MARAP

[jetjr]

Im seeing a gulf between head office and the membership

 

SUPPPOSED to be sorted by the elected board members

 

 

[Keith Page]

Good oh! Oscar

 

I am not sure ---- however there are some home builts out there which are of far superior build and more geometrically correct than the factory built aircraft. They are supposed to be bullet proof that is one end of the scale and at the other end of the scale they are just horrible.

 

So all 19's can not be put in the same pond.

 

Just because it came from a factory it is great and just because it was built at home it is rubbish ---- I am not going along with that line of thinking.

 

Regards

 

KP.

 

 

[Oscar]

Keith: I was by no means trying to suggest that all 19-reg aircraft are 'rubbish', nor all factory-built 'far superior'. I'm doing extensive work on a very early factory-built ( the first VH-reg'd Jab, in fact, later changed to 55-reg) that has work on it which I am very, very sure many kit-built Jabs. of the same era would have had done better. Pressure of production costs is a great leveller of quality - and as Nev has expressed above, a competent and conscientious builder will almost always find things that can be improved, for various reasons.

 

However - despite finding things that I have been at the least, surprised at (and making many detail and a few rather more serious changes, ( always in consultation with both of the then CAR-35 engineers who worked extensively with Jabiru in the early days, and who not only know these aircraft in intense detail but also have the data on just about every aspect, aerodynamic and structural, in their files!) in terms of apparent 'quality' - one fact is inescapably true: that little Jab. took everything that flying school work could throw at it for nearly 3,000 hours of service and didn't let anybody down. What I conclude from that, is this: the factory knew which stuff was 'good enough' for purpose even if it was nothing like 'perfect', and it did not take any shortcuts for the important stuff. I have no doubt that many Jab. kit builders were every bit as conscientious - but how can a buyer be assured of that?

 

The important point, I think, is that an aircraft built in an approved facility to a quality compliance standard provides an explicit 'guarantee' of meeting a defined level of 'good enough'. Further, there is a mechanism by which problems that arise later, are addressed. Is that always perfect? - obviously, NO - but at least there is a system in place for quality control and the rectification of problems. If - for example - a batch of bolts is found to be below-spec. - the manufacturer can identify the aircraft affected and issue a SB. If a particular bracket or fitting is found to be less than adequate - the manufacturer develops / accepts a modification and makes it available to the owners etc.

 

For an amateur-build aircraft, there just isn't the same depth of explicit QC for building and back-up in service. The buyer of a 19-reg aircraft simply has to take on faith ( and inspection and judgement) that everything has been done and maintained correctly. How many buyers of 19-reg aircraft would, for instance, seek the release note for critical components? How many owners (or even builders) would be able to supply them?

 

The late George Markey used to say, in his typically cynical fashion, that 'people really only buy the paint job.' Now George could reduce a plaster Saint to homicidal frustration over a cup of coffee - but there is more than a skerrick of truth in that statement. Generally bodgie work will be immediately evident - but how do you know, as the buyer of a 19-reg aircraft, that there isn't just one critical component that is the 'weak link' in the chain of stuff that ALL has to work properly, that you can't see? For instance, there is a market in re-plated AN bolts that are NOT to spec. - George himself had hundreds of the buggers in his quarantine store, that were fine for bolting on things like battery boxes but absolutely NOT fine for use for a close-tolerance, highly-stressed component such as an engine mount or undercarriage leg. You have to be extremely familiar with the subtle difference in colour to know they are re-plated; LAMEs should be able to see that immediately, not all L2's will, amateurs almost certainly will not. That's but one example...

 

Therefore, I suggest, applying the MARAP procedures to 19-reg aircraft, while commendable in theory, does in no way guarantee that the entire aircraft is 'good enough' for service. I know that Darren Barnefield has been consulting with experts in the industry to develop a 'schedule' of critical areas for extra attention for both the building and the maintenance of amateur-built aircraft and from that work I believe a sensible arrangement for at least improving the likelihood that these critical areas will be done correctly will emerge. That, I believe, is an important step forward for recreational aircraft.

