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[Guest L/D]

Whilst I don't want to put anyone down or criticise overly, there are a few things in the latest magazine that caught my eye, where it left me wondering - doesn't anyone else proof read the articles?

 

The issues I see lie currently with the tech department, and whilst I know Steve hasn't been there that long as yet, it has been about 8 months now so the ins and outs of the various registration categories should be starting to gel.

 

I read with amusement and concern in the latest magazine (march09) that when an aircraft is put into Experimental category, that the aircraft is no longer "operated" to the same safety standards as normal commercial passenger flight, (pg32 warning placard).

 

I disagree with that statement, and I really hope that it was a misprint and should have made some reference to "maintained" instead.

 

The next bit for which RA-Aus should be congratulated as it could never be done before was to place a factory built aircraft (aka Gazelle) into the experimental category after it has been modified without manufacturer's approval OR a CAR35 approval, for an infinite period of time. (pg 9+32)

 

Whilst this is good for us aviators with said aircraft, I hasten to think what the consequences to the organisation would be when there is a double fatality. Is this approved by CASA? Is it somewhere in the tech manual?

 

At least the resale value of the Gazelle just increased by 20% at least. Good for you Ian ;)

 

Page 9 is a concoction of all categories with bits of LSA and Amateur built requirements listed under the heading 'Factory Built Non LSA'.

 

 

[Guest TOSGcentral]

I feel I have to chime in here with some other views and hard data.

 

 

Even in an article the size of Steve Bell’s latest there is only a limited amount of space so we were getting effectively an information summary that will not tell the total story.

 

 

What I can say is that the Thruster Operator Support Group (TOSG) is most happy with what Steve is doing and the speed he is moving at. He has a very positive and enlightened attitude to airworthiness, particularly in resolving some of the convoluted (or even contradictory) administration areas.

 

 

Although certainly not a situation exclusive to Thrusters, there are very distinct hassles in situations when the Type Certificate holder is no longer active and supporting manufactured types. Existing fleets could be tied up or ‘technically/legally compromised’ just trying to keep them going.

 

 

To put that in a sharper focus I estimate that we have about $3M worth of second hand Thrusters still active. That sort of scale (particularly in a recreational area) is not something you lightly allow to be grounded just for paperwork issues!

 

 

As a practical example a TOSG member was challenged on the legality of his Thruster over a very benign modification issue. The aircraft has been inspected, found entirely safe and Steve slipped the machine sideways into Experimental so it could be still flown but time given to research the modification situation.

 

 

In my view that is enlightened activity of RAAus working for its membership in a practical manner and is to be applauded.

 

 

Tony

 

 

[Guest L/D]

So what you are saying is that whilst the modification is being proven, the aircraft has been moved into a category that does not exist within RA-Aus and is flying there happily, signed out by RA-Aus?

 

Or did I miss a piece of legislation somewhere?

 

 

[Guest brentc]

I read with amusement and concern in the latest magazine (march09) that when an aircraft is put into Experimental category, that the aircraft is no longer "operated" to the same safety standards as normal commercial passenger flight, (pg32 warning placard).

I disagree with that statement, and I really hope that it was a misprint and should have made some reference to "maintained" instead.

It is the unfortunate reality that an Experimental aircraft is not operated to the same standard as a commercial passenger flight. This isn't just about maintenance, but flight planning, crew resource management, support crew and crew training etc.

 

I have seen a modified placquard that said "the aircraft is not operated to the same safety standards as normal commercial passenger flight. It is operated to MY standards."

 

 

[Guest TOSGcentral]

L/D – there may be a bit of terminology or semantics at work here mate.

 

All I can say is that I have been in quite in-depth discussions with Steve this week over modifications and know that he is engaged in broad ranging and close discussions with CASA – so I do not think that he has blindly ‘invented’ some non existent category – and no, I cannot quote exactly what mechanism has been used in this situation you have brought up.

 

For the interest of readers here is some background information to the modifications area generally.

 

A modification to a certified aircraft can be a risky business if only for liability reasons if there is a bingle. The logic is if the modification has not been prior approved then the rego is void, if the aircraft is flown then it is illegal and if you illegally fly an aircraft in Oz a whole row of dominos go down that you will not be able to defend in court – so you have lost before you even start!

