RA Ops Manual

[dodo]

Has anyone read the new Ops manual? A few interesting new rules and limitations, as usual without consultation...

 

One nice one is that you can't let anyone else frly you plane unless they do it with an instructor (or have prior experience on the type). A few others that seem odd...

 

Any opinions? - after all, it is the majority of the rules we fly under that differentiate us from GA!

 

dodo

 

 

[Geoff13]

Yep I have read it. Not sure if I have adsorbed it all yet. I am not sure that I would want anyone to fly my plane unless they had experience on the type that is assuming of course that I had a plane. And I am sure that at this stage I certainly would not want to fly any plane without experience on type or at least with an instructor beside me.

 

Cheers Geoff13

 

 

[dodo]

"at least with an instructor beside me"..... Might want to make that "Pilot Examiner"

 

dodo

 

 

[turboplanner]

Has anyone read the new Ops manual? A few interesting new rules and limitations, as usual without consultation...One nice one is that you can't let anyone else frly you plane unless they do it with an instructor (or have prior experience on the type). A few others that seem odd...

 

Any opinions? - after all, it is the majority of the rules we fly under that differentiate us from GA!

 

dodo

Do you mean only an instructor can walk out to the apron and fly off in your plane, or only an instructor can fly your plane if you are in it.

If it's the second case, that just brings things into line with an existing CAR

 

 

[dodo]

I meant both cases I think . . I think I am now more confused.

 

I think I mean you may not fly my plane unless you have flown that particular make and model before eg Jab160

 

dodo

 

 

[dodo]

I rad it again, and my initial conclusion was wrong. Howver, I am still confused as to what sort or aircraft I could legally fly. I think the definition of type is unclear...

 

dodo

 

 

[Camel]

TYPE TRAINING

 

13. No Pilot Certificate holder shall operate a recreational aeroplane as pilot in command without having demonstrated competency on Type. Aeroplane Type Training must be undertaken with an RA-Aus Examiner who holds the respective aeroplane group and type.

 

The RA-Aus Examiner is required to make an entry into the pilot’s logbook detailing confirmation of the training undertaken and achievement of competency in accordance with Section 2.02 of this manual.

 

Note: Logbook entries showing a minimum of 2 hours pilot in command of an aeroplane type recorded prior to Issue 7 of this manual will be accepted as evidence of appropriate type training for that aeroplane.

 

Pilot Examiner (PE)

 

An RA-Aus Senior Instructor, eligible to be a Chief Flying Instructor and approved by the Operations Manager to examine recreational pilots and instructors.

 

RA-Aus Examiner

 

Means a Senior Instructor, CFI, PE, ROC, Assistant Operations Manager or Operations Manager, within the scope of their privileges, as detailed in this manual.

 

........

 

You don't need a " PE " but a senior instructor minimum. You do not want someone who can't fly your plane flying it. If you can fly it easy use the 2 hours to brush up other training, if you can't afford training then this sport is not a good idea. Training is cheap compared to damage or injury. When I changed aircraft type I took some lesson even though it was not a requirement and I have done this many times.

 

 

[flyerme]

So is aircraft type referred to as

 

LP tw

 

Hp tw

 

LP nw

 

Hp nw

 

Ect....?

 

Obviously it can not mean literal, as no one could take off in their new single seat

 

Eg .. One of a kind home built single seat .

 

 

[dodo]

Thanks Camel, but this still leaves the definition of type unclear. I can make some obvious guesses, but as "type" is clearly important, it‘s definition should be clear.

 

I agree a couple of hours training is seldom wasted, but I don't think that is a good approach to reading the Ops Manual,

 

dodo

 

 

[djpacro]

http://en.wikipedia.org/wiki/Type_certificate

[kaz3g]

I think "type" is interchangeable with "group" but I agree it isn't very clear. Group A, for example, is three axis.

 

Kaz

 

 

[Camel]

Thanks Camel, but this still leaves the definition of type unclear. I can make some obvious guesses, but as "type" is clearly important, it‘s definition should be clear.I agree a couple of hours training is seldom wasted, but I don't think that is a good approach to reading the Ops Manual,

 

dodo

If you fly a jabiru 160 it is well known that jabiru's handle very similar so that would be acceptable to fly other types of Jabiru I believe, but if you fly a foxbat then to fly a Jabiru would be a big change. I found a Sportstar very easy to fly but some people had trouble with toe brakes as use to single hand brake. I believe some discretion will always be required as some homebuilts are unique and some people have not seeked training in similar types and come to grief. A very capable Sportstar pilot could not fly a Jab well as on landing would pull power too early and flare too high but he had company who helped !

