RAA, Recreational Aircraft and ultralights ...

[kasper]

 

I am coming to the conclusion that:

 

• the distinction between GA and RAA aircraft has disappeared.
   
   
  
• the policy as applied and operational management of RAA do not see that the distinction is important
   
   
  
• 'high end/GA RAA' fleet and owners are driving RAA further into the the GA space in terms of airframes and operational limitations
   
   
  
• experimental RAA - be it 95.10, 95.32 or 95.55 are being ALLOWED by the RAA to become more and more controlled and aligned to factory built aircraft to the extent that there they may as well be home built factory aircraft.
   
   
  
• it might be time to consider the creation and operation of a new ULTRALIGHT organisation to move away from 'GA-lite' and to put back the ultralight in Australia and draw a line around them and their operations.
   
   
  

 

 

I am not going to write up all my reasons and evidence behind the above statements but post the thread here to hear from the rest of Australia.

 

And sorry to the rest of the world on this thread - I am not looking for comments saying that 'we have always had a permit system' (UK) or 'always had an inspection regime' (NZ) is not the point. We in Australia DID NOT have these on our experimental ultralights and our safety record is not horrendously bad as a result.

 

I am look to understand what RAA and Australian pilots think ultralights here are supposed to be about because:

 

• If the RAA has decided to abandon these freedoms to achieve greater access to airspace etc to allow the high end to operate effectively as 2 seat GA aircraft I think that is a price too far.
   
   
  
• If RAA has decided that there is no ability or point in saying NO to CASA anymore and just saying that's it, then that is a separate issue for the membership to understand and accept
   
   
  
• If its just the RAA executive and tech saying its too hard or not worth arguing with CASA then that's a board decision to either accept it or tell the executive not to as policy sits with the board
   
   
  

 

 

Because if its policy to not draw a line and 'defend' the current operational limits of ultralights then I think it is valid to consider a 'new AUF'

 

 

[facthunter]

How will you grow and fund a new organisation in any reasonable timeframe to get such an organisation up and running? If it's CASA initiated why would they listen to a smaller organisation? We have over 10,000 members. Work within the present show. If there is a great amount of apathy in our ranks, where will you get a large group of inspired people from?. They will not rise like a Phoenix from the ashes. Disunity is death. We have covered a lot of ground in the last few years which were the most challenging in the movements history. Give the current team a bit of credit and support..Nev

 

 

[kasper]

Credit and support when due - absolutely eg the MARAP process to support factory built aircraft move forward when there is not a factory or willing factory is brilliant and long overdue - brought together by current team - very well done

 

However, the approach of proposing back to CASA exactly what CASA said they wanted on 19 reg aircraft to create a process of modification and inspection for second and subsequent owners that does not exist at the moment is not something I think deserves credit.

 

My concern is that it appears that to get the increased access to airspace and operational freedoms the RAA are already prepared to just roll over on airframes and inspections ... for those who are basically running GA-lite under the RAA banner this is probably OK as they probably already have their airframes maintained and serviced by L2s ... but what about those who do not? What is the regulatory justification for adding admin and cost burdon to a segment of the aircraft? If the burdon is justified by CASA on the basis that there is now an ability to fly into controlled airspace then really it should be for the RAA board to openly state this BEFORE going ahead with it ... at the moment that does not seem to be the case.

 

 

[Guest asmol]

Who really cares about all this ?

 

You can legally fly now under the current system so stop winging and go FLYING.

 

 

[kasper]

Who really cares about all this ?You can legally fly now under the current system so stop winging and go FLYING.

Ummmm anyone who might want to operate a 19, 18 or 10 reg aircraft might be interested ...

and legally flying is not the point - its about the level of oversight and associated controls

 

eg on a 19 reg where you are not the original builder under whats proposed - crack a wooden prop blade in a hangar rash incident and replace with a nice new carbon fibre prop because the old manufacturer is not around and you are grounded until the L2 inspects the changes, the paperwork is through RAA in Canberra and you get the clearance .. .and then its possible you will be back on a test flight schedule

 

So simply saying go fly may just become a hell of a lot more expensive with nice chunks of time with aircraft grounded ...

 

 

[facthunter]

CASA can require whatever they want. They don't have to do trade offs..

 

I have a lot of controlled airspace time but do NOT believe we need more than transit a zone ability. The extra liability is large. IF you stuff up you may lose your house.

 

User pays should be a principle adhered to. It's only fair and I think the board members would appreciate this.

