CASA 292/14 - Conditions and direction about Jabiru engines

[Guest Ornis]

http://www.recreationalflying.com/threads/jabiru-limitations.128627/page-32#post-470245

 

Re CAE engines, bit more to it than 30 examplesThe around 3000 solid lifter engines sold worldwide could be considered version 1.0.

Latest CAE is V2 onwards, very similar with some valuable improvements.

 

Even Ian believes std Jabiru solid lifter engine is quite sound.

 

All the previous experience does build a bigger picture than just 30 V2 examples

 

What you say about acceptable numbers for destruction etc would be fine if the market was big and wealthy enough to pay for it like automotive. Would also be a problem if you expect this every time a few components are upgraded.

 

Your headed down the track of fully certified engines where things cant be improved due to cost of retesing and recertification

[jetjr]

Which you twisted to say he thinks all Jabiru engines are sound. Not true.

 

He designed and built it, now using it as a base for the improved CAE engine. Why wouldnt he think it was OK.

 

After the solid lifter engine, Jabiru went on a diferent track, using his and other parts.

 

 

[Oscar]

jj, you are not quite correct in saying that Ian Bent 'designed' the original Jab. 2200 ( the 1600 was all Rod Stiff's design, AFAIK) but he certainly did have input into translating Rod's ideas into manufacturable form, which was recognised by the original IP agreement between CAMit and Jabiru.

 

However, the following extract from a Yahoo 'Jab. engines' thread that appeared in the last few days was added by Ian and clarifies the CAMit position:

 

CAMit maintains an AS/NZS ISO 9001:2008 quality system #1776 2003; continuously audited by Telarc SAI Limited since 2003

 

� CAMit holds a CASA Production Certification authorisation #760529-1 which allows the manufacture of certified aviation products

 

� To quote a CASA auditor,” CAMit is seen as able and willing”

 

� CAMit has specifically not been allowed input into the design, or sourcing of components for Jabiru engines for 9 years

 

� No feedback is supplied by Jabiru to CAMit, of any issues that indicate a QA problem

 

� CAMit does not accept Jabiru supplied components into our quality system as we are not aware of their provenance. Jabiru are responsible for the compliance of these components

 

� On CASA’s advice, CAMit can only conform components sourced or manufactured by CAMit

 

� CAMit supplies contract measuring services for some Jabiru supplied components. Material qualification services are not (cannot be) supplied

 

� CAMit assembles and test runs Jabiru engines to Jabiru specifications. CAE engines are assembled and test run to CAE specifications. There are significant differences.

 

�

 

Further to this - and of direct relevance to this thread, is a copy of a response to a CAE engine owner's query to CASA seeking confirmation that CAE engines are not subject to the CASA restrictions:

 

To Whom It May Concern.

 

 

 

I can confirm that the CAMIT engine is not subject to the operational limitations described in 292/14, as this engine is not manufactured by a person under licence from, or under a contract with Jabiru.

 

 

 

Regards,

 

 

 

Mike Higgins

 

Manager

 

Continuing AirworthinessAirworthiness & Engineering Standards Branch

 

Standards Division

 

Civil Aviation Safety Authority

 

 

[Russ]

Appears to be a step forward, let's see how big that step gets. ( encompassing type "C" aircraft could save a lot of folks )

 

$14k changeover, no restrictions, I'm in.

 

 

[Oscar]

Appears to be a step forward, let's see how big that step gets. ( encompassing type "C" aircraft could save a lot of folks )$14k changeover, no restrictions, I'm in.

If the CAE 2200 engine ( not the CAMit-modded Jabiru engines, still plated as such) is certificated to JAH 22H, I believe it would be an acceptable substitution by EO, which will add a bit to the cost because of the unnecessarily complicated way that CASA requires EOs for 'major components' to be handled. It appears that testing for certification / certifying of the 3300 engine to ASTM is about to get underway (following the hiatus introduced into this work originally planned for late last year), but as far as I am aware it has yet to be decided exactly what sequence of testing will be undertaken, due in part to the complications that have recently happened.

