FAA’s Engine & Propeller Directorate meets with GA to improve how ADs are dealt with.
Early last December, I had the privilege of attending a two-day meeting at the offices of the FAA’s Engine & Propeller Directorate (EPD) in Burlington, Mass., about 30 minutes’ drive northwest of Boston. The meeting was billed as the first “GA Engine Summit.” It was the brainchild of AOPA’s Rob Hackman and EPD’s Wayne Maguire. The purpose was to try to improve the relationship between the FAA and the GA community, a relationship that has been strained nearly to the breaking point in recent years by a series of draconian Airworthiness Directives (ADs) against Superior and ECi cylinders that I’ve referred to as the FAA’s “war on jugs.”
The meeting was attended by a litany of FAA executives and subject matter experts from EPD, the Small Airplane Directorate (SAD), and FAA Headquarters. Industry was represented by delegations from AOPA, EAA, the Aeronautical Repair Station Association (ARSA), Continental Motors, Lycoming, Superior Air Parts, Danbury Aerospace (former owners of ECi), and a number of others.
When Rob Hackman left AOPA last June, his successor Dave Oord (AOPA VP of regulatory affairs) picked up the ball, and it was Dave who invited me to the meeting to brief the attendees on the current state-of-the-art of piston engine digital engine monitor equipment and engine monitor data analysis.
Why do piston engines fail?
EPD’s resident analyst James Gray gave a briefing on engine-caused accidents in piston GA airplanes. It turns out that loss of engine power is the #3 cause of GA fatal accidents (according to a study by the General Aviation Joint Steering Committee), right after loss-of-control (LOC) and controlled flight into terrain (CFIT).
Gray analyzed 282 NTSB accident reports of GA airplanes attributed to power loss. Of those, roughly two-thirds involved causes that could be determined by investigators. About 15% of them involved fatalities. Three-quarters of them involved Lycoming and Continental engines, with the remaining one-quarter involving Rotax and 52 other engine manufacturers.
As you might expect, pilot error was cited in more than half of these power-loss accidents—things like fuel starvation and fuel exhaustion and improper operation. But you might be surprised to learn that of the non-pilot-caused engine failures, improper maintenance was the principal culprit by a wide margin. Most of these maintenance-induced engine failures were caused by errors during assembly, installation and repair work (mostly involving cylinder replacement), although a significant number involved mistakes during engine overhaul.
System-wise, the leading cause of engine failures turned out to be the fuel system, with cylinders coming in a very close second. Most of the fuel system problems involved either fuel starvation or fuel contamination (both typically pilot-caused), while the cylinder problems were mainly maintenance-related. Failures due to improper manufacture or faulty components were insignificant by comparison. The main takeaway here is that if you’re involved in a power-loss accident, chances are it’ll either be your fault (for mismanaging fuel) or your mechanic’s fault (for bungling a cylinder change).
As we reviewed these findings at the summit meeting and discussed what might be done to reduce the incidence of these pilot- and mechanic-caused engine failures, something became painfully obvious: None of the FAA folks responsible for oversight of pilots or mechanics were in the room! Those folks work for the FAA’s Flight Standards Service (AFS), while both EPD and SAD belong to the Aircraft Certification Service (AIR).
Here’s the problem: When a GA airplane falls out of the sky and a mechanical issue is suspected, it’s the responsibility of AIR to determine whether an unsafe condition exists and, if so, do something about it. If it’s an engine or propeller issue, that task falls to the Engine & Propeller Directorate near Boston; otherwise, it falls to the Small Airplane Directorate in Kansas City. But these Directorates have no ability to influence what pilots or mechanics do; that’s the responsibility of Flight Standards. What the Directorates have the ability to do is to issue Airworthiness Directives.
Consequently, I couldn’t help but wonder whether the FAA’s organizational structure results in a bias toward issuing ADs rather than addressing problems at their source, which most of the time (according to the FAA’s own analysis) seems to be “stupid pilot tricks” and “stupid mechanic tricks.”
In fairness, the FAA does have some folks who serve as liaisons between AIR and AFS, and at least one of them was in the room. But before the engine summit was over, I think everybody in the room (FAA and industry alike) were convinced of the urgent need for a “maintenance summit” hosted by AFS-300, the Maintenance Division of Flight Standards. I hope AOPA and other industry groups can help make this happen.
Reorganizing the FAA was obviously beyond the scope of this summit meeting. But we did achieve something that I think might be at least a minor breakthrough in the way piston engine-related ADs will be dealt with going forward.
