CAO 100.5 Amendment 13

[tnuc]

From AMROBA...

CAO 100.5 Amendment 13 will become effective on 1st August 2013.

This CAO covers revised requirments for items maintained under AD/INST/8 & 9 and AD/RAD/43 and introduces a number of additional requirements in the form of Pitot static, encoder and fuel Qty checks similar to the way things used to be.

More importantly, and Of particular concern is the following wording which may have the effect of precluding the use of maintenance under Schedule 5 which is used by the majority of General Aviation Aircraft.

REPEALED
Quote:
9.1 For the purposes of subregulation 38 (1) of the Regulations, CASA directs each person who is the holder of the certificate of registration for an Australian aircraft to comply with the requirements specified in the Airworthiness Limitation Section of the maintenance manual of the aircraft for which the person is the holder of the certificate of registration.


NEW
Quote:
9.1 For subregulation 38 (1) of the Regulations, CASA directs the registered operator of an Australian aircraft to comply with the maintenance requirements for the aircraft and its aeronautical products, including life-limits, as established under the approved design for the aircraft or product.
Note Contravention of a CASA maintenance direction under this subsection is a strict liability offence under regulation 38 of the Regulations

The sudden and unexpected abolition of Schedule 5 may have huge ramifications for owners and the viability of General Aviation in this country.

It is hoped CASA will clarify this situation before 1st August.

Does anyone have any further information regarding this?

[Jabawocky]

Yes! I have the inside word from a little birdie, no not the Townsville or Leigh Creek refuellers either, that there is an inadvertent ooops and they did not mean to sweep all things into that statement.

A redraft is rapidly being produced. Lets hope they get it right this time round.

Stand by for the revision.

My take when I read it was it was only scooping up pitot static and such related things, but if you read it closer it scoops all things from the spinner to the tail light. That was not the intention apparently.

Some folk were on the ball. :ok:

[Aussie Bob]

9.1 For subregulation 38 (1) of the Regulations, CASA directs the registered operator of an Australian aircraft to comply with the maintenance requirements for the aircraft and its aeronautical products, including life-limits, as established under the approved design for the aircraft or product.

Struth, if this comes into effect it means goodby to any engine extension. There are a lot of PVT/AWK aircraft out there with calendar expired engines. There are a lot of perfectly good engines out there that have run beyond manufacturer TBO.

With SIDS and this, I am beginning to think GA is is going to shrink away even more.

[Jabawocky]

Hence the rewrite, an unintended consequence :ouch:

[LeadSled]

Folks,
Jaba has got it right, thanks to "an overwhelming avalanche of (aviation) public opinion", Herr. Boyd is having the instrument re-written to remove the unintended (but were they really unintended --- read the drafts of the proposed GA maintenance rules) consequences.
You will probably find something on AMROBAs web site, they have been very active in this (and many other airworthiness regulatory atrocity) matter.
Tootle pip!!

[duncan_g]

CASA have been hinting for a while (e.g. via ageing aircraft seminars) now that Schedule 5 is on the way out.. perhaps this particular effort jumped the gun, hence the re-write, but I don't think pvt/airwork CoR holders can expect to operate on Schedule 5 forever, particular for newer Cessna's etc where there is a well established manufacturer maintenance schedule.

I thought that the main intent of Schedule 5 is meant to be there for aircraft where the manufacturer maintenance schedule is non-existant or deemed deficient :confused:

[LeadSled]

Duncan G et all,

You should have a look a FAAs FAR 43, Appendix D, the FAA annual inspection schedule --- and compare it to Schedule 5.

Low and behold, you will find most of Schedule 5 is exactly the same, with some minor bits of Australian rubbish appended, which isn't surprising, because Schedule 5 was copied from FAR 43, Appendix D.

But Schedule 5 is not what it says it is, it is not a system of maintenance, (part of the Australian nonsense) it is an inspection schedule --- and you need the data to actually carry out the tasks on the Schedule ---- and this has been the huge mental block suffered by CASA re. maintenance of US built (and some other countries) FAR 23 light aircraft --- by far the majority of aircraft on the Australian register.

The US system is delightfully simple, where FAR 43, Schedule D is applicable, you must carry out an annual inspection, you do that using Schedule D, the manufacturer's MM and the whole FAA AC library, as applicable, but particularly AC43.13A & B.

The latter being the bible for the basic maintenance and repair of light aircraft.

As the manufacturer's aircraft is certified under this FAA system, by and large the manufacturer's MM only covers matters that are specific to the make and model of aircraft ---- it is not a manual that repeats all the standard practices, techniques etc that are in the ACs, particularly AC 43.13A & B.

Then some clown here looks at the typical US MM for a light aircraft and declares it "deficient", which it is not, in context of how the aircraft was certified, including the manufacturer's instructions for continuing airworthiness.

So, the proper way to comply with the aircraft certification, including (even when it is registered in Australia) instructions for continuing airworthiness, is to use Schedule 5 (except the Australian-isms) annually or every 100 hours, using the aircraft's MM for specific details and settings, rigging etc., and using the applicable AC.s for how to actually carry out the tasks.

It is the longstanding lack of understanding in Australia, as to the full ramifications of the certification of these USA built aircraft, that is deficient, not the aircraft's MM.

To make it easier, some years ago, the then "appropriate person" in CASA produced a Legislative Instrument to automatically make all FAA ACs and the equivalent from other countries, approved data for the continuing airworthiness of the relevant aircraft.

This meant that ACs didn't, any longer, have to be approved individually for each maintenance organisation.
ie; One smart bloke in CASA, with the right delegation, pulled the plug on the whole "approval" racket, including the costs, aggravation and delay inherent in almost any dealings with CASA.

His successor renewed the instrument several times.

Now, under the present crew, the automatic approval of documents such as AC 43.13A & B is back to case by case approval ---- what a great make work exercise. $$$$$$

In context, the MMs that those in CASA declare deficient are no such thing, it is the Australian rules for the proper processes to ensure continuing airworthiness of the kind of aircraft we are talking about here that are seriously deficient --- and it will be far worse under the proposed new rules.

