I've seen a lot of claims from shops and people saying it wouldn't cost that much. I think this is wrong and based on an incorrect understanding of what is in the SIDs.
The engine mount inspection alone is a major effort. It requires you to completely remove the engine and the engine mount, inspect it and then reassemble. That is a 2000-3000 € job alone and does no good because a lot can go wrong during this unnecessary disassembly and reassembly.
If a shop offers you to do it for a reasonable amount of money, be very very careful. If the shop fails to properly document the SIDs (I have seen reports from people that have something in the logbook like "completed SIDs" which is BS), you can do it again.
The German LBA are considering going in the opposite direction and declare them to be mandatory even though the EASA has publicly stated they are optional. If the LBA really manages to do that, I will most likely have to paint a new registration mark on my airframe. The SIDs are completely unnecessary if you know something about your aircraft and its state. When Cessnas start to fall apart by the dozens, I will be more receptive but before that happens, it's just Cessna lawyers' CYA.
What is interesting is to compare the letter from the CAA to the letter from the LBA section Hamburg (so not from the HQ).
CAA:
Cessna have published SIDs for its 100/200 series aircraft. They are not included in the airworthiness limitations sections of the Cessna Instructions for Continuing Airworthiness (ICA), and are not subject to any Airworthiness Directives. Therefore, Cessna SIDs for 100/200 series are not mandatory inspections from a regulatory point of view, even though they may be designated "mandatory" by Cessna.
2.3 Compliance with SIDs for Cessna series aircraft is recommended in line with the principles set out in Commission Regulation (EC)2042/2003, Part M, M.A.302 and the related AMCs (in particular Appendix I to AMC M.A.302 and AMC M.B.301(b) "Content of the Maintenance Programme", item 1.1.13a).
LBA (rough translation):
We inform you that these kind of documents, such as the SIDs from Cessna Aircraft Company, are applicable Instructions for Continuing Airworthiness by the type certificate holder according to M.A.401(b) of Part M of the Commission Regulation (EC) 2042/2003.
In addition to that, all continuing airworthiness documents according to M.A.401 (b) as part a continuing airworthiness instruction per M.A. 302 (g) of Part M of the Commission Regulation (EC) 2042/2003 are to be considered in the maintenance programs of the affected aircraft.
The problem with the CAA document is that it does not say anything that was not already true (because EASA said this months ago) and still leaves the potential for CAA surveyors to place their own interpretation on the SIDs...
What is needed is guidance how a private operator will record consideration of each task. The notice recommends involving the owner/operators CAMO. So, are we in a situation where CAA arrive, check records, decide the recording of the reasons for not adopting the recommended SIDs is insufficient and ground the aircraft?? If the CAMO is involved, who is the CAA going to hold responsible??
The only guidance that is required is to know if the private owner can simply say he does not want the SIDs carried out because they are not mandated.
But this is exactly what the CAA say. Note the "not mandatory inspections" and "compliance ... is recommended". How could the CAA be more explicit that you do not have to perform the SIDs? Of course they will say "recommended" because otherwise they would be discourage aircraft owners from performing a safety related inspection.
How could an inspector or whoever require you to perform the SIDs based on that CAA letter? I wished that letter came from the LBA, it couldn't be any better. If your CAMO/inspector says your Cessna is rusty and not airworthy, how does that relate to the SID? He can use the SID as a guideline to determine airworthiness of course and the course of action.
If the guidance was " you don't have to include what is not mandated under airworthiness limitations, etc", then it would be clear. But the letter goes on to say that the SIDs must be assessed, evaluated, CAMO's involved, etc.. And, as usual, the devil is in the detail. The CAA letter says that aircraft involved in CAT have to evaluate these as maintenance instructions. I have written maintenance programmes for CAT and trying to justify non-compliance with a recommended maintenance instruction can be very difficult, if not impossible. Some CAA surveyors apply the same standards to private aircraft and that's the problem. If a surveyor asks a private owner to justify why a SID has not been carried out, the answer "because it is only recommended" may not be acceptable. There is also a question of liability if the private owner involves a CAMO in the "decision-making process".
No, the CAA can't mandate that you include a SID on the basis of the CAA notice but someone could make it very difficult to go down that road - so difficult that it might be easier to carry out the SID.
Has anyone actually carried out the inspections (beyond any sensible checks for corrosion being carried out anyway)?
I know of a UK shop that took a 172 apart, engine, wings, the lot were removed. The owner was left with a $$$$$$$$$$$$$$$$$$$$$$$$$$$$$ worth of a bill.
The owner was left with a $$$$$$$$$$$$$$$$$$$$$$$$$$$$$ worth of a bill.
I bet!
More importantly, did they find anything?
I don't know. But if I go by the reputation of the guy who runs the shop the whole aircraft had to be replaced with a new one that he will sell you.
Interesting. I completed the full set of SIDs on a customers 300 series last year as we thought they were probably mandatory. Actually, when the wing spar attachments came off we found severe corrosion hidden behind them, so it was worthwhile, it did need doing. I’d say that replacement of those spar caps and the completion of all the SIDs nearly cost the owner more than the value of the aircraft due to parts no longer available from Cessna. At least 172/182 owners wont face that problem as their a/c are still in production.
No indication given as to whether SIDs are mandatory/recommended on 300 or 400 series? Would have been good if they had covered those a/c during this process.
CAMO is definitely taking some responsibility in this case if they disclude them from the maint program. But hey, that’s what they are paid for. Everyone in GA maintenance needs a pair, its inherently a more risky sector than working on pristine wide bodies :)
