"Type training" ops manual changes

[Guest Nobody]

Am I reading this correctly? The way I read it you will need a logbook sign off from an instructor for each aircraft type that you are going to fly. This seems a little over the top...

 

 

[coljones]

Am I reading this correctly? The way I read it you will need a logbook sign off from an instructor for each aircraft type that you are going to fly. This seems a little over the top...

What are you reading? Is this the missing RAA Draft Ops Manual that no-one will talk about?

 

 

[Camel]

Is that in USA..?

 

 

[Chird65]

What are you reading? Is this the missing RAA Draft Ops Manual that no-one will talk about?

Try:

http://www.raa.asn.au/2014/01/proposed-operations-manual-changes/

 

 

[Guest Nobody]

From the Members section of the RA-Aus website....

 

Proposed Operations Manual changes

January 23, 2014 | members

 

Acting on a Board request, Operations have proposed changes to some Endorsements detailed in the next Operations Manual (Issue 7).

 

Presently, members obtain a High or Low Performance endorsement on their Pilot Certificate based on the aircraft type they have trained in or converted to. The High or Low performance endorsement was intended to provide understanding of the different flight characteristics and possibly limited manoeuvring envelopes of different aeroplane types. However, the High and Low performance endorsement may not provide sufficient assurance that a pilot can safely operate a new aeroplane type. Experienced Instructors, CFI’s, glider pilots and commercial pilots all agree that it can take between 5 – 50 hours to become fully confident and competent on a new type, no matter how many hours a pilot may have. Obviously this figure varies based on factors including pilot currency, recency, competency, total experience and hours on a similar type.

 

A typical scenario where incidents or accidents may occur include members who trained on and gain a Pilot Certificate on one type of aircraft, then purchase a different type intended for use at an airfield different to their local aerodrome.

 

An incident or accident occurs during the take-off or landing phase. Aircraft types which figure prominently in this occurrence include types with Short Take-off and Landing (STOL) characteristics being flown by pilots who have been converted from a high performance (trainer) type. In this scenario, pilots generally require additional training in short field operations, decision making and setting of personal minimums.

 

All of which is a long winded explanation for why a change is proposed from the High/Low Performance category to simply – Type Training. Type training will involve the Pilot Certificate holder undertaking appropriate training in an aircraft type with an Instructor, who then makes a logbook entry to state that the pilot has been assessed as competent on type. No notification to RA-Aus is required, simply the logbook entry noting the aircraft type for which training has been completed.

 

Obviously, pilots and Instructors who have logbook entries of appropriate time in a specific type may be considered to hold the required type training for the type depending on pilot experience and currency.

 

We anticipate the new Operations Manual should be approved and distributed to members in the near future.

 

Operations.

[Tomo]

Interesting, probably makes sense for those that have really only ever flown one type of aircraft. Someone that has only ever flown Tecnam's are going to be a bit interesting in a Jabiru and so I'd encourage this. As long as instructors treat it right and don't rip people off by it.

 

 

[aro]

From the Members section of the RA-Aus website....

It's the sort of change that looks quite reasonable until you try to work out the details.

 

How do you find an instructor rated in type? Or are instructors assumed to have competence in all types?

 

What about types where training is not allowed e.g. amateur built where you are not the original builder?

 

What about single seat types?

 

I don't understand why RAA writes rules that are more restrictive than GA. If you train in a 172, what training are you REQUIRED to have before you fly a 152, a Warrior, GA reg. Jabiru or Gazelle, Tripacer, Glastar, RV-9A, etc? Certainly training is advisable. It might not always be available.

 

A wise pilot would get training in something as similar as possible, certainly. Are GA pilots wiser than RAA? If RAA pilots can't be trusted to make sensible decisions about training, maybe that needs to be addressed rather than making rules that are likely to be problematic.

 

 

[Guest Nobody]

There are a few issues I have with this. What is the definition of type in the RAA context? Is a jabiru 160 the same type as a 170 or will you need a separate sign off for both? If you have a flown a retractable tecnam sierra do you need further training to fly the fixed gear version?

