kasper

KasperMany years ago I was furious at the board at the time...not sure if you were a member back then in 2011 when we had just been grounded by CASA for failing the same Audit 4 times in a row.....At the end of the day the underlying issue was that the systems used within RAAus were simply not up to the task of ever meeting the Audit requirements for the size of the membership and aircraft base that we had at the time......

 

I was part of a group that called an Extraordinary GM to try and unearth the failings in a way that all members could see...... I believe that the group was successful in that endeavour because the old board members that presided over the audit timeframe mostly over the next 12 months resigned or were replaced through elections and a substantial portion of the group I was part of now, are board members of the organisation, myself being the last to take office in October last year.

 

What we found was the organisation was unsustainable and we set about to change that. Its my personal view that we had many many years of neglect to try and make up for and we have started that journey. Today RAAus isn't what we want it to be, but we are very close to being sustainable, rather than on a fast train to irrelevancy, and about another 10ish months from delivering core and fundamental systems changes that will provide the basis for significant improvements.

 

If the decay/neglect took a decade(ish) to put in place, then how fast can members reasonably expect it be fixed given that the board majority needed to drive the change needed wasn't really available until October 2014 and the appropriate president not in place until Early 2014?

 

If you feel the journey is too slow (and we all feel that from time to time) then the right approach instead of bleating here continuously is to stand for the board and offer your substantial aviation law expertise, your substantial Aeronautical engineering expertise to the board...Im sure we would be the better for your inclusion.

 

Be part of the solution, after all its a members organisation and your a member....aren't you? The next elections for NSW will have the current president stand for re-election (assuming Mick is up for another period) if you win that election then you can also stand for President....Now theres an offer you cant refuse...can you?

 

Andy

But I do find it galling for you to say that to be part of the solution I have to put myself forward AND get appointed as a board member ... we have more people in the association membership than could ever sit on the board and for an actual board member to say get on the board or effectively you care not part of the solution is right up there with the Tech manager last week telling me I don't own an affected aircraft therefore its not my problem.

Either we are a membership organisation with an exec and board that is open to listening to the membership or we are not.

The RAA employees when I have been speaking to them on actual live issues I have with my aircraft over the past 7 months have demonstrated themselves repeatedly to not actually get the policy issue behind the question raised and simply turn on me and say I am being obstructionist by not just doing what they say ... even when what they say is not within the tech manual and is in fact directly against the tech manual!

The RAA board do not have a member accessible RAA run forum such as this one and so there is not a formal RAA way of raising and discussing issues or points other than through this public forum so here we are - talking very publicly on a forum that is available.

And given the ample evidence in the last 12 months under the new exec and board of the RAA issuing a new Ops manual to the membership without prior view how can you be surprised when members come along after the event (because we were not included before the event) and say openly there are problems.

And we are about to get a new Tech manual - again without membership visibility and only snippets of change disclosed - and when you do raise with Tech serious fatal flaws in the drafting of what has been previewed (reg markings) and get attacked what do you expect?

So here is your factual challenge that shows what is about to happen with a tech manual change that was never released and reviewed by people affected by it - look at the drafting of the new Tech Manual on regn markings and tell me where and what size I have to mark a 95.10 weightshift aircraft ... hint - the first line of 9.1(3)(a) gives the answer - only fixed wing 95.10 are included in the tech amendment requirements to display markings.

It seems perfectly clear from all previous thread discussions that a PPL who is a member of RAA can fly an RAA plane without a pilot certificate. I am amused by the circuitous arguments that insist otherwise. There doesn't seem to be a skerrick of supporting legal evidence.

1. you are not flying on a pilots certificate so you are not subject to para 5 of CAO95.10 so good fun - while the aircraft has to be registered with RAA it is not subject to the tech manual and you are not subject to the ops manual as compliance with them is just part of operating within para5 to get the para3 exemptions ... and as you are in a 'rule breaking' mood tear off the warning sign about it being a 95.10 aircraft as that is also not required for this flight as that is under para5 and you are being a rebel

2. you are not operating within para5 so the exemptions under para 3 do not apply to your flight so you have to comply with all the bits in teh regs that para3 exempts pilot certificate holders from ...

para 3 - exemptions under reg 308

I am not complying with para 5(d)(i) So I AM required to comply with each of the bits under para 3 that I would be exempted from if I had a pilots certificate ... so here are the bits of CAR 1988 I have to comply with because I have a Pilots Licence and not a pilots certificate:

(a) Parts 4, 4A, 4B, 4C, 4D and 5;

4 Airworthiness requirements - issues - heaps - eg anyone who did not hold a CASA certificate to do ANY maintenance on that aircraft EVER makes it airworthy within the regs … flying an un-airworthy aircraft is against the regs - pilot in trouble.