 

Rather than damn the entire idea, I think it would be a far wiser move to seek 'fine-tuning' of it. 19-reg would seem to me to be an obvious area where some latitude should be introduced.

 

 

[robinsm]

Oscar, that is why the aircraft are registered as a 19... aircraft. They are owner built assembled and all that goes with that. If someone buys a 19 reg aircraft then it is buyer beware, On the other hand, if you buy a 24... reg aircraft then you are trusting that the "qualified " person working on it actually knows what they are doing and in some cases this is a little on the scary side. The average 19.. builder has a solid vested interest in doing the maintenance correctly as it is their a..se on the line, not just a weekly wage. A 19.. reg aircraft is just that..an amateur built aircraft.. and anyone buying it must realise that. Any amount of regulations is not going to make people instantly responsible. Amateur built is amateur built, professional built is different. Your term "good enough" worries the hell out of me, surely the aircraft should be built correctly and time taken to make it as good as you can, commercial interests aside. 19.. reg and 24.. reg are 2 different beasts and in my experience, most (not all) 19 reg are superior to the 24 built standards.

 

 

[jetjr]

This regulation on 19 is from CASA it seems, the text from RAA is straight from CASR so pretty hard to understand.

 

As many regulators dont see is that owners effected have on most cases a number of options

 

In this case they can continue with problems of problem parts and workmanship. Ie NOT fix known problems.

 

Even retrofit dodgy components. Literally refit std bolts rather than go through MARAP to fit AN ones

 

Or they can lie and say the aircraft always had those mods

 

Its classic CASA thinking for type certified factory built aircraft, these are not and perhaps RAA needs to lobby for change if its the case.

 

Id suggest of you asked 19 owners of they owned an LSA or not most would say no.

 

 

[Guest Maj Millard]

I haven't been too engaged in this area ( very busy in others) other than asking Darren at every opportunity how we are going with getting alternate prop approvals, particularly with approving Carbon fibre replacements for outdated original wooden models which may no longer be available.

 

The MARAP procedure is pretty well explained as I read it on the RAA website. It will be assessed on an individual case basis, and a fee will be levied on a user- pay level. On a prop arpproval that fee should be minimal, and one time only.

 

What MARAP is giving us is additional freedoms that we have been chasing for sometime, and by my way of thinking we certainly would not have recieved under previous administrators, and certainly not from SASAO until hell froze over.

 

It shows what a good relationship we have currently with the new administrator Mark Skidmore, and we need to take our hats off to the current excutive, board, CEO, and Tech team for achieving this excellent relationship for us.

 

MARAP is designed to tidy up those areas of illegality that exist with some aircraft, and is so to speak our own inhouse engineering - approval service as opposed to one having to pay a GA-based approved engineer thousands of dollars to (maybe) achieve the same thing for your aircraft.

 

I recommend we embrace it and work with it, to our advantage...

 

 

[fly_tornado]

Ross you are only looking at your mates with old lightwings, what about your #19 customers?

 

 

[jetjr]

We still have to pay for GA part 21 engineer? Says so.

 

Why will it be cheaper, we have to pay RAA tech guy too?

 

 

[Oscar]

Your term "good enough" worries the hell out of me, surely the aircraft should be built correctly and time taken to make it as good as you can, commercial interests aside. 19.. reg and 24.. reg are 2 different beasts and in my experience, most (not all) 19 reg are superior to the 24 built standards.

'Good enough' means that it meets the standard required and is (sometimes, I agree) ALSO 'fit for purpose'. For example, there are areas on the early Jabs where loose strands of glass are not sanded back and you can jag your hand when reaching in to a difficult area to get at a nut or bolt, there are some things secured by rivets where I believe bolts would be a better ( if weightier and more time-consuming) job to use in manufacture. But none of those had failed to do their job properly - therefore, to me were 'good enough' though had I been the builder I'd have done them to a slightly different standard.

