MARAP

[Guest Andys@coffs]

Correct

 

 

[Guest Andys@coffs]

Reality is that the total regulations that an aircraft owner must abide with are in the CASA exemptions and orders, and for RAAus also in the Tech manual. Modifications, which have a specific meaning that is usually defined in the legislation for almost every form of registration (wider than just RAAus) , are described in the legislation both in terms off who can authorise such modifications and who can then implement the modifications.

 

The current RAAus Tech manual is an enigma....its coverage of such subjects is poor in my opinion, but, in keeping with RAAus aims of affordability and low bureaucracy. As you will all have heard the Tech manual is undergoing a rewrite and has been, for almost as long as Ive been in RAAus......We want clarity, but we want to stick to our vision also.......

 

I guess the real question is, has lack of clarity about modifications in our aircraft caused safety related incidents...I personally don't know the answer but I do know that CASA took a hardline view for factory built aircraft where owner(s) over the years had introduced modifications where there was no clear path in legislation or Tech manual to do so, requiring reversion to original specification before reregistration could occur....easy if parts are available and impossible if not .... So we have a situation today where the introduction of such clarity is good for Aircraft of that type, but the exact same introduction for Aircraft of a different type where there is equally no legislative way forward (despite legislative basis for other Ametur Built aircraft existing) is seriously offensive for part of our membership..... Their isn't, in my opinion, a safety case based on actual failures/accidents, in our fleet to justify action in either case........and it is true that for 19 registered aircraft there are a bunch of risk reduction exclusionary statements of where you can fly etc that CASA believes (I presume) addresses the non participant risks.....So people suggest that their is no need for legislative coverage because mods or not nothing changes in that its was an unknown build state when first registered and a modification doesn't fundamentally change that.

 

Rock...Meet Hard place

 

 

[jetjr]

All pretty correct Andy

 

The problem with 19 aircraft has little to do with MARAP other than it has flagged an issue

 

I suggest a few will benefit from MARAP however there is already a process, so if it were of much value, they would have fixed the issue already.

 

for most the new process wont mean much at all too.

 

Id suggest MARAP would have some BIG advantages if it applied to Factory LSA allowing for example J170/230 owners to fit engine upgrades yet maintain training status

 

The risk is that clarification could see the end of any attraction to 19 aircraft after builder is finished with it.

 

This will affect further the assets of you me and hundreds of others and impact RAA as a whole

 

It has also illustrated some odd variation in rules regarding E-LSA and privaldges of them vs 19

 

 

[fly_tornado]

MARAP is a good solution for a lot of factory built aircraft, its a shame it can't be adopted to LSA. I don't think it will work with scratch built and experimental designs unless you can find an engineer who has a background in similar aircraft.

 

 

[Oscar]

FT, there are quite a number of engineers with extensive experience with 'similar aircraft'; most of the independent CAR35 engineers have been involved at various times with RAA aircraft, at least. If you don't include the really way-out-and-wonderful ( or awful, depends on your POV) 'specials', the more mainstream ( Gazelle, Drifter, Lightwing, Jabiru, Brumby etc.) have all had extensive input from some of the seriously respected senior CAR 35 / Part 21M engineers.

 

 

[fly_tornado]

Most of those planes where designed over 20 years ago (1995!). Its not like there are a lot of light aircraft being developed in Australia.

 

 

[Ron5335]

The Good News........ My rego has been approved and processed !!

 

The Bad News.

 

If MARAP is applied to a 19 reg and say the owner is a non builder, that keeps being fed the line that he cannot modify or repair his aircraft. (And believes it)

 

What happens when he needs to repair or modify?

 

At the moment he has 2 choices.

 

Either cover up the problem, keep quiet and and keep flying.

 

Or fill out an application form that is like giving someone an open cheque.

 

Once it is filled out it's handed around and probably back and forth between CASA, an Engineer, The Manufacturer & the Tech Man, and they will all charge the owner (User Pays remember)

 

and all this before $1 is spent on the fixing the actual problem.

