Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
Annex B
Consolidated Summary of Comments / Responses received,
CASA’s Response and Disposition Actions to NPRM 1101CS
Document NFRM 1101CS
Page B1
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
INTENTIONALLY LEFT BLANK
Document NFRM 1101CS
Page B2
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
Comments relating to the proposed amendments to
CAOs 100.5, 108.56 and the cancellation of
AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
(Issued under NPRM 1101CS)
NOTE: Most of the comments included below are in the original form submitted by the
respondents.
General Comments
COMMENT 1 – Keep all the requirements in the AD format
A number of respondents have stated that all the Key Proposals are not acceptable under any
circumstance as it would be better to leave the requirement in AD format. Placing it within the
CAO would result in the requirements being ignored.
CASA’s Response
CASA notes the general comments. The obligation to comply with the CAO will be
reinforced.
Disposition
No change.
Document NFRM 1101CS
Page B3
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
Key Proposal 1: FAR 43 Appendix E would be identified in
CAO 100.5 as the sole standard to be used for the calibration
of barometric altimeters
There were 55 respondents with 7 offering no comment to this proposal. The breakup is depicted
in Figure 1.
Not acceptable under
any circumstances
4%
Not acceptable but
would be acceptable if
changed
18%
No comment
13%
Acceptable without
change
54%
Acceptable, changes
would improve it
11%
Figure 1: Distribution of Comments for Key Proposal 1
COMMENT 2 – Altimeter standard
Respondent stated that: FAR 43 Appendix E is an American (FAA) standard, this standard is not
used to certify for the calibration of barometric altimeters in Europe, this leaves (LAME's) with a
problem when re install barometric altimeters that are received new or repaired in Europe for
installation in Australian aircraft, that the maintenance / manufacture is not certified to an
approved Australian standard (FAR 43 Appendix E) although no doubt the European standard is
equivalent to the FAA standard.
CASA’s Response
CASA disagrees with the response. FAA FAR 43 Appendix E, TSO-C10b and EASA ETSOC10b are all based on SAE AS392C. This document, originally published on 8 January
1947 and subsequently revised, is the current international standard for pressure actuated,
sensitive type aircraft altimeters. However, to minimise potential issues CASA will include
the test requirements as an Appendix to CAO 100.5 and amend the proposal to allow
equivalent standards from the recognised countries identified in Regulation 21.012 of
CASR.
Disposition
CASA has included the test requirements as an Appendix to the amended CAO 100.5. Proposed
CAO 100.5 has also been amended to recognise test standards from the recognised National
Airworthiness Authorities listed in Regulation 21.012 of CASR.
Document NFRM 1101CS
Page B4
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 3 – Tests in aircraft
Respondent stated: Delete that the tests can be carried out in the aircraft as it is not possible to
carry out all the tests associated with FAR 43 App E while the instrument is installed in the
aircraft. Reading FAR 43 Appendix E would have helped as if this was read the consultant would
have known that FAR 43 Appendix E is not possible to achieve while still connected to the pitot
static system and with no vibrator available. Also if these instruments are working all the time how is wear to be assessed without opening?
CASA’s Response
CASA disagrees with the response. If there is sufficient wear to affect the performance of
the altimeter then it should be detected during the testing program and either repaired or
replaced.
Disposition
Refer to CASA’s Disposition to Comment 2 above.
COMMENT 4 – Acceptable test procedures
Respondent stated: FAR 43 currently requires that altimeters be sent to an approved calibration
service, IE not on aircraft. Acceptable test equipment for on aircraft testing for VFR aircraft
needs to be affordable, not a $60000 test set. The current AD/INST/8 Req 2 (3 yr req) is quite
achievable now to the point that we opt to do it at 2 yr interval to coincide with the RAD 43 &
47, so we have no problem with the proposed intervals but want to ensure we can still do it
without requiring prohibitively expensive test equipment.
CASA’s Response
CASA disagrees with the response. Any test equipment that is required to be used to
perform such tests needed to verify the serviceability of the instruments being tested must
be suited to that task. The decision as to which particular type of test equipment is
appropriate will be dependent on requirements of the maintenance facility.
Disposition
Refer to CASA’s Disposition to Comment 2 above.
COMMENT 5 – Use of manufacturer’s test procedures
Respondent stated: Respondent removes altimeters and air data computers and send to a repair
facility for calibration. This is done per the altimeter / ADC manufacturer's Component
Maintenance Manual (CMM) which is equivalent to FAR 43 Appendix E. Suggest the
requirement should be that the calibration procedure and tolerance is as required by the
equipment manufacturer - in any case not to exceed the tolerances specified in FAR 43 Appendix
E. An Advisory Circular or CAAP should be produced in conjunction with the CAO to explain
exactly what is required.
CASA’s Response
CASA agrees with the response. The intent of the proposal is to ensure that, where
maintenance data for the instruments in question are missing or deficient, the amended
CAO will provide the minimum standard for the maintenance to be conducted.
Document NFRM 1101CS
Page B5
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
Disposition
No change.
COMMENT 6 – Retain existing provisions for VFR
Respondent stated: The provisions for testing Altimeters in CAO 108.56 para 3.2 should be
retained for aircraft not fitted with a transponder that are operated under VFR. There are many
Vintage and Sports aircraft that are only flown VFR and OCTA (and do not have transponders
fitted) and the Altimeters fitted to many of these aircraft were not designed to meet the accuracy
required by FAR 43 Appendix E.
CASA’s Response
CASA does not accept the continuance of two standards for aircraft operating in the same
airspace. The intent of NPRM 1101CS was to reduce the risk of loss of separation due to
aircraft utilising equipment calibrated to different standards. As stated in CASA’s Response
to Comment 2, SAE AS392C is the internationally accepted design standard for altimeters
having been originally published on 8 January 1947. The test parameters have not
changed.
Disposition
No change.
COMMENT 7 – Primary altimeter
Respondent stated: It should be clarified that only the primary altimeter is required to be tested
for Class B aircraft. Many warbird and vintage aircraft have instruments in two separate cockpits
(or both sides of the panel) left over from their military training roles. These aircraft are single
pilot and can usually only be flown 'in command' from one seat or cockpit, but the duplicate
instruments are retained for originality. The wording in para 2.1 of the proposed CAO 100.5 The
pressure altimeters installed in aircraft must be tested could give rise to an interpretation that
instruments other than those required to be fitted must also be tested. This conflicts with current
practice, supported by CASA Ruling 1/2004. An example of cost impact if these changes were
not made: a DH-82A Tigermoth, Day VFR, no electrical system and possibly no radio. Command
from rear cockpit only. Both altimeters would need to be replaced with 'modern' altimeters
designed to meet the test requirements of FAR 43 Appendix E at a cost of approx $1500 per
altimeter ($3000 initial cost). Re-test every 2 years to FAR 43 Appendix E would be $120 per
altimeter ($240 every 2 years) in addition to the pitot static test.
CASA’s Response
CASA accepts the need to clarify the application of the proposal to non-required
equipment. The additional equipment fitted over and above the requirements detailed in
Paragraphs 3 and 4 of CAO 20.18 do not have to be maintained but they must be placarded
appropriately. It is worth noting that Aviation Ruling 1/2004 is only applicable to charter
and RPT operations.
Disposition
CASA has amended the proposed CAO 100.5.
Document NFRM 1101CS
Page B6
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 8 – Testing in-situ
Respondent stated: Testing to FAR 43 Appendix E is not possible 'in situ' so there would be
downtime and freight costs involved as well. At present the primary (and usually the secondary as
well) altimeter would be tested in-situ with a suitable pitot static test set, also testing the ASI and
the pitot static system, to CAO 108.56 with no additional cost unless rectification is required.
CASA’s Response
Refer to CASA’s Response to Comment 2.
Disposition
Refer to CASA’s Disposition to Comment 2 above.
COMMENT 9 – Increased cost for VFR operators
Respondent stated: Our company policy is to carry out all Altimeter checks I.A.W. Manufacturers
specifications or FAR Part 43 Appendix E if not specified by manufacturer. No nett change to our
operations or testing of IFR or VFR aircraft Instruments. However; if VFR instruments are tested
to FAR Part 43 for all aircraft the cost will increase to VFR aircraft owners as they most likely
won't meet specification.
Furthermore; if new instrumentation designed to meet RVSM specifications is present in aircraft
those tolerances are going to exceed the limitations of FAR Part 43 Appendix E for Scale Error.
Manufacturer’s specs should be considered first, then FAR Part 43 Appendix E as a backup if
none exist. There will still be a mismatch of specs used and no improvement to safety unless
owners of VFR aircraft always agree to having an Altimeter within the FAR specs.
CASA’s Response
CASA disagrees in part with the response. There has only been one standard to altimeter
manufacture and this standard, SAE AS392C, was drafted in 1947. If altimeters cannot
meet the standard then they are considered unserviceable. CASA accepts the
manufacturer’s specification if it is detailed in the aircraft’s approved system of
maintenance or maintenance schedule. RVSM does not require altimeters to meet more
stringent requirements. The RVSM airworthiness standards are intended to minimise
altimetry system errors by ensuring the static system is maintained in accordance with
approved data. CAAP 181A-1(2 refers).
Disposition
No change.
Document NFRM 1101CS
Page B7
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 10 – Barometric scale units
Respondent stated: Far 43 App E only has inches of mercury pressure references Maybe add a
note showing Millibar equivalent to 29.92.
CASA’s Response
CASA agrees with the response.
Disposition
Refer to CASA’s Disposition to Comment 2 above.
COMMENT 11 – Altimeters not capable of being calibrated
Respondent stated: Many aircraft Jabiru etc are factory fitted with Chinese altimeters that are not
capable of being calibrated iaw FAR 43 APP E. If these aircraft are operated outside controlled
airspace I believe the tolerances as called up in CAO 108.56 for AD'S INST/8 AND INST/39 are
acceptable. Aircraft operating inside controlled airspace should have their altimeters calibrated
iaw FAR 43 APP E. Estimated cost to replace non-compliant altimeter is $1000-$2000.
CASA’s Response:
CASA does not accept the continuance of two standards for aircraft operating in the same
airspace. Refer to CASA’s Response to Comment 6.
Disposition
No change.
COMMENT 12 – Use of self-sealing couplings
Respondent stated: Paragraph 1.2(b) should consider as required by the manufacturer where
modern self-sealing couplings are used on LRUs, though must require flight verification of no
split before entering RVSM.
CASA’s Response
CASA disagrees with the response. Self-sealing couplings can deteriorate over time and
when disconnected and reconnected may leak. The pitot static leak check is to confirm the
integrity of the system following maintenance action.
Disposition
No change.
COMMENT 13 – Clarification of test requirements
Respondent stated: Clarify if the altimeter test requirement is all of Appendix E or is it just for
para (b) Appendix E. It should be specific, and list Appendix E para (a, b, c) etc.
CASA’s Response
CASA agrees with the response.
Document NFRM 1101CS
Page B8
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
Disposition
Refer to CASA’s Disposition to Comment 2 above.
COMMENT 14 – Calibration in situ
Respondent stated: CAO 100.5 must include clear reference to allow for the calibration of
altimeters whilst fitted to the aircraft provided that appropriate test equipment is available. FAR
43 App E (b)(1) call for test by ‘an appropriately rated repair facility’. This statement does not
transfer directly to CASA terminology and has led to individual interpretation within both the
industry and CASA. A CAR30 (or pt145) maintenance organization with appropriate approvals
and equipment must be able to test the altimeter whilst fitted to the aircraft.
