ECI Cylinder AD Clarification

James_Dean

James_Dean

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Eggman
So, I've got an engine that has cylinders that are +1000 hrs TIS and are affected by AD2016-16-12.

http://rgl.faa.gov/Regulatory_and_Guida ... -16-12.pdf

The annual was just completed and my IA refused to sign off due to the language in 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."

I had assumed that this applied to installation of an affected engine and that since this was not the case with my aircraft I would get the 160 hours or till engine removal as specified in 2(d)(iii),

"(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 just got confirmation that a Des Moines FSDO ASI confirmed that my aircraft is grounded until new cylinders are installed.


I asked the FAA person referenced in the AD about the language and the result was worse than I had feared. Once you reach 1000hrs TIS anything that requires a log entry is enough to ground the aircraft until new jugs are installed.

Maybe I was just the dummy that missed this application and interpretation as I was following this thing, but I think many owners who thought they had some time are going to be surprised.

Eggman
 
How has this not ended up as a lawsuit is beyond me, I'd think the FAA is screwing folks over without enough data to back their claims up.
 
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I feel if this was customer electronics, there would be a massive recall campaign and ECI would pay for it plus then some. Or a car. Or anything that doesn't have wings.
 
The safety Nazis are taking over. And it has nothing to do with "protecting the public". This is government bureaucrats doing what they think necessary to protect themselves from the people.

'Course you could always think about installing a Canadian engine :rolleyes:
 
Some ADs have language in them such as "special flight permits will not be granted"
 
Maybe just maybe this was all a plan. Since in the end only one big company makes them maybe part of the acquisition deal was to request and put in place an AD to junk 40,000 or cylinders before officially buying that company, then they get to manufacture all the replacements with no competition.
 
Think about what this AD means. You could have cylinders right now with 995 hours and get signed off on an annual. Per the plain language of the AD you think you have 320 hours to comply, but that really isn't the case. Once you go over 1000 hours and want an oil change you can't get a sign off unless you pull the jugs. How many A&P's check for AD compliance prior to ANY logbook entry? Technically, if you need a tire changed your mechanic should check the SN of your cylinders or he wasn't supposed to return the aircraft to service.
 
What that AD means is, that it is "acceptable" to manufacture sub-standard parts, then admit they were a bit sh*t, and force your customers to pay for new ones...
 
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.
 
James_Dean said:
. How many A&P's check for AD compliance prior to ANY logbook entry? Technically, if you need a tire changed your mechanic should check the SN of your cylinders or he wasn't supposed to return the aircraft to service.
Click to expand...
Yep that's where we are now plus you know why there are very few A&Ps working, this and the liability of touching a POS aircraft and getting blamed for what the owner did and didn't tell you about.
 
Well if you think the ECI was bad prior, the chinese own it now, as well as TCM and Lycoming. So now there is no competition watch what prices & quality do.
 
Tom-D said:
Well if you think the ECI was bad prior, the chinese own it now, as well as TCM and Lycoming. So now there is no competition watch what prices & quality do.
Click to expand...

The Chinese do not own Lycoming. Lycoming is still owned by Textron, which is a wholly US company last I checked.

The Chinese do own TCM/ECi/Superior, plus Cirrus and a few other GA entities that I don't recall.
 
Tom-D said:
Well if you think the ECI was bad prior, the chinese own it now, as well as TCM and Lycoming. So now there is no competition watch what prices & quality do.
Click to expand...

Lycoming is owned by Textron. It is not owned by the Chinese.
 
An A&P is not required to check the status of ADs each time he touches an airplane. It is up to the owner to ensure that ADs are taken care of. Read 91.403 and Part 39.
 
Textron is a US publicly traded company. I own some stock in it.

Along with Lycoming they own Cessna, Beechcraft, Bell Helicopter and other companies. Do some research if you want to know more.
 
Ted DuPuis said:
The Chinese do not own Lycoming. Lycoming is still owned by Textron, which is a wholly US company last I checked.

The Chinese do own TCM/ECi/Superior, plus Cirrus and a few other GA entities that I don't recall.
Click to expand...
OK, they don't actually own Lycoming yet, just a large block stock.
 
