[Aus-soaring] T&S as a mandated instrument
Dear Justin What a nonsense that the CASA inspector(s) foisted on you. If you read the TCDS for the Standard Jantar 2 and the TCDS for the Standard Jantar 3 then it is clear at point 8 "Operational Capability" that these sailplanes are rated for "VFR Day", and below that "Cloud flying" which is why a T&S (as a minimal capability piece of equipment for blind flying) has to be included in the standard equipment list. Since we are not permitted here to cloud fly and have such a placard in the cockpit, a T&S is not relevant to being mandatory standard equipment. Now we have more paper to cater for the bleeding obvious. Roger Druce ___ Aus-soaring mailing list Aus-soaring@lists.base64.com.au http://lists.base64.com.au/listinfo/aus-soaring
Re: [Aus-soaring] T&S as a mandated instrument
On 20/04/2016 10:23 PM, Roger.D wrote: Dear Justin What a nonsense that the CASA inspector(s) foisted on you. That's an incorrect assumption that CASA were involved in this at any point. If you read the TCDS for the Standard Jantar 2 and the TCDS for the Standard Jantar 3 then it is clear at point 8 "Operational Capability" that these sailplanes are rated for "VFR Day", and below that "Cloud flying" which is why a T&S (as a minimal capability piece of equipment for blind flying) has to be included in the standard equipment list. Since we are not permitted here to cloud fly and have such a placard in the cockpit, a T&S is not relevant to being mandatory standard equipment. We don't get to pick and choose how we interpret "relevant" rules when we don't like one that is not in our favour. I looked through at least another dozen gliders of varying age. All state cloud flying permitted, none, other than PZL require a T&B. Similarly, where specialised equipment for a task is needed (think G-meters and Aerobatics), they are listed separately in the TCDS - see the K21 as an example. PZL dropped that from the list in their most recent models of the 55 and Perkoz. I agree that the requirement for T&B for the MEL is silly, that's why I felt like it was worth sharing the story. Here's an example of some of the crazy paperwork that does exist out there, and we managed to find a decent workaround for it. It's also a cautionary tale about making sure that inspectors _actually_ read their paperwork that they claim to be signing off, rather than just waving their hands and saying "yeah I know what's written, I've done this a hundred times" that can be applied in many different situations. -- Justin Couch http://www.vlc.com.au/ Java 3D Graphics Informationhttp://www.j3d.org/ LinkedIn http://au.linkedin.com/in/justincouch/ G+ WetMorgoth --- "Look through the lens, and the light breaks down into many lights. Turn it or move it, and a new set of arrangements appears... is it a single light or many lights, lights that one must know how to distinguish, recognise and appreciate? Is it one light with many frames or one frame for many lights?" -Subcomandante Marcos --- ___ Aus-soaring mailing list Aus-soaring@lists.base64.com.au http://lists.base64.com.au/listinfo/aus-soaring
Re: [Aus-soaring] T&S as a mandated instrument
Hi all, This was picked up on my SZD36A Cobra 15 late last year during an audit. There was some discussion at the time about the probability that all the polish gliders would have the same issue. I had a look at the SZD gliders TCDS and it almost looks like a cut and paste from one glider to the next. The inspector who did my audit had said that he had seen a newly imported SZD glider without the T&B installed and the TCDS stating it as mandatory and no indication that one had been installed during manufacture. This has taken about 6 months work by the GFA team to sort this for us, job well done. At least now with the PU document having been amended to include the T&B we have a simple solution that enables us to be compliant. Phil On 21 April 2016 at 06:22, Justin Couch wrote: > On 20/04/2016 10:23 PM, Roger.D wrote: > >> Dear Justin >> What a nonsense that the CASA inspector(s) foisted on you. >> > > That's an incorrect assumption that CASA were involved in this at any > point. > > If you read >> the TCDS for the Standard Jantar 2 and the TCDS for the Standard Jantar >> 3 then it is clear at point 8 "Operational Capability" that these >> sailplanes are rated for "VFR Day", and below that "Cloud flying" which >> is why a T&S (as a minimal capability piece of equipment for blind >> flying) has to be included in the standard equipment list. Since we are >> not permitted here to cloud fly and have such a placard in the cockpit, >> a T&S is not relevant to being mandatory standard equipment. >> > > We don't get to pick and choose how we interpret "relevant" rules when we > don't like one that is not in our favour. I looked through at least another > dozen gliders of varying age. All state cloud flying permitted, none, other > than PZL require a T&B. Similarly, where specialised equipment for a task > is needed (think G-meters and Aerobatics), they are listed separately in > the TCDS - see the K21 as an example. PZL dropped that from the list in > their most recent models of the 55 and Perkoz. > > I agree that the requirement for T&B for the MEL is silly, that's why I > felt like it was worth sharing the story. Here's an example of some of the > crazy paperwork that does exist out there, and we managed to find a decent > workaround for it. It's also a cautionary tale about making sure that > inspectors _actually_ read their paperwork that they claim to be signing > off, rather than just waving their hands and saying "yeah I know what's > written, I've done this a hundred times" that can be applied in many > different situations. > > -- > Justin Couch http://www.vlc.com.au/ > Java 3D Graphics Informationhttp://www.j3d.org/ > LinkedIn http://au.linkedin.com/in/justincouch/ > G+ WetMorgoth > --- > "Look through the lens, and the light breaks down into many lights. > Turn it or move it, and a new set of arrangements appears... is it > a single light or many lights, lights that one must know how to > distinguish, recognise and appreciate? Is it one light with many > frames or one frame for many lights?" -Subcomandante Marcos > --- > > ___ > Aus-soaring mailing list > Aus-soaring@lists.base64.com.au > http://lists.base64.com.au/listinfo/aus-soaring > -- Phil ___ Aus-soaring mailing list Aus-soaring@lists.base64.com.au http://lists.base64.com.au/listinfo/aus-soaring
Re: [Aus-soaring] T&S as a mandated instrument
