LSA – register CASA or RA-Aus?

GA or RA-Aus 01 GA or RA-Aus 02One of the commonest questions I’m asked by new Light Sport Aircraft (LSA) buyers is: “Should I register the aircraft general aviation VH- with CASA or recreational with Recreational Aviation Australia (RA-Aus)?”. This question is, if anything, being asked even more frequently now CASA is offering the Recreational Pilot’s Licence (RPL), which allows RA-Aus Pilot Certificate owners to gain a license upgrade allowing them to fly certain larger VH- registered aircraft, even into certain categories of controlled airspace.

The answer(s) are not simple and depend on many variables – but get one thing straight up front: overall costs, based on a 3-year ownership of a new LSA, are pretty much the same whichever route you choose. Yes, you need a licensed engineer to sign your maintenance release on a VH- registered aircraft, and a CASA medical every so often, but these costs are completely offset by the annual aircraft re-registration and Pilot Certificate renewal charges made by RA-Aus.

“Ah yes”, I hear you muttering, “but under RA-Aus I can do all my own maintenance. Under CASA you have to pay an engineer.”

Putting aside the arguments for and against actually doing your own maintenance, CASA/VH- aircraft pilots can in fact carry out a lot of basic maintenance on their aircraft under something called ‘Schedule 8‘. For those of you unfamiliar with CAAP 42ZC-1 of CAR 1988 regulations, a summary follows.

But before you take maintenance matters into your own hands, read the relevant sections of CAR 1988 thoroughly to make sure (a) your aircraft is included in the definitions and (b) you are actually capable of doing the work. When it comes to aircraft maintenance – competency is king, whether you’re GA or RA-Aus.

Under Schedule 8, the main maintenance activities a pilot can carry out are:
– changing the engine oil and filter
– changing the air filter
– changing, replacing and/or gapping the spark plugs
– replacing the aircraft battery(s)
– topping up the hydraulic brake fluid
– changing and repairing the tyres & tubes, providing this does not require jacking the aircraft completely off the ground
– changing or replacing the seats, provided no disassembly of primary airframe parts or controls is required
– replacing seat belts/harnesses
– with some conditions, removing and replacing a door (eg for photo sessions)
– removing and replacing non-structural inspection plates and covers
– repairing/replacing safety-wire or pins, so long as they are not on primary controls
– even installing & removing a glider tow hook!

There are other activities which are also permitted. However, the main no-no is that the pilot cannot disconnect or reconnect any parts of the primary controls of the aircraft – although they can carry out the so-called ‘dual inspection’ of the controls after maintenance by a qualified engineer.

In short, a GA PPL can do most of the day-to-day maintenance on their aircraft, the same as an RA-Aus Pilot Certificate holder. If there is more extensive work to be done – eg repairs after an accident, or diagnosing and fixing an engine problem, personally I’d rather hand that over to someone who is properly qualified – be it GA or RA-Aus!

So, if not for cost or maintenance reasons, what other arguments are there for and against GA/RA-Aus? Sorry, but here I have to answer a question with a question, but it’s an important one: ‘What sort of flying do you really want to be doing?’

1. If you want/need to fly regularly into controlled airspace, at the present time you have no choice – it has to be a PPL/RPL license in a VH-registered aircraft. The same if you want to fly at night, which is currently not allowed under RA-Aus regulations. But there’s one small wrinkle – if you have both a current PPL/RPL and RA-Aus Pilot Certificate, you can fly an RA-Aus registered aircraft into controlled airspace…but not at night.

2. If you already have either an RPL, PPL or higher, then I’d register VH- with CASA. That way you don’t have to do the mandatory 5-hour RA-Aus conversion, and you’ll already be familiar with CASA rules & regs.

3. If you have an RA-Aus Pilot Certificate or no license at all, I‘d register the aircraft with RA-Aus because (a) you already know the rules and regs under RA-Aus and/or (b) the flight training is shorter (read: ‘less expensive’) than PPL training. You can always upgrade to an RPL or PPL later if you want to fly a bigger aircraft or into controlled airspace, which are currently outside the limits of RA-Aus.

4. If you have both an RPL/PPL or higher and an RA-Aus Pilot Certificate, and you don’t need to fly into controlled airspace, it really doesn’t matter how you register your LSA. Either way it will cost much the same and you can do most of the maintenance yourself.

This is intended to be a general summary of the issues around GA versus RA-Aus registration. As with everything in life, there are nuances and circumstances which may sway your own decision one way or the other. But remember – you can always switch an LSA registration from GA to RA-Aus (and vice-versa) later if you want; but make sure you keep meticulous maintenance records in the aircraft log books, and that it will cost you for a new CofA when you change registers.

