Flight Manuals

[Wheeler]

Well, its almost August 16.

Has everyone purchased their nice shiny new ($400?) Flight Manuals?

So now its absolutely certain we will have Flight Manuals that comply with the new CASA regs and the CAO's.....

We are still waiting for the front pages from CASA having applied for them many weeks ago, but absolutely certain they will arrive in time. After all, it was their wonderful idea and it is inconceivable they would not put in place the administrative processes to support it.

Any interesting experiences to share on this one?:( :D :D :confused:

[triadic]

What a load of Cr@p.

It is costing me (havn't paid yet!) around $300 for a new "approved" flight manual that is not applicable to my aeroplane! And with less info in it to boot!

Tell me the safety and cost benefit of that??

What does the 6 months grace mean? .... the rule should be scrapped.

[T]

Most Cessna's (even twins) don't need an AFM since they were certified without AFM, placards on panel and airframe suffice along with 6.2 weight and balance data from aircraft actual weight.
So knock your selves out, point at end of runway and launch, you won't know if you are safe or not, no data must be safe ??????

[djpil]

The biggest issue with flight manuals is the internal disconnect within CASA. From CAAP 54-1(2) "all aircraft must have the approved information necessary for the safe operation of the aircraft ...... The form and content of the information is that accepted and approved by the relevant NAA ..".

CAO 20.7.4 (and others in that series) require additional information to be supplied by the CofR holder. The whole philosophy of these CAO's is inconsistent with the use of the AFM/POH from the country of origin. It is impossible to comply with CAO 20.7.4 as it requires data per CAO 101.22 which was cancelled several years ago. The CAAP suggests that the data may be placed "in a convenient folder available to the pilot".
From the definition in CAAP 54-1(2) above - information for the safe operation of the aircraft is either in the AFM/POH or its not required full stop. The data required by CAO 20.7.4 should really be in a CASA approved supplement but that would mean replicating most of the old CASA AFM. The CAAP touches upon this subject in para 4.8.2.
"e.g. weight limitation for runway performance, requires approval by the authority, but is not required to be an AFM supplement, if the basic performance as detailed in the AFM can still be achieved." The later CASA guide to the new flight manuals doesn't address this subject. Even a Cessna 150 can't meet CAO 20.7.4 with the original AFM performance data. I would like to see a CASA example of a complete package meeting all of their requirements for a Cessna 150 then we can start discussing more complex airplanes.

From samples of new flight manuals that I've seen recently I'm quite sure that very few people in industry or CASA really understand the new rules of the game.

The second biggest issue is the question of retrospectivity. My aeroplane has been quite happy for the last 23 years with the old CASA flight manual. Why the need for change over for old aeroplanes if there's no other reason to amend the flight manual?

[john_tullamarine]

Hang on a bit, there, Pilks ..... you are starting to sound rational ... in discussing an irrational subject .....

damned if I can work out how people are going to approach some of the odds and ends which have fallen through the cracks ...

so far no-one has asked me to do a flight manual job ....

regards ....

[ulm]

Gee.

And isn't Airsafety Australia (aka Boyd) helping????? :confused: :confused:

Put youself in CASA's position (or the Minister for that matter).

AOPA says 'hey c'mon CASA, no one can work this new manual stuff out it time give us a break'

CASA says 'Oh OK then, we will try to be a good guy'

Boyd says "whack, aha, conspiracy, etc etc etc" and shoots out a whingeogram.

GOOD ONE!!! :mad:

You think the minister is gonna listen,...... complain when its bad, complain more when it's good. You think CASA is ever gonna try be the good guy again if they get whacked for it when they do.

DOH!!!!!! :rolleyes:

Sometimes some people might be the full six pack but lack the little plastic thingy keeping it all together!!!!! :D

[john_tullamarine]

Ulm,

Not too sure what your reference to Boyd might be ...

Pilks and I are being quite serious here .... and this sort of thing is in our line of business ...

CASA's desire to get out of the flight manuals business is not the problem ... there are many cogent reasons for the regulator to do so in respect of the majority of aircraft manuals.

We just have some concern that the procedure might well have been implemented differently and with a little more flexibility ...

Just an opinion, of course ....

