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 Post subject: Maintenance SIDS and part 91 piston twins
PostPosted: 11 Apr 2019, 14:35 
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I’m currently researching the SID requirements for a Cessna T303. In 2011 Cessna added 5 items that had been SIDS to chapter 4 “Airworthiness” of the maintenance manual under the heading Inspection Time Limits. My understanding to date has been that SIDS are never mandatory for piston aircraft operated under Part 91. My shop believes otherwise since these 5 SIDS were moved to chapter 4. Can anyone point me to a direct reference that states SIDS are not required in the US for part 91 piston aircraft.

I spoke to Textron piston tech support and was told that even though moved to chapter 4, these are still SIDS and not new requirements.

Thanks,

Kirk


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 Post subject: Re: Maintenance SIDS and part 91 piston twins
PostPosted: 11 Apr 2019, 15:08 
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FAA just put out a big A/C about this.

Ultimately you could always have the inspection done with discrepancies and have any a&p sign them as n/a afterward


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 Post subject: Re: Maintenance SIDS and part 91 piston twins
PostPosted: 11 Apr 2019, 18:06 
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What SIDS are new for the T303?. Last I knew the only thing was the eddy current insp of the rear spar which was listed as part of the type certificate. . That insp is not hard and I bought the test standard to have on hand to calibrate the machine. Its a good airplane if your looking at one. But misunderstood. Working on it has not been a problem over the last 10 years. Its a good alternate to Seneca or Aztec. Its not a 421 or 58 Baron


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 Post subject: Re: Maintenance SIDS and part 91 piston twins
PostPosted: 11 Apr 2019, 18:24 
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Username Protected wrote:
What SIDS are new for the T303?. Last I knew the only thing was the eddy current insp of the rear spar which was listed as part of the type certificate. . That insp is not hard and I bought the test standard to have on hand to calibrate the machine. Its a good airplane if your looking at one. But misunderstood. Working on it has not been a problem over the last 10 years. Its a good alternate to Seneca or Aztec. Its not a 421 or 58 Baron


I already bought it. We’re in annual now and the issue that’s been raised is that Cessna put some of the SIDS into Chapter 4. My shop says they must be complied with. I say no. The only one that matters at the moment is the engine mount inspection. It’s a SID recurring every 4000 hours. I have 4800 hours on mine with 1800 hour engines. I’d like to keep running past TBO and do the mounts when I do the overhauls vs having to remove the engines now to be able to remove and send off the mounts. Mike Busch and Tony Saxton have been a BIG help. Cessna has gone off the rails with this just like they did with the 210. The eddy current inspection was changed to 20,000 hours, there’s no longer a calendar requirement.

Kirk


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 Post subject: Re: Maintenance SIDS and part 91 piston twins
PostPosted: 11 Apr 2019, 18:31 
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I believe the ruling is the original mx manual edition that it was Type certificated uner still applies regardless of the changed. but only the original. The latest revision applies also. It has been discussed over on the Turbines side of things but maybe someone can verify


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 Post subject: Re: Maintenance SIDS and part 91 piston twins
PostPosted: 11 Apr 2019, 18:54 
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Here’s an excerpt from the official ruling from the FAA on the subject from 2015. This is what I was looking for...

This letter responds to your September 15, 2014 request for legal interpretation of 14 C.P.R.
§ 91.403(c) regarding whether replacement times and inspection intervals contained in an Airworthiness Limitations section (ALS) newly added to the maintenance manual or Instructions for Continued Airworthiness (ICA) by a manufacturer are mandatory for operators of an aircraft that was type-certificated and manufactured before the FAA approved the new ALS as a change to type design. On January 21, 2015, you amended your request, asking us to also address whether 14 C.P.R.§ 43.16 (Airwmthiness limitations) requires maintenance providers to perform inspections or other maintenance in accordance with the newly added ALS for those older aircraft. For aircraft operated under 14 C.P.R. part 91, the answer to your question is no. These after-added ALS requirements are not mandatory for operators or maintainers of the affected aircraft absent the FAA's issuing an Airworthiness Directive (AD) or some other notice and commentrulemakingthatwouldmakethemmandatory. Cessna includes these new replacement times and inspection intervals in an ALS instead of in another portion of the maintenance manual where they would be more appropriate as non-mandatory procedures.