On 21 Apr 2016, at 5:52 am, Justin Couch wrote: > We don't get to pick and choose how we interpret "relevant" rules when we > don't like one that is not in our favour. I looked through at least another > dozen gliders of varying age. All state cloud flying permitted, none, other > than PZL require a T&B. Similarly, where specialised equipment for a task is > needed (think G-meters and Aerobatics), they are listed separately in the > TCDS - see the K21 as an example. PZL dropped that from the list in their > most recent models of the 55 and Perkoz. > > I agree that the requirement for T&B for the MEL is silly, that's why I felt > like it was worth sharing the story. Here's an example of some of the crazy > paperwork that does exist out there, and we managed to find a decent > workaround for it. It's also a cautionary tale about making sure that > inspectors _actually_ read their paperwork that they claim to be signing off, > rather than just waving their hands and saying "yeah I know what's written, > I've done this a hundred times" that can be applied in many different > situations. Thank you Justin for sharing. I am however with Roger in this theme. There was a very good reason that gliding had ‘exemptions’ globally in the Regulations. To avoid this mismatch between commercial aviation and our sport specific needs. On my on-going theme - if the elder states people were drawn on by the federation - you would have had prior alert about your glider being illegal because it doesn’t carry the fire extinguisher, and in multi-seat ‘passenger’ capable airframe, the defibrillator. (Yes, this has actually been reasons for refusing certification during import ‘inspection’ - the standard paperwork insists on these). When we put a junior CASA officer and a junior (read - recently renewed) GFA ’system’ in the same place - all the 67 year history is lost and we go through the re-learning all over again from scratch. Including that the best results are achieved when GFA told CASA to stick it - that we are the experts in our sport, which needs to operate in specific ways in order to be safe. Remember the primacy - SAFETY. How does making the paper mound higher and in multiple mounds (the compliant, the interpreted work around, the reality) contribute positively to this? The argument that ‘society demands this’ is so hollow - as if the public bystander leaning on the aerodrome fence is able to tell the operator how to do things because of the unformed opinions - regulation by social media. Emilis ___ Aus-soaring mailing list Aus-soaring@lists.base64.com.au http://lists.base64.com.au/listinfo/aus-soaring
Re: [Aus-soaring] T&S as a mandated instrument
On 21/04/2016 8:40 AM, emillis prelgauskas wrote: There was a very good reason that gliding had ‘exemptions’ globally in the Regulations. To avoid this mismatch between commercial aviation and our sport specific needs. It's probably worth some time to chat with you privately to get some details on where these can be found. Unfortunately I am now far more intimate with both Oz and international airworthiness regulations than I really would like to be. If these exemptions do exist written down that you are claiming, I cannot find them, nor can anyone else at the GFA - perhaps they went up in smoke with the rest of our paperwork a few years ago? The regulatory framework that existed in the utopian past has changed, rather dramatically on us, so things that may have been in place before just don't work any more - if we can find the documentation of them at all. I see a lot of what is happening now as no different to then - someone finds yet another stupid rule, everyone mulls it over for a time, an exemption gets made according to the paperwork framework of the day, everyone shakes hands and moves on. I'd like to understand how you find this particular issue (T&B on MEL) any different to the fire-extinguisher example you cite. Both seem to involve a silly rule that doesn't apply to us, someone working out a way to get an exemption within the rules of the day, and everyone just moves on (and then 30 years down the track someone recounts it as a funny story of "Kids these days! Back in my day"). Including that the best results are achieved when GFA told CASA to stick it - that we are the experts in our sport, which needs to operate in specific ways in order to be safe. Remember the primacy - SAFETY. And, they in turn can tell us the same and stop gliding in it's tracks completely, or make it so financially uncomfortable for us to have the same effect. Neither is a good outcome for us. So, work out when to bend with the wind, and when to stand firm against it. Everyone has a different interpretation of that point. We, luckily, have some very good people on the GFA side that know the system inside and out as they deal with it professionally every day. So, when weird stuff like this happens, they already know what to do and slip in that extra one sentence into our paperwork so that the guys on the ground like you and I can continue to operate mostly unaffected. How does making the paper mound higher and in multiple mounds (the compliant, the interpreted work around, the reality) contribute positively to this? The argument that ‘society demands this’ is so hollow - as if the public bystander leaning on the aerodrome fence is able to tell the operator how to do things because of the unformed opinions - regulation by social media. The utopia of the good old days no longer exists and we do have to put up with this stuff whether we like it or not. I bet 40 years ago the elders of the time were decrying "adding more mounds of paperwork" too, comparing it to pre-WWII gliding. The more things change, the more they stay the same. Yes the world is getting more litigious (specially insurance companies!). On top of that, we now have a bunch of know-it-alls on social media condemning everything that can gut something almost instantaneously regardless of good intentions or not of the target. We can't live in a vacuum and pretend the world doesn't exist around us. If genetics have much to say, I have at least another 40 years of enjoying this sport - I'd like to still be able to have that option should I, and all the younger guys I'm trying to mentor, be interested. Anyway, I'll shoot you (emillis) a private email to see what we can dig up from historical paperwork and get into electronic form and weave into the current reality. -- Justin Couch http://www.vlc.com.au/ Java 3D Graphics Informationhttp://www.j3d.org/ LinkedIn http://au.linkedin.com/in/justincouch/ G+ WetMorgoth --- "Look through the lens, and the light breaks down into many lights. Turn it or move it, and a new set of arrangements appears... is it a single light or many lights, lights that one must know how to distinguish, recognise and appreciate? Is it one light with many frames or one frame for many lights?" -Subcomandante Marcos --- ___ Aus-soaring mailing list Aus-soaring@lists.base64.com.au http://lists.base64.com.au/listinfo/aus-soaring
