MTOW Increase – 601kg to 760kg

Q1. What is proposed?
RAAus has received CASA approval to operate type certified and amateur built fixed wing, 3 axis, single engine aircraft with a MTOW between 601 and 760kg, regardless of stall speed. The 760kg MTOW is based on the MTOW specified by the aircraft manufacturer. This new category of aircraft will be known as Group G and is based on the Civil Aviation Order (CAO) 95.55 and Civil Aviation Safety Regulations (CASR) Part 103 Lightweight Aeroplane (LWA).

Q2. Timing – When will the MTOW increase happen?
CAO 95.55 was updated to include Lightweight Aeroplane (the proposed 760kg weight increase) on 2^nd December 2021. This provided the legislative pathway for RAAus to receive CASA approval for updated Flight Operations and Technical manuals which includes the new Group G procedures and processes.

RAAus anticipates accepting applications for Group G aircraft registration, the issuing of a replacement Certificate of Airworthiness (CofA), if required, and the issuing of RAAus Group G Pilot Certificates, Ratings, and Approvals in Q2 of 2024.

Members will be advised of the implementation date for Group G once CASA approval is received, RAAus business processes are ready, and staff have been trained.

Q3. What progress has been made to date?
Many aspects of the operation, maintenance, and registration of Group G aircraft have had to be reviewed, and processes created for approval by CASA. While an additional 160kg in MTOW might not seem like a big change, the range, and types of aircraft available for RAAus members to operate in Group G meant many details had to be considered and solutions found.

Additionally, legislation had to be created, not only by changing the existing Civil Aviation Orders (CAO) that RAAus operate under, but also via organisational approvals under CASR Part 149 (Approved Self-administering Organisations), and operations under CASR Part 103 (Sport & Recreational Aircraft) and Part 91 (General Operating and Flight Rules).

Q4. Will the weight increase affect me or my current operation?
No – The introduction of Group G aircraft will in no way affect the current operations of RAAus members, flying schools and maintainers. However, anyone wishing to operate a Group G aircraft registered by RAAus will have to comply with the Group G Pilot Certificate, Endorsement, Rating and Approval requirements as relevant.

Q5. What benefit will members get from an increase in MTOW?
The MTOW weight increase for RAAus will have positive impacts on the aviation industry such as an increase in the range of aircraft make and model (types) that can be operated, improved aircraft utilisation and overall growth in aviation participation throughout Australia. Furthermore, some current RAAus registered aircraft will no longer have their MTOW artificially restricted therefore enabling more fuel to be carried on cross country flights resulting in significantly safer operations.

F1. What will be the costs associated with owning, registering, operating, and piloting a Group G aircraft?
The costs of owning, registering, operating, and piloting a Group G aircraft are the same as the fees for Group A aircraft.  Refer to the RAAus website “Schedule of Fees and Charges”. https://www.raa.asn.au/storage/schedule-of-fees-and-charges-5.pdf

F2. How much will it cost to transfer my Group G from VH registration to RAAus?
The cost to transfer your Group G aircraft (LWA) from VH registration to RAAus registration is made up of:

• the cost of reserving an RAAus registration number; plus
• the cost of registration; plus
• the cost of issuing an aircraft specific CoA either by RAAus for the simple process of transferring a VH registered LWA from CASA to RAAus (change of rego number), or by a CASA delegate for all other aircraft (e.g. unregistered certified aircraft, experimental amateur built aircraft).

A1. Will I be able to operate my Light Sport Aircraft (LSA) above 600kg when the weight increase is implemented?
No – LSA is a global standard with a MTOW limitation of 600kg.

A2. How can I determine if an aircraft kit is eligible for Group G registration?
The key to a kit being eligible for Group G (operations up to a MTOW of 760KG) lies with the Kit Manufacturer and/or the plans designer/builder. MTOW limitations are based on the aircraft’s (kit or plans) designed and approved MTOW.

Engine type and capacity has no impact on Group G eligibility other than affecting MTOW.

