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frank marriott

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Id guess our friends in CASA have a real problem with the concept that pilots can maintain aircraft satisfactorily without almost ANY training or direction. As with plenty of our regulators approaches, the reality and evidence doesnt have to exist. Id reckon they would dearly love to roll RAA over to LAME servicing and annual inspections.

 

In order to calm them and politicians, they have demanded a process to ensure complete novices at least realize the importance and responsibility of looking after an aircraft. Hopefully those without aptitude get someone else to help or do it for them.

 

If an online test and basic training allows us to continue self maintenance its not that tough.

 

 

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For those interested CAAP 42ZC-02 V1.1: MAINTENANCE OF AMATEUR BUILT AIRCRAFT Appendix A and B describe the requirements for a MPC. Very little practical (ie actually relevant to "hands on" maintenance) but predominantly dealing with compliance. FAA recently published a study on maintenance, part of which looked at the Canadian Owner Maintenance system.

 

Under the O-M Category, Aircraft Pilot/Owners are Eligible To:

 

  • maintain an airplane
     
     
  • refurbish all or part of an airplane
     
     
  • overhaul all or part of an airplane
     
     
  • install certified and uncertified parts
     
     
  • install or replace any instruments or avionics
     
     
  • modify an airplane
     
     
  • rebuild an airplane that is out of service
     
     
  • sign the maintenance release
     
     

 

 

The report referenced above says, “The overall accident trends and rates indicate that the

 

Owner-Maintained aircraft category is a safe fleet with accident rates comparable to Standard

 

Category.” That is: Enabling owners to maintain aircraft instead of forcing them to use licensed

 

aircraft engineers at considerable expense has not, empirically, reduced the safety of the fleet.

 

The tabular data presented on page 331 of the report indicates that approximately 2% of the

 

Canadian fleet was Owner-Maintained in 2010, and their year-by-year accident rates are

 

broadly in line with the accident rates for all aircraft registered in Canada.

 

Because the number of Owner-Maintained aircraft accidents are small, the report can provide

 

individual breakdowns of accident types: Seaplane takeoffs and landings are over half of the

 

accidents recorded since 2000. The remaining accidents where wreckage was located were

 

categorized as gusty wind-affected takeoffs and landings (5 accidents), snow-affected takeoffs

 

and landings (4), blow-overs caused by not securing the aircraft to the ground (2) and flight into

 

powerlines (1). None of these accident categories are affected by airworthiness standards, and

 

the report observes, “Neither the Owner Maintenance Program nor the use of non-certified

 

components has contributed to an accident in the Canadian O-M fleet in the last decade.”

 

Significantly, the report also says, “It is likely that because of the lower costs and greater

 

involvement of the aircraft owners, usage rates improved which contributed towards pilot

 

currency. In addition, owners may have replaced components more frequently due to the lower

 

cost thus improving the overall maintenance of the aircraft. Further, it is also likely that many of

 

the aircraft are equipped with improved avionics systems, allowing safer flight, than comparable

 

standard category aircraft because of the less burdensome approval process and lower cost.”

 

To summarize: By empowering owners of non-commercial aircraft to perform their own

 

maintenance, the Canadian regulator has improved the airworthiness scrutiny and safety of their

 

GA fleet, at reduced cost to industry; and also improved operational safety by improving the

 

equipage standard of the GA fleet, and pilot skill levels.

 

The conclusion on page 332 is definitive: “It is safe to conclude that the Canadian O-M system

 

has not detrimentally impacted safety and it is likely that it actually indirectly improved safety.”

 

(thanks to Mark Newton for the summary) see the report at :

 

https://www.faa.gov/about/office_org/headquarters_offices/avs/offices/air/directorates_field/small_airplane s/media/p23_reorg_arcfinal.pdf

 

 

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The fact is that if it is my backside in the aircraft, I would prefer to have maintained it myself than trust someone else to do it (providing I felt competent enough).

 

We used to do that with parachutes. Would you rather jump with a chute you had packed yourself (under direct supervision) or one that had been packed by a stranger?

 

The UK system works very well with no oversight of maintenance. Since they de-regulated their single seat aircraft, the onus is all on the pilot to look after his/her own safety. So far it has worked very well, also for the USA .

 

Unfortunately for us, it seems that Australia is heading in the opposite direction.

 

 

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Yes the SAAA system with MPC course is OK but you need to have built/assembled 51% of the aircraft and engine I thought.This should remove those without any skill or experience.

The MPC is nothing more than a rort organised by CASA for the benefit of SAAA -$1500 for the course. The whole thing could be done much cheaper and better under the auspices of CASA online. This alone would encourage participation.

Also, I seem to recall that the most dangerous time to fly an aircraft is straight after it has been in for maintenance.

