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This is in response to your August 25,2008, request for a legal interpretation on the use of the phrase "current maintenance instructions." Your request, including the factual circumstances contained in associated background materials accompanying the request, is premised on 14 C.F.R. § 91.409(£)(3), which uses the phrase "current inspection program."...
Larry Furnas Aviation Attorney's Response to the SID's
Supplemental Inspection Documents play an important role in aviation safety when utilized in the proper manner. A successful SID program assures continued airworthiness in the most economical manner and comes about as the result of a free flow of information between the operators, the FAA and the original equipment manufacturer.
FAA's Response to Interpretation of 14 C.F.R. 91.409(f)(3)
Background: There are two recent examples of manufacturers’ updating maintenance/inspection instructions to include new inspections and new inspection thresholds. Cessna developed a completely new structural inspection program, while Gulfstream reduced an inspection threshold by one half. The Federal Aviation Administration (FAA) has not issued an Airworthiness Directive (AD) that would make these inspections mandatory.
Larry Furnas Aviation Attorney's Response to the FAA
Please let me
introduce myself. I am an aviation attorney representing several owners of
Conquest aircraft that are deeply concerned about the SID program adopted by
Cessna and your interpretation of it being mandatory in your Info Memorandum if
the owner had not selected a maintenance program in their maintenance log prior
to August 31, 2007.
I have just a few
questions concerning this interpretation...
I have still not
heard back from the FAA re my questions but would appreciate if you would place
on your Conquest owners website a caveat that states that "Larry D Furnas
strongly recommends that each owner review their decision with their attorney,
insurance carrier, consider the aircraft total time and corrosion history, and
the type of operation the aircraft is being utilized to perform, before making
any final decision on the SID Inspection".
Mike, I make this
request since neither the FAA nor Cessna has responded to our questions and
numerous owners have contacted me direct saying they agree and are not going to
submit their aircraft to such an intrusive inspection, but without doing the
above statement, some attempts to apply liability could occur should someone
have an incident.
Should you have any
questions, please give me a call.
Larry D Furnas
Attorney at Law,
Aviation Advocates, LLC
O. Box 17007
Indianapolis, IN 46217
From: Steve Frost Sent: Tuesday, July 14, 2009 11:22 AM To: Richard Bacon; Leo Toews Subject: Re: FAA "Info" document
Well, I hope someone can enlighten me as to how to
interpret the FAA's attempt to get the Genie back into the bottle after the
legal interpretation of 91.409(f) was released.
I certainly agree with the sentiment contained in
InFO but, I have no idea what weight it bears. I have not seen an InFO notice
before, it is not a rule, it is not a supplement to the FAA Inspectors
handbook, as much as I much as I would like this to be the gospel, I do not
think it carries the weight of a legal interpretation of the rule and as such I
must assume it is ADVISORY ONLY and one way of complying with the rule.
As for the owner operator of the aircraft selecting
and identifying an inspection program and stating it in the aircraft records,
this is a rule that has been overlooked for decades, short of a few Part 135
operators that have written a AAIP this statement is rarely seen. I
am informing my customers about this need as we see them and their records. If
they have not selected a program they must do so and in as much as the legal
interpretation of 91.409(f) may certainly change how they select their
inspection program, I do not feel they could be held liable to
incorporate a program they felt they must use due to everyone's apparent
erroneous earlier interpretation of this rule.
As a part 145 repair facility, I have a need to
know what to advise my customers, InFO, I believe was an attempt to clarify
this but, I need someone in the FAA to tell me that the information in this
document is THE RULE, I question this.
Corporate Air Technology
----- Original Message -----
To: Leo Toews
Sent: Tuesday, July 14, 2009 8:43
Subject: Re: FAA "Info"
Thank you for the attached e-mail.
The reason a Conquest may be a candidate for
a Inspection Program that includes a SID extension is because it is a very low
time aircraft and no significant corrosion history. It is important
to remember that these qualifiers simply make the aircraft a candidate.
