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CASA 292/14 - Conditions and direction about Jabiru engines


coljones

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I was talking about very basic principles, and left Jabiru out of it. You've weaved it back in

Well to be fair it was you who reminded us not very long ago about the title of this thread. I was merely keeping the conversation relevant.

 

Since we were not talking about Jabiru, we won't confuse the issue, but we agree it sits in the newer category.

I don't want t get too cuddly so I'll reserve my decision on whether I agree with you on that. I'll give it some more thought overnight.

 

I'm now talking about the performance requirement, which is that spectators must be protected. (Standard would be the ADR if it was a car)

Now you're shifting the terms around again to suit your hypothesis. We are not talking about cars and their regulatory environment is not as analagous as you would like us to believe. There is no performance requirement for RAA engines. We did agree on that.

I'm happy to acknowledge your claim to have experience/expertise in the MV industry and I can't challenge your claim to have had a lot to do with road safety acts at the turn of the century, I was out of that sphere by then, but I think you place too much reliance on your experience there, and try too hard to translate that to the aviation sphere. I'm sure you do this for all the right reasons but I remain unconvinced by many of your arguments.

 

 

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Um, there are performance standards for engines. Jabiru hold JAR 22H certification for the 2200, and certify the 3300 against ASTM.

True but we are discussing engines in RAA aircraft in particular - the majority of which are not certified - not even the supposed gold standard of R**** (mustn't mention names!)

 

 

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Now you're shifting the terms around again to suit your hypothesis. We are not talking about cars and their regulatory environment is not as analagous as you would like us to believe. There is no performance requirement for RAA engines. We did agree on that.

My mistake on that, I should have left out any reference to ADRs and cars.

 

I'm sure you do this for all the right reasons but I remain unconvinced by many of your arguments.

I'm sure you could prolong this little word game for days; I really couldn't care whether you were convinced or not, but a lot of people have been burnt by this instrument, and despite all the huffing and puffing the instrument has stuck, and has not been budged in the slightest.

I'm not seeing too much interest from anyone else to participate in getting the best outcome as CASA continues/cancels/modifies up or modifies down this instrument, so I'm happy to leave you unconvinced.

 

 

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Lot of....you said, I said, I meant, you meant, I'm referencing, your referencing, I'm on topic, your not, ..........etc etc.

 

Hey guys, go smell some roses, light your incense burners, better still.........

 

Go flying, before moderator cracks his whip. ( just ask ol mate oscar, he'll explain the whip method ) ....this topic is not worth getting all cranky about.

 

 

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"Made 22 Dec 2014

 

Registered 23 Dec 2014

 

Date of Ceasing To be ceased 30 Jun 2015

 

Reason for Ceasing Self Ceasing"

 

The instrument self ceases at the end of June. CASA may choose to raise a new Instrument which would require DAS approval. Does anyone know if CASA intends to raise a new, similar or different instrument or live with the restrictions being lifted. Or is this query goading the bull?

 

 

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Sorry that you perceive it to be a word game. Your choice. I'm happy to remain unconvinced. So at last we have both achieved happiness. That will confuse FT even further.

 

Of course the instrument has stuck. Was there ever any doubt it would. Has it run, or nearly run it's course? We should know next month

 

 

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"Made 22 Dec 2014Registered 23 Dec 2014

Date of Ceasing To be ceased 30 Jun 2015

 

Reason for Ceasing Self Ceasing"

 

The instrument self ceases at the end of June. CASA may choose to raise a new Instrument which would require DAS approval. Does anyone know if CASA intends to raise a new, similar or different instrument or live with the restrictions being lifted. Or is this query goading the bull?

Someone, sometime should ask them nicely.

 

 

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Yes your right TP, someone should ask, i believe a few have and so has Raa

 

No reply, not even answering phones

 

SSAO arent even replying to questions from December

 

I spent a few hours on the phone to them today, 4 people, 7 or so transfers, trying to work out who could sign off a special inspection they requested. After finally getting an answer they called back and asked had i recieved a letter dated 28th (last Thursday) as it said I didnt have to do the inspection at all, they thought I was applying for something else.

 

Very frustrating dept to deal with.

 

 

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"Made 22 Dec 2014Registered 23 Dec 2014

Date of Ceasing To be ceased 30 Jun 2015

 

Reason for Ceasing Self Ceasing"

 

The instrument self ceases at the end of June. CASA may choose to raise a new Instrument which would require DAS approval. Does anyone know if CASA intends to raise a new, similar or different instrument or live with the restrictions being lifted. Or is this query goading the bull?

Being self ceasing sounds like a great outcome for CASA. They can say it was always intended to be temporary etc etc. Now that we have a new CASA boss who seems more positive about RA & CASA have no hard evidence ( well they have not been able to produce any) to substantiate the initial Instrument it will be hard for the lackeys to keep pushing an empty barrow when a new broom is looking for something to sweep.

