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Summary of Responses to NPRM 9801AW

Flight Manual Management Procedures

Readers should note that this Summary of Responses outlines CASA's agreed policy and intended legislative action and closes the public consultation process in respect of the NPRM Any member of the public can request CASA to reconsider its policy and intended legislation CASA will consider such requests if and only if they contain information not previously submitted and considered as part of the public consultation process 1
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CIVIL AVIATION SAFETYAUTHORITY AUSTRALIA

INTRODUCTION For a number of years concerns have been expressed within the aviation industry and the Authority over the effectiveness of the current flight manual management system In 1996 to address this situation a project called the Flight Manual Management Project was initiated under the Regulatory Role Program The project team comprised 6 CASA technical specialists 4 highly experienced industry representatives and 3 CASA personnel as ex officio members The group was tasked with reviewing the current system and procedures and developing recommendations for a new system

As part of this process Notice of Proposed Rule Making NPRM NPRM 9801AW Flight Manual Management Procedures was released for public comment on 30 January 1998 This NPRM contained proposals to change the legislation to introduce revised and simplified procedures harmonised with typical international practice as far as practicable together with transitional regulations The period for public comment on the proposals contained in the NPRM closed on 2 March 1998

Forty three responses to the NPRM were received including some substantive and comprehensive submissions Most respondents supported the proposal and many of the comments have been helpful in refining it

This Summary of Responses discusses comments received and provides a summary of the final rule The Authority will no longer require unique Australian aircraft flight manuals Certificate of Registration holders will be required to have the aircraft flight manual placards or other documents produced by the manufacturer or Type Certificate holder to keep them current and to incorporate amendments or supplements supplied by the manufacturer or required due to modifications or STCs

It is intended that the proposed system be brought into effect as soon as possible through amendments to the Civil Aviation Regulations CARs 1988 These amendments will subsequently be translated into the new Civil Aviation Safety Regulations CASRs which will progressively replace the CARs and Civil Aviation Orders CAOs over the next two to three years

Implementation of the proposal will begin when the notice of the making of the regulations is published in the Commonwealth of Australia Gazette Industry education material will be published shortly Finally I would like to thank everyone who has taken the time to respond to the NPRM

Richard G Yates Assistant Director Aviation Safety Standards

16 July 1999 3
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TABLE OF CONTENTS INTRODUCTION 1 TABLE OF CONTENTS 3 ABBREVIATIONS 4 SUMMARY OF THE FINAL RULE FOR THE ADMINISTRATION OF AIRCRAFT FLIGHT MANUALS 5

Basic Process 5 The following simplifications apply 6 ANALYSIS OF INDIVIDUAL COMMENTS 9 Background 9 Purpose 9 Analysis 9 DISCUSSION OF COMMENTS RECEIVED 11 Introduction 11 Specific Comments 11

ANNEX A Proposed new draft Civil Aviation Regulations A1 ANNEX B Draft Civil Aviation Advisory Publication CAAP 54 1 0 B1 ANNEX C List of respondents consenting to publishing name C1 5
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ABBREVIATIONS AD Airworthiness Directive AFM Aircraft Flight Manual AIP Aeronautical Information Publication AOC Air Operator Certificate AWI Airworthiness Inspector CAAP Civil Aviation Advisory Publication CAO Civil Aviation Order CAR Civil Aviation Regulation CAS Calibrated Airspeed CASA Civil Aviation Safety Authority CASR Civil Aviation Safety Regulation cg Centre of Gravity CoA Certificate of Airworthiness CoR Certificate of Registration DER Designated Engineering Representative FAA Federal Aviation Administration of the USA FAR Federal Aviation Regulation of the USA GAMA General Aviation Manufacturer's Association IAO Instrument of Appointment IAS Indicated Airspeed ICAO International Civil Aviation Organisation IFR Instrument Flight Rules IoA Instrument of Appointment LEP Log or List of Effective Pages MTOW Maximum Take off Weight NAA National Airworthiness Authority NPRM Notice of Proposed Rule Making POH Pilot Operating Handbook relevant NAA The foreign NAA responsible for the aircraft type certification that has been accepted by CASA

RPT Regular Public Transport RSOL Radio System Operating Limitations STC Supplemental Type Certificate TC Type Certificate TCDS Type Certificate Data Sheet 6
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SUMMARY OF THE FINAL RULE FOR THE ADMINISTRATION OF AIRCRAFT FLIGHT MANUALS

Basic process From the consideration of all comments received the proposal as presented in NPRM 9801AW has been amended slightly The final requirements and administrative procedures are summarised below

The requirement or otherwise for an AFM approved by the Authority depends upon the applicable airworthiness standards of the NAA responsible for the aircraft Type

Certification that has been accepted by CASA This NAA the relevant NAA is usually the NAA of the country where the aircraft was first manufactured and flown For some aircraft an AFM was not required but certain information was required to be provided to the pilot and the manufacturer chose to provide this information in a POH A POH containing such information required by the relevant NAA will become a CASA approved AFM For a large number of other aircraft only placards controlled by the aircraft's maintenance system are used to convey to the pilot such information required by the relevant NAA and a CASA approved AFM will not be required

CASA will hold and maintain a master copy of the manufacturer's or TC holder's AFM or POH for each aircraft type and model on the Australian Register for which a CASA

approved AFM is required CASA will issue a CASA Approval Page for each AFM or POH

A copy of this page is to be inserted by the CoR holder at the front of the folder containing the basic document

CASA will also make available an Amendment Record Sheet form This form or a form containing prompts for similar information is to be inserted by the CoR holder in the folder

containing the basic document as the record of the amendment status of the basic document and to list the changes or supplements applicable to that aircraft

For the issue of a CoA the Authority or an authorised person must verify whether an AFM is required If a CASA approved AFM is required then the CoR holder or nominated

representative is to a obtain the document approved by the relevant NAA as the AFM or POH supplied by the manufacturer or TC holder when the aircraft was delivered or a replacement copy

b obtain from the Authority the CASA Approval Page c obtain a blank Amendment Record Sheet from the Authority or another suitable blank containing prompts for similar information and fill in the following required information

i registration mark ii aircraft serial number iii actual issue status of the AFM or POH iv record of all amendments and supplements and d sign and date the Amendment Record Sheet once satisfied of the amendment status 7
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The AFM requirements for issue of a CoA will be satisfied when the Authority or an authorised person is satisfied that a the basic document is the appropriate one b the folder containing the AFM contains all the changes and supplements necessary because of the particular configuration of the aircraft as supplied by the manufacturer or as modified in accordance with STCs or by the installation of approved modifications and

c the CoR holder has a means in place to keep the manual current The CoR holder must supply a copy of the CASA Approval Page and Amendment Record Sheet and the identifying details of any LEP that is required to define the AFM but not the

LEP itself to the local CASA office to be placed on the aircraft file Note The CoR holder no longer has to supply a copy of the AFM to CASA for issue of a CoA to an individual aircraft

The CoR holder is responsible for keeping the AFM current and for supplying the Authority with a copy of the Amendment Record Sheet whenever changes to the AFM are made

A person holding an IoA under subregulation 55 4 of CAR 1988 may approve certain AFM data or information if such a person has been assessed as suitably qualified and experienced by the Authority The following simplifications apply Approved weight and balance information issued by a Weight Control Officer may be

inserted in the folder containing the AFM or contained in a suitable document available to the pilot without further approval

RSOL pages are no longer required Equipment Lists are optional unless contained in the AFM or POH issued by the manufacturer or TC holder

No factoring is required on the approved take off and landing performance data in the manufacturer's AFM or POH However operators should be aware that some operational requirements require extra or factored runway performance information This information may be in a suitable supplement kept in the folder containing the AFM

Other operational performance data or limitations required by the Authority for certain operations may also be kept in suitable supplements in the folder containing the AFM

Airspeeds in the AFM may be quoted in IAS or CAS or both as accepted and approved by the relevant NAA For aircraft operated under an AOC the AFM need not be carried in the aircraft provided that an operations manual is carried which contains the same information as that in the AFM and which does not conflict with the AFM An exemption is no longer required All other aircraft for which an AFM is required must carry the AFM

