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Ratten
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Are the potential benefits to aviation safety mentioned in the DP likely to be realised by implementing this proposal?
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No they are not likely to be realised (please specify why below)
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Comments
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Many aircraft currently approved as VH registered aircraft will not satisfy the 45 KCAS stall speed requirement even if they satisfy the MTOW of 760Kg or lower.
The proposal will fail to approve many VH approved aircraft to be registered in RAA and operate above 600Kg up to 760Kg MTOW. Therefore any potential safety improvements will be diminished.
A change of the maximum clean stall speed (above 600Kg and below 761Kg) to the VH approved stall speed limit for that aircraft is also required.
Many aircraft currently approved as VH registered aircraft will not satisfy the 45 KCAS stall speed requirement even if they satisfy the MTOW of 760Kg or lower.
The proposal will fail to approve many VH approved aircraft to be registered in RAA and operate above 600Kg up to 760Kg MTOW. Therefore any potential safety improvements will be diminished.
A change of the maximum clean stall speed (above 600Kg and below 761Kg) to the VH approved stall speed limit for that aircraft is also required.
Are the potential benefits to the aviation community mentioned in this DP likely to be realised by implementing this proposal?
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Yes they are likely to be realised
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No they are not likely to be realised (please specify why below)
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Comments
See General Comments
Many aircraft currently approved as VH registered aircraft will not satisfy the 45 KCAS stall speed requirement even if they satisfy the MTOW of 760Kg or lower.
The proposal will fail to approve many VH approved aircraft to be registered in RAA and operate above 600Kg up to 760Kg MTOW. Therefore any potential industry improvements will be diminished.
A change of the maximum clean stall speed (above 600Kg and below 761Kg) to the VH approved stall speed limit for that aircraft is also required in the change.
Many aircraft currently approved as VH registered aircraft will not satisfy the 45 KCAS stall speed requirement even if they satisfy the MTOW of 760Kg or lower.
The proposal will fail to approve many VH approved aircraft to be registered in RAA and operate above 600Kg up to 760Kg MTOW. Therefore any potential industry improvements will be diminished.
A change of the maximum clean stall speed (above 600Kg and below 761Kg) to the VH approved stall speed limit for that aircraft is also required in the change.
Do you consider the overall effect of the proposal on the aviation community to be positive or negative for private recreational aviation?
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Comments
See General Comments
Many aircraft currently approved as VH registered aircraft will not satisfy the 45 KCAS stall speed requirement even if they satisfy the MTOW of 760Kg or lower.
The proposal will fail to approve many VH approved aircraft to be registered in RAA and operate above 600Kg up to 760Kg MTOW.
A change of the maximum clean stall speed (above 600Kg and below 761Kg) to the VH approved stall speed limit for that aircraft is also required in the change.
Many aircraft currently approved as VH registered aircraft will not satisfy the 45 KCAS stall speed requirement even if they satisfy the MTOW of 760Kg or lower.
The proposal will fail to approve many VH approved aircraft to be registered in RAA and operate above 600Kg up to 760Kg MTOW.
A change of the maximum clean stall speed (above 600Kg and below 761Kg) to the VH approved stall speed limit for that aircraft is also required in the change.
Do the changes mentioned in the proposal affect you as an individual positively or negatively?
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Comments
I own a Jabiru J230 which was previously registered as a VH aircraft and now is RAA registered but without an approval for stall speed of 50 KCAS at 700Kg it cannot benefit from the proposed weight increase.
If applicable, does the proposal affect your aviation business positively or negatively?
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Options for discussion
Please indicate below which option you prefer.
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I agree with option 1
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I agree with option 2
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Other option
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Option 2 with changes to use the stall speed limits as applies to the same VH registered aircraft at their VH approved MTOW up to 760Kg.
General Comments
Do you have any additional comments about the proposed Maximum Take-Off Weight increase for aeroplanes managed by an ASAO.
Comments
There is a major problem and inconsistency in what is proposed that will prevent a large portion of the RAA fleet capable of safely flying at up to 700Kg MTOW from using this proposed change at all.