CASA’s Response
CASA agrees with the response.
Disposition
Refer to CASA’s Disposition to Comment 2 above.
COMMENT 15 – Electronic displays
Respondent stated: Newer general aviation (class B) aircraft have sophisticated integrated
avionics systems where altimetry information is displayed on electronic screens as opposed to
individual indicators. CAO 100.5 should consider calibration of such systems where information
displayed is provided by Blind Encoders or Air Data Computers/Systems. High end systems
provided by the likes of Honeywell and Rockwell Collins have detailed systems manuals that
define the OEM’s maintenance requirements for continuing airworthiness. This may not be
clearly defined by STC installed systems.
CASA’s Response
CASA agrees in part with the response. The electronic displays do not require calibration
as they only display the data provided. Blind encoders are dealt with in Attachment 1 to
Appendix 2 to CAO 100.5. Air data computers are covered by SAE AS 8002 dated 1981. If
the aircraft’s system of maintenance or maintenance schedule does not identify the
manufacturer’s maintenance requirements then you would be required to comply with the
amended CAO.
Disposition
CASA has amended CAO 100.5 to incorporate reference to air data computers.
Document NFRM 1101CS
Page B9
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 16 – Current practice
Respondent stated: This may improve safety, but VFR aircraft Altimeters are maintained by our
organisation to FAR Part 43 Appendix E and have for 14 years, no change in safety or flight level
separation in regard to our customers.
CASA’s Response
CASA agrees with the response.
Disposition
No change.
Key Proposal 2: The standard used for the calibration of
barometric altimeters would be deleted from CAO 108.56
Paragraph 3.2 and included in CAO 100.5
There were 55 respondents with 10 offering no comment to this proposal. The breakup is
depicted in Figure 2.
No comment
18%
Acceptable without
change
60%
Not acceptable under
any circumstances
2%
Not acceptable but
would be acceptable if
changed
16%
Acceptable, changes
would improve it
4%
Figure 2: Distribution of Comments for Key Proposal 2
COMMENT 17 – Alternative standard
Respondent stated: The standard specified in CAO 100.5 should be the manufacturer's CMM, in
any case the tolerances not to exceed FAR 43 Appendix E.
We do not agree that calibration should be every 2 years. The requirements of the MRBR for the
aircraft should determine the period for calibration, as this is based on reliability and operational
experience. The requirement should not apply to standby altimeters.
An Advisory Circular or CAAP should be produced in conjunction with the CAO to explain
exactly what is required - including advice on what is required for air data computers and
altimeters with electronic circuits rather than mechanical linkage.
Document NFRM 1101CS
Page B10
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
CASA’s Response
CASA agrees in part with the response. An aircraft that has a maintenance program
derived using MSG-3 or MRBR processes will not be required to comply with the
requirements detailed in CAO 100.5.
Disposition
CASA has amended CAO 100.5 to clarify the applicability of aircraft being maintained to
existing maintenance programs.
COMMENT 18 – Retention of existing standard for VFR
Respondent stated: If the content of CAO 108.56 para 3.2 is retained in its entirety and can be
elected to be used for the calibration of altimeters in aircraft not transponder equipped operated
under the VFR, this would be acceptable.
CASA Response
CASA does not accept the continuance of two standards for aircraft operating in the same
airspace. Refer to CASA’s Response to Comment 6.
Disposition
No change.
COMMENT 19 – Clarification of terminology
Respondent stated: I can't see that moving the specs from one CAO to another is better in this
case. Note(2) What is deemed appropriate test equipment? Should it be Calibrated or Approved ?
Does this still mean an Altimeter with a hand pump and static line attached? Some form of
RVSM compliant test set is required if safety is to be improved here.
CASA Response
CASA does not agree with the response. The consolidation of the various existing CAOs
and ADs into a single location with explicit requirements will ensure clarity of
requirements and consistency of interpretation. Due to the diversity of makes and models of
test equipment capable of performing the tests required the maintenance facility will need
to determine what particular unit is best suited to their needs.
The test equipment will need to be of a suitable standard and maintained on a regular
basis.
Disposition
No change.
Document NFRM 1101CS
Page B11
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 20 – Maintain the different standards
Respondent stated: Would be ok provided the above allowance was provided for aircraft
operating outside controlled airspace.
CASA Response
CASA does not agree with the response. Operations outside controlled airspace depend on
individual aircraft’s knowledge of its own position to be able to identify potential
separation issues. Having different standards that allow different error tolerances
increases the potential for loss of separation. Refer to CASA’s Response to Comment 6.
Disposition
No change.
COMMENT 21 – Moving the requirements
Respondent stated: It's just moving one set of instructions from one CAO to another. This will not
improve safety.
CASA Response
CASA does not agree with the response. Refer to CASA’s Response to Comment 1.
Disposition
No change.
Document NFRM 1101CS
Page B12
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
Key Proposal 3: AD/INST/8 Amdt 4 and AD/INST/9 Amdt 6
would be cancelled with the intent of the ADs included into
CAO 100.5.
There were 55 respondents with 8 providing no comment to this proposal. The breakup is
depicted in Figure 3.
No comment
18%
Not acceptable under
any circumstances
5%
Acceptable without
change
42%
Not acceptable but
would be acceptable if
changed
21%
Acceptable, changes
would improve it
14%
Figure 3: Distribution of Comments for Key Proposal 3
COMMENT 22 – Maintenance of AD format
Respondent stated: Taking away the AD's is dangerous on two levels. General Aviation Avionics
organisations have had a long standing battle to educate and convince C of R holders, operators
and owners that the requirements of the AD's for instruments is mandatory and the options
presented (requirements 1 & 2) have always created confusion and mismatched interpretations.
Having the requirement in a CAO (100.5) would bury the instructions further into the regulations,
make it harder for maintainers to monitor and advise owner/ operators that the periodic testing of
instruments is MANDATORY. I can not see that the owners, C of R holders & Operators will
comply with the CAO ahead of an AD, Will the endorsement of the CAO 100.5 on an MR stop
an aircraft flying or will the pilot understand this instruction as per the current Mandatory AD
instructions? Will the CAO100.5 outline the ongoing continuing maintenance of this instruction
to inspect instruments?
CASA’s Response
CASA does not agree with the response. The obligations for an operator to comply with the
regulations do not differ between a CAO or an AD made under Part 39 of CASR.
Disposition
No change.
Document NFRM 1101CS
Page B13
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 23 – General
Respondent stated: JUST AMMEND THEM TO BE ACCURATE.
CASA’s Response
CASA notes the response.
Disposition
No change.
COMMENT 24 – Alternative Systems of maintenance
Respondent stated: AD/INST/9 requirements relocated into CAO 100.5 should only apply to
aircraft that do not have an approved System of Maintenance (SOM). The SOM should address
instrument calibration requirements based on the MRBR for the aircraft (or manufacturer's
recommendations if there is no MRBR for the aircraft). Instrument calibration requirements and
periods should be as per the SOM - based on equipment reliability and operational experience.
CASA’s Response
CASA agrees in part with the response. Refer to CASA’s Response to Comment 17. The
intent of ADs will be incorporated into the amended CAO 100.5.
Disposition
Refer to CASA’s Disposition to Comment 17 above.
COMMENT 25 – Sourcing of technical data
Respondent stated: As an instrument workshop, we are finding it harder and harder to obtain
Technical Data from Manufacturers overseas. Often we try to obtain current data from Operators,
but they are also faced with the same problem. We are constantly getting told to return the gauge
to a facility on the other side of the world. This is impractical and causes a lot of delay in
returning an otherwise serviceable unit back into the aircraft and comes at a great cost to the end
user. I believe that something needs to be done to enforce companies to release Test Only Data to
Operators for this to work. This is particularly the case with Fuel Qty Indicators.
CASA’s Response
CASA notes the response. Whilst CASA is sympathetic these are commercial issues and
decisions are being made for commercial advantage.
Disposition
No change.
Document NFRM 1101CS
Page B14
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 26 – Maintain current ADs
Respondent stated: There is no point expressing the instructions as intended content. C of R
holders will mostly interpret the instructions differently to CASA and maintainers. The CAO will
not be considered powerful enough to ground an aircraft if not complied with. An outstanding
AD endorsed on a Maintenance Release does / will. This will not improve safety at all.
CASA’s Response
CASA does not agree with the response. Refer to CASA’s Response to Comment 1.
Disposition
No change.
COMMENT 27 – Maintaining existing standard for VFR
Respondent stated: VFR aircraft not transponder equipped should continue to be able to elect to
use CAO 108.56 para 3.2 for calibration of Altimeters, otherwise acceptable.
CASA’s Response
CASA does not accept the continuance of two standards for aircraft operating in the same
airspace. Refer to CASA’s Response to Comment 6.
Disposition
No change.
COMMENT 28 –Safety concern
Respondent stated: I commend CASA for finally making changes to what is a significant safety
concern. There are a lot of very unsafe aircraft flying at the moment with instrumentation that has
not been tested properly due to the confusion surrounding these AD's. Aircraft owners and
operators are choosing requirement one regardless of what is in their system of maintenance. This
has lead to instruments that are often out of calibration and is putting lives at risk.
CASA’s Response
CASA notes the response.
Disposition
No change.
COMMENT 29 –Fuel Gauge
Respondent stated: As the NPRM states, there have been accidents attributed to fuel gauges that
are out of calibration. I believe under the current system that more accidents are coming due to
poor instrumentation condition and these accidents won’t be limited to just fuel problems.
CASA’s Response
CASA notes the response.
Document NFRM 1101CS
Page B15
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
Disposition
No change.
COMMENT 30 – Removal of ADs
Removing the AD's poses a problem. The AD's were originally introduced to deal with the fact
that owners and operators were not maintaining their instrument systems properly. I believe there
were accidents at the time due to poor maintenance so the AD's were introduced to deal with this.
Removing the AD's and putting the information back into regulation will mean that owners and
operators will once again ignore what is required.
CASA’s Response
CASA does not agree with the response. ADs are intended to correct a design deficiency
and not address a maintenance issue.
Disposition
No change.
COMMENT 31 – Enforcement
Respondent stated: If you want to have safe aircraft again CASA will have to ensure there is
strong enforcement action to support the regulation. CASA will also have to train your own field
staff to ensure compliance. There are currently AWI's that actively tell owners and operators not
to do maintenance on their instrument systems, this issue will have to be addressed.
CASA’s Response
CASA notes the response.
Disposition
No change.
COMMENT 32 – Calibration intervals
Respondent stated: The NPRM is stating that fuel instruments will only have to calibrated every 5
years. The current system requires 3 years. Considering the fact fuel calibration has been
implicated in some accidents already I find 5 years to be a very strange period. Fuel calibration
must be done every 3 years. We find many systems out of calibration when we do the AD's, 5
years is too long.
CASA’s Response
CASA has reviewed the requirement in light of the comments received. The general opinion
is that the interval should be 48 months. CASA agrees that this interval is appropriate.
Disposition
CASA reviewed the proposed CAO 100.5 and amended the interval for fuel system calibration
interval to 48 months.
Document NFRM 1101CS
Page B16
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 33 – Broadening scope
Respondent stated: Your NPRM does not go far enough. You have not covered off on the rest of
the instrumentation. What about torque, MAP, etc, etc? What about AH, DG etc? All of these
instruments are being ignored currently, how long before they start being implicated in accidents.
Current aircraft SOM's are often deficient for avionics.
CASA’s Response
CASA has noted the response.
Disposition
No change.