AFM information issued by the aircraft manufacturer and approved by the relevant NAA is approved data for insertion in AFMs when such data is applicable to the specific aircraft

Such data does not need to be re approved by CASA

The preferred units of measurement in the AFM are knots for airspeed and feet for altitude The preferred units for all measurements are as given in the NPRM and AIP AIP GEN 4 8
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Whilst the preferred system is recommended for all units of measurement those contained in the AFM or POH approved by the relevant NAA and produced by the manufacturer or TC holder need not be changed It will be the responsibility of the C o R holder operator or pilot to provide appropriate conversion data if necessary to ensure that the aircraft is operated without hazard

The units of measurement used in placards and for instrument markings as well as their consistency are independently subject to maintenance system and AD requirements

the Authority will no longer advise CoR holders when an amendment or supplement is approved nor direct CoR holders to incorporate changes It will be the responsibility of the

CoR holder to be aware of obtain and incorporate approved changes CASA may direct certain changes in the interest of safety by AD action or by a written direction under subregulation 55 4 of CAR 1988

CASA will no longer issue operational supplements such as door off supplements For an aircraft for which an AFM or POH is not required supplements may be located in the aircraft in any convenient folder available to the pilot Supplements should be in the form

provided by the manufacturer or in the GAMA format

The proposed regulations are at Annex A Associated advisory information in the form of a draft CAAP No 54 1 0 Flight Manuals for Individual Aircraft is attached at Annex B 9
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ANALYSIS OF INDIVIDUAL COMMENTS Background On 30 January 1998 CASA released for public comment NPRM 9801AW Flight Manual Management Procedures This NPRM contained proposals to change the legislation to introduce revised and simplified procedures harmonised as far as practicable with typical international practice for the requirements and administration of flight manuals The period for public comment on the proposals contained in this NPRM closed on 2 March 1998

Purpose The purpose of this Summary of Responses is to provide a consolidation of all comments received

as part of the consultative process as well as to provide the CASA response to each of those comments and a final disposition in respect of the them

Analysis CASA received forty three 43 responses to the NPRM including some substantive and

comprehensive submissions most of which supported the proposal A list of respondents who have consented to their names being published is attached at Annex C

This Summary of Responses has been reviewed and agreed by the policy sponsor the General Manager Airworthiness

The disposition of Comments is shown in figure 1 below Subsequent to the closing date other input was received particularly by telephone after the publication of an article in Aiming Higher of March 1998 This input has been considered in the development of the final disposition

Comment Number received Acceptable without change 11 Acceptable but would be improved if changes were made 18 Not acceptable but would be acceptable if changes made 1 Not stated 10 Not acceptable under any circumstances 3 Total 43

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DISCUSSION OF COMMENTS RECEIVED Introduction Many comments were on specific topics whilst others were of a general nature All comments received were evaluated and where appropriate the suggestions made incorporated Comments of a general nature are addressed collectively in this Summary of Responses rather than individually

Administrative procedural and advisory material to support the new proposal has been produced by the Authority

For the purpose of this Summary of Responses comments have been grouped generically and sequentially numbered Thus one comment number may include responses by several respondents

Specific Comments COMMENT 1 Claims of CASA abrogating responsibility A number of commenters suggested that CASA would be abrogating its safety responsibility in adopting the proposed system

CASA Response Many of these comments were not supported by fact or example did not provide constructive suggestions and were often based on misconceptions or an incomplete understanding of the purpose of the AFM Hopefully the discussions in this document may help a fuller understanding The majority of respondents supported the proposal

The Authority disagrees with the suggestion that the proposal represents any abrogation of its responsibility for safety regulation This proposal does not change the requirement that all aircraft must have the necessary information available to the operating crew The information will be provided in the manuals or placards that were required when the aircraft was delivered from the manufacturer updated as necessary as a consequence of amendments or modifications

There is no proposal to abolish flight manuals issued by the manufacturer or TC holder and there is no lessening of the information that must be included in an AFM In fact there may be more information provided such as that contained in a POH

The major differences compared with the current system are the elimination of unique Australian requirements and the simplification of administrative procedures All International Civil Aviation Organisation ICAO requirements are met in the proposed system Thus the safety of air navigation will be unaffected

Disposition CASA will proceed with the proposal as described in the NPRM as modified in the light of responses submitted 13
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COMMENT 2 General opinions A number of commenters whilst supporting some of the changes made some emotive comments for example

The NPRM is ambiguous and is proliferated with words such as significant unnecessary and considerable

CASA has not presented any quantitative evidence to support these proposals This NPRM seems to be based largely on speculation and anecdotal evidence It is much easier cheaper and more sane to maintain a process is not substantiated with any objective or quantitative evidence and as such displays ignorance institutional timidity and the influence of vested interests

I've read the NPRM a couple of times and I'm not sure what exactly is the proposal Is a very narrow ill considered view in relation to the deletion of RSOL pages Most of the proposals are not consistent with the tenets of the harmonisation requirements

CASA Response The reasons for initiating the changes were explained in the Background section of the NPRM The views expressed were developed by a full CASA Industry team and harmonise as far as is practicable with typical international aeronautical practice

The overwhelming opinion of respondents is supportive of the proposed changes Some very helpful suggestions and comments were provided and have been incorporated in the proposed Final Rule as appropriate

It is accepted that some of the comments may be based on an incomplete understanding of the proposal and purpose of an AFM

The new administrative arrangements will benefit both CASA and industry See also Comment 21

It is not possible to quantitatively define the savings but there are savings to be made

Disposition CASA will proceed with the proposal as described in the NPRM

COMMENT 3 Placing the responsibility on the CoR Holder A number of commenters felt that it was inappropriate to put the responsibility on to CoR holders for ensuring that the aircraft has the appropriate AFM that the AFM reflects the configuration of the aircraft and is kept current Also some commenters felt that some CoR holders may not be able to obtain or maintain the required data 14
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CASA Response The current regulations require the CoR holder to ensure that the required maintenance is carried out on the aircraft

The proposal requiring the CoR holder to ensure that the necessary AFM information is provided is of the same order of responsibility as that for ensuring that maintenance is carried out CoR holders may appoint a representative to ensure the AFM is provided and amended in much the same manner as arrangements are made for maintenance on behalf of the CoR holder

Introduction of the proposed system will be accompanied by an industry education program which will enable CoR holders to understand the new requirements

CAAP 54 1 clearly explains the CoR holder's responsibilities and answers many of the expected questions

Refer to Comment 15 for information on the means of obtaining the required data

Disposition CASA will proceed with the proposal as described in the NPRM

COMMENT 4 CASA will no longer advise CoR holders when an approved amendment or supplement is applicable One commenter stated The ICAO requirement is that the State of Registry is responsible to advise and in many cases the aircraft manufacturer or STC holder does not know the location or operator of the aircraft so that if a safety amendment becomes necessary CASA will be the only source of this information

CASA Response It is the responsibility of the CoR holder to maintain the AFM to current status AFM information that is issued by the manufacturer and approved by the relevant NAA in the form of Alert Service Bulletins Service Bulletins and AFM amendments or supplements does not need to be re approved by the Authority The CoR holder should assess all continuing airworthiness information for relevance to the aircraft This will require the CoR holder to register with the manufacturer TC holder or distributor in order to receive such information

Provision will be available in the new regulations for the Authority to give directions to CoR holders related to flight manuals as in the current regulations However the AD process will be the preferred medium see also Comment 25

Disposition CASA will proceed with the proposal as described in the NPRM

COMMENT 5 Manufacturer's amendments One commenter stated The notification availability and distribution of the manufacturer's amendments and the implementation of those amendments are key safety issues in the whole process Unless CASA is in the distribution loop how quickly will a change of ownership be registered How will a pilot get the information if he or she is not the registered owner Some form of abbreviated list of registered owners frequently amended will need to be considered 15
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CASA Response Under the current legislation the Authority has no obligation to distribute AFM amendments or supplements It is the responsibility of the CoR holder to obtain these as will continue to be the case under the proposal Responsibility rests with the CoR holder to keep the manual current

