Experimental Amateur built major portion 51%

[Icarus]

Hi

 

Thought a few links to documents from CASA might be handy for anyone contemplating a build.

 

Kit or plans or even factory assisted build.

 

These advisories are from 2000 ,however I believe they are still relevant.[ they were modified last month]

 

The first one describes how to comply with the 51% rule.

 

https://www.casa.gov.au/file/151991/download?token=oStoRPdy

 

This one is more focused on the certification process

 

https://www.casa.gov.au/file/151881/download?token=2uCN_Fie

 

As both document refer to the FAA approved kits list ,here is a link to the List.....PDF last updated August 2016.

 

https://www.faa.gov/aircraft/gen_av/ultralights/amateur_built/kits/media/amateur_built_kit_listing.pdf

 

If your kit is not on the FAA list then you should use the check list on the last pages of the top linked document.

 

CASA may have a list of 51% approved kits. But I cant find them.

 

Here is the FAA Amateur-Built Fabrication and assembly Checklist Job aid.

 

As CASA is happy to accept kits approved by FAA it would seem relevant to use/read even if it has no legal standing in Australia.

 

https://www.faa.gov/aircraft/gen_av/ultralights/amateur_built/kits/media/Am_Blt_Chklist_Job_Aid.pdf.

 

It is important to meet th 51% rule so you can do your own maintenance ,either RAA , or VH experimental [after completing a course I believe]

 

I will post more links to legislation and relevant material soon.

 

Brendan.

 

 

[Icarus]

Here is the RAA Technical Manual.

 

https://www.raa.asn.au/storage/2-raaus-technical-manual-issue-4-single-pages.pdf

 

Recommended reading in the RAA manual is the FAA Acceptable Methods,Techniques and Practices -- Aircraft Inspection and Repair.

 

All 696 pages. This Manual is not to Replace Aircraft Manufacturers Manuals . However it is essential for anybody who is building or maintaining an aircraft with no manual available.

 

https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC43.13-1b.pdf

 

 

[spacesailor]

I tried, honest I did, ( page 64= 1st chapter wood(and the date 09/8/1998))

 

But I can't understand a lot of this lawyer-speak,

 

But why o why do we have to use two country's laws when only the Australian one is relevant.

 

It's rarely bad when a document has to be read with a couple of lawyer's present, even that is not infallible, I did what I was asked for, paid my dollar's. for the HB certificate,

 

But lo & behold no registration. so what is the answer! more weight and more legislation.

 

Only the lawyer's will win, at our expense.

 

spacesailor

 

 

[Icarus]

Hi Spacesailor

 

I feel your pain.

 

One of the reasons I am putting all the links up here, is to try and collate all the info needed to build and maintain your own aircraft either in RAA or VH experimental.

 

I found the info scattered all over the place . almost like its hidden.

 

As CASA accept FAA and other National Airworthiness Authority Approved Kits ,to comply with the Majority rule. You would hope the guide that FAA published would provide acceptable definitions of terms like "Fabricate and Assemble"

 

I could not Find CASA definitions of those terms.

 

The Paragraph below is from the FAA Job check guide as linked to Above

 

So Here is the FAA definitions.

 

FAA Order 8130.2 defines fabrication as: “To perform work on any material, part or component, such as layout, bending, countersinking, straightening, cutting, sewing, gluing/bonding, lay-up, forming, shaping, trimming, drilling, de-burring, machining, applying protective coatings, surface preparation and priming, riveting, welding or heat-treating, transforming the material, part or component toward or into its finished state. “

 

The FAA does not define “assembly.” However, such work that does not fall under the definition of fabrication is considered assembly. In work such as riveting, there can be some confusion concerning different components. The guidance this guide offers depends on the component, task at hand, and how it is being applied. When attaching a metal skin to a basic wing structure (i.e., the spar and ribs forming the basic wing structure) the riveting that fastens the skin to the ribs should be considered assembly work, not fabrication.

 

However

 

 

[spacesailor]

Hi Icarus "the riveting that fastens the skin to the ribs"

 

That riveting mean both pull rivets and solid formed rivets?, as the latter has to be inspected thoroughly by an L2 I was told. In Australia.

 

(see I said I'd need a lawyer)

 

spacesailor

 

 

[Dwilly]

Hi Icarus "the riveting that fastens the skin to the ribs"That riveting mean both pull rivets and solid formed rivets?, as the latter has to be inspected thoroughly by an L2 I was told. In Australia.

