Australian Part 121 regulations:
AusALPA made a submission to a recent CASA Part 121 consultation. The main subjects were regarding EDTO Alternate requirements (reduced requirements), TSI reporting (particularly unstable approach criteria), take-off splay and Implementation of the Global Aeronautical Distress Safety System.
Here’s a summary of Proposed Part 121 Changes & AusALPA Responses
Change 1 – Remove RFFS requirements at EDTO ERA aerodromes in Australia
Policy Intent
CASA proposes to remove the requirement for EDTO ERA aerodromes to have RFFS at least equivalent to RFF Category 4.
AusALPA Response
Q1 (Do you agree with the aim?) → Disagree
Reduced RFFS exposes crews and passengers to higher consequence risk during emergency diversions.
EDTO ERA selection involves multiple risk-critical factors (terrain, runway condition, aids, RFFS capability, facilities, medical support, pilot familiarity).
CASA relies too heavily on “low probability” rather than severity of consequence.
AusALPA wants a specific risk-based rule supported by AMC/GM—not just SMS guidance.
Will not support the change until AMC/GM is published and proven “fit for purpose.”
Q2 (Does the change achieve its aim?) → Agree (but disagree with the policy)
Acknowledges the policy does remove the RFFS requirement but reiterates that AMC/GM must define required mitigations.
Change 2 – Replace transitional RNP-based EODP obstacle assessment criteria (Part 135 relevant)
Policy Intent
Replace expired CAO method with updated, modern RNP-based engine-out departure obstacle assessment criteria.
AusALPA Response
Q1–Q5 → Agree on all items
Support the updated method.
Accept proposed conditions for operator/designer competency and operational controls.
Support consequential amendments as long as measures are properly implemented and enforced.
Change 3 – Permit reduced landing performance requirements for wet/contaminated destination aerodromes (Part 135 relevant)
Policy Intent
Allow planning to wet/contaminated runways using requirements “one step” less restrictive, with added controls.
AusALPA Response
Q1 → Not formally answered, but comments provided:
Pilots must be aware that reduced planning minima do not guarantee actual landing suitability.
Human factors risks include subtle pressure to continue to land.
Pilots must feel free to divert when conditions deteriorate.
Q2–Q3 → Agree
Change is acceptable if implemented correctly, and crews clearly understand that these are mitigations only—not a mandate to land.
Change 4 – Permit alternate minima to be no more restrictive than destination minima
Policy Intent
Allow destination alternate or non-EDTO ERA minima to match destination minima (not more restrictive).
AusALPA Response
Q1–Q2 → Agree
No additional concerns raised.
Change 5 – Add Table 4.11 provisions for aerodromes with ≥2 straight-in IAP to one runway
Policy Intent
Insert new criteria eliminating circling requirements where straight-in approaches exist, with specific additives (400 ft and 1.5 km).
AusALPA Response
Q1–Q3 → Agree
Supports eliminating circling approaches.
Additives are appropriate and consistent with ETOPS ERA planning.
Weather forecasting must be conservative.
Change 6 – Allow isolated destination aerodromes to be planned with a destination alternate
Policy Intent
Permit planning to otherwise isolated aerodromes, provided fuel requirements include a diversion beyond 90 minutes.
AusALPA Response
Q1–Q3 → Agree
Acceptable if Part 121 MOS 7.05 fuel requirements are fully applied for both flight and diversion planning.
Change 7 – Replace IAP classifications to align with updated Part 91 MOS
Policy Intent
Use the same IAP classifications (from Part 91 MOS) within Part 121, including for EDTO ERA minima determination.
AusALPA Response
Q1–Q2 → Agree
Change 8 – Amend TAWS Class-A and Class-B definitions
Policy Intent
Permit TAWS Class-A and Class-B equipment approved to (E)TSO-C151a or later.
AusALPA Response
Q1–Q2 → Agree
General Comments From AusALPA
CASA should strive for ICAO compliance, not rely on “filed differences.”
Statements like “it is too difficult here” are unacceptable as regulatory justifications.
An “acceptable level of safety” must be backed by quantitative analysis, not qualitative assertions.
AusALPA’s Top Three Priorities
A specific risk-based rule (with AMC/GM) for selecting an EDTO ERA—not reliance on SMS alone.
Protect pilots from subtle pressure to land when dispatch criteria are loosened—HF considerations must be explicit.
Ensure all proposed requirements, conditions, and criteria are actually implemented and enforced.