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Bob, the aircraft in question were all "approved" specifically for IFR operations by CASA, in full knowledge of their equipment levels and configuration. This is the purpose of the AP inspection and CofA issue process - to ensure the aircraft is legal for its intended operation, has a suitable system of maintenance and ensure no risk to third parties.
Owners and operators of these aircraft are entitled to rely on the advice of the Commonwealth and its delegates. I just don't understand why you would assume that has not occurred. These people all have a lot more skin in the game than you do, but you seem intent on proving a point. |
I have not read Bob's posts and have no intention of doing so as I am so over this it is not funny.
I personally headed the project response done by SAAA (2 years ago) and the report (around 38 pages) was put together by a member and RAAF guy who is building a rocket in Canberra. This guy has very good skills in doing this work.He produced the best response I have ever seen and I dare say CASA were so overwhelmed by it that they have been failing for over 18 months to respond. Yes read that again??.18 months ZERO correspondence. They acknowledged receipt of the document and silence since. CASA are a complete joke on so many fronts that they can't be confused as to why people have contempt for them. All the good folk there are brought down by all the incompetence around them. The "OPINIONS" of some at CASA are behind this incompetence (broadcast by an SAAA member who works there I might add) and they are opinions. Experimental category was pioneered in Australia by two fellows, one in Brisbane and one in Sydney, and the one in Sydney is a CASA AP still to this day. He knows more about ABE rules than anyone at CASA and is about the only person I know of that CASA regularly has taken a beating from. I suggest you consult him. Richard is 100% correct above. One Hundred Percent Correct! Until such time CASA start playing the game properly and start working with those that actually know their stuff and committed several hundred hours to resolving the topic, most of us are just simply going to ignore them and their opinions. The sheer height of rudeness and contempt displayed by CASA is simply disgusting. I would sack them on the spot if they worked for me. It is deplorable to say the least. And they wonder why industry treats them with contempt, mind you, they only dish back half of what CASA dish out. I had senior exec's from all the major suppliers contribute information and data, I had supporting studies etc from the USA and the UK bodies. Yet CASA buries its head in the sand and talks 'Charlie RAP'. You can tell I am very, no extremely cranky with these fools. So where is this going to end? Who knows. But suffice to say that one of my associates outside of the SAAA and in the avionics game, and myself are hoping to have a high level meeting with a serious no BS CASA- Board member in Canberra in the coming months. This will make waves and I hope put a cattle prod on some morons butts. because I am over it. If not I might sell the RV10 and buy a Bonanza that is N registered and do what all the Jet guys do here, ignore CASA completely. One last point??..The USA has the same number (possibly more now) of IFR Experimentals flying than we have flying GA piston singles. Weed out all the twins, help's and gliders etc from the register and that is what you get. CASA wake up, and if anyone at CASA has the guts to call me and make an appointment to see me?..please do. You can find my details very easily. RANT OVER?.on this post at least. |
Bob,
Firstly, I apologise if you feel that you have been abused. A robust rebuttal to your opinion is a predictable result of you making definitive (yet incorrect) statements on a subject with which you would appear have little first hand experience. We have RVs in common, we can still be friends :) Fin, I think we should just change the thread title (only kidding) DB, Nice rant! 9.5 out of 10. As far as I can see, people seem to far too easily fall into the trap of confusing "opinions" and "policy" with the "LAW" as its currently written. But hey, thats why we have lawyers... As David says, A LOT of SAAA work has gone into bridging the gap between what the law actually says, and what CASA want it to say. Most CofAs in the last year or two have been assessed with this in mind. In my opinion this should be a relatively straight forward exercise if the people making the decisions are well informed. SAAA and CASA are broadly on the same page as to where there is or isn't a safety case to answer. CofAs already require the instruments are maintained to IFR tolerances. And we all know who's calibrating who at each AD/INST/9 or 100.5 :p The reality is that it just currently doesn't warrant enough resources from CASAs side to get it completed or to continue discussions with industry. Hence the radio silence for the last 2 years. Id guess that the transition to CASR 149 is way ahead in terms of priorities for everyone. How about we shift the direction of this discussion from whether it is or isn't legal (all the lawyers I know just argue with each other) to how people think the regs as they stand may be amended in the future, and what compliance with that could look like if your current equipment configuration requires a change? IMHO the only viable path forward is to amend 20.18 to require that certain instruments meet the relevant TSO. It would then look similar to the paragraphs pertaining to GNSS, Mode S and ADSB. Its all a mouthful, but is relatively easy to get through for private ops. Similar to the Mode S mandate, a moderate introduction horizon should minimise any downtime. We are probably only talking about ALT and AH to be honest as NAV and GNSS is already singled out for TSO compliance. (and is undoubtedly complied with?.). So whats that all mean? an RC allen LCD AH plus a nice ALT, or a Sandia Quattro, or an Aspen VFR PFD (no less than 8 TSOs!). All significantly cheaper than they were a few years ago, and by the time we get this sorted out, will be cheaper still. To put that another way, all IFR pilots I know are acutely aware that a lot can kill them, and Id guess that instrumentation is probably already configured such to be low on that list. To you pilots I ask what regulations do you feel would make you safer? |
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I mean….you have an engine that has good EMS traces, good leak downs, and good oil tests, yet CASA mandate you pull it apart to see why it is operating so well. Out of all the gear in my plane, over 1000+ hours now, the items that failed several times and the least accurate were……the most expensive TSO'd items. GNS530W and the steam altimeter is not as accurate as the Dynon bits (4 separate adahrs). My previous aircraft same thing, the only bit that ever had to be removed was the TSO bit. Ask Gary W with his Lancair. Flying back from Perth in IMC and his TSO AI slowly and insideously rolled him over mentally……his MGL EFIS has been perfect.That same AI model from a TSO manufacturer has had two similar failures in other aircraft I know. Now don't start me on vac pumps and 6 pack steam instrument reliability. A TSO label means nothing about accuracy and quality. Nothing. Its paperwork. |
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To me if you can fix your position in 3d space and provide an accurate estimate for your arrival time overhead a fix that is all that should be required. I.e.
CAO 20.18 predates modern EFIS units, but the following interpretation seems reasonable and might be clarified:
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Would also need an approved (TSO?) altimeter for vertical separation especially outside radar/ADSB coverage.
Fin |
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If the altimeters and encoder pass preflight and regular IFR checks with the LAME they are airworthy. I'd argue that meets and exceeds the current requirement to have a single unit and should be approved. Perhaps even the encoder is negotiable - but it seems to me to be the cheapest way to meet the assumed requirement of having a TSO'ed altitude source. |
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