MARAP

[jabiruken]

Not so long back I was involved with a coronial inquest involving 2 fatalities in a 19 registered drifter.

 

Their families council tried very hard to prove that the aircraft was at fault, (wich it wasn't) Raaus representives St and zt (there initials) did very little to convince them otherwise. and the outcome? The coroners recommendation was that Raaus aircraft should have regular inspections to prove air worthiness by qualified persons.

 

Now in order to do this one needs to have a bench mark/syllabise to address such issues that arise from modification/maintenance, seems to me Marap will be the perfect instrument.

 

 

[Garfly]

That's interesting. But I wonder if the coroner knew, or would've found relevant, the distinction between a 19 aircraft owned by its assembler or by someone subsequent. The point being that in the former case MARAP will remain no instrument at all.

 

There's the rub.

 

 

[jetjr]

Enforcement the same was as currently done for factory built LSA and every aircraft. Up to the owner/ pilot to make sure its airworthy and complies with tech manual and 95.55.

 

The concept of the MARAp has come from the audits where it was clear we had no records or way to prove things were being modified safely. RAA has no record of how much and how many are modified in what way.

 

Id be hoping that for minor mods you simply submit a form, logbook entry and be done. Owner get something back have something saying the mod hasnt screwed with airworthiness.

 

 

[jabiruken]

Enforcement the same was as currently done for factory built LSA and every aircraft. Up to the owner/ pilot to make sure its airworthy and complies with tech manual and 95.55.The concept of the MARAp has come from the audits where it was clear we had no records or way to prove things were being modified safely. RAA has no record of how much and how many are modified in what way.

 

Id be hoping that for minor mods you simply submit a form, logbook entry and be done. Owner get something back have something saying the mod hasnt screwed with airworthiness.

Agreed, perhaps now that the CASA has finished the audit of Raaus administration it's now going to audit the Raaus fleet. Could be more pain on the way, another 6 months out of the air waiting for technicians to TSO 4000 or so alti meters etc..

 

 

[jabiruken]

That's interesting. But I wonder if the coroner knew, or would've found relevant, the distinction between a 19 aircraft owned by its assembler or by someone subsequent. The point being that in the former case MARAP will remain no instrument at all.There's the rub.

Yes the coroner was well aware of 19 rego privilege. His concern was that a person could modify that aircraft without regulation, in this case it was the 2 spectrum aviation long ponds that were joined to reassemble a canoe. It was argued that whilst the aircraft was spiralling could the mod have caused the aircraft become uncontrollable?

 

 

[pmccarthy]

Sounds like a valid concern and reason to take some action.

 

 

[Garfly]

Yeah, thanks for the info Jabiruken. But you mentioned earlier that you believed - or it was found that - the aircraft itself was actually 'innocent' in this case. So it might, then, be seen as a 'bum-rap' for the whole 19 reg. concept.

 

 

[Ron5335]

How will Marap be enforced/policed?Simple, bi annual inspections.... Oh joy!!

You are probably right !!!

 

MARAP is the process.... and a Condition Report is the tool that will identify (Catch) those who need to use it.

 

If so, then another interesting thread will fire up dealing with. Can a new requirement be placed on a "Registration that has been granted on a "Point of Time" determination.... In the name of safety I say it would get up.

 

Then the new requirement, will then be in contrast to the base law (95.55) as it makes no mention of a regular inspection process, but does state a type (One off inspection)

 

So then, the Regulator/Administrator (Who are responsible for it's introduction) must bear the costs imposed on those affected.

 

Eg.

 

Random Breath Tests (Now includes Drugs)

 

In the name of safety, RBT was introduced, and a condition for holding a drivers licence was that you could be randomly tested. (New Imposition placed on existing condition) and there were already laws in place for Drink Diving in the base law.

 

New laws were made and introduced, and the program costs lots of money to run, but the drivers tested, are not required to pay for the costs of being tested. (Definately Not User Pays) and the new costs were covered by those who introduced them.

 

 

[kasper]

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.

Sorry. No. You confuse the act of registration and the limits that are applied to it - they are not the same thing.

 

A 19 reg aircraft is registered when RAA takes the money and issues the numbers and certificate - the fact that the initial certificate may have 25-40 hours of restricted flying does not change the fact that it is in fact registered with the RAA.

 

Nowhere in the RAA tech manual is there at all mention of conditional or provisional registration in relation to a 19 reg aircraft - the only area where conditional or provisional permissions exist is in relation to a person/factory building second and subsequent aircraft under a program to approve a 95.10 kit where the tech manager gives permission for additional airframes to be built and provisionally registered to demonstrate the history of safe operation.

 

So no, the 19 reg issue is still a point in time determination - exactly the same as the 95.10 determination is a point in time with any and all subsequent changes completely without reference to design requirements other than those set out in the RAA tech manual ... and the tech managers over time have always when challenged by me on this agreed that as the design is not certified and any materials used are at my own discretion as I am the owner and take design responsibility (even if I did not build it initially).

