RAAus changes to applicable requirements ...

[kasper]

Damn ... looks like i will HAVE to bunk off work Friday and head to Tamworth ... not that I give it much hope BUT if the pollies are actually listening and it is presented that:

 

1. THIS is back door avoid-tabling-in-parliament re-regulation - if CASA really needed this why not put it in the CAO and face tabling it in Parliament ... or is it just easier to effectively bully RAAus to do their bidding by the back door

 

2. WITHOUT safety support (our accidents appear vast majority pilot issue not airframe issue ... probably not too different from what HORSCOTS back in 1988 found)

 

3. has a significant financial detriment effect on THOUSDANDS of Australians

 

4. this is a strong step away from what we have (which does not have a history of airframe failures) back to where we were with homebuilt GA 25 years ago

 

5. alignment of process upwards on regulation without safety case BASED ON REAL STATISTICS is directly in conflict with this governments claimed red tape challenge

 

And given the CEO and dep Tech Manager will be there I can hopefully get the letter confirming they were 100% wrong (again) on cancelling my reg rather than wait the minimum 10 business days it takes to get a letter from Canberra to a post box in Kentucky.

 

 

[fly_tornado]

So what happens if I install a new wizbang EFIS in my 25 year old Jabiru, this is a fairly common upgrade to an older aircraft. So the installation is smooth but the L2 "isn't that familiar with this model" and I end up crashing due to incorrect calibration, of the altimeter, airspeed, GPS/compass, cylinder head temp, fuel quantity or consumption etc.

 

Can my I or my heirs sue the L2 and RAA for allowing me to incorrectly install the EFIS? Seems like by paying for an L2 inspection and a subsequent approval by the tech manager the owner is receiving a guarantee of airworthiness.

 

 

[facthunter]

IF you want a guarantee you will have to pay heaps more to cover the person issuing it, their liability insurance. The job won't be any better and there will be fewer people wishing to do it. YOU will still be dead.

 

The pilot/operator is responsible for ALL required work being done in aviation. That might be the best and reasonable if we weren't so litigious. I have a strong view the owner /pilot is capable of good results as he/she has their own life at stake, so will, if educated do the job right or seek someone who will. If I can't supervise /do all the work on the U/L plane I fly , and own, I won't be flying .Nev

 

 

[fly_tornado]

So what am I actually paying for?

 

 

[kasper]

So what am I actually paying for?

CASA ticking another ineffective box????

 

 

[fly_tornado]

Its a bit more than that though as these are skilled professionals, I am getting some sort of guarantee of safety.

 

 

[kasper]

Its a bit more than that though as these are skilled professionals, I am getting some sort of guarantee of safety.

Nope. The design authority still sits with the initial builder and you are just paying for a tick in the box.

Still permitted to build a plane out of old paddle pop sticks and register it ... but your recommendations tot eh Tech Manager on limitations during your test period may be quite restrictive.

 

CASA and RAA Tech still do not seem to get it that this is experimental and the design authority as well as responsibility sits with the builder/owner AND the CAO is structured that the determination of application within the CAO attaches to the airframe at the single point of registration

 

Welcome back to the 1990's

 

 

[fly_tornado]

So another scenario, Oscar buys another crashed Jabiru, it has a damaged wing and decides to glue it back together, this is considered a repair and is not subject to an inspection. But when he replaces the J1600 with an J2200 that modification requires inspection

 

 

[facthunter]

It is apparent that CASA is moving to reduce it's liability about anything. That is why the stuff the CASA put out is legaleze and virtually impossible to comprehend. The authority won't interpret it for you. You will get a different answer from each person you enquire of. Nev

 

 

[kasper]

So another scenario, Oscar buys another crashed Jabiru, it has a damaged wing and decides to glue it back together, this is considered a repair and is not subject to an inspection. But when he replaces the J1600 with an J2200 that modification requires inspection

Yes and no.

Depends on which jabiru he is repairing or changing the engine on.

 

If its a factory built one then the repair schedule has to be factory approved and inspected etc as does the change of engine

 

If its an experimental one built from kit then he can slap a coat of Polyfilla over any cracks and put a Victa Lawnmower engine on it if he pleases - the design authority sits with him

 

 

[fly_tornado]

So why not just leave the liability with the owner and have the role of RAA as a source technical guidance.

 

 

[kasper]

So why not just leave the liability with the owner and have the role of RAA as a source technical guidance.

But thats what we used to have ... and apparently this gives CASA the heeby jeebies hence the return to authoritarian process and oversight that in truth is nothing more than box ticking.