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 Post subject: Re: Maintenance SIDS and part 91 piston twins
PostPosted: 11 Apr 2019, 19:47 
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Username Protected wrote:
Here’s an excerpt from the official ruling from the FAA on the subject from 2015. This is what I was looking for...

This letter responds to your September 15, 2014 request for legal interpretation of 14 C.P.R.
§ 91.403(c) regarding whether replacement times and inspection intervals contained in an Airworthiness Limitations section (ALS) newly added to the maintenance manual or Instructions for Continued Airworthiness (ICA) by a manufacturer are mandatory for operators of an aircraft that was type-certificated and manufactured before the FAA approved the new ALS as a change to type design. On January 21, 2015, you amended your request, asking us to also address whether 14 C.P.R.§ 43.16 (Airwmthiness limitations) requires maintenance providers to perform inspections or other maintenance in accordance with the newly added ALS for those older aircraft. For aircraft operated under 14 C.P.R. part 91, the answer to your question is no. These after-added ALS requirements are not mandatory for operators or maintainers of the affected aircraft absent the FAA's issuing an Airworthiness Directive (AD) or some other notice and commentrulemakingthatwouldmakethemmandatory. Cessna includes these new replacement times and inspection intervals in an ALS instead of in another portion of the maintenance manual where they would be more appropriate as non-mandatory procedures.


And that is all needs be said about that.

Reason is simple - otherwise the FAA would be effectively ceding AD rights to a manufacturer. Government agencies do not give away power.

RAS


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 Post subject: Re: Maintenance SIDS and part 91 piston twins
PostPosted: 11 Apr 2019, 20:27 
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Thanks Good to have that text to back things up.

Kirk check the diagonal engine mount tube that goes under your exhaust where the tailpipe connects to the turbo. I have had to repaint this tube and wrap with some high temp block material to keep the paint from cooking off the tube and allowing corrosion. When we got the airplane I had to weld in a new tube on the right engine mount in this location.


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 Post subject: Re: Maintenance SIDS and part 91 piston twins
PostPosted: 11 Apr 2019, 20:38 
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Username Protected wrote:
Thanks Good to have that text to back things up.

Kirk check the diagonal engine mount tube that goes under your exhaust where the tailpipe connects to the turbo. I have had to repaint this tube and wrap with some high temp block material to keep the paint from cooking off the tube and allowing corrosion. When we got the airplane I had to weld in a new tube on the right engine mount in this location.


Thanks Charlie. That area seems to be a “hot” spot on most of the 303s I’ve seen. So you were able to do a field repair on that section of the mount?


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 Post subject: Re: Maintenance SIDS and part 91 piston twins
PostPosted: 11 Apr 2019, 21:48 
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Yes I used the repair guidelines in the structural repair section of the T303 MX manual. It had a specific repair to sleeve that section of the mount, size and wall thickness of the tubing.

We were lucky it all matched up perfectly to what the repair manual called out.

Also study the main gear hydraulic cylinder adjustment and the main gear down locks. It’s a little odd in the cylinders flex slightly when pressurized and then the downlinks relax when unpressurized. The manual has the desired clearances but it’s tricky to get them within limits and not put a big bow in the cylinder center under pressure.

Watch your prop dome air pressures. It will affect your takeoff RPM’s.

Berryman B-12 in the turbo inlets to soak and drain out after a couple hours really helps.

The fittings are all O rings but possibly try the Viton o or some other type of oil resistant O ring. It seems all the fittings in the engine compartment are straight thread with O rings and they will leak as the O rings age.

The factory gear strut height can help prevent it from trying to overrotate on takeoff.

It takes a lot of fiddling but the throttle, prop and mixture levers can be made to line up in pairs during flight. On N303KJ they were way out, It took a while but things match up pretty good now.

The rest of the airplane has been pretty trouble free.


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