Dafydd Llewellyn

Keen, I think yu miss the point of ATSM certified, Jabiru has to prove the engines are safe and that the RAA standards are causing the failures

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 have no clue how you can arrive at the conclusion that the probability of catastrophic structural failure of a Jabiru is about the same as that of an engine failure in the same aircraft. There is nothing about that concept which makes sense from either a theoretical or real world perspective.

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.

 

 

The longer this mess is in the public arena the more damage is done to the brand. The simplest solution is a merger of CAMit and Jabiru. Both have much to gain- and everything to lose. Common sense maybe, but personalities are involved.

That is, I'm afraid, an understatement.

 

 

Is there a solution to the certification issue for CAE?

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.

 

 

the solution bought up at the meeting yestearday does not involve Camit

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

 

 

Dafydd, you mentioned a little earlier: The inclusion of experimental aircraft in that Instrument was a clear abuse of regulatory authority.Could you elaborate your thinking, I've been looking at the CASRs, but can't quite see where that might be. Ta!

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.

 

 

I am not happy with tone and attitude of some contributors to this site. However, they have achieved what they set out to do and ultimately, I feel it will be to my safety advantage to be able to choose to modify out some of the fragilities of my Jab engine .Out of the six Jabiru powered aircraft operating here, and they are all actively used and I have never heard of any engine problems - but that is irrelevant as in the big picture it is too small a sample.

 

I work in reliability and would not be happy using rumour, inuendo and some of very poorly qualified statistics that has been peddled here to sentence any machine. Surely the reliability critieria has to based on faults per hours flown across the fleet of each engine type, only RAA could have those data. Where is it in this case?

 

The Camit / Jabiru arrangement looks from a distance to be a very odd relationship, especially with Jabiru adamantly refusing to allow Camit upgrades to be approved and fitted. Now CASA has stepped in and one solution could be to mandate/allow some of these upgrades. Jabiru owners will then have to put their hands in their pockets to get their aircraft released from any CASA applied restrictations. This would be a win for all but the owners:-

 

Jabiru get to sell aircraft with more reliable engines - Jabiru win.

 

CASA is seen to be acting - CASA win.

 

Operators have the option of upgrading - Operator win (but at a significant cost, so irate).

 

Jabiru can continue to say the upgrades are not required, but CASA imposed - Jabiru win because it claims not to be to blame for Operators additional costs.

 

Is that too sinical?

 

Alan

(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.

 

 

We are nearing the season of GOODWILL & PEACE TO ALL MEN & as a goodwill gesture so as to keep the fleet of Jabs flying whereby even though you have entered the golden years of retirement, have you considered coming out of retirement just once more so as to compile an STC for either a Camit Engine ,Rotax 4 stroke, Lycoming or Continental engine to be installed into Jabs & donate the STC to those Jab owners who decide to perform this modification, & when the inevitable time comes ( which we must all face sooner or later to meet our MAKER) then you will have an epitaph when you enter "AVIATION HEAVEN" as being the only person who has saved the fleet of Jabs

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.

 

 

The Caboolture J160 is not a factory install. It is not an STC. My J160 has more or less the same mod, but here in NZ where the regs for micro lights are a bit more relaxed. The YCAB machine was converted using an EO specific to that aircraft.

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

 

 

Much fuss and fury, predictably.The Instrument is a Draft. Currently it is not in force. At the moment it doesn't apply. DO NOT PANIC!

 

What it has done is brought the issue to a head. The manufacturer of the engine (Jabiru Aircraft Pty Ltd) is being made to confront a perceived issue with engine reliability. It is probably well overdue. "The gun is loaded, the action is cocked and CASA are about to pull the trigger" but the sky isn't actually falling in - yet.

 

Now, the statistics of engine failures will have to be produced. If they can't then the premise of CASA's introductory paragraph is fatally flawed. Analysis will have to be made, and when it is there will be several quite clear conclusions. Once these are made, then the manufacturer will be aware of what issues need to be addressed, with some guidance as to possible remedies. It will also pinpoint, with some precision, those engines most at risk and those which are at a very low level of risk. Then - and only then - the Instrument can be refined.

 

What is of concern is the vast variation in "Jabiru engines". There are at least 9 on my local airfield, and they range from one 4-cylinder unit with a 3-digit serial number to a couple of brand-new roller-cam 3.3-litre engines which have just been installed. Most - but not all - have had the through-bolt upgrade. Some have been recently re-built with all the current upgrades. Clearly there is no "one-size fits all" solution here.

 

The two most pressing issues are through-bolt failure and exhaust-valve failures. These are mechanical issues rather than design issues. I believe the engine is essentially well-designed, and from my own experience (engine-failures), it is a tough engine because even with a major failure it ran long enough to get me back to a runway - twice.

 

From my own experience I can say the little Jab engine is a tough little unit, and the airframe is just about "unkillable". At the price, there isn't a better training-aircraft available. CASA could have simply grounded the entire fleet of Jabiru-powered aircraft in Australia, but what they have done is forced people's hands so the matters can be thrashed out and solutions found. It's my belief that was the intention of this in the first place.

 

So by all means make representations to your local MP, to Lee Ungerman and the Minister, but be respectful, polite, positive and bear in mind the thrust of this proposed Instrument is to fix a problem, not ground a fleet of aircraft. As for the immediate future, about all I can confidently predict is the email server at CASA is about to crash due to the volume of emails being received from all over the world, and the receptionist at Jabiru will most likely require stress-leave when this is all over.

 

One other observation, if I may; if the reaction to this proposed Instrument is as violent and widespread as some would have us believe, it may not reflect all that well on the regulator or on the person or persons who drafted it.

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

 

 

For those Jab Owners that are interested in upgrading their respective aircraft to the Rotax 4 stroke engine, well there is good news on the horizon, so don't think you have a boat anchor.Some years ago Bill Whitney -Aeronautical Engineer in Brisbane compiled an STC for installation firewall forward of a 4 stroke Rotax engine into a Jabiru airframe & this STC was approved by CASA. Several Jabirus owners went ahead with this modification, after which there was a saying going around in aviation circles as follows: "If you had a Jabiru with a Rotax engine then you had the best of both worlds".

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. . . .

 

 

Jabiru succeeded in stopping CAE from further proceeding in "certification" of the 2.2 engine, how can casa now acknowledge CAE ....??I see nothing but protracted court proceedings.

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.

 

 

The people in this country have given Mr Stiff the business he has today because they believed the publicity and bought his products.

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.

 

 

I wonder if people realise this won't just spell the end of Jabiru it has the potential to bring down RAAus. If there are not enough flight schools and training aircraft what do you think will happen to the membership? If there is a sudden decline in membership what do we think will happen to the financial viability of RAAus?

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 . . .