Random Paperwork Inspections

[kasper]

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

You do not have to take my word for it:

https://members.raa.asn.au/storage/57-may-2016-w.pdf

 

page 34

 

Step 2 - undertake at least 3 inspections and submit inspection for for each (inspection L2 or L4 per the explanation to the right)

 

Step 4 - undertake pre flight final inspection with ABI

 

and that is from the Tech Manager as its in his Tech Talk column

 

And from Michael Linke these changes are from the Board not CASA

 

 

[planesmaker]

Somebody correct me if I'm wrong, my understanding, it seems the tech manager can write new tech manual without member input, have CASA approve it then present it to the board for approval. Once approved we the members must abide by it. Seems we are being dictated to. Please tell me I'm wrong. Tom

 

 

[kasper]

But Tom, Darren and Jarad are REALLY good and ABSOLUTELY THE BEST Tech Team we could ask for - surely they know best, much better than any of us ...and of course the fact that the concepts set out in the Tech Talk are not actually within the structure of the CAO is completely immaterial, its for our best really ... trust us.

 

Sorry could not find an appropriately pi$$ take emoticon for this post but take it as read that the Tech office (if they wrote this) completely do not understand the legal structure of the CAOs and if its from the Board then the Tech Mabager SHOULD be pointing out that whats in there is actually not within the scope of the CAOs ... I challenge anyone to find withing 95.55 the concept of conditional registration ... or are we to see 95.55 replaced as well???

 

 

[planesmaker]

Thanks Kasper, I don't get to read the mag until a friend who subscribes finishes with it and passes it on. Only have my phone, not pleasant to read mag on it. I did just looked at what you quoted though

 

Tom

 

 

[storchy neil]

bull xxxx raa are not interested in the way my plane was repaired I have that in writing from bloody raa can produce any time want to take my statement to court that is from the currant ceo and the currant tec lets bring this out in the open ask and you will receive

 

raa have not been any where near me tec has photos off said repair bloody crap what some have written

 

this thread has made up my mind I will be taking the parts removed from my plane after it was repaired to Canberra on the 14 th you don't believe me you will be able to inspect them for your self neil

 

 

[nong]

It is clear that RAAus Tech has gone draconian.

 

The level of complaints being run past me, by members, has escalated from occasional, to regular, under the current regime.

 

If I were to guess, I would think the Tech Manager might have escaped from a military or airline environment, and possibly, might be a true believer that there is no better way to conduct aviation.

 

In the past, we had been blessed with Tech Managers who were able to adapt to our futuristic, low doc, method of aviation.

 

The new regime is hell bent on creating a 1960's style, centralised reporting system, and micro-managing the maintenance of every aircraft (left) in the fleet.

 

This will enable RAAus Corp. Pty Ltd to build a decent size Tech bureaucracy, headed by a manager who ought to be worth, say, at least $300k per annum.

 

Our members often find it confronting to be, out of the blue, slapped with some bizarre demand from RAAus Tech. A typical example might be where rego falls due, the money is paid, and then Tech spears the transaction with a demand for something described as a "weight and balance." "Huh, I just wanted to register the plane." The member, quite reasonably, has no interest in such matters. Aircraft drops off the register and continues to fly safely, just as it always did. Another outlaw.....courtesy of RAAus Tech.

 

There is no excuse for the working draft of our latest Tech manual, not to be a living document posted on the RAAus web-site.

 

Does anyone out there, smell a rat?

 

 

[storchy neil]

accountability as far as I can see when it was okay for raa to pay for another air craft that got repaired through a mishap but the so called experts could not and would not look into the repair that was done and was completely against the repair manual the repairer did not have said manual for aircraft when it was available to him

 

his claim that I as owner of said aircraft did not supply it to him he was at that time an l4 and a cassa lame

 

no a well known l2 did fly to were the aircraft was and did an inspection off said aircraft and was appalled at what he witnessed yet raa tec did not even bother to inspect parts remove from repaired at a fly in

 

don I have a feeling that you are being fed a heap of bull

 

specific question don take a look into storch s 24 4524 that was owned by neil t Bradley and the blatant disregard for rules and regulation by raa and you tell me its okay

 

when I informed raa about the rotax return line to the tank nothing has been done about it I have this gut feeling that this may have contributed to 3 accidents if not more why has this not been addressed as it has been in the rotax since 1997 on all 912 motors and 912 s motors

 

can you produce a document from rotax saying that a return line is not required on all 912 rotax motors as the tec has refused to supply me with it

 

don so an aircraft that requires a new engine frame, new windscreen, new legs, new under carriage, new legs,new firwall , new rudder peddles ,new gasculator ,repair to wing tip cracked leading edge ,re rigged as the rigging was 20 degrees out 2 l2 would not pass this aircraft as airworthy

 

trust raa to be transparent bull

 

I would hate to go flying with some take off and he hands me a shifter and says tighten the wheel nut will yah repairs on the run sound familure neil

 

 

[Keith Page]

In reply to nong post#81. My answer is yes.

