Clarification of 19 and 24 Registration

[old man emu]

Can someone tell me quickly which type of registration would apply in these cases?

 

1. A manufacturer builds an aeroplane from plans in its factory
    
    
   
2. The manufacturer supplies the materials to build the aeroplane in kit form to a person who builds more than 51% of it without assistance from the manufacturer.
    
    
   

 

 

OME

 

 

[skyfox1]

1 would be 24

 

2 would be 19

 

 

[Geoff13]

The newest LSA factory built that I am aware of is a 23 registered Jab J230.

 

 

[SDQDI]

Can someone tell me quickly which type of registration would apply in these cases?

1. A manufacturer builds an aeroplane from plans in its factory
    
    
   
2. The manufacturer supplies the materials to build the aeroplane in kit form to a person who builds more than 51% of it without assistance from the manufacturer.
    
    
   

 

 

OME

If it wasn't the manufacturers plane and they were just building the plane from plans it would also be a 19 registered plane.

 

 

[frank marriott]

The newest LSA factory built that I am aware of is a 23 registered Jab J230.

Geoff, you are correct now 23 - why is another question - not explained but what I have come to accept from the new administration of RAA, even less input from involved people than with CASA, but I have come to expect this approach. Was a member's organisation but that is only history.

 

 

[Downunder]

I'm wondering if they ran out of 24 xxxx numbers and then started from 23 0001....?

 

 

[Geoff13]

^ 23-8806^

 

 

[Kyle Communications]

maybe going backwards form 24 :)

 

 

[Happyflyer]

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

 

RAAus Tech manual 5.1-7 para 10.2 explains the new numbering system.

 

19 = Amateur built

 

24 = Type certified

 

23 = LSA

 

55 = Factory built non lSA

 

Etc etc. someone cleverer than me may be able to post the whole table.

 

 

[old man emu]

Thanks for your help everyone. I didn't know about the 23-, but that knowledge is useful to me.

 

Good night!

 

 

[Hwansey]

So does all that mean that retract, >120mph, factory build is 24? ie Alpi, Bristell RG etc.

 

 

[robinsm]

If it wasn't the manufacturers plane and they were just building the plane from plans it would also be a 19 registered plane.

The PERSON owning the aircraft must build a minimum of 51%. for it to be a 19 reg. Not for resale after completion as a 19. If a manufacturer builds an aircraft with a view to selling it, no matter where the parts came from, then 24reg.

 

 

[BusaKaine]

E24. NON COMPLIANT EXPERIMENTAL LSA. 95.32 OR 95.55

 

10. AMATEUR BUILT. 95.10

 

17. KIT BUILT EXPERIMENTAL LSA. 95.32 OR 95.55

 

18. AMATEUR BUILT W/S & PPC. 95.32

 

19. AMATEUR BUILT. 95.55

 

23. LSA. 95.32 OR 95.55

 

24. TYPE CERTIFIED. 95.55

 

25. EARLY ULTRALIGHT AEROPLANES (1985 ERA). 95.25 (SUPERCEDED)

 

26. G.A. TYPE CERTIFIED. 95.55

 

28. EARLY AMATEUR BUILT. 101.28

 

32. FACTORY BUILT WEIGHT SHIFT OR POWERED PARACHUTE. 95.32 W/S OR PPC (including LSA)

 

55. FACTORY BUILT AEROPLANE. 101.55 (non LSA)

 

 

[planesmaker]

That simplifies everything!

 

 

[Geoff13]

The PERSON owning the aircraft must build a minimum of 51%. for it to be a 19 reg. Not for resale after completion as a 19. If a manufacturer builds an aircraft with a view to selling it, no matter where the parts came from, then 24reg.

Do you have a reference for that?

 

 

[robinsm]

Do you have a reference for that?

Check with Raa Aus technical dept...

 

 

[Geoff13]

Check with Raa Aus technical dept...

So I will take that as a No.

 

It seems strange that a huge number of 19 reg aircraft can be advertised and sold using the club magazine and then have the registrations transferred by RAA as 19 reg aircraft if it is not legal to sell a 19 reg.

 

Further to that when taking advice from your reference on purchasing a 19 reg aircraft, they gave me solid advice on steps and procedures to follow.

 

Following on from your comment above "Not for resale after completion as a 19" there must be a hell of a lot of illegal aircraft flying around.

 

 

[robinsm]

If you have checked with Raa Aus then what is the point of your post. I understood that was the case but if I am wrong then so be it.

 

 

[kasper]

Do you have a reference for that?

I do wish people would start with the CAO wording. Then look at the tech manual. Then if you're still confused ring RAAus tech

The legal requirement for 19 reg is major portion. And that applies to the airframe when it's registered.

 

So a project can pass through many hands and still meet this - I can buy a part built kit that when completed ready for initial registration will comply with major portion and it's still OK

 

Then tick off that the major portion was done for the principal reason not commercial for all the builders (document, document, document)

 

Then register it. Simples.

