kasper

So here is the next one

So what really is the issue?

The syllabus for Group D being not what you like?

The structure of Instructor training within the RAA?

The fact that there are few are far between group D CFIs?

A bit of everything adding up to making it difficult to grow this area of RAA aircraft?

If its the syllabus then the CFIs and Instructors can and appear to be feeding into the ops manual for its amendment

If its the fact that we have Instructors who are effectively on training wheel until they have actually instructed real live students then its a more fundamental issue - regardless of what new instructors might think the structure we have was designed for clubs and low regulation as the actual instructor training is not the same as GA and the graduated stepped approach is lower cost and lower regulation - and to change the entire structure of instructor training and operations within the RAA for a small sector of the aircraft population when that would be a massive change from the CASA perspective is really just not likely to happen.

If its a lack of CFIs then its a question of what drives this - overly or difficult training or in reality the fact that the form of flying is limited in appeal and not the direction where flying schools can earn money

And if its a bit of everything then take your pick of where to start.

My understanding is that the definition was included to stop the practice of a CFI being able to authorise an instructors flights over the phone/email without having to physically be there. I have no idea why they thought that was required or if that practice had caused any problems. I certainly have not heard of any. I don't know whose bright idea it was but they certainly didn't ask any Instructors or people who wanted to go down that path.The real problem then kicks in of requiring a CFI supervision, but having only a handful of part time CFI's that can actually do it. The Instructor i mentioned previously took over two years and $12,000 to get a Class D instructor rating (and he tried damn hard) because the system is failing. He want to do a SI but is almost impossible for him to do.

 

I cant see the point in an instructor rating if they are not able to instruct without supervision.I can't think of one other qualification that says you are qualified to do a particular job, but only if someone else is looking over your shoulder. Certainly with a PPC, if you can fly it, can carry a pax and have an instructor rating I cant see the need for all the restrictions.

Please ignore and break the thought link of GA instructors - Class A, B, C, or D class means nothing in terms of the RAA system, yes it pisses off GA instructors that they have to go back through hoops to get recognized as RAA and then go through the process of stepping up from I to SI - but that is the structure and it is a progressive structure that gives you more authority the more steps you follow through with. So maybe you can't see the point of an RAA instructor rating - others can and see where that rating sits within the structure of the RAA.

Oh and looking back through the Ops manual the instructor (not senior instructor) must be directly supervised (no capitals) so even on the greatest lenience towards the horrendous drafting only the instructor is ever limited to direct supervision - the senior instructor only has to be supervised - strangely the Ops manual is italics here ... even though the defined term is using a capital ... just another of the joys of the appalling drafting within the Ops manual.

So basic rule giving the drafting the best tailwind - instructors (those just starting out without the right to authorise first or solo flight) have to be actually surpervised by the CFI or suitably qualified and authorsied SIs ... once you are an SI you can authorised solos, operate remotely and do not need to be in the sight of the CFI.

No different from how it was when I went through in 1994 ... just with 21 years of additional crap drafting making it all the muddier to actually understand

Kasper, prior to the review of the Op's manual last year there was a need for the instructor to be "supervised" by a CFI. This did not necessarily mean he had to be present at the time of the instructing but the instructor could go ahead with training with his knowledge and permission. This is the time that the Instructor i was talking about earlier had commenced and nearly finished his instructor rating.When the new Op's manual was imposed on us all without any consultation the wording was changed to "directly supervised" and a definition included that "directly supervised" meant the CFI had to be physically present. Instantly his rating was reduced to worthless unless he could travel to the CFI to train students under supervision.

 

With only 7 Group D CFI's in Australia, and most being affiliated with one brand of PPC (and refusing to train anyone who owns another type) what do you think the chances of any more instructors coming through the ranks are. I am guessing almost NIL.

 

This type of aircraft doesn't need 100's of hours to be able to teach someone how to fly it, and if someone who is qualified as an Instructor is not good enough to instruct without direct supervision then we have a problem with how we train our instructors.

 

Group A will usually fly from a recognised airfield with other aircraft, clubs, flight schools etc attached to that field. Any instructor has a good chance of being able to be supervised. PPC's usually fly from some remote field away from most other air traffic, no flight schools and no CFI's. (dont forget there is still only 7 CFI's in Australia) RAA has now made sure the PPC's will die out without changes to allow more instructors to be trained. They cannot operate under the same instructor training regime as other aircraft.