There are many variations in aircraft out there hand brake or toe brakes, castoring and steerable nose wheel, vernier and push throttle, yoke or stick, centre or side stick, air cooled or water cooled, low or high wing, side by side or tandem, etc . These are features of types I suppose and can take time to get use to, these things are not endorsements.

 

If you built or bought a plane say one of a kind or no instructor was familiar with and it had all the features you had used before and flown similar performance I'm sure no one would object to you being capable and suitably endorsed to fly, it would be worth a call to ops to reassure this.

 

I believe ops have taken a sensible approach as many accidents occur due to unfamiliar on type, I believe there will always be exceptions as some pilots will have so much experience on various types as a few more features wouldn't be a problem. The specific definition in RAA ops is not clear but I take it as don't fly something your unfamiliar with and I'm sure that is the intent.

 

To learn to fly say 25 hours, to be totally comfortable in another totally different type say 25 hours, maybe less but that's my opinion.

 

 

[Guest Crezzi]

I think "type" is interchangeable with "group" but I agree it isn't very clear. Group A, for example, is three axis.

"Group" is defined in section 2.04 e.g. 3-axis, weightshift etc

 

Camel's post above is a pretty good definition of "type" AFAIK

 

Cheers

 

John

 

 

[DWF]

From the new Ops Manual (page: Abbreviations and definitions - 2):

 

 

 

Aeroplane Group

 

See Section 2.04 for designations, which are generally divided by control design e.g. Group A – three axis control aeroplane.

 

 

 

Aeroplane Type

 

Aeroplane undercarriage configuration, design features, flight envelope (e.g. high drag/low drag and considerations of inertia), stall speeds and normal/emergency handling characteristics as designated by the manufacturer.

 

 

 

DWF

 

 

[kasper]

Starting at the top and going to bed before Pilots Certificates I came up with the following issues with the current Ops Manual issue 7

 

1.01 overall structure of the section - it is one section covering as I read it at least 4 separate areas and there’s is not a paragraph number in sight ... even though there are 3 sets of sub-paragraph lettering. Very difficult to reference into this area as its drafting is very poor.

 

1.01 "The Operations Manager will in turn approve the following qualifications"

 

Poor drafting - the listed areas below are not qualifications but a collection of variously named parts of the RAA structure being certificates and approvals and are not otherwise referred to as qualifications.

 

This should be tightened up in terms of language for precision.

 

1.01 Required to possess recommended documents

 

It is not good drafting structure to require anyone to possess recommended documents particularly as they are recommendations from various personnel without any form of documentation as to what has been recommended and when. The structure should be such that what is REQUIRED is very clear and specified and if there is uncertainly and flexibility then they should be recommendations.

 

In addition what IF you fail to possess these what is the issue? What is the sanction?

 

1.02

 

General - this is not a pure statement of duties and responsibilities as it contains the core of several actual powers eg right to suspend or cancel pilots certificate without investigation. It would be better structurally to separate explicit powers and make them nice and clear and put duties and responsibilities in a clear separate section that references the powers that the ops manager has duties and responsibilities in relation to.

 

Para 6 drafting is inconsistent - ROC is defined in the top and even in the preceding paragraph referred to by the defined abbreviation of ROC yet in this paragraph is spelt out in full.

 

Para 8 drafting is in error - clearly the words 'the issue' are missing from the start of the sentence as it currently is not an English sentence.

 

Para 15 as the power to immediately suspend or cancel a pilot certificate is an ultimate removal of permission held by a member the fact that it is held by the Ops Manager would ordinarily be very clearly set out ... current language of 'likely to reoffend' is quite imprecise and does not provide a lot of clarity/certainty to anyone as to when the power can be legitimately exercised and when it cannot. I would suggest that this area needs to be considered and the power more explicitly clarified this very expansive power.

