Monday, November 10, 2008

Justification For Change

Below is part of our submission to CASA for a weight increase. Both new and older members may be interested in this section as it details our history and safety stats.

Sorry, I can't seem to bring over the graphs.

John McK



CAO 95.10 was introduced in 1976. The rules were draconian, because it was all about control in the name of safety. In those early days the participants were not allowed to fly above 300' and they were not allowed to use two seat training aircraft. The engines were single ignition two strokes, (at the very beginning converted mower engines) so it is little wonder that untrained pilots who suffered from a sudden loss of noise, stalled at low altitude or had little option but to land straight ahead regardless of terrain and where only limited by the current days rules and red tape.

The fact that anybody survived those first few years is a credit to man's ability, fortitude and ingenuity. The fact that people insisted on re-inventing the wheel was a price that had to be paid to achieve the innovation in regulations, materials, engines and electronics that the movement enjoys today.


It is also now a historic fact that those very rules, which were put there to "protect" the public in fact, took a heavy toll on the participants.

Explanation of RA-Aus Membership Vs Fatal Accidents.

The repositioning of weight and performance barriers has had no impact on the general public over the history of RA-Aus but has meant huge safety benefits for the pilot/participants.

Ø 1985 CAO 95.25 "Flight Below 300" was raised to 500' and legalised two seat training approved. MTOW was increased to 400 kg. Within two years there was an improvement in the accident statistics. 1985, Fatality to membership ratio 1: 230, two years later 1: 480.

Ø 1990 CAO 95.55: Height limit was raised to 5000', (Higher with operational justification) MTOW 450 kg. Once again within the two year period we see an improvement in the fatal accident record. 1990 1:480, 1992 1:600.

Ø 1993 CAO 101.55 amended to allow 480 kg MTOW in accordance with energy formulae. The improvement trend continues with an improvement in the safety statistics. 1993 1:825, 1995 1:1800.

Ø 1998 CAO 95.55, Introduction of Amateur Built (Experimental), 544 kg MTOW. This was the start of a membership number increase, which has continued until the present day. There was a spike in the accident rate 2002/2003, (almost parallel to the increase in participant numbers), however a perusal of the accidents does not reveal any obvious pattern. They appear to be random events and since then, the trend is once again showing a continuing improvement in safety. The introduction of 544 kg. has allowed the use of four stroke engines and the legal carriage of both extra fuel and passengers.

Ø 2006 CAO 95.55, Introduction of LSA 600 kg. MTOW.

Ø 2006 Introduction of RA-Aus formalised Accident Investigator Training.

Ø 2007 Introduction of Human Factor Training to RA-Aus Instructors.

Ø 2008 Mandatory introduction of Human Factor Training for all Pilots, Instructors and Students.

In the 25 years that RA-Aus/AUF have been keeping records, no member of the public outside the aircraft has suffered any injury caused by an RA-Aus registered aircraft.

This graph is based on an average of 25,000 Class two medicals for both 2005 and 2006 and 6000 RA-Aus members in 2005 and 7000 in 2006.

2005 Private& Business Fatalities = 13 Source ATSB web

ratio 25000: 6000= 24%

24% of 13 = 3.1

2006 Private & Business Fatalities= 20 Source ATSB web

ratio 25000: 7000= 28%

28% of 20 = 5.6


The use of fixed wing statistics rather than including weight shift statistics is to use similar types of aircraft to get a fair comparison and is based on CASA 1988 Regulations, which delineate between the two groups for licensing purposes. (Group A and Group B ultralights) 2007 -2008 statistics on class 2 medicals was not available at the time of writing.

It should also be remembered that members of Recreational Aviation Australia Inc. members are informed participants in their chosen activity. Thus meaning that any participation is under taken at their own risk and that they are aware that the operation of aircraft involves and element of danger.

In the opinion of Recreational Aviation Australia Inc. an increase in the MTOW from 600kg to 760kg mitigated by the limitations of 2 occupants only, a stall speed of 45kts in the takeoff configuration and being limited to Day VFR conditions in the opinion of Recreational Aviation Australia Inc. does not constitute an increase in risk to the Australian Public or indeed to RA-Aus members themselves. In fact, the greater useable payload that the aircraft is able to legally carry can in fact increase safety in terms of greater carriage of safety related systems (Ballistic Rocket Systems), emergency rations and safety equipment, not to mention the safety benefits of increased range.


Recreational Aviation Australia Inc. supports Option 3a without any changes. RA-Aus believes that this option gives the maximum amount of flexibility, authority and autonomy to an RAAO to administer recreational aircraft up to 760kg MTOW.

Option 3a also enables Recreational Aviation Australia Inc. to carry out administration of aircraft up to 760kg MTOW using its current practices, without altering operational procedure to administer aircraft between 600-760kg MTOW under Part 91.

Recreational Aviation Australia Inc. proudly supports the view that past increases in MTOW that have been granted to AUF/RA-Aus over the 25 year history of the organisation have systematically enabled greater safety and personal freedoms to many RA-Aus members. Recreational Aviation Australia Inc. regards the weight increase to 760kg MTOW as a further extension of this safety and personal freedom to our membership, whilst giving a section of traditional General Aviation the choice of administration.

Recreational Aviation Australia Inc. has established itself as a capable leader in aviation self administration of aviation in Australia and looks forward to the challenges and safety benefits that administration of aircraft up to 760kg MTOW will bring.

In testament of the anticipated safety benefits of the increase to 760kg MTOW, attached as per CASA’s request, is a listing of members that agree with the position of RA-Aus in relation to the weight increase to 760kg. This listing is supplied to assist CASA in the correlation of the results of the DP from RA-Aus and is in addition to the hundreds of responses already received by CASA.

Lee Ungermann


Recreational Aviation Australia Inc.