Cessna C337 SID

[tkirklindale]

well i am very worried about my 337 and what im going to have to do. anyone have any news about what needs to be done to make my plane safe

[skymstr02]

Chances are that your plane is as safe now as it ever has been.

You don't need to do anything. The SID is optional, if your plane is used flying part 91, and you are not operating under an FAA approved maintenance program.

You just should be vigilant to normal deviations while performing your preflight inspection, such as skin wrinkles that weren't there before, smoking residue originating at rivets, and so forth.

Dave

[tkirklindale]

thanks for the advice. i bought this plane a year ago have spent alot of money making it airworthy and still need more im not speending any more money on it till this is resolved as i see it this is realy going to hurt the value of my plane. so i guess i will play the waiting game. any ideas from u guys would be great

[K337A]

Here is a interesting fellow with a valid argument. Looks as though the legal community has taken a small interest in the circumvention of the Administrative Procedures Act (APA) concerning SID's. With the form of Socialism which is in power in the US today I'm surprised Mr. Furnas and his fellow owners hasn't been herded off to the Gulag by the Fed's Ageing Aircraft leadership and their buddies at Cessna.

http://conquestowners.org/images/lar...esresponse.pdf

http://www.conquestowners.org/images..._DOCUMENTS.pdf

[hharney]

Ken
The attached documents above are very clear in understanding the SID situation. It is nice to see this in print from a legal perspective. The Skymaster community on this message board has been trying to read between the lines since all the SID proposals started. I think this hits the nail right on the head. Thanks for sharing this, I had spoke with the EO of the Conguest group several months ago. He indicated that there was effort being pushed on interpretation of the rules. This really clears the smoke.

Some key points made in the attachments:

Section 91.415 of the Federal Aviation Regulations establishes the intent to limit the authority of arbitrary changes to an inspection program where it states "(a) Whenever the
Administrator finds that revisions to an approved aircraft inspection program under
91.409(f)(4) or 91.1109 are necessary for the continued adequacy of the program, the
owner or operator must, after notification by the Administrator, make any changes in the
program found to be necessary by the Administrator."

Granted, this particular paragraph addresses "any other inspection program" and not "one
recommended by the manufacturer" which is included under paragraph 91.409(f)(3) but
the intent of the section is just the same and in accordance with the December 5, 2008
Memorandum issued by the FAA which stated in part "An interpretation of the regulation
that would allow manufacturers unilaterally to issue changes to their recommended
maintenance and inspection programs that would have future effect on owners of their
products would not be legally correct. This would run afoul of the APA."

Nothing is said about "new owners" of the aircraft, it states "that would have future effect
on owners". If the FAA allows a SID to be mandated by the manufacturer to any owner,
present or future, the FAA has delegated its rulemaking authority to the manufacturer
which it cannot do.
On December 5, 2008 the FAA issued a legal Memorandum addressing the question
“whether, if a manufacturer amends its maintenance/inspection instructions, an affected
aircraft operator is obliged to comply with the new instructions in order to be in
compliance with subsection 91.409(f)(3)”. The FAA responded, “It is our opinion that the
operator is not so obliged”.

Then, applying their legal conclusions to both current maintenance instructions or
current inspection program the FAA went on to say:
If “current” in subsection 91.409(f)(3) and similarly worded regulations could be
read to mean an ongoing obligation, manufacturers unilaterally could impose
regulatory burdens on individuals through changes to their inspection programs or
maintenance manuals”
“If such compliance were required, this would be tantamount to private entities
issuing “rules” of general applicability without meeting the notice and comment
requirements of the APA, and the public would not have had an opportunity to
comment on these future limitations changes.”

In summary, an owner’s election to comply with the SID is just that, an election. It can be
ignored, or it can be completed if the operator is concerned that his aircraft might have
any of the listed deficiencies. Should the FAA adopt the SID, or even parts of it, the
complying owner might be one-step ahead of the field, but should the FAA require some
different standard, they might have to be re-inspected just the same.

[hharney]

Just received the Maintenance Manual revisions, Part #D2500-2TR9, which update the February 1973 current Maintenance Manual, Part #D2500-2-13.