 

Para 16 language structure does not follow other areas and allow delegation of accident, incidents when requested by various listed personnel - where is the power to delegate to regional personnel or anyone for that matter?

 

1.03

 

General - same comment in relation to separating powers that need to be explicit from duties and responsibilities that are part of the duty of the role holder.

 

General - unless there are parts of the Ops Manager role that cannot be delegated (like accident/incident investigation - yet it APPEARS to be delegated here ???) it is a simpler form of drafting to state that the Assistant Ops Manager can exercise any or all powers of the Ops Manager and undertake the duties as specified by the delegation provided. This preferred structure is actually used in the next section 1.04 to reference the Pilot examiner into the ROC.

 

1.04

 

General - Same comment on separating powers as 1.02 and 1.03

 

General - what is the specific purpose of requiring some delegations or requests to be in writing and others not within the statement of duties and responsibilities? If it is not for a specific reason then I would suggest that the drafting be made consistent throughout all sections.

 

Para 8 - clearly envisages Ops Manager delegating investigations yet the ops manager duties and responsibilities does not allow this delegation explicitly yet is explicit on others - legal construct rules would lead to the conclusion that it can’t be delegated yet is - very poor and inconsistent structure thought the entire section

 

1.05

 

General - general as per 1.02-1.04

 

Para 7 - structure - it’s a very strong power and its very imprecise

 

- Ops manager receives a complaint - how and from whom?

 

- mixed language - Shall undertake a report = must, but in the same Para a required action to write a report is 'will' report and required elements in the report are set as 'will' and then are set out not as a list of aspects/requirements that must be considered but very general but comprehensive.

 

Structurally it would be far clearer to have a separate section setting out what an investigation is and must cover/report (the power section) and reference into roles and duties of the appropriate personnel the ability/duty to undertake or exercise the power.

 

1.06

 

General - as per proceeding

 

Para 2 - a real minefield as the language requires that aircraft hire must be to 'RA-Aus pilot Certificate holders of the Flight Training Facility"

 

- Pilot Certificate is a defined term and I can only assume that the lack of capital P on pilot is a simple error

 

- the concept of an RAA-Aus Pilot Certificate holder being 'of' an FTF is entirely new ... what make me a Pilot Certificate holder of the FTF and what particular requirements/obligations exist both ways between the FTC and the Pilot Certificate holder? This area really needs exploring and explaining.

 

Para 6 - is this a general power to recommend about any/all Pilot Certificate holders as to suspension/cancellation or just the Pilot Certificate holders of that FTF - whatever that means. And why if they are to be eyes and ears of the Ops Manager in this respect what not extend it to Approvals as well as Certificates, Endorsements and Ratings?

 

Para 8 - dogs breakfast of structure - How can a CFI appoint a Senior Instructor in the first sentence when the power is restricted to the Ops Manager in the second sentence of the same Para! And of course it requires an SI to be appointed - what about single CFI flight schools - are they no illegal or forbidden???

 

Para 11 - when does the requirement of the CFI to report exist separate to the Pilot in command or does this mean dual reporting requirements and what if the CFI does not report?

 

1.07

 

General - same as proceeding

 

Para 7 - OK I can get the requirement to notify CFI of unserviceable or aircraft unsuitable for training in the FTC but Hmmmm How do I 'ensure' that the fault/defect is repaired ... I am not the L2 or LAME so is it a documentary thing and what must I see to prove I have ensured it is done ... answers on a postcard for the litigation from family of injured when something goes wrong.

 

Para 8 - nice to see recency requirements in Senior Instructors ... but as it is not in the CFI I assume that they are not required to remain recent? No? well maybe there could be a bit more consistency.

 

Para 9 - same comment as per CFI on this area

 

1.08

 

General - same as preceding

 

rest as per 1.07

 

Note - going to bed at this point because sarcasm is creeping in.

 

 

[SDQDI]

Have you ever considered counting sheep?

 

 

[DWF]

Well done kasper.

 

I hope you have passed your suggestions on to RAAus Ops.

 

But don't give them your real name unless you want a job rewriting the manual!

 

 

 

I don't think your list is complete yet so read on.

