EAA to FAA: Withdraw AD on ECi Cylinders
December 12, 2013 - EAA is recommending that the FAA withdraw its proposed airworthiness directive (AD) regarding reciprocating aviation engine cylinder head assemblies manufactured by ECi Inc. because of a lack of data or adequate risk analysis performed by the agency.
In comments submitted to the federal rulemaking docket on December 11, EAA joined other GA groups in urging FAA to withdraw the AD because the FAA failed to follow its own data-driven risk assessment process designed for airworthiness corrective actions. As written, the AD would mandate removal of certain ECi cylinder assemblies well before the required aircraft engine overhaul.
EAA was joined in opposition to the AD by such organizations as AOPA, American Bonanza Society, and Aeronautical Repair Station Association. Even the National Transportation Safety Board did not find cause for the FAA's proposed AD.
EAA notes that "there is no record provided that a formal consideration of risks and potential remedies was ever undertaken" in advance of the proposed AD. EAA is concerned that FAA did not conduct an appropriate cost/benefit analysis for the AD, as the estimated $82 million cost of compliance for aircraft owners is disproportionately high for the handful of documented cylinder head separations, none of which resulted in domestic aircraft incidents or accidents.
The estimated cost for an individual aircraft owner would be at least $12,000 for a single-engine operator and $24,000 for a twin-engine aircraft operator.
The FAA has a well-established risk assessment process that was jointly created by the FAA and aviation industry, including EAA, called the "Monitor Safety/Analyze Data" (MSAD) program intended to be "a means to provide a consistent, data-driven approach to AD issuance by the agency." The supporting documents that the FAA provided to the docket did not contain any evidence that this process was followed, or that any formal risk assessment was undertaken.
The NTSB released a safety recommendation in 2012 suggesting that the cylinder assemblies in question be inspected on a recurring basis and then removed at the engine manufacturer's recommended TBO. The FAA received this safety recommendation, but there is no evidence that it was seriously considered by the FAA.