RAAus To RPL Conversion

[rhysmcc]

King_daniels, the key to the answer is, as I have mentioned previously - in the privileges of the instructor rating. A GA instructor cannot exercise the privileges of their rating in an RAA registered aircraft, nor can an RAA instructor in a GA registered aircraft. Even if the individual instructor holds both ratings, they cannot certify both flight reviews in a single flight. At best, a GA flight review can be accepted by RAA as a high performance flight review as the RAA Operations Manual allows it. There are no provisions in the CAR, CASR or CAO rules to allow an RAA flight review to be accepted as a GA flight review. As I have said, it relies on which "hat" the instructor is wearing, that comes down to under which set of rules the aircraft is operating, which is in turn determined by the aircraft registration. This has always been the case, any instructor signing off both in past years has been doing so incorrectly. (This interpretation was confirmed by a phone call to my local CASA FOI)

Where would one find these privileges defined? Is there a CASR/CAR that states he/she can only instruct in a VH registered aircraft or something? I'm not doubting you but trying to find the reference to back it up. Thanks

 

 

[Roundsounds]

CASR 200.025 and CAOs 95.10 and 95.55, para's 5, 6.1(b) and 6.1© state that you must operate an RAAus registered aircraft in accordance with the ops and tech manuals. To operate an RAAus registered aircraft on a CASR Part 61 Licence or Rating is a breach of Section 20AB of the Civil Aviation Act.

 

 

[Vev]

The reason I asked the question in the first place, was when I read the application form to apply for an RPL (61-1RA sec E) ... It talked about a flt test (not review) being conducted in a suitable aircraft that meets CASR 61.245 and Part 61 MOS. I looked this up but wasn't clear where it said anything other than category (fix wing etc) with no reference to registration, be it RAA or otherwise.

 

Forgive the logic, but accepting that CASA were about to hand over an RPL and endorsement based on the recognition that people holding RAA Pilot Certs had mostly accumulated their hours in RAA aircraft, then why wouldn't an RAA aircraft be acceptable to undertake a flt review?

 

However, I was not clear after reading the Regs and thought I would ask if anyone one actually knew the answer, as from my point of view, it would be good not to have to do multipul flt reviews to maintain both licences or certificates.

 

Cheers

 

Vev

 

 

[DrZoos]

Round sounds i disagree.

 

The new regs entirely change the rules.

 

an RAA aircraft is fit for both type and class

 

An instructor with both RAa and GA instructor rating is not breaching any rule.

 

And under the MOS and 61.245 an instructor neer only use an aircraft fit for type and class...

 

Nothing precludes that. There is no actual cluase in MOS part 61 or 95.10 or 95.55 that says or implies a dual qualified instructor can only exercise one priveledge under RAA or GA..

 

Your assuming that your interpretation is correct...and i think your completely wrong.

 

There is nothing that says a GA priveledge, endorsement or RPL flight test can not be conducted in an RAAus aircraft. It simply infers that a ga instructor without raa licence cannot fly the aircraft....

 

Please supply a quote of what actually states that one must wear one hat or the other while flyng.....

 

 

[DrZoos]

The way you are interpreting the law would also imply that a Pilot certificate holder who also holds a ppl cannot fly in controlled airspace. Because to do so they would be operating using their ppl priveleges and thus not under the ops manual allowed to do so...

 

 

[DrZoos]

Please find and quote where it says that they can only exercise a priveledge of one licence at any given point in time

 

 

[Roundsounds]

Dr Zoos, I did quote the regulations backing up my argument in earlier posts, maybe you should sit down and review them and the regulations quoted. Failing that call 131757 and ask to speak to a Flying Operations Inspector or an Aviation Safety Advisor (Teraya Miller would be best as she is both RAA and GA qualified).

 

 

[rhysmcc]

Dr Zoos, I did quote the regulations backing up my argument in earlier posts, maybe you should sit down and review them and the regulations quoted. Failing that call 131757 and ask to speak to a Flying Operations Inspector or an Aviation Safety Advisor (Teraya Miller would be best as she is both RAA and GA qualified).

I can't seem to locate the post you refer to. I'm not a GA instructor so not really sure where to find where the "privileges of the instructor" is listed that would indicate that their rating is only valid in a VH registered aircraft.

 

 

[Roundsounds]

Maybe give Teraya Miller at CASA a call 131757 or 0434 558 088

 

 

[rhysmcc]

I've had a quick read of CASR Part 61 which talks about the privileges of flight instructor ratings (starts at 61.1165) and I can't find anything that suggests they can't conduct flight training or review in a RA-AUS registered aircraft, assuming they are qualified to fly said aircraft. If you know this to be different, why not just provide the text that made you reach that conclusion.

