CASA 292/14 - Conditions and direction about Jabiru engines

[jetjr]

All good points you raise but the main one you missed is that the evidence doesnt support the action

 

but mainly as has been said REPEATEDLY

 

Most understand action was required, the method used will achieve nothing towards safety and damages owners and doesnt force Jabiru to do anything.

 

 

[Bruce Tuncks]

I was told that the real problem with Jabiru accepting CAMIT mods was the cost and difficulty of re-certification.

 

Now I've always thought CASA were pretty bad, what with them being staffed by ex-airforce people who have never had to think about time or money constraints, but surely they are not this bad?

 

I guess a related question is how much it would cost CAMIT to certify their engine and where would this money ( if any ) go to?

 

Here's an irrelevant point... the new strike fighters will cost the taxpayers $200 million each, and 80 are on order. Each one costs 2,500 Jabirus.

 

 

[Oscar]

I guess a related question is how much it would cost CAMIT to certify their engine and where would this money ( if any ) go to?

.

Bruce, it depends on what certification / certifying is undertaken.

 

However, for either set of tests, a facility that can undertake the required set of tests to the required standard of validation (i.e. using calibrated equipment, using a 'representative' propellor, and running to the prescribed set of 'blocks' that re designed to produce a representation of actual operational conditions) is required. There is a lot of data analysis necessary, and also things like 'tear down and measurement' of the engine when tests have been completed etc. If you were CAMit and looking to do a full 'suite' of testing for certification / certifying, start contemplating figures in the $350 - $500k mark and you're in the ballpark.

 

For JAR 22H certification ( as on the 2200 certificated engines, or the Rotax 912 A series, which produces a TCDS), CASA 'observation' of the testing is required under the standard. That alone is of the order of $50k based on rather old figures for CASA, it could be considerably more nowadays. Much of the rest of the costs is in consumables, engineer's services etc. Testing to JAR 22H requires 50 hours of running 2-hour 'blocks' of tests. JAR 22H does not produce figures for TBO's, those are established by the manufacturer based on experience in service.

 

For certifying an engine to ASTM (the 3300's are certified, not certificated), CASA is not involved though the reliability of the testing has to be carried out to a very similar standard, with records kept and the accuracy required meaning that the infrastructure used for testing is essentially identical. The test blocks are similar but not identical. However ASTM requires a set amount of testing time for the initial establishment of TBO ( I'm not sure what the mechanism is for 'adjustment' based on operational experience following that.) To claim an initial TBO of 1000 hours requires 200 hours of test running.

 

 

[Guest Ornis]

All good points you raise but the main one you missed is that the evidence doesnt support the actionbut mainly as has been said REPEATEDLY

Most understand action was required, the method used will achieve nothing towards safety and damages owners and doesnt force Jabiru to do anything.

You must have missed it, third in my list was "Lack of evidence". Leaving that aside, what action do you think CASA should have taken?

 

 

[Bruce Tuncks]

thanks Oscar, you sure know this stuff.

 

These sums of money are obviously beyond what the companies could pay. I would like to think that was deliberate, because this would mean there were some brains behind it all. Alas, I think it is the result of stupidity and having committees stacked with people who have always had fat government salaries.

 

Ornis, I think CASA should take the action to disband and return their last years salaries to the taxpayers.

 

 

[Oscar]

Ornis, we are actually progressing - rather painfully and with a huge amount of static from the drum-beaters who cannot get off their own soap-boxes - to an intelligent appreciation of the overall issues that the CASA action has raised.

 

When we discuss 'lack of evidence': to quote a famous phrase that has gone into the lexicon: 'what we have here is a failure to communicate'.

 

CASA has nominated a number of 'failures' that it claims validates its action. It has NOT released the raw data for public scrutiny, so we do NOT know whether CASA's definition of 'failures' corresponds to reality. I believe this needs to be recognised, because it is surely extremely dubious that if CASA believed it was a 'slam-dunk' situation, it would not be being evasive in supplying the data for public scrutiny. The ATSB figures do not provide authentication for the CASA assertions; the only 'authority' that has had access to the CASA data has emphatically repudiated its authenticity as validation for its action. Lest you think I am employing sophistry here, I do have some reason to believe that at lest one of the 'failures' listed by CASA was a locked brake - but without access to the CASA data, neither I nor anybody doubting that contention, actually knows.

 

When examining data at an epistemological level, to derive reliable 'truth' from the data it requires balancing the 'supportive' from the 'negative' data. In less sophisticated terms: if you have 10 occurrences of condition 'A' and 90 occurrences of condition 'B', it is invalid to state that condition 'A' predominates. The existence of indisputable proof of the existence of condition 'A' is NOT indisputable proof that condition 'A' is the ruling class.

 

There is no international standard measure for 'acceptable' reliability for aircraft engines. There are metrics for engines by which an individual may choose to judge her/his exposure to risk: TBO, MTBF etc. By its action, CASA has arbitrarily and unilaterally decided that there is a cut-off point for risks deemed attached to 'failures', above which it considers that participants in recreational aviating need additional limitations for their safety.

