In August 2008 the CAA consulted participants on a draft legal information bulletin number 4, about the interpretation of the Part 1 definitions of “crew member”, and “commercial transport operation”. Written submissions and feedback were received over the following months and were considered by the CAA.

The interpretation in the draft bulletin raised two issues of concern by submitters:

  • whether the requirement to hold a Part 119 air operator certificate applied to the carriage of certain passengers on agricultural operations, and
  • whether commercial wild animal recovery operations are required to be conducted under a Part 119/135 air operator certificate.

These issues, and the decisions made by the CAA, are outlined in more detail in the summary of submissions. That document also outlines the other issues raised by submitters and the CAA’s responses.

Summary of submissions on draft LIB 4 [PDF 63 KB] (includes CAA responses)

Letter from Crown Law concerning LIB 4 [PDF 182 KB]

Aviation Industry Association submission on draft LIB 4 [PDF 502 KB]