Oscar

a questionSome time ago we got letter from Jabiru claiming once any modifications were done, then the engine was no longer a Jabiru and the name plate should be returned.

How do you make it no longer a "jabiru".

Well, firstly you need to understand that the removal of a data plate from an engine, prop etc. is a criminal offence unless authorised by CASA:

 

Part 4D Removal of data plates and registration identification plates

 

56 Definitions for this Part

 

In this Part:

 

manufacturer’s data plate means a manufacturer’s data plate attached to an aircraft, aircraft engine or aircraft propeller

 

under Division 21.Q.2 of CASR.

 

57 Removal or alteration of manufacturer’s data plate

 

(1) A person must not remove from an aircraft, aircraft engine, aircraft propeller, propeller blade or propeller hub a

 

manufacturer’s data plate that has been attached to the aircraft, engine, propeller, blade or hub, if the person does not have

 

CASA’s written approval to do so.

 

Penalty: 20 penalty units.

 

Note The removal of a manufacturer’s data plate is permitted during

 

maintenance, subject to conditions — see regulation 60.

 

(2) A person must not, without CASA’s written approval, remove

 

or engage in conduct that results in the alteration of any of the

 

information on a manufacturer’s data plate required by

 

Division 21.Q.2 of CASR to be there.

 

Once Jabiru has released an engine with its data plate attached, it is a 'Jabiru' engine - modifications or not. That is why a CAMit 'core rebuild' engine retains the Jabiru data plate but adds a CAMit 'modifications' plate.

 

A CAE engine has NOT been 'released' by Jabiru but by CAE so it has its own data plate and Jabiru have no legal responsibility whatsoever for that engine.

 

So the short answer is: you cannot 'de-Jabiru' an engine that has had a Jabiru data plate attached.

 

 

The SPECULATORS don't have solid data.RAA DOES HAVE accurate data on every incident reported along with at least a brief set of notes as to the the cause (or for the pedants, the symptoms) - unless they've lost that data or thrown it out.

Safety decisions should always be based on specific evidence,.

RAA email of 22 December:

 

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.

 

 

Merv, I have no idea what you smoke, but it must be damn expensive.

 

Merry Christmas.

 

 

No, thats my primary ego.

Merv - I do share your pain. There may be an ointment?

 

 

Yep, you certainly would have taken a loss on that one too ey?Id be surprised if it takes that long, but Ill be here, egg removing utensils in hand (once again) to assist you :)

Merv, RAA did NOT take 'action' (it has no power to take 'action', you need to look at the regs here to realise why. ) CASA took 'action', and refuses even to divulge the 'data' it claims to hold as the basis for taking that action.

 

Look at the RAA response, FFS: the RAA Board repudiated the CASA action in toto. The intelligent members of the Board understand the scope of the issues involved.

 

 

Are you listening to your alter ego there?

 

 

Who wants a wager? Ill bet within 3 months we see Rotax optioned in jabs. $10. Cybershake on that!!

At $10, not worth even considering. But - I'll be revisiting that promise on 22/03/2015. Given your exposition early this current year that RAA was 'going to take action' on Jabiru, I reckon I'm on safe gound even if I took a $100 bet to be delivered bare-arsed in the middle of George Street on a Saturday afternoon. And I have NO desire to be the recipient of your bet.

 

 

In relation to the above quoted piece from Phil Ainsworth: IF my memory serves me correctly, the MTOW allowable under 95.55 at the time the LSA55 was designed, was 450 kgs. In one of the rare examples of the Australian Airworthiness authority actually listening to its constituency, it raised that to 544 kgs, quite a time later. (Just for once, Australia lead the world there).

 

Jabiru developed a unique business model for aircraft production: the extensive use of 'cottage' contractors supplying parts to the factory for assembly. ( One saw trailer loads of fuselages, wings etc. coming into town for delivery to the factory from the individual contractors.) That, in turn, necessitated a methodology for manufacture that could maintain adequate QA from production in a simple 'backyard' environment: hand laid fibreglass woven rovings with ambient-cure, temperature-tolerant resin: Araldite LC3600.