Worse, because it completely ignores the basic certification the aircraft, including the instructions for continuing airworthiness, which are all part of the C.of A.

Indeed, it can be legally argued that, under the present Australian legislation, a very large number of aircraft in Australia have an invalid C.of A, because the manufacturer's directions for continuing airworthiness are not being complied with, because Australian regulations do not allow compliance.

While all this probably induces brain ache, it is fundamental to the problems of proper and adequate maintenance of many light aircraft in Australia.

Tootle pip!!

[duncan_g]

Leadsled,

I feel some sense of enlightenment from reading your post - thank you :)

e.g. the Cessna 172R MM says:
Section 5-10-01 is an index of the inspections that you can use with 14 CFR, Part 43 inspection scope and detail. It is not recommended, however, that you use Section 5-10-01 as the primary checklist for inspection of the airplane.

Now I understand that Sched 5 is based on 43 App D, that makes more sense :ok:

[Creampuff]

duncan g said:I thought that the main intent of Schedule 5 is meant to be there for aircraft where the manufacturer maintenance schedule is non-existant or deemed deficient Is anyone able to point to the provisions of the regulations that manifest that intent? (Individual’s assertions as to what was intended don’t count.)

In any event, is anyone able to point to any airworthiness problem that has resulted from maintaining an aircraft in accordance the schedule of maintenance at Schedule 5 of the CARs? (When I say ‘in accordance with’, I don’t mean pencil-whipping inspections that haven’t happened. Those kinds of inspections result in the same outcome, whether by reference to Schedule 5, the manufacturer’s maintenance schedule, an approved system of maintenance or the astrologer’s advice in the local tabloid.)

[Mick Stuped]

Hi all, just new here and reading this thread and I was just as horrified to see the mistake when reading the new legislation early last week. This potentially would have grounded all GA fleet that operate under S5 on Aug 1st.

Reading the paragraph below from the new reg I take it to mean things like as an example, all rubber hoses in the aircraft eg fuel lines. Trim actuators, flap motors, speed brakes, ect, ect. Glad that got sorted. Sounds like they blamed the legal department for the draft.

Paragraph 9.1
For subregulation 38 (1) of the Regulations, CASA directs the registered operator of
an Australian aircraft to comply with the maintenance requirements for the aircraft
and its aeronautical products, including life-limits, as established under the approved
design for the aircraft or product.

So big question is when CASA get the maintenance sorted out for LCRPT or Part 135 and they want everyone to go on manufactures maintenance, I want to know, will this mean that all work previously done under S5 for aeronautical products, including life-limits have to be reversed before switching over to manufactures maintenance? What a big expensive time consuming exercise that's going to be.

Also if they want us all to go to manufactures maintenance and with Cessna this means part of the 100 hrly gets done at the 50 hrly then that really leaves the guys in the bush up the creek. Now they do the 50 hourly oil/filter change themselves and take it down for the 100 hourly. Isn't it going against the problem of aging aircraft as if a guy in the bush has a 2 to 3 hour ferry each way to get a 50hrly done he will be burning up 10% of the M/R just going to and from maintenance and running up TT unnecessary, let alone the cost of it all. It will be the final nail for bush operators. :sad:

Would like to know how the figures for accidents caused by Schedule 5 maintenance stack up to prove the need for change if it is a safety issue.

[LeadSled]

MIck Stuped,
Go back and have a re-read of my posts on the subject.
Most MM for US light aircraft are NOT comprehensive, because they are not intended to be, they assume the use of FAR 43, Appendix D (known here as Schedule 5, more or less) plus the FAA AC library, as required, but particularly AC43-13A&B.

All the detailed information on AC43-13A&B is not repeated in the manufacturer's MMs.

Thus, those in CASA don't (or don't want to) understand, declare my MMs "deficient" ---- when they are no such thing

Some current reading: Maintenance mayday ? screw-up or conspiracy? Opinion | Pro Aviation (http://proaviation.com.au/news/?p=1565)

Tootle pip!

[Jabawocky]

Thus, those in CASA don't (or don't want to) understand, declare my MMs "deficient"
.........and to add to your woes............

What worries me the most is MIF, Maintenance Induced Failure.

I had a case on the weekend where I diagnosed what I believe to be 2 induction leaks INDUCED by the LAME doing a 100hrly injector clean during an annual inspection.

The damned injectors should NEVER have been touched, they are flushed 100% of the time with a great solvent and unless a bit of debris finds its way there the injector is not at risk. So to get the injector out, the intake flanges are removed, reset in place and the gasket not replaced.

Had the owner not been astute, equipped with an EMS and not been to the worlds best training course, he would have been none the wiser, and several hundred hours down the track wondered why the life spad of some cylinders was not the same as others.

Doctors bury their mistakes, and often Maintenance orgs do too, well they replace them and you pay and never know.

So maintenance or extra unwarranted maintenance as it should be considered is the likely cause of problems. Mike Busch is worth looking up and reading the hundered or thousands of examples he has noted about this. But despite this CASA want to apply even more. Because they know better.

About time the federal government did something about trans Tasman love, and sub contracted the whole show out to the NZ CAA.

Would be cheaper and more effective :ok:

[Jabawocky]

Ohh and that Phelan artile = http://www.smileyvault.com/albums/userpics/13969/HitTheNailOnTheHead.gif

[Up-into-the-air]

Well again, casa screw up abounds at best.

At worst, a distinct hit at our industry

Which is it John - maybe a reminder of the Brisbane AMROBA debacle.

CAO 100.5 | Assistance to the Aviation Industry (http://vocasupport.com/?page_id=1815)

[LeadSled]

Jaba,
Interesting you should bring up the subject of maintenance induced failures.

Although "maintenance" is only a minor contributor to accidents in light aircraft (actually less than in large aircraft), a good proportion of those failure (no, I can't give you statistics --- just my recollection of having read many hundreds of accident reports) are "human failures", not a failure of the component itself --- ie; re-assembly was not carried out correctly.

In the early days of WW11, there was an interesting study done by the RAF, as the result of analysis of failure immediately after maintenance. This is the earliest paper, of which I am aware, that is the basis of "on condition" maintenance.