A change of CoR holder has no effect on the validity of the AFM it becomes the new CoR holder's responsibility to keep the AFM current Registration of aircraft is being reviewed under another project

The CoR holder or the nominated representative is responsible for ensuring that the required AFM information is available in the aircraft to the operating crew This includes the incorporation as appropriate of manufacturer's continuing airworthiness information and ADs related to flight manual issues

Disposition CASA will proceed with the proposal as described in the NPRM

COMMENT 6 Reliance on placards only A number of commenters expressed a concern that some light aircraft will not have an AFM Two commenters queried where supplements would be located for such aircraft One commenter suggested the supplement be entered on the CofA

CASA Response An AFM is one means of specifying the operating limitations but not the only means

Many light aircraft are operated quite satisfactorily overseas without an AFM Whether an AFM POH or set of placards is used depends upon the aircraft certification standard

Locally approved supplements eg Mogas door off glider towing etc manufacturer's supplements or other manufacturer's custom supplements may be located in any convenient folder that is available to the pilot There must be a system of indexing and amending these supplements such as including an Amendment Record Sheet in the front of the folder containing the applicable supplements Supplements should be either in the form supplied by the manufacturer or in the GAMA format When such supplements are incorporated a copy of the current Amendment Record Sheet is to be supplied to the local CASA office for file

The Authority does not agree that the supplements should be entered on the CoA It is considered that this is unnecessary and would require the CoA to be re issued every time a supplement was added or deleted

Disposition CASA will proceed with the proposal as described in the NPRM 16
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COMMENT 7 Use of placards in lieu of an AFM Several commenters suggested that a flight manual was the single logical place to keep all the pertinent data

One commenter suggested that additional placards of mandatory and non mandatory information would be impractical and potentially unsafe

One commenter suggested that aircraft engaged in RPT operations should have an AFM One commenter stated that FAR 21.5 applied only to aircraft of US origin CASA Response The AFM is the required place to keep specified information not all of the information required to operate the aircraft Other information may not be approved CoR holders may elect to locate other information in the folder containing the AFM but this would not form part of the approved AFM Alternatively the additional information may be located in any suitable folder available to the pilot

Nothing in this proposal requires additional placards Any required additional data may be located in a suitable document available to the pilot

If the specified information has been required by the applicable airworthiness design standards of the relevant NAA to simply be provided in placards then that is sufficient regardless of the category of operation If an AFM is required it must be provided

Aircraft engaged in RPT operations would be operated under an AOC Operational requirements may be contained in an operations manual An operations manual may also contain AFM information

Some early design standards did not require the aircraft to be provided with an AFM Also the United States CAR 3 and early versions of FAR 23 permitted aircraft of less than 2722 kg 6000 lb MTOW manufactured and flown before March 1979 to be exempt from having an AFM provided the required information is available in the form of placards or other documents such as a POH Many such aircraft are operated overseas with placards only

Disposition CASA will proceed with the proposal as described in the NPRM

COMMENT 8 Surveillance needed One commenter queried how CASA staff would be aware of the currency of approved data during Aviation Safety Surveillance Program or ramp checks

A number of commenters voiced concern that the proposed system would require a significant increase in surveillance activity

CASA Response CASA will maintain a flight manual database for the status of CASA approved AFMs It is intended that this database should also be placed on the CASA website Under the new AFM legislation AFM information issued by the manufacturer and approved by the relevant NAA for an aircraft type and model that has been accepted in Australia will be approved data for insertion in AFMs when such data is applicable to the specific aircraft 17
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If required in unusual cases CASA staff can check the status of AFM information by contacting Central Office

It is agreed that surveillance is one of the necessary and valuable tools of airworthiness control Some CASA resources will be freed up as a result of the changes to the present cumbersome administrative arrangements associated with AFMs and as a result of other initiatives

Disposition CASA will proceed with the proposal as described in the NPRM

COMMENT 9 Aircraft limitations One commenter stated that means should be established to identify which specific limitations apply to a particular aircraft for example those associated with which capacity fuel tanks are fitted which particular engine is installed which particular propeller is fitted etc

Two commenters stated that in some pre AFM aircraft some specific airworthiness limitations were not necessarily contained in placards but entered on the old DA14 CoA The old DA14s were replaced by the Civil Mk 1 and Civil Mk 2 AFMs This commenter queried how these limitations would be conveyed in the new system

One commenter stated that the Aerocommander AC500 S U aircraft have a higher MTOW in the current Australian AFM than on the FAA TCDS and that operators would not wish to lose this

CASA Response The AFM supplied with the aircraft when the aircraft was delivered contains the limitations relevant to that particular aircraft The modification status of an aircraft is reflected in the maintenance records of that aircraft and when a modification affects the approved AFM then the CoR holder must ensure that the AFM has been amended to reflect the changes made to the aircraft

As stated in Comment 6 it is considered impractical to require limitations to be entered on the CoA If CASA was to require changes to the certification airworthiness limitations for an aircraft of a type that did not require an AFM this would be advised to a CoR holder by an AD The requirement may be to modify existing placards or to install additional placards This is also explained in Comment 25

The situation with AC500 S U aircraft is that currently an Australian STC authorising the higher MTOW is approved The AFM is required to contain the supplement required by the STC

There is no suggestion that this change in approach to management of AFMs will result in any change to the existing need to define the configuration and limitations of an aircraft

Disposition CASA will proceed with the proposal as described in the NPRM 18
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COMMENT 10 Aircraft equipment A number of commenters stated that the equipment and instruments must be properly identified with a means of establishing the approval of such installations

One commenter claimed that it is already difficult to establish the exact modification status of an aircraft and that the NPRM proposals will make this more difficult

Two commenters claimed that a description of everything to do with the aircraft must be provided to the pilot

Several commenters claimed the AFM was useful as a configuration control document during audits

One commenter claimed that equipment lists including weight and balance must be made available to the pilot particularly where the aircraft may have various role equipments fitted

One commenter stated that equipment lists are required in the recently revised weight and balance data and should be retained Civil Aviation Order CAO CAO 100.7 refers

One commenter specifically agreed that equipment lists could be deleted from the AFM as the requirement was contained in the weight control data

CASA Response This proposal does not change the current requirement for the necessary information associated with the equipment fitted to be included in the AFM

As explained in Comment 7 the AFM is the required place to keep specified information not all the information required to operate the aircraft

The AFM is not for the purpose of the configuration control of the aircraft The aircraft permanent records are the appropriate place to determine the configuration

Many AFMs include an equipment list from the manufacturer which must be updated if modifications are incorporated and maintained for the benefit of flight crew members

If the original individual AFM with the original equipment list has been lost in many cases a replacement copy can be purchased from the manufacturer the Type Certificate holder or the distributor

AFM amendments or supplements for the equipment fitted are required to enable the pilot to operate the aircraft within the limitations that are appropriate for the combination of the aircraft and that equipment

The weight control data must address the equipment fitted In summary equipment lists are optional not required to be contained in the AFM unless contained in the AFM or POH issued by the manufacturer or TC holder Aircraft that do not require an AFM are not required to have an equipment list but the configuration of the aircraft must be defined in the permanent records of the aircraft and the associated necessary limitations are to be displayed on placards or in supplements

Disposition CASA will proceed with the proposal system as described in the NPRM 19
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COMMENT 11 Weight and balance loading A significant number of commenters responded on this issue All agreed that the basic certification limitations of weight and cg envelope should be contained in the AFM placards or other documents All agreed that information to ensure that the aircraft is operated within the weight and cg envelope is necessary

A significant number of these commenters suggested that the approved weight control data should be contained in an approved section of the AFM

One commenter queried what happens when a modification is incorporated which changes the empty weight and cg

CASA Response The aircraft flight and operational limitations must be contained in the AFM placards or other documents and no change to this is proposed How the aircraft is loaded to ensure that the particular aircraft remains within the certificated weight and cg envelope is a separate operational question

