Maintenance of Factory Built A/C

[sfGnome]

I've been hunting through the regulations regarding maintenance, and now I'm even more confused than before I started. I understand that if a factory built (24-xxxx) aircraft is being used for training, etc, then its maintenance must be performed by an L2 or better. However;

 

1. If it is just being used by the owner for their own fun and games, are they then allowed to do their own maintenance?
    
    
   
2. If they are allowed, then can the aircraft be used for training in the future, or does the first non-L2 maintenance render the aircraft forever marked as unsuitable.
    
    
   
3. If a syndicated limited liability company owns the aircraft, are the shareholders in the syndicate considered to be owners for the purposes of maintenance, or does the company put them at arms length so that an L2 has to do any work?
    
    
   
4. John Brandon, in one of his excellent tutorials states "Where there is a group-owned aircraft one owner must be appointed to be responsible for — and control of — all maintenance on that aircraft". Whilst that makes good sense (just as one should be responsible for finance and one for booking, etc), I couldn't find where in the regulations such a stipulation is made. Any ideas?
    
    
   

 

 

Thanks. Any answers much appreciated.

 

 

[Wayne T Mathews]

I've been hunting through the regulations regarding maintenance, and now I'm even more confused than before I started. I understand that if a factory built (24-xxxx) aircraft is being used for training, etc, then its maintenance must be performed by an L2 or better. However;

1. If it is just being used by the owner for their own fun and games, are they then allowed to do their own maintenance?
    
    
   
2. If they are allowed, then can the aircraft be used for training in the future, or does the first non-L2 maintenance render the aircraft forever marked as unsuitable.
    
    
   
3. If a syndicated limited liability company owns the aircraft, are the shareholders in the syndicate considered to be owners for the purposes of maintenance, or does the company put them at arms length so that an L2 has to do any work?
    
    
   
4. John Brandon, in one of his excellent tutorials states "Where there is a group-owned aircraft one owner must be appointed to be responsible for — and control of — all maintenance on that aircraft". Whilst that makes good sense (just as one should be responsible for finance and one for booking, etc), I couldn't find where in the regulations such a stipulation is made. Any ideas?
    
    
   

 

 

Thanks. Any answers much appreciated.

Good morning Gnome,

 

These are good and valid questions.

 

1/ Yes, an L1 can maintain his own (24 xxxx) RA Aus aircraft, for his own use, so long as it's not being used for commercial training.

 

2/ A factory built aircraft can be used for training, even after it's been maintained by an L1, BUT, it must be inspected, maintained and signed for by an L2 or above BEFORE, and then WHILE, it's used as a commercial trainer.

 

Questions 3 & 4 tie in and are a little more complex, so I'll answer them together:

 

In the case of any aircraft, syndicated or not, one person is nominated as being responsable for the aircraft's maintenance. That doesn't mean he has to do the maintenance, but it does mean he is responsable for ensuring the aircraft is maintained in accordance with the Maintenance Manual (MM), Service Letters (SLs), Service Bulletins (SBs), Airworthiness Directives (ADs) etc. by competent and qualified people. Now, depending on the syndicate members, that may be a big ask, or not, but it is required, and therefore finding someone to accept that responsability may be a possible downside in a syndicate owned aircraft.

 

Hullo, I've just realized while sitting here writing this, that I don't have the reference material in front of me to verify and explain the maintenance requirement complexities of training in a syndicate owned aircraft (it's out in the hangar) so I'll have to get back to you... To be continued...

 

Edit: Before I go, it may be quicker to pick the phone up and call Adam Finn in Canberra. He'll probably be able to give you a definitive answer quicker, and far more authoritative, than any interpretive answer of mine.

 

 

[sfGnome]

Thanks Wayne. Comprehensive answers, much appreciated. It's possible that I'll be talking to Adam et. al. before too long, but I didn't want to bother them until I had a better general picture.

 

Thanks again.

 

 

[Wayne T Mathews]

You will find the references I was looking for in the RA Aus Tech Manual, section 4.0, under the heading of Policy. There's three pages of good stuff there.