 

 

[rhysmcc]

a RA-AUS aircraft IS considered an Australian registered aircraft, the fact it doesn't have to comply with certain CAR/CASR (under certain requirements) is because it's legislated so. One of those requirements is a pilot certificate issued by RA-AUS.

 

You can't fly a chieftain with a RA-AUS pilot certificate because the regulations say you require a pilot license and appropriate ratings.

 

 

[DrZoos]

I have called casa a lot and they are lets just say .....not across this very well...they seem to know all about how a new pilot goes from nil to rpl...but no idea when it comes to transitioning...call 3 times, get 3 different answers

 

 

[DrZoos]

I did notice some minutes of an august meeting where they are aware of some of this confusion and they have a nov 4 th deadline to have some flyers or info on making the transition process clearer, in particular the flight review process

 

 

[Dafydd Llewellyn]

CASR 200.025 and CAOs 95.10 and 95.55, para's 5, 6.1(b) and 6.1© state that you must operate an RAAus registered aircraft in accordance with the ops and tech manuals. To operate an RAAus registered aircraft on a CASR Part 61 Licence or Rating is a breach of Section 20AB of the Civil Aviation Act.

I would question whether this is in fact correct.

 

 

[Dafydd Llewellyn]

a RA-AUS aircraft IS considered an Australian registered aircraft, the fact it doesn't have to comply with certain CAR/CASR (under certain requirements) is because it's legislated so. One of those requirements is a pilot certificate issued by RA-AUS.You can't fly a chieftain with a RA-AUS pilot certificate because the regulations say you require a pilot license and appropriate ratings.

Or another qualification that is appropriate for the class of aircraft.

 

 

[DrZoos]

Also the legislation to allow part 61 to fly ra aus in 95.10 is currently with the senate ..its been tabled on sept 12 th and should be signed off very soon.

 

Additionally i contacted RAAus and CASA have already made a public statement to say in the transition period rights of CAR 5 licences etc will be inferred as approved under part 61... So technically if you where extremely unlucky you might come out with an insurance issue, but its crystal clear CASa wont be policing this issue.

 

"The outgoing Director of CASA, John McCormick, in his speech to CFIs regarding the impending Part 61 rules stated” anything you could do under the CARs will still be permitted under the CASRs”, meaning while Part 61 will result in changes, there will be no loss of privileges in the transition."

 

 

[coljones]

Also the legislation to allow part 61 to fly ra aus in 95.10 is currently with the senate ..its been tabled on sept 12 th and should be signed off very soon.

Is this what you you are talking about?

25.10 has been amended by

 

"Civil Aviation Order (Flight Crew Licensing) Repeal and Amendment Instrument 2014 (No. 1)

 

- F2014L01177"

 

by

 

John F. McCormick

 

Director of Aviation Safety

 

27 August 2014

 

New Subparagraphs 6.4 (d) and (e), among many others

 

Substitute

 

(d) the aeroplane is flown by the holder of a pilot licence with an aeroplane category rating:

 

(i) issued under Part 61 of CASR 1998; and

 

(ii) that allows the holder to fly inside the controlled airspace;

 

(e) the pilot has a valid flight review for the class rating in accordance with Part 61 of CASR 1998;

 

=====================================================================

 

RAA pilots with an RPL (or higher) and controlled airspace and drome endos can fly suitably equipped RAA planes through controlled spaces - they will probably need both an RAA and a RPL radio endo as well.

 

 

[rhysmcc]

CASR 200.025 and CAOs 95.10 and 95.55, para's 5, 6.1(b) and 6.1© state that you must operate an RAAus registered aircraft in accordance with the ops and tech manuals. To operate an RAAus registered aircraft on a CASR Part 61 Licence or Rating is a breach of Section 20AB of the Civil Aviation Act.

The Ops manual allows you to operate a RAAus aircraft with a Part 61 Licence, provided you also have a pilot certificate. The fact it states you can fly in controlled airspace provided you also hold a PPL to me clearly shows the privileges of CASA issued licence can be used in a RA-AUS aircraft.

 

 

[rhysmcc]

Is this what you you are talking about?25.10 has been amended by

 

"Civil Aviation Order (Flight Crew Licensing) Repeal and Amendment Instrument 2014 (No. 1)

 

- F2014L01177"

 

by

 

John F. McCormick

 

Director of Aviation Safety

 

27 August 2014

 

New Subparagraphs 6.4 (d) and (e), among many others

 

Substitute

 

(d) the aeroplane is flown by the holder of a pilot licence with an aeroplane category rating:

 

(i) issued under Part 61 of CASR 1998; and

 

(ii) that allows the holder to fly inside the controlled airspace;

 

(e) the pilot has a valid flight review for the class rating in accordance with Part 61 of CASR 1998;=====================================================================

 

RAA pilots with an RPL (or higher) and controlled airspace and drome endos can fly suitably equipped RAA planes through controlled spaces - they will probably need both an RAA and a RPL radio endo as well.

