RAA

[gtboss16]

Could someone please tell me the pros and cons about an RAA licence and if i was going to go further into a CPL is it worth it?

I have flown a C172 for like 12 hours, so i wouldnt mine trying various aircrafts...
plus its a cheaper way

any thoughts?

[Horatio Leafblower]

The following is based on what we charge and assuming minimum hours because that's the only way to compare apples with small apples.

Up to 40 RAAus hours may be counted towards the 40 hours required for a PPL.

From my calculations (see above), RAAus with XC and Radio saves you about $1200 over a PPL.

When you then jump into a GA aircraft and have to learn how to handle the bigger/heavier machine, how to use radio navaids, how to handle controlled airspace AND do all the exams (because RAAus exams aren't acceptable to CASA) you have burnt up all the money you "saved" and then some.

Then there is the issue with RAAus and Commercial Pilot Licence requirements - we discussed this in the last 2 weeks - RAAus time cannot be counted towards your CPL (CAR 115(4) refers).

[VH-XXX]

HLB, haven't we done this to death only to come back to the fact that you can do up to 100 hours in RA-Aus for obtaining a CPL ? (with the remainder being GA time) 100 RAA + 100 GA = 200.

[Homesick-Angel]

Ive flown a fair bit in both RA and GA..

I chose to do my training at a school that caters for both so that the transition would be easier, and it was as they already knew my flying ability, and i knew their instructors.It certainly saved me a fair bit of cash, but im never doing the sums on how much it cost me to fly.I did it once and came down with the sweats..

When I crossed over to larger heavier GA aircraft i found the actual flying easier overall compared to the lighter RA Planes and found the extra weight helpful particularly with landings..Yeah there was a bit of learning nav aids etc and a few other odds and ends but it wasnt too much of a stretch at PPL level..
I did find simming very helpful for nav aid practice and general instrument practice..(That and asking a thousand questions of anyone who would listen or not avoid me when i walked toward them pen and paper in hand..)

The last time I checked there were a certain number of hours that you could put towards your cpl or generally counted as GA hours but Horatio's post is news to me and i hope not correct!..You will however need a cetain amount of time in GA aircraft(again cant remember the exact hours or times and im far too lazy to go look today)**posted this only to spot the above post afterwards**

Overall Im glad that I have experience in both and would suggest it because i think there is a movement toward the Light sport/RA categories and it is well worth having some time in them especially if you plan to instruct down the track..My guess is that within 5-10 years most schools that want to be financially viable will be training in either LS categories or RAA..

Hope that helps some..

Good luck.

[Horatio Leafblower]

No XXX - I will find my post from last month and paste it here because I don't have time to spell it out again:

How much do you spend? (http://www.pprune.org/dg-p-general-aviation-questions/405548-how-much-do-you-spend.html)

Thank you for the query - as CFI of both a CPL school and a RAAus school I was pretty confident of my ground. I have revisited the regs and I am still confident - although somewhat less so!


5.104 (1) (f) (ii): A CPL holder must have the experience described in 5.111 or (snip) 5.115

5.111 - a "150 hour" CPL must be flown in a registered aircraft (ie: VH-)

5.115 - must have 100 hours PIC, and 100 hours in a registered (VH-) or recognised (ie: military) aeroplane.

This is where the ambiguity comes in: subregulation 5.115 (4) stipulates that additional flight time to make up the total 200 hours must be flown in:
(a) a registered (VH-) aeroplane;
(b) a recognised (mil) aeroplane;
(c) a Helicopter;
(d) a gyroplane; or
(e) a glider (other than a hang glider).

Although Reg (2) stipulates what RAAus "recognised flight time" is, Reg 5.115 (4) does not list recognised RAAus flight time as an option.

Para (1) (b), (c) and (d) all make explicit reference to a recognised or registered aeroplane, while (1)(a) does not. 5.115(3) and (4) stipulate just about anything except an RAAus aircraft.

Having accrued the experience in (1)b/c/d you then need to make up the 200 hours in a VH aircraft. Are you suggesting that, having accrued 100 hours of RAAus experience before your CPL training you can avoid that requirement, but cannot accrue 100 hours of RAAus time to satisfy that after you satisfy 5.115(1)?

I am not saying you are wrong, nor that I am right -but I think my interpretation is more consistent than yours.

Cheers

..and then I said...

Further to my last:

This is extracted from the CASA Flight Crew Licencing Procedure Handbook:

Chapter 3.6 Aeroplane Pilot Licences
Page 3-31

:
• 150 hours total flown [all in aeroplanes (A)], to
an approved commercial syllabus including:
❍ 70 PIC
❍ 20 cross-country PIC
❍ 10 instrument flight
or
• 200 hours total, including:
❍ 100 PIC *
❍ 100 general (A)
❍ 20 cross-country PIC (A)
❍ 10 instrument flight (A).
* Can be in registered or recognised aeroplanes,
helicopters, gyroplane or gliders (other than hanggliders
or power-assisted sailplane).

I am much more sure of my ground now than I was then! :}

[VH-XXX]

❍ 100 general (A)


Isn't this 100 general part referring to 100 hours in GROUP A 3-Axis aircraft including ultralight?


It's all too hard. There are people out there with CPL's that should have them revoked if this is correct.

It would be great if you could call or email the regulator and ask but they won't put their butt on the line to give an answer these days. I'm still waiting to hear if you can legally learn to fly in an experimental aircraft including ab-initio EVEN THOUGH in the regs it clearly says that you can :ugh:

[Horatio Leafblower]

XXX

CAR 5.84 (2), referring to the PPL, states:

The 40 hours must be recognised flight time that was flown in a registered aeroplane, recognised aeroplane, helicopter, gyroplane, glider, power-assisted sailplane or Group A ultralight.

CAR 5.111 (2), referring to the 150 hour course ("Commercially trained persons"), states:

(2) For the purposes of subregulation (1), the 150 hours must be flown in a registered aeroplane and must include:
(a) 70 hours flight time as Pilot in Command... (etc)
ie: VH registered only.

CAR 5.115(1) states:

For the purposes of subparagraph 5.104(1)(f)(ii), the aeronautical experience ... must consist of:
(a) at least 100 hours as pilot in command; and
(b) at least 100 hours of flight time in a registered aeroplane, or a recognised aeroplane; and
(c) (XC time); and
(d) (IF time)

If you comply with 5.115(1) in less than 200 hours, you must then make up the hours according to 5.115(3) and 5.115(4) in;


(a) a registered aeroplane;
(b) a recognised aeroplane;
(c) a helicopter;
(d) a gyroplane;
(e) a glider (other than a hang glider).

Firstly, note that where CAR 5.84 specifically includes "Group A Ultralights" as an option for the PPL, CAR 5.115 (for the CPL) does not.

Secondly, 5.115(3) tells us that if we start our training in VH- and satisfy the requirements of (1) in less than 200 hours TT, we must finish the 200 hours in VH- (or otherwise, as per (4), above).

Are you telling me that we can circumvent that by starting in RAAus, then finishing in VH? :confused:

Such a reading would be inconsistent to say the least and contrary to the basic principles of legislative interpretation. :=

[VH-XXX]

For the purposes of subparagraph 5.104(1)(f)(ii), the aeronautical experience ... must consist of:
(a) at least 100 hours as pilot in command; and
(b) at least 100 hours of flight time in a registered aeroplane, or a recognised aeroplane; and
(c) (XC time); and
(d) (IF time)

Ok, well how about this?

The paragraph above clearly says:

(a) at least 100 hours as pilot in command; and
(b) at least 100 hours of flight time in a registered aeroplane, or a recognised aeroplane

Where does it say that 100 hours as PIC must be in a Registered aeroplane?

It doesn't.

This could mean:

100 hours PIC in a Group A Ultralight or Czech registered Crop-Duster
and
100 hours in a registered aeroplane.

Nowhere does it say:

100 hours as PIC in a registered aeroplane
and
100 hours in a registered aeroplane

and again...

This is where the ambiguity comes in: subregulation 5.115 (4) stipulates that additional flight time to make up the total 200 hours must be flown in:
(a) a registered (VH-) aeroplane;
(b) a recognised (mil) aeroplane;
(c) a Helicopter;
(d) a gyroplane; or
(e) a glider (other than a hang glider).


This paragraph talks about MAKING UP the remaining time in VH or recognised, it doesn't stipulate that the first 100 must be in such an aircraft.


Over to you......

[Horatio Leafblower]

XXX - Exactly - making up the hours you must use GA aircraft, Helos, Gyros, Gliders. NOT RAAus.

As I said Above:

Are you telling me that we can circumvent that by starting in RAAus, then finishing in VH?

Such a reading would be inconsistent to say the least and contrary to the basic principles of legislative interpretation.

:ugh:

If it was the intention of the legislature that you could use Group A Ultralights to log time towards a CPL, they would have stated so - as they did for the PPL.

Back to you :=

[VH-XXX]

It would appear from your statement that you agree with me.

XXX - Exactly - making up the hours you must use GA aircraft, Helos, Gyros, Gliders. NOT RAAus.

