FAA 2020 0894 0008 - Attachment - 1

Reference: 20-3835
Textron Aviation Comments - Special Conditions: magniX USA, Inc., magni250 and magni500 Model Engines
Comment #1
Affected Section: Proposed Special Condition 2
Current Text Proposed Text Comment/Justification
In addition to § 33.7(a), the design In addition to § 33.7(a), the design If there are material or component temperature limitations in
must comply with the following: Ratings and must comply with the following: Ratings and the engine these should be considered as part of proposed
operating limitations operating limitations special condition 2(a) for establishing limits as well as power,
must be established and included in the must be established and included in the torque and speed.
type certificate data sheet based on: type certificate data sheet based on:
(a) Power, torque, speed, and time for: (a) Power, torque, speed, temperature and time for:
(1) Rated maximum continuous (1) Rated maximum continuous
power; and power; and
(2) Rated maximum temporary power (2) Rated maximum temporary power
and associated time limit. and associated time limit.
(b) The duty cycle and the rating at
that duty cycle. The manufacturer must
declare the duty cycle or cycles in the
engine certificate data sheet.
Engine Ratings and Operating Limits Engine Ratings and Operating Limits The term speed can be misleading and thought to be referred
In addition to § 33.7(a), the design In addition to § 33.7(a), the design to as aircraft speed but us should be specific to the engine
must comply with the following: must comply with the following: RPM and depending could be shaft speed after a gearbox or
Ratings and operating limitations Ratings and operating limitations the main engine rotor RPM, specifics need to be made to
must be established and included in the must be established and included in the eliminate confusion.
(a) Power, torque, speed, and time for: (a) Power, torque, RPM speed, and time for:
(b) The duty cycle and the rating at (b) The duty cycle and the rating at
that duty cycle. The manufacturer must that duty cycle. The manufacturer must
declare the duty cycle or cycles in the declare the duty cycle or cycles in the
engine certificate data sheet. engine certificate data sheet.
Page 1 of 11
In addition to § 33.7(a), the design In addition to § 33.7(a), the design While takeoff power could be considered a maximum
must comply with the following: Ratings and must comply with the following: Ratings and temporary power, we believe specific takeoff power ratings
operating limitations operating limitations should be established in addition to maximum continuous and
must be established and included in the must be established and included in the maximum temporary (or emergency) ratings.
(a) Power, torque, speed, and time for: (a) Power, torque, speed and time for:
(b) The duty cycle and the rating at (3) Rated takeoff power
that duty cycle. The manufacturer must (b) The duty cycle and the rating at
declare the duty cycle or cycles in the that duty cycle. The manufacturer must
engine certificate data sheet. declare the duty cycle or cycles in the
engine certificate data sheet.
Comment #2
3. The engine design must comply with 3. The engine design must comply with (1) For example, electrolytic capacitors are known to age over
14 CFR 33.15. 14 CFR 33.15. time and are typically used in motor controllers. Normal use
In addition, produces heat caused by the capacitors inherent ESR; which,
(1) Component Aging permanently increases ESR. Over time ESR continues to
Electrical components that age and fail without increase until the capacitor catastrophically vents its
warning during normal use shall be avoided or a electrolyte. If the use of electrolytic capacitors cannot be
periodic replacement interval shall be determined avoided ESR must be tested periodically to determine an
as defined in special condition no. 13. appropriate replacement interval. Unchecked ESR can cause
(2) Component Environment unrecoverable engine shutdown, internal FOD, and a potential
Electrical components affected by the intended ignition source.
operating environment shall be avoided or the (2) For example, high voltage electrical components need to
effects shall be addressed via design or tested as be evaluated for the effects of altitude; ie, voltage breakdown /
defined in special condition no 10(e). corona / flashover / creepage / stike distance / cooling.
