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Genisis Dreaming
7th Mar 2012, 09:45
CAO 20.7.4 states that:

Where there is an approved foreign flight manual or a manufacturer’s data manual for an aeroplane that sets out the take-off distance required for that aeroplane, then that aeroplane must be operated so as to comply with either the requirements set out in paragraphs 6.1 and 6.2 or the requirements relating to take-off distance set out in either of those manuals.

Is it assumed that all (GA concerned only) aircraft not made in Australia have a foreign manual. Or will it be stated in the POH that CASA certifies it and I do not need to add the 15% take off and landing distance.

Thanks.

aussie027
7th Mar 2012, 11:30
G,
Does CASA still use the old P Charts for TKOF and LDG in light aircraft???
They had a safety factor % built in based on the aircraft's MTOW, that % scale IIRC is in a CAO concerning Performance.

IF that scale and mandatory safety buffer is no longer legally required by CAO or CAR then you can use the foreign flight manual charts if they are what is approved by CASA for that particular aircraft.

I would, from experience, however recommend retaining that safety buffer.
ALL those Performance charts are compiled by the manufacturers test pilots with brand new aircraft and new engines using the specified criteria on the chart.

Your technique would need to match those used exactly in order to get the stated figures, again with a brand new aircraft.

For eg, in light aircraft, the landing distance charts usually specify passing through 50' height at idle power, on speed, over the threshold. (ie a Glide Descent) This then often requires a more pronounced round out and flare than a flatter approach with some power on.
How do you normally do it, exactly like that???

Read those charts very carefully.

Even turboprop and jet aircraft engaged in commercial ops use a runway safety buffer, again they are stated in the CAO's.

Think carefully and fly smart and safe.:ok:

LeadSled
8th Mar 2012, 00:18
CAR 138
Pilot to comply with requirements etc of aircraft’s
flight manual etc
(1) If a flight manual has been issued for an Australian aircraft,
the pilot in command of the aircraft must comply with a
requirement, instruction, procedure or limitation concerning the
operation of the aircraft that is set out in the manual.
Penalty: 50 penalty units.

Folks,
What you are referring to is the AFM (Airplane Flight Manual) or equivalent, sometimes called a POH, Pilot Operating Handbook by some manufacturers.

CASA does not "approve"(certify) AFM/POH, and legally cannot direct you to operate contrary to the AFM/POH. If you want to amend the AFM/POH for your operation, you must have the agreement of the Type Certificate holder, which is defacto approval of the original state of certification.

As to the performance data, for T/O or landing, you need to know whether it is factored or not, for the aircraft in question, some are, some are not factored.

If you are operating an aircraft in AU on airwork/charter, look at the CAR/CAO/CAAPs/ CASA accepted Operations Manual for the AOC involved, factoring of un-factored data maybe/is required.

The old P Charts are no longer legally valid, and in any event, much of the T/O and landing data contained significant errors for some types.

Tootle pip!!

MakeItHappenCaptain
8th Mar 2012, 08:58
With all due respect,
If you still have the old CASA issued, typewritten, A5 and woefully inadequete flight manual, it most certainly is still legally binding and you must therefore apply the 15% (or more if MTOW exceeds the set limits). I believe CASA conducted their own flight testing on the aircraft to arrive at their data.

If you have the AFM/POH from the manufacturer, odds are it will be miles ahead in terms of detail and if it had been approved by CASA (in terms of you have notified them of the change in flight manual and they issue the approval sheet that specifies the exact document and is to be inserted in the front of the new flight manual) then you are permitted to utilise the data contained within without factoring. Be aware if ramped they will frown on retaining the CASA manual in the aircraft if you have a foreign manual approved.

There is a note (couldn't be bothered quoting it) that where there is a significant discrepancy, the foreign manual data should be treated with caution. Basically saying use worst case scenario, but not illegal to use best case.

As already stated, an ops manual may indeed require a greater margin than the manufacturer specifies and as always, if you are operating under that AoC, you are legally bound by it.

LeadSled
8th Mar 2012, 11:03
If you still have the old CASA issued, typewritten, A5 and woefully inadequete (sic) flight manual, it most certainly is still legally binding------

Makeithappen,
Sorry, whathappened is , that the legislation, under which the old Australian Black Books were issued was repealed in mid-1998, all said Australian Flight Manuals legally ceased to exist at that time.