 

In the choice of a low-tech composite construction capable of being produced very much on a 'shoestring' - without the expense of high-tech facilities that would have required significant increases in the cost of the aircraft in order to amortise the cost of the facility development - lies the genesis of the recognised Jabiru airframe toughness. Those who understand composite construction design will appreciate the differences between resilience and strength; for a classic example, you need look no further than mass-production low-tech and ( reasonably) affordable composite yachts that regularly bounce off wharves, rocks, other boats, vs. the ultra-hi-tech all carbon-fibre Australian 12 metre yacht that broke in half in San Diego harbour and sank in seconds. It was designed to provide maximum strength (and stiffness) for the duration of the Series and not one minute more (the designers' words), but missed that target..

 

NO Australian aircraft manufacturer - of which there are very few - has achieved the sorts of numbers for domestic and international sales, ever, that Jabiru has - by orders of magnitude. There is NO Australian-produced aero engine that has achieved certification / certifying to ICAO-accepted standards, other than Jabiru. Jabiru's competitiveness in the international market is a combination of performance and price and the cost of the engine is part of the price equation, while the weight is a significant part of the performance equation.

 

That current Jabiru engines do not cut the mustard by comparison with the 'industry' leader' - is incontrovertible. CAMit has an engine waiting in the wings, as it were, that would do that and be usable in a Jabiru airframe without negating any of that airframe's other desirable qualities: cost, performance, safety. Jabiru are being intransigent, CASA is being totally unhelpful and useless in allowing the marriage of a better engine with the good qualities of a great airframe.

 

The unfolding quasi-tragedy for recreational aviation in Australia is that a Stiff-necked attitude by Jabiru, and a totally antipathetic (and self-serving, in terms of bureaucratic ethos) attitude by CASA to providing resolution of the issues, may well be the straw that breaks recreational aviation's back. Agenda-borne stridency does precisely nothing to help the situation, but indeed hastens the possibility that recreational aviation could implode.

 

 

Nev, I am not knocking the Camit mods etc. by any means the point being that without "runs on the board" what proof is being used - Automatically accept it is better, over one I have no problems with anyway, It it just stated over and over like it is accepted fact. I am not knocking the work in any way just the apparent "approval"

Frank - to use the term 'approval' in regard to CAMit engines ( i.e. CAE-plated ones, not rebuild Jabiru ones that retain the primary Jabiru plate plus the CAE modifications plate), is technically incorrect. The CAE engines are not currently 'approved', but they are also not Jabiru engines by legal definition and so are not subject to the CASA restriction on the engine.

 

A Part 21 M engineer could issue an EO for 24'C' reg (and 55-reg, for that matter) aircraft that had a 'Jabiru' engine installed, to replace it with a CAE engine. The Part 21 M engineer responsible for running the original certification for the 2200 engine to the JAR 22H standard was well across the changes and prepared - following successful completion of the JAR 22H standard test runs regime on the CAE engine - to issue EOs accordingly. That testing, in a suitable facility, was just about to start when complications with IP rights were raised by Jabiru. The ins-and-outs of that issue are not for me to discuss nor comment upon.

 

Because of some particularly obstructive application of its regulations by CASA, replacement by an EO is made extremely paper-work intensive and requires a useless set of hoops to be jumped through. It becomes a serious question as to whether it is worth the effort for a company such as CAMit to pursue this route.

 

The next level of 'approval' for CAE engines would be certification to JAR 22h, requiring a set of test runs in a suitable test facility (approved by CASA) and observed by CASA. While the test regime only requires 50 hours of running to extremely specific standards that are deemed to emulate real-life use, the estimated cost for each engine is of the order of $350k ( and that is very much an 'economy' price, calling on some long-time friendships between all the participants and much goodwill). While that would get away from the necessity for the individual EO for each replacement installation, again, the question of whether CAMit could recoup just the costs of the testing given the size of the market, does not look promising - at least as a short-term investment.

 

From a market survival POV, CAMit's best option is to have its engines ASTM certified and sell them to the world market. ASTM certifying has a formula that allows an initial TBO to be applied dependent on the amount of time the engine has successfully run in the test conditions (again, these are a range of specific conditions similar to, but not exactly the same as, the JAR 22H test regime). For a 1000-hour initial TBO - which is realistically the minimum that would be attractive in the market-place - that would require 200 hours of test running. (Incidentally, there are engine tear-downs, inspections etc. required for both JAR 22H and ASTM certification / certifying - the cost isn't just putting the petrol in and running the thing). 200 hours of test running does not automatically mean 4 times the 50-hour JAR 22H cost - but it would be a very, very sizeable chunk of money, nonetheless.