[snarek]

I think Ulm's point is that Boyd's fax isn't helping.

A number of owners expressed concerns over getting the manuals in time, AOPA talked to CASA, CASA came to the party.

Continually bashing even when CASA help isn't productive.

AK

[Wheeler]

What do we do for p charts etc? The new manuals don't have any at all. Just simple tables that don't seem to cover half of the possible things a pilot might encounter. Do we need p charts to be legal?

It doesn't really matter I spose. Grant tells me he is far to busy to get on with this stuff anyway!

I reckon Boyd might have a point.

I wonder where the 'legal responsibilities of of CoR holders' will leave us if the baloon really goes up on this one - even if CASA say they will not enforce the law until a certain date.

[antechinus]

Mr Munro is miffed because AOPA did the sensible thing and negotiated a moratorium with CASA and stole his thunder.
In any event, Mr Munro does not have the ear of CASA or the Government so any grandstanding by himself or his disciples would be wasted.

The cost and difficulty in getting manuals out of the US aircraft manufcaturers is a serious problem. Perhaps CASA should have done a bulk deal with the manufacturers to get this sorted.

[john_tullamarine]

Wheeler,

You have identified one of the practical problems .... historically, Australian light aircraft manuals have put into the manuals the operational restrictions which the operator is responsible for in the US.

Whatever US manual you get for the new requirements is fine ... but you ought to give some consideration as to what safety fudge factors you might wish to apply in the real world use of the POH numbers ... if you still have the old P charts, there is nothing to stop your using them provided that they are conservative with respect to the US manuals ... as they almost always will be.

This is even a concern with the heavy manuals where the US practice is to present, for instance, landing data unfactored and then rely on, for example, 121 requirements to cause the operator to adopt the conventional fudge factors ....

Many traps for Australian players over the next few years until we have a few prangs and the message starts to filter through ..... suggest that people advance with caution in the matter of using US POH data ... the old paternalistic days of the Australian regulator's looking after us are GONE ..... we are now moving into the big bad real world where you are, to a large extent .... on your own.

One of the major concerns I have is in regard to the typical lightie pilot who routinely flys out of a nice long runway at, say, Moorabbin or Bankstown and then heads off bush and is faced with a critical landing/takeoff at a bush ALA or paddock ..... this is where mindless and uncritical use of the US data is going to bite and bite hard ...

It will be better when the harmonisation regulatory process catches up with itself ... if it ever does ..... but, at present, there are more than a few holes in the setup ..... please do be careful and cautious out there, good people ...

[PLovett]

Dear PPRuNe'rs

I put this forward as an idea and if I have completely misunderstood what is happening, please only throw food or money. I still have to live.

It would appear that what CASA is doing is absolving itself of any responsibility if someone has an incident/accident whilst using one of their modified p charts in a flight manual. :mad:

CASA would appear to have a history of disclaiming any responsibility for anything that may occur whilst an operator is complying with a CASA requirement. There is a strong argument that there is an abuse of legislative power in all of this.:mad:

[john_tullamarine]

... you have an accident ..... by definition you bear the greatest part of the responsibility (unless someone sneaks up behind you or you score some military ordnance in an area where it ought not to be ... then just depends on how innovative your mouthpiece is ....

[Blue Hauler]

John T,

'…but you ought to give some consideration as to what safety fudge factors you might wish to apply in the real world use of the POH numbers…'

If one considers the take-off requirements contained in the AFM and follows the appropriate instructions and orders I believe the solution is already before us. The C208B AFM for example tabulates the T/O Distance (GRD ROLL FT and TOTAL FEET TO CLEAR 50FT OBS) for a paved, level, dry runway – zero wind. The notes express percentage factors for headwind, tailwind, dry grass runway, and use of the inertial separator. If the final figure is then factored 1.25 as prescribed in CAO 20.7.4 surely no further fudge factors should be required.