 

This new constitution is the initial tool which will allow what you are advocating.

 

The rules you are mentioning just pop out of the air they are not in place within a system and process.

 

Regards,

 

KP.

 

 

[rankamateur]

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

Big incentive to get it registered before they do, me thinks! Nothing like moving goal posts to keep the team fit.

 

 

[kasper]

and while I am not the Tech Office and have not seen the V4 tech manual the Tech Managers in the current mag says current builders who already have a regn number can have 6 months to complete under current rules but anyone applying for a regn number allocation or who takes more than 6 months will have to follow the new process. But that is just what it says in the mag under the Tech Managers name in the Tech Matters column ... I am sure the reality will be something different.

 

 

[Bruce Tuncks]

kasper, that 3 inspection stuff has to be an error. Maybe there are 3 items or something.

 

We would all revolt if something as silly as 3 inspections was for real. I bet it gets fixed.

 

 

[fly_tornado]

It is clear that RAAus Tech has gone draconian. The level of complaints being run past me, by members, has escalated from occasional, to regular, under the current regime.

If I were to guess, I would think the Tech Manager might have escaped from a military or airline environment, and possibly, might be a true believer that there is no better way to conduct aviation.

 

In the past, we had been blessed with Tech Managers who were able to adapt to our futuristic, low doc, method of aviation.

 

The new regime is hell bent on creating a 1960's style, centralised reporting system, and micro-managing the maintenance of every aircraft (left) in the fleet.

 

This will enable RAAus Corp. Pty Ltd to build a decent size Tech bureaucracy, headed by a manager who ought to be worth, say, at least $300k per annum.

 

Our members often find it confronting to be, out of the blue, slapped with some bizarre demand from RAAus Tech. A typical example might be where rego falls due, the money is paid, and then Tech spears the transaction with a demand for something described as a "weight and balance." "Huh, I just wanted to register the plane." The member, quite reasonably, has no interest in such matters. Aircraft drops off the register and continues to fly safely, just as it always did. Another outlaw.....courtesy of RAAus Tech.

 

There is no excuse for the working draft of our latest Tech manual, not to be a living document posted on the RAAus web-site.

 

Does anyone out there, smell a rat?

If the tech manager wants a career in aviation administration in Australia, he has to demonstrate a willingness to support CASA policies regardless of the backlash.

 

 

[Keith Page]

If the tech manager wants a career in aviation administration in Australia, he has to demonstrate a willingness to support CASA policies regardless of the backlash.

OK!!!! You say a career in aviation, put it to you this way -- if all these policies and wishes are enacted there will be no planes about so what will be the use of aviation?

Regards,

 

KP.

 

 

[fly_tornado]

Try explaining to CASA staff that they are cutting their own throats by killing GA. Aviation is booming in every part of Asia but Australia.

 

 

[kasper]

kasper, that 3 inspection stuff has to be an error. Maybe there are 3 items or something.We would all revolt if something as silly as 3 inspections was for real. I bet it gets fixed.

Read the mag .. its very clear it is actually 3 separate inspections during construction followed by the ABI inspection at the end - they even give an example of a stage of pre-closure (anyone remember the good old days of 101.28 inspections???)

So will it be a revolt by burning at the stake - grumpy old gits writing letters to the board ... or something in between that you have in mind?

 

 

[Keith Page]

Try explaining to CASA staff that they are cutting their own throats by killing GA. Aviation is booming in every part of Asia but Australia.

SO Why is it dying in Australia??

KP.

 

 

[fly_tornado]

Different priorities, in Asia the gov's are trying to avoid building lots of roads and railways, so promoting aviation means a cost saving plus economic advantages of aviation. Look how well Asian tourism has grown in the last 30 years.

 

 

[Oscar]

In the past, we had been blessed with Tech Managers who were able to adapt to our futuristic, low doc, method of aviation.

Ah, yes, the 'good old days'. But, nostalgia is just not what it used to be.

 

That caused four successive CASA audits of compliance with the CAO's to fail.

