Trouble for Jabiru: Australian CASA restrictions proposed

Discussion in 'Firewall Forward / Props / Fuel system' started by Vigilant1, Nov 13, 2014.

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  1. Nov 22, 2014 #61

    SVSUSteve

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    That brings up the next logical question for Ron: is this failure mode limited to one model or is it an issue with all the Jabiru engines?
     
  2. Nov 23, 2014 #62

    BBerson

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    If all Jabiru engines are affected, they would have (or should have) responded decades ago.
    To compare an engine that is largely uncertified, against the worlds largest small engine manufacturer is unfair, at best.

    Is it the purpose of government to ban all products deemed slightly worse than the industry leader? Should they ban the Rotax two-stroke engines if worse than Lycoming?
    In that case, Cirrus and others should be banned and only Diamond (with the best ratings) should be allowed to continue.
     
  3. Nov 23, 2014 #63

    Wanttaja

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    I'm not that familiar with Jabiru engines, so my mind wasn't even thinking "Different models." Good catch.

    The Australian data doesn't include engine model, but the through-bolt issues all occurred to Jabiru J160 aircraft. According to Wikipedia, they mount the 80 HP 2200 cc engine.

    The US Homebuilt accident data shows a fairly even split between the 2200 and the 3300 engine, and engine-cause-of-accident split is roughly the same.

    Ron Wanttaja
     
  4. Nov 23, 2014 #64

    Wanttaja

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    The fact that the Oz Jabiru 2200s are suffering the through-bolt problem, but it hasn't happened to any of the US engines, does tend to make one think. A couple of things come to mind:

    First, it could just be related to total time on the aircraft. The Jabiru engines in Australia are used in trainers, which means, for the most part, commercial operation. The Jabirus in the US homebuilt fleet build time much more slowly...the Jabiru-powered aircraft in the US Accident database flew roughly 50 hours a year. A flight-training aircraft might see that many hours in a month.

    Second, it could also be related to the types of flying. A trainer is maneuvering a lot, and doing a lot of touch and goes. It might be related to heating/cooling cycles and gyroscopic forces. Though my Fly Baby does maneuver a lot, and does a lot of touch-and-goes.....

    Third, this could be due to a more-recent change in the engine design. I took a look at the FAA Registration Database, and tabulated the listed model year for all the aircraft identified with a Jabiru engine:
    jabiru model years.jpg
    The Model Year of the aircraft should approximately match when the airplane was completed. Note that the US saw a big surge in Jabiru-Powered aircraft in the ~2007-2011 time frame. In the normal course of homebuilt aircraft construction, of course, these engines were probably purchased several years earlier.

    So the incidence of "modern" Jabiru engines is probably pretty low. It might be that the Australian problems are related to a much later production run than is generally seen in the US homebuilt fleet. Hard to really say, as the ATSB data doesn't include the model year of the aircraft in question. In any case, an aircraft used for flight training may have had the engine replaced multiple times, over the years.

    Ron Wanttaja
     
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  5. Nov 23, 2014 #65

    cheapracer

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    It has been a continuous theme over 4 iterations and has been going on for "decades" - one of the reasons this has come about is because of the seemingly lack of action from Jabiru. That is an outside view, not an accusation but seems many hold the same view, enough to cause this action from CASA.

    http://jabirucrash.com/

    The airframe however is one of the safest you can fly in, sadly proven by some of the engine failures - ironic and praiseworthy in the same breathe.

    The CASA issue appropriately surrounds the engine, not the airframe.


    They are that bad Steve, they are anti-'anything you got'.
     
    Last edited: Nov 23, 2014
  6. Nov 23, 2014 #66

    Doug2233

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    Ron, thanks - this is very useful information.

    I think you will find the Jabiru engine population is many times greater in Australia than in the U.S since they were producing engines from 1995. While I have no specific knowledge these early iterations probably feature in the statistics. (Accident plus non-accident failure statistics. )

    Jabiru has always offered a reasonably priced rebuild service which has kept the engines in the field. Even so, it wil be difficult to trace config status of a bulk of these engines. Unless Jabiru can establish a firm basis to identify specific engines from their records it will be difficult for CASA to zero in on the problem children - this leaves them the only option to target all engines.

