Random Paperwork Inspections

[DonRamsay]

Very well put jetjr.

 

Everyone suspecting malevolence and more regulation when what the Tech Manager is doing here is helping us to hang on to our most valued freedom.

 

A few apologies would be good to see and some gratitude expressed for the great job Darren has been doing in digging us out of a deep hole that he had nothing to do with creating.

 

And how about a few of the perpetually, negative and always suspicious posters on here giving RAAus the benefit of the doubt until you know the facts?

 

This perpetual uninformed bagging of real people doing their level best wears pretty thin. Imagine how you would feel if people you didn't know, who hid behind pen names, who lack the full facts continually tell you what a crap job you are doing?

 

Don

 

 

[kasper]

and when will Darren and Jarad start putting in writing apologies to members for their errors and mistakes?

 

and whilst there are compliance issues with existing documentation requirements on airframes I am really looking forward to the new tech manual to see how much EXTRA paperwork is being added to a system that is already not working well ... and the reasons for the added paperwork.

 

Because if an existing system is not working through user disengagement its not a smart thing to ADD to the system becasue that will just lead to more disengagement and poorer outcomes.

 

 

[jetjr]

They are Ok admitting mistakes, maybe not to someone still giving them a hard time both online and in person.

 

A key problem is that tiny portions of the membership burn up massive amounts of time on complicated issues especially those requiring CASA interaction. No doubt they are valid concerns and need attention. Its a problem handling so many types of aircraft under one small tech team.

 

Granting permission in the past to fly without credible information being clear and supported in CASA's view, has landed the technical team in trouble in the past which persists today. Theres another threads with owner calling for legal action over previous approvals being revoked.

 

As with any good technical document, the new one will be open to suggestions and changes and no doubt see regular updates. Id imagine a hard part may be sorting out the real problems and workable solutions from those continually complaining about everything.

 

EXTRA PAPERWORK......did you read post #125?

 

We arent doing it currently, so can hardly be called extra

 

 

[kasper]

They are Ok admitting mistakes, maybe not to someone still giving them a hard time both online and in person.As with any good technical document, the new one will be open to suggestions and changes and no doubt see regular updates.

Really?

On my experience they are not great at actually putting that in writing ... in fact they managed to brief the CEO to such an extent he sent a very sarcastic email to me basically saying I am too dumb to understand the words in the tech manual ... even though BOTH of the members of the tech office had accepted the words were deficient AND had gone back to CASA MORE THAN A YEAR BEFORE to get change to the wording yet feel happy coming along and leaving a MEMBER who had been trying to HELP tech manager for MORE THAN A YEAR with a cancelled registration on the basis of false advice and a sarcastic email from the CEO.

 

You MAY think that they are good at accepting their errors BUT I am still waiting for the letter rescinding the cancellation of my registration - coming up two weeks now ...

 

 

[jetjr]

A common approach with upset customers, suggests the descision at some point that nothing will satisfy them, now or in the future.

 

Stop trying and move on to helping the majority of members, appreciative of efforts.

 

 

[kasper]

A common approach with upset customers, suggests the descision at some point that nothing will satisfy them, now or in the future.Stop trying and move on to helping the majority of members, appreciative of efforts.

So 'move on' leaving 1 member with an unregistered plane after 20 months is an acceptable outcome in a member organisation?

1 member without service doesn't matter so long as the other 9,999 are ok?

 

I am aware that pissed off customers will never like you ... but if I work thorugh their issues and give them what is acceptable and possible at least I have done the best ... RAAus do not seem to get that part of 'customer' service

 

 

[fly_tornado]

The RAA registry audit debacle resulted in 300+ being struck off the registry. That's a guess as no one from the RAA has ever told the members how many aircraft where lost

 

 

[Spriteah]

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. We currently have everything you mentioned except fines. I very much doubt RAAus will introduce fines. This document is shrouded in secrecy and a major component to its implementation is the first move to Company Limited Liability status. What secrecy? Tech and Flying instructors across the nation have viewed and commented on the documents. So have the board members, just rubbish. The main reason for putting this in place is the reduced number on the board so that the no votes are done away with. Name one resolution that was blocked by majority of the board in the last three years.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. Well you and you supporters failed in this already as the vote has been and gone with overall support of the members. CASA can stop RAAUS from flying at anytime. It is therefore the duty of the board and CEO to ensure this never happens.

