John Brandon

Aircraft owners interested in obtaining a little more detail about the aircraft noise regulations might view http://flysafe.raa.asn.au/regulations/aircraft_noise.html John Brandon

I quite agree that the link you describe must exist. I guess students and others all see the instructors as the frontline RA-Aus operation managers, but as you suggest not all instructors understand their responsibilities in this regard and may fail to inform the CFI that his/her grounding options for pilots and aircraft allowed by the ops manual section 4.01 para. 6 should be exercised. By the way that para has existed for at least 19 years but I have not seen any elucidation of it. John

You appear to be a person who accepts that fatalities in aviation are inevitable and so produce a general list of the probabilities of dying. You obviously haven't read the ' Recent RA-Aus fatal accident history' document I referred to in my post. If you had you would see that the heading of the opening section is a quote from Mark Twain - 'Lies, damned lies and statistics' and the first paragraph might describe your attitude to aviation safety and, of course, your own. Unfortunately this attitude is not rare in RA-Aus circles. 1.1 'Lies, damned lies and statistics' We seem to have heard of more fatal accidents in recent years. Why are these accidents occurring? Are sport and recreational pilots and/or aircraft less safe than they were in the 1990s? Any person believing that fatalities are inevitable in sport and recreational aviation and examining the fatal accident statistics (an annual average of 3.6 p.a. during the five years 2008-2012) may conclude that the RA-Aus membership — being representative of powered, fixed-wing, sport and recreational aviation — has, perhaps, been achieving near-reasonable safety results, after taking into account the fading away of the older ultralight types and the continuing introduction of faster, heavier, more complex and less docile aircraft; together with a marked reduction in the average years of experience of the RA-Aus pilot base. The latter is because of the accelerated intake, and training, of new pilot members in recent years — although there is a very high turnover in newer members. Such cold, bare statistics may be of some value, but they fail to reflect the heartache and economic difficulties within the families that result from serious and fatal accidents. What is perhaps even more distressing to all of us is that so many future accidents will still be considered as so-called 'pilot error'* or 'human error'. Generally, a shortcoming in knowledge, awareness and task management plus misjudgement and/or unwise decision-making or poor planning, and perhaps neglect plus complacency ("we won't bother with doing the checks again, we'll be OK!) figure prominently as causal factors in those accidents. Accidents also happen when we attempt to operate in circumstances beyond our experience and/or ability. Quite often, just two or three misjudgements, possibly not that significant in themselves, combine to lead on to a heap of wreckage. And, of course, there are those very few occasions where pilot incapacitation was thought to be the cause. For those older members be aware that our abilities (including judgemental ability) and both the speed and appropriateness of our reactions does continue to deteriorate as we age, but we tend to deny it to ourselves and to others. (Speaking as an octogenerian who has been able to observe the ageing process on myself and acquaintances for quite a number of years.) We — the sport and recreational pilot community — must do all we can to bring the number of all such accidents to zero. Fatalities are not inevitable, even an engine failure over heavily forested terrain is survivable and, possibly, some forms of pilot incapacitation accidents could be avoided if pilots follow the pre-flight safety and legality check procedures or appropriate aircraft maintenance in the case of carbon monoxide poisoning. Of course there are events that an individual pilot might have little control over such as a bird strike at a critical time or being struck by an overtaking aircraft on final approach, but again, there may be aspects of situational awareness involved. So, the only statistic that sport and recreational aviation should be striving for is 'zero'; no fatal accidents and no crippling injuries.

Perhaps, but you will recall that the then existing Pilot Certificate holders were not required to have completed an HF course, or just an "examination" until August 2010. John

You will have to go to the full document at http://flysafe.raa.asn.au/safety/intro2.html to access the reports.

