Ownership Hassle vs. an AD

 

The FAA has proposed an AD that would require the early replacement of thousands of aftermarket ECI Titan cylinders used on big-bore Continental engines. The FAA believes the proposed AD would hit at least 6,000 airplane owners at a total cost of more than $82 million.

This proposed AD is a perfect example of the FAA using the AD club to beat on what is really an airplane ownership issue. I guarantee that some ECI cylinders will crack and develop other problems, and so will some cylinders from any other manufacturer. It’s what cylinders do. If you haven’t had to repair or replace cylinders you either don’t own an airplane, or haven’t flown very much.

Cylinders are the wear item on any air cooled piston engine. They are the focal point for heat and stress. Though cylinder design and metals have improved over the decades, cylinder life is still unpredictable.

The proposed AD points to an unspecified number of cracks in ECI Titan cylinder heads, and also to some unannounced number of cylinder head-to-barrel failures. The aluminum head in any cylinder is joined to the steel barrel through a hot-cold process that permanently locks the two components together. If the aluminum head cracks severely at the head-to-barrel junction the head can separate making that cylinder inoperative.

So? An engine will continue to produce a large majority of its rated power after a head-to-barrel separation occurs. Oil loss will be minimal. Vibration will be scary, but the engine won’t break out of the mounts. The cylinder failure is a big bucks maintenance hassle for the airplane owner, but it won’t kill him. And the proposed AD doesn’t indicate that ECI cylinder failures caused any specific accident, or fatal crash.

Under FAA certification theory the failure of an engine is assumed. The reliability of any engine, piston or turbine, is not good enough to meet the high bar of “improbable” required to be the only difference between life and death.

In singles the backup to the engine is the 61 knot stall speed. The speed limit is set so that the amount of energy that must be dissipated in the forced landing after the engine fails is controlled and the outcome is likely survivable. In twins the second engine is required to be able to keep you flying after one engine fails. If a twin stalls at 61 knots or less there is no engine-out performance requirement.

On the other hand, ADs are supposed to be reserved to correct real safety of flight items. For example, if there is a problem with the primary structure of an airplane, or the flight controls, failure of those items in flight would almost certainly lead to a fatal crash. If a wing breaks off, or a tail surface departs, your chances are essentially nil. So those components must perform as designed and certified. If they don’t, an AD is necessary to correct the defect.

I’ve lost count of how many cylinders I have had to replace or have repaired over the decades, but it’s a lot. Usually it is valves that cause the cylinder problem, but I have had premature cylinder barrel wear, and several cracked heads. I haven’t had a head-to-barrel separation failure, but I did have a rocker boss failure that did the same thing by rendering that cylinder totally inop during flight.

In every case the cylinder failure is a pain in the wallet, not a threat to life. I’m sure there are owners of ECI cylinders who wish they had bought some other brand. But that could be said of owners of any brand of cylinder when it develops problems, and they all do sometime. To force thousands of airplane owners to replace cylinders that are working ok at the moment to spend millions of dollars to replace them is plain crazy. Who’s to say that whatever cylinders go on in place of the ECI Titans will fare any better?

Every airplane owner holds their breath over cylinder reliability, but not during flight. It’s at inspection time when the shop gets out the compression tester and other gear that cylinder fright grips all of us owners. And that’s as it should be. Cylinders are an ownership hassle, not a safety of flight item. The proposed AD would force thousands to spend millions and probably make the engines less safe because there is a chance the new cylinders will be installed incorrectly and the engine could then suddenly fail. This AD proposal needs to be withdrawn.

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32 Responses to Ownership Hassle vs. an AD

  1. Ted Klapka says:

    Mac’s comments seem to make an awful lot of sense.

    But I wonder how much vibration this will really cause and how scary will it be? Ergo, how many pilots will opt to just shut it down and set it down? An off field dead stick carries real risk, especially at night.

