Suddenly, I feel very tired. Seriously, are we paying people to write this?
Firstly, there is no definition provided for equipment or airflow. Nor is there any definition of airframe.
What constitutes a piece of equipment protruding into the airflow? An HF antenna? VHF, GPS, etc? We are required to install new antennae for ADSB & 406 MHz ELT's. To the letter of this circular we now need flight testing when we change the GPS & Transponder antennae when an aircraft is upgraded to ADS-B or if a 406 HHz ELT is fitted. Want to remove a redundant ADF? That will require a report & flight test to remove its antenna too.
Thinking about installing a JPI engine monitor? If you take the OAT option, that will require a report & flight test.
How about a new aircraft cover? Aren't the press studs equipment that protude into the airflow?
The circular only gives guidance for airflow. Where does one look for issues such as structural integrity, free control movement or CofG.
It does not define " Flight test validation". Does it need to conform to the CASA guidelines for Flight Testing? Is it required to be conducted by a specialist? Can the owner do the test flight? Is a flight test report required according to the CASA Flight Test Guide? Is a risk management assessment according to AC 21-47 required?
It does not define "an authorised person" who is required to create the application. Is this what we currently refer to as CASR 21.M Authorised person? There are less than 30 of these people outside the airlines. They might be about to be busy.
After DJP going into detail with me about how CASA has omitted the minor mod exemption that exists in US law, I'm surprised he didn't get into this. The biggest problem is that CASA is treating a camera mount the same way as the modification to carry a space shuttle on the back of a 747.