 

The way I see it as another rule that will have marginal improvement in safety but will become a compliance nightmare...

 

 

[metalman]

I had an instructor writing an entry into the endorsement section of my log book for every different RAA type I got checked out in,,,a GA instructor had a look at it one day and asked who wrote all the crap in my book, needless to say it didn't happen again, I always thought it was odd, but being a low timer I just accepted it as right

 

Matty

 

 

[coljones]

Try:http://www.raa.asn.au/2014/01/proposed-operations-manual-changes/

Ah Thanks Chird.

The note was posted on Thursday 23 Janaury. I note that this was requested by the board and would have been included in the secret minutes. So near and yet so far.

 

 

[storchy neil]

I had an instructor writing an entry into the endorsement section of my log book for every different RAA type I got checked out in,,,a GA instructor had a look at it one day and asked who wrote all the crap in my book, needless to say it didn't happen again, I always thought it was odd, but being a low timer I just accepted it as right

 

Matty

 

matty I have been checked out on four planes all are in my log book including cons speed prop all are different

 

your GA instructor is full of it xxxx

 

as one instructor found out that flying a storch s was totally different to a gazelle or a tecnam or a jab or Texan and yes he did two hrs at my cost whitch was a surprise to me

 

no surprise to me as I go to these meetings those of you that complain get of your arxx and attend meetings neil

 

 

[nong]

Great to see RAAus bringing in idiot regulations virtually identical to regulations that a predecessor of CASA abolished as unworkable and of no value, some decades back.

 

This is what happens when you turn over staff rapidly and there is no corporate knowledge in an organisation....no staff with a detailed history of their core subject matter.

 

 

[metalman]

I had an instructor writing an entry into the endorsement section of my log book for every different RAA type I got checked out in,,,a GA instructor had a look at it one day and asked who wrote all the crap in my book, needless to say it didn't happen again, I always thought it was odd, but being a low timer I just accepted it as right

Matty

 

matty I have been checked out on four planes all are in my log book including cons speed prop all are different

 

your GA instructor is full of it xxxx

 

as one instructor found out that flying a storch s was totally different to a gazelle or a tecnam or a jab or Texan and yes he did two hrs at my cost whitch was a surprise to me

 

no surprise to me as I go to these meetings those of you that complain get of your arxx and attend meetings neil

Neil, flying different types is NOT a new endorsement , you/ me are already endorsed to fly fixed wing single engine 544/600 for RAA or <5700 if PPL , a new type definatly needs a check ride to be shown any behaviours as well as being competent for insurance purposes, but a log book entry in endorsements , not needed, ,,,,,,unless it is with a new design feature CSU ,retract ,tailwheel ,IFA prop, then that feature needs to be entered as an endorsement , this is one of the annoying things in RAA, the instructors often make up rules to suit themselves , along with little odd things in the syllabus, if nothing else comes from the recent shake up a bit of standardization wouldn't go astray . And Neil, it's not just one GA FI ,it's actually normal for GA CFI's to know and understand the regs,

Matty

 

 

[Dafydd Llewellyn]

Great to see RAAus bringing in idiot regulations virtually identical to regulations that a predecessor of CASA abolished as unworkable and of no value, some decades back. This is what happens when you turn over staff rapidly and there is no corporate knowledge in an organisation....no staff with a detailed history of their core subject matter.

I have to agree. Way back, one had to have a separate endorsement in one's log book for each individual aircraft type. That was abolished in the late 1960's if my memory serves me correctly. Ever since then, in GA there are "class" endorsements - you need one for tailwheel, C/S propeller, retractable gear, floats, hulls, low flying, glider towing etc; but if you have, say, a glider towing endorsement in a Super Cub, it also holds for an Auster or a Pawnee or a Cessna 180.

 

If the RAA consider it necessary to take this retrograde step, that's an admission that the RAA training system isn't producing competent pilots, I'd say.

