MARAP

[Phil Perry]

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

Friction nut on a throttle assembly Nev ? ? ? Not a chance !!

 

Here in the UK, if you own a factory built, like a PA28 ( a friend does ) it is illegal to change a bulb in a wingtip nav light, even with the correct and approved type. He was recently quoted £647.00 plus 20% VAT to change three nav lights and a landing light bulb ( Globe ? can't remember if they were called that in Aust. ) . . . now obviously, some will say, hang on, . . where do you draw the line ?. . but my mate changed his own bulbs/globes with those recommended by the manufacturers agent,. . . and the total cost was thirty four quid. . . .yes, this was not correct, and I've seen the posts by those who operate aircraft repair outfits, ( tyre replacement - last year ? ? ? ) but why oh why do they have to charge such exorbitant fees for less than half an hour's work I wonder . . . Incidentally, matey is a veteran auto-electrician. ( yeah. . .I KNOW ! ) flying from his own farm strip. . . I can't, in all conscience, cast the first stone,. . . I realise that this example is only very slightly aligned with the thread, but we've covered "Alleged" over charging by authorised maintenance staff before . . . . so Gawd only knows what you would be charged for "sensible" mods on homebuilt aircraft types here if a similar situation to MARAP ever arises . . .

 

As a brief example, our X'Air build group made some advances to the BMAA to alter the wheel braking system on the aircraft to include toe brakes on the right hand side,. . . . we never got it through, after exhaustive trying. . . even though the kit manufacturers in Bangalore agreed that it was a good idea for instuctor use, even though it was not legal to actually train ab initio on the type. . . people do need checking out in it !. I designed a simple cabin heater for the same aircraft ( it gets a bit chilly here. . . ) but this was approved without any problems, BUT . . .the modification was restricted to that ONE AIRCRAFT ALONE. ( ? ) No, I don't understand either.

 

Best of luck with your system anyway,. . .hope it produces some useful changes. Phil

 

 

[robinsm]

Phil, I hope the cab heater was not the style that tended to kill people with fumes if the exhaust broke?

 

 

[Phil Perry]

Phil, I hope the cab heater was not the style that tended to kill people with fumes if the exhaust broke?

No, it used hot coolant from the engine circuit through a very small aluminium Mini heater radiator, with a 130mm 12 volt computer fan blowing through it. No exhaust involved, it worked, but on the very coldest days the engine, ( 582 oil injected bluetop ) being totally exposed on top of the fuse tube, had enough of a job keeping sufficient temperature itself for normal running. . . if the heater was used, the flydat showed that the normal operating temp was not being achieved . . . so we removed it . . .worked really well in the summer though ( ! ! )

 

Phil

 

 

[kasper]

I notice that all reference to 19 reg has disappeared from the RAA MARAP pages ... maybe people in Canberra listen and/or read these threads ... now MARAP only applies to "CAO 95.32 & 95.55 FACTORY BUILT AIRCRAFT (NON LSA/E-LSA)" ... which is what people on here said from day 1.

 

But the interpretation issues and 'new tech processes' still exist if you follow the MARAP FAQ on 19 reg ...

 

"Can the MARAP process work on my Amateur built aircraft?

 

The answer is no.

 

MARAP is not necessary for amateur built aircraft if you have constructed the major portion (+51%) for your own education and recreation. Therefore the builder is already entitled to modify the aircraft within the constraints of CAO 95:55.

 

If a Recreational Aviation member purchases an amateur built aircraft, MARAP cannot be utilised to incorporate any changes or modifications. Major Modifications can be carried out by the current and subsequent owners. On approach to the Civil Aviation Safety Authority for a ruling Recreational Aviation Australia proposed the follow process

 

• If the owner is not the 51% builder but has incorporated changes a Grandfathering acceptance will be given
   
   
  
• A list of what is acceptable as Minor and Major modification to be provided as guidance material for the owners
   
   
  
• Major modification can be incorporated into a 19 registered amateur built by the current owner
   
   
  
• A RA-Aus Level 2 to validate that works have been completed appropriately
   
   
  
• Copies of the appropriate logbook entries are to be supplied to the technical team to be included on the aircraft file
   
   
  
• The RA-Aus Technical Manager is to be notified once the modifications are incorporated. The Technical Manager may stipulate additional requirements such as a flight test program or additional documentation such as a weight and balance report
   
   
  
• Once formalised and approved and the above requirements are completed the member is free to exercise the privileges as a member of Recreational Aviation Australia"
   