I think most here have agreed this to be the case, just waiting on the New Ops Manual to remove the wording of private licence or higher in it's requirements.

 

 

[coljones]

I think most here have agreed this to be the case, just waiting on the New Ops Manual to remove the wording of private licence or higher in it's requirements.

The PPL or higher relates to the medical standard required to instruct in RAA. See Ops manual 2.10 b 2. see#8 above http://www.recreationalflying.com/threads/raaus-to-rpl-conversion.124449/#post-449595

The Ops manual provides the basis for flying PIC in a RAA plane. CTA access is controlled by 25.10 (as amended) rather than the RAA Ops manual and has recently been revised to account for Part 61 licences.

 

 

[rhysmcc]

The PPL or higher relates to the medical standard required to instruct in RAA. See Ops manual 2.10 b 2. see#8 above http://www.recreationalflying.com/threads/raaus-to-rpl-conversion.124449/#post-449595The Ops manual provides the basis for flying PIC in a RAA plane. CTA access is controlled by 25.10 (as amended) rather than the RAA Ops manual and has recently been revised to account for Part 61 licences.

I'm referring to Section 2.01 of the RA-AUS Operations Manual

 

6. Controlled Airspace a) holds a current and valid private or higher category pilot licence with CTA endorsement

 

 

[coljones]

I'm referring to Section 2.01 of the RA-AUS Operations Manual6. Controlled Airspace a) holds a current and valid private or higher category pilot licence with CTA endorsement

You may well find that the Ops manaual 2.01 6 d) and the revised 25.10 6.4 (d) and (e) covers that in that the written approval is 25.10. But you do have a point.

Maj and Andy, can you impress on the board the necessity to have the draft ops manual out for review so that this forum can fix it up?

 

 

[rhysmcc]

You may well find that the Ops manaual 2.01 6 d) and the revised 25.10 6.4 (d) and (e) covers that in that the written approval is 25.10. But you do have a point.Maj and Andy, can you impress on the board the necessity to have the draft ops manual out for review so that this forum can fix it up?

It's 6.1 (b) of the CAO that states it must be flown in accordance to the Ops Manual, as far as i can see that's not changed in 25.10.

 

However that shouldn't stop you from doing a RPL flight review/training in a RA-AUS aircraft as you're using the instructors license anyhow which does comply. Just no flying solo in CTA until the Ops Manual is updated. Was told it's a while off, being released to CFIs at the conference in Nov, not sure what happens after that.

 

 

[Vev]

It's 6.1 (b) of the CAO that states it must be flown in accordance to the Ops Manual, as far as i can see that's not changed in 25.10.However that shouldn't stop you from doing a RPL flight review/training in a RA-AUS aircraft as you're using the instructors license anyhow which does comply. Just no flying solo in CTA until the Ops Manual is updated. Was told it's a while off, being released to CFIs at the conference in Nov, not sure what happens after that.

Well done rhysmcc,

 

I guess the issue now is to get this recognised by the folks at CASA .... as Dr Zoos says, that dispite the number of contracts he has made with CASA they don't seem to understand the details of this issue behind the flt review process in the transition from RAA to an RPL.

 

It would be great to get these reviews done on one ac instead of jumping out of one RAA reg into a VH reg aircraft of the same make and model.

 

Cheers

 

Vev

 

 

[DrZoos]

Hows this for a contradiction of other clauses ???

 

 

 

61.480 Grant of recreational pilot licences in recognition of pilot certificates granted by certain organisations

 

(1) This regulation applies to an applicant for a recreational pilot licence if:

 

(a) the applicant holds a pilot certificate, granted by a recreational aviation administration organisation that administers activities involving aircraft of a particular category; and

 

(b) the certificate permits the holder to act as the pilot in command of an aircraft of that category.

 

(2) For subregulation 61.475 (2), the applicant is taken to have passed:

 

(a) the aeronautical knowledge examination; and

 

(b) the flight test;

 

for the licence and the associated aircraft category rating.

 

Subregulation: 61.475 Requirements for grant of recreational pilot licences

 

(2) Subject to regulation 61.480, the applicant must also have:

 

(a) passed the aeronautical knowledge examination for a recreational pilot licence and the associated aircraft category rating; and

 

(b) completed flight training for a recreational pilot licence and the associated aircraft category rating; and

 

 

 

 

This in my opinion possibly indicates we dont even need a flight review ??? Although other clauses say we do??