Random Paperwork Inspections

[billwoodmason]

Bill,You bitch and sook about what you don't get. Then you bitch and sook when RAAUS tries to give you more!!!!! You are high maintenance.

Mr Tatlock,

I'm entitled to express the truth as I know it, you may not like and are entitled to stick up for your mates in Canberra but I don't think personal attacks are appropriate - so in future keep your remarks about me to yourself - you do not know me personally.

 

 

[Yenn]

Why bitch about it. We are supposed to keep maintenance records. No reason given, but to me it is obvious keeping records of maintenance helps work out any problem that arises.

 

Those who don't like a random sampling would no doubt also not like having to produce records at every rego renewal. That would also be very expensive in time and money for RAAus and they would then have to increase fees.

 

I use the same maintenance release as for GA as it appears to me to be far better than using the maintenance log book for daily inspections.

 

 

[dutchroll]

I'm simply making the point Nev that "it's only a hobby, therefore I shouldn't need to keep compliance documentation" is not a very good argument and it doesn't wash anywhere in the world, except in despotic 3rd world countries with little or no functioning legal system.

 

I could've used any of dozens other examples of "private hobbies" where licensing, compliance, possible inspection of paperwork, etc are all applicable.

 

Honestly, if people truly want to be completely free of the "burdens" associated with doing stuff in a society, they should go and live in a remote cave in the mountains somewhere, but as soon as you start interacting with others, you have to deal with documentation/compliance/inspection regimes, and where you have those, you could have a requirement to produce evidence of it at any time.

 

Building something on your own block? You can be required to produce evidence of building compliance - even years later.

 

Going rabbit shooting with the lads? You could be asked to produce a licence, and you could be randomly inspected at home for firearm security.

 

Driving to a picnic? Firstly in most States you can't even renew your annual rego without inspection paperwork being forwarded to the appropriate authorities. You could also, if you are stopped, have your family Commodore inspected for defects even if there's no obvious reason there should be any, and asked for licensing documentation, and have your registration checked.

 

What is it about flying a plane which makes some people feel they should have special privileges and be exempted from this stuff?

 

 

[Keith Page]

Why bitch about it. We are supposed to keep maintenance records. No reason given, but to me it is obvious keeping records of maintenance helps work out any problem that arises.Those who don't like a random sampling would no doubt also not like having to produce records at every rego renewal. That would also be very expensive in time and money for RAAus and they would then have to increase fees.

I use the same maintenance release as for GA as it appears to me to be far better than using the maintenance log book for daily inspections.

Got to be a system and process with in the SMS. You all talking about auditing well some news there is no registered system and process in the SMS as to which path is used to monitor the log books.

Regards,

 

KP.

 

 

[facthunter]

Dutchroll, I'm not against record keeping. I do it on every vehicle or machine I run but the point I make is that what a GA, C-172 does is not necessarily the measure we should just adopt.

 

Signing a document something like Daily pre flight radio inspection carried out on VH ABC in accordance with CAR 124?? 3 (b) on 12 / 04/ 16 doesn't prove it was done properly or at all.. My inspections are rather thorough. People used to comment on the things I found wrong. I didn't make them wrong I just found the problems and if you find a few, you wonder if there are more you haven't found. Some people don't record problems and just carry the fault or malfunction even in the big stuff. I noticed sawdust on the ground near the door of an Auster I was going to fly some time back. ( over 55 years) and opening up a zipper on the fabric found RATS had been chewing the wooden wing spar badly. (There has to be a reason sawdust is on the ground) I could go on with pages of stuff like that. I could write a fair sized book. It's not about MORE paper work. Its a culture of safety and It's in your head. Nev

 

 

[M61A1]

I'm simply making the point Nev that "it's only a hobby, therefore I shouldn't need to keep compliance documentation" is not a very good argument and it doesn't wash anywhere in the world, except in despotic 3rd world countries with little or no functioning legal system.I could've used any of dozens other examples of "private hobbies" where licensing, compliance, possible inspection of paperwork, etc are all applicable.

 

Honestly, if people truly want to be completely free of the "burdens" associated with doing stuff in a society, they should go and live in a remote cave in the mountains somewhere, but as soon as you start interacting with others, you have to deal with documentation/compliance/inspection regimes, and where you have those, you could have a requirement to produce evidence of it at any time.

 

Building something on your own block? You can be required to produce evidence of building compliance - even years later.

 

Going rabbit shooting with the lads? You could be asked to produce a licence, and you could be randomly inspected at home for firearm security.

 

Driving to a picnic? Firstly in most States you can't even renew your annual rego without inspection paperwork being forwarded to the appropriate authorities. You could also, if you are stopped, have your family Commodore inspected for defects even if there's no obvious reason there should be any, and asked for licensing documentation, and have your registration checked.

 

What is it about flying a plane which makes some people feel they should have special privileges and be exempted from this stuff?

The point seems to have been completely missed. Not talking about producing licences ( a document certifying some for of competence), but the need for keeping records as a matter of compliance. Some records are necessary, some are not. Keeping documentation up to RPT or military standards may be what gets some people off, but it's just not necessary. Yes, you can have your Commodore inspected, but I bet they don't ask for the last 12 months of maintenance records. They won't even check to make sure the mechanic was qualified.

The comment "what is it about flying a plane", could easily be why is it that in aviation we feel the need to be special and feel the need for rules and regs that other parts of society feel completely unnecessary.

 

 

[billwoodmason]

I believe this request for compliance is a forerunner to the introduction of the Ops / Tech manual which is rumoured to contain stringent compliance demands backed by disciplinary actions and or fines, suspensions or deregistration for non compliance. This document is shrouded in secrecy and a major component to its implementation is the first move to Company Limited Liability status. The main reason for putting this in place is the reduced number on the board so that the no votes are done away with.

 

It seems the RAA is to become the enforcer. ie to take over CASA's ( Coots Against Small Aeroplanes) role.

 

It is imperitive that the introduction of this Constitutional change is slowed down so that the full impact of it and the updated Ops / Tech manuals is fully understood by the membership before its put in stone.

 

I urge every member to vote and in the interests of fairness vote NO to slow down this process so that nothing is done that could be detrimental or costly to members.

 

The RAA is supposed to be a members association whose charter is to represent it's members not the regulator.

 

If this is allowed to continue we are going to need a members association to represent us against our existing RAA association.

 

Somewhere along the way with the changes of CEO's etc the focus on our members rights has shifted to a focus on heavy handed policing of what the members are doing.

 

If these changes in total are adopted it is going to be costly to our members. AUF/RAAus was introduced as a low cost, minimum regulation form of recreational flying which it appears may be a thing of the past.

 

 

[facthunter]

Bill, most of what you have said there I predicted many years ago and went on record here with it. It must not happen or we have LOST our organisation and all the work that has been put in by many right back to the origins of it. A few years ago (about 6 Now) we looked as if we could lead the world then a certain person took over CASA and it's been downhill from there in large lumps. Nev

 

 

[DonRamsay]

Nev, Bill's idle speculation is utterly baseless and will have been seen to be like the claim "the sky is falling!!!" when V4.0 of the Tech Manual is released to all members, shortly.

 

The trend now in RAAus is to push back hard against any attempt by CASA to impose restrictions or obligations that do not have a demonstrated risk management safety case and/or conflict with Skidmore's 10 point plan.

 

I do understand why people like Bill can be so easily persuaded to expect the worst because of the performance of both CASA and RAAus in the past. But, as they say in investment circles, the past is not a guaranteed prediction of the future.

 

I also expect that the doubters are very unlikely to accept my apparent optimism and will "believe it when they see it" for themselves. I have no problem with that approach.

 

 

[facthunter]

OK I hear it . We do have a lot to lose and if the past is any gauge at all we have reason to be concerned. I do hope Skidmore does well and I have a glass of red with him one day. Nev

 

 

[pmccarthy]

I'm going to have a glass of red right now, in case I don't ever meet the man.

 

 

[Oscar]

With due respect to all, this debate is getting way off the mark. Linking it to the proposed constitutional changes is really a bridge too far.

 

May I ask everybody to look at the ACTUAL role that CASA imposes on all SASA organisations (the bolding is mine):

 

Australian sport aviation operates under self-administration. This means that CASA sets the regulations and then through its dedicated self-administering sport aviation office (SASAO) works in close cooperation with established recreational aviation administration organisations (RAAOs), to make sure the regulations are applied and enforced. The RAAOs provide CASA with specialist knowledge of, and insight into, the sport aviation industry.

