Zero Fuel Weight?

kgruber said:
I'm not buying into that either. "N" numbers change all the time. Serial numbers don't. I'd say the AFM follows the serial number.
Click to expand...

Whatever. Altering an "approved" document with a cross through and hand written correction typically won't fly because it's now not the document that was approved originally. It should have been changed as a revision which is how approved documents are required to be changed.

I've done a lot of approved manuals under 121 and 135, and the process is the same. FWIW.
 
Stewartb said:
CAR3 addresses AFMs and operating limitations. My own interpretation is that regardless of RW's reference to AFMs not being enforceable, the CARs definitely require that they were supplied to every airplane owner and are required equipment for the purpose of defining limitations. In airplanes with dual standard and utility category approval that's undeniable after reviewing the CARs.
http://www.supercub.org/photopost/data/500/CAR-PART3.pdf

I don't know how a competent pilot without experience in my airplane could be expected to safely operate my airplane without having the POH and supplements available. And my 1975 C-180 TCDS does require having the POH in the required equipment section. Common sense would have it there even in the absence of ANY regulations.
Click to expand...

Yes, CAR 3 (3.777) does address this. Please refer to CAR 3 as amended May 15, 1956. The version you are using was November 1, 1949 and thus superseded.

3.777%20pic_zpsp9f0d2pi.jpg
 
Last edited:
You did read the last line, yes? Doesn't matter to me. Every mechanic I've ever used has made sure my POH and supplements are on board before they sign off an annual. My link to the definition of airworthiness explains why. As I've said, sometimes common sense should prevail. For the rest of you, that's what regulations are for.
 
Stewartb said:
You did read the last line, yes? Doesn't matter to me. Every mechanic I've ever used has made sure my POH and supplements are on board before they sign off an annual. My link to the definition of airworthiness explains why. As I've said, sometimes common sense should prevail. For the rest of you, that's what regulations are for.
Click to expand...

I'm using common sense based upon written documentation. Since I also hold an A&P/IA I as well go back and refer to these documents. The key is understanding what it written. A prime example is what you cited above in CAR 3. You used a superseded document which would tend to give a different picture.

Everything I've presented is in writing, and not "I was told by some unknown in AFS-**** " with nothing to back it up.

What's kinda funny is this is actually pretty clear and concise.
 
RW, as an IA how do you assure conformity in order to sign off an airplane as airworthy? Do you dismiss the equipment requirements completely or just parts of the equipment requirements? That's a serious question, by the way. If the definition of airworthiness, a very concisely written definition, requires conformity with the TC, and you as the IA certify an aircraft is airworthy..... There seems to be a disconnect in there. Since you play both sides how do you reconcile it?
 
Stewartb said:
RW, as an IA how do you assure conformity in order to sign off an airplane as airworthy? Do you dismiss the equipment requirements completely or just parts of the equipment requirements? That's a serious question, by the way. If the definition of airworthiness, a very concisely written definition, requires conformity with the TC, and you as the IA certify an aircraft is airworthy..... There seems to be a disconnect in there. Since you play both sides how do you reconcile it?
Click to expand...

You consider the requirements as set forth by the regulations the aircraft was certified under. Go back and read Order 8620.2A which describes what you are asking and answers it.

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.
Click to expand...
 
I understand that. How do you reconcile it against the FAA definition of airworthy as I quoted and liked earlier?

a. The aircraft must conform to its type design. Conformity to the type design is considered attained when the aircraft configuration and the engine, propeller, and articles installed are consistent with the drawings, specifications, and other data that are part of the TC. This includes any supplemental type certificate (STC) and repairs and alterations incorporated into the aircraft.
Click to expand...

The reason I ask is that every mechanic I've used has the POH on board checked off on the annual checklist. Not rookie mechanics, either. So while your link has been interesting it led me to keep looking. I found the link that I posted equally interesting. And while you'll likely say that my link addresses Airworthiness Certificates it also includes language about STCs and repairs, clearly only applicable after the plane left the factory. Like I said, there's a disconnect.
 
Last edited:
Stewartb said:
I understand that. How do you reconcile it against the FAA definition of airworthy as I quoted and liked earlier?
Click to expand...

