1 Jan 2008 - the new laws

[John Young]

OK – Just exactly what are we fighting with Part 24, 62, 64 as well as all the other Pukking Parts, etc.

Frankly, I don’t think that any amateur pilot has a clue. No-one has yet put it down succinctly and in a way that all can understand.

Someone with more knowledge than the rest, please confirm or complete the following statements which become effective 1 January 2008, namely;

1. No owner-pilot maintenance. Maintenance may only be performed by AP’s, AMO’s and AME’s.

2. TBO for all 503 and 582 engines will be 300 hours.

3. No pre-owned trike will receive an ATF because …..

4. Only brand new trikes will receive an ATF because …………

5. Only genuine aircraft parts may be used – not Mercedes Benz Diesel Filters (as an example) etc.

6. Every AP, AMO and AME will be too S#$T scared to sign-off a microlight because …………..

7. Many airfields will be closed down because ………….

8. Many training schools will be closed down because …………….

9. Many trike pilots will be grounded because …………………

10. …………….

Skybound, where are you?

Lastly, David – support is guaranteed.

Regards
John ZU-CIB

[Hot Stuff]

Charlie Whiskey, could not agree with you more

[mike2flyfar]

David

One thing we are guilty of - is not communicating about these issues often enough. It is difficult because I am very busy and have limited resources ... but I took on the job so that is my problem. Anyway ...

As you know, I try to avoid dealing with you - but your latest, partially uninformed post, requires a response. I will get the facts from committee members (past and present), the Aero Club and the CAA and then will post a reply.

Of course I agree that there are many things that are not perfect and I constantly ask for input - so that if the majority of those affected agree, we can put regulation amendmants through. It really is so easy ... it just takes time.

Until we have EXACT details of what worries you with suggested amendments then no one will ever be able to help you.

Why don't you start with that? Maybe take one thing at a time ... put it here on these 2 forums for everyone to see and comment on and where everyone can have a say in working out a practical solution. Once we all agree then I assure you I will get onto it right away and will take it all the way (maybe in some instances we will do battle with the CAA and have to find a compromise) until it is promulgated or whatever. As you know I have already done this with some issues in Part 62 so I know what has to be done and am able to see it through.

Although Part 24 has been unchanged for a number of years, with promulgation now looming I think sorting out the problems in Part 24 is the most urgent. What do you think about that and if you agree what EXACTLY are the problems? Can you write it all up verbatim from the regulations as they are now - and then write up the the exact solution?

Thanks
Mike

PS I too would love to see a resurrection of trikes. Good luck.

[skybound®]

I guess to refresh we may need to read through some old posts:

viewtopic.php?t=4681

[skybound®]

I would also hazzard a guess here that even the CAA are not sure about how to implememt all these new bits of law.

I suggested a while back to CAA that they should embark on a road show to address our concerns and how they were practically implementing these new regs. We as the general pilot have no idea as how we need to copnduct ourselves from 1 Jan 2008.

[Brian Young]

Hi David, did you not in the past submit a change recomdation of 62 and 24 and it was ignored????
Mike all you have to do is read some of the posts to know what is the problems with the legislation. There is no reson that it had to go to the rediculous level this effects all microlighters, Aero club new of this 2 years ago why did they not do somthing about it ???????? Niel is a ex Micrlighter????
Regards,
Brian

[Tumbleweed]

Now we're getting somewhere.

[Gadget]

Mike, Dave, please keep this discussion live here so we all know what is going on. I have heard so many different tales in the last year that I don't know if if I should fly forward or backward anymore and frnakly i think it is annoying the sh!t out of every one, especially the paid up members who still believe a body is neccesary to protect us who don't know jack about legislation and just want to whirr up the motor.

I for one will not give up flying, authority to fly or not. I keep my bird safe and I stick with the rules, but if someone out there is making ridiculous decisions let them try stop me and i will give them a piece of my propwash ortwake turbulence(depending how big they are)

We have all invested a lot of money in our sport and cannot let the un-informed dictate tot us.

P.S. How many trike or microlight pilots work for the CAA?

[skybound®]

Mike, Dave, please keep this discussion live here so we all know what is going on. I have heard so many different tales in the last year that I don't know if if I should fly forward or backward anymore....

Gadget it can be daunting and there are many out there that seem to provide misinformation and more often than not - mostly unintentionally. I think it stems from the mood or attitude that since some of these regulations seem so far away from what should logically be expected, that people are flobbing off the truth and ignoring it.

I am the first in line to say that if someone gives you a piece of information - request them to provide their basis of the info. If it is regarding the regulations, request the regulation number or paragraph to support their argument. I would be hesitant to enter a debate without that level of support for my argument.

Playing some devils advocate here, if this was so close to MISASA member's hearts, it begs the question as to why only 18 people saw it important enough to attend the AGM where feedback on the new regulations was on the agenda.

[Harlequin]

Skybound and others.
There are many pilots who would have liked to attend the AGM but live in Cape Town. This absolutely does not mean we are not interested or do not give our support. Granted, there are some who are not MISASA members.
As mentioned, please keep this one live until there is some closure.
Thanks for the effort chaps.

Graham

[skybound®]

There are many pilots who would have liked to attend the AGM but live in Cape Town.

Undestand that fully since I am in PE and always grumble under my breath when all the meetings are based elsewhere. At least you okes had an inkling of having an AGM in CT a few years back.

Does not always mean that since the meetings are in JHB that we cannot participate in some limited way. It is possible.

Maybe next time around we could 'bid' for the AGM. The currency to be used could be number of souls to attend

[lamercyfly]

Hi John.

I will try my best to answer your questions. Many of them have been answered in June, on another page on this group.

It is very difficult to give you cut and dried answers. The laws are intertwined, and many times the interpretation can make all the difference. Just ask folk trying to get build numbers for their home-built imported kits, and you will see the CAA's Mr Mamba interprets things his way, which is so, so blantantly different to how the applicants interpret the same law. In these cases, matters would have to ultimately be interpreted by a court of law.

So, here's my best at helping you understand............my answers in bold


1. No owner-pilot maintenance. Maintenance may only be performed by AP’s, AMO’s and AME’s.

Yes, this is very clearly stated. See previous thread, reference to it on Page 1 of this topic I think. the applicable laws are stated cleary.

My Opinion :- I would like to see CATS-GMR removed from the equation. Does not belong in NTCA microlights. At the worst, I would like to change the wording to remove the word DIRECT SUPERVISION to SUPERVISION. This would be a win-win, as I have been exposed to really silly things, some of them with serious consequences, due to mistakes made by pilots doing their own maintenace without asking for help. So, I would like to say that owners of microlights operating outside of Part 96 (commercial) may do their own maintenance, as long as they are doing it under supervision. This supervision may be telephonically, by letter, e-mail whatever. Obviously, to remove confusion the supervising person my be an AP..

2. TBO for all 503 and 582 engines will be 300 hours.

Yes, also very clearly stated in the rotax maintenance schedule -see previous thread about this topic, copy of schedule was posted.

What I would like to see:- there are many options open to us pilots on this one, but the win-win, I believe, will be to offer the commissioner a proven, viable and very user friendly option. This involves doing a kinda
'shock compression' induced test at certain hours. This is a 20 minute test, which involves taking one spark plug out of each cylinder. NO opening of engine, NO compulsory TBO etc., When the reading on the dial exceeds the accepted, proven by industry limits, then you recommend to the owner that his crank gets done. So, we amend the Rotax maintenance schedule, and draw up our own.

3. No pre-owned trike will receive an ATF because …..

Well, as soon as the hours pass 150, unless the ol' rotax has been stripped down and the pistons and barrels and rings mic'd, then it is not going to get the AP's stamp......... See the maintenance schedule. There are also a couple of other issues that will make the AP really think hard before signing the aircraft out as Passing an inspection. The law is, however, very clear on the fact that the airworthiness of the NTCA is the responsibility of the OWNER. But, the AP is going to spend a lot of time pouring over your logbooks (yup, 3 of them, one for engine, one for propellor and one for undercarriage and wing) making sure they are ALL accurately filled out, all balancing, ALL maintenance entered and recorded etc., He accepts this responsibility by signing. He may ask for your personal logbook to compare hours etc.,

What I would like to see:- The above resolved by compliance to Question 3. I would like to see ONE logbook, but with columns for Engine, Wing, Undercarriage and Propellor. Annie and I have designned one which we have been using for about 2 years now. The reason is that Trike pilots change wings, sometimes just the fabric, other times change the wing completely, then other times we swop engines, or upgrade to a 582 etc., so to me it makes sense to keep separate logs of these items, but in the same logbook. That said and done, I am not aware of any Fatal Accidents in SA microlighting because we were not keeping 3 or 4 logbooks. So, possibly an overkill to keep all these separate logs, but an issue which needs industry input. I'll gladly go with industry on this one[/b]..

4. Only brand new trikes will receive an ATF because …………

Because the AP will know his backside is covered :D

5. Only genuine aircraft parts may be used – not Mercedes Benz Diesel Filters (as an example) etc.

this is a sticky one. The manual says 'Only genuine blah, blah, blah... But the local agents for Rotax recommend a Mercedes Diesel filter etc., many other examples......... I doubt CAA or an insurance assessor would try to argue this in a court of law. so I do not see much changing if you use what every one else is using. However, if you wish to change, and use Glass Fuel Filters (could'nt resist that one) then you are opening a can of worms.

What I would like to see:- You can use components which are not original factory issue, but that you should consult with either the factory or an AP. What I would like to see in Trike laws is more 'recommend' and more 'advised' and more 'we suggest' and less 'you will' and 'do it this way only' etc.,

6. Every AP, AMO and AME will be too S#$T scared to sign-off a microlight because …………..

Because of the Responsiblity which comes with only earning R500.00 Kinda need to charge R3000 and take out an insurance policy...... Also the friggin schlepp factor in the administrtion side of it....All the log book checks, reconciliation of times to maintenace (ie check that the plugs were changed every 25, so you have do the sums etc.,)

What I would like to see:- AP's remain the way it was (by default we were just glorified pre-flight inspectors ). It remains the pilots sole responsibility to keep his aircraft airworthy and legal in all respects.

the question begs to be answered again, how many fatal deaths and accidents are as a result of poor logbook maintenance?

Industry consultation on this one definately, as it could turn into a huge schlepp, but then again it can greatly increase the resale value of your aerie and just save your butt in the event of an insurance claim....

7. Many airfields will be closed down because ………….

this has nothing do do with part 24, but is a situation which has arisen due to DEAT. Unless you have an EIA done (if it is a new operation) or just a basic assesment , you will be operating illegally - the use of the airfield that is.......... Sorry, I am getting tired now, and my 6 year old son is listening to Uriah Heap while my 4 year old is doing break-dancing to same music........) Like I said, Overberg School Of Microlighting has already been closed down. Sure, if your airfield is a noise issue, but a private farm strip nowhere near anybody?

8. Many training schools will be closed down because …………….

I am not aware of many training schools whose aircraft have less than 150 hours on the cranks....... Training schools are also going to have to be operated as part 96 commercial operations. This means the AP's will have to be CAA approved AP's, not Aero Club or MIsasa etc., The framework for these AP's is not in place, so as of 1 January, who is going to AP school planes? Other issues as well. Also, to do flips is going to be a real issue, and a whole bunch of schools rely on the income from flips to support the meagre income from training. Once part 62 is in, then CAA will have the legal framework to prosecute anyone attempting to do flips using the lesson 3 under a part 141 training school.

What I would like to see:- microlight schools get removed from this 'commercial requirement, and secondly that schools be allowed to do flips. We applied, as an industry, to the last man, at the instructor seminar in 2005, to the CAA representative to present an application to CARCOM for flips to be allowed. this was not done. Annie and I then re-applied directly to Herman Wildenboer at CAA. Nothing came of this either. We can play our cards now, as on 2 occasions CAA have acted blatantly outside of the law.......... Will see


9. Many trike pilots will be grounded because …

Well, the pilot won't be grounded, the aircraft will..........But hey, that has not stopped the boys in the past hey

Hope this helps a little John. Ate up lots of time that I could have spent studying the law, but what the hell..........

I feel that I have not really answered your questions, but I hope that you will trust that between myself and a couple of other folk we are going to make sure that us microlighters keep on flying (espcially trikers

Regards.

………………

[skybound®]

The EIA issue (no 7 above) can also be used as protection of an airfield - so dont think we should be too hasty in wanting to toss that one altogether.

We have a case in point where a theme park with tourist accomodation wants to open up right next door to our airfield. As we all know that as soon as people move next door to an airfield the noise and even sight polution rears it's ugly head - even though the airfield was there a million years before the new development and property price adjusted accordingly via normal market forces.

They have now been ordered by the DEAT to undertake a full aeronautical impact study as part of their EIA. Not sure how it will all pan out, but at the very least there will have to be the aeronautic factors that cannot be mitigated by the developers. We are quite happy if the development goes ahead - but the day they complain about circuit noise or low flying traffic - will refere them straight back to the aeronautical part of their EIA.

So it does help cut both ways.

[African Grey]

Howsit Dave and others...

Just on the E.I.A story although separate to CAA and Law making etc...for me probably one of the biggest Prohibitive factors in our sport in times to come.

With development happening all over, to establish a New Airfield (Circus Airfield) especially for a Training facility has now taken me 3 Years and 7 Month to finally get all the permissions in place.......

The EIA covers everything....from Public meetings, comments, advertising, geological surveys, extensive environment factors and.....wait for it......"Migratory patterns of wildlife in the area".....!!! We sit between the R59 and a Railway Line....?

Then the Council require Land Use Applications and or Rezoning which must include comment from The Dept of Public Works and Roads...any one of these can scupper your project...

Cost of this lot excluding the time runs into tens of thousands closer to Hundereds....so starting an airfield think again or ask me where my savings have gone...will gladly assist

More on the more relevant subject.
My school had a "Short Notice Technical Inspection" done by CAA some 3 weeks back. I asked the Inspector questions similar to John's. None could be answered. Subsequent calls to CAA / Technical /Training Heads etc revealed that NOBODY could clarify the situation or give a direct answer (even a gent I spoke to who apparently sat on the CARCOM committee)

It looks to me that CAA need assistance from our industry in implemention and or modification of this impending law be it through directives delaying implementation from the Commissioner or otherwise.

Both Dave and MISASA have my full support and will assist wherever I can.

I just love flying....!

[John Young]

I hope that you will trust that between myself and a couple of other folk we are going to make sure that us microlighters keep on flying (espcially trikers)

Thanks to mike2flyfar, lamercyfly, skybound ®, African Grey and others.

Special thanks to Dave Daniel for taking the time to answer all those questions.

These issues are going to require cool heads, good leadership and strong rational thinkers to present our case/s if we hope to have a chance of reaching a win-win situation.

Thanks to all who are proceeding with these daunting tasks.

Regards
John ZU-CIB