Yes ops 7 has a definition of Direct Supervision (note the capital letters on both words)

No - Direct Supervision is not required by CFI of either instructors or senior instructors ... only supervision (no capitals)

Even though there is a capital S Supervision defined as

"Supervision The surveillance, assessment and correction of persons engaged in ground or flight training and associated operations. Supervision may be ‘direct’ in the presence of the supervisor or ‘indirect’ by the supervisor monitoring the operations through other persons, or means acceptable to RA-Aus."

this is not even applied in the operative sections of the Ops Man 7 pertaining to CFI oversight of instructors or senior instructors where they have forgotten (at best) to captialise to indicate its a defined term BUT even if it is supposed to be capitalised the definition of the tern Supervision directly allow for direct and indirect.

So No, even under OPs 7 there is no requirement for the instructor or senior instructor to be physically in the same area as the CFI for adequate and allowed supervision.

Hate the Ops Manual with a vengence for all the crap that is in it - on point Direct Supervision is defined ... then NEVER used in the entire damn ops manual

Shouldn't the instructor go to the CFI/Cfi's school to be passed out so to speak?

In the RAA structure any instruction has to be under a school - every school must have a CFI, if you hold an RAA instructor or senior instructor rating thats only step 1 - you cannot exercise the right to provide instruction other than through a school and under a CFI.

If by passing out you mean the instructor working with the CFI present to get passed by the CFI to then operate remotely that is exactly what the situation is for many remote/satellite schools and that is what I was getting at

If by passing out you mean the instructor gets permission from someone (RAA?) to operate on their own then that requires them to establish their own school and become a CFI in their own right ... hardly worth it for 1 student.

I think I might have misread the initial posting - I don't read that post as saying the CFI needed to be present but simply that the instructor has to be overseen/supervised by a CFI.

Within the RAA structure you have three basic levels of flying instructor - FI, SI and CFI. And ALL schools (or satellite schools) have to operate under the auspices of an approved CFI who is responsible for maintaining the level of instruction and providing the required facilities (teaching room, documentation etc)

So if you have found an instructor who is not a CFI and running a school then yep, he/she will have to operate under the auspices and supervision of a school and the CFI of that school.

As others have pointed out the RAA structure does allow a CFI and the instructor to be physically separate ... but if I were a CFI taking up an instructor I may not know anything about in terms of his/her background and teaching on the PPC I think I would like to have a fairly close look see at their instructing.

Me - I was in the past both an FI and SI in 3axis, and even though I am not currently working as an instructor the RAA biennials are ever so much fun because they are in effect treated like a reval on the instructor rating - so much so in fact that when I added weightshift to my RAA I had to have the full instructor reval as technically I could then go out and approach any CFI in an RAA school and get my instructor rating brought back on line with minimal examination ... and this would include instructing on weightshift as the instructor rating applies to all control types on my certificate ... I suppose I am one of the few 'instructors' out there with a technical ability to teach on the Balerit - I have combined controls on the cert ...

So I'm afraid I am on the side of the CFI here - if I was putting my butt and schools reputation on the line when approached by a student/instructor remote from my school with whom I have little knowledge I would be rather conservative and require actual physical oversight for at least a period until I was comfortable that the instructor was capable and trusted to operate in a way that fits with the school.

The name may have misled some as i wasn't referring to a PPC but thinking of looking for a project fixed wing.Probably a rag and tube.

 

Kev

then you are within 95.55 and are up against the same convince RAA tech that the original aircraft (whatever original reg) no longer exists and your aircraft is within the paragraph that is entitled to 19 reg and you can design/redesign/modify to your hearts content ... then if you ever sell it the new buyer has to argue that RAA should not need to apply MARAP to a 19 reg aircraft.

Thanks for your views,It seems as if doing the build as i intended could be a very risky business. I could have photos of the old airframe in bits to show it no longer exists but when it is rebuilt the tech team could say "it looks very much like it was originally so it is still a 32. and please remove those modifications you have done and you can't fly until we check it."

 

The whole purpose is to finish with an aircraft i can modify and maintain as i like without all the MARAP stuff coming into play.

 

When trying to prove the 51% is so subjective, using mostly all the parts of the old aircraft just might not be enough. Until there is some documented baseline on just what 51% is and how the percentages are allocated, maybe this is just not a good time to think of such a project.

So that said you are limited to 95.32 as two seat homebuilt (para 1.4 of 95.32) PROVIDED the RAA can be satisfied that the factory aircraft you have based your aircraft on is not in existance anymore and what you are presenting as a homebuilt 95.32 aircraft is a new aircraft.

If you want to limit it to single seat 300kg MTOW you could also go through 95.10 but be subject to similar convincing the RAA that whats presented is a new/different aircraft.

Either way if you get a PP through either 95.10 or 95.32 as 'homebuilt' you are outside MARAP and free to maintain/modify as you deem fit.