 

 

 

DWF

 

 

[kasper]

Well Don the RAA declined to interview me for the exec position when it was created so I'm not likely to want to volunteer to do a major piece of work for them when we have in place reasonably well paid personnel who have this as their actual job ;-)

 

But yes, I had a few more hours of boredom to kill so I looked into the grab bag of certificate endoresements etc as it was likely to throw up areas I should then read in detail ... and the number of really basic and obvious head scratchers would lead the cynic in me to question the compentcy of the person who wrote the ops manual in terms of understanding the structure of the CAOs and the interaction of them with the OPs manual ... but I'm not going to be a cynic this morning.

 

Section 2.04-2 table inconsistencies

 

PAX not available for combined controls ... pray tell how the two seater HM1000 already registered can operate with the second seat? - its 2-axis thereore flown under RA-Aus as combined control as only option available - same as me on the HM290 since mid 1990's

 

X not available for powered parachute - why?

 

Formation not available for other than weight shift and 3-axis - why?

 

GT not available for other than 3 axis ... even though there are weight shifts notified under

 

CAAP as allowable airframes for towing

 

HGT not currently approved for other than 3axis and weightshift but it COULD exist for combined control as the HM1000 was cleared for it in France ...

 

NW not for weightshift or powered parachute ... please point out ANY of these aircraft with a tailwheel - they ALL have nose wheel or quadricycle and thats for a really good reason as all of us who fly them know

 

AP not for weightshift ... so they are saying that if I build a home built weighshift I cannot put a vari prop on it? Get real guys an girls, home built experimental is the main reason we have all these endorsements and to attempt to limit them by pilot when the airframe is not is not realistic

 

RU not for combined - yep, there are none out there today but same comment as AP, its possible on the airframe so why limit it on pilot certificate?

 

WF not for combined - sorry but the HM1000 is approved for floats

 

FH not for combined - same as RU, not yet but you shouldn't limit operations on certificate that are permitted on the airframe

 

APA only for 3axis - really? are you saying that because I am combined control and weightshift I can't be considered advanced? Just because I can't perform elements of the requirements for the endorsement (slipping and uncoordinated flight etc) does not mean I should logically be excluded - like the training syllabus do a Group B specific one if the endorsement is actually at all useful - can't for the life of me see what its for other than bragging rights. Or we could look outside in the bigger world scene and discover that for advanced microlight/ultralight pilots there is this big organisation called the FAI that we are not a member of that already has multi staged advanced awards called the Colibri awards.

 

 

[kasper]

Had some more sleepless time to kill.

 

Simple and general thing - Abreviations and Definitions

 

As a rule anything that is in the abreviations section should be used in the document and similarly definitions should be used in the document - we have many abreviations (eg - ASRA, OCTA, SAAA, SASAO, UTC ETC) AND defintions (eg - Similar Type (Aeroplane)) that are up front defined and then not used in the Ops manual at all.

 

As a rule anything that is used in the document with a possibility of being misintrpreted on basic english defintion (called a term of art) should be defined - we have fairly important terms of art in the Ops manual that are undefined.

 

Eg when you can have your certificate suspended the process used should be very clear as its a fundamental removal of priviledges ... pray tell where the term "RA-Aus Just Culture principles" can be found ... because under 2.14(3) they are central to the requirements of an investigation ahead of removal ... not in the Ops Manual and not on the RAA website if you search ...

 

As a rule when drafting a defined term you consistently identify that it is a term of art and a defined term and not plain english ... usually its by Initial Capitalisation or by italisisiation and even sometimes bold or even underlined but it really should be clear and consistent so you know if you need to apply a definition or if you just apply the english language as you like ... Ops Manual has three different uses - plain text, Inital Cap and Italics ... and even uses DIFFERENT methods on teh one term eg recognised flight time is both italic and plain text in the Ops Manual. Not good and not easy to keep track of.

 

As a rule if you are operating as a subordinate document to another where the definition is owned/controlled by that master document you would refer in a definition/abreviation section to the master document - Ops Manual doesn't do this - and is at risk of becoming out of alignment with any change in the master docs.

 

So that put me to sleep once. I'll keep reading but to be truthfull the Ops Manual 7 is so oddly written and inconsistent throughout that its hard to work through without just saying it would be far easier to start again with a clearer and more consistent framework and build it again.

 

 

[rankamateur]

kasper, sounds like they are regretting not interviewing you!