Analysis of the records showed a history of in service failure rates receding after the first 10 hours or so. A lot of "maintenance" was changed to what we now call "on condition" --- a message that is not part of the mindset of a hard core of the "iron ring" in CASA, to this day.

Can you imagine how airline costs would skyrocket, it they were subject to the same nonsense that some in CASA (despite years of experience to the contrary) wants to once again impose on GA.

With a few exceptions, all the life extension programs for engines in charter have already gone, despite (in my case) some 40 years experience in the validity of on condition overhauls of piston engines.

There is no shortage of proponents in CASA ( and some of their conflicted supporters in the industry) for axing AD/ENG/4.

Tootle pip!!

[owen meaney]

Running piston engines on condition in a commercial environment should never have been approved by CASA.
The logic is beyond my understanding.

The requirements for pressure instruments is nothing new.
I had a case on the weekend where I diagnosed what I believe to be 2 induction leaks INDUCED by the LAME doing a 100hrly injector clean during an annual inspection.
Yada yada, LAME's don't know as much as pilots trained by GUMI bears

[Creampuff]

The logic is beyond my understanding.And therein lies one of the problems. Just because you don’t understand something doesn’t make it wrong. :=

Where are your data to prove that engines on 'on condition' maintenance or beyond manufacturers’ recommended TBO fail more frequently than those that aren't?

[LeadSled]

Running piston engines on condition in a commercial environment should never have been approved by CASA.

Owen,

Don't you mean DCA/DoT/CAA etc and CASA. The history goes back to the 1940/50s

You really have some conceptual problems, don't you, including with, it would seem, evidence based decision making.

Indeed, perhaps you would like to inform us of the basis for your regular decision making, or how you form your views, do you read the runes, consult Athena Starwoman, or analyses the Astrological Signs, or use beer goggles??

Just for starters, the engine manufacturers, with which I am most familiar, do not publish TBOs, they publish RTBO ---R for recommended being the critical word.

If you bothered to delve in to published data, including from the manufacturers ( apart from assisting your understanding) or, perhaps, just used a bit of unintuitive deduction, given that the operating environments for engines vary enormously, suggesting that there is one magic number, beyond which the engine should no longer be used used, or will be still operating satisfactorily --- makes no logical sense --- except, apparently, to you.

Indeed, in some circumstance, in severe operating environments, or at the opposite end of the spectrum, engines that are not regularly used, overhauls before RTBO may be the order of the day.

One size does not fit all.

In fact, CASA and its predecessors have quite a lot of data on reliability of engines run on engine life extensions under the "old" rules -- as Creamie anticipates, there is no operational outcome degradation, no increase in risk (or reduced safety, if you insist on using those word) , and the operating economies of a 2700 TBO v. 1700 RTBO even you should be able to work out.

Regularly used O-200 are quite happily running well over 3000h TBO.

Despite this evidence, collected over 20/30 years, just about all the life extension programs for aircraft used in charter/RPT have been withdrawn, and I am aware of several applications that have been rejected without explanation by CASA.

Tootle pip!!

PS: I suppose you know that most aviation turbine engines run on condition, and the varying commercial lives of individual engines in a fleet nominally operating under similar condition, makes an interesting engineering economic study.

[Jabawocky]

Owen

I take that rather seriously. LAME's often do know more than pilots but, there are some pilots out there that are streets in front of the LAME's, most of them, and this one in particular which I referenced above is gobsmacked now at the absurd advice coming from the Aircraft Manufacturer (one of the big 4). I support his stance, it is remarkable.

We give our students a 25 question test. The results after thousands of students all fall in the same parts of the bell curve every time. You would be surprised where the LAME's and A&P's score, and alarmed where the FAA and CASA folk score.

Can I invite you along to a really good weekend of education in November? See for yourself. Money back guarantee. :ok: And a bonus, $1000 if you provide data that proves anything we teach is incorrect. (Walters Money :E)

[owen meaney]

Well sorry to upset the engine Gurus with dissident thoughts.

[thunderbird five]

CAO 100.5....
10.00pm 30/7/2013 not available on CASA website or COMLAW.
So where did it come from? Was it leaked by Julian Assange?

So it's an amendment, not an amended CAO - which means we have to have both the old 2011 (of 2012) version and the new 2013 (of 2013) version to build one usable document from, somehow? HUH?:uhoh: How about issuing a whole new 100.5 CASA?:D

Supposed to bring everyone in line, singing from the same songbook, blah blah, HOWEVER.... RA-Aus aircraft do not comply with this CAO - they are bound by their Tech Manual Section 4.2.4-6 of July 2007 to do something else. So there goes CASA's theory of everyone's gear being tuned the same way so we don't meet in the middle of the big sky. Right or wrong, CASA requires RA-Aus flyers to do what is in their manual, not follow the CAO, so it's not the same for everyone like they claim is it! It's fundamentally flawed already, by their own CASA approvals!

Next, to harmonise with world's best practice, USA perhaps (who knows), FAR 91.411 only requires IFR aircraft instruments to be tested to the specs in Appendix E of FAR 43. VFR? Nope. Not required. Doesn't happen - according to my US contacts.

Makes a bit of a mockery to paras 1 & 2 of article 1 of the agreement on the promotion of aviation safety between the government of the united states of America and the government of Australia June 2005, don't you think?

(insert sound of pruners scampering off to go look that up...)

Next, did you all see that AD/INST/8 & 9 are now gone, as is CAO108.56.
All replaced by CAO 100.5 2011 (of 2012) and 2013 (of 2013).

Who was it said we should just switch to the New Zealand regs? Jibba Jabba? You got my vote.:ok: Where do I sign?;)

[Creampuff]

No thoughts please, owen.

Just data. :ok:

[Sunfish]

Aaaah! "Maintenance induced failure". This is the first cousin of "infant mortality" - premature failre by stuffing up replacement with new parts.

