RAA…..is it me?

[F10]

Well, apart from the fact every year I’ve been a member of RAA, the membership has gone up $25 every year….(you gotta wonder where that will end up), I have thought recently, what does RAA really do for me, after annual membership fees and aircraft registration fees? Well yes, they provide a framework and organisation under which we can operate sport and recreational aircraft, which is great. I love this concept, it has without doubt, allowed me as a retired aviator, to afford to keep flying, for fun, the best kind of flying. However, looking at the RAA charter, recently I have experienced what to me, has not been quite in the spirit of encouraging and promoting recreational aviation. 

My aircraft came up for it’s annual inspection. I asked someone else to do it, instead of another L1 who I know. I wanted another pair of eyes on it. So, this led to me fitting new seat harnesses, and oh no, forehead slap…there were signs of corrosion on the Bolley prop hub. Now, this Bolly had been fitted around 2007. I have evidence of the prop blades being reconditioned in 2014. There was corrosion, when I tried to undo the hub bolts, in trying to undo the blade root clamp bolts, I just started to shear the bolt heads off…so, after discussion with my ownership partner, we decided to cut out losses, and buy a new Bolley BOS3 3 blade prop. 
 

Wanting to do the right thing, I e mailed RAA informing them I wanted to replace the prop with the exact same model of prop. Then..I looked up my aircraft registration certificate, noting it showed a Bolley prop was fitted, all good….! I also thought, when I bought the aircraft, I had a condition report done…which also recorded a Bolley prop was fitted. 
 

Lo and behold, RAA wrote back and said I needed to submit a modification request form, and a condition report form…..🙈 Well, ok, not thrilled…but, the mod request was a one page form and hey, this Gazelle is in good shape…so, all good, RAA confirmed Bolley props were certified, all was good. Submitted all forms as required….so far, RAA had played no part except having forms I could print off…It had all cost me a fair bit 💸💸 then horror of horrors…

 

I then received an invoice from RAA, charging me $660 (tax included), for the issue of a modification approval. $660….!! Now I was smarting a little from yet another membership price increase, but to me, this was an outrageous amount of money, very nearly 1/3 of the new prop cost.
 

Not only this, but to me, to me, an administrative error has been made by RAA, because this aircraft had been sold 3 times, (by implication, three condition reports sent in) fitted with a Bolley prop, me being the third buyer. Why must I be saddled with the full MARAP cost? I was expecting around $200…..!

 

I have spoken about this to other aviators…needless to say, signs I noticed were, this is a disincentive to report aircraft modifications. I should have kept quiet! Not the desired outcome RAA wants I’m very sure.

 

Bolley went through an expensive no doubt, certification process…would they be happy RAA was charging this, to fit a Bolley prop? Is this promoting safety and efficiency? I know one mate who would love to fit a Bolley to his Jab, but won’t, because of the “paperwork”. Sad!

 

I just get a very “bureaucracy CASA” type feel over this. Like I said, without lifting a finger in this whole process, I pay them $600? I have no problem paying for a MARAP…but was expecting $200-250. Even $300 I would have reluctantly accepted.

 

Now to be fair, I have written to RAA, stating my case. I am hoping they may consider reducing the MARAP cost. We will see.

 

Is it me? Am I being overly reactionary? I will be interested to see any response to this.

 

 

 

 

 

 

[spacesailor]

Just tell them !.

No ' New Bolly prop ' , but will keep the OLD one .

Please return remittance. 

I wonder what the response will be.

spacesailor

[facthunter]

They DO have a monopoly but shouldn't abuse it. . CASA said at the beginning that RAAus Ops/requirements would NOT exceed what VH was subject to. You wouldn't be the only one in this situation. Prop swaps are not rare. IF it's their error ask for a review.    Nev

Edited June 28, 2023 by facthunter

[RFguy]

I wonder what they actually DID for their $660

If they had to do engineering legwork, ask them to provide the work done. 

IE was this just a money grab, or was an engineering appraisal done (and provide the worked solution please to prove that someone just didnt say ' yeah its fine')

 

Given how poor RAAus persue Jabiru on many things, and how poorly , and incompetently they look into accident reasons,  they are , in my opinion an incompetent organisation of gravy trainers with varying   standards . 

The staff earn good money and I am yet to see evidence of high competency / high performance.

[RFguy]

AND the other thing- 

Surely you re entitled to a quote or an estimate of costs BEFORE they send you an unknown bill ? IE a contract of sorts ?