4A Maintenance issues - heaps - eg maintenance releases by authorised personnel - a maintenance release doesn't exist for RAA and you just took off without a required documents - pilot in trouble.

4B Defect reporting Probably not so much an issue for the pilot - they are not being maintained by controlled people

4C Flight Manual issues - heaps - eg there is no approved flight manual, it probably was not carried on the flight (because it doesn't exist) - pilot in trouble

4D Removal of data plates Not so much - the data plates are not in place because they reg that requires them does not apply to RAA registered aircraft

5 Balloon flight crew licences Not so much an issue really

(b) subregulations 83 (1), (2) and (3) in respect of VHF equipment;

issue - must hold FRTOL - I have one of those as I have a PPL so no issue

© regulations 133, 139, 155 and 157;

133 Registration marks 133(1)(a) requires nationality and regn marks as per Part 45 …

"45.015 Australian nationality mark

The Australian nationality mark is the capital letters VH.

45.020 Registration mark

The registration mark of an Australian aircraft is the group of characters that is assigned to the aircraft under Part 47."

So any RAA aircraft cannot comply with this so issue - illegal flight

133 rating by crew 133(1) requires crew to hold all appropriate ratings for the aircraft … check my PPL for tailwheel if reqd …

139 documents to be carried in the aircraft PIC must carry in the aircraft the cert of reg (it does not exist for RAA) the cert of airworthiness (it does not exist for RAA) the maintenance release (it does not exist for RAA) the radio equipment licence - lots of issues for the pilot

155 aerobatic manourvers I will assume we are not going to be doing this …

157 low flying I will assume we are not going to be doing this …

(d) paragraph 166A (2) (f) in respect of powered parachutes;

(e) Division 4 of Part 13;

Dsiplaying lights etc Assume that the issues possible here are not arising

(f) regulations 207, 208 and 230;

207 Operational type Assume that the issues possible here are not arising eg not used for commercial BUT as CASA have not authorised the RAA aircraft specifically (because they wrote this to be exempted) it might be a bit messy

208 number of crew operating Minimum crew issues do not apply - it’s only got 1 seat …

230 starting and running engines Assume that the issues possible here are not arising

(g) subregulation 242 (2);

242(2) radio fault rectification Hmmm. If your radio check comes back faulty then only an approved person can fix it AND they have to certifiy it fixed … best not check the radio then because I can't change a fuse legally here …

(h) regulations 252 and 258;

252 Provn of emergency systems Bascially its about life vests and liferafts directed by CASA … assumed not to be an issue

258 flgiht over water Assume that the issues possible here are not arising

(i) regulation 322. no longer applies

So you are flying an illegally marked aircraft with multiple document problems and its technically unairworthy ... thats just YOU as pilot ... by flying it as an Australian Aircraft not under the exemptions of para3 you have also just opened up to challenge anyone who maintained or worked on that aircraft since it was registered ... probably the CASA and DPP will just go after you but technically your flight just impacted all people who worked on the aircraft back to date of registration as all their work was unrecognised due to either the person being non-approved or the process being undocumented - or both.

So dear PPL pilots, go fly an RAA aircraft and maybe the DPP will not go after you but be very aware, you are NOT flying it legally and to say otherwise is to be an idiot.

Cheers

I don't think the NZ system is as free as the current RAA system and I think RAA would better serve members by treating from an operational perspective factory built separately from home built/experimental.

This is not to say that everything should go back to 390kg MTOW fabric and tube ultralights etc. but to accepts that RAA aircraft are not 'old school' ultralights only BUT that there is a fundamental difference in the airframes within the RAA realm that should be maintained regardless of it flying at 50knts or 135knts.

This was the initial logical separation between those that were designed to an accepted set of criteria by an organisation that had undertaken the manufacture to the accepted design standards and those that were not.

On the basis that the aircraft came out of a factory and had been tested to an acceptable level the use to which the aircraft could be put was expanded beyond that of those that were not so designed and manufactured ie the experimental ones.

