Take off alternate - Landing distance req
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Leadsled,
review what I have written and then make comment on what I have actually said !
And as to confirm what I've said ; We won't make the landing distance that is written in the book because that distance has been written using test pilot, using certain parameters (positive landing, ....) and landing within the required zone that under stress an average pilot will not make.
so nothing reckless here, except you maybe unable to read a whole topic before replying to it !
regarding legality, i'm sure all in this forum will say that since we all began flying a new set of rules has been created that restrict the operation of what we use to do before. this goes to locked door, always 2 in cockpit, use of FDM, ....
Of course, all those rules where written to increase safety
review what I have written and then make comment on what I have actually said !
And as to confirm what I've said ; We won't make the landing distance that is written in the book because that distance has been written using test pilot, using certain parameters (positive landing, ....) and landing within the required zone that under stress an average pilot will not make.
so nothing reckless here, except you maybe unable to read a whole topic before replying to it !
regarding legality, i'm sure all in this forum will say that since we all began flying a new set of rules has been created that restrict the operation of what we use to do before. this goes to locked door, always 2 in cockpit, use of FDM, ....
Of course, all those rules where written to increase safety
-----so nothing reckless here, except you maybe unable to read a whole topic before replying to it !
Believe me, I have read every post on this thread multiple times, with some amazement, starting with the strange idea that there was some time in recent air transport history, before which we did not have to comply with aviation law --- is close to the Top 10 in all time ridiculous statements on pprune.
As for recklessness, I have merely used you own words to point out what you have said is you/your company’s practice, in law, is as good a case of evidence of recklessness as I have seen in a while.
In this area, there is no significantly new law, just developments from time to time. What is relatively new is both Boeing and Airbus making much more data freely available as “advisory” information , as an aid to planning operations.
Please be clear, such advisory material does not replace the position of statutory requirement. One poster has helpfully posted the FAR Part 121 statutory requirements, which are quite clear, and are not superseded by any apparently less restrictive advisory material. Don't forget that, in some jurisdictions, the that head and tailwind components used in deriving the published landing field lengths are also factored, half the headwind and double the tailwind.
Read the very clear disclaimers in the Airbus information helpfully provided in links on this thread.
The EASA regulatory framework is fundamentally the same, as is EASA derivation of statutory landing field lengths.
The idea that, in pre-flight planning for a statutory eventuality, you can plan on the use of a runway that you cannot legally use ( land and stop within the confines of the runway), except in extremis when you have no choice but to land anywhere as fast as possible ---- which would be pretty much limited to a catastrophic fire or fuel exhaustion, is something I have not ever come across before. A mere engine or systems failure, even multiple system failures, short of the immediately foregoing, does not change the statutory requirement to have adequate runway available.
And, as a minimum, that will be 1.67 times the raw data, if that is your staring point
If, in fact, your company manuals apparently permit a lesser field length, the manuals are wrong, and should not have been approved, or (as is possible in Australia, the representative of the approving authority is seriously deficient in aviation knowledge) have been approved in error, or are being misinterpreted. Over a long career, I have seen all the above happen, but so far such gross errors (in my world) have been picked up (several times by me) before an avoidable disaster resulted.
As to my legal knowledge, those who know my actual identity would testify that my background legal knowledge is of a different order to the “average” professional pilot, including understanding statutory and case law on criminal negligence and criminal recklessness.
Hopefully it will be more helpful if we look at the background to all this, and it is clear to me that that there is considerable confusion of terms, with the role of much “advisory” information not clearly understood -- in the legal sense.
In other words, the use to which much “advisory” information can be put is being apparently seriously mishandled.
Not, probably, with criminal intent, but nevertheless, ignorance is not a defence in any court of law, much less the court of public opinion, to which politicians and some brands of airline management will respond.