 

 

[sfGnome]

Thanks again Wayne. Would you believe that I scoured that document, but somehow skipped section 4.0.

 

 

[Wayne T Mathews]

Believe me, I understand Gnome. When I went to find the reference, I couldn't at first. And I must admit I wound up thinking, "Oh come-on, where'd I see that? Dammit!" I knew it was there, but I didn't know where. So I kept looking until I found it under Policy. What a confounding place to put it. Hiding in full view. How diabolical is that?...

 

 

 

[storchy neil]

Hiding in full view. How diabolical is that wayne t know what you mean

 

re l1 doing own maintenance on 24 reg aircraft i read that it has to be sighned of by l2 at the time of maint

 

i have been wrong before neil

 

 

[Wayne T Mathews]

Hiding in full view. How diabolical is that wayne t know what you mean :bash:re l1 doing own maintenance on 24 reg aircraft i read that it has to be sighned of by l2 at the time of maint

i have been wrong before neil

Good morning Neil,

 

The RA Aus Tech Manual section 4.0 - 4 states: "Maintenance to owner operated aircraft is the sole responsibility of the owner. ...."

 

Section 4.0 - 6 states: ".... Aircraft used for hire and reward are to be wholly maintained, and/or the maintenance authenticated by, an RA Aus Level Two Maintenance Authority holder. Daily inspections may be completed by the pilot-in command. ...."

 

Section 4.0 - 6.1 gives an out for the people who have been owner operating, and now wish to use the aircraft for hire and reward.

 

Please bear in mind though, this is my interpretation. If you see it differently, give Adam Finn a call for clarification.

 

 

[storchy neil]

You will find the references I was looking for in the RA Aus Tech Manual, section 4.0, under the heading of Policy. There's three pages of good stuff there.

wayne i am in noway having ago at you just to let you know

i changed the oil and plugs in my 24 reg aircraft if the aircraft was to be used for hire and reward my actions were illegal as they were not complated by a l2 this is stated by xxxxx neil

 

 

[Guest Maj Millard]

Assuming Neil that the "syndicated owners" are all legal part-owners of the aircraft in the eyes of the law, and not just users who have paid to have useage of the aircraft, as required as part of a 'syndicate'... If they were just "paid users" then the aircraft could technically be seen to be used for hire or reward, and therefore would need to be maintained and signed out by an appropriated rated L2. Or...even if it is used most of the time for private use, but needed to be used by an instructor, to conduct a BFR, TIF, or pilot check-out, or endorsement flight.. (IE: training !), then it would also need to be maintained and signed out by an appropriatly rated L2. Can't really have your cake and eat it too........................................Maj...

 

 

[Wayne T Mathews]

wayne i am in noway having ago at you just to let you knowi changed the oil and plugs in my 24 reg aircraft if the aircraft was to be used for hire and reward my actions were illegal as they were not complated by a l2 this is stated by xxxxx neil

Good morning Neil,

 

I'm not sure if you're asking me a question or telling me what xxxxx said. If you're telling me what xxxxx said, then he's right to a point, because the L2 doesn't have to actually carry out the plug and oil change on an aircraft before it's used for hire and reward, but he does have to authenticate and sign for it. That's clearly stated in Section 4 of the RA Aus Tech Manual under the heading of Policy.

 

Section 4.0 - 6 states: ".... Aircraft used for hire and reward are to be wholly maintained, and/or the maintenance authenticated by, an RA Aus Level Two Maintenance Authority holder. Daily inspections may be completed by the pilot-in command. ...."

 

Section 4.0 - 6.1 gives an out for the people who have been owner operating, and now wish to use the aircraft for hire and reward.

 

Assuming Neil that the "syndicated owners" are all legal part-owners of the aircraft in the eyes of the law, and not just users who have paid to have useage of the aircraft, as required as part of a 'syndicate'... If they were just "paid users" then the aircraft could technically be seen to be used for hire or reward, and therefore would need to be maintained and signed out by an appropriated rated L2. Or...even if it is used most of the time for private use, but needed to be used by an instructor, to conduct a BFR, TIF, or pilot check-out, or endorsement flight.. (IE: training !), then it would also need to be maintained and signed out by an appropriatly rated L2. Can't really have your cake and eat it too........................................Maj...

