by Zach Grant L1011jock » Fri Jun 02, 2017 4:06 pm
I corresponded with Vince on this, but the answer is not as cut and dried as it may seem on the surface. CAN the aircraft go higher, yes, however you are in Class A airspace at that point anywhere in the continental US. Thus you are going to be IFR, and as such must have a certified altimeter/Static system/encoder. That system can be certified to a value of 20K'. That is now your maximum allowable flight level as the certification of required components are such that they are the most limiting factor. An aircraft may have a certified ceiling of 25000' such as is the case with our turbocharged aircraft. IF you don't have O2 onboard you are limited to 14000' domestically as a maximum altitude (for 30 min), and 18000' if you have O2 but only a nasal canula. These systems limit the maximum certified level of the aircraft by their certification (or regulation), it is no different. Also, performance charts in a POH are not regulatory in any manner. They are marketing graphics in reality, until you get to the certified charts required in FAR 25 aircraft. The only limitations of the aircraft exist in the FAA Approved AFM, which is the stack of paper that you may have forgotten about somewhere in a seatback pocket (contains limiting airspeeds, powerplant and instrument markings, CG limits, operational limitations, and required placards). It is also ONLY Section 2 of the ICS AFM/POH (and any required suppliment you may have based on equipment. Autopilots, nav systems, oxygen, alternators etc., all come with an AFM suppliment). Anything that doesn't say FAA approved is just advisory. Next, we can look and see in the TCDS that the certification standards for the aircraft are CAR 3, NOT FAR 23, so applying FAR23 certification regulations retroactively is improper. A quick perusal of a 1961 250 limitations section I have in front of me yields no maximum certified altitude listed in limitations, nor does the TCDS have any max altitude limit specified for any Comanche aircraft other than the turbocharged 260 and twin. Does that mean the altimetry needs to be certified to infinity on all non turboed models? Of course not. Whatever you certify the unit to is your new certified ceiling as there is no other number published.
Zach
"Keep it above 5 feet and don't do nuthin dumb!"