This story rivals the Great Tea Trolley Disaster of ’67 http://www.guter.org/bristow/disaster.htm
REVIEW OF CAAP 54-1(2) Flight Manuals for Individual Aircraft
As of July 2000 and replaced by AC 21-34 in May 2017.
- Prior to August 1999 CASA (or its predecessors – but really the same organisation and the same people) required all aircraft to have an AFM per the CASA template. Let’s stick to simple single-engine airplanes so there is the Civil Mark 1 – see my example and compare it with the original AFM and manufacturers manual. Newer airplanes have a POH which combines the approved AFM and manufacturers manual – read the fine print to see which are the approved pages, the AFM.
- “It is the responsibility of the CoR holder to ensure the pilot is provided with all the information necessary to operate the aircraft safely. How this is achieved is the CoR holder’s responsibility. Such additional information is best contained in an operations manual or in a convenient folder available to the pilot, or it may be contained in the folder containing the TC holder’s AFM.” Gee, nothing to do with CASA is it (for imported types). But then, how does the aircraft owner (I will use that term instead of CoR holder) comply with this?
- “The Authority will issue and provide a copy of the CASA Approval Page which identifies the document that is approved as the AFM, and the initial Amendment Record Sheet to the CoR holder upon request. These pages are to be inserted at the front of the folder containing the TC holder’s AFM.” They couldn’t even get this right so they stopped doing this! See my example of my Decathlon. When I bought my Cessna it had the wrong POH.
- Some aircraft didn’t come with an AFM – that’s OK. The placards are very important in that case, and are very important even when there is an AFM. I see quite a few airplanes with missing or incorrect placards. When I bought my Cessna it was fitted with the wrong aircraft limitations placard. Wrong AFM and wrong placard – what did the pilots operate to?
- “The use of approved AFM data which has been re-formatted is the responsibility of the person converting the data. Examples are presenting data that was in tabular form in chart form, conversion of units etc. Such data is not part of the approved AFM or approved supplements and does not require approval by the Authority.” What is “etc”? Read the rules on pilot responsibility then consider that text.
- “there may be some delay in obtaining the required TC holder’s AFM. Until the end of the transition period, if the CoR holder can show documentary evidence of the action taken to obtain the document, the aircraft may continue to fly using the old AFM until the document is obtained” My Decathlon was manufactured by Bellanca and the new company manufacturing only Super Decathlons was taking no responsibility for aircraft manufactured by Bellanca. My guess is that they were also especially sick of Australians asking silly questions and wanting 30-year old documents from them. Even now, I see airplanes still using the old CASA Civil Mk 1 AFM! Like that Chipmunk in the ATSB report.
- “The airspeed datum(s) (IAS, CAS or both) specified in the AFM approved by the relevant NAA and produced by the TC holder need not be changed” Interesting that older American airplanes have their ASIs and AFMs in CAS rather than IAS! As all pilots know, there is a difference and the ASI indicates IAS, not CAS. So, what do you do when the ASI colour codes and numbers in the AFM are in CAS but the ASI is telling you IAS. (Not quite true as there is also an instrument error which can be up to 2 kts.)
- “The determination of the empty weight, empty weight centre of gravity position of an aircraft and the loading data is required to be approved by a Weight Control Officer (see CAO 100.7). This data may be inserted in the folder containing the TC holder’s AFM without further approval, or contained in another suitable document available to the pilot.” Gee, a WCA has to approve the loading data – but it is already in the AFM which is approved. If the WCA approves a different loading system then what about the law which requires that a pilot do what the AFM states?
- “The CoR holder has the responsibility to ensure that the pilot is aware of the need to use this loading data to comply with the limitations in the TC holder’s AFM, and any other limitations required by the Authority. Note: The loading data approved under CAO 100.7 overrides any loading data contained in the TC holder’s AFM.” Well, that explains my prior question however I would like to see the law which supports that!
