Good God, what a mess. I guess it's par for the course, considering the FAA removed "promotion of aviation" out of its charter. This seems in line with that platitude, symbolic as it was to remove it in the first place anyways.
I'm no fan of Conti engines, but it's contemptible to make the customer eat the socialized loss on this recall. What kind of damage are we talking for topping these engines with OEM replacement? 10-12AMU plus labor? I'd prob walk away from this avocation in principle if that happened to me.
Back to the AD and the OP's question. Like many, this AD is not particularly well written but clearly, item 2.(f) concerns INSTALLATION PROHIBITIONS and does NOT apply to an annual inspection, or any other unrelated maintenance or logbook entry. It says - do not return to service any aircraft into which you (or someone else) have INSTALLED an engine with an affected cylinder that has more than 1000 hrs TIS.
The OP is correct, despite what anyone is telling him, he has up to 1,160 or time of overhaul.
This AD is similar to the Lycoming crankshaft fiasco. They are basically saying that these cylinders "might" be dangerous, might even kill you, but it's perfectly okay to fly around with them for 1200 hours - which could be ten years or more for a lot of people. Is it just a classic blanket CYA move to get all of them out of the sky? So yea, you gotta wonder....
"The intent of the AD is that if an airplane that has affected non-overhauled cylinders that already have in excess of 1,000 hours total TIS (since new) is removed from service for any reason, such as to do maintenance ( including any that is not related to this cylinder issue) or to perform inspections of any kind (including annuals, etc.), then those cylinders must also be removed and replaced with airworthy cylinders prior to returning that aircraft to service. So, (f) (4) goes into effect under those circumstances."
The "anyone" is both an ASI as the Des Moines FSDO and Jurgen Priester who is the contact person at FAA listed on the AD. Here is my email string with him. Short of a clarification by the chief counsel, this interpretation means that once you pass 1000 hrs TIS you can not have the plane returned to service(any logbook sign off) without changing the jugs. I shared your view on this, but now have an AOG dictated by the local FSDO until I get the cylinders replaced.
"From: Jurgen.E.Priester@faa.gov [
mailto:Jurgen.E.Priester@faa.gov]
Sent: Wednesday, October 05, 2016 4:06 PM
To: JT Dean
Cc: Jurgen.E.Priester@faa.gov
Subject: RE: AD2016-16-12
True
From: JT Dean [
mailto:jtdean@versova.com]
Sent: Wednesday, October 05, 2016 3:40 PM
To: Priester, Jurgen E (FAA)
Subject: RE: AD2016-16-12
Just for clarification – If I had cylinders with 999 hrs TIS on 9/15/16, flew for an hour and asked my A&P to change my oil, the plane would be grounded until new cylinders were installed?
From: Jurgen.E.Priester@faa.gov [
mailto:Jurgen.E.Priester@faa.gov]
Sent: Wednesday, October 05, 2016 1:56 PM
To: JT Dean
Cc: Jurgen.E.Priester@faa.gov
Subject: RE: AD2016-16-12
Has anyone provided you with a different interpretation of that AD statement (f) (4), or were you just interpreting that yourself?
Please let me know either way, in case I need to clarify it to others as well.
Thanks
From: JT Dean [
mailto:jtdean@.com]
Sent: Wednesday, October 05, 2016 1:50 PM
To: Priester, Jurgen E (FAA)
Subject: RE: AD2016-16-12
I very much appreciate your timely response and clarification. In my specific case, I own two airplanes and the affected airplane is more of a pleasure craft that sees approximately 100 hours per year. In my original interpretation I had assumed that I would be able to make it until the next annual and defer a $12,000+ cost for an additional year. Of course if I had been better informed I would’ve scheduled my annual to be completed eight days sooner than it was and would’ve gotten that extra year of time and be in compliance with the AD. Live and learn.
Thanks again for your time,
James T. Dean
From: Jurgen.E.Priester@faa.gov [
mailto:Jurgen.E.Priester@faa.gov]
Sent: Wednesday, October 05, 2016 1:42 PM
To: JT Dean
Cc: Jurgen.E.Priester@faa.gov
Subject: RE: AD2016-16-12
Dear Mr. Dean,
The intent of the AD is that if an airplane that has affected non-overhauled cylinders that already have in excess of 1,000 hours total TIS (since new) is removed from service for any reason, such as to do maintenance ( including any that is not related to this cylinder issue) or to perform inspections of any kind (including annuals, etc.), then those cylinders must also be removed and replaced with airworthy cylinders prior to returning that aircraft to service. So, (f) (4) goes into effect under those circumstances.
The reason we wrote the AD that way was to minimize the number of airplanes that would be immediately grounded just due to the cylinder problem. However, our intent is that if the airplane is going to be grounded anyway for any other reason, then we see that also as a timely opportunity to correct this unsafe condition before further flight.
I hope this answers your question – please let me know if it does – or does not.
Thanks,
Jurgen
From: JT Dean [
mailto:jtdean@.com]
Sent: Wednesday, October 05, 2016 1:31 PM
To: Priester, Jurgen E (FAA)
Subject: AD2016-16-12
Mr. Priester,
I have an IO-520 with ECI cylinders in the range of AD2016-16-12 and have a clarification. For an engine with non-overhauled cylinders that accumulated more than 1000 hours time in service and has been continuously installed on an airframe, I am seeking to know which language in the AD is controlling in the case of an annual signed off on after the effective date of the AD of 9/15/16.
2(f)(4)?
"(4) Do not return to service any aircraft that has an engine installed with an ECi cylinder assembly subject to this AD, if the cylinder assembly has 1,000 or more operating hours TIS."
Or, 2(d)(iii)?
"For any affected cylinder assembly with more than 1,000 operating hours TIS since new on the effective date of this AD, remove the cylinder assembly from service within the next 160 operating hours or at next engine overhaul, whichever occurs first."
I had assumed that 2(f)(4) was applicable to an engine being newly installed to an airframe after the effective date of the AD and not intended to require removal of cylinders that had not yet accrued the 160 hours allowed in 2(d)(iii).
Can you help with some timely clarification please? The aircraft is currently grounded pending resolution.
Thanks in advance for your time and assistance,
James T. Dean"