Published this afternoon by RAAUS.
I have taken the highlighter pen to it just for fun.
As most people are aware, CASA published a draft instrument on 13 November 2014 which would have the effect of restricting the operations of aircraft with a Jabiru powerplant. This would affect more than 1000 RA-Aus registered aircraft and have an adverse impact on some two thirds of our flight training facilities.
Since the publication of this draft instrument RA-Aus has been working hard to understand the justification for these restrictions. We have, for some time, known that Jabiru engines have a higher tendency for failure than their Rotax counterpart and welcome any appropriate changes that would improve their reliability. We would also welcome any measures that result in improved reliability and safety of any aspect of our fleet. Having said this we are troubled by the process employed by CASA and especially the lack of transparency in terms of the implementation of these proposed measures.
RA-Aus has repeatedly requested the information used to justify statements made by CASA that claim the failure rate is increasing. We have also requested the analysis of said data in order to assess the veracity of these claims.
On 17 December 2014, almost five weeks after the draft instrument was published, RA-Aus received the data and was provided one, yes one, working day to respond. As one would expect we would have liked much more time to assess the data, understand the analysis and then form an opinion on the suitability of the proposed measures, however, regardless of taking some five weeks to provide the data, CASA allowed one day. In light of this our response was somewhat rushed.
Despite this, RA-Aus was able to note that the data provided to CASA on Jabiru engine failures only covered one partial year. The only time series data made available to us (although not provided to us) was via the ATSB. That is, no engine failure data beyond the beginning of 2014 was used by CASA to justify their position and they left us to infer what data the ATSB had provided.
With reference to the latter, RA-Aus has contested the validity of the ATSB data on the basis that it shows a decline in the hours flown by the RA-Aus fleet. This is in direct contrast to Government published figures which show a doubling in the number of hours flown since 2000.
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. This is despite their statement that they have found statistically significant evidence in support of their claims.
RA-Aus’ position is, as stated above, that the failure rate of Jabiru engines is greater than that of Rotax engines but that it is not worsening as per the unsubstantiated statement made by CASA.
In light of this RA-Aus responded to CASA, within their incredibly tight and unrealistic timeframe, to state that we oppose their draft instrument and suggested an alternative approach to addressing the real concerns. While CASA acknowledged that our response had merit within 24 hours of receipt they proceeded with the restrictions without due consideration of our arguments.
While the restrictions imposed on our members are less stringent than those originally proposed, our opinion is that they are still inappropriate. Furthermore, CASA has remained evasive in terms of providing information relating to what rate of failures would be deemed acceptable and so we remain uninformed as to what point the restrictions will be lifted other than the statement on the CASA website regarding a review by CASA early in the New Year and the six month validity of the proposed Instrument. We will continue to work with CASA and Jabiru in an attempt to address these issues, however, we can’t provide further information at this point.
RA-Aus is extremely worried about these actions and what this may mean for private aviation in Australia. Being the fastest growing sector of aviation it concerns us that unilateral action has been taken by the regulator that is not backed up by robust evidence which suggests the action is justified. It worries us that this precedent has the potential for further restrictions that may not be warranted based on incomplete data, deficient analysis and/or misleading claims. We also have concerns about the implications of CASAs decision and what it means for all self-administered aviation organisations as Part 149 is implemented.
RA-Aus will focus our efforts on improving safety in our sector by reviewing training methods and practices, improving our education programs, communicating safety findings (where permitted by law) and so forth. We will also remain very focussed on the outcomes of CASAs recent actions, the Governments recent announcements about the recommendations of the ASRR report and continue to hold CASA to the same high standards that they demand of the aviation industry.