For landing field length --- the ones that you have to use in all your normal planning, and the ones derived by either FAA FAR 25 certification, or the JAR/EASA equivalent, the “published” landing field length, is the raw data (obtained from test flying at certification) multiplied by 1.67. In reality, this has been expressed, for years, as the “demonstrated landing distance” being 60% of the published landing field length.
For clarity, I have not used acronyms.
Understand, very clearly, that whatever you are planning, whether pre-flight or inflight (except in an extreme emergency) the full 100%, not 60% of the landing field length must be available. The applicability of an additional 15% ( or raw data multiplied by 1.92) is (depending on the FCOM) usually at the discretion of the PIC.
However, as one of the links on a previous post so helpfully illustrates, the FAA has decided (along with EASA help) that 15% (1.92) is not enough under certain circumstances, FAA ARC has made recommendations, and a rulemaking is pending, the NPRM is not far away.
In my opinion, one area of confusion is what (at dispatch) “demonstrated 60%” means in practice. Legally it can mean only one thing, and I will use an example.
At the time the aircraft might arrive at an alternate ( to departure, destination or en-route), given all the circumstance, weight, met. etc., and the aircraft landing field length published is say, 5000 feet (easier than meters) that makes 60% a distance of 3000 feet. However, the statutory distance you must have is still 5000 feet minimum.
The alternate (for whatever purpose) at dispatch cannot be a 3000 ft runway. The only meaning in a dispatch guide of the reference to “60%” is to the raw number, you cannot use that in operational planning, or in flight.
In an extreme emergency, all bets are off, but otherwise statutory (“published” as in raw by 1.67) landing field length is the minimum.
Where Airbus and Boeing now publish all sorts of very helpful advisory information, which is a good guide to what the aircraft will actually achieve, in practice,(which hi-speed can I make) based on autobrake settings and use of reverse, for example, plus assumptions about real runway friction condition (and what other variables you might throw in) you will often see the result “factored” by 15%. That’s fine, as long as you understand that the resultant actual runway length available cannot be less than the statutory requirement.
These “recent” developments actually have a long history, going back to the BCARs and the UK ARB of the 1960s. The then UK flight test model sought to allow for the real world of line pilots flying line aeroplanes in line conditions.
The flight test guide required testing at a variety of Vref ++ over the 50’ fence, a variety of threshold crossing heights, and a variety of flare and landing techniques. The resulting landing field lengths were factored by “only” 15%.
In practice, the BCAR results (raw/demonstrated +15%) were almost the same as the FAA Flight Test Guide figures, and the FAA method of obtaining raw figures was more straightforward and more repeatable, if more brutal. I don’t know, but I have always assumed that JAA went along with the FAA. At the time, I was a little surprised when such practicality overrode the usual trans-Atlantic politics of differences for difference sake. This from an old mate of mine who, after the USAF, spent many years with McDonnell Douglas Flight Test at Longbeach, involved in both DC-10 and MD-11 certification in both US and in Europe.
This is a very long post, I hope some of you will read this far, this is a subject on which all pilots should be very clear.
Please understand that statutory landing filed lengths are the minimum, advisory information, including performance estimates in non-normal configurations, is very helpful, but except in an extreme emergency, you must meet the statutory requirement as a minimum.
You may, indeed, need much more, that is the role of the advisory material, but not less. The A-380, QF 32, at YSSS is a good example.
Tootle pip!!
Last edited by LeadSled; 7th Jan 2016 at 08:16.
Please understand that statutory landing filed lengths are the minimum, advisory information, including performance estimates in non-normal configurations, is very helpful, but except in an extreme emergency, you must meet the statutory requirement as a minimum
Once inflight the statutory landing distance requirement does not apply.
From the CASA documents (I am not an expert in the CASA regulatory structure so may have quoted the incorrect document).