 

 

[jetjr]

"jj, you are not quite correct in saying that Ian Bent 'designed' the original Jab. 2200"

 

Fair enough, I stand corrected.

 

 

[Oscar]

jj - was not intending to jerk your chain in any way, but to ensure that people are aware of the divergence between CAMit's 'responsibility' for Jabiru engines and where Jabiru has placed itself, and also the context ofCAMit's development programme for the CAE engine. Given the comments by some on this forum, they would have anybody associated with Jabiru tarred with the same brush and while the agendas there are obvious, it needs to be understood that the differences are real and significant.

 

 

[jetjr]

no problem.

 

Im tired of some thinking because some support Jabiru engines and are upset by CASA action that I somehow support Jabiru themselves.

 

They have plenty to answer for including poor customer service and backup.

 

I deliberately purchased a used 19 reg aircraft so I wouldnt be bound by LSA restrictions and therefore bound to Jabirus service and decisions. Ive had very little to do with them.

 

This action now makes some, who have near nothing to do with the company, totally reliant on them to fix the problems under a moral service to existing owners.

 

Jabiru believe all 19 and VH exp owners no longer have "Jabiru" engines due to possible (and probable) modifications. Where does that leave them?

 

 

[facthunter]

Unless you can't access "original" spec Jab parts because of some action on Stiffs part I can't see any change to the individual's circumstances UNLESS either organisation goes out of business.

 

When this is sorted ( or IF it is, ) you probably will not need to access original parts where you had to up till now. This is same manufacturer but in some instances "improved" product.

 

I can see the issue with "After market Parts and the factory support relationship". You can not expect factory support when you have undertaken extensive modifications to the basic engine (any more than you can if you don't install and service it correctly). It gives the manufacturer an "OUT" but don't forget that most warrantees have a MUSTadhere to proper service during the warrantee period, OUT or excuse for not honoring it.

 

Some of this difficulty is no doubt due to the complexity and cost of making mods to an aviation product that has been certified. The design SITS in time hard to improve.. Nev

 

 

[jetjr]

The problem becomes the limitations, loss in income for training org with Jab aircraft and devaluation of aircraft for them and others.

 

Getting parts for engines from elsewhere is largely only an option once rebuild or major work necessary - in which case you'd weigh up swapping to CAE entirely.

 

CAE cant supply "jab spec" parts as far as I know even if they produce them. So in the mean time we need Jabiru parts and need restrictions lifted. Only Jabiru can do this.

 

Experimental were unlikely to be requesting or deserving much factory support but now need it to regain full use of aircraft.

 

A NVFR J430 in VH reg based at a large airfield would be pretty restricted right now with not much way out other than new engine.

 

Warranty isnt an issue for many I expect but LSA is. Plenty are locked in there and it now becomes dependent on Jabiru to convince tech division they have fixed the problem. Any ideas how hard that will be to achieve?

 

Personally Im not too affected other than devaluation, but follow on like companies changing course, maybe folding or damage to RAA as a whole will have big impacts. No point screaming then, may as well do it now.

 

 

[turboplanner]

Once again, financial disadvantage, and we have seen multi-million dollar company closures, carries ZERO weight in safety matters. This is 2015.

 

 

[facthunter]

In some circumstances like this, it can be. Who's next?. Since the measure of suitability here is unclear it would appear it could be having to match a 912 Rotax performance at some loosely defined point in time.. Nev

 

 

[turboplanner]

Absolute rubbish FH. The Rotax name doesn't even need to be brought into the discussion for anyone with an objective mind who has been looking at the RAA reports for 7 to 10 years now.

 

Some people just like grasping at straws, and emotive red herrings like that have already been disposed of.

 

 

[frank marriott]

Absolute rubbish FH. The Rotax name doesn't even need to be brought into the discussion for anyone with an objective mind who has been looking at the RAA reports for 7 to 10 years now.Some people just like grasping at straws, and emotive red herrings like that have already been disposed of.

Alan

 

Do you currently actually fly or just talk about it. You have previously stated that you are not a member of RAA and thus don't have a certificate - your overt promotion of Rotax is "interesting" to say the lease for someone who doesn't use them or any other RAA registered aircraft for that matter?