 

Yes, I have certainly observed stuff on 24-reg aircraft that I doubt any experienced builder with reasonable knowledge would NOT have done, or done that way. I'll place a bet that any experienced LAME - let alone a Part 21 engineer- can find stuff on some 24-reg aircraft that they would reject as being 'best practice' - or even 'good practice'. However, not every builder of a 19-reg aircraft has an encyclopaedic knowledge of every facet of working on an aircraft, and a 19-reg buyer has to hope (to a degree) that there is not something, somewhere, in the aircraft that is a weak link.

 

 

[jetjr]

A 19 builder has to assure that the kit is manufactured to meet LSA standards and it is inspected.

 

Factory that produces kit and say it meets LSA std if made as per the manual

 

Interestingly it also says kit maker has to have built type certified?? version of the aircraft

 

Assuming this is correct there should be a certified 4 seat Jabiru out there somewhere??

 

The issue is that at the time when many 19 were popular, factory LSA largely didnt exist. Plenty of "builders" didnt do much building, maybe the min hours on fit out, assembly and paint. Im not sure how this reality makes them qualified to modify more than an owner

 

Still lost in CASR reading regarding owner/builder ans experimental type certs and who can do what. Plenty to said on factory built LSA, and Experimental but wide gaps on Experimental LSA

 

 

[facthunter]

Any part plated and not heat treated straight after is not useable on an aircraft. ref. Hydrogen embrittlement.

 

Are we going to stifle innovation? with rules , inspections and paperwork. This has tyo be done properly.

 

Wasn't using AC 43 13-1B/2A Acceptable methods Techniques and Practices for AIRCRAFT INSPECTION, REPAIRS and ALTERATIONS the "Bible" for all this.

 

Every operator should have (And read and understand) that publication which is still available from the RAAus I presume.

 

Auto grade 5 bolts are approved but why not use the AN system as it's not that expensive and getting quality bolts is nearly impossible now..

 

OXY welding is still used widely in the US. If it is Chrome molly it requires post welding heat treatment to achieve full tensile strength ( IF you need it) otherwise some tempering alongside any TIG weld, as a minimum.

 

IF you are wood building use approved adhesives and do test joints and keep samples.

 

Calculate strengths required and achieved from material specs but this isn't easy with wood, so test representative samples..

 

Tony Bingelis has lots on building your own plane with recommended safe practices for structural, electrical and other aspects of design ie stability. Bill Whitney has stuff on design that is understandable and practical. There is no need to re-invent the wheel. Test sample assemblies that are critical to the design to ensure your calculations are conservative and adequate safety and manufacturing variations are covered. Nev

 

 

[Guest Maj Millard]

Ross you are only looking at your mates with old lightwings, what about your #19 customers?

FT, that's a bunch of crap and you should know it......you would probabily go through life a little more productively if you didn't look at everything with such a negative slant all the time.

 

 

[fly_tornado]

Remove the experimental planes from this program and I will stop complaining, your happy, I'm happy your mates are happy.

 

The least you could do is explain why you need to include experimental aircraft with a rule designed to fix a legal restriction for factory built ones.

 

 

[Aerochute Kev]

I think that is a fair question FT, why is 19 rego included? Not only that, it wasn't long ago we had a poorly written Op's Manual imposed on us and after the flogging the Board took over that, was a promise the members would be consulted before major changes. I think this could be considered a major change as it affects a lot of members/aircraft.

 

Is the Board not still doing what it was several years ago, making major changes without consultation? I'm not sure i like where this is heading.

 

 

[Garfly]

But Andy has already told us (post #28) that the board was not involved in this decision. So I don't think it's fair to have a crack at our hardworking and conscientious reps. [but on face value it does appear to be a major blow to the whole idea of second-hand homebuilt aircraft ownership. No more mods to 19 cat. aircraft without MARAP approval - unless you happened to have put the kit together yourself.

 

Andy said:

 

"BTW the board were aware of the marap process only slightly before you guys in that its an operational issue between the CEO and the Tech team, there is no question of strategy or governance and as such we leave it to those that are charged with the responsibility to deliver....."

 

But to me there is so much unnecessary mystery surrounding this whole thing.

 

Why was this major new restriction to the way maybe 50% (a guess) of members are allowed to operate their aircraft just tacked on as a kind of afterthought to a minor regulatory fix (albeit an important and welcome one to those affected).