    This should be balanced against how many problems are going to be created by opening up a perfectly good (or acceptable) engine.

    It appears that the cure MAY be no better than the disease. Unless the FAA can Prove otherwise, it appears it may be best to leave well enough alone. If the Feds really want this AD, they need to lay out a lot more data.

  2. brett hawkins says:

    Is this possibly a little hint of the payback the FAA can visit upon private pilots who are so vigorously complaining about the 3rd class medical?

    “Notice: the beatings will continue until morale improves!”

    I know those supporting the 3rd class medical exemption probably don’t fly behind large displacement Continentals. This comment is just for laughs.

  3. Brian Curry says:

    Mike Busch wrote about this proposed AD as well. The numbers Mike cited make you wonder as to the motivation of the FAA in this matter. Does someone in the FAA get a bonus for ADs produced?

  4. This proposed AD against ECi Titan cylinders is even less justified than what Mac suggested in his blog post.

    Not only haven’t there been any accidents or fatalities arising out of the separation of an ECi cylinder, there haven’t even been any injuries of any kind. In fact, the FAA has so far been very evasive about its reasons for proposing the AD. They have not identified any specific head separation incidents in the NPRM or the rules docket, nor indicated what the safety consequences of those incidents was (if any). This is shocking, because the FAA is required by law to show proof that an unsafe condition exists before commencing an Airworthiness Directive rulemaking action.

    As Mac points out, the impact of a head separation is simply that one cylinder shuts down and the other five cylinders continue to produce power. (All affected engines are six-cylinder Continental 520s and 550s.) The engine will run rough with only five cylinders firing, but FAR Part 33 specifically requires that every certificated piston aircraft engine must be demonstrated to operate with one cylinder inoperative at all RPMs between idle and red-line without vibration levels that are dangerous. Like Mac, I’ve experienced in-flight cylinder shutdowns in six-cylinder Continental engines and they’re really no big deal. The engine runs rough, produces about 80% power, and you land at the next convenient airport.

    The fact is that this whole mess was triggered by a 2010 fatal crash of a Bahamian-registered Cessna 402C on takeoff from Nassau. The left engine of that 402C did suffer a head separation. Nine people died in the crash. But the facts of that fatal accident are important:

    – The head separation didn’t cause the crash, according to investigators.

    – The cylinder that suffered the separation was not an ECi TITAN cylinder, which are the cylinders being attacked by the proposed AD. It was an overhauled ECi FREEDOM cylinder, a continued-time cylinder with undocumented (but undoubtedly very high) time on the cylinder head.

    – The aircraft took off somewhere between 500 and 700 pounds over gross. (This was a Part 135 flight packed with paying passengers and way too much luggage.)

    – The pilot attempted a steep turnback maneuver that progressed to 90-degrees of bank before the airplane cartwheeled into a lake.

    – The pilot re-extended the landing gear before landing was assured.

    – The pilot shut down the GOOD engine! The head separation occurred in the LEFT engine, but investigators found that both mag switches and the alternator switch of the RIGHT engine had been turned off, and that both mag switches and the alternator switch of the LEFT engine were still on.

    – The pilot may have shut down both engines, because inexpicably investigators found that both fuel selectors were in the OFF position.

    – The pilot wasn’t legal to fly Part 135.

    – The pilot took an inordinately long time during the pre-takeoff engine runups, and some observers reported hearing backfiring.

    – Investigators agreed that the airplane was capable of climbing had the pilot not banked and lowered the gear (and at some point shut down the wrong engine).

    I could go on, but I won’t. I ask you, does this sound like the sort of accident that should trigger an AD calling for forced retirement of 30,000 ECi TITAN cylinders from 6,000 engines?