 

Obviously, unless Jabiru accepts the CAE engines as approved for LSA certified Jabiru aircraft, a big chunk of CAMit's potential market in Australia is denied to it. CASA could make a determination that allowed a variation from the 'usual' ASTM manufacturer-exclusive right to approve (or not..) modifications to its aircraft if it had the will to do that.

 

However - unless either Jabiru or CASA shifts its current position, the most likely market for CAE engines would be for aircraft NOT made in Australia. That is, providing CAMit is not drowned in the tsunami engulfing Jabiru at the moment.

 

 

Merv, you have my unalloyed support to do what you like with your own FTF. I already endorsed that.

 

As for the rest of your 'last post' - let it rest in the fading light of the evening. Jeez, you wouldn't want to be moderated for a personal attack, would you?

 

 

Way back when, casa signed off the " C " series, as structurely sound, engine etc delivered test figures to agreed values, etc etc, now they are saying it's no longer reliable, so it must follow.....the package ( type C ) is now not certified.( hello mr Camit, I'll pickup my new engine Friday )

The 2200J certification was conducted to JAR-22H standard, observed for compliance by CASA and conducted by Alan Kerr. (The Rotax 912A was also certificated to JAR-22H). The 3300 has never been certificated, but has been certified by Jabiru to ASTM standard.

 

CASA had NO input to the engine certification standards for either the 2200J or the certifying of the 3300 to ASTM standard. In the case of the 2200J, CASA observed compliance with the testing regime; I do not have information as to any CASA involvement in the case of the 3300 ASTM certifying.

 

Neither JAR-22H and (as far as I am aware), the ASTM standard for engines has a 'reliability' review factor. The engines pass the test standard, or do not - that's it. CASA is applying, in effect, a supplementary 'standard' of its own devising. Given that fact, it follows that CASA CAN accept variations to the (ICAO) standards in the domestic situation - which means it COULD accept the substitution of CAMit engines for Jabiru engines if it so chose to do.

 

Now - what we need to do is force CASA to make logical determinations that assist the recreational aviation arena. This fight is not over for any of us yet.

 

 

You are absolutely correct Kaz.I believe that this beat up on RAA needs to stop, yes the jab engine has problems but the CASA method is not going to fix it, it seems Jabiru doesn't listen to Cammit from what I heard, both will fold if this continues as I can't see anyone in their right mind buying a new Jabiru, a friend recently said he wanted to buy one and showing the fiasco to him put him right off, flying schools will need to get other than Jabiru if they want students to fly with them. If jabiru folded it would be an easy fix, just put Cammit and Rotax engines in and your laughing, I hope Jabiru goes broke and Cammit survive long enough for someone to take over.

Let's be realistic here: if Jabiru shuts up shop on Jan 1 2015, CAMit is almost certainly dead in the water as an Australian aero-engine manufacturer. CAMit invested $3.5M on equipment and facilities when Jabiru was ordering 90 engines/month; that dropped to 10 engines/month fairly quickly. Jabiru have stopped their January orders to CAMit.

 

There is no Australian 'White Knight' galloping in to save CAMit. The CASA action has, short of a bleedin' miracle, killed almost the last remnants of the Australian 3-axis and aero-engine manufacturing industry. GippsAreo has gone, Seabird has gone, Brumby has gone. Lightwing continues (I think), but has gone awfully quiet of late. Morgan and AAK are not manufacturers. Gazelles are, thankfully, reducing their numbers by attrition as contributors the the fatals rate, and does not exist anymore. Nestor Slepchev has buggered off, for which much relief.

 

So, for Australian, it's down to a Jabiru - with an international, statistically proven record as a safe airframe - or imports of varying quality and almost invariably a considerably greater price- getting worse as the $Aus depreciates. A Jabiru with a CAMit engine would be brilliant value for money.

 

 

Regard to engine the foxcon terrier was about the engine as it used a subaru with a dual ignition system but no dual plugs, so a debate able argument and that should have been sorted before it was approved.

NO! That goes against the whole philosophy of 19-reg., which is: you build it, you choose the components, and YOU take the risks. Morgan and AAK operate on this basis - do you want them exterminated?

 

 

45 in a year? Thin ?I'm not gunna entertain tit for tat with you again jet. Ic. Expressed my concerns as an operator, they don't relate to you so let's agree to comment on things that effect us ok?

