Accelerate/Stop Question

[FracCapt]

Your supervisor tells you that it is legal under Part 91 and this is "just part of flying in the real world" of corporate aviation.

Unfortunately, you're scenario is 100% legal....though not safe. Any aircraft 12,500lbs or under that is not a jet does not legally have to meet the acc/stop or acc/go distances. Any aircraft over 12,500 and any jet regardless of weight is legally required to meet those numbers. It happens all too often. If everything goes well, nobody will say a word to you....but if you take the thing off the end of the runway because you tried a high speed RTO and didn't have enough room for it....you'll be the one to get a violation or suspension.

Me? In the immortal words of George Bush Sr.....Not gonna do it..

 

[Singlecoil]

There are Part 135 scheduled flights operating twins into these airports right now, every day. This is an FAA approved scheduled operation. I don't see how that could be considered reckless. Taxiing out on one engine and trying to takeoff? That would be reckless. Taking off too heavy? That would be reckless. But operating within the regulations in this manner is not reckless.

 

[Lead Sled]

There are Part 135 scheduled flights operating twins into these airports right now, every day. This is an FAA approved scheduled operation. I don't see how that could be considered reckless. Taxiing out on one engine and trying to takeoff? That would be reckless. Taking off too heavy? That would be reckless. But operating within the regulations in this manner is not reckless.

Singlecoil...
Not to be repetitive here, but so what if the POI passes off on the operation? The expectation is that the PIC will not operate in way that would not compromise safety. The fact that you may have "the blessing" of your local FSDO means absolutely nothing - evidently you weren't around 15 or 20 years ago when the FAA's NASEP (Spelling ?) Team went around wreaking their havoc.

Lead SLed

 

[LAXSaabdude]

evidently you weren't around 15 or 20 years ago when the FAA's NASEP (Spelling ?) Team went around wreaking their havoc.

I started flying in 1987, and I don't seem to remember that. What was that about?

LAXSaabdude.

 

[Lead Sled]

NASIP stands for National Aviation Safety Inspection Program. It simply is a VERY thorough compliance inspection , the FAA equivilent to a full IRS compliance audit or better yet - a Salem Witch Hunt. Back in the mid-80's the FAA conducted these inspection on most (if not all) 121 and 135 operators. These folks really created havoc. If they encountered ANY discrepency (regardless if your local POI or FSDO approved it) you were assessed the appropriate fines and penalties. Flight crews who thought that they were in full compliance also received fines and suspensions. Without going into a lot of detail (No, I was never violated, but friends and associates were.), the lesson to be learned is that the fact that the local federales sign off on something means ABSOLUTELY nothing if the NASIP folks disagree. Several operators had their operating certificates suspended by the FAA due to the results of a "NASIP" inspection conducted by the FAA. Some were able to regain their certificate and start operations; some were not able to make it back. They all believed that they were in compliance with FAA regulations and that their records and record keeping systems were in compliance.

The FAA doesn't approve each and every takeoff or landing of a "scheduled" operation. They will merely expect that the PIC and operator operate appropriately. Again, as long as nothing happens no one will ever care. It's just that if (when) it does, the caca is going to hit the fan.

Jetguy

 

[surplus1]

Interesting Subject

Basically, I agree with the concept that this scenario is an exercise in risk management as opposed to a "legal" question. "One Level of Safety" does not in fact exist. That is why we do not have One Regulation that applies to this issue with which everyone must comply. From a safety perspective it makes little sense to have different rules based on whether one operates under Part 91, 135 or 121, but we do. The issue is economicis or more simply money. The rule maker (FAA) has a conflict of interest, the law requires it to establish safety rules but at the same time makes the Agency responsible for "economic viability" of its regulatory decisions. This is evident, to different degree, in all of the Regs (91, 135, & 121).

Think of these hypothetical scenarios.

Under 121, accelerate/stop and accelerate/go are both required by the Regs. When this adversely affects the potential operation a series of "variants" are permitted, e.g., balanced field vs. unbalanced field; the use of clearways, changes in heading, etc., and special exceptions granted on an individual basis. This is why Boeing 737's are not "grounded" when there are known anomalies in its rudder system that were not "fixed". The body count wasn't high enough to "justify" the grounding vs. the economic loss that would have occurred. So we continued to fly them while we guessed at how to "fix" them. The same thought process was applied to the propeller problems experience by the EMB-120 and the inadequacy of ice detection and elimination in the ATR. Money vs. Safety, more often than not, errs in favor of money.