I was thinking of a project that involves an unregistered aircraft that was previously rego'd 32. The aircraft will be totally stripped and any repairs/maintenance or modifications needed would be done then rebuilt but wanting to be classified as the builder under a 19 rego. I'm sure someone has done this before so i would like to know if they had any problems in doing so as under the current rules I think I could complete the aircraft and be told it is still a 32 and must stay as the factory built it.

At best its not going to end up under 19 reg (95.55 1.1 (a) excludes WS and PP from 19 regn altogether) but you are going to have issues with homebuilt under 95.32 as well - check 95.32 and call the tech office.

Basically: If it was registered as 32 under one of the manufactured categories you will have to demonstrate that the airframe no longer exists (forget about the old regn number - that attached to a factory built aircraft and will always remain so) and you still have to show that you can comply with para 1.4 on major portion.

Each to their own on crosswind comfort. 3axis or WS the capability and comfort of the pilot may be lower than the capability of the aircraft in anothers hands.

As for crosswind - crab offset approach (generally not as pronounced as 3axis - not as much side area) then kick it straight just before touchdown - works.

Capability of a trike is actually pretty good in some areas - not as fast as 3axis generally but I will happily operate a 65knt cruise 415kg two seat trike off 150m ... you have to go to pretty specialist 3axis for that sort of very safe performance but for a trike thats normal. For the single seater I am happy to operate of 100m of short grass. Horses for courses.

Looks to be a jabiru - and RAA registered

http://www.perthnow.com.au/news/a-light-aircraft-crash-landed-in-the-nattai-national-park-after-its-engine-failed-with-two-people-on-board/story-fnii5s3z-1227289453945

Funny thing about the M4 Severn Bridge Yenn, . . is that you get charged a toll to ENTER Wales, but reciprocally on the same bridge, no toll payable to Leave . . .? D'yer think the Taffies are trying to tell us something ?

But to look the other way ... The Welsh are telling themselves - feel free to leave but to come back to the good lands will cost you ... unless you drive to the old bridge up the channel ;-)

Living on the 'MAIN' land I am absolutely cacking myself laughing watching this arm wrestling comp between Tassie and England keep it up fellas:roflmao: It's like watching your little brother take on your little mother inlaw

The three big growth industries......Health care, Aged care, recreational pursuits.

Marty,. . .I agree with you vis a vis the Spitfeur. . . . . .but. . . . ( see below )Not much smaller than ours Marty,.. . . . .are you MAD,. . .? ?? ? your little island is less than a third of our landmass, and that's excluding Ireland. . . .Geez Mate. . . . . If you are having a "Landist" argument, then PLEASE get the Math ( if you are trained in America ) or the MATHS right if you are trained properly. . . .before arguing a lossmaking subject. . . . If we squashed Tassie up,. . .it would fit into Wales. . .and then you'd all be called TAFFY. D'you seriously want that ? ? ? ? Then you'd have to shag sheep, and speak in a really ridiculous 2000 year old language and have all your roadsigns changed to bi-lingual. . . . . I cannot believe you would countenance this. . . . . .

Tasmania - 26,410 miles ^2

Wales - 8,023 miles ^2

So to squash Tassie up and fit it in Wales as you say would rather overfill Wales ... a bit over 3 times

England - 50,346 miles ^ 2

So yep, Tassie is not as big, its only a bit over half the size

But come on, Tassie is a brilliant place, lived there for over 6 years and managed to get out without marrying a relative ;-)

If you can believe that Martin Bryant was the shooter...

Actually as you say it is point of time in the issuing of a 19 registration, but you don't go to having the full access to the 19 regime of flight until you have flown off the test hours. Airworthiness must be proven to a level sufficient for test flight at the time of rego, but is really proven as a result of successfully flying off the test hours and still being in one piece at the end without having killed the builder/pilot....As I suggested earlier if modification calls into doubt the test flight hours by fundamentally changing something that was originally proven through test flight then maybe some or all of those hours need redoing depending on the severity of the modification.....

 

I cant speak for others (especially the board...in other words these are my personal thoughts only) but on modifying undercarriage I would be much happier having an L2 review on completion of the mod, and a lets say for argument a 5 hour test flight regime including 150 landings at or within 10%of designed MTOW or legislated MTOW which ever is the lower, and an elevated inspection regime for the next 100hours where every 20hours the undercarriage is inspected by the modifier..... that seems to me to restore the risk reduction that CASA had required by having the initial test flight regime... From a cost perspective I don't see such an approach as an enormous impost, for most of us flying is flying..... and 5 hours of imposed circuit work probably replaces 5 hours of free choice circuit work with a flight here or there to break the monotony.