So 100 hours in essentially "anything" as PIC and the remainder in a GA aircraft.

Pretty simple stuff when you look at it like that.

If it was the intention of the legislature that you could use Group A Ultralights to log time towards a CPL, they would have stated so - as they did for the PPL.

That is an assumption and you can't go making assumptions here when we are talking about financial implications for other members of PPRune.

[Horatio Leafblower]

Sorry XXX, read it again.

How could what you propose be logically consistent? :uhoh:

The CAR requires you to amass the requisite experience for a CPL(AEROPLANE), including 100 hours in a registered AEROPLANE or a recognised AEROPLANE.

ie: You cannot do 190 hours in a recognised HELICOPTER or a registered GLIDER, top it up with 10 hours in a C182 and get your CPL(A).

There must be at least 100 hours of experience in a powered, heavier-than-air, fixed-wing, REAL aeroplane. The rest can be any of the things listed in (4).

If it was the intention of the legislature that you could use Group A Ultralights to log time towards a CPL, they would have stated so - as they did for the PPL.
That is an assumption and you can't go making assumptions here when we are talking about financial implications for other members of PPRuNe.

Bugger me I had better ask for the money back on my Dip Law. It ain't an assumption and I invite you to refer to the Acts Interpretation Act (1901), or refer to any number of excellent basic law texts. In particular I recommend Cook et al, Laying Down the Law 5th Ed, Ch 9.

Get it?
Got it?
Good!

Now that I have that sorted, where's that bottle of Red? :ok:

[Ultralights]

http://photos-h.ak.fbcdn.net/hphotos-ak-ash1/hs466.ash1/25589_10150121200995394_177259915393_11529762_4287814_n.jpg

[OZBUSDRIVER]

HTB...you say(b) a recognised (mil) aeroplane;


Whilst the quote from XXXFor the purposes of subparagraph 5.104(1)(f)(ii), the aeronautical experience ... must consist of:
(a) at least 100 hours as pilot in command; and
(b) at least 100 hours of flight time in a registered aeroplane, or a recognised aeroplane; and
(c) (XC time); and
(d) (IF time)

Which is as I have found written here Flight Crew Licencing Procedures (http://www.casa.gov.au/wcmswr/_assets/main/manuals/regulate/fcl/010r0301.pdf)

HTB:=, you misconstrue "recognised military experience" (your inference to experience in (b)) to mean recognised (mil) aircraft which is not the case. A class A ultralight is a recognised aircraft. Methinks your interpretation will lead people astray. 100hrs recognised plus 100hrs VH is the go.

AND, the advice I give my son...get RAA up to area endorsment...do all the CASA BAK and PPL subjects, recognised by RAA...then convert to VH and use both licences as you see fit. VH for aerobat and airspace issues and RAA to keep flying if you are dumb enough not to renew your medical in time. He wants to go LAME so will be very handy for him to have a certificate in both camps. If he goes on to CPL(A) then the issue is 100hrs of the RAA will go toward half his experience minimum as compared to a sausage factory licence.(EDIT- I do not trust the product from these schools...I have YET to see a good grade3..to what I consider a good standard... come out of such a school)

Face value..you should save at least a third of your costs compared to 100%CASA licence training. You still have to watch your schools like a hawk to ensure you are not being dudded with extra hours of training, regardless of RAA or GA.

[Horatio Leafblower]

Ozbusdriver,

HTB, you misconstrue "recognised military experience" (your inference to experience in (b)) to mean recognised (mil) aircraft which is not the case. A class A ultralight is a recognised aircraft.

I beg to differ.

CAR 5.115 (dealing with the experience required for a CPL (Aeroplanes) does not mention "recognised military experience" - it refers to a registered aeroplane or a recognised aeroplane.

A registered aeroplane is simple enough.

CAR 2 defines a recognised aeroplane as:

"recognised aeroplane" means an aeroplane:
(a) that is on the register of aircraft kept by a Contracting State; or
(b) that is operated by the Defence Force of Australia or of a Contracting State.

How would an RAAus aircraft fit into that definition? :confused:

You will find the quote from XXX is in fact a quote from my earlier post (#7 of this thread) :=

Sorry old bean - you can't just cast an eye over it and give it whatever spin you like. Read it again, and read my posts again.

[VH-XXX]

Here you go:

http://www.icao.int/fsix/AuditReps/initial/australia_1999_en.pdf

ICAO SUMMARY REPORT AUDIT OF THE CIVIL AVIATION SAFETY AUTHORITY OF AUSTRALIA. (these guys sound credible enough for this discussion)

STATUS OF DIFFERENCES TO ICAO STANDARDS
(ANNEX 1 — PERSONNEL LICENSING)
Note: This list incorporates differences previously notified by Australia. (**) Indicates a difference which should be endorsed on the licence in application of Article 39 of the Chicago Convention on International Civil Aviation.

2.3.1.3.2 (**) CAR5.84 There is no requirement that the flight experience for the PPL-A licence be
gained on an aeroplane.
2.4.1.3.1.1 (**)
CAR 5.115 The command time requirement for the CPL licence may be gained on an aircraft category other than aeroplane.

There you have it. Under ICAO it must be a registered / recognised aircraft and under CASA rules, it doesn't.


I rest my case your honour / worship / magesty, however I may wish to cross-examine if any further evidence is presented.

[VH-XXX]

PS OZBusDriver, what you are proposing for your son is a very sensible route, as in LAME's with RA-Aus and PPL are worth their weight in gold to a maintenance organisation and I think make much better mechanics than those without a licence. I get fed up of these guys that will fix aircraft but refuse to fly in them.

[OZBUSDRIVER]

HTB (a) that is on the register of aircraft kept by a Contracting State

Even by inference, a register held by the RAA is a register held by the CASA.

[OZBUSDRIVER]

and by definition=

responsible organisation means:
(a) the responsible authority of a Contracting State; or
Federal Register of Legislative Instruments F2009C00991
Part 1 Preliminary
Regulation 2
36 Civil Aviation Regulations 1988
(b) the Defence Force of Australia, or of a Contracting State;
or
(c) a sport aviation body.

[Horatio Leafblower]

Gents,

"Inference" doesn't cut it. :ugh:

ICAO SUMMARY REPORT AUDIT OF THE CIVIL AVIATION SAFETY AUTHORITY OF AUSTRALIA. - This isn't legislation, it's an Auditor's report. Get me a copy of ICAO FLS Annex 1 and we'll discuss ICAO requirements, but until you have that document you cannot credibly define any of the terminology used in that report.

BACK TO THE AUSTRALIAN LAW THEN! :D

"Aircraft" is defined at CAR 5.64 thus:

"aircraft" means a registered aircraft that is:
(a) an aeroplane; or
(b) a helicopter; or
(c) a gyroplane; or
(d) an airship.

Each of those headings (a) through (d) is an aircraft category. Hence, we have the categories of licence: CPL(A), CPL(H), CPL(G) and CPL (airship).

That Australia allows a CPL to be issued on the basis of flight time from another CATEGORY is clear, and is the source of your confusion. CAR 5.115(4) refers.

An "Ultralight aircraft" is not a different category of aircraft; it is an aeroplane the same as a Cessna C152, which is why you are explicity permitted to count ultralight time towards a PPL(A).

If CAR 5.86 specifically names Group A Ultralights as being acceptable for accruing flight time for a PPL(A), why does CAR 5.115(4) list everything except ultralights?

Over to you guys - I can talk Av Law all night :E

[Arnold E]

gtboss16 what you have here is some people that have a reason to tell you what they are telling you. They have a commercial interest in what they are saying. I would normally say, take care in what you take on board, but in this case I would say ignore all of what you see here:p

[Horatio Leafblower]

Arnold - as a CASA school AND a RAAus school I have a commercial interest - but which way? :confused:

[Horatio Leafblower]

Oh that's a good one! :D

Are you telling me that because RAAus is a "Responsible organisation", the aeroplanes it administers are registered to a "Contracting State"? :eek:

To pinch your quote: CAR 2 defines "responsible organisation" as
responsible organisation means:

(a) the responsible authority of a Contracting State; or
(b) the Defence Force of Australia, or of a Contracting State;
or
(c) a sport aviation body.

Yes RAAus is a "responsible organisation", but that phrase is not used at all in Part 5 of the CARs, which deals with personnel licencing. The fact that an aircraft is registered with the RAAus in fact removes it from the argument.

How so?

The purpose of the Ultralight movement, and its very legal existence, come from the EXEMPTIONS it operates under. These exemptions are grounded in CAO 95.55.

Para 3 of 95.55 specifically lists those provisions of the CARs from which Ultralights are exempted:
3 Exemption under regulation 308
3.1 If the conditions set out in this section are complied with in relation to an
aeroplane to which this section applies, the aeroplane is exempt from
compliance with the following provisions of the Regulations:
(a) Parts 3, 4A, 4B, 4C, 4D and 5;
(b) regulations 36A and 37;
(c) subregulations 83 (1) (2) and (3) in respect of VHF equipment;
(d) regulations 133, 139, 155 and 157;
(e) regulations 207 and 208;
(f) regulation 210 insofar as advertising of flying training to qualify for a
pilot standard specified in the RAA Operations Manual is concerned;
(g) regulation 230;
(h) subregulation 242 (2);
(i) regulations 252 and 252A.

