AOPA Pilot Magazine - December 2017 - 96

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SAVVY MAINTENANCE

special airworthiness information bulletin, et cetera). In the case of an AD, the
FAA then issues a notice of proposed rulemaking and addresses public comments,
then issues a final rule.
This process has worked well for air
carriers, but not as well for GA. In the world
of GA, event reporting is far less complete
and accurate, making numerical risk analysis more difficult. GA operators are much
more cost-sensitive, so the risk-versus-cost
evaluation can be challenging. The FAA has
historically had good communications with
the aircraft and engine manufacturers, but
less so with the people most affected: aircraft owners and operators. Unlike the
airlines, few GA operators have engineering staffs or individualized maintenance
programs, so most of us are reliant on recommendations from the aircraft and engine
manufacturers, whose best interests are
often different from ours.
In order to help the FAA gather needed
data for GA aircraft, and to help give GA
owners/operators a voice in the continued operational safety process, in 2001 we
worked with the Small Airplane Directorate
to create a new airworthiness concern
sheet (ACS) process. The ACS was designed
to provide an early heads-up to AOPA, EAA,
and relevant GA type associations whenever the FAA identified a potential unsafe
condition. The ACS solicited event data
from these groups, and gave them an opportunity to weigh in on the FAA's concerns
before formal rulemaking action kicked in.
Originally, the ACS process was limited to
the Small Airplane Directorate, but in 2015
the Engine and Propeller Directorate also
agreed to use the ACS process when it was
considering an AD that would affect GA.
In the past year, the ACS process was
extremely helpful in allowing GA to weigh
in on a threatened AD on Continental
520/550 camshaft gears that would have
been extremely costly to tens of thousands
of GA owners (see "Savvy Maintenance:
Crisis Averted," October 2017 AOPA Pilot).
Unfortunately, the FAA decided not to
issue an ACS before issuing the recent AD
against Lycoming connecting rod bushings and denied GA owner representatives
any meaningful input into the continued
operational safety process. At the meeting,

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96 | AOPA PILOT December 2017

several of us were vocal in expressing our
extreme displeasure at how the Lycoming
AD was handled, and asked that the FAA
try not to let this kind of thing happen in
the future.
We also discussed AMOCs: alternative
methods of compliance with ADs. If an
operator doesn't like the corrective action
mandated by an AD and thinks there's a better way to address the unsafe condition,
the operator can propose an AMOC, and
the FAA will approve it if the operator can
show that the proposed AMOC achieves a
level of safety acceptable to the FAA. The
airlines use this approach all the time, but
GA doesn't use it much, mostly because
few GA operators have the engineering
capability to create an acceptable AMOC
proposal. At the 2015 Engine Summit, the
FAA urged the various GA alphabet groups
who attended to make better use of the
AMOC mechanism.
In 2016, the FAA issued a draconian
AD against ECi cylinders on Continental
engines. AOPA, in partnership with several affected type associations, prepared a
proposed AMOC to allow the condemned
ECi cylinders to remain in service to TBO
under certain controlled conditions. The
FAA rejected the AMOC proposal on the
grounds that it had not provided sufficient data to prove that it would achieve
an acceptable level of safety. This subject
was discussed at length at the meeting. We
complained that the FAA had acted unreasonably by requiring operators to "prove
the unprovable." The FAA said their intent
was not to shoot down our AMOC but to
invite further discussions. Of course, by
now the subject is moot because virtually
all the affected ECi cylinders have been
removed from service. Representatives of
the owners and the FAA agreed to try to do
better next time.
All in all, the summit was a productive
meeting. Everyone agreed we should try
to have such meetings annually, and the
next one is tentatively set for September
2018.
AOPA
MIKE BUSCH is an A&P/IA.
EMAIL mike.busch@savvyaviator.com

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AOPA Pilot Magazine - December 2017

Table of Contents for the Digital Edition of AOPA Pilot Magazine - December 2017
