Sorry I didn't get to talk to him. Prebuy was canceled so we didn't get out. Oddly I talked to another mechanic who looked at a 303 in California which had been maintained by a Cessna service center since new. one owner. He was told by Cessna none of it applies including the original eddy current inspection unless used for Part 135. This was totally different than the answer I got from calling Textron twin engine support. So I guess still up to interpretation but I'm going to stay with the current manual revision we are using. Since we are Part 91 it might be unneeded but I figure it's the safe bet.

No idea if Mike Busch knows about a T303. But same thing he or Tony are just an interpretation also. If Cessna can't give a consistent answer what hope do we have anyone else is an authority.

Kirk Zastrow got to the bottom of this in 2019 after talking to Mike. Here are my notes from the chain of emails that resulted:

Information on Maintenance Requirements that are Specified by the Manufacturer


Summary: (they are NOT mandatory for Part 91 U.S. operators) (Examples: Cessna T303 Engine Mount Inspection and reat spar eddy current inspection called for by the Type Certificate)

Bob,
Attached (FAA Letter to Paul New) is the definitive word from the FAA on all this SID stuff. The very first paragraph says it all. They are not required even when inappropriately placed in Chapter 4 by Cessna.
Kirk

Ah yes, I remember this. Tony, Robert and I discussed this in 2015. What it says is Cessna cannot add to the ALS of the maintenance manual. That is what they tried to do with the 210. I am not aware that they ever tried to add anything to the 303 MM, but I could be mistaken.
I take this to mean that the ALS of the original MM is mandatory but anything that is added to it after that, is not.

Here is the sentence from page 2 of the 5-21-15 FAA letter to Paul New:
The only version of an ALS that is mandatory is the version that was included in the particular aircraft's type design that was approved by the FAA.

And I’m pretty sure the 4,000 hour engine beam inspection requirement was in the ALS of the original 303 MM.

Robert? Tony?
Bob

I have a copy of the original MM ALS attached. It is one page and only has a note. I’ve also attached the page added to the ALS in 2011 - according to the FAA’s interpretation, these are not required inspections since they were “later added”. The Type Data Sheet I have has no requirement regarding the engine mounts, it’s just a SID.
Kirk

Bob, this email from Mike Busch should put a bow on it. In summary:

1. SIDs are never required in the U.S. (for Part 91 airplanes) even if placed in the ALS of the MM. (As we’ve already seen from the 2015 FAA determination letter)
2. Inspections called out in the TCDS are also never required. This includes the rear spar eddy current inspection. See below from Mike Busch.

Begin forwarded message:
From: "Mike Busch" <mike.busch@savvyaviator.com>
Date: April 13, 2019 at 1:18:25 AM CDT
To: "kirk zastrow"
Subject: Re[6]: Cessna 303 SIDS moved to Chapter 4 now required??? Reply-To: "Mike Busch" <mike.busch@savvyaviator.com>

The TCDS is *not* regulatory with respect to maintenance. Just because some maintenance action is mentioned or referenced in the TCDS notes does *not* mean that you have to do it (absent some AD or other actual FAA regulation that says you do).

I am attaching a copy of FAA National Policy Notice N8900.410 which defines a national policy for inspection and overhaul requirements under Part 91. This was issued in 2017 by FAA HQ to eliminate confusion on this subject on the part of many FAA FSDO inspectors. I call your and Pete's attention to paragraph 5.a.(1)(d) on page 2 of this document which states:
(d) Type Certificate Data Sheet (TCDS) Notes. FAA legal interpretations state TCDS notes containing overhaul limits are not mandatory under our regulations. TCDS notes define the design of the aircraft and how that design meets the certification basis it is certificated under, not to define how it is maintained. Some manufacturers have attempted to put information into a TCDS that defines requirements for continuing maintenance of their aircraft; however, such information is not regulatory and is outside the purpose of the TCDS notes. Information not specifically referencing the design and configuration of an aircraft, such as ongoing maintenance requirements, is inappropriate and not binding on the owner/operator in a regulatory sense.

