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Proposed L2 changes


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Hi all, I received a letter today informing of the proposed changes and new regulation that is going to come into effect. It appears that regulation is way out ahead of any real statistics on this one, my scanner is playing up so will take a pic and post up the letter for those interested.

 

 

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What I see is a classic case of a bureau doing what any unchecked bureau does.

 

The rot started when CASA made it clear, by it's actions, that each Operations Manager would be offered a cushy position upon their resignation from RAAus.

 

Staff also flowed the other way. RAAus got too close to CASA. Then representation stopped. RAAus became a pure administrator. New so called "privileges" were cancelled and progress in that way has long since stopped.

 

Now we have entered the next stage. With CASA in the background cheering, RAAus has gone on a recruiting frenzy. New employed "experts" are thrust before us to sprout gobbledygook to make us feel bad about ourselves. Relax, it really is just gobbledygook and it doesn't make us safer.

 

Now the noose is tightening. Our maintenance system has been a fabulous success over the years. There is no problem. Now, despite this, it is time to create a maze of rules and to strip new pilots of their L1 authority. Now L2 is under attack. Oh dear, if an L2 happens not to work on any aircraft for a couple of years, they seem to be suggesting that said L2 might forget how to use a spanner or read a technical publication.

 

Read carefully folks. For the first time ever, there is a reference to the auditing of "maintenance facilities". "What? You're gunna audit my toolbox?"

 

Each of us will make our decisions.

 

 

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Nong, your right on top of it mate, I read that line as well and have seen it for what it is! regulation will kill our hobby and if you take the time to read between the lines and understand the suttle movements of all the chess pieces it has been coming for a while and is a premeditated attempt to destroy RAA. Last word from CASA = 'Check mate'

 

 

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seams all this has come about due to the large number of engine failures bought on by poor owner maintenance! apparently.. (where have i heard that before?)

Rob it seems to me that the only statistics that we should be concerned with are the number of engine failures reported and no examination of cause! I mean if the too many engine failure line is going to be used where are the hard facts, the investigation findings stating that it was maintenance caused etc. the only maintenance engine failures I can recall were all homebuilt. Changing the maintenance system when its more robust than the CASA 51% rule is a farce!

 

 

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Got my letter in the mail yesterday, however I tend to agree with the direction. From comments above it seems that people may not be aware that CASA apply a much higher 'recency' requirement on LAME's than 4 checks in 2 years. We need to demonstrate 6 months full time equivalent in two years in order to be eligible to keep signing out work so the new RAAus standard is a significant concession in comparison. The new system will also help protect against people who think an unlimited L2 (which in the past has been handed out with relative ease) means that you can do anything regardless of your actual experience on particular systems. As a LAME I was able to get an unlimited L2/L4 a number of years ago, however I have rightly 'self regulated' the jobs that I accept based on my experience. This means I have not accepted work/inspections of unfamiliar systems/structures such as wood construction as my experience does not cover this type of material.

 

The proposed changes will simply protect us all against L2's who may currently be making unwise choices and working beyond their experience levels and therefore risking the lives of people. On that basis, I support the change.

 

 

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Mriya,

 

comparing LAME work to RAA is a bit of a stretch in some respects, due mainly to the different level of regulation. Most RAA aircraft do not comply with airworthiness standards hence the mandatory placarding requiring owner and passenger to fly in it at their own risk, this is a trade off that many make to be able to afford and own a flying machine.

 

Statistically speaking there are none! and to fix a system there needs to be statistical evidence that its broken first, I dont think it is!

 

There is an adequite system for regulating L2 approvals now and it happens all the time, for example L2 restricted to airframes, L2 restricted to rotax engines and line maintenance etc.

 

Basically the motor mechanic that wants to get an authorisation submits his application with work history, trade certs etc.

