MARAP

[Kyle Communications]

This is interesting. Would be nice to be able to apply for a MTOW increase on a amateur built. Say I have a kit I build that can go to 750KG why can't I apply using this process to get my MTOW up to 750 or say 650 or even 700 kg?

 

 

[Nobody]

MARAP is a bit cryptic for me. Do you mind elaborating?

 

 

[ave8rr]

MARAP is a bit cryptic for me. Do you mind elaborating?

https://www.raa.asn.au/marap-faqs/

 

Mike

 

 

[Kyle Communications]

An amendment to CAO 95.55 was released on 24 February 2015. The amendment will allow Recreational Aviation Australia (RA-Aus) to authorise and permit modifications to RA-Aus registered type certified and amateur built aircraft. This process does not apply to LSA aircraft. These amendments are in the form of 2 new subparagraphs (1.2 (d) (iv) and 6.1 (f) (iv)).

 

Apart from this, there are no changes to the existing contents of CAO 95.55 except for updating certain provisions, including the exempting provisions mentioned in section 3. The changes only involve removing outdated references that are no longer in force and replacing them as necessary.

 

In relation to the amendments of CAO 95.55 that permit RA-Aus to approve modifications to RA-Aus registered type certified and amateur built aircraft, these have been agreed after CASA was satisfied with the relevant procedures set out in the RA-Aus Technical Manual amendments. A MARAP frequently asked questions document (FAQ) is available under the Technical tab on the website or by clicking here.

 

MARAP will enable members to apply to modify their type certified and amateur built aircraft. Some examples of modifications include but are not limited to engines, propellers and MTOW increases. In some circumstances applications may take up to 12 months, however in others the time to process the application may be shorter.

 

Recreational Aviation members will be able to make application using the Tech Manual form 014. Members will also be required to complete and provide an Aircraft Condition Report (ACR). Section 7.4.3 Annex B of the Technical Manual covers this requirement, which must be completed by a suitably qualified RA-Aus L2 privilege holder.

 

When an application is received the Technical Manager will review the application and make the initial decision to accept or refuse the application based on the information supplied by the applicant with Tech Form 014. In some circumstances the Technical Manager may request further information for clarity and/or additional data.

 

Members should follow the below 5 steps to familiarise themselves with the formal application process. Recreational Aviation Australia will further advise members of the necessary processes to follow as they become available. Any initial enquiries can be sent to [email protected]

 

Step 1 – read the FAQ

 

Step 2 – read MARAP process document

 

Step 3 – download tech manual form 014

 

Step 4 – Arrange completion of an Aircraft Condition Report

 

Step 5 – Deliver the completed documentation package to [email protected] or mail it to PO Box 1265, Fyshwick ACT 2609.

 

 

[jetjr]

Just got the email announcing this new "assistance" package, Friday afternoon.........

 

All great for type certified aircraft, theres now a process to change things

 

But for owners of 19, it appears they are getting massive changes

 

Reads to me that owners of 19 reg aircraft now have to get part 21 engineers, L2 and RAA tech team involved to modify aircraft in any way. Pay all of them.

 

I thought LSA was a screw up preventing experimental development, its looking looking easier.

 

Builders are OK, but after they sell nothing can be modified without this process.

 

Experimental Jabiru owners get a second rogering this time thanks to RAA.

 

So every SB Jabiru (that involves new bits) come up with or someone else comes up with a fix we have to go through this individually??

 

 

[fly_tornado]

Involving a sub part 21.M engineer will mean any mod will be expensive, as they accept the liability of any modification, instead of the owner of the #19. Which could be huge if its a 2 seater.

 

Maybe one of the RAA technical staff can clarify this better?

 

I know, I know call the office, we'll get back to you.

 

 

[fly_tornado]

Then you have to get an L2 to sign off on an ACR, again if they are taking liability for this it won't be cheap.

 

 

[dazza 38]

Just got the email announcing this new "assistance" package, Friday afternoon.........All great for type certified aircraft, theres now a process to change things

But for owners of 19, it appears they are getting massive changes

 

Reads to me that owners of 19 reg aircraft now have to get part 21 engineers, L2 and RAA tech team involved to modify aircraft in any way. Pay all of them.

 

I thought LSA was a screw up preventing experimental development, its looking looking easier.

 

Builders are OK, but after they sell nothing can be modified without this process.

 

Experimental Jabiru owners get a second rogering this time thanks to RAA.

 

So every SB Jabiru (that involves new bits) come up with or someone else comes up with a fix we have to go through this individually??

If somebody who scratched built a aeroplane, registered 19. Would they still need sign off for mods ?