On this logic was based the use of aircraft for hire and reward.

On this logic was based the requirement for L2 maintenance for those used for high and reward.

On this basis was based the initial extension of operational limits into airspace that was previously not available to any AUF/RAA aircraft

Where I consider RAA went wrong is that they sort removal of operational restrictions without differentiation between the factory built and the non-factory built airframes - focused on getting expanded access based on pilot endorsements/qualifications.

The result of this is in my opinion the ability of CASA to turn around now and say

1. ops between the two areas of airframes is approximately the same therefore

2. risk to persons outside the plane are approximately the same therefore

3. maintenance and modifications between the airframes should be approximately the same

If the board were to have a stated policy position on what the difference should be between the airframes coming out of factories and those coming out of garages then it would be much clearer to assess apparent policy positions as articulated by the RAA exec, tech and ops areas because at the moment there is a situation where board members when asked can and have said that 'that's for the executive to deal with - the board to not micro-manage as we have in the past'

If there was the stated policy position of the RAA board then the RAA executive an tech department would not be managed by the RAA board but they would be bound to follow the board policy in dealing with CASA in discussion of changes requested to be included in the tech manual etc. and when conflict between RAA policy and CASA position exists they would have to either hold the RAA line or refer back to board.

Frankly I am going to piss off RAA employees here - it's for the board to set policy (even if its not in line with current legal positions) and its for the executive and employees to implement and manage operations within the legal requirements and to operationally seek through change to the legal requirements the implementation of RAA policy.

Yes the exec and employees have input to the policy formation within the board but ultimately its the board that is responsible for policy not the exec/employees.

Only in this way - and with clear statement of the policies of the RAA to the membership - can the membership hold the board to account for policy positions.

On calls within this thread for US style 103 - my opinion is to forget it in Australia. We had that before 1988 ... and the HORSCOTS report fundamentally and comprehensibly set out why no training in ultralights was never going to be acceptable - the pilot certificate is here and will stay ... no politician will move away from that as the first death of an untrained pilot after removal would be their political death knell. And in any event how many actual 103 US ultralights are really 103 compliant? the fat ultralight situation in the US should not be allowed in another country and from a physics perspective focusing on MTOW and wing load is more logical - 300kg of aircraft, pilot and fuel flying at 45kts has the same energy regardless of the distribution of mass between the airframe and pilots/fuel - trading useful load to airframe can be a safety enhancement ... as noted by HORSCOTS in the report that removed the 115kg empty weight from 95.10 ...

Please everyone stop preaching to the choir...... I know the answers to these questions just as well as you do, and if it were my SOLE role to answer them I would....but it isn't and I wont in isolation...... The question will be answered correctly....and even better by the people whose paid job it is to do so!And while Im feeling sh!tty about being preached at.......Kasper the board strategy for RAAus spans a time period greater than 1 year......presuming in your post that far looking for us is 1 year is objectionable, as is you preaching to me on IP management...I've only been doing that within a 7000 employee company within the IT department (so about 110% of the damn time!) for a decade or so.....Point me to a member who would have, on my post about IP management not understood what the issue was I was discussing (high level, not the specific relevance to RAAus circumstances) . I was discussing with the average member not an IP Lawyer! your point of clarification is just nit picking....hmmm trend???

1. I was NOT responding directly to your post - or I would have replied and you would have seen your post - I am VERY consistent on this issue within forum use - if I post without a quote or reply it is to the thread and readers on the topic and issues within and not in specific reply to a single post

2. You in post #4 introduced the issue of IP specifically so it was within the thread and given my point above it was not towards you specifically but a more general comment on the area clarifying what I see the issue to be = BTW its the same issue you raise in post #4 so basically I am AGREEING WITH YOU

As for your 'just nit picking' my comment on this as an RAA member is get off your high horse - not all members agree with you on interpretation of some of the existing RAA and CAO documents.

The three significant issues I have discussed on this forum in relation to APPALLING drafting within the Ops Manual and the inability of the Tech Office to UNDERSTAND the drafting of their Tech Manual changes as they APPLY TO MY AIRCRAFT are not nit picking. Explain to me HOW it is nit picking to be waiting for 7 months AFTER CALLING TECH to register an aircraft when the only issue is how to comply with the display of regn markings?