    Jabiru is in a difficult position - I hope they can get through this. I cannot help thinking that they would have had a much bigger share of the market now taken by Rotax (2000-3000 aero engines per annum according to Kitplanes) had they responded earlier to the issues.
     
    Last edited: Nov 23, 2014
  7. Nov 23, 2014 #67

    BBerson

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    The ban should only apply to the certificated Jabiru engines, for which CASA has authority and data, and responsibility to act.
    The FAA doesn't collect data on or regulate the safety of non-certificated engines. Just look at that auto conversion equipped RV-10 accident report that Steve was talking about a few days ago.

    So is this all Jabiru? Or just certified Jabiru?
     
  8. Nov 23, 2014 #68

    cheapracer

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    You are missing 3 key points.

    Although RAA and other aviation bodies operate with a degree of impunity, at the end of the day CASA is responsible overall for anything aviation.

    Automotive engines are a self development, Jabiru is a manufacturer/retail seller and are responsible for their products under Oz law regardless of use.

    Australian Regulatory culture is not the same as the one you are used to and sadly, Oz has no where near the freedoms you guys enjoy. We probably "save" more people from themselves from death and serious injury than most anywhere in the World, but geez, it feels like you can't breathe sometimes.
     
  9. Nov 23, 2014 #69

    BBerson

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    I am still missing your point.
    Are you saying CASA issues Airworthiness Directives for non-Type certificated or experimental products?
     
  10. Nov 23, 2014 #70

    SVSUSteve

    SVSUSteve

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    If we're being brutally honest, the FAA doesn't do a very good job of collecting general aviation safety information at all at least compared to what they could be doing.
     
  11. Nov 24, 2014 #71

    cheapracer

    cheapracer

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    CASA can do anything, period.
     
  12. Nov 24, 2014 #72

    bmcj

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    That's unfortunate and, I think, counter to the general impression that most Americans have of Australia. I think the American (stereotypical) view of Australia aligns more closely to what our old 'wild west' used to be... wide open and largely unregulated, where people pretty much make their own rules with little interference from government. From what I've read here from the Aussie members, this American view of Australia is apparently very wrong. Of course, our 'wild west' may have been much different than we perceive, too... much of our perception of history (American and Australian) comes from Hollywood.

    Back on topic, I hope Jabiru can work past these problems (both mechanical and regulatory)... the little Jab engine is a neat little engine. I do see this action as potentially causing a flood of cheap, used Jabirus on the market.
     
    Last edited: Nov 24, 2014
  13. Nov 24, 2014 #73

    cheapracer

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    Mr Lee Ungermann
    Project Leader on Consultation Draft – CD1425SS
    Civil Aviation Safety Authority – Australia
    GPO Box 2005
    CANBERRA ACT 2601

    Dear Mr Ungermann,


    Consultation Draft – CD1425SS – Operating limitations for aircraft fitted with Jabiru engines
    We, Recreational Aviation Australia (RA-Aus), write to you with concern for the proposed actions as
    outlined in the above draft instrument. We would also like to draw your attention to the misconduct
    of the Civil Aviation Safety Authority (CASA) in relation to this matter and the negative impacts their
    actions will have on aviation in Australia and the broader economy. These impacts include far
    reaching financial and social impacts as well as, and perhaps more importantly, significant safety
    impacts in the aviation sector. It is with respect to these latter impacts that the Government should
    perhaps pay a great deal of attention as CASAs primary purpose is to advance safety in the sector
    and not hamper it. Their actions are also illustrative of their lack of concern for the recommendations
    made by the independent Aviation Safety Regulation Review panel contained in the ‘Forsyth Report’
    published in May 2014.

    Introduction
    RA-Aus express serious concerns at the recent actions of the CASA in relation to proposed
    restrictions relating to operations of aircraft in Australia. While we concede that the actions taken are
    in relation to the reliability of Jabiru engines and agree that said engines display markedly lower
    reliability figures than competitor engines, it is our belief that irreparable damage has been caused
    to the already fragile Australian aviation industry as a result of the regulators actions.
    Without due concern for the industry CASA has embarked on a destructive path that threatens the
    existence of an Australian aviation manufacturing company, Jabiru, along with associated
    businesses. Further, this proposed action threatens the existence of Recreational Aviation Australia,
    the body charged with the responsibility to administer the safe training and operation of
    approximately 10,000 pilots and 3,500 aircraft.