COMMENT 34 – Auditing of delegates
Respondent stated: The delegate’s or AWI's who are approving the systems need to be audited as
they are currently often getting it very wrong and are only interested in saving money and are not
interested in keeping aircraft safe.
CASA’s Response
CASA has noted the response.
Disposition
No change.
COMMENT 35 – In-situ testing of altimeters
Respondent stated: In situ altimeter checks are not possible. You cannot do FAR 43 altimeter
checks correctly in the aircraft. You can only fully comply by doing the check on the bench.
CASA’s Response
CASA disagrees with the response.. In-situ testing is possible in some circumstances.
Disposition
Refer to CASA’s Disposition to Comment 2.
COMMENT 36 – Tracking of compliance
Respondent stated: In forcing the requirements to carry out the two yearly testing of
Transponder/Altimeters will be very hard as we will rely on the owners or B1 engineers for
smaller a/c to track and request this to be done, a good example would be the current AD/INST/9
in which CASA has totally failed two enforce Req 2 to be carried out on a/c where the system of
maintenance does not cover the instruments and as per the AC CASA issued requires that you
elect to do Req 2 not requirement 1. We look after about 200 GA a/c and I think we are one of the
few c/o Req 2 and still have many arguments with B1 maintenance company’s and owners.
Document NFRM 1101CS
Page B17
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
CASA’s Response
CASA does not agree with the response. The requirements are to be done on a regular
basis that has a finite interval. The responsibility for planning the maintenance is vested in
the operator of the aircraft. A B1 licensed engineer can only perform replacement of
avionic line replaceable units where simple tests are required to prove its serviceability. A
B2 licensed engineer has full avionics privileges.
Disposition
No change.
COMMENT 37 – Cross referencing
Respondent stated: I believe that there is a valid case for the standard as per AD/INST 8 and
AD/INST/39. Should this not occur then many altimeters would have to be replaced?
CASA’s Response
CASA notes the response. AD/INST/39 was published in 1996 and since then there have
been 5 reported instances of defective altimeters, the latest being in 2000. AD/INST/39 will
be cancelled and the requirements of the amended CAO 100.5 will apply to all altimeters.
Disposition
CASA will cancel AD/INST/39.
COMMENT 38 – Maintenance of other instruments
Respondent stated: Please flag in the revised CAO 100.5 of the need to ensure that other
instruments (aside from those noted in CAO 20.18) are maintained to AC manufacturer
requirements.
CASA’s Response
CASA agrees with the response. Requirements for maintenance of any aircraft components
are mandated by Regulation 39 of CAR (class A) and Regulation 41of CAR (class B).
Disposition
CASA has included the requirement to maintain other instruments to approved maintenance
programs in the amended CAO 100.5.
COMMENT 39 – Maintenance of other instruments
Respondent stated: The proposed amendment to CAO 100.5 [ANNEX A of the NPRM]Does not
mention the compass checks as reqd in the AD/INST/8 Amdt 3and does not mention the Testing
of All the Aircraft's Instruments as required in AD/INST 9 Amdt 5. I believe INST 8 AMDT 4
and INST 9 Amdt 6 should never have been issued, it made a mockery of the intent of the
original AD's and gave aircraft owners the feeling that they didn't ever have to check any other
instruments, just do the altimeter each 2 years. I would prefer that both INST AD'S remain, but
correct the wording to reflect the real requirements, however if you wish to drop them and hide
them in CAO 100.5 you had better spell out the full requirement in 100.5.
Document NFRM 1101CS
Page B18
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
CASA’s Response
CASA notes the response.
Disposition
No change.
COMMENT 40 – Retain ADs
Respondent stated: From a maintainer's and pilot's point of view, I think it would be better to
retain and amend the AD's concerned as people directly involved in the changes, ie pilots and
maintainers, are familiar with them. It is less ambiguous and more instructive to list an AD in a
work package or on an MR than to list bits and pieces of a CAO, depending on applicability. It is
also simpler to concisely convey maintenance carried out in a logbook entry. There is also less
scope for people to get confused when carrying out the required maintenance. Call me old
fashioned, but having this type of action which applies across the board listed in one place (list of
Australian AD's) is worthwhile.
CASA’s Response
CASA does not agree with the response. Refer to CASA’s Response to Comment 1.
Disposition
No change.
COMMENT 41 – Clarification of wording
Respondent stated: The intent of confirming the calibration of instruments must be clearly
worded. There appears no draft for these words in the draft 100.5.A Ref to all the instruments
required for an aircraft to operate either by 20:18, flight manual etc for these to be maintained checked etc.
CASA’s Response
CASA notes the response.
Disposition
No change.
COMMENT 42 – Lack of compliance action by CASA
Respondent stated: While we support the concept of cancelling the ADs and moving the content
into CAO 100.5, AEA is concerned that the situation that led to the lack of compliance with the
original regulatory requirements have not been completely resolved and without focused effort on
the part of CASA, aircraft owners may again opt not to have this vital inspections accomplished.
The association encourages CASA to amend internal documents to instruct field inspectors to
include these inspection items in their audit checklists.
CASA’s Response
CASA notes the response.
Document NFRM 1101CS
Page B19
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
Disposition
No change.
Key Proposal 4: AD/RAD/43 would be cancelled following the
incorporation
of
the
repetitive
requirements,
with
applicability extended to all aircraft fitted with active Mode
C transponders, into CAO 100.5
There were 55 respondents with 9 providing no comment to this proposal. The breakup is
depicted in Figure 4.
No comment
16%
Not acceptable under
any circumstances
6%
Not acceptable but
would be acceptable if
changed
16%
Acceptable without
change
53%
Acceptable, changes
would improve it
9%
Figure 4: Distribution of Comments for Key Proposal 4
COMMENT 43 – Retaining AD format
Respondent stated: Without an approved System of Maintenance to reference the specific
requirements to test instruments periodically, I can see that compliance of this instruction in the
AD will not continue as accurately as if it were a Directive from CASA. The changes as proposed
are allowing all classes of aircraft NOT to have a SOM and to fall back on wider times between
instrument checks. No improvement to safety in these changes.
CASA’s Response
CASA does not agree with the response. See CASA’s Response to Comment 1.
Disposition
No change.
Document NFRM 1101CS
Page B20
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 44 – Calibration in-situ
Respondent stated: Must be done in a workshop environment.
CASA’s Response
CASA does not agree with the response. Automatic Pressure Altitude Reporting Equipment
and ATC Transponder System Integration Test may be performed in-situ with equipment
installed in the aircraft. Refer to CASA’s Response to Comment 2.
Disposition:
No change.
COMMENT 45 – Alternative standards
Respondent stated: The requirements in 100.5 should be changed to either:
Option 1, remove para 2.6. as the basis of Rad/43 was FAR43 Appendix E(c) which clearly
intends to test the whole reporting system, altimeter, encoder and transponder, regardless of the
system set up. Even where the encoding is contained within a single unit, the encoding can differ
from the indicated alt and mode C display.
OR
Option 2 instead of deleting para 2.6 change the ref in 2.6 that refers to the requirement in 2.3 to
read requirement in 2.5.Additionally the check is 2.4 (a) (b) of 100.5 should read ref to 2.1 for
pressure altimeters .Sub para 2.4 (b) appears to remove the requirement from testing the
integrated system to confirm the correspondence of indicated and transmitted altitude. Delete
para 2.4(b).
CASA’s Response
CASA agrees with the response. The text in Mode C correspondence checks may be seen as
ambiguous.
Disposition
CASA has amended CAO 100.5 Para 2.6 (now Para 4.8) to better explain the requirements.
COMMENT 46 – Guidance material for maintenance data
Respondent stated: Altimeter and transponder correspondence checks should be as per the MRBR
for the aircraft (or manufacturer's recommendations if there is no MRBR). An AC or CAAP
should be produced to provide guidance as to the circumstances when correspondence checks are
required - as not all equipment changes affect correspondence. Wording of proposed CAO is not
very clear for aircraft that have a SOM, for aircraft that do not have mechanical pressure /
barometric altimeters, for air data computer systems, for standby altimeters. Maintenance
requirements should be based on equipment reliability and operational experience - as specified
in the MRBR.
Document NFRM 1101CS
Page B21
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
CASA’s Response
CASA agrees in part with the response.
Disposition
CASA has amended CAO 100.5 to clarify which aircraft are exempted from these requirements.
COMMENT 47 – Availability of LAME
Respondent stated: AD/RAD/43 was last modified because due to shortage of radio LAMEs. It is
not practically or economically possible to be carried out by many maintenance organizations in
rural areas. Many aircraft in these areas do not go into controlled airspace ever. I believe the
maintenance release on these aircraft should be endorsed not to be flown in controlled airspace
until AD/RAD/43 complied with. My preferred option would be to allow an airframe or
instrument rated LAME with the appropriate transponder tester to carry out the mode c
calibration and adjustment as the blind encoder adjustments are very simple to make and the
engineer is dealing with the aircraft static system. Prior to AD/RAD 43 being altered last time I
had to obtain some 35 plus engineering orders to disable transponders at great expense to the
owners, also denying RFDS and other aircraft fitted with TCAS the added safety of flying
through station country knowing if an aircraft was flying locally. I fully realize the advantages of
having Mode C check calibrated but it must be catered for in a practical, cost effective and
achievable manner.
CASA’s Response
CASA disagrees with the response. CASA believes that the operator of the aircraft has
sufficient notice of the scheduled maintenance to make the appropriate arrangements.
Disposition
No change.
COMMENT 48– Applicability of Mode C checks.
Respondent stated: AD/RAD/43 requirements should apply to all aircraft with active Mode C
transponders, not just IFR operating in CTA, otherwise from a system integrity perspective all
non-IFR aircraft in CTA and all IFR OCTA replies should have the Mode C inhibited in the SSR
operator display, since only IFR aircraft in CTA Mode C replies could be 'trusted'. Potentially
there maybe some scope for relaxation of the testing requirements for ATC transponders that
display the altitude, or FL. If this functionality was actually used by the pilot, the pilot could
cross-check between their ALT after allowing for the sub-scale offset.
CASA’s Response
CASA agrees with the response. CAO 100.5 will apply the testing requirements of
AD/RAD/43 to all aircraft fitted with altitude reporting equipment.
Disposition
No change.
Document NFRM 1101CS
Page B22
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 45 – Enforcement of CAO requirements
Respondent stated: How are maintainers and maintenance controllers going to enforce the
compliance with the CAO the same as with the current AD's endorsed on an MR? If the CAO
100.5 sections for this test are moved from the AD, the tests and instructions haven't changed,
just moved out of an AD. This will not improve safety, in fact the confusion with CofR holders
will continue, the pressure on maintainers to educate them and then become stressed over
belligerent owner/operators with financial issues will not improve safety.
CASA’s Response
CASA disagrees with the response. See CASA’s Response to Comment 22.
Disposition
No change.
COMMENT 50 – Compliance enforcement
Respondent stated: As above CASA will have to enforce compliance. Don’t expect LAME's to be
your police on this issue. You will have to ensure operator compliance, they won’t listen to us.
CASA’s Response
CASA notes the response.
Disposition
No change.
Document NFRM 1101CS
Page B23
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
Key Proposal 5: Operators would be required to ensure that
there are appropriate instructions and data for the ongoing
verification of instrument accuracy and the integrity of the
associated instrument systems
There were 55 respondents with 11 providing no comment to this proposal. The breakup is
depicted in Figure 3.
