A-R-O-W ????
by H. Dean Chamberlain
FAA Aviation News, July/August 1999
Recently one of the technical representatives at the Aircraft Owners and Pilots Association (AOPA) sent an email message to this writer asking what was the regulatory basis for the aircraft acronym "AROW." or those not familiar with the term, pilots use the term as a memory aid for remembering the documents required in most general aviation aircraft before a flight. The person had been asked by an AOPA member for the information, and although a flight instructor, the AOPA representative said he couldn't remember where to find the appropriate FAR requirement for all of the letters of the acronym. He had them all except for the "W" or the letter representing weight and balance.
A-R-O-W
For those not familiar with the acronym: "A" refers to the airworthiness certificate required to be displayed in the aircraft; "R" refers to the aircraft registration certificate required to be in the aircraft; "O" refers to the operating limitations (aircraft flight manual, pilot operating manual, placards, etc. as appropriate); and the "W" refers to weight and balance data. Some of you may remember that AROW once had two "R's" in it. The second "R" referred to radio and the required Federal Communication Commission's (FCC) radio station license. The FCC no longer requires an aircraft radio station license for radio communications transmitters in U.S. registered aircraft in domestic operations. Remember, travel to Canada and Mexico are international flights.
A-R-O-W AND THE FAR
How many of you know what is the regulatory basis for the various documents required to be onboard a general aviation aircraft operated under FAR Part 91 ?
If you are not sure, let's review the requirements. Some are obvious. Some are not so obvious. But we must point out we are only talking about those aircraft being operated under FAR Part 91 that are small, single-engine piston powered aircraft and are not being operated for hire or commercial purposes. The reason for the limited type of aircraft and operation is because certain types of aircraft and operations such as commuter or air carrier cps have their own specific rules that apply to the aircraft or flight operation. In many cases, the other aircraft and operating rules are more explicit than FAR Part 91.
Let's do the easy ones first. FAR §91.203, Civil aircraft: Certifications required, states in part that "(a) Except as provided in §91.715, no person may operate a civil aircraft unless it has within it the following: (1) An appropriate and current airworthiness certificate...." The rule then goes into detail of what meets this requirement for different types of operations and circumstances. Section (2) of the rule then states, "An effective U.S. registration certificate issued to its owner or, for operation within the United States, the second duplicate copy (pink) of the Aircraft Registration Application as provided for in §47.31(b), or a registration certificate issued under the laws of a foreign country." Then paragraph (b) of the rule states, "No person may operate a civil aircraft unless the airworthiness certificate required by paragraph (a) of this section or a special flight authorization issued under §91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew.
The above rule makes the requirement for the airworthiness and registration documents in civil aircraft pretty cut and dried. Nothing too complicated in this rule. The rule even states where the airworthiness certificate has to be displayed. As noted, the rule only applies to civil aircraft. It does not apply to military or public aircraft.
As we said earlier, the "A" and the "R" are easy to identify. The harder ones are to come.
THE CASE OF THE MISSING "O"
The "O" is not as clearly defined as the "A" and "R" were. The "O," operating limitations, for our specified general aviation aircraft starts getting a little complicated.
WHAT IT MEANS TO BE PIC
Let's review some basic rules before we discuss the our "O" requirement. FAR §91.3, Responsibility and authority of the pilot in command, states in part, "(a) The pilot in command of an aircraft is directly responsible for, and is the final authority as to, the operation of that aircraft."
Again, this rule is simple and pretty straight forward. The pilot in command (PIC) is responsible for the safe operation of the aircraft. Period.
Then §91.7, Civil aircraft airworthiness, makes two very basic and far reaching statements. It says in part, "(a) No person may operate a civil aircraft unless it is in an airworthy condition." Then it states, "(b) The pilot in command of a civil aircraft is responsible for determining whether that aircraft is in condition for safe flight. The pilot in command shall discontinue the flight when unairworthy mechanical, electrical, or structural conditions occur." This rule now makes the PIC responsible for determining if the aircraft is in an airworthy condition for a safe flight and what the pilot must do if an unairworthy condition occurs.
Keep this requirement in mind.
CIVIL AIRCRAFT FLIGHT MANUAL, MARKING, AND PLACARDS
FAR §91.9, Civil aircraft flight manual, marking, and placard requirements, spells out what modern aircraft must contain. The rule states in part that, "(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"
Section (b) of §91.9 then states, "No person may operate a U.S.-registered civil aircraft-(1) For which an Airplane or Rotorcraft Flight Manual is required by §21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. (2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof."
FLIGHT RULES: FAR §91.103PREFLIGHT ACTION
This rule says simply that "Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight." This information must include(in part) "(b)(1) For civil aircraft for which an approved Airplane or Rotorcraft Flight Manual containing takeoff and landing distance data is required, the takeoff and landing distance data contained therein; and (2) For civil aircraft other than those specified in paragraph (b)(1) of this section, other reliable information appropriate to the aircraft, relating to aircraft performance under expected values of airport elevation and runway slope, aircraft gross weight, and wind and temperature." This FAR section combined with the previous FAR sections details what actions a PIC is expected to comply with as part of his or her preflight actions. The rules say who is responsible for finding the information to ensure the aircraft is airworthy, where to start to find that information (such as in a flight manual or even something as simple and basic as a operating placard), and what the extent of that information should be. In other words all available information. This preflight rule even includes the first use of the concept of aircraft performance and gross weight because both are related to safely operating an aircraft and operating that aircraft within its operating limitations.
