Operating Limitations, 1946 Cessna 140

[Greg Bockelman]

Everyone knows that the O in ARROW is Operating Limitations. On the post 1978 airplanes, those are contained in the Pilot Operating Handbook that is required to be in the airplane. Pre 1978, what is the actual requirement? I know Placards and Markings suffice, but where does one find if those are accurate? TCDS?

Originally, there was a document similar to:

http://www.cessna120-140.org/forum/download.php?id=1019

How does one get a replacement copy of that document? How does one update that document since the airplane is not equipped as it was when it left the factory? (100 HP Continental vs 85 HP Continental)

How can one make the airplane legal with regard to the O in ARROW?

 

[tonycondon]

i assume there is an STC for the upgrade to the 100 HP engine? if so i would expect the new operating limitations to be included in that STC

 

[Greg Bockelman]

i assume there is an STC for the upgrade to the 100 HP engine? if so i would expect the new operating limitations to be included in that STC

Yeah, but that would only be PART of the deal. That would only update those limitations that had to do with the engine.

 

[tonycondon]

what other limitations do you expect would change due to the engine change?

 

[poadeleted20]

The TCDS would be the place to start, and note that the 140A (5A2) is on a different type certificate than the 120/140 (A-768). As you posted the document for the 120/140, we'll stick with that. The TCDS lists that Approved Flight Manual as item 403 in the equipment list, and Note 2c says this placard must be installed:

NOTE 2. The following placards must be displayed in full view of the pilot:

...​

(c) "This Airplane to Be Operated in Accordance with the Flight Limitations of the Operations Manual." (Refers to Item 403, Airplane Flight Manual.")

...and the AFM says on its face that it must be in the plane.


For a replacement copy, you'd have to contact Cessna or the ACO covering that model (which I'm guessing is the one in Wichta -- Cessna should be able to help). As for any supplement to the AFM for an STC'd engine change, you'd have to contact the STC holder or the ACO covering the STC.​

 

[Fearless Tower]

Yeah, but that would only be PART of the deal. That would only update those limitations that had to do with the engine.

Judging by the simplicity of the AFM that you linked....I wouldn't think there is too much to change.

My 1948 170 has a 1 page (two-sided) AFM which includes the take-off/landing distance charts, so an engine upgrade would conceivably alter the performance charts...in that 140 document, you don't even have those.

 

[RotorAndWing]

Judging by the simplicity of the AFM that you linked....I wouldn't think there is too much to change.

My 1948 170 has a 1 page (two-sided) AFM which includes the take-off/landing distance charts, so an engine upgrade would conceivably alter the performance charts...in that 140 document, you don't even have those.

FWIW, if the engine upgrade gives the aircraft better performance, there is no need to change take off and landing distance charts.

However, if there was a mod that increased t/o or landing data (higher gross weight?) then the charts would have to be altered to show the new data.

 

[Fearless Tower]

FWIW, if the engine upgrade gives the aircraft better performance, there is no need to change take off and landing distance charts.

However, if there was a mod that increased t/o or landing data (higher gross weight?) then the charts would have to be altered to show the new data.

Good to know, thanks!

 

[Greg Bockelman]

The TCDS would be the place to start, and note that the 140A (5A2) is on a different type certificate than the 120/140 (A-768). As you posted the document for the 120/140, we'll stick with that. The TCDS lists that Approved Flight Manual as item 403 in the equipment list, and Note 2c says this placard must be installed:

...and the AFM says on its face that it must be in the plane.


For a replacement copy, you'd have to contact Cessna or the ACO covering that model (which I'm guessing is the one in Wichta -- Cessna should be able to help). As for any supplement to the AFM for an STC'd engine change, you'd have to contact the STC holder or the ACO covering the STC.​

Ok, Ron, a couple of questions.

Does the document I linked in the first post constitute the "Approved Flight Manual" as described in your post here, and as specified in Item 403?

The follow on question to my original question is "Do any and all STC supplements that may have accumulated over the last 65 years have to be onboard the airplane at all times when it is flown?" There is no such thing as a POH, so they cannot be attached to that document. IOW, they are sort of stand alone documents.

For what it is worth, I found the original document. It is in pretty sad shape. Funny think is, it is an EXACT DUPLICATE, right down to the signature and date, of the one I linked except the N number is different.

