Part 135 T/O distance

[cvsfly]

Sorry to bring up a subject that has been discussed at length, but I may not be finding a specific answer for this. Trying to limit answer for specific category of aircraft. Part 135 Operation with "small non-transport category aircraft" - BE-200, 7 passenger seats, 2 crew. Applicable regulations (I believe) - 135.181, .183, .399 and 91.9, .103. Do the publication of Accelerate-Stop AND Accelerate-Go (one engine inop) performance data become "operating limtations" according to 91.9 and "take-off and landing distance data" according to 91.103. If answer is yes, obviously Part 91 vs 135 is irrevalent. Part 135.399 references "take-off WEIGHT limitations in AFM". Does this mean every chart that references weight in take-off calculations - whether 2 eng. or 1 eng. inop. has to be considered? We do reference a weight limitation on our load manifest in reference to 135.181 and BE-200 chart "Maximum Enroute Weight". I have trouble reading 135.399 due to the reference to 135.169(b)(2-6) which appears to apply to seating configurations of 10 seats or more (NA to our BE-200), but also says "or equivalent for operations under this part". Part 135.365-.398 appear to be much more specific for the performance requirements. If Accelerate-Go performance in particular is a limitation then BE-200s would require a minimum of 5500' at SL in summer (35*C) at MTOGW flaps 40% and many operators are violating this (while allowing a PC-12 to go). A late model BE-58 by comparison would be severely limited - about 7500' in this situation - but older light twins with no published Accel-Go data would not be as limited. Our training provider, of course, tests us on Accel-Go as a limitation for T/O. They also make reference to considering a % of a "usable clearway" in the calculation as stated on the chart - where is clearway (as defined in Part 1.1) information for a particular airport listed? Of course one is likely to reference 91.103 as the catch all for making decisions "with all available information". What is the consensus without considering accident aftermath lawyers? What am I missing?

 

[Doc Holiday]

I'll take a stab at this, although others (like Sled) can probably shed more light on the subject.

You were asking about accelerate stop/go being limitations on a BE200. The BE200 was certificated under Part 23 if I remember correctly and therefore is not a 'transport category' aircraft. 135.399 refers to "Small nontransport category aircraft" and says that the operator must comply with the takeoff weight limitations found in the AFM. If you look in a Part 25 AFM, there will be more than one factor to consider when calculating the maximum takeoff weight. Whichever of these factors results in the least takeoff weight is considered limiting, and that is the aircraft's MTOW in order for it to perform according to it's Part 25 certification. (the manual I'm familiar with has four items including climb performance/brake energy limits which can roughly be translated into accelerate stop/go). It's been a long time since I have looked at a King Air 200's manual, but I'm pretty sure you will not find language limiting takeoff weight like I described above. The BE200 is a nontransport category aircraft and did not need to demonstrate those types of performance to be certified. The only takeoff/landing limitations you will find are the associated maximum certificated weights (12500 for TO and 11000(?) for landing). In other words, the accelerate stop/go charts are presented, but not required (don't take that as me saying they are not important). Accelerate stop/go are not limitations for nontransport catergory aircraft.

I think you may have taken the end of 135.399(a) out of context a bit. The way I read it, "...or equivalent for operations under this part...", refers to the AFM, as in AFM or it's equivalent, not the type of operation being conducted.

The other regs you mentioned (135.181, 183, etc.) do not specify a particular aircraft certification (transport/nontransport/commuter) so I would interpret those as encompassing all aircraft.

Hope this helps.

 

[501261]

Now forgive me if I get some of this wrong, it's been more than 10 years since I was a BE20 check airman, but I seem to remember that when you get down to it most 135 T/O performance rules are not applicable since the airplane is Small, Nontransport, and (this is key) usually configured for less than 10 pax seats.

If you look up 135.399, it sends you to 135.169, which states that 135.169 only applies to planes with more than 10 pax seats, and transports. So 135.399 doesn't apply to most BE20's.

Basically 135.399 was written for Jetstreams, etc. Small, nonstransport airplanes, carrying more than 10 pax.

