AOPA has filed formal comments asking the FAA to withdraw a proposed airworthiness directive (AD) that could affect thousands of ECi cylinders. The association’s Dec. 11 comments warn that the drastic course proposed by the AD isn’t supported by the data, could cost much more than the FAA estimates, and has the potential to cause more safety problems than it solves.
The proposed AD calls for repetitive inspection and early retirement of replacement cylinders with serial numbers manufactured between May 2003 and October 2009 by Airmotive Engineering Corp. and marketed by Engine Components International Division, better known as ECi. The NTSB had previously recommended a more moderate course to include repetitive cylinder inspections.
“The proposed AD covers an inappropriately broad swath of affected cylinders while also requiring an extremely draconian and economically harsh call for the early retirement of affected cylinders,” AOPA wrote in its comments. “The proposed actions are based upon inadequate and flawed data and improper assumptions in applying the FAA’s Risk Analysis guidelines. There are no known cases of failures of these cylinders leading to accident or injury, further bringing into question the FAA’s proposal for early retirement.”
The FAA has estimated the proposed AD would cost $82.6 million and affect 6,000 aircraft with Continental 520 and 550 engines. But AOPA and others are concerned that costs could actually go much higher as aircraft are grounded for extended periods of time. The possible safety ramifications of inadequate capacity at overhaul facilities and the sudden need to replace thousands of cylinders in the field could create additional safety issues, AOPA noted in its comments.
AOPA asked the FAA to work with stakeholders to educate pilots about operational concerns and symptoms of problems. “We strongly contend that better education is often the most effective tool to improve aviation safety and offer our assistance in any educational effort,” AOPA wrote.
“This AD simply goes too far,” said AOPA Vice President of Regulatory Affairs Rob Hackman. “The FAA needs to step back from this proposal and take a hard look at the available data before taking any further action.”
In fact, according to AOPA’s analysis of the supporting data provided by the FAA, the AD proposal is based on only 15 cases of documented cylinder failures out of a population of some 30,000 cylinders affected by the AD.
In November, the National Transportation Safety Board (NTSB) took the unusual step of filing formal comments of its own in which it asked the FAA to take action “more consistent” with NTSB recommendations released in February 2012, saying there was no available evidence to support the FAA’s more drastic proposal.