CAAP 235-5(0) New performance provisions for CAO 20.7.1B and CAO 20.7.4
5.3 Actual landing distance
5.3.1 In response to recommendations of the FAA’s Take-off and landing performance assessment aviation rule making committee (TALPA ARC), the manufacturers of some jet-engine aeroplanes now supply actual landing distance information to help pilots make more accurate in- flight assessments of the landing distance required in unusual situations. Actual landing distance information takes into account: reported meteorological and runway surface conditions, runway slope, aircraft configuration, planned approach speed, thrust reversers and any other deceleration devices planned to be used for the landing. The FAA’s Safety Alert For Operators (SAFO 06012) contains useful information about the recommendations of the TALPA ARC.
5.3.2 Actual landing distance information is intended to show landing performance that can realistically be achieved by flight crews in commercial operations. This is distinct from landing performance demonstrated by test pilots during flight tests for aircraft type certification. The safety factor applicable to in-flight actual landing distance information is 1.15. The safety factor applied to aircraft type certification for pre-flight planning landing distance is 1.67. Pilots of jet-engine aeroplanes that do not have actual landing distance information should continue to make in-flight assessment of landing distance required using the manufacturers landing distance information with an applicable safety factor.
5.3.3 Two major manufacturers, Boeing and Airbus, have introduced a new reference for in-flight landing distance performance, catering for both normal and abnormal system operations. The new distances are referred to by Airbus as Operational Landing Distances (OLD) and In-flight Landing Distance (IFLD) whereas Boeing incorporates the actual landing distance in the Performance In- flight section of the Quick Reference Handbook. Both manufacturers have included this data in their respective performance applications. The actual landing distances are a realistic representation of operationally achievable landing performance. The representation of this information is generally “unfactored” unless otherwise stated. The CAO 20.7.1B amendment facilitates the adoption of manufacturers’ performance applications along with the application of the 1.15 safety factor.
May 2014
CAAP 235-5(0) New performance provisions for CAO 20.7.1B and CAO 20.7.4 5
FAA and EASA have adopted the in-flight landing distance factoring as policy, and along with ICAO are in the process of rulemaking.
c100driver,
In fact, that is close, but no chocolate frog.
The numbers derived from the tables that Boeing and Airbus produce will always ( I have never been able to see anybody demonstrate otherwise) produce a landing field length longer than the raw test flight figure factored by 1.67.
I think I said words to the effect that the landing filed length cannot be less than the statutory length, raw factored by 1.67.
Indeed, some of the recommendations that will be in the forthcoming FAA NPRM will turn some of these recommendations into statutory requirements, and in the case of wet/contaminated runway, looks like they will be greater than the raw figure factored by 1.92
As I alluded to, in a previous post, the "new" approach is very much like (but more conservative than) the BCARs of the 1960s/70s.
Here is the relevant CASA CAO 20.7.1b
11 Landing distance required 11.1 For subparagraph 5.1 (a), the landing distance for a jet-engined aeroplane is:
(a) for an aeroplane engaged in regular public transport operations when landing on a dry runway, or in charter operations when landing on a dry or wet runway — 1.67 times the distance required to bring the aeroplane to a stop on a dry runway; or
(b) for an aeroplane engaged in regular public transport operations when landing on a wet runway:
(i) 1.92 times the distance required to bring the aeroplane to a stop on a dry runway; or
(ii) the distance set out in the flight manual or operations manual for operations conducted on wet runways.
11.1.1 For the purposes of subparagraph 5.1 (a), the landing distance required in relation to a propeller driven aeroplane that is engaged in regular public transport, or charter, operations is:
(a) for a landing at a destination aerodrome:
(i) when the runway is dry — a distance equal to 1.43 times the distance required to bring the aeroplane to a stop; or
(ii) when the runway is wet — a distance equal to 1.67 times the distance required to bring the aeroplane to a stop; and
(b) for a landing at an alternate aerodrome — 1.43 times the distance required to bring the aeroplane to a stop.
11.1.2 Subject to paragraph 11.2, the landing distance required under paragraph 11.1 or 11.1.1 must be determined using information set out in the flight manual.