By using the regulations that the aircraft was certified under. Example, CAR 3 requires certain placards be installed in view of the pilot, so I confirm using the TCDS that said placards are installed.

Please understand this, so many believe the TCDS is a regulatory document and must be abide by to the letter. It's not, the FAA has made that extremely clear. If one reads something in the TCDS that is suspect, he then must refer back to the regulations the aircraft was certified under for clarification.

I've done conformity inspections on aircraft while at the FAA and this is consistent when we were doing it there.
 
Thanks, I don't doubt your knowledge. I still am split between your perspective and Ron's. The CAR3 docs say placards or manual. When I did a ground up restoration of a 1947 PA-12 it was required to include a flight manual. That's why I was somewhat familiar with CAR3. I think an administrative law judge would have a severe headache trying to sort through the contradictions in the regs. I have a POH in my plane and intend to keep it there so this is little more than curiosity for me. I do appreciate the info.
 
Stewartb said:
Thanks, I don't doubt your knowledge. I still am split between your perspective and Ron's. The CAR3 docs say placards or manual. When I did a ground up restoration of a 1947 PA-12 it was required to include a flight manual. That's why I was somewhat familiar with CAR3. I think an administrative law judge would have a severe headache trying to sort through the contradictions in the regs. I have a POH in my plane and intend to keep it there so this is little more than curiosity for me. I do appreciate the info.
Click to expand...

No problem. I can see where someone may be confused by it, but again the regulations and guidance are very succinct.
 
RotorAndWing said:
What's at question here, and what Ron can't understand, is yes, the manufacturer can produce that document and submit it to the FAA for approval, and the FAA can approve it. However, there is no regulation requiring that document to be onboard the aircraft.
Click to expand...
R&W's statements are his own personal opinion, unsupported by the FAA, either Flight Standards or the Chief Counsel. I've personally asked FAA HQ about this, and they say he's wrong. Y'all do what you want, but before you rely him or anyone else posting anonymously on the internet, I strongly suggest you ask someone who actually currently works for the FAA and has the authority to give you a reliable answer. And if you choose to fly without that document, think about what you're going to say to a real, current FAA Inspector who wants to know why you are flying an airplane which is missing "Required Equipment" per the Type Certificate and a manual signed by the FAA Aircraft Certification Office which says the manual "must be kept in airplane at all times".
 
Last edited:
kgruber said:
I'm not buying into that either. "N" numbers change all the time. Serial numbers don't. I'd say the AFM follows the serial number.
Click to expand...
The Baltimore FSDO agrees with you, as my old Cougar had an N-number change, and my current Tiger had an N-number change, and as long as there was documentation showing the changes for that s/n, they were happy with a pen-and-ink change to N-number on the cover of that plane's AFM.
 
Ron Levy said:
R&W's statements are his own personal opinion, unsupported by the FAA, either Flight Standards or the Chief Counsel. I've personally asked FAA HQ about this, and they say he's wrong. Y'all do what you want, but before you rely him or anyone else posting anonymously on the internet, I strongly suggest you ask someone who actually currently works for the FAA and has the authority to give you a reliable answer. And if you choose to fly without that document, think about what you're going to say to a real, current FAA Inspector who wants to know why you are flying an airplane which is missing "Required Equipment" per the Type Certificate and a manual signed by the FAA Aircraft Certification Office which says the manual "must be kept in airplane at all times".
Click to expand...

Actually he provided the documentation. You just fail to make the distinction and combine separate issues under one umbrella.
 
Ron Levy said:
R&W's statements are his own personal opinion, unsupported by the FAA, either Flight Standards or the Chief Counsel. I've personally asked FAA HQ about this, and they say he's wrong. Y'all do what you want, but before you rely him or anyone else posting anonymously on the internet, I strongly suggest you ask someone who actually currently works for the FAA and has the authority to give you a reliable answer. And if you choose to fly without that document, think about what you're going to say to a real, current FAA Inspector who wants to know why you are flying an airplane which is missing "Required Equipment" per the Type Certificate and a manual signed by the FAA Aircraft Certification Office which says the manual "must be kept in airplane at all times".
Click to expand...