 

He then has two recomendations from other L2's or LAME's, the technical department at RAA forms a board to review the application, if the applicant meets what they determin to be a low level of risk they will approve the applicant but because of limited aviation experience will require that they are supervised for a set period and are only allowed to conduct line maintenance or some other limitation.

 

After the period imposed the applicant submitts his record of experience attained over the two year period and the technical department either imposes further probation, a category of approval limitation or some other restriction.

 

I, like you supplied my licence details and received an unrestricted licence and like you I pick and choose the work I do and who I do it for.

 

Your argument points to evidenced L2 maintenance or legislation violation/failures but I dont see the reports or investigations into violations coming out of the RAA office or CASA's.

 

Those that partake in RAA flying do so with an understanding of the risk and the lower regulation, Casa traded these risks off with at first no flights higher than 300 feet and no road crossings and an MTOW under 540kg, then the height was extended to NA 5000ft and so on as the statistics proved that it was no more prone to accidents than GA.

 

Our roots come from a dream to build and fly affordable and experimental aircraft with factored risk and mittigated safety, so what happened and where are we now?

 

We are about to become over regulated based on a fear campaign that has no evidentary fact.

 

I say show us the statistics of dodgy L2's, the investigation findings and their L2 removal or punishment! maybe if our technical manager put as much energy into defect investigation the uninvestigated 'engine failures because of operator error' may prove to be a faulty product I was told by the CASA head of defect investigation that they arent funded to investigate defects under RAA!

 

One thing that text does not portray well is tone, this text is not designed to be nasty or condescending so please dont take it that way.

 

 

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Before I start let me make clear that I am not a L2,3 or 4, however have 12 years trade experience on F111's and P3C aircraft working Radio/Radar equipment. I own a 19 registered aircraft and happily carry out maintenance on that aircraft where I know that I have experience and skills sufficient for the task.

 

However when it comes to covering the remaining areas it is, like everything in aviation, very much Caveat Emptor and in a technical area being "informed" enough to make a decision on who you want to do your work is not a simple matter. I would like to think that someone who is prepared to do a complete tear down and rebuild of a jabiru engine knew exactly what he was doing but its my view that the number of L? maintainers who can actually do that are much smaller in quantity than those who will happily take on the task of doing so.

 

The argument that RAAus is not equivalent to GA in both assurance/quality and oversight is true and my wallet thanks those in charge, however I don't want the standards so relaxed that every member needing maintenance has to have enough maintenance experience and technical training to allow them to make a truly informed decision on who they will use to have their work done. Its a balance and personally I don't see that this approach is unreasonable.

 

As an argument for this approach, look for the posts that Storchy Neil made about his experience with post crash rectification of his Aircraft. Storchy as a writer makes a great gardener, but if you can get past the poor construct of his messages you will see that he claims that a maintainer repaired his aircraft in ways that would be unacceptable to repair your kids bike let alone an aircraft. I heard from a maintainer that I trust, that he had reviewed the "finished" product and was of the view that it was very much "finished" but not in the way that was intended, unless garden ornament was the intended future use! It sucks that Storchy had that happen to him and anything that prevents someone who doesn't have the experience and skills from being provided substandard work is IMHO a reasonable position, especially where the likelihood of the repairs killing the owner are very real!

 

Andy

 

 

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ha ha ha I am laughing told you so you recond that is the end no way you blokes can cop it now so suck it up darlings

 

you blind persons read your own rules and regs the court case that I lost trough your tec manager not getting involved in the repair of the aircraft that I did own

 

the handing out of the l2 l3 was a farce

 

now in your defence read what a magestraite said in my case you don't have to repair a plane to airworthy just repair it neil

 

 

 

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I know what your saying andy, those stories are everywhere including in GA, its not the regulations that have let this man down, its that the regul;ators didnt act. There is enough regulation for safe operation of RAA aircraft, its only when people step outside the regs that bad things happen. The example that you quoted is a fine case for litigation, I as an L2 and LAME have professional indemnity insurance and so should this 'repairer', storchy should have persued his rights first with the comission and then with RAA and CASA. I assumed that he paid for the work? if so why?

