dazza 38 Posted March 20, 2015 Posted March 20, 2015 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? Hey, there is nothing wrong with Bunnings Aerospace.
jetjr Posted March 20, 2015 Posted March 20, 2015 Yeah Ive spent 8 years fixing the builders shortcuts and poor work or otherwise sorting out Jabiru shortcomings. Feedback from some on the board is that its always been illegal for non builders to mod aircraft so bad luck, great news there is a process to have it all Ok now. And it has been thoroughly canvassed to members, they cant contact them all as thats why we have a professional board!!! Might want to tell all the owners, many L2's , Jabiru, CAE, and others who all believed when I asked them in the past that its Ok to modify 19 reg. Upon reading it seems actually simpler and maybe cheaper to modify under CASA than RAA now. why the *&(#$ do we stay?
Guest Andys@coffs Posted March 20, 2015 Posted March 20, 2015 Gents Have a search on these forums for a set of posts by a guy in SA who owned a lightwing, in his case reregistration proven to be a problem because the certification required a prop that wasn't manufactured anymore and he had a bolly prop fitted. Because there was no equivalent process available the only way he could be reregistered was to take off the superior bolly prop and replace it with something that at its time might have been Ok but by todays standards was suboptimal.......Finding one of these props required a significant and painful search.....he eventually found one and staggered back into the air........Today this process means the approach that either he, or the previous owner took, to replace the prop with he Bolly is achievable legally..... The Aircraft OEM could have solved this if they wanted......but they didn't want, the aircraft is no longer in production and is reasonably old.... Questions as to how many of these types of issues are there? There are heaps of these issues, everytime a manufacturer closes shop due insolvency or retirement or whatever or simply chooses to no longer support, then aircraft are left in a suspended state. I own, as second owner, a 19 registered J230 so the issues you are discussing are real to me, however the board has to do what is best for the majority of the membership. Our fleet in single hull isolation is simple, in sum complex, I doubt that any change to anything will ever produce a single positive result across the entire membership. My personal view is that this change is on balance much better than not. Its also the case that changes to 19 registered aircraft by 2nd or subsequent owners have always been a problem with no legal way forward (other than the builder....in my case he's either dead of old age or a mere 1500kms away from me...and was builder in name only...chequebook builder) . There is a legal way forward now...... So again, this process imho fixes much more than it breaks, and broken in this context is not a function of a bad place from which there is no way out, it merely, like everything in aviation, requires some $ to be spent........Its also my view (and not a board view) that if the legal impediment that would have prevented subsequent owners making modifications before did not do so, then neither will a process to remove the legal impediment, prevent those same owners doing what they want..... Andy BTW the board were aware of the marap process only slightly before you guys in that its an operational issue between the CEO and the Tech team, there is no question of strategy or governance and as such we leave it to those that are charged with the responsibility to deliver.....
fly_tornado Posted March 20, 2015 Posted March 20, 2015 I can see what MARAP is trying to achieve so why include #19 at all?
Guest Andys@coffs Posted March 20, 2015 Posted March 20, 2015 Because there was no LEGAL way forward....... exactly the same as every other case that MARAP deals with....... BTW the issues this process deals with are discussed in this thread http://www.recreationalflying.com/threads/the-effect-of-the-audit-dang.54171/
Keith Page Posted March 20, 2015 Posted March 20, 2015 Hey, there is nothing wrong with Bunnings Aerospace. What about Masters? KP. 1
facthunter Posted March 20, 2015 Posted March 20, 2015 It appears that all the advantages of 19 .... are gone and all of the restrictions remain? Not used for training etc. You can build a crap heap but you cannot improve one, that someone else built. Bad as GA, where you can't even fit a friction mechanism to the throttle. unkess yiu are young enough to spend the years getting the change approved Nev 1 1
fly_tornado Posted March 20, 2015 Posted March 20, 2015 The problem I have with this is it looks like you are rewriting the law to suit one group of individuals at the expense of others. The idea that the non building owners of experimentals don't gain some educational benefit from owning and modifying their aircraft is completely false. 3
dazza 38 Posted March 21, 2015 Posted March 21, 2015 So in a nut shell, a person who builds the aircraft can still modify it if they want to. But a person who buys a 19 registered aircraft cannot carry out any improvements without going through all the MARAP crap.
fly_tornado Posted March 21, 2015 Posted March 21, 2015 yes that's it, where as if you have a VH registered experimental the owner can continue to modify the plane but you require a LAME to do your annuals if you're not the builder.