I had a classic at Ansett many years ago. The MTBF of F27 gyros was only a few thousand hours over many years. Sunfish analysed the data - and found a classic infant mortality curve graphing failure vs time in service. What happend was that the delicate gyro bearings were being stuffed (brinelling) by ham fisted installers.

Sunfish solution: stop changing them so often, TBO increased by ten thousand hours. Problem solved:ok:

[Jabawocky]

Sunny :ok:

TBirdV, I did not say switch to the NZ regs....I said we should sub contract the entire job to the NZ CAA. Big difference.

I am surprised Creamie has not pulled you up on that subtle but important point. Disband and sub-out ;)

Owen, nothing to be sorry about, seriously. Genuine offer to help, what have you to lose? :ok:

[owen meaney]

Hi Creampuff and Jabawocky,
With nearly 30 years experience on piston and light turbine engines fitted to both fixed wing and rotorcraft, I can only go on experience and my thoughts.

Perhaps you can baffle me with your academic prose, but my reality is that piston engines on condition leads to more trouble than I need.

As for Sunfish saying that faulty fitment causes brinelled bearings in Gyros, that is typical pilot blaming the engineers. The main cause is moving the aircraft before the gyro has fully run up or run down.

Cheers

[Creampuff]

It’s not academic prose.

How much time have you spent in the air behind an on-condition engine?

What is 'the trouble' to which you refer, which is caused by running an engine on condition?

Re Sunfish’s example, if it were true that the damage was caused by moving the aircraft before the gyros had fully run up/down, rather than the engineers fiddling with them, the MTBF would not have been affected by stopping the engineers fiddling with them.

[owen meaney]

Hi Creampuff

So many questions and so little time.
1. I don't have to fly them, just keep pilot happy in the air.

2. The trouble with OC maintenance of engines
Pilots screaming at me is the main problem
Engineers at remote localities refusing to sign engine out OC.
Pilot dumped an aircraft next door to Bum Fck nowhere and refusing to fly any further.
Different to private operations I would suggest.

3. Sunfish makes some outrageous claim about brinelling, that happens when the balls starts skipping in the race, and blames it on engineers. Get it, the bearing has to be running and under load for brinelling to occur.
Muck Fee, extended a TBO by 10000 hours, yeah sure.

Cheers

[Volumex]

Get it, the bearing has to be running and under load for brinelling to occur.
Oh dear.

Moving on.

Leadie, is the maintenance induced failure paper the same one referred to in this article? Waddington Effect (http://www.sportaviationonline.org/sportaviation/201103?pg=98#pg100)

[Jabawocky]

Owen, 3. Sunfish makes some outrageous claim about brinelling, that happens when the balls starts skipping in the race, and blames it on engineers. Get it, the bearing has to be running and under load for brinelling to occur.

:\ I can accept a pilot or an accountant, damned even lawyers will get some sympathy from me for not knowing what Brinelling is, but not an engineer. So may I point out that you might want to take a trip back to the text books. You will find the exact opposite. I have seen and suffered the fate of this on a few occasions in my engineering business. This plane stuff is only a tiny part of what I do.

PS Brinell is spelled with a Capital B too :ok: Like Pascal and Newton and so on.

Cheers :ok:

[thunderbird five]

Sub-contract all admin and rules to CAA NZ - yes, that works for me!:ok:
Though they should dunnit when the $ was at a better rate!

[owen meaney]

Hi jaba
You are refering to heavy machinery. Brinelling also occurs exactly as I described.

[Jabawocky]

Brinelling does not discriminate from heave-light or in-between.

I just checked with Mrs Jaba....her words were exactly as I expected, and concur with
Brinelling
A form of mechanical damage in which metal is displaced or upset without attrition. Permanent deformation of the bearing surfaces where the rollers (or balls) contact the races. Brinelling results from excessive load or impact on stationary bearings.
Found op Brinelling - DiracDelta Science & Engineering Encyclopedia (http://www.diracdelta.co.uk/science/source/b/r/brinelling/source.html)

Brinelling
Brinelling is a material surface failure caused by contact stress that exceeds the material limit. This failure is caused by just one application of a load great enough to exceed the material limit. The result is a permanent dent or "brinell" mark. It is a common cause of roller bearing failures, a...
Found op Brinelling - Wikipedia, the free encyclopedia (http://en.wikipedia.org/wiki/Brinelling)


A house with two mechanical engineers and one studying.....it is a sad place :} There is hope one is doing a degree in nursing.

[T28D]

It is also a recognised method of measuring surface hardness using a defined spherical tool under load to measure the indent in samples.

[Jabawocky]

Actually that is the Brinell hardness test, which is where it all began. As in difference to Brinelling which is the term which came from the Brinell hardness test. Brinelling came from the indentation damage caused by a stationary load not unlike the Brinell hardness test.

Glad you brought that up T28D, I should have started with a history lesson first .....my bad.:ok:

[CHAIRMAN]

So Sunny was right after all:ok:
Thanks Jaba:D

[601]

A house with two mechanical engineers and one studying.....it is a sad place

Time to get a man shed with a wooden boat in it.:ok:

[Up-into-the-air]

Reading through the directions for the regulatory process, (http://www.casa.gov.au/wcmswr/_assets/main/lib100096/f13-4067.pdf) the December 2007 process calls for:

Outcome-based safety regulations

The principle behind outcome-based regulations is to allow for an outcome to be
reached via multiple or various pathways, while maintaining an acceptable level of safety. The outcome-based approach contrasts with the traditional prescriptive approach to regulation, where specific process and procedures are set as requirements.

CASA is implementing an outcome-based regulatory framework comprising:

• Outcome-based Regulations;
• Technical Standards;
• Acceptable Means of Compliance; and
• Guidance Material.

Outcome-based Regulations involve the implementation of relatively simple and brief
regulations that express high-level safety outcomes.

Technical Standards include requirements that, for the purpose of clarity and effective administration, are best contained outside the regulations.

Acceptable Means of Compliance set out acceptable methods of demonstrating
compliance with outcome-based regulations. Authorisation by the regulator is assured if an industry applicant follows the relevant Acceptable Means of Compliance. The applicant retains the ability to propose alternatives for consideration should they so wish, provided those alternatives would achieve the required safety outcome.

