RAAus and our new Tech and Ops manuals - how to drive a horse and cart through them

[Blueadventures]

1 hour ago, Roscoe said:

Ok here is the reply I received today

A MINIMUM NON FLYING MEMBERSHIP IS TO BE MAINTAINED WITH RAA for an L2

The question i asked  was if a LAME had to be an RAA member to act as an L2

Happy with that.

[slb]

Does anyone know abut any changes to being able to do any modifications to our own aircraft?

 

The previous Tech manual said under the heading of:

5 Approval Of Modifications

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.

 

However I cannot find any reference to that being allowed in the new Tech manual. All I can find is 

 

4 Approval of Modifications

The owner/operator of the aircraft or aeronautical product is ultimately responsible for the airworthiness of the aircraft or product. This includes ensuring that any modification has been approved and is compatible with the configuration of the aircraft, that the conditions of any approval have been complied with, that the airworthiness records for the aircraft or product are up to date, and for reporting major defects to RAAus associated with the modification.

 

I have read through most of the new manual and originally thought that the above statement was for experimental or LSA aircraft but cannot find where is says you are still allowed to do minor modifications on non-LSA aircraft. 

Edited April 27, 2021 by slb

[WaterWings]

Is L1 L2 L3 L4 on the way out as well?

 

https://www.casa.gov.au/sites/default/files/maintenance-amateur-built-light-sport-aircraft.pdf

 

CASA is proposing to adopt the FAA Repairman Certificate model (to be described in Part 43 as an aircraft maintenance technician certificate (AMTC)) to provide for specific maintenance tasks to be carried out by qualified persons who do not hold a Part 66 licence.

These authorisations for maintenance were previously (and are currently) available via various legal instruments made under regulation 33B or 42ZC(6) of Civil Aviation Regulations (CAR).

[Thruster88]

I don't think the casa proposal has anything to do with RAAus. It will apply to VH amateur built aircraft, RV6 etc.

[Thruster88]

The SAAA is working on a course to allow non builder owners of amateur built VH reg recreational aircraft like me to conduct the annual inspection.

 

In response to encouragement from CASA, almost completed development of a Maintenance Techniques Course (MTC). Beyond creating a comprehensive knowledge base, the MTC aims to streamline (and replace) the current Maintenance Procedures Course (MPC) and also provide a basis for non-builder aircraft owners to conduct their own annual inspections and related certifications of their aircraft. We hope to be able to submit the course and all supporting documentation to CASA for approval mid-2021 – given CASA’s long-standing support for this, we are hopeful of an expedient approval

[Kyle Communications]

The SAAA do courses every year for maintenance. Its for owner builders and you can do all your own maint...legally also you can sign off on anyones W&B as well but it of course is not recommended to do.  I did the maint course in Feb last year

 

[WaterWings]

3 hours ago, Thruster88 said:

I don't think the casa proposal has anything to do with RAAus. It will apply to VH amateur built aircraft, RV6 etc.

Did you read it ??

 

“Maintenance for LSA (factory built and certified) aircraft”

Doesn’t sound like an amateur built RV6 to me

[Kyle Communications]

I just read that CASA document and it is basically the MPC course that SAAA do. Yes its done if you build your own and maintain your own VH registered aircraft. It looks to me like CASA will adopt that for LSA and ELSA aircraft..they come under the pervue of RAA now. The L1 course RAA do is not like the MPC course. Most of the MPC course is literally all the legal paperwork and structures of maintenance of a VH aircraft. I expect if Group G happens for RAA that is what the maint proceedures will become.

 

[Thruster88]

7 hours ago, WaterWings said:

Did you read it ??

 

“Maintenance for LSA (factory built and certified) aircraft”

Doesn’t sound like an amateur built RV6 to me

Apologies, I had not read it all when I posted. 

What I don't get is why we continue to divide light recreational aircraft into classes. The non builder owner of an RV6 will need AMTC3 a 16 hour course. The owner of a LSA Tecnam or jabiru will need  AMTC4 a 120 hour course. At work we inspect,  repair and maintain a wide range of aircraft, amateur built, LSA, and certified piston and turbine aircraft. Do they need different levels maintenance,  no an elevator control system for example requires the same maintenance regardless of class.