 

I am one of the stupid ones that will touch the jabiru engine, and I mean stupid in the sence that its a product that has the potential to bite you even when its put together right and there is nothing overly complicated apart from the factory's many tested and refined loop holes of convenience whenever you have a component failure. Much to the disgust of my peers (LAMEs) that say you must have rocks in your head, you could lose everything on those timebombs, I document everything and record the critical steps on film.

 

The maintenance caused engine failures that have supposedly spurred this course of action, have as I understand it come from multiple jabiru failures, these are always explained away by the factory as operator or maintainer error, without investigation just acceptance of the word from a factory with a history of deceipt.

 

Shouldnt RAA be investigating the cause otherwise its an erronious statistic that counts for nothing. If not for defect clarity then purely to protect their members from any identified causal factors? do they have the stats that show this info?

 

Heres what to expect if they make mandatory the suggested practises in the tech manual, recent comparison of 100 hrly GA to RAA, Piper pa38a $3500 Jabiru J230 $550. The costs of maintaining a facility to the letter of an audit will be passed on, and IAW the big game of chess thats slowly playing out in front of us the goal posts will be moved until its so close to GA that the statement will be made well its only a small change now lets just go GA.

 

This is not what we are about, its not where we have come from and we all should speak up and ask why the change? On what statistics.

 

Point of note: Anyone seeking rectification or servicing work should first research the person they are about to engage, if you need an overhaul send it to the best person you can find etc. if you except the least experienced and cheapest person then the product will reflect. and lsatly, ask them to provide a copy of their insurance just in case they damage your equipment.

 

 

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ha ha ha I am laughing told you so you recond that is the end no way you blokes can cop it now so suck it up darlingsyou blind persons read your own rules and regs the court case that I lost trough your tec manager not getting involved in the repair of the aircraft that I did own

 

the handing out of the l2 l3 was a farce

 

now in your defence read what a magestraite said in my case you don't have to repair a plane to airworthy just repair it neil

Storchy, can you send me a link? who did the destruction?

 

 

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Deadstick has a point: CASA should provide evidence that there is a need for more regulation of repairer and maintainers.

 

If they don't even investigate fatal accidents, how are they going to gather that evidence?

 

Storchy Neil's bad experience may not be the only case of dodgy repairs, but how would CASA or RAA know without some form of research?

 

Has our sector escaped the Federal Government's drive to cut regulation and abolish mobs of agency and authorities?

 

 

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Actually in retrospect introducing the jabiru engine as an example was foolish in extreme. In my situation as a 19 registered aircraft I can choose to deviate from Jabiru's repair manual and choose to use non jabiru sourced parts. Others, particularly 24 registered, have no such leeway. So please forget about that example.

 

FWIW, I don't use Jabiru sourced valve guides, I use Jabiru sourced cylinders, but only after they have been rehoned back to jabiru standards, the ones sourced for me last year were not supplied to the drawing standard. If Ian Bents inhibiting system works as intended then that will be fitted to my 3300 and failing that if I need cylinders again (and that is likely if I go for more than 3 weeks without flying) I will have them Eurosil coated to try and get past the crap corrosion issue we currently have.

 

Deadstick, your point that regulations can either be enforced as they are, or strengthened but remain unpoliced and therefore continue to fail is an interesting one. As we are today the workforce size and costs we as members (or as the board) are prepared to invest in our technical area is challenging, but I would suggest that it not be considered one or the other, policing or tightening regulation, but best practise might well be both.....In the context of regulator policing of existing regulations that presumably occurs after an incident has occurred and therefore a member has already been put at risk, where as the approach of checking that sufficient experience has been applied to maintain the L? rating would seem to be proactive in advance of a member being put at risk, rather than reactive?