(see I said I'd need a lawyer)

 

spacesailor

[Icarus]

I would think that the person inspecting the aircraft would like to see the back side of the solid rivets to ensure they are squashed properly and not too close the Rib flange edge. Wether they Must is probably debatable , however if the wing is already assembled and there is no inspection holes that will be difficult. A couple small holes and a bore scope might be a solution to that

 

 

[Dwilly]

Is that a sealed or open/pulled/pushed/domed rivet???

 

 

[Icarus]

Where did Spacie go?

 

maybe bed.

 

You Need to remember that the inspector wants to see that the wing is built properly for your own safety.He does not want to be the guy who signed off the experimental AC that shed a wing on the first flight. Even if he is not legally responsible, he would never forgive himself.

 

This is why photos and log books are important. Not a bad Idea to get inside wings inspected before closing. If not by the final certifier then by a LAME or someone qualified. take photos and get them to sign log book.

 

 

[bexrbetter]

...the inspector .......He does not want to be the guy who signed off the experimental AC that shed a wing on the first flight.

He is not responsible for the engineering, only to site that the work has been pursued in a competent manner.

 

 

[spacesailor]

Yes

 

I went to bed, I had my photo's on a disc, but such a long time has past, I don't have a clue were to look for them.

 

As to get things signed off, my first training flight was Not signed, & no-one will sign off on it.

 

Also hard rivets, if sandwiching two skins either side of a six mm block why cant I dimple the skins and counter-sink both sides of the block to have both sides smooth.

 

spacesailor

 

 

[Jaba-who]

He is not responsible for the engineering, only to site that the work has been pursued in a competent manner.

Yep and the liability remains with the builder. The AP is only certifying that the builder has not done anything glaringly stupid. However The SAAA now has a fairly complex tool for recording the inspection processes during the build and this "risk radar" is supposed to help the AP weed out poor build stuff way before it gets to the stage of the final inspection. Personally I find the risk radar to be a bit problematic but it covers a huge amount of stuff and does highlight issues.

The AP actually has no right to actually refuse the C of A but he can put such restrictions on it that make it near impossible to do anything with it.

 

The AP can for instance require any number of hours for the phase 1 testing period. ( typically 25 hrs for a kit that has built exactly according to the manual, 40 hrs if there is a single modification using well known or certified parts modification but can insist on any number of hours beyond that for a complete unknown entity aircraft )

 

Further the AP can limit where the aircraft can do the phase 1 testing. Typically within 25 mm of the airport but can be far more restrictive such as not to leave circuit area or not to cross roads or airport boundary.

 

And finally can limit the aircraft to never carrying any passengers.

 

 

[spacesailor]

Silly question, again,

 

What's an "AP"

 

spacesailor

 

 

[Jaba-who]

Sorry, mea culpa.

 

AP = Authorized Person

 

Someone authorised by CASA to give a Certificate of Airworthiness and to decide how/what limitations will be applied during the Phase 1 testing of an experimental GA build. That AP also issues initial approval for a builder to do ongoing maintenance if he's convinced the builder did more than 51% of the build and fulfills the other requirements to be eligible to do the maintenance.

 

The Sport Aircraft Assoc of Aust has APs within its organisational structure and there is at least one AP that I know of who is not part of the SAAA. There is no requirement for a builder to go through or be a member of the SAAA to have a home built GA experimental unlike the RAAus.

 

 

[Icarus]

Also hard rivets, if sandwiching two skins either side of a six mm block why cant I dimple the skins and counter-sink both sides of the block to have both sides smooth

I cant help with that Spacie . Hopfully someone who can will come along soon.

 

Would you like to fill us in on what exactly is going on with your build/inspection?

 

He is not responsible for the engineering, only to site that the work has been pursued in a competent manner.

Yes I am aware of that .

 

Perhaps the sentence followinng that should have read " Even THOUGH he is not legally responsible ................

 

I just finished reading the RAA tech manual.

 

I was always under the impression that I had to build the aircraft to maintain it. [i believe this is the case in GA experimental]?

 

Now I realise that you only need L1 after a short course and test to maintain, except LSA flight training and hire AC needs L2

 

This is great news to me as It means I don't need to spend the time I don't really have spare ,building an aircraft ,so I can maintain it.?

 

I can go and buy a 2nd hand j230 , do the L1 and maintain it? is that correct?

 

Would I be able to fit Rotec LCH , and direct fuel injection , or would this need modification approval?

 

Have I got the facts straight here?

 

 

[Jaba-who]

What does an L1 course teach?

 

How long does it take to do?

 

Is it really enough to maintain an aircraft?

 

 

[Icarus]

Here are some paragraphs from RAA tech manual

 

For AMATEUR-BUILT and E-LSA AIRCRAFT 3.1 Builders of amateur built and E-LSA aircraft may themselves weigh their aircraft and prepare the required weight and balance reports, after becoming a “Qualified Weigher” from successful completion of the RAAus Weight & Balance online education package.