--- and if it had been approved by CASA

Sorry, wrong again, see my previous post. Since mid-1998, CASA issue type acceptance for non-Australian type certified aircraft, ie; most of the aircraft in Australia, bar the few Australian built aircraft, and the AFM, by whatever name, is part of the type acceptance, CASA has no legal power to approve or disapprove an AFM, short of refusing to issue a type acceptance document.

An AFM is part of the certification of the aircraft, and like any other part of the details of type certification by another NAA, CASA has no power to unilaterally amend a type certification, except by issuing an Airworthiness Directive, and unique Australian ADs (except for AD/GEN) are now mercifully rare.


Tootle pip!!

PS:Re. Factors for un-factored performance, the only 15% I know is the (sometimes) optional +15% for wet runway accountability --- is this the 15% you are referring to, or are you confusing the old BCARs factoring?

thorn bird
8th Mar 2012, 18:27
Leadie,
you maintain that the AFM is the defining document for aircraft operation. What legal standing do these FCOM's or part B's CASA requires, where large portions of the AFM are to be cut and pasted, and manufactureres operating procedures altered generally on the direction of the CASA type expert of the day.
I've often wondered how we would stand with an insurance company if it was found we were operating contrary to the manufacturers procedures.
The FOI's of the day will insist on these changes but will never give a written direction, just not include the type on your AOC so CASA is off the hook.

Kharon
8th Mar 2012, 21:09
LS - As to the performance data, for T/O or landing, you need to know whether it is factored or not, for the aircraft in question, some are, some are not factored. Spot on. Refer CAO 20.7 (for your operation) if they are not factored. Be careful of using data, factors, speeds and performance numbers which are 'home made'.

TB - where large portions of the AFM are to be cut and pasted, and manufacturers operating procedures altered generally on the direction of the CASA type expert of the day. See a lot of this sort of thing around the traps – fraught with peril. It' s a question of fluffing up a manual to make it appear that the 'author' actually knows what's what. You also see a lot of 'band aid' material stuffed willy nilly into these manuals, usually to satisfy some 'expert' who decides that, for example, that the operator will nominate a 'standard fuel burn rate' for a turbine/jet aircraft.

It should a simple exercise in two paragraphs; 1 to 'annexe' the AFM to the operations manual; and 2, making the AFM procedures SOP, not optional. The rest is already contained within the AFM 'suite' so why duplicate it ?.

TB - I've often wondered how we would stand with an insurance company if it was found we were operating contrary to the manufacturers procedures. Assume this was a rhetorical question – you know full well the first bloke out will be the 'expert'. Some of these 'experts' can enter a revolving door behind you and leave ahead of you, it's an art form.

Charlie Foxtrot India
9th Mar 2012, 05:19
Last time I looked CASA exams still had those Cessna performance graphs where you went around the boxes rather than the real tables found in section 5 of the POH...

I've had this discussion at length with a CPL ATO who insisted on candidates adding the 15% factor on to figures in a Piper POH with CASA approval page or he would fail them...he wouldn't budge. :ugh:

I also blame the old AFMs for a lot of the old wives tales floating about and some of the "one size fits all" procedures that don't take the POH requirements into account, particularly cocnerning use of carb heat and electric fuel pumps....

LeadSled
9th Mar 2012, 06:43
CFI,
It's hard to teach and old dog new tricks.

This is a glaring example of what two ICAO audits and the recent FAA audits found, CASA's lack of internal training and standardization, and a lack of solid advisory material --- and the industry knowledge level is not too flash, either!!!

The legal position is clear and simple --- you are legally bound by the AFM, but culturally and individually far too many FOIs ( and there is no shortage of individuals in industry agreeing with them) that are, quite simply, years out of date.

In one instance, we have had to get a "strongly worded letter" from the US Type Certificate holder for the Metro, a CASA FOI was demanding "stall demonstrations" with the stall and attitude warning system/stick pusher deactivated. As a subsequent accident in Scandinavia has illustrated, and we have always known, the stall demonstration demanded by the CASA FOI would have almost certainly resulted in the loss of the aircraft and crew ---- and was strictly prohibited by the AFM ---- a fact the FOI refused to recognize.

Sadly, the C&T pilot who refused to accede to the direction of said FOI (he didn't wish to commit suicide) has effectively committed professional suicide ---- as so often happens with CASA, you can win the battle, but lose the war.

Can I suggest you take it up with the the Office of the Director, he doesn't believe his troops are doing anything but a great job.

