The Latest Outstanding Communication from RA-Aus

[kgwilson]

1 hour ago, Carbon Canary said:

I had a leaky mitral heart valve resulting in breathlessness on exertion. I voluntarily grounded myself but hadn’t got around to formally advising CASA. On my most recent visit with the cardiologist involving a treadmill stress test, ecg, ultrasound etc. the leaky valve problem has completely resolved by itself, and the cardiologist doesn’t wish to see me for at least two years.

 

Do I inform CASA that I had an unreported historical problem, but now I don’t ?

You say Nothing a la Sgt Schultz from Hogans heroes. I have heard many stories of pilots informing the DAME/CASA about an issue that was but is no longer & tens of thousands of dollars later they are still awaiting a decision.

[facthunter]

There's no way to  fathom it. At one stage they put a condition of must wear corrective lenses. I kept on doing eye exercises and easily passed the test years later without glasses. They still wouldn't remove the condition. HOW bl@@dy silly s that?. Nev

[jackc]

44 minutes ago, Old Koreelah said:

I suspect that for road users and flyers, the biggest risk factor is not physical health but mental.
Is there a test to weed out those of us with faulty decision-making, let alone a dangerous attitude?

Nearly every politician has that problem……and they make the rules, so essentially we are all doomed?   Its just the  degree of doomness 😞 

[jackc]

I have been described as a nut case by people all my life because I am adventure driven BUT I am still alive 🙂 

Thinking back…….it probably started when I got expelled from a private boarding school, they said there NO hope for me…..Wanchors!!

 

[facthunter]

Pollies don't get to make the rules The Legislation would closely follow ICAO compliance  and the end users get Airservices or CASA operatives to deal with. The CASR's (or whatever they are now called) are processed by the government pretty much as a rubber stamp  There's NEVER a Minister for CIVIL Aviation like there used to be. It's all lumped into Transport  and even other folios. Nev

Edited April 10, 2023 by facthunter

[jackc]

9 minutes ago, facthunter said:

Pollies don't get to make the rules The Legislation would closely follow ICAO compliance  and the end users get Airservices or CASA operatives to deal with. The CASR's (or whatever they are now called) are processed by the government pretty much as a rubber stamp  There's NEVER a Minister for CIVIL Aviation like there used to be. It's all lumped into Transport  and even other folios. Nev

And today, the Qld Minister for Transport announces on the radio, he wants driving tests for existing car licence holders.  All the fat cat bureaucrats will be burning their biros out tomorrow, making submissions to the minister for suggestions, so they can get their bonus points with the minister.  

So yep, legislation starts with the minister and the bureaucrats pour  fertiliser  on the ministers idea.

[facthunter]

I wonder of that can be justified on a cost basis.  Most of the cars that get driven badly are stolen and they have no licence. Nev

[onetrack]

They'd never be able to find enough testers. Just stepping into a DOT centre and waiting for 2 hrs to get served is indicative of the massive load just in processing driving licences and vehicle registrations.

 

In W.A., it's been proven that testing of elderly drivers wasn't useful, nor effective. The setup now is your doctor has to advise the DOT if your driving skills are seriously affected by health issues.

Most people drive to their limits. The really old people choose their driving times to avoid heavy traffic, and only drive short distances to places they know.

[jackc]

IF a Police Officer ever suggested a physical driving test to me. I would say right, lock up your Patrol Car and we do it right NOW.  IF my Doctor suggested I was unfit to drive…..I would give him the same treatment.  I consider myself capable, at this time.

One day it WILL be over and I will retire to my bombed up mobility scooter 🙂 

I see Hoon Meetups in my future at the local Woolies car park, after midnight 🙂 

[Old Koreelah]

39 minutes ago, jackc said:

I have been described as a nut case by people all my life because I am adventure driven BUT I am still alive 🙂 

Thinking back…….it probably started when I got expelled from a private boarding school, they said there NO hope for me…..Wanchors!!

 

How many of your risk-averse peers have you outlived?

Quite a few of mine succombed to that greater risk: not enough physical activity to burn off what they were drinking and eating.

[jackc]

Not drinking and not smoking, ever….i believe has benefited me, plus a severe mental attitude of not having any fcuks to give 🙂 

[facthunter]

You can only be insulted by people you respect. Nev

[facthunter]

 On one CRM (psych) course I did, one of the observations was I don't suffer fools Gladly. However could they reach THAT conclusion?  Nev

[turboplanner]

CASA Time delay in getting an answer

 

From 30/8/2019 to 28/9/19 CASA sought feedback from the industry ….to permit 3-axis aeroplanes up to a maximum weight of 760 kg to be included as aircraft that could be administered by an ASAO [Approved Self-Administering Aviation Organisation].