Re: [Aus-soaring] T&S as a mandated instrument
Justin and others One of the benefits of simple regulations is that they will inherently contain less internal conflicts. In this case the conflict is between the norms for aircraft certification and the operational rules. "Everyone" in Certification knows that the TCDS (Type Certificate Data Sheet) is sacrosanct and only an amendment to the type certificate (STC or supplemental type certificate) can override it. However, particularly something that was type certificated several decades ago in a country that at the time was not fully aligned with the more modern (and lesser in number) "international' standards may have items included that are relevant to the operating rules of the country of origin rather than design integrity. Cloud flying in glider was not only permitted, but regularly encouraged, in eastern Europe post WW2, so including the T&S or an AH in the TCDS rather than the operational equipment list was not considered wrong. Hopefully the current FAR and EASA certification standards are sufficiently clear to distinguish between operational role integrity equipment and basic design integrity requirements. However, when the Poles brought their gliders here for the 1974 and 1987 Worlds, they had a competition rule that prohibited all blind-flying instruments, and knowing this, they removed them from the gliders. So the SP-registered PZL gliders that entered those comps were in breach of their TCDS and you can bet the Polish airworthiness authority did not think to issue an STC to allow them to fly clear of cloud without a T&S! For many years the GFA has had exemptions against the standard schedules of instrument requirements for powered aeroplanes granted by CAO 95.4 to vary CAO 100.18 - but as an appropriate operating rule, nobody thought (and I was one of them at the time) to go into details of type certification for foreign gliders, particularly when the old Department had agreed that the GFA was capable of managing its own affairs, and the intention of the rule was rarely defeated by someone reading the literal content out of context. Not so any longer - particularly in a litigious society where everybody wants to admit no blame and obtain a legal ruling supporting their interpretation of a poorly-written old rule. Such is the problem of a society where every rule has to be written with no room for interpretation, no legislator has room for any discretion lest they run foul of someone's view of "fairness" and gross-scale bias verging on corruption (think banks, tax havens and the construction industry) is ignored by the "ruling classes" whilst people faff around the edges worrying about whether a T&S is necessary for safe operation of a Jantar but not of a Janus; whether a yaw string satisfies an operational requirement for a slip indicator; not to mention whether GPS has made the magnetic compass redundant (there are serious international musings on whether to base global navigation on true north by satellite data in lieu of the old Greek lodestone). My two bob's worth on this! Wombat On 21/04/2016 9:55 AM, Justin Couch wrote: On 21/04/2016 8:40 AM, emillis prelgauskas wrote: There was a very good reason that gliding had ‘exemptions’ globally in the Regulations. To avoid this mismatch between commercial aviation and our sport specific needs. It's probably worth some time to chat with you privately to get some details on where these can be found. Unfortunately I am now far more intimate with both Oz and international airworthiness regulations than I really would like to be. If these exemptions do exist written down that you are claiming, I cannot find them, nor can anyone else at the GFA - perhaps they went up in smoke with the rest of our paperwork a few years ago? The regulatory framework that existed in the utopian past has changed, rather dramatically on us, so things that may have been in place before just don't work any more - if we can find the documentation of them at all. I see a lot of what is happening now as no different to then - someone finds yet another stupid rule, everyone mulls it over for a time, an exemption gets made according to the paperwork framework of the day, everyone shakes hands and moves on. I'd like to understand how you find this particular issue (T&B on MEL) any different to the fire-extinguisher example you cite. Both seem to involve a silly rule that doesn't apply to us, someone working out a way to get an exemption within the rules of the day, and everyone just moves on (and then 30 years down the track someone recounts it as a funny story of "Kids these days! Back in my day"). Including that the best results are achieved when GFA told CASA to stick it - that we are the experts in our sport, which needs to operate in specific ways in order to be safe. Remember the primacy - SAFETY. And, they in turn can tell us the same and stop gliding in it's tracks completely, or make
Re: [Aus-soaring] T&S as a mandated instrument
nicely put, a 2 bob cheque in the mail > On 21 Apr 2016, at 4:09 PM, Mike Cleaver wrote: > > Justin and others > > One of the benefits of simple regulations is that they will inherently > contain less internal conflicts. In this case the conflict is between the > norms for aircraft certification and the operational rules. "Everyone" in > Certification knows that the TCDS (Type Certificate Data Sheet) is sacrosanct > and only an amendment to the type certificate (STC or supplemental type > certificate) can override it. > > However, particularly something that was type certificated several decades > ago in a country that at the time was not fully aligned with the more modern > (and lesser in number) "international' standards may have items included that > are relevant to the operating rules of the country of origin rather than > design integrity. Cloud flying in glider was not only permitted, but > regularly encouraged, in eastern Europe post WW2, so including the T&S or an > AH in the TCDS rather than the operational equipment list was not considered > wrong. Hopefully the current FAR and EASA certification standards are > sufficiently clear to distinguish between operational role integrity > equipment and basic design integrity requirements. > > However, when the Poles brought their gliders here for the 1974 and 1987 > Worlds, they had a competition rule that prohibited all blind-flying > instruments, and knowing this, they removed them from the gliders. So the > SP-registered PZL gliders that entered those comps were in breach of