Caught by an Odd Required Equipment Question!

[KennyFlys]

Yesterday was the oral for my CFI Initial. Nope, I didn't pass. I rather expected it. I knew I had weaknesses but not sure what. It's easy to go through things and think you have an item covered well enough but there are some elements still slipping. One such area for me was visual scanning. I missed a couple visual illusion items. In all there were ten out of some seventy-five items we covered.

Even though only a couple tasks are required to be covered in each area, he manages to link to practically every other task throughout the entire PTS. Sometimes he would just bring up an element that linked but most of the time he took advantage of my answer. When I finished an explanation, he'd reply with, "Speaking of 'blank'..." Open mouth, insert foot!

This week, I'll go through my deficiencies and prepare to complete the oral before the flight next Tuesday. I shouldn't have any problems at all. I had worried over the FOI and I flew through it quite well.

One of the things I thought about during discussion of maneuvers was while working from the CFI PTS, without directly referencing my lesson plan, I was forgetting about tolerances during a maneuver. Along with other references in the CFI task, writing the corresponding Private Pilot or Commercial Pilot task letter could be a reminder to bring up other elements and tolerances as well as quickly refer to that specific task in the appropriate PTS.

I had a couple very odd ones for which I'm dumbfounded. So, I'm kicking them out there for some help...

1) We were discussing Systems & Equipment Malfunctions (CFI Task XIII-B ). I went through those items just fine but then he took it bit further with regard to Required Equipment which links back to Task III-E, a task we did not do in that area.

Continuing from an Engine Overheat, he asked about the cylinder head gauge as required equipment. Okay, it's not required per 91.205 but it is required in the POH Section 6 Equipment List.

So far, so good. He's not done, though. "What about the older planes with a POH that were only this thick?", while indicating a thickness of barely a quarter-inch. The best I've determined thus far he was referring to aircraft prior to 1966. The POH for those aircraft do not have an equipment list.

So, the question is... How do you know if such an airplane would require a given piece of equipment that is NOT required by 91.205?

I stated an AD was one possibility. He accepted that but he wanted more. Thus far, neither I, my Chief CFI nor three A&Ps who maintain our birds can provide an answer.

After the oral, I went to lunch with him. He told me some very interesting stories which I'll tell at the bottom of my post. One was regarding a compass card. I stated I did not know how a compass was swung to get such precise deviations of only a few degrees but it had to be an interesting process. He said the maximum deviation allowed is five degrees. The most interesting thing he said afterward was this rule is not in any of the existing FARs or other easily available publication. It's part of the original Civil Aviation Regulations before the issuance of the first FARs we now work from. I'm at a loss if this is the same source for my answer.

2) The other one I got hit with was from Task VI-A, Radio Communication, item 1-b, specifically phraseology. He asked about the terms, "Over" and "Out." I answered them as follows:

Over: Your transmission is complete and you're returning control to the other party.

Out: Your communication is complete and you have nothing further.

But, he wanted more than that. I haven't the slightest clue as to what! Any clues as to what I may be missing?

Okay, I promised to pass on a couple stories...

One multi-engine pilot showed up with a Seneca to take his commercial-multi add-on. There was no compass card so the ride was off. While the examiner was still there talking with the pilot, another pilot arrived and had offered to loan his compass card to the pilot in the Seneca so he could complete his his checkride. Doh!

Another pilot had a compass card that didn't have any numbers filled in. When queried on the lack of a complete compass card, the pilot stated he bought a blank one for fifty cents because the avionics shop wanted over $200 to get one that was filled in.

There were several more that included bribe offers but the granddaddy of them all was the female CFI who showed up with her female student. The local weather wasn't quite right for a checkride so the CFI suggested they fly up to Kentucky, get a hotel for the night and do the checkride the next morning when weather was going to be clear. Of course, only one hotel room would be necessary.

This guy taught his first lesson as a college student in 1969. He's got the makings for a great book. I hope he writes it. I'll sure as heck buy one!

 

[alaskaflyer]

2) The other one I got hit with was from Task VI-A, Radio Communication, item 1-b, specifically phraseology. He asked about the terms, "Over" and "Out." I answered them as follows:

Over: Your transmission is complete and you're returning control to the other party.

Out: Your communication is complete and you have nothing further.

Maybe he was wanting you to hit the contrast a little harder: "Over" indicates you expect a response, "out" indicates that you do NOT.