Aerolite 103 with 4-stroke engine

Aerolite 103

Aerolite 103 at Oshkosh 2014

Regular readers will know about my interest in cheap (or rather, ‘less expensive’ – nothing in aviation is cheap) single seat ultralight aircraft.

One of my favourites, the Aerolite 103 (Aerolite 120 in Europe) is now available with a 4-stroke Briggs & Stratton 22 hp engine. Although heavier and a bit less powerful than the 2-stroke alternatives, the B&S motor still gives the aircraft a climb rate around 600 fpm and a cruise speed in the same 60 mph range. And of course it does it more quietly, using less fuel and, dare I say it, more reliably.

These very light 1-seat ‘Part 103’ aircraft have been slow to catch on, even in the USA, where you can fly them legally without registration or even a pilot’s license. This, in spite of the low purchase and running costs and (optional) folding wing, which allows storage in a garage or in the corner of a hangar which can’t be used by conventional fixed-wing aircraft. However, Aerolite reports growing sales in USA – more than 40 in 2014 – and now there is a German type-certified version – the Aerolite 120 – it looks like sales are set to grow exponentially over the next few years.

Priced from under US$15,000 (factory built!) for a 2-stroke version and probably under US$16,000 for a 4-stroke version, the Aerolite represents a great starting point for impecunious aspiring young pilots.

Factory-built single seat aircraft which are accepted under FAA Part 103 still cannot be registered in Australia, you have to build from a kit to be legal. In spite of lobbying from several sources, CASA and RA-Aus have still not woken up to the potential of these low cost aircraft as entry points for the more expensive end of the market. I wonder when RA-Aus will stop moaning about declining membership numbers and do what they should be doing to open aviation at grass roots level and work with CASA to ‘de-regulate’ these single seat aircraft? USA has done it. UK has done it. The rest of Europe has, in its own way, done it. Australia is now well behind in this growing ultralight market – what a shame.

RA-Aus AGM – membership apathy reigns

Lots of empty chairs at the AGM

Lots of empty chairs at the AGM

On Saturday 18 October I flew over from Tyabb to Lethbridge for the Recreational Aviation Australia (RA-Aus) Annual General Meeting (AGM). It was a great day for flying – high cloud filtering the warm sun and light northerly breezes. A perfect day for my first visit to an RA-Aus AGM.

However, out of a total membership said to be approaching 10,000 people, only around 50-55 attended and 15 of those were board and committee members and executive. That makes 35-40 ordinary members out of 10,000 willing to make the effort to go. Says a lot about something…

I know that AGMs in any sphere are not renowned for high attendance rates. However, RA-Aus does not have any electronic voting and proxy voting or live AGM web-casting, all of which would potentially reduce physical attendance.  So I was stunned by the tiny numbers. A mountain of pre-meeting burgers and bangers (‘snags’ to my Australian friends) went to waste. As did over 100 empty chairs in the meeting hangar.

I want to say right out that I make no direct criticism of the officials – elected and employed – who have clearly been putting a lot of work into turning round the disastrous mess left by previous RA-Aus administrations. Solving and resolving the problems of registrations and re-registrations, sorting out the technical issues and dealing with the mighty bureaucracy that is CASA isn’t an enviable task. Also, it cannot be easy to report mounting financial losses, particularly when CASA pays RA-Aus about $7 per member per year for the $170 per member per year value of RA-Aus services CASA receives in return.

I was also stunned by the interminable questions from the floor – mostly inaudible and not repeated by the recipient using the microphone – about rearranging the deck-chairs. The new CEO, Michael Linke, made two short presentations (he only joined in July) about what he saw as the recent achievements and what’s on the radar to deliver. He seems to have a good grip after only such a short tenure and he was at least trying to look forward. Jim Tatlock, the Treasurer, also deserves a mention for a commendably concise and clear presentation of the financials. Much of the red ink is down to investing in technology and other things which should have been done long ago. It always costs five times as much to catch up as it does to keep up.

But for the rest…too much concentration on the cost part of the equation as opposed to income generation. And nothing remotely inspiring to get your blood pumping about the future. Maybe that’s why attendance was so low – although Eugene Reid (a previous President of RA-Aus) said that it was about ‘average’ for these meetings.

No doubt there will be a full report of the meeting on the RA-Aus website in due course (please note: you’ll need to be a member of RA-Aus to access financial reports and other similar material). And lengthy analysis in the forum chatrooms by people who didn’t attend….