 

What the Canadian experience has shown is that most people understand the limits of their capabilities and seek assistance when in doubt. Not doing things "illegally" encourages people to seek help when they are out of their depth, rather than hide their incompetence in a potentially dangerous aircraft.

 

 

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SAAA course is not 1500. Have you attended it Jim?

Have not attended - was $1500 last time I looked - If it is less I apologise - but even at half that it is way too much.

Remember, that when Experimental category was introduced there was no MPC requirement. Then some SAAA members who could not let go of the idea that 101.28 gave some sort of regulatory approval to their construction efforts, lobbied CASA for introduction of this requirement effectively benefiting a private organisation in a way that legislators normally avoid.

 

 

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The RAA requirement to do an exam to be able to carry out L1 duties which previously was a right given to RPC holders in order to be able to maintain their aircraft is nothing more than an a—e kissing exercise by our heirarchy to the regulator. (with a financial benefit for RAA ofcourse).

 

I have held an RPC (with an L1 rating) since the late 1980’s and suddenly I am unable to do maintenance on my own aircraft anymore. What a croc!!. Just more of RAA ( read the two Micks) imposing itself unnecessarily on members to get them used to being compliant to please CASA and look great on their CV’s for life after RAA.

 

 

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And CASA demanded a process to gain L1 privaledges i believe.

I wouldn't mind seeing a copy of the CASA request - in my experience it is common practice for administrators to claim instruction from on high when none actually exists.

 

 

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How does it financially benefit RAA?Opposite id have thought

And CASA demanded a process to gain L1 privaledges i believe.

Depends what CASA "demanded" if in fact they demanded anything.

The Self Administering Organisations are set up to throw legal responsibility over to the people gaining the benefit where there is a high risk present.

 

Having achieved that, the smartest thing for CASA to do is to stay out of the management chain (demanding people do this or that) and remain an arm's length Safety authority, just auditing what is going on.

 

If in their regular auditing, which can come from formal reports, formal accident investigation results, or even the lurid stories, photos and videos from social media, they found that a string of people didn't even know how to tighten spark plugs etc. they may well suggest to RAA that that isn't good enough, and it's then up to the self administering organisation to decide what it wants to do.

 

However, if CASA, once in a blue moon, forgets what the SAOs were set up for and simply orders, or demands a specific action, or process, and RAA is simply complying with a mandatory directive from CASA, the legal flame is likely to stop at their door.

 

There's a big difference between the two management methods, and I would be very surprised if CASA slipped up.

 

 

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The L1 test is not free Jetjr, RAA would have covered cost and then some ( just look at registration costs - ever increasing. How much does it cost to keep a record of RAA aircraft?) Re your point about CASA demanding that everyone sit a test, everything is up for debate - why did not RAA defend the system that was in place and demand evidence that change was necessary. If there was 1 or 2 isolated incidents that is not reason enough to inconvenience every L1 in RAA. I’m not convinced there was a demand from CASA. RAA does little or nothing in regard to defending members rights as far as I can see.

 

 

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RAAus is now compromised. It needs to curry favour with the CASA , AND act in the members best interests, How can it do both? The risk is that in attempting to cover #1 It may act over zealously in the requirements or the punishment to keep CASA from poking it's nose in. SOME Airline managements did this subjecting it's pilots to measures probably in excess of what the CASA would have done, if they were handling it.. OUR organisation should fight for US when it's justified. I doubt they will, as the easier way is to not make waves.. This was predicted by many years ago. No surprises there. Nev

 

 

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Casa wanted annual inspections on all aircraft and modifications to all go through std engineering process.

 

Raa argued against this and had to offer alternative solutions. No annual inspections is a big deal as it forms basis for GA maintenance. MARAP also being part of this Id say.

 

Doing nothing or continuing L1 without training wasnt ever going to cut it unless an L2 inspected the aircraft annually.

 

Id have guessed it all happened as part of tech manual acceptance process

 

This is all hearsay but more realistic than the conspiracy theory RAA staff just out to screw members or overreaching to placate CASA i think

 

 

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And for those who keep saying things along the line of "RAA should just say no to casa" obviously don't remember just what casa can do. For example do we remember when the whole fleet was grounded?

 

 

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And for those who keep saying things along the line of "RAA should just say no to casa" obviously don't remember just what casa can do. For example do we remember when the whole fleet was grounded?

I'm sure we do; and we remember the clowns who thought they could get away doing beat ups and generally not complying with much at all.

 

 

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Changes are OK when they are effective, and proper reviews are part of the process. Owner maintenance has good aspects to it from the safety angle, Owners tend to be more careful of something they fly in (on the whole) Education beats punishment and masses of paperwork. .Always has and always will. There are some who will try to get around rather than do stuff. I've seen it happen in all areas. The right balance is what we should seek, not make the rules for the worst case, thereby punishing all of us for the sins of a few. RAAus is NOT Airlines. Nev

 

 

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