 

 

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I suggest that it is more likely than not, that the Instrument will not be - at least, immediately - replaced with a continuation / extension / revision. To do so, CASA would open itself up again to scrutiny of the basis of the original Instrument and given its resistance to releasing for such scrutiny the data on which the decision was made, I think it is extremely reasonable to assume that this is something CASA wishes to retain undiscovered.

 

Of course, this then raises a question - and a serious question - as to 'what has changed?' to justify NOT continuing the extension?

 

As far as I can see, the only thing that has changed, is a schedule of inspections and some mandatory replacement directives, coming from Jabiru, that are based on an enhanced 'risk assessment' regime that basically takes into account more factors of operation and maintenance. As far as we know, there has been no work done by CASA to actually identify and research specific mechanical issues and require specific changes to components, design or installation.

 

If the 'incident' rate has actually fallen since the imposition of the Instrument - and any proof of that would have to be made in association with the hours / flights undertaken in the period - then paradoxically, it would be proof of Jabiru's 'standard' position on reliability, that it is largely a factor influenced by operation / maintenance. If the incident rate has remained constant - then the Instrument has had no effect and the obvious conclusion has to be made that CASA's failure to properly analyse the information to hand and react with considered and effective measures has done nothing but damage the Jabiru community for nor useful purpose. If the incident rate has risen, then CASA has failed - rather spectacularly - to address safety issues when it had made a very, very public announcement that safety issues existed.

 

I can't see how CASA can do much more, without opening the whole basis for the Instrument and likely ( and even more embarrassingly, the way in which the action was handled) renewed scrutiny than drop the Instrument and say, in effect: 'well it seemed like a good idea at the time'. That is not going to wash well and in itself might provide considerable ammunition for legal action on the basis of tort. An AAT appeal would be embarrassing for CASA; it has already been pointed out that the application of the Instrument to Experimental aircraft is contrary to CASR 21.195. The AAT generally takes a dim view of government instrumentalities not even abiding by their own regulations..

 

 

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Think it fits the concept of a structure/ process they might have vaguely in the back of their minds. "Self cancelling" sounds strange . An edict could be for a specific time or expire on a certain date, or it could have a sunset clause, which means it ceases to have an effect (unless revived) at the time stated. I think they might just like it to" go away". Nev

 

 

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where does the term "self cancelling" come from, I don't see it in the instrument, it does however mention and expirey date, along the same lines that the CAOs have, surely we aren't expecting them to just expire?

 

 

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They are also know as sunset clauses, often used by government to address issues expected to be temporary, saving the cost (which can involve a lot of work hours, and several departments, people). It also allows a fresh start without first having to address old, legislation/actions if new actions are required.

 

 

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where does the term "self cancelling" come from, I don't see it in the instrument, it does however mention and expirey date, along the same lines that the CAOs have, surely we aren't expecting them to just expire?

The words are "self ceasing" eg. it ceases to have effect.

 

 

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Off topic........but

 

what aircraft ( non jab powered ) would be comparable with the "package" of a j230...........just asking

 

 

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Brumby high wing, Australian made, similar empty weight, similar fuel capacity and endurance, similar cruise speed and on RAA rego same mtow.

 

Price ?????

 

 

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Hello Jabiru Fleet,

 

This week CASA invited representatives from Jabiru, RAA and SAAA to meet in Canberra with them to discuss the expiry of the self ceasing instrument that placed precautionary limitations on Jabiru powered aircraft and what, if anything is to follow after the expiry on the 30th of June. The meeting was very productive and positive.

 

Mr Alan Kerr Chief Engineer of Aeronautical Design Service and CASA Design Approval Delegate also attended the meeting and made a presentation summarising and explaining clearly the many detailed technical reports that have been provided to CASA over many years and also in recent times regarding through bolt and valve train developments by Jabiru. He outlined how Jabiru has addressed issues by service bulletins and letters, design changes, maintenance requirements and instrumentation. CASA, RAA and SAAA were pleased to have received the insight given by Alan into the extent and amount of technical research and development undertaken by Jabiru. They encouraged Jabiru to continue to be more communicative of research and development work.

 

Jabiru proposed that all limitations be lifted on Jabiru powered aircraft that are found to be compliant with service bulletins and letters, that are operated and maintained in accordance with Jabiru manuals and have no unapproved modifications.

 

SAAA explained the risk assessments their organisation do on their experimental aircraft and that experimental aircraft are limited by SAAA’s individual assessment of the modifications used on each aircraft and reviewed at 100 hourly intervals if necessary. They should not be limited by CASA limitations. RAA also explained that they can assess modifications and apply the appropriate limitations to their experimental fleet.

 

All parties will continue to liaise over the coming weeks for further discussions and to finalise the outcome of the meeting.

 

 

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