 

That put RAA in the position of defending a nearly $1m lawsuit for its failure to properly administer the requirements ( and which it escaped not by having a decent case, but by an unrelated but fortuitous judicial decision of the fundamental nature of Recreational Aviation being 'inherently dangerous').

 

That has left many aircraft owners with aircraft that cannot legally undertake flying in the circumstances for which they were purchased, with regard to MTOW for a start.

 

That allowed aircraft that had NO actual qualification to BE registered.

 

RAA does not set the requirements - it only ADMINISTERS them ( see post #62 for a reproduction of the ACTUAL role of RAA, and WHO sets the requirements.)

 

 

Which part of 'CASA, on behalf of the Federal Government, is our master' is so difficult to grasp?

 

 

[Bruce Tuncks]

Gosh kasper, "grumpy old git " is a cap that fits me so well...

 

 

[DonRamsay]

Don that really did not answer anything

True, it didn't and you just may have noticed that I am very reluctant to get into arguments over the Tech Manual. While I have read the drafts and followed the changes I have certainly not been a leader in this area. That task on the Board is better suited to people like Trevor Bange.

 

does the board have any input or know what is going on?

Yes and yes. There has been very considerable toing and froing between the Board and the Tech Dept. I've read through the V4 draft and followed the discussion and the revisions. There were some things I was not comfortable with, e.g. Form 121 and the Aircraft Condition Report. But I'm not going to tell Board Members like Trevor Bange how to suck eggs on any of the more technical policy stuff.

The Board approved a version to go to CASA for their review and comments. That is not the end of the approval process. The Board is the ultimate approval authority and it treats the Tech and Ops Manuals as critical.

 

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

Tom, like I said, I am not the person to argue the merits of technical questions like this. My personal rule is that if you never make mistakes you never need to have anything checked, ever. If I were building, I would want everything checked by an expert before that aspect is not able to be checked due to being obscured. But, that's my accounting background - belts and braces is hardly enough. However, I don't plan on inflicting my ultra-cautious approach on experienced builders. I'll leave that sort of judgement to the experts.

 

We do have a principle that we hold dear in RAAus and that is that we should not have regulation for which GA does not have regulation. If I see that on the way through then I would be concerned and argue the point. Back in 2012 I backed a move to get rid of the ACR and thought we had been successful until CASA refused to approve a Tech Manual that did not have the ACR. You don't need to be a LAME to know that the ACR is unnecessary regulation. But, in the end, the 800 lb gorilla does have the muscle and we would be unrealistic to think we out rank them and can put in the Tech Manual whatever we feel like having in there.

 

The Board also appreciates that once you get away from the major population centres L4s are pretty thin on the ground.

 

The Board will have a session with Darren at the Board Meeting on 14th May and make a decision to approve and release v4.0 or require further amendment. If further amendment is required the amendments will have to be approved by CASA of course.

 

Don

 

 

[planesmaker]

Thank you for your reply Don. I have also spoken with Darren and expressed my concerns. Tom

 

 

[aro]

We do have a principle that we hold dear in RAAus and that is that we should not have regulation for which GA does not have regulation.

That went out the window in RAA many years ago. High performance, low performance, 2 stroke, nosewheel endorsements...

 

I was denied my certificate renewal a few years back because I hadn't provided details of my AFR, then I needed to sit the additional human factors exam. All additional regulations. Meanwhile I continued flying happily on my PPL. I fly GA not RAA because the constantly changing requirements in RAA became too annoying. The only issue I have in GA is the medical requirement. Say what you like about CASA, at least they introduce changes much more slowly and with much more consultation (or at least publicity) than RAA.

 

It would be interesting to compare the inspection etc. requirements for amateur built GA to amateur built RAA.

 

 

[DonRamsay]

That went out the window in RAA many years ago. High performance, low performance, 2 stroke, nosewheel endorsements...

Nong,

 

Our endorsements do not represent more regulation than GA. Just called different things in GA like "type", etc. Show me a PPL who has not had to jump through a hoop for Radio, carrying passengers, Navs, NW/TW, etc. We just give them endorsement names.

 

I was denied my certificate renewal a few years back because I hadn't provided details of my AFR

Can't see a problem there.

 

then I needed to sit the additional human factors exam.

HF is just as relevant to a RA as a GA pilot. Still the biggest cause of aviation fatalities by far. Nobody is ever going to apologise for requiring a knowledge of HF.

 

. . . Say what you like about CASA, at least they introduce changes much more slowly and with much more consultation (or at least publicity) than RAA.