The exemption against Part 3 is the exemption against registration with CASA. If it is exempted against registration with CASA, how can it be on the CASA register as you assert at your post #17?

Sorry OZBUS it just doesn't wash. An RAAus aircraft, be it 10- or 32- or 25- or 55- registered, is not on the CASA register and therefore is not on the register held by the Responsible Authority of a contracting state (not to be confused with an Australian responsible organisation such as RAAus), and is therefore not a registered aircraft.

An RAAus aircraft is not registered to the ADF or to the defence forces of an ICAO-contracting state, therefore it cannot be a recognised aeroplane.

VH-XXX in your post #15 you assert:
There you have it. Under ICAO it must be a registered / recognised aircraft and under CASA rules, it doesn't.

This is incorrect. CAR 5.111 (150 Hour CPLs) specifically states that it MUST be a "registered or recognised AEROPLANE";

and CAR 5.115 paras (1)-(4) permits that it may be a recognised or registered AEROPLANE, or a GLIDER, or a HELICOPTER, or a GYROCOPTER.

...but not an Ultralight, or a Group A Ultralight, because while the other classes (Glider, helo, gyro, recognised/registered aeroplane) are specifically allowed, Ultralights are NOT.

The legal principle is expressio unius est exclusio alterius, meaning that the explicit inclusion of one thing means the implicit exclusion of those things not listed.

The PPL provisions at 5.84 specifically and deliberately list "Group A Ultralights". The CPL provisions at 5.115(4) specifically and deliberately do not.

VH-XXX and OZBUSDRIVER I have previously laboured under the same misapprehension as you good sirs; my study and preparation for testing officer approval has changed my opinion on this matter. Please re-read what I have offered and if you doubt it please call me or call CASA.

Cheers! :ok:

[Arnold E]

I believe that I only said that people here have a commercial interest, and so therefore may not be without predudice, so beware:=

[sprocket check]

gtboss:

Unfortunately it is up to each of us to read the regs. Some have different interpretations than others. Call CASA if you are still doubtful after HLs excellent references and explanations. It might well save you a heartache later.

The only way you could get your CPL hours by flying an ultralight is by doing it in another country that does not have the exemptions, such as Czech Republic where a SportStar is on the civil register as they do not have a RAA type organisation and it is a Contracting State. Or maybe South Africa, etc etc.

Arnold E:
To advise someone to ignore the law, especially when their future may well depend on it, is very irresponsible. There is definitely some crap on PPRUNE but there is also gold.

Judge for yourself.

[VH-XXX]

I formally declare that I have no (zero) commercial interests in aviation unlike other parties in this discussion and contrary to what Mr Arnold may think.

I am all for reducing the cost of aviation in Australia as long as it is safe and falls within the legalities of the governing bodies.

If anything a precedent has been set with RA-Aus hours having been counted towards and accepted for the issue by CASA of a CPL to the extent of flying schools offering flight time in both aircraft towards obtaining a CPL.

It would be be beneficial to everyone if one of us were to contact the relative authorities to attempt to gain a satisfactory and legal understanding of this. Perhaps if I am "biased" then I should not be the one to do this.

Any volunteers?

[Horatio Leafblower]

It would be be beneficial to everyone if one of us were to contact the relative authorities

I have called the Registrar of Births, Deaths and Marriages (the relative authority in NSW) but they are closed on a Saturday :}.

I have Emailed an officer from the CASA Flight Testing and Training Office - the relevant authority - and will post the reply if and when received.

[Arnold E]

To advise someone to ignore the law,
Where did I do that????

[sprocket check]

[QUOTE] but in this case I would say ignore all of what you see here/QUOTE]

sorry Arnold, it seemed to me this very general comment did exactly that seeing as regulations were quoted directly. I apologise if I misread.

[gtboss16]

i havent read above yet... but cant you fly 100 hrs RA?

[onemore]

Not surprised there are differing interpretations because I bet when the founders of RAA got together with CASA to reduce the regs and introduce a RECREATIONAL flying category they never imagined that a few years later a bunch of people would try to remove the RECREATION component and set up commercial operations under a RECREATIONAL tag

Never been able to understand the little bits like: Do the GA CASA tests while you get your RECREATION licence. For example when you do your RECREATION licence theory tests shouldn't your answer to Pilot Maintenance refers to the RAA regs and not CASA. So how is that catered for by doing the GA exams.

As for the RA debates about whether or not they should carry radios and other technology, well its about time the term RECREATION was reintroduced. Its about flying from non towered on radio airfields, below 5000ft and staying outside Class A, B, C, D, E airspace. Having fun in cheaper, lighter sportier aircraft without the rules.

RECREATION flying schools should teach pilots how to be part of the RECREATION flying environment

The real problem is that a lot of GA schools will fold because they cant compete with the RECREATIONAL low start up costs - so what happens when all these RAA students go to continue on to CPLs and further when there are not the schools to teach it. The Industry should put some investment back in to the GA schools and help them financially to keep the breeding ground going, and RECREATION should get back to its roots

Off my soapbox now :)
Yes I do hold GA and RAA tickets, but I am so over the dumb path RECREATION is dragging itself down

[Sunfish]

Horatio Leafblower, please check PM's.

[VH-XXX]

Don't forget that CASA never introduced the proposed "Recreational Licence" that we all spoke of a few years ago. We are referring to an organisation that is responsible for administering Ultralights that just happened to change their name to "Recreational Aviation Australia" to release from the stigma associated with "ultralights" and their perceived safety or lack thereof.

Nothing has changed in terms of the rules and regs regarding ultralights of late, buy we are seeing many individuals attempting to grey the lines between the two disciplines for their own benefits that are not interested in persuing the GA avenue. It will be interesting to see what RAA does next to respond he the cries of the members that want more for less. I sit in both camps but clearly know the boundaries of each (subject to the outcome of this thread).

[OZBUSDRIVER]

Ouch..this is heading for a Kick RAA thread.

I cannot find the words in text. RAA ADMINISTERS recreational aviation for the CASA. RAA do not make the rules nor police them..The rules are all set by the CASA. The contracting state is Australia, the instrument of that contracting state is the REGS, CARS and CASRs The CASA enforces the instrument. RAA administers a part of avaition environment as does the GFA and the Warbirds and the like for the CASA. The rules by which RAA GFA and Warbirds all fly by are set by the CASA not each individual administration.

It all seems to be based upon "Informed Consent"

As for the hours issue in the CARs..I would suggest that AUF/RAA is a child too new to be fully written in to the CARS hence the exemption in CAO95.

As hours are recognised for flying gyrocopters and gliders..why not RAA aircraft. Reality is that a group A ultralight is every bit an aeroplane to fly as a Cessna..even harder to fly because of its design..inertia being the biggest catch out....The experience of flying a C152 or a Jab230 is still no comaprison to what is required to manage the systems of more complex aircraft other than you pull on the stick you go up, pull further and you will eventually go down again.

If there is an ambiguity in the Regs then the Regs need looking at...and that is the CASAs job...it just may take another hundred years before they get off their collective buns and actually do something about the regulation re-write.

[Horatio Leafblower]

As for the hours issue in the CARs..I would suggest that AUF/RAA is a child too new to be fully written in to the CARS hence the exemption in CAO95.


Nah, sorry - doesn't hold water. CAO 95.25 was drafted in the late 1980s I think and was replaced by CAO 95.55 in the mid 1990s or so - before I started flying AUF, anyway.

CAR 5.86 specifically nominates Group A Ultralights.
CAR 5.115(4) specifically does not.

CAR 2 defines a Group A Ultralight:
"group A ultralight" means an aircraft that is classified by Recreational Aviation Australia Inc. as a group A ultralight. ...and even mentions RAAus by name (not even "AUF").



As hours are recognised for flying gyrocopters and gliders..why not RAA aircraft.
That one I cannot tell you without speculation :uhoh:
However, if you will permit:
1/. Gliders ARE registered aircraft on the VH- register
2/. Gyroplanes are also able to be VH-registered and you are able to hold a CPL(Gyroplane).

As onemore said,
RECREATION flying schools should teach pilots how to be part of the RECREATION flying environment
The idea of having CAO 95.X exemptions for recreational flying is that it allows you to OPT OUT of the rigour and administrative control of the ICAO-compliant regulatory scheme of the national aviation authority.

If you read CAO 95.55 it allows Ultralight aircraft to opt out of nearly half the CARs: Part 3 (Registration, now in the CASRs), Part 4 (Maintenance) and Part 5 (Licencing).

Those controls and regulations are there to ensure a minimum standard and are policed by CASA. CASA inspectors conduct ramp checks, do flight tests, audit operators, approve syllabi, inspect aircraft, the list goes on.