The additional factors that Gregg mentions: landing cycles, location of
operations, and lost records will be explored and weighed in the decision
of whether or not to allow the extension of the SID. Some of the other
important factors are: where the operator will be operating the aircraft, how
many hours (and cycles) per year will the aircraft be used, what type of
operations (past and future), hangar (history, current and future)
(enclosed, temperature controlled), maintenance history,
physical examination of the aircraft, and maintenance log review.
As you know, the SID is not an AD.
The owner/operator of a qualified aircraft has the
choice of applying for a Inspection Program that includes the SID, but extends
only the yearly deadline based upon the history, the condition, and the future
usage of the aircraft.
The SID inspections are quite invasive and this
needs to be considered in the decision.
Additionally, buy extending the yearly deadline of
the SID, it gives the owner/operator the ability to incorporate portions of the
SID at logical times during the continued maintenance of the Aircraft.
(When replacing boots, is the logical time to inspect under the boots)
(When changing engines is the logical time to inspect areas
requiring removal of the engines)
I would hope we would work together to create
Inspection Programs that are logical and the best overall programs for the
On Jul 8,
2009, at 5:08 PM, Leo Toews wrote:
I too have talked with Rusty a couple of times and
asked very specific to the point questions. I believe Richard’s
statements are factual but there is more. When I asked Rusty how someone
in the FAA could approve an inspection program that doubles the manufacturers
initial compliance time from 20 years to 40 years without any testing or
analysis he told me the FAA has no control over the FSDOs or individual inspectors
and some may approve things he wouldn’t necessarily approve. It is up to
the local FSDO where the aircraft is based to approve the program.
Following is a quote from the Fresno FSDO office regarding Mr. Bacon’s letter
dated June 17, 2009:
This is just one side of the story. If FAA has
agreed to the items mentioned, he should request some sort of written document
so that it may be included as a part of the inspection program. How and
who will determine what a low time/low corrosion airplane is. How about
landing cycles, foreign country operations, lost records or funny looking
wrinkles in the skin. This is going to be a difficult subject for some
time yet. I still do not understand the last InFo that explained the
Not sure the info was correct or useable. More will have to
come from AFS-300/320 before I will have anything to do with a (f)(4)
inspection program. To many variables at this time.
Feel free to respond,
From:Richard Bacon Sent:Thursday, July 02,
2009 9:04 AM To:Richard Jaffe; Subject:FAA
Many owners of Conquests are taking the position that
they are not required to do the SID because of the legal memorandum dated
Rusty Jones, FAA Manager, Special Programs Branch,
AFS-320 issued a Information for Operators (InfO) document on 5/22/09.
There continues to be misunderstandings on whether or
not Conquest owners can simply choose to not do the SID.
I just spoke to Rusty Jones, the author of the FAA
"Info" document on SID inspections. The conversation was
lengthy and detailed. The FAA's position is:
1)A Conquest owner
must do the SID if their last Inspection was after August 31, 2007 (the day
before the SID was issued). The exception will be: if before that date,
in the aircraft maintenance records, the owner selected an approved inspection
program other than the current Manufacturer's inspection program.
2)If no inspection program was selected
as required in 91.409(e&f) then the "current" Manufacturer's
inspection program, at the time of the last inspection is controlling.
The bottom line is: the great majority of Conquest
owners did not select (written in the a/c maintenance records) an inspection
program other than the current Manufacturers inspection program.
And, the great majority of Conquest owners last inspection was
after August 31, 2007. Therefore, the great majority of Conquest
owners are required to do the SID inspections.
3)I further clarified that the
Inspection Program I am suggesting, which includes the SID inspections, but
delays the SID inspections due to the low time and low corrosion, is a
valid inspection option for low time, low corrosion Conquests.
Rusty is being included in this mailing, if anything I
have stated is not 100% accurate, please respond to all parties.
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