James_Dean said:
So, I've got an engine that has cylinders that are +1000 hrs TIS and are affected by AD2016-16-12.

http://rgl.faa.gov/Regulatory_and_Guida ... -16-12.pdf

The annual was just completed and my IA refused to sign off due to the language in 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."Eggman
Click to expand...
(4) pretty much life limits the cylinder to 1000 hours. your's are more than that? buy new.
 
bnt83 said:
Maybe just maybe this was all a plan. Since in the end only one big company makes them maybe part of the acquisition deal was to request and put in place an AD to junk 40,000 or cylinders before officially buying that company, then they get to manufacture all the replacements with no competition.
Click to expand...
Ted DuPuis said:
The Chinese do not own Lycoming. Lycoming is still owned by Textron, which is a wholly US company last I checked.

The Chinese do own TCM/ECi/Superior, plus Cirrus and a few other GA entities that I don't recall.
Click to expand...
who owns the cylinder supplier?
 
OK, thread drift so fast it might as well be part of a hurricane. let's go back to the real issue.
1. Are the affected cylinders unsafe?
As far as I can read (without making this a full time occupation) it appears that the failure rate is far above what we can accept being that anything man made can fail. The FAA claims the failure rate is 32 times the fleet average. Others throw a 3 year old tantrum and say it is not. (liars - figures, well you know the saying)
The FAA formed a review group to look at the NPRM (after it took incoming in the public comments phase) and see if it passes the smell test. I would be a lot happier if that review group were not all FAA/DOT employees. But hey, it's an imperfect world and at some point you have to accept that most folks have not sold their souls.
So, having flown behind 520's for many thousands of hours (non currently) I will accept the premise that the FAA actually has a reasonable grounds here for the official action. (and NO, I do not buy the premise that they are in league with Satan and the Chinese)
I will accept that there is a major problem in that ECI has thickened metal at the transition point, increased the radius of the critical cut and increased the interference fit between the barrel and the head. Enough smoke there to convince me there is fire.

2. Who should pay for this?
Well, BINGO. My advice is for all affected owners to band together, simply go ahead right now and replace their affected cylinders (renting airplanes while theirs is down) and then file for class action status and sue ECI for expenses, loss of use, punitive damages, insomnia, loss of consortium, and being laughed at around the water cooler. Get a true junkyard dog for an attorney. Personally I would think maybe Jeff Feiger because this is the kind of fight he just loves. But I don't have a dog in this scrum so it is merely my opinion from the peanut gallery.
 
Checkout_my_Six said:
who owns the cylinder supplier?
Click to expand...

Were you aware that ECI & Continental Motors are the same company, since 2015ish? I'm pretty sure that no other company is manufacturing PMA replacement engine parts for most Continental engines now.

it wasn't that long ago Lycoming was interested in buying Superior but was stopped by antitrust laws IIRC.
 
Tom-D said:
OK, they don't actually own Lycoming yet, just a large block stock.
Click to expand...
No, they own Lycoming outright. There's no "block of stock." Avco and Lycoming are not traded. Lycoming was fully owned by AVCO since Cord (the car guys) formed it by moving all their aviation interests into it. While Textron blurs the history, the current Textron really is AVCO. They just thought that Textron was a snazzier name (which interestingly enough comes from the fact that Textron was originally a textile corporation called specialty yarns).
 
flyingron said:
No, they own Lycoming outright. There's no "block of stock." Avco and Lycoming are not traded. Lycoming was fully owned by AVCO since Cord (the car guys) formed it by moving all their aviation interests into it. While Textron blurs the history, the current Textron really is AVCO. They just thought that Textron was a snazzier name (which interestingly enough comes from the fact that Textron was originally a textile corporation called specialty yarns).
Click to expand...

You've got the history down right.

The Lycoming plant was originally the Demorest Sewing Machine factory. It's also now a superfund site.
 
Superior makes cylinders for 470s and 520s again. They stopped for a few years after Millenniums suffered through a series of ADs but they're in the catalog again. My own TCM 520 has Millenniums that are subject to a limited run AD. The Cub I built after that used ECI Titans, which quickly became included in a limited life AD. The guy I sold that Cub to has had a cylinder fail in flight. Head separationat <250 hours since new, just what the AD addressed. I know guys with much worse ECI failure rates on their TCMs. One friend had been through 6 sets of ECI cylinders on a first run Texas Skyways O-520 before he scrapped that engine and installed a Ly-Con overhaul. I know of another Skywagon that's ECIs passed at annual, had a rough run squalk 20 hours later, and when checked by the same reputable mechanic had four cracked cylinders. I didn't used to support the AD but my mind is changing.
 