But, this is not what is happening at all:

We now have a completely useless, complicated and injurious set of regs, that are not [even after 25 - odd years] complete.

[601]

Authorisation by the regulator is assured if an industry applicant follows the relevant Acceptable Means of Compliance

Does this mean the powers that issue the approvals do not have to interpret legislation as they previously did. This of course had led to a myriad of different points-of-view and different standards even though it was prescriptive legislation.

Now who determines the "relevant Acceptable Means of Compliance" if all we have in legislation is "relatively simple and brief regulations that express high-level safety outcomes".

This of course will NOT lead to a myriad (to 10th power) of different points-of-view and different outcomes, will it?

[LeadSled]

This of course will NOT lead to a myriad (to 10th power) of different points-of-view and different outcomes, will it?

601,
Of course not, all CASA personnel will be standardised, regularised, tenderised, sanforized and pasteurised, and all will be well with world !!
The world will flock to Australia's door to see how to do aviation properly --- didn't Mr. McCormick say we are already the envy of the world, or some such thing??
I jest, of course!!
Tootle pip!!

[Kharon]

Panic over according to Phelan – Maintenance mayday resolved (http://proaviation.com.au/news/?p=1574)– Phew; but read on, the erstwhile Cannane is still recovering CASA chestnuts – for no recompense I note. Perhaps CASA could hire him as one their "consultants" at great expense to the public purse. There's a hoot – "AMROBA experts fix the problem – again".

Bravo Ken and crew, the hand made (embossed and brinelled) chocolate frogs are being delivered as we speak......:D

[Creampuff]

And what are the various bodies which purport to represent the interests of GA aircraft owners and pilots doing about these kinds of issues, other than looking like rabbits in spotlights? :rolleyes:

I have a close friend who is a paid up member of a number of aviation representative bodies in Australia. Not a single email or call for united action in response to these profoundly important issues. :ugh:

[thunderbird five]

Another CASA Fluster Cluck:

CAO 100.5 - 2013 has been repealed/ceased as of 2 August.

Civil Aviation Order 100.5 Amendment Instrument 2013 (No. 1) (http://www.comlaw.gov.au/Details/F2013L01330)




What hope have we got... :(

[Hasherucf]

there is a " No.2" version .Few days ago it wasn't on the website but may be now

[Me_3]

The No. 2 version is still not posted, and still leaves the possibility of a large number of aircraft being grounded before next flight. When casa is contacted for clarification on the new document over a few different issues, the only reply is "We are awaiting a reply from our standards department"

Once again, casa has changed the rules, but still has no idea on what the rules are... Makes me wonder why we bother trying to do the right things sometimes..

[thunderbird five]

No. 2 Version is now on CASA website, easily found under CAOs.

Praise Allah.:rolleyes:

[owen meaney]

The CAO amendment doesn't appear to change any maintenance requirements for my aircraft. Can someone explain what I have missed?

Cheers

[Aussie Bob]

Every time I look at this thread my eyes glaze over and I get a terrible thirst. Hard enough keeping up with flying stuff, no time to try to interpret this.

Can anyone tell me: If I am flying an aeroplane with a calendar expired engine that is running on an extension can I still fly it?

If the same aircraft has a calendar expired engine that is perfectly good at the next annual will an extension be possible?

[owen meaney]

Aussie Bob, doesn't affect other ADs.
Read more here Civil Aviation Safety Authority - Briefing: amended Civil Aviation Order 100.5 (http://casa.gov.au/scripts/nc.dll?WCMS:STANDARD::pc=PC_101622)

[thunderbird five]

Yes, does affect common ADs.

AD/RAD/43 cancelled
AD/INST/8 cancelled
AD/INST/9 cancelled
CAO 108.56 repealed (cancelled)

CAO 100.5 combines all that stuff into the one thing and attempts to have every aviator flying with instruments tuned to the same specs. Except various recreational aircraft which must follow their own tech manual requirements, which in some cases, through no fault of their own, are different to the CAO!:D:ugh:

[Oracle1]

Has schedule 8 been repealed as well?

[Aussie Bob]

Thanks Owen, but still none the wiser as to my questions ...

Can anyone tell me: If I am flying an aeroplane with a calendar expired engine that is running on an extension can I still fly it?

If the same aircraft has a calendar expired engine that is perfectly good at the next annual will an extension be possible?

[Me_3]

Hi Aussie-Bob
Thanks Owen, but still none the wiser as to my questions ...
Quote:
Can anyone tell me: If I am flying an aeroplane with a calendar expired engine that is running on an extension can I still fly it?
Quote:
If the same aircraft has a calendar expired engine that is perfectly good at the next annual will an extension be possible?


We have asked CASA these questions, only to get an answer back of 'Awaiting a reply from standards" on this, and lots of other questions. If you read the amendments, it can even make casa's own maintenance system invalid. (Sched5)

Its been two days now, and still no reply from casa, they can't tell us if we are violating the regulations by signing out aircraft that are affected so who knows what's going on....

Oh, and if you haven't had your pitot/static system checked in the last two years (Have been previously using the 3yr requirements), according to casa your grounded. Although they don't seem keen to pass that onto the aircraft owners...

[Aussie Bob]

Thanks Me 3,

Ah, the pitot static, never thought of that one ... I guess I will just keep flying and see what happens.

[Jabawocky]

I know of people who have been caught in the 3yr Pitot Static checks, they are just outside 2 years but caught out by the 3 years.

Grounded..... too bad if you now cant fly it to somewhere to get it done under a say, 90 day amnesty or something. no dont event suggest getting a ferry permit :rolleyes:

[601]

Its been two days now, and still no reply from casa

That is not too long. I have had questions with CAsA for over 5 years ans still no answer.

[Sunfish]

Creampuff:

And what are the various bodies which purport to represent the interests of GA aircraft owners and pilots doing about these kinds of issues, other than looking like rabbits in spotlights?

I have a close friend who is a paid up member of a number of aviation representative bodies in Australia. Not a single email or call for united action in response to these profoundly important issues.