Many RAAus schools operate to GA standards and procedures and I am certain that there are many RAAus schools which maintain a higher standard than some GA GA schools.

But the point is, the GA schools are overseen and controlled by CASA and so CASA can vouch that the school meets the minimum applicable standard for an ICAO-compliant flying school.

RAAUs schools are not directly overseen by CASA. CASA does not approve the school's syllabus or student administration systems, they do not set the examinations or administer the examination system. Yes, RAAus inspectors do all those things for RAAus schools ... but that's the point, they aren't CASA inspectors and they don't hold CASA delegations. They aren't CASA.

Reality is that a group A ultralight is every bit an aeroplane to fly as a Cessna.

Yeah well... that's an argument for another thread :oh:

Ouch..this is heading for a Kick RAA thread.

Doesn't need to be, but there are differences between real licenced flying and RAAus flying. Those differences have very little to do with physics or aerodynamics and a lot to do with administration, operational control, international public law and politics.

I cannot find the words in text.
With all due respect, my friend, I suspect the words you are looking for are not there :(

I did an Aviation degree in the early 1990s and got a Distinction in Aviation Law (the only one in my undergraduate career. Ienjoyed it and was good at it). 5 years later as a Chief Pilot I found that I was regularly disagreeing with the local CASA guys over interpretation of the CAOs and Regs. They were all good pilots and experienced pilots but not lawyers and sometimes laboured under misapprehensions or perpetuated myths. Occasionally I suspect they made it up on the spot based on what seemed reasonable :hmm:

I started studying law so that I could win those arguments. These days if I disagree with the local blokes (very rare) I explain my interpretation clearly and CC it to CASA legal dept. I dunno if they ever get it or read it but I usually win the argument! :}

[onemore]

Ouch..this is heading for a Kick RAA thread.

I hope my reply doesn't lead it that way that really wasn't my intent. Also dont have a real view on whether hours should count or not, because at the end of the day a person will still be required to pass the same exams and flight test.

Call me old fashioned but I love the RA-Aus mission statement and I just want it to remain :)
To foster, encourage and develop safe Recreational Aviation in Australia with minimum bureaucracy and minimum cost.

Which to me means that I dont like the move towards setting up schools and advertising it as a "cheap path to a CPL", it will just lead to big sausage factories requiring more association oversight

[maverick22]

Wow, this old chestnut again.

I was formerly of the belief that the RAAus hours could be counted towards the CPL, as this was my interpretation of the regs and I worked for a school which was of the same opinion. However, you raise some very valid points Mr Leafblower.

I look forward to reading your response from CASA on the issue

[OZBUSDRIVER]

HL, I would demur to your opinion.

Would be interesting to see what the CASA has to say to clarify this situation. In fact, it may well direct my son's efforts toward the more expensive GA route.

[OZBUSDRIVER]

Just to add...my opinion of the CAO95 exemption was to allow the legitimacy of ultralight aviation. The CASA led the world on this regard. There is a lot more history to how this came about. "Opting Out" would be reserved for those of VH registered machines reverting to RAA reg.

[seavenom]

HLB may not like it but there are schools all over oz training to CPL with a big chunk of the time on RAA. 5 minutes on the web will confirm this... then I suggest a couple of phone calls tomorrow to the schools.:O

[VH-XXX]

Maybe don't make the call tomorrow, we will need to wait 8 weeks for CASA to reply to HL's correspondence.

[Horatio Leafblower]

What I think is right/wrong is niether here nor there. I have argued it as I read it, but no doubt CASA has their own view on the matter and that is the one that counts.

It would possibly bring students if I could do their first 100 hours (or credit them) in an Ultralight, but I cannot do it in good conscience.
If those other schools can get away with it, there must be a CASA delegate willing to bet his house on it.

...I just promise you it just won't be me! :uhoh:

On the other hand, I have had RAAus students convert to GA and go to Bankstown to hire an aircraft. Even if they have a PPL (from an afilliated school no less :hmm: ) they were told "oh well that'll be at least a 5-hour check flight process, 'cos you're ultralight trained"

THAT is prejudice :suspect:

[Horatio Leafblower]

..from a District Flight Operations Manager (DFOM) and one of his helpers at about 1630 today.

His office had taken a couple of days to read and digest my email and consider a response.

Their response is that my interpretation (as outlined at length though this thread) is correct, and they then went into some detail as to why they believed that to be the case.

The CASA position is that RAAus hours CANNOT be counted towards a CPL, be it a "150 hour" CPL or a "200 hour" CPL. You must gain all of the required 200 hours on the classes of aircraft described at CAR 5.115(4) For example, if a person gained their PPL entirely on the basis of 40 hours RAAus time, then they will need to have minimum 240 hours of logged experience come time for their CPL flight test.

In my Email I also asked if CASA had some other guidance or policy document that clarified the situation. The response I received was that CASA had produced the CARs, and if a lowly dunderhead such as Horatio Leafblower could interpret it correctly then no further clarification would be needed. :hmm:

We then had a longish philosophical discussion and it was made clear to me that the following should be disseminated to industry:

1/. There is currently a CPL holder and an ATO under investigation because a CPL was issued on the basis of 200 hours flight time, including (n) RAAus hours. :uhoh:

2/. Flight schools, ATOs and flying instructors MUST read and understand the requirements of CAR 5.115 :=

3/. Be aware that CPLs issued on a 200 hour total which includes RAAus time may be cancelled, varied or have other limitations, requirements or restrictions placed upon them. :ooh:

I post this in good faith as an honest representation of the conversation I had this afternoon with a CASA inspector of some 15 years experience.
I understand this is bad tidings for some, and for that I am sorry.

Avast, and belay there!

Horatio

[maverick22]

Well kids I guess that clears that one up then! I must say I have found the CASA flight crew licensing department to be quite good as of late as I have had several queries of my own regarding the regs and they have been quite prompt in ringing me back and also putting it in writing as well. Times must be changing.

With regard to the original post, from my own experience instructing both RAAus and GA, as much as I like to wave the RAAus flag I would say that if you are going down the commercial/airline path then you are wasting your time with RAAus flying. Not only has Horatio outlined this with regard to the aeronautical experience requirements for the CPL, but also at the end of the day GA time is always looks better than ultralight time in your logbook through the eyes of an airline. Sure, you can count up to 750 hrs of group A ultralight time towards your ATPL, but that's still no good to you if the airline you will potentially work for does not recognise that ultralight time to meet their own requirements.

Get your RAAus licence down the track so you can have some fun on the weekends, but otherwise stick to GA. Take it from someone who has been there and done that:ok:

[superdimona]

Fair enough. Makes you wonder though, why they consider Glider time A-OK but not something like a Tecnam or Jabiru - at least those have engines!

[j3pipercub]

Please don't refer to Jabiru or Jet-ski motors as 'engines' :}

[VH-XXX]

CAREFUL PLEASE, my Kawasaki jet-ski engine is far more reliable than a Jabiru engine! At-least with the jet-ski you have to dunk it in salt water before it needs a rebuild rather than simply just using it.

[Tankengine]

Gliders are VH registered.:ok:
The reason why this is so and why RAA time is not enough is a different issue.:hmm:

[Horatio Leafblower]

I have just had a call from RAAus and been provided with a letter from the CASA head of personnel licencing, Dick Reynoldson.

That letter states that RAAus command time may be used to satisfy the 100 hours command time requirement of CAR 5.115 (1). :uhoh:

While I know I am correct, :} it pains me to say it appears CASA have a different interpretation of the law :ouch: I have had a couple of mates who are working lawyers (one barrister one a solicitor) examine the relevant parts and they seem to agree with me. :confused:

Further opinions expected in due course. :ugh:

[VH-XXX]

Is that letter a recent one as I have seen something similar before which is why I was so adament from the start, however without knowing where it was or where it came from I wasn't able to provide a reference?

Those kind of letters pop up quite often in CASA. For example, one that I can think of was a one-off letter from the head of CASA saying "for night registered experimental VH registered aircraft based solely in Australia, a red all-round beacon is not required for NVFR operations provided that strobe light(s) are fitted."

Perhaps the CASA officer that claims that a CPL holder is under investigation need to be told about this letter... sooner rather than later :)

[Jabawocky]

I have a feeling Horatio is on the right track, but here again its ask three people at CASA, get three answers and pick the one you like best.:rolleyes:

They even refer to it as shopping around your question........:ooh:

If you have to employ a lawyer to decode this stuff.....its WRONG to begin with, and it should be fixed!!! Because even then you can get two lawyers who see it from two different angles.....and if it went to court.....toss a coin!:eek:

I am sure Leafie would like to say its not really that way......but I am confident he knows it is!

A re-write of the rule book is in order, apparently that was started 20 years ago :ugh:

Jaba is going to :oh: it for a bit now before I get carted off to the dock!

[Horatio Leafblower]

XXX

The CASA dude actually changed his position on reading the letter, which was addressed to Paul Middleton and dated 2002.