Get the lawyer blowtorch on this lot. I'll put in.

 

[kasper]

Sorry but RAAus is not a body that has to negotiate.  
 

they set their fees and that’s that. 
 

and whilst I agree that they appear to be poor value they are at least open on MARAP - their published fee is a minimum cost of $660 so that’s just life. 
 

MARAP when introduced was a horrible structure in my opinion - search for MARAP on here and my name and you can waste some time  reading many problems with it. in my opinion.

 

so just to summary - MARAP is a real disincentive to remain legal as EVERY change to make on an airframe subject to it is a seperate MARAP.

prop change MARAP

change wheel rims and/or brakes MARAP

recover with a fabric paint system different from the original MARAP 

change the instruments MARAP 

change from r532 to r582 MARAP 

change from one gear ratio intbeh r gearbox to suit new prop MARAP 

put spats on an airframe that didn’t have them MARAP

 

now how many light wings and thrusters have NOT had at least a few of these over the past 30 years?  

[spacesailor]

BUT To change " same for same " should Not be MARAP .

As there Is No change ! .

spacesailor

[F10]

2 hours ago, facthunter said:

 IF it's their error ask for a review.    Nev

Well as I said, I have asked them to consider reducing the cost as this mod should have been picked up years before I bought the aircraft. It seems no one looks at condition reports? So we will we. I just think $600 is an outrageous sum.

[F10]

22 minutes ago, kasper said:

Sorry but RAAus is not a body that has to negotiate.  
 

they set their fees and that’s that. 
 

and whilst I agree that they appear to be poor value they are at least open on MARAP - their published fee is a minimum cost of $660 so that’s just life. 
  

Just life…well again as I said, I didn’t actually put the Bolley on, it was done years ago….and not picked up by RAA I guess, despite condition reports. So why must I pay the full amount? RAA according broadly to it’s charter, has a mission to promote sport aviation aviation safety and to support it’s members. Charging a member $600 to fit a certified and technically superior propeller to an aircraft, should not cost that much.  

[RFguy]

It would not take much effort to change the organisation if we wanted to by getting active before the AGM.

Its an org elected by members so we can change it if we want to... just takes a little effort.

Edited June 28, 2023 by RFguy

[aro]

If it's the same model propeller I wouldn't expect a form would be required.

You're just replacing a worn out part, same deal as changing a tyre.

[Flying_higher]

Sorry, but isn't a MARAP like an STC? Doesn't that mean that the RAA or someone has paid for the R&D to enable the part to be put onto the aircraft? Surely we can't just go and bolt any part onto our aircraft.

 

Given that RAA or someone has paid for it, aren't they entitled to recoup their money for the R&D and any liability?

 

Don't get me wrong, I think this is unfortunate for F10, given his situation, but if MARAP didn't exist F10 would need to put the original parts back onto the aircraft for it to be compliant.

[facthunter]

You  are not just bolting ANY part on your plane.  It's from a recognised Manufacturer. IF that prop is OK'd Once it shouldn't have to have any extra time spent on that matter.  In any case for certain categories you could make your own prop and engine if it came to that. It's NOT Airlines we are dealing with here.  Nev

[440032]

MARAP is like an STC for RAAus factory built aircraft - yes.

It came about (in part) to be able to support older aircraft where original parts (as per the Type Acceptance Certificate data sheet) became no longer available. Listed propellers for example.

Until MARAP came a long, perhaps the only other option to change prop was a full CAR 35 engineered and CASA approved STC.

 

 

[Flying_higher]

44 minutes ago, facthunter said:

You  are not just bolting ANY part on your plane.  It's from a recognised Manufacturer. IF that prop is OK'd Once it shouldn't have to have any extra time spent on that matter.  In any case for certain categories you could make your own prop and engine if it came to that. It's NOT Airlines we are dealing with here.  Nev

If there was no R&D performed on that aircraft/engine/prop combination, how are we going to know if there are no adverse effects such as vibration, aerodynamic changes, loading up the crankshaft, or what ever? Therefore in my books it is just bolting any part to the aircraft. Using your analogy I should be able to attached a DC3 prop to my certified Jabiru with no worries at all apart from the prop weighing more than the aircraft!

