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Ask The Experts...
Users may ask aviation related questions of interest to corporate operators (No tax or
accounting questions please).
CAVU will post the answer obtained through query of its extensive knowledge
network, including contacts from FlightSafety, SimuFlite and all aircraft
manufacturers.
| Climb Gradients, a
primer Determining the climb gradient performance for a departure
begins with clarifying the vernacular between:
A) what the aircraft is actually
capable of doing (actual) and
B) the regulatory or physical
gradient (required).
The actual climb gradient is based on atmospheric conditions,
take-off weight and aircraft configurations, such as flap setting, slots
etc, whereas the required gradient is based on aircraft
certification, regulation and obstacle clearance. We will consistently
identify the gradients using italicized labels of actual and required, so as
to reduce confusion throughout the discussion.
Under visual rules, pilots may not concern themselves with climb
gradients as long as obstacles can be visually circumnavigated; however,
even without the presence of obstacles, the aircraft must still be able to
meet or exceed jet aircraft certification climb performance. In other
words, a two engine aircraft must be able to meet, with one engine
inoperative, a minimum required gross gradient of 2.4% (3 engine
aircraft 2.7% and 4 engine 3.0%). We will discuss gross versus net in
a bit, but notice that this is the required gradient. Many
manufacturers include a Max Weight Climb chart to determine if this most
basic criteria can be met. If one is not available, then the
aircraft's 2nd segment climb charts must be visited and the pilot must make
the appropriate adjustments for gross versus net.
If the flight is to be conducted under IFR, then a decision tree logic
must be applied.
First, is a departure procedure or SID established for the runway to be
used?
If yes, then FAA TERPS criteria establishes the required gross
gradient. As a minimum, we are familiar with the 200 feet per NM
requirement; this translates to a 3.3% gradient (200 ft / 6060 ft/NM).
Since most depart plates describe the required gradient in terms of feet/NM,
the pilot must make the conversion to a percent gradient.
If a departure is not established, then the pilot must determine the
obstacle clearance gradient as described below; but first let us discuss
gross versus net gradients.
GROSS versus NET
When the government determines minimum climb performance for aircraft
certification or departures, they add a "fudge factor" to compensate for
pilot reaction time, aircraft complexity etcetera. The actual
calculation of this factor involves complex formulations of obstacle
penetration of planes extending varying degrees from the departure path.
Suffice it to say, that the 200 ft/NM gradient includes governmental "fudge
factors" for safety, therefore the value is gross. In fact, aircraft
certifications (remember the 2.4% spoke of earlier) also contain "fudge
factors" and are also gross requirements. The government wants the
aircraft to be able to actually fly at least as well as these values,
with one engine inoperative.
Before we speak of how the pilot compares chart data with these
required values, let us look at the other situation. When a
departure procedure is not established for the runway. Here the pilot
must determine if the aircraft can clear an obstacle that lies within the
departure corridor if an engine should fail. This becomes a bit more
involved and provides the basis for how actual numbers are compared
to required gradients.
The required net (no government "fudge factors") 2nd segment climb
gradient is calculated by determining the rise in altitude from a reference
point above the end of a runway to the top of the obstacle. If an
aircraft were precisely able to maintain this gradient, it would "scrap
paint" as it passed over the obstacle. The government therefore would
like to "fatten" up this requirement ("gross-ify" it if you will) by
imposing regulation that requires 135 operators to clear the obstacle by 35
feet and also by adding its "fudge factor" to all operators. That
factor is 0.8% for two engines, 0.9% for three engines and 1.0% for four
engine aircraft.
Lets look at an example; an obstacle is 140 feet above the runway and
2000 feet from the runway end. The reference point above a dry runway
is 35 feet (15 feet for a wet runway, effectively increasing the required
gradient). Therefore, the geometric rise of 115 feet (140-35) divided by the
run of 2000 feet renders a required net gradient of 5.75%. Add
in the Part 135 requirement (35 feet clearance) and the resulting
required net gradient is 7.0%. Assuming a twin engine jet, the
required gross gradient becomes 7.8%.
Now that we know what minimum performance we must meet, we turn to the
performance charts to determine the actual climb gradient of the
aircraft under our specific take-off weight and atmospheric conditions.
Most 2nd Segment Climb charts are presented with Net results. This
means that the 0.8% "fudge factor" has been subtracted from the actual
performance of the aircraft. The pilot must carefully compare "apples
and apples". Directly comparing the results from a Net 2nd Segment
chart to required gross gradients (such as when departure procedures
exist) will be conservative because the "fudge factor" has been added twice.