 

 

[fly_tornado]

From what I am reading:

 

If you're the builder of a #19 or ELSA you can continue to mod it, if not it now looks like you have to go through MARAP.

 

If your aircraft is registered ELSA and you are not the builder you can modify without manufacturer's approval.

 

 

[jetjr]

Have to call Monday, old CASA trick, send things out friday arvo so no one can question it for a few days.

 

Love the new consultative RAA processes

 

Ive emailed Darren, but its pretty clear this is the case, only the BUILDER can modify without approval not the subsequent owner. First time theres been a difference in RAA that Im aware.

 

CAA have similar rules and it has stifled any improvements or development. Need to get approvals for new brand of oil filter.

 

yes re L2 ACR, and they have to fill out forms for you.

 

LSA and VH experimental are now easier to live with. Big hit to used 19 reg aircraft. This freedom to modify was the only thing making them attractive.

 

Whole point was these aircraft didnt meet stds therefore cant be used for training or CTA.

 

No mention of existing aircraft and their status, I would assume they are all grounded until MARAP completed for every modification since builder sold it

 

The MTOW upgrades would only be up to 600kg, thats the catagory limit.

 

 

[fly_tornado]

I'm wondering what point you need to do a MARAP though?

 

The FAQ is saying changing engine, propeller and MTOW and it only applies to "some" amateur built aircraft.

 

What if you or a previous owner has changed the windscreen material, size of tyres or the fuel hoses, these are common replacement items in any maintenance process.

 

The odd thing is they use the example of not being able to change a #24 Jabiru to an auto based engine but can you now put a Rotax into one and use it for training?

 

The biggest problem I see for this process is where you have professional engineers signing off on old experimental aircraft.

 

 

[rhysmcc]

You can't use this process for LSA and it isn't required if you built 51% of the aircraft (since you can do these things already), from what i can see on the RAA page anyhow.

 

 

[kasper]

Then you have to get an L2 to sign off on an ACR, again if they are taking liability for this it won't be cheap.

Level 2 are never signing responsibility with an ACR - it is just a statement of condition on the day and not any form of guarrantee

 

 

[Guest Crezzi]

I don't have much to do with kit built so won't comment on the concerns regarding those but it seems to me there are a lot of winners with this.

 

Factory built aircraft for which original parts are no longer available now have a means to get approval for modern replacements without involving a 21M engineer. I think there have been threads on here previously about some such difficulties e.g Gazelle props - an easier solution must surely be a good thing & should be applauded ?

 

Cheers

 

John

 

 

[jetjr]

Yes for type certified there might be advantages, but not clear how its different. They certainly DO need a part 21 engineer under this setup too???

 

Yes, LSA have to follow manufacturers approval, however dopey.

 

Exemption for E LSA doesnt make sense they are the same as 19?? I thought.

 

Builders are OK too

 

What about the bulk of aircraft with 19 reg and second owners?

 

Until now owners had the same rights as builders. This is a fundamental change to RAA.

 

Id say its assumed "modification" and repairs" fall under std CASA definition which is basically everything.

 

Reads that RAA will get a Part 21 to oversee EVERY modification. Who is wearing liability? Going to be very expensive

 

Talk of accepting group proposals - who is paying after the initial group?

 

Could read that they have dragged 19 reg down into Type certified requirements with none of the privileges.

 

 

[jetjr]

From Draft AC 21-8, Approval of modification and repair designs under Subpart 21.M

 

2.1.5 Repairs

 

2.1.5.1 A repair, in the context of this AC, is a design change to an aircraft or aeronautical

 

product intended to restore it to an airworthy condition after it has suffered a defect.

 

2.1.5.2 A repair may be permanent or temporary.

 

Note: Aircraft return to service without repair cannot be approved under Subpart 21.M, nor can damage or a

 

defect be considered a modification. See AC 21-28 for more information on approval of permissible

 

unserviceabilities under regulation 21.007.

 

2.1.6 Modifications

 

2.1.6.1 A modification is a change to the design of an aircraft or aeronautical product which is

 

not a repair.

 

2.1.6.2 A modification may be any one or a combination of a physical design change, or a

 

change to an operating envelope, performance, operating characteristics, limitations or ICA. The

 

change can be a single change or a collection of changes.

 

2.1.6.3 Approval of an aeronautical product (including materials) as an alternative to an

 

aeronautical product specified in the approved design of an aircraft or another aeronautical

 

product may also be approved as a modification under Subpart 21.M. See subsection 4.4 for

 

more information on approval of alternative products.

 

Note: Approval under Subpart 21.M does not constitute approval for the purposes of approval of required

 

instruments or equipment under the operational regulations (e.g. regulation 207 of CAR).