Other than that, I thought I read somewhere that the terms were considered by the FAA to be obsolete and should no longer be used, but I can't remember where I read it and might be making that up completely

 

[alaskaflyer]

1) We were discussing Systems & Equipment Malfunctions (CFI Task XIII-B ). I went through those items just fine but then he took it bit further with regard to Required Equipment which links back to Task III-E, a task we did not do in that area.

Continuing from an Engine Overheat, he asked about the cylinder head gauge as required equipment. Okay, it's not required per 91.205 but it is required in the POH Section 6 Equipment List.

So far, so good. He's not done, though. "What about the older planes with a POH that were only this thick?", while indicating a thickness of barely a quarter-inch. The best I've determined thus far he was referring to aircraft prior to 1966. The POH for those aircraft do not have an equipment list.

So, the question is... How do you know if such an airplane would require a given piece of equipment that is NOT required by 91.205?

Type Certificate Data Sheet?

 

[tonycondon]

thanks for the report Kenny. Sorry you busted but it seems that you are moving on from it and learning from it, great! Seems sorta lame (to me) that on the stuff you missed he was expecting more of an answer but then after you didnt know he wouldn't tell you what he was looking for.

 

[KennyFlys]

Maybe he was wanting you to hit the contrast a little harder: "Over" indicates you expect a response, "out" indicates that you do NOT.

Other than that, I thought I read somewhere that the terms were considered by the FAA to be obsolete and should no longer be used, but I can't remember where I read it and might be making that up completely

I had even stated I never used them and seldom heard them used when listening to JFK tower and airliners.

All he would tell me is there were very definite meanings and they were often misused.

 

[tonycondon]

Type Certificate Data Sheet?

thats what I was thinking as well. All the required instruments are on them, at least on the few I've looked at, and that was for airplanes with 1/8" thick POH's

 

[alaskaflyer]

thats what I was thinking as well. All the required instruments are on them, at least on the few I've looked at, and that was for airplanes with 1/8" thick POH's

That is the only place I know of where required equipment is listed on CAR-certified airplanes such as mine.

 

[KennyFlys]

thanks for the report Kenny. Sorry you busted but it seems that you are moving on from it and learning from it, great! Seems sorta lame (to me) that on the stuff you missed he was expecting more of an answer but then after you didnt know he wouldn't tell you what he was looking for.

A couple times, he gave me leading questions as he was pretty sure I knew but was drawing a mental block. Hence, my suggestion at referencing other PTS tasks in the CFI PTS. I knew the landing point tolerance for a power-off 180 was -0/+200. But, WHY did I know that??? Oh yeah, it's in the Commercial PTS! Doh!

A few things were pretty lame and stupid on on my part but I crossed the threshold on anxiety that seemed to put me over the edge. I was trying to rattle off light signals and VFR cloud separation and blew both. I just have to keep writing my diagrams in my head so they are more clear as envision them and read from the picture in my mind.

That, and do more drugs!

I drove up the night before thinking I could be better rested by staying in a local hotel. I wasn't. Lesson learned: Don't stay at a cheap hotel! Between a lousy bed and horrible heating control, it wasn't pleasant. The funny thing was, I'm used to trains going by my house just 200 yards away. I couldn't get used to the cars outside the door. Next week, I'll fly up that morning.

 

[KennyFlys]

Type Certificate Data Sheet?

thats what I was thinking as well. All the required instruments are on them, at least on the few I've looked at, and that was for airplanes with 1/8" thick POH's

The 1/8" is more accurate for those manuals I recall. I don't have any of those in hand. It's been a while since I've looked at a TCDS but I'll look up some on the FAA site.

Can anyone recall an older aircraft where a CHT guage or other instrument may be required but is not in the POH? I'd like take back a specific example either with an older Cessna or something specific to a CHT guage.

 

[tonycondon]

kenny i'd look at the TCDS for an old 182. I believe that most of them just say something like "engine gauge cluster" in the equipment list instead of specifically CHT, EGT, Oil Temp etc. IMO that means they all have to be working.

 

[alaskaflyer]

The 1/8" is more accurate for those manuals I recall. I don't have any of those in hand. It's been a while since I've looked at a TCDS but I'll look up some on the FAA site.

Can anyone recall an older aircraft where a CHT guage or other instrument may be required but is not in the POH? I'd like take back a specific example either with an older Cessna or something specific to a CHT guage.