kasper Posted March 21, 2015 Posted March 21, 2015 well i am playing the RAA are crap at drafting card again. this encapsulation of 19 reg into something needed to fix operational issues with 101,55 and 95.25 is entirely at the feet of RAA. CASA in 95.55 were very careful to not require non mod on 19 reg and under the CAO 19s are effectively the same as 95.10 on purchasers maintainer / mods. I think its time the BOARD told the EXECUTIVE that the POLICY is to maintain recreational flying with the minimum of admin and regulatory overhead Sorry Andy, the board may not need to be involved in the detail but they OWN the policy so when RAA add a requirement through the tech and ops manuals that are not written in the CAO the BOARD are responsible FULL STOP And bluntly I am not a happy bunny about this. 9
mAgNeToDrOp Posted March 21, 2015 Posted March 21, 2015 No doubt it will make it harder to sell your 19 registered aircraft. Resale value.... 2
fly_tornado Posted March 21, 2015 Posted March 21, 2015 Andy has the CEO or the tech manager advised you the costs this new process is likely to add to the cost of modifications? I know its a case of how long is a piece of string but consider the situation where you have a used #19 aircraft without factory support and it requires new parts being scratch built, the cost of the parts and paperwork is going to push the cost of the maintenance above a lot of comparable aircraft. As far as something like a Drifter goes, I can't see anyone buying a used one because they being so old and not having scheduled maintenance through out its operational life, the probability of spending big on an engineer to get small fixes applied. Something like a Drifter is not even worth much as parts because who is going to want to buy the parts? Very few drifters would be owned by the original builders. The situation of your Jabiru is the same, your potential buyer is stuck putting the dodgy Jabiru parts back into the plane and can't use anything that CAMiT or others develop. 2
facthunter Posted March 21, 2015 Posted March 21, 2015 The ONLY reason I back the RAAus is because I can modify and service my OWN aircraft. IF that's gone .It's all over Rover, for me. I want responsibility for my own planes safety. All the rules in the world won't stop the "BAD" guys doing dodgy stuff. It happens in GA, keeping an old mates $#!theap in the air. After he/she passes on, the real state of the plane becomes known. The reason an owner/pilot does it right is because it's their NECK........ IF that's not enough motivation, then there is no helping them. There won't be enough qualified people around to bother doing all this cover the ar$e stuff, which is peripheral to the real issues.. Nev 10
fly_tornado Posted March 21, 2015 Posted March 21, 2015 Ill be interested to hear from [uSER=852]@Maj Millard[/uSER] on this issue being the most technical experienced board member.
robinsm Posted March 21, 2015 Posted March 21, 2015 Sounds like the 19 ## aircraft people need another organisation that is not trying to be a CASA wannabe and alienate the members (and board). This is for RECREATION, and fun and other stuff, not a CASA over regulated organisation that is slowly but surely alienating the people that are its main supporters. The point about the servicing and parts for older aircraft is valid and I wonder what the reason for the changes are. As stated above, I fly in it so it is my responsibility to make sure it is correct, not a 3rd party. If do it, I know it is right and if not, then it is my fault and my responsibility only. 3
Keith Page Posted March 21, 2015 Posted March 21, 2015 facthunter is on to it. He says buy a pile of crap and you not aloud to make it safe, hello -- come on. I agree some of those kits are a bit tough to construct and one needs to have a lot of good knowledge to put it together. What facthunter is on to -- say a tough kit plus a lot of rip tare bust plus no thought going into the construction, then the builder is overwhelmed then they sell it on. The new buyer then has a big task of undoing and reconstructing almost the whole project. So where dose the CAO 95.55 amendments and advice from the Tech department fit into the dilemma? CAO 95.55 has some new amendments that is good but who will be interpreting these new amendments there is my concern. Because now when one calls up for an interpretation the answer is "That is what CASA said" or Is it? One of those old standard answers "That what they said" I am bit of cunning here -- all those theys have names. or Is it a case of over regulation? Looks like RAAus is letting over regulation creep in. Regards KP 3
facthunter Posted March 21, 2015 Posted March 21, 2015 I think they are cowed by CASA. This often happens in aviation. The company will be harder on you than CASA would have , to keep them away from the operation, and leave you (the outfit), alone. Keith, sometimes also there are some fairly ordinary aspects to a design, here and there, that you just want to improve on for your own piece of mind. like access to service points and inspection (as an example).Nev 2
fly_tornado Posted March 21, 2015 Posted March 21, 2015 so the tele conversation goes like: RAA: g'day CASA we need to find some way to keep these older type certificate airplanes airworthy. CASA: ok that sounds like a good idea RAA: these aircraft just need to allowed to be modified to use currently available parts. CASA: that shouldn't be too hard RAA: hey its us the RAA, come on. CASA: ok how about we ground a bunch of experimental aircraft whilst we are looking into this? RAA: where do we sign up?
