Clarification of 19 and 24 Registration

[pylon500]

I think there may be a different way of looking at the manufacturer building thing in that;

 

A. For a manufacturer to build a 24 aircraft, it has to go through some certification acceptance as well as workshop acceptance.

 

B. A manufacturer is still only an 'entity', which is backed up by a person(s), the company owner.

 

This entity still has the privilege of building something privately (most likely more than 51%) and registering it as a 19-.

 

The only problem comes if/when he tries to sell it.

 

I think it has to be deemed 'second hand' before it can be sold, but I'm not sure of the definition of that?

 

Twelve months old?

 

Twenty five hours old?

 

Maybe once the 'builder' deems it to be 'surplus' to requirement (non following on from the prototype, company folds, company goes in different direction), and if the aircraft has a 'safe history of operation', there should be no reason it couldn't be sold.

 

Too busy to sift through all the paperwork to be sure, just my gut feeling.

 

 

[fallowdeer]

Following this thread from over the ditch I'm truly impressed by how complicated your regulator has managed to make the management of recreational aviation. We only have two classes of microlight aircraft, Class One and Class Two with the primary difference being one or two seats.

 

Any maintenance in the not for hire or reward microlight world can be done by any person (avionics and static system certification perhaps being an exception) with the proviso being the annual inspection which requires a LAME or Inspection Authority. An IA is an authority granted to an individual by the controlling Part 149 organisation. It doesn't require a formal aircraft engineering qualification but obviously does require a certain depth of knowledge and experience.

 

It'd be interesting to calculate whether this more liberal regime has created a greater accident rate from maintenance failings. Personally I doubt it.

 

And if it flies, no matter what it is or whether it's lifted by hot air or rotor blades or whatever or built by Joe Bob or Boeing it carries a ZK prefix.

 

Seems a lot simpler over here....

 

Peter

 

 

[kasper]

I think there may be a different way of looking at the manufacturer building thing in that;A. For a manufacturer to build a 24 aircraft, it has to go through some certification acceptance as well as workshop acceptance.

B. A manufacturer is still only an 'entity', which is backed up by a person(s), the company owner.

 

This entity still has the privilege of building something privately (most likely more than 51%) and registering it as a 19-.

 

The only problem comes if/when he tries to sell it.

 

I think it has to be deemed 'second hand' before it can be sold, but I'm not sure of the definition of that?

 

Twelve months old?

 

Twenty five hours old?

 

Maybe once the 'builder' deems it to be 'surplus' to requirement (non following on from the prototype, company folds, company goes in different direction), and if the aircraft has a 'safe history of operation', there should be no reason it couldn't be sold.

 

Too busy to sift through all the paperwork to be sure, just my gut feeling.

Yes and no. IF there is a factory and design that meets 24 reg that company can build for recreation and reg as 19. It's eligibility to hold 19 is the point of time it's registered. Once it has 19 reg it can then be sold the day later - no set time later it's the same as any 19 reg. can't really see much benefit in doing this except to experiment on the airframe because logically 24 reg should have greater value and hold it better than 19 reg

The real problem is where there is no 24 possibility. IE there is no factory finished and accepted option just 19 kits from a manufacturer. The exact same could apply to an airframe built there but what really falls down is where a kit is built for $$

 

Take a look at the crashed spitfire investigation for horrific ignoring of the rules on homebuilt.

 

 

[jetjr]

19 reg have no annual airworthiness to perform, its all just maintenance and any L1 can do it.

 

Until recently there was no difference between first and subsequent owners of 19 experimental aircraft under RAA - not so for VH where builder is the only one who can maintain or sign off.

 

Now its a bit more restricitive and major modifications have to run through MARAP process but still simple for minor changes.

 

19 cant be used for training but have no requirement to adhere to manufacturers LSA spec.

 

LSA is not automatically be an asset as if your manufacturer, who carries LSA certification responsibility, comes up with expensive upgrades or pointless changes, you have no choice but to implement them.

 

If they ever dissappear you are back to effectively 19 or -E regs anyway.

 

 

[kasper]

19 reg have no annual airworthiness to perform, its all just maintenance and any L1 can do it.Until recently there was no difference between first and subsequent owners of 19 experimental aircraft under RAA - not so for VH where builder is the only one who can maintain or sign off.

Now its a bit more restricitive and major modifications have to run through MARAP process but still simple for minor changes.

 

19 cant be used for training but have no requirement to adhere to manufacturers LSA spec.

 

LSA is not automatically be an asset as if your manufacturer, who carries LSA certification responsibility, comes up with expensive upgrades or pointless changes, you have no choice but to implement them.

 

If they ever dissappear you are back to effectively 19 or -E regs anyway.

NO!!!!

MARAP cannot ever apply to 19 reg. it is for modification to factory built where the factory does not exist or wish to involve itself wiTh the mod.

 

The second and subsequent 19 reg issues on modifications is completely seperate from MARAP and does not involve a technical analysis of the mods just an inspection and recommendation.