   
  

 

 

 

So now if you are 19 reg and not the original builder:

 

- they have created a grandfathering (date and list of aircraft impacted posted on the RAA website would really help here as the MARAP date has already passed so presumably they already know the aircraft involced):

 

- Have Minor and Major mods listing (listing on RAA website might help, as would a definition of both of this purpose)

 

- Woo Hoo!!!!!! L2 are not just doing an ACR but validating the work has been carried out appropriately ... that sounds incredibly like taking responsibility for it ... very new ... and the Woo Hoo is sarcasm just in case it was missed

 

- Copies of docs and logbooks to go to Tech and given Tech can stipulate part/all new flight test programs etc

 

- Only after getting all of that can you operate the 19- regn aircraft

 

So we have twin track 19- regn if you accept the Tech office FAQ at face value on this:

 

- if you built it you can merrily do your own thing without reference or inspection or notifying anyone (just note it in the logbook) BUT

 

- if you bought it then you can't use MARAP but the processes above outlined mean you sort of start again as if you were first registering the aircraft as 19 and get a test schedule (or not)

 

I must say I am absolutely dying to see the new Tech Manual and see if that little bundle of joys is in it because it certainly 'aint in the CAO or the current Tech Manual.

 

And the BOARD should note that THIS SAYS THAT THE RAA ARE PROPOSING THIS TO CASA SO CHEERS GUYS - YOU ARE MAKING EXPERIMENTAL THAT LITTLE BIT (OR LOT) MORE DIFFICULT IF YOU ALLOW THIS TO CONTINUE.

 

How about a few emails to [email protected] to ask for a please explain and confirmation that the RAA policy is to ask CASA for more restrictive and controlling processes.

 

 

[kasper]

Ok have spoken to Darren B on this and I am differently furious

 

1. The original description of MARAP posted by RAA Tech that included 19- in MARAP was as directed by CASA ... so clearly they did not know what they actually wrote in the the CAO

 

2. The currently MARAP description by RAA Tech (without 19- reg) has the 'new' 19- changes for second and subsequent owners because apparently CASA only ever intended for experimental 19- to be modified without overview and process if you were the original owner because only the original owner met the builder rules and the RAA proposal is a response to the CASA saying you must do this.

 

Despite 2. being driven from CASA it is a horrible starting point because the logic that a modification to a home built aircraft is only available to the original builder equally applies in logic to the home built 95.32 (18- reg) and the entire 10- reg series.

 

So I am still furious that RAA are simply proposing back to CASA a significant change that logically can be applied to other areas of RAA aircraft on the basis that CASA want this because its not an equivalent process as the SAAA for 101.28s on the VH register.

 

If this is allowed to go unchallenged by RAA from a policy perspective we may as well just give up having a board or membership because in effect its a matter of whatever CASA say - if that is it then get rid of RAA and move the lot into CASA and remove the pretense of membership involvement in policy or process.

 

 

[jetjr]

The issue on 19 reg is still being finalized. Whilst the FAQ is a little unclear the news for second owner 19 is basically good and it has altered based on our feedback.

 

Problems on this basically arose due to CASA not considering 19 mods AT ALL until last minute. ie they believed second owners could NEVER modify at all.

 

This process, inc Marap, is being proposed because CASA isnt happy currently regarding mods. For some there was no process to perform sensible mods.

 

The concept for 19 is...

 

Builder, do what you want, same as always.

 

Later owners, Existing mods grandfathered, Yes Marap doesnt apply, It doesnt need to.

 

You can do whatever you like but if its a major modification (list to be provided once finalised Id guess) you will need L2 sign off and a record of Mod to go to RAA.

 

No ACR, No Part 21, No test flight program.

 

Id guess that if Tech dept saw something questionable you might get some extra attention - so might the L2 who inspected it.

 

That being the case there has to be a system to make sure the modification is safe and its recorded. Mainly so no one does anything stupid or beyond their skill level. CASA (and common sense) demand this.

 

Annual L2 inspections is another way to keep track of unregulated Mods but most want to go down this track. Maybe it might be good for safety to have owner maintained aircraft looked at once a year?

 

If it were up to CASA, we would have same rules as GA Experimental, no self maint, no mods. All mods to type cert AC run through their process including individual Part 21 engineer approvals.

 

To greater extent you are correct, what CASA says is how it is going to be. Always been the case for everyone in aviation.

