Here are some examples of what people have said about CASR 47 and the new aircraft registration procedures. Note the immense gulf between why CASA said they were needed when first proposed, and why CASA now says they are needed.
Do not transfer the registration of your aircraft to someone else unless you fully understand the potential consequences of doing so and you have satisfied yourself that there really is a legal requirement to do so. Put CASA's letter of 21st September 2000 in the appropriate (round) filing place.
Here are some comments I have received from real people.
The purpose of this Notice of Proposed Rule
Making (NPRM) is to:
* simplify the aircraft registration
procedures
* clearly identify the person in
possession of the aircraft as the person
responsible for airworthiness control of the
aircraft
* remove the need to record property
interest details in the Civil Aircraft Register.
CASA, 4th August 1998 (NPRM 9807)
CASR Part 47 is being introduced because there
have been too many incidents in which vital safety
information (such as Airworthiness Directives) has
not been passed on by the Certificate of
Registration holder to the person controlling the
airworthiness and maintenance of an aircraft.
CASA, 21st September 2000 (Letter to aircraft
owners)
You should also note that, amongst the 61
comments received on the NPRM for Part 47, was one
from the Aircraft Owners and Pilots Association
dated 25 September 1998, indicating that the
proposal in the NPRM was acceptable without
change.
CASA, 29th September 2000 (Letter from Richard
Yates to Boyd Munro)
Unfortunately AOPA did not even inform its members
after agreeing to this - much less consult them
beforehand.
May I acknowledge to you my gratitude for your
concern on matters affecting myself and other
people like me who are pilots with a simple taste
for flying that wish to escape the bureaucratic
overload with which we are incessantly bombarded
… Thank you.
Cessna Owner, Queensland, AOPA member
My first thought when this lovely piece of CASA
toilet paper arrived was SOD OFF. It took me 16
years of hard work, huge amounts of grovelling to
the Mrs and a dose of insanity to buy my Cessna.
There is no way known I would ever assign my C of
R to some one else. ITS MINE......
Cessna owner, Victoria
Thank you for your constant vigilance - the
lawmakers at CASA are either incredibly devious or
overwhelmingly stupid. People like you keep
them on their toes and are invaluable to the rest
of us poor trusting slobs.
Piper owner, NSW, former AOPA member
Thanks for the valuable information. I had no
intention of transferring my aircraft's
registration and your letter certainly justifies
my decision.
Piper owner, Queensland
Thank you Boyd for keeping us informed.
Original letter from CASA sure was
misleading. Good on you, keep them
honest.
Cessna owner, NSW, former AOPA member
Thanks for doing this, Boyd .Of course this was
not necessary before the change to the CARs made
it so. Bloody xxxxxx again.
Light aircraft owner, Victoria, AOPA member
Thanks Boyd, I got this letter saying that
regarding CofR transfers and I thought to myself
"what a load of ****", and threw it
away, hoping CASA wouldn't get upset. Your e-mail
makes me feel better about it.
Cessna owner, Queensland
That's a very interesting letter.
Unfortunately (or maybe fortunately) I do not own
an aircraft but it sure is a very complicated and
sensitive issue.
Private Pilot, Victoria, AOPA member
Thanks Boyd. I had suspected as much (not
that I have any desire to transfer the C of R of
my aeroplane anyway).
Cessna owner, NSW, AOPA member
I think that this latest proposal of CASA to
transfer aircraft Registrations is absolutely
crazy. It seems to me that they must mirror
their own mentality when thinking about aircraft
owners. I often wonder how many of them have
bought their own aircraft with their own funds
after having worked and saved for many years to
accumulate those funds. I think they lack
commercial reality.
Beechcraft owner, NSW, AOPA member
Thanks for your message. I do own a small
'bug smasher' and when I read the letter from CASA
my immediate understanding was that I control the
maintenance because I arrange to have the
servicings done when required. I immediately
binned the letter.
There is absolutely no way I would be signing over
the certificate of registration to anyone else,
particularly not a maintenance facility!
I really can't see the need for this CASA
requirement. Surely any
organisation/operator who finds the owner
unwilling to pay for maintenance to a required
standard has the option of not utilising that
aircraft? Either way, it is a matter between
the owner and the operator and the owner's rights
should not be eroded. Thanks for keeping me
informed.
Piper owner, Queensland, AOPA member
Thanks for the information. I have been very
concerned about our club aircraft in this
situation. We have an operator that does all our
maintenance and we were getting very concerned
about the whole thing. Can you recommend an
aviation lawyer who can advise us on this matter?
Cessna owner, Victoria, AOPA member
Got the letter from CASA and thought "What
are they up to now". Dispatched it to the
bin. Pleased to get your fax re same and I
followed instructions and mailed accordingly.
Light aircraft owner, Victoria, AOPA member
Thank you for your information on CofR. I too
have serious misgivings in this area.
Although there are times in which I certainly
disagree with your views, nevertheless I still
appreciate your efforts, not only in this matter,
but others as well. Once again thanks for
the "heads up".
Cessna owner, NSW, AOPA member
Boyd, thanks very much for the last email, I
appreciate all your correspondence.
Commercial Cessna operator, Victoria, former
AOPA member