Kenny, prior to 1966 there was no such thing as a "POH" in a small aircraft. Many planes had owners manuals which did not carry approved data and were not required to be on board. There was a sheet of paper which had approved data such as RPM limits, oil temps, MP limits etc. but not required equipment. We are now required to have that paper on board.

I'd go to the FAA website and look up a TCDS for a late 50's or early 60's era 182 or 180 to see if a CHT guage is listed.

 

[midlifeflyer]

So, the question is... How do you know if such an airplane would require a given piece of equipment that is NOT required by 91.205?

I like this examiner, if only because the unjustified and misguided concentration on 91.205 is one of my soapbox issues.

I don't know what he was looking for, but I know that 91.213(d)(2) gives you, in the absence of a MEL, a punchlist of the sources of required equipment information:

==============================
(i) Part of the VFR-day type certification instruments and equipment prescribed in the applicable airworthiness regulations under which the aircraft was type certificated;
(ii) Indicated as required on the aircraft's equipment list, or on the Kinds of Operations Equipment List for the kind of flight operation being conducted;
(iii) Required by § 91.205 or any other rule of this part for the specific kind of flight operation being conducted; or
(iv) Required to be operational by an airworthiness directive;
==============================

Of course, unless you're dealing with current FAR certifications, you might have a bit of difficulty locating the old CAR references for (i). The TCDS might or might not give you the full answer.

 

[ejensen]

My 68 Mooney only has a 1/4 thick Owners Manual but it also came with a compete equipment list for W&B. Don't know if this make the equipment required or not. There are some items listed on the TCDS but not much.

 

[gkainz]

* Over — I have finished talking and I am listening for your reply. Short for "Over to you."
* Out or Clear — I have finished talking to you and do not expect a reply.
* Roger — Information received.
* Copy — I understand what you just said (after receiving information).
* Wilco — Will Comply (after receiving new directions).

(underline mine: gdk)

"Over and out" is an incorrect combination, since the two statements contradict each other.

"Roger" was the U.S. military designation for the letter R (as in received) from 1927 to 1957.

http://en.wikipedia.org/wiki/Voice_procedure


See http://www.faa.gov/airports_airtraffic/air_traffic/publications/media/aim.pdf Glossary, page PCG O−3

 

[KennyFlys]

* Over — I have finished talking and I am listening for your reply. Short for "Over to you."
* Out or Clear — I have finished talking to you and do not expect a reply.
* Roger — Information received.
* Copy — I understand what you just said (after receiving information).
* Wilco — Will Comply (after receiving new directions).

Thanks Greg. I'm still not sure how my answers fell out of line with what you're stating or what I've seen in the AIM. I'll take the AIM references, discuss it with my CFI and go from there.

 

[poadeleted20]

For those older planes, there may be items listed in the type certification package which aren't in the TCDS, and the only way to find out for sure is to go to the Aircraft Certification Office covering your type and find that package. Just pray it wasn't flooded out and destroyed by a faulty fire alarm at the Atlanta ACO like the official, original AFM for the pre-s/n 41 GA-7 Cougars, for which no truly legal replacement is available (the only other source, the current French type certificate holder, being uninterested in helping). However, I've never heard of the FAA jamming up a pilot over whether or not something not listed in the FAR's or any readily available document is required for flight, and the Baltimore FSDO was satisfied with a photocopy of someone else's pre-s/n 41 Cougar AFM with suitable inserts for my Cougar's W&B and equipment list.

 

[MathewSharp]

Regarding the CHT gauges:

If the aircraft has cowl flaps it is going to require a CHT gauge. The red line should be set to the POH number for CHT if there is one.....

I prefer never to see CHT's great than 400 on any aircraft personally!

Matt

 

[JohnR]

"How do you know if such an airplane would require a given piece of equipment that is NOT required by 91.205?"

Parts manual. Optional vs. Installed equipment?

Sorry to hear about your bust. Keep trying. Builds character.

 

[MauleSkinner]

Kenny, prior to 1966 there was no such thing as a "POH" in a small aircraft. Many planes had owners manuals which did not carry approved data and were not required to be on board. There was a sheet of paper which had approved data such as RPM limits, oil temps, MP limits etc. but not required equipment. We are now required to have that paper on board.

I'm not sure that this is entirely correct...I did a little research regarding this subject for a post on the Red board about the manual requirements for a Pacer:

The PA-22 was certificated under CAR 3. Already back in 1951, there was a requirement for an approved Airplane Flight Manual in the regulation under which the airplane was certificated.