 

This principle applies to any certified aircraft but it is a bit more convoluted in 95.25 category. 95.25 was from the outset intended as a stop gap measure to allow things to get going, training be introduced promptly (as per HORSCOTS requirements) and in due course 95.25 was rescinded and merged with 95.55.

 

At the point of that happening an edict came down that no new 95.25 designs could be made (no ordinance for them to be built under any longer) but new examples of existing types could be manufactured (eg the wire braced Drifter) and also that while minor modifications (duly certified by a CAR35 engineer) could be acceptable, major modifications could not be so made.

 

Where the dividing line between major and minor is actually drawn can turn out to be a matter of opinion and can result is some time consuming and expensive back and forth with CASA.

 

With the Thrusters some kind of benchmark line was established via retrofitting the Rotax 912 motor. CASA said NO – it was a major mod. Newton Hodgeskiss (the Thruster actual 95.25 designer) argued the toss and the engine was in fact accepted. I am currently using that as part of the justification for getting a BMW R100 motor certified for the Thrusters.

 

With the minor mods (and in fact any mod) another bench mark line may be drawn on the basis of ‘if the aircraft is changed in any way from how it came out of the factory’ That statemement may be expanded to say ‘or is retrofitted with a component issued for the type by the manufacturer’. In the case of a 95.25 school aircraft the part would then have to be signed by a RAAus L2 as having been correctly installed.

 

What wraps all this lot together is that the factory (not RAAus or CASA) produces a signed statement that the aircraft has been manufactured in the manner, and to the design, that the factory has been granted approval for and is therefore compliant to CAO 95.25 (or whatever category the aircraft is in). The factory has to have one ‘Authorised Person’ to make this declaration – not just any factory employee, or even owner, can sign it.

 

This process is extended to non-factory authorised mods. This allows manufacture of modification components by other than the aircraft’s Type Certificate holder (normally the manufacturer). An example of what TOSG does will illustrate this more clearly.

 

Thruster owners have a challenge in that we can no longer obtain factory supply of critical primary structure components. So TOSG commissioned Engineering Orders (EOs) so that supply could be maintained. The process is somewhat involved.

 

Firstly the CAR35 Engineer designs the part and produces technical drawings. These are combined into a document that also details how the component is to be made and how it is to be correctly fitted. In our case a single fabricator is appointed and the part is only able to originate from this source – which gives total quality control.

 

The fabricator issues a Release Note stating that the component has been produced in accordance with the EO. TOSG then issues an individual serial number for the component and this is engraved into the component (or attached by a riveted plate etc). TOSG also maintains a master record of each component issued and which aircraft (by rego number and serial number) the part has been made for.

 

Now a CAR35 authorised modification is for a single aircraft. The above process meets this requirement but allows for manufacture without the factory having to be involved as individual aircraft can be treated in sequence under a blanket control Order. Each individual aircraft’s compliance is therefore preserved.

 

OK that is all a bit convoluted and messy but it works and is quite legal and kosher. But damn do people (or interpretation of the Ordinance itself) make things difficult to impossible!

 

If we go strictly ‘by the book’ then your (for example) 95.25 Thruster must be exactly the way it came out of the factory, or any modifications must comply with the procedures given above.

 

Great! The standard equipment on a factory produced Thruster did not include a compass. A compass is a desirable part of an aircraft. If you retrofit a compass to any 95.25 Thruster then technically you have voided your compliance!

 

Similarly if you want to enhance your operational safety and so fit balloon tyres for beach operations then you have voided your compliance because the factory never fitted them.

 

On the other hand if the original owner had specified both a compass and balloon tyres at the original order and the aircraft was supplied as such, then this would be covered under the factory ‘compliance signature’ and the aircraft is legal.

 

Bloody ridiculous is it not?

 

Now, in the example that I indicated in my post above, the circumstances were as follows: The aircraft was a 95.25 Gemini that had been retrofitted with a R582 motor and was challenged that it had been illegally modified as the factory never produced Geminis with that motor. That is mainly because the motor was not available at the time the Geminis were built but were fitted to Thrusters as soon as they did become available!

