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That's not entirely true - the CAO can be changed, and as far as I understand you need to be in compliance with the CAO as it exists at the time the flight takes place. The CAO also requires that you follow the RAA Ops and Technical manuals, so the RAA can basically write any additional restrictions they like - but with a quick look I didn't see anything there restricting modifications to 19 reg to the original builder.

Can you at least tell us which regulations you believe state this? from CAO 95.55: 1.1 This Order applies to a single-place or 2-place aeroplane that: ... (e) is mentioned in paragraph 1.2 1.2 For subparagraph 1.1 (e), an aeroplane must be 1 of the following: ... (e) an aeroplane, the major portion of which has been fabricated and assembled by a person who undertook the construction project solely for the person’s own education or recreation... 6 General conditions ... (f) in the case of an aeroplane to which this Order applies by virtue of subparagraph 1.2 (b), © or (f) — the aeroplane must not have been modified without the approval of CASA or of an authorised person for the purposes of regulation 35 of CAR 1988; (g) in the case of an aeroplane to which this Order applies by virtue of subparagraph 1.2 (a), (e) or (g) — the aeroplane must: (i) before its initial flight, have been inspected by a person authorised by CASA for that purpose; and (ii) if any condition or limitation has been imposed under paragraph 6.3 — be operated subject to that condition or limitation. If the limitation comes from 6(f), that does not apply to amateur built aircraft (subparagraph 1.2 (e) ) - only subparagraph 1.2 (b), © or (f). I am looking for something that applies only to the builder but I don't see it. It seems like another case of someone reading the regulations to mean what they think they SHOULD say, rather than what they actually say...

The student has a log book, but the school will be required to keep their own records as well. I would expect these to be more detailed than what is in the logbook - information about strengths/weaknesses, whether sequences have been completed satisfactorily etc. I think one of the criticisms out of the ferris wheel crash was about the adequacy of the particular school's student records.

5 The CFI of a flying school must not permit a student pilot of the school to undertake a solo flight in a Jabiru-powered aircraft unless the CFI has: (b) before subsequent solo flights by the student pilot at a flying school: (i) confirmed that the student pilot has competently performed engine failure exercises at the school in either the preceding 2 hours of flight time or 7 days, whichever is the more recent (ii) noted the competence in subparagraph (i) in the student pilot’s record, countersigned by the student. 5(b)(ii) is obviously designed to make compliance easily auditable even if there are no incidents - I am waiting for CASA to announce that they are conducting (or having RAA conduct) an audit, with the aim of shutting down schools that are not complying with this requirement.

Did they remove the radios already?

Solowheels look like fun. I suspect they are illegal in public places in Australia though... the same as Segways.

Multiple flights. According to the report I read, there wasn't even direct evidence of taking selfies on the accident flight, but it was concluded that it was the likely cause due to selfies on multiple previous flights.

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.

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.

Hmmm, yes it appears you are correct, according to the ops manual that form is for instructors without a class 2 medical. So the answer to the original question seems to be that you need a statement from your GP that you meet the health standard to drive a motor vehicle, and you must also comply with any conditions or restrictions that apply to your drivers license. I am still not convinced that RAA has the medical expertise to perform health assessments, I would rather see a requirement that instructors hold a class 2 medical and be done with it...

According to the RAA ops manual, all you need is a statement from your doctor that you are fit to drive a motor vehicle. No requirement for CASA involvement, DAMEs, or a Recreational Aviation Medical Practitioner's certificate. The questionnaire and examination form linked above appears to be something that someone has tacked on over and above what the rules say. (Not the first time that has happened, and why I continue with GA rather than the constantly moving goalposts of RAA.) Despite what the RAA ops manual says, I suspect that they would withhold your certificate if you only provided a statement from your doctor that you are fit to drive a motor vehicle without the questionnaire and examination form. I wonder whether RAA actually employs anyone qualified to evaluate these forms i.e. a medical doctor? That's because in aviation, many people operate according to their own opinion of what the rules should say, rather than what they actually say...

Interesting form. It seems a lot more than "a medical statement from your doctor stating that you are fit to drive a motor vehicle." It basically means that RAA is a Health Services Provider for the purposes of the Privacy Act, and they are collecting Sensitive Personal Information. I wonder whether they comply with Privacy Act requirements for handling that type of information? http://www.oaic.gov.au/privacy/privacy-resources/privacy-guides/guide-to-information-security

What is required when you hire an aircraft may be different to what is allowed if e.g. you own an aircraft. If you learn in a Tecnam and buy a Jabiru, are you allowed to jump in and fly away? If you learn in a Jabiru and buy a (single seat) Rans S14? In GA, if you learn in a C172 and buy a C152? If you learn in a C172 and buy a PA28? In all these cases some training would be a very good idea, but at some point you have to stop trying to write rules for everything that would be a good idea, and trust people to evaluate the situation for themselves.

What is an "engine incident"? One of the difficulties is that people are more likely to report if there has been publicity already, so vocal people complaining of problems are likely to increase the number of reports. This needs to be take into account when comparing numbers with other engine types. Forced landings would be relatively easy to compare. Other items less easy. Is a sunk float in a Rotax required to be reported, for example? Would it be considered an engine incident?

12 forced landings is rather different to 40, which is how the statistics seemed to be presented. Were the numbers for the other engines engine failures with forced landings, or "engine incidents", whatever they are? Do we even have a consistent definition of "engine incident" across the different engine types?

A few numbers have been posted. They suggest that Jabiru have a greater failure rate than some others, but leave many questions unanswered. I would hope there are MUCH more detailed stats somewhere to justify this level of action.