SHORT REVIEW
The preceding FAR sections established the operating requirements that cover most of the "AROW" acronym. In our response to AOPA, we even included various references to FAR Part 23, Airworthiness standards: Normal, utility, acrobatic, and commuter category airplanes. AOPA responded by asking what about those aircraft that don't have FAA approved flight manuals with the necessary operating limitations listed in FAR §23.1583, Operating limitations. The required limitation data includes weight and center of gravity.
At this point we thought we had answered AOPA's question. Wrong! Nothing is simple in Washington. This was one of those times. The technical specialist responded with, "Thanks for the response. We're close, but not quite there." He went on to say, "23.1583 (c and d) establish what the manufacturer has to tell me about weight and balance in the manual, but plenty of airplanes don't have and never did have manuals. Which regulation establishes the information that I have to have in the airplane pertaining to weight and balance information?
It was back to the proverbial drawing boards, or in the case of this writer, back to the keyboard, regulations, and subject matter experts for more information.
AROW: WHAT GOES UP MUST COMEDOWN
He is correct. Many older aircraft didn't have the operating information that newer models are required to have. One of the reasons for the newer manual requirements was the lack of uniformity and information in previous aircraft operating manuals. So a new manual format was introduced to help pilots find similar operating data in specified sections of FAA approved aircraft flight manuals. Today, FAA approved Airplane or Rotorcraft Flight Manuals are serialized for a given aircraft and must be kept current. Many of the older aircraft may have had a generic operating manual that was not developed for a specific aircraft. It was up to the pilot to review the aircraft's type certificate data sheet or maintenance logs to ensure that the data for that specific aircraft was being use when determining the various operating limitations. For example, only the latest weight and balance data for an aircraft must be used in determining its performance data and limitations.
Also, as the more modern aircraft were being produced, the simpler flight systems and operating equipment became more complex necessitating more complete flight information. Gone were the simplier days of the classic Piper J3 Cub and similar aircraft. Today's home microwave ovens have more detailed operating instructions than some older aircraft. There may be more people alive today who know how to fly a J3 Cub than there are who can program their home VCR or set its clock.
But even those simplier aircraft of what some people have referred to as aviation's "Golden Age" had to meet certain certification requirements. Those requirements were outlined in the various type certificate data sheets (TCDS) issued by the FAA's predecessor, the Civil Aeronautics Administration (CAA). Like now, those older aircraft had to conform to the government's approved type certificate for that particular make and model of aircraft which for many was Civil Air Regulation (CAR) 3. Once produced, for those aircraft to remain airworthy, their owners/operators had to maintain and operate their aircraft in a condition as required by the manufacturer in its various manuals and operating limitations provided by the manufacturer as part of the TCDS.
PIC OF OLDER AIRCRAFT
Now enter a pilot of such a vintage aircraft. As we outlined at the beginning of this article, the PIC is responsible for ensuring that an aircraft is airworthy before a flight. One way to check that an aircraft is airworthy in addition to meeting all of the maintenance related requirements is to operate that aircraft within the operating limitations outlined in the aircraft's type certificate data sheet. Simply stated, an aircraft must be operated in accordance with the information provided by its manufacturer and approved by an appropriate government agency as contained in the aircraft's approved type certificate or as subsequently modified with appropriate government approval. That is why when new equipment is added to an aircraft or old equipment removed, a new weight and balance calculation must be made by someone approved and qualified to do the work.
Each aircraft's type certificate data sheet includes approved weight and balance information as well as other operating limitations to ensure its airworthiness and conformity to its type certificate. A PIC is responsible for ensuring that the aircraft meets and is operated within the aircraft's type certificate specifications. Whew!
Add in the FAR requirement for "all available" information, and you have the basis for the W in the regulations of both FAR Parts 21, 23, and 91. It is too bad that FAR Part 91 regulations just don't require that current weight and balance data be required in an aircraft like the aircraft's airworthiness and registration forms are required. It would have saved a lot of work here at the office. But then maybe, general aviation pilots operating under FAR Part 91 are better off without the hard requirement like those contained in the other parts of the FAR.
In those sections, commercial operators are required to fill out weight and balance data forms for each flight and keep that data for specific periods of time. Is this level of record keeping necessary before you take off in your Mark I single-engine aircraft to buy that proverbial $100.00 hamburger? You own the aircraft. You weigh the same. The fuel level is full. And nothing has been added or removed from the aircraft since its last flight yesterday when you calculated the weight and balance. Do you need to recalculate it again today on a special form that needs to be filed and retained for possible FAA review? Or is the fact that you reviewed your weight and balance data as part of your performance calculations for takeoff enough? What do you think? Enjoy the burger.