What Maj is addressing here is one of the complexities of syndicate owned aircraft. Quite obviously (I'll use a blatant example here), if an aircraft is "available" for a group of people who have paid $1 to be part of "the syndicate" and are then paying $150/hr to use the aircraft, then the aircraft is not really a syndicate aircraft, and is in fact being used for hire and reward.

 

I know if I was going to be involved with a syndicate aircraft, I'd want the deal run past Zane and Adam before I ever handed over my money, just to be sure the deal was kosher...

 

 

 

[storchy neil]

hi wayne maj totaly agree wish i could add names 10 sept to 18th after eight days of court will know more neil

 

 

[winsor68]

In the end... Self regulation, which is what Ra-Aus at it's roots was all about... would dictate that at the end of the day ALL responsibility lies with the owner to see that regulations are complied with I would guess.

 

It is an unfortunate situation and IMO the waters have been muddied a bit by a lack of ability upon "the regulators" part to oversee and effectively audit the operation of the many flying schools that have sprung up.

 

I can see how it would be easy to purchase an aircraft and have BIG problems with cross hiring to a school to the unwary.

 

 

[Guest Maj Millard]

Yes the key here of course is the wording "for hire or reward".....As far as I know the sharing of fuel costs with a passenger for private ops is still allowed, as long as that passenger hasn't "hired you" for the flight............................................................Maj...

 

 

[Wayne T Mathews]

Yes the key here of course is the wording "for hire or reward".....As far as I know the sharing of fuel costs with a passenger for private ops is still allowed, as long as that passenger hasn't "hired you" for the flight............................................................Maj...

What Maj says is true, Folks. Cost sharing is acceptable, so long as you're only sharing the costs. But I'm told selling someone a box of matches for $200 and then taking them up for an aeroplane ride is not considered acceptable (apparently it's happened in the past)... Hey, you may well get away with it. But if/when something does go wrong (and as sure as God made little apples, sooner or later it will), and the powers that be find out about it, they're gunna cut you a new one... An' it ain't gunna be either pretty, pleasant or elegant... My opinion? Cost share if you wish. But for goodness sake, don't try to be a barnstorming, joyflight charter pilot unless you is one... And even then, please don't do it in one of our recreational registered aircraft. The rest of us don't want the hassles you'll bring down on all of us. And we'd really rather keep thinking you're not that silly, inconsiderate, or irresponsable...

 

 

 

[spacesailor]

I'de like to have a "joyflight", with me throwing a few bucks into some-ones fuel cost, as I'm a trainee (RAA) would it be such a bad thing to see (and feel) a differant aircraft, than the only one I've flown in ?

 

Bryan

 

 

[Guest Maj Millard]

Not at all Bryan, go do it. Every aircraft type has something to teach you. It's all experience under your belt really, and you can always reference it in the future..................................................Cheers...... Maj...

 

 

[Bandit12]

Is the RAA definition of cost sharing any different from the GA one? If so, as long as the pilot is contributing an equal or greater amount than the passenger, there is not usually a problem. I scored quite a few hours soon after getting a license with friends and family coming along to share some of the costs.

 

 

[Wayne T Mathews]

Is the RAA definition of cost sharing any different from the GA one? If so, as long as the pilot is contributing an equal or greater amount than the passenger, there is not usually a problem. I scored quite a few hours soon after getting a license with friends and family coming along to share some of the costs.

In my opinion, there is no difference between GA and RA Aus on this issue... Cost sharing is when we, the people in the aircraft, share the cost of the flight...

 

 

 

[REastwood]

A question then, does the RAA Tech manual (4.0 para 6) in regards to maintenance (Daily inspection only if used for Hire & Reward) counteract CAR 1988 Schedule 8 (sub regulation 42ZC (4) which allows a pilot to conduct certain activities on a B Class aircraft (i.e. Replace, clean, gap spark plugs, change oil, replace batteries etc.). It would be strange (but no real surprise) for GA to be less prescriptive than RAA!