 

 

[Camel]

In some circumstances like this, it can be. Who's next?. Since the measure of suitability here is unclear it would appear it could be having to match a 912 Rotax performance at some loosely defined point in time.. Nev

You are 100% correct in your statement! I thought CASA would not be game to hurt Jabiru, so they have everything in their sights, " just destroy everything" is the CASA moto. In a sense Jabiru have been the most successful in LSA production. Piper, Cessna and others have failed ! CASA's limitations are hurting operators not solving the problems.

 

Things are just getting warmed up as I think something is going to hit the fan soon !

 

 

[turboplanner]

I was not under the impression I had promoted Rotax all. In fact I consider it irrelevant.

 

I have repeatedly referred to published RAA statistics, apparently one of the very few people to actually check the figures.

 

It's a fantasy to suggest that safety action should be based on a popular engine rather than evidence based issues.

 

 

[Camel]

As you are not a member of RAA you would not have read the December newsletter. Here is the relevant part.

 

Note to members on Jabiru issues

 

As most people are aware, CASA published a draft instrument on 13 November 2014 which would have the effect of restricting the operations of aircraft with a Jabiru powerplant. This would affect more than 1000 RA-Aus registered aircraft and have an adverse impact on some two thirds of our flight training facilities.

 

Since the publication of this draft instrument RA-Aus has been working hard to understand the justification for these restrictions. We have, for some time, known that Jabiru engines have a higher tendency for failure than their Rotax counterpart and welcome any appropriate changes that would improve their reliability. We would also welcome any measures that result in improved reliability and safety of any aspect of our fleet. Having said this we are troubled by the process employed by CASA and especially the lack of transparency in terms of the implementation of these proposed measures.

 

RA-Aus has repeatedly requested the information used to justify statements made by CASA that claim the failure rate is increasing. We have also requested the analysis of said data in order to assess the veracity of these claims.

 

On 17 December 2014, almost five weeks after the draft instrument was published, RA-Aus received the data and was provided one, yes one, working day to respond. As one would expect we would have liked much more time to assess the data, understand the analysis and then form an opinion on the suitability of the proposed measures, however, regardless of taking some five weeks to provide the data, CASA allowed one day. In light of this our response was somewhat rushed.

 

Despite this, RA-Aus was able to note that the data provided to CASA on Jabiru engine failures only covered one partial year. The only time series data made available to us (although not provided to us) was via the ATSB. That is, no engine failure data beyond the beginning of 2014 was used by CASA to justify their position and they left us to infer what data the ATSB had provided.

 

With reference to the latter, RA-Aus has contested the validity of the ATSB data on the basis that it shows a decline in the hours flown by the RA-Aus fleet. This is in direct contrast to Government published figures which show a doubling in the number of hours flown since 2000.

 

This led us to a simple conclusion – CASA has not undertaken robust analysis on reliable data to establish with any degree of accuracy that the failure rate of Jabiru engines is increasing over time. This is despite their statement that they have found statistically significant evidence in support of their claims.

 

RA-Aus’ position is, as stated above, that the failure rate of Jabiru engines is greater than that of Rotax engines but that it is not worsening as per the unsubstantiated statement made by CASA.

 

In light of this RA-Aus responded to CASA, within their incredibly tight and unrealistic timeframe, to state that we oppose their draft instrument and suggested an alternative approach to addressing the real concerns. While CASA acknowledged that our response had merit within 24 hours of receipt they proceeded with the restrictions without due consideration of our arguments.

 

While the restrictions imposed on our members are less stringent than those originally proposed, our opinion is that they are still inappropriate. Furthermore, CASA has remained evasive in terms of providing information relating to what rate of failures would be deemed acceptable and so we remain uninformed as to what point the restrictions will be lifted other than the statement on the CASA website regarding a review by CASA early in the New Year and the six month validity of the proposed Instrument. We will continue to work with CASA and Jabiru in an attempt to address these issues, however, we can’t provide further information at this point.