And how is it nit picking to point out that a policy change in relation to all 19 reg aircraft not owned by the original builder is going to actually ground aircraft for periods of time and require the additional expense and time of L2 inspections ... or that the drafting of the Tech office when outlining this actually would mean that the L2 will 'validate that works have been completed appropriately' ... not oversee a builder inspection or state an opinion on a condition report but validate appropriateness ... this is substantially MORE than applies to the initial inspection and registration process and I hope the RAA is providing insurance coverage for the L2s who are would be required to sign of appropriateness and validity of not just work but of design.

Sorry but I am pissed off completely with being attacked by RAA employees and board members fo asking valid questions.

This week being told I by the Tech Manager that as I do not own an aircraft affected it is not my problem is NOT a helpful way of engaging with members who are trying to head off drafting issues that really have the ability to significantly impact members broadly.

That is correct, before depreciation.

I appreciate that for private flying (unless LSA) the 912 overhaul life is not an issue but even without limiting the engine life to 10-12 years if you have a factory built that is at all used for hire/reward the 912 engines has to run to schedule (subject to change depending on what Tech can get agreed for on condition running and overruling manufacturers yet retaining CAO compliance on actual entitlement to be an ultralight) and pricing in around $1,000-1500pa separate from the depreciation is required because the engine gets to end of life before your 20 year air-frame life.

Many confuse Intellectual Property rights (IP) with distribution and availability - the IP legally remains with the author if claimed at publication - RAA own the IP and others cannot use that IP without permission ... its up to us to decide if we want to distribute the IP freely or restrict it.

Given that the stated aim of even bothering with any form of printed magazine under the announced decision of the board is to distribute to flying clubs and schools as an advertisement I am astounded that we are even worrying about the likelihood of wide distribution - we actually want that as its a way of getting into people under the age of 30 who may be interested now and take up ultralights at a date in the future - and to be fair if its only at the club or school the person reading it has already got an interest and is acting on it so damn it all i vote for as wide a distribution electronically as possible to get it out there to people who might have an interest but have NOT acted on it already - that's what the paper mag in the newsagent targeted but it just cost too much in that form.

Changes in society with digital media and the mountainous cost of production have killed the mag as a printed 'member only benefit' and really the only question now is what do we want to do with the mag in digital form - either its NOT for advertising to non-members (club mag) and we go the way of behind the RAA members section for access with as much/little 'protection' as we decide OR its advertising of the sport AND communication to the members that is available regardless of RAA membership.

From my perspective the current RAA announced decision is completely mad and will last 1 year ... printing costs per magazine are higher the lower the numbers printed ... printing only copies for flying schools and clubs is a line of distribution that has only 1 end point - a very sharp escalating cost not covered by members funds with members who are cranky about the fact that the removal of the printed mag came at no reduction in membership ... and its only being seen by people who have already got an interest in the sport and acted on it to go the club/school ... right or wrong next year the printed mag will die unless it is printed from digital at the point where it is used IE by the flying clubs and schools at their expense.

Frankly the digital mag is good as far as it goes - its a digital replication of the existing paper so no point complaining about content and the format is pretty much the best you can get if you are just replicating a magazine in a different media ... All digital publication has limitations compared to paper but I have been reading digital mags and books for over 6 years and you adapt to them.

Lucky to survive that trike crash there nothing in front to take the impact and a motor driving you into the ground behind .

And if we are running out of good mechanics ... and the CASA/RAA are making it compulsory for a significant sector of our aircraft (all 19 reg not owned by original builder) to have L2 signoff of ALL modifications (minor or major) AND the aircraft is grounded until that and the admin process is finished can you from a practical capacity and use perspective see that the change as difficult?

Oh from a personal perspective I should be happy - lapsed L2 here and if they keep going this way with increased involvement I might look at going back into that but I just do not like to see 'experimental' being turned into quasi factory built on a justification of 'protecting' the people inside - its experimental, its stated as such and logically there is no distinction between someone flying a plane built/assembled by the owner and someone flying the same plane when its been sold to someone else.

Rather a broadbrush series of statements. Perhaps you should put some meat and muscle on the skeletons so we can see where you are missing out.A similar statement could be made that the cookiecut, manufactured aircraft have less problems per member (and plane) than the homemades. The millions of dollars the readymades pour into RAA goes to help all planes and pilots and the necessary activities to support them.