 

As for feeling safer if an L2 looked over something that is entirely up to the owner/builder. Much the same as the L4 during the build phase of a 19 reg cannot insist on a change or declare that something is not kosher ... the role is to oversee the builder inspection and recommend limitations to the initial operation of the aircraft ... paddlepop stick props on lawnmower engines are likely to get much more severe restrictions than a commercial prop on an aircraft engine ... but the registration exists following completion of the paperwork and payment of the fee ... RAA cannot legally refuse registration if the steps are complied with when it is either a 95.10, 95.32 self design trike/parachute or a 19 reg.

 

 

[Guest Andys@coffs]

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

 

.

There are many aircraft 19 registered, including mine, that predate LSA....as such any reference to LSA and my aircraft is wrong.

 

Furthermore, LSA standards of themselves don't exist. rather an LSA Aircraft is made against one of the set of acceptaqble standards, of which there are a number for LSA aircraft. As Builders are very unlikely to have, as an example, access to ASTM or JAR22 or BCAR standards used by OEMS of LSA aircraft then I would argue it unlikely that any builder can of themselves can declare that the aircraft was built to LSA standards....... They can say that they built it to the kit manufacturers instructions, but I wonder how you build a repeatable QA structure into kit instructions..... For example, how do we know that the resins used by the builder of a jabiru kit are appropriately mixed and will meet the designers required strengths and longevity?

 

Andy

 

 

[Oscar]

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.

Yes, absolutely correct, and that is why MARAP cannot, I believe, be legally enforced on 19-reg aircraft. However, if one looks at tghe rationale behind the controlling of modifications as being (rather crudely expressed), to ensure that as a result of the modification the aircraft is 'no less safe than it was before the modification' , it appears to me that there are now potentially two alternative ways of achieving that.

 

The first way, is to replicate the original flight test conditions, operating with the original restrictions.

 

The second would be, by following the MARAP, to have engineering justification done. Now that requires establishment of the 'original condition' against which the new condition can be evaluated. If there is adequate, reliable engineering data available for the 'original condition', your Part 21M engineer has something to work on (hence, my 'a bit experimental' classification: an aircraft that is legally NOT TC'd but is a known and documented quantity, vs. an aircraft that has demonstrated against a flight requirement that it has not fallen apart..)

 

In Andy's putative undercarriage mod., there is (assuming that there is evidence that his aircraft was constructed correctly from factory-supplied parts) extensive data of the 'original condition': the full specification and manufacturing schedule for the legs, the results of the drop-tests etc. A Part 21M engineer can, in most cases at least, calculate whether the proposed change will result in something 'of equivalent' (at least) safety.

 

Real-life case: I have put a UL (same as J120) fin and rudder on my LSA55, replacing the broken original fin and rudder. It has considerably more area than the original, for both the fin and rudder, and should provide better low-speed directional control (for which the original LSA55 is known to be a bit 'soggy' in response.. This change was discussed with Rod Stiff who believes that it will result in an improvement to the handling of the thing).

 

The fin and rudder are factory-supplied parts, so of known quality; the attachment work uses a schedule provided by a Part 21M engineer for the lay-up etc., and the thing has been tested to replicate the limit-load condition for the original aircraft modified to take into account the extra area. Hence, it can be shown to be 'no less safe' structurally, than original. However, the increased area will also mean that in order to meet at least the same aerodynamic stability considerations as the original, there will need to be an increase in dihedral - which will mean new lift-struts of longer length, and flight testing (not durability testing as per the 25 or whatever hours, but testing to a specified set of parameters of in-flight behaviour.

 

Once all of that is completed, the results can be assembled and presented using MARAP for approval. There should be no reason for RAA (or CASA) to require further testing, and I believe that this 'suite' of mods should be able to be used as a template for other LSA55 aircraft to be similarly modified, provided they conform to all aspects of the mod.

 

And the point is? - well, LSA55's do tend to play dead ants a fair bit and fin/rudder damage happens; here could be an easy and effective repair scheme that will actually improve the wee things.

 

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.

But I think we understand that it was CASA's insistence that 19-reg aircraft be lumped in under MARAP? I'd like to see further information about just how that happened and where the decision for it was made, before we lay the blame on the Tech Manager.

 

 

[Guest Andys@coffs]

Sorry. No. You confuse the act of registration and the limits that are applied to it - they are not the same thing. A 19 reg aircraft is registered when RAA takes the money and issues the numbers and certificate - the fact that the initial certificate may have 25-40 hours of restricted flying does not change the fact that it is in fact registered with the RAA.

 

Nowhere in the RAA tech manual is there at all mention of conditional or provisional registration in relation to a 19 reg aircraft - the only area where conditional or provisional permissions exist is in relation to a person/factory building second and subsequent aircraft under a program to approve a 95.10 kit where the tech manager gives permission for additional airframes to be built and provisionally registered to demonstrate the history of safe operation.

 

So no, the 19 reg issue is still a point in time determination - exactly the same as the 95.10 determination is a point in time with any and all subsequent changes completely without reference to design requirements other than those set out in the RAA tech manual ... and the tech managers over time have always when challenged by me on this agreed that as the design is not certified and any materials used are at my own discretion as I am the owner and take design responsibility (even if I did not build it initially).