[I Fly]

CAO 20.7.4 also requires take-off and landing climb weight limits. I have just paid $ 491.06 for my brand new manual that looks very much like the $70.00 one I bought a couple of years ago. It only tells me what the max. Rate of climb is at MTOW at different height and temperatures. No way of working out what weight reduction I need to calculate the 6% or 3.2%. Some month ago I hand delivered a letter to Mike Toller requesting information on how to calculate. Eventually I got a letter back stating I could sent my old CASA P Charts to CASA for their acceptance and then incorporate them in the new Manual. And then get that approved by CASA. The 'old FM' already referred to the POH for a lot of things. When this mess first got mooted I understood that the C of R holder could decide on what manual s/he would keep, as long as ALL the safety information was there. I thought I could keep my old FM in conjunction with the POH. Somewhere the story changed and now I am NOT ALLOWED to keep the old FM but should / must incorporate data from it into the new manual. In addition CASA stated that when the new Part 91 replaces CAO 20.7.4 only the POH information will be necessary. Will they change the aerodrome design criteria and only permit flat country around an airport? Do the hills know they will have to move?
I'd be interested to hear how our cousins in the US calculate this.

[djpil]

That's a very important letter that you have from CASA, I Fly. I'd like to get a copy.
I actually enjoyed calculating the climb gradients for my airplane - the good news was that mine complied with CAO 20.7.4.

I wonder what response I'd get if I followed that letter up asking for exact instructions on how to do a Cessna 150 AFM under the new rules. I bet that, even if I got a straight answer, it would be a lot different than the way it's being practiced.

[john_tullamarine]

The problem with the standard US manuals is that they have no interest in the CAOs and generally present unfactored (ie raw distance) data .... the next problem is that the average punter has difficulty in knowing just what the status is for the particular manual which he/she might pick up from the flying school ...

I can only suggest a degree of conservatism chaps ... lest you be called to account for your calculations at the subsequent enquiry ... which hopefully won't be a coronial ...

[gaunty]

john_t

You don't happen to have any of the old "P"charts for the DC3, 4, 6 or 7 and perhaps the Lockheed 1049.

There must have been one for the Viscount and Electra too ?? ;)

[john_tullamarine]

Gaunty,

I certainly have somewhere under the dustpiles and assorted detritus DC3 and probably DC4 charts ... pity I never finished the 3 endorsement ... at one stage I was hoping to do a 2 endorsement ...... all a fading memory now ....

The Connie guys at Bankstown probably have some data for their bird ...

The "Goose" was a bit later on in the certification system and had more conventional data ... I probably still have some of my AN ops manual data somewhere ... or are you talking the really old Electra ? ...

I would be very surprised if Centaurus didn't have some Viscount data .. he flew them for some time when he was in the RAAF as I recall ... and he is a wonderful source for data on just about any pilot type subject you can think of ....

[HarveyGee]

Blue Hauler

It is with some trepidation that I question your interpretation of 20.7.4, my good friend, but the way I read it you don't have to apply the 1.25 factor to the manufacturer's data - it's a one thing or the other type rule.

djpil

I doubt that the intention is that everybody has to calculate climb perfomance data to comply with 20.7.4. I believe that is a certification requirement, so it would be a surprise if your aircraft did not comply. In other words, if it achieves Aust certification, you can take it as read that it meets these requirements. Can anyone confirm this?

[Blue Hauler]

Harvey Gee,

It is with some trepidation that I question your interpretation of 20.7.4, my good friend, but the way I read it you don't have to apply the 1.25 factor to the manufacturer's data - it's a one thing or the other type rule.

I stand corrected and thank-you for pointing that out to me. CAO 20.7.4 (6.1) clearly applies the factor to actuals; (6.3) allows the use of AFM data without the need to factor. I knew that – I just misplaced the information and re-programmed with faulty data!!! I guess that comes with old age.

[djpil]

HarveyGee's questions
I doubt that the intention is that everybody has to calculate climb perfomance data to comply with 20.7.4. I believe that is a certification requirement, so it would be a surprise if your aircraft did not comply. In other words, if it achieves Aust certification, you can take it as read that it meets these requirements. Can anyone confirm this?
________________________

With the demise of CAO 101.22 those special Australian certification requirements have gone. They remain as operational requirements in CAO 20.7.4.
When I said that my airplane complied I meant, for example, that using the USA AFM data it could achieve 6% climb gradient in take-off configuration at take-off safety speed at all altitudes quoted in the take-off chart.
Many airplanes are weight limited on take-off if needed to comply with CAO 20.7.4 climb gradients, the Cessna 150 being a good, simple example. Test question: when can you use flaps for take-off under the new rules? Of course, we don't all have to calculate climb performance - we simply use the old Australian P charts, so what have we achieved? The issue is that these P charts are no longer in the Flight Manual (read previous posts now). And, its not just the P Charts themselves - look for references to other sections of the old flight manual which must also be provided.