'millions of dollar the readymades pour into the RAA'

1. Aircraft regn fees are exactly the same between readymades and homemades - and a 2 seater aircraft provides RAA with $250 in its first year and $130 in each following year

2. the last financial reports from RAA showed an annual registration income of just $218,264

Demonstrably there are NOT millions flowing in from ANY aircraft and what flows in per airframe is the same between experimental and factory

Some meat:

Hard to recognise as an ultralight a variable pitch retract aircraft with a cruise speed in the area of 120knt+ with a MTOW getting on half a ton. They are Recreational GA-lite. Not saying thats bad but its not an ultralight - ultralights were low inertia/low energy aircraft and that is what made them fundamentally different from GA and justified the distinctly lower regulatory regime. The closer to GA your aircraft and ops are the easier it is for CASA to bring in more and more GA like processes and controls.

Application of this is to the move to require inspections and signoff of mods on experimentals - for goodness sake its experimental! JUST because some very high performance 'ultralights' are registered under this and their owners sort of treat them like the extra performance does not justify this. And the logic behind the application of inspections and signoff is equally applicable to 18 and 10 registrations ... may as well just give up and reg is through SAAA as GA experimental and put VH on the side.

As for all the great new operating limits - they are functionally not available to 10 regn ... they need to have certified or CASA accepted engines under 101.55 ... not many 10's have a 912 or a jab.

A bit more meat - RAA Tech applying one size fits all - apply to transfer a basket case 10 reg aircraft - had the docs done, had an ACR done and it was agreed by everyone it was not airworthy - RAA decide to try and cancel the registration rather than transfer it ... but that's NOT available to RAA under the CAO or the Tech Manual because sole determination of airworthiness is the pilot on the day and the only time the aircraft actually has to be together as an aircraft (and not even be able to start or fly) is the day it is weighed for its initial registration - that's the ultimate freedom and the concept of 'protecting' owners and pilots in some 19 experimental when there is a nice big sticker stating the aircraft is NOT designed to a standard and the CASA and RAA do not take responsibility for airworthiness is a bit of a conflict if allowed to go forward applies equally to 10 and 18 reg

CASA can require whatever they want. They don't have to do trade offs..I have a lot of controlled airspace time but do NOT believe we need more than transit a zone ability. The extra liability is large. IF you stuff up you may lose your house.

User pays should be a principle adhered to. It's only fair and I think the board members would appreciate this.

 

There is no doubt CASA have hardened up on this. the last CEO was not sympathetic or across the essence of the movement. Perhaps that will improve now but I wouldn't bank on it. Nev

Is RAA :

1. just an outsourced administration are arm of CASA in relation to a group of aircraft and pilots or

2. a member organisation with delegated administration PLUS a political organisation with an agenda and program separate from CASA?

As the AUF it was squarely 2. ... talking to Darren about the 19- issue for second and subsequent owners and how/why the proposal is as it is RAA are looking much more like 1. in some aspects of operation

Another way of looking at it is:

CASA 'own and author' the CAOs with oversight and acceptance by parliament (they are tabled)

RAA 'own and author' the RAA Tech Manaul with oversight and acceptance by CASA - it's a controlled document

If we are now saying that we will not even defend a current privilege in our operations (end to end) because CASA don't like what we want or want a change that is not in the CAO then lets be prepared to draw the line and say NO - let them put it in the CAO if CASA feel that strongly about it BUT by imposing ADDITIONAL controls and processes through the Tech Manual we are in effect allowing CASA to avoid the oversight and scrutiny of Parliament that exists on the CAOs.

Who really cares about all this ?You can legally fly now under the current system so stop winging and go FLYING.

and legally flying is not the point - its about the level of oversight and associated controls

eg on a 19 reg where you are not the original builder under whats proposed - crack a wooden prop blade in a hangar rash incident and replace with a nice new carbon fibre prop because the old manufacturer is not around and you are grounded until the L2 inspects the changes, the paperwork is through RAA in Canberra and you get the clearance .. .and then its possible you will be back on a test flight schedule

So simply saying go fly may just become a hell of a lot more expensive with nice chunks of time with aircraft grounded ...

Credit and support when due - absolutely eg the MARAP process to support factory built aircraft move forward when there is not a factory or willing factory is brilliant and long overdue - brought together by current team - very well done

However, the approach of proposing back to CASA exactly what CASA said they wanted on 19 reg aircraft to create a process of modification and inspection for second and subsequent owners that does not exist at the moment is not something I think deserves credit.