You may find the latest update of the document 'Recent RA-Aus fatal accident history' at http://flysafe.raa.asn.au/safety/intro2.html of interest, particularly the following extract. So, what are the reasons? RA-Aus introduced human factors (HF) training in 2008 and from August that year all student pilots were studying HF in their training and all existing Pilot Certificate holders were required to complete an HF course, or just an examination, by August 2010. In the 28 months since January 2011, 17 accidents have killed 23 persons. On top of that it was only extremely good fortune that the October 2011 controlled flight collision with an operating Ferris wheel at Old Bar did not add members of the public at large to the toll. HF training is not designed to worsen the safety record, so there must be something wrong in the RA-Aus HF training syllabus, or lacking in its implementation or in the quality assurance outcome, of both the association's HF training for student piots and the 2010 HF 'examination' of the, then existing, certificated pilots. In addition, there are concerns whether it is appropriate for the RA-Aus board to persist in its long standing opposition to the dissemination of information concerning the occurrence of a serious accident, and the later distribution of the RA-Aus accident investigation team's report. The current situation is that the occurrences are never mentioned in the website news section or the monthly journal 'Sport Pilot'; not even when the member concerned is well known to, and well respected by, the broad membership. The unpublished policy is that it is left to the membership to learn of the event via the public media's uninformed reports and the internet forums' sometimes grossly speculative reporting, and thus the membership learn nothing of real value from the accident, except, when necessary but very occasionally, an aircraft airworthiness directive might be issued as a result of the investigation. Certainly, this negative attitude is doing absolutely nothing to improve safety outcomes and the governance of the Association is neglectful of member safety — including those members who need to be protected from their own wilful actions. Paragraph B.7 in the statement of purpose section of the RA-Aus constitution is a reminder to all ordinary members and all board members. It states: "To set promote and maintain standards of safety for recreational aircraft by the specification and dissemination of information concerning standards of airworthiness for aircraft, standards of workshops and standards of knowledge for pilots and in particular, to specify, impose and enforce standards of skill and competence reactive to all stages of flying operations and to require any Member to meet such standards to the satisfaction of the Association before authorising such Member to engage in flight operations or any stage or aspect thereof and to grant, issue authorise, modify, cancel, suspend or revoke under the rules of the Association for the time being in force certificates and authorisations relating to aircraft, aerodromes, flying instructing and flying schools and to the skill and qualifications of pilots, instructors, navigators, drivers, mechanics and all persons managing, flying, driving, constructing, repairing or otherwise engaged in connection with recreational aircraft or recreational activities and to do all things relating thereto as may be deemed expedient and to make reports and recommendations to any clubs, authorities or persons concerning the same." I leave it to the reader's own experience to judge whether the requirements of paragraph B.7 are currently being fulfilled and, as B.7 contains the constitution's sole reference to 'safety' (and 'aircraft safety' at that), does the constitution as drafted really express any concern with theongoing safety of all the membership and their passengers? Why doesn't the constitution require dissemination to the membership of RA-Aus serious accident events, investigation progress and the very valuable RA-Aus investigator reports summarising the facts and the investigator'sconclusions? Accident investigator's reports were last published in the AUF website in 2004. The following are previously published examples of AUF investigators reports, without the photographs. Capella 3 November 2002 combination of factors. Chinook 31 May 2003 pilot lack of capability. RANS Coyote 5 July 2003 unauthorised low flying. Drifter 22 February 2003 'get-home-itis' – flight into IMC. Airborne Edge X 19 December 2002 combination of factors. Harrier 23 March 2002 wing divergence due to aileron flutter in dive. Bantam B22S 22 February 2005 EFATO turn back. Corby Starlet 4 October 2003 misjudged forced landing. Drifter 30 July 2003 mustering, no low-level training.

I have completed the annual review of the trend in RA-Aus fatal accidents. See http://flysafe.raa.asn.au/safety/intro2.html#fatal_accidents John Brandon

Just to inform you all that, in my opinion, it is downright stupid to carry any small child in any sport and recreational aircraft or other very light aircraft. See http://flysafe.raa.asn.au/emergencies/deceleration.html#restraint John Brandon

Well I doubt that mtow was exceeded so the aircraft was probably not overloaded. Also CASA made a ruling some time ago that defined the number of excess passengers (i.e. infants/children) that may be carried for various numbers of seats and for a two-place aircraft it is one, so I don't see that the pilot has broken any CASA ruling. Also CAO 95.55 limits the number of aircraft places to two, not the number of souls on board. I don't think the RA-Aus ops manual says anything about carrying only one passenger. So I can't see any RA-Aus rule being broken. If the police consider an inadequate restraint system was used then they might take civil action, but most officers would believe that the pilot has more than enough grief to cope with. So all in all, I don't believe any aviation laws were broken and the sky will not fall on RA-Aus. cheers John Brandon