 

[poadeleted21]

Ok, Ron, a couple of questions.

Does the document I linked in the first post constitute the "Approved Flight Manual" as described in your post here, and as specified in Item 403?

The follow on question to my original question is "Do any and all STC supplements that may have accumulated over the last 65 years have to be onboard the airplane at all times when it is flown?" There is no such thing as a POH, so they cannot be attached to that document. IOW, they are sort of stand alone documents.

For my 1963 Cherokee, there's a generic Owners Manual then there's a serial number number specific AFM. You can get the Owners Manual from Essco for 10 bucks or so and it suffices, for the AFM you have to get it directly from piper and it's 250ish bucks. No AFM was required back then but since Piper put it out there and it's in the TCDS, it has to be in the plane. Now as for the AFM supplements, yes you would be required to carry around supplements to a non-existent AFM if there was no AFM specified in your TCDS. In my plane for instance, I have to carry around the AFM Supplement for my IFR GPS and If I want to run auto fuel, I have to have that AFM supplment in the plane too.

 

[Fearless Tower]

Does the document I linked in the first post constitute the "Approved Flight Manual" as described in your post here, and as specified in Item 403?

Can't imagine what other Approved Airplane Flight Manual there might be.

For the 170, it is the same. I'd post a link to it, but it is on the 170 Association members only part of the site.

It has the same signature as the 140 (Charles F. Dycer I believe). The NC number is blank - to be filled in by Cessna or Yingling (who delivered the planes).

 

[RotorAndWing]

No AFM was required back then but since Piper put it out there and it's in the TCDS, it has to be in the plane.

Based upon which regulation? Type Certificate Data Sheets are not regulatory.

http://www.faa.gov/documentLibrary/media/Order/8620_2A.pdf

Order 8620.2A

7.
TCDS. Consistent with 14 CFR, a TCDS is part of a product’s type certificate (TC). A TCDS is a summary of the product’s type design. It is used primarily by authorized persons during initial or recurrent issuance of a Standard Airworthiness Certificate. It is neither a regulation, a maintenance requirements document, or a flight manual document. As such, for aircraft holding a valid and current airworthiness certificate, a TCDS should not be used as a sole source to determine what maintenance is required or what the flight operations requirements are. Any language on a TCDS, by itself, is not regulatory and is simply not enforceable. There must be a corresponding rule to make any language on the TCDS mandatory. For example, there is a mention of “operating limitations” on most TCDS. The corresponding rule for “operating limitations” is 14 CFR § 91.9(a) which states, “Except as provided in paragraph (d) of this section, no person may operate a civil aircraft without complying with the operating limitations specified in the approved Airplane or Rotorcraft Flight Manual, markings, and placards, or as otherwise prescribed by the certificating authority of the country of registry.” Without § 91.9, the TCDS requirement to comply with operating limitations would not be enforceable.

10.
Summary. Consistent with 14 CFR, a TCDS is part of a product’s TC. As such, for aircraft holding a valid and current airworthiness certificate, a TCDS should not be used as a sole source to determine what maintenance is required or what the flight operations requirements are. Any language on a TCDS, by itself, is not regulatory and is simply not enforceable.

 

[RotorAndWing]

Does the document I linked in the first post constitute the "Approved Flight Manual" as described in your post here, and as specified in Item 403?

Yes.

The follow on question to my original question is "Do any and all STC supplements that may have accumulated over the last 65 years have to be onboard the airplane at all times when it is flown?"

If the STC includes a supplement and states it must be carried aboard, then yes.

There is no such thing as a POH, so they cannot be attached to that document. IOW, they are sort of stand alone documents.

Make a folder and insert them. Place in a safe place in the airplane.

For what it is worth, I found the original document. It is in pretty sad shape. Funny think is, it is an EXACT DUPLICATE, right down to the signature and date, of the one I linked except the N number is different.

Laminate it and place in the airplane. There's no requirement for the condition it must be in. As long as it's legible you're good to go.

 

[Fearless Tower]

So, are you saying that required equipment listed in the TCDS is not actually required to be onboard?

 

[RotorAndWing]

So, are you saying that required equipment listed in the TCDS is not actually required to be onboard?

If there is a regulation requiring the equipment, then yes it has to be on board.