Additionally, some manufacturers calculate the 2nd Segment climb
performance from the wheels up and locked altitude versus the 35 foot
reference point. Comparing the required gross gradient from our
calculation above, to an actual gradient using this higher reference
point results in a conservative comparison.
This discussion does not address Vmbe limitations, unbalanced field
lengths or other factors addressed individually within the operating
manuals.
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QUESTION:
If I am type rated in two aircraft (i.e. Challenger and Falcon), can I use
my night currency in the Challenger to fly the Falcon at night?
ANSWER:
Yes, if you meet the following:
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You are not operating under
parts 121, 125 or 135. In other words, you're operating under part
91 [61.57 (e)(1) and (2)]
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The type certifications are for
aircraft that require more than one pilot. [61.57 (e)(3)]
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You hold at least a valid
commercial pilot certificate. [61.57 (e)(3)(i)]
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You have logged at least 1500
hours total time [61.57 (e)(3)(ii)]
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You have logged at least 15
hours within the last 90 days within the Falcon. [61.57
(e)(3)(iii)]
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You are either:
night current in the Challenger
through three (3) actual take-offs and landings to a full stop within the
preceding 90 days [61.57 (e)(3)(iv)(A)]
OR
night current in the Challenger
through six (6) level C or D Challenger simulator take-off and landings to
a full stop within the preceding 12 months [61.57 (e)(3)(iv)(B)]
QUESTION:
In reading §61.57(e)(3)(iv)(B),
it appears this alternative night takeoff and landing currency requirement
provides that a PIC ". . . who operates more than one type of an airplane
that is type certificated for more than one pilot flight crewmember . . ."
has only a yearly night takeoff and landing currency instead of the every
"90 days" night takeoff and landing currency of §61.57(b)(1)? Is this
correct?
ANSWER: Yes, provided
the PIC meets the requirements of §61.57(e)(3) and complies with the
requirements of §61.57(e)(3)(iv)(B), then as per §61.57(e)(3)(iv)(B) the PIC
need only accomplish ". . . within the preceding 12 calendar months prior to
the month of the flight, ...which requires the performance of at least 6
takeoffs and 6 landings to a full stop as the sole manipulator of the
controls in a flight simulator that is representative of at least one of the
types of airplanes that the pilot seeks to operate under this
alternative . . ."
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| QUESTION:
What chart gives the 2.4% climb gradient requirement within the regs? ANSWER:
All the requirements of Part 25.121 pertaining to
takeoff limits, from liftoff to final segment, is covered within the MAX
WEIGHT FOR CLIMB table. This folds in the positive climb during 1st
segment, 2.4% in 2nd segment and 1.2% in final segment. All the other
stall speed and other requirements are also addressed in this table. If
you are at or less than the weight in the table, you meet these
requirements, which is part of the airworthiness of the aircraft. If you
are over the weight, the aircraft is no longer airworthy. Landing
Approach Max Weight covers the climb requirements for landing.
The third segment geometry is not factored into the
MAX EIGHT CLIMB table. Its is ignorant of the field you are departing
from and also of the terrain your are attempting to clear. This is the
main reason why a performance calculator is needed.
The 2nd segment charts give instantaneous values when
the gear is up and locked only. The 400 or 1500 foot limitation applies
to the extent of the distant obstacle chart. In other words, the
manufacturer has only performed performance degradation calculations out
to these altitudes, due to engine time and other operational criteria.
So 2nd segment tables are the snapshot of performance
at gear up and locked (which is predicated largely on weight), distant
obstacle charts are the calculated climb capability down range of the
point in time when the gear are up and locked assuming a given
instantaneous 2nd segment value.
Third segment is the distance you will cover, while in
level flight, to retract flaps and accelerate to Vfinal speed.
Then you add on Final segment and then enroute segment
capabilities.
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| QUESTION:
What constitutes an
instrument approach for purposes of logging and maintaining Part 61
Instrument currency? ANSWER: Any
published (approved) instrument procedure that utilizes a:
- Non-Directional Beacon (NDB)
- Localizer-type Directional Aid (LDA)
- Very high frequency Omnirange Station (VOR)
- Global Positioning System (GPS)
- Simplified Direction Facility (SDF)
- Instrument Landing System localizer (LOC)
- Microwave Landing System (MLS)
If the approaches are performed within an approved simulator or flight
training device, an authorized instructor (CFII or Instrument Ground
Instructor) must be present.
Unless you are referring to Instrument Proficiency Checks under 135, 121
or 91K, there is no requirement to fly the approach to minimums. You must
only "perform" the procedure. Perform, is generally understood to mean
"Start and conclude" the IAP, and an IAP is started at the FAF
and concluded either by breaking out or missing.