A 19 reg aircraft is registered when RAA takes the money and issues the numbers and certificate - the fact that the initial certificate may have 25-40 hours of restricted flying does not change the fact that it is in fact registered with the RAA.

Nowhere in the RAA tech manual is there at all mention of conditional or provisional registration in relation to a 19 reg aircraft - the only area where conditional or provisional permissions exist is in relation to a person/factory building second and subsequent aircraft under a program to approve a 95.10 kit where the tech manager gives permission for additional airframes to be built and provisionally registered to demonstrate the history of safe operation.

So no, the 19 reg issue is still a point in time determination - exactly the same as the 95.10 determination is a point in time with any and all subsequent changes completely without reference to design requirements other than those set out in the RAA tech manual ... and the tech managers over time have always when challenged by me on this agreed that as the design is not certified and any materials used are at my own discretion as I am the owner and take design responsibility (even if I did not build it initially).

As for feeling safer if an L2 looked over something that is entirely up to the owner/builder. Much the same as the L4 during the build phase of a 19 reg cannot insist on a change or declare that something is not kosher ... the role is to oversee the builder inspection and recommend limitations to the initial operation of the aircraft ... paddlepop stick props on lawnmower engines are likely to get much more severe restrictions than a commercial prop on an aircraft engine ... but the registration exists following completion of the paperwork and payment of the fee ... RAA cannot legally refuse registration if the steps are complied with when it is either a 95.10, 95.32 self design trike/parachute or a 19 reg.

I agree - the more 'experimental' a 19-reg aircraft is, the more you are out there on your lonesome.much clipped'.

The MARAP as drafted by CASA within the Changed 95.55 applied to the certified aircraft from factories ... those designed to a known standard and all coming off the line the same. These are aircraft where the registration is dependant not on being able to meet a weight/build definition at the time of registration (experimental and 95.10) but on meeting and maintaining the standard to which it was built.

The MARAP as CAO 95.55 covers is well designed to allow a modification path through the RAA and as there is a design standard behind te design that they are looking at changing then it is possible to assess the change and know it within a known environment of a design standard compliant airframe.

Nothing at all wrong in that - bloody comendable as it allows a lifeline for all those older 95.25 without an active manufacturer or the earlier 101.55 where the manaufacturere may not be interested or see it as financially viable to support modification programs for aircraft they have moved on from eg jab LSA55

The ONLY reason we have an 8 page thread on here is the bewildering insistence by the RAA Tech in announcing MARAP that it include sthe 19 series .... the only part of 95.55 that has no design standard behind it and is explicitly not covered by the amendments to the CAO that introduced MARAP

So over to the RAA - explain why 19 is included in the announcement when the CAO changes do require it or admit that they got it wrong ang 19s remain as they were - free to modified at any time by any owner as the definition in 1.2(e) is a point of time at initial registration test.

much clipped ...Kasper you are missing a very important step.... I know that the step that's missing doesn't fit with your agenda that its the board and staff that are out on a mission to bone the members.... The step that's missing is we can rewrite the tech manual till the cows come home (and we all know that it was due for a complete rewrite about 30 seconds after first release!) until CASA are happy that everything they want included, is, and everything they want omitted, is , the document can not be released to the members as "The Tech Manual" . You seem to think its our remit and to an extent it is, its our words...right up to CASA wants them changed!

 

Andy

Sorry but I do not have an agenda - I have no interest in pushing one side or the other just to understand that what is told to us by the RAA (board or executive) is correct in facts.

IF the CAO 95.55 change did not impact on 1.2(e) aircraft (the 19 reg) then ALL of the statements from RAA Tech and board are based not on a requirement from law but from a document authored by the RAA over which the board does have oversight and control.

I am absolutely aware that the tech manual is an approved document and needs CASA approval prior to being operational within the RAA.

However, that fact alone does not change the reality that when the Tech Manual goes further than the CAOs and places limitations on one group of aircraft that are specifically NOT included in the CAOs a very reasonable assumption from those not involved is that the inclusion is coming from the RAA not CASA or they would have included it in the changes to the CAOs themselves as they have full drafting control over this area. And if the CAO are trying to insist on extensions within the RAA Tech Manual that are were explicitly not included in the very recent CAO change why the hell are the RAA Board and Exec not standing outside the Ministers office screaming bloody murder? After all, from my point of view, thats the reason the board are there - to represent the views of the RAA membership in defense of the operations that we consider to be legitimate, valid and justified based on risk and evidence.

My agenda, if you like, is to see the RAA board and executive communicate more openly with the membership.

Where are the board statements of principle of what the RAA is all about?