This is the second revision to the current Maintenance Manual indicated above. The first revision is Part#D2500-2TR8 and deals with the Reel Type Seat Stops, Landing Light Switch and Corrosion Inspection of the Main Landing Gear. This new revision released last October are the Supplemental Inspection Documents (SID) and the Corrosion Prevention and Control Program (CPCP) that have been discussed on this message board for the last 2 1/2 years. See the threads below for more information about SID's:

http://www.337skymaster.com/messages...ead.php?t=2513

This revision, D2500-2TR9, contains 176 double sided pages. This revision covers 1965 -1973 337. The following are the revision numbers for the applicable models.

336 - D238-2TR6
1965-1973 337 D2500-2TR9
1974-1980 337/T337 D2506-8TR9
1973-1980 P337 D2516-9TR8

These revisions were all released 4th Qtr 2010. I ordered mine through Yingling http://www.cessnadirect.com and it was $8.11 online order. These are available in paper only, no electronic format unless you subscribe to a service.

I have not reviewed the document yet as it just arrived by courier. I will start to review today and update soon. If anyone has any questions you are welcome to post here or use private message feature.

[hharney]

Nothing really new here with this podcast but it may be helpful to understand the role that the FAA has with this program. Check out the podcast below:

http://www.avweb.com/podcast/podcast...1.html?kw=self

I found this website while googleing the revised maintenance manuals. Marv Nuss suggests that owners of aging aircraft visit this website for information on the program. On the surface there is really very little about Skymaster's. The site does not even mention the SID's.

http://www.aginggeneralaviation.org/

[sns3guppy]

I hate to say it guys but if it's in the manual and you don't comply your aircraft isnot airworthy!!!

This is incorrect. Airworthiness is defined by two parallel standards, or prongs. The first is legality, which means that the aircraft is in compliance with it's type certificate and any amendments thereto (supplemental type certificates, etc). The second prong is a requirement that the aircraft be safe for it's certified operations.

After reading over the thread, I see a lot of good information, and a lot of misinformation and misunderstanding. This is particularly true where issues regarding the requirement for compliance have come up.

When an aircraft is inspected, the aircraft must be found to be in compliance with the airworthiness requirements applicable to to the type certificate issued to that aircraft, and other specific amendments (STCs and so on). For Part 91 operations, an owner/operator is not responsible for compliance with manufacturer-mandated inspections or procedures. As others have noted, the FAA does not and cannot delegate authority to aircraft manufacturers which mandate specific maintenance or compliance practices. If an aircraft manufacturer wishes to have specific maintenance practices, inspections, and other actions legally mandated, the manufacturer must petition the FAA and submit those actions to the approval process (which allows for public input and comment, publication in the Federal Register, and scrutiny, among other things). A manufacturer cannot simply invent an inspection or practice, label it "mandatory" or state that it's required, and make it so.

If I perform an inspection on an aircraft intended for use under Part 91, I am not beholden to ensure that every service bulletin, for example, shows compliance. The aircraft may be declared airworthy and approved for return to service without compliance with service letters, service bulletins, and inspection documents. I am only required to ensure the inspection has been performed if the inspection is mandated by an Airworthiness Directive (AD).

If I perform an inspection and find discrepancies, I am required to provide a list of those discrepancies to the owner/operator. The inspection may be signed off, and the owner/operator becomes responsible for those discrepancies. If an inspection is performed and outstanding SB's, SID items, or other "mandatory" or "recommended" inspections have not been performed, these should be listed, where known, and provided to the aircraft owner. Compliance is at his or her discretion, not mine.

When manufacturer dictated maintenance is performed, unquestionably it increases the resale value of the aircraft, although by how much is subjective and highly variable. The economic value of performing some of these inspections must be considered carefully when deciding whether to perform or defer them. In some cases such inspections may be deferred indefinitely, while in others they may be performed at a later date when other maintenance that needs to be performed in the same area will make the older inspection more cost effective.