Flying beyond the FAF and going missed or completing the approach visually ("breaking out")
prior to the decision height or MDA is considered a "concluded" approach and
appropriate for logging.
61.57(c)
Instrument experience. Except as provided in paragraph (e) of this
section, no person may act as pilot in command under IFR or in weather
conditions less than the minimums prescribed for VFR, unless within the
preceding 6 calendar months, that person has:
(1) For the purpose of obtaining instrument experience in
an aircraft (other than a glider), performed and logged under actual or
simulated instrument conditions, either in flight in the appropriate
category of aircraft for the instrument privileges sought or in a flight
simulator or flight training device that is representative of the aircraft
category for the instrument privileges sought --
(i) At least six instrument approaches;
(ii) Holding procedures; and
(iii) Intercepting and tracking courses through the use of
navigation systems.
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| QUESTION:
The question
came up about logging "actual" instrument time when over the desert at
night with no visual references. When you are flying with sole reference to
instruments, is that actual time? If not, is it "simulated" instrument time?
Our take on the question is actual instrument time can only be logged when
the aircraft is in IMC. The weather determines actual instrument time, not
flying by sole reference to instruments. That settles the actual instrument
question, but what about "simulated" instrument time? Our feeling is it can
be logged as "simulated instrument time." It would be the same as having a
hood on while flying by sole reference to instruments.
ANSWER: Ref. §61.51(g); The only definition in the rules is the
definition on "instrument flight time" and that is addressed in §61.51(g)
and is defined as:
(g) Logging instrument flight time.
(1) A person may log instrument time only for that flight time when the
person operates the aircraft solely by reference to instruments under actual
or simulated instrument flight conditions.
However, I understand your question to be that you’re asking for a
definition of "actual instrument time" as opposed to "simulated instrument
time." I believe you’re interchanging the terms "actual instrument time"
versus "actual instrument conditions." And you state "simulated instrument
time" but the rules only state "simulated instrument conditions."
So there is no official FAA
definition on "actual instrument time" or "simulated instrument time" in the
FARs, FAA Orders, advisory circulars, FAA bulletins, etc. And the reason why
the FAA has never officially defined "actual instrument time" or "simulated
instrument time" is because in all of the aeronautical experience
requirements for pilot certificate and/or ratings in Part 61, the rule does
not differentiate
between "actual instrument time"
as opposed to "simulated instrument time." In fact, in Part 61 it only
refers to the aeronautical experience for instrument time to be ". . .
instrument flight time, in actual or simulated instrument conditions . . ."
So it is irrelevant whether the instrument flight time is logged as "actual
instrument time" or "simulated instrument time." Part 61 only refers to
"actual instrument conditions" or "simulated instrument conditions."
I agree with your statement that
just because a person is flying ". . . by sole reference to instruments . .
." has nothing to do with whether the flight can be logged as "actual
instrument time" or "simulated instrument time." Only the weather conditions
establish whether the flight is in "actual instrument conditions." And that
is dependent on the weather conditions where the aircraft is physically
located and the pilot makes that determination as to whether the flight is
in "actual instrument conditions" or he is performing instrument flight
under "simulated
instrument conditions."
But for a "quick and easy" answer
to your question, it was always my understanding if I were flying in weather
conditions that were less than the VFR weather minimums defined in §91.155
and I was flying "solely by reference to instruments" then that was the
determining factor for being able log instrument flight under "actual
instrument conditions." Otherwise, if I were flying solely by reference to
instruments in VMC conditions then I would log it as instrument flight in
"simulated instrument conditions." In your example, the flight is clear of
clouds and in good visibility conditions at night over the desert with an
overcast above and no visible horizon. But other examples could include
flight between sloping cloud layers or flight between layers of clouds at
night. These could equally meet the requirement for operations that can only
be accomplished solely by reference to instruments but remain in VMC.
Therefore, I would log this time as simulated.
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| QUESTION:
I have heard that drinking diet soda has caused
side-effects, especially for high altitude flying. Is this correct?
ANSWER:
I have heard this, however, besides the basic
dehydration problem which can be associated with diet-drink-only (no water
or other drinks) type of scenario, it seems there is no credible
scientific literature which supports the concerns.
It is my understanding that Aspartame is digested into
three components:
(1) Amino acids
(2) Phenylalanine
(3) Methanol
Typically the body gets these components in higher
quantities from foods. Unless one is drinking high quantities of diet
drinks and nothing else, diet drinks seem to pose no great health threat.