AIRPLANE FLIGHT MANUAL

§ 3.777 Airplane Flight Manual. An Airplane Flight Manual shall be furnished with each airplane. The portions of this document listed below shall be verified and approved by the Administrator, and shall be segregated, identified, and clearly distinguished from portions not so approved. Additional items of information having a direct and important bearing on safe operation may be required by the Administrator when unusual design, operating, or handling characteristics so warrant.

§ 3.778 Operating limitations—

(a) Airspeed limitations. Sufficient information shall be included to permit proper marking of the airspeed
limitations on the indicator as required in § 3.757. It shall also include the design, maneuvering speed, and the maximum safe air speed at which the landing gear can be safely lowered. In addition to the above information, the significance of the air speed limitations and of the color coding used shall be explained.

(b) Power-plant limitations. Sufficient information shall be included to outline and explain all power-plant limitations (see § 3.744) and to permit marking the instruments as required in § 3.759.

(c) Weight. The following information shall be included:

(1) Maximum weight for which the airplane has been certificated,

(2) Airplane empty weight and center of gravity location,

(3) Useful load,

(4) The composition of the useful load, including the total weight of fuel and oil with tanks full.

(d) Load distribution.

(1) All authorized center of gravity limits shall be stated. If the available space for loading the airplane is adequately placarded or so arranged that any reasonable distribution of the useful load listed in weight above will not result in a center of gravity location outside of the stated limits, this section need not include any other information than the statement of center of gravity limits.

(2) In all other cases this section shall also include adequate information to indicate satisfactory loading combinations which will assure maintaining the center of gravity position within approved limits.

(e) Maneuvers. All authorized maneuvers and the appropriate air-speed limitations as well as all unauthorized maneuvers shall be included in accordance with the following:

(1) Normal category. All acrobatic maneuvers, including spins, are unauthorized. If the airplane has been demonstrated to be characteristically incapable of spinning in accordance with § 3.124 (d), a statement to this
effect shall be entered here.

(2) Utility category. All authorized maneuvers demonstrated in the type flight tests shall be listed, together with recommended entry speeds. All other maneuvers are not approved. If the airplane has been demonstrated to be characteristically incapable of spinning in accordance with § 3.124 (d), a statement to this effect shall be entered here.

(3) Acrobatic category. All approved flight maneuvers demonstrated in the type flight tests shall be included, together with recommended entry speeds.

(f) Flight load factor. The positive limit load factors made good by the airplane’s structure shall be described here in terms of accelerations.

(g) Flight crew. When a flight crew of more than one is required to operate the airplane safely, the number and functions of this minimum flight crew shall be included.

§ 3.779 Operating procedures. This section shall contain information concerning normal and emergency procedures and other pertinent information peculiar to the airplane’s operating characteristics which are necessary to
safe operation.

§ 3.780 Performance information.

[(a) For airplanes with a maximum certificated take-off weight of more than 6,000 lbs. information relative to the items of performance set forth in subparagraphs (1) through (5) of this paragraph shall be included. ]

(1) The stalling speed, Vso, at maximum weight,

(2) The stalling speed, Vs1, at maximum weight and with landing gear and wing flaps retracted,

(3) The take-off distance determined in accordance with § 3.84, including the air speed at the 50-foot height, and the airplane configuration, if pertinent,

(4) The landing distance determined in accordance with § 3.86, including the airplane configuration, if pertinent,

(5) The steady rate of climb determined in accordance with § 3.85 (a), (c), and, as appropriate, (b), including the air speed, power, and airplane configuration, if pertinent.

(b) The effect of variation in (a) (2) with angle of bank up to 60 degrees shall be included.

(c) The calculated approximate effect of variations in subparagraphs (3), (4) and (5) of this paragraph with altitude and temperature shall be included.

Note that an AFM is required, but the information required is limited when MTOW is 6000 lbs or less.

When Part 23 became the standard in 1964 or 65, it stated:

Part 23 AIRWORTHINESS STANDARDS: NORMAL, UTILITY, ACROBATIC, AND COMMUTER CATEGORY AIRPLANES
Subpart G--Operating Limitations and Information
Airplane Flight Manual

Sec. 23.1581

General.