Look at it this way, the TCDS is only enforceable if there is a regulation to back up what it is requiring.

Let's say for sake of argument that Cessna revises the TCDS of your 170 and puts in the notes "Wings must be removed every 100 hours for inspection."

Withstanding an AD stating to do this or a regulation requiring it, it does not stand and you are not required to comply.

 

[Tom-D]

FWIW, if the engine upgrade gives the aircraft better performance, there is no need to change take off and landing distance charts.

However, if there was a mod that increased t/o or landing data (higher gross weight?) then the charts would have to be altered to show the new data.

That is dependent upon how the STC is written.

ANY real ASI would know that..

The STC may simply say that this data must be carried in the aircraft.

 

[Tom-D]

How can one make the airplane legal with regard to the O in ARROW?

Follow the instructions given in the paper work upgrading the engine STC or Field approval. both will have all the changes to the flight charistics of the aircraft?

If there are none, the manufacturers data will not be altered.

My engine upgrade 1 time STC gives the new engine operating RPM and power setting but changes nothing on the OEMs flight manual. and has a statement that a copy of this SCT must be carried in the aircraft.

 

[Greg Bockelman]

If there are none, the manufacturers data will not be altered.

The O-200 upgrade on this airplane was based on a field approval of another airplane. The only documentation was the 337. Kinda weird, but it has stood the test of time since 1974 or so.

Also, something kind of weird is that it is limited to 90 HP because of the prop that was required by the other field approval. (I think.) Seems like quite a hassle for only 5 HP.

 

[Tom-D]

The O-200 upgrade on this airplane was based on a field approval of another airplane. The only documentation was the 337. Kinda weird, but it has stood the test of time since 1974 or so.

Also, something kind of weird is that it is limited to 90 HP because of the prop that was required by the other field approval. (I think.) Seems like quite a hassle for only 5 HP.

Then it was done on a field approval, and there are no modifications to the OEMs Data the old document you have is good to go, carry it in the aircraft.

I placed all my required paper work in a 3 ring binder in document protectors. It probably would be a good Idea to have a dup made of the old doc, and carry that rather than the original.

In 1974 we had FAA inspectors that would approve 337s now we must do a 1 time STC. all the testing all the engineering, every thing, the good old days weren't so bad.

 

[poadeleted20]

Does the document I linked in the first post constitute the "Approved Flight Manual" as described in your post here, and as specified in Item 403?

It does appear to.

The follow on question to my original question is "Do any and all STC supplements that may have accumulated over the last 65 years have to be onboard the airplane at all times when it is flown?" There is no such thing as a POH, so they cannot be attached to that document. IOW, they are sort of stand alone documents.

That plane may not have a POH as described in Part 23, but it does have an AFM (which you posted). Thus, any AFM supplements which came with any STC's became part of that AFM and must be aboard. That said, old STC's may not have any AFMS to append to the AFM you have. No way to know without seeing the STC paperwork package.

For what it is worth, I found the original document. It is in pretty sad shape. Funny think is, it is an EXACT DUPLICATE, right down to the signature and date, of the one I linked except the N number is different.

That's typical of those ancient AFM's.

 

[poadeleted20]

Based upon which regulation? Type Certificate Data Sheets are not regulatory.

http://www.faa.gov/documentLibrary/media/Order/8620_2A.pdf

Order 8620.2A

7.
TCDS. Consistent with 14 CFR, a TCDS is part of a product’s type certificate (TC). A TCDS is a summary of the product’s type design. It is used primarily by authorized persons during initial or recurrent issuance of a Standard Airworthiness Certificate. It is neither a regulation, a maintenance requirements document, or a flight manual document. As such, for aircraft holding a valid and current airworthiness certificate, a TCDS should not be used as a sole source to determine what maintenance is required or what the flight operations requirements are. Any language on a TCDS, by itself, is not regulatory and is simply not enforceable. There must be a corresponding rule to make any language on the TCDS mandatory. For example, there is a mention of “operating limitations” on most TCDS. The corresponding rule for “operating limitations” is 14 CFR § 91.9(a) which states, “Except as provided in paragraph (d) of this section, no person may operate a civil aircraft without complying with the operating limitations specified in the approved Airplane or Rotorcraft Flight Manual, markings, and placards, or as otherwise prescribed by the certificating authority of the country of registry.” Without § 91.9, the TCDS requirement to comply with operating limitations would not be enforceable.