No comment
20%
Acceptable without
change
43%
Not acceptable under
any circumstances
4%
Not acceptable but
would be acceptable if
changed
22%
Acceptable, changes
would improve it
11%
Figure 5: Distribution of Comments for Key Proposal 5
COMMENT 51 – Maintenance data
Respondent stated: A basic standard is required to be defined within the required regulation as
many GA aircraft manufacturers (and instrument manufacturers) do not have appropriate
maintenance instructions or data available. Aircraft maintained under a manufacturers system of
maintenance (late model aircraft) generally have sufficient instructions however older aircraft
maintained under schedule 5 require a basic guideline for pitot/static systems and instruments,
compasses and fuel gauges. The rest of the instruments should be on condition.
CASA’s Response
CASA agrees with the response. If no appropriate maintenance instructions are available
then CAO 100.5 is to be used.
Disposition
No change.
COMMENT 50 – Log Book Statements
Respondent stated: If you leave it to the operator/owners it won’t happen. It would be better if the
a/c Log Book statements are required to reflect these requirements, also CASA should have to
approval/accept LBS as currently the maintenance companies print them out and stick them in the
log book and that’s the end of the process.
Document NFRM 1101CS
Page B24
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
CASA’s Response
CASA agrees with the response. There is no issue with making reference to the
requirements detailed in the CAO in aircraft log books. Operators need to be aware of any
changes that may take place with CAO, if they quote the contents of the CAO in the aircraft
logs.
Disposition
No change.
COMMENT 53 – Inclusion of additional systems
Respondent stated: Recommend consideration be given to the inclusion of compass system and
perhaps gyroscopic instrument maintenance into CAO 100.5, as Instructions for Continued
Airworthiness are typically lacking in these areas for older GA type aircraft.
CASA’s Response
CASA notes the response.
Disposition
No change.
COMMENT 54 – Unclear intent of proposal
Respondent stated: The wording of the proposed CAO does not clearly indicate the intent of this
proposal. An aircraft SOM based on an MRBR for the aircraft type does not require all
instruments to be calibrated. The SOM will indicate those that do require calibration at a
specified period - the others are calibrated when their performance suggests calibration is
required. If the SOM clearly states that all MRBR requirements are to be complied with then
there should be no need to repeat what those requirements are in the SOM. The MRBR
requirements are usually expressed in the Maintenance Planning Document and in a large number
of individual task cards. The proposed CAO wording suggests all the information needs to be in
the SOM rather than in documents referenced in the SOM. An AC or CAAP is needed to explain
what is required for aircraft with a SOM and the CAO wording should allow some flexibility with
respect to what maintenance the SOM specifies and when it is to be carried out. This proposal
will require all existing SOM's to be revised to address the CAO 100.5 requirements, at
considerable expense to the industry.
CASA’s Response
CASA disagrees with the response. If the SOM references the appropriate data there is no
requirement to incorporate that detail into the SOM.
Disposition
No change.
Document NFRM 1101CS
Page B25
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 55 – Compliance
Respondent stated: The only way operators and C of R holders will comply with these
instructions is if the Systems of Maintenance for each aircraft type are stated in the Log Book
Statement as they are now. However, instead of Schedule 5 for Instruments, then a type
certificate schedule of Instrument maintenance needs to be established, in detail, prior to aircraft
attaining a C of A or for current aircraft registered in Australia, prior to exiting their next
scheduled maintenance (periodic/100hrs) and make it mandatory as an AD for all aircraft to
comply. The requirement for appropriate instructions needs to be very, very clear, not open to
interpretation by C of R holders and operators. The cost impact for this on owners / operators
would be substantial and avoidance of complying with this should be expected. This will only
improve safety if a prescribed System of Maintenance, AKA Schedule 5 beefed up or
personalised, is implemented for ALL aircraft as law.
CASA’s Response
CASA does not agree with the response. The requirements for the maintenance of any
aircraft components are mandated by Regulation 39 (class A)of CAR and Regulation 41
(class B) of CAR. The intent of the proposal is to provide a baseline standard for those
instruments considered critical and where no other data is available.
Disposition
No change.
COMMENT 56 – Retain existing CAO 108.56
Respondent stated: Where OEM data is not available, the use of the current CAO 108.56
Specifications should be acceptable. Many General Aviation aircraft manufacturers do not supply
sufficient data on the calibration of instruments.
CASA’s Response
CASA does not agree with the response. See CASA’s Response to Comment 6.
Disposition
No change.
COMMENT 57 – Approved data
Respondent stated: What will be deemed as appropriate instructions? Will this be confined to
OEM schedules and CASA approved SOM's? There will be holes in the regulation if this
proposal is solidified, meaning, there are options for Class A aircraft not to have an SOM and fall
back on wider intervals between instrument checks. No improvement to safety in these changes.
This is simpler to monitor and regulate at the point of C of A for all aircraft prior to C of A
approval, however what of the aircraft already on the register? How will the approval of SOM's
be monitored and carried out for compliance? I can only see that Maintainers will have to spent
inordinate amounts of time, not only researching and verifying compliance for each aircraft, but
also educating and negotiating with Operators to comply.
Document NFRM 1101CS
Page B26
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
CASA’s Response
CASA disagrees with the response. Appropriate instructions are those provided by the
aircraft or equipment manufacturer. If the aircraft is modified post CoA then the SOM
would need to be amended. There are existing regulations in place to deal with this issue.
See CASA’s Response to Comment 55.
Disposition
No change.
COMMENT 58 – No safety improvement
Respondent stated: This will be detrimental to safety in many ways, not to mention the additional
financial impost maintenance organisations.
CASA’s Response
CASA notes the response.
Disposition
No change.
COMMENT 59 – Enforcement
Respondent stated: Must include all instrumentation. Must be enforced. Delegates and SOM's
must be audited to ensure short cuts are not taken.
CASA’s Response
CASA notes the response.
Disposition
No change.
COMMENT 60 – On condition maintenance
Respondent stated: I believe that constant monitoring of an aircraft’s instrument systems with
faults being rectified as and when reported is adequate for most light aircraft applications. Fuel
amounts consumed and accuracy of compasses are easily monitored by pilots just as are the
accuracy and serviceability of dg systems. I would not want to see a return to the old way of
pulling out perfectly serviceable instrument systems every 3 years for little or no benefit. General
aviation is in real decline and while real safety must be maintained the cost factor to the owner
must be considered. I have no problem with maintenance of the aircrafts pitot static system.
CASA’s Response
CASA does not agree with the response. The instruments targeted by this proposal are
those that have a direct safety impact. Vertical separation with other aircraft is ensured
with an accurate altimeter/pitot static system. Often the pilot is not aware of gradual
degradation. Maintenance should not be considered a cost burden but a means to ensure
continuing safe operation of these systems.
Document NFRM 1101CS
Page B27
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
Disposition
No change.
COMMENT 61 – Maintaining ADs
Respondent stated: What is wrong with just updating AD INST 8/9 to reflect the requirements.
Most operators do not know anything about their maintenance requirements, it is the LAME that
does the job and sorts through the mishmash of CAO's AD's CAR's and CASR's, if the operator
sees that an AD has been cancelled, he won't be bothered sorting through all the mess to find
where it went.
CASA’s Response
CASA disagrees with the response. Refer to CASA’s Response to Comment 22.
Disposition
No change.
COMMENT 62 – Location of amendment
Respondent stated: Not sure where the wording for this will be. Is this also a proposed change to
100.5? Any wording should make ref to the required instruments for an aircraft and so cover all
the items listed in CAO 20:18 for a specific aircraft, as this seems to be the basis for some of the
changes presented already in the NPRM.As an example there is no check for compass systems(
direct or stabilised). These are required in all aircraft in various forms of CAO 20:18 so a
minimum should be included here as well. I have seen instances where compasses have not been
checked for 8 years as the OEM did not include it and the SOM hasn’t picked it up.
CASA’s Response
CASA disagrees with the response. The proposal is to amend CAO 100.5 to include the
requirements from certain maintenance related ADs. It also seeks to publish one standard
for altimeters. Refer also to CASA’s Response to Comment 55.
Disposition
No change.
COMMENT 63 – Appropriate data
Respondent stated: Registered operators or AMOC would be required to ensure that there are
appropriate instructions and data for the ongoing verification of instrument accuracy and the
integrity of the associated instrument systems, and that the testing requirements in this AD are
carried out by an appropriately rated B2 licence Holder.
CASA’s Response
CASA agrees in part with the response. The comments are correct but the intent of the AD
for testing will be moved into CAO 100.5.
Document NFRM 1101CS
Page B28
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
Disposition
No change.
COMMENT 64 – Test intervals
Respondent stated: The Association supports the 60 month fuel gauge correlation check provided
the fuel quantity indicating systems receive a correlation check annually as part of an annual
inspection using a simple validation process using a calibrated measuring device (fuel quantity
stick). Should the correlation be in error a full system correlation check should be performed.
CASA’s Response
CASA agrees in part with the statement. See CASA’s Response to Comment 32.
Disposition
CASA has amended CAO 100.5 to change the interval to 48 months. However operators may
wish to utilise this method in their approved maintenance schedule.
COMMENT 65 – Additional testing
Respondent stated: The association believes that the compass swing should be performed every
36 months or following significant avionics change. The compass swing can be performed either
from a certified compass rose, or in absence of a certified compass rose, a calibrated test set.
CASA’s Response
CASA notes the response.
Disposition
No change.
Specific Issues
COMMENT 66 – Paragraph 2.4(a): Proposed CAO 100.5
Respondent stated: 2.3 refers to encoders when the text refers to pressure altimeters i.e. 2.1.
Change ref from 2.3 to read 2.1.
CASA’s Response
CASA agrees with the response, editorial error.
Disposition
CASA has amended CAO 100.5 to correct the error.
Document NFRM 1101CS
Page B29
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 67 – Paragraph 2.4(b): Proposed CAO 100.5
Respondent stated: 2.3 refers to encoders while text refers to altimeters, i.e. 2.1. Change ref from
2.3 to read 2.1.
CASA’s Response
CASA agrees with the response, editorial error.
Disposition
CASA has amended CAO 100.5 to correct the error.
COMMENT 68 – Paragraph 2.5(b): Proposed CAO 100.5
Respondent stated: The phrase equivalent reporting directly to ATC, seem very cumbersome.
After equivalent, include device or another word to give clear meaning to phrase.
CASA’s Response
CASA agrees with the response.
Disposition
CASA has amended CAO 100.5 to include the term “device”.
COMMENT 69 – Paragraph 2.6(b): Proposed CAO 100.5
Respondent stated: The clause in 2.4 permits subsection 2.6 to negate the requirement to test any
of the mode C data if it utilises a single source. This is not the intent of app E (c) where all are
tested. Delete.
CASA’s Response
CASA agrees with the response.
Disposition
CASA has deleted the original Section 2.6 has been deleted and amended CAO 100.5 to clarify
the intent.
COMMENT 70 – Paragraph 4.2(a): Proposed CAO 100.5
Respondent stated: Fuel is identified as an issue, where currently carried out the usual time is 36
months. So 48 is still an increase in time. It makes for a simplification of requirements in 100.5 of
24 or 48 months. Change 60 months to 48 months.
CASA’s Response
CASA agrees with the response. See CASA’s Response to Comment 55.
Disposition
Refer to CASA’s Disposition to Comment 55.
Document NFRM 1101CS
Page B30
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 71 – Paragraph 1.1(c): Proposed CAO 100.5
Respondent stated: Won’t CAO 108.56 be cancelled? The procedure set out in para x.x of CAO
100.5.