 

 

[Bob Llewellyn]

I have to agree. Way back, one had to have a separate endorsement in one's log book for each individual aircraft type. That was abolished in the late 1960's if my memory serves me correctly. Ever since then, in GA there are "class" endorsements - you need one for tailwheel, C/S propeller, retractable gear, floats, hulls, low flying, glider towing etc; but if you have, say, a glider towing endorsement in a Super Cub, it also holds for an Auster or a Pawnee or a Cessna 180. If the RAA consider it necessary to take this retrograde step, that's an admission that the RAA training system isn't producing competent pilots, I'd say.

A very grey area; please ignore the spruik in the tail of the attached doc, and look at what the stats do (and don't) indicate...

Becoming Safe, staying Safe.pdf

 

Becoming Safe, staying Safe.pdf

 

Becoming Safe, staying Safe.pdf

[Dafydd Llewellyn]

A very grey area; please ignore the spruik in the tail of the attached doc, and look at what the stats do (and don't) indicate...

Well, that surely indicates that introducing individual type endorsements into RAA training is about on a par with buttering the edges of a slice of bread.

 

 

[Bob Llewellyn]

Well, that surely indicates that introducing individual type endorsements into RAA training is about on a par with buttering the edges of a slice of bread.

Yes, a completely wrong focus. RAAus safety has actually developed rapidly to an outstanding level, as shown in the attachment in question; and it's not a very tricky bit of statistical analysis to see that RAAus needs to get real about maintenance, about 3 years ago would be perfect...

 

 

[aro]

A very grey area; please ignore the spruik in the tail of the attached doc, and look at what the stats do (and don't) indicate...

I'm not sure that any conclusion can be drawn from the stats as presented. When you apply a reasonable assumption (RA and GA human factors accidents happen at a similar rate) and come up with an unreasonable conclusion (96% of accidents are caused by aircraft failures) I think it points to a problem with the original figures. You then adjust the assumptions (rate of human factors accidents) to get a more reasonable answer for aircraft failure accidents. This doesn't seem right to me.

 

Am I correct that you are comparing GA in the 1960s to RA in 2000+?

 

To get any valid conclusions, I think more variables need to be understood. What types of flying are included in the GA figures? Are there significant differences in e.g. age and experience of the 2 pilot samples?

 

It would be interesting to compare GA vs RA accident rates for GA private pilots only. Or pilots who flew less than 100 hours in the previous 12 months. That would give you are more comparable sample. And I think the comparison should be for a similar time period, not 40 years apart.

 

It's tempting to say "Well, this is the best data we have, so we will see what conclusions we can draw from it" but sometimes the answer has to be "Not enough information".

 

 

[Bob Llewellyn]

I'm not sure that any conclusion can be drawn from the stats as presented. When you apply a reasonable assumption (RA and GA human factors accidents happen at a similar rate) and come up with an unreasonable conclusion (96% of accidents are caused by aircraft failures) I think it points to a problem with the original figures. You then adjust the assumptions (rate of human factors accidents) to get a more reasonable answer for aircraft failure accidents. This doesn't seem right to me.Am I correct that you are comparing GA in the 1960s to RA in 2000+?

 

To get any valid conclusions, I think more variables need to be understood. What types of flying are included in the GA figures? Are there significant differences in e.g. age and experience of the 2 pilot samples?

 

It would be interesting to compare GA vs RA accident rates for GA private pilots only. Or pilots who flew less than 100 hours in the previous 12 months. That would give you are more comparable sample. And I think the comparison should be for a similar time period, not 40 years apart.

 

It's tempting to say "Well, this is the best data we have, so we will see what conclusions we can draw from it" but sometimes the answer has to be "Not enough information".

The first conclusion must be (as some people have already observed) that the RAAus accident reporting - that is, the information provided to RAAus by operators and CASA's expert accident investigation team (sorry, put that in for a laugh) is inadequate.

