risk, economic and cost impact
Subsection 9A(1) of the Act states that, in exercising its powers and performing its functions, CASA must regard the safety of air navigation as the most important consideration. Subsection 9A(3) of the Act states that, subject to subsection (1), in developing and promulgating aviation safety standards under paragraph 9(1)(c), CASA must:
(a) consider the economic and cost impact on individuals, businesses and the community of the standards; and
(b) take into account the differing risks associated with different industry sectors.
The cost impact of a standard refers to the direct cost (in the sense of price or expense) which a standard would cause individuals, businesses and the community to incur. The economic impact of a standard refers to the impact a standard would have on the production, distribution and use of wealth across the economy, at the level of the individual, relevant businesses in the aviation sector, and the community more broadly. The economic impact of a standard could also include the general financial impact of that standard on different industry sectors.
The economic and cost impact of the instrument has been determined by:
(a) the identification of individuals and businesses affected by the instrument; and
(b) consideration of how the requirements to be imposed on individuals and businesses under the instrument will be different compared to existing requirements; and
(c) a valuation of the impact, in terms of direct costs on individuals and businesses affected by the instrument to comply with the different requirements. This valuation is consistent with the principles of best practice regulation of the Australian Government; and
(d) a valuation of the impact the different requirements would have on the production, distribution and use of wealth across the economy, at the level of the individual, relevant businesses in the aviation sector, and the community more broadly; and
(e) consideration of community impacts, beyond those direct impacts on individuals and businesses affected by the instrument, that are relevant if the instrument were to result in flow-on effects to other aviation businesses, or local non-aviation businesses that experience a change in their activity due to the instrument.
CASA has assessed that the economic and cost impact of the instrument is not significant. The instrument makes minor or machinery changes to an existing instrument and there will be no significant change to the economic or cost impact on individuals, businesses or the community. The Office of Impact Analysis (OIA) has also made an assessment that its impacts are unlikely to be more than minor (see below) and an Impact Analysis (IA) is not required.
The aircraft type ratings and type rating endorsement amendments made by the instrument do not substantially change existing regulatory requirements. The amendments are only relevant to:
- an aircraft operator that intends to operate a relevant aircraft type in Australia
- MTOs
- a Part 145 organisation that intends to carry out maintenance on a relevant aircraft type
- a holder of a Category B1, B2 or C AEL engaged by a Part 145 organisation that intends to carry out maintenance on a relevant aircraft type.
Before the holder of a Category B1, B2 or C AEL may exercise the holder’s privileges under the licence on an aircraft type added by the instrument, the holder must have the relevant aircraft type rating endorsed on the licence. Before the endorsement may be effected, the holder must satisfactorily complete training in relation to the aircraft type, which will involve training costs. These requirements and training costs are considered appropriate in the context of enhancing the safety of air navigation in relation to the aircraft type. These requirements will have a positive safety effect in the industry.
Impact on categories of operations
The aircraft type rating and endorsement amendments made by the instrument concern aircraft of a particular size or complexity that CASA has designated as requiring type rating and associated additional training. These amendments will have a positive and appropriate safety effect on this sector of industry as they require LAMEs who will maintain and certify maintenance performed on these aircraft to undertake aircraft-specific type training.
Impact on regional and remote communities
The aircraft type rating and endorsement amendments made by the instrument would have no negative impact on regional and remote communities, as they will only affect those operators and aircraft maintenance engineer licence holders who will operate and maintain these new aircraft types. As some of these new aircraft types are to be used for firefighting operations, they will provide a beneficial impact on regional and remote communities, who may be exposed to seasonal bushfires.
Office of Impact Analysis
An IA is not required in this case as the instrument is covered by a standing agreement between CASA and OIA under which an IA is not required for amendments to Manual of Standards as they are minor or machinery in nature (OIA id: OIA23-06250).
Statement of Compatibility with Human Rights
The Statement of Compatibility with Human Rights at Attachment 1 has been prepared in accordance with Part 3 of the Human Rights (Parliamentary Scrutiny) Act 2011.
Making and commencement
The instrument has been made by the Director of Aviation Safety, on behalf of CASA, in accordance with subsection 73(2) of the Act.
The instrument commences on the day after it is registered and is automatically repealed in accordance with section 48A of the LA.
Attachment 1
Statement of Compatibility with Human Rights
Prepared in accordance with Part 3 of the
Human Rights (Parliamentary Scrutiny) Act 2011
Part 66 Manual of Standards Amendment Instrument 2025
This legislative instrument is compatible with the human rights and freedoms
recognised or declared in the international instruments listed in section 3 of the
Human Rights (Parliamentary Scrutiny) Act 2011.
Overview of the legislative instrument
The purpose of the legislative instrument is to amend the Part 66 Manual of Standards (the Part 66 MOS) to:
- add some new aircraft types, and new type rating endorsements, to Appendix IX
- remove from Appendix IX some incorrect commercial designations for specified aircraft types
- make some minor corrections or machinery-type changes to provisions.
Appendix IX of the Part 66 MOS deals with type rated aircraft types and type rating endorsements for Category B1, B2 or C aircraft engineer licences.
The amendments will ensure that licensed aircraft maintenance engineers (LAMEs) undertake specific type training in order to maintain and certify maintenance performed on the new aircraft types.
Human rights implications
The instrument is compatible with the human rights and freedoms recognised or declared in the international instruments listed in section 3 of the Human Rights (Parliamentary Scrutiny) Act 2011.
The instrument engages in a positive way with the right to work in Article 6 of the International Covenant on Economic, Social and Cultural Rights by facilitating the performance by LAMEs of maintenance work relating to the new aircraft type ratings added to the Part 66 MOS. Persons working at a maintenance training organisation (MTO) may also benefit from the delivery by the MTO of the required training to obtain the relevant type rating endorsement if a maintenance organisation requests the MTO deliver the training and it is approved by CASA.
The instrument promotes the right to life in Article 6 of the International Covenant on Civil and Political Rights by protecting aviation safety by ensuring that type rated Australian aircraft are maintained by LAMEs who have met the relevant Australian training standards and requirements administered by CASA.
Conclusion
This legislative instrument is compatible with human rights.
Civil Aviation Safety Authority