Cessna C337 SID

[WebMaster]

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N number _________
Serial number __________
Year and model __________

How long have you owned it __________
Total airframe time __________
Your location ____________
Are you Private, Commercial or an ATP ___________

Is your aircraft used in your business, and if so, what percentage of the time is spent on business. ______

Is your aircraft used, or has it been used for low level terrain following operations (e.g pipeline patrol, cattle management)?______

Average hours you fly annually, over the past 2 years. ____________

Is your airplane kept in a hangar? How long have you kept it hangared? ____________

[Paul462]

Mike Busch, author of Cessna 400-Series Wing Spar Update, and who had considerable involvement in that situation, has this to say:


Paul, I'm not sure why you're so concerned about this. The Cessna SIDs have no regulatory impact in the US, except possibly for Part 135 operators who have committed to comply with service bulletins in their op specs. (I don't think there are a lot of 337s in Part 135 service.) We've seen absolutely no evidence that the FAA intends to mandate any of the SIDs via Airworthiness Directive, except for the 400-series twins where they've already done so. It looks to me as if Cessna ultimately will issue SIDs on all their piston GA aircraft. The FAA is not involved in this: SIDs are essentially giant service bulletins issued unilaterally by Cessna without FAA involvement or concurrence. Unless the FAA makes some radical course change, Part 91 operators can simply ignore the SIDs. Unless you're aware of some actual safety-related aging-aircraft issues with the 337 that could trigger FAA rulemaking action, I would not lose any sleep over this.

The situation is different in some other countries, where the local CAAs require Part 91 operators to comply with the SIDs. The Cessna SIDs program has been a real disaster for owners in Australia, for example. But in the U.S., it has been more or less a non-issue (except for the 401/402/411/414 aircraft affected by the spar-strap AD).

I don't think it's worth trying to oppose the SIDs unless the FAA issues an SAIB or NPRM that suggests they are planning to mandate any of them. In the absence of such a signal from the FAA, making a big deal over the SIDs can only be counterproductive by focusing FAA attention on the subject. My thoughts, for what they're worth.

Best...Mike


We asked Mike about the reasons that the 337 SID may not come back to haunt us as an AD, and he responded:


The 400-series spar-strap ADs were triggered by a series of unfortunate events and decisions.

There was a fatal accident in a 402C where the wing came off in flight. The airplane had 20,000 hours, and the NTSB investigation revealed that the origin of the spar fatigue failure was a pre-existing flaw in the spar that was there when the aircraft originally rolled out of the Cessna factory. In addition, the aircraft had previously had a hard-landing incident that tore a main gear leg out of the wing and overstressed the spar beyond design limits. Despite both of these problems, the airplane flew 20,000 hours before the wing came off. This was a one-time freak accident, but it put the 402 on the FAA's radar screen anyway -- specifically the aging aircraft folks (notably Marv Nuss) at the FAA Small Airplane Directorate in Kansas City. That is never a good thing.

Then, the FAA became aware of some spark cap cracks (not failures) in a few old high-time tip-tank 402s that had been in Grand Canyon sightseeing service, and had been operated at an extreme corner of the loading envelope with extremely heavy cabin loads and extremely light fuel loads in turbulent conditions, thereby placing tension stresses on the lower spar cap far in excess of what is ever experienced in airplanes operated with more normal cabin and fuel loads. (I strongly suspect that these aircraft were operating over-gross, but of course can't prove it.)

Under the circumstances, an AD mandating lower spark cap reinforcement for the 402 was inevitable. We tried very very had to persuade the FAA to limit the scope of the AD to the 402, because no other 400-series twin has ever exhibited any spar cracking and no other 400-series twin operates in the extreme corner of the loading envelope that these 402s did. Despite our best efforts, the FAA rejected our arguments and issued a spar-strap AD that affected 401s, 411s and 414s, none of which had ever exhibited any problems because they're never operated in the extreme loadings that the problem 402s used. Owners of those models were unfortunately caught in the crossfire over the 402 spar issues, and I feel bad that we were not able to prevent this (and heaven knows we tried).

Unless and until actual cracks or other clear safety-of-flight issues appear in other Cessna models (and I sincerely doubt that they will), I see no reason for the FAA to consider ADs against 300-series Wallace twins, Skymasters, or Centurions..

I don't have a crystal ball, so I could be wrong. I hope not.

Best...Mike



Thanks for the input, Mike!

[iswap]

Originally Posted by Paul462

Mike Busch, author of Cessna 400-Series Wing Spar Update, and who had considerable involvement in that situation, has this to say:

Paul, I'm not sure why you're so concerned about this. The Cessna SIDs have no regulatory impact in the US, except possibly for Part 135 operators who have committed to comply with service bulletins in their op specs. (I don't think there are a lot of 337s in Part 135 service.)

Here in the West there are quite a few 337s in Part 135 service (or on contracts requiring Part 135 levels) to the Forest Service for fire fighting/spotting; to the BLM for a myriad of range management duties; to Interior, Energy, Homeland Security, Border Patrol, Joint Drug Task Forces, etc.

The requirement to go to digital tactical radios was already a big financial hit.

Any program with an impact like the one for the 401 and 402 fleets would be devastating.

[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.