 

 

 

 

 

The Sport Aviation Self Administration Handbook 2010 provides further detail of CASA’s expectations for RAAOs and their board members in ensuring that self-administration is providing a safe environment for sport aviators, as well as for other airspace users and people and property on the ground.

 

 

 

 

 

RAAOs are required to meet performance standards and undergo surveillance events (audits). The organisations must continually assure CASA that they are providing appropriate oversight of their sport aviation activities and managing risks.

 

Anybody who has had to deal with CASA directly, knows that it can be dictatorial, unpredictable and sometimes downright vindictive in the way it approaches the 'industry'. The Forsyth Review highlighted this concern that was - and remains - an endemic problem for everybody under its jurisdiction - which means, anybody who flies anything (including drones flown using your iPhone.. Kites may be excepted). Ask any engineer who has worked under the CAR regime, or now works as a Part 21M engineer, about dealing with CASA.

 

In order to gain more 'freedom' to just fly our aircraft around, blaming RAA (or SAA, HGFA or GFA) is tilting at the wrong windmills. Whilst ever CASA is THE 'authority' with the power, we are stuck with it. If you want change, then get POLITICAL, lobby for exception - rather than exemption - from CASA authority, to be recognised in Federal legislation. Good luck with that. I'll happily join with anybody in pushing for it, but I will not expect to be successful. Once Federal legislation is invoked, removing it is historically almost never successful.

 

If RAA had invested, years ago, an IT-based on-line system for reporting and recording maintenance compliance, these audits would not be required - other than perhaps to prove that the self-reporting was accurate and true. CAR 35 and Part 21M engineers are subject to CASA audits, about every 2 years; it takes weeks to ensure that every piece of paperwork is 100% in order, and sometimes days to undergo the audit. What does it take to photocopy your log books and post that off? A couple of hours?

 

Random audits of many aspects of our lives is a fact of life. Have you ever looked at the powers of the ATO to audit your financial records? It exceeds most Police powers!. If you can't produce every bit of paper for the last 7 years - you can be in deep cacky. Have you never been pulled off the road for an RBT? If you hold a gun licence, you WILL be visited by the Police for an inspection of your storage facilities and the fact that all your guns are securely in that storage facility, with the bolts and ammunition in a separate locked facility, and they don't make appointments. OHS inspectors can descend on your workplace at any time - and I happen to know of one case where this happened and the builder of crew (house-building) was charged for not having provided safe seats for smoko- they were sitting on their eskies - and several were charged with having no record of their passengers travelling in their registered vehicle to the workplace. If you are an owner-builder knocking up a shed - you are not immune to inspections.

 

It is entirely possible - I completely accept that - that these RAA audits are not being handled in the best possible way. I believe that RAA is coming from so far behind the 8-ball in regard to its systems - and that is a legacy of years of ridiculously / scandalously poor administration - that it has to adopt an inefficient methodology to accomplish this. It will take quite a lot of investment in systems development to improve that situation.

 

I would suggest, that these audits are a response BY RAA to keep RAA members protected from worse consequences, should CASA determine - arbitrarily as CASA does - that there is a 'safety' issue they decide to address. CASA is the master of inventing ways to augment its authority and by that, improve its intervention in matter of aviating - thus increasing de facto its powers and staff required to implement its powers.

 

If you are really, really incensed by this action by RAA, then just possibly, you are participating in the wrong sport. Try rock fishing - it has less intervention. You have a statistically greater chance of being killed, but it's your choice.

 

 

[kaz3g]

I think it's time to stop and smell the roses :construction:f

 

And perhaps write those letters to the new Minister who seems to think everything is ok in their world of aviation and CASA is doing a great job keeping the public safe.

 

Kaz

 

 

[planesmaker]

Don, why is it that the soon to be released tech manual has not been out to be commented on by the members? Has CASA already approved it? or is it still drafting and open for membership comment?

 

Tom

 

 

[kasper]

clipped ... Just give Jared a ring and ask him. He's a very reasonable fellow and he can give both the legal basis for the request and the policy thinking behind it....

Would this be the SAME Jarad that last week decided after 18 months of working on registering my aircraft under 95.10 decided that LEGALLY it was NOT possible to register any weightshift under 95.10 - advised the CEO of this and had my reg cancelled???

Is this the SAME Jarad that works with a Tech Manager that write Tech Articles for the Mag on regulations YEARS out of date?

 

Same Jarad that turns on MEMBERS and says I am being difficult and trying NOT to comply when pointing out for 6 MONTHS that the Tech Manual is deficient on a specific requirement?

 

Same Jarad ...

 

I'll stop there but on 1 aircraft registration I can list MORE error in LAW from Jarad/Darren so Don I am not surprised members ask for clarification/guidance here because from my experience what you get on legal requirements from Tech Office depends on the day of the week and the who you get

 

 

[Kiwi]

The same Jared that has always been courteous and helpful, The same Jared that always returns my calls and emails ?

 

You catch more flies with honey than vinegar.

 

 

[kasper]

The same Jared that has always been courteous and helpful, The same Jared that always returns my calls and emails ?You catch more flies with honey than vinegar.

Agreed - honey for the first year then it goes a bit sour ... and after he cancels your reg 4 weeks after the card arrives in the post its a bit hard to be generous

 

 

[kasper]

clipped ...The trend now in RAAus is to push back hard against any attempt by CASA to impose restrictions or obligations that do not have a demonstrated risk management safety case and/or conflict with Skidmore's 10 point plan.

...

So according to Michael Linke who STATED that the decision to legally required for the first time L2 signoff on any/all mods to 19 reg aircraft coming FROM the Board and not CASA is an example of the Board pushing back hard agaisnt CASA?

And moving from 1 inspection at the end of the 19 reg process and replacing that with 4 inspections is addressing exactly what demonstrated risk?

 

You can say whatever you like Don on what the board see BUT when the membership SEE the opposite in print on V4 of the tech manual in our magazine AND the CEO states unequivocally that these were NOT requirements of CASA but FROM the board you have to expect a few raised eyebrows on the part of members

 

 

[DonRamsay]

Don, why is it that the soon to be released tech manual has not been out to be commented on by the members? Has CASA already approved it? or is it still drafting and open for membership comment?Tom

Tom,

If you would like to know how much and with whom the consultation has been done, you'd get a better briefing from the Tech Manager.

 

 

[kasper]

Don, why is it that the soon to be released tech manual has not been out to be commented on by the members? Has CASA already approved it? or is it still drafting and open for membership comment?Tom

According to Michael Linke on Friday its an interative process - the draft as it was going to the Board HAS been approved by CASA but the board could reject it ... but unexpected as RAAus wrote it so effectively its a done deal unless the board decide to change their minds on what was put forward to CASA

 

 

[DonRamsay]

Would this be the SAME Jarad that . . .

ad nauseam.

 

I am happy to reiterate about what I said about Jared above and ask people on here to understand that you are only seeing one side of this matter on here.

 

I hope that the Tech Dept. don't get into a discussion on line, in public, of one member's dispute with RAAus. There is a clear appeals process available to Kasper from Tech to CEO to the Board. My knowledge about this matter is not great. It is not my area of expertise and I'm happy to let the process work its way out and if it ends up at the Board then I will make sure I am fully aware of all aspects.

 

Don

 

 

[kasper]

And would this be the SAME Tech office that appears to have allowed onto the RAAus 95.10 register a factory built aircraft (completely illegal under 95.10 at the time it went on the register) that just happens to also be a weightshift?

 

http://www.ebay.com.au/itm/Airborne-T-Lite-Nanolight-Trike-/201576991891?hash=item2eeeeccc93:g:kdQAAOSwLs5XKd3o

 

Seriously the Tech office seen to have one rule for some on one day of the week and a different rule for someone else on other days of the weeks ...

 

 

[rankamateur]

And moving from 1 inspection at the end of the 19 reg process and replacing that with 4 inspections is addressing exactly what demonstrated risk?

And just how does a 19 builder with a near complete plane organise these other 3 inspections at this end of the project?

 

 

[kasper]

And just how does a 19 builder with a near complete plane organise these other 3 inspections at this end of the project?

That would be a question for either the Board or the Tech office ... after they have published the Tech Manual

 

 

[planesmaker]

Tom,If you would like to know how much and with whom the consultation has been done, you'd get a better briefing from the Tech Manager.

Don that really did not answer anything, does the board have any input or know what is going on?

If what Kasper refers to 19 building requiring 4 inspections, surely the members should have a say! VH exp only requires one inspection or are we going backwards to years gone by under amateur built category? What is the justification for extra inspections? It is not a CASA requirement. Tom