 

Yes its from a nasty start point but RAA has been pushing back with alternative options more to our liking.

 

 

[ave8rr]

Jetjr...said....

 

(Annual L2 inspections is another way to keep track of unregulated Mods but most want (or Jetjr do you mean DON'T) want to go down this track. Maybe it might be good for safety to have owner maintained aircraft looked at once a year?)

 

This happens in NZ for ALL microlight (ultralight) aircraft. The equivalent of our L2 type people do the annual and in most cases for little or no fee.

 

Inspector checks logbooks and a general look at the aircraft and issues an authority to fly for a further 12 months. A bit like our annual registration but the aircraft is actually looked at and not just some fee paid to RAAus for what? Our aircraft (19 category anyway) usually only get an independent look at during and ACR upon sale.

 

 

[jetjr]

Um yep thats what I meant, most dont want inspections.

 

Id be Ok with this as Im sure I miss things due to familiarity blindness - dont see an issue because its always there or problem gets worse without knowing.

 

Even to check all applicable SB implemented.

 

Having this process in place would take a lot of heat from CASA away I believe.

 

 

[jabiruken]

Ok have spoken to Darren B on this and I am differently furious1. The original description of MARAP posted by RAA Tech that included 19- in MARAP was as directed by CASA ... so clearly they did not know what they actually wrote in the the CAO

 

2. The currently MARAP description by RAA Tech (without 19- reg) has the 'new' 19- changes for second and subsequent owners because apparently CASA only ever intended for experimental 19- to be modified without overview and process if you were the original owner because only the original owner met the builder rules and the RAA proposal is a response to the CASA saying you must do this.

 

Despite 2. being driven from CASA it is a horrible starting point because the logic that a modification to a home built aircraft is only available to the original builder equally applies in logic to the home built 95.32 (18- reg) and the entire 10- reg series.

 

So I am still furious that RAA are simply proposing back to CASA a significant change that logically can be applied to other areas of RAA aircraft on the basis that CASA want this because its not an equivalent process as the SAAA for 101.28s on the VH register.

 

If this is allowed to go unchallenged by RAA from a policy perspective we may as well just give up having a board or membership because in effect its a matter of whatever CASA say - if that is it then get rid of RAA and move the lot into CASA and remove the pretense of membership involvement in policy or process.

A point here also is that insurance companies will baulk at 19 cat and what's worse find ways out of paying claims,

 

Um yep thats what I meant, most dont want inspections.Id be Ok with this as Im sure I miss things due to familiarity blindness - dont see an issue because its always there or problem gets worse without knowing.

Even to check all applicable SB implemented.

 

Having this process in place would take a lot of heat from CASA away I believe.

Don't let the CASA distroy RAAUS the way it did GA, if you feel annual inspection will benefit you then fine. Just do it, you shouldn't need it to be made compulsory. In my view we are under serious threat of over regulation and am sure that the RAAUS executive doing its best to protect our privileges..

 

 

[jetjr]

Insurance? - why will they baulk? less chance of dopey mods now than before

 

Findings of airworthiness problems or non compliances after accident will end our catagory faster.

 

 

[facthunter]

This isn't commercial aviation. You make your own luck to a great degree. You carry an informed person . There are some whose plane I would never fly. Some people don't even look at their tyres before they go on a holiday .Some should never go near an aeroplane. There's not a huge number and generally we collectively have a rough idea of who is a bit suss. Whatever we do we shouldn't make the careful people suffer for a few idiots. If someone is proven to be unreliable , watch them, or weed them out, and leave the sensible people alone. There's already enough paper work and assessment. Nev

 

 

[flyerme]

Hey guys snd gals , I have been reading all the comments and reference to my thread and feel I should give a little clarity to my (25 reg) dealings , ( being the first to face certified troubles). So if you hadn't clicked the link from Andy here's a little run down ... Back in 2013 I applied for reg renewal only to be declined due to UNCERTIFIED propeller fitted .. The original prop and maker are very much long gone so I went about on my lonesome having a new current prop certified ( bolly ground adjustable)for my LW-1 rotax 582 c box. .. Between , me ,RAA, my aircraft builder and prop maker this was done and reg granted.