You are a fool or you are being sarcastic and I missed it?

All the various "bodies" have been put on notice that their continuiing relationship with CASA is predicated on them not publicly criticisng CASA over anything.

Furthermore, at least one "body" has advised its members to likewise refrain from any criticism.

This is the entire trouble with the classification of Aviation as a "priviledge" which can by definition be withdrawn at any time for no particular reason.

To put that another way, publicly criticisng CASA and wishing to continue aviating are mutually exclusive options.

[Jabawocky]

I can assure you a great number of the significant and the tiny orgs are at present finally banding together, sharing and uniting with strong support from all participants.

This will take a little while for the effects to be seen, but progress is being made in that area.

Turning back the tide will take a while though.:sad:

For a tiny bit f evidence I was reading in the RAAus mag yesterday and they have one article written in there that touches on the subject. As one of the instigators having played a minor role, it brought a smile to jaba's face.

Time will tell.

[Creampuff]

I wasn’t being sarcastic, Sunfish. Therefore I must be a fool.

What worries me most is not that the various bodies which purport to represent the interests of GA aircraft owners and pilots may be unwilling to publicly criticise and challenge CASA. Rather, it’s that I doubt whether many of them have the expertise to know when CASA’s done something that deserves public criticism and challenge, or how to do it properly.

CASA is disintegrating, operationally. Sure: there will still be a bunch of people getting paid to produce glossy annual reports and front parliamentary committees etc. But the level of operational disfunctionality is obviously increasing.

It would be better if the GA ‘industry’ had a united and coherent solution to present to government to ensure the operational disintegration of CASA does as little damage as possible in the real world.

[Aussie Bob]

Ahhh Sunny, you depress me with your inconvenient truth. Makes me think back to the early 90's when Dick and Boyd took over AOPA for a short time. I joined in support. Sadly it was indeed short lived.

AOPA has long gone back to the fawning and grovelling, in the pocket of CASA, organisation that ununited pilots deserve. It is also unfortunate that pilots will never unite for long enough to make change due to their vastly differing opinions and circumstances.

[owen meaney]

Aussie Bob
From my area office:
No change to schedule five.
You may want to look at your engine overhauls, commercial ops that is although no one can say if and/or when may happen.

All the various "bodies" have been put on notice that their continuiing relationship with CASA is predicated on them not publicly criticisng CASA over anything.please supply evidence of this, or is this part of your group's circle jerk

[Creampuff]

You may want to look at your engine overhauls, commercial ops that is although no one can say if and/or when may happen.It’s so comforting when a regulator provides certainty, because businesses can then make well-informed strategic decisions. :ok:

[owen meaney]

Creampuff
That was the best I could get out of them.
Reading between the lines I would say that On Condition engines for commercial operations of all kinds will disappear under 119/135/136/137.

As for the private operations, no one really cares if you kill yourself and your family, no implications for CASA, ATSB nor for the CAR30 Workshop that signs you out with your OC heap of poo.

Sunfish
I have passed your claims about CASA onto John Mac for comment.
Be ready to provide evidence please.
Cheers

[Up-into-the-air]

Is that meany awi or meany foi???

[owen meaney]

UITA,
Read and digest the new regs mate, if you can't see the writing on the wall, hopefully you aren't involved in real aviation. Or are you part of Kharons so called cricket team that won't come out and play.
And no. I eat AWIs for breakfast, and FOIs are beyond my remit.

[LeadSled]

owen,
Can you point to me where, in AD/ENG/4 you can use engines on condition, now, for Charter or RPT.
I don't see "commercial operations" under 119/135/136 being any different to the present situation, Part 137, Ag, is a different matter.
As far as I know, the long and successful history of life extension programs for Charter and RPT piston engines have been ignored and have all been extinguished.
Tootle pip!!

[owen meaney]

There are commercial operations other than charter and RPT as you well know.

[Sunfish]

Owen, take it from me that there was a strong recommendation that members are not to criticise CASA because it would "prejudice the relationship". Someone else may decide to give you a quote. I won't.

And furthermore Owen, are you incensed because you believe CASA is above criticism, or are you incensed because of a sense of shame that someone would feel it necessary to caution their members because they are personally afraid of the regulators reaction?

Go ask AMROBA about their meeting. Do you think anyone else wants a repeat?

And furthermore, as far as I can tell, the common factor in some removals of AOC's ( Polar, Barrier and maybe others) is a pre existing complaint about the conduct of individual CASA staff.

Can we be forgiven for thinking that the conduct of your staff, including, allegedly, that of your CEO at the AMROBA meeting, suggests you are bullies?

And how dare you make a personal threat aimed at me?

I have passed your claims about CASA onto John Mac for comment.

Be ready to provide evidence

[owen meaney]

Stop being so precious Sunfish.
I made no threats to you, simply asked if you can provide evidence.
FFS, even my manager wants to go softly softly, sometimes that does not work.
Know the regulations and pick your fights

You and your circle group have beaten to death your view that every organisation shut down were the good guys.
Move on mate, the modern world beckons you

Cheers

[T28D]

For a CASA stooge the name Owen Meany is such a good choice, golden.

[LeadSled]

There are commercial operations other than charter and RPT as you well know.

Owen,
As previously suggested to you, one again I suggest you develop a more nuanced understanding of our present and draft future regulations. Then, an only then, might you develop some understanding of the limitations of a generic expression such as "commercial" operations.

I must say I agree with T28D, there is something very Freudian about your choice of handles.

Tootle pip!!

PS:
Sunfish,
Follow the money, there is more than simple old fashioned bullying that helps keep the various alphabet soup organisations quiet.

In Dick and Boyd's time, part of the AOPA statement of principles was:" Pay your own way and have your own say". AOPA was entirely financed by members' funds and profit from the magazine.
Back in the '90s, AOPA got things done by talking a political path, not unsuccessfully brown-nosing the bureaucrats. A number of successful campaigns to have dis-allowance motions pushed through had a salutary effect in CASA. The successful campaign against fixed ELT (with their 95% proven failure rate) legislation saved owners (in then dollars) around $16M. Just two examples.