CASA’s Response
CASA agrees with the response. The procedures detailed in CAO 108.56 will be migrated
to CAO 100.5
Disposition
CASA has amended CAO 100.5 to include these procedures.
COMMENT 72 – Paragraph 2.2 (note 2): Proposed CAO 100.5
Respondent stated: Supporting documents, ARC must be kept in LOG BOOK. In-situ tests would
need to view the Serial # in the panel to make a log book entry to comply. How do you determine
the Serial# fitted has been checked?
CASA’s Response
CASA notes the response. It is the Maintainer’s responsibility to take whatever action is
required to record the maintenance performed.
Disposition
No change.
COMMENT 73 – Paragraph 2.6: Proposed CAO 100.5
Respondent stated: This reads that those systems do not require testing at all. Encoding
Altimeters & integrated systems would only be tested as per para2.1 Pressure Altimeters?
CASA’s Response
CASA agrees with the response. The statement will be reviewed for clarity.
Disposition
CASA has amended CAO 100.5 to clarify the intent.
COMMENT 74 – Paragraph 2.6: Proposed CAO 100.5
Respondent stated: A class A aircraft that doesn’t include testing intervals for ASI's within 48
months should not be approved by CASA in the first place. 24/36 months for Class A and Class
B aircraft regardless.
CASA’s Response
CASA notes the response.
Disposition
No change.
Document NFRM 1101CS
Page B31
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 75 – Paragraph 4.2: Proposed CAO 100.5
Respondent stated: A class A aircraft that doesn’t include testing intervals for Fuel QTY;s within
60 months should not be approved by CASA in the first place. 24/36 months for Class A and
Class B aircraft regardless.
CASA’s Response
CASA notes the response.
Disposition
No change.
COMMENT 76 – Paragraph 2: Pressure Altimeters – Note 2, Proposed CAO 100.5
Respondent stated: FAR43 App E includes requirements for testing of backlash, friction and
hysteresis which is not possible to measure on aircraft. Delete the means for carrying out
altimeter tests on the aircraft.
CASA’s Response
CASA disagrees with the response. Refer to CASA’s Response to Comment 2.
Disposition
Refer to CASA’s Disposition to Comment 2.
COMMENT 77 – Paragraph 3.2: Proposed CAO 100.5
Respondent stated: Should coincide with altimeter testing every 24 months. Not exceeding 24
months
CASA’s Response
CASA disagrees with the response. CASA considers the 48 month interval appropriate for
that instrument.
Disposition
No change.
COMMENT 78 – Paragraph 4.2: Proposed CAO 100.5
Respondent stated: Should coincide with fuel calibration every 3 years. Not exceeding 36
months.
CASA’s Response
CASA disagrees with the response. CASA considers the 48 month interval appropriate for
that instrument.
Disposition
No change.
Document NFRM 1101CS
Page B32
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 79 – Paragraph 2.2 Note 1: Proposed CAO 100.5
Respondent stated: Introduction of CASA's changes to CAO100.5 is good and although
Appendix E is the "world" standard if safety is not compromised, then CASA should not
overburden maintainers - an additional 50 ft error for VFR means 70 ft at sea level rising to 180 ft
at 20,000 ft. (for VFR) 180 is much less than the 600 ft currently available.
Add the words following Appendix E of FAR 43 "except for VFR ONLY aircraft, an additional
scale error of +/- 50 ft is acceptable" (added under, and as part of, note 1.
CASA’s Response
CASA disagrees with the response. Refer to CASA’s Response to Comment 2.
Disposition
Refer to CASA’s Disposition to Comment 2.
COMMENT 80 – Proposed CAO 100.5
Respondent stated: I feel the need to spell out the requirements for other instruments.
Please flag in the revised CAO 100.5 of the need to ensure that other instruments (aside from
those noted in CAO 20.18) are maintained to AC manufacturer requirements.
CASA’s Response
CASA notes the response.
Disposition
No change.
COMMENT 81 – Paragraph 2.2, Note 2: Proposed CAO 100.5
Respondent stated: Reading FAR 43 Appendix E would have helped as if this was read the
consultant would have known that FAR 43 Appendix E is not possible to achieve while still
connected to the pitot static system and with no vibrator available. Also if these instruments are
working all the time - how is wear to be assessed without opening.
Delete that the tests can be carried out in the aircraft as it is not possible to carry out all the tests
associated with far 43 app e while the instrument is installed in the aircraft.
CASA’s Response
CASA disagrees with the response. The tests may be conducted in situ, with the only test
where some vibration is required being the friction test. This can be achieved with
altimeters having an integral vibrator or the vibration may be applied by lightly tapping the
instrument panel adjacent to the altimeter.
Disposition
No change.
Document NFRM 1101CS
Page B33
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 82 – Paragraph 1.2(a): Proposed CAO 100.5
Respondent stated: The addition of a planning tolerance similar to those that exist in many
current aircraft maintenance schedules will allow the tests to be done conveniently and coincident with other inspections such as those for the issue of a MR.
24 months + 1 month which is not to be cumulative to the next Test.
CASA’s Response
CASA does not agree with the response. With an interval of 24 months there is sufficient
time to plan according to the operational program. The option is always to perform the test
early.
Disposition
No change.
COMMENT 83 – Paragraph 2.2: Proposed CAO 100.5
Respondent stated: Ditto to 1.2. (a) above.
24 months + 1 month which is not to be cumulative to the next Test.
CASA’s Response
CASA does not agree with the response. With an interval of 24 months there is sufficient
time to plan according to the operational program. The option is always to perform the test
early.
Disposition
No change.
COMMENT 84 – Paragraph 3.2: Proposed CAO 100.5
Respondent stated: Ditto to 1.2 (a) above.
48 months +1 month which is not to be cumulative to the next Test.
CASA’s Response
CASA does not agree with the response. With an interval of 24 months there is sufficient
time to plan according to the operational program. The option is always to perform the test
early.
Disposition
No change.
Document NFRM 1101CS
Page B34
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 85 – Paragraph 4.2: Proposed CAO 100.5
Respondent stated: Ditto to 1.2 (a) above.
60 months = 1 month which is not to be cumulative to the next test ; and
CASA’s Response
CASA does not agree with the response. With an interval of 24 months there is sufficient
time to plan according to the operational program. The option is always to perform the test
early.
Disposition
No change.
COMMENT 86 – Paragraph 4.2: Proposed CAO 100.5
Respondent stated: So that it aligns with altimeter & ASI inspection…at intervals not exceeding
48 months.
CASA’s Response
CASA agrees with the response. The interval has been amended to 48 months. Refer to
CASA’s Response to Comment 32.
Disposition
CASA has amended the interval to read 48 months.
COMMENT 87 – Paragraph 2.4: Proposed CAO 100.5
Respondent stated: Paragraph 2.3 is about encoder tests, not pressure altimeter tests. Pressure
altimeter tests are referenced in paragraph 2.1. Change the references to para 2.3 in 2.4 (a) and (b)
to para 2.1.
CASA’s Response
CASA agrees, editorial error.
Disposition
CASA has amended CAO 100.5 to correct the error.
COMMENT 88 – Paragraph 2.2: Proposed CAO 100.5
Respondent stated: People will just put on a standard Pitot Static tester, run up to 10,000 feet and
say it’s done. It needs to be firmer in its language. Appropriate test equipment and published
procedures may allow.
CASA’s Response
CASA does not agree with the response. The altimeter test is quoted fully in the procedure
contained in the Appendix to CAO 100.5, there is no requirement to re-cover all the
information in the content of the CAO.
Document NFRM 1101CS
Page B35
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
Disposition
No change.
COMMENT 89 – Paragraph 4.2: Proposed CAO 100.5
Respondent stated: 5 years is too long for fuel calibrations……at intervals not exceeding 24 or 36
months.
CASA’s Response
CASA agrees with the response. The interval has been amended to 48 months. Refer to
CASA’s Response to Comment 32.
Disposition
CASA has amended CAO 100.5 to change the interval to read 48 months.
COMMENT 90 – Proposed CAO 100.5
Respondent stated: There is still not a clear requirement to test other aircraft instruments.
CASA’s Response
Refer to CASA’s Response to Comment 55.
Disposition
No change.
COMMENT 91 – Proposed CAO 100.5
Respondent stated: There is no reference to servo driven altimeters. There needs to be plain
language stating that the source AND display of altimetry needs to be calibrated.
CASA’s Response
CASA does not agree with the response. There are various configurations for altimeters
and the information being presented to the pilot is to be within the limits specified. If the
remote display has maintenance requirements then it needs to be included. Refer to CASA’s
Response to Comment 15.
Disposition
No change.
Document NFRM 1101CS
Page B36
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 92 – Paragraph 1.1(a): Proposed CAO 100.5
Respondent stated: The test procedure (manufacturer's AMM procedure) is not in the SOM
document. Some of our aircraft will be subject to CASR Part 42 and will not have a CAR 42M
SOM. They will have a Maintenance Program approved under CASR part 42.
Should say the test procedure referenced in the SOM or Maintenance Program.
CASA’s Response
CASA agrees with the response.
Disposition
CASA has amended CAO 100.5 to clarify applicability
COMMENT 93 – Paragraph 1.2(a): Proposed CAO 100.5
Respondent stated: The MRBR checks and interval should apply to an aircraft that has a SOM
based on the MRBR. Leak check should be done at the period specified in the SOM or
Maintenance program.
CASA’s Response
CASA agrees with the response.
Disposition
CASA has amended CAO 100.5 to clarify applicability.
COMMENT 94 – Paragraph 2.1: Proposed CAO 100.5
Respondent stated: The manufacturer's test procedure should always be used, but the tolerances
should be no greater than specified in Appendix E. Pilots can check standby altimeter for
accuracy against the calibrated altimeters.
Should be a procedure equivalent to Appendix E and should not apply to standby altimeters
(which can be checked during flight against the main altimeters). Clarify what is meant by
pressure altimeter.
CASA’s Response
CASA agrees in part with the response. All altimeters fitted in accordance with the
certification requirements of the aircraft are to be tested. The procedures detailed in the
proposal are those to be used when manufacturer’s data is not available.
Disposition
No change.
Document NFRM 1101CS
Page B37
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 95 – Paragraph 2.3: Proposed CAO 100.5
Respondent stated: The test should be done per the manufacturer's procedure for the installed
equipment.
Should say an integration test of the automatic pressure altitude reporting equipment and ATC
transponder system installed in an aircraft must be carried out in accordance with a procedure
equivalent to FAR part 43 Appendix. Tolerance not to exceed that specified in Appendix E (i.e.
125 feet).
CASA’s Response
CASA does not agree with the response. The test required in Para 2.3 is the
correspondence check where the output of the blind encoder is compared to that of the
pilot’s altimeter to ensure they are providing the same output. Refer to CASA’s Response to
Comment 69.
Disposition
No change.
COMMENT 96 – Paragraph 2.4: Proposed CAO 100.5
Respondent stated: The FAR's do not require the integration test to be done at the same time as
the altimeter calibration. Under the FAR's it is as per the maintenance program (if applicable) or
24 months. Australian requirements for all these tests should be the same as the FAR's. Current
wording is too complicated.
This should state at the period specified in the SOM or Maintenance Program, or each 24 months.
CASA’s Response
CASA partially agrees with the statement..
Disposition
CASA has amended CAO 100.5 to clarify the applicability.