 

There is no doubt CASA have hardened up on this. the last CEO was not sympathetic or across the essence of the movement. Perhaps that will improve now but I wouldn't bank on it. Nev

 

 

[kasper]

CASA can require whatever they want. They don't have to do trade offs..I have a lot of controlled airspace time but do NOT believe we need more than transit a zone ability. The extra liability is large. IF you stuff up you may lose your house.

User pays should be a principle adhered to. It's only fair and I think the board members would appreciate this.

 

There is no doubt CASA have hardened up on this. the last CEO was not sympathetic or across the essence of the movement. Perhaps that will improve now but I wouldn't bank on it. Nev

OK - then I'll focus on one aspect...

Is RAA :

 

1. just an outsourced administration are arm of CASA in relation to a group of aircraft and pilots or

 

2. a member organisation with delegated administration PLUS a political organisation with an agenda and program separate from CASA?

 

As the AUF it was squarely 2. ... talking to Darren about the 19- issue for second and subsequent owners and how/why the proposal is as it is RAA are looking much more like 1. in some aspects of operation

 

Another way of looking at it is:

 

CASA 'own and author' the CAOs with oversight and acceptance by parliament (they are tabled)

 

RAA 'own and author' the RAA Tech Manaul with oversight and acceptance by CASA - it's a controlled document

 

If we are now saying that we will not even defend a current privilege in our operations (end to end) because CASA don't like what we want or want a change that is not in the CAO then lets be prepared to draw the line and say NO - let them put it in the CAO if CASA feel that strongly about it BUT by imposing ADDITIONAL controls and processes through the Tech Manual we are in effect allowing CASA to avoid the oversight and scrutiny of Parliament that exists on the CAOs.

 

 

[facthunter]

Under great pressures I believe WE (our current exec) have done about as well as could be hoped. What makes you think things would just go on as easy as it used to be?. How we would be as the old AUF is conjecture. We have been overtaken by events extra to ourselves. You have to measure our situation against an even possible worse one if you want to relate to the good old days, as if they are still a possibility in the current environment. We are not another GA where you just put up with the deal dished out or join AOPA to try to get something fixed. It COULD be that we end up just as unable to control things as GA is but if THAT happens it's because WE take our eye off the ball. Most people out there who don't fly U/Ls or anything for themselves wouldn't know, wouldn't care if we didn't exist. We are a small self interest group.

 

ALL forms of non airline aviation activity must be prepared to act as one to ensure we continue at all. Take nothing for granted. WE used to lead. or we were equal to the best in the world.. Now where are we?.Nev

 

 

[Teckair]

kasper this has come up many times in the past and it boils down to this RAA has gone the way it has because it is what the majority of members want. People who wanted the AUF got run over by the mob, I watched it happen. Affordable aviation got replaced with 'lets fly GA style on a ultralight certificate mentality' and I don't think there is anything anyone can do about it.

 

 

[coljones]

I am coming to the conclusion that:

 

• the distinction between GA and RAA aircraft has disappeared.
   
   
  
• the policy as applied and operational management of RAA do not see that the distinction is important
   
   
  
• 'high end/GA RAA' fleet and owners are driving RAA further into the the GA space in terms of airframes and operational limitations
   
   
  
• experimental RAA - be it 95.10, 95.32 or 95.55 are being ALLOWED by the RAA to become more and more controlled and aligned to factory built aircraft to the extent that there they may as well be home built factory aircraft.
   
   
  
• it might be time to consider the creation and operation of a new ULTRALIGHT organisation to move away from 'GA-lite' and to put back the ultralight in Australia and draw a line around them and their operations.
   
   
  

 

 

I am not going to write up all my reasons and evidence behind the above statements but post the thread here to hear from the rest of Australia.

 

And sorry to the rest of the world on this thread - I am not looking for comments saying that 'we have always had a permit system' (UK) or 'always had an inspection regime' (NZ) is not the point. We in Australia DID NOT have these on our experimental ultralights and our safety record is not horrendously bad as a result.

 

I am look to understand what RAA and Australian pilots think ultralights here are supposed to be about because:

 

• If the RAA has decided to abandon these freedoms to achieve greater access to airspace etc to allow the high end to operate effectively as 2 seat GA aircraft I think that is a price too far.
   
   
  
• If RAA has decided that there is no ability or point in saying NO to CASA anymore and just saying that's it, then that is a separate issue for the membership to understand and accept
   
   
  
• If its just the RAA executive and tech saying its too hard or not worth arguing with CASA then that's a board decision to either accept it or tell the executive not to as policy sits with the board
   
   
  

 

 

Because if its policy to not draw a line and 'defend' the current operational limits of ultralights then I think it is valid to consider a 'new AUF'

Rather a broadbrush series of statements. Perhaps you should put some meat and muscle on the skeletons so we can see where you are missing out.

