Letter To The Agency Asks For Withdrawal Of AD

Seven general aviation organizations are asking the FAA to withdraw a proposed airworthiness directive affecting ECi cylinders used as aftermarket replacements on thousands of Continental Motors 520 and 550 engines until the GA community receives the information and time needed to respond.

A letter dated Aug. 30 asks the FAA to withdraw its notice of proposed rulemaking (NPRM) and provide the data and analysis justifying the proposed airworthiness directive (AD). Alternatively, the letter asks the FAA to provide the information and then give pilots and industry an additional 120 days to respond.

In the letter, the associations say that while they share the Agency’s concern for the safety of General Aviation, without the Agency providing supporting data used in drafting this proposal, they 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," the letter states.

"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.

"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 We are also asking that the proposal be immediately withdrawn until such time as this information is made available, or once this data and analysis is supplied, the comments period be extended an additional 120 days, to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."

FMI: http://eci.aero/pages/nprm-AEC631397-cylinders.aspx