I’m not going to end on a negative note. A few people – at least the 15 board /committee members and employees at the meeting – have been willing to put up their hands and spend a lot of their time and energy working to get RA-Aus back into a state we can be proud of. The least we can do is show up and support them.

So why couldn’t you muster up the enthusiasm to attend the RA-Aus AGM?

PS – One small point: I am wondering why RA-Aus has not formed a trade forum for recreational aircraft manufacturers and importers? After all, we experience at first hand the questions & reactions of buyers, all of whom are potential and existing RA-Aus members. 

PPL Medical

I just did my bi-annual medical forCASA DAME Stamp my PPL. These days, it seems this is the only time I get to see a doctor, so I treat it as my regular health check.

CASA has joined the digital age and the medical form is now filled in online by the doctor, as you answer the questions. All that stuff about how much alcohol I (shouldn’t) drink and how much exercise I (should) take. I wonder if anyone ever answers ‘yes’ to the question: “Are you a regular user of cocaine, LSD, amphetamines, marijuana or other regulated narcotics?”. It seems like an endless series of questions, about all aspects of your life, most of which you wouldn’t want to admit to even if you had the ailments/conditions they refer to. I suppose if you give an incorrect answer and then have a ‘mishap’ in an aeroplane, particularly if it is anything related to the wrong answer, they throw a book at you. And any aviation insurance you may have would probably be invalidated. Lucky for me, I’m a clean living boy with no skeletons in my cupboard.

Then after the form filling comes the physical bit. It never ceases to amaze me how even the simple things have been mechanised/computerised. I remember when your blood pressure was taken by the doctor pumping up a cuff on your arm, then slowly releasing the pressure and listening through a stethoscope for your heartbeat, noting the pressures. This time it was a gizmo with a little pump and sensor that did it all automatically and displayed the two pressures on the obligatory LCD screen. Headsets and bleeps for your hearing – my doctor used to stick his finger in one (of my) ears and whisper numbers near the other, asking me to repeat them….And talking of fingers, there’s the mandatory rubber glove treatment for us men ‘down there’.

So far, what’s good are my blood pressure, decreasing weight, and blood sugar levels. Not so good is my eyesight; by my next medical I may even have to consider glasses. Well, I suppose I should be grateful I got this far without them. Now, where was I?

Next are the ‘bloods’ – whatever happened to blood tests? And an ECG as I’m getting older and haven’t been to my GP in the last 2 years. These are not mandated by CASA, so the medical certificate has been issued and I can fly again for another two years.

Deep breath for my Bi-annual Flight Review – BFR – later this week. More of that anon.

Pacific Flyer Magazine – RIP

Pacific Flyer - last cover

Pacific Flyer – last cover

Over the years, I have spent many thousands of dollars advertising the Foxbat (and a while back now, the SportStar) in Pacific Flyer magazine – including my usual half-page in the latest and – as it turns out – the last issue.

They offer a few reasons for folding (forgive the pun). I suppose top of the list must be their declining advertising revenue, but what’s caused this?

Pacific Flyer quotes the continuing effects of CASA (over) regulation of the industry, leading to buyer deterrence and disinterest. The squabbles in RA-Aus over the last couple of years cannot have been helpful either. Maybe the overall state of the Australian economy is to blame – although Australia is among the top five most successful economies in the world, even ahead of Germany, France, UK, Japan, USA etc etc, we seem to have got cold feet about debt, whether national or personal. People are not buying so many small light aircraft at the moment and, as a result, fewer advertisers are willing to reach into their pockets. So it goes.

Something Pacific Flyer would not want to mention is unfortunately what feels like a rather basic approach to design and layout in the magazine. Sometimes the quality of the photos is not good – whether this is down to the originals or the printing process I don’t know but either way, it leans towards a more amateur look. If you compare Pacific Flyer with other professionally produced aviation magazines, it does begin to appear more like a well-produced flying club newsletter. Attractive though some may find this style, in this very competitive market place, it cannot help sales. Overtly or subliminally, this design look probably puts off more readers than it attracts – however interesting the actual content.

As I said, I have been a great supporter of the magazine over the years, both financially and socially, mentioning it to customers and others alike. They have carried a great variety of articles covering the whole range of aviation, from small single seat aircraft (one’s featured in the last issue) through to warbirds and heavier metal.

So it is a great pity that another light aviation publication goes to the wall. To all at Pacific Flyer: thank you for your magazine and good luck in your next ventures.

Now where am I going to place my next series of adverts?

