Cessna C337 SID

[Roger]

First please see: http://www.faa.gov/other_visit/aviat.../info09008.pdf

I had a nice talk today with Rusty Jones at the FAA (listed at the bottom of the attached link). Among other issues I asked him about the previous stated concerns that 14CFR43.19.409(f) might be construed to be applicable to turbin aircraft only, and that 14CFR43.13 (b) may require IA's to comply with inspections as provided by the new service or maintenance manuals as it refers to "structural strenght and deteroration" . Rusty said that in his readings of the points referenced, he can see how the "words" may make it appear that those specific conclusions could be drawn, but he does not beilieve that this is the case. He suggests that SOAPA designate a quesiton or list of quesitons for legal clarification, and submit them through the AFS-300 process for specific clarification.

That being said, we should then perhaps come up with a correctly phrased question or two that the IA' AP's here may help us to clarify, on how they as inspectors and we as owner/operators can best protect our respective intersts going forward so as to not run afoul of regulations.

He likewise made a point of discussing the attached link (which is how I found him) and suggests that we might be well served to take advantage of the answers to these frequestly asked questions. I for one will be making sure that my aircraft maintenance Log clearly states that I am using the maintenance programs for 12 month and/or 100 hour inspections as defined at the time or original manufacture.

Rusty has been around this whole issue for a long time and cut his teeth on Aloha and the 400 series. I might suggest that those who are more knowledgeable about these things contact him direct. That being said, after talking to him about how this has come about with Cessna, and how an AD such as those with the 400 series evolved, I came away with no concern what-so-ever that we will see an AD for the 336/337 on any of these SID issues.

This is essentially a Cessna Protection program, not an Owner/Operator protection program

[hharney]

Good job Roger, the SOAPA steering committee has circulated this document and I was going to call Rusty but hadn't yet. I am glad you talked to him and the steering committee will take some action on your suggestion.

[Skymaster337B]

Ok, so here's the first question that comes to mind.

- Does the term "current" as interpreted for FAR 91.409 that means "current at time of manufacture" apply to all of FAR 91 with respect to "current" maintenance manual and/or inspection programs?

[skymstr02]

Are you operating in accordance with a maintenance program?

[hharney]

Attached is the FAA's Letter of Interpretation (LOI) on "current" maintenance programs as listed in 91.409. This might help clear up some questions. It's all good.

[K337A]

It is good to know that the FAA Legal team has given the heavy aircraft a outlet to avoid useless SID's. Unfortunately in the FAA world this has not been applied to C337's, C402's, C414's, at this point in time. Is this by accident or neglect? Has Textron/Cessna attempted to clarify this to customers? I believe it's time to heavily publicize Textron/Cessna's ability to foresee fatigue failure of Cessna manufactured aircraft by Using "advanced systems and techniques" as described at length by Doug Oliver Textron/Cessna mouthpiece. What fool would by a Cessna product after examining Cessna's/FAA cozy relationship after this fiasco? I know one individual who was in the market for a nice new Citation. After explaining Cessna's style of doing business and their expertise with "advanced systems and techniques he has chosen a used G3. He looked into Cessna's SID formulation after i explained Cessna's actions. No way would he buy a Cessna. . Owners and Buyers become very attentive when the specter of wing/fuselage de-mateing is spoken. Especially when the trigger for this very expensive endeavor is "advanced system and techniques" along with a phantom plane with no investigatory history as the #1 reason for the very, very, very expensive maintenance or potential scrapping of a a expensive airframe prematurely.. Cessna 's Citation assembly line could loss a few sales very easily. I'm waiting for a Citation X SADASS ( Special Advanced Design Aeroknowledge Symptom Schedule) to be posted for a wing/fuselage removal and replacement. Of course predicated upon "Advanced Systems and Techniques", being used as the justification for the 8 million dollar MX.

[skymstr02]

Herb, that FAA letter is not applicable to our situation.

It only applies to large and turbine powered aircraft operating under an approved maintenance program. Research 14cfr91.409(f)(3) referenced in the letter for details.

The maintenance manuals for the 336/337 series aircraft are not FAA approved documents, however, mechanics are required to inspect and repair aircraft in accordance with 14CFR43.13.

And some thing to ponder, do you honestly think that The FAA would spend the time and money to write this document (SIDS), and then tell the owners that this is optional to comply with? All that is required to mandate is to place this in the type certificate data sheet to be complied with at XX interval, and voila, its here. The FAA is not our friend.