Possible Raa Fleet Grounding

[The Baron]

I heard yesterday that there is a chance that casa is going to ground the entire raaus fleet, also they are not processing rego renewels or transfers or new rego's until further notice, is there any truth in the rumour???? Cheers Steve.

 

 

[Robbo]

very much dout that !!!

 

Plus CASA doesent do RAA registrations its RAA Australia

 

But there under supervision from CASA so I suppose CASA could do something, but I very much dout it as it would have been all over the internet :)

 

 

[Guest ozzie]

2nd time I've come across this rumor today. Would not surprise me after what seems to be a near constant stream of 'paper work' stuff ups coming out of the office.

 

 

[winsor68]

It is not just paperwork Ozzie... its oversight.

 

 

[Guest Michael Coates]

Perhaps I can give you a little bit more information based on my experience..... Aircraft are still being registered, we have had a couple registered in the last few days and we have also had registration number assignments approved in the last few days so the system is working up until about lunchtime today that I can confirm.

 

I do understand however that there still are aircraft under suspicion and pending action. A lot of these aircraft are missing paperwork let me use an example without any names....

 

An aircraft called "big wing" (don't try and guess any names because I just made up this name to be anonymous and it is not intended to subliminally suggest any aircraft whatsoever) is made in another country, the country does not have very strict aviation rules and does not have a proper system in place for certification. A local guy in Australia decides that importing big wing makes financial sense and he can make a business of it so we start importing one for himself and one for a friend and then tries to sell more from there. Everything goes fairly well for a period of time and he sells a few until there is a CASA audit and it is discovered that big wing does not have the required paperwork and certification to allow it to be registered in Australia as an ultralight or an LSA aircraft.

 

How does this happen ?

 

Obviously when the aircraft were originally brought in the paperwork was not scrutinised sufficiently to show complete compliance with Australian regulations. Of perhaps 10 statutory documents required perhaps 6 are correct and 4 are wrong.... but unfortunately for the importer and his customers the aircraft are grounded pending the correct documentation coming through. What gets really interesting is that this documentation does not exist or has been issued by an authority not approved or accepted by the CAA in the country of manufacture and therefore the aircraft cannot be legally on the Australian register. Result = very unhappy customers with aircraft grounded.

 

Situation II, an importer starts bringing in a couple of big wing aircraft as factory built and they qualify for full registration and acceptance but then an importer starts to get the ideas that if he builds the aircraft from a kit or a partial kit in Australia and still sells it as a factory built aircraft then he can make more profit margin. Fill in the paperwork, sign a few documents that you shouldn't, get the aircraft registered and sold as a factory built and move onto the next aircraft and start the process again. Everything goes okay until CASA do an audit and they have suspicions that aircraft are not being manufactured overseas but are being built locally. Request a few details from the manufacturer overseas about how many planes they have shipped to Australia as factory built aircraft, request shipping documents to prove that fully built aircraft came to Australia from overseas and when you start getting a few question marks it becomes obvious that you cannot get eight factory built, ready to fly aircraft into a shipping container on one bill of lading but you can get eight kits in the same said container. Houston we have a problem!

 

I can't comment on how far this will go and how many aircraft will be affected but I do have a feeling it is a substantial number that are flying today but will shortly be grounded..... another example, an aircraft comes into Australia as an LSA and has an in-flight adjustable propeller. No problem as far as Australia law is concerned with regards to LSA aircraft provided the aircraft propeller in question has a type certificate. Unfortunately this propeller is not type certified and therefore it cannot be used on anything except an experimental aircraft, all of a sudden we have a problem because this aircraft is a factory built, has a non-certified in-flight adjustable propeller making the aircraft non-compliant. Only choice is to remove the propeller and fit one approved by the manufacturer which is either a fixed pitch or has a TSO certificate.

 

These are just a couple of anonymous examples affecting the industry.

 

 

[David Isaac]

Michael, is it not the importers responsibility to furnish the correct documentation and RAAus's responsibility to scrutinise the process?

 

 

[Guest Michael Coates]

Yes it is David.... having put around 16 different aircraft through the process I know it fairly well. The only responsibility on getting the paperwork correct is with the importer of the aircraft, nobody else! The RAA simply registers the aircraft based on the information they are supplied if the aircraft meets the required documentation standards. If somebody makes up paperwork to get an aircraft through the system how are the RAA to find out, they are not document investigation experts.

 

The RAA has a responsibility to apply the rules and scrutinise the documentation. If your application ticks all of the boxes then it can proceed along a path to have the aircraft accepted into the Australian fleet. If you don't tick all of the boxes then you either go back to the manufacturer of the aircraft and get the required documentation for the aircraft doesn't get accepted.

