RAAus To RPL Conversion

[rhysmcc]

Yeah I seem to remember in the early days a "guide" which suggested we only had to fill out a form and we would get the RPL. However we still had to conduct a flight review prior to using it.

 

The whole thing is a mess. Need to find an instructor who's willing to conduct the flight review in a RA-AUS aircraft, do the paperwork and see what happens.

 

 

[SDQDI]

The fact that there is even reasonable doubt about all this shows the shambles that it is.

 

 

[dazza 38]

Yeah I seem to remember in the early days a "guide" which suggested we only had to fill out a form and we would get the RPL. However we still had to conduct a flight review prior to using it.The whole thing is a mess. Need to find an instructor who's willing to conduct the flight review in a RA-AUS aircraft, do the paperwork and see what happens.

Yup, same as GFPT, I remember that. Basically fill out the forms then the RPL will be issued, but the pilot could not exercise the privilege of using the licence until a flight review is carried out. I suppose some GA schools had a whinge.

 

 

[Roundsounds]

I agree, my statement regarding Section 20AB was incorrect - thank you Dafydd.

 

I cannot understand why the concept of only exercising the privileges of a GA instructor rating in VH registered aircraft and Pilot Certificate / Pilot Instructor in an RAA registered aircraft is so hard to grasp?

 

To be permitted to conduct a flight review for the holder of a Part 61 licence, the instructor must hold a valid GA instructor rating with flight review privileges. A part 61 licence (current rules) does not authorise the holder to operate an RAA registered aircraft (refer CAO 95.55 and RAAus Ops Manual for the requirements to operate / instruct in RAA registered aircraft). The instructor rating is attached to the Part 61 licence, not an RAA Pilot Certificate. The argument of using a Part 61 licence privilege in an RAA aircraft in controlled airspace is not valid, it is simply a recognition of competency and is addressed in CAO 95.55, the pilot is not exercising the privileges of the Part 61 licence.

 

The process of gaining an RPL is as stated by DrZoo's last post. You need to either:

 

- complete the exams, flight training and flight test (61.475(2)) or

 

- if you hold a pilot certificate (in the category of aircraft you wish to gain the RPL) issued by an RAAO you are considered to have met the requirements of 61.475(2).

 

I cannot see this how is a contradiction.

 

Moving on let's assume you now hold an RPL issued on the basis of your RAA pilot certificate, before you exercise it's privileges you will will need to meet the requirements of CASR Division 61.E "Pilot licensing - general limitations and authorisations" This addresses things like medical certificates, flight reviews and recency requirements. An RAA flight review doesn't meet the requirements of 61.400. (I can see this becoming a circular argument! - an RAA pilot instructor is not a person mentioned in 61.400 2© as they do not meet the requirements of CASR sub part 61T)

 

It would be foolish of any GA instructor, given the strict liability nature of Part 61, to "conduct the review in an RAAus registered aircraft, do the paperwork and see what happens" as suggested above.

 

I'm not trying to be difficult here, I work within these regulations on a daily basis and am merely trying to point people in the right direction and avoid them incurring penalties.

 

As suggested earlier, give CASA a call - Teraya Miller is well aware of the requirements as are the other members of the CASA Aviation Safety Advisor team (phone 131757) If they don't immediately have the answer, they will get it and come back to you.

 

 

[rhysmcc]

I would argue by flying a raa aircraft in controlled airspace because you have a PPL and CTA endorsement then you in fact are exercising the privileges of that license. In the same way if you were "naughty" you could have that license suspended even if you were in a RAA aircraft.

 

 

[DrZoos]

Rounds about... rhysmcc has a huge point.. You absolutely must be exercising a CASA licence priveledge to fly in CTA previously ...sorry but your argument is floored

 

I really think you have made a huge assumption that is wrong.. and i dont say that lightly as i dont like using this language

 

In fact i rang CASA today and two people said the RAA aircraft cannot be used for the flight review...but when challenged as to why, they where absolutely stumped. I asked them to check with their supervisor...again they came back saying no, but could in no way state why.. when challenged as to which rule said no , they went back to the supervisor who again could not state why..... so they forced us to write to them...