[Creampuff]

Be that as it may, owen, you said that “no one can say if and/or when [changes to commercial aircraft engine overhaul regulatory requirements] may happen”. So, what strategic decisions should commercial operators make?

Your narrow mind arising from your narrow experience (I’m guessing the same year or two, twenty times over) is showing here:As for the private operations, no one really cares if you kill yourself and your family, no implications for CASA, ATSB nor for the CAR30 Workshop that signs you out with your OC heap of poo.But what if that “OC heap of poo” operated by the “private” pilot spears into a school full of disabled kiddies, owen? And what if that “OC heap of poo” explodes in Victor 1, under the A380 on approach to 34L at YSSY?

They’ll all be killed!

It will be all the regulator’s fault!

The regulator must require someone to fiddle with aircraft bits, constantly, to improve their reliability! No aircraft component could possibly be reliable unless the likes of owen are f*cking around with them, constantly, and someone from the regulator is constantly checking that the likes of owen have been f*cking around with them, constantly. :yuk:

[LeadSled]

“Never confuse faith, or belief—of any kind—with something even remotely intellectual.”

Dear Owen,
Just what does the above statement have to do with the price of fish on Fridays, or anything in this thread.

I am really getting quite concerned about you, are you actually channeling John Irving and his "Prayer for Owen Meany". You didn't even get the spelling correct, when you adopted the persona?? That being the case, now I am not so surprised at you "understanding" of basic aviation regulations.

<http://www.corpus-delicti.com/barb/owenmean.html>

I certainly hope you do not actually have anything to do with matters operational and/or continuing airworthiness with actual aircraft.

Tootle pip!!

[Socket]

I see again and again criticism of CASA's performance at the AMROBA meeting, I have heard through various attendees that what was said before CASA arrived and after is not quite what is reported here. I think someone mentioned that a transcript would be posted, where is it?

[Socket]

By the way, word is that new maintenance regs aren't likely till 2015 and even then will have around a 3 year time frame for compliance.

[owen meaney]

I am actually a 15 year old model aircraft fabricator with nothing better to do than sniff glue and post on aviation forums

[thorn bird]

Ah Owen, thats a start, the biggest hurdle is actually accepting you have a problem.
There are lots of organisations out there that can provide you with assistance.

[Arnold E]

Know the regulations

CAO 100.5 - 2013 has been repealed/ceased as of 2 August.

AD/RAD/43 cancelled
AD/INST/8 cancelled
AD/INST/9 cancelled
CAO 108.56 repealed (cancelled)

The one's today or the one's tomorrow??:ugh: or maybe yesterday?

[owen meaney]

The one's today or the one's tomorrow??:ugh: or maybe yesterday? I am concentrating on the changes that affect my company's operational category, and I found it pays to know some of yesterdays regs as well, comes in handy in an argument with a freshly minted AWI.

"If you care about something, you have to protect it – If you’re lucky enough to find a way of life you love, you have to find the courage to live it.”

Cheers

[Up-into-the-air]

Here is casa's NFRM for parts of 100.5 (http://vocasupport.com/?page_id=1921). Note the changes where casa blames the industry. Where was casa in this, if the matter is so bad. There is no evidence I have seen which shows near misses in regulated airspace.

Oh, by the way, the last time that I looked, all aircraft have a pitot system!!

Final Rule Making

1. Background

1.1 The primary method used by pilots to monitor and maintain a desired altitude is with a barometric altimeter. It works by measuring ambient air pressure (static pressure) and providing a display to the pilot in units of height. These instruments, whether they are aneroid based or solid state, need to be checked on a regular basis to ensure that what is being presented to the pilot is accurate. This is particularly critical during approach and departures that have terrain obstacles in close proximity.
1.2 AD/INST/8 Amdt 4 and AD/INST/9 Amdt 6 formerly required either:



the pressure altimeter/s fitted to an aircraft are tested every two years in accordance with the nominated altimeter maintenance standard; or
all aircraft instruments and instrument systems are tested in accordance with specified requirements every three years.

1.3 Following correspondence from industry regarding those altimeter setting procedures, a review of those procedures exposed an indirectly related anomaly in published material regarding altimeter maintenance standards.

1.4 Conflicting maintenance standards that are defined for aircraft operating under the Visual Flight Rules (VFR) and Instrument Flight Rules (IFR) effectively allowed aircraft with altimeters maintained to different standards to operate in the same airspace which, in the worst case scenario, could result in a loss of separation between the two aircraft.

1.5 With the introduction of Wide Area Multilateration systems into the Sydney metropolitan area as well as large areas of Tasmania it is essential that accurate altitude information is broadcast, via the Mode C transponder, for Air Traffic Control purposes. This would apply to any aircraft transmitting Mode C information regardless of operation under either the VFR or IFR.

1.6 An unintended consequence of allowing a choice of actions within the Airworthiness Directives (ADs) had been the interpretation that, with opting to do the pressure altimeter check, other aircraft instruments and instrument systems did not have to be maintained. This may have resulted in the accuracy of critical aircraft instruments degrading.This just points to a regulator that does not even have an awi system that works. There are lots of examples of this causing issues that casa just chooses to sweep under the carpet.

[T28D]

Oh, by the way, the last time that I looked, all aircraft have a pitot system!!

REALLY, all Tiger Moths have pitot ??? The Tipsy Nipper ???? Camel ???

Smarter statement might be , All commercial aircraft have pitot systems.

[Up-into-the-air]

I thought all these had crashed in the 1st world war!!!!! Sorry I missed these ones!! Not quite ALL

But there are also non-commercial GA aircraft in PVT category though.

[Kharon]

Trying to find the mirrors through the smoke, I cribbed this article from the excellent AMROBA (http://www.google.com.au/url?sa=t&rct=j&q=amroba&source=web&cd=1&cad=rja&ved=0CCsQFjAA&url=http%3A%2F%2Famroba.org.au%2F&ei=fq4WUsD7FaujiAeQ9IHwCg&usg=AFQjCNFsCESb4wxNofvB-etKRZ2xXucZTQ&bvm=bv.51156542,d.dGI)web site.