 

The consultations closed with 408 responses received (out of the roughly 15,000 people affected in GA and RA)

 

Seven issues were looked at:

1.     MTOW

2.     Stall speed

3.     Maintenance requirements

4.     Medical standards

5.     Flight standards

6.     Safety implications

7.     Cost implications.

 

On December 6, 2019, three months after the CASA Consultation period had closed, a spirited thread was started by Walrus and debated by a lot of people and finally ended by Walrus with the poetic “I love the base leg at Milford Sound and the final turn by the Cliffs.”

 

We didn’t get to know how many, if any, submissions from RAA members were received.

 

DISCLAIMER

This started as a response to the current criticism that CASA is taking too long to make a decision on the 760 kg MTOW request, but as I looked into it there are good reasons to want CASA to look very carefully, and a chance of it disadvantaging people in both GA and RA flying. As much as there’s a lot written, it only covers the tip of the iceberg and some of the 7 points, so if you are likely to be affected, I recommend you do your own research of the full CASA, RAA, Austroads etc documents because it looks very complicated to me.

 

1,2: Increase in MTOW

There were two key safety factors which allowed the original home built AUF aircraft to fly; low stall speed and light weight.

With the smaller, two stroke engines it was expected that many of the flights would be downhill into whatever was below, which was intended to be grass or low shrubs.

The low stall speed allowed a lower impact collision with terrain and the lighter weight ensured a lower inertia driving the aircraft and pilot into the ground.

 

Here the proposal was to reverse some of that by increasing the MTOW by 27%

Doesn’t sound a lot, but the rules that allowed the Recreational Aviation exemptions to fly under the RAA system today were based on 450 Kg MTOW and the increase from there is 69% which opens up a pandora’s box.

 

The Low Inertia rule which many on this site have interpreted as bullet proof aircraft also has to be recalculated for 760 kg MTOW.

 

My rough calculation of inertia at 450 kg MTOW is 648 kg-m² increasing to 1094 kg-m² for 760 kg MTOW. That would introduce considerations on FRP laminate thickness, gusset size and thickness, mounting points and many other items, producing a heavier aircraft, so some of the gain can be lost. Bigger engines are also heavier so more gain is lost. The question becomes  “What is the nett gain in payload?”

 

Maintenance

Very important to the cost of RA operations is the freedom for anyone to maintain their own aircraft, saving around $100.00 to $160 per hour in labour cost.

 

This freedom takes into account mistakes that some might make which would result in a forced landing, and that’s where the stall speed and weight rules play their part, and the guy who didn’t tighten the spark plug, or didn’t put the engine back together correctly only gets a minor injury rather than something more serious.

 

Self-Maintenance comes under scrutiny with that sort of increase in weight.

 

That is compounded by the CASA requirement in place for aircraft in the 760 kg MTOW like Cessna 150/152 to only be maintained by a LAME.

 

There is a public liability exposure if an organisation has a safe benchmark in place, and then opts to do something less safe. CASA may resume some unwanted liability and that’s expensive.

 

Add to that the fuel of the GA 760 kg aircraft coming over to RA and telling LAMES they’ll be maintaining their own aircraft from now on. CASA maintenance critical mass for LAME cost coverage would be threatened, reducing safety again.

 

4: MEDICALS, Source: CASA.gov.au

 

 

Class 1 Medical certificate

·       Air Transport Pilot Licence

·       Commercial Pilot Licence (other than Balloons)

·       Multi-Crew Pilot Licence

·       Flight Engineer Licence

 

Class 2 Medical Certificate

·       Since 2018 CPL can do some operations with a Class 2 Medical

Basic Class 2 Medical Certificate

Same standard as an Unconditional Commercial Driver standard and allows for vision correction and hearing aids. (Refer Austroads).

·       Only private day operations under VFR below 10,000’

·       Max 5 passengers

·       Only piston engine aircraft

·       MTOW less than 8618 kg

·       No use of Operator Ratings such as instructor rating, instrument rating

·       No use of aerobatics or low level (except if valid Class 1 or 2 in a flight seat)

·       Does not allow for the management of medical conditions a DAME or CASA can consider when issuing a normal Class 2 Certificate.