 

Next year I apply again for rereg and again I'm declined? Requiring an engineering order.This time due to UNCERTIFIED 582 rotax as my LW-1 came out with the old 532... Now we are talking about 2 rotax 65 hp engines... I rang bertflood and was told the 532 do not exist anymore and they were replaced with the 582! Wal's opinion was they are a changeover replacement engine Not a modified Change? But anyway I then rang Howie and found NO help and felt really left in the dark on what to do? After some investigating I found a fellow in same situation as me with same plane and yet another fellow with identicle plane able to re reg no issues?WT. So I really started investigating and eventually from the horses mouth found that when CASA. Did the audit,only a random select few files were actually audited ( mine being one) ok so I feel slightly singled out and I find it not fair the joe up the road with identicle plane( infact modified more than mine ) re regs every year no questions asked but every year my less modified, same make, model, year ,and only 2 serial no apart gets the full scrutiny ? Oh well I spose a bit of suck it up princess and carry on?

 

So after Allso finding out the same plane in same situation as I was given provisional reg I emediatly jumped on the phone And soon had a year of " provisional reg". E/O pending.

 

So 6 months into it and armed with my little inheritance I began to go about the E/O business! OMG... No one wanted to know about it?

 

I tried hard and eventually a little bird told me to wait it out?

 

Couple months back i ran into Lee Eugermen ( spelling? ). I had never met or seen him before but he mentioned he had been petitioning for CASA to approve this new MARAP the past year and he was excited to have it passed on that day.. I had read only bad things about him and was surprised at his still passion for RAA and for helping ( at least me) out of a ugly mess. To be honest at the time I really had No idea what he meant by MARAP as he didn't elaborate other than it was to help us old modified 25 reg guys out.

 

Well as it stands my LW -1 is currently unreged as $$$$ real tight ( still some of my awesome book avail- pm me -shameless plug right there). I assumed I'd still need this E/o and last I was told I would need to take her to lame for a CAR.35 - um bit hard when the dudes in QLD.

 

my lightwing is not coming apart again I can assure you of that! And i can't fly it's not reg now!

 

So for me at least the MARAP sounds pretty good if I only need l2 report ,pics ,a bit paperwork some $$$ and job done! I'm going to Speak with Darren ( whome has been very helpful and approachable ) this week and hope to have the lighty back carving holes soon.

 

Oh ,I'm happy with annual inspections... So long as there free. :)

 

PS . The current board IMO. Are really doing there best in an ugly situation, I sure as hell don't envy any of their positions... We as Pilots know you never stop learning right? I bet that goes for head office too :). Happy days. Happy flying

 

DREAM, BELIEVE, ACT. ;) And NEVER give up. Tim

 

 

[Doug Evans]

I tend to blame member for these problems we are bringing these problem onto our selfs as most no longer fly ultralights .

 

Eg aircraft that have a max speed of 80 kn and below anything above 80 kn in my opinion are LSA just as an example a super cub or a Cessna 150 are not but can be reg as Raa ?

 

Member are wanting too get more faster craft and access to controlled areas which in my opinion is not and should not be a avaible to ultralights for safety reasons

 

If people wish to have these options then step up too general aviation levels ,

 

The idea of AUF / RAA back when I started to fly in the early 90s was fun affordable flying for the Joe blows that only wanted too go fly too there mate strip for a bbq and social group off like minded people ( which is what type of flying that I do I only do two longish trips twice a year eg old st / Woodstock ace field ) both about 280 mn the rest is local flights of my home area ,

 

I Always fly IFR. I follow roads and try too keep my craft in tip top condition as it is a two stroke which has served me well never failed over my 20 year or so flying behind one .

 

These days people are taking a lot more risk bye flying a gps routes as the crow flys over country that no single engine craft should in my opinion ,

 

Which is what causing a lot of our problems with people making wrong or bad choices with weather and committing to get there right or wrong mentality so the results are more mishaps and people losing there life

 

So the Boffin at the helm are seeing these problems happening over time and are trying to find ways of controlling or limit the amount of problems bye red tape and or controls in place to try and prevent it

 

I guess we are a race that wont too have more for less and we will always have this wail we travel this path ,.

 

This will upset a few or more but I think the fix is to take afew step back and look at the way we are classing these craft of today and maybe look at the certication classes and licenseing .

 

Go back and look at what the AUF stood for .

 

Just my two bob worth .

 

 

[Guest Andys@coffs]

You guys who fly, using your criteria, slower than or equal to 80kts, do so using the same exemptions as the faster aircraft do, there is absolutely nothing different legislatively and RAAus process wise between a lightwing (meeting your criteria) and a Jab (as a faster beast!) for example.....when CASA audits, the bar is set no differently for your aircraft vs my aircraft (well actually that's not true...its set lower for my faster one than yours because mine was experimental built and I presume yours was factory built..)