Data issued by a Weight Control Authority is approved data and must be made available to the operating crew However there is no need for this data to be contained in the AFM

The folder containing the AFM is one of a number of suitable locations for this data There is no need to amend the AFM every time the weight and balance information changes

If a modification is embodied on an aircraft which affects the empty weight and or cg then a record must be made of the change If the empty weight and or cg change exceeds prescribed limits as given in CAO 100.7.6.3 the weight and balance information must be revised so that the aircraft can be operated within the certification weight and cg envelope

If the modification affects the AFM weight and cg envelope then this is a change to the Type Certification basis which must be properly justified and an appropriate AFM supplement must be approved and issued by CASA or an authorised person

Disposition CASA will proceed with the proposal as described in the NPRM

COMMENT 12 Aircraft Performance Data A significant number of comments were received on this topic Most commenters stated that performance information needed to be available to the pilot

Some commenters were of the opinion that factors should be applied and that the pilot should be made aware of the factors this being felt to be increasingly necessary as aircraft suffer performance degradation with age

Some commenters observed that manufacturer's data did not usually contain additional factors Some commenters questioned where the performance data should be located suggesting it should be in an approved part of the AFM

One commenter felt that as an absolute minimum a direction should be given to AOC holders to comply with the landing requirements of CAR 92 1 Regulation 92 1 of CAR 1988

One commenter asked how errors in performance charts would be dealt with 20
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One commenter suggested CASA should maintain a database of approved performance charts Several commenters agreed specifically with the proposal

CASA Response The requirement or otherwise for performance data is specified in the airworthiness standards that applied when the aircraft was certificated Any such information would be required to be contained in the approved section of the AFM or POH

For the past 8 years in Australia take off and landing distance factors have not been mandatory in private aerial work and charter operations in aeroplanes having a MTOW not exceeding 5700 kg Unfactored runway performance information is present in a majority of manufacturer's flight manuals and this will continue to be acceptable in Australia

AOC holders are required to make available to the pilot an operations manual which will contain any additional performance limitations

CASA does not believe directions need to be given to AOC holders to comply with what is mandatory For example to get the maximum takeoff weight allowable to comply with an operational CAO which requires that the take off distance required must be equal to the actual distance needed to take off multiplied by a factor the standard AFM data may be entered with an appropriate reduced distance equal to the declared distance for the runway divided by that factor

The AFM contains the certification data in the approved section Any additional approved data may be contained in the folder containing the AFM but this data is not part of the basic AFM Alternatively the information may be in other documents such as operations manuals

It is considered that establishing and maintaining a database of performance charts goes beyond the Authority's mandate

If the Authority should become aware of errors in any AFM information then an AD would be raised or a written direction under new subregulation 55 4 of CAR 1988 would be sent to affected CoR holders

Disposition CASA will proceed with the proposal as described in the NPRM

COMMENT 13 Door off supplements and other local operational supplements One commenter suggested that if CASA has approved certain door off supplements then these could continue to be supplied for those types and models

One commenter suggested that door off supplements could be approved on the basis of similarity to another type not models but for large doors or high speed aircraft an engineering and flight test assessment is necessary

One commenter asked where the door off supplement will be located One commenter asked who will issue door off supplements and what is the CASA approval route One commenter agreed with the proposal as described in the NPRM

CASA Response Any required door off AFM supplement or other local operational AFM supplement must 21
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be approved for the aircraft type and model This could be manufacturer's approved data approved STC or an AFM supplement approved by CASA or an authorised person after an engineering assessment by a CAR 35 authorised person together with flight tests if required

An engineering assessment is usually necessary and flight tests may also be required The CoR holder has the responsibility to ensure that any previously issued supplement is applicable to the manufacturer's or TC holder's AFM by the end of the twelve month transition period which the Authority has provided see Comment 23 For an aircraft without an AFM because one is not required supplements may be located in the aircraft in any convenient folder available to the pilot All supplements should be in the form as provided by the manufacturer or in the GAMA format be indexed and the amendment status noted

Disposition CASA will proceed with the proposal as described in the NPRM

COMMENT 14 Contents of AFM Several commenters claimed that the AFM was the best source of the consolidated data available to the operating crew

Several commenters claimed that the AFM was required by CASA for assessment of applications for an AOC assessment for issue of permits exemptions Minimum Equipment Lists and other approvals investigation of alleged breaches post crash investigations

Some commenters claimed that CASA offices should hold copies of the individual AFMs or at least copies of the manufacturer's FM as held in Central Office

One commenter claimed that reliance on the CoR holder to provide the AFM to CASA does not always work in practice Also that the AFM may be destroyed in a crash

Several commenters asked how a CoR holder or CASA would know if particular data e g a narrow runway supplement was approved

CASA Response As explained in Comment 7 the AFM is the required place to keep specified information not all of the information required to operate the aircraft However if an AFM was not required by the relevant NAA for a simple aircraft then it is not required

Any operator making any application to CASA must supply sufficient data to CASA to support the application as it is not part of CASA's regulatory role to obtain that data Nor is it CASA's responsibility to maintain copies of individual aircraft AFMs or copies of any manufacturer's AFM or POH at the local CASA offices for checking purposes The logistics and costs to CASA for obtaining storing and amending AFMs prohibit this

Investigations of alleged non compliances should be undertaken using the AFM as used by the operator Part of the investigation may be an audit on the AFM itself to confirm the 22
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issue status and applicability If the CoR holder cannot or will not supply the AFM then this is a non compliance in itself

Although CASA will not hold copies of individual AFMs the CASA Approval Page and Amendment Record Sheet from the front of the AFM as last advised to CASA will be on the CASA office aircraft file This will be available for post crash investigations to establish the content and status of the AFM

All approved AFM information is identified as approved by the relevant NAA or CASA CASA Inspectors and Engineers can determine the status of the AFM by reference to the listing of AFM status on the Public Folders or via the CASA website when available or by reference to Central Office

Disposition CASA will proceed with the proposal as described in the NPRM

COMMENT 15 Obtaining AFM information A number of commenters expressed concern as to where and how the required AFM information can be obtained and particularly as to what AFM information is required

CASA Response All manufacturers are required to supply an AFM or POH with each aircraft delivered if an AFM or POH is required to satisfy the applicable airworthiness certification standards of the relevant NAA or to ensure that the aircraft has the appropriate placards or other documents if an AFM or POH is not required

The manufacturer the TC holder or the distributor is the best source for AFM information required for a particular aircraft The holder of an STC is the source of any flight manual supplement required as the result of installation of an STC The TCDS in many cases states the AFM required by document number

Many CoR holders will already possess the AFM or POH issued with the aircraft when first delivered In most other cases a copy can be purchased from the manufacturer the TC holder or the distributor together with an update service

Disposition CASA will proceed with the proposal as described in the NPRM

COMMENT 16 Cases where the manufacturer or TC holder has ceased operation Several commenters queried what would be the procedure if an AFM was required by the applicable airworthiness standards but the manufacturer is no longer in operation or no longer supports the aircraft and the relevant NAA no longer supports or holds documentation for a particular aircraft type

CASA Response If an AFM is required a CoA cannot be issued until the aircraft has the appropriate AFM

It is the responsibility of the CoR holder to obtain an AFM applicable to that serial number aircraft or to prepare a suitable AFM which would need to be approved by a person holding an IoA under subregulation 55 4 of CAR 1988 23
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The relevant NAA may be able to provide a copy of the manufacturer's AFM The applicable design standard usually states the information required to be in the AFM The TCDS should provide the certification limitations

For old aircraft the CoR holder may be able to obtain a sample of an AFM from another owner museum etc

It is expected that some of these aircraft will need to be treated on a case by case basis

Disposition CASA will proceed with the proposal as described in the NPRM

COMMENT 17 Approval of the AFM Several commenters questioned how the adequacy of an AFM is determined

One commenter suggested that it is sufficient for the applicant to supply CASA with advice of the amendment status rather than a list of effective pages