 

AUSTROADS

What is an Unconditional Commercial Driver standard?    (Commercial = Truck)

An Unconditional licence holder is a person who has fully developed and practised their driving skills (usually over a two to three year period) and is considered competent to drive with the minimum allowable restrictions and to supervise learner drivers. In 1997 Australia implemented the National Driver Licensing Scheme (NDLS).

 

What is Austroads?     Austroads is a section of the National Transport Commission (NTC), a Commonwealth Government entity.

 

Assessing Fitness to Drive; Austroads – 2022 Edition, Austroads.

This is the link to the 264 page Medical standards for licensing and clinical management guidelines

https://austroads.com.au/__data/assets/pdf_file/0037/498691/AP-G56-22_Assessing_Fitness_Drive.pdf

 

Here are a few items:

Fitness to Drive Assessment P66

Blackout definition and pathways P68 – example Private (car) licence, should not drive for six months; Commercial should not drive for five years.

Cardiovascular P62

High blood pressure P77

 

Basic Class 2 Requirements

You can get a Basic Class 2 examination from any medical practitioner who does medicals for commercial motor vehicle drivers.

 

Basic Class 2 Equivalent

It is the same as an unconditional commercial driver standard and allows for vision correction and for hearing aids.

 

Basic Class 2 Disqualifying conditions

 

·       Don’t meet unconditional commercial driver licence medical standard for your Basic Class 2 Medical.

·       Have a pre-existing condition

 

You can still apply for a Class 2 Medical certificate with a full assessment from a DAME who has more flexibility.

 

RAMPC

Cheaper and application process easier than Class 1 and Class 2

Medical standard is less flexible

Does not allow for management of medical conditions

 

RAMPC Restrictions

Only single engine piston aircraft (fixed wing or helicopter)

MTOW 1500 kg or less

Day operation, VFR , below 10,000 feet

No more than one passenger

No acrobatic flight

Unless a pilot in a flight control seat has suitable qualifications valid for Class 1, Class 2 Medical.

 

RAMPC Disqualifying Conditions

Don’t meet the unconditional commercial drivers licence medical standard

Have certain medical conditions (but can apply for a Class 2)

 

 

 

LICENCES, Source: CASA.gov.au

 

PPL

RPL

Solo at night if receiving training and under the supervision of flying school and Flight Instructor

Recreational Aviation Medical Practitioners Certificate (RAMPC)

 

RPL

·       Carry 1 passenger if you hold a Recreational Aviation Australia Pilot Certificate

·       Carry more than one passenger if you hold an RPL and either:

o   Hold a Class 1 or Class 2 Medical Certificate (or fly with another pilot who holds a Class 1 or 2 Medical Certificate and occupies a  flight control seat in the aircraft and is authorised to fly that aircraft.

 

RPL Pre-Requisites

·       Single engine only

·       At least 16 years old

·       Able to speak and understand a certain level of English

·       Class 1 or Class 2 Medical Certificate or:

o   Recreational Aviation Medical Practitioner Certificate (RAMPC)

For the RPL Iicence to be active:

·       Do a Flight Review

·       3 takeoffs and landings in the previous 90 days if you wish to carry a passenger

·       Have a Class 1 or Class 2 medical certificate to fly above 10,000’ (or have another authorised pilot, in a flight control seat, who has one.

 

An RA-AUS Pilot Certificate is equivalent to an RPL

 

Recreational Aviation Australia Ltd

“self-certification of their health and fitness (if no nominated medical conditions are evident*).”

 

“In general terms if a RAAus member is fit to drive a private motor vehicle, they are at a fitness level suitable to fly a RAAus aircraft. However, this medical freedom includes a responsibility to self-assess and be responsible for ensuring their own fitness to fly every time they intend to fly.”

 

This is the link to Recreational Aviation Advisory Publication RAAP 9

https://www.raa.asn.au/storage/raap-9-medical-guidance-for-raaus-members.pdf

 

Compare the Unconditional Commercial Driver Licence standard with the RA Self-declared Car Licence and see where you would rather be for your medical situation.

 

Summary

You can’t come down from an Industry Standard, Australian Standard, International Standard, Safety Standard without incurring Liability.

 

You can reduce your liability by going up in standards, reducing incidents.

 

You can’t operate at a lower standards in one section of an organisation than another without increasing liability and discriminating.

 

You can’t disadvantage ones group of people by hiving them tougher standards and higher costs than another group doing the same job with the same equipment as another group.

 

You can’t have one maintenance standard and cost in one group and a higher standard and group in another when they are doing the same job.