 

MAINTENANCE POLICY Under a grandfather clause all members who are maintaining their own RAAus registered aircraft have until 01/02/2017 to complete the L1 maintenance authority assessment. After 01/02/2017 members who have not completed the L1 assessment cannot continue to sign for maintenance performed on their own aircraft. (Does not apply for members completing line maintenance only)

 

An individual that has completed the mandatory RAAus L1 or higher training process and has the appropriate qualifications and experience to carry out maintenance on an aircraft or aeronautical product may carry out the maintenance in accordance with the manufacturer’s schedule to ensure the continuing airworthiness of the aircraft

 

the text below is from a chart on page 87 tats why its all messed up!

 

MAINTENANCE TASK

 

MAINTENANCE AUTHORITY REQUIRED PRIVATE OPERATIONS AMATEUR BUILT PRIVATE OPERATIONS FACTORY BUILT HIRE &/OR FLYING TRAINING

 

Pre-flight Final Inspection (FORM 007)

 

Builder with L4 observing Not Applicable Not Applicable Daily Inspection Pilot Pilot Pilot (not student) or Instructor Pre-flight inspection (“walk-around”) Pilot Pilot Pilot or Instructor (including students under supervision) Line Maintenance Pilot or L1, L2, L4 Pilot or L1, L2, L4 L2, L4 Scheduled Maintenance L1, L2, L4 L1, L2, L4 L2 or L4 Periodic Inspection L1, L2, L4 L1, L2, L4 L2 or L4 Repairs L1, L2, L4 L1, L2, L4 L2 or L4 Modifications Refer to Section 6.1 of Technical Manual Refer to Section 6.1 of Technical Manual Refer to Section 6.1 of Technical Manual RAAus or manufacturer Airworthiness Notices L1, L2, L4 L1, L2, L4 L2, L4 Heavy landing inspection L1, L2, L4 L1, L2, L4 L2, L4 Component overhaul L1, L2, L4 L1, L2, L4 L2, L4 Component replacement L1, L2, L4 L1, L2, L4 L2, L4 Welded repairs L1, L2, L4 CASA Welding Authority holders CASA Welding Authority holders Weight and Balance activities Qualified L1, L2, L4 or CASA WCO Qualified L1, L2 or CASA WCO Qualified L2 or CASA WCO

 

Five levels of RAAus Maintenance Authority exist. To exercise any of these privileges, current membership of RAAus must be retained.

 

Line Maintenance (LM): Pilot Certificate holders. Perform and record basic maintenance tasks listed in Section 12.7 of this manual (similar to the CASA Schedule 8 pilot permitted items). Pilots are reminded that they need to be competent to carry out the tasks.

 

Level One (L1): Pilot Certificate holders. Perform and record maintenance activities carried out only on their own aircraft which are not used for hire and/or flying training. Completion of a Level 1 training course is required

 

LINE MAINTENANCE (LM) Authority

 

3.1.1 All Pilot Certificate (excluding students) holders are automatically issued Line Maintenance Authority.

 

3.2 LEVEL ONE (L1) Maintenance Authority 3.2.1 Pilot Certificate holders (non-student) may be issued with an L1 Maintenance Authority following successful completion of the RAAus training and assessment available through the L1 Maintainer Training and Assessment Site within the RAAus website. Membership lapses in excess of 2 years will require re-validation of the maintenance authority by undertaking the course again. See Section 11.3 of this manual for more information

 

INTRODUCTION 1.1 To qualify for a Level 1 (L1) Maintenance Authority, members must successfully complete the RAAus assessment available through the L1 Maintainer Training and Assessment Site within the RAAus website, or via an alternately arranged paper based assessment.

 

1.2 A training package is available, consisting of a self-paced course utilising a range of resources, which include: a study guide, an FAA Publication providing maintainers with guidance on how to complete various maintenance and inspection tasks, a link to the CASA airworthiness directives (ADs) webpage and a links to other relevant resources. Annex A within this section, describes the basic elements of the training package.

 

1.3 Upon successful completion of the assessment, results advice will be sent to the member and will have the L1 qualification added to their Pilot Certificate at the next renewal. In the interim, the results advice may be used as evidence of having satisfactorily completed the course.

 

1.4 Persons completing this training package are expected to: • Complete the Study Guide • Review the guidance material provided • Complete the on-line assessment (50 multi-choice questions, 80% pass mark, 3 hours 30 minute time limit) • Provide feedback on the training and assessment package

 

2 RECORD OF EXPERIENCE 2.1 It is suggested that L1’s maintain a separate record of their maintenance experience, listing aircraft type(s) and work performed. This may be useful in the event that an L1 wishes to apply for an L2 maintenance authority at a later date, or, to assist with any competency based audits that the Technical Manager may request.