 

When i asked i i should consult Taraya the answer was a reasonably stern "No" "I need to consult my supervisor" ...Is she nearby "Yes"....could i talk with her? "No she has no more idea on this then us " " our supervisor is the person to consult"....

 

When you have called them 20 times like i have the last week , you will realise that even CASA has no idea how the transition works...they are absolutely clutching at straws and I would go so far as to say they have pre-concieved ideas how it works and are possibly even making things up and telling people ringing them , that is not in the legislation.

 

When or if i get a response i will let you know.

 

 

[Guest ozzie]

I think the Yanks got it right

 

FAR103, LSA LSAE and GA all bar 103 wear N number. No self regulation

 

 

[Roundsounds]

DrZoos, I don't believe my interpretation of the various regulations concerning the licensing requirements regarding operations in CTA to be floored or flawed. As requested by various posters I have quoted CASR, CAO and RAA Ops manual references in support of the argument. With reference to controlled airspace op's maybe CAO 95.55 para's 6.1 and 7.3 would be worth reading.

 

So how about someone start quoting regulations supporting the argument that an RAAus aircraft can be flown by the holder of a Part 61 licence and how a GA instructor may exercise the privileges of their rating in an RAA registered aircraft?

 

When contacting CASA regarding the interpretation of Part 61 matters, you should ask for a Flight Operations Inspector (FOI) or Aviation Safety Advisor. The clerical staff wouldn't have undergone the training course the FOIs and Safety Advisors have. I suggested Teraya as she is both GA and RAA qualified, so has need to search out answers to these types of enquiries. (I listed Teraya's number in an earlier post). As I mentioned previously, I'm not gaining anything from this discussion, I am simply trying to help people from being led up the garden path which could lead to unnecessary expense down the track.

 

 

[Roundsounds]

The only problem with the US system being you must have an AMP (LAME equivalent) do annual inspections on type certified aircraft and there's a 120 hour approved course requirement if you want to maintain your own non type certified aircraft. The system here will work out ok I think, we just need to stay involved in the Part 149 development.

 

 

[DrZoos]

Yeh rounds i take your point its not u v me or others... but its just everyone including CASA who say you cant do XYZ has no idea why ?? they claim its in the legislation but i have spent a week reading the various legislation's, calling CASA and asking people why and absolutely no one can quote why???

 

If it is infact banned or allowed then there absolutely must be some legislation stating why....

 

I hope you can see my point re PPL use of CTA implies a CASA privledge is excercised while flying an RA-Aus aircraft

 

 

[DrZoos]

Clearly you have more experience with this then I.. however i do have a good interpretation of the law and how it applies. Im well educated and particularly with this sort of issue and how to resolve it... But my point is and remains..ok you say it has to be done "this way" show me where or why.

 

And after a solid week on this CASA is yet to show me legislation that supports much of what it is saying about the Transition Process.. They are absolutely making shit up...

 

The laws that have gone thru do not state what CASA is saying.. Granted there may be clauses hidden in areas i am not aware of... but if they are CASA has no idea where they are either...

 

 

[rhysmcc]

Thinking about it today, I don't know why they just don't add a ultralight endorsement which permits flight of raa registered aircraft. Move all pilot training and licensing back to part 61 and leaving raa to regulate ultralight aircraft registration/building/maintenance. Would need to reduce the medical standard to self assessed like it under raa so no pilots are worse off.

 

I can't seem to find any regulations on which aircraft can be used for training, it quoted on the other thread regarding raa aircraft being considered Australian registered, you're using all your licenses and rating every time you fly, regardless of what aircraft your in. They are all on the line if something goes wrong.

 

 

[rhysmcc]

Flight schools shouldn't be worse off either since AOC aren't required anymore for training.

 

 

[DrZoos]

Flight schools shouldn't be worse off either since AOC aren't required anymore for training.

I think Flight schools see RA-Aus conversion as a short term cash cow....hence the only way to cash in is to convince CASA they either need more training or need to fly CASA aircraft.