  5. Greg Broburg says:

    Does anyone remember the Continental VAR crankshaft game? It went something like this, you need to replace your crankshaft with this new vacuum arc remelt technology cause too many of the old ones been breakin. So we did that and lo and behold a message comes down from the heavens that we gotta go drill some test plugs from our new flange to see if we had ones with excess Vanadium content. Kinda turned out that there were a bunch of airplanes that were having problems with the new VAR parts. It seemed a lot worse than the original situation. I agree with Ted above, “they need to lay out a lot more data”

    • Greg, that’s an excellent example. Industry let the FAA get away with the VAR crankshaft AD despite a great deal of evidence provided by the Aeronautical Repair Station Association that no unsafe condition existed. Unfortunately, ARSA was a lone voice in the wilderness and was not backed up by the rest of the industry. The AD went through, and lo and behold we wound up having vastly more failures of the new-and-improved VAR crankshafts than we ever had with the old airmelt crankshafts.

      This ECi AD promises to be even more of a travesty than that one was. It must be stopped.

  6. Ashley Palmer says:

    The reason for the AD is to put ECI out of business.

    • Well, I’m not enough of a conspiracy theorist to make that assertion, but that could easily be the result if the AD is not stopped. And if ECi goes out of business, prices of engine components will rise dramatically. A study of Continental and Lycoming parts prices shows conclusively that OEM parts that have no aftermarket STC equivalents sell for 2 to 3 times the price as comparable parts that have aftermarket competition.

  7. Mike Massey says:

    Had one head blow apart while climbing through 11,000 ft (T210) while leaving Sun-N-Fun in 2009. Ran rough with reduced power, landed, still had about 4 quarts of oil.
    Put a new cylinder on with no damage to the rest of the engine. I had run that turbo-charged engine hard and hotter than I should have and have since done a major overhaul and installed a graphic engine monitor. That engine had about 1600 hrs with about 900 on the cylinders.
    Our government is completely out of line requiring this. Putting graphic engine monitors on all these airplanes and not allowing cylinder temperatures to exceed about 400 degree’s would probably save 10 times more cylinder failures than this!!!

    Our government is doing so many things I disagree with. There has to be a way to stop them. By the way my current cylinders are ECI nickel, but are not in this AD.

  8. Richard Frederick says:

    While I agree with Mac’s basic point that cylinder failures are an economic problem rather than a safety problem, I don’t believe the problem should exist to begin with. If the industry had engineered and built water cooled, high RPM engines years ago we would be in a different situation. Japanese (and later, European) motorcycle manufactures managed to water cool their engines and fit them in small packages. I would like to see what Honda (or BMW or Yamaha, etc.) could do if cut loose to solve the problem. Now, however, it is all pain and no gain for a manufacturer to jump into the product liability swamp that is general aviation. Too late now.

  9. Joe Campbell says:

    Something is fishy here?? I would be very suspect of Teledyne. I had a crank failure in my Baron E-55.. Replaced it with with a remanufactured Continental engine. Had nothing but trouble with exhaust valves with less than 200 hours.. Had a kick back at 300 hours and ring gear broke. Sent the engine out for rebuild and I had the shop replace all cylinders with ECI cylinders.. Funny thing,,the shop questioned the crank ( remember 300 hours) they sent it to Continental for the final say,,,,,,, would you believe they lost my crank shaft??? They finally after weeks ,sent a new crank… All this FAA paper work B… So,,the engines with ECI,,not one problem in the past 500 hours and I have 100% confidence in them. The other engine with stock cylinders?? I want to replace with ECI… I only wish that ECI had a complete engine I could buy!!
    Joe

  10. Mike Massey says:

    I am not a conspiracy advocate either, but didn’t a Chinese outfit buy Continental Motors? I prefer to believe the bureaucrats at the FAA are just a little slow and not trying to actually ruin our country. That’s a happier thought isn’t it???

    • Continental Motors, Superior Air Parts and Cirrus Aircraft are all now owned by Chinese owners. Can Lycoming and Cessna be far behind?