 

I'm not suggesting this is the airlines Nev, but it's also not 1950. There still needs to be standards as there is no 'experimental' category for type accepted aircraft and therefore it much either conform with the type certificate or have some other mechanism to provide assurance, in this case its a MARAP. In the VH world this would be an STC or EO. Remember, a type certified aircraft can be used for flight training therefore is it fair that little johny's mum and dad take him to the airfield for flight training thinking that the aircraft meets a standard (no matter how 'loose') and it doesn't? This is why initial training isn't permitted in amateur built aircraft. 

[old man emu]

When did this MARAP come in? Was it after RAA became a SAAO? I ask because I can remember replacing props on Jabirus that had become damaged by raindrop strikes and other normal things that wreck wooden props.

 

5 hours ago, RFguy said:

It would not take much effort to change the organisation if we wanted to by getting active before the AGM.

Its an org elected by members so we can change it if we want to... just takes a little effort.

Methinks you have identified the problem. If I recall, there wasn't a groundswell of activity amongst the members when there was the major change to the the organisation's structure a few years ago.

[Flying_higher]

Sorry, I hit 'submit reply' a little too early in my previous post. 🙄

 

Just to be clear, I would love for there to be an experimental category that does actually permit these types of modifications without the need for a MARAP. This would permit people to take the control of risk back into their own hands, like the AUF days, and also reduce the burden of overly complex and costly compliance, noting it would likely introduce some operational restrictions like no flight over built up areas or flight training, for example. It's my understanding that the RAA have been trying to get CASA to agree to this for years. Hopefully CASA will see the light and allow this so many of us can go back to simple flying.

[facthunter]

You're NUTS if you fly over populous  areas anyhow on ONE engine.. VH EXP is what you want. There should be an equivalent in RAAus or the GAME stinks IF fairness matters.. RAAus is first and foremost a BUSINESS. There's little expertise in it for what we want and so it's not likely to keep them awake nights and make any changes . Nev.

[pmccarthy]

24 minutes ago, facthunter said:

You're NUTS if you fly over populous  areas anyhow on ONE engine.. 

Do you mean all the single engine flying that is done legally and safely today over towns and cities? Or do you have a particular type of engine in mind?

[440032]

The MARAP process came in around 2015 or so. So it's nothing new.

[kgwilson]

MARAP of course relates only to factory built aircraft but I think the $660.00 fee is over the top and some justification for this fee is required even though it is published as such. I built my own aircraft and so can maintain and modify it as I wish.

 

I installed a new 2 blade Bolly BOS-5 prop in December 2018, completed the appropriate form with the prop data supplied by Bolly and that was it. No fee and my aircraft record is updated so why this exhorbitant fee for doing essentially the same thing. Given the prop being replaced is identical and I imagine is also installed on other Gazelles I can see no justification at all.

 

RA was supposed to make aircraft ownership more affordable but all they seem to be doing is trying to emulate the ridiculous compliance costs of GA. The circumstances surrounding this specific case should see the fee refunded in full in my opinion.

[facthunter]

PMC what's your plan of action IF the engine fails over a populous area? If it's a turbine it's probably 20 times safer. You are in an aeroplane  that doesn't stay up there for long without an engine working regardless of whether  it's legal or not. You operate under LAWS of Strict Liability which means no excuses for creating damage. etc and you CHOSE to make the flight.  Nev

[BrendAn]

23 minutes ago, facthunter said:

PMC what's your plan of action IF the engine fails over a populous area? If it's a turbine it's probably 20 times safer. You are in an aeroplane  that doesn't stay up there for long without an engine working regardless of whether  it's legal or not. You operate under LAWS of Strict Liability which means no excuses for creating damage. etc and you CHOSE to make the flight.  Nev

so you want to shut down all metropolitan flying schools in  australia because they do this thousands of times a week with piston engines as you know. usually the ones that fall out of the sky manage to find somewhere to land/crash without hurting anyone else.

[facthunter]

Of Course not but students etc should be aware of the situation they are in.  Single engine Night VMC is also allowed but it's difficult to get pilots to check others out. CASA prefers PIFR. So do I.. I prefer more than one engine but people have to fly them well or THEY are deadly too. Nev

[kgwilson]

59 minutes ago, facthunter said:

PMC what's your plan of action IF the engine fails over a populous area? If it's a turbine it's probably 20 times safer. You are in an aeroplane  that doesn't stay up there for long without an engine working regardless of whether  it's legal or not. You operate under LAWS of Strict Liability which means no excuses for creating damage. etc and you CHOSE to make the flight.  Nev

Well at least we can land on sports grounds, golf courses and roads without power lines in our small aircraft.