Dafydd Llewellyn

No, not so. ASTM certified requires the manufacturer to certify that the product complies with the relevant ASTM standard - in the case of an engine, ASTM F 2339. The requirement is spelled out in CASA AC 21 - 42 para 6.5: 6.5 LSA Statement of Compliance 6.5.1 For a production LSA to be issued a Special Certificate of Airworthiness, the manufacturer is required to sign a Statement of Compliance (see example at Appendix 2 to this AC) for each aircraft that is produced. This Statement of Compliance indicates the aircraft complies with all the applicable LSA standards for the aircraft type. (See Appendix 1 to this AC). Nothing more than this is enforceable by CASA.

I didn't say it was. I said, people are unconscious of the fact that the design standards for such aircraft do not address this aspect; and as a result, the probability is uncontrolled and could be as high as 0.1% - or higher. It may also be lower - and since Alan Kerr did some fatigue work on the Jabiru 160C, the probability, in its case, may be several orders of magnitude lower (but keep an eye on the lift strut end fittings). The higher risk is likely to occur in a rivetted aluminium airframe, especially one having cantilever wings.

Much to my distaste, I have a question. It may at first seem irrelevant to the subject, but it is not: Just how worried are the contributors to this thread, about the wings of their aircraft falling off? I've not heard such a commotion as is evident on this thread, about that risk. In fact, I'd venture that nobody here has any idea of what the statistical probability of that might be, or even thinks about it. So if we're going to make such a fuss about statistics, let's put them into some sort of perspective: I note that the CASA document refers to "an extraordinary high rate of partial and complete engine failures". Pray, what is the statistical rate that is "extraordinary high"? I see reference to a rate of engine problems per aircraft movement, for Jabiru aircraft, from RAA data, of 0.03% - is this correct? How does this translate into a rate per flying hour? If, for example, the average flight time per movement were, say, 20 minutes, then the rate would surely be 0.09% per flying hour, would it not? For the sake of this discussion, let's round that off to 0.1% per flying hour , i.e. a probability of one in one thousand per flying hour. How does this compare with other relevant probabilities? One that is surely relevant would be the probability of a wing falling off due to a structural fatigue failure. The liklihood of surviving an engine malfunction or complete failure is vastly better than of surviving a major structural failure, so this is a conservative comparison. The "safe life" criterion that applies to the majority of GA aeroplanes flying in Australia to-day, was CAO 101.22 Appendix II (No, you won't find it on the CASA website, it's been superseded - but it was relevant up to about 2004 or thereabouts). That specified a safe life of one fifth of the calculated mean time to failure, and was supposed - if I recall it correctly - and taking into account not only the variability of the fatigue life of a structure, but also the inherent inaccuracy of estimating the loading spectrum that causes it, to give a probability not exceeding 1 in 1000 per flying hour - i.e. 0.1%. More modern standards set the bar a bit higher, but they are not yet in general application for the GA fleet, let alone recreational aircraft. Standards for recreational aircraft such as CAO 101.55, BCAR S, ASTM F2245 etc, do not even mention fatigue life. There is no requirement whatsoever in these standards for any estimate of the safe structural life to be calculated. So the possibility of a structural failure may well be higher than 0.1% per flying hour - yet all you people blythely ignore this. RAA is, I can just about guarantee, completely unconscious of this. The airworthiness authorities that drafted those design standards were not, however - they knew the score; but they did not consider it sufficiently important, for a recreational aircraft, to bother with putting such a requirement into the product safety standard. So how consistent is it for the RAA to protest to CASA about a failure rate for the Jabiru engine, that is of the same order as the probability of a catastrophic structural failure, which they considered insufficiently important to bother about? How consistent is it for the protagonists on this thread, to focus on the engine alone? I would suggest that nobody here is exhibiting anything remotely able to be considered either competent or logical. This being the case, I do not see that the rate being reported by RAA for Jabiru engine issues, warrants the action proposed in the draft Instrument. It would seem that the sports office in CASA is equally ignorant and inconsistent. You can vote with your cheque books, after all. Isn't it about time people started to look at the big picture? And be just a little bit consistent? We are, after all, talking about a recreational activity that has been defined as "inherently dangerous" by the courts. How does 0.03% compare to other "inherently dangerous" recreational activities? I would be obliged if the moderators could refrain from interfering with this post. (Ok so far we wont, however we reserve the right to edit any post that contains material contrary to the rules as per our brief....mod)

Well, ta-ta. Too much bias on this website for me. Thanks to those of you who have provided me with useful information.