10.
Summary. Consistent with 14 CFR, a TCDS is part of a product’s TC. As such, for aircraft holding a valid and current airworthiness certificate, a TCDS should not be used as a sole source to determine what maintenance is required or what the flight operations requirements are. Any language on a TCDS, by itself, is not regulatory and is simply not enforceable.

These are not notes appended by the manufacturer, they are part of the aircraft's required equipment. R&W and I went around this one before, and this issue was elevated to AFS-350 which wrote that AC. They passed it to AFS-830, who said yes, it really is required by the type certificate and must be in the aircraft. Anyone with any questions about that should contact Ray Stinchcomb in AFS-830.

 

[poadeleted20]

So, are you saying that required equipment listed in the TCDS is not actually required to be onboard?

R&W has said that before, and is saying it again, but according to AFS-350 and AFS-830 (as well as the individual FSDO Airworthiness Inspectors I have asked), R&W is wrong. If the TCDS lists it as required equipment, it is because the type certificate requires it, and that means it really is required equipment and must be in the plane for the plane to be legal. The regulations are only a minimum standard; additional required items may be added during the certification process, and the TCDS includes the summary of what those additional items are.

For regulatory background, see 91.9:

Sec. 91.9

Civil aircraft flight manual, marking, and placard requirements.

(a) Except as provided in paragraph (d) of this section, no person may operate a civil aircraft without complying with the operating limitations specified in the approved Airplane or Rotorcraft Flight Manual, markings, and placards, or as otherwise prescribed by the certificating authority of the country of registry.

...and the approved AFM says the AFM must be aboard, as well as 91.213(d)(2):

(2) The inoperative instruments and equipment are not--
...
(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;

...which the AFM is in the equipment list in the TCDS.

Again, if you have questions, take them to an Airworthiness Inspector and ask them to confirm what they say with AFS-350/830.

 

[Tom-D]

R&W has said that before, and is saying it again, but according to AFS-350 and AFS-830 (as well as the individual FSDO Airworthiness Inspectors I have asked), R&W is wrong. If the TCDS lists it as required equipment, it is because the type certificate requires it, and that means it really is required equipment and must be in the plane for the plane to be legal. The regulations are only a minimum standard; additional required items may be added during the certification process, and the TCDS includes the summary of what those additional items are.

For regulatory background, see 91.9:
...and the approved AFM says the AFM must be aboard, as well as 91.213(d)(2):
...which the AFM is in the equipment list in the TCDS.

Again, if you have questions, take them to an Airworthiness Inspector and ask them to confirm what they say with AFS-350/830.

Ron is absolutely correct on this, The AFM must be in the aircraft to be airworthy, simply because the type certificate says the AFM is a part of the design.

But, when the aircraft is modified, the ruling document is the "Suplimental Type Certificate" or the approved data on the field approval. because that modifies the design.

and this thread is one more reason I do not believe rotor is who he says he is.

 

[RotorAndWing]

R&W has said that before, and is saying it again, but according to AFS-350 and AFS-830 (as well as the individual FSDO Airworthiness Inspectors I have asked), R&W is wrong. If the TCDS lists it as required equipment, it is because the type certificate requires it, and that means it really is required equipment and must be in the plane for the plane to be legal. The regulations are only a minimum standard; additional required items may be added during the certification process, and the TCDS includes the summary of what those additional items are.

For regulatory background, see 91.9:
...and the approved AFM says the AFM must be aboard, as well as 91.213(d)(2):
...which the AFM is in the equipment list in the TCDS.

Again, if you have questions, take them to an Airworthiness Inspector and ask them to confirm what they say with AFS-350/830.

So you are saying FAA Order 8620.2A is wrong?

Are you also saying the manufacture has regulatory authority over the FAA?

As far as AFS-350 or AFS-830 are concerned, I haven't seen anything official from them stating to ignore, amend or cancel FAA Order 8620.2A.

8620.2A is very clear and easy to understand.

 

[poadeleted20]

So you are saying FAA Order 8620.2A is wrong?

Are you also saying the manufacture has regulatory authority over the FAA?

As far as AFS-350 or AFS-830 are concerned, I haven't seen anything official from them stating to ignore, amend or cancel FAA Order 8620.2A.