 

2.1.6.4 A modification/repair design may provide for the use of commercial/off-the-shelf (COTS)

 

parts. However, the showing of compliance approved under regulation 21.009 for the design

 

must include the part(s). See subsection 4.3 for more information on COTS.

 

Then goes on to say aircraft under RAAO are exempt!!!

 

 

[Guest Crezzi]

Yes for type certified there might be advantages, but not clear how its different. They certainly DO need a part 21 engineer under this setup too???

The latest CAO 95.55 linked in the doc makes it clear that part 21 engineering approval is NOT required if it is approved by RAAus under the new process

 

Cheers

 

John

 

 

[jetjr]

Read the RAA doc it says RAA will get approval from Part 21M engineer.

 

14.The Technical Manager can refuse to issue an approval, (RA-Aus will not approve any modification without the support, acceptance (or similar) of a Subpart 21.M Approved Person.)

 

Not understanding as document above says RAAO exempt then RAA is implementing same process.

 

Only difference I see is RAA are doing administration not CASA.

 

 

[Garfly]

Herewith, the correspondence I've just had with Darren on the issue:

 

Dear RAAus,

 

Surely I’ve got this wrong! Right?

 

I’ve read the FAQ.

 

Are you really saying that as of RIGHT NOW (without so much as any discussion or warning)

 

I am suddenly unable to make any alterations to my bought - not built - 19 aircraft without going through

 

an expensive and time wasting process?

 

(Presumably, even clearly safety enhancing alterations like, maybe a parachute or better fuel tank or whatever.)

 

I must have it wrong. Nothing so drastic could come out of nowhere in a democracy.

 

And it’s being touted as a WIN? I’m missing something.

 

I must have it wrong. But if I haven’t got it wrong. Well may you say ‘STAY CALM’.

 

It’d back to GA then. Or LSA experimental. Or something.

 

-----------------------------------------------------------------------------------------------------------------------------

 

G’day Gary,

 

In regards to 19 Amateur builds, MARAP is only applicable to those who have purchased the aircraft from either the original or second plus owners. As the current rule states, A person or group of persons must fabricate or manufacture the major portion (51%) for education and recreation that then allows them to gain the ability to modify and maintain the aircraft. If the original owner did the mods on behalf of subsequent owners this is totally legal.

 

MARAP was intentionally designed for the type certified legacy or heritage aircraft that over time have been modified. The problem was back in the day they wasn’t any ability in legislation that allowed it unless it held an Australian type certificate.

 

All items that have been previously incorporated on amateur builds will remain valid and we already have a few processes underway to help members with major concerns. This will be a step forward for most of the membership who in the past have not had clear direction and have down various mods under a shadow of doubt.

 

This is a new process that is designed to aid the membership with a path to compliance that RA-Aus or the old AUF never had. This in time will show that we are compliant and will aid the management team when we approach CASA to increase the members privileges

 

Happy to assist further or discuss next week. Thanks for taking the time to ask these questions and please feed this back to the membership or get them to shoot me an email.

 

Regards,

 

Darren Barnfield

 

National Technical Manager

 

CASA Authorised Person 1-13BVSM issue 01

 

Part 66 License 434006

 

-----------------------------------------------------------------------------------------------------------

 

Dear Darren,

 

thanks a lot for taking the time to get back to me.

 

I’m still a bit vague. It seems to me to be very widely (mis)understood within the rec aviation community

 

that even second-hand 19 aircraft can be modified (of course, only by approved qualified people).

 

And that this new MARAP regime will seem to represent a major change to that arrangement.

 

Seemingly out of the blue.

 

I am relatively new to the RAAus scene, but from all the listening and reading and socialising

 

I’ve done over the past couple of years it seems everyone I come across has the above understanding.

 

Apparently all wrongly.

 

So I imagine that this will really be throwing a cat among the pigeons.

 

No doubt it will all become clear when the smoke clears but my current take on the issue

 

is that the intended (good) consequences of this change will be quite overshadowed by

 

the (bad) unintended (?) consequences. Another regulatory/engineering morass.

 

But, again, I’m sure I’m not yet really getting it.

 

But let’s just take the examples I mentioned. Would I need to go MARAP to get an airframe parachute

 

installed on my second-hand Skyranger? Or, if I was to think about installing the new Aussie designed

 

wing tanks (an improvement developed with the cooperation of the original French designer) ?

 

If so, I probably wouldn’t bother with either. For no good reasons. None at all.

 

Quite the opposite.

 

And to what regulatory end?

 

all the best,

 

Gary.

 

 

[jetjr]

I got exact same response email from Darren.