 

In the real world, you would hope that this type of owner would build a strong bond with L2"s & L4s any any other owner builder, to help and assist him to maintain his aircraft in the highest condition, but now, if there is a problem that may require attention, all of the above mentioned mentors will adopt the Shultz attitude of " I SEE NOTHINGGGG" and steer clear of him and protect themselves from the inevitable.

 

That's just my spin on things.. But my mind maybe warped

 

 

[fly_tornado]

Imagine the bill if you can't find a solution everyone one agrees on and it does the rounds a few times and the RAA then lose your paperwork or find the paperwork not 100% and you have to start over again. A lot of planes either won't get maintained or they will get maintained illegally.

 

 

[Oscar]

The risk is that clarification could see the end of any attraction to 19 aircraft after builder is finished with it.

This will affect further the assets of you me and hundreds of others and impact RAA as a whole

Actually, I'm not at all sure that you're not just looking at the entirely negative side here.

 

With a bit more experience of it and some intelligent development of its application, MARAP could just prove to be an unexpected blessing for 19-reg owners - at least, of certain aircraft. Let me explain why I think this way.

 

Taking a 19-reg Jab kit-built aircraft as the example, because that's the only one I know much about, what you have is essentially (for the LSA55 and all 'variants' thereof through to the J160), an owner-built example of a certificated aircraft. Provided that the kit-built Jab. has not been modified in any substantive way ( i.e. potentially affecting safety) from the kit and has been built to the Jab. instructions, it is a known quantity from an engineering POV and a Part 21M engineer can evaluate a proposed mod. against the standard to which the 'factory-built' equivalent was originally certificated. That allows a Part 21M engineer to evaluate the proposed mod. as being ( or not being, as the case may be) 'of equivalent safety' to the original.

 

Without the documentation of 'equivalent safety' (or alternatively, 'no adverse effect') for a component change, in theory at least any change to a 19-reg aircraft might require going back to the 'proof' under restricted flight conditions of 25 hours in a remote location etc. - for every one of 19-reg aircraft that happens to use a particular mod. By using the MARAP, a specific mod. could potentially avoid that for ALL the 19-reg aircraft that qualify, or at least reduce the impediment to one 'proof' aircraft.

 

Hypothetical example: someone develops a composite, ground-adjustable propellor for the J2200 engine. ( Of course, someone HAS - Jabiru - but it's only applicable for the LSA certified engines, and Jabiru appear to not be interested in spreading its applicability beyond those.) Using MARAP intelligently, there could be an avenue for its acceptability for 19-reg 2200-engined Jabs. as a simple 'application' to be able to install one on your 19-reg Jab 2200-engined aircraft.. Or changing to MATCO brakes, or installing a FWF CAMit-2200 engine package...

 

I suspect that with more introspection, the selective use of the MARAP may prove to be very advantageous. So far in this thread there seems to have been rather more heat than light; however if people are capable of unshackling their minds from the negative and looking at ways to embrace the positive, we might well find that RAA has managed to achieve a progression for its members of very significant proportions. ( and by way of declaration of interest, I am NOT (currently) a member of RAA).

 

 

[fly_tornado]

So what about the situation where a #19 Jab has a Rotax put in it and the factory refuses to approve any subsequent modifications? Plane is now worthless

 

 

[Oscar]

Most of those planes where designed over 20 years ago (1995!). Its not like there are a lot of light aircraft being developed in Australia.

And what is the primary concern of most aircraft owners? Aircraft that were designed over 20 years ago.. the more 'modern' ones are LSA aircraft and nothing in MARAP applies to LSA certified aircraft.

 

 

[Oscar]

So what about the situation where a #19 Jab has a Rotax put in it and the factory refuses to approve any subsequent modifications? Plane is now worthless

The factory did not approve the putting in of a Rotax anyway. So whatever the value of a rotax-engined 19-reg Jabiru was once it had an approval to fly, absolutely NOTHING is changed by the introduction of MARAP .

 

 

[Ron5335]

Oscar

 

Don't get me wrong, the MARAP is a great piece of work and a great step forward for factory builts, !As you described in your post), it's just the inclusions of the 19's that stuffed it up.

 

It's akin to comparing all the planning that went into the Sydney Olympics, then a couple of weeks out from the starting of the games, someone said

 

"Rather than run the Modern & Para Games separately, Lets run them together, What could possibly go wrong?"

