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Rolls Royce TSIO-360
Hi guys, I have a major paperwork problem with my newly acquired T337G. The front engine is a Rolls Royce TSIO-360-D. I was told that this was licensed by Continental and made by RR.
Now, according to Continental, they do not hold the type certificate for the Rolls Royce TSIO-360 and thus cannot determine equivalency. So even though this engine has been installed and working for decades, Transport Canada says it needs to be replaced. Do you guys have any information about the certification of these engines when they were installed? Based on a search of this forum it seems there are at least a few other P337's out there with the RR engines. Thanks, DD |
My understanding the RR motors were all installed in the French Reims built Skymasters, which were built under license from Cessna. How one ended up in Canada is a mystery!
If you have to replace it, I'll be happy to take it off your hands. :p Does the RR version have its own service manual, or does it use the standard Continental manuals? Someone with half a brain at CAA should be able to figure this out. |
I have the RR engines and paperwork
I have the RR engines in my P model 1973...
I’ll look through my logs to see how they did it and report back. It’s been awhile since I looked at how they did it for 58C. Hopefully I have something that will help you. Steven |
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Thanks Dan |
Engines
Dan - FWIW, I think you need to have it in writing from them why they will not accept the engine. Check what your IPC says for P/N, then compare with the P/N on the engine. I know with my 337A it calls for an IO-360C, and that is the P/N on the motor. I would also call Cessna next - they may have a Service Letter or SB that allows for this engine (RR) on the aircraft. Don't remove based on some Transport Canada Weeny (I can call them that cause both my brothers are Transport Canada Weenies and they call themselves that!).
Don't worry about Continental - the TC holder of the airframe (Textron/Cessna) is the one you need to coordinate with. Jeff |
This not a new issue unfortunately. In the 70's a number of RR TSIO 360 engines were installed on T337G's (P337's) by various entities (engine shops, MRO's etc.). In a number of cases, the FAA became aware and forced the removal of the RR engines as they were never certified in the US in the first place.
I owned N78C a while back and the log books contained several entries including paperwork from the FAA forcing the removal of the RR engines shortly after installation. The FAA had been notified by a shop doing maintenance on the airplane... It would be interesting to find out how some owners overcame that hurdle. |
Register it in France? Find a French aviation atty.
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Status update: no real progress yet.
Continental has been worse than helpful. They basically sabotaged me by denying any knowledge of RR tsio-360’s even though there’s multiple service bulletins from the era. I’m waiting to receive the records from the FAA. I may pursue a limited stc. I may need to buy a whole new engine and I won’t even get core credit for this. DD |
Would overhaul (not by continental) “zero” this out? If so maybe you can find reasonable overhaul shop.
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It might not be airworthy due to the VAR crankshaft AD that hit all the old TCM 360 models.
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From the FAA. " One commenter states that the AD should be withdrawn, since the FAA
has not substantiated the inclusion of the Rolls-Royce, plc engines which are not US type certificated. The FAA does not concur. The FAA stated in the second SNPRM that the Rolls-Royce, plc engines are identical in design and manufacturing process, which substantiates their inclusion. It is true that there is no US type certificate for these engines; however, these engines are accepted for use on US type certificated airplanes, and several are installed on US registered aircraft. Therefore, TCM service information and FAA ADs apply to these engines." |
I believe Mr. Coffman has hit the nail on the head! The FAA's response to the AD comment clearly states that RR IO-360's are flying on FAA-certified aircraft, and with the FAA's implied blessing!
If I'm reading the tea leaves correctly, the issue the FAA has is NOT that the engines are RR, but that they have not had the VAR crank AD applied? So it would follow logically that if a RR IO-360 had the VAR crank AD complied (and any other that is applicable), it would be acceptable to the Administrator??? |
VAR crank issue doesn’t apply unless the case halves are opened.
The way I read it, basically same rules apply to the RR engines as domestic continentals. Also interesting sentence “accepted for use on US type certificated airplanes”. Question would be if you can twist that into FAA acknowledgment of treatment of them same as others gets you over the hump. And transfer that over to CAA. How about a call to AOPA legal services? |
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So the FAA is saying that for regulatory purposes, a RR IO360 is the same as a Cont IO360, that they us the same manufacturing methods, maintenance manuals, SBs, parts manuals, etc. If the FAA claims they have regulatory authority over the RR IO360's, and insists they must comply with the ADs for the Cont IO360, how can they then turn around and say one engine may not be swapped for another in a USA certified aircraft? It makes no sense. By claiming the authority over the engine, they've just defacto approved it, as long as all ADs are complied with. Am I missing anything? |
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If you find you need some friendly FAA airworthiness peeps to talk to, PM me, I might be able to help. -LJ |
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DD:
Attached is the Aircraft Condition Notice issued by the DEN FSDO back in 1989 for N78C. The logs show that in the end, the owner at the time elected to replace the engines with Continental TSIO 360's. The records that I have also show that the owner at the time engaged in legal action against the provider/dealer for the engines. From what I can see, the record is inconclusive and I am not sure that any compensation was paid. PM me if you are interested and I will be more than happy to mail you all of this. It may be of assistance, or it may not. Richard |
Quote "Attached is the Aircraft Condition Notice issued by the DEN FSDO back in 1989 for N78C"
Approval was by CCA only - Canada Civil Aviation |
Frank:
The certification authority for the RR engines was the CAA (Civil Aviation Authority) from the UK. Richard |
Register it in Canada - Problem solved. :p
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DD |
can you just leave it registered in the US? Plenty of aircraft are registered owned by "holding companies" not necessarily geographically located where you, the individual, is at.