By the way, as a general FAA regulatory proposition, it is always permissible for a Part 91 operator of a small piston or single-engine turbine airplane to elect to follow (1) the current maintenance manual, (2) the version of the maintenance manual that was in effect when the aircraft was manufactured, or (3) any version of the maintenance manual published in between those two versions. The reason is that the basic maintenance performance rule (43.13) requires the use of "methods techniques and practices specified in the manufacturers current maintenance manual or instructions for continued airworthines *OR* other methods techniques and practices acceptable to the Administrator." The methods techniques and practices specified in the maintenance manual that was current when the aircraft was manufactured was obviously acceptable to the Administrator at that time, so absent some AD or other notice-and-comment rulemaking action to the contrary it remains acceptable to the Administrator today.
Hope this helps. Tell Pete I said "hi." --Mike

Thanks for sharing but this raises more concerns. So how does this all hold up when an IA is required to confirm the airplane meets its type design or conforms to the TCDS. But the FAA says we can ignore some parts of the TCDS during an annual. Cessna says no. But FAA attourneys say yes. Then calling Cessna gets a different answer depending on who answered the phone. FSDO has another opinion. Yet they have the power to violate me if they think my interpretation was wrong.

I HATE the current FAA and everything having a different opinion or double-talk on regulations.

How the hell do I do my job as an IA with this type of crap going against the approved data in front of me. If it is not allowed why did the FAA approve the TCDS and its revisions with the maintenance note included?

Disregarding the type certificate note 5. I have some question about the way the Policy notice was written, it does not allow "inspections" to be exempt part 91. But they are using Maintenance as a word to include "Inspections and Overhaul". If all notes in the type certificate like this are not allowed then we can ignore them.

In all this it appears to be that you need to keep an electronic or paper copy of the original or pre 2011 update manuals to supply to your shop or mechanic.

If the airplane goes to a repair station and they reference or use a current manual subscription for inspection then the current Chapter 4 inspections would apply. Including the engine mount magnaflux.

It's the owners choice to use the older manual to get around this. And in this case for good reason.
But you need one to supply from Essco or similar if the shop only has electronic otherwise they are on the wrong revision.

It is interesting because since A/P school I have been told by FAA inspectors only the original or current manual was valid. Even my son said they were teaching the same thing 2 years ago when he was there. Yet it is not correct. And I have been told multiple times that once updated to a later revision you could not go back. This is also in question.
Lastly I have always been told Part 91 that you should sign off annuals or 100hr per FAR Part 43 appendix D because then you are covered if the manual was not updated.

In this case the earlier manual would need to be referenced to show what revision was used to avoid the unneeded inspections. But the T303 does not have an Annual or 100 Hr inspection checklist in the old manual or new. It only has the progressive care checklist for 50 hrs inspections to 200 hrs 1-4 and repeat.

Just to show the difference between manuals.

Early revision Chapter 4 vs current

The only twin Cessna I've really looked at is the T303 or perhaps a non-pressurized 335. I'll be in the market to buy an airplane in the near future and for a while my number 1 go to has been a nice E55 or maybe a 58. My main concern about the T303 is the parts/support angle...sounds like it isn't too bad at this point. Those with experience operating a T303 or even a 335...are they substantially more expensive to feed and care for than a Baron? Thanks!

I had a 303 for eight years. I loved it. Shortly after I got it, I put a large amount into it for optional upgrades (panel, interior, new engines, props, LEDs everywhere, and everything FWF). It didn’t need nearly as much as I put into it - but I really wanted a super clean and healthy plane.

The plan worked. the following 600 hours over 6 years were almost trouble free. I had put on lightweight starters during the big upgrade and then I went back to standard starters. Other than that, no real problems. And none of the problems we had were specific to a 303.

I don’t think I cancelled a flight during that period. And maintenance bills were minimal. At the very end, we had to chase an NLG shimmy. That was a pain. We ended up replacing everything that could possibly wear in the NLG collar area.

I loved the cabin, the short field capability, handling, looks, and reliability. I only sold it because my mission changed. About four months after I sold it, I was back looking for a decent cross country plane again. Oh well.

Good Luck.

Zeke