[Kharon]

Ref: Pg 44 - https://www.raa.asn.au/safety/accident-a...summaries/ & https://www.vision6.com.au/em/message/em...R-IHlhWLWs & https://www.atsb.gov.au/publications/inv...-2018-066/ & https://www.atsb.gov.au/publications/inv...-2019-071/

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If, you go down to the woods today- etc.

Not a big surprise to stumble into P2; rootling about the metaphorical woods of 'research'. I was hot on trail of a mystery which has me intrigued, P2 was hunting down some 'strange and wonderful' things to do with the black arts of 'certification and the approval process for aircraft and their operations. Our paths crossed at exactly the the same junction; “Ullo” say's he, “What cheer” I replied. Seemed like a good time to take a break, have a cuppa and exchange information; a log each to sit on - “You first” say's P2. “What you doing cruising this neck of the woods. “Accidents and statistics” say's I – You? “Certification and stuff” he replied. Well, we compared notes, seems we were both hunting the same strange beast; but, from different directions. Your indulgence for a ramble is now required; we have not, as yet got this 'thing' properly lined up, some dots and dashes  are missing, but I will sketch the outline and fill in the facts once we have opinion from 'expert' sources. 



To begin, I was curious about a 2017 RA Oz aircraft accident. RA Oz were to investigate the serious crash and present a 'report' to CASA; as it was one of their own. There were a couple of interesting questions begging answers, for which we awaited 'the report'. The first question being, where was the accident report? I did look long and hard – but nary a sign of that elusive document did I find. It may well be lurking in some festering pile or another – however, to those who may have an interest – it has not been, thus far located. From this puzzle, other important questions are raised, the first being a potential conflict of interest due to the RA Oz system having a clear commercial interest in keeping LSA on the front lines of training.



This naturally leads one to ponder a couple of salient points; for instance – accident statistics, in proportion to fleet size. ATSB are big on 'statistics' and when you get down to numbers and the 'type' of frequent LSA accident and serious injury, you have to wonder whether ATSB is 'frustrated' or complicit. There are several mentions on the ATSB web site of 'technical assistance' being provided to the RA Oz 'investigators, but no follow up reports. Then there are no 'identified; investigators mentioned which means the qualification and experience of those investigating cannot be readily and openly assessed. RA Oz most certainly do not provide a list of accredited investigators and they do not publish the results of the investigations. WTD?

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"History shows that where ethics and economics come in conflict, victory is always with economics. Vested interests have never been known to have willingly divested themselves unless there was sufficient force to compel them."― Bhim Rao Ambedkar

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That, standing alone is cause for real concern. Anyone operating an air-frame / engine LSA has a right to understand not only what caused the accident, the integrity of the investigation and, if needs be, the qualification of the IIC: if only for insurance purposes and coroners court. 

This rummaging around for information is where P2's and my own pathways met. I was concerned about the 'suitability for purpose' of the LSA fleet, the design philosophy and risk assessment, the various types of certification needed to meet different 'intended' operational criteria. Three areas of concern, in non technical language (i) air-frame structural life (fatigue) forecast based on intended (design) use: (ii) 'repair ability' and limitations on repeat repair: (iii) fit for intended purpose.

Much of this comes into the 'certification' of aircraft. An aircraft may be designed and 'certified' for a specific role and that role only. Much depends on whether the aircraft is to be used for 'commercial' purpose or private use or both. It is alarming to discover that RA Oz have the authority to 'certify' aircraft. Once again I find no published list and qualification of those who 'certify' the LSA, and how and to what purpose. The Bristell being an example – the mark and model 'certified' is the retractable undercarriage model; originally certified by the Brits for 'pleasure and leisure'. 

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Ref: https://t.co/q1RfnE3VCA?amp=1 

P2 is working through that puzzle as the RA Oz aircraft is different – but the type certificate, issued by Israel has been 'accepted' by RA Oz. If one considers flight training as a commercial operation; then not only has there been an error in RA Oz certification, but in the intended use for which the aircraft was intended and originally certified.

By now, you're probably cow eyed with boredom; for this I apologise. However, even by the ATSB weird sisters accounting ledger and Jonathan (where's me marbles) Alec's peculiar circular arguments on accident research; one thing sticks out like the proverbial dog's whatsits. RA Oz in it's current format is 'wrong'. SOAR being the classic example. The minister has hired the RA Oz tea lady as an adviser; CASA won't get stuck in despite much more draconian action being taken for much lesser accident rates than RA Oz generate; ATSB cannot independently assess the crash reports – even the fatal ones; and, there's a bunch of kids out there (or was) teaching student pilots to fly in aircraft which were never designed to take flight school beating – year in – year out. Or was it?

MTF on this as we collect and collate 'expert' data – particularly on 'certification'. It's probably all kosher – but something, somewhere, is 'off'. I've said it before – I don't have a quarrel with private LSA, think its great for a person to buy an aircraft and go flying – no problem. But when you have large commercial operations, with a high accident rate using a LSA in a manner which was never envisioned or designed for – and no open publication of accident report – it sorta looks a bit 'odd' minister – don't it?

There ramble over; it helps to draft it, precursor to a Senate submission perhaps – we shall see. P2 and I will keep digging about while we wait on expert, qualified opinion. We seem to have the time to do it now. Amazing ain't it – dream of a life of idle luxury – every minute of every day spent as pleased you best, then it happens – Arrrggghhh!

Aye well the Devil makes work for idle hand – my clock awaits,

Stay well – Selah.