In my own case I saw that the Australian P charts had a take-off safety speed of 58 kts cf the USA chart of 52 kts. (still gives more than 1.2Vs). Do I need to submit a report to CASA to show that the USA AFM complies with CAO 20.7.4? No fancy calculations, can almost do it in my head from the info in the USA AFM but its a bit beyond the normal flight performance sums expected of a pilot.

Turn the question around now. USA chart has a take-off distance of 370 m to 50 ft. The P chart gives 425 m. The 1.15 factor explains that, or does it? The USA AFM is for a sealed surface and correction to grass surface adds a bit. My quick sums suggest an extra 50 m to accelerate that extra 6 kts. Climb gradient - not much in it between 52 and 58 kts. So it beats me how CASA's predecessor came up with that P chart - 430 m from them vs 500 m or so from me. Maybe the USA AFM data is very conservative (a later story as I also have test data). As a CofR holder I'm certainly not going to provide P Charts under my own authority without substantiating data.

This example is not the only one I've got doubts about. Don't assume that the locally produced P Charts are more conservative than the manufacturer's data even with that fudge factor.

[gaunty]

Dave

I'm happy to stand corrected, but if I recall it correctly the old DCA "P" chart data was actually derived from data "flown" by or under the supervsison of the DCA and paid for by the manufacturer and/or his local representative.
The manufacturers data was ignored, presumably on the basis that the air was different in the US, :rolleyes: but certainly on the premise that the information was for "sales" purposes and therefore not to be trusted. :rolleyes:

This information and the copyright was "owned" by the manufacturer or whoever had paid for it and it was required to be included in the AFM for the new aircraft wjen it was put on the OZ register.

What that meant was if you tried to broker an aircraft into the country from other than the factory representative the only way you could get an Oz AFM was by buying a license for it from the copyright owner, the factory representative.
You could photocopy the info from another AFM to get it registered but that was a breach of copyright and therefore could not be accepted by the DCA therefore no rego, in any event the local DCA offices made it easy for you by giving the applicant a copy anyway. :mad:
But who cares about the niceties of copyright and the law, this is Oz aviation after all.
By the time this was becoming a problem it was all over in Oz piston aviation anyway, DCA was being dismembered in a way that made the Rape of Nanking look like a fairy tale and just about everthing worthwhile was being thrown out with the bathwater.

It would have made an interesting case with just about every Regional office inc HO, in court with their respective @rses being sued.

So now we come around in a circle once again, in any event what would the manufacturer of the aircraft know anyway.:eek:

[HarveyGee]

djpil and Blue hauler

Thanks for replies, guys. If what djpil says is correct, and it certainly seems to be, then how are we meant to comply with 20.7.4 when we don't have the data? This looks like quite a problem to me.....

[djpil]

HarveyGee - sorry to confuse you - compliance with 20.7.4 is easy if you choose to use the old P Charts. Just read I Fly's post about the letter he has from CASA on how to do it.

It seems that this subject is causing sleepless nights for Gaunty and myself. I've done some more digging on the origin of the P Charts for my airplane. I don't doubt that some actual airfield distance measurements were made on an 8KCAB when the first one arrived in country back in '74. It seems that it had a constant-speed propeller and that would account for the discrepancy I mentioned earlier. There are quite a few with the optional fixed-pitch propeller - I wonder if the Department realized it back then or whether it was simply an oversight that my airplane received the wrong P Charts. Of course, most of us are reasonable people and wouldn't get in a situation where we'd have to consider whether a 400 m strip was long enough.