Note that the basis of comparison is the timebase against airworthiness standards, which is accepted by ICAO as the prime determinate of hardware safety.

 

Now, if one applies the (some would say, optomistic) assumption that RAA & GA human factors rates are equal, then even on a 1-sigma basis it must be accepted that hardware failure accident rates in RAAus MUST BE higher than in GA. Having been involved in the wreckage analysis of a few light aircraft crashes, and having had over 300 aircraft repair schemes approved, I have no doubt whatsoever that most RAAus aeroplanes would not meet a GA airworthiness standard - or even many ultralight / sports airworthiness standards - in many areas; as said standards are a mechanism for reducing accident rates, the argument is a non-event. Try it thussly:

 

1) Airworthiness Design Standards reduce the accident rate;

 

2) Most RAaus aeroplanes meet, at best, parts of an airworthiness design standard;

 

3) RAAus aeroplanes should, therefore, have a higher accident rate from hardware failure than GA aeroplanes;

 

4) RAAus aeroplanes do have a higher accident rate due to hardware failure, than GA, although there is insufficient data to be precise about the figure;

 

5) The Maintenance of Airworthiness, via Approved Maintenance Organisations, Licensed Aircraft Maintenance Engineers, and Approved Maintenance Data, prevents the vast majority of hardware failures in GA;

 

6) RAAus maintainers have very little training*, very few aeronautical engineering qualifications, and extremely little Approved Maintenance Data; and there is no parallel substitute; so RAAus aeroplanes must undergo a higher rate of hardware failures per hour of operation, as they operate under the same laws of physics etc;

 

7) The RAAus accident rate is increasing from a minima, and the fleet mean age is growing. It is internationally accepted that the older the fleet (GA or otherwise), the more rigorous the demands on maintenance.

 

*LAMEs are trained to apply Approved Data; LAME training is not of great use in RA, without Approved Data specific to the Type in question.

 

So - RAAus needs to lift the maintenance game. Now, as CASA is ultimately responsible, and CASA does not provide RAAus resources (fiscal or otherwise) to enhance the maintenance practises and expertise of the membership, it is CASA'a irresponsibility - imposed upon them by various Ministers for Aviation - that allows this failure.

 

If you can demonstrate that, somehow, design, construction, and maintenance in accordance with Design Airworthiness Standards do not enhance safety, then there is no safety issue, and the world's airworthiness authorities can retire, saving quite a lot of money,

 

 

[M61A1]

The first conclusion must be (as some people have already observed) that the RAAus accident reporting - that is, the information provided to RAAus by operators and CASA's expert accident investigation team (sorry, put that in for a laugh) is inadequate.Note that the basis of comparison is the timebase against airworthiness standards, which is accepted by ICAO as the prime determinate of hardware safety.

 

Now, if one applies the (some would say, optomistic) assumption that RAA & GA human factors rates are equal, then even on a 1-sigma basis it must be accepted that hardware failure accident rates in RAAus MUST BE higher than in GA. Having been involved in the wreckage analysis of a few light aircraft crashes, and having had over 300 aircraft repair schemes approved, I have no doubt whatsoever that most RAAus aeroplanes would not meet a GA airworthiness standard - or even many ultralight / sports airworthiness standards - in many areas; as said standards are a mechanism for reducing accident rates, the argument is a non-event. Try it thussly:

 

1) Airworthiness Design Standards reduce the accident rate;

 

2) Most RAaus aeroplanes meet, at best, parts of an airworthiness design standard;

 

3) RAAus aeroplanes should, therefore, have a higher accident rate from hardware failure than GA aeroplanes;

 

4) RAAus aeroplanes do have a higher accident rate due to hardware failure, than GA, although there is insufficient data to be precise about the figure;

 

5) The Maintenance of Airworthiness, via Approved Maintenance Organisations, Licensed Aircraft Maintenance Engineers, and Approved Maintenance Data, prevents the vast majority of hardware failures in GA;

 

6) RAAus maintainers have very little training*, very few aeronautical engineering qualifications, and extremely little Approved Maintenance Data; and there is no parallel substitute; so RAAus aeroplanes must undergo a higher rate of hardware failures per hour of operation, as they operate under the same laws of physics etc;

 

7) The RAAus accident rate is increasing from a minima, and the fleet mean age is growing. It is internationally accepted that the older the fleet (GA or otherwise), the more rigorous the demands on maintenance.