A little history: In 1999, the FAA issued a proposed AD against the exhaust systems of turbocharged twin Cessnas. Had the AD been issued as proposed, it would have been catastrophic for the owners of these aircraft. The fleet would have been grounded indefinitely and the resale value of the airplanes would have dropped to near-zero. AOPA, Cessna Pilots Association, and some other industry groups fought hard to oppose this NPRM, and I was right in the middle of the fight. Ultimately, sanity prevailed and a far more reasonable AD came to pass, but not before a lot of feathers were ruffled and blood was shed on both sides of the conflict.
Because the exhaust systems on these twin Cessnas were technically airframe parts rather than engine parts, responsibility for the AD fell to the Small Airplane Directorate (SAD) rather than the Engine & Propeller Directorate (EPD). Once the AD was a done deal, industry groups met with SAD leadership to discuss how future AD actions could be handled without so much stress, turmoil and bloodshed. What came out of that meeting was a new SAD protocol known as the “Airworthiness Concern Sheet” (ACS) process whereby SAD agreed to notify AOPA, EAA, type clubs, and other relevant industry representatives (by sending them an ACS) before issuing a proposed AD, and soliciting their input before rulemaking begins and rigid ex parte communications rules kick in that make it all but impossible for FAA and industry folks to discuss the matter. In essence, the Airworthiness Concern Sheet is the FAA’s way to tell industry that “we’re thinking about issuing an AD, but before we do we’d like your input.”
Over the past 15 years, this ACS process has been very effective in helping to prevent the FAA from issuing proposed ADs that are unreasonable or impractical. But here’s the rub: The ACS is strictly the brainchild of the Small Airplane Directorate, and has not been used by other AIR Directorates (including the Engine & Propeller Directorate). So sadly, it was not employed in—and therefore could not mitigate—the FAA’s recent “War on Jugs.”
As a result of the engine summit meeting, this appears likely to change. Industry reps make a strong appeal at the meeting for EPD to adopt the ACS process before proposing ADs against piston aircraft engines, and EPD agreed to do so. While this won’t affect ADs that have been issued (like the one affecting Superior Millennium cylinders) or are already in the pipeline (like the one against ECi cylinders), it should be of great help going forward. I think that’s real progress.
Another interesting subject discussed at the engine summit was AMOCs. “AMOC” is FAA-speak for “Alternative Method of Compliance.” If you read the fine print of virtually any Airworthiness Directive, you’ll find a sentence that says something like this:
An alternative method of compliance that provides an acceptable level of safety may be approved by the Manager, [Wherever] Aircraft Certification Office.
Historically, an AMOC is a special, negotiated “deal” between an aircraft operator and the FAA Aircraft Certification Office (ACO) responsible for an AD, in which the ACO agrees to allow the operator to comply with the intent of an AD using a different method and/or timetable than what is set forth in the AD. According to FAA Order 8110.103A, an operator may find it desirable to request an AMOC if he (1) devises a better way to address the unsafe condition, (2) wants to accomplish AD actions in a way that better suits his operational needs, or (3) wants to adjust the compliance time of an AD. The operator requests such an AMOC from the FAA ACO responsible for the AD, and the ACO will approve the AMOC if it is persuaded that it addresses the unsafe condition that prompted the AD in a fashion that the ACO believes will provide an acceptable level of safety. The airlines make extensive use of such AMOCs to make compliance with ADs affecting their fleet less burdensome and more convenient, and the FAA has historically been quite cooperative in approving such AMOCs.
At the summit meeting, several FAA folks opined that GA was “underutilizing” the AMOC process. There’s a good reason for this. Unlike the airlines, very few GA operators have the engineering or regulatory expertise to draft a persuasive AMOC proposal and assemble the requisite data and analysis to convince the FAA that the alternative being proposed would provide “an acceptable level of safety.” Consequently, most GA operators find themselves with no practical choice but to comply with ADs as written, even if those ADs are extremely burdensome.
In 2014, however, there was an encouraging development: AOPA and Superior Air Parts sought and obtained approval of an AMOC to provide relief for operators who would otherwise been forced by AD 2014-05-29 to retire their Superior Millennium cylinders after 12 years in service. An AMOC allowing affected cylinders to remain in service for an additional five years (to age 17) was approved by the Ft. Worth ACO. It saved affected owners millions of dollars and thousands of hours of downtime. Unlike most AMOCs that are applicable to only a single operator, the Superior cylinder AMOC was a “Global AMOC” that can be utilized by any operator affected by the AD.
I am encouraged by the FAA’s willingness to approve the Global AMOC for Superior cylinders, and by its words of encouragement at the engine summit for the GA community to use the AMOC mechanism more often. Together with EPD’s agreement to adopt the Airworthiness Concern Sheet process, I feel hopeful that the future will being greater cooperation and less conflict between the FAA and the GA community with respect to engine-related ADs.
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