(a) Furnishing information. The applicable information in Secs. 23.1583 through 23.1589 must be furnished--
(1) For each airplane of more than 6,000 pounds maximum weight, in an Airplane Flight Manual; and
(2) For each airplane of 6,000 pounds or less maximum weight, in an Airplane Flight Manual or in any combination of manuals, markings, and placards.
(b) Approval and segregation of information. Each part of the Airplane Flight Manual containing information prescribed in Secs. 23.1583 through 23.1589 must be approved, segregated, identified, and clearly distinguished from each unapproved part of that manual.
(c) Additional information. Any information not specified in Secs. 23.1583 through 23.1589 that is required for safe operation because of unusual design, operating, or handling characteristics must be furnished.

In this case, an aircraft of 6000 lbs or less MAY have an AFM, or it could be "any combination of manuals, markings, and placards." This has historically been the source of the old wives' tale that no AFM's were issued prior to 1978.

Which brings us to the 1978 revision of Part 23:

Part 23 AIRWORTHINESS STANDARDS: NORMAL, UTILITY, ACROBATIC, AND COMMUTER CATEGORY AIRPLANES
Subpart G--Operating Limitations and Information
Airplane Flight Manual and Approved Manual Material

Sec. 23.1581

General.

[(a) Furnishing information. An Airplane Flight Manual must be furnished with each airplane, and it must contain the following:
(1) Information required by Secs. 23.1583 through 23.1589.
(2) Other information that is necessary for safe operation because of design, operating, or handling characteristics.
(b) Approved information.
(1) Except as provided in paragraph (b)(2) of this section, each part of the Airplane Flight Manual containing information prescribed in Secs. 23.1583 through 23.1589 must be approved, segregated, identified and clearly distinguished from each unapproved part of that Airplane Flight Manual.
(2) The requirements of paragraph (b)(1) of this section do not apply if the following is met:
(i) Each part of the Airplane Flight Manual containing information prescribed in Sec. 23.1583 must be limited to such information, and must be approved, identified, and clearly distinguished from each other part of the Airplane Flight Manual.
(ii) The information prescribed in Secs. 23.1585 through 23.1589 must be determined in accordance with the applicable requirements of this part and presented in its entirety in a manner acceptable to the Administrator.
(3) Each page of the Airplane Flight Manual containing information prescribed in this section must be of a type that is not easily erased, disfigured, or misplaced, and is capable of being inserted in a manual provided by the applicant, or in a folder, or in any other permanent binder.
(c) [Reserved.]
(d) Table of contents. Each Airplane Flight Manual must include a table of contents if the complexity of the manual indicates a need for it.]

Now, each airplane, REGARDLESS OF MGW, must have an AFM.

Obviously, the PA-22 being a CAR 3 airplane, must have an approved AFM, and according to the TCDS, this AFM is included in the "Interior Equipment" list that is noted by the "Required Equipment" paragraph for each individual model.

Additionally, my 1963 Maule has an AFM with an equipment list that shows "required" equipment and "optional" equipment, and is the only document I've found that lists some of it as "required" for my airplane. I don't remember the misconception I had that caused me to look for this list specifically, but I WAS proven wrong

If you really want something to take with you, I can try to scan this equipment list out of my Maule for you, but it'd be the weekend before I'm home to do it.

Fly safe!

David

Edit: I think the requirement I was looking for was a generator...not required for certification under the CAR or by 91.205, and not listed on the TCDS, but it IS required by the equipment list.

 

[KennyFlys]

If you really want something to take with you, I can try to scan this equipment list out of my Maule for you, but it'd be the weekend before I'm home to do it.

David, I'd appreciate that. I'm keeping a record of various bits posted here and I'll add your provided information and scanned sheets to this for future reference along with a printout of the TCDS for the Maule. I see only the one TCDS for Maule, 3A23. Is that going to cover yours?

Do you by chance still have the manual for the PA-22? I'd be curious what, if anything, might be indicated as required equipment. I'm seeing the required equipment items in the TCDS so that adds to my curiosity. If that is possible to scan, assuming it's not that huge, I'd appreciate it.

I'd love to return to this examiner somewhat armed with some information and backup material.

 

[MauleSkinner]

David, I'd appreciate that. I'm keeping a record of various bits posted here and I'll add your provided information and scanned sheets to this for future reference along with a printout of the TCDS for the Maule. I see only the one TCDS for Maule, 3A23. Is that going to cover yours?

Do you by chance still have the manual for the PA-22? I'd be curious what, if anything, might be indicated as required equipment. I'm seeing the required equipment items in the TCDS so that adds to my curiosity. If that is possible to scan, assuming it's not that huge, I'd appreciate it.