Where are the positions of the RAA on areas of aviation regulatory change to be found?

Why is it that this absolutely devastating change to the 19 reg aircraft comes at the membership out of the blue with no consultation period ... because I can assure you if members had understood the scope fo the impact on the 19 reg the consultation would have been heated!

Could be right but the claim was that CASA prevented owners modifications, seems its RAA manual that doesIt is being rewritten

If there a things to change or clarify lets do it

 

Current practice aees things finalised and released apparantly before the board know about it.

Yes the CAOs can be changed to remove entirely the exemptions so that is the ultimate.

No - against anyone (CASA or RAA) saying that the second and subsequent owners of 19 reg aircraft can't mod or repair the CAO 95.55 is clear - it MUST be a point in time registration determination of CAO satisfaction or there there could be no second or subsequent owner as to contrue the annual RAA fee as a new registration excludes the ability of the aircraft to meet the requirements of 19 reg to anyone but the original builder.

So yes and no. Yes the the CAO can be withdrawn or rewritten but No, the construction of and interpretation of 95.55 to mean that each annual registration is a registration is not supported.

IF the RAA Tech are looking at amending the Tech Manual to include 19 reg is the changes tat now apply to other type certified stuff then it is for the BOARD to state what the policy is and let the MEMBERSHIP know what they are doing because it is NOT due to the CAO changes from CASA.

Can you at least tell us which regulations you believe state this?from CAO 95.55:

 

1.1 This Order applies to a single-place or 2-place aeroplane that:

 

...

 

(e) is mentioned in paragraph 1.2

 

 

 

1.2 For subparagraph 1.1 (e), an aeroplane must be 1 of the following:

 

...

 

(e) an aeroplane, the major portion of which has been fabricated and assembled by a person who undertook the construction project solely for the person’s own education or recreation...

 

 

 

6 General conditions

 

...

 

(f) in the case of an aeroplane to which this Order applies by virtue of subparagraph 1.2 (b), © or (f) — the aeroplane must not have been modified without the approval of CASA or of an authorised person for the purposes of regulation 35 of CAR 1988;

 

(g) in the case of an aeroplane to which this Order applies by virtue of subparagraph 1.2 (a), (e) or (g) — the aeroplane must:

 

 

 

(i) before its initial flight, have been inspected by a person authorised by CASA for that purpose; and

 

 

 

(ii) if any condition or limitation has been imposed under paragraph 6.3 — be operated subject to that condition or limitation.

 

If the limitation comes from 6(f), that does not apply to amateur built aircraft (subparagraph 1.2 (e) ) - only subparagraph 1.2 (b), © or (f).

 

I am looking for something that applies only to the builder but I don't see it. It seems like another case of someone reading the regulations to mean what they think they SHOULD say, rather than what they actually say...

OK Perfect - we have a completely incompetent BOARD and TECH Manager

I have quoted the above because it is correct - I did not read the new 95,55 closely enough -the two areas of change - as noted in the post I quote - only impact aircraft under 95.55 that are NOT under 1.2(e) ... that those excluded are the 19 reg aircraft.

So there you go there is NOT an inclusion of 19 reg in the change from CASA to the CAO

Now, apart from the tech manual - the law for 19 reg remains as it was last Wednesday... and despite what any board member or Tech manager may WISH TO BELIEVE the requirement to reg a 19 ultralight is NOT a continual process it is a POINT IN TIME determination.

Once an aircraft meets the definition in the CAO it can be placed on the RAA register and it remains registered FOREVER but only permitted to be operated when the requirements of the RAA annually are complied with - annual RAA aircraf processes are not a registration each year but akin to an annual revalidation.

So there you go. ANYTHING from the RAA - Board, Tech manager or front office staff - saying that 19 reg aircraft are impacted by the 95.55 change last week need to be shown the red card - they are wrong.

well i am playing the RAA are crap at drafting card again.

this encapsulation of 19 reg into something needed to fix operational issues with 101,55 and 95.25 is entirely at the feet of RAA.

CASA in 95.55 were very careful to not require non mod on 19 reg and under the CAO 19s are effectively the same as 95.10 on purchasers maintainer / mods.

I think its time the BOARD told the EXECUTIVE that the POLICY is to maintain recreational flying with the minimum of admin and regulatory overhead

Sorry Andy, the board may not need to be involved in the detail but they OWN the policy so when RAA add a requirement through the tech and ops manuals that are not written in the CAO the BOARD are responsible

FULL STOP

And bluntly I am not a happy bunny about this.

Then you have to get an L2 to sign off on an ACR, again if they are taking liability for this it won't be cheap.

I can't get my head around the price.