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19 May 2022, 17:08 [ UTC - 5; DST ]


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 Post subject: Re: Aircraft inventory levels are critically low.
PostPosted: 30 Dec 2021, 12:03 
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Username Protected wrote:
They call it a life limit. I thought life limitations were mandatory regardless of the inspection program you are using.

It's not a life-limit. It's an MSB (Now part of the SID) requiring replacement of the spar-cap at 12,500 hours. According to Scott Dickey's post above, it will have a compliance cost of about $90K.

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 Post subject: Re: Aircraft inventory levels are critically low.
PostPosted: 30 Dec 2021, 18:33 
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Username Protected wrote:
They call it a life limit. I thought life limitations were mandatory regardless of the inspection program you are using.

It's not a life-limit. It's an MSB (Now part of the SID) requiring replacement of the spar-cap at 12,500 hours. According to Scott Dickey's post above, it will have a compliance cost of about $90K.


From the 425 TCDS: Wing, lower carry-thru main spar 12,500 Hours

Is that not the same "spar-cap'?

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 Post subject: Re: Aircraft inventory levels are critically low.
PostPosted: 31 Dec 2021, 10:30 
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Username Protected wrote:
From the 425 TCDS: Wing, lower carry-thru main spar 12,500 Hours

Is that not the same "spar-cap'?

Perhaps I misunderstood what you were implying. Yes, the spar-cap has a life-limit of 12,500 hours, not the entire airplane.

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 Post subject: Re: Aircraft inventory levels are critically low.
PostPosted: 31 Dec 2021, 10:55 
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Username Protected wrote:
I don't know of any conquest I's flying beyond 12,500 hours but theoretically if you made an election in the MX logs to stay with the previous version of the MM then the new version with the new phase would not apply to you and you could keep flying. That's my interpretation of how it works anyway.


But an election of a MM version just ties you to the non Chapter 4 inspections in that specific MM, right? Chapter 4 life limits if changed will still need to be abided by?


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 Post subject: Re: Aircraft inventory levels are critically low.
PostPosted: 31 Dec 2021, 13:33 
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Username Protected wrote:
But an election of a MM version just ties you to the non Chapter 4 inspections in that specific MM, right? Chapter 4 life limits if changed will still need to be abided by?

This is getting over my head. Perhaps someone else should answer your question.

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 Post subject: Re: Aircraft inventory levels are critically low.
PostPosted: 31 Dec 2021, 18:55 
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This all is over my pay grade as well concerning the 425 SIDS. However, when I bought mine in 2017 I had West Star do the SIDS which involved removing the wings, the tail, and both motors. They did the spar straps at my request. My bill was around $140k. I am sure it would be higher today.

See pictures of my disassembled 425:


Please login or Register for a free account via the link in the red bar above to download files.

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 Post subject: Re: Aircraft inventory levels are critically low.
PostPosted: 31 Dec 2021, 23:55 
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Username Protected wrote:
But an election of a MM version just ties you to the non Chapter 4 inspections in that specific MM, right? Chapter 4 life limits if changed will still need to be abided by?

I believe that once you elect an inspection program in the records, then you are not beholding to ANY changes to the MM after that point in time. To allow otherwise disagrees with the FAA counsel opinion on OEMs exercising rule making authority.

If the OEM updates chapter 4 (life limits), those changes may not apply to you UNLESS the life limits are further enforeced by AD or other FAA action.

Mike C.

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 Post subject: Re: Aircraft inventory levels are critically low.
PostPosted: 01 Jan 2022, 01:06 
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You must have paper copies of the MM because if you are on one view it automatically updates.


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 Post subject: Re: Aircraft inventory levels are critically low.
PostPosted: 01 Jan 2022, 09:52 
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Username Protected wrote:
You must have paper copies of the MM because if you are on one view it automatically updates.

Not if you capture the online MM to PDFs.

A bit tedious to do for Textron, but once done, a lot more convenient to manage if electronic form.

Mike C.

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 Post subject: Re: Aircraft inventory levels are critically low.
PostPosted: 01 Jan 2022, 09:58 
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Username Protected wrote:
But an election of a MM version just ties you to the non Chapter 4 inspections in that specific MM, right? Chapter 4 life limits if changed will still need to be abided by?