Jaba

If there is more than one interpretation of something as basic as the quantity and type of hours acceptable as experience for a CPL, then yes the Regs are not clear.

From what I have seen of the CASRs, 'clarity' does not seem to be a key design objective :hmm:

[Jabawocky]

CAR's, CAO's CASR's.........apart from the letter 'C' they all have something in common, you summed it up......"clarity" :(

[onemore]

Although the Recognised aeroplane requirements seem open to debate, I think the definition from the CARs Part 1 2: Interpretation is fairly clear that RAA hours on group A ultralight should be acceptable


recognised flight time means flight time that is:

(e) in the case of flight time in a group A ultralight:
(i) flown by the holder of a pilot certificate, either before or after the certificate was issued to the holder, being a pilot certificate, other than a student certificate, issued by Recreational Aviation Australia Inc.; and

(ii) recorded in the holder’s logbook and certified by a member of Recreational Aviation Australia Inc. who is authorised by that body to certify flight time.

[Horatio Leafblower]

No, recognised flight time and recognised aeroplane are 2 seperate things.

Recognised flight time is as you state.

Recognised aeroplane is an aeroplane of the Australian Defence Force or an aeroplane registered in a foreign (ICAO-)contracting state

[Jabawocky]

So a suitably equipped Tecnam or Jabiru....or Cessna Skycather on the VH register is all OK I assume it to mean.

[LeadSled]

From what I have seen of the CASRs, 'clarity' does not seem to be a key design objective

Folks,
A direct quote from a well known former Head of Office of Legal Counsel at CASA, and I can swear a Stat. Dec. as to the statement

Aviation regulations are for lawyers and judges, for the safe conviction of pilots and engineers.

So there you have it, the reason for the Act, Regulations and Orders, nothing about clarity, or, for that matter, air safety ---- In my opinion an attitude still alive and well in CASA.

In the "you ain't seen nuttin' yet" stakes, the new Part 91, General Operating and Flight Rules is a doozy, combined with the signaled cancellation of the VFG (again, this organisation never learns) it will be hell for student pilots --- not to mention their instructors etc.

Tootle pip!!

[LeadSled]

Folks,
Have a look in the Act at the definition of an aircraft:

Australian aircraft means:
(a) aircraft registered in Australia; and
(b) aircraft in Australian territory, other than foreign registered
aircraft and state aircraft.

(b) is significant in this debate, an RAA aircraft is an Australian aircraft.

Once again, the rules are contradictory, with "consequential amendments" that have never been made. All part of the regulatory mess.

Tootle pip!!

[Frank Arouet]

Rules contradictory;

No actually.

A nice bottle of red would have us at each others throats over that statement Clinton. If you don't remember the Alamo, you will certainly recall the Maule.:(

[Horatio Leafblower]

I think it is appropriate, at this point, to repeat the clauses which are subject to debate.

Hours required for a 200-hour CPL:

CIVIL AVIATION REGULATIONS 1988 - REG 5.115
Aeronautical experience for subparagraph 5.104 (1) (f) (ii): persons other than helicopter pilots
(1) For the purposes of subparagraph 5.104 (1) (f) (ii), the aeronautical experience of a person who is not covered by regulation 5.113 or 5.114 must consist of:
(a) at least 100 hours as pilot in command; and
(b) at least 100 hours of flight time in a registered aeroplane, or a recognised aeroplane; and
(c) at least 20 hours of cross‑country flight time as pilot in command of a registered aeroplane, or a recognised aeroplane; and
(d) at least 10 hours of instrument flight time in a registered aeroplane, or a recognised aeroplane.

(2) For the purposes of subregulation (1), the same flight time may be counted towards as many of paragraphs (1) (a), (b), (c) and (d) as describe the flight time.

(3) If a person complies with subregulation (1) by flying a total flight time of less than 200 hours, the person's aeronautical experience for the purposes of subparagraph 5.104 (1) (f) (ii) must include a period of additional flight time equal to the difference between 200 hours and that total flight time.

(4) In this regulation:
"additional flight time" means recognised flight time as a pilot of any 1 or more of the following:
(a) a registered aeroplane;
(b) a recognised aeroplane;
(c) a helicopter;
(d) a gyroplane;
(e) a glider (other than a hang glider).

CAR 5.84 Private pilot (aeroplane) licence: aeronautical experience required
(1) For the purposes of paragraph 5.77 (1) (f), a person's aeronautical experience must consist of at least 40 hours of flight time as a pilot, being flight time that includes:
(a) at least 5 hours of general flight time as pilot in command; and
(b) at least 5 hours of cross‑country flight time as pilot in command; and
(c) at least 2 hours of instrument flight time.
(2) The 40 hours must be recognised flight time that was flown in a registered aeroplane, recognised aeroplane, helicopter, gyroplane, glider, power‑assisted sailplane or group A ultralight.

Compare para (2) of the PPL experience required to para (4) of the CPL flight time required.

Note also the requirements for "flight time as pilot in command", for both PPL and CPL, is totally general in nature.

The natural reading of 5.84 would tell you that you can fly your solo time in any of the aircraft categories listed in (2).
A natural reading then of 5.115 would be the same; command time required would be in any of the aircraft categories listed in (4).
------------------------------------------------

Relevant definitions from CAR 2:
"aeroplane" means a power-driven heavier-than-air aircraft deriving its lift in flight chiefly from aerodynamic reactions on surfaces remaining fixed under given conditions of flight, but does not include a power-assisted sailplane.

"recognised aeroplane" means an aeroplane:
(a) that is on the register of aircraft kept by a Contracting State; or
(b) that is operated by the Defence Force of Australia or of a Contracting State.

"recognised flight time" means flight time that is:
(a) in the case of flight time in a registered aeroplane, or a recognised aeroplane -- flown by the holder of:
(i) an aeroplane pilot licence; or
(ii) a student pilot licence; or
(iii) an overseas pilot licence that authorises the holder to fly aeroplanes; or
(iv) a pilot qualification issued by the Defence Force of Australia, or of a Contracting State, that authorises the holder to fly aeroplanes as pilot in command or in dual flying; or
(b) in the case of flight time in a helicopter -(snip); or
(c) in the case of flight time in a gyroplane -(snip); or
(d) in the case of flight time in a glider, or power‑assisted sailplane - (snip)
(e) in the case of flight time in a group A ultralight;
(i) flown by the holder of a pilot certificate, either before or after the certificate was issued to the holder, being a pilot certificate, other than a student certificate, issued by Recreational Aviation Australia Inc.; and
(ii) recorded in the holder's logbook and certified by a member of Recreational Aviation Australia Inc. who is authorised by that body to certify flight time.


...and from CAR 5.64:

CIVIL AVIATION REGULATIONS 1988 - REG 5.64
Interpretation
In this Division:
"aircraft" means a registered aircraft that is:
(a) an aeroplane; or
(b) a helicopter; or
(c) a gyroplane; or
(d) an airship.

The RAAus have made much of the fact that Group A ultralights are mentioned as "recognised flight time" in CAR 2 definition. The fact remains that:
(1) the phrase "recognised flight time" is not used in either CAR 5.84 (PPLs) or CAR 5.115 (200-hour CPLs); and
(2) Reg 5.64 (above) specifically states that an aircraft for the purposes of ALL of Division 5 is a REGISTERED AIRCRAFT; and
(3) Group A Ultralights are specifically allowed under CAR 5.84, but are not mentioned as allowable in in any way under CAR 5.115

What we are all REALLY wondering about is:
how do CASA define a registered aircraft?
While discussing this with the RAAus Ops Manager this morning, the only matter we agreed upon was that this definition (once included in CAR 2) may be the crux of the argument.
WHY was it omitted? :=
(in the 1993 edition of the regs, available on the A-G's website, registered was defined as "registered in accordance with these regulations". With the move of CAR Div3 to CASR 47, this def was no longer relevant to the CARs and omitted).

THIS THEN IS MY CONTENTION:
The intention in drafting CAR 5.115 (1) was to allow Helicopter pilots, Gyroplane pilots, Glider pilots, military pilots and foreign pilots to credit their command hours to the command requirements of 5.115(1)(a).

Sub-paras (1)(b), (1)(c) and (1)(d) then specify that certain experience must be in an aeroplane, as defined in 5.64 specifically as a registered/recognised aeroplane, as opposed to a registered/recognised Glider, registered/recognised Helo, or registered/recognised gyroplane.

ie: ya gotta fly a plank, and a registered or recognised powered plank at that, to get a CPL(A). Once you have the requisite experience you can make it up as per 5.115(4).... but NOT in an Ultralight.

Tonight I received a PM from a learned person not entirely removed from this question, and he (privately) backed my reading. Thank you :ok:

[VH-XXX]

I think the reality is that you are right, as the rules stand, it doesn't count.

Probably some years ago people started complaining about the hours not counting so CASA boss wrote a directive to allow it which was far easier than making a change to the regs. There are many examples out there of these "one off" exemptions.

[rgmgbg01]

Take anything before a court and it is a roll of the dice - HLB would know this too! (if the law was simple there would be no need for days of arguement about points of law - as apposed to just the facts of the case).