Gaunty refers to overseas performance data being generated for "sales" purposes as the reason for the Department doing its own testing. Quite true but one slipped through. I spent quite a bit of time with one of the old guys who'd been around the USA GA engineering/manufacturing industry for a long time. In those days the USA AFM did not require airfield distance data. I don't know where he got the data from. Maybe he paced out the ground roll on one occasion. I do know that his rate of climb is about double what anyone will actually see when flying the airplane. He presented his "sales" info to the Australian Department who dutifully applied the 1.15 factor and made P Charts out of it. Some years later the USA FAA wanted airfield distances for a new model of the airplane and he submitted the Australian P Charts - now "approved" data. The FAA rejected it so he then had to conduct some flight tests. It'd be interesting to compare those results with the P Charts.

[I Fly]

Gaunty, I need your help. I had asked how our US friends did it, but to date no reply.
My problem. The aerodrome certification allows a 5% gradient of the hard stuff. Disregarding CAO 20.7.4, my aircraft can not out-climb that hill at the end of Adaminaby or Armidale with a density height of up to 7000' in summer. How do I calculate the Take-off weight where my aircraft WILL do better than 5 or 6%. How do they do it in the Rockies????????

[djpil]

I Fly - the answer to your question depends on the type of airplane.
FAR 23 airplanes will have a climb gradient chart in the POH. Airplanes with earlier certification may not have a GAMA Spec manual so could be difficult.
My Owner's Manual for the 1958 model Cessna 172 gives take-off distance for 6500 ft pressure height and 25 deg C temperature, for example, so I knew that Jackson Hole airport was long enough at 6300 ft. Rate of climb was only provided for ISA conditions so I'd do some serious thinking before I flew up there for lunch. I put more faith in my memory of how it performed last time I flew it than what I read in the book. Not a lot of info with which to calculate the climb profile but fortunately only a gentle turn required to stay in the valley.
Regardless of published climb gradients even the slightest wind with a touch of wind shear can ruin your whole day there.
Home base had a runway length of 4700 ft, long enough for the 172 even with the 1.15 fudge factor at 8500 ft density altitude but it sure took a long time to climb to 11,000 ft pressure altitude to get out of the valley.
If the Heiner strip (1300 ft long) was destination for lunch then it'd have to be the Husky.

[gaunty]

Daves got it pretty much in one.

If it is a FAR23 certification it will have a climb gradient chart in the POH.

And you'll just have to keep unloading fuel bags and bodies until you get back to a weight at which for the DA of the day get you over yon hill.

When to get down to the point where it is either only you in your jock strap with fuel for a circuit or there is no escape route down the valley, as Dave says wheel out the Husky, or go back to the bar for the arvo.

Have a rummage around in the FAR 23 (http://www.access.gpo.gov/nara/cfr/cfrhtml_00/Title_14/14cfr23_00.html)

I you haven't already done so you will find it interesting and educational.
The Climb sections talk about engine inops etc. they obviously dont apply, but the rest does.

As Dave says if it is pre GAMA its probablyb fairly optmistic.

I'm stoked out about his 8KCAB "P" chart story and the bureaucratic madness, delightful aircraft in which I spent some delightful hours, including some interesting inverted aeros.

As for his US mate and the DCA "approved" data, reminds me of that wonderful philosophical question "what if the person you are following is following you."

[john_tullamarine]

Australian P-charts, on occasion, were not flown independently in Australia .... many were done by calculation based on the US POH data with the relevant fudge factors plugged into the final graphs. In fairness to DCA, on those occasions where I saw this occur .. the base data had to be reasonably convincing .. Icko T and John F were not given to having the wool pulled over their eyes ...

Generally, when tests were done, the extent of measurement usually ended up being no more than a few still camera shots from which some (generally adequate) figures were scaled .. the Nomad was a little different as the RAAF's cinetheodolite gear was nicked for the purpose ...

Regarding copyright .. I actually had a surveyor ring me up on one occasion to check if one of my P-charts was OK to be used by Bloggs in a particular aircraft ... I had, by this stage, long since given up worrying about such things ..... and as for trimsheets ... it's just all a bad joke ... but, then again .. I guess one can look at it on the basis of a compliment if people keep pinching your stuff ...

[gaunty]

john_t

And if you did rear up, as we did for a time when we had the brokers selling new aircraft that looked $10,000 cheaper than we could bring ashore and of course when they needed a AFM with P chart, we were abused and called greedy, cheating unprincipled, b@stards who had no right to deny them the "right" to buy their aircraft from wherever they wished.
And then the local DCA office would hand it over anyway.

