MauleSkinner
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Yup...and "civil", which, if we take it out of context as well, could mean it only applies to aircraft that are not jerks.
Ya gotta read the WHOLE THING.
A/FD recommended takeoff and landing runways
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Ya gotta read the WHOLE THING.
I did. The phrase I quoted is a portion that I think some people are ignoring.Yup...and "civil", which, if we take it out of context as well, could mean it only applies to aircraft that are not jerks.
Ya gotta read the WHOLE THING.
MauleSkinner
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In the case of the OP's 140, you're clearly ignoring the part about an AFM not being required.
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Im not really responding to your post, just jumping off from it.This part of the discussion confuses me. The reg requires familiarity with takeoff and landing data. As @tspear said earlier, all (b)(1) and (b)(2) do is give two potential sources for tha data - (1) an AFM with required data and (2) if there is no AFM required data, "other reliable information."
The somewhat stilted langusge aide (I've seen much much worse), the reg is pretty simple. It jus says, when you fly, you need to know runwas lenghts and at least enough performance information to know whether you and your aircraft can do the job.
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I'm not talking about the OP's 140. It appeared to me that some people have been making claims about the meaning of 91.103(b) that are not consistent with the portion I quoted.
Sounds reasonable. My point about the passage I quoted is that if an AFM containing takeoff and landing distance data is required, then the only takeoff performance data that 91.103(b) requires the pilot to know is that which is contained in the AFM.
denverpilot
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Yup...and "civil", which, if we take it out of context as well, could mean it only applies to aircraft that are not jerks.
Ya gotta read the WHOLE THING.
Sorry that's not the purpose of "civil" in that sentence. They're exempting their own aircraft and military aircraft, in their own strange way. "Civil aircraft" has a distinct definition elsewhere.
Slightly stilted? LOL.
I think they're really admitting that they once didn't produce AFMs. One paragraph says what you must use if an AFM exists. Lots of aircraft that don't have one. So they added another paragraph. Because you know how law works... more paragraphs is mo' bettah'. LOL.
And your last paragraph agrees with my original point. How do you prove you know if someone asks? If I walk up to you and say I'm an inspector and want to see your paperwork for the aircraft and ask you the runway lengths and your calculated performance numbers are, "Oh I know the airplane will do it..." going to cut it? Will "Takeoff will be about 1200' today" good enough?
Of course there's the principal of this being the usual "minimum standard" vs a pilot exceeding minimums to be accounted for, also. Obviously that same inspector could ask, "What's the weather between here and there?"
I contest that they could have just dumped the clarifying paragraphs after the initial sentence, and no change happens legally. You can still be charged with violating it without mentioning takeoff and landing data at all.
Otherwise they might as well just list every single item in a pre-flight briefing. Why only that data?
MauleSkinner
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Maybe reply to those posts so it's clear what you're talking about.
MauleSkinner
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No, it doesn't...it says what you must use if the AFM IS REQUIRED to exist.
denverpilot
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Same thing for purposes of this discussion. FAA decides if an AFM is required to exist. The two paragraphs are just them pointing out that they didn't used to require AFMs. My airplane doesn't have one.
They start with "all" things you need to know about the flight.
Then they added two paragraphs to make sure you use the aircraft specific AFM if they required one to exist for that aircraft. In other words, it was built after Part 23 came along instead of CAR 3.
If it doesn't have an AFM then they relax a little and say "use whatever you can find".
The overlying weirdness is that they already said you have to familiarize yourself with everything. Everything.
Then they emphasized takeoff and landing data and runway lengths. Like those things are the only things they wanted to emphasize.
That they had to jump through hoops to make two paragraphs to explain what to reference for that data, because they find if the AFM better, if there is one, is just them making a different statement, "If we required an AFM you have to use it. Not other crap. Before we required AFMs, use whatever you can justify."
Which is probably the generic non-aircraft specific POH, obviously. But maybe like in my airplane it's the STC that changed the stall speed and runway use data. POH loses. If my airplane were newer, the STC would have modified the AFM. But STCs didn't do that in 1975. Because AFMs didn't exist.
That's all the hoop jumping of those two paragraphs is.
I don't have anything to prove. You seem for some reason to be stuck on a requirement for precise calculations and paperwork showing it. Your requirement doesn't exist. If you choose to fill out a TOLD card every time you do touch and goes at the home drone, I compliment you on your attention to detail, but I do not agree It is required.
In the highly unlikely event I were asked, after looking a little surprised at the question, the answer is, "here's my chart. You can see the runway length here is 6,000'. That's more than enough runway for this Skylane to take off."
