{"id":"F2005B00933","name":"Civil Aviation Amendment Order (No. R87) 2004 - Civil Aviation Order 100.91 - Administration and Procedure - Aircraft Maintenance Engineer Licences - Category Airframes (12/12/2004)","slug":"civil-aviation-amendment-order-no-r87-2004-civil-aviation-order-100-91-administration-and-procedure-","collection":"legislative_instrument","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":null,"makingDate":null,"administeringDepartment":null,"currentVersion":{"id":32329,"registerId":"commonwealth-F2005B00933-current","compilationNumber":null,"startDate":"2026-04-01","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"1","sectionType":"section","heading":"Civil Aviation Amendment Order (No. R87) 2004 - Civil Aviation Order 100.91 - Administration and Procedure - Aircraft Maintenance Engineer Licences - Category Airframes (12/12/2004)","content":"Civil Aviation Amendment Order\n\n(No. R87) 2004\n\nI, WILLIAM BRUCE BYRON, Director of Aviation Safety, on behalf of CASA, issue the following Civil Aviation Order under regulation 31 of the Civil Aviation Regulations 1988.\n\n\\[Signed Bruce Byron\\]\n\nBruce Byron\n\nDirector of Aviation Safety and\n\nChief Executive Officer\n\n12 December 2004\n\n\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\\_\n\n1 Name of Order\n\nThis Order is the Civil Aviation Amendment Order (No. R87) 2004.\n\n2 Commencement\n\nThis Order commences on gazettal.\n\n3 Replacement of section 100.91 of the Civil Aviation Orders\n\nSection 100.91 of the Civil Aviation Orders is omitted and a new section substituted as set out in Schedule 1.\n\nSchedule 1 Substitution of section 100.91 of the Civil Aviation Orders\n\nSECTION 100.91\n\nADMINISTRATION AND PROCEDURE — AIRCRAFT MAINTENANCE ENGINEER LICENCES — CATEGORY AIRFRAMES\n\n1 APPLICATION\n\n1.1 Except where otherwise approved or directed by CASA, this section of the CAOs applies to the requirements for the grant of an aircraft maintenance engineer licence in category airframes and for the grant of additional ratings to a licence in this category.\n\n1.2 This section of the CAOs is to be read in conjunction with the current issue of CAO section 100.92 and AAC 9-91.\n\n2 DEFINITIONS\n\nTerms and abbreviations used in this section are detailed in CAO section 100.90.\n\n3 RATINGS\n\nCategory airframes is classified into the following ratings:\n\nGroup 1 Aeroplane systems not classified in Group 2 to 20 inclusive.\n\nGroup 2 Helicopters not fitted with flight control hydraulic boosting.\n\nGroup 3 Wooden airframe structures.\n\nGroup 4 Fabric covering of airframe structures.\n\nGroup 5 Power driven fluid systems other than Groups 2, 19 or 20.\n\nGroup 6 Airconditioning systems.\n\nGroup 7 Aircraft of fibre reinforced plastic composite construction as specified by CASA and listed in AAC 9-91.\n\nGroup 10 Pressurisation systems.\n\nGroup 19 Helicopters with hydraulically powered flight controls, not classified in Group 20.\n\nGroup 20 Aeroplanes, powered by turbojet/turbofan engines, or pressurised and of MTOW greater than 8 000 kg as listed in AAC 9-91; and\n\nHelicopters of MTOW greater than 3 500 kg fitted with flight controls powered from more than 1 hydraulic source as listed in AAC 9-91; and\n\nAircraft listed in AAC 9-91 deemed by CASA to be of an unusual design requiring specialised maintenance techniques.\n\n4 LICENCE RATINGS AND FORM OF ENDORSEMENT\n\n4.1 Ratings specifying the groups of airframe systems and/or the specific aircraft type for which the privileges of the licence may be exercised, must be endorsed on the licence.\n\n4.2 Applicants who comply with the experience and examination requirements of subsections 5 and 6 of this section may be granted the appropriate rating, subject to the conditions specified at paragraphs 4.3 to 4.5 inclusive.\n\n4.3 Applicants for a Group 3, 4, 5 or 10 rating must hold a Group 1 rating.\n\n4.4 Applicants for a Group 6 rating must hold a Group 1, 2 or 19 rating.\n\n4.5 A separate rating in Group 20 is required for each aircraft listed in AAC 9-91.\n\n4.6 Endorsement of ratings shall take the following form:\n\nAeroplane Airframe Systems Group 1\n\nHelicopter Airframe Systems Group 2\n\nWooden structures Group 3\n\nFabric Covering Group 4\n\nPower Driven Fluid Systems Group 5\n\nAirconditioning Systems Group 6\n\nComposite Aircraft Group 7\n\nPressurisation Systems Group 10\n\nHelicopter Airframe Systems Group 19\n\n\\*............................................ Group 20\n\n\\*(The appropriate aircraft type or series description as listed in AAC 9-91 is inserted in the space).\n\n5 EXPERIENCE REQUIREMENTS FOR EXAMINATIONS, GRANT OF A LICENCE OR ENDORSEMENT OF A RATING\n\n5.1 There are no work experience requirements to be met prior to sitting any examination.\n\n5.2 Successful completion of a relevant training course acceptable to CASA, will be required for all aircraft classified in Group 20, with the exceptions specified by CASA and listed in AAC 9-91.\n\n5.3 The minimum experience required for the grant of a licence is 4 years aircraft maintenance or aircraft component maintenance including:\n\n    (a) 2 years aircraft maintenance experience in category airframes; and\n    (b) practical experience in the group or type for which a rating is sought, to the scope and depth indicated in the relevant Schedule of Experience issued by CASA, or other approved documents.\n\n5.4 For aircraft classified as high capacity, practical experience must be specified in a Schedule of Experience compiled by the operator and found acceptable by CASA.\n\n5.5 For the endorsement of additional airframe ratings the minimum experience required is that specified in the relevant Schedule of Experience.\n\n6 EXAMINATION REQUIREMENTS\n\nFor the grant of a licence or endorsement of additional ratings, applicants must pass the relevant examinations specified by CASA and listed in AAC 9-91.\n\n7 LICENCE RATINGS AND EXAMINATION EQUIVALENCY\n\n7.1 From the effective date of this CAO, ratings granted in accordance with section 100.91 will be deemed to be equivalent to the corresponding ratings listed in AAC 9-91.\n\n7.2 From the effective date of this CAO, examination credits granted in accordance with section 100.91 will be deemed to be equivalent to the examinations listed in AAC 9-91.","sortOrder":0}],"analysis":{"flash_summary_failed":{"failed":true,"reason":"Unauthenticated. Configure AI_GATEWAY_API_KEY or use a provider module. Learn more: https://ai-sdk.dev/unauthenticated-ai-gateway","source":"analysis-cron"},"flash_summary":{"complexity_score":4,"scope_assessment":{"changed":true,"description":"This substituted version expands and clarifies the original administrative framework in several concrete ways: it formalises a distinct Group 20 for unusual or large aircraft requiring separate, type‑specific ratings (sections 3 and 4.5); it imposes a mandatory CASA‑acceptable training requirement for Group 20 aircraft (section 5.2); it sets a clear minimum 4‑year experience rule including 2 years in airframes (section 5.3); and it expressly deems ratings and exam credits equivalent to AAC 9-91 entries (section 7). These changes shift substantive detail into AAC 9-91 and Schedules of Experience that CASA issues or accepts, expanding the regime’s operational reach and delegating implementation detail to agency instruments (sections 2, 5.2, 5.4, 7.1–7.2)."},"complexity_factors":["Cross-references to external instruments: CAO section 100.92, CAO section 100.90 for definitions, and AAC 9-91 for lists and exam details (sections 1.2, 2, 7.1–7.2).","10 defined rating groups with special‑case rules (Groups 1–7, 10, 19 and 20) and type-specific endorsement requirements (section 3 and 4).","Conditional endorsement prerequisites (e.g. Group 3/4/5/10 applicants must already hold Group 1; Group 6 requires 1, 2 or 19) (section 4.3–4.4).","Experience rules split across general minima, group/type practical experience, and operator-compiled Schedules for high-capacity aircraft (sections 5.1–5.5).","Delegated detail: reliance on Schedules of Experience and AAC 9-91 means the CAO text is short but operational complexity is pushed to external documents (sections 5.2, 5.4, 7.1–7.2).","Equivalency/deeming clauses that convert prior ratings and exam credits to the new scheme (section 7), which raises transition considerations."],"plain_english_summary":"**What this instrument does (mechanically)\n\n- Replaces the previous CAO section 100.91 with a new, consolidated set of rules that govern how Aircraft Maintenance Engineer (AME) licences for the airframe category are administered.\n- Defines the different \"ratings\" (sub-categories) of airframe work (Groups 1–7, 10, 19 and 20) and sets what endorsements must appear on a licence (section 3 and 4).\n- Sets minimum experience and training requirements for obtaining a licence and for adding ratings to a licence (section 5), and requires passing specified examinations to get a licence or an additional rating (section 6).