It doesn't really matter whether it actually applies. The publication of the draft is damaging enough. Everyone who was about to buy a Jabiru has just put their wallat back in their pocket and thought "Hmmm, maybe I'll give it 6 months or a year and see how this pans out... or buy a Rotax." People leaning to fly will think maybe it's not a good idea to learn at a school that uses Jabirus, I might not be able to fly solo. Flying schools that were planning to borrow to expand their business suddenly have a potential cash flow hit to consider. If a flying school has borrowed money and the banks find out, you might get an invitation to explain your contingency plan. The bank might tell you they aren't comfortable with your current level of borrowing, and would like an immediate reduction in your debt level. You try to sell an aircraft, but no-one is buying Jabirus. The bank do whatever they do when a business can't repay to the banks satisfaction... The draft by itself will probably costs RAA related businesses/individuals millions, maybe tens of millions - unless there is an immediate mechanical fix that which CASA bless as THE solution to the issue.

Piper Navajo - at least 10 dead in engine failure accidents in the last 15 years, some other accidents without fatailities. Is that better or worse per hour than Jabiru? Considering that they are supposed to be maintened at a level several increments higher than an RAA aircraft. What percentage of Australian registered Piper Navajos have had off airport landings or crashes due to engine failure?

If the intention is to take a stick to Jabiru, it seems like a strange way of going about it. Why wouldn't you just e.g. suspend their authority to certify new engines until a fix is developed, and revoke any authorizations for Jabiru to fly over built up areas? The RAA rules were developed when 2 stroke engines were common, and on the assumption that engines were unreliable e.g. must be able to glide clear of built up areas. Does the Jabiru engine have worse reliability than 2 strokes? Is the accident rate high enough that those rules are not enough? I don't see it. It looks to me like the rule was designed to have maximum impact on RAA and related businesses, without the headlines that "Jabiru grounded" would generate. I genuinely fear for the future of all RAA based on this, not just Jabiru. Even if the proposed restrictions do not go ahead, the publication of the consultation draft is very damaging to Jabiru and RAA. Just the knowledge that the threat has been made must influence the value of Jabiru aircraft, and the business plans of Jabiru and businesses that depend on them. Once you pull a gun on someone, your relationship is irretrievably altered - even if you don't pull the trigger.

The instrument defines a Jabiru engine as "an engine that is wholly or partly manufactured by a person under licence from, or pursuant to a contract with, Jabiru." Are you sure that those engines are not even partly manufactured under license from Jabiru? Simply modifying an engine so that it is no longer considered a Jabiru engine for the purposes of certification doesn't seem to be enough...

That wasn't how I interpreted eligible. Correct? I'm not sure. What other requirements and standards should be used to determine whether they should be granted the endorsement? 61.495 specifically excludes people eligible under 61.500: 61.495 Requirements for grant of recreational pilot licence endorsements (1) This regulation applies to a person other than a person who is eligible to be granted a recreational pilot licence endorsement under regulation 61.500. So the requirements set out in 61.495 don't apply. Are there any other requirements? I looked for some other uses of the word eligible in these regulations to see if I can work out what it means... 61.280 The holder of a commercial pilot licence or an airline transport pilot licence granted by the Civil Aviation Authority of New Zealand is eligible for an equivalent Australian licence and equivalent ratings and other endorsements Seems to be a pretty close match in usage and intentions. Do they have to do a flight test to demonstrate that they meet the standards, or do they just have to apply? That is written in the regulations and it basically makes sense because normally the flight test counts as a flight review, so if you didn't do a GA flight test you don't have a GA flight review. And it is a logical place to have a proficiency check, and allows an instructor to verify that they really do meet the standards. This issue only really arises if you get the RPL, and then do a RAA nav endorsement - which bypasses the navigation component of the flight review. So you wouldn't issue a sticker for a tailwheel endorsement if requested by another instructor, without conducting a flight test yourself? I agree that CASA should be granting the endorsements - they seem to be the logical people to be issuing licenses and endorsements in recognition of existing qualifications, not individual schools/instructors...

I don't operate under an AOC. I can see how that would be required for a commercial operation, but what about private? If you do your AFR a month before it is due, and the instructor isn't happy with your practice forced landings, are you allowed to rent an aircraft and go and practice until 2 years from your previous review, or are you grounded?

That goes without saying, but the question is whether you can stop them from flying home in their 172 if you think their flying is not up to PPL standards?

I don't think that's a good idea. While RAA and GA are different (weight limits etc), there is a logical justification for the RAA medical requirements being different. I fear if the RAA/RPL qualifications are merged and it is 1500kg across the board the RPL medical standard will be applied and a large number of RAA pilots will be grounded.

According to 61.170, they "must grant a flight crew endorsement ... if ... the applicant meets the requirements mentioned in this Part for the grant of the endorsement." (my bold) The requirements in the Part appear to be met by 2 hours instrument time and a RAA navigation endorsement, so by my reading there is no "should" about it, the regulations say "must". Asking you to fly a nav is the same as passing your PPL flight test then being asked to do another nav to make sure before the license is issued. You have met the requirements, the license should be granted. Years ago I did my GA tailwheel endorsement. The instructor who did the tailwheel training didn't have authority to issue sticky labels. So I had to get a different school/instructor to issue the label on his say so. They didn't ask me to demonstrate tailwheel proficiency before they issued the label - they trusted the instructor who provided the training. Same deal here. The regulations say that CASA trust RAA to provide adequate training for a RPL navigation endorsement. So they need to either trust them, or change the regulations.