Two commenters suggested that CASA provide a database of approved AFMs One commenter queried the procedures if the CoR holder changes indicating that the onus is still on the CoR holder to keep the AFM current

One commenter suggested CASA should review all AFM amendment and supplement data for adequacy even if this was subsequent to the CoR holder incorporating the change

CASA Response As part of the certification process for each aircraft type and model CASA will determine the adequacy of the AFM for the type prepared by the manufacturer or TC holder and approved by the relevant NAA CASA will then issue a CASA Approval Page listing the basic document identifier the aircraft type and model and the serial number applicability or LEP reference

The person issuing the CoA or conducting an audit is to verify that the CASA Approval Page and Amendment Record Sheet page correctly list the basic document identifier that the document is the current issue and that approved supplements or changes are listed to reflect the actual configuration of the aircraft It should be noted that in some cases an LEP is required to define the particular AFM

CASA agrees that in many cases the supply to CASA of advice as to the amendment status rather than an LEP is sufficient However for some aircraft an LEP is required to define the particular AFM

The proposal has been modified to require submission to the Authority of a copy of the CASA Approval Page and Amendment Record Sheet and the identifying details of any LEP that is required to define the AFM but not the LEP itself 24
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A change of CoR holder has no effect on the validity of the AFM the new CoR holder has the responsibility to keep the AFM current The new CoR holder must subscribe to any manufacturer's AFM or POH amendment service or be satisfied that any contracted agent who will maintain the AFM has access to the manufacturer's AFM or POH amendment service The status of the AFM will be checked by CASA during surveillance

The CASA database of AFM status will be placed on the CASA website when available to assist CASA and Industry

Amendments and supplements issued by manufacturers and TC holders and approved by the relevant NAA for aircraft that have been accepted in Australia are already approved AFM information There is no need for the Authority to approve data that is already approved

Disposition CASA will proceed with the proposal with the modification that the CoR holder is to supply the Authority with a copy of the CASA Approval Page and Amendment Record Sheet and the identifying details of any LEP but not the LEP itself required to define the particular AFM at CoA issue and whenever an amendment or change is made

COMMENT 18 Airspeeds IAS CAS Several commenters agreed that the proposal to accept IAS or CAS was acceptable but that the AFM placards and instrument markings should be consistent

CASA Response The airspeed datum s IAS CAS or both specified in the AFM or POH approved by the relevant NAA and produced by the manufacturer or TC holder need not be changed

The airspeed datum s used in placards and on instrument markings and their consistency one within the other may be independently subject to AD requirements

Disposition CASA will proceed with the proposal with the modification that airspeeds in the AFM may be IAS or CAS or both as approved by the relevant NAA and that airspeeds on placards and instrument markings are independently subject to maintenance system and AD requirements It will be the responsibility of the CoR holder operator or pilot to provide appropriate conversion data if necessary to ensure that the aircraft is operated without hazard

COMMENT 19 Units of Measurement Several commenters expressed views that various units were acceptable provided that flight manuals placards and instrument markings are consistent

Two commenters suggested dual Imperial Metric units could be provided One commenter suggested a placard should be placed next to the instrument if other than knots is used on the airspeed indicator

Other commenters expressed views that metric units should be used One commenter referred to ICAO Annex 5 requirements indicating that Australia should comply

CASA Response 25
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Australia has previously advised ICAO that ICAO Annex 5 is adopted without change The units of measurement advised to ICAO are as given in the NPRM CAAP 54 1 and AIP GEN 4 This proposal is primarily a change in the administration of the management of AFMs and is not intended to change the units of measurement for aviation

The preferred system of units for all measurements as given in the NPRM and AIP GEN 4 is recommended However CASA believes no safety problem would occur by permitting the units of measurement to remain unchanged in the AFM or POH produced by the manufacturer or TC holder and approved by the relevant NAA It will be the responsibility of the CoR holder operator or pilot to provide appropriate conversion data if necessary to ensure that communications with ATC are in the ICAO recommended units and that the aircraft is operated without hazard

The units of measurement used in placards and on instrument markings as well as their consistency are independently subject to maintenance system and AD requirements

Disposition The proposal has been modified in that whilst the preferred units of measurement are as given in the NPRM CAAP 54 1 and AIP GEN 4 the units of measurement contained in the AFM produced by the manufacturer or TC holder may remain unchanged It will be the responsibility of the CoR holder operator or pilot to provide appropriate conversion data if necessary The units of measurement used in placards and on instrument markings are independently subject to maintenance system and AD requirements

COMMENT 20 Radio System Operating Limitation pages Several commenters stated that they believed the RSOL pages were useful in that they enabled the pilot to know which equipment s were approved for IFR

Several commenters specifically agreed that RSOL pages were unnecessary CASA Response The category of operation is stated on placards and or in the AFM

CAO 20.18 states that aircraft with a MTOW greater than 5700 kg operated for the purpose of RPT or charter are required to be in the IFR category and hence RSOL pages are unnecessary for these aircraft

RSOL pages are a unique Australian requirement and thus do not represent harmonisation especially considering their limited usefulness

The aircraft logbook is the appropriate place to list the equipment fitted It is recognised that the logbook is not normally available to the pilot however it is the responsibility of the CoR holder to ensure that the appropriate equipment is fitted for the category of operation

The IFR status of the aircraft is indicated on the Maintenance Release which is available to the pilot

RSOL pages have often been used in the past as a configuration control document but this is not their function

Disposition The proposal to delete the requirement for RSOL pages will proceed 26
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COMMENT 21 Costs One commenter queried the expected resource savings for the Authority

One commenter queried the costs to the Small Supplementary Airlines or similar to establish and maintain a flight manual section

CASA Response There will be CASA administrative resource savings in the revised procedures for the Authority at both Central Office and Local CASA Office levels

There is no intention to increase the administration costs related to AFMs for an airline The airlines including low capacity airlines currently have to incorporate amendments and supplements The only change is that CASA will not be directing the changes

Disposition CASA will proceed with the proposal as described in the NPRM

COMMENT 22 Carriage of the AFM Three commenters objected to the proposal and suggested that if an AFM is required it should be carried one referring to FAR 91.9 Also commenters questioned who would verify that the operations manual or other documents actually do contain the information available in the AFM

CASA Response Aircraft operated under an AOC are required to have an operations manual If the appropriate section of the operations manual contains the information available in the AFM and this does not conflict with the AFM then that section of the operations manual may be carried in lieu of the AFM The AFM is required to be maintained as a reference document

The only change from the present system is administrative simplification in that an exemption under old regulation 139 of CAR 1988 need not be applied for if the operations manual has been assessed by CASA as satisfactory

All other aircraft are required to carry the AFM if an AFM is required

Disposition CASA will proceed with the proposal as described in the NPRM

COMMENT 23 Transition Arrangements A number of commenters requested more information on the transition arrangements where by it was proposed to cancel manuals produced by CASA or predecessor where none was required in the country of certification

One commenter suggested that the situation in which an AFM for aircraft below 2722 kg 6000 lb manufactured and first flown before 1 March 1979 is not required applies to USA manufactured aircraft only

One commenter suggested that cancellation of the CASA produced manuals for this class of aircraft should only be with the agreement of the CoR holder Also that if the manual is to be cancelled the Authority should write to the CoR holder and advise how the CoR holder can find 27
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out what he she is supposed to have One commenter suggested that CoR holders should have access to the master FMs held in Central Office

One commenter disagreed with the proposal claiming that the design standard for these old imported light aircraft was CAO 101.22 and similar CAO 101.22 specified that an AFM was required

CASA Response CASA has further considered the transition arrangements since the NPRM was published with a view to harmonisation and simplification In particular this has covered the difficulty for CoR holders in making changes to unique Australian AFMs rather than directly incorporating approved changes into the manufacturer's or TC holder's AFM and ensuring that there is nothing contained in the unique Australian AFM that conflicts with the manufacturer's or TC holder's information It is also considered that effective surveillance of unique Australian AFMs would be very difficult Further a proliferation of different manuals or in some cases no AFM at all in the same type of aircraft would lead to confusion The Authority seeks simplicity and uniformity