For the past couple of months, I've been performing inspections and maintenance on several large aging aircraft. Some of the inspections that are being done are unnecessary but repeats of previous work, only because the owners paperwork was destroyed in a fire. In other cases, the owner has elected to have inspections done because the area was already opened up for other work; he thus combined the inspections to save money.

I don't presently own a Skymaster, although I have flown them professionally (and maintained them). I'm considering purchase of a 336 at the moment, and while I've followed discussion of the SID problem since it became known, I'm taking some time to examine it again. One may rest assured that while I can work on and inspect my own aircraft, and while I have the tools and means and equipment to do so, I won't rush to tear the airplane apart and perform all the SID inspections.

Many owners aren't aware that annuals aren't the only means of accomplishing maintenance requirements. In fact, while many owners and mechanics take their playbook page for their inspection right out of the manufacturer maintenance manual, there exists NO requirement to do so. One can invent any number of means of compliance and gain FAA approval if that inspection program meets the requirements of 14 CFR Part 43, Appendix D. Progressive inspections, phase inspections, annual inspections, and other means can be used to assure compliance. It doesn't all need to be done at once, and it doesn't need to come out of the manufacturer maintenance manual. Work performed, that is to say specific operations performed, should be drawn from and comply with manufacturer ongoing maintenance instructions, but one is not beholden to perform non-mandated (read: non AD) inspections or practices that are established by the manufacturer.

If the aircraft is maintained in accordance with the Type Certificate and it's supplements or amendments, and is safe for it's intended operations, it may be signed off annually as airworthy, even if the service bulletins or other manufacturer inventions are not in compliance. Those are generally listed separately, and it's the discretion of the owner/operator to seek or forestall compliance.

[sns3guppy]

Someone entered into a discussion about signing off an aircraft at an annual inspection, with the possibility that the Part 91 airplane be subsequently sold into or placed into commercial service. This is a non-issue.

An aircraft which is inspected annually is declared airworthy at the time of the inspection, and the mechanic/inspector (IA) assumes liability with that declaration for the moment the signature is entered in the maintenance records, working backward. It's often said that he or she "buys" the history of the aircraft with that signature. If prior improper maintenance has been done, the inspector signing the aircraft off must either repair it (or set it right), or note it as a discrepancy before completing and signing the inspection.

A mechanic/inspector who signs off an aircraft, airframe, powerplant, appliance, or accessory does not "buy" the future. If a Skymaster is signed off without SID inspections done, he or she has signed off an airworthy airplane. The inspections aren't required under Part 91. If the owner subsequently elects to put the Skymaster into commercial service, the owner/operator is responsible for seeking compliance; the mechanic/inspector who performed the prior inspection is NOT responsible for that.

14 CFR 91.409(a) dictates the 12 month inspection term for the "annual" inspection.

91.409(c)(2) provides that the provision of 91.409(a) doesn't apply to aircraft operated under a maintenance program for Part 135. In other words, if you inspect a Skymaster for Mr. Bob, who operates the airplane under Part 91, you aren't obligated to perform that the SID inspections have been performed. You're not obligated to perform them, either. If you do the work following the inspection that's necessary to bring the airplane into compliance with the regulation, and you sign off the aircraft as airworthy, you're done when you sign the logbook. If Mr. Bob then puts the airplane into commercial service with a Part 135 operator, the aircraft is no longer airworthy until it's brought into compliance with the Part 135 maintenance program under which it's operated. Furthermore it must continuously be operated under that program, in full compliance with that program, so long as it's in Part 135 service. That's not your responsibility. It's the responsibility of the owner/operator.

The owner/operator is substantively responsible for the maintenance of the aircraft and it's records. This is firmly established by 91.403(a), which clearly states "The owner or operator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition, including compliance with part 39 of this chapter." Part 39 encompasses AD's.

Each foreign operator must take up the legal requirements of operating his or her aircraft in accordance with the respective airworthiness authority. It's beyond the scope of most, if not all, to attempt to dictate this or address this. It's certainly beyond my intent to address, consider, concern, or comment on such a vast and variable topic.