Page 2 of 11
Comment #3
The engine design and construction The engine design and construction The existing proposed wording matches the intent of §33.19(a)
must minimize the development of an must minimize the development of an but omits the requirements of §33.19(b). As noted in the
unsafe condition of the engine between unsafe condition of the engine between NPRM for amendment 33-28, any propeller controls that are
maintenance intervals, overhaul maintenance intervals, overhaul certified as part of the engine type design should meet the
periods, or mandatory actions described periods, or mandatory actions described same requirements as propeller controls that are certified as
in the applicable Instructions for in the applicable Instructions for part of the propeller type design. This is true for any type of
Continued Airworthiness (ICA). Continued Airworthiness (ICA). engine including an electric one, so the requirements of
Each component of the propeller blade pitch control §33.19(b) should be added to the proposed special conditions
system which is a part of the engine type design either here or as an additional special condition.
must meet the requirements of Sec. Sec. 35.21,
35.23, 35.42 and 35.43
Comment #4
7. Engine Mounting Attachments and 7. Engine Mounting Attachments and (1) An aircraft propeller and engine rotating mass can be a
Structure Structure much higher percentage of the total engine mass of an electric
The engine mounting attachments and The engine mounting attachments and propulsion system vs reciprocating or turbine engines. The
related engine structure must comply related engine structure must comply rotating and non-rotating components of a typical electric
with 14 CFR 33.23. with 14 CFR 33.23. motor are not frangible in the event of interference, unlike a
In addition, turbine engine. An electrical motor’s rotating components can
(a) Sudden Stoppage become nearly instantly coupled to the non-rotating
The engine mounting attachments and related components due to FOD, internal failure, rotor growth, and/or
engine structure shall be designed to withstand a commutation errors. A mounting system should be designed
sudden engine stoppage or be mitigated by design to absorb this load or mitigate the effect on aircraft CG and
to ensure aircraft CG is maintained within the flight aerodynamic effects in the event the engine and propeller
envelope. become dislodged.
(b) Bearing Protection (2) Studies and industry experience have proven the
Engine bearings must be protected from rotor premature wear of motor bearings caused by improperly
voltage or a periodic replacement interval shall be grounded rotor shafts.
determined as defined in special condition no. 13.
Page 3 of 11
Comment #5
9. Overspeed 9. Overspeed Same as comment 1
(a) A rotor overspeed must not result in a burst, (a) A rotor overspeed must not result in a burst,
rotor growth, or damage that results in a hazardous rotor growth, or damage that results in a hazardous
engine effect, as defined in special condition no. engine effect, as defined in special condition no.
17(d)(2). Compliance with this paragraph must be 17(d)(2). Compliance with this paragraph must be
shown by test, validated analysis, or a combination shown by test, validated analysis, or a combination
of both. Applicable assumed speeds must be of both. Applicable assumed RPM speeds must be
declared and justified. declared and justified.
(b) Rotors must possess sufficient strength with a (b) Rotors must possess sufficient strength with a
margin to burst above certified operating conditions margin to burst above certified operating conditions
and above failure conditions leading to rotor and above failure conditions leading to rotor
overspeed. The margin to burst must be shown by overspeed. The margin to burst must be shown by
tests, validated analysis, or a combination of both. tests, validated analysis, or a combination of both.
(c) The engine must not exceed the speed (c) The engine must not exceed the RPM speed
operational limitations that could affect rotor operational limitations that could affect rotor
structural integrity. structural integrity.
Comment #6
Affected Section: Proposed Special Condition 10(b)
(b) Engine control. (b) Engine control. §33.28(c) addresses failures resulting in changes to the
The engine control system must The engine control system must operation of the engine (e.g from a primary to backup control
ensure the engine does not experience ensure the engine does not experience system or from one FADEC channel to another). Without a
any unacceptable operating any unacceptable operating detailed understanding of the proposed electric engine’s
characteristics or exceed any of its characteristics or exceed any of its control system, there is no obvious reason why the same
operating limitations. operating limitations including in failure conditions requirements should not be applied to an electric engine. The
where the fault or failure results in a change from proposed added words address the same concern as the
one control mode to another, from one channel to existing §33.28(c)
another, or from the primary system to the back-up
system.
Page 4 of 11
Comment #7
Affected Section: Proposed Special Condition 10(h)
(h) Protection systems. (h) Protection systems. The proposed special condition matches the requirements of
The design and function of the engine (1) The design and function of the engine §33.28(f)(1), however the requirements of §33.28(f)(2) and
control devices and systems, together control devices and systems, together (f)(3) are not included. There is no obvious reason why the
with engine instruments, operating with engine instruments, operating same requirements for overspeed protection would not also
instructions and maintenance instructions and maintenance apply to an electric engine, so those requirements should be
instructions, must ensure that engine instructions, must ensure that engine added to the proposed special condition.
operating limitations will not be operating limitations will not be
exceeded in-service. exceeded in-service.