 

*LAMEs are trained to apply Approved Data; LAME training is not of great use in RA, without Approved Data specific to the Type in question.

 

So - RAAus needs to lift the maintenance game. Now, as CASA is ultimately responsible, and CASA does not provide RAAus resources (fiscal or otherwise) to enhance the maintenance practises and expertise of the membership, it is CASA'a irresponsibility - imposed upon them by various Ministers for Aviation - that allows this failure.

 

If you can demonstrate that, somehow, design, construction, and maintenance in accordance with Design Airworthiness Standards do not enhance safety, then there is no safety issue, and the world's airworthiness authorities can retire, saving quite a lot of money,

I think that you are correct in saying that the airworthiness standards improve safety, that really cannot be argued, but I do think that the statistical methods used are somewhat skewed in the direction that the author wants them to be.

No, the RAA accident reporting is not going to yield any hard information, but, rather than manipulate stats to say what you want, would it be more reliable to use a probable cause, for example, it would be realistic to suggest that an aircraft stalling as it turns from base to final, or flew into ground when it was dark, was a human, aircraft handling problem, rather than say "we can't be sure it wasn't maintenance, so lets make new maintenance rules"?

 

We seem to have had quite a few of these sorts of incidents of late. I know that we can't rule out maintenance as a factor, but I would consider that human factors is a more probable answer for a significant proportion of our incidents. We already have HF training, but in it's current form, I doubt it has done much, but that's just a personal viewpoint based on my experiences in aviation maintenance.

 

I'm only going from memory, but if there are actual stats that clearly show maintenance is an issue, bring 'em out, I'd love to see 'em.

 

Good maintenance certainly can't hurt, but I doubt very much that it will make much of a difference to the actual issue of the govt wanting people to stop hurting themselves in those dangerous machines.

 

Those who prefer certified aircraft, with certified maintenance have that option already.

 

 

[aro]

The problem with your stats is not with the RAA portion - if you want to compare total RAA fatal accidents, I would expect the RAA stats are adequate - all you need is hours vs. fatal accidents. However, if you want to compare it to GA you need to separate out the portion of GA that is equivalent to RAA flying, e.g. day VFR private flying. This is, I think, difficult.

 

To address your points:

 

1) Airworthiness Design Standards reduce the accident rate;

 

Initially I'm sure they did. Are aircraft still designed to the minimum required by design standards? Do more design standards reduce the accident rate more? How much is enough? Many would argue that airworthiness design standards currently prevent innovations that could themselves significantly reduce the accident rate, e.g. compare non certified synthetic vision features and prices vs certified.

 

In most cases it is the requirement to produce safe and reliable products that drives design, rather than design standards e.g. I understand Lycoming engines far exceed the reliability required by design standards.

 

2) Most RAaus aeroplanes meet, at best, parts of an airworthiness design standard;

 

3) RAAus aeroplanes should, therefore, have a higher accident rate from hardware failure than GA aeroplanes;

 

I'm not sure that necessarily follows - really, it is the question that we are trying to answer.

 

4) RAAus aeroplanes do have a higher accident rate due to hardware failure, than GA, although there is insufficient data to be precise about the figure;

 

I wouldn't be surprised if this is true, but I don't know either way. I don't think the figures you present demonstrate that.

 

5) The Maintenance of Airworthiness, via Approved Maintenance Organisations, Licensed Aircraft Maintenance Engineers, and Approved Maintenance Data, prevents the vast majority of hardware failures in GA;

 

I would expect that is true. I also suspect, paradoxically, that maintenance also causes many of the hardware failures i.e. they prevent wear related failures, but generate maintenance error failures. The relative rate of the different types of failures would be interesting to know.