Lets get back to what is good for aviation.

Is 100 hours in a 3 axis RAAus aircraft just as useful as 100 hours in a glider or gyrocopter? - Yes

Does it have an effect on safety? - No

Will it lead to the end of aviation as we know it? - No

SO WHO CARES !!:rolleyes:

[LeadSled]

Clinton,
Perhaps you would like to remind us all why the definition of Australia aircraft in the Act was changed (10-12 years ago ??) to include (b).
Tootle pip!!

[sprocket check]

It seems like CASA had better make a definitive determination of this. Isn't the Attorney-General responsible/capable of determination?

[le Pingouin]

Take anything before a court and it is a roll of the dice - HLB would know this too! (if the law was simple there would be no need for days of arguement about points of law - as apposed to just the facts of the case).

Lets get back to what is good for aviation.
......
SO WHO CARES !!:rolleyes:Who cares? You bloody well should if you're taking this route. The good of aviation doesn't enter into it in a court of law, which is where it really matters if you've survived when the wheels fall off. If Horatio can cast doubt on the legality then so can some expensive silk. CASA's opinion isn't worth much when you're in court.

[VH-XXX]

The CASA executive can make any excemptions they want without changing the rules. Nobody said the definition of an aircraft changed years ago, however an excemption has been made which over-rides the regulations.

[Horatio Leafblower]

The CASA executive can make any exemptions they want without changing the rules. Nobody said the definition of an aircraft changed years ago, however an exemption has been made which over-rides the regulations.

Sorry XXX mate, not correct.

The letter floating about is an interpretation, not an exemption from anything.

RAAus aircraft operate under exemptions to the CARs published in CAO 95.55 (and others).

Exemptions are created by instrument and those instruments are published, eg: various airlines have had exemptions against carrying the normal compliment of Cabin crew.

A letter from a CASA officer giving an interpretation of the Regs (and I have received one or two myself) is not an exemption.

[SokPuppet]

I bet when the founders of RAA got together with CASA to reduce the regs and introduce a RECREATIONAL flying category they never imagined that a few years later a bunch of people would try to remove the RECREATION component and set up commercial operations under a RECREATIONAL tag

Pretty much sums it up and is a good fit to the regulations, I think. ;)

[Homesick-Angel]

Just to throw another spanner in the works..

I spoke to a CFI who's school caters for both RA and GA, and he has a written confirmation from casa stating that RA hours wont count for the 150 hour course but can for the 200??..

All i can say is what the??:ugh:

Seem that there are, as has already been stated, 3 or 4 differing answers...

[VH-XXX]

Sorry XXX mate, not correct.

The letter floating about is an interpretation, not an exemption from anything.


You would need to put up a copy of the letter to better explain.

If what you say is true and that it is an interpretation, then yes, shaky ground indeed.

[LeadSled]

Clinton,
With all due respect, I disagree.

That was the point at which "ultralights" became "Australian aircraft", and were counted for the first time in the Australian fleet, for purposes of ICAO reporting, because the "conventional" (ie:VH-) fleet had dropped below 10,000 aircraft.

This was the point at which an aircraft didn't have to be an Annex VIII aircraft to be included in the list of Australian aircraft.

The idea that command hours on a C-150/152 are of greater career value than in a modern Jabiru, based on the aircraft alone, is laughable.The latter is faster, has longer range, often better equipped, and is in no way a lesser "Australian aircraft" than a C-150/152.

I further suggest that much of the problem debated here is caused by the various dates that various legislation has been enacted, and the perennial problem of changes not catching "unexpected consequences".

I am further of the opinion that "letters of interpretation" or "CASA policy" have no standing, when contrary to the law as enacted. You know the form, better than I do, for making concessions/exemptions lawful by a legislative instrument.

This is something that should be put on a sound footing, sooner rather than later.The idea that a pilot could be stripped of a CPL, because of the lack of legal standing of of a CASA"letter" , is abhorrent.

Tootle pip!!

PS: Some models of Jabiru can be VH- registered, registered as an LSA, or just registered as an "ultralight" --- just to add a few more combinations and permutations --- but don't anybody hold their breath waiting for the RPL that was first proposed (in the modern era) in 1996.

[LeadSled]

Sokpuppet,

CASA and Recreational Aviation Australia did no such thing.

CASA has only been around since the mid-90's, when CAA was split up

Self administration has been around since not long after WWII, in the GFA case.

The advent of the Australian Ultralight Federation ( with a very recent name change to Recreational Aviation Australia) grew out of the "Darling Report", from memory in the early '80's, (long before "CASA") and it was suggested that SAAA take over administration of "ultralights". Indeed, it was more of an ultimatum, (CAA or whatever it was then refused any direct involvement), the Minister said that, if community (self) administration was not set up, the relevant aircraft would be grounded.

As always, there were many objectors to such a change, forecasting the end of civilization as we know it, bodies plummeting from the skies etc ---- all the usual stuff from the "the only acceptable change is no change" brigade. But Government policy it was (and has been ever since) and the Government prevailed over the naysayers, many of whom have not caught up, to this day.

The SAAA declined, so a breakaway group from SAAA set up the AUF, with just a handful of members. One of the founders,AUF pilot certificate holder No. 2, still lives in Bunderberg. He's not No.1, because he and the other main founder tossed for who got No.1.

Growth was steady but unspectacular until 1998, when it was decided that new CASR 21 Experimental Amateur Built aircraft that fell within the weight limit of AUF administration, (488 kg AUW, later increased to 544 kg) could be registered with/administered by the AUF. Not to be confused with 95.10, 95.55 etc. aircraft.

After this, expansion of the AUF was rapid, going from about 2500 members in 1996, to today's 10,000+, with the number of RAA aircraft outnumbering active VH- single engine aircraft.

The advent of the "Light Sport Aircraft" as a design/certification category gave a further boost to AUF, and, I assume, helped play an important part in the name change, as "AUF" were no longer about "ultralights", but a range of certification categories, and Recreational Aviation Australia became the new organization name.

Maybe the arrival of the new C-152 replacement will help, Cessna will not be happy if the aircraft cannot be used in many flying schools doing CPL training.

The Flycatcher (sorry, Skycatcher) is NOT a FAR 23 aircraft, it is certified as an LSA --- have our complex, convoluted and contradictory regulations caught up with that ---- if they hits Cessna sales, watch the rapid action to redress any "anomalies".

Tootle pip!!

[Frank Arouet]

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Piper Aircraft Inc. is headquartered in Vero Beach, Fla. Piper’s rich legacy is born of 72 years of unparalleled history, with almost 150,000 aircraft brought to market and more than 160 models certified. Approximately 90,000 of those aircraft are still flying and being serviced and supported on every continent by Piper’s 65 service centers, 27 dealers and 2,500 field personnel. Piper is the only general aviation manufacturer to build and offer aircraft for every general aviation mission, from trainers and high-performance aircraft for personal and business use to turbine-powered business aircraft and the PiperJet. For more information about Piper Aircraft and to find an authorized service center near you, please visit www.piper.com (http://www.piper.com/).
# # #
Graphics/photos/video available upon request
For further information, contact:
Mark S. Miller
(772) 299-2900
Fax: (772) 978-6597
mail to: [email protected] ([email protected])
www. piper.com

For additional information or questions about
the general aviation industry, contact the
General Aviation Manufacturers Association (GAMA)
(202) 393-1500
www.GAMA.aero (http://www.gama.aero/)

[Frank Arouet]

YouTube - Piper's New LSA Entry: The PiperSport (http://www.youtube.com/watch?v=F4nrIm8XqkU)

[SokPuppet]

Leadsled,

Thanks for the info. :ok:

SP

[LeadSled]

SokPuppet,
A pleasure.
Come to think of it, I am going to give the MD of the local Cessna agents a call, and let him know there may be a problem using Skycatchers for CPL training in Australia ---- because students may not be able to log the hours ---then sit back and watch the action.
He will be on to Albanese in a trice, and Albanese will listen.

Clinton,
Perhaps I have not expressed myself sufficiently clearly, I will have a think about it tomorrow (later today --- say he looking at the time) but in short, the industry has run far ahead of the rules, and RAOz aircraft are just as much "registered" "Australian" aircraft as those carrying VH-.

Tootle pip!!

[VH-XXX]

LeadSled, there is no need to call anyone as LSA aircraft can be registered GA or RA-Aus. Indeed there may be RA-Aus registered Skycatchers out there eventually though.


Contrary to what many people may think, LSA was actually invented (or should I say adopted in Australia) for the GA market to compete with RA-Aus by allowing more affordable GA aircraft at the bottom end of the market from local manufacturers. It was intended to help not only training establishments but those local manufacturers.

It's in the CASA mandate for GA published quite some time ago.

[Frank Arouet]

Lets not forget the Australian manufacturers locked into the same concept. The Goard Brumby from Cowra is a little beaut.