    In order to effectively perform these functions RA-Aus provides services in a number of areas
    including:
     The development of training syllabi for the maintenance and operation of aircraft,
     Oversight of flight training facilities to ensure high standards of operation, and
     The administration of events to promote safety in the sector.

    In addition to this RA-Aus delivers critical services in relation to accident investigation and has
    been called upon to provide assistance and support to the Australian Transport Safety Bureau
    where their resources are not sufficient.

    Background

    The majority of Jabiru aircraft and other types powered by Jabiru engines in Australia are registered
    by RA-Aus. The number of aircraft in the RA-Aus fleet affected by these actions totals more than
    1000 and these aircraft have flown in excess of 92,000 flights totalling more than 41,000 hours in
    the 10 months from January through October 2014. With the weather becoming more favourable for
    flying activities coupled with extended daylight hours, it is expected this number will grow quite
    markedly during the final two months of the year. In 2013 more than 100,000 flights were conducted
    totalling 47,728 hours. There are a further 131 Jabiru powered aircraft on the CASA register that will
    also be adversely affected.

    CASA has provided no specific failure data related to Jabiru engines to industry other than to suggest
    an increasing rate of engine failures. At no point has CASA published evidence or otherwise to
    substantiate its claims. RA-Aus and the aviation community have no evidence to suggest that the
    statements by CASA are made with any substance.

    RA-Aus have also noted a marked improvement in the reporting culture of members in recent years,
    making it critical to fully understand the underlying data and apply sound statistical analysis to test
    conclusions drawn from any data. A key area to understand in relation to placing these statistics into
    context is the possibility of not just engineering or manufacturing issues, but also correct operation
    of the engine in accordance with manufacturer information.

    Process
    On 27 October 2014 RA-Aus received a request from CASA for specific data relating to operations
    of Jabiru aircraft. This request was made with a specific deadline of 10 November 2014, requiring
    significant investment of RA-Aus resources, and was requested for the purposes of a proposed
    SASAO audit of Jabiru’s operations on 17 November 2014. The data provided contained information
    on incidents and accidents involving Jabiru engines for the year to date, covering the period from 1
    January 2014 until 27 October 2014.

    RA-Aus formally submitted this information to SASAO on 3 November 2014.

    On 4 November 2014 CASA engaged directly with Jabiru in relation to the proposed restrictions on
    Jabiru aircraft which included all aircraft manufactured by Jabiru as well as those non-Jabiru aircraft
    that have a Jabiru powerplant.
    In this notice CASA clearly states the following:
    “Prior to making the instrument, CASA invites Jabiru to make representations about the terms of the
    proposed instrument…”

    In the days immediately following this Jabiru made arrangements to meet with CASA on 14
    November 2014 to address the concerns and to take advantage of the opportunity to discuss the
    terms of the instrument as outlined in the regulators notice. This meeting was also intended to action
    CASAs request for Jabiru to respond by 10 November although it should be noted that due to illness
    of key CASA staff the meeting could not take place by the required date and that CASA agreed to
    extend the time. At this point Jabiru was led to believe that the proposed instrument would not be
    published until after the scheduled meeting.

    On the afternoon of 13 November CASA pre-empted the outcome of the scheduled meeting with
    Jabiru and effectively ended the consultation with the manufacturer by publishing the commercially
    destructive proposed instrument. This occurred some 18 hours prior to the scheduled consultation
    with Jabiru.

    In the days prior to this RA-Aus began receiving enquiries from concerned members noting that
    CASA officials had made mention of the proposed actions “over a beer or two” during the national
    Chief Flying Instructor conference held by RA-Aus. The conference is an annual event designed to
    inform RA-Aus instructors on new developments, changes to rules and generally improve safety in
    the aviation industry through the provision of training and education. It is fully funded by RA-Aus with
    no support from CASA or any other public source of funds.

    Following the publication of the draft instrument RA-Aus has been inundated with communication
    from aircraft owners, Flight Training Facilities and aircraft maintainers expressing concerns about
    the proposed restrictions and the potential impacts on business viability and reputational damage as
    a result.