 

Even if we are disposed to accept that CASA's 'line in the sand' is reasonable, the question of why those engines that do not demonstrate reliability at or below the level of the 'line in the sand' has to be resolved. For instance: just because a small number of participants may fly behind an auto-engine conversion that does not statistically achieve the 'line in the sand', how does that justify the non-application of the 'new' CASA standard for reliability?

 

The CASA action, when looked at holistically, ( and by that I mean taking into due consideration the actual figures for the effects of Jabiru engine problems in terms of fatalities/serious injuries to participants / any effects on 'non-participants aka 'innocent victims on the ground'), is extremely lacking in credibility. CASA itself will not open its 'validation' to public scrutiny.

 

I have no issue whatsoever in supporting the general belief that Jabiru engines need improvement to their reliability. However, that is not the entire spectrum of the issue here, which is: what actual risk factor of fatality/serious injury is attendant on the use of Jabiru engines by comparison with other engines? The argument of 'potential' is bullsh#t here: we have the figures for 25 years of operation of Jabirus with possibly one fatality due to engine failure; there are a considerable number of other types with multiple fatalities and serious injuries that appear to have escaped any CASA attention.

 

Should pressure be put on Jabiru to seriously improve the reliability rate of their engines?" I believe that answer to that is a resounding 'YES'. Has CASA undertaken action that would achieve that result, while still considering the full implication and effects of their precipitate action? I believe that the answer to that is an equally resounding 'NO'.

 

 

[turboplanner]

It's rather interesting that when these broken records were formally given the opportunity by CASA, who had publicly stated a proposed action, to make their cases, no substantive submissions appear to have been received.

 

 

[Oscar]

thanks Oscar, you sure know this stuff.These sums of money are obviously beyond what the companies could pay. I would like to think that was deliberate, because this would mean there were some brains behind it all. Alas, I think it is the result of stupidity and having committees stacked with people who have always had fat government salaries.

Ornis, I think CASA should take the action to disband and return their last years salaries to the taxpayers.

Bruce: the 'system' means that the companies HAVE to pay these sorts of sums to get the necessary 'ticks in boxes'. If you are a company like Textron or Bombadier, that investment is a line item in the annual budget submission; if you are a Jabiru or a CAMit, it's 'my home and everything we all own, maybe down the gurgler later this year' stuff.

 

World-wide, the premier manufacturer of light sport aircraft engines is Rotax (Bombadier), with Jabiru second and Lycoming a very distant third on numbers in use. Companies like d-motor and UL Power, are frankly minnows in the Pike pool by comparison and are not even in the hunt for certification / certification.

 

 

[Oscar]

It's rather interesting that when these broken records were formally given the opportunity by CASA, who had publicly stated a proposed action, to make their cases, no substantive submissions appear to have been received.

That is a complete and utter denial of the submissions, including by RAA. Repeated assertions of an untruth do not change its status.

 

 

[facthunter]

Is there anyone in CASA who would be across this in a technical sense? I was unable to find access to one. My main objection has been the process. The technical issues are another matter. Calling people broken records doesn't help Turbs. People are entitled to have a different view to you. I stand for the owners and operators getting a fair go and the means of rectification being still around in the future. (Not sent to the wall).

 

You have labelled some of my comments as "Absolute Rubbish" and "Hysterical". Thanks for that. Doesn't leave much does it? Nev

 

 

[turboplanner]

No it doesn't, but I'd sure sit up and sing the opposite tune if I saw some substantive facts.

 

 

[gandalph]

It's rather interesting that when these broken records were formally given the opportunity by CASA, who had publicly stated a proposed action, to make their cases, no substantive submissions appear to have been received.

"No substantive submissions appear to have been received." ? You have some evidence to back that assertion or is that simply your opinion, belief, guess?

 

David posted earlier that you have made many valuable posts related to safety and I have seen many posts from you on a variety of matters where you put forward cogent arguments to support your opinions, but posts like the one quoted above do nothing for your credibility.

 

 

[turboplanner]

Well clearly you don't have any evidence of one Gandalph, so no need to bother engaging in your games.

 

 

[Oscar]

No it doesn't, but I'd sure sit up and sing the opposite tune if I saw some substantive facts.

And yet you espouse the validity of the CASA action based on a complete lack (refused to divulge the substance) of substantive facts? The rest of us can see a double standard here...

 

 

[Guest Ornis]

When examining data at an epistemological level

Thanks, Oscar, and I do take you seriously, seriously, but this is not a question of metaphysics. The simple fact is there is a problem with Jabiru engines and my question is, what was CASA supposed to do?

 

 

[gandalph]

Well clearly you don't have any evidence of one Gandalph, so no need to bother engaging in your games.