8620.2A is very clear and easy to understand.

I'm saying the people who wrote it say your interpretation of it is wrong. Call Ray and ask before you get someone in trouble with your inaccurate information.

 

[RotorAndWing]

I'm saying the people who wrote it say your interpretation of it is wrong. Call Ray and ask before you get someone in trouble with your inaccurate information.

I'm quoting an FAA Order and it's very simply written. If there was such a problem with it I'm sure an amended version would have been issued, or even an official memo seeking clarification.

Again as in the Summary of 8620.2A:

10.
Summary. Consistent with 14 CFR, a TCDS is part of a product’s TC. As such, for aircraft holding a valid and current airworthiness certificate, a TCDS should not be used as a sole source to determine what maintenance is required or what the flight operations requirements are. Any language on a TCDS, by itself, is not regulatory and is simply not enforceable.

 

[poadeleted20]

I'm quoting an FAA Order and it's very simply written. If there was such a problem with it I'm sure an amended version would have been issued, or even an official memo seeking clarification.

Again as in the Summary of 8620.2A:

10.
Summary. Consistent with 14 CFR, a TCDS is part of a product’s TC. As such, for aircraft holding a valid and current airworthiness certificate, a TCDS should not be used as a sole source to determine what maintenance is required or what the flight operations requirements are. Any language on a TCDS, by itself, is not regulatory and is simply not enforceable.

Quote away. Just don't tell anyone your personal interpretation of that document is official Flight Standards policy until you do as I did and ask the people who decide that. Otherwise, you may get someone who listens to you in a lot of trouble when they run into an Inspector who does know what that official interpretation is.

 

[RotorAndWing]

Quote away. Just don't tell anyone your personal interpretation of that document is official Flight Standards policy until you do as I did and ask the people who decide that. Otherwise, you may get someone who listens to you in a lot of trouble when the run into an Inspector who does know what that official interpretation is.

I have posted the document and read it verbatim, never injecting a personal "interpretation". On it's face it's very clear and concise in it's language which is where you seem to have issues with it.

My "opinion" of the order and how it is written are one in the same. I simply agree with it's language.

 

[Fearless Tower]

and this thread is one more reason I do not believe rotor is who he says he is.

Why? Because his opinion/interpretation is different from what someone else in the FAA says?

I always thought that was SOP for FAA folks

 

[wabower]

Other potential benefits (accessories, etc) are possible when using the O-200 rather than other variants, as we learned with our L-2 project.

We also tried to get a one-time STC based on the data submitted by another guy who was successful in obtaining a one-time STC for his airplane (he gave us written permission, all supporting information/material, etc.) but FAA said no.

The O-200 upgrade on this airplane was based on a field approval of another airplane. The only documentation was the 337. Kinda weird, but it has stood the test of time since 1974 or so.

Also, something kind of weird is that it is limited to 90 HP because of the prop that was required by the other field approval. (I think.) Seems like quite a hassle for only 5 HP.

 

[poadeleted20]

I have posted the document and read it verbatim, never injecting a personal "interpretation". On it's face it's very clear and concise in it's language which is where you seem to have issues with it.

My "opinion" of the order and how it is written are one in the same. I simply agree with it's language.

So, if you run into R&W, you won't be dinged for not having the AFM required by the type certificate. Run into any other FAA Inspector and you probably will be. Show up for a practical test with a DPE without one, and you'll probably not get to start the ride and have to walk home. And telling them an anonymous inspector on the Internet told you it was OK will not get you out of the 91.9 violation.

As I said, if you want to know what this means, ask the folks who wrote it.

Also, R&W's reading of the language is incomplete. It only says that the TCDS should not be used as the sole source, and that if there is a question, the type certificate itself or the AFM should be consulted, and in this particular case, the AFM signed by the certifying authority says it must be in the aircraft and that makes it official and required by 91.9(a).

 

[RotorAndWing]

So, if you run into R&W, you won't be dinged for not having the AFM required by the type certificate. Run into any other FAA Inspector and you probably will be. Show up for a practical test with a DPE without one, and you'll probably not get to start the ride and have to walk home. And telling them an anonymous inspector on the Internet told you it was OK will not get you out of the 91.9 violation.

Whatever Ron........