 

The best way to reduce failures is to reduce the amount of maintenance actually required. Design standards and inflexible maintenance schedules can work against this. RAA aircraft in theory are simpler and require less maintenance - which was the original basis of the current rules.

 

6) RAAus maintainers have very little training, very few aeronautical engineering qualifications, and extremely little Approved Maintenance Data; and there is no parallel substitute; so RAAus aeroplanes must undergo a higher rate of hardware failures per hour of operation, as they operate under the same laws of physics etc;

 

Must? Why? If they are simpler or designed to require less maintenance, it is still possible to be more reliable. Do modern cars have more failures per hour of operation than GA aircraft, due to the lower qualifications required for car mechanics?

 

7) The RAAus accident rate is increasing from a minima, and the fleet mean age is growing. It is internationally accepted that the older the fleet (GA or otherwise), the more rigorous the demands on maintenance.

 

True, although the overall effect depends on the baseline level.

 

If you can demonstrate that, somehow, design, construction, and maintenance in accordance with Design Airworthiness Standards do not enhance safety, then there is no safety issue, and the world's airworthiness authorities can retire, saving quite a lot of money

 

I suspect a lot of fat could be cut from the worlds airworthiness authorites without significantly affecting safety.

 

 

[Bob Llewellyn]

I think that you are correct in saying that the airworthiness standards improve safety, that really cannot be argued, but I do think that the statistical methods used are somewhat skewed in the direction that the author wants them to be.No, the RAA accident reporting is not going to yield any hard information, but, rather than manipulate stats to say what you want, would it be more reliable to use a probable cause, for example, it would be realistic to suggest that an aircraft stalling as it turns from base to final, or flew into ground when it was dark, was a human, aircraft handling problem, rather than say "we can't be sure it wasn't maintenance, so lets make new maintenance rules"?

We seem to have had quite a few of these sorts of incidents of late. I know that we can't rule out maintenance as a factor, but I would consider that human factors is a more probable answer for a significant proportion of our incidents. We already have HF training, but in it's current form, I doubt it has done much, but that's just a personal viewpoint based on my experiences in aviation maintenance.

 

I'm only going from memory, but if there are actual stats that clearly show maintenance is an issue, bring 'em out, I'd love to see 'em.

 

Good maintenance certainly can't hurt, but I doubt very much that it will make much of a difference to the actual issue of the govt wanting people to stop hurting themselves in those dangerous machines.

 

Those who prefer certified aircraft, with certified maintenance have that option already.

I'm trying to show that the stats establish some boundaries, and anywhere within those boundaries (save for what I consider a laughably high human factors contribution), the hardware contribution is orders greater than GA. I note that some people separate human factors during maintenance (eg misfuelling, not checking a clogged fuel filter) and human factors during flight, which further confuses the issue!

A perusal of the accidents and incidents in back copies of the AUF / RAAus rag tend to show more hardware issues - generally minor - than pilot choices gone wrong.

 

At present, L1s and L2s are trying to keep aeroplanes flying with scant or non-existant type specific maintenance data; and I'm saying that relatively little expenditure on training and processes could reap a disproportionally large improvement in achieved safety.

 

 

[M61A1]

At present, L1s and L2s are trying to keep aeroplanes flying with scant or non-existant type specific maintenance data.

I must admit,I'd love to get my hands on some drawing and specs for Drifters.

I see more clearly what you are saying now, and I agree some maintenance training can't hurt, but I suspect it will improve things very little.

 

 

[aro]

I'm trying to show that the stats establish some boundaries, and anywhere within those boundaries (save for what I consider a laughably high human factors contribution), the hardware contribution is orders greater than GA. I note that some people separate human factors during maintenance (eg misfuelling, not checking a clogged fuel filter) and human factors during flight, which further confuses the issue!A perusal of the accidents and incidents in back copies of the AUF / RAAus rag tend to show more hardware issues - generally minor - than pilot choices gone wrong.