Well, they did get the warranty that they were due but had to pay for the work first, because Cessna wouldn't recognise other than a dealers workshop and then lodge the claim with the selling dealer in the US. Another reason to call us unprincipled b@rstards.

The pick of the crop was when a Police Dept bought a NEW C182 from the local Piper dealer without tender and then got all bent and twisted when we wouldn't spring with the Oz AFM or support the Warranty. Very clever the Plod you know. Much heavyweight yelling much equally heavyweight ignoring. :rolleyes:

Trouble is, every body in this industry has been playing so fast and lose with copyright nobody knows what it means anymore.

My childrens school wont now allow photocopying of any material without attention being paid to and copyright being paid and registered.

The best compliment anybody can pay you, is when they pay you for your expertise. :D

Now which planet am I on today.:confused: :D

[Wheeler]

Ok, thats's all very interesting and shows the complexities of this debate!

BUT

1. Are we now legal to fly with our new flight manuals or not?

2. Does the 6 month grace period (or what ever it is) mean we just continue to forget about it for another 6 months as we have done for the last 2 years?

3. If we still have not got our amendment pages, having followed the CASA procedures, does it matter?

Or do we need to wait until someone gets to court?

[john_tullamarine]

Legal ??

.. sometimes I get the impression that half the time OLC is not too sure themselves ...

could it be possible that the system is legislating to the extent that everything is going the way of becoming so complex that no-one really has a handle on what some of the requirements might be ?

[gaunty]

john_t

WARNING!, WARNING!, WILL ROBINSON.:eek:

could it be possible that the system is legislating to the extent that everything is going the way of becoming so complex that no-one really has a handle on what some of the requirements might be ?

Serious Deja vu what! Sounds just like the good old days.:D

So all the shenanigans, bloodshed, demagoguery and tomfoolery by Indiana and his flock of galahs have been shown up for what they were. :rolleyes:

At least we were happy in our ingnorance.:confused:

[john_tullamarine]

The overly paternalistic nature of the old DCA of Sir Donald's day was probably not good either ... but at least the system sort of bumbled along and things got done ..... the industry had some idea of where it might be going and the DCA guys could try to do a reasonable job ... without always having to watch that they covered their tails at every step taken ......

or is what I am suggesting heresy ? ... or even a longing reminiscence ?

even getting off thread ..... never mind .... Pilks will steer it back to the straight and narrow ..

[djpil]

I can't resist that invitation, JT.

Wheeler has asked some questions that I've been avoiding until now. I guess that there would've been much internal CASA debate prior to that decision to let things ride for 6 months so there's a leap of faith to this next statement that no-one is at risk of liability because it is conservative to retain the old flight manuals. Of course there are exceptions which prove that rule. Like the one where the CASA manual has a higher crosswind limit than the USA manual. (I know its not a limit) Its up to individual pilots and CofR holders to make the assessment on a case by case basis. Shouldn't be hard to make that decision. My answers to Wheeler's questions:
1. Yes, the new flight manuals are legal but see the answer to #3.
2. Forget about it? Well, I'm going to forget about it (apart from asking other Decathlon owners what take-off chart they have).
3. Yes, the approval page is required before the new flight manual goes in the airplane.

About the only positive thing I can say is that this period of 6 months gets us closer to the withdrawal of CAO 20.7.4. So, there'll be another change and those P Charts will disappear for good.

[john_tullamarine]

just one caveat to Pilks' post ..

.. some (but certainly not all) of the crosswind limits are just that ....

As an example, I had an involvement with the Rockwell Commander singles when they first went onto the local register years ago (nice little aeroplanes to fly but not for you and I, Dave .. or Gaunty .. jointly and severally, we would never fit into the seats .. I am convinced that they were intended for the Japanese market) ... the specific numbers elude my memory but I vaguely recall that the original US figure was 15 knots (?) and we upped that to something like 18 knots or so ... that level of crosswind was flown and was getting to a point where the aircraft was becoming not very pleasant ..... while I would be happy to land many aircraft of my acquaintance in quite strong crosswinds, for that particular family I would respect the number in the Australian manual ...