Here's from the Inspector's Handbook (8400.10 part 963):

963. RULES FOR RELEASE OF SMALL, NORMAL CATEGORY AIRPLANES WITH LESS THAN 10 SEATS. Reciprocating or turbopropeller powered airplanes certified in the normal category and operated under Part 135 with less than 10 passenger seats have specified rules. Small turbojet airplanes certified in the normal category are treated as if they were certified in the transport category for the purposes of Part 135 (see previous paragraph 955).
TABLE 4.3.2.6.
RULES FOR RELEASE OF SMALL, NORMAL CATEGORY AIRPLANES
WITH LESS THAN 10 PASSENGER SEATS
----------------------------------------------------------------------
Temperature Correction No AFM data shown at standard temperature.
Structural Limits
Max. Taxi Wt. Yes AFM or Placard
Max. Takeoff Wt. Yes AFM or Placard
Max. Landing Wt. Yes AFM or Placard
Zero Fuel Wt. No (Not an AFM limit)
Takeoff
Accelerate-Stop No
All-Engines No
Accelerate-Go No
Obstacle Limit No
T/O Climb Limit No
Enroute Limits
All-Engines No
One Eng. Inop Yes FAR 135.381
Overwater Yes FAR 135.383
Approach Climb No
Landing Climb No
Max. Landing Wt. Yes AFM
Runway Limit
Destination No
Alternate No
----------------------------------------------------------------------
A. Weight Limit. There are not takeoff weight limits in Part 135 for these airplanes. There are both takeoff and landing weight limits in the AFM. The regulations that make the AFM limitations apply to Part 135 operations are FAR 91.31 {See 91.9 - Ed.} and FAR 91.9.
B. Takeoff Runway Limits. There are no runway performance limits specified in either the AFM or in Part 135. Many of these airplanes have accelerate-stop distances expressed in flight manuals as advisory information. An accelerate-stop distance is a limitation only when expressed as such by the AFM. Some airplanes of the same make and model have such limitations while others do not, depending on the airplane's date of manufacture.
C. Climb Limits. There is no requirement that the airplane must be able to maintain a positive gradient in case of an engine failure. These airplanes are not required to be able to clear obstacles in the takeoff path in case of the loss of an engine.
D. Enroute. The provisions of FAR 135.181 for IFR operations with passengers and the provisions of FAR 135.183 for overwater operations with passengers apply to these airplanes (see paragraph 929 of this section). Most airplanes with less than 6,000 pounds takeoff weight are unable to meet the FAR 135.181 restriction, which effectively precludes their use in planned IFR passenger operations. Multiengine airplanes with over 6,000 pounds MTOW must be able to climb at a rate (depending on temperature) specified in Part 23 with one engine out at 5,000 feet MSL. Many of these airplanes are not be able to meet the requirements of FAR 135.181 over any surface higher than sea level.

 

[mike1mc]

Here's the way I understand it for the King Air series (9 or less seats):


FAR 135.397 - SMALL TRANSPORT CATEGORY AIRPLANE PERFORMANCE OPERATING LIMITATION
This FAR refers you to 135.379 for turbine powered aircraft (with some exceptions)

FAR 135.379 - LARGE TRANSPORT CATEGORY AIRPLANES: TURBINE ENGINE POWERED - TAKEOFF LIMITATIONS
1) Need to comply with AFM Weight Limitations
2) Must have compliance with Accel-Stop performance data
3) Must meet Takeoff Distance requirements
4) Paragraphs (d) and (f) don't apply per FAR 135.397 (b)

 

[501261]

Here's the way I understand it for the King Air series (9 or less seats):


FAR 135.397 - SMALL TRANSPORT CATEGORY AIRPLANE PERFORMANCE OPERATING LIMITATION
This FAR refers you to 135.379 for turbine powered aircraft (with some exceptions)

FAR 135.379 - LARGE TRANSPORT CATEGORY AIRPLANES: TURBINE ENGINE POWERED - TAKEOFF LIMITATIONS
1) Need to comply with AFM Weight Limitations
2) Must have compliance with Accel-Stop performance data
3) Must meet Takeoff Distance requirements
4) Paragraphs (d) and (f) don't apply per FAR 135.397 (b)

There you go, a great example of misunderstanding. Notice the second word of 135.397 TRANSPORT. King Airs are NOT transport catagory, so 397 does not apply.