HarryMann;
My pleasure as always.
"> ##" is to me a higher CG, so aft is what I meant...BUT, I see what you mean wrt the QRH and therefore it is open to interpretation and it shouldnt' be - may take it up. To me, ">39%" means further aft. If it means further forward, as a pilot I have to assume still, that there is "no risk, no danger" as there are no cautions/warnings.
I'm unsure of what the meaning of "unstable" is in a fbw design. As we both know, fighters are inherently unstable without fbw to reduce drag and increase maneuverability. The 330 is not nearly in that category of course but still, any instability, or flight control problem, (floating spoiler) or CG issue would be masked by the fbw response until the autoflight gave up due to being beyond it's design certification limits.
So "unstable" isn't something an Airbus pilot would be expected to handle/deal with except again, in jet upset conditions, then all bets...etc.
Re "not initiating", oh, ok - I had mis-understood, believing that some were considering an aft CG could have been an initiating item in heavy turbulence - sorry. In heavy turbulence the only caution is to slow down - Mach 0.78 to 0.80 or 280kts if I recall. Also, it is recommended to disconnect the autothrust to keep it from hunting the airspeed.
best,
PJ2