That is quite misleading. VHF Flightwatch has never closed down. The dedicated FIS frequencies were removed from the November 2009 charts and those on-request FIS service responsibilities assumed by ATC units on the VHF area frequency or others. The callsign is the generic 'Flightwatch' usually preceded by the ATC unit callsign but the latter is not necessary, just 'Flightwatch' is sufficient if in difficulties See ERSA-GEN-FIS 3.2 Kaz (post 12) demonstrated that the revised system is seamless. ML CEN provided their on-request FIS service seemingly without Kaz recognising the flightwatch service was in operation. John Brandon

Turbo and others. I think you may be missing my point in my plea for restraint (not cessation). The election is over and the NSW by-election will be decided next week, after a long lead-up debate in these forums. I believe that debate was very helpful to the candidates and to the electorate (though it did not induce the voting numbers hoped for), so the forum discussions have served a very useful purpose. I am quite sure that the members-elect are quite familiar with those discussions and we should not now presume to tell our new representatives what to do, or question them about how they intend to go about the rather daunting task that lies before them. They will learn about the previously undisclosed problems that beset the board, learn their task, learn to work cooperatively with the older, long time members so that knowledge is passed along, while seeking to reshape the old principles that have hamstrung the board and annoyed the ordinary membership for so long. I am sure there will be progress reports posted in the forums along the way. And, of course, the board executive members must be decided by the board members at the next meeting, not at these forums. Let all the board members get on with their task, without unnecessary distractions and let us try to help where we can. I wish the members-elect, the forthcoming new members from the by-elections, and the existing board members every success in a very daunting, time-consuming task. It will not be easy to re-focus the board and what we don't need is another non-cohesive board. Ssomething was said about the "high death rate of members" in one reply. The attrition I was referring to is the high rate of non-renewals by relatively new members and probably the younger ones at that, much of which may be caused by the realisation that their dream of owning and operating an aeroplane was unrealistic. Unfortunately we are no longer an ultralight association. John Brandon