That is, I'm afraid, an understatement.

If you mean, CAE core-rebuilt (which means 100% repair-by-replacement) Jabiru engines, or the equivalent scratch-built CAE version of the Jabiru engine - (really the same thing physically, but completely different from a regulatory point of view) there is certainly a regulatory path - several, in fact. However, the obstructions (as I understand the matter) are twofold: Firstly, Jabiru does not acknowledge that Ian Bent has equal rights to the basic IP for certain Jabiru engines. That would have to change before CAMit could make Jabiru parts under its own APMA authorisation, because it would otherwise result in a legal wrangle that would ruin both parties. Secondly, who would then carry the product liability for those parts of the engine that were NOT changed in the course of implementing the modifications - for example, the method of attachment of the propeller flange? One can readily visualise the dog-fight that would erupt over that. So the practical effect will be, I think, that CAMit will not take the modified Jabiru engine past experimental stage; but will instead go the whole nine yards and produce a "drop-in" engine in which everything is modified, so there can be no IP or liability squabbles. It will be a second-generation engine, incorporating all that Ian Bent has learned from manufacturing 4000 odd Jabiru engines, plus his own research. So now it comes down to $$$. This may require a joint venture with an aircraft manufacturer, who may - I'm speculating, here - require exclusive rights to the engine.

Yep. It'll happen again. Both feet, I said.

Firstly, see post # 139 on this thread. Secondly, Ian Bent (proprietor of CAMit) has been doing research and development testing on the various aspects that are identified (and some that are not generally identified) as being the causes of such problems in Jabiru engines as resulted in the CASA draft Instrument that is the subject of this thread. To implement those modifications CAMit has been doing "core rebuilds" of Jabiru engines, and also building CAE (Camit Aero Engines) engines from scratch, incorporating those modifications. Because the CAMit mods are not yet formally approved, those engines are suitable for only experimental aircraft (which includes RAA -19 registered aircraft). However, experience has been showing that the modifications are effective. Therefore, one of the obvious ways to "fix" the Jabiru engine issues, is seen as being to implement the CAMit modifications. That was the reason for the comment.

Thanks, Deb - that's the piece of information I've been waiting for.

See attached Ministerial letter2.doc Ministerial letter2.doc Ministerial letter2.doc

So - do you want blood on the floor, or do you want the problem fixed? Because it's a question of priorities; get the order wrong, and you'll get neither.

(Sigh) - For Rod Stiff to "allow" the CAMit mods onto his LSA aircraft, means he would be accepting the legal liability for something he has not designed. For CAMit to simply hand-over their IP for over four years of research to Rod - are you joking? Would you? The workable alternative would be for Rod to acknowledge that Ian Bent has an equal right to the Jabiru IP for the basic engines. That would allow CAMit to get APMA approval from CASA to manufacture APMA parts for jabiru engines (an APMA part is a legally approved alternative for an OEM part). Since CAMit already makes the OEM parts, they are the only ones with any chance of getting APMA approval. It would help if CASA would fast-track that process. Then, the CAMit mods need formal design approval - which means running an engine with those mods through the required 50 hours of instrumented running at all the red-line limits, under CASA surveillance. You expect Jabiru to do that? The test article has to be fully conformed against its drawing package, again under CASA scrutiny; run through a power rating test, then through the endurance test, and then through a final power rating test, followed by a strip inspection - all under CASA's scrutiny. CASA demands to be paid up front for its services. Figure 200 man-hours at about $200 per hour.

I'm prepared to run a CAE-modified Jabiru through it's required 50 hours in the test cell - which I have built at my own expense - for just the fuel cost. I'm a subscriber to the views of Ayn Rand; I want a certificated 3300, so it's in my interests to do this. Aviation heaven be buttered.

You can't do that any more, under CASR Part 21M, because it's a major modification, and therefore MUST go the STC path - but that's no help whatever to the LSA aircraft

Just one point to add to that: The inclusion of experimental aircraft in that Instrument was a clear abuse of regulatory authority.

That's ONE STC for ONE Jabiru airframe. Yes, that can be done, but who's going to front-up with the cost of the STC? You have to pay CASA in advance. . . .