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....
 
hindsight2020 said:
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.
Click to expand...
Silvaire said:
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....
Click to expand...

"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"
 
Good luck, I predict a lot of blown engines as a result of this "corrective" action. Continentals have a bad habit of coming apart after cylinder work.
 
flyingron said:
Good luck, I predict a lot of blown engines as a result of this "corrective" action. Continentals have a bad habit of coming apart after cylinder work.
Click to expand...

No need to worry about that. According to the FAA's own risk analysis for this AD, that never happens, because they can assume nothing ever goes wrong after doing engine work. I wish I was making this **** up.
 
I love the language to the effect of "as long as it's down anyway it's a great time to comply with the AD." Great for you in your air conditioned office, maybe. Not so great when you're an owner on a budget, took your aircraft in for minor/inexpensive MX and are now being told that your plane is grounded until you pony up 12k+...

I agree with a couple others. It's time for legal action.

On a semi-related topic, why are only the 520 cylinders affected (i.e. in my noob brain, it seems like they would've had similar issues with others like the 470).
 
Silvaire said:
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....
Click to expand...

More from Mr. Priester -


"James,


I hear what you are saying, but that is not the intent of paragraph (f) (4) in AD 2016-16-12.


Let’s take a closer look at it in the screenshot below:

Untitled.png



Item (4) really is not worded such that this return to service prohibition would only be specific to the case where someone would attempt to return an aircraft to service following an engine change.


If we had intended that, then we would have simply stated that with wording that was similar to the wording we used in subparagraphs (3) – we would have said -


“Do not install any engine that has one or more affected ECi cylinder assemblies which have in excess of 1,000 hours total TIS since new, onto any aircraft.”


But, we did not do that, because we did not intend for that statement to apply only to the isolated case of an engine change.


Our intended direction in the AD was to expeditiously remove as many of the affected cylinders that are as close to 1,000 hours total TIS as is possible to reduce the ongoing safety threat they pose to the general aviation fleet.


But, we also sought to minimize the number of airplanes that would be immediately grounded solely to perform the required cylinder change.


However, if an airplane is being removed from service anyway, for any other reason, then we want to take that opportunity to correct the unsafe condition at that time as well – if the affected cylinders already have in excess of 1,000 hours. That is the intent of (f) (4).



Also, consider that if we had intended for (f) (4) to mean what you and others interpret it to mean, then we would have used the same “return to service” language in subparagraph (f) (4) – but we did not do that.



So, again, subparagraph (4) is not isolated to the situation where someone would seek to install an engine that has affected cylinders in excess of 1,000 hours total TIS since new.


What it means is –


If you have an airplane – and if the engine (that is already installed or is intended to be installed in the special case you refer to) in that airplane – has affected cylinders – that have in excess of 1,000 hours total TIS since new – then you cannot return that airplane to service without first replacing those cylinders with airworthy cylinders.


I hope this further clarifies the wording and intent of paragraph (f) (4) in the AD.


Thanks,


Jurgen"
 
So where does the 1,160 hours TIS number come from? Why was that even put in the AD? Does Mr. Priester know so little about piston engine operations that he thinks an operator could possibly go 160 hours without doing any kind of maintenance? At a minimum, oil changes would be needed (likely at least 3 in 160 hours), and also likely a spark plug cleaning/rotation (often done at 100 hrs).
 
Jeff Oslick said:
So where does the 1,160 hours TIS number come from? Why was that even put in the AD? Does Mr. Priester know so little about piston engine operations that he thinks an operator could possibly go 160 hours without doing any kind of maintenance? At a minimum, oil changes would be needed (likely at least 3 in 160 hours), and also likely a spark plug cleaning/rotation (often done at 100 hrs).
Click to expand...

All good questions and I think from what I have learned today that AOPA, ABS, and TTCF are all working on this with FAA. Hopefully owners will at least get the extra time allotted in the AD without the onerous provision under installation.
 
Have him explain the meaning of (e)(5)(iii)


(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 see an impending revision in the not too distant future. As an A&P/IA I should not have to solicit opinions as to the meaning of any AD, it should be concise and clear. This one appears to be a complete CF
 
As usual Mike Busch had some good input on this issue with the statistics and math to back his position
 
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