There has been much recent recreationalflying.com forum activity (from perhaps less than 0.5% of RA-Aus membership) that, if continued, will be detrimental to the RA-Aus board members in executing their prime task and may, in fact, make their task increasingly difficult to accomplish; and thus detrimental to all RA-Aus members. BOARD STATUS Currently the RA-Aus board has only 11 members, four of whom will retire at the September AGM and the four members-elect will take their place. The NSW by-election on September 9 will add another new board member and the following NT by-election will most likely add another new member, returning the board to the normal 13-member status. However the level of experience contained within the new board will be far short of normal. Consider this: By October the board will consist of six first-time members; two members (John and Steve) with less than five years under their belts; two members (Nick and Miles) with five or six years and the three long-termers (Paul, Rod and Eugene) with a wealth of experience between them. Paul, of course, had been Operations Manager and CEO for a long period before his election to the board. Rod has also had a spell as Operations Manager in the early '90s and also as board president and I seem to recall he was in the National Flying Coach role before Tony Witlox. Eugene is the longest serving board member and, at around 8 years, also the longest serving President. I think Eugene opened the first legal AUF flying school about 1986 at Sandfly, so he is probably one of the most experienced members of the association. On top of that, I believe there is a possibility that one of those long-term board members might stand down to take on another role, necessitating a third by-election this year. In that event the new, inexperienced members will be in the majority. I guess, it will take at least 12-18 months before the six or seven new members have absorbed sufficient knowledge about RA-Aus board activities, their relationships with the association's employees, CASA's requirements for governance and performance standards, relationships with other sport and recreational aviation organisation's, the threats facing RA-Aus, etc, etc, to settle into the task. This is in addition to the normal knowledge every director of every association must absorb about ethics, board operations, confidentiality, fiduciary duties, responsibilities to association membership and so on. All of this means that the board will have severe resource and experience difficulties just at the time that the CASA's Self Administrating Organisations Section is requiring, and expecting, demonstrated progress in the current RA-Aus Deed of Agreement schedule, in order to maintain their confidence in RA-Aus governance and performance standards. WHAT'S THE BOARD MEMBERS' TASK? Basically, it is to ensure that (1) the association continues to exist and (2) that current and future ordinary members are able to satisfy these prime needs: 1. To learn to fly at a reasonably convenient location and at reasonable cost to qualify for a sport and recreational aviation Pilot Certificate, rather than the more costly Pilot Licence or perhaps the proposed Recreational Pilot Licence, both of which must be gained at a flight school having a CASA Air Operator Certificate. 2. To have a reasonable range of choice in the procurement of relatively low-cost, new/used, day VFR, very light aircraft or aircraft kits; or the ability to scratch-build their own, or other's, experimental design without the need for a Certificate of Airworthiness before registration. 3. To register such aircraft with an authority that allows owner maintenance. STAFF-ASSOCIATED PRESSURES ON THE BOARD MEMBERS The recent resignations of Lee Ungermann, Mick Poole and Julie Roll has reduced the number of senior experienced staff by 60%. Recent losses of experienced secondary level staff (e.g. Lani) adds more pressure to the organisation. The loss of knowledge of even small things (that people not involved would regard as superfluous) is time consuming and very annoying to the remaining staff. Also the present CEO did not apply for his position, he was requested to assume the responsibility. He has no reason for loyalty to the association in difficult times, particularly so when querulous remarks about excessive salary were bandied about in these forums. It would be no surprise if Steve got fed up and opted to return to his semi-retired lifestyle. History indicates that suitable CEOs are difficult to attract to RA-Aus. The knowledge that all the recent resignees went to much better paid positions and a better working environment (and that RA-Aus has not had the financial wherewithal to retain staff or establish a functioning successor development plan) places a lot of pressure on the board, and eventually the ordinary members. FUTURE MEMBERSHIP LEVELS During 2005, 2006 and 2007 the ordinary membership increased by an average of 830 persons (13% p.a.) each year. During 2008 the increase was 8% (640 persons) and 2009 was 9.5% (798 persons). During 2010 the increase dropped to 460 persons (5%) so the annual rate of membership increase peaked in 2006 at 16% and has been dropping since then. The intake of new members appears to have been reasonably consistent during the last five years, around 1100-1300 per year but, during the same period, the number of ordinary members not renewing membership has been increasing, reaching about 640 (or 7% member turnover) in 2010. A high and increasing member turnover perhaps coupled with poor first year retention, is not a good sign. And remember that, under CASR Part 103, CASA is required to implement the 'parallel path principle' for those who choose not to join RA-Aus or any other RAAO. The Recreational Pilot Licence (which will probably have a medical requirement standard8 equivalent to that required for issue of a commercial vehicle driver licence) could also be available when CASR Parts 103 and 149 are promulgated; so there are future possibilities for considerable change in the structure of sport and recreational aviation. The total membership figure may start to decrease soon, which will be a problem for both the organisation's financing and the flight training facilities. (* If you are interested I have placed a copy of the GP's guide to 'Assessing fitness to drive' for private and commercial vehicle drivers at http://www.recreationalflying.com/tutorials/students/AFTDrive.pdf ) CASA PRESSURES ON THE BOARD MEMBERS In March 2011 the Director of Aviation Safety [John McCormick] announced that CASA had set up a new Self-Administering Sport Aviation Organisations section in the Office of the Director of Aviation Safety and that CASA's recreational and sport aviation regulatory functions have been moved from the Standards Division to the Office of the Director of Aviation Safety, reporting to the Associate Director of Aviation Safety. The recent recruiting drive by CASA for staff for the Self-Administering Sport Aviation Organisations section shows that the top level of CASA believes in and supports sport and recreational aviation but is determined to assure their confidence in the board's governance and the performance standards of RA-Aus (and the other RAAOs of course), in accordance with the current RA-Aus/CASA Deed of Agreement. [There is a pdf copy of the 'Sport Aviation Self-administration Handbook' in the tutorials section http://www.recreationalflying.com/tutorials/regulations/CASA-sport_aviation_selfadmin_hdbk.pdf ] Lee Ungerman left RA-Aus to join the Self-Administrating Sport Aviation Organisations section (probably as a team leader) and, from CASA's point of view, there is no doubt that he is a very good choice as point man in establishing the confidence, or otherwise, of the CASA management, in the governance and performance standards of RA-Aus. The following is an 18 August 2011 advertisement for Sport Aviation Safety Assurance Officers initiated by Lee Ungermann (note the salary range for an officer reporting to Lee): Sport Aviation Safety Assurance Officer Permanent role Brisbane or Canberra location $86,783 - $112,456 + 15% superannuation Office of the Director of Aviation Safety Duties: The Sport Aviation Safety Assurance Officer will assist the Team Leader Self Administrating Organisations Section in overseeing the Recreational Aviation Administration Organisations by conducting audits of safety assurance systems to ensure that risk is contained to an acceptable level and thus providing a safe environment for participants as well as other airspace users and the general public. The Sport Aviation Safety Assurance Officer is also responsible for developing policy, implementing strategies and managing the Deed of Agreement structure in accordance with government requirements for the oversight of the Recreational Aviation Administration Organisations. Experience/qualifications: To be successful in this role, you will have excellent working knowledge of Australian legislation in relation to sport aviation as well as a solid understanding and experience in risk management principals For further information about this role, please contact Lee Ungermann on 131 757. Do not kid yourself that RA-Aus is fireproof. The recent action against Tiger Airlines demonstrates that CASA is now quite prepared to suspend any organisation in which it loses confidence, no matter what the travelling public or the politicians might think. If CASA suspended RA-Aus because it had no confidence in the board's governance and the performance standards, then ALL RA-Aus registered aircraft would have to remain on the ground during the period of suspension or face severe penalty. The suspension period should not be thought of as just a punishment period, it would continue until the Office of the Director of Aviation Safety is reassured that RA-Aus does meet the performance standards and schedule specified as part of the Deed of Agreement. Would YOU, as an RA-Aus ordinary member, be happy with that? I guess not; so instead of trying to tell the board members how to do the task (often anonymously and without quoting your RA-Aus membership number) and demanding answers forthwith, would you please ask yourself: "How can I assist my association in ensuring that the Office of the Director of Aviation Safety's confidence in us is greatly improved?" To paraphrase JFK; "And so, my fellow members: ask not what your board can do for you - ask what you can do for your board". John Brandon