 

The problem we have which I see is that the documentation was not scrutinised heavily enough.... it could be as simple as.... missed RAA I don't have that form yet but I will send it to you next week, next week comes and the importer is ringing up the RAA asking for his aircraft to be accepted and they forget about the missing document & sign it off..... there are so many scenarios of what should happen and what could happen but there have also been a few mistakes/errors.

 

 

[Guest Michael Coates]

This will give you an idea of "some" of what is required.....

 

 

Certification Details - Type Certificate

 

Type certificate from a core ICAO nation

 

 

Aircraft Details - Type Certificate Data Sheet, and Drawings

 

A copy of the Type Certificate Data Sheet is required. Full details of the aircraft type and model are required giving at least: dimensions, engine, propeller, type of drive to the propeller, stall speed (calibrated) in the landing configuration at MTOW, MTOW, wing area, wing loading, number of seats. This is normally stated in full in the Type Certificate Data Sheet. Photographs of the aircraft and details of variants would be valuable.

 

A guarantee is required that general and detail drawings will be provided if needed by RAA or CASA.

 

 

 

Details of the Certifying Body and of Approving Bodies in Other Countries.

 

Full details of the certificating or approving Authority or Body are required.

 

If the certificating Organisation is not the NAA of a Contracting State but an authorised body within it, a document from CASA advising the RAA that the Organisation is acceptable for the purpose of certifying the aircraft documentation will probably be required (see CAO 95.55 para 6 at Part 2).

 

If the aircraft has been approved for service in other countries, details of the countries and approving bodies together with details of the approvals under which the aircraft are operating in those countries will assist evaluation.

 

 

Details of the Design Standard.

 

The design standard of the aeroplane is to be stated ( and if the standard is not internationally recognised a copy will be required by the RAA)

 

Noise certification or noise approvals are to be addressed. Noise certificates are required if they have been issued. If not, a certified statement that the aircraft has not failed noise certification testing against a noise standard is required.

 

 

Full Details of English Speaking Contacts.

 

To assist in evaluation of the aeroplane and in maintaining continuing airworthiness, the RAA requires written advice of reliable and guaranteed English speaking contacts:

 

within the foreign NAA who can provide details of certification;

 

in the factory who can provide data on design, manufacture and continuing airworthiness support; and

 

inAustraliawho can provide local support

 

 

Full details of the Manufacturer.

 

Note that CASR 21.43 states that CASA is not required to consider an application if the location of the manufacturing facilities places an undue burden on it in administrating applicable airworthiness requirements. The same will apply to the RAA.

 

Who is the manufacturer?

 

Who is to be responsible for the aircraft as a type, its import and support in Australia?

 

Does the manufacturer hold a Production Certificate, Approval to Manufacture (or equivalent) from a National Airworthiness Authority or an Organisation authorised by a National Authority to do so? If so, who? Copies may be required.

 

Where is the manufacturer located?

 

What is the background of the manufacturer?

 

Did the manufacturer design the aircraft?

 

What qualifications or background does the manufacturer hold to design the aircraft?

 

If the manufacturer did not design it, who did?

 

What qualifications does the manufacturer have to manufacture the aircraft?

 

Does the manufacturer manufacture all components and if not what components are outsourced and from whom?

 

Do the outsourced component manufacturers hold any form of aviation regulatory approval? If so what are they? Certificates may be required.

 

What other types of aircraft does the manufacturer produce now and in the past?

 

 

 

Airworthiness History of the Aircraft, its Engine and Propeller.

 

As much detail on the Airworthiness history as possible on the aircraft, its engine and propeller should be provided as this may reduce some of the detail needed in other areas. Some of these aspects may be implicit in the type certification covered in para 4 above, but they need to be covered, even if only by reference to the certification documents.

 

Approximately how many aircraft of the subject type have been produced?

 

Approximately how many aircraft are in service, in what roles and where?

 

Has the aircraft been tested to any standard and if so, what is the standard?

 

Has the engine been tested to any standard and if so, what is the standard?

 

Has the propeller been tested to any standard and if so, what is the standard?

 

Has any aircraft or engine testing been witnessed or reviewed by a regulatory authority. If so, give details.

 

What major modifications or changes to design or manufacture of the aircraft or of the engine (in its fitment to the aircraft) have been necessary since prototyping?

 

How many hours has the world fleet of the type accumulated?

 

How many hours has the high time aircraft achieved?

 

What is the history of the high time aircraft?

 

How many fatal accidents have they been involved in?