COMMENT 97 – Paragraph 2.5: Proposed CAO 100.5
Respondent stated: The proposed wording does not state what additional test is required. Also not
clear what situation requires the test. (eg. change of a component or change to a component?) Not
all component changes require an integration (correspondence) test.
State what test is required.
CASA’s Response
CASA agrees with the response. Requirements on what test to be carried out is ambiguous.
Disposition
CASA has amended CAO 100.5 to clarify intent.
Document NFRM 1101CS
Page B38
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 98 – Paragraph 2.6: Proposed CAO 100.5
Respondent stated: FAR 43 Appendix E (c) requires all altitude reporting and transponder
systems to be tested.
Not clear.
CASA’s Response
CASA agrees with the response.
Disposition
CASA has amended CAO 100.5 to clarify intent.
COMMENT 99 – Paragraph 3.1: Proposed CAO 100.5
Respondent stated: The SOM should be able to reference the manufacturer's procedure to be
used, without containing the procedure. If the MRBR does not specify a test requirement then
SOM should be able to state that.
Should state the test procedure specified in the SOM or Maintenance Program.
CASA’s Response
CASA agrees with the response.
Disposition
CASA has amended CAO 100.5 to clarify intent.
COMMENT 100 – Paragraph 4.1: Proposed CAO 100.5
Respondent stated: The SOM should be able to reference the manufacturer's procedure to be
used, without containing the procedure. If the MRBR does not specify a test requirement then
SOM should state this.
Should state the test procedure specified in the SOM or Maintenance Program.
CASA’s Response
CASA agrees with the response.
Disposition
CASA has amended CAO 100.5 to clarify intent.
COMMENT 101 – Paragraph 4.2(b): Proposed CAO 100.5
Respondent stated: Change to a system component suggest a modification of the component
rather than replacement of it.
Replacement of, or modification to.
Document NFRM 1101CS
Page B39
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
CASA’s Response
CASA does not agree with the response. A change can be a modification, replacement or
the result of work carried out on a system.
Disposition
No change.
COMMENT 102 – Paragraph 2.1: Proposed CAO 100.5
Respondent stated: The pressure altimeters REQUIRED TO BE installed in an aircraft.
If additional instruments are provided over and above those required to be fitted (by CASA or the
Type Certificate) they should not be included in the mandatory requirements.
CASA’s Response
CASA agrees with the response. Non-required equipment is to be placarded.
Refer to CASA’s Response to Comment 7.
Disposition
CASA has amended CAO 100.5 to clarify intent.
COMMENT 103 – Paragraph 2.1: Proposed CAO 100.5
Respondent stated: Specify aircraft with transponders to be tested to FAR 43 app E.
The pressure altimeters REQUIRED TO BE installed in an aircraft fitted with a Mode A+C or
Mode S transponder must be tested in accordance with the procedures set out in Appendix E
contained in Part 43 etc.
CASA’s Response
CASA notes the response.
Disposition
CASA has amended CAO 100.5 to reference revised standards incorporated in CAO 100.5.
COMMENT 104 – Paragraph 2.2: Proposed CAO 100.5
Respondent stated: Option to do either test for VFR no transponder aircraft.
The pressure altimeters REQUIRED TO BE installed in a VFR aircraft NOT fitted with a Mode
A+C or Mode S transponder must be tested in accordance with the procedures set out in CAO
108.56 para 3.2 or Appendix E of FAR 43.
Document NFRM 1101CS
Page B40
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
CASA’s Response
CASA does not agree with the response. The intent of the proposal is to have a single
altimetry standard.
Disposition
No change.
COMMENT 105 – Paragraph 2.3: Proposed CAO 100.5
Respondent stated: As per para 2.2 in the current proposed amendment.
No change, just renumbering of paragraph in incorporated suggestions above.
CASA’s Response
CASA notes the response..
Disposition
No change.
COMMENT 106 – Paragraph 1.1: Proposed CAO 100.5
Respondent stated: No known schedule from OEM or Schedule 5 outlines Pitot/Static test
tolerances.
This will 99% default to 1.1(c) suggest make SOM mandatory for all classes of aircraft to include
testing schedules.
CASA’s Response
CASA notes the response.
Disposition
CASA has amended CAO 100.5 wording to clarify intent.
COMMENT 107 – Paragraph 1.1(c): Proposed CAO 100.5
Respondent stated: This could include Class A & B aircraft without an SOM will default to this
CAO 108.56?
Clarify which aircraft are included here? Its not just for aircraft other than class A&B.
CASA’s Response
CASA notes the response.
Disposition
No change.
Document NFRM 1101CS
Page B41
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 108 – Paragraph 2.1: Proposed CAO 100.5
Respondent stated: Integrated instrument systems with higher resolution will require
Manufacturer compliance more so than FAR Part 43 Appendix E.
Inclusion of Manufacturers Specifications needs to come first then default down to FAR Part 43
as RVSM compliance will dictate tighter tolerances.
CASA’s Response
CASA does not agree with the response. There is no differentiation in altimetry standards
for RVSM operations.
Disposition
No change.
COMMENT 109 – Paragraph 2.4: Proposed CAO 100.5
Respondent stated: Appropriate has always been debated as up to interpretation, and an FAR
calibrated Altimeter with a hose coming out if it has been accepted in the past for these checks.
That needs to be explained or clarified to include RVSM compliant test Equipment that has
current calibration certification above and beyond the same specs that the unit under test is being
tested to.
Appropriate test equipment should read Approved or Calibrated IAW AMO.
CASA’s Response
CASA disagrees with the response. The use of the term “appropriate” is intended to ensure
that the correct equipment is being used that is capable of performing the task to the
required standard. The equipment needs to be calibrated to confirm that the equipment is
performing to its design specifications. FAR Part 43 Appendix E provides no differentiation
for RVSM operation.
Disposition
No change.
COMMENT 110 – Paragraph 3.2: Proposed CAO 100.5
Respondent stated: Interpretation possible from CLASS A & B operators to conclude that if the
Class A aircraft SOM does not include periodic testing of ASI.
Remove 3.1(a) & 3.1(b) reference and only include sub-class aircraft.
CASA’s Response
CASA disagrees with the response. The intent is that aircraft that have an approved
maintenance program are exempt from the requirements of this CAO amendment.
Disposition
No change.
Document NFRM 1101CS
Page B42
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 111 – Paragraph 4.2: Proposed CAO 100.5
Respondent stated: If the maximum time between checking Fuel QTy systems is 5 years, then
maintainers will have to remove indicators and probes to insist on Fuel Calibration at intervals of
lesser time under CASA Schedule 5 for these aircraft. If a Class A aircraft has an approved SOM
that doesn’t include FUEL QTY system checks more frequent than 60 months, there is major
shortfalls with the approval of CAR 42M SOM.
Same as 3.2, Remove the possibility for Class A&B aircraft to have SOM.
CASA’s Response
CASA notes the response.
Disposition
No change.
COMMENT 112 – Paragraph 4.2: Proposed CAO 100.5
Respondent stated: Given that fuel quantity indication error have been identified as a direct
contributing factor to aircraft accidents, is it appropriate that the calibration interval is the longest
of any proposed? The interval should be reduced to a maximum of 24 months to align with other
checks.
Interval for fuel quantity indicator calibration should be reduced to less than 60 months.
CASA’s Response
CASA disagrees with the response. Refer to CASA’s Response to Comment 55.
Disposition
Refer to CASA’s Disposition to Comment 55.
COMMENT 113 – Paragraph 2.2: Proposed CAO 100.5
Respondent stated: Airspeed indicator checks could easily be carried out at the same time as other
Pitot/Static checks carried out at 24 month intervals.
Align airspeed indicator calibrations with other checks.
CASA’s Response
CASA disagrees with the response. Whenever an operator wishes to perform the test within
the time period specified is up to the operator. The intervals are such that all tests can be
aligned.
Disposition
No change.
Document NFRM 1101CS
Page B43
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 114 – Paragraph 2.2: Proposed CAO 100.5
Respondent stated: I can't think of many SOM that would make the requirement less than 24
months, so this line may just be indicating that 24 month checks may not be required?
Could 2.2 b) be removed?
CASA’s Response
CASA agrees with the response. .
Disposition
CASA has amended CAO 100.5 to clarify an exempt aircraft.
COMMENT 115 – Paragraph 3.2: Proposed CAO 100.5
Respondent stated: Avoid any doubt that airspeed checks can be extended beyond 48 months.
Replace with just Airspeed indicator checks must be performed at intervals not exceeding 48
months.
CASA’s Response
CASA does not agree with the response.
Disposition
No change.
COMMENT 116 – Paragraph 4.2: Proposed CAO 100.5
Respondent stated: Avoid any doubt that fuel quantity gauge checks can be extended beyond the
stated period.
Replace with just Fuel quantity measuring system accuracy checks must be performed.
CASA’s Response
CASA does not agree with the response.
Disposition
No change.
COMMENT 117 – Paragraph 4.2(a): Proposed CAO 100.5
Respondent stated: Given that incorrect fuel indications are found by ATSB in many incidents, I
think the period should be maximum 24 months, similar to the altimeter. 24 months is a long time
for any aircraft, and especially an older aircraft.
Change to 24 months.
Document NFRM 1101CS
Page B44
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
CASA’s Response
CASA does not agree with the response. See CASA’s Response to Comment 55.
Disposition
CASA has amended CAO 100.5 to decrease interval to 48 months.
COMMENT 118 – Paragraph 1.2(b): Proposed CAO 100.5
Respondent stated: This is an allowable practice in Canada and I believe FAA in 25 years of
operation of the DASH-8 Qantaslink have never replaced a quick disconnect due to a leak.
Add new sections allowing for no leak check requirements static pitot if aircraft system has dual
ADC system using quick disconnect fitting and only one system disturbed.
CASA’s Response
CASA notes the response. The CAO amendment is intended to be applicable to those
aircraft that do not have an approved system of maintenance or maintenance schedule.
Those aircraft would not necessarily have MRBR data to support this proposal.
Disposition
No change.
COMMENT 119 – Paragraph 2: Proposed CAO 100.5
Respondent stated: If you wish to remove ambiguity and stop misinterpretation of requirements
one could argue the fleet that on electronic display / servo driven device is not an actual pressure
altimeter.
Heading should be opened up to include servo driven altimeter PFD (electronics) altimeters;
CASA’s Response
CASA notes the response. CAO amendment is intended primarily for the self-contained
mechanical altimeters. Air data computers etc are to be maintained in accordance with
manufacturer’s recommendations.
Disposition
No change.
COMMENT 120 – Paragraph 2.1: Proposed CAO 100.5
Respondent stated: Q400 Thales requirements are more rigid that that is shown in FAR 43 eg
30,000 ft tolerance + 0ft. This is the highest allowable tolerance figure. Currently one could view
the fact that FAR 43E over rides manufacturer’s tolerance so they can meet Australian CAO
requirements. Refer to FAR 43E(2).
Making reference only to FAR 43E needs to be opened up to include manufacturers required
tolerances. FAR 43E is the minimum tolerance required. Manufacturer’s tolerance could be
higher.
Document NFRM 1101CS
Page B45
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
CASA’s Response
CASA disagrees with the response. The CAO amendment is intended to be applicable to
those aircraft that do not have an approved system of maintenance or maintenance
schedule.
Disposition
CASA has reworded CAO 100.5 to clarify which aircraft are exempt from these requirements.
COMMENT 121 – Paragraph 2.3: Proposed CAO 100.5
Respondent stated: The current terminology represents only one method of altitude transmission
to ATC transponder. Adopting my suggested working I believe covers a more broad ranging of
available systems. It is sort of being described within section 2.5.