CASA will provide a period of grace in that all manuals approved under the old regulation 138 of CAR 1988 may remain in force for a period of up to twelve months from the commencement of the regulations The changeover will be required earlier if an amendment or change is made to the AFM The CoR holder will be responsible for ensuring that the appropriate manufacturer's or TC holder's AFM is available in the aircraft

The AFM must also be the current issue and reflect the configuration of the aircraft by having all required AFM supplements for all the STCs and modifications installed

Where an AFM or POH is not required by the relevant NAA there would be no financial penalty on the CoR holder as the CoR holder does not have to obtain a manufacturer's AFM or POH if it is not required If an AFM or POH is required then the CoR holder may already have the AFM or POH supplied with the aircraft or will have to purchase a replacement copy But as pointed out in the NPRM this is not a significant cost The advantages of reverting to the standard manufacturer's or TC holder's manuals will greatly benefit industry and the Authority

CoR holders may find the superseded document a useful reference but it will no longer be approved or controlled by the Authority and the aircraft must be operated in accordance with the required AFM POH and or placards

Specific answers to respondents FAR 21.5 applies to all aircraft registered in the USA regardless of where they were manufactured Refer also to comment 36

Aircraft manufactured outside the USA and imported to Australia will be required to have the AFM required by the airworthiness certification standards of the relevant NAA and that may be that an AFM or POH is not required

The new legislation supersedes the requirement under the old CAOs to provide an AFM even where no AFM or POH was required under the airworthiness certification standards of the relevant NAA 28
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Disposition The proposal is modified in that within twelve months of the commencement of the regulations or earlier if an amendment or change is required to the AFM the CoR holder will be responsible for ensuring that the AFM meets the requirements of the new regulations

COMMENT 24 AFM requirements for Experimental Limited and Historic and Exmilitary category aircraft One commenter enquired as to the requirements for these aircraft

CASA Response As stated in the NPRM whether an AFM or POH is required or placards are adequate will be determined by what was required by the certificating authority when the aircraft was first flown

Most of the above types of aircraft are not certificated to any civil design standard and hence no AFM would be required

However these aircraft are expected to have sufficient information in the form of pilots notes military manuals placards etc to operate the aircraft safely but this information will not be approved or controlled under the flight manual CARs

Disposition CASA will proceed with the proposal as described in the NPRM

COMMENT 25 Airworthiness Directives Two commenters asked how CASA would mandate required amendments to AFMs

One commenter asked how CASA would know what the text or direction is going to be without reference to a flight manual or the unknown document placard

CASA Response It is the responsibility of the CoR holder to have access to the manufacturer's data for AFM amendments and incorporate amendments if applicable to the particular aircraft

If the Authority should require a limitation or flight manual change to be imposed because of an unsafe condition this will normally be by AD action requiring the CoR holder to incorporate an amendment In some cases a direction under new subregulation 55 4 of CAR 1988 may be given to the CoR holder The amendment itself may be available from the manufacturer or in some cases may be achieved by inserting a copy of an AD in the AFM

Disposition CASA will proceed with the proposal as described in the NPRM

COMMENT 26 Approval of Australian flight manual amendments and supplements by CAR 35 authorised persons A significant number of commenters objected to this proposal on the grounds that the FAA and other NAAs do not delegate this function

Two commenters suggested the proposal was satisfactory subject to the condition that the 29
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delegation is only given to experienced persons who have been trained by CASA CASA Response The FAA permits certain DERs to approve minor AFM amendments FAA Order 8110.37B refers related to transport category aircraft However the FAA does not permit DERs to approve AFMs AFM amendments or AFM supplements for FAR 23 class aircraft

The FAA permits holders of a Delegated Option Authority to approve AFMs and AFM amendments Part 21 of CAR 1998 makes provision for a similar delegated option in Australia However no Australian organisation has yet been granted this authorisation Also the FAA permits certain Delegated Alteration Stations to approve AFM amendments and AFM supplements usually related to installation of their proprietary avionics equipment There is no equivalent in Australia

Although direct correlation does not exist with the FAA CASA believes that suitable persons could be delegated the authority

In consideration of the comments and the FAA situation the proposal is amended in that legislative provision is made that CASA or an authorised person may approve Australian AFM amendments and supplements under subregulation 55 4 of CAR 1988 An applicant may apply to CASA for this delegation and will be assessed as to the competency and experience to hold an IoA

Disposition The proposal is amended such that a person holding an IoA under subregulation 55 4 of CAR 1988 may approve certain AFM information changes if the person has been assessed by CASA as suitably qualified and experienced

COMMENT 27 Exported Aircraft Several commenters expressed concern as to the acceptability of Australian aircraft to overseas NAAs if AFM information has been approved by CAR 35 authorised persons

CASA Response As explained in Comment 26 the proposal has been amended in line with comments received CASA or an authorised person may approve AFM amendment or supplement information Modifications approved under CAR 35 may be subject to review by overseas NAAs The associated AFM changes are part of the data package and as such may be subject to a similar review

As it is proposed that all previously imported aircraft will have the manufacturer's AFM rather than a unique Australian AFM and all Australian manufactured aircraft will have a CASA approved AFM developed as part of the certification the export situation will be improved

Disposition CASA will proceed with the proposal as described in the NPRM

COMMENT 28 Australian manufactured aircraft One commenter felt that the NPRM does not specify which rules will apply for Australian manufactured aircraft after the proposed changes are implemented 30
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CASA Response Generally an AFM in the GAMA format is required for Australian manufactured aircraft If the design standard specifies that an AFM must be provided then the generic AFM prepared by the manufacturer will be assessed and approved by the Authority The manufacturer must supply an AFM with each aircraft delivered

The same procedures for issue of a CoA apply to all aircraft both locally manufactured and imported

Aircraft certification requirements including the AFM requirements are now contained in CAR 1998 Parts 21 35

Disposition CASA will proceed with the proposal as described in the NPRM

COMMENT 29 Access to master AFMs held at Central Office Two commenters asked about access to the copies of the master AFMs held in Central Office

CASA Response CASA stores and maintains only one master copy of the manufacturer's or TC holder's generic AFM or POH This is a CASA reference document and not for loan

CASA staff may view the master copies of the AFMs in Airworthiness Information Section as required or request portions to be photocopied and or faxed to them

Industry persons should deal directly with the manufacturer the TC holder or the distributor

The proposed CASA website database of AFM status is another means by which industry persons will be able to determine the appropriate document for their aircraft

Disposition CASA will proceed with the proposal as described in the NPRM

COMMENT 30 Publication of lists of AFM requirements One commenter suggested that CASA should publish a list of aircraft which do not require an AFM and lists of manufacturer contact details

CASA Response The Flight Manual Status List currently on the CASA internal computing network is proposed to be converted to a database of AFM status and put on the CASA website This database will contain the document identifier for the AFM for each type and model of aircraft that has been assessed by the Authority and which requires an AFM 31
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It is intended that another list be produced progressively to contain entries for those aircraft that do not require an AFM If a particular type and model is not listed in the AFM status database the CoR holder must not assume that an AFM is not needed but must make his her own enquiries Refer to Comment 15

The CoR holder or nominated representative can obtain the AFM or POH requirements from the manufacturer the TC holder or the distributor or in some cases from the TCDS

CASA does not have the resources nor the mandate to publish and maintain a list of manufacturer contact details which are available from commercial industry references

Disposition CASA will proceed with the proposal as described in the NPRM

COMMENT 31 AFM status checks One commenter suggested there should be a mandatory check of AFM status when the CoR holder changes

One commenter suggested that AFMs should be subject to a periodic inspection in the same way that other vital aircraft equipment is periodically inspected

CASA Response The validity of the AFM is unaffected when the CoR holder changes Whilst the suggestions have merit they do not reflect accepted international practice CASA accepts that normal surveillance will be sufficient

It is good aeronautical practice to maintain the amendment status and physical condition of the AFM