My concern is that it appears that to get the increased access to airspace and operational freedoms the RAA are already prepared to just roll over on airframes and inspections ... for those who are basically running GA-lite under the RAA banner this is probably OK as they probably already have their airframes maintained and serviced by L2s ... but what about those who do not? What is the regulatory justification for adding admin and cost burdon to a segment of the aircraft? If the burdon is justified by CASA on the basis that there is now an ability to fly into controlled airspace then really it should be for the RAA board to openly state this BEFORE going ahead with it ... at the moment that does not seem to be the case.

I am coming to the conclusion that:

• the distinction between GA and RAA aircraft has disappeared.
   
   
  
• the policy as applied and operational management of RAA do not see that the distinction is important
   
   
  
• 'high end/GA RAA' fleet and owners are driving RAA further into the the GA space in terms of airframes and operational limitations
   
   
  
• experimental RAA - be it 95.10, 95.32 or 95.55 are being ALLOWED by the RAA to become more and more controlled and aligned to factory built aircraft to the extent that there they may as well be home built factory aircraft.
   
   
  
• it might be time to consider the creation and operation of a new ULTRALIGHT organisation to move away from 'GA-lite' and to put back the ultralight in Australia and draw a line around them and their operations.
   
   
  

I am not going to write up all my reasons and evidence behind the above statements but post the thread here to hear from the rest of Australia.

And sorry to the rest of the world on this thread - I am not looking for comments saying that 'we have always had a permit system' (UK) or 'always had an inspection regime' (NZ) is not the point. We in Australia DID NOT have these on our experimental ultralights and our safety record is not horrendously bad as a result.

I am look to understand what RAA and Australian pilots think ultralights here are supposed to be about because:

• If the RAA has decided to abandon these freedoms to achieve greater access to airspace etc to allow the high end to operate effectively as 2 seat GA aircraft I think that is a price too far.
   
   
  
• If RAA has decided that there is no ability or point in saying NO to CASA anymore and just saying that's it, then that is a separate issue for the membership to understand and accept
   
   
  
• If its just the RAA executive and tech saying its too hard or not worth arguing with CASA then that's a board decision to either accept it or tell the executive not to as policy sits with the board
   
   
  

Because if its policy to not draw a line and 'defend' the current operational limits of ultralights then I think it is valid to consider a 'new AUF'

Ok have spoken to Darren B on this and I am differently furious

1. The original description of MARAP posted by RAA Tech that included 19- in MARAP was as directed by CASA ... so clearly they did not know what they actually wrote in the the CAO

2. The currently MARAP description by RAA Tech (without 19- reg) has the 'new' 19- changes for second and subsequent owners because apparently CASA only ever intended for experimental 19- to be modified without overview and process if you were the original owner because only the original owner met the builder rules and the RAA proposal is a response to the CASA saying you must do this.

Despite 2. being driven from CASA it is a horrible starting point because the logic that a modification to a home built aircraft is only available to the original builder equally applies in logic to the home built 95.32 (18- reg) and the entire 10- reg series.

So I am still furious that RAA are simply proposing back to CASA a significant change that logically can be applied to other areas of RAA aircraft on the basis that CASA want this because its not an equivalent process as the SAAA for 101.28s on the VH register.

If this is allowed to go unchallenged by RAA from a policy perspective we may as well just give up having a board or membership because in effect its a matter of whatever CASA say - if that is it then get rid of RAA and move the lot into CASA and remove the pretense of membership involvement in policy or process.

I notice that all reference to 19 reg has disappeared from the RAA MARAP pages ... maybe people in Canberra listen and/or read these threads ... now MARAP only applies to "CAO 95.32 & 95.55 FACTORY BUILT AIRCRAFT (NON LSA/E-LSA)" ... which is what people on here said from day 1.

But the interpretation issues and 'new tech processes' still exist if you follow the MARAP FAQ on 19 reg ...

"Can the MARAP process work on my Amateur built aircraft?

The answer is no.

MARAP is not necessary for amateur built aircraft if you have constructed the major portion (+51%) for your own education and recreation. Therefore the builder is already entitled to modify the aircraft within the constraints of CAO 95:55.