[SSCBD]

How stupid is RAA,  that a LAME cannot do work on a RAA aircraft.  Why would a LAME pay for a RAA membership to work on toy aircraft compared to the GA stuff - really.   

 

[kasper]

1 hour ago, SSCBD said:

How stupid is RAA,  that a LAME cannot do work on a RAA aircraft.  Why would a LAME pay for a RAA membership to work on toy aircraft compared to the GA stuff - really.   

 

And there is a reason they have to be members of RAAus ... a legal reason ... it’s that RAAus is responsible under the CAO to set and manage repair/maintenance and without membership the tech office have NO ability to monitor or manage the LAME ... CASA can manage and control LAME ops on the non”toy” aircraft because they are not under the CAOs that the RAAus aircraft are.  
 

true it would be possible for CASA to rewrite the CAOs to allow them to manage and monitor LAMEs doing work on “toy” planes BUT it’s then taking onto CASAs risk the ops of the “toy” planes ... which they have never wanted to do so there is an active reason for CASA to say no way to change from RAAus oversight of the airframes and maintenance  

[jackc]

13 minutes ago, kasper said:

And there is a reason they have to be members of RAAus ... a legal reason ... it’s that RAAus is responsible under the CAO to set and manage repair/maintenance and without membership the tech office have NO ability to monitor or manage the LAME ... CASA can manage and control LAME ops on the non”toy” aircraft because they are not under the CAOs that the RAAus aircraft are.  
 

true it would be possible for CASA to rewrite the CAOs to allow them to manage and monitor LAMEs doing work on “toy” planes BUT it’s then taking onto CASAs risk the ops of the “toy” planes ... which they have never wanted to do so there is an active reason for CASA to say no way to change from RAAus oversight of the airframes and maintenance  

In other words the system is a mess.......that is not going to get any better?

[tillmanr]

It would be reasonable for RAA to create a technical membership for LAMEs at a reduced annual fee. This would allow a greater access to skilled services for the members who cannot effectively carry out servicing. 
As with GA instructors who have only a few RAA BFRs it is not economical to retain their RAA membership to provide this service.

[spacesailor]

BUT

With all those home built airframes AND motors Not all LAMES  would be qualified !.

I Hear Carbon-Fibre airframes cannot be repaired by Most LAMES.

and the One who specialises Wants Half the aircraft SHARES as well as money. 

spacesailor

[tillmanr]

I am not suggesting that LAMEs are a cure all nor to be mandated but they are a resource that could be used where appropriate.

Pilots can’t fly all aircraft and LAMEs can’t service all aircraft.

I have experienced ordinary servicing by LAMEs, L1s and L2 s as well.

You can can only regulate so much.

[jackc]

1 minute ago, tillmanr said:

I am not suggesting that LAMEs are a cure all nor to be mandated but they are a resource that could be used where appropriate.

Pilots can’t fly all aircraft and LAMEs can’t service all aircraft.

I have experienced ordinary servicing by LAMEs, L1s and L2 s as well.

You can can only regulate so much.

The trouble is we regulate TOO much,  LAMEs would rather work on GA than RAA, it’s an ego thing. More money in GA at all levels too. GA does not want RAA to have more privileges?

Just like GA pilots and RAA pilots......RAA pilots play with ‘toy’ planes?

I would like to see another category with LESS privileges and no licence, no rego.....call it Foundation Aviation:-)

 

[turboplanner]

1 hour ago, jackc said:

In other words the system is a mess.......that is not going to get any better?

It's not a mess; Kasper has pointed out an issue.

As a Self Administering organisation, RAA carries the Public Liability for ALL the import, construction and operations of aircraft, and for the people it trains to flying them and their operations and for the people who maintain them.

 

Where someone is killed or injured, and there is an allegation that RAA breached its duty of care, RAA is likely to be a Defendant, and ultimately this could affect shareholders pockets.