Disposition CASA will proceed with the proposal as described in the NPRM

COMMENT 32 Flight manual shape and format One commenter suggested flight manuals could be improved in shape and format to make them more user friendly

CASA Response While this point is desirable by following the harmonised approach the Authority cannot insist on different shapes or formats to that approved by the relevant NAA

For light aircraft manufactured in Australia the flight manual requirements were contained in CAO 101.22 the new requirements are in the design standards referenced in CAR 1998 Parts 21 35 For light aircraft the GAMA format is generally required

Disposition CASA will not specify shape or format of AFMs different to that approved by the relevant NAA 32
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COMMENT 33 Changes to pilot syllabi One commenter suggested that changes will be required to the Private Pilot Licence and Commercial Pilot License aeroplane syllabi as these use the uniquely Australian P charts

CASA Response Changes may be necessary

Disposition This matter has been referred to the Authority's Flight Crew Licensing Branch

COMMENT 34 Commercial operations to require an AFM One commenter recommended that the regulations be amended to require any commercial operation to have an operations manual

CASA Response This is the current requirement regulation 215 of CAR 1988 There is no requirement to carry the operations manual in the aircraft old regulation 139 of CAR 1988 However some operators do carry the operations manual in lieu of the AFM Comment 22 refers

Disposition CASA will proceed with the proposal as described in the NPRM

COMMENT 35 Australian safety rules One commenter stated that Australian safety rules should overrule any company rules This would include minimum performance requirements per aircraft type CASA would prescribe vice the previous tedious process of approvals exemptions and the like

CASA Response Australian regulations always take precedence over company rules A CoR holder may apply for an exemption or variation against certain legislative requirements which may be granted or approved if adequate justification is presented

The basic performance requirements of an aircraft are contained in the applicable airworthiness standards It is not required to incorporate factoring of the manufacturer's approved take off and landing performance data in the AFM

However as indicated in the Authority's response to Comment 12 operators should be aware that operational requirements do in some instances require extra or factored information As previously stated this may be located in a suitable folder available to the pilot which may be the folder containing the AFM

Disposition CASA will proceed with the proposal as described in the NPRM

COMMENT 36 Miscellaneous Issues Two commenters suggested fuel tank capacity should be in the AFM One commenter suggested the aircraft footprint should be in the AFM 33
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One commenter queried the limitation cut off of 2722kg 6000 lb and 1 March 1979 for aircraft to not require an AFM One commenter questioned the commonality and accuracy of the actions of CoR holders

One commenter asked what other options were considered One commenter stated that clarifications as to the applicable airworthiness standards as mentioned throughout the NPRM would have been helpful

CASA Response For practically all aircraft the airworthiness standards of the relevant NAA which aplied when it was first manufactured and flown required that information and instructions concerning airworthiness limitations together with any other information and instructions necessary for its safe operation be provided to the pilot This can be found in design codes such as CAR 3 FAR 23 etc and certification requirements such as FAR 21.5 and regulation 21.5 of CAR 1998

When the manufacturer or TC holder has supplied that information required to be provided to the pilot in a manual that is clearly identified as an AFM then that AFM will obviously become the AFM approved by the Authority for the particular aircraft type and model concerned

When the manufacturer or TC holder has supplied that information in a POH that is clearly identified as containing such information required to be provided to the pilot then that POH will become the AFM approved by the Authority for the particular aircraft type and model concerned Examples of such POHs are those produced in the GAMA format after 1975

To clarify the time cut off after which all aircraft manufactured and flown for the first time must have an AFM the text from FAR 21.5 is as follows

With each aeroplane or rotorcraft that was not type certificated with an aeroplane or rotorcraft flight manual and that has had no flight time prior to 1 March 1979 either the holder of a type certificate or a supplemental type certificate or the licensee of a type certificate must give the owner when the owner takes delivery of the aeroplane or rotorcraft from the holder or licensee a current aeroplane or rotorcraft flight manual that is approved under these regulations

In summary Under FAR 21.5 or regulation 21.5 of CAR 1998 all type certificated aircraft manufactured and first flown after 1 March 1979 must have an AFM

Many aircraft manufactured and first flown prior to 1 March 1979 do not require an AFM whether they were manufactured in the USA or not As stated in Comment 23 aircraft manufactured outside the USA and imported to Australia will be required to have the AFM required by the airworthiness certification standards of the country of certification which may mean that an AFM is not required The 6000 lb cut off is contained in CAR 3 and early versions of FAR 23 34
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Some aircraft below 6000 lb which were provided by the manufacturer or TC holder with a GAMA format POH before 1 March 1979 will have that POH as the CASA approved AFM and FAR 21.5 and regulation 21.5 of CAR 1998 apply to all aircraft that have had no flight time prior to 1 March 1979

The commonality of the actions of CoR holders should be acceptable in that all AFMs must have the CASA Approval Page specifying the basic document to be used and then on the Amendment Record Sheet to list the changes to that AFM due to particular amendments and the incorporation of AFM supplements for that aircraft

As explained in the Options Considered section of the NPRM the options available were limited probably only to retaining the present system or adopting the harmonised approach outlined in the NPRM Any combination of these would result in unique Australian requirements which could not be justified

Disposition CASA will proceed with the proposal as described in the NPRM with the modification that for some aircraft if the manufacturer or TC holder has provided a document that is clearly identified as containing information required to be provided to the pilot under the airworthiness standards of the relevant NAA then that document such as a GAMA format POH will become the CASA approved AFM for that aircraft 35
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ANNEX A Final Draft Amendments to Civil Aviation Regulations 1988 37
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Civil Aviation Amendment Regulations 1999 No

Statutory Rules 1999 No

1 WILLIAM PATRICK DEANE Govemor General of the Commonwealth of Australia acting with the advice of the Federal Executive Council make the following regulations under the Civil Aviation Act 1988

Dated 1999

Governor General By His Excellency's Command

JOHN ANDERSON Minister for Transport and Regional Services

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Civil Aviation Amendment Regulations 1999 No

Statutory Rules 1999 No 2 made under the Civil Aviation Act 1988

Contents Page 1 Name of regulations 2 2 Commencement 2 3 Amendment of Civil Aviation Regulations 1988 2

Schedule 1 Amendments 3

1999 Civil Aviation Amendment Regulations 1999 No 1

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Regulation 2 1 Name of regulations These regulations are the Civil Aviation Amendment Regulations 1999 No

2 Commencement These regulations commence on gazettal

3 Amendment of Civil Aviation Regulations 1988 Schedule 1 amends the Civil Aviation Regulations 1988

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Amendments Schedule 1 Schedule 1 Amendments regulation 3

1 Subregulation 2 1 definition of flight manual substitute flight manual has the meaning given by regulation 54

2 Subregulation 2 1 insert

relevant airworthiness standards means a for an aircraft that conforms to a type certificate issued or taken to have been issued under regulation 21.13A or 21.29 of CAR 1998 the airworthiness standards included in the type certification basis for the aircraft or

b for an aircraft for which a type acceptance certificate has been issued or is taken to have been issued under regulation 21.29A of CAR 1998 the airworthiness standards that the aircraft had to meet for the issue of the foreign type certificate that was the basis for issuing the type acceptance certificate

Note For type certification basis and foreign type certificate see the Dictionary at the end of CAR 1998

relevant NAA for an aircraft manufactured in a foreign country means the NAA of the country whose airworthiness standards make up the relevant airworthiness standards for the aircraft

Note For NAA see the Dictionary at the end of CAR 1998

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Amendments Schedule 1 3 After Part IVB insert

Part 4C Flight manuals 54 Meaning of flight manual 1 The flight manual for an aircraft is a if a flight manual for the aircraft was given to the aircraft owner under regulation 21.5 of CAR 1998 that flight manual or

b in any other case any manual or other document not being a placard that must under the relevant airworthiness standards for the aircraft be provided with the aircraft and contain the following information and instructions about the aircraft

i the limitations within which under the relevant airworthiness standards it is considered airworthy

ii any other information and any instructions necessary for its safe operation

2 However if a change has been made to the flight manual under regulation 55 a reference in a provision other than this regulation to the flight manual is a reference to the flight manual as changed