 

As for feeling safer if an L2 looked over something that is entirely up to the owner/builder. Much the same as the L4 during the build phase of a 19 reg cannot insist on a change or declare that something is not kosher ... the role is to oversee the builder inspection and recommend limitations to the initial operation of the aircraft ... paddlepop stick props on lawnmower engines are likely to get much more severe restrictions than a commercial prop on an aircraft engine ... but the registration exists following completion of the paperwork and payment of the fee ... RAA cannot legally refuse registration if the steps are complied with when it is either a 95.10, 95.32 self design trike/parachute or a 19 reg.

Kasper I may be slow and incompetent as you have said...but would you please take the statements I wrote in the post you responded to and show me exactly where it is that I have written something that is wrong. I believe that the limits are applied as a result of risk review and are applied at the time of registration, nowhere did I say they were the same thing, but I did infer and I stand by the inference that limitations cannot be applied until registration is conferred. they are not the same but one drives the other... I did not use the term conditional registration, nor do I believe I inferred it. That all said the limitations initially applied are not optional, they must be complied with.

 

 

[fly_tornado]

Andy is it possible that the RAA and CASA could work out what's so bad about owner's modifying #19s and then work backwards to fix "the problem". As opposed to punishing #19 owners just to make paperwork.

 

I still don't understand what the problem is. #19 builders can still build and fly death traps and most #19s that do crash, from what the EAA have published, tend to crash with the original owner at the controls.

 

 

[jetjr]

Ok, this is a good point, why then are 19 kit builts given an experimental LSA certificate.

 

A week ago I would have argued mine too was not LSA, but seems incorrect. (Didnt we debate this and we both had opposing views)

 

The LSA standards are listed in one of the regulations, i saw them when digging.

 

The kit maker declares that if the kit is made according to instructions it will comply with LSA

 

Kit maker has to have same aircraft flying under factory LSA- which confuses me, as you say factory LSA, didnt exist when mine was made??

 

The kit builder does make some pretty big declarations, like that it was done per instructions and meets LSA standards

 

Its pretty clear that when mods away from this are done exp cerrt is invalid

 

OUTSIDE LSA requirements builder can do what they like. Really comes back to what these LSA std are i think

 

 

[fly_tornado]

ELSA is pretty strait forward, the manufacturer has to produce at least one prototype. ALL of the ELSA kit must be bought from the manufacturer, even the engine. The kit must be built to be a 100% perfect copy of the SLSA prototype. Once registered the owner is free to change it, with it seems only the annual as a safety measure. If you buy an ELSA you have to do 16 hours training to do your own annuals or have an AP/LAME do your annuals.

 

At least that's how it works in the US. The RAA ELSA system works differently, the RAA manual makes no mention of annuals or repairman certificate training

 

*sigh* because the RAA always get it right

 

https://www.raa.asn.au/wp-content/uploads/2014/12/LSA-Synopsis.pdf

 

 

[Oscar]

Ok, this is a good point, why then are 19 kit builts given an experimental LSA certificate.

Only kits of an aircraft that has been certified to the ASTM LSA standard could be given an e-LSA registration. A kit of an aircraft that is certificated to a different standard ( JAR, BCAR etc.) could NOT be given e-LSA registration - by definition. Kits of aircraft that have not been either certified or certificated cannot be 'deemed' to meet any standard, even if they are built in every miniscule respect to the manufacturer's specification.

 

Aircraft that do not meet an internationally-recognised standard, have indeterminate status: Ibis aircraft, for example.

 

 

[fly_tornado]

there where many exemptions for the existing "fat ultralights", 2 seat ultralights supposed to be sold only for training but they sold like hot cakes as they had a 1000lb weight limit and 2 seats. These where factory built and could be registered as ELSA or EAB dependent on the specs.

 

 

[Oscar]

An 'experimental' CANNOT be 'factory build', by definition.

 

 

[fly_tornado]

ELSA essentially crosses that border as it no longer requires 51% user input. have you seen Glasair's two weeks to taxi program?

 

 

[jetjr]

yep thats correct

 

Whats confusing many is

 

Experimental certificate

 

Experimental LSA certificate

 

E24 reg LSA

 

ELSA

 

And old LSA Jabiru

 

True LSA carry a Special CofA and are factory built, locked in for life to manufacturer only approvals

 

Im now confused as to what cert pre 2006 factory assist Jabiru might have?

 

 

[rhysmcc]

ELSA essentially crosses that border as it no longer requires 51% user input. have you seen Glasair's two weeks to taxi program?

According to Glasairs website, the FAA has deemed the two weeks to taxi program meets the 51% requirement.

 

 

[fly_tornado]

TWtT is you and 2 helpers/trainers

 

 

[rhysmcc]

verbal instructions rather then reading from a manual, same same no? Pretty sure "you" do all the building, they just tell you what parts go where and pass you the tool.

 

 

[fly_tornado]

Its a good system, I think they have done about 200 aircraft through it.

 

 

[jetjr]

Used to run factory assist programs at Jabiru builders here too

 

Much more than 2 weeks though

 

You still have to fly off 25 hours locally