If a Recreational Aviation member purchases an amateur built aircraft, MARAP cannot be utilised to incorporate any changes or modifications. Major Modifications can be carried out by the current and subsequent owners. On approach to the Civil Aviation Safety Authority for a ruling Recreational Aviation Australia proposed the follow process

• If the owner is not the 51% builder but has incorporated changes a Grandfathering acceptance will be given
   
   
  
• A list of what is acceptable as Minor and Major modification to be provided as guidance material for the owners
   
   
  
• Major modification can be incorporated into a 19 registered amateur built by the current owner
   
   
  
• A RA-Aus Level 2 to validate that works have been completed appropriately
   
   
  
• Copies of the appropriate logbook entries are to be supplied to the technical team to be included on the aircraft file
   
   
  
• The RA-Aus Technical Manager is to be notified once the modifications are incorporated. The Technical Manager may stipulate additional requirements such as a flight test program or additional documentation such as a weight and balance report
   
   
  
• Once formalised and approved and the above requirements are completed the member is free to exercise the privileges as a member of Recreational Aviation Australia"
   
   
  

So now if you are 19 reg and not the original builder:

- they have created a grandfathering (date and list of aircraft impacted posted on the RAA website would really help here as the MARAP date has already passed so presumably they already know the aircraft involced):

- Have Minor and Major mods listing (listing on RAA website might help, as would a definition of both of this purpose)

- Woo Hoo!!!!!! L2 are not just doing an ACR but validating the work has been carried out appropriately ... that sounds incredibly like taking responsibility for it ... very new ... and the Woo Hoo is sarcasm just in case it was missed

- Copies of docs and logbooks to go to Tech and given Tech can stipulate part/all new flight test programs etc

- Only after getting all of that can you operate the 19- regn aircraft

So we have twin track 19- regn if you accept the Tech office FAQ at face value on this:

- if you built it you can merrily do your own thing without reference or inspection or notifying anyone (just note it in the logbook) BUT

- if you bought it then you can't use MARAP but the processes above outlined mean you sort of start again as if you were first registering the aircraft as 19 and get a test schedule (or not)

I must say I am absolutely dying to see the new Tech Manual and see if that little bundle of joys is in it because it certainly 'aint in the CAO or the current Tech Manual.

And the BOARD should note that THIS SAYS THAT THE RAA ARE PROPOSING THIS TO CASA SO CHEERS GUYS - YOU ARE MAKING EXPERIMENTAL THAT LITTLE BIT (OR LOT) MORE DIFFICULT IF YOU ALLOW THIS TO CONTINUE.

How about a few emails to [email protected] to ask for a please explain and confirmation that the RAA policy is to ask CASA for more restrictive and controlling processes.

The glider is the Horten Ho X a and the bottom photo is the Horten PUL-10. Designed by Reimer and Walter Horten. Originally in Germany, but later in Argentina.

Photos 1 and 2 are Bill Moyes Horten Xc

3 is the Horten Xb from Argentina

4 is the Horten designed PUL10 (Panek UltraLight 10m)

Love the woodwork in the H Xb ...

new post to bump it back up the list - nobody even going to guess?

What? Did he tell you to be offended - or not? Not sure the meaning of this.

 

Indeed. Hell awaits the God haters. But the good news is it doesn't have to be: "God has been pleased by the foolishness of the preaching to save those that believe."

 

Time to stop scoffing and look into this seriously, the consequences are eternal Kasper.

I just checked with my husband - the post by Gnarly on a back handed homophobic joke around the the changing meaning and use of the work Gay says more about him and his ideas of society and language than the reality of ... we had a quick look on the old god thread running around in circles on here and decided there was no hope for some.

Cest La Vie

On condition, has been part of the tech manual for a long time now, including for training. Nothing new here, a bit of carry through from GA actually. LSA is different kettle of fish with airworthiness responsibilities lying with manufacturer and what they dictate.

eg 1. The current Appendix A for 'on condition' 4 strokes requires you to record the leak down results on 'the maintenance release' ... this is not a document that exists for RAA aircraft ans shows that this part of the appendix was without care lifted from GA

eg.2 the same appendix requires that "oil consumption shall be monitored in accordance with approved maintenance data" ... as we don't have a maintenance release to record this on its moot but where are we to get "approved maintenance data" from?

eg3 The Tech manual has been in its current form for 8 years ... no Appendix B for 2strokes ... so guys couldn't find a GA text that set out how to manage a 2 stroke eh?