Current wording "altitude encoders" should be reviewed and changed to "Automatic Pressure
Altitude Reporting Systems".
CASA’s Response
CASA agrees with the response.
Disposition
CASA has reworded CAO 100.5.
COMMENT 122 – Paragraph 2.6: Proposed CAO 100.5
Respondent stated: I believe content wording is encouraging one not to test the output of mode 'c'
ATC output. An ADC or combined instrument should be tested. A combined instrument has two
seperate functions and the hidden / unviewed mode 'c' output function can fail.
My take on this paragraph is no testing is required if you have a combined display / mode 'c' unit.
CASA’s Response
CASA agrees with the response.
Disposition
CASA has amended CAO 100.5.
COMMENT 123 – Paragraph 3: Proposed CAO 100.5
Respondent stated: DASH-8 do not have any requirement to check calibration of ASI. In this,
Quantaslink falls within 3.1(c). The tolerances found within 108.56 are not within manufactures
specifications. There is no benefit to operator or safety for a Class 'A' RPT aircraft to complete
such a maintenance action.
An aircraft class 'A' in an RPT environment will have no operational benefit of completing a
scale error check. Flight crews will advise very quickly of any noted errors.
Document NFRM 1101CS
Page B46
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
CASA’s Response
CASA agrees with the response. Class A aircraft with an approved SOM are exempt
aircraft.
Disposition
No change.
COMMENT 124 – Paragraph 4: Proposed CAO 100.5
Respondent stated: An RPT operator would be engaging in fuel quantity checks using manual use
recording conversion / calculation and instrumentation - for Qantaslink allowance is 4% if
outside this limit, maintenance actions are necessary to determine difference. DASH 8 200/300
does have a maintenance task card to check fuel qty probes - there is no need to check calibration
of instrumentation. DASH 8 - 400 has no maintenance requirements against fuel qty system. This
system has a fuel qty control box which continually monitors system and probes. If the detectors
card finds an issue the fuel qty for that affected side becomes invalid. No need to calibrate as it is
continually monitored. Airline operation has methods of determining fuel consumed against fuel
on board. If the calculated figures notate a difference then maintenance actions are undertaken to
determine the error. Airline procedures continually monitor systems by the fact the aircraft
operational environment.
An aircraft class 'A' RPT has requirements under CAO 20.2 to ensure systems are in place that
fuel quantity is verified before flight.
CASA’s Response
CASA agrees with the response. Class A aircraft with an approved SOM are exempt
aircraft.
Disposition
No change.
COMMENT 125 – Proposed CAO 100.5
Respondent stated: Replacing AD/INST/9 and AD/RAD/43 with a CAO doesn't necessarily
remove all the anomalies that have been associated with an operator showing compliance with the
equipment calibration requirements specified in those AD's. There has been debate over the years
as to what was expected of the operator of an Australian aircraft (that has a System of
Maintenance) to show compliance with the intent of these requirements. AD/INST/9 was
originally directed at General Aviation aircraft subject to the three-yearly "Major Inspection"
requirement of ANO 100.5.1 - which does NOT apply to aircraft operated under an Airline or
Supplementary Airline licence. The latter aircraft were expected to have an approved System of
Maintenance (SOM) that would address any instrument calibration requirements for the particular
aircraft type. It was to some extent accepted that the maintenance philosophy for complex aircraft
was somewhat different to that for small general aviation aircraft. The introduction of the
maintenance Class A and B philosophy via the 1988 CAR's (which did away with the threeyearly Major Inspection for GA aircraft) confused the situation regarding which aircraft needed
to comply with AD/INST/9.
Document NFRM 1101CS
Page B47
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
The new compliance wording of the AD indicated applicability of ALL aircraft (i.e. GA and
Airline) and suggested that an aircraft's SOM should specify and interval at which each
instrument was to be calibrated - presumably even if the manufacturer of a complex airline
aircraft didn't recommend or require periodic calibration. (Modern maintenance philosophies
such as MSG-3 don't require hard-time bench checks of all instruments).
It is understood that one of the objectives of the amendment is to remove the different calibration
standards for IFR versus VFR aircraft altimeters, and there is no objection to that. However the
proposal affects all aircraft and introduces a number of changes affecting maintenance
requirements that have been the subject of some debate over the years as regards modern aircraft
and instrument systems. The following issues from the perspective of the operator/maintainer of
large modern aircraft.
AD/RAD/43 further confuses the above situation by requiring each "pressure altimeter" to be
calibrated per FAR 43 Appendix E. This appendix is both a procedure and a set of tolerances and is written around the simple mechanical aneroid type altimeter. The term "pressure altimeter"
isn't defined in the AD, so it's not clear if this includes servo altimeters and altimeter systems that
use an air data computer sending a signal to an electric altitude indicator or flat screen display. Or
is it simply intended to eliminate "radio altimeters" from the requirement. FAR 43 Appendix E
does go some way towards addressing different types of altimeters by indicating that where an
altimeter has internal air data correction or an associated air data computer - then different
calibration procedures supplied by the manufacturer can be used, if acceptable to the FAA
"administrator". Using different procedures to that specified in Appendix E can be
accommodated under the FAR's. Here in Australia strict literal compliance with the AD is usually
expected - which involves a certification for AD/RAD/43 in respect of each affected piece of
equipment. When a test of a servoi altimeter or air data computer has been carried out to data
other than Appendix E (i.e to manufacturer's data) - the checking organisation is often reluctant to
certify compliance per AD/RAD/43, which causes problems for the Australian aircraft operator.
There is currently nothing in the Australian regulatory system to indicate that other
"manufacturer's data" specifying tolerances equivalent to Appendix E can be used to satisfy
AD?INST/9 or AD/RAD/43 altimeter calibration requirements.
Also, under the FAA system, an aircraft maintained to a continuous airworthiness maintenance
program (CAMP) is not required to comply with the FAR 43 maintenance requirements. The
CAMP is expected to address the maintenance requirements for the altimeter and transponder
systems - based on the aircraft/equipment manufacturer's recommendations and operational
experience. A CAMP is essentially the FAA equivalent of a SOM - therefore it would be
reasonable to expect that an Australian aircraft's SOM should specify what altimeter calibration
procedure is to be carried out and the frequency of same - base don manufacturer
recommendations and operational experience. The reliability and redundancy built into modern
aircraft means that some ideas on maintenance aren't necessarily relevant any more. The
Maintenance Review Board analysis of an aircraft and its systems to MSG-3 (and production of
an MRB report that an Operator can use as the basis of a maintenance program) should be given
some credit against the need for "hard-time" calibration checks. (Approval of a SOM may take
this into account to some extent, but it is entirely at the discretion of the approving delegate).
Arbitrary removal of instruments for calibration often causes the equipment to ultimately be less
reliable, due to transit damage, connector damage, infant mortality failures, etc.
Document NFRM 1101CS
Page B48
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
After an MRB analysis of an aircraft the manufacturer may give a maintenance manual test
procedure of the altimeter system - and the MRB document may call up this check as the sole
scheduled maintenance requirement for the system - with no requirement to "calibrate" the
altimeter/air data computer.
This begs the question - is it (in principle) acceptable to have this arrangement approved in the
SOM - or would CASA expect some specific "calibration" to be carried out as well? (It's
appreciated that the proposed CAO refers to "pressure altimeters" which although not defined
may exclude some modern equipment).
CASA’s Response
CASA notes the response. Aircraft that have an approved SOM or maintenance program
are exempt from the proposed amendments.
Disposition
No change.
COMMENT 126 – Proposed CAO 100.5
Respondent stated: AOPA is not satisfied that the proposals set out in this NPRM will increase
aviation safety. We observe the significant cost burden that these onerous proposed requirements
will impose on small VFR aircraft operators, especially those in remote and rural locations.
CASA’s Response
CASA notes the response. There is a requirement in accordance with Regulation 39
(Class A) of CAR and Regulation 41 (Class B) of CAR to ensure that there was provision
for the maintenance of all aircraft components fitted to the aircraft. NPRM 1101CS
proposed the minimum acceptable standards that CASA considered necessary when
considering the Australian fleet as a whole.
Disposition
No change.
General comments
COMMENT 127 – Transponder testing
Respondent stated: Whilst amending CAO100.5 for these reasons, consideration should be given
to adding the Transponder Tests currently in AD/RAD/47. As a practical measure the Pitot-Static
Leak Checks, Altimeter / ADC accuracy and Encoder Tests can all be done conveniently at the
same time using portable Pitot -Static Test Equipment. Doing these at the same time overcomes
any out-of-step tests causing unnecessary downtime involving the test equipment which can for
some types take considerable time to prepare and set up on the aircraft.
CASA’s Response
CASA agrees with the response. Requirements detailed in AD/RAD/47 Amdt 2 will be
incorporated into CAO 100.5 in the future.
Document NFRM 1101CS
Page B49
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
Disposition
No change.
COMMENT 128 – General comments
Respondent stated: I carry an Instrument for the Issue of Special Certificates of Airworthiness in
the Experimental Category and can issue IFR Certificates also. In checking Aircraft builders data
for compliance with the relevant AD/INST/8 or 9 I have come across strong opposition to the
compliance with the testing of any other instrument than the Altimeter because the aircraft
builder/owner has read the AD and chosen to only do the altimeter check every two years, totally
misunderstanding that the other instruments are required to meet some standard and believing
that to have to check the calibration of the other instruments is an onerous task which is not
required and will cost him money, because of the way the most recent amendment of both the
AD's were written. As reflected in my answers to the previous questions, I do not fully agree with
dropping the AD's but suggest that you amend them to reflect the date you wish to have the
instruments maintained to. In moving the AD's content to CAO 100.5 I suspect that it will be lost
on those of us that are required to maintain the aircraft, and the operator will think he does not
have to comply with the improved calibration standards. Another thing that I have noticed in my
job as a LAME is that most of the Instrument Shops and Avionics shops are not providing a
record in the aircraft logs of the results of the calibration checks as required by reference to the
instruction pages of the recommended aircraft log books, I think this should be addressed in any
change to the CAO 100.5 to clarify that results of special inspections or checks be recorded in the
aircraft's log book. I currently am employed as Chief Engineer with Sport Air Services at
Coolangatta and maintain a fleet of Diamond aircraft along with Cessna's and Beechcraft
Duchess and find that the Diamond Aircraft Maintenance Schedule to be quite good in the E,I
and R categories and engine and airframe, in fact these are aircraft that really need to be
maintained to the Factory Schedules. We also maintain the Duchess to the Factory Schedule and
find that to be better than CASA Sched. 5 for this aircraft. I believe that the Cessna's should also
be put on the Cessna schedule rather than Sched 5 as it is more applicable. CASA requires
aircraft to be maintained to Approved Data CAR 2,2A,So how does CASA allow aircraft to be
maintained to CASA Shed 5 when that aircraft has approved Factory data? Surely CASA is
turning a blind eye to the miss management of maintenance of aircraft maintained to Sched
5.Sched 5 is inadequate for the maintenance of modern Cessna 172 series aircraft, Cessna have
very good maintenance systems and Structural Repair manuals and continued airworthiness
manuals, which are being ignored in many cases by operators, maintainers and CASA.I have
digressed a little to Sched 5, however much of the calibration requirements are listed in the
aircrafts approved data, to which the aircraft is meant to be maintained to, but which sched 5 in
general use ignores, even though it is spelt out in the preface to Sched 5.