I'd love to return to this examiner somewhat armed with some information and backup material.

Did a little looking around on the Maule website...http://www.mauleairinc.com/flight_manuals.htm has copies of all of the AFM's, and towards the top are links for "required equipment list" and "optional equipment list", as well as "supplements" for various models. The Required Equipment List is for later models than mine, but is definitely more readable (that 1963 ditto machine ink wasn't the most permanent stuff ) and is probably just as good for your purposes.

Note that while the specific items/models are required, they can be replaced by other part numbers via STC or field approval, but the new type of equipment is still required, and these STC's or 337's may specify additional requirements for "continued airworthiness". I've seen things as mundane as RTV sealant in the gap between the cylinder heads and baffling material as being required for proper cooling when a change was made under the cowling.

All the Maule models fall under the same TCDS...you'll notice that the manuals on the newest models still don't have performance information, which is required by FAR 23, but wasn't required under CAR 3 where the airplane was certificated. They've been accused of a "Mr. Potatohead" philosophy of airplane design...just take this set of wings, this fuselage, and this engine; all of which have been certificated before, just not together, make a new airplane, and add it to the same old TCDS.

I don't have any Pacer manuals...the discussion where that came up was started by somebody wondering if there was a difference between the expensive manuals that Piper sells and the cheap ones available from Wag Aero or other aftermarket retailers.

Amazing how a seemingly "simple" topic can spiderweb out so severely, huh?

Fly safe!

David

 

[MauleSkinner]

I'd also be a little careful about how big a pile of supporting documentation you bring in to the DE...That can spiderweb on ya pretty quick, too

If I were you, I'd find, review, and organize all the types of documentation discussed here that apply to the airplane you're using for the checkride...tell him that some airplanes have a required equipment list..."Here's the one for my airplane." The TCDS may require things..."Here's the one for my airplane." STC's and field approvals may require certain equipment..."Here are the ones for my airplane, this is where I would find those requirements if they actually existed on these documents." You may want to touch on the historical FAR's for certification. The TCDS tells you which FAR/CAR revision applies to your airplane, and they're available on the FAA web site. Figure out how to find them, but I wouldn't go so far as printing them out to take with you.

Take the stuff that applies to your airplane, be able to discuss a little bit of the variations for different airplanes and their certification basis, but simply say "I would find the information specific to that model at...."

As a CFI, there's a LOT of information that you need to be able to discuss intelligently and use for your checkride and subsequent flight instructing. Very little of it requires that you carry it around with you. You simply need to be able to point yourself in the general direction of the information that you need at a specific time so that you can find it when you need it.

Fly safe!

David

 

[midlifeflyer]

I'm not sure that this is entirely correct...

Of course, since a "POH" is a uniform format created by GAMA in the 1970s for the collection of materials that makes up a flight manual containing both required and optional materials. ...

 

[poadeleted20]

The Maule and Piper companies wrote into their type certificates the requirement for an AFM long before the FAA made it mandatory in 1977 but Cessna and Grumman did not, which is why you see them for older P/M's but not C/G's.

 

[MauleSkinner]

The Maule and Piper companies wrote into their type certificates the requirement for an AFM long before the FAA made it mandatory in 1977 but Cessna and Grumman did not, which is why you see them for older P/M's but not C/G's.

I don't think we're disagreeing, but just to clarify...

Note in my post above that there was only a single period of roughly 14 years since the early 1950's that an "approved AFM" was optional by certification regulations, however. Long before 1977 (early FAR 23) Piper was using them. Longer before 1977 (CAR 3) everybody had to have one. Longer yet before 1977 (AB7/7A) I'm not 100% sure, but I don't think they were required.

The only "choice" in the matter that Maule made was to continue certificating all of their airplanes under CAR 3. This required them to have an AFM. Piper was also required to have them in their CAR 3 airplanes (Pacers for example).

Fly safe!

David

 

[poadeleted20]

Note in my post above that there was only a single period of roughly 14 years since the early 1950's that an "approved AFM" was optional by certification regulations, however. Long before 1977 (early FAR 23) Piper was using them. Longer before 1977 (CAR 3) everybody had to have one.

I think we are saying the same thing -- for post-early-50's/pre-77 planes certified under CAR 3 (e.g., the 1975 C-182), an AFM was not an FAA requirement, but some mfrs (like Piper) chose to make it so for their airplanes.