 

Or have I still missed the point?

 

Andy

 

 

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Sorry andy, I used the jabiru example as it was quoted to me as the cause of the "maintainer induced engine failure reasoning" by a board member, and I respect your point, but I dont think the system needs changing for the sake of changing. Every further requirment lumped upon us without justification is just another move towards inadequite oversight and beurecratic red tape. I mean RAA apear to not be doing what is already legislated, all that well! if its better training and currency requirments that are needed then so be it, but how much is too much and wheres the stats. I find it hard to beleive that a person that only performs one 100 hourly a year will dramatically forget skill of hand or industry practice! FFS I only have to do a BFR once every two years and how many operations verse maintenance accidents are there? CASA has developed the RPL licence for a reason and its just one move in their big game of chess, here comes the next one and before you know it RAA does not exist...

 

 

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Also be very carefull on your view that you can choose to deviate from the engine manufacturers best practice, there has been a case of a LAME in australia loosing everything he has worked for because of a non mandatory AD, story goes he performed the annual and checked all AD's in australia, the particular AD showed up but was not mandatory here, however it was mandatory overseas in a CASA recognised AA, subsequently the AD caused the aircraft to crash and the legal team ruled the LAME negligent. This will happen if you are ever held to account for persons or property damage resulting from yourdeviation from the factories advice even though its not illegal under aviation legislation.

 

 

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Does the 2-year currency apply to those who have genuine training and recognised qualifications? If you are unable to work on a particular type within the 2 years do you have to re-take your Cert IV or AME qualifications? What happens if you no longer have a qualified L2 anywhere close due only to lack or currency, not knowledge or capability. Seems like although it may be a good thing on paper, it may end up in a huge shortage of 'current' L2's available.

 

Once out of currency how would they get it back again?

 

 

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the written contract for the repaires was with ME and [removed] the repairer LAME plus l2 l3

 

vero insurance was the insurer I refused to sighn the release form so as they VERO could pay [removed] that was feb 2008 I HAVE NEVER SIGHNED THE RELEASE FORM

 

I was abused by [removed] about not sighning release form but vero paid [removed] without my knowledge

 

casa wrote back to my solicitor and said civil mater take it to raa donkin wrote back to my solicitor civil mater

 

in court it was stated that the repairer did not have any repair manuals at all neil

 

ps their is only one tec bloke that was looking at our problem I was willing to pay for his in put to assessing the problem with my plane and he was sacked

 

how would you explain my plane that I did own as a garden ornament bit embarasing for aviation I would say neil

 

Neil,

 

On advice from a qualified legal professional, names have been removed and will continue to be so. - Mod

 

 

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flysynthesis storch s 912 s 80 hp

 

I was landing into a paddock and failed to see power wires

 

power wires tore off nose wheel I then flew 5 nm and landed on a strip

 

with no nose wheel I landed use power as I no that I could land at 40 knts very safely by leaning back in the seat I kept the nose up in the air

 

when I reached for magy switch it went on to the nose tail was near vertical right hand wing slammed in to the ground broke the prop broke the windscreen broke off fin under tail through keeping nose so high

 

parts ordered were new prop new right hand wing tip new wind screen new fuel gasculator new nose wheel and olio new fin on tail new door

 

now the l2 l3 could not get the eltric flaps indercator to work nor could he get the egt to work and told me to fly the plane to melb

 

[removed] sighned out aircraft

 

found by another l2 l3 after repaires done

 

rigging out 20 25 degrees

 

leading edge off right hand wing cracked

 

windscreen not installed properly

 

mod to gasculator not legal

 

bent undercarriage

 

bent legs

 

loose engine bolts not torqued to engine frame

 

bent engine frame from prop strike

 

no weight and balance done

 

bent rudder peddles

 

return fuel line not on air craft as should be on all 912 engines

 

new right hand wing tip was not put on plane as l2 l3 could make it fit neil

 

 

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