FAR23 types: Missed approach climb & flap extended

[Tinstaafl]

I work for a charter company operating predominantly FAR23 aircraft ranging from PA34s to PA31s to Kingairs + a couple of other piston things. We recently added a business jet to the fleet. With the exception of the jet, all of our aircraft are operated SP.

Our Director of Flight ops - who flies transport category aircraft in his alternate job - has decided that AEO missed approaches shall be flown with flap left in the approach position ie not full down but not to be retracted to 0 deg as part of the missed approach. His argument is that climb performance is at least sufficient AEO and relieves the pilot of the workload of retracting flap during a busy period of flight. He also wants to standardise procedures across the fleet especially now that we have the jet. This is what his other employer mandates across their fleet (all FAR25 types) and, he says, is common across all carriers now.

NB: In the case of OEI then we are to retract flap as per normal engine failure drills.

I'm rather concerned about this procedure for several reasons:

1. Climb performance is not charted in these FAR23 types with flap extended. The sole indication that climb would be adequate is that some of their POHs specify in the take-off charts that flap be left in the take-off position until the obstacle is cleared.

2. I consider being able to retract flap during a climb out or missed approach to be a reasonable competency for a pilot.

I can see his argument for reducing workload but believe that even if speed control is not quite as precise due to the configuration change, the desirability to gain as much height as possible as a buffer in case of engine failure is more important.

In other words I trade the slight reduction in workload in these normal ops/leaving approach flap extended for a greater buffer for the much less likely but *far more critical* engine failure case.

Am I barking up the wrong tree? Are my concerns insignificant w.r.t. the workload reduction *and* commonality of procedures across FAR23 & 25 types? I'd appreciate discussion & comments around this topic. Quite possibly I've not even considered something that is important for either argument so any & all input is welcome.

[LeadSled]

Tinstaafl,
Your DFO is in urgent need of the completion of his aviation education.
Rule (1) --- Comply with the recommendation of the POH/Flight Manual for each type.
Rule (2) --- Do not plan approach configurations and profiles for approach based on the unlikely case of a missed approach and engine failure, that leads to compromising 100% of approaches as stable approaches, to cater for about a 1 in 10 to the -4 or -5 event probability.
Sadly, lack of understanding of the factors in Rule (2) in Australia, both by "industry professionals", as is often the case,only so qualified by time, and far too many CASA inspectors with little or no real depth on knowledge of such matters, result in "new kids" being taught 100% unstable approaches in normal operations (min. "Blue line" to somewhere on final) to cater for a very, very remote possibility, really dumb ---- showing no understanding of proper risk analysis and management.
Remember, unless it is a FAR 23 aircraft certified to the "Commuter Amendment" a FAR 23 twin is certified as a single with twice the chance of engine failure.
Convince your DFO to standardise on the manufacturers recommendations, normal pilots are quite capable of coping with the variations between types.
FAA has some excellent literature that your DFO needs to read.
Tootle pip!!