The owner of the late-model Cessna T206 Turbo Stationair was livid.
“Imagine your car is equipped with a Takata airbag system whose faulty inflators often rupture and spray shrapnel into drivers and passengers, resulting in at least 11 deaths in the U.S. and hundreds of injuries,” his email to me began. “But instead of being recalled by the manufacturer, you were instructed by the government that to continue driving your car legally, you were required to take it to a mechanic every 500 miles for a costly inspection at your expense. If your airbag system didn’t pass the inspection, you would be required to pay about $1,200 for a new airbag inflator, again at your expense.”
The Stationair owner was reacting to a just-issued Airworthiness Directive against the exhaust system of his Lycoming TIO-540-AJ1A engine. There are 758 of these engines currently in service. AD 2017-11-10 was apparently prompted by reports of exhaust leaks that could result in excessive carbon monoxide (CO) getting into the cabin. Some of these leaks were caused by cylinder exhaust port studs coming loose, while others were caused by cracked exhaust pipe weld joints.
The AD requires an initial exhaust system inspection and fastener torque check within 10 hours, and then repetitive exhaust system inspections every 25 hours and torque checks every 100 hours. The FAA estimated the cost of compliance to be $85 (one hour of labor) per required inspection, but that doesn’t take into account the burden on the owner of having to take his airplane to an A&P mechanic every 25 hours (which is half the normal oil-change interval).
Lycoming issued a service bulletin which allowed the repetitive inspection interval to be extended from 25 to 50 hours if the aircraft was equipped with a carbon monoxide detector, but inexplicably the AD does not include this provision. Lycoming presently doesn’t have a fix for this problem (although they claim they’re working on one), so there’s no way of knowing how long the owners of the 758 affected Lycoming TIO-540-AJ1A engines will be required to do these 25-hour exhaust inspections.
“Why do aircraft owners put up with this?” the Stationair owner continued. “For decades, Cessna and Lycoming have been building the same product, and they still can’t get it right. Why? Because they have no incentive to do so. If they make a design or manufacturing mistake, they just pass the costs on to their customers. Nice scam.”
I felt the owner’s pain. I fly a Cessna 310 with a cabin heater made by Stewart-Warner (Southwind), and was just hit with an AD against my heater that will force me to replace it with a new AD-free heater at my upcoming annual in October, at a cost of $6,000 in parts and probably $2,000 in labor. And as I discussed in my last blog post, the FAA is threatening to issue an AD against the camshaft gears in my two Continental TSIO-520-BB engines (and tens of thousands of other engines) that could cost owners like me a bundle.
It’s gotten so bad that when a colleague of mine recently told me he was looking to buy an airplane and was thinking about an older Mooney, I suggested he look into buying an amateur-built experimental airplane instead in order to get out from under the AD burden that has been plaguing us owners of certified airplanes.
It’s different for cars
The Stationair owner was right to point out that the rules are very different for motorists than they are for aircraft owners. In 1966, Congress passed The National Traffic and Motor Vehicle Safety Act (49 USC 301) that gave the Department of Transportation’s National Highway Traffic Safety Administration (NHTSA) the authority to issue vehicle safety standards and to require manufacturers to recall vehicles that have safety-related defects or do not meet Federal safety standards.
Effectively, these NHTSA motor vehicle recalls are the automotive equivalent of Airworthiness Directives. But there’s a big difference: In most cases, the auto manufacturers are required by law to bear the cost of fixing the vehicles. The burden usually doesn’t fall on the vehicle owners.
Why isn’t there a similar law for aircraft? I’m guessing that there are just not enough folks in Congress who care about aircraft owners to support such legislation. By contrast, every member of Congress is a motorist, so the laws are spring-loaded in favor of protecting motorists. But even if the laws protecting motorists were extended to aircraft owners, the lion’s share of the AD burden wouldn’t go away.