 

Then after this is the syllabus in chart form etc .

 

Really is compulsory reading for all RAA members I think.

 

Enjoy the read. Im off to bed

 

Brendan

 

 

[spacesailor]

I heard that to undertake a L1 maintenance syllabus, you first had to have proven mechanical training (mechanic) to even try for it.

 

spacesailor

 

 

[Icarus]

That would be for L2 Spacy

 

Do yourself a favour and read the RAA tech manual.

 

Listening to old mate who heard from old mate, who................ will only get you BS.

 

Look at Section 11.3 in the tech manual

 

https://www.raa.asn.au/storage/2-raaus-technical-manual-issue-4-single-pages.pdf

 

 

[spacesailor]

Thanks Icarus.

 

I downloaded the manual, But have problems making sense of it, too lawyer-speak for my understanding. is it page 93 of 216.

 

Is this bit the American rule, we are to be under? " an FAA Publication providing maintainers with guidance on how to complete various maintenance and inspection tasks",

 

Far above my level of education, couldn't pass the "Basic Aeronautical test" .

 

spacesailor

 

 

[Icarus]

Yes page 93 and 98

 

Is this bit the American rule, we are to be under? " an FAA Publication providing maintainers with guidance on how to complete various maintenance and inspection tasks",

That manual is is just recommended reading / reference/if your aircraft does not have a manual, ie plans built

 

There is no American rule which we will be under . CASA however does recognise FAA publications and Kit 51% approvals .

 

The pages93 and 98 explain what is required to be L1 and L2

 

 

[spacesailor]

Found the relevant document on the RAA site:

 

• USA Federal Aviation Administration handbooks.
   
   
  
• Technical handbooks
   
   
  
• Pilot handbooks
   
   
  
• At least I think it is.
   
   
  
• spacesailor
   
   
  
• Now Iv'e got dots infront of my eye's
   
   
   
  

 

 

 

 

[440032]

A small correction to your earlier post Jaba-Who: APs (for VH experimental) don't actually have the power within their CASA Instrument of Appointment to approve any maintenance aspects for anybody, but they sure do have the power to prevent it, ie, LAME maintenance only, "in the interests of safety of other airspace users and persons on the ground or water." This is common for bought aircraft (to be newly registered), brought in (to Aust) aircraft, and cases where the applicant cannot prove to the satisfaction of the AP that they built it (well, more than 51% of it). So regarding APs "approving maintenance", a better description is that they have no reason to disagree with owner/builder maintenance happening. CASA takes care of the approvals via the various criteria within the maintenance Instrument of Appointment (currently, Instrument 15/16.) If one meets those listed criteria, that makes you approved, and away you go. An APs Instrument of Appointment details very specifically what they can do, and approving maintenance is not one of them. Back at the start of Experimental, yes, it was common for an AP to approve (really, concur with) builder maintenance, (before CASA mandated certain things to happen.) Now, not so.

 

You have a very good understanding of the processes for VH EXP Jaba, thank you for your contributions to the discussion and keeping people on the right track!

 

 

[Jaba-who]

A small correction to your earlier post Jaba-Who: APs (for VH experimental) don't actually have the power within their CASA Instrument of Appointment to approve any maintenance aspects for anybody, but they sure do have the power to prevent it, ie, LAME maintenance only, "in the interests of safety of other airspace users and persons on the ground or water." This is common for bought aircraft (to be newly registered), brought in (to Aust) aircraft, and cases where the applicant cannot prove to the satisfaction of the AP that they built it (well, more than 51% of it). So regarding APs "approving maintenance", a better description is that they have no reason to disagree with owner/builder maintenance happening. CASA takes care of the approvals via the various criteria within the maintenance Instrument of Appointment (currently, Instrument 15/16.) If one meets those listed criteria, that makes you approved, and away you go. An APs Instrument of Appointment details very specifically what they can do, and approving maintenance is not one of them. Back at the start of Experimental, yes, it was common for an AP to approve (really, concur with) builder maintenance, (before CASA mandated certain things to happen.) Now, not so.You have a very good understanding of the processes for VH EXP Jaba, thank you for your contributions to the discussion and keeping people on the right track!

Thanks for that correction 440032.

There appear to be more than a few places in the CASA rule book where that appearance of the double negative can lead the observer to the mistake that something is actively approved where in fact is only not disapproved.

 

 

[440032]

Precisely! Well described!