    It should be noted that the information provided covered a period of less than one year and should
    have resulted in deeper engineering analysis as to root causal factors, along with requests for further
    detail prior to any action taken by the regulator. RA-Aus is firmly of the view that any conclusions
    drawn from the data are deficient in detail and do not address fundamental issues relating to potential
    manufacturing, operational and any other possible deficiencies.

    At the time of writing this submission it has become apparent that CASA recognised this deficiency
    in terms of their understanding of the data that was provided on 3 November. On 18 November
    CASA wrote to RA-Aus seeking instruction on how to identify 28 engine related issues referred to
    earlier in this submission. It is of serious concern that CASA does not only provide a basis for its
    decision, it does not understand the data provided by RA-Aus and has acted on a flawed
    understanding of the issues.

    Impacts on industry, aviation and RA-Aus
    Whilst the impacts on industry should not be an overriding factor when related to safety and decisions
    made, consideration must be given to potential financial and reputational damage caused by the
    issue of this consultative document to industry with insufficient analysis of data and short response
    times. Moreover, the ability of a crippled industry to cope with and implement growing requirements
    in terms of safety should be a consideration. This is certainly the case when proposed actions may
    indirectly and adversely impact the industry’s ability to sufficiently address future safety related
    issues.

    RA-Aus has approximately 1000 affected aircraft on its register and charges $130 for the annual
    registration of each. With around three times as many pilots as aircraft it could be argued that there
    will be around 3000 affected members, each of whom pays $210 per year to maintain their pilot
    certificate.1

    If all those affected chose to discontinue their relationship with RA-Aus as a result of
    these restrictions then the worst case loss of income may be in the order of $760,000 per annum.
    With an operating budget of approximately $2.5m per annum (compared to some $180m for CASA
    to administer around the same number of private pilots) if even a small proportion of these pilots and
    aircraft owners left the association then the ability of RA-Aus to administer its safety related functions
    on behalf of the Government would be severely impacted.2

    If Jabiru, the aircraft and engine manufacturer were to fail, this would result in a worsening of the
    situation and a deterioration of safety standards. Not only would RA-Aus struggle to maintain its
    activities in relation to improving safety in light aircraft, current Jabiru owners would have no access
    to ongoing support or spare parts for their current aircraft. That is to say, if Jabiru failed as a result
    of CASAs actions, owners would no longer be able to maintain their aircraft to a standard that would
    be safe due to a lack of ongoing support from the manufacturer.

    With US media outlets already publicising CASAs blunt approach to the problem the news is already
    reaching foreign shores. Indeed at the time of writing this submission RA-Aus has become aware of
    at least two foreign manufacturers that have cancelled orders which will have a notable financial
    impact on Jabiru and affect their ability to address the many concerns that CASA may have.

    1 Given that more than two thirds of RA-Aus’ 170+ flight training facilities use Jabiru aircraft or engines, the true
    number of affected pilots may indeed be much higher.
    2 While CASA is not transparent in terms of how it allocates its funding it should be noted that their total operating
    budget is in the order of $180m annually. With similar numbers of private pilot licence holders (although again, CASA
    is not transparent in terms of how many are active) to RA-Aus’ active pilot community it is clear that RA-Aus ostensibly
    performs comparable functions in a much more efficient manner than CASA.

    CASA has been cited in the Forsyth Report as being adversarial with industry and, some five months
    after the publication of this report, appears to be maintaining that style of approach despite it being
    ineffective as noted in the same document. The manner in which this matter has been handled to
    date is a standout example of the type of behaviour for which the Forsyth Report reserved its
    strongest criticism. That the CASA personnel involved either didn’t recognise or didn’t care that their
    actions constitute that kind of behaviour is of great concern and suggests that CASA has made no
    efforts to address the significant concerns of the report in the five months since its publication.
    CASA states on its website that its mission is “To enhance and promote aviation safety through
    effective regulation and by encouraging the wider aviation community to embrace and deliver higher
    standards of safety” yet the actions outlined above seemingly contradict with this mission. Indeed,
    the actions taken on this occasion can only be described as far from encouraging a positive result.
    In addition to these impacts the aircraft types in question form a large part of the fleet used for training
    purposes. Flight training is the first opportunity for RA-Aus (and any flying body) to impress the need
    for high levels of safety on new pilots. With two thirds of the RA-Aus flight training facilities relying
    on Jabiru for their operations, this safety message can no longer be promulgated to pilots.