Apparently some pilots have boycotted the sweetener
because it was reputed to cause all kinds of bad stuff, including memory
problems, seizures and cancer. No peer-reviewed literature has confirmed
these claims. Check the Junk Science web page at:
http://www.junkscience.com/jun99/aspart.htm
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| QUESTION:
Where is the datum that MSL (mean sea level) is
measured?
ANSWER:
Mean Sea Level (MSL) is a local tidal datum which is determined by averaging
the hourly height readings over a specific 19 year period.
NOS operates a network of water level stations for which those local
datums are determined.
The term MSL has also been confused with the geodetic datum, National
Geodetic Vertical Datum of 1929 (formerly called the Sea Level Datum of
1929). It has appeared and may still appear on outdated maps or references
to land based topographic elevations as the geodetic datum zero. It was
originally based on local mean sea level measurements at 26 tide
stations in the US and Canada and adjusted in the year 1929.
The geodetic datum, NGVD is a fixed datum, while MSL is not.
Steve Lyles, National Ocean
Service
National Oceanic and Atmospheric
Administration
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| QUESTION:
2) What special equipment and crew training is
needed and at what altitude may I fly?
ANSWER:
Q1 Yes, but you will not be able to fly in RVSM airspace airspace
(FL290 to FL410) , therefore you'll have to file FL280 or below, or
FL430+. RVSM also applies in Europe and, if you fly across the Atlantic
at FL430+, you will be descended below RVSM airspace as soon as possible
on leaving oceanic airspace.
Special procedures do apply to delivery flights or emergencies which
relax the rules.
Q2 If you fly in MNPS airspace you must have approval for
both the equipment and crew from the State of Registry of the aircraft.
MNPS airspace extends from FL 285 to FL420 so to avoid both RVSM &
MNPS you still have to fly at FL 280 or below or FL430+ . Note, however
that you still are required to have appropriate HF Comms. equipment. If
you do not have HF R/T equipment it is still possible to fly on special
routes via Greenland and Iceland, where VHF cover is available, however
prior approval is required for this from both Gander and Reykjavik ATC.
Response given by
North Atlantic Program Coordination Office (NAT-PCO) on behalf of the
International Civil Aviation Organization (ICAO)
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QUESTION:
On a jet
aircraft with electronic standby instruments, the standby airspeed
indicator shows approximately 5 knots higher IAS (about .03 higher mach)
than the pilot's and copilot's airspeed indicators that are fed through air
data computers. This occurs at altitude (FL 370) and the error decreases as
altitude decreases. Why?
ANSWER: The standby instrument does not take into account
compressibility.
Compressibility increases with altitude.
submitted by David Synder, CFII |
| QUESTION: What, if any, compensation is
made to IAS by air data computers (i.e. does
an ADC correct for density altitude)? ANSWER: ADC's compensate for
compressibility and instrument error. ADC will also
compensate for density altitude, and it will display TAS in another location
(ie. MFD or separate SAT/ TAS gauge).
submitted by David Synder, CFII |
QUESTION: The FARs Part 1.1
(definitions) define indicated airspeed as
"the speed of an aircraft as shown on its pitot static airspeed indicator
calibrated to reflect standard atmosphere adiabatic compressible flow at sea
level UNCORRECTED for airspeed system errors." The Instrument Flying
Handbook AC 61-27C defines indicated airspeed basically the same with the
exception "calibrated to reflect standard atmosphere adiabatic compressible
flow at sea level CORRECTED for airspeed system errors." Which one is
correct and what exactly does this mean?
ANSWER: I believe the only difference is whether or not your aircraft
has an Air Data Computer (ADC)
or not. In other words, both are correct. The FAR is correct for non ADC
aircraft.submitted by David Synder, CFII
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QUESTION:
What are special airworthiness certificate in the limited, restricted,
experimental and primary
categories?
ANSWER: The Limited certificate is issued to operate surplus military
aircraft that have been converted to civilian use under the following
conditions:
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The aircraft has a limited type certificate. |
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The FAA has determined that the aircraft is safe to
operate. |
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Operations may not include carrying passengers or cargo
for hire. The FAA may prescribe additional limitations as necessary for
safe operation. |
FAA Order
8130.2 contains a list of aircraft models that have been issued limited
category type certificates.
Primary category aircraft are of a simple design and
intended exclusively for pleasure and personal use. Although these aircraft
may be available for rental and flight instruction under certain conditions,
the carrying of persons or property for hire is prohibited.
Aircraft certificated in the primary category must be
manufactured under a production certificate. This includes aircraft
assembled from a kit under the production certificate holder's supervision
and quality control system. Kit-built aircraft built without the production
certificate holder's supervision are only eligible for certification in the
experimental category (see below).