 

A factory built aircraft has a strong data base to draw from from , a #19 Experimental does not.

 

 

[Oscar]

I agree - the more 'experimental' a 19-reg aircraft is, the more you are out there on your lonesome.

 

But conversely, diligently 'kit-build' 19-reg aircraft - if from a kit that has parentage in a certificated aircraft - the more you have a fairly solid investment. I believe that CASA's determination that all 19-reg aircraft must be subject to MARAP is simply incorrect, by the very definition of what constitutes a 19-reg aircraft. It's a bit like lumping a rallye-modified Subaru WRX in with home-built desert-racer specials.

 

If a kit-built aircraft has 'parentage' to a certificated aircraft, there is a heap of factory components that are documented to meet a standard. In the case of a kit-build Jabiru, I can't readily think of any components that are on the 'critical' list for safety, that aren't in fact produced by the factory to full factory standard: engine, wings, lift struts, engine mount, undercarriage, control surfaces, control runs etc.. TBH, a 'factory-assist' 19-build Jabiru is in my estimation about 99.9% likely to be every bit as good as a factory-build - if not even better. Those who did a 'factory-assist' build, are probably the BEST informed owners of a Jabiru - they know every inch of that aircraft.

 

Whether that holds good for other makes, I have no idea and therefore would not venture to comment. I assume that you have a far, far better knowledge of your Super Diamond than a second owner who has not really put a spanner (or riveter, for Morgan aircraft) on their aircraft. Presumably, you have done proof / limit load testing of your work to the manufacturer's specifications?

 

And here, I believe, is the crux of the problem for acceptance of repairs and modifications. Without going into boringly extensive explanation, repairs and modification IF THEY ARE NOT TO BE SUBJECT TO NEW TESTING, need to be provable that they are of 'equivalent' standard to the original. That can only be done by evaluation against the original documentation.

 

In the case of kit-build Jabirus, the original documentation is available. If it is NOT available for aircraft XX, but that aircraft has passed the 25-hour ' it's OK' test, then an engineer can't do anything more that evaluate the relevant areas of the aircraft and say: 'the proposed modification is at least as good as the original'. CASA could then reasonably respond with: 'then it has to pass the same test'.

 

 

[Guest Andys@coffs]

Oscar

 

I was talking to another guy about this yesterday. I refer to my aircraft as a J230 because it was built from a jabiru provided J230 kit. However at the end of the day, assuming for the argument that I was the builder, I not sure in a legal sense that finished product is a Jabiru J230, because neither Jabiru, nor me, can put hand on heart and say that a factory built J230 and an amateur built J230 kit are exactly the same, in fact I would almost go so far as to say that it would be rare that the finished AB product is exactly the same as the factory produced ones....I know mine has a mixture of MGL avionics, old steam driven gauges and Trio autopilots fitted and I'll bet one just like it never came out of the Jab factory..... It goes to the point that Rod Stiff made quite emotionally recently about when is a jabiru engine not a jabiru engine......the same rationale applies to the bigger picture I think......Because there is no definitive engineering baseline....as you said in an earlier post the approach to registration is about risk management and reducing risk to uninvolved participants until the "final product" has proven itself to some extent through the airborne testing regime..... As such perhaps the same methodology needs to apply to a modification regime in my opinion. If we must have one then a risk review process needs to apply, and if appropriate a flight test regime might well need to be applied again in part or full depending on the extent of the modification.......In my case changing brand X avionics for brand Y does nothing to modify aircraft airworthiness in the VFR context so no real extended airborne testing beyond a single acceptable test flight is needed........If I change the gear structure, then perhaps some appropriate airborne circuit testing at full MTOW without passengers and perhaps a more frequent review than 100houly for undercarriage continued serviceability might, as an example, be appropriate to prove its continued risk reduced impact to uninvolved 3rd parties

 

Andy

 

 

[fly_tornado]

Watch the price of used RAA experimental aircraft plummet over the next few months once people realise what a liability MARAP is creating.