 

RA-Aus is extremely worried about these actions and what this may mean for private aviation in Australia. Being the fastest growing sector of aviation it concerns us that unilateral action has been taken by the regulator that is not backed up by robust evidence which suggests the action is justified. It worries us that this precedent has the potential for further restrictions that may not be warranted based on incomplete data, deficient analysis and/or misleading claims. We also have concerns about the implications of CASAs decision and what it means for all self-administered aviation organisations as Part 149 is implemented.

 

RA-Aus will focus our efforts on improving safety in our sector by reviewing training methods and practices, improving our education programs, communicating safety findings (where permitted by law) and so forth. We will also remain very focussed on the outcomes of CASAs recent actions, the Governments recent announcements about the recommendations of the ASRR report and continue to hold CASA to the same high standards that they demand of the aviation industry.

 

 

[turboplanner]

Yes Camel, I'm aware of all that.

 

Given that the first multiple forced landings I looked at were in 2007, I don't have a problem with the timelines or actions, because I've been dealing with the same timelines for decades, and it even seems to me that some of the policies of other DIRD departments have flowed on to CASA in recent years.

 

One point here. This matter is between CASA and Jabiru the company, so I wouldn't expect CASA to have to explain their actions to others.

 

Regardless, the Instrument is in force and still there is very little understanding of the operational implications. That's where the discussion needs to be.

 

 

[aro]

This matter is between CASA and Jabiru the company, so I wouldn't expect CASA to have to explain their actions to others.

Not true - the action is effectively between CASA and Jabiru owners and operators. CASA haven't put any restrictions on Jabiru's manufacturing (other than the obvious problem of selling aircraft with these restrictions on operators). The restrictions apply to the operaton of existing aircraft. Jabiru itself is just the company that the Jabiru owners and operators hope will fix the problems. Jabiru could easily decide that it's all too hard, and leave the aircraft manufacturing business altogether. It's probably the rational choice - trying to fix the problem risks spending a lot of money on testing and development, without any guarantee that you can satisfy CASA at the end of it.

 

The biggest issue is that the problem seems so loosely defined that it could take years to gather enough data to say whether any particular fix is effective. The data we have seen showed a failure every 1500 hours, from memory - how long does it take to produce enough hours on enough engines (with whatever changes are proposed) to say whether that rate has changed?

 

There are other important questions, like the distribution of failures - are they evenly distributed through the engine lifetime, or mostly early or late in the engine lifetime? Clusters in certain operators, or random? All these questions effect how you determine whether the problem is fixed. This is the type of information that people asking for statistics want - not just the number of failures which seems to have been all that has been provided.

 

 

[turboplanner]

I note your use of the word "effectively", but it works on the "direct" parties.

 

If the manufacturer were to solve the problem and issue a recall, it would all go away.

 

It's up to the manufacturer to solve the problem, not the Safety Authority, and it's up to the people affected to find a safe way to operate within the Limitations which highlight the risk possibilities in a very public way, making it a potential minefield.

 

 

[aro]

I note your use of the word "effectively", but it works on the "direct" parties.

If you read the Instrument it sets out "Operating Limitation for Jabiru Powered Aircraft". Operating limitations affect the operator, not the manufacturer, and the Instrument specifically says the "pilot in command of a Jabiru-powered aircraft" and "The CFI of a flying school" operating Jabiru powered aircraft. They are the direct parties in the Instrument.

 

 

[turboplanner]

So CASA wrote to those people, and asked them to comment?

 

If not, they are indirects.

 

 

[Guest Ornis]

Which you twisted to say he thinks all Jabiru engines are sound. Not true.He designed and built it, now using it as a base for the improved CAE engine. Why wouldnt he think it was OK.

 

After the solid lifter engine, Jabiru went on a diferent track, using his and other parts.

No, I didn't twist it, I know what you said. I gave you an answer then and I'll give you the same answer now:

 

I agree with jetjr there was a well tested precursor to the CAE but I don't think CAMit thinks the solid lifter Jabiru is quite sound.I think Ian "understands" the engine and believes he can make worthwhile improvements, and has indeed made modifications which - as facthunter has explained - should counter some of the problems. Better alloy for the heads is no secret.