A1. Will I need to deregister my aircraft with CASA before I can apply for the reservation of a RAAus registration number?
No – this is because when applying for the allocation/reservation of a RAAus aircraft registration number, it does not yet register your aircraft.  The process of aircraft registration is a separate process that requires you to complete the appropriate application form and pay the prescribed fee, depending on the type of aircraft that is being registered and it is during this registration process that de-registration would occur. Refer to question A5 for more about registration of a Group G (LWA) aircraft.

A2. Will 760kg be the maximum possible operating weight?
Yes – If an aircraft can operate above 760kg according to the manufacturer published information, it cannot be registered with RAAus and it cannot be operated by a pilot issued with a RAAus Group G RPC.

A3. Will there be a cost to reserve an RAAus Group G registration Number?
Yes – refer to the FAQ section on RAAus Fees.

A4. Will there be a cost to register a Group G aircraft with RAAus?
Yes – This remains unchanged. RAAus charges an initial registration fee for a first-time registration, and then there is an annual renewal fee.  The Aircraft registration fee is based on the number of seats in the aircraft (e.g. single seat or two seat). Refer to the FAQ section on RAAus Fees.

A5. Will I still have to comply with CAO100.5 requirements etc. when shifting my aircraft from VH to RAAus registration?
Yes – compliance with the requirements of CAO 100.5 is applicable to all RAAus registered aircraft.

CoA 1. Will I have to apply for a CoA?
Simple answer is yes, depending on the type of aircraft and the aircraft’s airworthiness disposition at the time.

CoA 2. Will I have to pay for the issue of a CoA?
Yes – refer to FAQ F2 in the Section on RAAus Fees.

CoA 3. Can the MTOW placard on my aircraft be amended once Group G is approved?
No – A change to the MTOW placard may only occur after an application for a Group G CoA  and aircraft registration has been issued.

AM 1. Who can maintain a Type Certified Group G (LWA) aircraft?
A CASA Part 66 licence holder (LAME) with the relevant licence categories. A RAAus L1, L2 or L4 maintainer is not approved to conduct maintenance on a type certified Group G aircraft.

AM2. Who will be able to maintain an amateur built or Experimental Group G aircraft?
A CASA Part 66 licence holder (LAME) or the builder of the amateur built or experimental aircraft, who meets the requirements of instrument 18/22 (further details will be provided when finalised).

AM3. I have an RAAus registered Group G aircraft (LWA) currently registered in Group A that I maintain as a RAAus L1 maintainer. If I transfer it to Group G will I still be able to maintain it?
Only if:

• You are the primary builder; and
• You meet the requirements of CASA Instrument 18/22; and
• The aircraft has been issued with a Special CoA in the form of an experimental certificate

AM4. If I purchase a Group G eligible aircraft or a VH registered aircraft that I wish to transfer to RAAus as a Group G (LWA) can I maintain it?
Only if:

• You meet the requirements of CASA CAAP 42.ZC-02 v1.2; and
• The aircraft has been issued with a Special CoA in the form of an experimental certificate

FO1. When will Group G be implemented?
Refer to ‘Q2 Timing’ for the answer.

FO2. Will I have to undertake extra training to have Group G added to my existing RPC?
It depends:

• If you have an RPC for Group A (3 axis), Group B (Weightshift Microlight) or Group D (Powered Parachute) aircraft, you will need to complete additional training to add Group G (3 axis 601 – 760kg MTOW) aircraft. This training will be competency based, will not require a stipulated minimum number of hours, and is intended to ensure pilots understand the potential additional challenges for operation of a heavier aircraft.
• If you own the Group G aircraft and have logged flight time in it (registered VH for example or overseas aircraft that meet the category), it will be as simple as completing new written multiple-choice exams called Recreational Pilot Certificate and Passenger Carrying (if you want to carry passengers) to ensure your knowledge is up to date and then completing a flight test with a RAAus Group G DCFI or CFI or PE.
• Alternatively, if you hold a current CASA RPL or PPL (a current flight review that has been conducted in a VH registered aircraft, (MTOW <1,500 kg)), instead of completing the flight test with the RAAus CFI, you can provide the CFI with a copy of your CASA Flight Crew Licence (FCL) and your latest flight review. The CFI will confirm your competency to the Group G syllabus requirements and you may not have to complete any additional flight training for the issue of a Group G RAAus RPC. As noted above you will be required to complete written multiple-choice Recreational Pilot Certificate and Passenger Carrying exams to ensure you understand the specific RAAus requirements and limitations.
• The CFI will send a recommendation to RAAus using the required form (RPC001G) along with a copy of your FCL and latest flight review.