 

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. Name one occasion where there was heavy handed policing handed out by RAAus or its employees.

 

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. AUF originally you could only fly upto 500 ft and not cross a road. Are they the days you long for? If so find a mates paddock or buy one yourself. Get a scout and cut loose. Hopefully the neighbours won't dob you in.

Guys and gals,

 

The sky is literally the limit for our great organisation. Your staff and volunteer board, flight schools and many others work tirelessly for you. Stop throwing rocks and join in the fun. If you ever want to help and have a skill set you can offer then make yourself known. Intervene when you see members doing the wrong thing!

 

I hope you get on board Bill. Apologies if you thought I was attacking you. All those that know me realise I work for the good and future sustainability of the organisation. The past is exactly that. The future is what we, the members make it.

 

Jim T

 

 

[Spriteah]

So 'move on' leaving 1 member with an unregistered plane after 20 months is an acceptable outcome in a member organisation?1 member without service doesn't matter so long as the other 9,999 are ok?

I am aware that pissed off customers will never like you ... but if I work thorugh their issues and give them what is acceptable and possible at least I have done the best ... RAAus do not seem to get that part of 'customer' service

What is the reason the plane is unregistered. Does it fit correctly within our permissions?

 

 

[Spriteah]

The RAA registry audit debacle resulted in 300+ being struck off the registry. That's a guess as no one from the RAA has ever told the members how many aircraft where lost

Struck off? Well a few were incorrectly registered as factory built. Casa eventually agreed to allow them on as 19. Plenty of owners retired their aircraft and I believe this was mainly due to them in states of disrepair in the back of the garage. I'm not sure many were struck off. If the owners chose not to provide requested documents then they were not re-registered. Pretty much the same as car rego. If your asked to provide a roadworthy and proof of ownership then you either do that or you car is not registered.

 

Hope that makes sense. Jim T.

 

 

[Spriteah]

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.

Never have truer words been said. Well put. Ps some on this board will find blame with the fish or waves.

 

 

[fly_tornado]

From the figures published in the magazine, I have observed that there was a net loss of 300 planes over the audit period. When consider how many new planes were added to the registry over the 2 odd years it was running thats a decent drop. I don't think they were all misregistered. At a conservative estimate of $20K a plane thats $6M of planes scrapped. Again that's a net number, not a gross number which would be closer to around 500.

 

 

[Spriteah]

And its also not supposed to be about 'its better than we have even though its not what we would/should have'The fact that there will be a 4.1 should in my opinion not in any way allow through in 4.0 new regulation, cost and bureaucracy that is not supported by a risk based assessment.

 

Loath to tie this to the argument that the Constitution as presented is not the best but its better and we need to move forward ... but the comparison might be made.

 

have fun on the briefing ... and FYI your notes from members on areas to explain MIGHT have been a touch more timely and complete IF the draft had been released to members for comment ... just saying

All our documents and policy should be living documents. Change with the industry as required. Jim.

 

 

[facthunter]

Perhaps plenty have realised aviation in this country isn't getting a very good deal, and have given up waiting for improvement. There's plenty of other factors outside of RAAus control. Once a plane sits for a while it's not something you just jump in and fly.(If you have any brains). Nev

 

 

[kasper]

What is the reason the plane is unregistered. Does it fit correctly within our permissions?

The plane was unregistered because I removed it from the UK register where I had been operating it for a few years after designing and building it myself,. It fits smack bang in the middle of 95.10 and it took a HUGE effort to get RAAus Tech to accept that the single failing to getting it registered was their own interpretation of the tech manual.

The full history of the issues and actions by RAAus Tech office and the CEO are with a current board member for direct raising with them at yesterdays board meeting.

