The FAA has released a supplemental notice of proposed rulemaking affecting ECi cylinders, but AOPA says the new proposal doesn’t go far enough to mitigate the impact on aircraft owners.
At issue is a proposal calling for the 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.
On Jan. 8, the FAA published the supplemental notice of proposed rulemaking in the Federal Register, opening a new comment period through Feb. 23. The supplemental proposed rule was issued after the FAA received numerous comments, including comments from AOPA, on its original notice of proposed rulemaking recommending that the airworthiness directive be withdrawn.
In light of those comments, the issue underwent what the FAA called a “multi-directorate/multidisciplinary team review,” and determined that the cylinders are still unsafe but that comments did support a lengthier compliance interval. The review determined that cylinders should be removed at an average of 1,000 hours’ time in service (TIS), rather than the 1,700-hour time between overhauls (TBO) recommended by the manufacturer, an increase in allowable service time over the original proposals for some of the cylinders. The National Transportation Safety Board had recommended that the cylinders be allowed to reach their 1,700-hour TBO before being removed.
“We appreciate the FAA’s extensive internal review of the proposed rule, but we continue to believe that the FAA should do more to minimize the impact on aircraft owners and align with the NTSB’s recommendations,” said Rob Hackman, AOPA vice president of regulatory affairs. “AOPA will file formal comments on the supplemental notice of proposed rulemaking and, once again, ask the FAA not to insist on early retirement of these cylinders.”
The supplemental notice of proposed rulemaking makes several changes to the original NPRM, including removing a requirement for repetitive 50-hour inspections and modifying the schedule for removing affected cylinders. Under the new proposal, cylinders with 680 or fewer hours 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 previous version of the proposed rule would have divided the cylinders into two groups based on their serial number and given owners as little as 25 operating hours to remove them.
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. 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 National Transportation Safety Board had recommended allowing the cylinders to go to TBO, rather than early retirement and replacement, a solution which AOPA has argued is more appropriate given the small number of cases involved.