Nobody has the actual data for the claimed 45, other than CASA, and it refuses to release the details even to RAA. Draw your own conclusions, but we don't have to believe them until we see the evidence.

 

Merv - I have NO problem with you putting a sign out the front of your FTF that says: 'We don't use no steenkin' Jabirus around here'. I happily accept the Voltaire principle. I also accept that I fly recreational aircraft - an action that is now legally classed as a 'dangerous recreational activity' at least in NSW - at my own risk. I have never taken off solo without the certain knowledge that it was my own decisions and actions in any circumstance that ensured my own safety.

 

You - quite evidently - have your standards for those who rely on your advice and judgement. That's entirely appropriate to your status as a CFI and nobody should have any quibble with that. But by what right do you decide that your standards must apply to everybody else? The CFI's of around 170 FTF's using Jabiru aircraft don't agree with you. That makes you in a minority of less than 1%. As the old saying goes: 'there's me bhoy - the only one in step.'

 

 

Oscar, please don't wish CASA looking at Rotax on us. The issue here is CASA's out of proportion reaction to the "jabiru problem". One of the reasons we all kicked back against their illogical response is because following this example there is no limit to the harm that they could do to light aviation.

Don - I do NOT want CASA to look at Rotax - that was not my intent at all. But you can see the rationale here: if someone makes a legal challenge against this - and there is a pretty high likelihood that someone will (remember Jabiru is legally represented by Spencer Ferrier, and a more knowledgeable of aviation matters and very capable legal counsel in this sphere you could not find), the question of 'what is an acceptable rate of failure' will arise. Since the ATSB figures ( the only ones we have to work on at the moment) conclusively demonstrate that the rate of Jabiru failures had fallen between 2012 and 2013 while Rotax figures had risen by a disproportionate amount, there is going to be almost no chance that a legal challenge will refer to those figures and demand of CASA why Jabiru had been singled out.

 

Once the fire has been lit, it burns anybody who is too close. The simple implication here, is that CASA has made a determination that the Jabiru failure rate is unacceptable while the Rotax (and any other engines used in recreational aircraft, including those that may have a greater failure rate than Jabiru engines, for that matter) is OK. Do you really think that is going to wash in a Court?

 

The CASA action is so full of both legal and regulatory compliance holes it would be shot to pieces in a Court challenge ( CASA has wildly exceeded the terms of its regulations here, by the way: neither 19-reg, nor E-LSA and Experimental-VH can, by CASA regulation, be subject to this determination). CASA would be forced to either: unilaterally retract the directive - leaving it totally open to legal action for the consequences of having started it in the first place - OR justify the action and demonstrate equivalence in applying the same standard across the board in respect of any engine used in Recreational / Sport aviation. It's going to be extremely hard for CASA to make a determination that Rotax 'makes the grade' while everybody else does not.

 

If you throw a hand grenade into a pub, you can't be sure that only the infidels will be injured.

 

 

Not at all Gandy. Nev made a statement that if true has lots of merit in the conversation. if there is indeed a "worse" engine out there, then I for one want to know what it is. Secondly, CASA need to explain why these "worse" engines arent being legislated 'against'. I dont want p1ssing contest either, but I would like statements like " there are worse" engines to be explained.We have a hole in our school now, that needs filling. If there is another suspect engine out there, I want to make sure we dont end up with that bugga online too:)

Merv - what is, in your view, the cut-off point for an acceptable rate of engine failures per 10,000 hours of flying vs a non-acceptable rate? I think we all agree that there is no such thing as a fail-proof engine, so at what point would you be prepared to say to your students: 'well, this engine is less of a risk than that one, so I'm happy to send you off into the blue with this engine but I wouldn't dream of exposing you to the risk of that one?'

 

Your concern for your student's safety is commendable and I in no way denigrate the value of that; there are apparently about 170 FTFs that currently have a different view to you. Here's an opportunity for you to provide them with guidance.

 

 

The failures have to be defined more accurately. and have to be a % of hours flown or take offs or such. I wouldn't rate a soft cylinder at 500 hours as a failure. Plenty of engines won't make that and often there are specific reasons why these things happen. (Like leaving the engine sit idle for long periods or having a severe overheat event, that is not followed up). Nev

CASA has resolutely - and in the face of repeated requests from RAA - refused to make the data they are quoting available for inspection and comment/challenge. Board members were fighting against this action right up to the knock of Friday afternoon, working through the night and the wee small hours of early Friday morning. It is of course entirely a matter for the Board to make the details of how the actions of the last few days between RAA and CASA have played out, but if that ever surfaces it will be apparent that the RAA Board went down fighting valiantly to the last. An immediate challenge to the directive is underway.

