This has been debated many times before with a range of views, transatlantic and EASA operators.
I wonder if it is reinterpreted against EASA’s IR-OPS there would be any revised views.
CAT.OP.MPA.300 “should not prevent a safe approach, landing or missed approach, having regard to the performance information contained in the operations manual.”
CAT.POL.A.100 requires the use of “approved performance standards that ensure a level of safety equivalent to that of the appropriate chapter.”
CAT.POL.A.105, “performance data contained in the AFM shall be used to determine compliance” This appears to contradict OP.MPA.300.
CAT.POL.A.230 Landing — dry runways
“The landing mass of the aeroplane determined in accordance with CAT.POL.A.105(a)” i.e. AFM. See conflict with MPA 300.
“ for turbo-jet powered aeroplanes, within 60 % of the landing distance available (LDA)” 1.67 factor
e) For dispatching the aeroplane. … the 1.67 above applies (note wet adjustment, 1.92, below).
CAT.POL.A.235 Landing — wet and contaminated runways
“(a) … may be wet, the LDA shall be at least 115 % of the required landing distance, determined in accordance with CAT.POL.A.230.” 1.92 factor
“… may be contaminated, the LDA shall be at least the landing distance determined in accordance with (a), or at least 115 % of the landing distance determined in accordance with approved contaminated landing distance data or equivalent, whichever is greater.” Methods for providing contaminated data are given in AMC CS 25.1591, recommended reading for the operational limits and assumptions.
Conclusions? Use AFM data unless there is specifically approved landing data is in the Ops Manual, (FCOM, QRH)
For takeoff use 1.67 / 1.92 based on the AFM.
For landing use AFM or alternative approved data which provides equivalent safety. Noting that most Ops Manual data allows credit for reverse, but it’s not clear how this can be related to the non-reverse AFM data to show equivalent safety, or how the 1.67 / 1.92 factors (CAT POL A 230) should be applied or not. One view is that the new Airbus (OLD/FOLD) performance, with more realistic landing distances, plus 15%, provides equivalence with the AFM; but is this factored or un-factored AFM data?
What do operators actually do?