Restricted category aircraft is limited to special
purposes identified in the applicable type design. These special purpose
operations include the following:
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Agricultural (spraying, dusting, seeding, and livestock
and predatory animal control). |
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Forest and wildlife conservation. |
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Aerial surveying (photography, mapping, and oil and
mineral exploration). |
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Patrolling (pipe lines, power lines, and canals). |
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Weather control (cloud seeding). |
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Aerial advertising (skywriting, banner towing, airborne
signs, and public address systems). |
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Any other operation specified by the Administrator. |
The Experimental certificate is issued to operate
an aircraft that does not have a type certificate or does not conform to its
type certificate. Additionally, this certificate is issued to operate
kit-built aircraft that were assembled without the supervision and quality
control of the production certificate holder. Special airworthiness
certificates may be issued in the experimental category for the following
purposes:
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Research and development: to conduct aircraft
operations as a matter of research or to determine if an idea warrants
further development. Typical uses for this certificate include new
equipment installations, operational techniques or new use, or pure
research. |
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Showing compliance with regulations: to show
compliance to the CFR when an applicant has revised the type certificate
design data or has applied for a supplemental type certificate or field
approval. |
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Crew training: for training the applicant’s
flight crews in experimental aircraft for subsequent operation of aircraft
being flight tested in Type Certificate programs or for production flight
testing. |
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Exhibition: to exhibit an aircraft’s flight
capabilities, performance, or unusual characteristics for air shows,
motion pictures, television, and similar productions, and for the
maintenance of exhibition flight proficiency. |
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Air racing: to operate an aircraft in air races,
practice for air races, and to fly to and from racing events. |
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Market surveys: to conduct market surveys, sales
demonstrations, and customer crew training for U.S. manufacturers of
aircraft or engines. |
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Operating amateur-built aircraft: to operate an
amateur-built aircraft in which the major portion has been fabricated and
assembled by persons for their own recreation or education. An aircraft
built from a kit may also be eligible for amateur-built certification.
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Operating kit-built aircraft: to operate a
primary category aircraft that was assembled by a person from a kit
manufactured by the holder of a production certificate for that kit,
without the supervision and quality control of the production certificate
holder. |
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QUESTION:
Let's say that I have logged one instrument approach each month from
April through August. I have not flown an instrument approach in September
but I expect one on the last day of the month. I have a flight on September
15, can I legally be PIC on an IFR flight?
ANSWER: No.
Ref. §61.57(c) and (d); A person may not act/serve as PIC under IFR or in
weather conditions less than the minimums prescribed for VFR if he has not
accomplished the instrument currency tasks of paragraph (c) of § 61.57
within the preceding 6 calendar months. The way to read §61.57(c) and (d) is
as follows:
In order for a pilot to act/serve as PIC under IFR or in weather
conditions less than the minimums prescribed for VFR, that pilot a person
must have ". . . performed and logged under actual or simulated instrument
conditions, either in flight in the appropriate category of aircraft for the
instrument privileges sought or in a flight simulator or flight training
device that is representative of the aircraft category for the instrument
privileges sought--
(i) At least six instrument approaches;
(ii) Holding procedures; and
(iii) Intercepting and tracking courses through the use of navigation."
Otherwise, the pilot should check their logbook to find that it shows the
following instrument currency tasks performed within the preceding
6 calendar months:
(i) At least six instrument approaches;
(ii) Holding procedures; and
(iii) Intercepting and tracking courses through the use of navigation
systems.
Our example:
An IFR flight is proposed on the 15th of September.
The pilot would check for the required instrument currency experience back
as far as the first day of March [i.e., as per § 61.57(c) ". . . within
the preceding 6 calendar months, that person has . . ."] emphasis added "calendar months." In this scenario, ". . . within the
preceding 6 calendar months, that person has . . ." equates to experience
for the requirements logged up to 204 days previous, rather than just 180
days, because as per § 61.57(c) ". . . within the preceding 6 calendar
months, that person has . . .". However, if for instance only 5 approaches
had been logged during this period and the first of the required 6
approached had been logged on February the 28th the pilot could
not file the flight plan and be able to act/serve as the pilot-in-command
under IFR or in weather conditions less than the minimums prescribed for
VFR. His currency for this purpose would have ended on August 31.
Now, in our example, if the first of the usable five approaches had
been logged, lets say, on the 10th of June and the
holding/intercepting requirements had been met since then, our pilot could
not act as PIC, but he is "within 6 calendar months after the prescribed
time" (the second six months). As soon as he makes at least one additional
instrument approach (actual or simulated conditions) his currency for
acting (serving) as PIC suddenly jumps to December 31st, representing 6
calendar months from June 10 through December 10 and actually to the end
of December.