People mention the HORSCOTS 1987 report quite a lot, but I fancy very few have ever read the committee's final report following their enquiry into sports aviation safety, probably because it is so hard to locate. It makes good reading these days. I have placed a 9 MB pdf copy at http://www.recreationalflying.com/tutorials/students/horscots_1987_PP3A.pdf cheers John Brandon

I quite agree. I would like to point out that when CASR Part 103 finally reaches fruition, the part of the aviation scene, administerd by RA-Aus, HGFA, GFA, ABF and ASRA, will officially be known as 'Sport and recreational aviation'. The title encompasses flying for pleasure, diversion, adventure, technical flying, experimental or personal education/development and competitive sport. You will note that SAAA is not included, SAAA is not an RAAAO. HGFA, GFA, ABF and (I think) ASRA are very much into competitive sport on a regional, national and international (FAI) basis, but RA-Aus is not. You may recall that in the earlier years the AUF had an honorary position of National Flying Coach (on the same level as the current operations manager and technical manager positions). Tony Witlox held the position from the early '90s until about 1997, I think Tony took over from Steve Burgess. The NFCs aspirationwas the promotion of competitive sporting activities within the AUF, with the hope of bringing the association up to a status similar to our sister associations. Unfortunately the project was not successful and the NFC job was abandoned in 1997. Consequently the AUF/RAA has never really had a well developed competitive sporting spirit, more the pity because it does promote better flying abilities. The CAGIT trophy is an example; 20 years in existence and only about 50 claims and quite a few are multiple claims from one person. I believe the title 'Sport Pilot' is appropriate even if it just reminds members that there is plenty of room for development of competition within the association. cheers to all John Brandon