 

RAA needs to train and Audit LAMES for that reason; they probably wouldn't need a lot of training, so it would be possible for RAA to protect its members' access to repair facilities by developing a Subsidy policy.

 

[tillmanr]

Sorry jackc  my experience doesn’t accord with your view.

There are different attitudes around.

[jackc]

Just now, tillmanr said:

Sorry jackc  my experience doesn’t accord with your view.

There are different attitudes around.

There sure are some different attitudes around, and you might be surprised what they are and the people who have them.

Many are tiring of the b/s overload that Aviation seems to be suffering right now.

The ‘empire of years ago needs to strike back’..........

[jackc]

14 minutes ago, turboplanner said:

It's not a mess; Kasper has pointed out an issue.

As a Self Administering organisation, RAA carries the Public Liability for ALL the import, construction and operations of aircraft, and for the people it trains to flying them and their operations and for the people who maintain them.

 

Where someone is killed or injured, and there is an allegation that RAA breached its duty of care, RAA is likely to be a Defendant, and ultimately this could affect shareholders pockets.

 

RAA needs to train and Audit LAMES for that reason; they probably wouldn't need a lot of training, so it would be possible for RAA to protect its members' access to repair facilities by developing a Subsidy policy.

 

Let me say this.....I have been told in a phone call to RAA that they are not worried whether you glue your 19 rego aircraft with bluetack, IF an aircraft crashes and the Coroner reports on his/her findings including a safety problem?   Coroner sees the words ‘Amateur Built Aircraft’ and closes that case.......next please.

In other words RAA does administration of the sector and has no responsibility.

No, I won’t say who told me that.......buses are mongrel things to get thrown under......

So I have to ask WHY do I need to be an RAA member, WHY register my aircraft with them?   IF all that is the case WHY do I even need an RPC?   

[turboplanner]

37 minutes ago, jackc said:

Let me say this.....I have been told in a phone call to RAA that they are not worried whether you glue your 19 rego aircraft with bluetack, IF an aircraft crashes and the Coroner reports on his/her findings including a safety problem?   Coroner sees the words ‘Amateur Built Aircraft’ and closes that case.......next please.

In other words RAA does administration of the sector and has no responsibility.

No, I won’t say who told me that.......buses are mongrel things to get thrown under......

So I have to ask WHY do I need to be an RAA member, WHY register my aircraft with them?   IF all that is the case WHY do I even need an RPC?   

Someone has a LOT of study to do. A Coroner decides the cause of death. In the case of an amateur built aircraft crash the Police investigate the crash, call in RAA to assist when there are technical matter and present a brief to the Coroner. Independent of this, the family of the deceased or the injured victim can sue whoever breached their  duty of car, starting with you, the pilot if you were negligent even if it was accidental. This will be heard in.a Civil Court. If the Court finds you , or anyone associated with the flight whether building the aircraft, teaching you, owning the airstrip etc. Self Administration is self administration and RA aircraft fly under exemption from certain regulations on condition that it self regulates.

[jackc]

Then you get to find out GOOD the RAA insurance is, something else I have little faith in these days.....it’s not ‘insurance’ anymore, its risk mitigation on varying levels usually dictated by how many pages the PDS is.......

[turboplanner]

14 minutes ago, jackc said:

Then you get to find out GOOD the RAA insurance is, something else I have little faith in these days.....it’s not ‘insurance’ anymore, its risk mitigation on varying levels usually dictated by how many pages the PDS is.......

No good growling about it. These are the times we live in.

 

[spacesailor]

Until that

BIG REVOLUTION.

Then the proverbial poop hits the fan !

and

Starts the poopfight

The new microlights Don.t need an airfield as such, & will fly, then disappear Before the Cops & CASA gets  off their derriere. 

There WAS a PP training group in Richmond, ( noisy sods ), but were chased out. Autogyro's in Eastern-Creek area. long gone.

How long before the RAA get the push.

All go to VH with the Big boys.

Unless the American 103 gets here.

spacesailor

 

[jackc]

26 minutes ago, turboplanner said:

No good growling about it. These are the times we live in.

 

I don’t growl, I just do stuff!

NO guts.....NO glory:-)