... actually, I fibbed . make that several caveats ...

As I haven't had to address a flight manual task in recent times I haven't done any specific research and I don't have the answers to the following ... perhaps Dave has considered these ?

(a) where do all the lighties which had an Australian 27/22 CTA and associated documentation go for their new flight manuals ? .. a number of aircraft flying around have flight manuals which I put together, for instance and both the aircraft and the manuals are somewhat different to the US versions ...

(b) what about aircraft like the AC 50A and S models, for instance, which have higher takeoff weights than the US standard TC permits ? (this came about due to differences which were exploited in ANO 101.22 and the serendipitous family of higher weight aircraft to which they belong

(c) having picked up on audits entire model ranges which had been issued with the wrong flight manual by the regulatory specialists in innocent error ..... how many of the well intentioned CofR holders out there are going to fall into all manner of traps ?

[djpil]

JT, you're just making life more difficult.

Refresh my memory on those 27/22 manuals - sounds like a case for new AFM Supplements. It seems that there's a company offering new manuals for Victas, I don't know why though. The Chipmunk manual saga is still not resolved as far as I know.

The AC's - I hope that's easy, should just need a supplement.

The wrong manuals assigned? Well, I haven't told you even half of my Decathlon story but at least I have discovered the problems. The traps that JT referred to are the very reasons that the new flight manuals should not have been introduced retrospectively but we're too late to do anything about that aren't we? Or can the 6 month grace period be extended indefinitely?

On second thought, all of the above are good reasons to extend the grace period.

[Blue Hauler]

If we see a withdrawl of CAO 20.7.4 will we also see 20.7.1B pass into oblivion? Particularly restrictive to RPT and CHTR operations are the requirements of paragraphs 11.1 and 11.1.1 which add 67% and 43% to the landing distance required for jet and propeller aircraft respectively.

Viz:-

Citation 560 - Sea level, ISA +15:
16,300 LB (MTOW), TODR 3,510 FT.
15,200 LB (MLW), LDR 2,930 FT. PLUS FACTOR (67%) 4,893 FT!

No wonder most operators are still flying 30 year old Navajos if 21st century technology is so restrictive!

[gaunty]

Blue Hauler

Ahhh now that's another story altogether and revolves around a certification philosophy, known as FAR Part 25 Transport Category which just happens to apply to all aircraft >= 5700kgs.

Landing is the least accurate of all our pitiful fumblings around in the manner of piloting a heavier than air machine..
So they apply a cuppla std deviations (67%) to the figures that are derived by everything happening exactly as it should to allow for that.
That is, if you use the factored number you have got your arse statistically covered for just about every reasonable combination of events not happening exactly as planned.

It is to do with giving the fare paying passenger an even break.:D

Thers a fair bit more to it but that'll do for the moment, I'm off to bed.

[djpil]

On the subject of airfield performance for little airplanes used for charter and RPT.
I haven't been looking at those new regs but my guess is that something will appear thats not too much different from CAO 20.7.1. The factors that Gaunty mentions for FAR 25 also appeared in the old FAR 135 Appendix A (they may have moved to FAR 23 since) and were applicable to small airplanes. Apart from airfield distance there were additional climb weight limitations.

[john_tullamarine]

Good heavens ... a bloke goes and has a coffee and a snooze and the thread balloons in the interim ...

Dave,

Re the ANR27/CAR22 problems, I was harking back to pre-NAA TC rubber-stamping days. The one which particularly intrigues me (and it may already have been addressed ... I am not up to speed on the state of play in the flight manual arena this week and haven't been in a Shrike for quite a while) is the AC50S takeoff weight .. I can just imagine the various operators meekly going back to the lower US weights ...

Victas ... ah, fond memories ... whatever happened to your old bird that we did our initial aeros in with Aub C. all those years ago ?

Chippies .. several of those with my charts in ... hope I don't have to supply manuals for them ... and JNSJ doesn't fly them anymore anyway ...