 

You can’t fracture Medical standards to create a level with lower standards for doing the same job.

 

Something has to crack.

 

Self servicing and car medical standards becomes very attractive for older people running out of money with developing medical conditions but it introduces more risk to the lower level group and pulls membership out of the higher group, destabilising schools and LAME income.

It can add more liability so more cost to RA operations. That could be offset by a suitably higher subscription for ex GA and other 760 kg aircraft, but that in turn could make them non-viable.

 

It would cause even less attention being given to the backbone of RA, affordable flying in rag and tube and 80 hp class aircraft.

 

And so on.

 

Hopefully you will have read all the clauses from the Unconditional Commercial Medical and realised that it’s as complicated as the CASA system, without the ability to manage your condition; get the condition; you’re retired.

 

Same for the BASIC Class 2; that’s for People with no medical issue. Class 2 is actually better because if you do have a condition, the DAME is authorised to manage it and keep you flying longer.

 

If I was doing a full analysis it would be another ten pages at least to cover all aspects, but I thought I would pull some data to show that you are better off with a long period of investigation and cross-checking in cases like this.

 

It would be easy to put all the over 80 hp aircraft into GA, and leave the grass roots as it was in RA.

 

It would be easy to transfer all sub 760 MTOW into RA, introduce Class 2 Medical for the lot

 

And so on, but that type of decision making can wipe out half the industry.

 

Better to take it easy and let the decision makers make their decision.

 

This discussion isn’t going to change anything. Clever ideas like adopting other Countries’ ideas had to be submitted by September 2019.

[Flying_higher]

Whilst I reckon you’ve done some great comparisons there, one thing you fail to acknowledge is that CAO 95.55 has allowed an ASAO (not just RAA) to apply for increase in MTOW since 2021. The time for debate is done and I think the RAA CEO was just suggesting that even though the rules already exist, CASA still hasn’t approved RAA’s formal application to apply those rules. Pretty fair complaint given it’s April. 

[facthunter]

At the end of the day, Turbs most of that is your opinion. On what basis is it any more value than anyone else's and it always ends up "leave it to those in charge and all will be Hunky Dory".  Nev

Edited April 14, 2023 by facthunter
typo

[pmccarthy]

No one is proposing to take away any rights from existing flyers. The rules allowing Drifters and Thrusters are still there, if that is your thing.

[turboplanner]

14 hours ago, pmccarthy said:

No one is proposing to take away any rights from existing flyers. The rules allowing Drifters and Thrusters are still there, if that is your thing.

Did anyone say they were?

[hkaneshiro]

the sweet spot at the moment are the Sling 2 planes. Good hybrid between RAAUS / GA. Can train in one and easily get converted either way and performance isn't that different from a C152.

 

Realistically what does the increase in MTOW achieve? What are the other GA planes that can realistically be captured into the RAAUS system with an increased MTOW apart from the C152?

 

 

[pmccarthy]

Airtourers AT-100 and AT-115, Jabiru J-430 (with back seats permanently removed)? Early Ercoupes. Some Austers, Cubs, and various biplanes.

[turboplanner]

Cessna C150, the fifth most produced aircraft ever - 726 kg MTOW 

USD prices approx $30,000 < $60,000, C150 Aerobat $59,900.00

 

Cessna C152, 757 kg MTOW.

[jackc]

12 minutes ago, turboplanner said:

Cessna C150, the fifth most produced aircraft ever - 726 kg MTOW 

USD prices approx $30,000 < $60,000, C150 Aerobat $59,900.00

 

Cessna C152, 757 kg MTOW.

Some have been repowered?  How are they affected?

 

[turboplanner]

9 minutes ago, jackc said:

Some have been repowered?  How are they affected?

 

Best to wait and see what's decided.

[jackc]

Modern day attitudes seem to be that the ‘whole’ recipe does not get published until the end.

Keep people in the dark so they cannot make forward plans.

We will start construction……but we don't have all the plans…….

Better shut mouth before I put my foot in it 🙂

[turboplanner]

Just now, jackc said:

Modern day attitudes seem to be that the ‘whole’ recipe does not get published until the end.

Keep people in the dark so they cannot make forward plans.

We will start construction……but we don't have all the plans…….

Better shut mouth before I put my foot in it 🙂

The reason I did the research was to show how complicated chopping up the industry is particularly the health part, where if you have an ongoing condition you are batter off with a DAME managing it than giving up flying. This one was one of those "Be careful what you ask for" requests.