The FAA Rec. Flying Certificate allows day VFR flight in an aircraft under 5700 kg but limited to 4 seats (but only one passenger), fixed gear and one engine up to 180 hp. Thirty hours minimum for the basic certificate (vs 40 for the Private Pilot) then endorsements/ratings for cross-country beyond 50 nm, entry into controlled airspace, aerobatics etc. Class 3 medical required. There aren't many active certificates; perhaps no more than 5oo; a PPL would be more logical and cost effective. cheers John

I don't think that is true. When the FAA brought out the Recreational Pilot Certificate, about 1990, it was most unsuccessful. I seem to remember that only a few hundred pilots were certificated in the first three years or so and in 2005 or 2006 it was largely replaced by the Sport Pilot Certificate concept. With that history in the US I can't see why CASA would bother to repeat much the same exercise. (For those who are not aware of it, the FAA does not have pilot licences ( nor even licenses) only certificates.) cheers John Brandon

Thanks rgmwa and others. A printed format has often been suggested in the past but, as an octogenarian, it is not something with which I would choose to burden myself. Also the tutorials lack diagrams and other images that would certainly be necessary in print. The tutorials contain nearly 500 000 words of text plus the existing illustrations so it would cover two average manuals. The tutorials are designed as web-based material (with thousands of 'in-text' hyperlinks that provide its utility. cheers John Brandon

I have made some substantial additions to a few of the tutorial modules; The general theme of the changes follows the design manoeuvring flight envelope, the gust envelope, flight load limits, turbulence and vertical gusts, excessive speed, the speed to fly in turbulence and the V-speeds in general. I believe all this safety oriented material is well worth reading. The modules concerned are: 'Airspeeds and the properties of air' http://www.recreationalflying.com/tutorials/groundschool/umodule2.html; 114 kbytes; chiefly sections 2.9 and 2.10. 'Microscale meteorology and atmospheric hazards' http://www.recreationalflying.com/tutorials/groundschool/umodule21.html; 70 kbytes; additions in most sections. 'Wind shear and turbulence' http://www.recreationalflying.com/tutorials/safety/wind_shear.html; 61 kbytes; additions in all sections but particularly 6.4. 'Don't fly real fast!' http://www.recreationalflying.com/tutorials/safety/excess_speed2.html; 46 kbytes; additions in all sections, particularly 1.1. 'Safety: flight at excessive speed' http://www.recreationalflying.com/tutorials/groundschool/flutter.html; 43 kbytes; smaller additions in all sections. This module shares some material with the preceding module. cheers John Brandon

It's fixed now, I hope. John

I have updated and expanded the document "Overview of the legislative framework enabling recreational aviation" and added much onsite material accessible via intext links. http://www.recreationalflying.com/tutorials/regulations/regulations.html The document now contains the following sections and sub-sections: 1. The Civil Aviation Act Regulations and RAAOs The aviation Acts The CARs and CAOs CASR structure CAAPs and ACs Recreational aviation administration organisations RAAO involvement in the legislation review program 2. Aircraft Type Certification and Certificates of Airworthiness The Type Certificate Type Acceptance Certificate for imported aircraft Production Certificate Certificate of Airworthiness Certificates of Approval (of company operations) RAAO acceptance CASA approval of recreational aircraft engines 3. Exemption aircraft 4. The exemption Orders specific to 'aeroplanes' — CAOs 95.10, 95.32 and 95.55 Operating airspace allowed, pilot qualifications and equipment required Aeroplane take-off weight limits Civil Aviation Order 95.10 Civil Aviation Order 95.32 Civil Aviation Order 95.55 5. The exempted Regulations Exemptions common to 95.10, 95.32 and 95.55 Exemptions common to 95.10 and 95.32 only Exemptions common to 95.32 and 95.55 only Exemptions applying to only one CAO 6. The design and airworthiness certification Orders for powered recreational aeroplanes Civil Aviation Order 101.28 Civil Aviation Order 101.55 7. The proposed CASR Part 103 8. The civil legislation governing RAAOs Also the "Australian airspace regulations' document at http://www.recreationalflying.com/tutorials/navigation/airspace.html has been updated and expanded. cheers John Brandon PS: suggestions for changes in the above or further expansion would be helpful before I commence the next major project to cover 'Learning to fly' in the sectors of Australian recreational and sport aviation administered by our RAAOs. PPS: Dave, would you mind running your editor's eye over the two html files mentioned above?