MauleSkinner
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You're missing the whole category of airplanes that have non-required AFMs.
I guess I lost situational awareness.
MauleSkinner
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denverpilot
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No I didn't. It just added more useless information since the initial question was "Why make this data the only data that FAA calls out specifically when they've already said "everything"?
Worrying about why they have to twist themselves into a pretzel to cover the various certification and non-certification paths isn't the point I was making, nor do I care in the slightest about it.
dmspilot
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As I've already said, it's not the only data. There are six items enumerated, not two.
denverpilot
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I don't, but the sentence says those things are a "must", not optional. I'm simply pointing out the hideous wording of the law.
The wording paraphrased is...
You familiarize yourself with everything, but it "must" include this thing.
How you handle proving the "must" is completely up to you.
There's nearly a zero chance anyone will ever enforce it. But it's a good reminder that for some reason, FAA thinks pilots don't do it.
This thread seems to prove that.
There's also a lot of folks who are angry about it, which is entertaining. Those same pilots will crow about how Commercial ops are safer in other threads. Guess what every commercial op does?
I removed (a) because it wasn't the point being made. Those items require IFR or "flight away from the airport" and not every flight meets those criteria.
*All *flights meet the criteria of (b), which was the topic at hand. We could morph into why those items on the other list are only required if you go somewhere.
Weather and fuel not important if you don't leave the pattern? LOL. Mmmm Kay.
MauleSkinner
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What post number contains the "original question" to which you're referring? I thought this thread was about performance planning. The presence of an AFM or not has nothing to do with having performance documentation.
MauleSkinner
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Looking at performance charts is definitely not the part that makes commercial ops safer...it's the fact that most pilots operating under those rules use techniques that reasonably replicate the performance data.
Far too many light airplane pilots, even those who never take off or land without a "50% safety factor", use techniques that nearly double the book numbers for takeoff and landing without realizing it. The good news is that most light airplane ops have way more runway available than what they need.
Not only does the presence of an AFM have nothing to do with performance documentation as I stated above, the presence of performance documentation has very little to do with how much room the average light plane pilot will need to takeoff or land.
Well, a good TOLD analysis will include a buffer. But, are you picturing the same accident investigation as I? 100 hour private pilot runs off the runway and shows the the investigator the TOLD card that says he had 100 feet more than required 4 hours earlier when he planned the 3 hour flight? Did the precise calculation, but really had no understanding of how it applied to him and his capabilities and the need to make "on the fly" adjustments based on conditions.
I was thinking that may be precisely the reason why the FAA chose the understanding, application, correlation intensive "familiar with" requirement rather than the rote, "show me you know how to use a calculator."
MauleSkinner
Touchdown! Greaser!
I was not aware of that accident (can you provide a link? It's intriguing), but I have flown with numerous pilots over the years who were accident-free only because they didn't fly from runways that were less than double the book distance plus the "safety factor" that they thought was keeping them safe.
I agree with you...the FAA specifically DIDN'T say you had to have runway available as calculated from the AFM charts.
And by the way, commercial ops are apparently not exceptionally safe in this regard, either... The FAA not too long ago came out with a SAFO that basically requires a buffer for landing distances in commercial ops.
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No, it wasn't a real accident (at least AFAIK), Just one I was mentally picturing. Actually, I don't recall seeing an accident report mentioning a TOLD calculation. Nor have I seen a reported FAA enforcement action under 91.103 involving runway length issues (doesn't mean they are not there; indications to the contrary, I really don't send all my time reading this stuff). Like you, I far more suspect the reality is, >90% of runway overruns or hitting trees on takeoff and landing would have been found A-OK under a numerical performance chart analysis.
MauleSkinner
Touchdown! Greaser!
Ok... I misread.
denverpilot
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Which makes their emphasis on them in this particular FAR, even stranger.
dmspilot
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Posting the same thing over and over doesn't it make it true and doesn't convince other people your'e right.
denverpilot
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Which would apply to both of us in this case.
Familiarize *must* include... that's the sentence. And lawyers only write *must* when they think it's important to place in a law. Otherwise the familiarize by itself adequately covers it.
dmspilot
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What point are you trying to make?
denverpilot
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Already made. Suggest you read up the thread.
Just stuff guys, really. . .3,000 feet of runway, spring day, 70 degrees F, sea level; I do not/not do runway required computations, or a W&B, flying alone in my 172. I am/am "familiar" with the data, to the point I know I'm within the performance envelope. I've met the spirit, intent, and letter of the rule.
dmspilot
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Why would you presume that I didn't? It's hard to keep track of your doubletalk. Your point seems to be that misquoting a reg over and over results in being able to infer a different meaning than what is written.
