Dick Smith
15th Jul 2016, 04:57
Some may remember, in 1990, with the propagation of Regulation 22A of the Civil Aviation Regulations that introduced automatic acceptance of Foreign Type Certificates. This is from an ATSB paper ;
Response Text: By the end of the 1980s Australia had a large number of design standards applicable to aircraft. Most were published in Part 101 of Civil Aviation Orders. Others were published in Parts 105, 108 and elsewhere in Civil Aviation Orders. The design standards in CAO 108.26 are an example. These design standards were a controversial part of Australian aviation legislation. In the late 1980s the Board of the Civil Aviation Authority commissioned Mr Ronald Yates to investigate these design standards.
Mr Yates advised that the design standards were inappropriate when applied to aircraft which had already been certificated by competent aviation authorities and he recommended their use be discontinued. The Board accepted the recommendation and, as a result, Australia's aviation legislation was amended in 1990 to introduce the concept of automatic acceptance of aircraft type certificates issued by the aviation authority in certain recognised countries. This was achieved by promulgation of regulation 22A, and amendment of regulation 24, of the Civil Aviation Regulations. The effect of this change was to render Australian aircraft design standards ineffective when new aircraft types were introduced to Australia, even though those design standards had not been cancelled.
See here for a copy of the Advisory Circular put out in March 2009, Type Acceptance Certificates for Imported Aircraft;
http://rosiereunion.com/file/casaadvisorycircular.pdf
Notice paragraph 7.2.1
“Persons intending to apply for a TAC should note that CASA may……. refuse to issue a TAC if there are reasonable safety grounds.”
Despite this really clear information - and when there is clearly no " reasonable safety grounds" , CASA has insisted Australian aircraft being imported from the USA comply with the ICAO recommendation that for aircraft over 12,500 pounds, they are fitted with a flight data recorder.
The US requirement is on passenger numbers and so aircraft like the Citation CJ3 do not have a flight data recorder as standard equipment.
Amazingly, some 26 years after Ron Yates made his incredible recommendation which has assisted aviation greatly in Australia, CASA are still insisting, if I sell my CJ3 here and it’s used for charter, a flight data recorder has to be fitted.
The quote from Aeromil, the Cessna dealer here is that for an FAA standard FDR installation, the estimated cost is US $200,000 (AUD $261,160) or if the EASA standard FDR installation is fitted, it would be US $250,000 (AUD $326,450).
For a start you can see why following EASA will further destroy our industry with higher costs!
Both of these total amounts don’t increase the earning capacity of the aircraft when it’s on charter, in fact they decrease it because you have the added weight of the flight data recorder and also the sometimes, quite high cost of maintenance.
It makes you wonder if the USA, with its very litigious society and its 330 million population and the largest manufacturer of GA aircraft in the world, can operate aircraft with standards set on passenger numbers, why can’t we?
The prime reason I have not been able to sell my aircraft here (and let a small charter operator, operate it so I can charter it from time to time ) is the fact that once you add the cost of ADSB, the flight data recorder and the extra maintenance, the whole operation becomes unviable.
All of the people that could have had some employment from my aircraft will now lose out- the air traffic controllers, the maintenance people, the head office staff at Airservices, the people who work for the airports, the mechanics and everyone else associated with the operation of aircraft - have less work available and industry is further depressed.
I sometimes despair- why did I do all the work to bring in the Yates Report when it’s simply ignored by fools. No one has ever said why we can’t accept the US standards for flight data recorders?
There has never been any discussion on this, just a one way concrete minded refusal to accept First of Type from the USA in this way.
As I have said many times before, get out of aviation before you are completely destroyed and you lose everything.
Response Text: By the end of the 1980s Australia had a large number of design standards applicable to aircraft. Most were published in Part 101 of Civil Aviation Orders. Others were published in Parts 105, 108 and elsewhere in Civil Aviation Orders. The design standards in CAO 108.26 are an example. These design standards were a controversial part of Australian aviation legislation. In the late 1980s the Board of the Civil Aviation Authority commissioned Mr Ronald Yates to investigate these design standards.
Mr Yates advised that the design standards were inappropriate when applied to aircraft which had already been certificated by competent aviation authorities and he recommended their use be discontinued. The Board accepted the recommendation and, as a result, Australia's aviation legislation was amended in 1990 to introduce the concept of automatic acceptance of aircraft type certificates issued by the aviation authority in certain recognised countries. This was achieved by promulgation of regulation 22A, and amendment of regulation 24, of the Civil Aviation Regulations. The effect of this change was to render Australian aircraft design standards ineffective when new aircraft types were introduced to Australia, even though those design standards had not been cancelled.
See here for a copy of the Advisory Circular put out in March 2009, Type Acceptance Certificates for Imported Aircraft;
http://rosiereunion.com/file/casaadvisorycircular.pdf
Notice paragraph 7.2.1
“Persons intending to apply for a TAC should note that CASA may……. refuse to issue a TAC if there are reasonable safety grounds.”
Despite this really clear information - and when there is clearly no " reasonable safety grounds" , CASA has insisted Australian aircraft being imported from the USA comply with the ICAO recommendation that for aircraft over 12,500 pounds, they are fitted with a flight data recorder.
The US requirement is on passenger numbers and so aircraft like the Citation CJ3 do not have a flight data recorder as standard equipment.
Amazingly, some 26 years after Ron Yates made his incredible recommendation which has assisted aviation greatly in Australia, CASA are still insisting, if I sell my CJ3 here and it’s used for charter, a flight data recorder has to be fitted.
The quote from Aeromil, the Cessna dealer here is that for an FAA standard FDR installation, the estimated cost is US $200,000 (AUD $261,160) or if the EASA standard FDR installation is fitted, it would be US $250,000 (AUD $326,450).
For a start you can see why following EASA will further destroy our industry with higher costs!
Both of these total amounts don’t increase the earning capacity of the aircraft when it’s on charter, in fact they decrease it because you have the added weight of the flight data recorder and also the sometimes, quite high cost of maintenance.
It makes you wonder if the USA, with its very litigious society and its 330 million population and the largest manufacturer of GA aircraft in the world, can operate aircraft with standards set on passenger numbers, why can’t we?
The prime reason I have not been able to sell my aircraft here (and let a small charter operator, operate it so I can charter it from time to time ) is the fact that once you add the cost of ADSB, the flight data recorder and the extra maintenance, the whole operation becomes unviable.
All of the people that could have had some employment from my aircraft will now lose out- the air traffic controllers, the maintenance people, the head office staff at Airservices, the people who work for the airports, the mechanics and everyone else associated with the operation of aircraft - have less work available and industry is further depressed.
I sometimes despair- why did I do all the work to bring in the Yates Report when it’s simply ignored by fools. No one has ever said why we can’t accept the US standards for flight data recorders?
There has never been any discussion on this, just a one way concrete minded refusal to accept First of Type from the USA in this way.
As I have said many times before, get out of aviation before you are completely destroyed and you lose everything.