(2) When electronic overspeed protection systems
are provided, the design must include a means for
testing, at least once per engine start/stop cycle, to
establish the availability of the protection function.
The means must be such that a complete test of the
system can be achieved in the minimum number of
cycles. If the test is not fully automatic, the
requirement for a manual test must be contained in
the engine instructions for operation.
(3) When overspeed protection is provided through
hydromechanical or mechanical means, the
applicant must demonstrate by test or other
acceptable means that the overspeed function
remains available between inspection and
maintenance periods
Comment #8
11. Instrument Connection 11. Instrument Connection §33.29(f) requires the applicant to assess the possibility and
The applicant must comply with 14 The applicant must comply with 14 subsequent effect of incorrect fit of instruments, sensors, or
CFR 33.29(a), (e), (f), and (g). In CFR 33.29(a), (e), (f), and (g). In connectors as part of the safety assessment completed for
addition, as part of the system safety addition, as part of the system safety §33.28(g). Special condition 10(g) applies in lieu of §33.28(g),
assessment of special condition no. assessment of special condition no. and the words “…as part of the system safety assessment of
10(g), the applicant must assess the 10(g), the applicant must assess the special condition no.10(g)…” in proposed special condition 11
possibility and subsequent effect of possibility and subsequent effect of reflect that fact, so compliance with §33.29(f) should not be
incorrect fit of instruments, sensors, or incorrect fit of instruments, sensors, or required.
connectors. Where practicable, the connectors. Where practicable, the
applicant must take design precautions applicant must take design precautions
to prevent incorrect configuration of the to prevent incorrect configuration of the
system. system.
Page 5 of 11
Comment #9
Affected Section: Proposed Special Condition 13(b)(1)
The engineering plan must establish activities to be In addition to the activities which must be completed The current text is not clear on what required the post-
executed both pre- and post-certification. prior to certification, the engineering plan must certification activities are. The Textron Aviation proposed
establish activities to be executed both pre- and wording takes wording from earlier in the NPRM describing
post- certification. include a reporting system that the proposed special condition and adds it to the special
flows problematic issues that develop in engines condition to clarify the post certification requirements.
while they operate in service back to the applicant
so the design process can address them.
Comment #10
15. Power Response 15. Power Response Electrical motors have the capability to produce significantly
The design and construction of the The design and construction of the more torque than reciprocating or turbine engines.
engine must enable an increase— engine must enable an increase— Unregulated application of torque could be detrimental to the
(a) From the minimum power setting (a) From the minimum power setting flight characteristics of the aircraft or the structural
to the highest-rated power without to the highest-rated power without components of the aircraft.
detrimental engine effects; and detrimental engine effects; and
(b) From the minimum obtainable (b) From the minimum obtainable
power while in-flight and while on the power while in-flight and while on the
ground to the highest-rated power ground to the highest-rated power
within a time interval for safe operation of the within a time interval for safe operation of the aircraft;
aircraft. and
(c) of torque without detrimental engine or aircraft
effects. Aircraft components must be designed to
withstand unregulated application of torque or the
application of torque should be controlled to ensure
aircraft structural integrity or aircraft aerodynamic
characteristics are not exceeded.
Page 6 of 11
Comment #11
16. Continued Rotation 16. Continued Rotation Back driven electrical motors have the capability to produce
If the design allows any of the engine If the design allows any of the engine energy. Motor designs incorporating permanent magnets
main rotating systems to continue to main rotating systems to continue to may not prevent the generation of electric fields that produce
rotate after the engine is shut down rotate after the engine is shut down energy while the motor is free turning. This resultant energy
while in-flight, this continued rotation while in-flight, this continued rotation must be safely dissipated. If the energy is dissipated to the
must not result in any hazardous engine effects, as must not – electrical bus (regeneration) it shall be conditioned so that it
specified in special condition no. 17(d)(2). (a) result in any hazardous engine effects, as does not affect other electrical equipment connect to that bus.
specified in special condition no. 17(d)(2); and Reference, ASTM F2639 and RTCA DO-160 Section 18
(b) result in any hazardous electrical bus effects from (note: this is an input requirement, but represents the amount
the regeneration of electrical energy. Generated of noise aircraft electrical equipment is typically qualified to
power must be conditioned to ensure proper withstand).
operation of the electrical equipment installed on the
bus.