Consider the case where CASA approved a Jabiru J230 to be registered on the VH register under the ASTM standards for Light Sport Aircraft CASR Subpart 21.H. There are 27 such aircraft currently on the VH register. This would allow it a MTOW of 700Kg, (and allows it to have a VS1 stall speed equal to or under 50Kts)
If this aircraft was transferred to the RAA register it would currently fly with a MTOW of 600Kg and 45kts stall speed upper limit for which it complies.
The Discussion Paper introduction states “Other limitations such as maximum stall speed would not be changed by this proposal.”
While limited to 45 KCAS VS1 stall speed (as limited in the CASA Discussion Paper), it would not be able to fly a new MTOW of up to 700Kg due solely to the slightly higher, 50 KCAS VS1 stall speed while operating at 700Kg MTOW.
Of the 1250 RAA aircraft relevant to the Discussion Paper, 181 (15%) are J230 models. The J230 models can safely operate at 700Kg MTOW while on the VH register however the same aircraft would not be allowed fly at MTOW of 700Kg while operating in RAA registration solely due to the slightly higher stall speed.
Also, as additional examples
Cessna A152 (1978) POH states CAS for VS1 of 48kts
C150 C150 (1964) POH states CAS for VS1 of 48kts
Piper Tomahawk PA-38 (1978) POH states VS1 of 48 to 52 KIAS
These could not satisfy the requirements of operating up to their VH MTOW which would also prohibit these aircraft to be registered in RAA while operating to their VH MTOW under the proposed changes.
Therefore the stall speed limit when operating under the proposed higher MTOW rules should be amended to allow for aircraft already approved for VH registration at 50kts stall speed or their approved VS1 speed when used in the VH register mode to operate up to their CASA approved MTOW up to 760Kg.
Without such an amendment ALL RAA registered J230 and VH registered Cessna 150/152 and Piper Tomahawk aircraft, for example, will be prevented from these benefits as RAA registered aircraft yet can operate exactly to at least 700Kg MTOW or more if registered as VH aircraft.
Consider the case where CASA approved a Jabiru J230 to be registered on the VH register under the ASTM standards for Light Sport Aircraft CASR Subpart 21.H. There are 27 such aircraft currently on the VH register. This would allow it a MTOW of 700Kg, (and allows it to have a VS1 stall speed equal to or under 50Kts)
If this aircraft was transferred to the RAA register it would currently fly with a MTOW of 600Kg and 45kts stall speed upper limit for which it complies.
The Discussion Paper introduction states “Other limitations such as maximum stall speed would not be changed by this proposal.”
While limited to 45 KCAS VS1 stall speed (as limited in the CASA Discussion Paper), it would not be able to fly a new MTOW of up to 700Kg due solely to the slightly higher, 50 KCAS VS1 stall speed while operating at 700Kg MTOW.
Of the 1250 RAA aircraft relevant to the Discussion Paper, 181 (15%) are J230 models. The J230 models can safely operate at 700Kg MTOW while on the VH register however the same aircraft would not be allowed fly at MTOW of 700Kg while operating in RAA registration solely due to the slightly higher stall speed.
Also, as additional examples
Cessna A152 (1978) POH states CAS for VS1 of 48kts
C150 C150 (1964) POH states CAS for VS1 of 48kts
Piper Tomahawk PA-38 (1978) POH states VS1 of 48 to 52 KIAS
These could not satisfy the requirements of operating up to their VH MTOW which would also prohibit these aircraft to be registered in RAA while operating to their VH MTOW under the proposed changes.
Therefore the stall speed limit when operating under the proposed higher MTOW rules should be amended to allow for aircraft already approved for VH registration at 50kts stall speed or their approved VS1 speed when used in the VH register mode to operate up to their CASA approved MTOW up to 760Kg.
Without such an amendment ALL RAA registered J230 and VH registered Cessna 150/152 and Piper Tomahawk aircraft, for example, will be prevented from these benefits as RAA registered aircraft yet can operate exactly to at least 700Kg MTOW or more if registered as VH aircraft.