 

So there is absolute acceptance that its single seater self design ed and built - that was worked through with UK CAA and also with RAAus Tech back in 2014 ... and the receipt of the final reg card is dated 31 March 2016 following payment of the full reg finalization fee on 10 April (lost the $50 regn number reservation due to SO many delays) and the CEO email effectively cancelling it from 95.10 on the advice of Tech office was dated 2 May - my registration effectively lasted less than a month.

 

But until I hear back from the board member OR the CEO decides to actually sent the letter restoring the regn that he said was in front of him on 5th May but remains outstanding I am gently simmering. Particulraly as RAAus Tech NOW (AFTER they issued the regn invoice and the FULL REGISTRATION have said that they either never got the pics and weight dec or they misfiled it becazue they NOW can't find it ... great new admin system we have eh?

 

 

[kasper]

All our documents and policy should be living documents. Change with the industry as required. Jim.

Jim - your task this evening it to read from the RAAus website the RAAus Tech Manual section 9.1 on registration markings for 95.10 aircraft that has applied since 2014 and answer this - if you have a 95.10 weightshift aircraft which sections of that apply to the aircraft.

hint - answer is there is NO requirement to mark AND RAAus Tech have no discretion under the tech manual as it stands today ... and this was pointed out to Darren on the phone and in email by me on day 1 of that sections application because he told me to hang off registration under the old sections because these new sections would fix all the problems of the old Ops Manual words!

 

Agree absolutely that documents need to be dynamic - but they also need to to accurate and provide complete coverage and be reasonably applicable - NONE of which can be said for tech 9.1

 

 

[facthunter]

It's clearly NOT working for you. Since you have been stuffed around perhaps a concerted effort to expedite it might be in order. Nev

 

 

[nong]

Struck off? Well a few were incorrectly registered as factory built. Casa eventually agreed to allow them on as 19. Plenty of owners retired their aircraft and I believe this was mainly due to them in states of disrepair in the back of the garage. I'm not sure many were struck off. If the owners chose not to provide requested documents then they were not re-registered. Pretty much the same as car rego. If your asked to provide a roadworthy and proof of ownership then you either do that or you car is not registered.Wrong.

 

An aircraft need not be airworthy to be registered.

[DonRamsay]

Nong, registering an aircraft that was not airworthy sounds like throwing good money after bad.

 

 

[kasper]

The plane was unregistered because I removed it from the UK register where I had been operating it for a few years after designing and building it myself,. It fits smack bang in the middle of 95.10 and it took a HUGE effort to get RAAus Tech to accept that the single failing to getting it registered was their own interpretation of the tech manual. The full history of the issues and actions by RAAus Tech office and the CEO are with a current board member for direct raising with them at yesterdays board meeting.

 

So there is absolute acceptance that its single seater self design ed and built - that was worked through with UK CAA and also with RAAus Tech back in 2014 ... and the receipt of the final reg card is dated 31 March 2016 following payment of the full reg finalization fee on 10 April (lost the $50 regn number reservation due to SO many delays) and the CEO email effectively cancelling it from 95.10 on the advice of Tech office was dated 2 May - my registration effectively lasted less than a month.

 

But until I hear back from the board member OR the CEO decides to actually sent the letter restoring the regn that he said was in front of him on 5th May but remains outstanding I am gently simmering. Particulraly as RAAus Tech NOW (AFTER they issued the regn invoice and the FULL REGISTRATION have said that they either never got the pics and weight dec or they misfiled it becazue they NOW can't find it ... great new admin system we have eh?

Heard back from the board member and in summary:

1. I was technically correct that the tech manual made no provision to require markings for the aircraft (asn still does not)

 

2. I should have just gone along with the suggestions of alternates not within the Tech Manual and which the Tech Manager has no actual authority under the CAO or the Tech Manual to make as this would make life easy for all involved

 

Well that is fine as a concept EXCEPT that the requirements of the Tech Manual are a controlled document under the CAO and CASA can enforce the CAO so no. I am not happy to make up rules as we go along and not even publish the 'alternate' rules to the membership.

 

So

 

1. I have a registration card on the airframe showing full registration until 31 March 2017. So until there is a requirement in the Tech Manual for the 95.10 aircraft to have a weight certificate for ongoing ownership after initial registration the fact that RAAus cannot find the photos and weight docs sent in is NOT MY PROBLEM as I FULLY comply with the requirements of the CAO in relation to registration.