 

10 things to know about Light Sport Aircraft (LSAs)

ASTM home-logo21. LSAs were originally devised in the early 2000’s in the USA where they were intended to bridge the gap between unlicensed ultralights and fully certified GA aircraft. The objective was to make non-ultralight flying less expensive, through cheaper aircraft and reduced pilot license requirements. Instead of FAA certifying aircraft, the responsibility was shifted to the the manufacturer to confirm their aircraft were compliant with a number of quite rigorous ASTM standards (formerly known as the American Society for Testing and Materials).  These standards cover everything from original design through to manufacture and flying characteristics. FAA continues to police the manufacturers through full-blown inspections of their factories and processes to ensure ASTM standards are being met.

2. As of 15 April 2014 there are 134 different approved LSA aircraft available in USA. The number approved in Australia is unknown as neither CASA nor RA-Aus publishes this information.

3. The very first officially approved LSA aircraft in both USA and Australia was the Evektor SportStar Plus. Thus with some pride, Evektor claims to be the ‘Number One LSA’ company. In USA sales terms, they rate at No. 5.

4. The ASTM LSA standards were over-ridden by CASA in Australia in a number of areas. The reasons for this are unclear but rumour has it that some local manufacturers felt some of the standards could not be easily met by their products at the time. The main differences are:
– the USA straight & level, full power, maximum speed limit is 120 knots. There is no maximum speed in Australia
– the USA stall speed at maximum take-off weight (MTOW) must be under 45 knots ‘clean’ – ie no flaps. In Australia it is 45 knots in landing configuration – ie with as much flap as you need.
– the USA allows both glider and banner towing by LSAs. Australia only allows glider towing.

5. LSAs may be factory manufactured – in which case they are known as ‘Special’ or S-LSAs – or built from approved kits – in which case they are known as ‘Experimental’ or E-LSAs. In Australia, E-LSA aircraft registration numbers on RA-Aus aircraft (but not CASA VH- aircraft) are preceded with the letter ‘E’ – for example: E24-8460. Under E-LSA regulations, there is no ‘51%’ rule, so an aircraft can be almost complete, with only a few items for the builder/owner to finish.

6. An LSA aircraft may only be modified from its delivered configuration with the manufacturer’s written approval. This includes adding to or changing instrument types on the panel (including changing the radio type), changing any of the installed equipment, even installing bigger (or smaller) tyres. Contrary to popular belief, a CASR Part 21 engineer (previously known as a CAR 35 engineer) cannot legally approve modifications to an LSA.

7. In Australia, LSAs can be either be VH-registered with CASA or 24-registered with RA-Aus – the aircraft are identical, only the paperwork and pilot license requirements are different.

8. CASA-registered LSAs (but not RA-Aus registered LSAs) can be flown in Night VFR conditions, provided they are fitted with the required Night VFR equipment and the pilot has a night rating or higher.

9. Retractable (‘re-positionable’) landing gear is only permitted for amphibious LSAs . Landplanes must have fixed landing gear.

10. The Aeroprakt A22LS Foxbat is an approved LSA aircraft both in USA and Australia. Customer aircraft are registered both with CASA and RA-Aus. Among them in Australia, there are both amphibious and Night VFR rated aircraft.

More single seat ultralights

aerolite_103_7The second single seat ultralight Rob writes about is the Aerolite 103 – so named after the Part 103 regulations in the USA under which it’s built and flown. In Germany it’s known as the Aerolite 120, reflecting the maximum empty weight allowed in Europe.

This aircraft is a more traditional ultralight than the Sirocco NG (see an earlier post) in that it’s constructed from aluminium tube and dacron fabric covering. It uses a range of 2-stroke engines with electric and maybe 4-stroke propulsion in the pipeline. Favourite engine is the Hirth F33, a 28hp 2-stroke with electric start. With this engine, the aircraft sells in the USA ready to fly for under US$17,000, making it a very affordable way to get in the air. Main options include a ballistic rescue system, wheel spats and lift strut fairings. A range of dacron colours and patterns are available.

The Aerolite 103 will carry 140 kgs including 20 litres of fuel. Cruise is a gentle 50 knots maximum, take off and landing are in the 30-50 metres range.

There’s more information about this amazing little aircraft on byDanJohnson – a major USA website/blog covering a vast range of light sport and ultralight aircraft. His posts are quite frequent, particularly at this time of the year, with not only Aero Friedrichshafen but also Sun ‘n Fun in Florida. So have a look now while the Aerolite post is current.

What a pity CASA and RA-Aus do not permit these beautiful and relatively inexpensive factory built aircraft to be registered in Australia.