Blue Hauler,

Keep in mind that the Oz experience was run a little differently to the US' .. the US has clearly defined airworthiness and operational regulations (eg 25 and 121) and both are part of the operator's bookshelf detritus ... the local practice was to fudge into the airworthiness documentation (ie the flight manual) the operational requirements (so we had ANO 101.5/6 mandated flight manuals which contained the sorts of things which were in 20.7.1b. This latter rule, of course, had more than the odd variation with respect to the 101 series and that always caused the more honorable engineers a bit of a concern .... when OLC eventually gets the rule rewrite finished we will end up with something similar to the FAR/JAR system ... it would have been just so much easier if the system could have just adopted the FARs as is ....

You may recall that, in Dick S. days, when the operational factors for private operations became optional, a Citation, if my memory serves me correctly, wet its toes in the water at Lord Howe within a week or two of the rule change ? .. much to the amusement of some of the airworthiness people who had argued against the change on risk grounds.

As you have mentioned landing distances, might I go a bit further than Gaunty's comments and suggest that the raw data distances are, in general, not reasonably achievable or repeatable by mug pilots such as most of us are .. even on our best day ? Might I suggest that performance landing tests (which are used to validate the raw data figures) are, in my opinion, amongst the most routinely terrifying sort of flying going ? ... as I recall, several of the DC9 family test vehicles were broken (big time) doing such tests ...

He who views the operational factors through rose coloured glasses full of parallax error is setting himself up for a fall from grace .... if not worse.

[LeadSled]

All,
Re: FAR 25 landing field lengths, JT is right, the flying techniques used to produce the raw data is not what you would do with customers on board, they would never buy a ticket with you again. Even if you have the ability to reproduce the result.

The raw data becomes approx. 66% of the published filed length ( not factored by 66%), and in the real world of real pilots, there is little margin in the published figures.

Then add some more margin for wet runways, lots more for wet grass etc., and unless you really know what you are doing, don’t even think about ice effected runways.

It is interesting to compare the old UK ARB approach, which took into account all sorts of factors that would be "deemed" average pilot handling, bit high over the fence, bit fast etc, then only added about 15% margin.

Hey, presto, the result was not much different to the FAA system plus its much bigger factor.

Hands up all those who can recall various busted aeroplanes as a result of the “unique Australian test flying requirements” of years ago, a Merlin at Mangalore, Riveria seaplane at the bottom of Pittwater, several other busted light aircraft, a sadly deranged Beech 1900 come to mind immediately.

Tootle pip!!

[john_tullamarine]

LeadSled,

You might consider revisiting your distance factors discussion ? Normal approach to the numbers is raw data/0.6 (or factored by 1.67) for the destination landing case from which arises the 67 percent fudge factor margin. The normal US requirements impose additional penalties for wet and contaminated runways as described in (the never issued but used by all in the Industry) AC91-6B.

Having an airworthiness background, I have to take a contrary viewpoint regarding the "unique Australian requirements" .. while some may have been the object of derision, justified or not (the flight manual stowage requirement typified this), the local certification assessment of foreign aircraft, from time to time, discovered things which had been overlooked in the original process. More usefully, the pre-rubber-stamp days had the advantage that local modifications and the like could be negotiated with DCA (and all its variant names). No system is perfect .. but what we had did have more than a few tangible advantages mixed in with the perceived disadvantages.


Another thing to keep in mind is that most of the US flight manuals (certainly those which I have played with) present unfactored data for the landing distance to meet the airworthiness requirements. The US operator then has to apply whatever operational fudge factor is applicable to his operation in the application of the flight manual data. This represents a major paradigm shift in thinking for the average operator or pilot in this neck of the woods and, I have no doubt, there will be a few frights or worse in the learning curve process ..... while the new flight manuals are assimilated within the local operating scene.

[the wizard of auz]

I guess I'm just lucky..........my aircraft is on the exempt list.....when looked into further it seems that my old bomb didnt require one because the manufacturer has mandated placarding all over the aircraft and it is deemed to be enough information for the aircraft to be flown without the requirement of an AFM.......I opted to use the old one anyway and the guy at CASA said thats fine.....we dont care anyway as your aircraft was exempted.

[Wheeler]

Its interesting whether one needs a basic AFM or not. There seems to be some pretty complex types that can be flown without one (some C310's and 340's? - now one of them without a basic AFM does seem a bit scary!) but the little old C152, clearly a very unforgiving beast that has to be flown just right, does.
Or have I got that wrong?