I can recall substantial work being done on the constitution document by a member with a legal background (Max Brown?) to bring the wording up to the regulatory standards expected. The result was maybe issue 9 of the constitution which I think was the first time the constitution was published on the website. My recall of time is what you would expect from an octogenarian, but maybe it was five or six years ago. Suggest Ian might ask Julie about the history. cheers John

Those who are interested in trends in enforcement by RAAOs and strict liability might read this proposed ASRA by-law: ASRA Enforcement Scheme 2011 ASRA (By-Law 2010-01) http://www.asra.org.au/documents/2010-01_ASRA_ByLaw.pdf cheers John

Yes that would be correct. The draft Part 103 attached to the NPRM should contain all the rules for height and distance and collision avoidance (which one could presume to be fundamental) but as the NPRM was issued December 2006 there may be differences from the current Part 91 proposal, hence the need for comparison. cheers and happy reading. John

The last few paragraphs of the document at http://www.recreationalflying.com/tutorials/regulations/benchmarks.html provide some information on the current status of the changes to the three RA-Aus exemption CAOs. These changes are required by RA-Aus so that we get early implementation of a few items that will appear in CASR Part 103. Those few CAO changes would not be necessary if Part 103 was just around the corner: Regulatory environment CASA's Project OS 08/13 'Early implementation of certain proposed CASR Part 103 standards via CAO' has still not come to fruition but is expected in 2011*, hopefully providing revised exemption CAOs incorporating the following changes: • MTOW for CAO 95.55 aircraft to be the lower of the aircraft's design MTOW or 600 kg. • Flight over water to come in line with GA requirements (not for powered 'chutes) • Flight above 5000 feet approved in line with GA; i.e. flight above 10 000 feet only if pilot and passenger supplied with oxygen from an approved system • Entry to active restricted areas (dependent on conditional status). * The revised hang-gliding CAO 95.8 was issued 30 March 2011. ( CASR Part 103 and Part 149 seem to have disappeared from view; however, in March 2011 the Director of Aviation Safety [CASA's chief] announced that CASA's recreational and sport aviation regulatory functions have been moved from the Standards Division to the Office of the Director of Aviation Safety, reporting to the Associate Director of Aviation Safety. Hopefully this will result in more decision making being directed toward the long overdue promulgation of CASR Part 103 'Sport and Recreational Aviation Operations' and Part 149 'Sport and Recreational Aviation Administration Organisations'. The long history of the proposed Part 103 and Part 149 legislation perhaps reveals a reason for the Director to now assume close oversight. The first notices of proposed rule making [NPRM] relating to Parts 103 and 149 were published 13 years ago (about two years after initial industry discussions) as NPRM 9808RP and NPRM 9805RP. These were subsequently followed, in 2000, by a set of rules drafted by the Attorney General's Department as another NPRM, which was promptly withdrawn by the then Director of CASA. Six years later, in December 2006, CASA published NPRM 0603OS, the current proposal relating to Part 103 followed, in July 2007, by NPRM 0704OS, the third proposal relating to Part 149.) If you read the 4th paragraph in the foreword plus section 3.1.3 of NPRM 0603os http://www.recreationalflying.com/tutorials/regulations/nprm0603os.pdf you will see that only the fundamental operating rules from CASR Part 91 will be enclosed within Part 103. Other rules of that type appropriate to each individual administration organisation will be included in those organisations' procedures/operating manuals. So it's only the fundamental rules you need to be concerned with in the current Part 91 nprm. The question is which are the 'fundamental' flight rules? The following section of the regulatory framework page has a bit more information on the CAOs. http://www.recreationalflying.com/tutorials/regulations/regulations.html#exemption cheers John

The history page http://www.recreationalflying.com/tutorials/regulations/benchmarks.html has been updated; you may find the 2010 RA-Aus member turnover statistics of interest. Also I have revised the regulatory page http://www.recreationalflying.com/tutorials/regulations/regulations.html . The corresponding pages on the RA-Aus website will not be updated and presumably will soon be removed from that site. cheers John Brandon