\n- Requires specific training for aircraft listed in Group 20 and makes practical experience requirements dependent on Schedules of Experience issued or accepted by CASA (sections 5.2–5.5).\n- Declares that ratings and examination credits issued under this CAO are to be treated as equivalent to the corresponding entries in AAC 9-91 (section 7).\n\nWho it affects\n\n- Individuals seeking an Aircraft Maintenance Engineer (airframes) licence or seeking additional airframe ratings.\n- Aircraft operators and employers who must document or provide practical experience (notably for \"high capacity\" aircraft) and may need to run training acceptable to CASA (sections 5.4 and 5.2).\n- CASA (Civil Aviation Safety Authority), which approves courses, accepts schedules of experience, lists aircraft and training exceptions in AAC 9-91, and endorses licences (sections 1.1, 2, 5.2, 5.4, 7.1–7.2).\n\nWhy it matters (purpose-claims and practical effects)\n\n- The CAO aims to set clear, uniform requirements for who can be licensed to perform airframe maintenance (stated in section 1.1). Practically this establishes what training, experience and examinations an applicant must have before they can lawfully exercise maintenance privileges for particular aircraft systems or types.\n- It tightens regulatory detail for more complex or unusual aircraft by: (a) introducing Group 20 as a distinct class requiring separate ratings for each listed type (section 3 and 4.5), and (b) requiring completion of CASA-acceptable training for Group 20 aircraft (section 5.2).\n\nCosts, incentives and trade-offs (mechanisms, not judgments)\n\n- Direct costs and time: applicants must pass CASA-specified examinations (section 6) and, where required, complete CASA-acceptable training (section 5.2). Those costs are typically borne by the trainee or their employer.\n- Barrier to entry / credentialing: the minimum experience for a licence is 4 years including two years in airframes and practical experience in the relevant group/type (section 5.3). That raises the time and employment-experience threshold before someone can hold full privileges.\n- Delegated detail and administrative discretion: key details (which aircraft fall into Group 20, training exceptions, and the specific exams) are determined by AAC 9-91 and Schedules of Experience that CASA issues or accepts (sections 2, 3, 5.2, 5.4, 7.1–7.2). This means operational specifics sit outside the CAO and rely on CASA’s instruments.\n- Operator responsibility for high-capacity aircraft: practical experience for high-capacity aircraft must be set out by the operator in a Schedule of Experience and accepted by CASA (section 5.4). That shifts preparation and documentation work onto operators for those types.\n\nWho pays and who decides\n\n- Who pays: applicants and/or their employers pay for training, examinations and the time spent gaining required practical experience. Operators may incur costs preparing Schedules of Experience for high-capacity aircraft (section 5.4).\n- Who decides: CASA decides which aircraft are in Group 20 and what training/examinations/schedules are acceptable (sections 3, 5.2, 5.4, 7.1–7.2). CASA issues or accepts Schedules of Experience and lists in AAC 9-91.\n\nImplementation risks and compliance burden\n\n- Reliance on external instruments (AAC 9-91 and Schedules of Experience) concentrates detailed rulemaking outside the CAO; this could create uncertainty for applicants until those external lists and schedules are published and kept current (sections 2, 3, 5.2, 5.4, 7.1–7.2).\n- Practical experience requirements and type-specific endorsements (particularly for Group 20) create an administrative burden for both applicants (recording experience) and operators (compiling acceptable Schedules of Experience) (sections 4.5, 5.3–5.5).\n\nShort summary of the main obligations (by section)\n\n- Section 3: Defines the Groups (ratings) for airframe maintenance.\n- Section 4: Requires that ratings be endorsed on licences and sets preconditions for certain endorsements (for example, Group 3–5 and 10 applicants must already hold Group 1) (4.3–4.5).\n- Section 5: Sets experience and training rules — 4 years total experience for a licence (including 2 years in airframes) and CASA-acceptable training for Group 20 (5.2–5.3).\n- Section 6: Requires passing CASA-specified examinations for licences and ratings (6).\n- Section 7: Declares equivalency with AAC 9-91 for ratings and examination credits (7.1–7.2).