    CASA will argue that the flight training activities being proposed are not eliminating pilot training,
    they are simply restricting pilot training to dual pilot operations. That is, pilot training can continue
    but trainee pilots cannot go solo using Jabiru aircraft. This sentiment further reinforces the lack of
    understanding of the industry on the part of CASA, the body responsible for regulating it.

    Pilots are required, by law and under the RA-Aus Operations Manual, to undergo solo training before
    being issued with a licence or pilot certificate. This is a fundamental requirement of any training
    regime whether it be administered by RA-Aus, CASA or another body. The simple fact is that you
    cannot become qualified to fly an aircraft in Australia without conducting solo flying time. Thus, the
    restriction on flying schools that renders them unable to provide such training and effectively shuts
    them down.

    Before any student is permitted to undertake a solo flight of any type, competency in managing
    emergency situations which include engine failures must be demonstrated. This is a requirement for
    both the CASA and RA-Aus flight training syllabi and is intended to equip pilots with the required
    knowledge to safely cope with such an event. Thus the recommendation to restrict solo flight training
    operations in Jabiru powered aircraft is a position that RA-Aus patently disagrees with and vigorously
    opposes.

    The negative effects of the proposed restrictions must include potential loss of income and the threat
    to the livelihoods of those Australian’s that are employed in the industry. These include, but are not
    limited to, the direct impact on manufacturing (including the sub-contractors involved in Jabiru’s
    manufacturing processes), the employment of aircraft maintainers in the industry (a sector already
    crumbling under pressure) and the pilots and instructors that have devoted significant amounts of
    time and money to gain their flying credentials. With dwindling opportunities in the sector there is a
    significant possibility that these people, especially pilots, will leave the country to seek work
    elsewhere contributing to the existing problem of a decline in aviation expertise in Australia.

    For private operators of the aircraft the ramifications are equally significant. With many individuals
    purchasing these aircraft with the intention of using them as a two seat vehicle, the proposed
    restrictions effectively render them unsuitable for this type of operation. Furthermore, each and every
    aircraft is required to have a warning sticker attached to the instrument panel that is visible by all
    occupants stating that the aircraft does not comply with the standard safety regulations and that all
    persons fly in the aircraft at their own risk.

    In addition to this, many operators use their aircraft for work related purposes such as cattle spotting,
    observing fences and checking dam levels. For regional Australia where these type of operations
    are common the implications of the restrictions will extend well beyond aviation and into other,
    struggling sectors such as agriculture. With regional employment already suffering this proposed
    restriction has the potential to worsen an already difficult situation. There is also a significant chance
    that many regional based pilots will ignore the proposed instrument and continue with the status
    quo.

    3
    These impacts on regional Australia and the potential employment effects are in addition to the
    simple economic impacts of stranded capital in the economy. There are well in excess of 1000 Jabiru
    aircraft or other types of aircraft with Jabiru engines fitted currently registered with RA-Aus. With a
    conservative estimate of $40k per aircraft the implications of this action at worst will be some $40m
    of aircraft rendered useless in the economy.

    RA-Aus also note the inclusion of experimental or amateur built aircraft in the proposed instrument
    could be considered as outside CASA authority. This class of aircraft is not subject to any CASA
    imposed safety standards and by their inclusion CASA could be perceived to be acting beyond its
    remit demonstrating a clear lack of understanding of the implications of the proposed restrictions or
    the regulations it is supposed to administer. This highlights yet another example of the regulator
    being ineffective due to an insufficient understanding of the industry.

    Summary
    Whilst RA-Aus is supportive of moves to improve the reliability of Jabiru engines and safety in the
    sector, the adversarial approach taken by CASA and the lack of due process, transparency and
    direct consultation may be extremely damaging to aviation and the broader economy. The extent to
    which these impacts may affect the aviation sector include damaging the ability for the sector to
    improve safety related practices relating to all aspects of the industry be they maintenance or flying
    operations. For the broader economy the impacts are widespread and include negative employment
    impacts, adverse effects on regional Australia and the issue of stranded capital. Further, given that
    Jabiru aircraft are under-represented in fatality statistics, any claim of safety benefits arising from
    these measures is dubious at best.