F03. What additional syllabus items will I be required to complete to add Group G to my existing Recreational Pilot Certificate?
Group G requirements have been added to the RAAus Syllabus of Flight Training which include specific competencies that must be demonstrated for the addition of Group G to an existing RAAus Group A Pilot Certificate. These include:

• Engine management and operating differences – mixture controls, spark plug management (fouling); and
• Engine and Aircraft performance characteristics – take-off and landing differences on high density altitude days, fuel management, wind, runway surface etc.; and
• Aircraft specific W&B considerations for heavier, up to 760kg MTOW, aircraft

FO4. Will I be able to use my CASA RPL or higher Licence (FCL(A)) as a recognised qualification, flight time and attainment of competency for the issue of a Group G RAAus Pilot Certificate?
Yes – see question F02 above.

FO5. If my CASA FCL(A) is used as recognition of competency for the issue of a RAAus Pilot Certificate with a Group G will I also be granted Group A?
If you meet the practical and theoretical competencies of Unit 1.01 of the RAAus Syllabus of Flight Training, including the required exams and pass a flight test in a Group A aircraft with a RAAus Group G DCFI, CFI or PE (as requested by the CFI) you can be recommended for the issue of a Group A RAAus Pilot Certificate.

FO6. What about the endorsements on my CASA Licence?
Endorsements on your CASA RPL or higher Flight Crew Licence FCL(A) may be recognised and added to your RAAus Pilot Certificate, as appropriate, for the operation of Group A, B, D and G aircraft. Version 8 of the RAAus Flight Operations Manual will provide a table of possible endorsements for each aircraft Group. The RAAus Examiner can use form END002 to recognise endorsements.

FO7. I hold a current RAAus instructor or higher rating for Group A aircraft. What will I need to do add Group G to my instructor privileges?

In broad terms, an applicant will need to hold 100 hours PIC time in an aircraft of the same Group (3 axis aircraft up to 1500kg MTOW and a current RPL, or higher CASA licence), or a touring motor glider and current GFA certificate. If you hold a CASA or Defence Force instructor rating, see question FO8 below.

• Specific minimum aeronautical experience requirements for higher approval holders are provided in Flight Operations Manual v8 which must relate to the aircraft group being sought.
• Group G instructor rating holders will also be required to provide evidence of proficiency in a CASA spin recognition and recovery or similar or complete a spin recognition and recovery course prior to delivering instruction in Group G aircraft.
• All existing and new RAAus Group A instructors will be required to provide evidence of or complete a spin recognition and recovery course within 3 years of Group G implementation.
• Due to the considerations of power on spin manoeuvres and recovery procedures, the completion of GFA spin proficiency does not meet the spin requirement. RAAus expects to provide more information about the specifics of this proficiency once an implementation date has been confirmed.
• The instructional experience you hold as a Group A Instructor rating or approval holder will be accepted towards the minimum requirements for the addition of Group G. You will need to complete the requirements for issue of Group G Pilot Certificate as provided in question F02.

FO8. I hold a CASA or Defence force Instructor rating and would like to obtain a RAAus instructor rating – what will I need to do?

• If you hold a current CASA Grade 3 or higher instructor rating, or a Defence Force issued Instructor rating, once you have been assessed by the CFI, they will complete and supply RAAus Group G Form RPC002G to RAAus.
• With this form, you will need to provide a copy of your CASA Flight Crew Licence FCL(A) or Defence qualifications for review by RAAus and provide documents that confirm you meet the required medical standard.
• You will need to be issued with a RAAus Group G Pilot Certificate (see question FO2), complete the RAAus Instructor multiple choice exam and finally, complete a flight test with a RAAus PE, IT, AHFO or HFO.

FO9. Will my RPL or PPL need to be current to be issued with a Group G RPC?
Yes, a current CASA flight review will be required to have your licence recognised for RAAus Group G Pilot Certificate.

FO10. Will I be able to start instructing immediately at my FTS for Group G?