      However, it’s worth considering that had Chinese owners not stepped in to buy these companies, they very well may have gone out of business. Lycoming tried to buy Superior’s assets out of bankruptcy in order to make sure they stayed dead and could never again compete with Lycoming, and they would have succeeded but for the heroic actions of the Anti-Trust Division of the Texas Office of Attorney General (which whom I worked to stop Lycoming’s acquisition).

      In my view, a healthy Continental, Superior and Cirrus under Chinese ownership is a helluva lot better than a dead Continental, Superior or Cirrus. Sure I would have preferred these companies remain American-owned, but no American capitalists were willing to step up to the plate at the time.

  11. Steve Carter says:

    More heavy handed draconian measures by an agency / administration that is obsolete by today’s aviation standards. Bring Orville back! He did it right.

  12. Dale Schultz says:

    It is interesting to see that there are a lot of people that know engines, comment negatively about this proposed AD. My gut feeling is that they are correct.
    GA is being put out of business by restrictions. Do ya think??

  13. Rodney Hall says:

    If one chose you could look at it as another attack on those overly rich folks who own airplanes. I think that is the way the current administration views us. There really is no logic behind this AD and while it won’t affect me personally it is bad policy to send out a fix for a non problem just to justify your existence. It will severely impact a lot of pilots.

    • Steve says:

      Why doesn’t one of our large pilot organizations (AOPA, EAA) engage legislators to draft a bill that requires FAA to justify these types of random proposals with facts and economics? Why is it that we are always on the defensive with the same folks that are supposed to be working for us? This is moronic is it not? Why can’t we hold them accountable for their proposals and proposed actions as they do us?

      • Steve, the facts and economics are already required, both by law (Administrative Procedures Act and several other federal laws) and by regulation (FAR Part 39). It’s just that in this case the FAA didn’t follow the law, the regulations, or the FAA’s own Airworthiness Directive Manual. FYI, a joint letter from AOPA, EAA, and several other associations is being sent to the FAA today, demanding that they provide the required supporting information and then extend the NPRM comment period until 120 days AFTER they have provided the required information to the docket. The information requested is specific documentation of all the cylinder failures that the FAA is relying on to justify the proposed AD, together with all related accident and incident reports and service difficulty reports (SDRs).

        • Steve says:

          Thanks Mike! Guess we will see what the outcome of the action will be. Filing legal action against FAA is surely being considered. How about finding out who is submitting this type of proposal and removing them? Remove their supervisors as well. Our government is out of control by any measure. What happened to common sense?

        • Ted Klapka says:

          It would be good if AOPA, EAA or someone publicly posted that joint letter.

          • Mike Busch says:

            The letter has been submitted to the docket and should become visible on regulations.gov sometime Tuesday Sept. 3rd.

          • Steve says:

            Would it be an inconvince to send to all current members?

          • Steve says:

            Sorry for the bad spelling

          • That request is above my pay grade. EAA’s Sean Elliott is a signatory on the letter. You could ask him for a copy. But it’s probably just easier to wait until Tuesday and grab it from the docket at:

            http://www.regulations.gov/#!docketDetail;D=FAA-2012-0002

          • Steve says:

            Mike

            It’s a shame that the whole membership is not notified timely by its Core.

            Steve

          • Ted Klapka says:

            August 30, 2013
            U.S. Department of Transportation
            Docket Operations, M-30
            West Building Ground Floor
            Room W12-140
            1200 New Jersey Avenue SE
            Washington, DC 20590

            RE: Docket No. FAA-2012-0002: Airworthiness Directives; Continental Motors, Inc. Reciprocating Engines Notice of proposed rulemaking (NPRM)

            The cosigners of this letter represent the pilots, aircraft owners, operators, and small businesses impacted by the FAA’s proposed Airworthiness Directive (AD) FAA-2012-0002 on certain Airmotive Engineering Corp. replacement cylinder assemblies marketed by Engine Components International Division (ECi). With this letter, we are requesting that the FAA provide to the docket the data and analysis that led to the agency’s proposal. We are asking that the agency either withdraw the NPRM until such time as information can be provided to the docket or, that the Agency extend the comment period 120 days from the time additional information is provided.