    The aforementioned Forsyth Report noted that “the industry’s trust in CASA is failing” and the actions
    undertaken by CASA on this occasion provide evidence that CASA simply does not care. CASA
    shows a complete lack of respect for the industry and the Government commissioned report is being
    treated with the same lack of respect. This is a clear demonstration that CASA is simply not
    interested in taking on the practices of leading regulators around the world and has even less interest
    in reforming its practices and heeding the advice of the report:
    “The Panel concludes that CASA and industry need to build an effective collaborative relationship
    on a foundation of mutual trust and respect.”

    It is clear to RA-Aus that CASA views itself as being responsible to no stakeholders be they industry,
    Government or any other sector within the economy. They have an attitude that they can unilaterally
    take any actions they please and have demonstrated their clear arrogance and belief that nothing
    needs to change despite professional and independent advice to the contrary.

    They also show complete contempt for the present Government’s mandate of only introducing
    regulations and rules where there can be a clear and demonstrable benefit arising out of the new
    regulations. With no transparency, data or analysis it is once again clear that CASA believes it can
    operate outside of those rules that guide decision making in all other government departments.
    The lack of transparency and consultation relating to Jabiru powered aircraft is of huge concern to
    industry. Not only has CASA made a decision that is not transparent, it has not sufficiently engaged
    with industry in an attempt to solve the perceived problem. CASA has also, in the days following the
    action, shown a lack of understanding of the data that was obtained through misleading statements
    making its claims even more dubious.

    RA-Aus vigorously opposes all of the actions proposed by CASA and strongly urges the Department
    and the Minister to:

    1. Withdraw the instrument in full and appropriately consult with all parties to develop an
    acceptable solution,

    2. Review the process for addressing the so called issues,

    3. Reconsider the findings of the five month old Forsyth Report, and

    4. Act on the recommendations contained within the Forsyth Report.

    Delaying such actions will only allow CASA to continue to have damaging effects on aviation in
    Australia and indirectly impact the broader economy.

    Yours faithfully,
    Michael Monck
    President
    Recreational Aviation Australia
     
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  14. Nov 24, 2014 #74

    BBerson

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    Well, that is a sad situation.
    It seems to me that as long any government has created an agency charged with the "mission" to "enhance aviation safety with effective regulation", the result will be a continuous trend toward banning the most affordable activity.
     
  15. Nov 24, 2014 #75

    autoreply

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  16. Nov 24, 2014 #76

    cheapracer

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    Was pretty darn good up until the 1970's.

    I could give hundreds of examples, we're not here for that though, but here's some to take away that Wild West impression;

    If you are at a bar and the barman decides you have had enough to drink, he will ask you to leave. If you don't leave immediately, as in right now, you will be arrested - not maybe, will be. You may have images of people being rolling drunk for that to happen, I assure you not. You can't drink in public places either.

    Oh and to have a Wild West you would need guns, the Government took them off us in the 90's by illegitimate mandate.

    I grew up in Australia, owned businesses, raised a family and "Owner/Builder" built 2 houses there, have lived in China for 10 years, I have no doubt that your perception of which place is highly regulated and which place is free are completely opposite to fact ;)
     
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  17. Nov 25, 2014 #77

    Vigilant1

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    [h=1] As someone once wrote:
     
    bmcj, akwrencher, Pops and 1 other person like this.
  18. Nov 25, 2014 #78

    DaveD

    DaveD

    DaveD

    Well-Known Member

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    There's no doubt that CASA has its issues, but having come to Australia from the UK I can safely say that Australia is a designer/homebuilder's utopia compared to the level of regulation back in "Blighty".
     
    SVSUSteve likes this.
  19. Nov 25, 2014 #79

    cheapracer

    cheapracer

    cheapracer

    Well-Known Member

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    Completely different demographic, we have farms bigger than all of England, light planes are an absolute necessity due to our distances and needs, it's all relative.

    You didn't mention the ramp checks by the way, how would you guys like to land at Oshkosh to be met by an official who checks over your airworthy'ness, weights and certifications and will fine you on the spot if they aren't all perfect ... great way to start your weekend.

    In England you can build and licence all sorts of manner of car, Internationally famous for their low volume cars, kit cars and IVC - try it in Australia one day.
     

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