 

If we go a step further we should look at the overall 95.25 Thruster range (Gemini A & B, TST, TST L, TST E, T300 and T500). All of these were built to the same original design standard with some detailed changes here and there. Their aerodynamics, wing sections, geometry, size and form all remained constant.

 

The majority of people cannot tell the types apart even when they are standing next to them and certainly not at a distance! They are just ‘two seat Thrusters’. Yet some people are only too happy to start splitting hairs on ‘ordinance technicality’ and giving owners a hard time as a result because they ‘know a bit’. How much do they know?

 

In the case in point – the Gemini has the strongest boom of all the two seaters. It has a 2mm wall against the later 1.4 mm wall. It uses exactly the same engine mount (the 503, 532 and 582 mounts are common to all these engines). The 582 is safer in the Gemini than it is in the T300 it was first fitted to!

 

In fairness it is perhaps too easy to get cute when you know these types like I do and in comparison (as an L2) I would not know what modifications if any had been done to most ultralight types – and there are hundreds of them! But there is also a requirement that an inspector, at the point of a UACR or UCR, the modification status and that the aircraft is compliant if a certified type.

 

Inspectors and owners need hard information to base upon. TOSG did that with the Thrusters and made a list of known factory modifications to the various types and published it. This is underpinned by data that TOSG has and the prime area of this is factory brochures which illustrate or list the improvements.

 

The stance thus taken is that anything that came out of the factory had to be approved and due to the commonality of the Thruster two seater sub types then any such enhancements may be legally retrofitted to earlier models to enhance both their efficiency and safety. Sound reasonable enough?

 

Let me illustrate how simple it can be to apply ordinance and yet that ordinance appear to be totally prohibitive.

 

Back in 1984 and 1985 the Glasshouse and Gemini X Thruster two seaters were manufactured and sold. These were totally illegal aircraft as there was no ordinance to cover them. 95.25 gave us legal two seaters but even that was a bit daft to start with. You could do legal training in them but could not fly passengers unless you were an instructor. Common sense prevailed and the ordinance was changed. Common sense is what a lot of this is about – not getting away with doing uncontrolled and potentially dangerous things.

 

So nobody ‘grounded’ the Glasshouse and Gemini Xs – they should not have been flying in the first place. But they could not be registered yet were perfectly safe aircraft. Many years later TOSG stepped in and rationalised the situation in the following manner.

 

The original Thruster factory had no manufacturing approvals to build the machines – therefore they were just a bunch of enthusiasts building ultralights. By definition the aircraft were ‘Amateur Built’. So by definition they were eligible for the ‘Amateur Built’ category of 19 series rego. It was as easy as that! AUF accepted the premise and now you can fill the forms out (TOSG will help free of charge) and fly your aircraft legally.

 

This is what RAAus is doing now – putting common sense into the situation, attempting to obtain more autonomous decision power while complying with the ordinance in place but make it work better and more understandably for L2 inspectors and owners alike.

 

I say more power to their arm (in this area at least). I am quick to criticise RAAus when it appears to not be sufficiently pro-member or communicating well enough. But I am even handed and will willingly add my admiration and support when they are being most pro-active – as Steve Bell is currently being and applying a lot of effort to. So let us cut him some slack and let the man work for all of our benefits.

 

This should not be taken a critique of yourself L/D – I believe your observations were valid. I have just attempted to cast those critiques in a broader context.

 

PS. Despite all of the above I still missed a bit (probably several but I am sure that I will be told).

 

There is a distinct difference between a modification and a repair - even if the repair is a total refabrication of a part.

 

So for example you stuff a wing spar going through a fence and it is unsalvageble/repairable. This does not mean that you have to get a new factory made spar.

 

You can use your Maintenance Authority (L1, L2 etc) to fabricate a replacement. However by doing so YOU take responsibility that you have used the correct materials and the work has been done to an acceptable standard. This should be entered in the aircraft's log book for future reference

 

Aye

 

Tony

 

 

[Guest ozzie]

:confused:

 

 

[geoffreywh]

What a great explanation of a complex subject, Thanks, G