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Mechanics and Maintenance Shops

Fuel System vs TCDS
Author Last Post
The larger tanks should be shown on the mfg's equipment list.

Order 8620.2A


Consistent with 14 CFR, aTCDSis part of a product’s type
certificate (TC). ATCDSis a summary of the product’s type design. It is used primarily by authorized persons
during initial or recurrent issuance of a Standard Airworthiness Certificate. It is neither a
regulation, a maintenance requirements document,
or a flight manual document. As such, for aircraft holding a valid and current airworthiness certificate, aTCDS
should not be used as a sole source to determine what maintenance is required or what the flight operations requirements are.
Any language on aTCDS, by itself, is not regulatory and is simply not enforceable. There must be a corresponding rule to make any language on theTCDSmandatory. For example, there is a mention of “operating limitations” on most
TCDS. The corresponding rule for “operating limitations” is 14 CFR § 91.9(a) which states, “Except as provided in paragraph (d) of this section, no person may operate a civil aircraft without complying with the operating limitations
specified in the approved Airplane or Rotorcraft Flight Manual, markings, and placards, or asotherwise prescribed by the certificating authority of the country of registry.” Without § 91.9, theTCDSrequirement to comply with operating limitations would not be enforceable.
This was also posted on the CPA website.  Anyone with a 185 thru E model with long range tanks?  The TCDS only lists a 65 gallon system.  How are your IAs indicating conformity with TCDS 3A24 Rev 39?   Cessna and the FAA have not been much help.
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