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denverpilot
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I have not misquoted it. It's very difficult to misquote it since it's been posted in the thread.
If you don't like what the word "must" means, I recommend a call to Webster or maybe Oxford to see if they care.
dmspilot
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I don't have any problem with the wording of the regulation. But you do. You are the one that called it "****ty" and "garbage". Your posts on the subject are primarily nonsense and doubletalk.
denverpilot
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It is garbage. Any engineer can write a better logic flow. Nobody can explain why there's an emphasis on it, nor even explain why they would mandate weather only if leaving the airport. LOL. It's crap writing.
But it keeps a future generation of lawyers busy re-writing it whenever they get around to it.
I contend the first sentence took care of it. If you're going to make a vague law that insinuates every pilot know everything so you have a fallback law to toss at anyone, might as well leave it vague. It's a catch-all law and completely subjective until you get to Runway data and takeoff and landing performance and then all of a sudden it says "must". I can think of a lot of other "musts" they might as well have listed.
I've made an assertion. The doubletalk has been in the responses that "must" doesn't mean what the word means because "someone told me so". Last I checked, that's not how laws work.
Whether they're enforced, is a separate issue.
I've only asked questions beyond that. What constitutes proving you've "familiarized" under the "must" clause? @midlifeflyer actually answered the question as to how he'd handle it.
Everyone else has just whined that they don't like the reg telling them what they "must" do. And nobody has argued that having the numbers isn't a best practice. Takes less than a minute nowadays with a smartphone anyway.
dmspilot
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I could but why bother. LOL.
The above is nothing but a strawman. You have whined, and others have whined at you for whining. No one has whined about the regulation itself. Do you hear voices too?
Maybe put into the practice the "listen to understand, not refute" from the FOI.
tspear
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Timothy
Actually go back to my post. I answered it.
If the data exists, you must use it. If the data does you not exist in thr AFM you must use reasonable sources to derive it. It is pretty simple really. No where in the reg does it state you cannot take off / land or fly if the AFM does not have the data.
As for what is reasonable, the FAA will only tell you after you crash.
Tim
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denverpilot
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You seem to be the only person concerned enough about it to carry on.
What harm would the proper interpretation of the word "must" have on you or anyone else?
You keep babbling about everything BUT the words in the regulation or their application.
You're quoting the FOI now? Seriously?
Strawman? A straw man requires that you make an actual argument for me to ignore. You haven't made one. Saying words don't mean what the dictionary says they mean, isn't valid.
I've said ...
- Pilot has to familiarize with everything. It's a catch-all law after all.
- Add on in (b) says that familiarization "must" (the exact word used by FAA) include two things.
And I've asked how YOU will prove you did so if the law is applied in any fashion to you.
@midlifeflyer has given his method. I've given another and admitted I don't always do it.
You've just gone back and forth with multiple attempts to discredit via personal insult, using multiple catch-phrases like "straw-man"which is normal for weak internet arguments, so they don't really bother me.
Must admit though, I love the refusal to answer a question posed and then a lecture that one should listen to the answer (not given) in the same post.
"I won't answer your question but you should listen." ROFLMAO.
That's some kick ass logic there. Super job.
Want a do over? Want to answer why it's emphasized and says "must" considering the hundreds of things the superseding rule above it covers, including these two items?
I'm ... all ears.
dmspilot
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Yet here you are.
That's not what a strawman is.
A strawman occurs when you accuse your opponents of making an argument that they didn't make. Which is exactly what you are doing.
I don't have a problem with the dictionary definition of the word "must", and your assertion that I do is bizarre, and again, is a straw man.
There are other participants in the thread beside myself.
The original question that started this debate was whether or not a pilot has to calculate the takeoff and landing distance for every takeoff and landing. Not the meaning of the word must, or why certain items are enumerated. You have decided change the nature of the argument at will. So I am not interested in answering your question.
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It's the part after the "must" where the disagreement seems to exist.
denverpilot
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Already covered. (1) and (2) describe the two ways to get the data. AFM or no AFM.
(b) supersedes (1) and (2) and if they're removed, the emphasis (b) adds to the main reg still stands. In fact, the portion that says "runway length" proves it. You get a runway length whether or not you have an AFM or not.
The split for AFM is the second half of he sentence and (1) and (2) simply describe the ways to get takeoff and landing performance data for an AFM or non-AFM required aircraft.
Say AFMs never existed. Line (b) still would exist and apply to the main reg.
Technically "runway length" is implied anyway. You can't get takeoff or landing data without it. It's superfluous.
Just like all of (b) is, unless there's a specific reason to emphasize it into law.