Are you operating in accordance with a maintenance program?

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.

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.

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.

Is the FAA writting the SIDS ? I thought it was Cessna?

Regarding the last two messages:

1. Cessna, not the FAA, is writing the SIDs, but under a mandate from the FAA, who in turn is responding to Congress after the 1988 in-flight failure of a high-time Aloha Airlines Boeing 737, where a section of the upper fuselage ripped away because of fatigue. Initially only transport aircraft were considered but that was later expanded to cover smaller aircraft.

2. But, yes, even though it's being done under FAA auspices, the FAA has made it clear that it doesn't apply to Part 91 -- in fact, it doesn't apply to some Part 135 operations, either (see the FAA’s Final Rule on the matter at http://edocket.access.gpo.gov/2002/pdf/02-30111.pdf). Also, although the referenced letter may apply to large and turbine powered aircraft, the rationale and underpinning for the opinion make it crystal clear that the policy applies to all Part 91 operators. One other point that has not been mentioned: on the Cessna 400-series SIDs, which have been implemented now for several years, Part 91 operators do not have to comply and few do(except for the single SID that became an AD).

In a 1/27/2010 Message in the thread entitled "How are you going to handle the SID?", Herb's point 5 is short and to the point: "Unless these inspections become AD's we will NOT have to comply". Based on all we know -- principally the FAA’s Final Rule and Notices -- he's right.

Ernie

When you say "We do not have to comply", what you really mean is that Part 91 operators in the USA do not have to comply. That statement, however, ignores the problem that operators in the rest of the world will face.

They will have to comply. They will have no choice.

Saying that we don't have to comply ignores all those people who don't live in the USA and will have to comply.

Larry, most of this thread and all of the last message deals only with Part 91 operators. Herb's point 5 also dealt solely with Part 91.

As you note, most foreign operators, won't be so lucky. And some Part 91 operators may have to comply if their insurance companies require it.

Ernie

It may very well be true that operators in other countries need to comply with rules and regulations that are different than those in the US, but that's the way it is with a lot of things. A perfect example is the ELT change. We can't fight everybody's battles for them.

It would seem that operators outside of the US should seek their own clarification or rule changes to be afforded the same protections from these onerous "recommendations" as provided to US operators.

I would imagine that as Cessna continue across all makes and models, they will eventually hit the one model that will cause an uproar casuing a change in how other countries view the implementation of these SIDS. The 337 family is too small to bring about significant change (whihc is mroe than likely why they started here).

I for one can't wait to see the 172 operators reaction

The above message was moved from an unrelated thread. Here are two responses that followed:

1. I wrote: "Cessna 172s are not subject to SIDs unless in Part 121 operations, a point I made on the thread entitled "AV Web SIDS Article 12-24-09", where I pointed out that the FAA's Final Rule on SIDs clearly specifies that they apply only to Part 121 operations and multiengine Part 129 and 135 operations (see http://edocket.access.gpo.gov/2002/pdf/02-30111.pdf)."

2. Tropical wrote that Cessna 172s can't be in Part 121 operations.

Ernie

AvWeb Story
 

AvWeb has a story about the New Jersey Skymaster crash trying to correlate the SID concern with the wing detachment of N12NA. This is not good exposure for our side.

http://www.avweb.com/eletter/archive...ll.html#202067

I don't know about exposure, but on the merits it's good news. If the NTSB preliminary report is correct, it supports what at least one structural expert with Skymaster knowledge told me when I analyzed the SIDs. Here's the gist:

"If fatigue-tested to failure, no one knows where it will fail. Cessna doesn't know and I don't know. But I know that the wing-fuselage attach points are the least likely to fail. If I had to guess it would be just outboard of the strut, or perhaps the strut itself, but not at the strut attach point with the wing but further down."

He dismissed a failure at the wing-fuselage attach points because of the massive over-design and because the front attachment, which carries the heavier load, is in compression in flight, meaning that the wing is pushing down on the top of the fuselage, rather than trying to pull up (i.e., separate) from the fuselage.

Ernie

From a capitalistic point of view
 

Why are we pilots in the USA surprised by this SID? We are living in a DIFFICULT economic time, most companies are struggling to keep the doors open, a lot of them are in bankruptcy. We have seen our government input billions of dollars into the economy. You don't have to be an economist to realize what Cessna is doing with this "mandate." Cash flow is their primary reason. In order to generate CASH-the needed element in a capitalistic society-Cessna has devised this new revenue source, and the FAA is probably in cahoots (blame it on the lobbyist). To be honest I am surprised that they still let us fly our 30+ year airplanes. But the truth is the economy has to be stimulated and cash has to flow or else capitalism does not have a chance.

I recently had to spend $1000 dollars on a new set of golf clubs... with some discussion about square grooves versus rounded grooves, rendering my good old set useless. How much money are the golf club manufacturers going to make in the coming years with new purchases from individuals? I think I am going to invest my retirement in them, or maybe I should invest in Cessna?

Sid
 

who came up with the potential 60k expense? after all to separate both wing and inspect is no more than three or four days work, tops three or four thousand dollars labor! If there is more to it than what I am hearing, guys please elaborate.

Several IA's
 

Nick,
Several people were involved in the review and cost estimates of SID compliance.

Removing both wings from the fuselage is a labor intensive project. Re-assembling them is even more labor intensive. In between, there is the eddy current inspection of each of the attach points, in the fuselage, and the wing. In addition to the wing removal, there are several other items that must be inspected. The cost is real. You may have a lower labor rate, and get eddy current inspection at a lower cost, but the total cost will significant. In addition, there is the very real possibility that the re-assembly will damage the aircraft.

That is why SOAPA has campaigned to have the wing attach inspection removed from the SID inspection.