their > TCDS and you can bet the Polish airworthiness authority did not think to > issue an STC to allow them to fly clear of cloud without a T&S! > > For many years the GFA has had exemptions against the standard schedules of > instrument requirements for powered aeroplanes granted by CAO 95.4 to vary > CAO 100.18 - but as an appropriate operating rule, nobody thought (and I was > one of them at the time) to go into details of type certification for foreign > gliders, particularly when the old Department had agreed that the GFA was > capable of managing its own affairs, and the intention of the rule was rarely > defeated by someone reading the literal content out of context. Not so any > longer - particularly in a litigious society where everybody wants to admit > no blame and obtain a legal ruling supporting their interpretation of a > poorly-written old rule. Such is the problem of a society where every rule > has to be written with no room for interpretation, no legislator has room for > any discretion lest they run foul of someone's view of "fairness" and > gross-scale bias verging on corruption (think banks, tax havens and the > construction industry) is ignored by the "ruling classes" whilst people faff > around the edges worrying about whether a T&S is necessary for safe operation > of a Jantar but not of a Janus; whether a yaw string satisfies an operational > requirement for a slip indicator; not to mention whether GPS has made the > magnetic compass redundant (there are serious international musings on > whether to base global navigation on true north by satellite data in lieu of > the old Greek lodestone). > > My two bob's worth on this! > > Wombat > > On 21/04/2016 9:55 AM, Justin Couch wrote: >> On 21/04/2016 8:40 AM, emillis prelgauskas wrote: >>> There was a very good reason that gliding had ‘exemptions’ globally in the >>> Regulations. To avoid this mismatch between commercial aviation and our >>> sport specific needs. >> >> It's probably worth some time to chat with you privately to get some details >> on where these can be found. Unfortunately I am now far more intimate with >> both Oz and international airworthiness regulations than I really would like >> to be. If these exemptions do exist written down that you are claiming, I >> cannot find them, nor can anyone else at the GFA - perhaps they went up in >> smoke with the rest of our paperwork a few years ago? >> >> The regulatory framework that existed in the utopian past has changed, >> rather dramatically on us, so things that may have been in place before just >> don't work any more - if we can find the documentation of them at all. I see >> a lot of what is happening now as no different to then - someone finds yet >> another stupid rule, everyone mulls it over for a time, an exemption gets >> made according to the paperwork framework of the day, everyone shakes hands >> and moves on. >> >> I'd like to understand how you find this particular issue (T&B on MEL) any >> different to the fire-extinguisher example you cite. Both seem to involve a >> silly rule that doesn't apply to us, someone working out a way to get an >> exemption within the rules of the day, and everyone just moves on (and then >> 30 years down the track someone recounts it as a funny story of "Kids these >> days! Back in my day"). >> >>> Including that the best res
Re: [Aus-soaring] T&S as a mandated instrument
Emilis - I agree totally with your thoughts and agree that it would be prudent for GFA to utilise the knowledge of senior members. Justin: I have no idea of your capabilities re GFA operational and regulatory issues - nor do I have knowledge of your GFA authorities and qualifications or personal aviation qualificationsl. Please advise. Your Utopian past really did exist and we had sufficient capability with the statesmanship of GFA and DCA officers to develop a very sound and universally admired operation which was adopted by many other international authorities. You may question my authority to make such a statement so see following. I was besotted by aviation at a very young age and was adopted by members of the Adelaide Soaring club at the time GFA was formed. I am probably the only member living that experienced its formation and proceeded through its entire existence to this day. I' ve lived, achieved and performed their dreams and my wife and I have mentored numerous youth into an aviation career. I'm appalled that current GFA officers have caved in to junior and unqualified CASA emplyees. FYI I wouldn't piss on you if you were on fire unless you can provide info. otherwise. Noel. -Original Message- From: Aus-soaring [mailto:aus-soaring-boun...@lists.base64.com.au] On Behalf Of Justin Couch Sent: Thursday, April 21, 2016 9:26 AM To: Discussion of issues relating to Soaring in Australia. Subject: Re: [Aus-soaring] T&S as a mandated instrument On 21/04/2016 8:40 AM, emillis prelgauskas wrote: > There was a very good reason that gliding had 'exemptions' globally in the Regulations. To avoid this mismatch between commercial aviation and our sport specific needs. It's probably worth some time to chat with you privately to get some details on where these can be found. Unfortunately I am now far more intimate with both Oz and international airworthiness regulations than I really would like to be. If these exemptions do exist written down that you are claiming, I cannot find them, nor can anyone else at the GFA - perhaps they went up in smoke with the rest of our paperwork a few years ago? The regulatory framework that existed in the utopian past has changed, rather dramatically on us, so things that may have been in place before just don't work any more - if we can find the documentation of them at all. I see a lot of what is happening now as no different to then - someone finds yet another stupid rule, everyone mulls it over for a time, an exemption gets made according to the paperwork framework of the day, everyone shakes hands and moves on. I'd like to understand how you find this particular issue (T&B on MEL) any different to the fire-extinguisher example you cite. Both seem to involve a silly rule that doesn't apply to us, someone working out a way to get an exemption within the rules of the day, and everyone just moves on (and then 30 years down the track someone recounts it as a funny story of "Kids these days! Back in my day"). > Including that the best results are achieved when GFA told CASA to stick it - that we are the experts in our sport, which needs to operate in specific ways in order to be safe. > Remember the primacy - SAFETY. And, they in turn can tell us the same and stop gliding in it's tracks completely, or make it so financially uncomfortable for us to have the same effect. Neither is a good outcome for us. So, work out when to bend with the wind, and when to stand firm against it. Everyone has a different interpretation of that point. We, luckily, have some very good people on the GFA side that know the system inside and out as they deal with it professionally every day. So, when weird stuff like this happens, they already know what to do and slip in that extra one sentence into our paperwork so that the guys on the ground like you and I can continue to operate mostly unaffected. > How does making the paper mound higher and in multiple mounds (the compliant, the interpreted work around, the reality) contribute positively to this? > The argument that 'society demands this' is so hollow - as if the public bystander leaning on the aerodrome fence is able to tell the operator how to do things because of the unformed opinions - regulation by social media. The utopia of the good old days no longer exists and we do have to put up with this stuff whether we like it or not. I bet 40 years ago the elders of the time were decrying "adding more mounds of paperwork" too, comparing it to pre-WWII gliding. The more things change, the more they stay the same. Yes the world is getting more litigious (specially insurance companies!). On top of that, we now have a bunch of know-it-alls on social media condemning everything that can gut something almost instantaneously regardless of good intentions or not of the target. We can't live in a vacuum and
Re: [Aus-soaring] T&S as a mandated instrument
CAO 95.4 , exemptions , (l)subregulation 207 (2) as far as the carriage of a gyroscopic turn and slip indicator and an outside air temperature indicator as prescribed in Appendix I of Civil Aviation Order 20.18 is concerned; > On 21 Apr 2016, at 8:55 PM, Noel Roediger wrote: > > Emilis - I agree totally with your thoughts and agree that it would be > prudent for GFA to utilise the knowledge of senior members. > > Justin: I have no idea of your capabilities re GFA operational and > regulatory issues - nor do I have knowledge of your GFA authorities and > qualifications or personal aviation qualificationsl. Please advise. > > Your Utopian past really did exist and we had sufficient capability with the > statesmanship of GFA and DCA officers to develop a very sound and > universally admired operation which was adopted by many other international > authorities. > > You may question my authority to make such a statement so see following. > > I was besotted by aviation at a very young age and was adopted by members of > the Adelaide Soaring club at the time GFA was formed. > > I am probably the only member living that experienced its formation and > proceeded through its entire existence to this day. > > I' ve lived, achieved and performed their dreams and my wife and I have > mentored numerous youth into an aviation career. > > I'm appalled that current GFA officers have caved in to junior and > unqualified CASA emplyees. > > FYI I wouldn't piss on you if you were on fire unless you can provide info. > otherwise. > > Noel. > > > -Original Message- > From: Aus-soaring [mailto:aus-soaring-boun...@lists.base64.com.au] On Behalf > Of Justin Couch > Sent: Thursday, April 21, 2016 9:26 AM > To: Discussion of issues relating to Soaring in Australia. > Subject: Re: [Aus-soaring] T&S as a mandated instrument > >> On 21/04/2016 8:40 AM, emillis prelgauskas wrote: >> There was a very good reason that gliding had 'exemptions' globally in the > Regulations. To avoid this mismatch between commercial aviation and our > sport specific needs. > > It's probably worth some time to chat with you privately to get some details > on where these can be found. Unfortunately I am now far more intimate with > both Oz and international airworthiness regulations than I really would like > to be. If these exemptions do exist written down that you are claiming, I > cannot find them, nor can anyone else at the GFA - perhaps they went up in > smoke with the rest of our paperwork a few years ago? > > The regulatory framework that existed in the utopian past has changed, > rather dramatically on us, so things that may have been in place before just > don't work any more - if we can find the documentation of them at all. I see > a lot of what is happening now as no different to then - someone finds yet > another stupid rule, everyone mulls it over for a time, an exemption gets > made according to the paperwork framework of the day, everyone shakes hands > and moves on. > > I'd like to understand how you find this particular issue (T&B on MEL) any > different to the fire-extinguisher example you cite. Both seem to involve a > silly rule that doesn't apply to us, someone working out a way to get an > exemption within the rules of the day, and everyone just moves on (and then > 30 years down the track someone recounts it as a funny story of "Kids these > days! Back in my day"). > >> Including that the best results are achieved when GFA told CASA to stick > it - that we are the experts in our sport, which needs to operate in > specific ways in order to be safe. >> Remember the primacy - SAFETY. > > And, they in turn can tell us the same and stop gliding in it's tracks > completely, or make it so financially uncomfortable for us to have the same > effect. Neither is a good outcome for us. So, work out when to bend with the > wind, and when to stand firm against it. Everyone has a different > interpretation of that point. > > We, luckily, have some very good people on the GFA side that know the system > inside and out as they deal with it professionally every day. So, when weird > stuff like this happens, they already know what to do and slip in that extra > one sentence into our paperwork so that the guys on the ground like you and > I can continue to operate mostly unaffected. > >> How does making the paper mound higher and in multiple mounds (the > compliant, the interpreted work around, the reality) contribute positively > to this? >> The argument that 'society demands this' is so hollow - as if the public > bystander leaning on the aerodrom
Re: [Aus-soaring] T&S as a mandated instrument
Are you suggesting that a glider using water ballast is exempt from the manufacturers requirement to have a working outside air temperature indicator as well ? The reason the manufacturer has this requirement is prohibit flight above the freezing level, which in turn is to prevent water freezing in the tanks which could lead to C of G shifting too far back (tail tank can’t dump), or even worse, the expansion causing failure of the structure - broken fin or split wing in flight. My reading of the exemption is that it applies just to the CARs, which require those instruments in addition to what the manufacturer may require. As a result, the manufacturers requirement still exists, hence needing a STC or PU to be able to remove the T&S in this case. Noel - whilst the utopian past may well have existed, it certainly doesn’t now - actually, I don’t believe it did, just that the legislated oversight to the GFA delegations were never conducted. GFA were left with 2 simple choices - fix the documentation (and requirements) to meet with CASA audit approval in a very short time frame or lose all airworthiness delegation with no prospect of CASA being able to pick up, with the end result, grounding all Australian registered gliders. Nowhere was there an option to keep what had been before, much as all of us would have preferred. > On 22 Apr 2016, at 8:38 , Martin wrote: > > CAO 95.4 , exemptions , (l)subregulation 207 (2) as far as the carriage > of a gyroscopic turn and slip indicator and an outside air temperature > indicator as prescribed in Appendix I of Civil Aviation Order 20.18 is > concerned; > >> On 21 Apr 2016, at 8:55 PM, Noel Roediger wrote: >> >> Emilis - I agree totally with your thoughts and agree that it would be >> prudent for GFA to utilise the knowledge of senior members. >> >> Justin: I have no idea of your capabilities re GFA operational and >> regulatory issues - nor do I have knowledge of your GFA authorities and >> qualifications or personal aviation qualificationsl. Please advise. >> >> Your Utopian past really did exist and we had sufficient capability with the >> statesmanship of GFA and DCA officers to develop a very sound and >> universally admired operation which was adopted by many other international >> authorities. >> >> You may question my authority to make such a statement so see following. >> >> I was besotted by aviation at a very young age and was adopted by members of >> the Adelaide Soaring club at the time GFA was formed. >> >> I am probably the only member living that experienced its formation and >> proceeded through its entire existence to this day. >> >> I' ve lived, achieved and performed their dreams and my wife and I have >> mentored numerous youth into an aviation career. >> >> I'm appalled that current GFA officers have caved in to junior and >> unqualified CASA emplyees. >> >> FYI I wouldn't piss on you if you were on fire unless you can provide info. >> otherwise. >> >> Noel. >> >> >> -Original Message- >> From: Aus-soaring [mailto:aus-soaring-boun...@lists.base64.com.au] On Behalf >> Of Justin Couch >> Sent: Thursday, April 21, 2016 9:26 AM >> To: Discussion of issues relating to Soaring in Australia. >> Subject: Re: [Aus-soaring] T&S as a mandated instrument >> >>> On 21/04/2016 8:40 AM, emillis prelgauskas wrote: >>> There was a very good reason that gliding had 'exemptions' globally in the >> Regulations. To avoid this mismatch between commercial aviation and our >> sport specific needs. >> >> It's probably worth some time to chat with you privately to get some details >> on where these can be found. Unfortunately I am now far more intimate with >> both Oz and international airworthiness regulations than I really would like >> to be. If these exemptions do exist written down that you are claiming, I >> cannot find them, nor can anyone else at the GFA - perhaps they went up in >> smoke with the rest of our paperwork a few years ago? >> >> The regulatory framework that existed in the utopian past has changed, >> rather dramatically on us, so things that may have been in place before just >> don't work any more - if we can find the documentation of them at all. I see >> a lot of what is happening now as no different to then - someone finds yet >> another stupid rule, everyone mulls it over for a time, an exemption gets >> made according to the paperwork framework of the day, everyone shakes hands >> and moves on. >> >> I'd like to understand how you find th
Re: [Aus-soaring] T&S as a mandated instrument
Thanks Martin - I've been off colour this week or I would have remembered/noticed that! Of course it is there! Wombat On 22/04/2016 8:38 AM, Martin wrote: CAO 95.4 , exemptions , (l)subregulation 207 (2) as far as the carriage of a gyroscopic turn and slip indicator and an outside air temperature indicator as prescribed in Appendix I of Civil Aviation Order 20.18 is concerned; On 21 Apr 2016, at 8:55 PM, Noel Roediger wrote: Emilis - I agree totally with your thoughts and agree that it would be prudent for GFA to utilise the knowledge of senior members. Justin: I have no idea of your capabilities re GFA operational and regulatory issues - nor do I have knowledge of your GFA authorities and qualifications or personal aviation qualificationsl. Please advise. Your Utopian past really did exist and we had sufficient capability with the statesmanship of GFA and DCA officers to develop a very sound and universally admired operation which was adopted by many other international authorities. You may question my authority to make such a statement so see following. I was besotted by aviation at a very young age and was adopted by members of the Adelaide Soaring club at the time GFA was formed. I am probably the only member living that experienced its formation and proceeded through its entire existence to this day. I' ve lived, achieved and performed their dreams and my wife and I have mentored numerous youth into an aviation career. I'm appalled that current GFA officers have caved in to junior and unqualified CASA emplyees. FYI I wouldn't piss on you if you were on fire unless you can provide info. otherwise. Noel. -Original Message- From: Aus-soaring [mailto:aus-soaring-boun...@lists.base64.com.au] On Behalf Of Justin Couch Sent: Thursday, April 21, 2016 9:26 AM To: Discussion of issues relating to Soaring in Australia. Subject: Re: [Aus-soaring] T&S as a mandated instrument On 21/04/2016 8:40 AM, emillis prelgauskas wrote: There was a very good reason that gliding had 'exemptions' globally in the Regulations. To avoid this mismatch between commercial aviation and our sport specific needs. It's probably worth some time to chat with you privately to get some details on where these can be found. Unfortunately I am now far more intimate with both Oz and international airworthiness regulations than I really would like to be. If these exemptions do exist written down that you are claiming, I cannot find them, nor can anyone else at the GFA - perhaps they went up in smoke with the rest of our paperwork a few years ago? The regulatory framework that existed in the utopian past has changed, rather dramatically on us, so things that may have been in place before just don't work any more - if we can find the documentation of them at all. I see a lot of what is happening now as no different to then - someone finds yet another stupid rule, everyone mulls it over for a time, an exemption gets made according to the paperwork framework of the day, everyone shakes hands and moves on. I'd like to understand how you find this particular issue (T&B on MEL) any different to the fire-extinguisher example you cite. Both seem to involve a silly rule that doesn't apply to us, someone working out a way to get an exemption within the rules of the day, and everyone just moves on (and then 30 years down the track someone recounts it as a funny story of "Kids these days! Back in my day"). Including that the best results are achieved when GFA told CASA to stick it - that we are the experts in our sport, which needs to operate in specific ways in order to be safe. Remember the primacy - SAFETY. And, they in turn can tell us the same and stop gliding in it's tracks completely, or make it so financially uncomfortable for us to have the same effect. Neither is a good outcome for us. So, work out when to bend with the wind, and when to stand firm against it. Everyone has a different interpretation of that point. We, luckily, have some very good people on the GFA side that know the system inside and out as they deal with it professionally every day. So, when weird stuff like this happens, they already know what to do and slip in that extra one sentence into our paperwork so that the guys on the ground like you and I can continue to operate mostly unaffected. How does making the paper mound higher and in multiple mounds (the compliant, the interpreted work around, the reality) contribute positively to this? The argument that 'society demands this' is so hollow - as if the public bystander leaning on the aerodrome fence is able to tell the operator how to do things because of the unformed opinions - regulation by social media. The utopia of the good old days no longer exists and we do have to put up with this stuff whether we like it or not. I bet 40 years ago the elders of the time were decrying "
Re: [Aus-soaring] T&S as a mandated instrument
Further clarification (or maybe not) :-) There is a problem here, however! While Martin's answer is quite correct, it is not the answer to Justin's original question. It is one of the operational approvals I mentioned originally, but Justin's question was about certification. So while the CAO covers gliders in general, it does not cover the Polish gliders that had the requirement for a T&S as part of their type certificate (the document that must exist before a Certificate of Airworthiness is issued). That is where the solution must be found - to vary the type certificate so that a Jantar can be airworthy for flight in Australia (not in cloud) without having blind flying instruments. Wombat On 22/04/2016 8:12 PM, Mike Cleaver wrote: Thanks Martin - I've been off colour this week or I would have remembered/noticed that! Of course it is there! Wombat On 22/04/2016 8:38 AM, Martin wrote: CAO 95.4 , exemptions , (l) subregulation 207 (2) as far as the carriage of a gyroscopic turn and slip indicator and an outside air temperature indicator as prescribed in Appendix I of Civil Aviation Order 20.18 is concerned; On 21 Apr 2016, at 8:55 PM, Noel Roediger wrote: Emilis - I agree totally with your thoughts and agree that it would be prudent for GFA to utilise the knowledge of senior members. Justin: I have no idea of your capabilities re GFA operational and regulatory issues - nor do I have knowledge of your GFA authorities and qualifications or personal aviation qualificationsl. Please advise. Your Utopian past really did exist and we had sufficient capability with the statesmanship of GFA and DCA officers to develop a very sound and universally admired operation which was adopted by many other international authorities. You may question my authority to make such a statement so see following. I was besotted by aviation at a very young age and was adopted by members of the Adelaide Soaring club at the time GFA was formed. I am probably the only member living that experienced its formation and proceeded through its entire existence to this day. I' ve lived, achieved and performed their dreams and my wife and I have mentored numerous youth into an aviation career. I'm appalled that current GFA officers have caved in to junior and unqualified CASA emplyees. FYI I wouldn't piss on you if you were on fire unless you can provide info. otherwise. Noel. -Original Message- From: Aus-soaring [mailto:aus-soaring-boun...@lists.base64.com.au] On Behalf Of Justin Couch Sent: Thursday, April 21, 2016 9:26 AM To: Discussion of issues relating to Soaring in Australia. Subject: Re: [Aus-soaring] T&S as a mandated instrument On 21/04/2016 8:40 AM, emillis prelgauskas wrote: There was a very good reason that gliding had 'exemptions' globally in the Regulations. To avoid this mismatch between commercial aviation and our sport specific needs. It's probably worth some time to chat with you privately to get some details on where these can be found. Unfortunately I am now far more intimate with both Oz and international airworthiness regulations than I really would like to be. If these exemptions do exist written down that you are claiming, I cannot find them, nor can anyone else at the GFA - perhaps they went up in smoke with the rest of our paperwork a few years ago? The regulatory framework that existed in the utopian past has changed, rather dramatically on us, so things that may have been in place before just don't work any more - if we can find the documentation of them at all. I see a lot of what is happening now as no different to then - someone finds yet another stupid rule, everyone mulls it over for a time, an exemption gets made according to the paperwork framework of the day, everyone shakes hands and moves on. I'd like to understand how you find this particular issue (T&B on MEL) any different to the fire-extinguisher example you cite. Both seem to involve a silly rule that doesn't apply to us, someone working out a way to get an exemption within the rules of the day, and everyone just moves on (and then 30 years down the track someone recounts it as a funny story of "Kids these days! Back in my day"). Including that the best results are achieved when GFA told CASA to stick it - that we are the experts in our sport, which needs to operate in specific ways in order to be safe. Remember the primacy - SAFETY. And, they in turn can tell us the same and stop gliding in it's tracks completely, or make it so financially uncomfortable for us to have the same effect. Neither is a good outcome for us. So, work out when to bend with the wind, and when to stand firm against it. Everyone has a different interpretation of that point. We, luckily, have some very good people on the GFA side that know the system inside and out as they deal with
Re: [Aus-soaring] T&S as a mandated instrument
On 22/04/2016 9:16 PM, Mike Cleaver wrote: Further clarification (or maybe not) :-) There is a problem here, however! While Martin's answer is quite correct, it is not the answer to Justin's original question. It is one of the operational approvals I mentioned originally, but Justin's question was about certification. So while the CAO covers gliders in general, it does not cover the Polish gliders that had the requirement for a T&S as part of their type certificate (the document that must exist before a Certificate of Airworthiness is issued). That is where the solution must be found - to vary the type certificate so that a Jantar can be airworthy for flight in Australia (not in cloud) without having blind flying instruments. Thanks Mike, pretty much covers it. I've been a bit busy today with too many irons in the fire, so haven't had a chance to chime back in. I am (and was) aware of the original CAR/CASR exemptions, and mentioned it when it was first brought up in our club's audit. I don't recall the exact response at the time by the RTO/A, but it was very similar to this. In summary, it was felt that the CAR exemption applied to operational aspect of flying, but not the original (and ongoing from an airworthiness perspective) certification. The analogy used was that the CAR could amend/exempt the flight manual, but not the type certificate. Since CASA is mandated to accept the NAA TC/TCDS verbatim, and is not permitted to issue variations on them. Thus we end up in this apparently grey area legally. Now, I'm definitely no expert on this area, but I've been chasing down as much of the paperwork as I can to either prove or disprove this point about whether this is a correct assumption or not - and would love as much help on it as people can give. Mike C is probably our best bet on this due to his long time on the CASA side of the fence and intimate knowledge of all that stuff. Now, before everyone jumps up and down on the RTO/A and our Airworthiness department guys, please understand that I feel they handled the situation professionally. There was no panic/overreaction and immediate grounding of the gliders. The RTO/A himself was surprised by this as much as any of the rest of us. Also the discussions were held very tightly, only amongst those that know of the initial "eh?" moment - CADs, our club's AAO, myself, and it seems like one or two other poeple such as the Cobra owner from earlier in the thread. In fact, I wasn't in most of those discussions, until the very end when I got an email with the PU doc attached and a simple statement of "I think this should cover you". We were audited back in November last year, and this issue is only hitting the public now - some 6 months later. A far cry from the typical CASA response we've had in other situations. If we really do have a paperwork problem (yet to be proven or disproven either way I personally feel), I'm disappointed that people don't see the humour in that we've solved it by the application of a bit of sticky tape and string - vintage, old school gliding at it's best! Anyway, I'll shut up on this issue now and let smarter minds than me work out what the hell is going on -- Justin Couch http://www.vlc.com.au/ Java 3D Graphics Informationhttp://www.j3d.org/ LinkedIn http://au.linkedin.com/in/justincouch/ G+ WetMorgoth --- "Look through the lens, and the light breaks down into many lights. Turn it or move it, and a new set of arrangements appears... is it a single light or many lights, lights that one must know how to distinguish, recognise and appreciate? Is it one light with many frames or one frame for many lights?" -Subcomandante Marcos --- ___ Aus-soaring mailing list Aus-soaring@lists.base64.com.au http://lists.base64.com.au/listinfo/aus-soaring
Re: [Aus-soaring] T&S as a mandated instrument
At 11:48 AM 4/22/2016, you wrote:
GFA were left with 2 simple choices - fix the documentation (and
requirements) to meet with CASA audit approval in a very short time
frame or lose all airworthiness delegation with no prospect of CASA
being able to pick up, with the end result, grounding all
Australian registered gliders.
Really?
CASA is required by Parliament to administer the safety of civil
aviation in Australia. All of it. Gliders are VH registered
Australian aircraft, ICAO recognised. If the GFA doesn't do it CASA
can delegate to some other individual delegate or do it itself. CASA
Sport Aviation
did in fact issue Experimental certificates when GFA lost that
ability due to failing an audit.
In the last couple of years I've heard from many long term glider
pilots (30+ years in the activity). I've heard offers of substantial
sums of money to get rid of Denis Stacy, the bloke who introduced him
to gliding spontaneously apologised for doing it and a suggestion that
Australian glider pilots need a Glider Pilots and Owners Association
to protect them from the GFA and represent them politically,
something the GFA is clearly incapable of doing while it is a CASA
sycophant in order to fulfill its insane desire to be the SOLE controller of
all gliding in Australia. They are also appalled at the information
they are required to sign off on that is held by the GFA as they have
no confidence how this might be used by GFA or anyone else who demands it.
So if Matt Gage is right the GFA has cleverly manoeuvred itself into
a situation where its members can be grounded because of incompetence
or omissions by the GFA control group ("Leadership Group" seems to be
inappropriate for what they do).
Maybe it is time that Australian gliding reconsidered its
structure. Is the current setup actually achieving what was
intended? Are costs really lower than simply taking your glider to a
country maintenance organisation and having them do the annual
inspection. Seems
easier if all GFA is going to do is mirror the CASA Maintenance regs.
Maybe we should have a glider endorsement on the RPL or PPL or higher
license? Let CASA deal with 2500 individuals and 1200 gliders and
motorless gliders instead of ONE organisation, which is meant to
represent its members, being a convenient target for a
predatory bureaucracy.
Mike
Borgelt Instruments - design & manufacture of quality soaring
instrumentation since 1978
www.borgeltinstruments.com
tel: 07 4635 5784 overseas: int+61-7-4635 5784
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