Saturday, November 14, 2009

Draft Maintenance Regulations

CASA's new draft maintenance regulations are available for comment until 18th December.
http://www.casa.gov.au/scripts/nc.dll?WCMS:STANDARD::pc=PC_93516

A few years ago I was in Canberra for a presentation by CASA near the start of this project. The intent was to base it on EASA with local improvements for “world's best pratice” etc. The principle was to have outcome based regulations rather than prescriptive regulations.

My little experience with EASA is that they are very bureacratic and only make general aviation more difficult. My quick look at CASA's draft regulations indicate that they have failed to make them outcome based – they are very prescriptive and will introduce more bureaucracy and expense to us.

A few examples.

I can currently do the second inspection of the control system on an aircraft (mine in particular) after maintenance. The new regulation would make it very difficult for me to do that.

We currently have a maintenance release with a requirement for a daily inspection to be certified. The draft requirement is for a technical log with the pre-flight inspection to be signed by the pilot.

Take a look here to see how NZ does it.
http://www.caa.govt.nz/Advisory_Circulars/ac91-6.pdf Reasonably sensible in my opinion – it is a daily system, not a lot different than what we currently do and provides for a variety of means to comply.

However, the CASA requirement is "pilot in command of an aircraft for a flight must ensure that the information about the flight is recorded in the flight technical log for the aircraft (unless CASA has approved another means of recording the information)." No longer a record at the end of the day's flying. Take a look at the NZ AC again to see what you can expect when CASA fills in the details with their AC. Remember, that will be required after each and every flight.

Read that rule above in conjunction with a new requirement for the pre-flight inspection, if required by the aircraft's flight manual. The Decathlon and Laser manuals, for example, are quite specific on the pre-flight check – not an issue as it includes the usual things that a pilot would do anyway. Do you think that CASA will expect that it be certified in the new technical log or not? I didn't see a requirement for a daily inspection anywhere in these draft regulations.
Consider how you operate your aircraft, say, at an aerobatic contest or practice weekend with several flights back to back.
More unnecessary paperwork and more time wasted.

The requirement for fitting a fabricated part – only if it has been made by the approved maintenance organisation doing work on the aeroplane. A simple part such as the special canopy bolt for the Pitts – the maintenance organisation had to contract the work to a specialised machining company but it seems that is no longer acceptable. The alternative is to buy the original factory part or a get that other company to get that bolt approved as a PMA'd part.

Replace a few screws on your aeroplane. Make sure that they are accompanied by evidence that they conform to the specification and are eligible to be fitted to the aircraft. Much more prescriuptive than the current reegulations I believe.

It seems that these draft regulations require more scrutiny by those people who will pay more as a result. i.e. everyone should take a look and respond to CASA. Why can't we do things the way they are done in the USA? I thought that was the original intent of regulatory reform twenty years ago. Last time I asked that of CASA in a meeting in Canberra I was told that the FAA would like to change their regulations in the same way. Guess what – the American aviation community wouldn't let them. The Australian way is to ignore drafts and simpy whinge when the new requirements are imposed on us - it is time that we changed our approach to CASA.

Tuesday, November 10, 2009

Spin Placard

New spin placard, well not really new as it has been in FAR 23 for many years but only newly certified airplanes will have it. Worth noting as it emphasizes a limitation on the number of turns in a spin based on what was tested.
[(d) For acrobatic category airplanes and utility category airplanes approved for spinning, there must be a placard in clear view of the pilot--
(1) Listing the control action for recovery from spinning maneuvers; and
(2) Stating that recovery must be initiated when spiral characteristics appear, or after not more than six turns or not more than any greater number of turns for which the airplane has been certificated.]
Aerobatic category airplanes are normally tested to 6 turns and with a comprehensive spin matrix of configurations and modes so your favourite video on Youtube doesn't count for much. i.e. the recommended maximum number of turns in a spin is 6 (there are physiological effects on the pilot which also support that same limit).

Friday, November 6, 2009

Sport Aerobatics Magazine - safety articles

There have been some interesting articles in Sport Aerobatics magazine this year.

One in the October issue that I have just received: “Making Safer Takeoffs”

“... The overabundance of horsepower and the ability to climb out at an obscene angle is a great way to demonstrate one of the highest-performance maneuvers of the entire flight. … As aerobatic airplanes have become more powerful over the years, excess horsepower has seduced many aerobatic pilots into flight profiles that will not tolerate an engine failure. …
let's say you are at 300 feet above ground level (AGL) after takeoff and the engine quits cold … Your airspeed is 90 mph … and your climb angle is 30 degrees. Wait about two seconds, because that's your typical reaction time in spite of what you might think … As you shove the stick full forward, the airspeed will continue to drop back … Now you are sinking and stalling … Now look at your energy state. You have no airspeed to work with, and you are going down rapidly … You need a descent angle of about 30 degrees to start building airspeed … You're going through 150 feet now with the ground coming up fast … Either way you are out of options and you will hit the ground at more than 20 g's, plenty hard enough to ….

Get some altitude someday and try it...even when pulling the engine back to idle power, you will be in for a surprising altitude loss, but nothing compared to a surprise engine failure. … Recognise a steep climbout for what it is: a deviation from established safe procedures. … Observers may then recognise you as one who really does know how to handle a high-performance airplane.”

Another in May, the annual safety issue: “Why it's important to follow briefed contest operating procedures”

“ … Pilots taking off were briefed to fly an upwind leg followed by a right turn into the holding area when clear of the runway. They were instructed not to perform “zooming” (an extended ground effect followed by a steep rapid climb) takeoffs. …. The incident pilot taking off performed a zooming takeoff during which he performed a sharp steep-banked 90 degree right turn at approximately mid-field. … The collision courses of the two aircraft were visible to most people at the contest …

As aerobatic pilots, we are amongst the pinnacle of skilled aviators. As an organisation of aerobatic pilots, our goal should be to always conduct ourselves in a manner that is an example for and the envy of other vaiators. Where there is an aerobatic contest, there should be pilots marvelling at the decorum of our well oiled machine. That is not possible unless everyone practices the superior judgement that sets a superior pilot apart from a pilot with merely superior skills.

The primary goal of contest organizers is to send everyone home in the same number of pieces that they showed up in, namely one. ...”

I wonder how many aerobatic pilots even bother to read them or take any notice?