 

[MauleSkinner]

I think we are saying the same thing -- for post-early-50's/pre-77 planes certified under CAR 3 (e.g., the 1975 C-182), an AFM was not an FAA requirement, but some mfrs (like Piper) chose to make it so for their airplanes.

The way I'm reading it, CAR 3 (early 1950's to about 1963) airplanes required the AFM. Airplanes certificated under early FAR 23 (1964-1976 or so) had the AFM optional, and subsequent to 1977 the AFM was required again.

In other words, I think there are 3 distinct groups there, rather than just two.

I will admit, however, that I didn't check every revision of CAR 3 and FAR 23...only the first CAR3 that shows up on the FAA web site, the first FAR 23, and the 1977 (78?) FAR 23. Things may have moved around a little bit in between there.

Fly safe!

David

 

[poadeleted20]

The way I'm reading it, CAR 3 (early 1950's to about 1963) airplanes required the AFM. Airplanes certificated under early FAR 23 (1964-1976 or so) had the AFM optional,

I can say for sure that this isn't true, because I just looked it up this week for the Cessna 182, originally certificated in 1956 under CAR 3 without a requirement for an AFM. The 182P, added to the 182 type certificate around 1975 with CAR 3 as the certification basis, also has no AFM requirement.

 

[MauleSkinner]

I can say for sure that this isn't true, because I just looked it up this week for the Cessna 182, originally certificated in 1956 under CAR 3 without a requirement for an AFM. The 182P, added to the 182 type certificate around 1975 with CAR 3 as the certification basis, also has no AFM requirement.

OK...I'm confused now, Ron...

I see in the TCDS where it only requires an AFM for s/n 18266591 through 18268586, as well as a series of R182 s/n's.

But CAR 3.777 seems to require an AFM for all aircraft with CAR 3 certification basis...

AIRPLANE FLIGHT MANUAL

§ 3.777 Airplane Flight Manual. An Airplane Flight Manual shall be furnished with each airplane. The portions of this document listed below shall be verified and approved by the Administrator, and shall be segregated, identified, and clearly distinguished from portions not so approved. Additional items of information having a direct and important bearing on safe operation may be required by the Administrator when unusual design, operating, or handling characteristics so warrant.

I really don't see how the manufacturer could choose whether or not to require an AFM in the TCDS based on the above CAR. The TCDS in this case seems to contradict the CAR that is its certification basis. Is it possible that there was a waiver of some sort or an "equivalent level of safety" involved?

Also, one of the items "listed below" is

§ 3.779 Operating procedures. This section shall contain information concerning normal and emergency procedures and other pertinent information peculiar to the airplane’s operating characteristics which are necessary to
safe operation.

Where is this information found in the airplanes you researched? A lot of the other items could probably be placed as "placards and markings", but this seems to require some sort of separate document.

 

[alaskaflyer]

You guys have kind of lost me, but here is info from the TCDS for the Cessna 170, 170A, and 170B, 1948-1956:

Certification Basis Models 170: Civil Air Regulations Part 03 dated December 15, 1946, as amended by 03-1 thru 03-3.
Models 170A: Civil Air Regulations Part 03 dated December 15, 1946, as amended by 03-1 thru 03-4.
Model 170B: Civil Air Regulations Part 3 dated November 1, 1949, as amended by 3-1 and 3-2.
Type Certificate No. 799 issued June 1, 1948.
​

Required interior equipment:

(a) CAA Approved Airplane Flight Manual and pertinent revisions  applicable to the particular model, serial number, and landing gear installation.
​

The AFM is a one sheet piece of paper in this case.

 

[poadeleted20]

I really don't see how the manufacturer could choose whether or not to require an AFM in the TCDS based on the above CAR. The TCDS in this case seems to contradict the CAR that is its certification basis. Is it possible that there was a waiver of some sort or an "equivalent level of safety" involved?

BSOM, but that's the way it is. Bottom line is that on any pre-77 airplane, you gotta look it up in the TCDS to be sure either way.

 

[MauleSkinner]

BSOM, but that's the way it is. Bottom line is that on any pre-77 airplane, you gotta look it up in the TCDS to be sure either way.

Well, at least you, me, and Alaskaflyer are all confused...I think we have a quorum!

Fly safe!

David

 

[KennyFlys]

Well, at least you, me, and Alaskaflyer are all confused...I think we have a quorum!

Fly safe!

David

Heck, it just turned what I thought was a relatively simple question into huge question!