11.2 For a landing on a contaminated runway, the landing distance required is:
(a) subject to paragraph 11.3, the distance set out in the flight manual or the operations manual for operations conducted on contaminated runways; or
(b) the distance approved by CASA for operations conducted on runways covered by slush, snow or a depth of water.
11.3 For subparagraph 4.1 (d) and paragraph 5.1, an aeroplane engaged in private, or aerial work, operations must be operated so that compliance with the landing requirements is demonstrated using data set out in:
(a) the flight manual; or
(b) the manufacturer’s data manual; or
(c) the approved foreign flight manual.
Note The data contained in some manufacturers’ data manuals is unfactored and makes no allowance for degraded aircraft performance.
11.5 This subsection does not apply in the case of an emergency.
Critical to the reading of the above is the status of the information currently presented. It is a very legalistic approach in Australia, and the differences between certified, acceptable and advisory information is absolutely critical in determining legal compliance. All AFM "data" has to be "accepted" (in reality, approved) by CASA for use under an FCOM, it makes for some very interesting "discussions".
Tootle pip!!
In fact, that is close, but no chocolate frog.
The numbers derived from the tables that Boeing and Airbus produce will always ( I have never been able to see anybody demonstrate otherwise) produce a landing field length longer than the raw test flight figure factored by 1.67.
I think I said words to the effect that the landing filed length cannot be less than the statutory length, raw factored by 1.67.
Indeed, some of the recommendations that will be in the forthcoming FAA NPRM will turn some of these recommendations into statutory requirements, and in the case of wet/contaminated runway, looks like they will be greater than the raw figure factored by 1.92
As I alluded to, in a previous post, the "new" approach is very much like (but more conservative than) the BCARs of the 1960s/70s.
Here is the relevant CASA CAO 20.7.1b
11 Landing distance required 11.1 For subparagraph 5.1 (a), the landing distance for a jet-engined aeroplane is:
(a) for an aeroplane engaged in regular public transport operations when landing on a dry runway, or in charter operations when landing on a dry or wet runway — 1.67 times the distance required to bring the aeroplane to a stop on a dry runway; or
(b) for an aeroplane engaged in regular public transport operations when landing on a wet runway:
(i) 1.92 times the distance required to bring the aeroplane to a stop on a dry runway; or
(ii) the distance set out in the flight manual or operations manual for operations conducted on wet runways.
11.1.1 For the purposes of subparagraph 5.1 (a), the landing distance required in relation to a propeller driven aeroplane that is engaged in regular public transport, or charter, operations is:
(a) for a landing at a destination aerodrome:
(i) when the runway is dry — a distance equal to 1.43 times the distance required to bring the aeroplane to a stop; or
(ii) when the runway is wet — a distance equal to 1.67 times the distance required to bring the aeroplane to a stop; and
(b) for a landing at an alternate aerodrome — 1.43 times the distance required to bring the aeroplane to a stop.
11.1.2 Subject to paragraph 11.2, the landing distance required under paragraph 11.1 or 11.1.1 must be determined using information set out in the flight manual.
11.2 For a landing on a contaminated runway, the landing distance required is:
(a) subject to paragraph 11.3, the distance set out in the flight manual or the operations manual for operations conducted on contaminated runways; or
(b) the distance approved by CASA for operations conducted on runways covered by slush, snow or a depth of water.
11.3 For subparagraph 4.1 (d) and paragraph 5.1, an aeroplane engaged in private, or aerial work, operations must be operated so that compliance with the landing requirements is demonstrated using data set out in:
(a) the flight manual; or
(b) the manufacturer’s data manual; or
(c) the approved foreign flight manual.
Note The data contained in some manufacturers’ data manuals is unfactored and makes no allowance for degraded aircraft performance.