If it can be done in an hour or two in an RA-Aus aircraft then chi ching is not going to happen

 

see http://www.casa.gov.au/wcmswr/_assets/main/casadata/flt_sim/flying-traing-panel-minutes-august20-21-2014v1.pdf

 

Trying to convince CASA of the difference between RA-Aus deficiencies and GFPT

 

 

[Roundsounds]

Surely this is now a wind up? Flying schools not needing an AOC! I'd consider a Part 141 certificate the same thing by a different name.

 

 

[DrZoos]

The bizarre thing is CASA repeatedly says we need to do a flight review in the aircraft to be flown under the RPL

 

So if i am to fly my aircraft why the hell does it make sense to do my flight review in Cessna 152 which i will never fly or hire.

 

It makes sense to force us to do a heavy aircraft review ....eg a 172 or 182...but to require a flight review in a 152 is ridiculous at best and corrupt or insane at worst

 

 

[pmccarthy]

I haven not been following the rule changes but I repeat that in past years CASA has accepted GA flight reviews in RA aircraft. It is consistent with the preference that the review be conducted in the aircraft type most recently and regularly flown. It is common sense, regardless of selective interpretation of regulations which does not seem to have advanced this discussion in three separate threads in recent times. The CASA employees are not legal experts either. If we want a particular outcome, which is the flexible and common sense one, we should either rely on common sense and precedent or hire a lawyer. I don't understand why the contra case is being fought so vigorously here, it is in no-ones interest. No one will be fined or punished for doing their GA review in an R A aircraft, submitting it and having it accepted. If it bounces, then the interpretation of the rules have changed and we either accept it or hire that lawyer.

 

 

[turboplanner]

The RPL is a GA derivative intended for GA aircraft and GA pilots. Some fertile RA minds have got to work and convinced themselves this is the loophole to break some RA boundaries.

 

I'm not surprised CASA people would be confused, but I suspect that after they grasp what some RA people are trying to do they'll close the loophole so don't be too disappointed if they do . Have another look at the earlier threads.

 

 

[rhysmcc]

and here I thought it was intended for Recreational Pilots, those who have no interest in flying for money, on instruments or heavier complicated aircraft...

 

 

[turboplanner]

GA is divided in Australia between Commercial and Non Commercial, the non commercial being Recreationa

 

The pilots and aircraft you are talking about were allowed to fly bu exception and were known as Ultralights. RAA was a development of the Australian Ultralight Federation and its members have confused the industry and themselves ever since with one element wanting to get into aerobatics, cta, commercial activities and even search and rescue and the other element knowing that would be suicide to the hard won freedoms they originally wanted.

 

 

[facthunter]

I presume you mean by exemption. which the CASA seem to have a problem with continuing, although there will always be a need for exemptions to be available some times. The confusion might have arrived because of the "parallel paths" concept espoused to cover the monopoly situation, which no one is supposed to have. Nev

 

 

[rhysmcc]

Makes sense that recreational aviation should continue to develop then. The aircraft would still operate under the exemption, the licensing would be regulated.

 

What freedoms are you referring to that are at risk? Restricted to flying only over your property or under 300 AGL?

 

I can't think of any activities from 30 years ago that would still be operating today without any extra regulations?

 

 

[camo645]

I am quite interested in the RPL, Has anyone actually started the conversion process yet?

 

 

[nickduncs84]

I am quite interested in the RPL, Has anyone actually started the conversion process yet?

I sent off my papers today. I'll let you know how it goes. I filled everything out with the help of my cfi who had just had a meeting with a casa rep about the Ra Aus to rpl process so I can't imagine too many issues. If there are issues I'll just stop being lazy and sit the ppl exam and not bother with the rpl thing.

 

 

[djpacro]

a RA-AUS aircraft IS considered an Australian registered aircraft

Is it? Or does it have an exemption from being registered (and I mean the definition of register per CASA's regs)?

 

61.007 Application of Part 61(1) This Part applies to flight in a registered aircraft of any of the following categories:

(a) aeroplane;

So, I can fly a registered aircraft on my Part 61 PPL and an authorised instructor per Part 61 may do a flight review in it.Conversely, if the aeroplane is not registered per the definition in CASA's regs then Part 61 does not apply to flight in it.