 

P.S. Class B aircraft covers GA private, airwork and charter.

 

 

[Wayne T Mathews]

A question then, does the RAA Tech manual (4.0 para 6) in regards to maintenance (Daily inspection only if used for Hire & Reward) counteract CAR 1988 Schedule 8 (sub regulation 42ZC (4) which allows a pilot to conduct certain activities on a B Class aircraft (i.e. Replace, clean, gap spark plugs, change oil, replace batteries etc.). It would be strange (but no real surprise) for GA to be less prescriptive than RAA!P.S. Class B aircraft covers GA private, airwork and charter.

I have just spoken to Adam Finn, the RA Aus Tech Mangager in Canberra, and he has confirmed that as per the RA Aus tech manual (4.0 - 6): ".... Aircraft used for hire and reward are to be wholly maintained, and/or the maintenance authenticated by, an RA Aus Level Two Maintenance Authority holder. Daily inspections may be completed by the pilot-in command. ...."

 

He went on to say though, that members who want to maintain an RA Aus "hire and reward" aircraft to the equivalent level of GA's schedule 8, may be able to do so by applying for a restricted RA Aus level two authority for line maintenance as defined in the tech manual (4.1.1 - 9). Each applicant will be assesed individually, and Adam will make the call as to whether an applicant is considered competent enough to be issued a line maintenance L2 authority, or not.

 

The procedures and requirements for applying for an L2 authority are listed in the tech manual (4.1 - 1 thru 4.1.1 - 7)

 

And yes, in answer to your question reference comparing RA Aus and GA standards, RA Aus is more prescriptive than GA in this instance when dealing with "hire and reward" aircraft, which may not only be used by instructors and students for training, but may also be hired by the general, qualified, public.

 

 

[Yenn]

What is GA schedule 8. I know about schedule 5 but 8 is a new one for me.

 

 

[Wayne T Mathews]

What is GA schedule 8. I know about schedule 5 but 8 is a new one for me.

I'm told you'll find it under CAR 1988 Schedule 8 (sub regulation 42ZC (4) which allows a pilot to conduct certain activities on a B Class aircraft (i.e. Replace, clean, gap spark plugs, change oil, replace batteries etc.).

 

I haven't personally checked the reference is correct. I simply know of it as schedule 8, and it lists what basic line maintenance GA pilots are allowed to do on their aircraft. It's a very similar list to what we have in 4.1.1-9.

 

 

[Mriya]

A question then, does the RAA Tech manual (4.0 para 6) in regards to maintenance (Daily inspection only if used for Hire & Reward) counteract CAR 1988 Schedule 8 (sub regulation 42ZC (4) which allows a pilot to conduct certain activities on a B Class aircraft (i.e. Replace, clean, gap spark plugs, change oil, replace batteries etc.). It would be strange (but no real surprise) for GA to be less prescriptive than RAA!P.S. Class B aircraft covers GA private, airwork and charter.

Your observation is correct. RAAus does not have a direct equivalent to CASA Sched 8. If a RAAus aircraft is to be used for hire or reward, then a L1 (pilot/owner) is limited to conducting a daily inspection only. Any maintenance (including that specified in CASA sched 8) must be done by a L2. The only way around this was mentioned earlier in this thread, where someone may apply for a Line Maintenance Only L2 Authority, however you will note that this work is then still being done under the authority of a L2, even if their scope has been limited.

With regards to CASA Sched 8, it should be noted that CASA 'strongly recommend' that pilots seek guidance from a LAME to become familiar with how to perform the allowable tasks and they are also required to have access to current maintenance data, while using calibrated equipment.

 

Hope this helps:book:

 

Justin

 

 

[spacesailor]

How about a new twist!, I buy a two seat RAA aircraft and pay (hire or reward) a pilot to fly me around.

 

"No chance of own pilot certificate."

 

So is this legal ?

 

Bryan