CASA taking 18 years to not finish the CASRs definitely qualifies for introducing "changes much more slowly". And guess who drives what's in the Ops Manual? CASA.

 

 

[kasper]

True, it didn't and you just may have noticed that I am very reluctant to get into arguments over the Tech Manual. While I have read the drafts and followed the changes I have certainly not been a leader in this area. That task on the Board is better suited to people like Trevor Bange.

Yes and yes. There has been very considerable toing and froing between the Board and the Tech Dept. I've read through the V4 draft and followed the discussion and the revisions. There were some things I was not comfortable with, e.g. Form 121 and the Aircraft Condition Report. But I'm not going to tell Board Members like Trevor Bange how to suck eggs on any of the more technical policy stuff.

 

The Board approved a version to go to CASA for their review and comments. That is not the end of the approval process. The Board is the ultimate approval authority and it treats the Tech and Ops Manuals as critical.

 

Tom, like I said, I am not the person to argue the merits of technical questions like this. My personal rule is that if you never make mistakes you never need to have anything checked, ever. If I were building, I would want everything checked by an expert before that aspect is not able to be checked due to being obscured. But, that's my accounting background - belts and braces is hardly enough. However, I don't plan on inflicting my ultra-cautious approach on experienced builders. I'll leave that sort of judgement to the experts.

 

We do have a principle that we hold dear in RAAus and that is that we should not have regulation for which GA does not have regulation. If I see that on the way through then I would be concerned and argue the point. Back in 2012 I backed a move to get rid of the ACR and thought we had been successful until CASA refused to approve a Tech Manual that did not have the ACR. You don't need to be a LAME to know that the ACR is unnecessary regulation. But, in the end, the 800 lb gorilla does have the muscle and we would be unrealistic to think we out rank them and can put in the Tech Manual whatever we feel like having in there.

 

The Board also appreciates that once you get away from the major population centres L4s are pretty thin on the ground.

 

The Board will have a session with Darren at the Board Meeting on 14th May and make a decision to approve and release v4.0 or require further amendment. If further amendment is required the amendments will have to be approved by CASA of course.

 

Don

Don,

If we expect CASA to not regulate unless there is a demonstrable risk and we request that they set out the risk based assessments for regulation then it is fair that RAA Members request the same of the RAA Board when they are making through the Tech Manual and Ops Manual changes that impact in even more detail than the CAOs.

 

From the two pages in the Magazine on the V4 tech manual there are several changes that the Board should explain the risk based assessment for :

 

1. CAO 95.55 homebuilt aircraft moving from 1 supervised inspection at the end of build with recommendations for setting initial conditions of operation moving to 4 inspections and 4 reports sent to RAA.

 

What is the safety risk identified from the past 18 years of operations of the current system that requires the change?

 

2. does the change in 1 apply to CAO 95.32 homebuilt aircraft - if yes same question, if no on what basis are the two areas of aircraft dealt with differently if this is a risk based change?

 

3. Experimental aircraft under CAO 95.55 must be registered with RAAus to allow flight (CAO 95.55 1.1 (d)) and the restrictions on the flights (ie test hours) apply under CAO 95.55 6.1 (g) & 6.3. How does the concept of provisional registration fit within this legislative framework and how does a permit as a concept fit within this concept? Specifically if a Registration is separate from a Permit on the basis that RAAus intend to manage access to flight only if Registered AND in Permit then the CAO fails completely to allow for this ... and I point to the fact that the CAO in allowing conditions on flight (test hours) only applies to airframes before first flight not after ... RAAus do not get to come along later and say we want to reintroduce conditions ...

 

Not saying Don that you need to answer these, fully accept that you have indicated that Trevor is leading on this area from a technical perspective BUT if is not in my opinion acceptable as a board member to apply the logic that it never hurts to have someone look over your shoulder when the fact of moving to 4 inspections is a new regulation on the builder without a clear risk based need.

 

 

[DonRamsay]

Kasper,

 

Some good points well made. I'll be getting a thorough briefing on this matter on Saturday and nothing that has been published to date will be in the final, approved V4 unless both a Board majority and CASA approve the document. But that day is drawing very close.

 

Whether V4 is perfect or just a quantum leap over the current awful document is not a bad position to be in. And there will be a V4.1

 

There is just too much improvement on offer to delay much longer.

 

I appreciate heads-up on all these things and will have them on my notepad at the Board Meeting. Wish me luck!

 

Don

 

p.s. I know, I know . . . it's not supposed to be about luck . . .