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The FAA CLEARLY stated in the VAR crank AD comment response section that US-certified AC were currently flying with the UK-certified RR engine, AND THEREFORE the AD must apply to them as well. So if I understand this, the FAA will allow RR engines (at least theoretically based on their own commentary), but CAA will not??? So maybe maintain the N# registration? There are literally thousands of aircraft around the world that will never see US airspace yet proudly sport N# registration. Seems crazy that the CAA won't accept RR certification from the UK, which is their controlling country. What they are are saying is because your plane was not built in France, it may not have a RR engine, even though both the airframe and engines were certified as identical. An interesting thing to research: Do they allow Continental engines on Reims aircraft??? My guess is they might. This whole sorry saga is the definition of bureaucratic madness and ineffiency. The RR engines should be looked at as equivalent to the Continentals, and that should be that. |
DD:
Looking through the paperwork that I have from 78C, it appears that there is a way to actually certify the RR TSIO 360's for use on US registered aircraft. On 9-18-1989, Continental issued a Service Bulletin (M89-20) titled Conversion of Rolls Royce Engines. The SB describes how the RR nameplates can be replaced by Continental nameplates. While the Bulletin was rescinded on 12-15-1989 due to FAA objections outlined in a letter signed by the Manager of the Engine Directorate New England Region, the issue was brought to the attention of FAA national shortly thereafter. On July 6 1990, the FAA (AIR-1 Director of Aircraft Certification) issued an Action Notice (A8110.21) titled Acceptance Procedures for Rolls Royce/Continental Model TSIO 360 Series Engines. The AN explains how the engines can be approved on an engine by engine basis: provide the initial UK CAA Approved Certification/Dispatch Instruction" which was issued with each new engine and then have the engine inspected by an IA or a Repair Station which can then sign the installation off. Overall, there were 40 RR engines imported into the US. So the AN provides a path of a RR engine to be approved in the US. That still leaves Canada. The US and Transport Canada have reciprocal certification agreements in place and a particular engine approved by the US FAA should be allowed by Transport Canada on the basis of reciprocity. Hopefully this is helpful. I am happy to provide copies of that documentation if interested. Richard |
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The Type Certificates for most of the Reims-produced Cessna aircraft were transferred to Cessna in 2006. This allowed owners of Reims Cessnas to register their aircraft on the U.S. N-number registry with minimal difficulty. In the eyes of the FAA, Reims Cessnas are “considered domestic products for the purpose of design certification and continued airworthiness” per Type Certificate A23EU.
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However, this avenue may have already been tried by people working on my behalf. There have been nuances in the logistics/paperwork that have killed every possible lead so far. Thanks, DD |
Guys,
Be sure not to show them a copy of Type Certificate Data Sheet A23EU that I posted links to a couple of messages ago, or they might go, "Oh No problem here. Have a nice day." Then you would have to find another dead horse to beat. |
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DD |
That explains a lot. Have a nice day.
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DD:
The TCDS lists the parameters and equipment for a type certification. I have attached the top part of the TCDS for the French built 337's. This does not help. The TCDS for the FT337GP lists the Continental TSIO 360C. See the second attachment. In fact, no French built 337 was equipped with the RR engines when they came out. They were equipped with Continental engines. All Reims did was assemble kits supplied by Cessna under the Cessna TCDS which has always listed the Continental engines. Richard |
"In fact, no French built 337 was equipped with the RR engines when they came out. They were equipped with Continental engines. (BUILT IN ENGLAND BY ROLLS ROYCE) All Reims did was assemble kits supplied by Cessna under the Cessna TCDS which has always listed the Continental engines."
Ed |
Many thanks to rrolland! The documentation he was able to send me was accepted by Transport Canada and the engine has been accepted. The FAA action notice previously mentioned was the key document.
I've very glad this has been resolved! dd |
Dr. Dan, that's GREAT news, ... congratulations!
rrolland, ... excellent assistance! Rick |
I love a happy ending! :D
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Really glad the material was useful and that you are back in the air!
Richard |
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