 

This was the acting DAS, Terry Farqharson's last-ditch act of bastadry towards Sport aviation and there can be no effective comeback against him. It book-ends the McCormick 'regime's' entire tenure at the top of CASA and its consistent opposition to Sport aviation generally. The incoming CASA DAS, Mark Skidmore, attended the AOPA Flight Crew Licensing Regulations Review Forum meeting on Wednesday 17th December. The report of that meeting concludes:

 

The new DAS Mark Skidmore, whilst he has a huge task ahead of him, seems genuine in his desire to change the culture within CASA, he reiterated his and CASA's intent to implement the recommendations of the ASRRP.

 

I suggest it is not at all fanciful to believe that this final act by Farquharson was a parting shot across Skidmore's bows as he hoves into view - a spiteful 'cop that, young Harry' act motivated by indignation that the McCormick / Farquharson 'legacy' might be repudiated and dismantled. In a just world, those two would be hunted down by a righteous Sport aviation community and gutted like clams - oh, I AM sorry, I mean apprised of our displeasure.

 

 

Since the ATSB figures recently released showed a DECREASE of about 18.75% in the rate of Jabiru engine 'incidents' from 2012 to 2013, while Rotax had an INCREASE in 'incidents' of nearly 60% over the same period, it's a bit of a stretch on CASA's part to single out Jabiru as having an increasing rate of failures while ignoring Rotax. By what logic does a difference of .6 of an engine 'incident' per 10,000 hours flown become the dividing line between 'unacceptable' and 'acceptable'?

 

 

I know a number of excellent LAMES and L2's, but a bad operator is bad news. We recently visited the RAA Tech. Assistant Manager with photo evidence of work done by a (very well-known!) L2 on our aircraft and the log-book entries associated with that, for advice as to how RAA wanted that handled. Suffice it to say that Jared was appalled and required us to submit a detailed Defect Report - it will take several pages - but RAA has also recognised that the current RAA aircraft Log book does not meet standards for evidence and needs an upgrade.

 

Since that work was done prior to our ownership of this aircraft, I have no idea of at what cost - but work was signed off by an L2 that was, quite simply, potentially fatally dangerous. A rudder locked over on one extent is an unrecoverable situation. The main U/C leg bolts potentially failing because they were of incorrect length and used when new should have been installed (by the Maintenance requirements) when changing from a standard to 'heavy duty' main legs, is probably not potentially fatal, just potentially damn expensive.

 

 

Deb ... is apparently the only one on this site "coming out with crap"

Please - not when I have a mouthful of coffee. Have a care for the replacement cost of screens.

 

 

That is in fact, quite incorrect.

 

CAMit engines are - by specific written statement from CASA - NOT Jabiru engines. They have a CAE data plate attached and a CAE serial number. They are NOT affected by the proposed notice and no restriction on the operation of aircraft powered by a CAE engine would apply even if the proposed CASA action eventuates.

 

CAMit holds a letter from CASA stating this, that CASA issued for clarification of that matter within a day or so of the original draft notice. This applies to aircraft registered either as VH or by RAA. I am aware that at least some Board members - who are across the issue - know this.

 

 

I don't think there's anything special about steel for the pins but I could ask Ian Boag PhD (Chemical Engineering).

Perhaps for your safety, you should do that, with reference to the electrical potential of different alloys. That is, if you don't want your control surfaces to drop off.

 

 

Good on yer mate.The factory has an "option A" on factory-built aircraft with just one CHT and no EGT.

 

How is a buyer supposed to know that this factory option is (in your opinion) dumb? Could there be other dumb ideas from this factory? Perish the thought.

Well, for sure. Or, you could decide to spend more than $40k installing a Rotax, rather than $2k installing a full EMS using an MGL Extreme and just perhaps been able to monitor your engine management and get a decent life out of the engine you decided to throw away? Yet - if I remember correctly - you were the guy who replaced your aileron hinge pins with bronze wire to save the cost of changing the hinge pins to the recommended material.

 

 

Bit of a crude heads-up there, Gandalph...

 

 

I'm really hurt by that lack of trust Oscar

Jeez, you must be used to it by now, FT....