Why? Well, for one thing, 49 USC 301 requires automobile manufacturers to bear the expense of recalls only for vehicles that are less than 10 years old. While this covers most cars that are recalled, the overwhelming majority of today’s GA fleet consists of airplanes that are more than 10 years old, frequently much more.
The lion’s share of piston GA aircraft were built in the 1960s and 1970s, and then production all but stopped in the 1980s and never came close to recovering to the levels seen in the salad days of piston GA. (My 1979 Cessna 310 is 38 years old, and it’s a “recent model” as Cessna 310s go.) So for most GA airplanes, the manufacturer would be off the hook.
In addition, the law only requires the manufacturer to pay for repair of recalled vehicles if those repairs are performed by an authorized dealer of the manufacturer. Relatively few GA owners have their maintenance performed at authorized dealers, and many makes of GA aircraft no longer have dealers; indeed, many were manufactured by companies that aren’t in business anymore. In general, GA has a far less robust support system compared to automobiles.
Changes I’d really like to see
The laws I’d most like to see extended to GA are the ones that deal with repair facilities. Automotive repair facilities are typically regulated by the states, not by the feds. Most states require automotive repair facilities to be licensed, and have lots of state laws protecting motorists from unscrupulous repair shops. In most cases, an automotive repair shop cannot work on your car until they’ve given you a written work order itemizing the work they will do and providing a cost estimate (including parts, labor, and outside work), and obtained your signature approving the work order and estimate. Then they are required not to charge you significantly more than the agreed-to estimate.
In the event that the shop runs into something that might result in exceeding the original estimate, they are required to stop work, furnish you with an explanation and a revised estimate, and secure your approval of the new estimate before they may continue. These rules ensure that there will never be any surprises when you receive the final invoice.
To comply with these rules, most auto repair shops use a flat-rate price list for all the most common maintenance tasks they perform. You’ll typically pay the same price for, say, an oil change or a brake job or a tire rotation regardless of how much time the technician spent doing the work.
By contrast, most maintenance work on airplanes is done on a time-and-materials basis, often with no paperwork until the job is done. Sticker shock is rampant as a result, because often the owner doesn’t have a clue what the work will cost until it’s done. This is a bad system, and often results in hard feelings and arguments when owners feel they’ve been charged too much.
I’d love to see the state laws that govern auto repair extended so that they cover aircraft maintenance shops as well, but I’m not holding my breath. Few state legislators give a fig about aircraft owners. In the meantime, it’s up to the owner to demand a written estimate before permitting any shop to work on their aircraft, and to hold the shop to that estimate unless there’s an awfully good reason that it was exceeded.
Not long after this blog post was published by AOPA, I received a phone call from Lycoming and learned that there is some good news and some light at the end of the tunnel for owners of TIO-540-AJ1A-powered Cessna T206s affected by AD 2017-11-10.
First, Lycoming requested and the FAA approved an Alternative Means of Compliance (AMOC) that extends the exhaust inspection interval from 25 hours to 50 hours for aircraft that are equipped with a suitably sensitive carbon monoxide (CO) detector. That will halve the inspection burden and promote CO detector installation, both of which are good things.
I also learned that Lycoming has redesigned the TIO-540-AJ1A exhaust system in order to provide a permanent solution to the problem and a terminating action for the AD. The new exhaust system will be made of 321 stainless steel, in contrast with the Inconel used in the current system. Inconel has outstanding high-temperature characteristics, but it is much more brittle and harder to work with than 321 stainless, and has a much less desirable failure mode. Lycoming concluded that the Inconel system was not sufficiently flexible to deal with the dimensional changes and thermal stresses that occur as the exhaust system heats up and cools down. Most other turbocharged Lycoming engines used a stainless steel exhaust system, and Lycoming believes the new system will prove much more durable and less failure-prone than the current one.
No word yet on when production quantities of the new exhaust parts will be available or what they will cost. But it does look like the repetitive inspections mandated by AD 2017-11-10 won’t have to go on forever. –MDB