 

All pretty proud of themselves

 

Seems anyone with old non Australian type cert ie. imported, is happy. How many of them is there?

 

Meanwhile second hand 19 get a major change.

 

I agree everyone i know in Raa believes 19 can be modified including manufacturers and far more qualified people than me. and im yet to see otherwise.

 

Isnt even a section on mods to 19 in the tech manual

 

Even 95.5 and new AC21 say RAA is incharge of this so it is a new change stuffing up many 19 reg owners

 

95.5 outlines which aircraft are exempt, no question they comply

 

All mod information in manual reltes to 55, 25 and 55 registered

 

If it isnt limited then it is legal.

 

I had this debate at length with RAA a couple of years ago.

 

 

[Garfly]

Yeah, and whereas I'm very happy to see owner-builder mates benefitting from that exemption, it makes hardly any sense from a safety perspective.

 

A builder - with a bad attitude - is as capable of making dodgy mods as is a downstream buyer of similar disposition. What's the point? What's going on?

 

 

[robinsm]

empire building?

 

 

[fly_tornado]

Groan, so all the faulty rubbish sitting in barns across Australia built with Bunning's nuts and bolts is legal. But anything modified after this is illegal without an engineer's approval?

 

 

[jetjr]

Yeah, dont want to go theough MAPRAP so will remove all the well thought out modifications and revert to pre 2005 Jabiru bits. Everyone knows they were at the top of their game back then.

 

Ditch the new brake calipers, the 6 channel dynon , AP. Better remove new oil coler that works and refit one whoch was prone to exploding and didnt work. How about the exhaust gaskets that leaked CO onto cabin and needed replacement every 50 hrs, Oh and old heads and prop which allowed redline op temps and vibration which made dash shake so much you couldnt see it

 

Guess the wire and baling twine used to fix control cables will have to go back on too.

 

OR i could just say it was like that when I bought it.

 

 

[Garfly]

One reading of the third par of Darren's letter:

 

"All items that have been previously incorporated on amateur builds will remain valid and we already have a few processes underway to help members with major concerns. This will be a step forward for most of the membership who in the past have not had clear direction and have down various mods under a shadow of doubt."

 

... suggests that modifications completed by March 20th 2015 will remain 'valid' for non-builder owners of 19-xxxx aircraft. Okay, so actions that were valid last Thursday are now, presto, invalid. So that implies an overnight change of law, right?

 

So why were people not given due warning so that they could, say, have a parachute fitted - or even a windscreen replaced - before administrators and aeronautical engineers became involved and tripled (?) the cost? And/or grounded the aircraft for a year while a far-away boffin researches the myriad design features of the ... let's see, of the ... Acme SuperFlyer MkIIIA, 1965 model - and finally consults his insurance broker on the likely premium-hit for signing off on that particular (heretofore perfectly allowable and unremarkable) modification.

 

Darren reassuringly refers to having "a few processes under way to help members with major concerns".

 

Well, here's a few more Q's I'd add to those 'Frequently Asked' ones:

 

What are those processes?

 

And where is the list of foreseen circumstances and possible exceptions they address?

 

And ... if a member happens to be planning to finish off some (once legal, now illegal) mods to his or her aircraft this very weekend, should he or she down tools immediately, ground the aircraft, and start form-filling?

 

And how, by the way, is the safety and integrity of the fleet now 'compliant' and properly under-control when it's only the second-hand 19 rego'd aircraft that are covered by this new (and oh, so vital) ruling? How is this protecting anyone in any meaningful way?

 

Also this sentence also has me wondering:

 

"This in time will show that we are compliant and will aid the management team when we approach CASA to increase the members privileges."

 

If the management team is facing problems with the regulator and is trying to find ways to solve them, even exploring ways to get us extra privileges (Class-C transit ? ;-) why wouldn't they explain that to us; involve the membership in the problem and in the process? In the likely costs and benefits? We're adults, we can handle a little detail. (Hell, we've even passed the Human Factors exam!) Maybe then, as a group, we'd come over a bit appreciative of management efforts. As, no doubt, we should, really.

 

But why this top-down approach? Springing nasty surprises on us, so that we're just left wondering why.

 

There is now even a regular email newsletter. How about less coverage of staff members' hobbies and favourite colours etc. and a bit more meat. What are the problems, really? What is CASA demanding of us and why? What more might they offer us and what not? And for what quid pro quo?

 

It seems that government by captain's-call is catching in Canberra.

 

But hey, Prince Phillip can keep his new lifetime Pilot Certificate just as long as I can have my windscreen competently replaced without the whole world needing to get involved. Why else are we in RAAus?

 

And frankly, the whole world has better things to do.