\n\nSource pointers: the main operative provisions are in sections 3, 4, 5, 6 and 7 of the substituted CAO section 100.91."},"kimi_summary":{"content_quality":"ok","complexity_score":5,"scope_assessment":{"changed":false,"description":"This is a straightforward amendment order replacing one section of the Civil Aviation Orders. It maintains the established scope of regulating aircraft maintenance engineer licensing for airframes. The structure of rating groups and the reference to external documents (AAC 9-91) appears consistent with the original framework of the Civil Aviation Orders system, not an expansion beyond the original regulatory purpose."},"complexity_factors":["20 distinct rating groups with specific prerequisites and dependencies (e.g., Groups 3-5 and 10 require Group 1; Group 6 requires Group 1, 2, or 19)","Heavy reliance on external documents: references to 'AAC 9-91' (an Advisory Circular), 'CAO section 100.90' (definitions), 'CAO section 100.92', and 'Schedule of Experience' documents issued by CASA — the full rules are not self-contained","Conditional logic for Group 20: separate rating required per aircraft type, with exceptions to training requirements also listed in AAC 9-91","Cross-referencing between multiple CAO sections (100.90, 100.91, 100.92) and regulations (CAR 1988, regulation 31)","Specific technical classifications (MTOW thresholds of 8,000kg for aeroplanes and 3,500kg for helicopters) that trigger different rating requirements","Transitional provisions (section 7) creating deemed equivalencies between old and new rating systems"],"plain_english_summary":"**What this legislation does:**\n\nThis Order updates the rules for who can get a licence to repair and maintain aircraft airframes (the main body structure of planes and helicopters) in Australia. It replaces the old rules with a new system for issuing **Aircraft Maintenance Engineer Licences** specifically for the \"airframes\" category.\n\n**Who it affects:**\n\n- **Aircraft maintenance engineers** who want to get licensed or add new qualifications (called \"ratings\") to work on airframes\n- **Training organisations** that teach aircraft maintenance\n- **Airlines and operators** who need to ensure their maintenance staff are properly qualified\n- **CASA** (the Civil Aviation Safety Authority) — the regulator that approves licences\n\n**Key things it sets out:**\n\n- **20 different ratings** (specialist qualifications) covering different types of aircraft and systems:\n  - Groups 1–6, 7, 10, 19, and 20 — ranging from basic aeroplane systems to complex pressurised jets and composite materials\n  - **Group 20** is special: it covers large jets, heavy helicopters, and unusual designs — each aircraft type needs its own separate rating\n\n- **Experience requirements:**\n  - **4 years total** maintenance experience (2 years specifically on airframes)\n  - Practical experience in the specific area you want to be rated for\n  - Special training courses required for Group 20 aircraft\n\n- **Examination rules:**\n  - You can sit exams **before** getting work experience (unlike some previous rules)\n  - Must pass CASA-specified exams for each rating\n\n- **Prerequisites:**\n  - To get Groups 3, 4, 5, or 10, you must already hold Group 1\n  - To get Group 6, you must hold Group 1, 2, or 19\n\n**Why it matters:**\n\nThis ensures that people fixing aircraft are properly qualified for the specific systems they're working on. A mechanic qualified to patch fabric on a small plane (Group 4) shouldn't automatically be allowed to repair hydraulic systems on a Boeing 747 (Group 20). The rules create a clear ladder of qualifications, with the most complex aircraft requiring the most specific training and experience."}},"importantCases":[],"_links":{"self":"/api/acts/civil-aviation-amendment-order-no-r87-2004-civil-aviation-order-100-91-administration-and-procedure-","history":"/api/acts/civil-aviation-amendment-order-no-r87-2004-civil-aviation-order-100-91-administration-and-procedure-/history","analysis":"/api/acts/civil-aviation-amendment-order-no-r87-2004-civil-aviation-order-100-91-administration-and-procedure-/analysis","conflicts":"/api/acts/civil-aviation-amendment-order-no-r87-2004-civil-aviation-order-100-91-administration-and-procedure-/conflicts","importantCases":"/api/acts/civil-aviation-amendment-order-no-r87-2004-civil-aviation-order-100-91-administration-and-procedure-/important-cases","documents":"/api/acts/civil-aviation-amendment-order-no-r87-2004-civil-aviation-order-100-91-administration-and-procedure-/documents"}}