Received a reply today from CASA in relation to my invited submission on the proposed draft document.
In part below.
Sounds like they are on the front foot. IMHO
CASA has been looking at data and reports about Jabiru piston-engine failures for some time. In the course of that review, problems related to Jabiru engines that have stood out range from full and partial power loss and in-flight engine shutdowns, to rough running and oil leaks. CASA has identified more than 40 Jabiru engine problems and events that have occurred in 2014 alone.
Mechanical problems that have been identified by Jabiru include through bolt, valve and cylinder, and fly-wheel bolt failures. The contribution of particular kinds of operations (for example, student training) and maintenance-related factors to some of these failures has yet to be determined.
Jabiru, as the manufacturer of these engines, has certain obligations under the relevant International Standards, and civil aviation safety legislation in terms of the identification and rectification of such engine problems irrespective of when they occurred or what may have caused them, and CASA is working with Jabiru to arrive at a solution.
Phil.