Dear Mr. Lewis:
The Aircraft Owners and Pilots Association (AOPA) has received numerous calls from concerned members regarding the potential impact of Critical Service Bulletin (CSB) 99-3A and its associated airworthiness directive (AD). We agree that the actions required by this service bulletin are necessary to prevent additional crankshaft failures and to ensure the safety of the operators of affected aircraft. Further, AOPA recognizes that Teledyne Continental Motors (TCM) is making an effort to mitigate the impact of this manufacturing defect by absorbing the cost of the required inspections and any necessary repairs. However, AOPA members have reported that at present, there are only 10 inspectors qualified to conduct the required ultrasonic inspections. AOPA is concerned that such a small number of available inspectors will not be able to conduct the vast number of required inspections in a timely manner, leaving affected aircraft grounded for an unacceptable period of time.
It has been reported that the required ultrasonic inspection will take an average of � day to complete. Consequently, it would take 10 inspectors more than 5 months to complete the over 3000 required inspections. Long periods of aircraft grounding, such as this one, can have a substantial financial impact upon affected aircraft owners. These owners must continue to pay aircraft loans, monthly hangar or tie-down rental fees, chart subscriptions, costly GPS database subscriptions, and aircraft insurance premiums regardless of whether or not their aircraft are flying. Many aircraft owners who utilize their aircraft for business purposes may be forced to rent another aircraft or make other travel arrangements at considerable expense. Additionally, many owners may need to rent aircraft to maintain currency of their operational privileges. For these reasons, AOPA holds that a potential five-month (or even a three-month) aircraft downtime would be unacceptable.
AOPA implores TCM to seriously consider the impact of extended aircraft grounding and make an earnest effort to minimize the downtime for affected aircraft. We are aware that training classes are currently underway to certify more technicians to conduct the required ultrasonic inspection. AOPA urges TCM to accelerate these efforts to increase the number of qualified inspectors to a level that will ensure that affected aircraft spend a minimum amount of time on the ground.
AOPA believes the potential adverse financial impact of grounding over 3000 aircraft for up to five months demands serious attention and consideration on the part of the Teledyne-Continental Motors. It is AOPA's sincere hope that TCM recognizes and fully understands the impact of any extended periods of aircraft grounding and makes every effort to substantially reduce the aircraft downtime for affected aircraft owners.
Thank you for your time and consideration on this matter. AOPA stands ready to assist TCM in any way possible to minimize the burden of this airworthiness action on owners of aircraft utilizing affected TCM crankshafts.
Respectfully,
Phil Boyer