Basic point - to remain within the approval for being a factory built RAA registered aircraft its either certified or built by an approved factory to an approved/accepted design. If that design documentation requires that the engine be a 912A then putting a 912ULS in makes it no longer comply ... unless you have a reg 35 engineer (out of date name but you known what I mean).

If that 912A is documented in the acceptance process by CASA to have the rotax manual incorporated not following it also makes it no longer meet the design requirements to be operated in the original category ...

This minefield is not new and for the most part its been pretty much ignored but its there as an issue.

so what some are saying raa and casa ARE AUTHURIZED TO CHANGE THE ROTAX MANUALS ON ENGINE MANAGMENT AND INSTALATION OF ROTAX 912 ENGINESplease show letter off approvel from rotax neil

brave RAA, very brave

At least they do not appear to be saying that LSA can go this way.

What is needed - and only this much - is for a way of dealing with old certified/approved airframes where the manufacturer no longer exists and the airframe needs support - thats what I thought the new MARAP process was to provide - in that respect the RAA with the backing of some aeronautical personnel are taking the design role because there is nobody doing it - but to do that to an airframe where the manufacturer still exists is in my opinion 'brave' and unnecessary.

What about the crank shaft vs crank case question?

The 12 year life applies per overhaul on early series engines and the overhaul life in years cannot be extended - you serial number sets the limits. The later cases have 15 years life.

So overhaul a 12 year engine and it gets another 12 years, overhaul a 15 year engine and it gets another 15 years.

As I think you have come around to the fact is IF you are required to follow rotax life/overhaul requirements because your RAA registered aircraft manufacturer REQUIRES you to follow engine manufacturers overhaul and service requirements THEN the usual sensible option is to replace the engine in total with a new one at end of overhaul life because you will recover more $$$ from selling a time expired 912 to someone who DOES NOT need to follow the rotax overhaul schedule and can either run on condition already (all those 19 reg aircraft and others not used for hire and reward (very complex to work out so this is a gross simplification) or will be able to under new tech manual (?).

The new tech manual I understand will extend the on condition running but I will be astounded if it extends to aircraft for hire and reward and would seem impossible to extend to LSA not experimental.

Well AAIB tells an admittedly not fun story of autopilot pitch trim countering nose up pilot input with a max nose down attitude of 19deg - not exactly a nose dive but still lowest level 1100ft and VNE exceeded by 80KIAS is not my idea of a fun flight

"The flight crew decided to discontinue their approach to Runway 27 at Sumburgh Airport because of weather ahead. As it established on a southerly heading the aircraft was struck by lightning. The commander made nose-up pitch inputs but perceived that the aircraft did not respond as expected. After reaching 4,000 ft amsl, the aircraft pitched nose-down to a minimum of 19° and the applicable maximum operating speed (VMO) was exceeded by 80 KIAS with a peak descent rate of 9,500 ft/min. The aircraft started to climb after reaching a minimum height of 1,100 ft amsl. Recorded data showed that the autopilot had remained engaged, and the pilots’ nose-up pitch inputs were countered by the autopilot pitch trim function, which made a prolonged nose-down pitch trim input in an attempt to maintain its altitude-tracking function."

https://www.gov.uk/aaib-reports/aaib-investigation-special-bulletin-s1-2015-saab-ab-saab-2000-g-lgno

IF you were going to do this I would definitely do it in something overpowered and cheap ... like taking a T85 thruster and giving it an engine transplant along the lines of a 100hp two stroke - then you have the get up and go to get to 1000ft quickly and the drag to get back down quickly to get the wheels down.

Or do like the, in my opinion, mad UK microlight comps boys n girls do and take a flexwing trike and throw it at the ground regardless of speed and hope the snoot holds for the hour of abuse. You can pick up an old pegasus xl or raven x for under a thousand pounds and a time expired 912 for around 3000 ... take out the seatbelt and its SSDR 300kg and away you go - up and down at 45mph and you can be in the air and steep climbing turn a few feet up.

Not that I want to do this mind. I have no interest in trying to do extreme flight in that direction - much more interested in the FAI records ... except its impossible in this country to do them because the RAA is not affiliated and the organisation that is affiliated is not interested in responding to queries from ultralight pilots :-/

Googling nikasil cylinders may be enlightening for some, I don't believe it's a cure all for engines.I've seen an engine where some of the nikasil had flaked off a piston after only 3-4 hrs, not a good look.

The airframe manufacturer has not been offering the Nikasil option for the engine for some time now.

 

Jake j