Brumby Aircraft Australia (http://www.brumbyaircraft.com.au/)

[LeadSled]

VH-XXX,

I would suggest that the LSA is the US catching up with what we have been doing for about 20 years, and to a lesser extent catching up with EASA(JAR)VLA.

The adoption of the FAA LSA design rules was straight forward, BECAUSE CASR 21 to 35 is largely (but not entirely --compare FAR and CASR 189, as one example) a certification framework references to the FAR. QED.

JAR/VLA and the US Primary Category already rate a place in CASR 21 etc. But, once again, the Australian Primary Category is less inhibited than the FAR, we do not limit it to a single engine, for example.

Let's take a case of a pilot who gets an RAOz Pilot Certificate on a Flycatcher, then goes on the get a PPL, on a VH- Flycatcher, counting some of the RAOz hours.

The he, she or it decides they want a CPL, almost all done on a Flycatcher --- does it make any sense that, suddenly, some of the Flycatcher hours cannot be count (depending on the course) --- because of a set of rules that were written before all this was even envisaged.

Exactly the same thing can happen now, with the various models of Jabiru, and a bunch of aircraft out of Eastern Europe.

Tootle pip!!

PS: I don't think (in fact, I know) that "helping GA compete" was not a significant consideration in adopting the FAA LSA rules. Many flying schools have long since been both CASA and RAOz licensed schools, to cater "for the market" --- and have had access to aircraft that could be registered with either.

Putting a VH- Jab (or Flycatcher, or Tecnam or etc., etc) versus the same aircraft RAOz registered, on the line is a business decision that operators have been able to make for quite a while now.

What would give GA a real fillip would be the RPL, that was all ready to go in 1999, here we are 10 years later, with no progress, while many EEC countries have already put in place a "sub-ICAO PPL" license, called in the UK a "national PPL".

[Horatio Leafblower]

As I said before, it is largely about quality control. There is 2/10 of 3/5 of F/all quality control in RAAus - only the pride/honour of the CFI.

CASA does not monitor RAAus, cannot vouch for the quality of its output or safety, and does not warrant the 'product'.

[VH-XXX]

I would suggest that the LSA is the US catching up with what we have been doing for about 20 years, and to a lesser extent catching up with EASA(JAR)VLA.

Interesting that you say that as it's almost like they copied our Ultralight certificate from us, but then invented and called it LSA, made it restrictive, eg 120 knots an no retracts, then we copy LSA off them and remove some of the restrictions. Pity they are not the same rules because then the European designers could stick with the one identical market.

[Propjet88]

Interesting debate largely centred around what hours can count.
It is obvious that the existing regs don't make it clear and it appears that even CASA can't make its mind up with various interpretations at various times.

Isn't the easy answer to make it all about competence? Sure there needs to be minimum number of hours of aeronatutical experience, but everyone agrees that the regs allow those hours to be accumulated in a glider or rotorcraft. Possibly because those were the main forms of "alternative" flying when the regs were written.

A simple and sensible solution would be to use the flight tests as the competency "gateway". Beef up the flight tests if necessary but if your prior training and aeronautical experience is up to it (wherever and however gained), you will be able to demonstrate all of the required competencies.

All logical views appreciated (including contra ones).

PJ

[LeadSled]

Propjet88,
Indeed, in theory at least, all our aviation training standards are "competency based" as of right now.

But, as always, old shibboleths are hard to shake, ICAO doesn't help much, nor does the FAA etc., and minimum flight hours "fly in the face" of the whole idea of competency based standards.

Which make it even sillier, that hours on a VH- Jabiru can be counted to a CPL, but not on the same aircraft, on the RAOz register.

Tootle pip!!

[Frank Arouet]

Good stick and rudder men/ women are hard to find sometimes.

Thank goodness for GFA and RAA for instilling this in their training.

Some actually do go on to fly "real aeroplanes".

[Horatio Leafblower]

Guys who understand the rules and have a thorough, deep and technical knowledge of their subject matter and a professional attitude are hard to find sometimes.

Thank goodness for professional and regulated flight instruction for commercial pilots.

Some of us even go back to Aero Clubs and fly "Fun aeroplanes" to try to show them what airmanship is all about :ugh:

..It's a tough job, especially since most of them have been taught by PPL holders with a grudge and a chip on their shoulder.

...and before you come back at me have a little think about your equally stupid generalisations :rolleyes:

[Propjet88]

Hello there Leadsled,

You are on the money. Competence should be nothing to do with hours, but it is unlikely that industry is ready for complete removal of min specified hours just yet. I can only imagine the arguments.

The problem is that while CASA has made a fair first attempt at defining flight competencies, these are not, by any means, flly developed.

In the area of technical (handling) skills there is much confusion surrounding demonstrating competence. Defining VFR competencies as, for example, holding VApp -0/+10 kts, or achieving touchdown +/- so many feet / (metres?) from the centreline is wrong. Even more confusing is that these metrics differ for CPL and PPL. The achievement of technical competence may be evidenced by being able to achieve these numbers, but just achieving this numbers does not always indicate competence.

It gets more difficult in the area of so called "non - technical skills" (bad term) such as airmanship and situiational awareness. These competencies are not well defined at all - nor frankly are they well understood. It is only when we carefully analyse and break down such skills, can we hope to try to teach / encourage / engender them. "I know good airmanship when I see it" is not good enough for instructors.

The upcoming pilot shortage, that has been lying dormant for a couple of years due to the GFC, will soon be on us with a vengeance. If we are to maintain (and hopefully improve) standards we must focus on the true competencies needed in professional pilots rather than arguing about whether numbers or letters are painted on the side of the training aircraft.

Gone are the days when we will have the luxury of saying (or perhaps thinking):

"We can teach you to push and pull the aircraft but don't really know how to teach what else you need to be a professional pilot. But if you do 150 hours we will give you a CPL,then you can go and fly in PNG or the bush for a couple of years and if you come back, whatever it is - you will have picked it up"! (Sorry to be cynical, but I hear this type of stuff regularly).

A couple of summary points for consideration:

Competence can be obtained by "experiential learning" but this is an inefficient, rocky and dangerous path. Whether letters or
numbers are painted on the side of the aircraft has little effect on this pathway.

Competence is most efficiently and safely attained and retained by effective teaching. If there is any hope of maintaining standards (never mind improving them) during the upcoming pilot shortage, we must get the best minds together and start properly defining the full range of professional competencies and developing the best ways to teach these. Whether letters or numbers are painted on the side of the aircraft (or simulators) has little effect on this pathway either.

As always, completely open to reasoned discussion.

Best wishes
PJ

[Howard Hughes]

Interestingly, the single most important flight in any pilots log book is competency based!;)

[Frank Arouet]

Horatio Leafblower;

most of them have been taught by PPL holders with a grudge and a chip on their shoulder

And you obviosly don't!

thorough, deep and technical knowledge of their subject matter

So a dyslexic can't be a good stick and rudder man because he can't fathom the innards of a radio?

Your "elitist" crap is part of the problem, not the solution.

[Horatio Leafblower]

You said:

Good stick and rudder men/ women are hard to find sometimes.

Thank goodness for GFA and RAA for instilling this in their training.

This is a stupid statement which I simply matched with equally stupid statements.

Was Col Pay a good Stick & Rudder man? Chuck Yeager? Bob Hoover? Scott Crossfield?

...did any of them learn in RAAus or in GFA gliders?

The RAAus training syllabus places no greater emphasis on stick & rudder skills than the GA syllabus.

There is good and bad in both school groups; there are good and bad instructors in GA and in RAAus; there are some students with more aptitude than others in both GA and RAAus.

With 800 hours of RAAus instruction under my belt and having conducted over 40 Pilot Certificate tests I would say no, I have no grudge or chip, but I have a good understanding of both RAAus and GA instruction.

How many hours do you have as an instructor, Frank? The attitude you display with your sweeping generalisations about GA pilots flying skills would indicate that YOU have the chip on your shoulder. :=

[Frank Arouet]

did any of them learn in RAAus or in GFA gliders?

No, and neither did Adolf Galland. I don't think GFA or RAA was around then. But Galland did learn to fly in gliders if that helps.

I've had a PPL since 1965. (Never instructed), but like you, have seen the good and bad. I have moved to recreational flying because of the insanity rife in GA. Seen the cons, witnessed corruption, watched the industry just about regulated out of existence, paid the financial costs and lived in the real world.

I'm sick of the aviation "pecking order" in this country, so I'm sorry if I offended your ego. I'm sure you'll get over it.:ok:

Does a 40Kt ragwing open cockpit ultralight pilot really need to know how to do a 1:60 when he only needs some basic mapreading skills to get where he's going. Has he been badly taught when you consider the agility he would need to carry out such a task in the open cockpit? Something that would bring into question safety issues. Is he therefor an inferior pilot?

If you have 800 hours instructing RAA and you see it so bad, why don't you try to make change from within?

Or have you already tried that?

[Horatio Leafblower]

Where did I say that I saw RAAus as being bad? :confused:

I think RAAus is fantastic - it can be awesome fun and offers freedoms that the GA system cannot.