- “The AFM is no longer required to contain operational limitations or operational performance data additional to AFM information approved by the relevant NAA. Operators should be aware that some operational requirements require extra or factored runway performance information. Such additional operational performance data required by the Authority e.g. weight limitation for runway performance, requires approval by the Authority”. Consider this later in my page on Performance Stuff.
- It is worth noting that back then CASA stated on their website that they had withdrawn those “P” Charts however we may still use them but the owner takes responsibility for the data. Consider this later in my page on Performance Stuff.
- Amateur-built “aircraft may not necessarily be required to have an AFM but, for these aircraft, it is expected that sufficient information to operate the aircraft safely will be available to the pilot.” Nil requirements, just “expected”. Read detail in the CAAP and it is only “should”. Be wary of homebuilt aircraft is my advice.
That Chipmunk accident mentioned above makes me angry. Read the ATSB report here https://www.atsb.gov.au/publications/investigation_reports/2014/aair/ao-2014-114/si-01/ and you will see why it makes me angry. “The spin recovery methods taught by the flying school were inconsistent across instructors and training material, and were not always appropriate for the Chipmunk aircraft type used by the school.”
See the email correspondence below with CASA in 2002 after I bought my Standard Decathlon in 2001. I obtained the correct AFM from ACA but had lots of issues getting it approved by CASA. First they tried to tell me that JIR had a 180 hp engine with a C/S propeller. Then they accused me (or someone) of changing the engine from 180 hp to 150 hp without approval! Nope, it still had the same 150 hp engine that it left the factory with over 30 years previously. Change of registration papers don’t include engine information so who corrupted CASA’s database? Search the database on CASA’s website you won’t see what engine is listed. Then they tried to tell me that I need to fix their database? I can’t see that the engine is wrong in their database, it is their database and only they could’ve corrupted it. Then after much trouble to convince CASA of the engine they then were unable to comprehend the basic principles of document control – the difference between an “issue” and a “revision”. Let alone applicability of a particular revision of the AFM to a particular SN of aircraft. No wonder they got out of approving AFMs as they incompetent.
Let’s compare one of those old CASA AFM’s with the original AFM (and now the current AFM in Australia) for a simple airplane:
- The CASA AFM has 28 pages vs 37 for the original (with supplements) and CASA wasted many pages with document control and regulatory matters so we should expect many differences, and this is for a simple airplane which had a simple AFM per very old USA regulations. The original had much information on weight and balance as required by FAR 23.
- The CASA AFM specifies a never exceed speed of 172 KIAS and a manoeuvring speed of 130 KIAS. The original AFM has 176 KCAS and 134 KCAS. When the aircraft arrived in Australia the ASI was required to be changed so that all markings were in KIAS instead of the original MPH CAS. Did anyone change them back to CAS to conform to the legal requirements?
- The CASA AFM states “No acrobatic manoeuvres are permitted except those listed below.” Words have specific meanings and that sentence is quite clear – anything not on that list is not permitted! The original AFM lists the “approved maneuvers and recommended entry speeds” as required by FAR 23. One must refer to another paragraph of FAR 23 to see that if any maneuver is not permitted (for acrobatic category only) then it must be listed in the limitations section of the AFM – none are listed!
- The CASA AFM states “The maximum permissible crosswind component for take-off and landing is 17 knots.” The real AFM only mentions “Demonstrated cross-wind velocity is: 20 MPH”.
- The CASA AFM states stall speeds of 55 KIAS and 52 KIAS at weights of 1575 lb and 1500 lb respectively compared to the real AFM 61 MPH CAS at 1575 lb. That is 53 KCAS. I wonder where we can find the IAS-CAS conversion?
- The real AFM states that 200 ft is lost in a power-off stall as required by FAR 23. Nil info in the CASA AFM.
- The CASA AFM has those “P” Charts which I shall discuss separately on the Performance Stuff page. Nil info in the real info as per the old FAR 23 that was included in the separate manufacturer’s manual, being unapproved data.
- You can see how Australian pilots were developed with a distorted view of flying airplanes.