RAA Part 149

[Kyle Communications]

So RAA now has Part 149...was reading a few things..this interests me..So do L1 maintainers now not exist?????Obiously for schools and certifed aircraft nothing really changes but for people that build and maintain their own under L1..whats the go?

 

 

The following changes relate to RAAus Maintainers:

 

• Added L2 minimum qualification and experience requirements for initial issue (without repairs):

LAME license; or

Two years demonstrated history of aircraft maintenance experience, and has demonstrated competence in conducting at least two annual inspections or two 100 hourly’s or a combination supervised by a current L2; or

Person holding a relevant trade certificate or experience and has demonstrated competence in conducting at least one annual inspection or one 100 hourly supervised by a current L2.

Note: for 2 and 3 above, maintenance is to be conducted on the category of aircraft being applied for, with the annual or 100 hourly maintenance activities supervised by a current L2.
 

• Added an L2 must conduct at least two annual or two 100 hourly inspections or a combination within a two year period to renew their authority

• Added further detail regarding the minimum requirement for L2 renewal. Further process added to section for applicants that cannot meet these requirements

3.3.2 Applicants that cannot satisfy the L2 maintenance authority renewal requirements will not have their authority reinstated and will be advised by RAAus in writing. 

3.3.3 In the event that an applicant cannot satisfy the renewal requirements of 3.3.1 due to extenuating circumstances, the applicant may apply to the HAM for an L2 renewal approval by providing at least six months maintenance activities through the supply of the applicants Level 2 Maintenance Authority Diary.

3.3.4 The holder of an expired L2 maintenance authority that is within 24 months from the date of expiry may apply to the HAM for reinstatement of a L2 maintenance authority by supplying evidence to the HAM of completing at least one annual inspection or at least one 100 hourly supervised by a current L2 within the preceding six months of application. Beyond 24 months post expiry the applicant will need to reapply for an L2 maintenance authority as per 3.3.1

3.3.5 A person holding a valid LAME licence is issued with a perpetual L2 maintenance authority, subject to continued validity of the LAME licence. No L2 renewal is required whilst holding a valid LAME licence. In the event that a member’s LAME licence becomes invalid, they must notify RAAus within 7 days and will be required renew their L2 as per section 3.3.1.
 

• Aircraft operating in class G must use a GPS capable of an accuracy within 100 feet for checking airspeed and altimeter accuracy. Previously manual stated GPS without a defined accuracy parameter.

[jackc]

And for those who have a 19 reg aircraft and are not the original builder?

[Kyle Communications]

Oh what a wicked web they weave

 

[Flying_higher]

If you re-read their email you’ll see that they say there are no material changes or costs to members. And the list you’ve posted are the summary of changes only. L1 continues to exist as does everything else, given there are no material changes.

[Jabiru7252]

It's all too hard for my failing brain. AS recreational pilots I thought we could be free of the BS that GA pilot/owners put up with. Now I have to find some clown with a soft condescending tone to explain this crap to me while sitting me on her lap.

[jackc]

In the coming days, the wheat will be sifted from the chaff......

[Kyle Communications]

Well is it?  They say the revised Tech manual V4.1...which isnt posted yet. This is some of what it says about changes to the Tech manual

 

• Section 6 regarding aircraft modifications has been rewritten to provide more clarity on requirements for modifications in respect to the differing aircraft certification bases
• Maintenance policy updated to provide further clarity regarding maintenance schedules

So it will be interesting to see what these are. 

 

With all these changes and new acronyms.....more acronyms means more cost

 

[dlegg]

Aircraft operating in class G must use a GPS capable of an accuracy within 100 feet for checking airspeed and altimeter accuracy. Previously manual stated GPS without a defined accuracy parameter.

 

So now we have to have a GPS? Just how accurate is the ipad/android collection. My samsung phone with RWY is at least 100ft out all the time.

[Kyle Communications]

The GPS in the ipad and phones is very accurate

 

[Flying_higher]

The GPS 100m requirement relates to the calibration of instruments whilst on doing maintenance. It’s not about using a GPS for navigation in Class G.....because we are visual pilots where the mark 1 eye ball is what we should be using....

And re the iPad performance, this wouldn’t meet the requirement as it doesn’t meet the 100m performance standard like a WAAS capable device. 

The only difference I can see from the current tech manual requirement for calibrating instruments is that a performance standard for the GPS is now stipulated. 

[Kyle Communications]

Taken from the web

 

Is iPad GPS accurate?

The iPad with the 3G/cellular option has an embedded GPS. The WiFi only iPads do not have an embedded GPS. ... When you use an iPhone or iPad to geotag a photo, the accuracy is about 100 feet (about 30 meters), because Apple only stores GPS data down to the nearest second in latitude and longitude.