• Once the processes noted above for issue of Group G rating or approval are completed and the Group G qualification has been issued by RAAus, to deliver Group G instruction, the CFI and the FTS must be approved by RAAus for Group G operations.
• CFIs should provide RAAus with a new FTS001 form, which provides the relevant information.
• If the CFI is an existing Group A CFI who is adding Group G, RAAus will waive the initial FTS fee and work with the candidate to ensure the new Group G FTS is compliant to the Flight Operations Manual requirements.
• An appropriate factory built Group G aircraft must be registered (factory built, type certified and LAME maintained) with RAAus for use at the FTS once approved.
• Only when these requirements are met can the CFI complete Standardisation and Proficiency (S&P) checks with any Group G Instructor on the aircraft type and commence training for Group G RPC for RAAus members.

FO11. What aircraft will I be able to  use for instructing in Group G at my FTS?
Once the aircraft meets the requirements of Section 15 of the Tech Manual, is registered with RAAus and issued with the applicable CoA for a Group G aircraft it can be used to provide flight training for the issue of a Group RPC, Group G BFRs and endorsements.

For maintenance requirements when a Group G aircraft is used for flight training refer to question AM1.

FO12. Can I conduct aerobatics in my RAAus registered Group G aircraft?
RAAus notes that the CASR Part 103 legislation will permit the conduct of aerobatics in appropriately certificated and capable aircraft by appropriately qualified pilots, however at this early stage, RAAus has not completed all the work required to ensure this is managed safely and compliantly.

So the short answer right now is, not yet, but eventually, RAAus looks forward to this capability being possible under RAAus registration in due course.

FO13. Can I fly in controlled airspace in my Group G aircraft?
Not automatically. At this time, RAAus is focussing on Group G implementation, with the intention to apply for controlled airspace and controlled aerodrome access for all RAAus members next.

The only circumstance where a RAAus aircraft can be flown in Controlled Airspace at this time is explained in RAAP 14- Can I fly in Controlled Airspace. If you and the aircraft meet the requirements outlined in this RAAP, you can currently operate in Controlled Airspace and at Controlled Aerodromes in your Group A RAAus registered aircraft.

FO14. Is spin proficiency required for Group G pilots?
RAAus has aligned with CASA requirements for Group G instructors, who will be required to confirm spin proficiency and recovery competence prior to being issued with a Group G rating or approval.

For Pilot Certificate holders, as CASA is not requiring licenced pilots to meet this requirement, neither is RAAus. Of course, RAAus encourages pilots to gain personal proficiency in spin recognition and recovery in an appropriately certificate and capable aircraft and has redesigned our Syllabus of Flight Training to include Upset Prevention and Recovery Training elements.

ST01. I am a new student.

• If you are currently completing training for a Group G RPC, once the new manuals are implemented, you will be required to complete the new exams, as the exam suite has been updated and restructured for the new Flight Operations and Technical Manuals and Syllabus of Flight Training requirements. This is an unfortunate consequence of the implementation of the new manuals and is required even if you have successfully completed all the current exams. If you are able to complete the training prior to the implementation date, completion of the new exams will not be required.
• The Syllabus of Flight Training has been completely reviewed, but for current students, the instructors may need to confirm competency to the two additional elements prior to solo, advanced turns and scenario based stalling.
• If you want to train to add a Group G RPC, you will need to demonstrate and meet the competency requirements of the Group G syllabus (Unit 1.05) and complete the new exams.

MO01. I am a current member with a Recreational Pilot Certificate.

• If you already hold a Recreational Pilot Certificate, the new manual provides additional recognition of flight reviews conducted under the CASA Flight Crew Licence and RAAus will now recognise AFRs in VH aircraft up to MTOW of 1500 kg, single and multi engine, under Day VFR or IFR.
• RAAus will also be changing the processing of validity dates of flight reviews to align with CASA processing. Flight reviews will be processed as valid for two years expiring at the end of the month the review was conducted in.
• If I purchase a Group G eligible aircraft or a VH registered aircraft that I wish to transfer to RAAus as a Group G (LWA) you can maintain it, only if the aircraft is amateur built and you meet the requirements of CASA instrument 18/22 and the aircraft has been issued with a Special CoA in the form of an experimental certificate. All manufactured Group G aircraft must be maintained by a Part 66 licence holder.