 

Suddenly it seems that 19 category homebuilts will be treated like certified aircraft as far as modifications are concerned. This is huge.

 

Some, reportedly, say 'well, it's just a regularisation of what was always actually the legal case'. Others here deny that. But who, here - or at RAAus for that matter - ever knew about that? And/or acted as if it actually was the case?

 

What really is the legal situation?

 

Is this an idea hatched in our head office (maybe for very good reasons, but we need to know what they are) or is it something that has been absolutely imposed by CASA?

 

We need to know the genesis of this new ruling - or new understanding or whatever it is.

 

Any defence of these new (?) rules on safety grounds simply breaks down when it's seen to apply only to the non-builder-owners and their 19 cat. craft - though the perceived perils can scarcely be seen as different. In fact, the new ruling itself is a safety threat because it means that owners will be constrained in or discouraged from making - or ordering - needed safety improvements to the aircraft they buy, or worse, have already bought with an eye to fixing them. (Believing that to be legal.)

 

And how are those pro aero-engineers, referred to in the MARAP FAQ, supposed to gain intimate knowledge of all the myriad homebuilt types out there so that they can properly make their (expensive) determinations ... as to, say, whether a new cup holder* or compass or ballistic parachute or fuel tank or engine change-out, whatever, is to be deemed permissible?

 

Maybe these fears are misplaced. (I keep saying that I must have it wrong ;-) Maybe it'll actually be an easy and quick process in most cases and maybe this new regularisation (if such it be) will indeed open up ways for us all to get additional privileges from CASA. Maybe it does herald a bright new future with a friendlier regulator. But that's not necessarily the impression one is getting.

 

Anyway we just need to know ... and soon. People could be spending time and money right now on what are (all of a sudden) illegal improvements to their bought 19 cat. aircraft.

 

So if Andy and Ross and co. could assist by sussing out some of this stuff with head office and letting us know here it'd really help a lot.

 

(* By the way, that's not to suggest that a poorly installed cup-holder could not bring an aircraft (or car) to grief. It could. But there are already legal instruments - and common sense principles - in place to minimise that risk. The new arrangements do little to eliminate it.)

 

 

[Ron5335]

But wait...... It Just gets Better !!!!!!!

 

 

MARAP is designed to make modification to a factory Built Aircraft....... Fine, it's a way forward for that group and something new (No one is caught up in it, enter it at your own risk)

 

If you include 19 Reg into it, there is a dilemma.

 

How many owners are there out there carrying out mods to their aircraft (That was up to last week, quite legal in what they were doing)

 

This week they are all now illegal, because they are modifying their aircraft without permission.

 

The only way they can become legal again, is to submit an application form on a form that applies to a different category of aircraft (Falsify Document)......No Provision on the document for a 19 reg.,

 

to carry out proposed changes that may have already been done (Falsify Document Again). or Backdate it (Just as Bad).

 

 

 

No transitional period is mentioned.... On Thursday some owners were legal law abiding citizens, and on Friday RAA made them criminals !!!!!!!!

 

Case in Point.

 

 

After making mods to my aircraft that started in Dec 2013, (all mods ran by Kit manufacture & Ok'd) and finished in March 2015, I forwarded COA, Photos etc. (All that was required at the time) to RAA.

 

only to be told that as of today (last week) I would have to go through the MARAP.

 

So I am supposed to submit an application (Say in April 2015) for a 19 Reg aircraft, on a form specifically devoted to a Factory Built Aircraft, to commence modifications (If approved) on my aircraft whilst, RAA are in possession of a full set of photographs

 

(Dated March 2015) showing all the work is completed.

 

If I pull it off..... Do I end up with a 24 Reg aircraft.???? or thrown in jail for submitting false documents ???????

 

Sounds like someone thought "It seemed a good idea at the time" and added the 19's to the original proposal for 24's & 55's

 

 

 

[fly_tornado]

I would like to know how much its going to cost to get your mod's approved and how long before you can legally fly again.

 

 

[Ron5335]

fly_tornado That's an interesting point.

 

As it stands....No mods have been carried out to the aircraft following the release and implementation date of MARAP.

 

Requirements and Laws cannot be backdated !!!! and everything in place prior to the new Laws and Requirements being introduced, are legal under the laws that existed at the time .

 

That's why there needs to be a Transitional Period, if you plan to change something that is current.

 

 

[fly_tornado]

The RAA hasn't worked like that previously, why should it start doing that now?

 

Obviously, releasing a discussion paper showing various legal options and a period of feedback from various parties and stake holders would have made this implementation worked a lot better. But this is the RAA, the CEO gets paid the same regardless of how many planes are grounded whilst he is at the helm.

 

I hope you get to fly your plane again.

 

 

[skeptic36]

the CEO gets paid the same regardless of how many planes are grounded whilst he is at the helm

You're looking at the wrong guy.

Ask yourself who has the tech knowledge to work out what's what. Then ask what line of work are the people in who have just been given a whole lot more work to do by this decision.

 

 

[facthunter]

I would NOT blame the CEO. This is between the Techman and CASA. This is the second time I've been caught with retrospective rule changes and the cost is mounting and time and any remaining confidence is being exhausted. The last thing being considered is the individual.

 

. 19 .xxxx... was a pretty open category that you could DESIGN and BUILD and MODIFY pretty freely. Where are all the crashed aeroplanes causing concern?

 

The biggest cause of death in MALES in this country aged between 15 and 40 is SUICIDE. and 10.000 die because of maladministration in Hospitals. Over 3 times what is killed on the roads. Nev

 

 

[dazza 38]

I can just imagine Billy Bob saying to his mate Ben Dover from the bush when looking into the MARAP and saying " it doesnt effect me" my ultralight hasn't been registered for 10 years and I dunno who the RAA is.

 

 

[Ultralights]

so seeing as i have done a lot of work repairing corrosion, installing newer and safer aircraft grade components, including paint and corrosion resistant treatments, now do i have to remove all the new parts, install the old worn, corroded and cracked parts, apply for engineering approval, wait, pay, and probably pay again, before i can reinstall the new parts again? and who do i trust to approve all this considering i have been an aircraft structures engineer now for 25 years, with experience on every airliner boeing and airbus make, and the entire aus defence force fleets, i now have to trust someone who doesnt know the inside of a Savannah from a drifter?

 

 

[Guest Andys@coffs]

Folks

 

I spoke with the Techman today about this issue......His view, as mine, was that it is clear in regulations that 2nd and subsequent owners have no right to modify 19 registered aircraft. However he and I agreed that as RAAus is an administrator not a regulator that it was then the regulators job of interpreting the specific RAAus implications on which all the griping is based. As such he has sought a ruling from CASA and will abide by the interpretation that the CASA legal dept place on it. It is our view (in advance of the ruling and therefore subject to change if we get it wrong) that MARAP is an administrative process based on CASA's regulations, in fact we believe it fills in holes.

 

Sounds like someone thought "It seemed a good idea at the time" and added the 19's to the original proposal for 24's & 55's

That's exactly it...the someone was CASA as part of their review and approve of the MARAPprocess.......

 

This is my last communication on MARAP, until I have seen the CASA interpretation that has been asked for from CASA earlier today. We can discuss in a more informed way when we have that.

 

Andy

 

P.S Ultralights I had similar questions as yours when I discussed some changes I had made to my 230 over years past....I added a 2 axis Autopilot as an example, but when discussing with Darren the fact that I was a 3year tertiary trained RAAF avionics tech he provided me 2 points, but the one of greatest import was that anything done up to last Friday is grandfathered in.....and anything you do tomorrow will be discussed as part of the MARAP process.....in your case with your skills and experience any major modifications (and there don't sound like there were many (or even any?) of those, more that basic maintenance was performed) are likely to be approved PDQ from what we discussed......

 

 

[fly_tornado]

Andy, if the 2nd and subsequent owners of experimental are unable to make repairs to maintain airworthiness, those aircraft should be placed into a yearly inspected regime and grounded when appropriate.

 

Waiting for an aircraft to fall out of the sky and kill the owners due to poor maintenance can't be CASA's intention.