If our pilot had logged all of the 5 approached in June and did not
have the opportunity to do any further instrument flight on or before the
last day of June the next year, our pilot would now be required to meet
the instrument proficiency check requirements of §61.57(d). And then the
clock starts all over again (i.e., first six calendar months, second six
calendar months, and IPC).
If our pilot had 1 approach/month, with the first in April
AND did not have the opportunity to do any further instrument flight on or
before the last day of of March the following year, our pilot would now be
required to meet the instrument proficiency check requirements above.
What you expect to fly in the future is irrelevant.
QUESTION:
How did the FAA come
up with the two engine second segment 2.4% climb gradient? Is it tied to
anything or is it purely arbitrary? Why is the three engine and four engine
different?
ANSWER:
Actually,
The 2.4% mentioned has nothing to do with the 2nd Segment climb. It
refers to the certification of transport category aircraft with 2 jet
engines in particular. That type of aircraft must, with one engine
inoperative, be able to climb to 400 ft with flaps in the takeoff position
at no less than a 2.4% gradient. 2nd Segment typically goes to 1500 and
flaps can be retracted before 400 feet. Three engine is 2.7% and 4
engine is 3.0%.
The 3 and 4 engine differences comes into play by a requirement in the
General section of FAR 25;
(h) The procedures established under paragraphs (f) and (g) of this
section must—
(1) Be able to be consistently executed in service by crews of average
skill;
(2) Use methods or devices that are safe and reliable; and
(3) Include allowance for any time delays, in the execution of the
procedures, that may reasonably be expected in service.
(i) The accelerate-stop and landing distances prescribed in §§25.109 and
25.125, respectively, must be determined with all the airplane wheel brake
assemblies at the fully worn limit of their allowable wear range.
The FAA decided that to meet these requirements, that aircraft with more
engines, usually heavier, longer accelerate-stop distances needed to be
able to climb at the higher gradient.
Keep in mind, that minimum SID requires 3.3% or higher. So your Max Wgt
for Climb charts only confirm basic aircraft certification. To ignore, or
not calculate this value, if such a chart exists for your aircraft, is to
run the risk of taking off with conditions that do not meet the aircraft's
certification, i.e the aircraft is not airworthy. You then need to
confirm that you can make the SID by comparing the 2nd segment charts (or
better yet SID climb charts if available).
Remember to compare Gross gradients (SIDs) with Gross (not Net)
performance charts.
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So what’s going on with the
latest advisory circular on weight & balance? Well, first, for whom is
AC120-27E intended? In a word, everyone. The circular clearly states that
the process described within is applicable to part 91, 91k, 135 and 121, but
unless you operate in the realm where Advisory Circulars are law, the eighty
page document is advisory in nature only. If you choose not to follow the
circular, understand that the FAA, under current regulations can, and
probably will, ask you to demonstrate how the center of gravity is
maintained within the operational envelop during the ENTIRE flight.
AC120-27E is a product of recommendations from the NTSB after a commuter
aircraft crash in South Carolina. Even though W&B played only a minor role
in the incident, the NTSB made several observations that current loading
procedures, do not take into consideration, passenger, crew and equipment
movement during flight. So right out of the chute, even if you use actual
weights, if passengers or crew have the opportunity to move about during
flight, you are affected by this circular.
Two other factors which
were identified that could potentially be problematic are the use of
standard or segmented weights and non-assigned seating. Ultimately, the FAA
solution to these recommendations involves curtailing (trimming down) the CG
envelop. The crew and passenger movement factor is a fairing
straight-forward adjustment, but the later two methodologies require a more
elaborate correction involving statistical sampling and adjustments to the
CG envelop. Each adjustment is cumulative, in other words, each curtailment
is on top of the previous adjustment. So, if you plan on using segmented
weights, unassigned seating in a cabin with a lavatory, then be prepared to
greatly reduce the operational CG envelop of your aircraft.
Since all piston and
single engine turbine aircraft are prohibited from using anything other than
actual weights, their only consideration, and the first consideration for
everyone else, is crew, passenger and equipment movement within the cabin.
The idea is to determine the most extreme and probable change in CG by the
movements. Assuming that the aircraft manufacturer did not already curtail
the envelop during certification to account for passenger movement, then the
moment change for, lets say, a crew member moving to an aft lavatory, must
be added to the total aircraft takeoff moment. If the resulting CG falls
outside the envelop then this would be a potentially adverse condition. So
the moment adjustment must be translated to a CG arm restriction in order to
keep the loaded CG from falling too close to the aft limit. Other common
movements might be passengers moving from the aft seats to the jumpseat or
galley. Though not mentioned within the circular, operational limits can be
addressed within the ops spec that would make certain movements unlikely,
such as "No passengers allowed into the galley for twenty minutes after
takeoff or until the fasten seat belt sign has been extinguished". This
approach would require FSDO approval and appropriate justification, i.e.
twenty minute fuel burn would eradicate the potential CG violation of the
limits due to the passenger movement. These extreme movements may be found
within the loading documentation of your aircraft, but if not, one must be
determined for your unique interior design.
