Part 135 SID...SB's and AAIP

[((7))]

How hard is it to develop a AAIP for a single pilot/single plane 135 Certificate? Spoken with 3 IA's and it is still a mystery. I have no problem bringing the airplane into Conformity per the Manufactures MX Manual but if I state upon the Compliance Statement that Cessna Service Manual will be used for maintenance scheduling will this preclude the company from using a AAIP in the near future? The FSDO is as clear as mud on this issue. It is a large road block at this time. The expenses in the near future with proposed SID's could cause the effort to obtain a Certificate meaningless. If I construct a AAIP is it normal to omit SID compliance along with non compliance with SB's? Seems hard to believe this is true.

 

[erj-145mech]

In all likely hood, the FSDO will not approve the AAIP without SB compliance.

 

[ProFracPilot]

I assume you're dealing with a turbine powered aircraft. In my experience, you can use the manufacturer's chapter 5 inspection program as the BASIS for YOUR AAIP, but you will have to construct it yourself. Engine inspection requirements will have to be a part of this, generated from the engine manufacturer's chapter 5, not the airframe manufacturer. Also, continued airworthiness / structural inspections will likely have to be incorporated into YOUR AAIP.

Don't let them box you in on the S.B. issue. The problem with S.B.'s is that some manufacturer's will identify them as being mandatory, when in actuality a particular bulletin may only a product improvement - as opposed to a bulletin written to correct an airworthiness issue. I've stood my ground with more than one FSDO on this issue and won each time. The only thing MANDATORY, other than life limits, are A.D.'s.

Unfortunately, there are NO standards in Flight "Standards" District Offices - especially when it comes to AAIP's. Develop a good relationship with your PMI, POI AND the office manager. Chances are they'll work with you as much as they can. Good luck.

 

[((7))]

No this particular subject relates to a light twin. Day, VFR. A few Cessna Gurus state that there is no need to raise any questions about the coming SID for my aircraft. They state that the SID will not apply to "most" twin Cessna operators because they have a AAIP in place which will allow them to ignore the SID requirements. The SID cost to perform will easily exceed the value of the aircraft. I'm in Phase I writing the Compliance statement and need to know, do I declare a AAIP in the Compliance statement? Once this is done do I argue my case from there with the FSDO? I'm leary to breach too many points with the FSDO on this. I have ample financial resources but there comes a time to not throw good money after bad. I'm not trying to avoid the SID per say. Some sections of the proposed SID as written at this point are very invasive to the airframe and do more harm than good in a lot of professional engineers opinions. The Non factory Cessna Gurus are selling the no problem approach useing the AAIP as a non compliance ability. I don't think that will fly with any FSDO. Does anyone know a FSDO which will go along with SID non compliance for a Part 135 operator using the AAIP as a non compliance instrument?

 

[avbug]

That SID wouldn't by any chance be for a Cessna 337, would it?

 

[((7))]

Yes it is coming for the C337 series. Cessna has it now after a comment dialogue with part 91 operators and selected Part 135. Cessna gurus state that there is no worry. Your AAIP will preclude "most" operators from compliance. My fledgling company (singlepilot/single plane) (Non USFS contract work) in Phase 1 of Part 135 Certification is being hit broadside with this. I have a compliant aircraft per Cessna Service Manual. Calender and time and most S.B.'s. Trying to do it right but with the coming 28point SID it is a large question mark. Have not breached the subject with the FSDO yet. Just started Phase 1 have compliance statement ready but still not sure of course of action. Not sure if I could construct and apply for a AAIP in Compliance Statement right from the start. I'm not trying to avoid SID compliance but just desire the same as other contractors or a little time to get the company generating revenue.

 

[avbug]

The SID(s) to which you refer don't exist yet. The Skymaster Owners and Pilots Association just submitted a 38 page brief to the FAA, addressing every point in detail...but no documents will be forthcoming from the FAA until next year.

You can get a copy of the SOAPA's statement by emailing [email protected] , and Larry Bowdish will forward the 38 page report.

The idea behind an AAIP is that you write it. You can do just about anything you want, so long as all the necessary mx and inspections are done.

If you have an existing program and additional inspections become necessary, then you can always revise.

So far as what's mandatory and what's not...many manufacturers will attempt to create "mandatory" SB's and mandatory inspections. Until they petition the FAA to make it a regulatory requirement as an Airworthy Directive...they can call it "mandatory" all they like and it isn't. Simply because the manufacturer states it's "mandatory" doesn't make it so.

Many "mandatory" SB's and inspections are the manufacturers way of trying to protect themselves with some liability insulation. The FAA's position is that the manufacturer must submit documentation to the FAA for approval, and in the case of a manufacturer adding requirements after documentation has been approved, it's not mandatory unless they're willing to seek an AD.

The manufacturer in turn is seldom willing to seek an AD because that can have a negative impact on sales, as well as hurt the reputation of the manufacturer.

You've got a ways to go before you need to submit an AAIP, if you're just to the compliance statement.