Under 135, we see similar scenarios (in the area of takeoff performance) but most importantly, the aircraft is "assumed" by the FAA to be capable of flying through obstructions in the flight path as opposed to over obstructions (121). Very different. Common sense tells you that no aircraft can successfully fly through an obstruction without an "accident". Nevertheless, the FAA "approves" procedures that assume it can. Why? Because if they did not, those aircraft would cease to operate. They simply are not capable of complying with 121 and, due to economic considerations we create 135 and attempt to "manage the risk" by presuming that many engines just aren't going to "quit" in that particular area of the operation. Statistically they don't. If it is not your day and you crash because of this, you will merely become a "bump" in the statistics and nothing will change. In the opinion of the FAA, the "risk" is adequately managed. The Public, which knows nothing about any of this, doesn't have a clue that there is more than "one level of safety". In fact they are deliberately led to believe that they are being "protected" by the Agency. In fact, they are not; certainly not to the same degree.

Under 91, very nearly any risk that you choose to take is permitted under the law. The FAA changes its focus and shifts the "burden" from itself, to the pilot or operator. Why do you think they have 91.13? That is nothing more than a CYA program designed to protect the Agency from it's failure to accept responsibility. If the same rules (121) were applied to "light twins" many if not most of them would never fly. Their "single-engine" peformance is either non-existant or so marginal as to be irrelevant in the takeoff/climb out phase. They can't climb over obstructions on one engine, so what does it matter if they can't accelerate and stop either? The only thing that will change in that scenario is the physical point of impact. In the eyes of the FAA it's perfectly OK for you to kill yourself if you want to and if someone tries to blame them well, your "careless and reckless" operation will cover their butts, courtesy of 91.13. Part 91 is a classic case of tokenism. When a little airplane doesn't make it, the body count doesn't make the front page and you don't see it on FOX news for a week. In fact you don't see it at all, unless some big-wig happens to be on board.

I'm not suggesting what anyone should do but I will say that my own decisions are not based on some rule in a book. Yes, I follow the law but my decisions are based on my judgement which is tempered by my experience. The Regs expect this to a certain extent. That is why we give the PIC the authority to deviate from any rule in the interest of safety. Uner Part 91, what is "safe" and what is not rests mainly on the shoulders of the PIC and not the FAR's. That may be a cynical view, but it's pretty close to the mark.

To the maker of the thread: I believe it is legal for you to depart without accelerate/stop. Your "risk" is much higher in the accelerate/go phase of flight --- you will NOT be able to climb over most obstructions in any light twin (with and engine failure), but you aren't even required to consider that. If you were required to consider it, the data you have available makes it impossible to do so. You don't really have a clue as to where the obstructions are or how high they might be on any runway. Bottom line: If you're not comfortable, don't do it. The life you save will be your own. That's more valuable than any job and more importan than any FAR.

 

[cvsfly]

......I'm not suggesting what anyone should do but I will say that my own decisions are not based on some rule in a book. Yes, I follow the law but my decisions are based on my judgement which is tempered by my experience. The Regs expect this to a certain extent. That is why we give the PIC the authority to deviate from any rule in the interest of safety. Uner Part 91, what is "safe" and what is not rests mainly on the shoulders of the PIC and not the FAR's. That may be a cynical view, but it's pretty close to the mark......

Best worded post I've seen in awhile. They can't be expected to print every rule to keep every operator out of trouble or to provide goverment oversight. The operator has to take the responsibility some of the time.

 

[GVFlyer]

I've heard the arguement before. And still not sure. Lets compare a BE-58 and a BE-200. Both have charts for accel-stop & go. If you comply with Accel-stop do you also comply with the Accelerate-Go figures for? It's the difference between Part 23 vs 25 certified aircraft. Applicable Part 91 regs maybe 91.9, 91.13. Is the Performance section in the AFM also considered Limitations? Part 135 & 121 address aircraft performance in more detail.

Part 23 and 25 establish airworthiness standards for aircraft certification and unless that's what you're doing have no bearing on your operation of an airplane. Parts 91, 121, 125, and 135 set forth operational requirements and establish performance criteria for you to follow.

The military is the largest operator of King Airs in the world. I had 74 C-12's in my last command. The Air Force, Army, Navy and Marine Corps all require that accelerate - stop requirements be met.

GV

 

[cvsfly]

Part 23 and 25 establish airworthiness standards for aircraft certification and unless that's what you're doing have no bearing on your operation of an airplane. Parts 91, 121, 125, and 135 set forth operational requirements and establish performance criteria for you to follow.

........ The Air Force, Army, Navy and Marine Corps all require that accelerate - stop requirements be met.

GV

Well that's the problem here. The regs don't specifically support requiring Accl-stop/go under 91 & 135 for small non-transport, non-turbojet aircraft. Unless the interpretation is that all performance data published in the AFM is limiting. Did you also meet accel-go? Professional safety standards suggest that you do limit yourself to the given data. I for one in the BE-200 do not give up accel-stop, but there are many instances where accel-go cannot be met. For most operations accel-stop at SL, flaps appr, 30*C, 12,500 lbs (no mods) = 3600' & accel-go is 5100'. We always pick the best available runway, fuel load - by-pass the airports that don't meet our standards - and brief every departure and landing.

 

[Canucit]

ask any air ambulance driver how often he flys out of short strips and see what he says


good luck