The use of standard or
segmented weights adds another level of uncertainty to the loading
equation. Standard weights have been identified by the FAA through a survey
conducted by the Center for Disease Control. While you are not required to
use these values, the alternative is to conduct your own survey with the
sample size numbering more than two thousand passengers. This, therefore,
would only be recommended if your particular operation routinely and
pervasively involved passengers not meeting the FAA criteria. To their
credit, the FAA filtered through piles of statistical studies and created
subsets of "passengers" who where adult versus children and further divided
the adult group into male and female subsets. Members of each group who
fell well outside the mean were removed. Crew member weights on the other
hand came from first and second class medical records. Baggage and carry-on
weights were derived from several airline studies.
So why, you might ask,
if we are using these standard weights must the operational envelop be
curtailed further? Well, you have probably heard the adage, "there are
lies, damn lies and then there are statistics". Statistics are only 100%
reflective of the entire population when you sample the entire population.
This obviously is not practical and the reason we have statistical analysis
at all. As you sample fewer and fewer people, the confidence level one has
in the results, of accurately describing the population, becomes less and
less. Ultimately, our goal is to make a statement of fact (the average
weight of our passengers) based on the average of a very large group of
passengers. The more people in each group, the better the two will match.
Therefore, a large aircraft with several hundred passengers, will have an
average weight that is statistically more reflective of the entire
population than an aircraft with only four passengers. So, even though we
are both using the same standard weight for a passenger, the likely hood
that a small aircraft actual average weight will vary from the entire
population is greater. It is this uncertainty that the FAA wants factored
into your operational CG envelop. One more thing, even with the curtailments
described above, there must be a procedure in place to override an obvious
non-standard passenger weight.
The third factor has
to do with how passengers are seated within the cabin. When passengers are
not assigned seats, there is a seemingly endless number of seating
combinations, i.e. passenger A in seat one, passenger B in seat 2 and so on.
To get a manageable handle on these possibilities, we are allowed to make
assumptions to eliminate those possibilities that are not probable. For
instance, it is highly unlikely that a sole passenger onboard would sit in
the lavatory. Airlines, for years, have used a widely accepted assumption
called the "window-aisle-remaining" method. Passengers are assumed to take
the nearest window seat, then the nearest aisle seat and then those
remaining. The statistics and subsequent curtailment of the envelop to
accommodate this seating flexibility probably does not warrant its use in
small cabin aircraft, particularly if the inconvenience of using the actual
seat assignment can be minimized.
Obviously, due to the
mathematical gymnastics involved, the old style manual loading manifests and
wiz-wheels will soon reveal themselves as burdensome. EFB-Pro with the
Standard Weight module simplifies the assignment of seats. In fact,
passenger seating adjustments can be performed and the entire W&B
recalculated on-the-fly without undo inconvenience or even awkwardness. The
program automatically uses one envelop when using actual weights and another
when using standard weights. As male, female and children counts are exact,
then a smaller curtailment is required than if the FAA's standard passenger
(gender neutral) weight is used. If all actual weights are used, then the
envelop reflects only passenger movement curtailments. The fuel burn CG is
graphically overlaid on the operational CG envelop from takeoff to zero fuel
weight (actually reserve fuel only weight), thus no further curtailment is
required. While this article does not go into the detail necessary to
actually create the curtailments discussed, CAVU Companies is available to
assist any operator.
Question:
Under Part-135, am I legal to depart on the basis of "Area Forcast" when
destination station does not have weather(METAR/TAF available). If yes,
then how I am going to decide that whether I need an "Alternate" or Not.
Answer:
Normally, an IFR certified 135 operator will have the weather reporting
requirements identified within the C55 section of their Ops Spec. and of
course airports with instrument approaches would have the reporting
requirements. Ops Specs may have conditions (i.e. An airport without
weather may use an airport within 20 miles to determine current weather
etc) outlined for the specific operator.
Now assuming the Ops Spec is silent on this issue or the operations are
conducted purely under VFR, then the overall impression would be governed
by part 91.103, appropriate 135 subsections and the examiners handbook
8400.10. Overall, I would say an Area Forcast does not meet these stated
regulatory requirements for terinal operations. An aera forcast does meet
enroute operational weather forecasting. I have included sections 1407 and
1409 of the handbook to substantiate this position.