A couple of other points, as many owners aren't aware: by it's nature, an inspection does not include maintenance. Many seem to view an annual inspection as inclusive of all the things necessary to fix the airplane or bring it into compliance. This isn't the case. An inspection is just as it sounds: it's an examination of the aircraft and it's records. An owner may elect to have the inspector perform the maintenance to bring it into compliance, or may elect to have the work done elsewhere. The owner may also elect to seek determination that not all the work is necessary.

The other point is that while a mechanic holding an Inspection Authorization can declare an aircraft airworthy as part of an annual inspection, he or she cannot return the aircraft to service. The same applies when work has been performed on an aircraft; the person performing the work declares that work acceptable for return to service, but doesn't return the aircraft to service. Only the pilot does that, by flying the aircraft.

There are really only two times that a mechanic declares an aircraft airworthy (generally a mechanic only approves an aircraft for return to service; this is a significant distinction from declaring the aircraft airworthy): one is when signing a special flight permit ("ferry permit"), and the other is upon completion of an annual inspection.

One doesn't need to cite the airplane as airworthy at the conclusion of an annual inspection. One can also state that the aircraft isn't airworthy, and that a list of discrepancies has been provided to the owner.

Sometimes owners feel hostage to the shop or mechanic/inspector who does the inspection, as though they're stuck paying for all the work to be done. This isn't necessary and it's incorrect.

Years ago I served as the Director of Maintenance for a Part 135 operation that flew King Airs in medical service. Upon taking that position, I elected to do a records inspection, and found numerous discrepancies. Among them was an AD that was 20 years out of date, and missing phase inspections. I gave the operator an ultimatum: I'd begin providing service after an independent Beech center had performed two major inspections (a "C" and a "D" inspection) to bring the airplane into compliance, as well as addressing the AD.

Following the inspection, the owner received the estimate for the work that needed to be done: it came to over nine hundred thousand dollars. He came unglued. He ordered me to go to the service center and see that half that bill was "removed." I traveled to the service center, reviewed the records, and found a lot of items that didn't need doing. Some could be deferred, some weren't necessary. One that I recall was an oil line which had a slight dent. The line cost about nine hundred dollars. I inspected the line, and found that it wasn't out of tolerance, as the center suggested it was. Although the center insisted on all their items being done if they were going to sign off the phase inspections, I was still able to knock several hundred thousands of dollars off the cost by finding unnecessary work or work that could be deferred. Simply because an inspector or shop tells you they want this or that done to sign something off, doesn't make it so...any more than Cessna saying the SID inspections are mandatory makes them mandatory. Say it ain't so...because it ain't.

--Sorry for the length. Larry Bowdish did say it's okay to be verbose, and I felt it had to be said. I also divided the reply into two parts, because it's too long for one post.

[Gord Tessier]

Boy that clears up a lot of confusion. Obviously from your comments you have thorough understanding of the position the owners are in. To help validate your comments can you tell us a little more about yourself? expertise etc.
Well done.

[sns3guppy]

Gord,

I'm afraid that my own resume won't change the validity of what's been said, although I believe I provided adequate information to enable anyone to establish the information for themselves.

I fly internationally, and work as both a pilot and mechanic and inspector. I'm also a flight and ground instructor (and flight engineer, if that makes any difference). Presently I'm abroad, operating a large aircraft, primarily in hostile areas. I would prefer to say no more than that.

[WebMaster]

Be as verbose as you please.
The software has limits of how big a post can be, but I don't.

[Gord Tessier]

SIDS not mandatory...

SID inspections are NOT mandatory for Canadian registered, small, privately owned aircraft.

From Transport Canada

"For non-commercial owner/operators of small piston aircraft who are operating under Standard 625 Appendix B however the ability to operate to the general annual inspection requirements of this appendix removes the requirement to perform the SID inspections.The Regulations state only the minimum requirements in order to comply however Transport Canada encourages all owners to assess manufacturer’s recommendations for their aircraft".

So now we know.

[hharney]

That is great news Gord

[hharney]

The rest of fleet is joining the fun.

http://www.aopa.org/aircraft/article...WT.mc_sect=gan