CASA’s Response
CASA agrees in part with the response. The reason the requirement is being migrated to the
CAO is that an AD is intended to correct a design deficiency not as the vehicle for ongoing
maintenance.
Disposition
CASA has amended CAO 100.5 to clarify documentation requirement.
Document NFRM 1101CS
Page B50
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 129 – Typographical error
Respondent stated: I assume that the writer of this reg accidently made reference in para 2.4 (a)
and 2.4 (b) to para 2.3 when he/her meant para 2.1.
CASA’s Response
CASA agrees, editorial error.
Disposition
CASA has amended CAO 100.5 to correct the error.
COMMENT 130 – Location of requirements
Respondent stated: Testing requirements for instruments and transponder systems should be
incorporated into one (1) AD, not tucked away in the mass of CAO's. This would make
administration and application simple and reduce the likelihood of the requirements being
overlooked and will also conform to entry into the current MR .The AD should incorporate the
following for ALL aircraft as a minimum.
Req.1 Calibrate pressure altimeters every 24 months I.A.W. FAR 43 App.E. (It should be noted
that insitu calibration to FAR 43 App.E is almost impossible as it incorporates far more testing
than just an accuracy check.
Req.2 Test the transponder systems as per existing AD/RAD/43 and AD/RAD/47 requirements
every 24 months. Additionally Mode S codes shall be verified. (CASA needs to make these codes
readily accessible via their website perhaps incorporated with the registration search details).
Req.3 Pitot/Static leak check every 24 months as per existing 108.56 standards.
Req.4 Fuel Qty gauge calibration and ASI accuracy check every 48 months (every second
requirement 1, 2 & 3 inspection)as per existing 108.56 standards. This AD should be applicable
to all aircraft so that aircraft maintained to Schedule 5 have a basic standard to comply with as
most manufacturers do not have adequate requirements in within their data. For aircraft
maintained to a manufacturers system these requirements can be a minimum for any area not
covered by the manufacturer. If the manufacturers system does cover all these aspects then that
system can be used as an alternative. It is important that all altimeters and transponders are tested
to the same standard irrespective of VFR or IFR as the level of operation does not restrict flight in
controlled or radar coverage airspace. Consideration also needs to be given to the Recreational
sector to ensure they conform to the same standards. We have given this topic careful
consideration and engineers consider this to be the best option providing a high level of
compliance and lower cost impact on an already struggling industry. CASA has an opportunity to
get this right this time. Lets hope they do.
Include a minimum for compass swings suggest 24 or 48 months in same format as other
proposals in 100.5. Per SOM, or OEM or iaw with 100.5. Does the requirements in 100.5 apply
to Class A aircraft that will be covered by the new Part 42 rules and approved maintenance
programs?
Document NFRM 1101CS
Page B51
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
CASA’s Response
CASA notes the response. Proposed requirements are not applicable to a Class A aircraft
provided the SOM addresses the ongoing airworthiness of the systems identified.
Disposition
No change.
COMMENT 131 – Regulatory authority
Respondent stated: The removal of AD's will transfer the instruction to the CAO, what measures
are there in the Orders under Law to restrict the flight of aircraft off the ground if the CAO 100.5
is not satisfied? What power does the CAO hold over a Pilot in command as opposed to an
Airworthiness Directive in the minds of Operators and C of R holders. My concern is that
Maintainers will have to police this and be pressured by Operators and C of R holders to limit the
scope of the SOM's to reduce costs. This will jeopardised safety not improve it. Mandatory
compliance of the CAO 100.5 must be expressed to C of R holders by CASA in some form. The
only improvement to safety in the proposed changes listed here is the abolition of the prescribed
testing of Altimeters to CAO 108.56 specs. The rest of it will cause confusion amongst Operators
and maintainers alike and make it easier for C of R holders to avoid regular checks on
instruments that may affect safety. The intent of these changes, I understand, is to clarify the
intent of the original AD's and improve safety. Tougher, clearer instructions in the Maintenance
Schedule CAR 5 for Class B and below aircraft should be the benchmark, it just needs the list of
specific instruments and the intervals built in. The approval process of Class A aircraft SOM's
needs to be addressed if statements such as Para 3.2 & 4.2 are necessary at all.
CASA’s Response
CASA disagrees with the response. ADs and CAOs are all regulations made under either
the CAR or CASR. They have equal standing in law and penalties associated with noncompliance.
Disposition
CASA has amended CAO 100.5 to remind operators of the requirement to comply.
COMMENT 132 – General comment
Respondent stated: Regional Express supports the proposed changes because they provide
simplification of the requirements, there are no significant costs associated with the proposed
changes and in the case of the changes to fuel quantity indication system maintenance there is a
direct safety benefit.
CASA’s Response
CASA notes the response.
Disposition
No change.
Document NFRM 1101CS
Page B52
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 133 – System of Maintenance
Respondent stated: Overall the solution to the periodic testing of instruments, in my view, is to
create tighter controls over the approval, incorporation and policing of Systems of Maintenance
to include these instructions for each aircraft type. Without the SOM in place the back-stops and
fallback tolerances and prescribed testing scales / processes will always be negotiated by Owner /
operators to the lowest common denominator. No improvement of safety will be introduced by
moving away from Airworthiness Directives (as open for interpretation they may be) and burying
the instructions in Civil Aviation Orders. Not only will there be no marked improvement in
safety, but in addition Maintainers and C of R holders will still differ on the intent and
legitimacies of CAO's Vs AD's and what is Mandatory and what is not. Get SOM's sorted out and
the safety and maintenance standards will fall into place.
CASA’s Response
CASA notes the response. Systems of Maintenance apply to only Class A aircraft in
accordance with Regulation 39 of CAR. Class B aircraft may have either a maintenance
schedule or be maintained in accordance with Schedule 5 of CAR. The proposal is intended
address the latter.
Disposition
No change.
COMMENT 134 – Current altimeter checks
Respondent stated: At present operators often choose to only do altimeters every two years,
thinking this is their only requirement to comply. The remaining instruments in the aircraft are
not regularly checked at all. This NPRM will clarify the requirements and give clearer guidance
to operators and maintainers.
CASA’s Response
CASA notes the response.
Disposition
No change.
COMMENT 135 – System of Maintenance
Respondent stated: Note 1: For definition of approved system of maintenance refer to CAR 1988
Regulation 2.
Qantas welcomes the proposal to move the additional maintenance requirements from AD-INST9 (and -8) and AD-RAD-43 into the Civil Aviation Orders (in advance of the promulgation of the
relevant sections of CASR Part 91).The numerous references to a CAR 42M SoM in the proposed
changes indicate that it is CASA’s intent not to require any additional maintenance on Class A
aircraft that are maintained in accordance with a continuous airworthiness maintenance program (
approved system of maintenance ) over and above the tasks which exist in that maintenance
program. Most if not all modern transport category (Class A) aircraft have a manufacturer's
maintenance program developed using the MSG-3 analysis methodology which provides for the
safety and airworthiness of the aircraft.
Document NFRM 1101CS
Page B53
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
This analysis takes into account the design of the relevant systems including redundancy,
integration, fault detection and alerting, fault tolerance, and cross-checking.
Recently type certified aircraft make extensive use of these design features and require little
additional periodic maintenance to ensure ongoing safety and airworthiness. United States
Federal Aviation Regulations 14 CFR Part 91 General Operating and Flight Rules Subpart E
Maintenance, Preventative Maintenance and Alterations, Regulation 91.411 stipulates similar
requirements to those currently in AD-INST-9 (& -8) and AD-RAD-43. 14 CFR Part 91
Regulation 91.401 (b) however states: Sections 91.405, 91.409, 91.411, 91.417, and 91.419 of
this subpart do not apply to an aircraft maintained in accordance with a continuous airworthiness
maintenance program as provided in part 121, 129, or 91.1411 or 135.411(a)(2) of this chapter.
Qantas believes that CASA should use a similar approach to the US FARs, and that the proposed
changes to CAO 100.5 would be greatly improved by using a single clarifying statement covering
all proposed additional maintenance relating to Class A aircraft with an approved system of
maintenance, either:(a) (preferred). The additional maintenance requirements for pitot-static
systems, pressure altimeters, airspeed indicators and fuel quantity gauges do not apply to a Class
A aircraft maintained in accordance with an approved system of maintenance. Note 1 For
definition of approved system of maintenance refer to CAR 1988 Regulation 2 or, (b). For a Class
A aircraft, the requirements, procedures and intervals in accordance with the approved system of
maintenance may be used.
CASA’s Response
CASA agrees with the response.
Disposition
CASA has amended CAO 100.5 to clarify intent towards Class A and Class B aircraft.
COMMENT 136 – Location of requirements
Respondent stated: I don’t believe putting it all into regulation will work. I think owners will
ignore the requirements, this is why the AD's were introduced in the first place. The maintenance
of instruments has always been required through other regulations and yet the owners and
operators continue to ignore this fact. What are you going to do to stop them ignoring their
regulatory requirements? As I stated earlier I commend CASA for at least trying to something as
the current situation is creating some very dangerous aircraft.
CASA’s Response
CASA notes the response.
Disposition
No change.
Document NFRM 1101CS
Page B54
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 137 – Test equipment standards
Respondent stated: Specific requirements for the test equipment standards could be addressed to
remove any misinterpretation from inappropriately qualified LAME's. Specific requirements
detailing the license and ratings held in order for a LAME to certify this AD should also be
addressed. This NPRM will only enhance the safety and achieve the objectives and intent of the
NPRM if it is clearly stated that the test equipment and qualifications are clearly defined. There
are avionics qualified personnel throughout Australia that are able to and willing to carry out
these inspections correctly. There should be no method within this NPRM that allows any
misinterpretation of these duties and responsibilities.
Organisations that do not have the support of an avionics organisation within a 2 year period are
simply lying, and there should be no concessions (surely every aircraft on the continent can get
access to an Avionics LAME within a 2 year period?!)I also believe that the Standby Compass
should also be calibrated every 2 years and included in this NPRM.
CASA’s Response
CASA does not agree with the response. License coverage for aircraft equipment is covered
under CAO 100.90 and Part 66 MOS.
Disposition
No change.
COMMENT 138 – Clarification of terminology
Respondent stated: When it is stated any change to, or modification of I'm not sure if this
includes when a unit is removed and then re-installed. If it does include removals & reinstallations I think this should be clarified in this statement, maybe any change to, replacement
of, or modification of.
CASA’s Response
CASA notes the response.
Disposition
No change.
COMMENT 139 – Fuel quantity indicating system
Respondent stated: Consideration for fuel Qty testing, 60 months is too greater interval for testing
of such a vital system, keep it aligned with 24 months, that way there is no misinterpretation and
the operator pressuring the lame that it is current don't worry about that one.
CASA’s Response
CASA agrees with the response. The interval has been shortened to 48 months in response
to comments received.
Disposition
CASA has amended CAO 100.5.
Document NFRM 1101CS
Page B55
Notice of Final Rule Making
Amendments to Civil Aviation Orders 100.5,
108.56, AD/RAD/43, AD/INST/8 Amdt 4 and
AD/INST/9 Amdt 6
COMMENT 140 – Compass swing
Respondent stated: Compass swings still need to be carried out, as there are no compass roses
then a system comprising of AHRS alignment such as capital avionics CA320 taking away the
errors due to engineers and misreading and interpreting wet land compasses. While it does not
cater for a poor site at least there are not dual or triple ways for errors to accumulate.
CASA’s Response
CASA notes the response.
Disposition
No change.
Document NFRM 1101CS
Page B56