AOPA is continuing to oppose a proposed airworthiness directive (AD) affecting ECi cylinders after the FAA published new analysis showing that the agency significantly underestimated the impact of its plan.
The Initial Regulatory Flexibility Analysis, published March 21, shows that, contrary to the FAA’s initial assertions, the AD would have a substantial impact on more than 600 small Part 135 operators and another 5,000 small air services businesses.
At issue is a proposal calling 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.
AOPA has repeatedly asked the FAA to rescind the notice of proposed rulemaking on the grounds that FAA underestimated the impact and lacked evidence that such drastic measures were needed. There have been no known cases of an accident or injury being caused by failure of the affected cylinders.
In December 2013, AOPA filed formal comments asking the FAA to withdraw the AD. The publication of the new analysis opens a new comment period, and AOPA will again file formal comments before the May 12 deadline. Aircraft owners and operators who would be affected are encouraged to file comments of their own and include information about how they would be affected, including the costs of downtime, loss of business, the need for replacement aircraft, and other expenses or hardships they would incur as a result of the AD.
The FAA originally estimated the proposed AD would cost $82.6 million and affect 6,000 aircraft with Continental 520 and 550 engines. But AOPA believes 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.
“As proposed, this AD creates more problems than it solves,” said Rob Hackman, AOPA vice president of regulatory affairs. “There are better ways to address safety concerns, and we are prepared to work with the FAA to find a way forward that protects pilots without needlessly grounding thousands of aircraft.”
According to AOPA’s own 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.