CAMit was until 2011, merely a sub-contractor to Jabiru, operating under Jabiru's Production Certificate (and subject to CASA surveillance). However in 2011 I licenced CAMit to manufacture parts for the life-extension of the Blanik glider, under my STC, SVA-542, so they were able to obtain a limited Production Certificate to manufacture those parts kits, on a one-off basis (each aircraft owner has to give them a Production Order - it's another example of bureaucratic obstructionism by CASA). However, it's the thin edge of the wedge; they can expand it or take advantage of it to obtain an APMA approval to manufacture Jabiru parts. The issue of IP has been opposed by Jabiru, and whilst CAMit has the higher legal ground, the cost of a legal wrangle over that means that CAMit is more likely to pursue a version that was wholly CAE; but to do any of those things, they have to stay in business.

Ian Bent is seeking a clear statement from CASA separating CAE engines from Jabiru engines. If he doesn't get it, and quickly, CAMit will be out of business, to my understanding. Stop Press: I've just been advised that CASA has stated that the Instrument does NOT refer to CAE engines in any way.

No, CASA does NOT make the regulations - federal Parliament does. Mind you, they usually accept what CASA puts up. The process is NOT rapid.

QUOTE: Well... not exactly. CAMit, as I understand it, owns half the intellectual property on the design of the engine. And, as such, had negotiated something of an agreement for the manufacture of the Jab engine to be done by them. However, as I understand it, there is nothing stopping CAMit from profiting from a design the owner part owns. And, despite being the same, it is not a Jabiru engine. Even Jabiru will tell you that. The internals have differences... specifically stated as being in place to overcome the issues spoken of with such fond-banter, on forums such as this (attributable to CAMit, this sentence). To clarify - yet again: Jabiru engines are manufactured under Jabiru's Production Certificate by CAMit Pty Ltd, strictly in accordance with Jabiru's specifications (as they must be). This is subject to CASA surveillance. These engines have a Jabiru data plate. CAMit also holds a CASA Production Certificate in its own right; however this is at present limited to "one off" items; and in any case, a PC can only be applied to a product for which the manufacturer either holds a TC or a licence from a TC or STC holder. The CAMit engine is not as yet certificated, so it has been being built as an engine for experimental & amateur-built aircraft. CAMit engines have a CAE data plate; and are physically interchangeable with Jabiru engines, but not legally interchangeable with them in factory-built aeroplanes. Jabiru engines that have been "core-rebuilt" by CAMit have a Jabiru data plate plus a CAE modification data plate. Since the CAMit modifications are not as yet formally approved by CASA, they are also restricted to experimental and amateur-built aeroplanes. The CAE experimental engines and CAE experimental core rebuilt Jabiru engines incorporate a considerable number of modifications , most of which are quite subtle, so they are NOT Jabiru engines for the purposes of the CASA Instrument.

The CASA instrument is demonstrably incorrect in including experimental aircraft. I expect this will be withdrawn.

My point is NOT that there are not problems or that Jabiru has acted sensibly; my point is that what has been triggered by RAAus plus the agitators, is very likely to backfire on the membership. RAA is NOT in a position to fix the problem by waving a big stick; more likely it's shot both its feet off. Time will tell.

Yes; if Jabiru simply walks away, how do you people imagine that will affect the membership of RAA? Who would trust that management team after this? I'd predict a mass-movement to the RPL and VH experimental.

Aren't you all forgetting something? Firstly, CAMit has to stay in business before it can provide the fixes. Its business, unfortunately, is building Jabiru engines to Jabiru's specifications. So if Jabiru stops selling engines, how do you imagine CAMit will be able to keep going? The baby will go out with the bathwater. Secondly, to install a Rotax engine into a Jabiru airframe requires either a supplemental type certificate (for Jabs up to & including the 160C) - and it will require a separate engineering justification for each aircraft model; OR for the LSA models, it requires an equivalent amount of work by Jabiru in order to comply with the ASTM standard. If Jabiru is in convulsions as a result of this Instrument, who is going to (a) do the engineering work (which includes flight testing), and (b) Who is going to supply the up-front money? Thirdly, why should Rod Stiff bother? You people seem to imagine you can get your way by waving a big stick. I think you are in for a significant object lesson. No doubt people will be very self-righteous about it. You make me nauseous. Clever country, eh?

Y'know, I got an invitation - as a lapsed member - to renew my membership of RAA, a day ago. I'm VERY glad I declined . . .