I believe that once you elect an inspection program in the records, then you are not beholding to ANY changes to the MM after that point in time. To allow otherwise disagrees with the FAA counsel opinion on OEMs exercising rule making authority.

If the OEM updates chapter 4 (life limits), those changes may not apply to you UNLESS the life limits are further enforeced by AD or other FAA action.

Mike C.


Mike, do you have reference to that legal opinion?

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 Post subject: Re: Aircraft inventory levels are critically low.
PostPosted: 01 Jan 2022, 10:21 
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Username Protected wrote:
But an election of a MM version just ties you to the non Chapter 4 inspections in that specific MM, right? Chapter 4 life limits if changed will still need to be abided by?

I believe that once you elect an inspection program in the records, then you are not beholding to ANY changes to the MM after that point in time. To allow otherwise disagrees with the FAA counsel opinion on OEMs exercising rule making authority.

If the OEM updates chapter 4 (life limits), those changes may not apply to you UNLESS the life limits are further enforeced by AD or other FAA action.

Mike C.


I don't agree about Chapter 4. The life limits in Chapter 4 and the TCDS are FAA Approved. The rest of the MM (including the inspection intervals) is not approved, just accepted by the FAA. So any changes in Chapter 4 constitute FAA action.

For any approved FAA inspection program, 91.409(e) says:

"No person may operate a large airplane, turbojet multiengine airplane, turbopropeller-powered multiengine airplane, or turbine-powered rotorcraft unless the replacement times for life-limited parts specified in the aircraft specifications, type data sheets, or other documents approved by the Administrator are complied with"

So I see how electing an inspection program protects you against changes by the mfr to inspections additions and changes in subsequent MM revisions, but I don't see anything that lets you ignore life limits.

But if you have a reference to a legal opinion that supports your understanding it would change my mind. I bet any legal opinion is going to refer to changes in Chapter 5 inspections, not FAA Approved life limits.

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 Post subject: Re: Aircraft inventory levels are critically low.
PostPosted: 01 Jan 2022, 17:34 
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Terry, maybe Mike is referring to the Williams interpretation. But see the later Stroik interpretation.

https://www.faa.gov/about/office_org/he ... tation.pdf

https://www.faa.gov/about/office_org/he ... tation.pdf

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 Post subject: Re: Aircraft inventory levels are critically low.
PostPosted: 01 Jan 2022, 17:50 
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Username Protected wrote:
Terry, maybe Mike is referring to the Williams interpretation. But see the later Stroik interpretation.

https://www.faa.gov/about/office_org/he ... tation.pdf

https://www.faa.gov/about/office_org/he ... tation.pdf


The Williams opinion says the TCDS references the unapproved MM so operators are not bound to follow it. Stroik says Williams isn't relevant since they are Part 135 and have to follow what their program says.

Neither of these addresses life limits in the TCDS or an FAA approved limitations section of the MM.


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 Post subject: Re: Aircraft inventory levels are critically low.
PostPosted: 01 Jan 2022, 22:15 
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Username Protected wrote:
I don't agree about Chapter 4. The life limits in Chapter 4 and the TCDS are FAA Approved.

I believe you are correct. Chapter 4 is FAA approved, nothing else in the MM is.

The statement in my 560 MM in chapter 4 is:

"The Airworthiness Limitations section is FAA-approved and gives inspections and maintenance procedures that are required by Parts 43.16 and 91.409 of Title 14 of the Code of Federal Regulations, unless an alternative program has been FAA-approved."

Quote:
So any changes in Chapter 4 constitute FAA action.

Seems so.

I didn't realize Chapter 4 had a different approval process than the rest of the MM.

Mike C.

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 Post subject: Re: Aircraft inventory levels are critically low.
PostPosted: 04 Jan 2022, 21:58 
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Thanks Terry!

Not many folks get Mike C. to admit he was wrong!

Thanks Mike for your humility.

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It's not so much what we do not know, it's that much of what we are being told just isn't so.


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