Tootle pip!!

PS: It is so long since I have used a "Black Book", I don't remember where the 15% come in?
If you have un-factored AFM/POH data, it need careful though as to factors. For landing, in my opinion, 15% is cutting it too fine for most of us who are not test pilots, how about 50% plus.
After all, for FAR 25 aircraft ( and some FAR 23) the demonstrated landing field length is 60% of the length published in the AFM/POH.

Charlie Foxtrot India
11th Mar 2012, 04:30
There's another who won't let the candidates file a flight plan on NAIPS becaue they say it is "flight planning software" so the dudes have to send a fax! :\

MakeItHappenCaptain
11th Mar 2012, 06:19
Thanks, Leadsled.
Happy to bow to your experience.
My understanding was that some aircraft still posessing the old CASA manuals were the entire reason for the performance factoring in 20.7.4.
Will have to research the current standings a little further, obviously!
Although most a/c I fly these days have the manufacturer's manual, (and I do encourage these owners to get the manufacturer's document "approved", I still get a few AFRs in old Cherokees that still have the CASA document. Didn't realise they were illegal.

CAO 20.7.4

The 15% was a 1.15 factor applied to MTOW 2000kg or less, 1.25 for MTOW 3500 kg and interpolation on between (another 0.01 per 150 kg over 2000kg) for T/O distances.

Landing was 1.15 (2000kg MTOW) and 1.43 (4500kg MTOW) again with interpolation (approx 0.01 per kg over 2000kg).

Any of the CASA AFM charts (which were actually suprisingly easy to use compared to "add x% to ground roll for wet grass runways etc...) already had the relevant factor built in and stated in the conditions box.

Bear in mind that although the manufacturer's data may be with brand new aircraft, engine, prop etc., they are required to be derived (by the FAR's) with a pilot of "average skill". How advanced/average skill is determined, I don't know.:rolleyes:

Re wrong again, the "approval" I referred to, as stated, was limited to the approval page to be added to the flight manual, not CASA verifying the manufacturer is correct in terms of this information. Under no illusion about that aspect.

LeadSled
11th Mar 2012, 08:36
---the "approval" I referred to, as stated, was limited to the approval page to be added to the flight manual,Sorry 'bout the implication, but what I just love about such bureaucratic b----t, is the idea that such a page has any legal meaning, given CAR 138.
Just like manual pages that say ----- must comply with the Civil Aviation Act, Regulations and Orders ---- you mean I have a choice ----- unless said page is duly inserted, blessed, anointed and necessary incantations are uttered to "make it legal".

Tootle pip!!

CFI --- love the bit about the fax'd flightplan --- on the east coast, FOIs are "saying" manual flight plans are "policy", and objecting to JeppView and similar services ---- for jet aircraft.

They have even invented a magical new aircraft ---- for flight planning (even jets) that has a fixed rate of fuel flow, regardless of weight, cruise altitude, flight level, leaned or not, all based on something called "normal cruise".

'Tis even in Part 91 draft regulations, and being "enforced" now in Operations Manuals --- all to make "enforcement" easier at audit or ramp check time ---- unless you flight plan quotes exactly from the Ops. Manual ---- regardless of the actual conditions of the flight and actual fuel flows --- you have committed an offense.

Draft Part 91 does not contain any definition of this amazing new parameter --- Normal Cruise.

Ixixly
11th Mar 2012, 08:49
Unless it specifically states that all figures your using have the extra applied then do it IMHO, for example the C310 I fly has the original charts then right at the back it has CASA charts that specifically state in the bottom left hand corner they have had the safety factor applied.

MakeItHappenCaptain
11th Mar 2012, 11:14
Aha,
Perfect example of ideal vs. real world application.
You apply a 1.25% safety factor to, say, a Caravan (4000kg+ MTOW) and see how far you get with a strip that might be less than 700m long. You may be already weight limited on the take off, but apply 25% to the manufacturer's (already adequate) data and you can't operate at all.
Not good for continued employment.

Last time I got ramped, the FOI wasn't particularly happy about the CASA manual being in the aircraft with the manufacturer's POH at all.:=

LeadSled
14th Mar 2012, 03:08
----- the FOI wasn't particularly happy about the CASA manual being in the aircraft with the manufacturer's POH at all.

Makeithappen,
At least one FOI who was up to date, good to hear it!!
Tootle pip!!