I have it in writing from an operator I know, straight from the FAA, that the gear overhaul for part 91 on US register is not mandatory. This is a huge savings for part 91 operators of this aircraft:
Andy,
I am going to assume they are operating Part 91. AS such they are only recommended to follow the manufacturer’s chapter 5 . This also matches the FAA legal interpretations. If it were in chapter 4 they might also be required to overhaul, but in this case they are not required, only recommended.
It would be different if they were air carrier , 135 or 121.
John Thomas
Aviation Safety Inspector/Airworthiness
Will Rogers FSDO, SW-15
Ph. 405-951-4220, Fax 405-951-4282