And if CASA and RAAus want to have their fun with this I will build a 95.32 homebuilt single seat trike out of scaffold poles and a beadspread after the changes to prove the point that I can do as I damn well please ... all they can do is restrict he first x hours of flight

 

 

[facthunter]

For a non flying school plane , that's close to what it should be. but don't ask to fly it in controlled airspace or over a city, town or populous area. Nev

 

 

[kasper]

For a non flying school plane , that's close to what it should be. but don't ask to fly it in controlled airspace or over a city, town or populous area. Nev

Agreed. If it aint certified then it should leave people alone, problem is that SO many of the owners of 19 reg aircraft that are in effect the same as a certified keep pointing fingers and saying it aint fair ...

 

 

[facthunter]

The aeroplane may be identical, but once it operates under a certain regime where exemptions apply to CAO's etc it then becomes a horse of a different colour. You can't cherry-pick the scene. Nev

 

 

[Oscar]

Well, Oscar's aircraft was first registered as a 95.55 machine, certificated under BCAR S. To maintain that status, JUST the FLYING test section that requires a response is somewhere in the order of 260 individual statements of compliance, each one requiring comment in every box that, for each requirement, is: Means of Compliance > Who will Recommend Compliance> Who will find Compliance > Remarks.

 

Most of those boxes will be 'N/A' response but there must be a damn response in every box! So, for instance, for S23 - Load Distribution Limits, you get the following: 'Means of Compliance': 'No change'. 'Who will recommend Compliance": 'N/A' Who will find Compliance': 'N/A'. 'Comments': 'CG limits are not affected. Compliance is shown at the Existing CG limits, as applicable.'

 

One Compliance box down, about 259 to go... And 'Who will Recommend Compliance' will be an ex-CAR35 engineer, and 'Who will find Compliance' will be a Part 21 M engineer.

 

And - this is NOT a requirement from RAA, but from CASA, who certificated the thing.

 

 

[fly_tornado]

Are you enjoying the compliance process?

 

 

[M61A1]

I agree, regulators cant be trusted with good intentions. Their creeping action of choking free thought and behaviour is constant and relentless. To slow it down IS the better of the situations.CASA and many in RAA were of the understanding that only builders could modify 19 aircraft and this was always the case. I have a list of heated emails arguing this with board members and TM. Its why 19 were left out of MARAP process originally.

 

There was real chance CASA was going to rewrite regs to make this clearer. Your comment that this reasoning "is rubbish" defies logic and indicated we have options or some kind of negotiating position with whatever SSAO decides will be the action of the day.

 

The current position is far better. At the least we are able to discuss/modify and approve within RAA. Many are now able to modify and upgrade due to this new system which MARAP is a part of.

 

CASA have every intention of regulating RAA experimental back to GA standards. They arent even comfortable with the situation there.

 

This has put brakes on this for the time being.

I agree that it is better to have RAA manage mods for RAA aircraft, but no, homebuilts have always been left alone as long as they still met the requirements. I can understand that factory built aircraft should need some form of formal engineering process, so the FT's of this world feel they know who to sue.

The "rubbish" comment is more to do with my disgust in the management in the way in which they deal with things by telling us they negotiated a "least worst "option, when the original regs quite clearly do not require it.

 

Having read through a good portion of the new mag, I can see we are a long way down that slippery slope, and those who still stand up a spout on about there being nothing stopping "grass roots" ultralighting, have been proven wrong, they have made a truckload of new processes and procedures to be complied with, and then THEY decide whether or not you can.

 

 

[facthunter]

Ir's easier to give in than have CASA get up you. Airlines used to punish pilots severely to keep CASA off "their"backs also. It's not the way to get the best outcome(s) Nev

 

 

[fly_tornado]

so the FT's of this world feel they know who to sue.

This sort of regulation is more about squeezing out cheap aircraft ownership options and pushing pilots into renting, good for the flying schools but bad for the industry in the long run.

 

 

[Oscar]

And that, coming from one of the chief banner-carriers waving flags against Jabiru?. You must love the smell of hypocrisy in the morning...

 

 

[fly_tornado]

Jab are still garbage, if you keep taking it back to bundy to get it fixed it's not a cheap option.

 

 

[facthunter]

It's a wonder a lawyer or two doesn't come after you. ft. Nev

 

 

[fly_tornado]

Because that would require Jabiru to defend their engine's reliability record.

 

I'd love to buy a 2200 but I just don't want to be that guy.

 

 

[jetjr]

An EFIS upgrade would require nothing but a email Id expect, No inspection or nothing. Id suggest its a good idea to make sure installed correctly.

 

New replacement engine same or similar would also require a email, L2 wasnt needed.

 

Replacing a part same as original would quite sensibly require an L2 or at least another maintainer as you have fiddled with control cables