Oscar Posted March 21, 2015 Posted March 21, 2015 It does seem a bit illogical to include all of the MARAP provisions for 19-reg aircraft. Any buyer of a 19-reg aircraft is (whether they realise it or not, and if they do not, then surely it is a problem of adequate INFORMATION rather than regulation), buying a basically unknown quantity. The phrase 'sold with all faults, if any' springs to mind. Buyers of 19-reg aircraft are - whether they make this decision as an informed decision or not - buying something that simply does not have the backing of an approved manufacturer with defined QC requirements. Certainly, there are checks: if I am not mistaken, there is a mandatory L4 inspection required before first flight, and there is also a re-registration L2 condition report required. Neither of those can, realistically, guarantee that other than visible problems have been identified. Such things as incorrect preparation of bonded surfaces, incorrect mixing ratios of bonding materials, incorrect post-curing of materials - even the use of unspecified materials in certain areas - cannot be realistically determined other than by (usually) destructive test methods. Inadequate corrosion protection of materials, the substitution of release materials by non-release materials that appear identical, the degradation of glues and such things as wood-rot in inaccessible locations, cannot realistically be determined without major strip-inspection. ( And it should be noted: some of those conditions are NOT limited to amateur-built/maintained aircraft - I am currently repairing and modifying a 55-reg aircraft that has both factory AND L2 -maintenance-work horrors that most people would not like to know about). I think that applying all of the MARAP procedure to 19-reg aircraft is rather akin to trying to make a silk purse from a sow's ear. However, I also believe that we should look at the benefits for 55-reg and 24 'C' reg aircraft, and in that respect, I believe that RAA has come up with a very respectable idea that people should applaud. 1 1
jetjr Posted March 21, 2015 Posted March 21, 2015 In discussions with board member, seems everyone here thinking they can as owners modify 19 aircraft is "incompetant" as are the L2 and manufactirers Ive been dealing with for 9 years Apparantly Its always been the case that only CAR35 can modify 95.5 aircraft.........? Now thats all fixed with MRAp He sees no reason to ground aircraft despite the CASR 21 saying Cof A should be surrendered immediately modifications are done. Keep flying guys its all ok, just keep being incompetant owners with no understanding of the rules we operate under. Oh and board members are working very hard for us advancing privaleges and keping RAA going, if i sont like it i should stand for election. On deeper reading i dont see who is to approved mods to E LSA. They are modified away from Factory LSA, cant acess Mod process.
fly_tornado Posted March 21, 2015 Posted March 21, 2015 ELSA require no approval to modify as best as I can tell. Owners aren't required to do 51% of the work either but they have to build the plane exactly to the manufacturer's specifications.
jetjr Posted March 21, 2015 Posted March 21, 2015 They are factory built, ie used to be full LSA until modified If its modified then it isnt as factory released it If the manufacturer didnt approve the mod, then it is no longer eligible for exp C of A I dont get it
Garfly Posted March 21, 2015 Posted March 21, 2015 Andy@Coffs wrote that: ".... BTW the issues this process deals with are discussed in this thread http://www.recreationalflying.com/threads/the-effect-of-the-audit-dang.54171/ It's interesting, though, that throughout that thread the general presumption seems to be that dropping back to 19 rego would be a way of getting around the (second-hand) factory built, prop-certification problem. In fact that's the understanding underpinning much of what I've seen discussed here over recent years around regulatory issues. So there's heaps of "incompetence" to go around (see Jetjr's post #43 above). It's a wonder that the competent ones didn't pipe up more often to set us to rights.
robinsm Posted March 21, 2015 Posted March 21, 2015 In discussions with board member, seems everyone here thinking they can as owners modify 19 aircraft is "incompetant" as are the L2 and manufactirers Ive been dealing with for 9 yearsApparantly Its always been the case that only CAR35 can modify 95.5 aircraft.........? Now thats all fixed with MRAp He sees no reason to ground aircraft despite the CASR 21 saying Cof A should be surrendered immediately modifications are done. Keep flying guys its all ok, just keep being incompetant owners with no understanding of the rules we operate under. Oh and board members are working very hard for us advancing privaleges and keping RAA going, if i sont like it i should stand for election. On deeper reading i dont see who is to approved mods to E LSA. They are modified away from Factory LSA, cant acess Mod process. I built it, I fly it, I have serviced it without accident or fault for 8 years. I have flown all over the state. Incompetent...maybe..?? 2
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