 

What caused the fatal accidents?

 

When was the last major and fatal accident and what caused it?

 

 

Airworthiness and Operational Documentation

 

What Documents and Manuals are available to Operators and Maintainers and in what form e.g. paper, electronic, CD? (The RAA will require at minimum the Flight Manual, Manufacturer's Instructions for Continued Airworthiness of the Aircraft, engine and propeller; Parts Catalogue, Field Service Documents etc)

 

The RAA will require copies of all documents: CD versions if available, otherwise hard copy.

 

What are the provisions and procedures for updating these documents?

 

An undertaking for continued supply to the RAA of service bulletins, instructions and any amendments of the continuing airworthiness documents for aircraft of that type in a manner acceptable to the RAA is required.

 

What systems are in place for the manufacturer to receive reliability and airworthiness feedback from the field?

 

Is airworthiness information passed to the NAA?

 

What system is in place to review field information and to promulgate action requirements arising from field airworthiness feedback? Where is this done?

 

What system is in place for promulgating new service and maintenance data?

 

What system is in place for configuration control and its recording; and what would be availability of fleet configuration status detail to the RAA?

 

What data, records and documentation accompany each aircraft?

 

 

Continuing Support.

 

A guarantee that any in-service problems or major accidents caused through airworthiness defects in the world fleet will be reported immediately to the RAA is required

 

Details of English speaking Engineering and Operational contacts are required. (See also para 5 above).

 

A guarantee that detailed and comprehensive continuing airworthiness support will continue to be available for the aircraft, that this will be available to the RAA and details of who will supply it and by what method is required.

 

 

[Guest Michael Coates]

okay guys, I have an update !

 

I rang and spoke to the RAA personally and yes they are currently under restrictions from CASA !

 

Until advised otherwise they are not allowed to register any new aircraft in Australia, they are not allowed to renew any aircraft registration in Australia and they are not allowed to transfer any aircraft registrations in Australia !

 

There is a possibility that the entire fleet may be grounded by the end of next week......

 

There is a lot more information available but it is not really suitable to be put on a public forum.

 

 

[Guest David C]

That's one hell of a bombshell . Any grounding will have a devastating effect on flying schools , some of which I can only assume will go to the wall .. The future of some importers and local manufactures must be in jeopardy too .

 

Dave C

 

 

[Guest avi8tr]

Aircraft Registrations and Renewals

 

November 9, 2012 | opsassist

 

Following a CASA Directive RA-Aus is unable to process aircraft registrations, including renewals until further notice.

 

RA-Aus regrets this inconvenience and the board and staff are working closely with CASA to resolve this situation as soon as possible.

 

This notice will be updated by close of business Monday 12 November 2012, or earlier if there is any change.

 

 

[Guest avi8tr]

I can't believe that there would be posters out there implying that posters on here are parasites when this information is quite obviously in the public domain. Some people should think a little more before putting their fingers to the keyboard.

 

 

[Guest Michael Coates]

I can't believe that there would be posters out there implying that posters on here are parasites when this information is quite obviously in the public domain. Some people should think a little more before putting their fingers to the keyboard.

YEAH !

 

 

[Guest Andys@coffs]

I rang Steve Tizzard this afternoon and asked if the rumours of a potential grounding of the entire fleet had any basis and he advised me that was B/S and that at this stage they working with an aim/hope to have the temporary restrictions removed by Monday.

 

Now, for clarity Im not claiming others have it wrong....merely reporting what I was told in response to questions about a total grounding of the fleet...That said Steve Tizzard, in this case is the recipient of the instruction, not the provider of the instruction...Perhaps Michael is quoting someone more on the providing side than receiving side of the equation....

 

Andy

 

 

[dazza 38]

I can't believe that there would be posters out there implying that posters on here are parasites when this information is quite obviously in the public domain. Some people should think a little more before putting their fingers to the keyboard.

I better add that I was the respondent to the post.I in no way meant to imply that anybody on anyforum is a parasite. I have changed my reply because it could have come across that I may have implied or agreed with the post I was replying to. When I replied with "True " I meant true the infomation could possibly be incorrect. NOT true that the poster was a parasite.Which of course he is not.

I have since removed the first "True" word from that post.

 

Sorry about that.

 

 

[Guest Michael Coates]

Hello Andy, I have been speaking with both sides (as you mention above the recipient and the provider), there is a lot more information to this than what you have been told, it is something I have been very aware of for a long time and without sounding off, I know a lot more about what is going on than a Friday afternoon telephone call to the RAA office.