 

The factory did not approve the putting in of a Rotax anyway. So whatever the value of a rotax-engined 19-reg Jabiru was once it had an approval to fly, absolutely NOTHING is changed by the introduction of MARAP .

Manufacturers could simply refuse to approve any further mods to any airframe just to ground it, think of it like a stimulus package for importers and manufacturers. Gary Morgan has already indicated he won't support any modifications he doesn't like, it won't the rest long to realise this is an easy way to "hide the ugly children".

 

 

[jetjr]

Ive been following this up and there are some good and bad things about it

 

Darren has been very open and helpful

 

Firstly any kit built 19 aircraft was built to LSA standards.....the kit maker declared it and the builder said so and declared it too. It must be kept to meet LSA standards, modified or not.

 

Manufacturers arent involved, if its not factory built, owner can go theough MARAP. How can they ground an homebuilt aircraft anyway?

 

You could put any crazy idea theough process but be prepared to have restrictions or test flying schedule reapplied

 

The intention with the MARAP is that RAA is running it and giving approval and or conditions, part 21 is helping make that descision. CASA not involved. This is a big deal some years in the making

 

Costs are supposed to be shared over time for common requests.will work a little like an STC but RAA is paying money upfront.

 

All mods to date are covered.

 

There should be a better idea of minor and major modifications which may or may not require full process

 

I think the bad is that CASA are likely to align 19 rules with other experimental like SAAA meaning no mods except for builder. Some thoughts are that this is already the case.

 

We can hope that this alignment could result on similar privaledges like CTA for 19 aircraft.

 

 

[gandalph]

Imagine the bill if you can't find a solution everyone one agrees on and it does the rounds a few times and the RAA then lose your paperwork or find the paperwork not 100% and you have to start over again. A lot of planes either won't get maintained or they will get maintained illegally.

Great Scott FT, does that rain cloud follow you EVERYWHERE.

 

 

[Garfly]

I'd have thought that the simpler 'legal way forward' for 19-xxxx (also the most logical, consistent and no less safe way) is to just clarify the notion that builder rights, vis-a-vis mods, flow on to subsequent owners.

 

(Confident that outright dodgy-practice is sufficiently constrained by existing instruments.)

 

Which, according to many here who've taken the trouble to go searching, seems, indeed, to be the implication of the laws as they stand. At least no one has yet pointed to the exact clause which contradicts that.

 

I hope CASA come to see it that way.

 

How could it be regarded as making consistent (safety) sense, otherwise?

 

It's really part of the whole homebuilt recreational flying idea to be able, with minimum fuss (whilst living with certain restrictions) to make - or have competently made - improvements to one's (#19) aircraft; for better safety and better enjoyment.

 

Of course, many of the things one wants to do would hardly effect the integrity of the original design. It can, indeed, be stuff like swapping out electronics, even a new thermos clamp or map pocket.

 

But one fears, if one goes asking for it, a TSO-like regime being imposed, like in GA. One fears that the whole activity will lose much of its point, and for no substantive reason. Okay, as Jetjr has suggested above, maybe a 'minor mod' exemption will be built into the new system. That'd probably work, if the legal drafters can be persuaded to make those complicated distinctions; to take the trouble. If I was a regulator, though, I might be tempted to take the easier and most ass-covering option.

 

In any case, what about the huge load of paperwork and engineering processing that will descend on the staff at head office; all the anger and frustration that'll come with. It won't be easy. I do feel for our administrators existing between that rock and that hard place.

 

 

[fly_tornado]

honestly, I just can't have a great deal of confidence in the RAA. This new process just seems like its a ticking time bomb. You don't own a experimental Gandalf so it doesn't affect you, at the moment.

 

 

[kasper]

I agree - the more 'experimental' a 19-reg aircraft is, the more you are out there on your lonesome.much clipped'.

BUt that is the rub - there is no such thing as a bit experimental - all 19 reg are experimental regardless of them being as vanilla a kit as you can get or a one off built of paddlepop sticks.

The MARAP as drafted by CASA within the Changed 95.55 applied to the certified aircraft from factories ... those designed to a known standard and all coming off the line the same. These are aircraft where the registration is dependant not on being able to meet a weight/build definition at the time of registration (experimental and 95.10) but on meeting and maintaining the standard to which it was built.