All the tripe (above) about counting RAAus hours towards CPL (or not) is an argument about legal interpretation, not the quality (or otherwise) of RAAus output.

The fact that CASA does not monitor, administer, surveil, check or vouch for the quality of RAAus school output does not mean for a second that RAAus schools cannot exceed CASA requirements - we both know many RAAus schools do so.

However, I have also seen in the RAAus system something I hesitate to call "corruption" - let's call it a lack of rigour. For example, as an Aero Club CP/CFI I was put into a position where I was forced to report the (PPL qualified, not RAAus, not an instructor) Club president to CASA and RAAus for a long list of Reg breaches - sly charter, back yard ultralight instruction, Low flying to name a few.

I lost my job, and RAAus not only made him an instructor - he is now the RAAus Senior Instructor for the Club. :ugh:

Now I see that operation doing stupid, dangerous stuff all the time because the instructional staff are PPLs who have never worked under the supervision of a wise old head and haven't had their self-discipline developed over an apprenticeship period.

They have risen up through a Club situation where they are now the "ranking pilots" :rolleyes: and everyone, including them, believes that they now know everything. :ugh:

I think I remember my late Dad telling me "The biggest turds always float to the top, son..."

You may ask why I will not report them again: that's because following my "confidential report" from the last episode a CASA officer disclosed my identity to the person in question. :oh:

Confidential my arse.:ouch:

[Homesick-Angel]

hallelujah!

[OZBUSDRIVER]

Interesting point Propjet88. [thread drift] forget about hours in what type...standardise the instructor! A CFI must have a competency certificate from the CASA run school of instructing. Once certified this individual may teach individual students or run a school as the CFI without the need for an AOC...The chief instructor's certificate is the AOC. DIRECT RESPONSIBILITY!

If the school requires a CFI, whether GFA, RAA or GA they gotta have a certificate from the CASA as passing to the CASA standard. Only then will we get rid of the short cuts and BS....If a product fails scrutiny down the track, its all filed away under the CFIs dossier. To many of the same thing going wrong and lets come in for a cup of tea, shall we.[/thread drift]

[Frank Arouet]

Horatio Leafblower;

We do have some common ground then, but I'm still sick of the "aviation pecking order":*

Apologies for not knowing your particular situation.:ugh: Sounds like a job for The Commonwealth Ombudsman.

Was it CASA that breached your confidentiality? CAIR matters should go to CASA de-identified. Or so I was lead to believe.

[LeadSled]

Folks,

Fortunately, the "old" CASA confidential reporting system is long gone, and good a bloody good thing, the system was a hazard to air safety, not a benefit. It was a system for backstabbing and malcontents to "get even". It was a perversion of a "proper" confidential scheme, as you find in US or UK.

The new system is run by ATSB, under a very tight legislative leash, with serious penalties for any person breaching the confidentiality rules. Still not as good as the US or UK, but very close, let's hope it makes an actual contribution to airsafety.

It WILL NOT BE just another source of "evidence" for CASA Compliance and Enforcement.

Tootle pip!!

[Dnav31]

Guys,

Just skimmimg the pages, but the general idea is, GA vs RAA. How many PPL holders that work 40+ hours a week painting and building etc. (e.g every day people) can afford to pay over $200/ hr + landing fees and all the other BS........ These guys can go and hire a RAA aircraft for $140/hr, it cruises at 120kts, with fuel tanks and his mate, and not have to worry about the BS that goes on at Flying schools anymore. 1. He saves over $60 per hour.... Second, I know of at least 1 school, RAA based, that is embrasing systems like the safety management system, and the DAMP. This school may be dealing within the GA market, but they choose to run with these 'ideas', because thay work.

Fact is, like it or not, RAA is here to stay, we just need all the operators, to come in line, and make it a bit more professional.

[LeadSled]

PropJet 88,
You'r spot on, particularly the need for much further development of the description of the competencies. Indeed, the early attempts were really quite funny.

If you were flying any tail-dragger, "clearing the nose" would have been a fail, because of "unacceptable heading deviations during taxi". Likewise, turning into wind to do a run-up would also have been a failure --- to remain aligned with the taxiway --- and so it went on.

I have serious reservations about GA "experience" for brand new pilots (CPLs), all too often it is XXX hours of consolidation of errors, training shortcomings and misconception and surviving intact ( or not, as the case may be)--- ergo that must be the way it's done.

My experience in hiring low time pilots is that those whose first job was as an instructor are far more likely to meet the stick and rudder standards and other general standards I want to see. Not only have they had the extra time doing the initial rating, but their own shortcomings will be magnified in their student ---- It's a good CFI's job to fix both to instructor and the student.

That may sound a bit tough on the student, but that's how it has been for years, and is not about to change.

Tootle pip!!

[LeadSled]

----whether GFA, RAA or GA they gotta have a certificate from the CASA

Oz,
As a matter of interest, the GFA Instructor Course is being looked at very as the basis for heavy revisions to the CASA GA Instructor program.

In particular, the GFA approach to "teaching to teach" is about half the (ground school) course --- In other words, instruction in the theories and practices of Adult Education ---- Completely missing from the CASA course.

Sadly, a CASA Instructor Rating course is all too often a remedial flying training course for the candidate.

Tootle pip!!

[Horatio Leafblower]

In other words, instruction in the theories and practices of Adult Education ---- Completely missing from the CASA course.

:confused:

Well bugger me - I spent all that time studying for nothing?

Oh hang on - here's the CAO reference:

CAO 40.1.7 Flight Instructor Ratings
4.1 An applicant for the issue of a flight instructor (aeroplane) rating grade 3 must:
(a) in accordance with paragraph 4.1A, have completed a course of flight
instruction that is conducted in accordance with the outline in Appendix I,
at a flying school that has the approval to conduct instructor training
endorsed on its AOC; and
(b) have completed a course of instruction in instructional principles and
methods of at least 12 classroom hours in accordance with the syllabus
specified in Appendix I; and...

Appendix I, incidentally, includes the following detail:

2 Grade 3 ratings — theoretical and air training
2.1 For clarity, the syllabus is divided into theoretical and air training, although in
practice the 2 areas are interrelated and complementary. Theoretical training is
oriented towards providing the junior instructor with a knowledge of
elementary learning processes and the practical aspects of instructional
principles. In addition to the 12 hour ground training course, additional
experience in the conduct of pre-flight and post-flight briefings is to be
acquired by the trainee instructor for each of the airborne sequences in the
syllabus.
2.2 Theoretical training. A course of at least 12 hours’ duration in instructional
principles and methods is to include the following topics:
• Learning theory
− definition of learning
− perception
: types of perception
: factors affecting perception
− transfer (positive and negative)
− motivation (positive and negative)
− factors which aid and hinder the learning process
• Instructional techniques
− effective communication
− teaching methods
: lecture
: theory and skill lessons
: guided discussion
: briefing
− questioning techniques
− application of learning and teaching principles to airborne
instruction
• Aids to instruction
− types of aids
− how to use teaching aids
• Behavioural objectives
• Lesson planning
• Conducting a lesson period and pre-flight briefing
• Practice in conducting instructional periods and pre-flight briefings.

Grade 1 Instructors must pass a CASA exam in Principles and methods of instruction, which is more than any RAAus Senior Instructor or CFI must do.

Sorry Leadsled, your posts are tripe and can only be calculated to mislead readers :=

[superdimona]

I'm not sure that the GFA model is the best to emulate. This is the organization that has trivial exams for the A,B and C badges, all of which can be answered verbally and are on the net to memorise beforehand.

Because the GFA keeps such a tight leash on pilots, many non-instructors who don't fly cross-country (at some clubs, that's most solo pilots) don't ever get exposed to little things like airspace or an ERSA. At one club I know students are simply told 'don't fly above 4500 feet' and it is possible to get a C certificate without ever even seeing a VTC, let alone know what something like 'C LL 4500' means. There is simply no process that makes sure students know the theory.

There are some great clubs out there, and I'm sure the majority are good. However, the worst clubs turn out pilots with 5% of the theory knowledge of a GFPT student

[LeadSled]

Folks,
My specific reference was to the GFA ground school element of instructor training.

Yes, there could be improvements, but compared to the CASA syllabus and training in practice, which in reality barely touches on "Adult Education" , the GFA model of instructor training is significantly more advanced -- to say the very least.

That glider flying is very different to powered flying, that some pilots hardly ever leave sight of the launch area etc., all has nothing to do with instructor training --- or the comments I made.

The fact remains, the training of instructors in GA, particularly "teaching to teach", is woefully lacking, and it shows.

Tootle pip!!

PS: The CAO's 12 hours of generalities is not withing a bull's roar of the GFA requirement ---- which, in themselves are being reviewed and updated.

[Frank Arouet]

Caution Wind Up Alert!:=

[VH-XXX]

RAA has got their hands full now with the latest crash near Rockhampton taking out a prominent member of society.

I heard from a source that the pilot wasn't appropriately endorsed for the flight. That could get a bit nasty in the courtroom.