A similar statement could be made that the cookiecut, manufactured aircraft have less problems per member (and plane) than the homemades. The millions of dollars the readymades pour into RAA goes to help all planes and pilots and the necessary activities to support them.

 

 

[kasper]

Rather a broadbrush series of statements. Perhaps you should put some meat and muscle on the skeletons so we can see where you are missing out.A similar statement could be made that the cookiecut, manufactured aircraft have less problems per member (and plane) than the homemades. The millions of dollars the readymades pour into RAA goes to help all planes and pilots and the necessary activities to support them.

OK lets unroll this:

'millions of dollar the readymades pour into the RAA'

 

1. Aircraft regn fees are exactly the same between readymades and homemades - and a 2 seater aircraft provides RAA with $250 in its first year and $130 in each following year

 

2. the last financial reports from RAA showed an annual registration income of just $218,264

 

Demonstrably there are NOT millions flowing in from ANY aircraft and what flows in per airframe is the same between experimental and factory

 

Some meat:

 

Hard to recognise as an ultralight a variable pitch retract aircraft with a cruise speed in the area of 120knt+ with a MTOW getting on half a ton. They are Recreational GA-lite. Not saying thats bad but its not an ultralight - ultralights were low inertia/low energy aircraft and that is what made them fundamentally different from GA and justified the distinctly lower regulatory regime. The closer to GA your aircraft and ops are the easier it is for CASA to bring in more and more GA like processes and controls.

 

Application of this is to the move to require inspections and signoff of mods on experimentals - for goodness sake its experimental! JUST because some very high performance 'ultralights' are registered under this and their owners sort of treat them like the extra performance does not justify this. And the logic behind the application of inspections and signoff is equally applicable to 18 and 10 registrations ... may as well just give up and reg is through SAAA as GA experimental and put VH on the side.

 

As for all the great new operating limits - they are functionally not available to 10 regn ... they need to have certified or CASA accepted engines under 101.55 ... not many 10's have a 912 or a jab.

 

A bit more meat - RAA Tech applying one size fits all - apply to transfer a basket case 10 reg aircraft - had the docs done, had an ACR done and it was agreed by everyone it was not airworthy - RAA decide to try and cancel the registration rather than transfer it ... but that's NOT available to RAA under the CAO or the Tech Manual because sole determination of airworthiness is the pilot on the day and the only time the aircraft actually has to be together as an aircraft (and not even be able to start or fly) is the day it is weighed for its initial registration - that's the ultimate freedom and the concept of 'protecting' owners and pilots in some 19 experimental when there is a nice big sticker stating the aircraft is NOT designed to a standard and the CASA and RAA do not take responsibility for airworthiness is a bit of a conflict if allowed to go forward applies equally to 10 and 18 reg

 

 

[coljones]

OK lets unroll this:'millions of dollar the readymades pour into the RAA'

1. Aircraft regn fees are exactly the same between readymades and homemades - and a 2 seater aircraft provides RAA with $250 in its first year and $130 in each following year

 

2. the last financial reports from RAA showed an annual registration income of just $218,264

 

Demonstrably there are NOT millions flowing in from ANY aircraft and what flows in per airframe is the same between experimental and factory

 

Some meat:

 

Hard to recognise as an ultralight a variable pitch retract aircraft with a cruise speed in the area of 120knt+ with a MTOW getting on half a ton. They are Recreational GA-lite. Not saying thats bad but its not an ultralight - ultralights were low inertia/low energy aircraft and that is what made them fundamentally different from GA and justified the distinctly lower regulatory regime. The closer to GA your aircraft and ops are the easier it is for CASA to bring in more and more GA like processes and controls.

 

Application of this is to the move to require inspections and signoff of mods on experimentals - for goodness sake its experimental! JUST because some very high performance 'ultralights' are registered under this and their owners sort of treat them like the extra performance does not justify this. And the logic behind the application of inspections and signoff is equally applicable to 18 and 10 registrations ... may as well just give up and reg is through SAAA as GA experimental and put VH on the side.

 

As for all the great new operating limits - they are functionally not available to 10 regn ... they need to have certified or CASA accepted engines under 101.55 ... not many 10's have a 912 or a jab.

 

A bit more meat - RAA Tech applying one size fits all - apply to transfer a basket case 10 reg aircraft - had the docs done, had an ACR done and it was agreed by everyone it was not airworthy - RAA decide to try and cancel the registration rather than transfer it ... but that's NOT available to RAA under the CAO or the Tech Manual because sole determination of airworthiness is the pilot on the day and the only time the aircraft actually has to be together as an aircraft (and not even be able to start or fly) is the day it is weighed for its initial registration - that's the ultimate freedom and the concept of 'protecting' owners and pilots in some 19 experimental when there is a nice big sticker stating the aircraft is NOT designed to a standard and the CASA and RAA do not take responsibility for airworthiness is a bit of a conflict if allowed to go forward applies equally to 10 and 18 reg

Thanks for the meat, now we can work on it.