 

The MARAP as CAO 95.55 covers is well designed to allow a modification path through the RAA and as there is a design standard behind te design that they are looking at changing then it is possible to assess the change and know it within a known environment of a design standard compliant airframe.

 

Nothing at all wrong in that - bloody comendable as it allows a lifeline for all those older 95.25 without an active manufacturer or the earlier 101.55 where the manaufacturere may not be interested or see it as financially viable to support modification programs for aircraft they have moved on from eg jab LSA55

 

The ONLY reason we have an 8 page thread on here is the bewildering insistence by the RAA Tech in announcing MARAP that it include sthe 19 series .... the only part of 95.55 that has no design standard behind it and is explicitly not covered by the amendments to the CAO that introduced MARAP

 

So over to the RAA - explain why 19 is included in the announcement when the CAO changes do require it or admit that they got it wrong ang 19s remain as they were - free to modified at any time by any owner as the definition in 1.2(e) is a point of time at initial registration test.

 

 

[fly_tornado]

Never lose site of the primary goal which is aviation safety.

 

 

[Guest Andys@coffs]

BUt that is the rub - there is no such thing as a bit experimental - all 19 reg are experimental regardless of them being as vanilla a kit as you can get or a one off built of paddlepop sticks.The MARAP as drafted by CASA within the Changed 95.55 applied to the certified aircraft from factories ... those designed to a known standard and all coming off the line the same. These are aircraft where the registration is dependant not on being able to meet a weight/build definition at the time of registration (experimental and 95.10) but on meeting and maintaining the standard to which it was built.

 

The MARAP as CAO 95.55 covers is well designed to allow a modification path through the RAA and as there is a design standard behind te design that they are looking at changing then it is possible to assess the change and know it within a known environment of a design standard compliant airframe.

 

Nothing at all wrong in that - bloody comendable as it allows a lifeline for all those older 95.25 without an active manufacturer or the earlier 101.55 where the manaufacturere may not be interested or see it as financially viable to support modification programs for aircraft they have moved on from eg jab LSA55

 

The ONLY reason we have an 8 page thread on here is the bewildering insistence by the RAA Tech in announcing MARAP that it include sthe 19 series .... the only part of 95.55 that has no design standard behind it and is explicitly not covered by the amendments to the CAO that introduced MARAP

 

So over to the RAA - explain why 19 is included in the announcement when the CAO changes do require it or admit that they got it wrong ang 19s remain as they were - free to modified at any time by any owner as the definition in 1.2(e) is a point of time at initial registration test.

Actually as you say it is point of time in the issuing of a 19 registration, but you don't go to having the full access to the 19 regime of flight until you have flown off the test hours. Airworthiness must be proven to a level sufficient for test flight at the time of rego, but is really proven as a result of successfully flying off the test hours and still being in one piece at the end without having killed the builder/pilot....

 

As I suggested earlier if modification calls into doubt the test flight hours by fundamentally changing something that was originally proven through test flight then maybe some or all of those hours need redoing depending on the severity of the modification.....

 

I cant speak for others (especially the board...in other words these are my personal thoughts only) but on modifying undercarriage I would be much happier having an L2 review on completion of the mod, and a lets say for argument a 5 hour test flight regime including 150 landings at or within 10%of designed MTOW or legislated MTOW which ever is the lower, and an elevated inspection regime for the next 100hours where every 20hours the undercarriage is inspected by the modifier..... that seems to me to restore the risk reduction that CASA had required by having the initial test flight regime... From a cost perspective I don't see such an approach as an enormous impost, for most of us flying is flying..... and 5 hours of imposed circuit work probably replaces 5 hours of free choice circuit work with a flight here or there to break the monotony.

 

 

[jabiruken]

How will Marap be enforced/policed?

 

Simple, bi annual inspections.... Oh joy!!

 

 

[gandalph]

honestly, I just can't have a great deal of confidence in the RAA. This new process just seems like its a ticking time bomb. You don't own a experimental Gandalf so it doesn't affect you, at the moment.

It sure does, or at least it will if the damn thing ever gets finished!