            The FAA estimates that this AD would affect approximately 6,000 aircraft costing operators a combined $82.6 million. This proposed AD would result in an enormous financial burden for the industry and requires the replacement of many cylinders, in addition to repetitive inspections. The early retirement of cylinders goes well beyond the February 2012 safety recommendation of the National Transportation Safety Board.

            According to the notice, this AD was prompted by reports of “multiple cylinder head-to-barrel separations and cracked and leaking aluminum cylinder heads.” To date the FAA has provided no supporting or substantial data of any kind to the docket to back its proposed action. Additionally, at this time the docket contains no FAA supplied reports of the referenced “multiple cylinder head-to-barrel separations” or any accident reports or Service Difficulty Reports that the FAA may have used in developing the extensive and significantly burdensome course of action proposed in this notice.
            While we share the Agency’s concern for the safety of General Aviation, without the Agency providing supporting data used in drafting this proposal, we can neither fully understand nor evaluate the agency’s safety concerns. This inhibits the industry’s ability to effectively comment on the Agency’s safety concerns and provide potential alternatives to the proposed course of action.
            We request that the Agency post to the docket, the risk analysis and all supporting data and documentation that lead to the decision to require this level of action. RE: Docket No. FAA-2012-0002 August 30, 2013
            2 | P a g e

            Specifically, we ask that any information, including the “multiple cylinder head-to-barrel separations and cracked and leaking aluminum cylinder heads,” referenced in the proposal as well as any accident or incident reports and Service Difficulty Reports the agency may have used as a part of its analysis be included. Our request that this data be added to the docket is supported by the Agency’s Airworthiness Directive Manual which states, “the AD docket must contain any documents that support the 14 CFR part 39 action.”

            In closing and to summarize, we are requesting that the Agency provide the supporting data and analysis used in developing this proposal and any future proposals. We are also asking that the proposal be immediately withdrawn until such time as this information is made available, or once this data and analysis is supplied, the comments period be extended an additional 120 days, to provide for full review, analysis and formulation of sustentative comments.

            Sincerely, Robert E. Hackman
            Vice President, Regulatory Affairs
            Aircraft Owners and Pilots Association
            Thomas P. Turner
            Executive Director, ABS Air Safety Foundation
            American Bonanza Society

            John M. Frank
            Executive Director
            Cessna Pilots Association

            Sean Elliott
            Vice President, Advocacy and Safety
            Experimental Aircraft Association
            John McGraw
            Director of Regulatory Affairs
            National Air Transport Association
            Michael D. Busch A&P/IA
            CEO
            Savvy Aircraft Maintenance Management, Inc.
            Robert D. Thomason
            President
            The Twin Cessna Flyer

  14. Gary Peare says:

    No its likely the engine manufacturers trying to eliminate the competition in these dieing days of aviation. What better way to lobby a government agency. I only have to look at the current Piper AD regarding the turnbuckles for the stab on pretty much every model from the 28 to the 44. Every flipping aircraft manufacturer uses a similar type. We inspect these on a regular basis. What’s next?

  15. SkipD says:

    How many mag switches and magnetos have been checked, looked at, taken apart, rebuilt, etc., only to find that they have no issues and have lot 500 more hours of life left in them, according to the logbook entries?

    How many Piper “six” seats have been checked for security- year after year after year, to just make sure that they are still attached tor the floor?

    On and on and on………… into oblivion.

  16. Steve Carter says:

    This is an excellent rebuttal and will require the FAA to do its job. Lets see where they go from here. Thanks AOPA, EAA, etc. etc. NOW………where is that 400 plus thousand that EAA paid to the FAA? Is it in an interest bearing account……wait maybe it’s in T bills lol lol! We want it back!

    The Members

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