WRT millions - I'm not sure about the numbers but if 2/3 of the membership is plastic pilots then they are contributing over a million a year. I am hoping that part of the audit of Services V Revenue that RAA "should" be doing will reveal who are the "Lifters" and who are the "Leaners". Part of my complaint about ditching the magazine was that it may be the major return I was getting for the membership fee I pay.

 

 

[Guest ozzie]

Just gimme an FAR 103. I don't need no 'new AUF'.

 

 

[facthunter]

I don't want to fly what I'm not fixing. We are running out of good mechanics. Nev

 

 

[turboplanner]

I don't want to fly what I'm not fixing. We are running out of good mechanics. Nev

If that's the case then RAA privileges for maintaining own aircraft should be curtailed at the same rate.

 

 

[kasper]

And if we are running out of good mechanics ... and the CASA/RAA are making it compulsory for a significant sector of our aircraft (all 19 reg not owned by original builder) to have L2 signoff of ALL modifications (minor or major) AND the aircraft is grounded until that and the admin process is finished can you from a practical capacity and use perspective see that the change as difficult?

 

Oh from a personal perspective I should be happy - lapsed L2 here and if they keep going this way with increased involvement I might look at going back into that but I just do not like to see 'experimental' being turned into quasi factory built on a justification of 'protecting' the people inside - its experimental, its stated as such and logically there is no distinction between someone flying a plane built/assembled by the owner and someone flying the same plane when its been sold to someone else.

 

 

[facthunter]

It probably takes less knowledge to build it initially than maintaining it, in some cases at least. Damage repair is more difficult than initial build.

 

If you build from old drawings /plans only then you are in a different category. but usually all your components are new and YOU don't have to repair an engine for example.

 

A second or subsequent owner may well vastly improve a plane if qualified and capable.

 

Owners are involved with their own safety a strong motivator to be careful. Education not regulation is the key to higher quality outcomes. Nev

 

 

[coljones]

Owners are involved with their own safety a strong motivator to be careful. Education not regulation is the key to higher quality outcomes. Nev

As is commonsense and quiet contemplation of the whole task at hand.

 

 

[Guest ozzie]

Part 103 is alive and well not to mention growing in the US. Europe and the UK have seen the light ours was snuffed out 35 years ago. Shame over regulation and a minority of 'do what we say' has killed it here.

 

http://generalaviationnews.com/2015/04/29/part-103-ultralights-are-hot/#comments

 

 

[Happyflyer]

Ozzie is right, 103 sounds fantastic. Single seat, 115 kg max empty weight, 24 kt max stall speed, no licence, no rego. The reg can be written on back and front of a single A4 page. However it is very hard to see this amount of freedom allowed here with our current culture of over regulation. Doesn't mean we shouldn't try though!

 

 

[Methusala]

So many owners have modified their original aircraft to improve the safety, utility and flying qualities over the original design. Mostly this goes unremarked unless the mod results in a failure. I added a turtle deck extending back to the rudder on my Volksplane. This improved airflow over the rudder so well that when i first took off the rudder felt as thought it was locked! Gone was its horrible dutch roll when flying straight and the rudder was actually far more effective at yawing the aeroplane. We are required to placard these machines so that pilots and passengers will know that it is not certified to any standard.

 

 

[Guest john]

Unfortunately the good old days of freedom to fly are over due to all the red tape & bullshxt that CASA , ASIC &RAA have implemented over recent times ,& those of us that have been privileged to be involved in the good times at least can dream about them now. The young ones now becoming involved in aviation, only know what exists now & have not been privy to the good old times .

 

More stricter rules & regulations from both CASA & RAA are only going to go from bad to worse in the near future as sure as night follows day, whether we like it or not, so all one can do now is try & keep the DREAM ALIVE.

 

 

[Deskpilot]

In today's world, I think the 55knot max speed will kill it off.....again. Too much 'need for speed' these days.

 

 

[Guest ozzie]

The way the Americans got around it is that they are classed as recreational vehicles, not aircraft. Challenge CASA tell them you want your original ANO95:10 back.

 

 

[bexrbetter]

Ozzie is right, 103 sounds fantastic.

Or is is that higher classes of flying are ridiculously hard to meet for most and 103 less hassle and cheaper?