 

Also, he will state categorically you need to monitor all CHTs and EGTs whereas Jabiru continue the line "one CHT no EGTs" which is 100% wrong.

I think you have misunderstood Ian Bent's thoughts. You have built up a picture in your mind which is at variance with the facts but reassures you your engine is safe, as safe as any other. Solid lifter Jabiru engines had serious problems and yours - being secondhand(?) - has an unknown history. I doubt it had six CHTs and EGTs from new.

 

CASA ignored problems with Jabiru for years but has finally acted. You think CASA is wrong. Never mind.

 

Are you really quite sure you want your children in the aircraft if you have an engine failure? YES/NO.

 

 

[Guest Ornis]

CASA made a judgement. It is primarily a judgement that there is a problem with Jabiru engines. But, secondarily, it is a judgement RA-Aust is incompetent.

 

RA-Aust did nothing. It's so unfair.

 

 

[jetjr]

I have and will continue to fly many hundreds of hours with my kids in the plane. Its no more dangerous than it was in November or the previous 7 years

 

For whatever reason, in almost 1500 hrs in Jabs I havent had one issue from engine reliability. And many hundreds of others are the same.

 

I clearly understood my conversation with Ian, as is often the case these conversations should be kept private as this sort of crap happens. The conversation was over 30 minutes, care to comment on what else was said and he really meant?

 

Not sure why you even comment on my aircraft and history as you have no idea about it or me and once again quite wrong.

 

Yes there were some issues in solid lifters, some not yet solved but many were. A portion of those in NZ were plainly poor operation and dodgy components from what ive seen.

 

Issues with overheating heads, tappet adjustments and not enough fuel were well known enough in 2007 for some in Jabiru to be recommending full EMS systems, coming out with cooling upgrades and new fuel mixture SB's and privately some doubt as to hydraulic engines reliability.

 

Discussions with engine dept would have given guidance to head recession management.

 

Operators assuming they were just like a Certified GA engine are a key problem even today. LSA perpetuates that myth.

 

Im not actually sure why those with no vested interest in this problem bother to come here and comment.

 

If you think theres a safety problem get rid of the aircraft, dont selectively fit a few aftermarket bits, tighten the flywheel and say its now all OK because youve done a few hours like that.

 

Numbers touted now indicate 12 engine outs in 90,000 movements. In addition NO ONE has been hurt, as far as I can see ever.

 

As far as the safety issue is concerned, the ATSB data from 2009 seems to show no major issue TP, yours must be from somewhere else. The issue very plainly Rotax vs Jabiru as this is what CASA have stated. Id suggest many other engines are in line for similar treatment if thats the industry standard, including other models of Rotax.

 

Tomorrow Jabiru could decide to fit Rotax engines and keep selling aircraft. Thats their business, not servicing old ones.

 

Theres no concrete reason for them to do anything about it so absolutely this is an attack on owners who have no capacity to release restrictions but move to other engines.

 

Remember all those 1000 x aircraft will now be experimental and can fit and modify whatever crazy engine they like. What if those new wide selection of engines, many completely uncertified, have little reliability data and are totally untested? You think that is a good safety outcome?

 

CONTINUALLY people are repeating "just should have fixed it", its clearly not that easy and operations and maintenance have a part in it. The incidents are random and we dont know if they follow a pattern or not as little data is held.

 

I cannot believe you think that financial impacts wont effect safety under a self maintenance system.

 

Yes CASA wrote, many hundreds replied, they ignored them. Treated RAA with contempt and hardly spoke to Jabiru and didnt contact CAE at all.

 

Couldnt even be bothered to analyse data they were given. Doent even match ATSB preliminary data or findings.

 

Fine piece of management and regulation there........and your supporting it why?

 

Sounds like you think current regulators are doing a great job choking the life out of general aviation.

 

Just because many disagree with the course of action doesnt mean they disagree that action needed to be taken. There are productive and destructive methods of regulation and this will most likely produce nothing and cost plenty