[facthunter]

I think  we have the blind leading the blind. Nev

[Flying_higher]

2 hours ago, Kyle Communications said:

Taken from the web

 

Is iPad GPS accurate?

The iPad with the 3G/cellular option has an embedded GPS. The WiFi only iPads do not have an embedded GPS. ... When you use an iPhone or iPad to geotag a photo, the accuracy is about 100 feet (about 30 meters), because Apple only stores GPS data down to the nearest second in latitude and longitude.

I know that they are pretty accurate. I’ve certainly had no problems myself either however when it comes to what their certified performance accuracy is, it doesn’t meet the same as that required for 100m accuracy all the time, as in needed in this case. And if you look at the WAAS capable GPS levels of accuracy, this does meet this standard which is why these are used for IFR approaches. 

[walrus]

We don't have WAAS in Australia.

[Flying_higher]

Correct, we don’t have WAAS but a WAAS capable device has a performance standard of better than 100m even when not using WAAS. 

[kgwilson]

A lot of (cheaper) phones and iPads have AGPS only. The A stands for "Assisted" and the assistance is provide by the cellular system which can be fairly accurate in an area with a lot of towers so you get reasonable triangulation. In more remote locations it is useless. Quality phones have their own GPS chips and don't rely on the cellular system. It also depends on what system they use. Some use multiple systems, some only 1 or 2. There is GPS (US) Glonass (Russia), BeiDou (China) Gallileo (Europe) and there are regional Japanese and Indian systems. If you have a Spot tracker it uses a private GPS system called Globalstar (who own Spot) which is very accurate (to within a few feet). This covers most land masses like all of the continents, Australia & NZ,  but not Antarctica and large areas of ocean.

Edited March 15, 2021 by kgwilson

[Keith Page]

I am at a loss how did RAAus get granted Part 149 when their manuals are not completed.

I am of the view all those manual are to be ticked off before Part 149 is granted.

The other missing issue Part 149 is what one is going to do and Part 103 is how one is going to carry out operation.

Now Part 103 is now actually a MOS for Part 149, the goal posts have wheels under them.

The Glider federation paid a lot of money to have their SMS formulated and the goal posts moved on that one.

So happy times. No wonder aviation is going backwards.

KP

[jackc]

The manuals are probably completed and signed off and RAA are keeping them under wraps until D Day.  In the meantime they will be writing their ideas of what we must do to comply.  
Hopefully the more knowledgeable among us will scour through all and tell us the real story.

[Keith Page]

2 hours ago, jackc said:

The manuals are probably completed and signed off and RAA are keeping them under wraps until D Day.  In the meantime they will be writing their ideas of what we must do to comply.  
Hopefully the more knowledgeable among us will scour through all and tell us the real story.

That is all OK...CASA is derelict in duty for signing off before all the requirements are not address and compliant.

The manuals must be compliant as a requirement of gaining Part 149. How will the process stack up in an audit?

If there is any other process -- could be a case of supposed non compliance.

[Flying_higher]

2 hours ago, Keith Page said:

I am at a loss how did RAAus get granted Part 149 when their manuals are not completed.

I am of the view all those manual are to be ticked off before Part 149 is granted.

The other missing issue Part 149 is what one is going to do and Part 103 is how one is going to carry out operation.

Now Part 103 is now actually a MOS for Part 149, the goal posts have wheels under them.

The Glider federation paid a lot of money to have their SMS formulated and the goal posts moved on that one.

So happy times. No wonder aviation is going backwards.

KP

Perhaps the fact that the 149 certificate doesn’t come into effect till 31 March and because they’ve told us the manuals will be published by then, that in fact they have been signed off.

 

And if you actually understood the regulations you would know that CASR Part 149 has a Part 149 MOS. Part 149 is the regulations for how an ASAO administers it’s operations. 
Part 103 reg and mos are the operational regs that go hand in hand with Part 91. It works the same way as Part 121 does with 91. 
 

 

[dlegg]

So what exactly is the big deal, what exactly has changed apart from new acronyms to learn and new titles dished out to elite management, bigger manuals that only lawyers can read. CASA sure is having a big joke at our expense.....

[Yenn]

Not much has changed but an awful lot has happened. There has been a large amount of time and money expended on keeping the situation the same as before.

At least one competitor to RAAus has poured a lot of time into becoming compliant ages ago, only to be brushed off by CASA.

[Jim McDowall]

53 minutes ago, Yenn said:

There has been a large amount of time and money expended

RAAus paid a lot of money only to have the GFA sponge on its work and decide to "copy and paste" RAAus's P.149 work product - also agreed to pay a consultant who I believe did work for RAAus's Part 149 exposition (application?) $10K to assist with the process. (see GFA minutes August 2020). At that stage RAAus's exposition was not in the public domain.