 

I more than anybody hope that no aircraft get grounded because that means the end of my business; but I can tell you that the RAA themselves are extremely concerned about the possibility of either the whole fleet being grounded, the training fleet only being grounded or somewhere halfway in between. As a suggestion it might be only two seat aircraft which are being grounded ?

 

The other side of the fence in their lavish offices are also extremely concerned about a number of matters and I am not going to elaborate only to say that grounding of the fleet is a very real possibility. I hope it does not happen, but the information I have received indicates that this will be a very likely possibility by the end of next week. I stress again I really do hope the one-on-one conversations I have had with people do not come to fruition because the immediate outcome is certainly not guaranteed or known. If you want more information then I suggest you call me directly.....

 

For the rest of us, there are some real problems happening at the moment and rather than get all excited and start yelling that the sky is falling, we really need to band together, support the RAA (who are not without fault in this matter) and do as much as we can as a group of responsible and sensible aviators to find our way through these troubling times.

 

No progress is made if every single member rings the office and tries to take up 15 minutes of the executive's time, this may well be an occasion where we all have to agree not to ring and instead receive updates through their website. Just a suggestion.....

 

 

[Guest Michael Coates]

Additional thoughts for consideration......

 

As we all know the RAA had a problem when they had an audit some time ago, probably four months ago if my memory serves me correctly. During this audit huge discrepancies were found in the paperwork for one reason or another, the RAA were then given directions to get their house in order..... you can imagine the conversation went something like.... "OK guys, we found some real problems here that need to get fixed we can come back in a couple months and do another audit and see what progress you are making"

 

You can imagine the type of conversation between CASA and the RAA would probably be very similar to above. Well, last week they came back and did another audit and as a result of the audit we now find that the RAA are no longer able to register, renew or transfer aircraft registrations.

 

Despite all of the waffle on the Internet this really means that the follow-up audit by CASA was obviously not acceptable, CASA went away for a few days and then came back with their decision to withdraw some of the delegations given to the RAA.

 

We need to look at this simplistically, either the RAA didn't do anything between the first audit and the second, CASA were mighty annoyed and withdrew their delegation.

 

I don't believe myself that this was the case, from what I understand the RAA started doing their audit internally and rather than being able to check off 10 aircraft files each day they found that everyone they picked up had some sort of issue, missing information, wrong document, something not signed etc etc. I really believe the technical people within the RAA are putting 120 percent effort into getting everything correct but I personally believe we are looking at just such a high workload its not something that can be finished in weeks or months.

 

I made the offer today to volunteer my services to the office for a week and if somebody gives me a checklist I will go through whatever files I am handed and check the documents against the checklist, put the bad ones to one side and a good ones to another and whilst I was made to feel that my offer was welcome and appreciated it could probably never happen for privacy rules.... I am sure we could get another 10 or 15 people like myself together, deputise them as some sort of RAA Deputy (to get around the privacy rules) and put them to work. My offer still stands to volunteer my assistance if it can help make any progress in getting over some of these problems. If the RAA reconsider and needs some help I will put out calls through the website here to try and assemble a team of competent paperwork inspectors and we can get ourselves to HQ and make good of what is starting to become a bad situation.

 

Anyway, enough of the dribble now for some really serious information.....

 

One of my friends works in a sign shop and is managed to get a really good deal on self-adhesive letters .... as long as it starts with the letters... VH- we can get two sets of $50..... okay a bad joke but something we may have to consider in the future.

 

 

[winsor68]

Does the paperwork problem go as far back as when the current CASA staff were with Ra-Aus?

 

 

[Guest Michael Coates]

Further, i am sorry to say but its about the time you refer to that things got much worse I am told

 

 

[Guest avi8tr]

It would seem that the paperwork issue goes back to the beginning of the LSA era. Many would also argue that it has been going on for years.

 

 

[metalman]

the whole LSA thing seems to have been a real f**kup, I think they've dramas in the states with them as well

 

 

[Guest Michael Coates]

Yes they have, the same problems have happened in the US and I have been involved in three FAA audits/requests already for some of the aircraft I represent in other markets. The whole system for LSA aircraft was not regulated enough in my opinion and some people just made up documents to suit the day of the week.... this is happening around the world not just in Australia. The FAA have cracked down and they now have a six person audit team which go and visit the manufacturer whether they are in the USA or overseas where they spend about three days going through everything. It is interesting to note that people in the industry know more about the rules than those enforcing them (in the USA at least). The problems we have with the RAA are certainly able to be overcome, they just take a little time.

 

We all need to remind ourselves that the RAA by comparison to the resources available in the USA are just not even close to comparison so let's give them some assistance and encouragement to move forward.