11.5 This subsection does not apply in the case of an emergency.
Critical to the reading of the above is the status of the information currently presented. It is a very legalistic approach in Australia, and the differences between certified, acceptable and advisory information is absolutely critical in determining legal compliance. All AFM "data" has to be "accepted" (in reality, approved) by CASA for use under an FCOM, it makes for some very interesting "discussions".
Tootle pip!!
Here is the current one from the CASA website.
The note at the bottom says that it include the Legislative Instrument from May 2014 (what ever that means in Aussie speak)
note 11.2
The note at the bottom says that it include the Legislative Instrument from May 2014 (what ever that means in Aussie speak)
note 11.2
11 Landing distance required
11.1 When determining the maximum weight for take-off of a jet-engined aeroplane of maximum take-off weight greater than 5 700 kg for the purpose of subparagraph 4.1 (d), the landing distance required is:
(a) for an aeroplane engaged in regular public transport operations when the appropriate weather reports and forecasts, or a combination, indicate that the runways will be dry at the estimated time of arrival, or in charter operations — 1.67 times the distance required to bring the aeroplane to a stop on a dry runway; or
(b) for an aeroplane engaged in regular public transport operations when the appropriate weather reports and forecasts, or a combination, indicate that the runways may be wet at the estimated time of arrival:
(i) 1.92 times the distance required to bring the aeroplane to a stop on a dry runway; or
(ii) the distance set out in the flight manual or operations manual for operations conducted on wet runways.
11.2 When determining the maximum weight for landing of a jet-engined aeroplane of maximum take-off weight greater than 5 700 kg for the purpose of subparagraph 5.1 (a), the landing distance required is 1.67 times the distance required to bring the aeroplane to a stop on a dry runway or, if actual landing distance data is supplied by the aircraft’s type certificate holder, 1.15 times the actual landing distance.
11.1 When determining the maximum weight for take-off of a jet-engined aeroplane of maximum take-off weight greater than 5 700 kg for the purpose of subparagraph 4.1 (d), the landing distance required is:
(a) for an aeroplane engaged in regular public transport operations when the appropriate weather reports and forecasts, or a combination, indicate that the runways will be dry at the estimated time of arrival, or in charter operations — 1.67 times the distance required to bring the aeroplane to a stop on a dry runway; or
(b) for an aeroplane engaged in regular public transport operations when the appropriate weather reports and forecasts, or a combination, indicate that the runways may be wet at the estimated time of arrival:
(i) 1.92 times the distance required to bring the aeroplane to a stop on a dry runway; or
(ii) the distance set out in the flight manual or operations manual for operations conducted on wet runways.
11.2 When determining the maximum weight for landing of a jet-engined aeroplane of maximum take-off weight greater than 5 700 kg for the purpose of subparagraph 5.1 (a), the landing distance required is 1.67 times the distance required to bring the aeroplane to a stop on a dry runway or, if actual landing distance data is supplied by the aircraft’s type certificate holder, 1.15 times the actual landing distance.
As an interesting aside the regulators Airline Inspectors (ex airline pilots) believed the rule to be observed as per despatch inflight, however the performance specialists who wrote the rule within the regulator have told me that the rule is specific to prior to takeoff only.
Before departure, takeoff optional. plan conservative.
Inflight, Landing mandatory. actual plus 15%
Before departure, takeoff optional. plan conservative.
Inflight, Landing mandatory. actual plus 15%
c100,
I have been doing some homework since my last post, just to make certain that I have my facts straight --- something I had drummed into me from an early age by a barrister/politician father.
The results are most interesting.
Re. Australian CAO 20.7.1b ( my post was from the Comlaw web site, the "law", which CASA web site is not) and it looks like the only aircraft able to use the amendment is the A380, probably the QF A-330 in the near future. The latter based on answers to questions to a C&T mate of mine at QF. It is not clear what Virgin are doing.
In both the US and EASA-land, the operational landing field length remains the "certified" or "published" length, being the test flight figures factored by 1.67, or as more correctly expressed in both EASA or FAA regulations, the demonstrated field length is 60% of the published length.
Until there is a suitable rule-making to authorize something like CASA CAO 20.7.1b, landing field lengths LEGALLY remains the certified length.
In the CASA case, it seem there is a disconnect between the Australian Type Acceptance Certificate based Certificate of Airworthiness details, and the adoption of the "advisory" figures as the certified figures. That will now be looked into. Remember, in the Australian legal framework, a CAO does not outrank a regulation.
EASA has indicated (presumably under the terms of the Trans Atlantic Mutual Cooperation Agreement) that they will follow the FAA, which has not got to even an NPRM, as far as I can determine.
It follows that all the "Advisory" information is just that, advisory, and does not supersede the current (traditional) certified landing field lengths.
If you read a bunch of the Airbus publications on the subject, it actually says this, and warns that Advisory is just that, advisory.
Once the law changes, not much will really change, because the length required (was advisory, now "acceptable data" +15%), once you have taken all the factors into account, will be much the same as now, except for wet or contaminated runways, which will be longer than now, as, not only will the equivalent of the present 1.92 factor be mandatory (no Captain's discretion) but the increment for wet or contaminated will actually increase in most circumstances.
Just because words appear in an FCOM or a dispatch manual say it, or an FOI and other specialists have varying interpretations, one thing is certain, it is not the law until it is the law. Then it is what is in the statute books, as it is, not as somebody thought it was going to be.
FAR Part 121 is particularly clear on the subject, the relevant para. is somewhere on this thread.
What will not happen, under any circumstances, and which is where this thread started, will anybody be able to plan, pre-flight or in-flight, to use a runway that is only 60% of the present certified landing distance, or anything like it.
It seems that confusion reigns supreme, a lot of people, and some NAAs have jumped the gun, and misunderstandings abound.
I have seem this often enough in Australia, where FOIs start demanding amendments to FCOMs, "because the law is changing", and then it doesn't happen, or the new "rules" vary very substantially from the CASA PR and internal training of FOIs. CASR Part 61 is a classic example of an complete shambles, which bears only a fleeting ( and probably accidental) resemblance to the explanatory memoranda and early FOI training.
Tootle pip!!
I have been doing some homework since my last post, just to make certain that I have my facts straight --- something I had drummed into me from an early age by a barrister/politician father.
The results are most interesting.
Re. Australian CAO 20.7.1b ( my post was from the Comlaw web site, the "law", which CASA web site is not) and it looks like the only aircraft able to use the amendment is the A380, probably the QF A-330 in the near future. The latter based on answers to questions to a C&T mate of mine at QF. It is not clear what Virgin are doing.
In both the US and EASA-land, the operational landing field length remains the "certified" or "published" length, being the test flight figures factored by 1.67, or as more correctly expressed in both EASA or FAA regulations, the demonstrated field length is 60% of the published length.
Until there is a suitable rule-making to authorize something like CASA CAO 20.7.1b, landing field lengths LEGALLY remains the certified length.
In the CASA case, it seem there is a disconnect between the Australian Type Acceptance Certificate based Certificate of Airworthiness details, and the adoption of the "advisory" figures as the certified figures. That will now be looked into. Remember, in the Australian legal framework, a CAO does not outrank a regulation.
EASA has indicated (presumably under the terms of the Trans Atlantic Mutual Cooperation Agreement) that they will follow the FAA, which has not got to even an NPRM, as far as I can determine.
It follows that all the "Advisory" information is just that, advisory, and does not supersede the current (traditional) certified landing field lengths.
If you read a bunch of the Airbus publications on the subject, it actually says this, and warns that Advisory is just that, advisory.
Once the law changes, not much will really change, because the length required (was advisory, now "acceptable data" +15%), once you have taken all the factors into account, will be much the same as now, except for wet or contaminated runways, which will be longer than now, as, not only will the equivalent of the present 1.92 factor be mandatory (no Captain's discretion) but the increment for wet or contaminated will actually increase in most circumstances.
