The FAA’s supplemental notice of proposed rulemaking (SNPRM) on ECi cylinders is not justified by the agency’s documentation and doesn’t fully account for the economic and safety implications of its requirements, AOPA said in formal comments filed Feb. 23.
AOPA is asking the FAA to align its rule with recommendations from the National Transportation Safety Board (NTSB), publish the findings of a “multi-directorate/multi-disciplinary team” review by the FAA, and consider the safety and economic impact of forcing 5,000 aircraft to undergo maintenance and cylinder replacement almost immediately.
In its own formal comments to the supplemental notice of proposed rulemaking filed Feb. 11, the NTSB recommends allowing the cylinders to go to the manufacturer’s recommended time between overhauls (TBO), rather than requiring early retirement and replacement, a position AOPA has supported throughout the rulemaking process.
“AOPA continues to oppose this airworthiness directive and urges the FAA to take action which is more limited in scope and is in closer alignment with NTSB recommendations,” the association wrote in its formal comments, adding that “…the continued call for early retirement of ECi cylinders prior to their reaching TBO is unjustified by FAA documentation and NTSB review and recommendations.”
At issue is a proposal calling for 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 cylinders are installed in thousands of Continental 520 and 550 engines.
The supplemental proposed rule was issued Jan. 8 after the FAA received numerous comments on its original notice of proposed rulemaking (NPRM) recommending that the airworthiness directive be withdrawn, including comments from AOPA.
In light of those comments, the issue underwent what the FAA called a “multi-directorate/multidisciplinary team review” which determined that the cylinders are still unsafe. But the details of that review have not been made available to the public. AOPA is asking the FAA to publish that information and extend or reopen the comment period to allow for meaningful input from the stakeholder community.
Under the SNPRM, cylinders with 680 or fewer hours’ time in service (TIS) should be removed before reaching 1,000 hours TIS. Cylinders with more than 680 hours TIS but no more than 1,000 hours TIS should be removed within the next 320 operating hours or within 1,160 hours TIS, whichever occurs first. And cylinders with more than 1,000 operating hours should be removed within the next 160 operating hours or at the next engine overhaul, whichever comes first. The new proposal also eliminates reporting requirements for all cylinders removed and adds removal of overhauled cylinders within 80 hours.
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 would be much higher as aircraft are grounded for extended periods of time and orders for replacement cylinders back up. 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.
“The mass replacement of thousands of cylinders in the field could ultimately compromise, rather than enhance, pilot safety,” AOPA warned in its comments.