Comment #12
17. Safety Analysis 17. Safety Analysis Electrical component manufactures typically have no
(c) The applicant must comply with (c) The applicant must comply with knowledge of the end use of their components or the
14 CFR 33.75(d) and (e) using the failure 14 CFR 33.75(d) and (e) using the failure definitions implications to safety of changes made to the design and/or
definitions in special condition no. 17(d) of this in special condition no. 17(d) of this special condition. manufacturing process.
special condition. In addition, if electrical components of a safety
system are outside the control of the engine
manufacturer, then the manufacture must implement
a component tracking system to monitor component
revisions, change of manufacture, counterfeit parts,
and component End of Life (EOL).
Page 7 of 11
Comment #13
Affected Section: Proposed Special Condition 18(a)
(a) Ingestion from likely sources (a) Ingestion from likely sources The current text lacks definition of the ingestion threat. That is,
(foreign objects, birds, ice, rain, hail) (foreign objects, birds per Tables 1, 2 and 4 of how many and what size birds need to be ingested? What
must not result in unacceptable power §33.76, ice per §33.77(e), rain and hail per concentrations of ice, rain and hail need to be considered?
loss, or in hazardous engine effects as §33.78(a)) Definitions for these threats for turbine engines exist in
defined by special condition no. must not result in unacceptable power §§33.76, 33.77 and 33.78, similar definition should be provided
17(d)(2) loss, or in hazardous engine effects as in the proposed special condition.
defined by special condition no.
17(d)(2).
18. Ingestion 18. Ingestion The accumulation of ferromagnetic material in an air-cooled
(a) Ingestion from likely sources (a) Ingestion from likely sources motor could block air passages or may produce a short circuit
(foreign objects, birds, ice, rain, hail) (foreign objects, birds, ice, rain, hail) between the rotor and the stator.
must not result in unacceptable power must not result in unacceptable power
loss, or in hazardous engine effects as loss, or in hazardous engine effects as
defined by special condition no. defined by special condition no.
17(d)(2). 17(d)(2).
(b) If the design of the engine relies on (b) If the design of the engine relies on
features, attachments, or systems that features, attachments, or systems that
may be supplied by the installer for the may be supplied by the installer for the
prevention of unacceptable power loss prevention of unacceptable power loss
or hazardous engine effects following or hazardous engine effects following
potential ingestion, then the features, potential ingestion, then the features,
attachments, or systems must be attachments, or systems must be
documented in the engine installation documented in the engine installation
manual. manual.
(c) For non-sealed engines, the accumulation of
magnetically attracted FOD within the engine shall be
prevented or an internal inspection interval shall be
established.
Page 8 of 11
Comment #14
19. Liquid Systems 19. Liquid Systems Approved fluids should be listed as are currently for approved
(a) Each liquid system used for lubrication or cooling (a) Each liquid system used for lubrication or oils and fuels limiting the installer to those liquids only.
of engine components must be designed and cooling of engine components must be designed
and constructed to function properly in all flight
constructed to function properly in all flight attitudes
and atmospheric conditions in which the engine is attitudes and atmospheric conditions in which the
expected to operate. engine is expected to operate.
(b) If a liquid system used for lubrication or cooling (b) If a liquid system used for lubrication or cooling
of engine components is not self-contained, the of engine components is not self-contained, the
interfaces to that system must be defined in the interfaces to that system must be defined in the
engine installation manual. engine installation manual.
(c) Approved coolants and lubricants must be listed
in the engine installation manual.
19. Liquid Systems 19. Liquid Systems The accumulation of magnetically attracted FOD in liquid
(a) Each liquid system used for (a) Each liquid system used for coolant passages could block or limit coolant flow.
lubrication or cooling of engine lubrication or cooling of engine
components must be designed and components must be designed and
constructed to function properly in all constructed to function properly in all
flight attitudes and atmospheric flight attitudes and atmospheric
conditions in which the engine is conditions in which the engine is
expected to operate. expected to operate.