At present, L1s and L2s are trying to keep aeroplanes flying with scant or non-existant type specific maintenance data; and I'm saying that relatively little expenditure on training and processes could reap a disproportionally large improvement in achieved safety.

You're probably right, I just see problems with the stats you are using. Adjusting the assumptions until the results are within expected bounds isn't right.

 

I would be more interested to see (and much more convinced by) stats that showed RAA accidents vs. GA private flying accidents, for the same years. Even then you would have doubt about the effect of RAA vs. PPL training, unless you had the figures for how many of the RAA pilots had a PPL and could adjust for that.

 

 

[Bob Llewellyn]

The problem with your stats is not with the RAA portion - if you want to compare total RAA fatal accidents, I would expect the RAA stats are adequate - all you need is hours vs. fatal accidents. However, if you want to compare it to GA you need to separate out the portion of GA that is equivalent to RAA flying, e.g. day VFR private flying. This is, I think, difficult.To address your points:

 

1) Airworthiness Design Standards reduce the accident rate;

 

Initially I'm sure they did. Are aircraft still designed to the minimum required by design standards? Do more design standards reduce the accident rate more? How much is enough? Many would argue that airworthiness design standards currently prevent innovations that could themselves significantly reduce the accident rate, e.g. compare non certified synthetic vision features and prices vs certified.

 

In most cases it is the requirement to produce safe and reliable products that drives design, rather than design standards e.g. I understand Lycoming engines far exceed the reliability required by design standards.

 

2) Most RAaus aeroplanes meet, at best, parts of an airworthiness design standard;

 

3) RAAus aeroplanes should, therefore, have a higher accident rate from hardware failure than GA aeroplanes;

 

I'm not sure that necessarily follows - really, it is the question that we are trying to answer.

 

4) RAAus aeroplanes do have a higher accident rate due to hardware failure, than GA, although there is insufficient data to be precise about the figure;

 

I wouldn't be surprised if this is true, but I don't know either way. I don't think the figures you present demonstrate that.

 

5) The Maintenance of Airworthiness, via Approved Maintenance Organisations, Licensed Aircraft Maintenance Engineers, and Approved Maintenance Data, prevents the vast majority of hardware failures in GA;

 

I would expect that is true. I also suspect, paradoxically, that maintenance also causes many of the hardware failures i.e. they prevent wear related failures, but generate maintenance error failures. The relative rate of the different types of failures would be interesting to know.

 

The best way to reduce failures is to reduce the amount of maintenance actually required. Design standards and inflexible maintenance schedules can work against this. RAA aircraft in theory are simpler and require less maintenance - which was the original basis of the current rules.

 

6) RAAus maintainers have very little training, very few aeronautical engineering qualifications, and extremely little Approved Maintenance Data; and there is no parallel substitute; so RAAus aeroplanes must undergo a higher rate of hardware failures per hour of operation, as they operate under the same laws of physics etc;

 

Must? Why? If they are simpler or designed to require less maintenance, it is still possible to be more reliable. Do modern cars have more failures per hour of operation than GA aircraft, due to the lower qualifications required for car mechanics?

 

7) The RAAus accident rate is increasing from a minima, and the fleet mean age is growing. It is internationally accepted that the older the fleet (GA or otherwise), the more rigorous the demands on maintenance.

 

True, although the overall effect depends on the baseline level.

 

If you can demonstrate that, somehow, design, construction, and maintenance in accordance with Design Airworthiness Standards do not enhance safety, then there is no safety issue, and the world's airworthiness authorities can retire, saving quite a lot of money

 

I suspect a lot of fat could be cut from the worlds airworthiness authorites without significantly affecting safety.

Pre flight inspections are a maintenance procedure - by your argument, eliminating pre-flights will increase safety. Well, off you go then!