Twin Performance Question

[Charles Schefer]

Kristin - all good points.

- Charles

[Charles Schefer]

I finally got a chance to talk with my PMI at the Washington (DC) FSDO yesterday. I laid out the issue and he said no 337 and no logbook entry required to use the ICS AFM. He asked "is it an FAA Approved Flight Manual" and I said "yes it says so on the cover". He then asked in turn: "so why would you need any other FAA approval if it's already approved?". He said just stick it in and use it. He said if you feel more comfortable keep both the ICS and the original aboard but he said no 337 nor a log entry is required.

So playing Devil's advocate I asked "ok well if I buy an STC product that is also FAA Approved - I still have to file a 337 for the already approved change and do a log entry..." He said yes - that's because it's an alteration to the aircraft that affects performance and it's altering the approved baseline manual (i.e. with a new supplement). He said simply switching to a different fully approved manual does not require any additional approval.

So there you have it... you can agree or disagree but that is the Washington FSDO's position.

- Charles

[Timothy Poole]

[Kristin Winter]

I have sent it to my FSDO and we will see what they make of it. Based on the response you got, I am not entirely certain that they understood the question. I wouldn't say that a new AFM with different limitations does not affect performance.

[Charles Schefer]

Tim - You called it but who else could it be when it comes to maintenance at our local FSDO? I've actually found him to be quite a stickler for detail over the years.

Kristin - I don't disagree with you, I'm just sharing one inspector's response. I think he understood the issue just fine, we had a detailed discussion and he is a detail guy. I'm curious as to what your FSDO says. In my experience I've found different FSDOs will sometimes give different responses to the same question. In fact often two inspectors from the same FSDO won't agree. Such is the "clear cut" realm we live in .

As an attorney I'm sure you'd agree that the Judicial branch of government exists to interpret the law. The law (including FAA regs) is not always clear-cut. So there is often room to debate and interpret.

- Charles

[Kristin Winter]

FAA regs are anything but clear cut, and even the FAA recognizes that it has a problem with varying interpretations among the different offices.

I will let you know when I hear back from my FSDO. I emailed it to them as I was not about to drive down to Oakland to knock on the door. Depending on what I hear, I may run this up the flag pole to FAA legal in DC. As an IA, I rather need to know if there is paperwork that needs to be done to count the Killough manual as the official AFM.

[Charles Schefer]

Makes sense Kristin. I'm interested to learn what you hear back...

- Charles

[Charles Schefer]

On the related subject of certification standards for FIKI it looks like ATSM is publishing new standards where it will no longer be a "one size fits all approach". Sounds like a good thing...

http://www.avweb.com/avwebflash/news/AS ... 797-1.html

- Charles