(b) If a liquid system used for (b) If a liquid system used for
lubrication or cooling of engine lubrication or cooling of engine
components is not self-contained, the components is not self-contained, the
interfaces to that system must be interfaces to that system must be
defined in the engine installation defined in the engine installation
manual. manual.
(c) For liquid cooled engines, the accumulation of
magnetically attracted FOD within the engine
coolant passages shall be prevented or an internal
inspection interval shall be established.
Page 9 of 11
Comment #15
24. Temperature Limit 24. Temperature Limit Prolonged high temperature engine operation should be
The engine design must demonstrate The engine design must demonstrate demonstrated at worst case environmental conditions for
its capability to endure operation at its its capability to endure operation at its engine cooling to evaluate cooling system performance.
temperature limits plus an acceptable temperature limits plus an acceptable
margin. The applicant must quantify margin. The applicant must quantify
and justify the margin at each rated and justify the margin at each rated
condition to the Administrator. The condition to the Administrator. The
demonstration must be repeated for all demonstration must be repeated for all
declared duty cycles and associated declared duty cycles, and associated
ratings. ratings, and operating environments.
Comment #16
If shaft rotation is prevented by a If shaft rotation is prevented by a Add clarification to the definition of “hazardous effects” to be
means to lock the rotor(s), the engine means to lock the rotor(s), the engine consistent with the rest of the proposed special conditions.
must demonstrate reliable rotor locking must demonstrate reliable rotor locking
performance and that no hazardous performance and that no hazardous
effects will occur. effects as specified in special condition
no. 17(d)(2) will occur.
28. Rotor Locking Demonstration 28. Rotor Locking Demonstration If the engine is shut down in flight and the locking devise is
If shaft rotation is prevented by a means to lock the (a) If shaft rotation is prevented by a means to lock automatic the crew need to have a means to remove and
rotor(s), the engine must demonstrate reliable rotor the rotor(s), the engine must demonstrate reliable restart the engine without creating a hazard.
locking performance and that no hazardous effects rotor locking performance and that no hazardous
will occur. effects will occur.
(b) When the locking device is in place a indication
shall be provided so that the crew will be able to
retract the device while in flight.
Page 10 of 11
Comment #17
29. Teardown Inspection 29. Teardown Inspection Electrical components in the controller should be inspected
The applicant must comply with The applicant must comply with after endurance and durability demonstrations. Fasteners,
either (a) or (b) as follows: either (a) or (b) as follows: heat transfer components, dissimilar metallic junctions, and
(a) Teardown evaluation. (a) Teardown evaluation. age/use affected electrical components should be evaluated at
(1) After the endurance and durability (1) After the endurance and durability a minimum.
demonstrations have been completed, demonstrations have been completed,
the engine must be completely the engine must be completely disassembled, and
disassembled. Each engine component the controller must be disassembled to permit the
must be within service limits and components can be adequately inspected. Each
eligible for continued operation in engine and controller component must be within
accordance with the information service limits and eligible for continued operation in
submitted for showing compliance with § 33.4, accordance with the information submitted for
Instructions for Continued showing compliance with § 33.4, Instructions for
Airworthiness. Continued Airworthiness.
(2) Each engine component having an (2) Each engine and controller component having an
adjustment setting and a functioning adjustment setting and a functioning characteristic
characteristic that can be established that can be established independent of installation
independent of installation on or in the on or in the engine or controller must retain each
engine must retain each setting and setting and functioning characteristic within the limits
functioning characteristic within the that were established and recorded at the beginning
limits that were established and of the endurance and durability demonstrations.
recorded at the beginning of the
endurance and durability
demonstrations.
Comment #18
Affected Section: Proposed Special Condition 30(a)
(a) The design of the case surrounding (a) The design of the case surrounding The current wording is vague on how much margin to burst
rotating components must provide for rotating components must provide for would be required. The proposed wording, modified from the
the containment of the rotating the containment of the rotating description of the proposed special condition earlier in the
components in the event of failure components in the event of failure NPRM, is more definitive.
unless the applicant shows that the unless the applicant shows that the
rotor has a margin to burst that would rotor has a margin to burst that would
justify no need for containment features. justify no need for containment features
margin to rotor burst unconditionally rules out the
possibility of a rotor burst
.
Page 11 of 11

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Reference: 20-3835

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