 

The 51% "rule " is not in the law and not even in the tech manual as a requirement. Is a guideline to help people understand what major portion is usefully aligned to to help you work out if it's compliant as an aircraft

 

So if you want to buy a kit that CAN comply with the accepted definition to get 19 reg BUT it was assembled by someone you paid to do it for you that airframe falls OUTSIDE the rules and IF casa or RAAus work that out you are stuck with an airframe that should not be registrable at all.

 

 

[Geoff13]

If you have checked with Raa Aus then what is the point of your post. I understood that was the case but if I am wrong then so be it.

The point of my post was simply to ask if you had a reference as what you were saying was different to what I had been able to find and what I had been told.

 

If my understanding was wrong I would have liked a reference to show that, but if my understanding was correct then I would not like to se a post that stated something that was wrong go unchallenged.

 

Some people may see it without knowing the rules and be led in the wrong direction.

 

My understanding of the rules was exactly as Kasper posted below.

 

I do wish people would start with the CAO wording. Then look at the tech manual. Then if you're still confused ring RAAus techThe legal requirement for 19 reg is major portion. And that applies to the airframe when it's registered.

 

So a project can pass through many hands and still meet this - I can buy a part built kit that when completed ready for initial registration will comply with major portion and it's still OK

 

Then tick off that the major portion was done for the principal reason not commercial for all the builders (document, document, document)

 

Then register it. Simples.

 

The 51% "rule " is not in the law and not even in the tech manual as a requirement. Is a guideline to help people understand what major portion is usefully aligned to to help you work out if it's compliant as an aircraft

 

So if you want to buy a kit that CAN comply with the accepted definition to get 19 reg BUT it was assembled by someone you paid to do it for you that airframe falls OUTSIDE the rules and IF casa or RAAus work that out you are stuck with an airframe that should not be registrable at all.

[kasper]

And to add to the big warning sticker on paying someone to assemble your kit for 19 reg ... if you do that and CASA and/or RAAus find out your aircraft will be ineligible for 19 reg AND not eligible for any other reg under RAAus as the CAOs are pretty damn clear on factory built and a kit assembled for reward is not ever going to be within that.

 

If people with nice fat wallets want to ability to pay to assemble them get a new/change to the CAOs and go legit. I doubt there will be a lot of appatite for it but you never know the political and coverage ambitions that some non-member associations have these days.

 

 

[NT5224]

1 would be 242 would be 19

Actually I think it might be more complex than that. My own plane is RA registered 19, but was built by the manufacturer as a demonstrator.

 

From this I surmise that if a manufacturer is not a registered supplier of factory build aircraft but only of kits, then even if they build an aircraft on their factory floor it's still a 19.

 

 

[kasper]

Actually I think it might be more complex than that. My own plane is RA registered 19, but was built by the manufacturer as a demonstrator.From this I surmise that if a manufacturer is not a registered supplier of factory build aircraft but only of kits, then even if they build an aircraft on their factory floor it's still a 19.

I'd be quite cautious about your situation as a kit manufacturer cannot assemble on their factory floor and reg 19 unless it was within 95.55 1.2 (e) ... and building as a demonstrator would be hard pressed on challenge to be within "the major portion of which has been fabricated and assembled by a person who undertook the construction project solely for the person’s own education or recreation"

No quibble that practically you may want a factory test or demo airframe BUT 19 reg on it seems to have holes.

 

Now do not shoot me BUT 95.10 explicitly allows reg of demonstrator airframes with reg in category for the purposes of demonstrating compliance ... 95.55 and 19 reg has no equivalent.

 

I'd never buy a factory demonstrator with 19 reg as I do not feel comfortable that the registration basis is not liable to be challenged by CASA on any audit of the register ... and without 19 reg it's unregiaterable in Australia

 

The best interpretation of fitting into 19 is that it was for their education in how to assemble the airframe from their kit. I can see that as a basis but I think it's probably only applicable to the very first airframe ... any subsequent airframe would be hard pressed to fit the definition.

 

 

[NT5224]

"I'd be quite cautious about your situation as a kit manufacturer cannot assemble on their factory floor and reg 19 unless it was within 95.55 1.2 (e) ... and building as a demonstrator would be hard pressed on challenge to be within "the major portion of which has been fabricated and assembled by a person who undertook the construction project solely for the person’s own education or recreation"

 

Thanks Kasper. You make good points, but I'm fairly confident about my own rego as the aircraft was a used import and so was subject to a high level of scrutiny and inspection to get it into Australia and onto the RAA register. It was not a first of type build, but just a well-finished one the company wanted to tour the airshows in the US and Canada and promote sales with. I was just pointing out (as you have too), that the situation can get a little murky depending on interpretation of how the aircraft was constructed and where, and possibly whether the manufacturer is on record as a supplier of finished or kit aircraft.

 

Alan

 

 

[Yenn]

The big advantage of a 19 reg aircraft is the ability of the builder to maintain and issue annual airworthiness docs. If a Murphy rebel was built by the factory and registered 19, it would be the same as any other 19 reg owned by someone who didn't build it. What is the builders name on the data plate?