PART 24 - Airworthiness: NTCA

[RudiGreyling]

OK it has been discussed at length here on the Forum, I am a bit late to post this, but I thought it still important to have it here, for future reference.

When I get anything on the anticipated Statement on 7 December I will also post it here

Regards
Rudi

To summarize about the CAA industry liaison meeting yesterday: The CAA CEO and acting Commissioner are aware of the problems with Part 24 and are working on finding a solution … probably in the form of exemptions until the amendments to the regulations are promulgated.

1. NTCA DEVELOPMENTS
Amidst rising emotions, borne out of frustration of affected parties, today's Industry Liaison Forum has injected a glimmer of hope regarding the NTCA issue. In his capacity of chairman, the SACAA's CEO, Mr Zakes Myeza, once again guided the proceedings in such a fashion that representatives felt that the first inklings of an emerging solution is appearing. The acting Commissioner, Mr Gawie Bestbier, proposed that the CAA should internally revise policy and issue a statement to that effect by 7 Dec 2007. With such policy in place the CAA will then continue its deliberations with industry representatives who form part of a workgroup tasked to deal with this issue. This workgroup, which will have members of EAA and Aero Club, will amongst others formulate the criteria for interim exemption from the application of regulations that have led to the current stale mate situation. Senior management of the SACAA were in agreement with GA representatives that urgent attention needed to be given to the issuing of this exemption to alleviate hardship caused by restrictive practices relating to the issuing of build permits, authorities to fly and the registration of NTCA aircraft.

Mr Myeza's timely intervention, supported by Mr Chakarisa and Mr Bestbier, has the potential to arrest the damage caused to industry so far and will be recorded as another example of his sound leadership.

[grostek]

Looks like the NTCA update scheduled for Dec 7 2007 is still in the SACAA system.

Ah well, all comes to those that wait (patiently)

Gunter Rostek

[RV4ker (RIP)]

This off the EAA mail group this morning...

All thanks to you & the others that helped with the NTCA effort. Many meetings have taken place between the Aeroclub & CAA.

It surely helped the the Commissioner, Mr Gawie Bestbier attended the NTCA Workshop, where we highlighted the various problem areas in the various parts, including the interpretation of many requirements.

Immediately thereafter the various bodies got meetings going & initially started dealing with individual plane requirements & the administrative handling thereof.

Of course the submission of illustrative documentation helps too.

As this weekend progresses, Gawie Bestbier & Neil de Lange are putting heads together to come up with solutions on our NTCA problems areas. They hope to get the documentation thru the system so that a fair amount of "fixes" can be implemented by middle Jan 08. Anyway, this is the goal they are working towards.

They have my admiration & thanks! Also all the unknown volunteers putting their valuable time into this effort!

[RV4ker (RIP)]

From CAA section on Avcom

Joined: 18 Feb 2005
Posts: 341
Location: Midrand

New postPosted: Fri Dec 07, 2007 8:28 pm Post subject: Discussion Document - NTCA Policy Reply with quote
CAA will release a discussion document on NTCA policy on Monday. The deadline of today, Friday, 7 December 2007, could unfortunately not be met due to major unforeseen events having to be attended to during the past two weeks.
_________________
Kind Regards
Mary Stephens
Senior Manager: Client Services
SACAA

[grostek]

This is good news because things are moving in the right direction.

Thanks to all who are working in and out of the spotlight to rectify the current NTCA situation.

Kind regards,

Gunter Rostek.

[RudiGreyling]

For your information, from the MISASA committee email group.

I have received some correspondence where the acting Commissioner is addressing all the issues on Part 24 … unfortunately he has not yet decided how to handle it, but I hope to hear this week still.

[skybound®]

http://www.avcom.co.za/phpBB2/viewtopic.php?t=28009

If that is the extent of the relief - we are screwed come 1 Jan 2008.

[RudiGreyling]

Update:

I have just got off the phone with Neil …BTW, Neil mentioned to me that they have made excellent progress and it is important that their efforts are not damaged by antagonizing the CAA through irresponsible and ill-informed statements - so if anyone knows of a problem or if anyone wants more info can you please let me know or if there is anything I need to address to prevent that from happening. As I get more information I will let you know.

Can you please post this and the CAA statement on microlighters."

On Part 24, Neil de Lange (Aero Club GM) and Stan Oliver (Aero Club Chairman) had a meeting with the CAA acting CEO and the acting Commissioner yesterday and thereafter the CAA issued the statement – see below.

There are many issues to be dealt with (the initial list has 20) and the priority today is the 100 odd aircraft that need to be registered, build numbers issued etc. - of which quite a number are microlights. That said, there is no less priority on the maintenance and other issues that affect everyone. As per the CAA statement a working group is being formed to also deal with all the Part 24 and Part 94 issues. The first meeting of this working group is to be Friday the 14th. The process of amending the regulations could take from 2 to 6 months - in the meantime the working group will address each specific problem and will advise the Commissioner on the short term solutions where practical. I will be able to confirm who is in the working group by Friday.

CAA DISCUSSION DOCUMENT: SACAA POLICY STATEMENT RE NTCA

11 December 2007

The South African Civil Aviation Authority (SACAA) considered the urgent issues, relating to various NTCA matters raised at the SACAA-Industry liaison meeting held on 27 November 2007, and resolved as follows:

Flowing from amendments to various applicable Parts of the Civil Aviation Regulations, as well as its corresponding Technical Standards, which amendments have caused varying degrees of unintended difficulties, a considerable number of aircraft in the NTCA sector are not being allowed registration on the South African Aircraft Register.

Most of these aircraft would have qualified for registration under the previous legal framework. Consequently, some of such aircraft are registered irregularly at times.

In order to remedy the immediate status quo, the following course of action will apply:

A special task group comprising of senior SACAA technical staff and technical experts from the industry be formed to consider and recommend proposals to address the problem areas highlighted by industry and experienced by SACAA. The proposals shall form the basis for addressing any other matter related to NTCA and should include proposals for future regulation of this sector, with specific reference to commercial operations and applicable limitations. The proposal shall then be referred to the SACAA, with the differing points of view, and the reasons for consideration.

In parallel and at the same time, the task group will consider and recommend the required amendments to the regulations and technical standards to resolve the recurrence of these problems in future.

For NTCA aircraft awaiting registration, consideration will be given, by SACAA, to the history and commencement of individual projects, where applicable, as well as the current and historical legal requirements and registration status in the international arena.

Following the outcome of the task team, such proposals shall be evaluated and, where necessary, amendments will be submitted as a matter of priority to the CARCOM secretariat.

While the process is ongoing, the following has to be re-iterated:

The Parts 24 and 21 requirements for substantiation will be applied strictly in the importation of any NTCA aircraft. No aircraft without substantiation, as per Part 24 and 21, either existing at the SACAA or available in advance, before approval for import, will henceforth be approved for importation or placement on the South African Register.

In summary the process will unfold in the following manner
A.Selection and Commissioning of Task Team.
B. Clear terms of reference supplied.
i) Task Team to give project plan.
ii) Benchmarking for informed input.
iii) Review of existing documentation on the subject matter.
C. Submission of possible solution to the CAA.
D. Consideration of outcome by CAA and compiling a draft policy.
E. Seek public input both internal and external on the draft policy.
F. Refer clarification arising from public input to subject experts in the Task Team for further recommendation.
G. Compilation of final draft policy to be submitted to the Safety Committee of SACAA's Board.
H. Adoption of final policy.
I. Presentation to CARCOM on regulatory changes.
J. Update of guidance material.

[RudiGreyling]

Ok now for my personal opinion...

Let's keep calm, there are a lot of problems, and the 100 odd aircraft waiting for registration is the biggest concern, with the biggest financial impact, our maintenance problems are smaller in comparison.

It would have been nice if CAA could have issued a status quo on the maintenance issues, but then again there is only so much that can be tackled at the same time.

Let's keep our fingers crossed, while Mike keeps his finger on the pulse.
Contact Mike if you have queries or concerns!
Mike Blyth [mike(AT)aviation-engines.co.za]

Regards
Rudi

[RudiGreyling]

Mike asked me to post this, correspondence between Neil (Aeroclub and Him)

Dear Mike

The CAA issued a policy statement on the immediate way forward regarding NTCA.

Herewith some info relating to this document;

The policy deals with principally two issues;

1. A queue of disgruntled and unhappy chaps who, for one reason or another, can not get their aircraft registered, or can not obtain a built number,

2. A way forward on the interpretation or amendment of Part 24 and 94 ASAP.

Keep in mind that Part 24 and 94 was effected a number of years ago to "test" it, but it was never promulgated.

This is undesirable.

Now it will be promulgated.

Problem is, suddenly it is interpreted differently, more strictly, and in places, seems to have been amended(somehow?)

As far as the policy issued Dec 11 2007 is concerned, the first meeting of the task team is scheduled for Dec 14 2007.

This is the earliest opportunity as the CAA executive must first approve the members of this committee, and this is scheduled for Dec 13 2007.

The plan agreed at the preliminary meeting is to group the "problem cases" of aircraft struggling to be registered, e.g., 8 RV7 a/c struggle due to some document on analysis not at the CAA. This will be one decision fits all, and the required amendment to the regulation proposed.

The above will be done to all aircraft with BONA FIDE problems. Where the applicant has not followed due process, he will be requested to do so.

During this process, various other refinements to the regulations in question will be recorded, so as to prevent recurrence of the above. This will however follow the ordinary CARCOM process. Whilst in process, the Commissioner may grant exemption in terms of Part 11 to introduce these refinements until such time as the refinements are promulgated.

We are working on a solution urgently.

Regards

Neil

Mike Comments:

Apparently the intent of those writing the regulations was never to restrict recreation aviation to the extent it will, once Part 24 is promulgated. Everyone, including the CAA agree on that. The question is how to fix it. You cannot just re-write a part of the regulations – there is a whole process to follow … and also the Commissioner will not do the same (by way of an exemption or whatever) on pressure from one group or another. Everything is carefully considered before any decision is made or regulation changed.

I have been at the CAA many times and the diversity of problems and issues they are dealing with, is immense. They have a high staff turnover and some of the staff are inexperienced. On top of that they often prefer to delay decisions rather than take the bull by the horns and get things done.

So we (the Aero Club and it’s sections) have to push for change and do most of the work …. such as re-write the regulations (after consultation) and then submit them for approval, get everyone to OK them and when that has happened then we can try to persuade the Commissioner to issue an AIC or put an exemption in place pending the promulgation of the amendments.

Initially I thought that there were just a few small issues, but I soon realized there’s lots and that means a lot to do …

One thing for sure, most of the CAA are positive and want to see these issues attended to and working solutions put in place.

If they didn’t then I would be worried. … so now it is just a matter of time!

I’ll keep you informed of the progress.

Cheers
M

[JACO]

HI ALL

QUESTION ?

MY AUTHORITY TO FLY ON MY WINDLASS 582 EXPIRES IN FEB 2008,
1. DO I KEEP ON FLYING COME 1/1/08, AND TRY TO RENEW IN FEB,
WITCH MAY OR MAY NOT BE ALLOWED OR
2. DO I AP AND RENEW NOW, IF CAA WILL ALLOW ME, AND KEEP ON
FLYING TILL NEW RULES AND REGULATIONS COME INTO AFFECT OR
3. STOP RENEWING AND FLYING ALLTOGETHER ?

CAN I BUY MYSELF SOME TIME ? I BOUGHT THE TRIKE A YEAR AGO,
BEGAN LESSONS, AND INTEND TO SOLO IN JANUARY. WILL BE A SHAME TO HAVE SPEND ALL THE MONEY FOR NOTHING

[skybound®]

Has anyone got any advice on how to get people to take you seriously and not to think you are talking nonsense?

Look at the date the warning shots were fired - even before gazetting of the current state of affairs.

viewtopic.php?t=4681

[RudiGreyling]

Hi Jaco,

Everybody is asking the same over here..viewtopic.php?t=6110&highlight=

Short answer is we do not know yet?!?!
If I were you I will wait as long as possible, and see if we get the right guidence.
And No #3 is not an option !!!

Regards
Rudi

[RudiGreyling]

Has anyone got any advice on how to get people to take you seriously and not to think you are talking nonsense?

Look at the date the warning shots were fired - even before gazetting of the current state of affairs.

viewtopic.php?t=4681

Skybound,
Good you picked it up early, you are awarded the early bird gets the worm award!

It takes time to make people aware of it, I think your post started getting it into the general pilots mind. Before that I did not even know about part 24 or changes I just merrily enjoyed my flying. After a bit of education I also saw how important it is, then when you have enough people concerned will the powers at be react.

6 Months in government time is = 1 week in normal business time!

PS: Talking directly to people in power also helps instead of talking the general population. The people in power don't always visit forums regularly. So they think everything is fine, but when the population riot start they notice and sit up.

Regards
Rudi

[skybound®]

[quote="RudiGreylingSkybound,
Good you picked it up early, you are awarded the early bird gets the worm award!
Rudi[/quote]

Got it already Rudi



Please dont get me wrong - not pointing the finger at our represenative bodies - every individual has the responsibility to know what is going on around them and to escalate these things. The reason I did not make contact with the likes of MISASA is I do not currently own a Micro (or even a NTCA for that matter) and am not a member currently - hence no right to call upon them. I did have some assistance from SAPFA where I am a member, but they are not that heavily affected.

Just for the record too - I am no way involved commercially with aviation, I am an IT manager working for a professional services firm. (I got asked this a while back)