Both matters being discussed here -- the scope of the wing/fuselage SID and whether an IA may require that the SIDs be complied with at annual -- were addressed in one of my prior posts. It is in the "AV Web SIDS Article 12-24-09" thread (see
http://www.337skymaster.com/messages...2598&page=2#23) and elements of that message were later posted in the much longer "Cessna C337 SID" thread. For those of you who have not seen it, here again are excerpts (the material in square brackets are current additions for clarity and context):
The [large]cost estimates were arrived at by separate parties working independently. I believe they are accurate for the SIDs now under consideration and driven principally by the need to remove and inspect the wing attach bolts. Currently, such removal can be done safely only by separating not only the wings from the fuselage, but also the booms and tail, and derigging the aircraft. Cost won’t be significantly less unless the SIDs are changed or someone comes up with an alternate form of inspection such as X-ray.
But if you are a U.S. Part 91 operator, I don’t believe you will be required to perform the SIDs.
I have been reading various comments on this Board about the possibility of an IA requiring the SIDs, either out of an abundance of caution or if Cessna issues a revised Service Manual with SIDs. While I can’t rule out a poorly informed IA taken such a stance, I think the record is clear that Part 91 operators will not have to do the SIDs.
My basis is the FAA’s Final Rule and Notices (“FRN”) on the matter, which is essentially the mandate for the SIDs. Later I will provide you a link so you may peruse the document, but here’s a summary.
The genesys of SIDs was 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. Congress pushed the FAA into evaluating steps that should be taken to prevent such future failures in high-time (or “aging”) aircraft. Initially only transport aircraft were considered but that was later expanded to cover smaller aircraft.
Both the heading and the first paragraph of the FRN make it clear that only Part 121, Part 129 and Part 135 operations are covered. Moreover, on Page 5 (3rd full paragraph of the 3rd column) Part 135 cargo-only and on-demand operations are excluded.
Concerns that SIDs may become ADs also appear unfounded. On Page 2 (1st full paragraph of the 3rd column) the FAA explicitly states that ADs will be issued only to address “unsafe conditions that have already been identified.” And the [7 years of experience with] the Cessna 400-series SIDs supports this, because only one of the SIDs became an AD after cracks were found and a fatal in-flight failure occurred, [and Cessna 400-series aircraft in Part-91-only service have not been required to comply with the SIDs].
Given that SIDs were mandated by the FAA and the FRN’s clear intention to exclude Part 91 and some Part 135 operations, I do not believe [anyone] can take actions that would essentially contravene the FAA.
All of this is small consolation to many non-commercial foreign operators who will be subject to the SIDs.
The FRN may be found at http://edocket.access.gpo.gov/2002/pdf/02-30111.pdf.
Ernie Martin