I'm not the one making the assertion Turb, you are. I was just asking if you had some evidence to back yours up.

I don't have any evidence other than posts from people here who say they made submissions. But that's not evidence, it's heresay. They might all be telling fibs. I don't know what was in those submissions other than what the posters alluded to here in these threads, so I can't judge if they were substantive or otherwise. Can you?

 

I'm not saying you're wrong I'm just inviting you to help us less fully folk here informed folk believe you might be right. It was an invitation, not a demand.

 

I don't think I'm playing games, It wasn't me who called it fun.

 

 

[gandalph]

Thanks, Oscar, and I do take you seriously, seriously, but this is not a question of metaphysics. The simple fact is there is a problem with Jabiru engines and my question is, what was CASA supposed to do?

Better minds than mine have argued that their decree exceeded their authority and that they should have restricted their action to that allowed by law. That argument is pointless now as the damage has been done. We now have to play the cards we've been dealt.

Wow! 2 cliches in a row, time for a coffee or a glass of red.

 

 

[turboplanner]

And yet you espouse the validity of the CASA action based on a complete lack (refused to divulge the substance) of substantive facts? The rest of us can see a double standard here...

No Oscar.

 

 

[turboplanner]

You have labelled some of my comments as "Absolute Rubbish"

 

There's far more pressing safety issues than this one Turbs.[/Quote]Now's your opportunity to get these out in the open, so any injuries and fatalities can be prevented/reduced.

[Guest Ornis]

Better minds than mine have argued that their decree exceeded their authority ... argument is pointless now as the damage has been done.

It still doesn't answer the question, what was CASA supposed to do? I think it's a reasonable question. CASA could have done nothing or grounded Jabiru-powered aircraft or something in between - which it did, restrictions on who, where and when you fly. But what could or should it have done?

 

I have no opinion on CASA exceeding its authority. I don't think Jabiru would want lawyers poking into its affairs though.

 

Nor do I think it needed intervention from CASA to damage Jabiru's reputation and sales.

 

 

[jabiruken]

I have been watching this thread for a while. It seems to me that what has emerged in all this is, that casa has taken some 20 years to claim jabiru engines are not safe.. Really? If casa audit was only compiled using only recent 12 months worth of statistics of engine failures, then that should reflect on current engines and not engines in service 12 years or more such as mine. especially experimental wich are most likely modified.. If casa had done its home work all would be not doom and gloom for jabiru, but offered a way out to improve its reliability.

 

 

[Bruce Tuncks]

Good point Jabiruken. My engine is S/n 425 and hardly any of the AD's apply to it. Last week I asked about changing the flywheel bolts and I was told it wasn't needed because there hadn't been any problems with those engines.

 

Oscar, what do you see as the way out here for Jabiru and Camit and us owners? Personally, I have had 15 years of trouble-free operation, but I wouldn't object to anything that increased reliability, after all you can't have too much reliability.

 

For example, could Jabiru accept some modifications under its existing certification, without incurring megabucks of costs?

 

 

[dazza 38]

A

 

I was told that the real problem with Jabiru accepting CAMIT mods was the cost and difficulty of re-certification.Now I've always thought CASA were pretty bad, what with them being staffed by ex-airforce people who have never had to think about time or money constraints, but surely they are not this bad?

I guess a related question is how much it would cost CAMIT to certify their engine and where would this money ( if any ) go to?

 

Here's an irrelevant point... the new strike fighters will cost the taxpayers $200 million each, and 80 are on order. Each one costs 2,500 Jabirus.

Actually I can assure you that it is a fallacy to say that Airforce people don't have to think about time or money constraints. In the nineties, we had to complete with civilian companies for intermediate and deep level maintenance on F111's. It has been the same ever since. The military do not have a open check book.

 

 

[jetjr]

Casa could have spent time gathering data, making sure it was sound and real causes for problems identified, narrowed down to engine model, age, use, maintenance proceedures, getting responses from those who do have technical expertise

 

Enabled certification proceedures for other manufacturers to provide parts to LSA aircraft.

 

Maybe have a path to solution worked out rather than asume by punishing owners a very small manufacturer, no doubt in financial stress, would donate massively to customers to fix engines.

 

A detailed risk analysis of actual not percieved risks

 

Think i wrote this same message a few times now, talk about not getting the message.

 

 

[jabiruken]

Good point Jabiruken. My engine is S/n 425 and hardly any of the AD's apply to it. Last week I asked about changing the flywheel bolts and I was told it wasn't needed because there hadn't been any problems with those engines.Oscar, what do you see as the way out here for Jabiru and Camit and us owners? Personally, I have had 15 years of trouble-free operation, but I wouldn't object to anything that increased reliability, after all you can't have too much reliability.

For example, could Jabiru accept some modifications under its existing certification, without incurring megabucks of costs?

Rotax 912 have tbo 2000 hours or 10 years, which ever comes first. Seems we both exceed those limits in years, mine is s/n 738.