CASA issued and then repealed the following CAR 38(1) maintenance direction to all Registered Operators of aircraft. CAO 100.5 paragraph 9.1: “For subregulation 38 (1) of the Regulations, CASA directs the registered operator of an Australian aircraft to comply with the maintenance requirements for the aircraft and its aeronautical products, including life-limits, as established under the approved design for the aircraft or product.”

Though this direction is under a heading that was once related to Time Lifed Components that were in the Airworthiness Limitation Section of the Maintenance Manual, this direction is all encompassing whether the aircraft is currently being maintained to the CASA Maintenance Schedule, the aircraft manufacturers’ maintenance schedule or a system of maintenance.
Some have also raised the issue that it applies to an “Australian Aircraft”. The Civil Aviation Act defines an Australian aircraft as: (a) an aircraft registered in Australia; and (b) an aircraft in Australian territory, other than foreign registered aircraft and state aircraft.

In other words, it applies to more than just aircraft registered in Australia; it also applies to all aircraft in Australian territory. The Act definition, if applied to this direction, would encompass aircraft registered with other bodies beside CASA.

This direction does not state aircraft registered with CASA – it refers to “Australian aircraft”.
AMROBA raised the problem with the wording of the Act previously with CASA.

So, after two decades of amended Aircraft Maintenance Schedules/Systems of Maintenance by Registered Operators, this direction overrides previous justifications and directs the adoption of aircraft and product manufacturer’s maintenance requirements.

“Under the approved design for the aircraft OR product”.

This means all manufacturers, aircraft and product, must now be complied with.
AMROBA has raised the issue with CASA. We have also advised operator associations like AOPA, AAAA AWA of this issue.


I also stumbled over some very informative reading, like this one (http://amroba.org.au/files/2012/7666/3568/Is%20CASA%20Creating%20Unsafe%20Conditions.pdf). There's no doubt about it; if you want a second opinion on CASA, just ask them.

[Jabawocky]

my heads hurts :ugh:

Does anyone really know what you must do, should do, could do, maybe not have to do and not do at all? :uhoh:

[004wercras]

owen meaney

Join Date: Aug 2012
Location: Dark side of the moon
Age: 50
Posts: 115

I am actually a 15 year old model aircraft fabricator with nothing better to do than sniff glue and post on aviation forums

Hmmmmm, straight from the horses mouth!

[Kharon]

Bad 004 – No Choccy frog.....http://images.ibsrv.net/ibsrv/res/src:www.pprune.org/get/images/smilies/cwm13.gif

There is, on this forum a prerequisite for concise definition within the descriptive, particularly when detailing technical matters. In your example # 84 it is essential that the intake end be correctly identified as well as the exhaust end. I suggest you correctly redefine from which from end of the horse the alleged data was acquired.

For example.

[Up-into-the-air]

casa claim that there is no major effect to aviation due 100.5, yet they publish the following (http://www.casa.gov.au/scripts/nc.dll?WCMS:PWA::pc=PC_101737) yesterday:

Project CS 13/27
Project CS 13/27 - Review the requirements for the calibration for certain aircraft instruments when the aircraft is operating under the Visual Flight Rules

Issue

Civil Aviation Regulations (1988) (CAR) 39 (Class A aircraft) and 41 (Class B aircraft) require that all aircraft components from time to time included in or fitted to the aircraft, are maintained. Those regulations go further and prohibit operation of that aircraft unless there is a maintenance program that includes instructions for all those components included in, or fitted to, the aircraft.
Three Airworthiness Directives (ADs) were published to address the needs of certain instruments to ensure consistent standards were being applied:


AD/INST/8 applicable to aircraft operating under the Visual Flight Rules (VFR),
AD/INST/9 applicable to aircraft operating under the Instrument Flight Rules (IFR) and
AD/RAD/43 applicable to any aircraft fitted with a transponder and altitude encoding equipment and operating under either the VFR or IFR.

A review of appropriateness of using airworthiness directives for maintenance directions resulted in Civil Aviation Order (CAO) 100.5 being amended to include Paragraph 11, Additional maintenance requirements, which has replaced the three ADs. It is important to note that Schedule 5 of the CAR does not provide any testing parameters needed when performing scheduled maintenance on these instruments and systems.
CAO 100.5 requires that all aircraft, with some exemptions, operating in Australian airspace are to have specific maintenance tasks completed on the aircraft's pitot static system, including altimeter and airspeed indicator every 2 years and the fuel quantity indicating system every 4 years. Exempted aircraft are those aircraft which have an existing approved maintenance program that includes these specific requirements.
CAR 39 and 41 make no distinction as to the nature of operations the aircraft is to be used for. To allow aircraft operating under the Visual Flight Rules to be excluded from the requirement to regularly maintain certain aircraft instruments and systems would require CAR 39 and 41 to be amended or that provision included in the proposed CASR Part 91.
Concerns have been raised by some members of the aviation industry that the current universal requirements to regularly calibrate certain aircraft instruments and systems are an unnecessary cost impost on some sections of the aviation industry in Australia and are unwarranted.
By not requiring a section of the Australian fleet to perform regular maintenance on certain equipment when they are potentially operating in the same airspace as aircraft being maintained may increase the risk of loss of separation.
A Discussion Paper will be prepared and released to determine the extent of the concern regarding the costs of these maintenance actions for aircraft operating under the VFR and the associated risks. This may lead to further consultation linked to regulatory changes.
Project objective

To release a Discussion Paper to present the issues and, following review of responses, determine if further action is warranted.
Rules affected

CAR 39, CAR 41, CASR 91, CAO 100.5
Status

This project was approved by: Peter Boyd on 22 October 2013.
Project management

Project Leader/s: Charles Lenarcic ([email protected])
Project Sponsor/s: Peter Boyd, Executive Manager Standards Division
Standards Officer/s: Mick McGill ([email protected])
Project Priority

Medium


Is this burying the matter again??

[Jabawocky]

better idea? Civil Aviation Authority of New Zealand (http://www.caa.govt.nz)

Yours Truly Confused
:ugh: