CASA and RAAus want us all to discuss the paper that proposes an increase to the MTOW limit of 600kg imposed on aircraft on the RAAus register (and other ASAO’s) to 760kg. So, I’m going to give you my view. This is not necessarily the view of AOPA Australia – and it’s likely not the view of the majority for RAAus members, who may stand to benefit from the increase. Of course some RAAus members won’t care, because they will never fly aircraft over the current MTOW limit. And some GA pilots will not care all that much either; many ultimately don’t consider an RAAus license unless AVMed says that they are an unreasonable risk in the air on medical grounds.
There are big stakes here for RAAus. If adopted, the provision could boost their coffers and its membership base as GA pilots turn to RAAus for registration and membership of their aircraft. Naturally, this growth could be accelerated further in time if medical standards are not changed across the recreational aviation space – and CASA insists that GA pilots need at least a Class 2 (or Basic Class 2 Medical) to fly their recreational type.
HISTORY & READINESS
Of course CASA and RAAus have been working closely behind the scenes on this project for many years – and the latter has been promising the weight increase to members for some time. To its credit, RAAus has been continually trying to prove to CASA (and the broader aviation industry) that it is ‘mature’ enough (their phrase) to deal with the increase in weight and the growth that could inevitably follow. Their ‘maturity’ has merit in many respects; the organisation has shown that it has the financial and administrative capacity to handle a large number of aircraft and paying members – and it has gone to some lengths to recruit adequate IT systems and people-power to do this job well. So far, it has been a successful business model and the customers appear to be relatively satisfied with their lot – many of whom would not be able to fly if AvMed had their way.
INVITATION TO CONSULT
In a carefully worded note to members yesterday, RAAus invited members to submit their opinions by filling in the discussion paper – and CASA has invited everyone to have a say. I’d encourage all AOPA Australia members to fill it in for the sake of balance and sample size.
Here’s the link for you if you’re interested: https://consultation.casa.gov.au/regulatory-program/dp-1912ss/consult_view/
IS THE MTOW INCREASE A BIG DEAL IN A FLYING SENSE?
Let’s be clear; despite the RAAus claiming that less momentum is more safe, to fly an aircraft that’s heavier that 600kg MTOW is not in itself more, or less, dangerous than flying a heavier type. It’s not from an aerodynamic or pilot skills standpoint. And certainly not from a medical standpoint. It’s just different. Some pilots transitioning from RAAus to GA find the increased weight takes a bit of getting used to because of less drag and more momentum, but equally when this is reversed there are other issues at play. I would say each is as difficult (or risky) as the other when all is said and done.
The real issue in play is of pilot competence. That is, the pilot’s ability to fly that type of aircraft safely from the standpoint of skill and capability. I know this because I’ve flown aircraft that challenged me – and I’ve taught others how to handle types that they need help to fly safely. It’s about ensuring competence on type, not of aircraft weight per se.
TRAINING & FATAL ACCIDENT RATES
With that topic over to one side, let’s talk about training specifically. I have known pilots transitioning from both sides of the (rather unfortunate) GA / RAAus divide that simply lack appropriate skills and techniques required to fly a wide range of aircraft. This comes from the fact that flight schools across the board are still not teaching to an appropriate standard or providing students the skills needed to transition into a wide variety of types – and also from pilots themselves who insist on flying all sorts of aircraft (heavier or lighter) without the confidence, skill, familiarity and recency to handle them properly. Weight, in itself, remains irrelevant in this equation.
Looking at the published fatal accident rates, the numbers support this hypothesis. Trending fatality rates were roughly equal in 2016 and generally speaking, have remained so across the years. There is simply no valid argument for increased (or decreased) MTOW contributing to fatal accidents.
If one was to publish the private thoughts of many DAME’s across our land, you’ll surely reach the conclusion that a recreational pilot is just as likely to suffer an asthma or Myocardial Infarction in a 760kg aircraft than in a 600kg aircraft. There simply is no valid argument for not having self-declared medicals on both sides of the fence. For CASA or RAAus to defend their members rights to medical privilege by using a self-declared system, while others are denied the same right, is pure nonsense.
A big, unexpected speed hump has arisen with the CASA consultation paper and I think it took everyone, including RAAus by surprise. The RAAus has been consistently peddling the notion that maximum stall speeds would naturally increase with an increase MTOW. It makes sense, aerodynamically. But, CASA seems to have other ideas because the consultation paper seems to assume that stall speeds should remain unchanged. This is curious because, to my mind, either RAAus was being less than transparent with its members, or alternatively, CASA is throwing a curve ball at RAAus to limit the number of types that could be included in any provisions for an MTOW increase. Either way, it’s embarrassing for RAAus, who will, no-doubt be rallying their CASA contacts to ensure this issue is resolved if an MTOW increase is granted.
Here’s an extract of the CASA discussion paper on this point:
“The proposed amendment to the MTOW limit would not change the limitations that presently apply to stall speeds or minimum useful load requirements.
Not all of these aeroplanes would meet the additional requirements of clause 1 of CAO 95.55; such as maximum stall speeds (45 kts) and minimum useful load calculations. Therefore, the actual number of aircraft effected would likely be less.”
And here’s the RAAus response to members which looks like a massive ‘back-peddle’ to me.
“RAAus will address this point in a formal response to the consultation however we need to ensure members are aware of the RAAus position. As aircraft weight is increased, in many cases so too does the stall speed. In rebuttal to restricting the stall speed to 45 knots, RAAus argues the Recreational Pilot Licence (RPL) and the Recreational Pilot Certificate (RPC) are similar….”
It goes on to attempt to explain a connection between stall speeds in RAAus and a conversion to RPL, which naturally allows converting RAAus pilots to fly aircraft with various stall speeds. Not many RAAus pilots will convert. So this, to me, is a moot point. This consultation should surely be about RAAus pilots and their registered machines exclusively as the consultation paper applies to RAAus – not to GA.
The RAAus explanation and their promise to ‘address the point’ either reeks of naivety in assuming that CASA was expected to include the provision (perhaps as promised), or, an admission that they forgot to specify how important the stall speed issue was when negotiating with the Regulator. Perhaps still it’s just a bit of PR to soften the impact of knowing that they were unlikely to deliver what they were ‘promising’ all along? In any event, the question of why CASA failed to contemplate stall speeds going up commensurate with MTOW is curious at best – and makes this whole exercise largely academic, not practical if adopted in its current form. Stall speed simply must increase with MTOW.
WHAT AIRCRAFT TYPES ARE AFFECTED
This is really interesting. What is actually likely to happen if an MTOW increase is granted is that aerobatic experimental types, like RV3,4,6 (and maybe some 7’s) will be included in the RAAus register at 760kg MTOW. But these are aerobatic aircraft. The provisions will be permitting flight for pilots operating these types, while disallowing the full flying capabilities of these wonderful machines. It’s just disabling aircraft so that some pilots can fly them ‘straight and level’. Add to this the fact that GA pilots are not allowed to fly them (because they have numbers on the tail), and we have created a nonsensical rule that denies full access to some beautiful aircraft.
Some types, like Cessna 150/152, Tomahawk, Sling 2 (at a new 700kg MOTOW) will be allowed into the fray. This is a great thing because the aircraft will be unlimited by weight – and it’s also good that manufacturers will be able to look to designing and manufacturing better aircraft, rather than having to restrict themselves to an arbitrary 600kg MTOW limit.
OPTIONS FOR CONSIDERATION
The CASA discussion paper is clear and concise. It essentially presents us with two outcomes. One, keep the regulations as they are. Two, allow a MTOW increase but no change to anything else, including medical standards and stall speeds (for now).
I know which way I’m voting. Yes to the MTOW increase. It would be good for the industry, assuming the stall speed increases. But if they do adopt these provisions, we need to assume that CASA will also take on self-declared medicals for the entire recreational industry (for the same aircraft types).
If they ignore this huge elephant in the room, CASA will remain the only aviation regulator in the world to take on the job of extending well beyond their aviation safety remit by assuring the growth and financial stability of a private member company. They would be signing off a set of policies that remain unfair to – and that stifle the growth of – the remainder of the recreational aviation industry. And that would be simply rotten at the core.
It’s over to you to have your say. You can find the consultation paper at: