AOPA is once again asking the FAA to withdraw a proposed airworthiness directive (AD) that could affect thousands of ECi cylinders. The association repeated its request in formal comments on the FAA’s Initial Regulatory Flexibility Analysis.
In the May 12 comments, AOPA noted that the FAA’s own analysis indicates the agency underestimated the impact of the proposed AD, which would have substantial effects 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.
“From the beginning we’ve argued that this AD is not justified by the evidence, and this analysis only reinforces that belief,” said Rob Hackman, AOPA vice president of regulatory affairs. “As written, the proposal is overly broad and the suggested remedy could cause serious economic and safety problems. There have been no known cases of an accident or injury being caused by failure of the affected cylinders, so we want the FAA to withdraw the proposal and re-evaluate the evidence.”
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 exceed $100 million 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.
“Any airworthiness directive should be based on solid evidence,” said Hackman. “Given the available data, there are more appropriate and less draconian ways to address these safety concerns.”
The National Transportation Safety Board had recommended recurring inspection of the cylinders, rather than early retirement and replacement, a solution which AOPA argues is more appropriate given the small number of cases involved. 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.