 

What the hell tech office will ever do with an unfavourable recommendation is still to be tested ... because even with this they are not the designer - that's the owner - but please be careful - MARAP does not apply to 19 reg or any of the homebuilt groups

 

 

[M61A1]

19 reg have no annual airworthiness to perform, its all just maintenance and any L1 can do it.Until recently there was no difference between first and subsequent owners of 19 experimental aircraft under RAA - not so for VH where builder is the only one who can maintain or sign off.

Now its a bit more restricitive and major modifications have to run through MARAP process but still simple for minor changes.

 

19 cant be used for training but have no requirement to adhere to manufacturers LSA spec.

 

LSA is not automatically be an asset as if your manufacturer, who carries LSA certification responsibility, comes up with expensive upgrades or pointless changes, you have no choice but to implement them.

 

If they ever dissappear you are back to effectively 19 or -E regs anyway.

SECTION 12.8

 

PERIODIC INSPECTIONS

 

1 INTRODUCTION

 

1.1 Privately operated aircraft require a comprehensive periodic inspection each year (regardless of hours flown), by the holder of an appropriate RAAus maintenance authority. This is also commonly known as the Annual Inspection.

 

1.2 Aircraft operated for hire and/or flying training require a comprehensive periodic inspection each year, or each 100 hours – whichever occurs first, by the holder of an appropriate L2 maintenance authority.

 

2 MAINTENANCE SCHEDULE (by whatever name)

 

2.1 All aircraft must be maintained to the manufacturer’s maintenance schedule which specifies all of the required maintenance items to be checked, replaced, repaired etc.

 

2.2 Some manufacturer’s schedules may make no mention of an annual inspection. The Annual or 100 hourly periodic inspection detailed above, must be completed if the maintenance schedule makes no mention of such an inspection.

 

2.3 For other than aircraft used for flying training or hire, if no manufacturer’s schedule (or other approved Schedule; CASA Schedule 5 for example) is available, one should be obtained or prepared. Acceptable schedules can either be based on, or developed from: • CAAP 42B-1(n) CASA MAINTENANCE SCHEDULE • Appendix 1 of FAA AC 90-89A AMATEUR-BUILT AIRCRAFT AND ULTRALIGHT FLIGHT TESTING HANDBOOK • Aircraft TYPE groups may also have a suitable schedule available.

 

2.4 Maintenance schedules must contain instructions for the maintenance of airframe, engine, propeller and fitted equipment.

 

 

[jetjr]

Best to stay quiet here it seems

 

I did word it poorly, no annual airworthiness docs other than logbook, but there is an annual inspection which is done by an L1......ie almost anyone in RAA.

 

MARAP is used for major modifications, minor is done via notification

 

If what you say is true are 19 reg not able to be modified other than by original builder?

 

What if they are gone?

 

 

[M61A1]

I don't like what they've done but these are the regs as written in the TECH Manual, available to everyone on the RAAus website....

 

8 MODIFICATIONS TO AMATEUR BUILT AIRCRAFT CAO 95.10, 95.32 & 95.55 (10-, 18-, 19- & 28- prefix registrations)

 

8.1 The amateur builder who has constructed the major portion (51%) of an amateur-built aircraft may modify the aircraft that they have completed. All modifications must be entered into the aircraft logbook and builders are to notify RAAus through the submission of an updated aircraft data sheet.

 

8.2 An owner (who was not the builder) of the amateur-built aircraft may incorporate an owner generated major Modification, however, further flight is not permitted until an RAAus L4 is consulted and has examined the aircraft, then provided the RAAus Technical Manager with their recommendations, and the Technical Manager has supplied written approval for further flight. The modification must be described by the aircraft owner on Tech Form 019 and must include such things as:

 

(a) plans, drawings, photographs of the modification; and

 

(b) the reasons for the modification; and

 

© describe how the modification may affect matters defined as a major modification; or (d) describe why the modification will not affect the safety of the aircraft; or

 

(e) describe how the modification will enhance the safety of the aircraft.

 

(f) a copy of the maintenance log book entry detailing all known matters regarding the modification

 

RAAus TECHNICAL MANUAL Section 6.1 - 4 ISSUE 4 - AUGUST 2016

 

8.3 The L4 shall then examine the aircraft and will recommend to the Technical Manager

 

(a) that the modification is acceptable with no further test flying; or (b) that the modification is acceptable, with more ground testing or test flying.

 

8.4 If the L4 finds the modification unacceptable on the grounds of the safety of the aircraft, the Technical Manager will be notified.

 

8.5 Approval or refusal to approve modifications will be in writing from the Technical Manager.

 

 

[jetjr]

• Factory or designer mandated or optional major modifications need not be approved. Such modifications must incorporate only the approved parts and utilise the approved instructions and procedures.
   
   
   
   
  
• Owner generated (Not the original builder under 51%) major modifications must be approved.
   
   
   
   
  
• Factory, designer, or owner generated minor modifications generally do not require approval, though owners may need to be prepared to justify why a modification is not considered to be a major modification.
   
   
  The key here is the definition of major and minor mods
  Minor mods cover some big changes, simply need a form sent to RAA and they indicate if they have concerns and its done or they request inspection, hours, L4 inspection
  A phone call covers plenty of minor thongs