 

2. I am going confirm my direct and complete application of the Tech Manual to my aircraft in relation to display of registration - I will peel the regn numbers off the side of the aircraft this evening and until there is a retrospective change to the Tech Manual it will be flown completely unmarked - the fact the Tech Manual is deficient in requiring display of regn marks is NOT MY PROBLEM as I FULLY comply with the requirements of the Tech Manual.

 

And as neither the CEO and Tech Manager have in writing on paper cancelled the registration certificate issued in April I await their next move. And it had best be in writing sent to my address not by email - completely sick of RAAus firing off emails that are WRONG and adversely impact me only to then accept they are WRONG after a phone call or three BUT then taking up to FIVE MONTHS to put in writing the acceptance of error.

 

 

[kasper]

Nong, registering an aircraft that was not airworthy sounds like throwing good money after bad.

Except if you buy a basket case and intend rebuilding it you ARE likely to be transferring a registration on an unairworthy airframe ... oh and yes, I've had this EXACT argument with AUF Tech when I bought an unairworthy 95.10 sapphire and transferred the regn on purchase ... the Tech office decided to cancel the regn on that aircraft without power or authority as well ...until I pointed out that they had no power or authority to do that.

 

 

[Bruce Tuncks]

Good onyer kasper. I reckon that a failure to respond should be considered as an approval.

 

You have given them the opportunity to say what (if any) was the problem and they didn't respond so they didn't have a problem.

 

Bureaucratic nyet men are ruining this country.

 

 

[fly_tornado]

Nong, registering an aircraft that was not airworthy sounds like throwing good money after bad.

Blaming the members

 

 

[jetjr]

Registration documents are not ownership papers

 

If its unairworthy then its unable to fly, therefore registration to do so would very much seem a waste of money.

 

Maybe registration is too cheap........aw hang on its too dear for many, yet seems you have exposed 300x members have been affording this without using it.

 

Kasper it might just be a point of view but why make such a problem over number markings and a weight certificate?

 

If your documents, werent recieved at RAA, how is it their problem. Consider emailing another copy, if only to get a settled end result.

 

Love to hear how any of your dealings with Avmed or CASA progressed, much worse than RAA

 

 

[kasper]

Registration documents are not ownership papersIf its unairworthy then its unable to fly, therefore registration to do so would very much seem a waste of money.

Maybe registration is too cheap........aw hang on its too dear for many, yet seems you have exposed 300x members have been affording this without using it.

 

Kasper it might just be a point of view but why make such a problem over number markings and a weight certificate?

 

If your documents, werent recieved at RAA, how is it their problem. Consider emailing another copy, if only to get a settled end result.

 

Love to hear how any of your dealings with Avmed or CASA progressed, much worse than RAA

When you have to arrange and pay for an L2 to travel a couple of hours each way to witness some photos that in fact are lost by either AustPost or RAA its a big deal.

If you have to arrange an L2 to travel a couple of hours each way and pay for them to complete the ACR required to transfer the registration to your name you throw the registration transfer in whenever you can get it done regardless of the airworthiness of the aircraft on the day.

 

Practical issues often dictate that inspections happen at times that appear from the outside to be head scratchers.

 

And the ISSUE I have with the marking issue is that I pointed a partial error out to AUF Tech back in 1998 ... moved overseas for 12 years, came back and the error still existed ... NEW RAAus Tech Manager tells me to delay registration until new Tech Manual THEN find that the markings issue got worse under his drafted Tech Manaul than it was under the old Ops Manual ... and then he decides to make up rules without any authority to do so and hope I just roll over and accept this ... sorry but regn markings are a damn easy ramp check item for CASA and I am not going to display markings that are OBVIOUSLY not in accord witht eh published RAA Tech Manaul so by flying without ANY markings its actually a very clear statement from me to the RAAus as a whole - fix your tech manual because if CASA ramp check me you are going to look damn silly in any court because it is black and white clear that the requirements for my aircraft are met with no markings ... and i have that in WRITING from RAAus Tech.