MO02. I am a current member who owns an aircraft.

• If you own a Group A, B or D aircraft and intend to continue to operate at the MTOW it is currently approved for, the maintenance requirements will not change.
• If you have an RAAus registered Group G aircraft (LWA) currently registered in Group A that you maintain as a RAAus L1 maintainer and transfer it to Group G you will still be able to maintain it, only if the aircraft is amateur built and you are the primary builder; and you meet the requirements of CASA Instrument 18/22; and the aircraft has been issued with a Special CoA in the form of an experimental certificate.
• If you intend to register a Group G aircraft, and it is a Type Certified Group G (LWA) aircraft a CASA Part 66 licence holder (LAME) with the relevant licence categories will be required to maintain the aircraft. A RAAus L1, L2 or L4 maintainer is not approved to conduct maintenance on a type certified Group G aircraft.
• If you intend to register a Group G aircraft and it is an amateur built Group G aircraft, a CASA Part 66 licence holder (LAME) or the builder of the amateur built or experimental aircraft, who meets the requirements of instrument 18/22 will be able to maintain it. (further details will be provided when finalised).

IN01. I am an Instructor.

• All converting instructors from another sport organisation or CASA will be required to complete the RAAus Instructor exam, to ensure they completely understand specific RAAus privileges, limitations, and responsibilities.
• For initial issue of any Group G Instructor rating or higher, the candidate must have completed spin recognition and recovery training and provide a copy of the relevant licence or logbook entry.
• To conduct flight training in a new aircraft type an Instructor will need to complete 3 take-off and landings and whatever flight time is required to confirm their competence in the aircraft type. Previously, the requirement was for 5 hours as PIC of the new aircraft type.
• If Instructors also hold a current CASA Grade 3 FIR or GFA Level 1 rating with Powered Sailplane Touring Endorsement, they may supply RAAus with a copy of the revalidation documentation to have their RAAus Instructor rating revalidated.
• However, as CFI, a Standardisation and Proficiency (S&P) check for all Instructors at the FTS would still be expected to be completed.

IN02. I am a Senior Instructor.

• If an Instructor is about to upgrade to a Senior Instructor rating, they are required to complete the RAAus Flight Examiner Course (FEC) prior to upgrade to SI.
• If you are an existing Senior Instructor, you need to complete the RAAus Flight Examiner Course (FEC) ASAP as once the manuals are implemented, you will not be able to recommend endorsements if the FEC is not completed.
• If converting a current CASA Grade 2 FIR, you are not required to deliver and recommend 3 first solo candidates to their CFI but must supply a copy of the FPC with the SI upgrade form.
• If converting a current CASA Grade 3 FIR or GFA Level 2 rating, you will be required to train and recommend one candidate for first solo to the CFI.
• To conduct flight training in a new aircraft type they will need to complete 3 take-off and landings and whatever flight time is required to confirm their competence in the aircraft type. Previously, the requirement was for 5 hours as PIC of the new aircraft type.
• If the FTS also employs Instructors, CFIs may approve Senior Instructors to supervise the delivery of flight training by these Instructors. Previously SI supervision was approved by the RAAus Head of Flight Operations.
• There are specific requirements, including completion and review of the Senior Instructor Questionnaire (QSI001), available from the Instructor Portal to a satisfactory standard with the CFI, and a written approval letter from the CFI is to be retained on your file at the FTS. RAAus has produced form SIS001 to record and comply with this requirement.
• CFIs may nominate Senior Instructors who meet the minimum requirements, to conduct and recommend Cross Country endorsement. Requirements are provided in the CFI Procedures Manual and on RAAus Form SIC001, but in summary include the SI completing the RAAus Flight Examiner Course (FEC), they hold a minimum 250 hours instructing in RAAus aircraft or are the holder of a current CASA Grade 1 FIR and the CFI has conducted a review of testing requirements and standardisation processes.
• For flight testing purposes, Appendix 1 of the Flight Operations Manual provides the minimum flight tolerances which a pilot certificate candidate must demonstrate while managing the operation of a RAAus aircraft and in Section 3.03 there is specific information about criteria which must be met, or if breached will result in a failed flight test.