Just because words appear in an FCOM or a dispatch manual say it, or an FOI and other specialists have varying interpretations, one thing is certain, it is not the law until it is the law. Then it is what is in the statute books, as it is, not as somebody thought it was going to be.
FAR Part 121 is particularly clear on the subject, the relevant para. is somewhere on this thread.
What will not happen, under any circumstances, and which is where this thread started, will anybody be able to plan, pre-flight or in-flight, to use a runway that is only 60% of the present certified landing distance, or anything like it.
It seems that confusion reigns supreme, a lot of people, and some NAAs have jumped the gun, and misunderstandings abound.
I have seem this often enough in Australia, where FOIs start demanding amendments to FCOMs, "because the law is changing", and then it doesn't happen, or the new "rules" vary very substantially from the CASA PR and internal training of FOIs. CASR Part 61 is a classic example of an complete shambles, which bears only a fleeting ( and probably accidental) resemblance to the explanatory memoranda and early FOI training.
Tootle pip!!
Firstly my commiserations of having to put up with the total mess of incomplete, incompetent and contradictory information masquerading as Civil Aviation Regulations of Aussie. They are a total shambles and it is no wonder that PPrune has so many conflicting discussions on what is correct.
While trying to check some of the comments I have found "legal documents" that are unsigned in comlaw, explanatory statements that explain what the law is meant to say! (why could they just not write it correctly in the first place)
However I did find that the CAR's authorise the director to issue any directions via a CAO. So in this case the director can in-fact over rule (redefine?) the content of the rule.
Whilst attempting to research the facts I did come across an exemption to Tiger for the use of IFLD plus 15% IAW CAO 20.7.1B. Because the com law and CASA websites were written by a 5 year old child with learning disability I have not bothered to look for the rest of the airline exemptions though I suspect that they are all there.
The FAA 121.195 only mentions "prior to takeoff" in respect of landing distance it never mentions landing distance requirements inflight.
While trying to check some of the comments I have found "legal documents" that are unsigned in comlaw, explanatory statements that explain what the law is meant to say! (why could they just not write it correctly in the first place)
However I did find that the CAR's authorise the director to issue any directions via a CAO. So in this case the director can in-fact over rule (redefine?) the content of the rule.
Whilst attempting to research the facts I did come across an exemption to Tiger for the use of IFLD plus 15% IAW CAO 20.7.1B. Because the com law and CASA websites were written by a 5 year old child with learning disability I have not bothered to look for the rest of the airline exemptions though I suspect that they are all there.
The FAA 121.195 only mentions "prior to takeoff" in respect of landing distance it never mentions landing distance requirements inflight.
The FAA 121.195 only mentions "prior to takeoff" in respect of landing distance it never mentions landing distance requirements inflight.
Because the required pre-flight planning is required to cover, in this case, what happens in flight, as well.
The issue that surprised me, is that FAA and EASA have not yet legislated to recognise the "proposed" system, and EASA is waiting for FAA to move.
As to a CAO (or, for that matter, a regulation) being used to "over-ride" a provision of the Act., or a CAO over-riding a provision of a regulation, in Australia, that has a long and inglorious history, it quite contrary to any known legal principle, in the first instance, as for CAR/CASR versus CAO or other legal instrument, what a mess --- the is no legal certainty.
At least, under the Legislative Instruments Act, each and every case requires a Legal Instrument, that LI can be rejected by the Parliament, to that extent the "whatever" has been passed by Parliament, it is not a decision by a public servant.
Hence the expression:"inadvertent criminals", or "pilots and engineers are just criminals who haven't been caught yet".
There is reasonable legal certainty with what Qantas is doing with the A380, as certain as is possible in the legal shambles we live and work under in AU.
Tootle pip!!