 

Furthermore, for guys like Tim who is 25 Rego'd, that has been around for a long time now, and hasn't changed much at all over that time....The only difference is that now UL fliers (in the broader sense than just 25 registered) instead or being a rarity are reasonably common.

 

If you want the perceived problems of oversight to go away you need to go back in time, and set it up so that UL flying is successful enough that you don't become extinct, but not successful enough that it grows in size.....of course being managed by Sports Aviation Office in CASA that looks after all similar endeavours you would also need that all other arms are equally sustained but not grown....

 

Change is constant in our world......wishing it wasn't so is in my opinion as equally fruitless as wishing you could win Lotto...focus on the things you can change would be my advice...

 

 

[Doug Evans]

Your right Andy and Iam not wishing on the past but using it as a guilde trying too see where the Raa has derailed may be misguided in my opion but that the way I see it .

 

I feel that there should be class or groups for the different way we use our craft

 

Eg : 80 kn & below ultralight rag & tube ultralight cat

 

80 kn above say 115 kn LSA cat

 

Your Rv classes of craft would then be in experimental

 

Then ya super Cubs & Cessna should be VH ..not I light sports areas

 

But as you say we have to look forward and try and streamline or better manage what we have too limit people making mistates .

 

 

[Guest Andys@coffs]

Its my view that the managers of the past have, correctly in my view, understood that in doing something 100 times there is a fixed cost and a per time cost that add together to give a user cost of $XXexpensive...if that was then applied to 10,000 members the fixed cost remains the same and the variable cost presumably because of efficiency of operation reduces so that the $XX cost to members in real terms is substantially cheaper........The problem has been that as the member count goes up, our accident rates have increased in raw counts (as you would probably expect to some degree) and that has focused CASA's attention who has then required additional activities from us and has then lifted the fixed cost portions.....

 

 

[fly_tornado]

I love reading the comments, its enough to put you off flying in a GA plane.

 

http://www.pilotworkshop.com/tips/aging_aircraft_airworthy.htm

 

 

[Doug Evans]

Saying that Andy you don't think that it should go along the path that the more prilivgaes that one or won't has too pay extra for that class or grade ,?

 

Thoughts ,,

 

 

[Guest Andys@coffs]

I think I reported back just after the last AGM that the board were looking to see if there is a really simple and easy UL pilot certificate that might be quite constraining in terms of where you can go, but at the same time pretty simple.....The issue I perceive is that we fly as a result of CASA legislative exemptions...there isn't one covering what we want and as such it wont be simple to bring into play....which is not that we shouldn't look to see it established, but more about managing expectations that such a thing isn't likely to be an overnight change....

 

With respect to costs, again the cost driver changes we have seen in recent years, such as a focus on safety management aren't unique to a group of pilots and cant in my opinion be apportioned more to pilot of aircraft type X than type Y....it reminds me of the Cub saying at about the time it was released...its so safe it can barely kill you.....but kill you it can.

 

If RAAus is successful in establishing access to CTA, or the ability to pilot an aircraft that has an MTOW somewhere between what we have now and for argument sake 1500kgs then I would expect that as the MTOW goes up, or the closer you get to class A airspace then there will be costs both within RAAus and external to RAAus that you must pay for....As someone who possibly aspires to transit class D as the likely only benefit of CTA access (assuming we cant get some appropriate G through CorD lanes of entry....where feasible to do so) then I would be really unhappy if my RAAus membership was to go up in leaps and bounds to cover the extra 5 staff we need to manage our CTA endorsements etc.... But that isn't the case today, I don't believe there is any one group (except by being a larger group overall) that we can point the finger at and say.it was them! they drove up the costs!!

 

Today we try to be as simple as we can, because generally simple will result in cheaper rather than more expensive.....however only where all things remain the same......Our growth rates outgrew simple paper based solutions a long time ago, but our team at the time didn't change to a more complex, but appropriate solution.......Or to try and put it simply...... as simple as possible, while still doing the intended job....in such a case simple, might look to be relatively complex, but it may not be able to be simplified further.....

 

Hope that's clearish.......These are my personal views and may or may not represent the boards position.

 

 

[Doug Evans]

Thank u Andy that gives me an understanding of the structure behind the scenes

 

Thanks for taking the time too reply to my queries

 

Cheers