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Old 18th Aug 2002, 07:26
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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.
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Old 18th Aug 2002, 11:01
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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.

Last edited by djpil; 18th Aug 2002 at 13:16.
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Old 18th Aug 2002, 15:21
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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, but certainly on the premise that the information was for "sales" purposes and therefore not to be trusted.

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.
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.
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Old 19th Aug 2002, 00:02
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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.....
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Old 19th Aug 2002, 00:42
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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.
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Old 19th Aug 2002, 09:14
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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????????
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Old 19th Aug 2002, 10:52
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How they do it in the Rockies

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.

Last edited by djpil; 19th Aug 2002 at 22:48.
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Old 19th Aug 2002, 12:21
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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

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."
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Old 20th Aug 2002, 13:47
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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 ...
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Old 20th Aug 2002, 14:09
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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.

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.

Now which planet am I on today.
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Old 20th Aug 2002, 18:03
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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?
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Old 20th Aug 2002, 23:58
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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 ?
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Old 21st Aug 2002, 00:22
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john_t

WARNING!, WARNING!, WILL ROBINSON.

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.

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

At least we were happy in our ingnorance.
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Old 21st Aug 2002, 03:24
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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 ..

Last edited by john_tullamarine; 21st Aug 2002 at 03:42.
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Old 21st Aug 2002, 11:36
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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.
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Old 21st Aug 2002, 11:50
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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 ?

Last edited by john_tullamarine; 21st Aug 2002 at 11:58.
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Old 21st Aug 2002, 12:29
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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.

Last edited by djpil; 21st Aug 2002 at 20:31.
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Old 21st Aug 2002, 12:40
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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!
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Old 21st Aug 2002, 14:03
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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.

Thers a fair bit more to it but that'll do for the moment, I'm off to bed.
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Old 21st Aug 2002, 20:42
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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.
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