Oh boo hoo Ron. You sound like a little kid running away from the playground because we "won't play by your rules" :rolleyes2:

And to quote " Ya'll do what you want, but before you believe a CFI who constantly post on the internet "I was told by...." without ever providing any documentation" to please read the regulations, orders and notices and make an educated decision.

And please Ron, stop with this nonsense that you are the only one to be able to approach the FAA with a question. I did contact several Inspectors, a FSDO manager and an assistant manager as well as a Regional Counsel on this, and they agreed with the written documentation I presented here.

Now take your ball and run home crying. :rolleyes:
 
Last edited:
Ron Levy said:
The Baltimore FSDO agrees with you, as my old Cougar had an N-number change, and my current Tiger had an N-number change, and as long as there was documentation showing the changes for that s/n, they were happy with a pen-and-ink change to N-number on the cover of that plane's AFM.
Click to expand...

That's because your AFM is not an approved manual because you are operating Part 91, not Part 135.

If you ever learn the difference between "accepted" and " approved" and how it relates to FAA documents come back and we'll have an adult discussion on it, not the Ron "my way or else" you've become known for.

And BTW All Mighty and All Knowing One, it's rather pompous to make the statement "The Baltimore FSDO agrees with you" since they don't even know this guy and what this is about, and that you are trying to speak on the behalf of the Manager of the Baltimore FSDO without his knowledge. :rolleyes2:
 
Last edited:
Let me know when you contact the Chief Counsel or AFS. And please show us the written, signed opinion on FAA letterhead from either the Chief Counsel or AFS-300 which says that it's legal to fly without a flight manual required by the TCDS and signed as required by the FAA Aircraft Certification Office despite what it says in 14 CFR 91.9. Until then, please stop giving people advice which can get them in trouble with the FAA.
 
Ron Levy said:
Let me know when you contact the Chief Counsel or AFS. And please show us the written, signed opinion on FAA letterhead from either the Chief Counsel or AFS-300 which says that it's legal to fly without a flight manual required by the TCDS and signed as required by the FAA Aircraft Certification Office despite what it says in 14 CFR 91.9. .
Click to expand...

You have falling off the deep end on this one.:rolleyes2:

Ron Levy said:
Until then, please stop giving people advice which can get them in trouble with the FAA.
Click to expand...

You know, I have to ask, " Who the hell are you to get on here and demand I not post my opinion?" You constantly post meaningless and inconsistent information on FAA and regulatory matters and use the Ron Levy patented "name dropping" and innuendo to try to come across as some expert on something you're clearly not. You are not a DPE,you are not an A&P with an IA, you are not a part of and have never been a part of the FAA in any capacity other than a volunteer safety counselor, and you sure as hell have no formal legal training other than a few classes.

So if you can't participate in a discussion without your constant condescending drivel to those who disagree with you, go elsewhere.

And with that "Have a nice day" :D
 
Last edited:
RotorAndWing said:
...You are not a DPE, you are not a part of and have never been a part of the FAA in any capacity other than a volunteer safety counselor, and you sure as he'll have no formal legal training other than a few classes.
Click to expand...


But...but...but...44 years!!!!! :D

However, you must remember that Ron has the special decoder ring and knows the secret handshake to be able to communicate with "the people" he knows at the FAA. ;)
 
Wait, wait, wait.... so does the maximum zero fuel weight go up or down if you leave the AFM in the hangar?:stirpot:
 
Subsea said:
Wait, wait, wait.... so does the maximum zero fuel weight go up or down if you leave the AFM in the hangar?:stirpot:
Click to expand...
Since it's required (allegedly). It's considered part of the airframe and is thus part of the empty weight of the airplane.... you need to have it. If it's not required you need an A&P/IA to do a new W&B entry for you. I called a guy whose initials were F.A.A and he agreed.
 
bartmc said:
Since it's required (allegedly). It's considered part of the airframe and is thus part of the empty weight of the airplane.... you need to have it. If it's not required you need an A&P/IA to do a new W&B entry for you. I called a guy whose initials were F.A.A and he agreed.
Click to expand...

:goofy:

:rofl:
 
You must log in or register to reply here.
Back
Top