1407. POLI CY ON CONDITI ONAL
PHRASES IN REMARKS PORTION OF
WEATHER FORECAST.
A. Weather forecasts provided by the National
Weather Service (NWS) and other sources often
have conditional phrases such as “occasional,”
“intermittently,” “chance of,” or “tempo” in the
remarks portions of the forecasts. These phrases
supplement the main body of the forecast by
indicating the probability of changing conditions
during the forecast period. These modifying
phrases, used in the remarks portion of a terminal
forecast (FT), indicate the weather conditions for
an area within 5 nautical miles of a runway
complex. Certain regulations concerning the
selection of destination and alternate airports
require that “weather reports or forecasts, or any
combination thereof, indicate that the weather
conditions will be at or above...” the minimum
weather conditions specified in those regulations.
The FAA Office of Chief Counsel has consistently
interpreted these regulations to mean that the
worst weather condition in any of the reports or
forecasts used to control a flight movement is the
controlling factor. These interpretations make the
remarks portion of a forecast as operationally
significant as the main body of the forecast.
Therefore, it is FAA policy that the worst weather
condition in the main body or the remarks portion
of a terminal forecast, as well as any weather
report used, is the controlling fact or when
selecting a destination or alternate airport.B. Thi s p ol i c y mu st be
ap pl i e d w hen
determining compliance wi th the following
regulations:
• §121.613 - Dispatch or flight release under
IFR or over the top
• §121.615 - Dispatch or flight release over
water: Flag and supplemental air carriers
and commercial operators
• §121.619 - Alternate airport for destination:
IFR or over the top: Domestic air
carriers
• §121.621 - Alternate airport for destination:
Flag air carriers
• §121.623 - Alternate airport for destination;
IFR or over the top: Supplemental
air carriers and commercial operators
• §121.625 - Alternate airport weather
minimums
• §135.219 - IFR: Destination airport
weather minimums
• §135.223(b) - IFR: Alternate airport
requirements
• § 91.169 - Flight plan; information
required (IFR alternate airport weather
minimums)
1409. POLICY FOR DETERMINING THE
CONTINUED ADEQUACY OF WEATHER
REPORTS AND OBSERVATIONS.
A. The purpose of regulations which establish
weather minimums, or which require flightcrews
and dispatchers to consider weather conditions, is
to prevent unsafe flight operations. The phrases
“current weather” and “latest weather report”
have occasionally been interpreted inappropriately
resulting in noncompliance with 14 CFR and in
diminished safety inflight operations.
B. Because weather conditions can change
rapidly, a continuing watch over weather
conditions must be maintained wherever Part 121
4/2/03 8400.10 CHG 18
Vol. 3 3-659
or IFR Pa rt 135 termina l operations are
conducted. For surface weather observations to be
considered “current,” one of the following two
conditions must be met:
(1) A specifically approved automated
weather observation system must be fully operational
while terminal area flight operations are
conducted.
(2) An observer station of an appropriate
type (listed in paragraph 1439 or 1441) must be
fully operationa l and must maintain a basic
weather watch as follows:
(a) For scheduled operations, a basic
weather watch must begin in time to make an
observation available to pilots and dispatchers at
least 30 minutes before the estimated time of
arrival or departure. The basic weather watch may
not be discontinued until the arrival or departure is
completed.
(b) For nonscheduled operations, the
basic weather watch should begin at least 30
minutes before the estimated time of arrival or
departure and must begin in time to provide pilots
with an observation before beginning the approach
or departure. The basic weather watch must not be
discontinued until the arrival or departure is
completed.
14 11. SOURCES FOR TECHNICAL
ASSISTANCE AND METEOROLOGICAL
REFERENCES. When ev aluat ing wea ther
information systems, an inspector should not hesitate
to contact local NWS facilities for technical
assist anc e and expe rt ise. An inspector who
encounters situations which are not addressed in
this handbook should contact AFS-400 for technical
assistance.
A. Additional meteorological information can
be found in the following selected references:
• Advisory Circular (AC) 00-6A, Aviation
Weather
• AC 00-24, Thunderstorms
• AC 00-45C, Aviation Weather Services
• AC 00-50A, Low Level Windshear
• ICAO Document 8896-AN/893/2, Manual
of Aeronautical Meteorological Practice
• FAA Windshear Training Aid, volumes 1
and 2
B. For information on obtaining aviation
weather from the internet, see AC 00-62, Internet
Communi cat ions of Avi at ion Wea ther and
NOTAMs.
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