55 Changes to flight manuals for Australian aircraft 1 This regulation applies to the holder of the certificate of registration for an Australian aircraft for which a flight manual has been issued if

a the aircraft's manufacturer or the holder of the type certificate to which the aircraft conforms gives an instruction to the effect that a change must be made to the manual and

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Amendments Schedule 1 b the change is approved by CASA or the relevant NAA for the aircraft Note For relevant NAA see subregulation 2 1

2 This regulation also applies to the holder of the certificate of registration for an Australian aircraft for which a flight manual has been issued if

a a modification that conforms to a supplemental type certificate applying to the aircraft or an aircraft component fitted to the aircraft is carried out on the aircraft or aircraft component and

b the holder of the supplemental type certificate gives an instruction to the effect that a change must be made to the manual because of the modification and

c the change is approved by CASA or the NAA that issued the supplemental type certificate

Note For NAA see the Dictionary at the end of CAR 1998

3 This regulation also applies to the holder of the certificate of registration for an Australian aircraft for which a flight manual has been issued if

a a modification that does not conform to a supplemental type certificate is carried out on the aircraft or an aircraft component fitted to the aircraft and

b CASA or an authorised person has approved the design of the modification under regulation 35 and

c CASA or the authorised person gives an instruction in writing to the effect that a change must be made to the manual because of the modification

4 This regulation also applies to the holder of the certificate of registration for an Australian aircraft for which a flight manual has been issued if CASA or an authorised person instructs the certificate holder in writing for the purpose of ensuring the safety of air navigation to make a change to the manual

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Amendments Schedule 1 5 The holder of the certificate of registration for the aircraft must make the change to the aircraft's flight manual

a if the instruction indicates the period within which the change must be made within that period or

b in any other case before the aircraft is flown for the first time after the certificate holder is told of the instruction

Penalty 50 penalty units 6 If the certificate holder makes a change to the aircraft's flight manual under subregulation 5 the holder must tell CASA in an approved form about the details of the change within 48 hours after the aircraft is flown for the first time after the change is made

Penalty 20 penalty units

4 Regulation 138 substitute

138 Pilot to comply with requirements etc of aircraft's flight manual etc

1 If a flight manual has been issued for an Australian aircraft the pilot in command of the aircraft must comply with a requirement instruction procedure or limitation concerning the operation of the aircraft that is set out in the manual

Penalty 50 penalty units

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Amendments Schedule 1 2 If a flight manual has not been issued for an Australian aircraft and under the relevant airworthiness standards for the aircraft the information and instructions that would otherwise be contained in an aircraft's flight manual are to be displayed either wholly on a placard or partly on a placard and partly in another document the pilot in command of the aircraft must comply with a requirement instruction procedure or limitation concerning the operation of the aircraft that is set out

a on the placard or b on the placard or in the other document Penalty 50 penalty units

5 Subregulation 139 3 substitute

3 An aircraft that is operated under an AOC need not carry its flight manual when flying if it carries on board an operations manual that

a contains the information and instructions that are required under the relevant airworthiness standards for the aircraft to be included in the flight manual and

b does not contain anything that conflicts with the information or instructions

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Amendments Schedule 1 6 After regulation 321 insert

322 Transitional changes to flight manuals for Australian aircraft 1 Subregulations 4 and 5 apply to the holder of the certificate of registration for an Australian aircraft for which a flight manual has been issued if

a the aircraft's manufacturer or the holder of the type certificate to which the aircraft conforms gave an instruction before the commencement of this regulation to the effect that a change must be made to the manual and

b the change has been approved by CASA or the relevant NAA for the aircraft

Note For relevant NAA see subregulation 2 1 2 Subregulations 4 and 5 also apply to the holder of the certificate of registration for an Australian aircraft for which a flight manual has been issued if

a a modification that conforms to a supplemental type certificate applying to the aircraft or an aircraft component fitted to the aircraft was carried out before the commencement of this regulation on the aircraft or aircraft component and

b the holder of the supplemental type certificate gave an instruction before the commencement of this regulation to the effect that a change must be made to the manual because of the modification and

c the change has been approved by CASA or the NAA that issued the supplemental type certificate

Note For NAA see the Dictionary at the end of CAR 1998

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Amendments Schedule 1 3 Subregulations 4 and 5 also apply to the holder of the certificate of registration for an Australian aircraft for which a flight manual has been issued if

a a modification that does not conform to a supplemental type certificate was carried out before the commencement of this regulation on the aircraft or an aircraft component fitted to the aircraft and

b CASA or an authorised person approved the design of the modification under regulation 35 and

c CASA or the authorised person gave an instruction in writing before the commencement of this regulation to the effect that a change must be made to the manual because of the modification

4 The certificate holder must make the change to the aircraft's flight manual a before the end of the period of 1 year beginning on the commencement of this regulation or

b if another change to the aircraft's flight manual is required under regulation 55 and the other change is made before the end of the period mentioned in paragraph a before the other change is made

Penalty 50 penalty units

5 If the certificate holder makes a change to the aircraft's flight manual under subregulation 4 the holder must tell CASA in an approved form about the details of the change within 48 hours after the aircraft is flown for the first time after the change is made

Penalty 20 penalty units

323 Transitional documents to be carried in Australian aircraft 1 This regulation applies to an Australian aircraft if a change or changes to its flight manual are required under regulation 322

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Amendments Schedule 1 2 Despite subregulation 139 1 during the transition period the aircraft is not required to carry its flight manual when flying if it carries on board the manual that was the aircraft's flight manual immediately before the commencement of this regulation

Note An aircraft's flight manual immediately before the commencement of this subregulation was the manual in force for the aircraft under regulation 138 as that regulation was in force immediately before that commencement

3 In subregulation 2 transition period means a if the change or changes to the aircraft's flight manual are made before the last day of the period within which the change or changes must be made the period beginning on the commencement of this regulation and ending at the end of the day on which the change is made or

b if paragraph a does not apply the period within which the change or changes must be made under subregulation 322 4

Notes 1 These regulations amend Statutory Rules 1988 No 158 as amended by 1988 Nos 209 373 and 376 1989 Nos 31 and 276 1990 Nos 100 215 216 258 260 289 310 331 332 and 466 Act No 25 1990 Statutory Rules 1991 Nos 54 147 157 247 287 382 409 410 426 and 487 as amended by 1992 No 174 1992 Nos 36 174 254 258 279 325 342 380 417 and 418 1993 Nos 221 268 319 new regulation 239 contained in regulation 16 was disallowed by the Senate on 23 March 1994 and 368 1994 Nos 93 173 187 188 260 294 382 and 396 1995 Nos 122 147 148 and 224 1996 No 88 1997 Nos 23 67 Ill 139 and 220 1998 Nos 31 32 219 234 disallowed by the Senate on 8 March 1999 235 236 and 288

2 Made by the Governor General on 1999 and notified in the Commonwealth of Australia Gazette on 1999

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Summary of Responses NPRM 9801AW Flight Manual Management Page B1 ANNEX B Final Draft Civil Aviation Advisory Publication CAAP No 54 1 0 Flight Manuals for Individual Aircraft 53
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Summary of Responses NPRM 9801AW Flight Manual Management Page B2 INTENTIONALLY LEFT BLANK 54
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Draft Copy 18 5 99 CAAP 54 1 0 Flight manuals for individual aircraft The relevant regulations and other references Regulations 54 55 138 and 139 of the Civil Aviation Regulations 1988 CAR 1988

Who this CAAP applies to Holders of the Certificate of Registration CoR for an Australian aircraft

Industry persons who are authorised to issue Certificates of Airworthiness CoAs

Industry persons who are authorised to approve flight manual information

Why this CAAP was written CASA has issued revised new legislation for ensuring that the information required for the safe operation of the aircraft is provided in the aircraft to the operating crew

This CAAP was written to assist industry to understand the new rules governing the required flight manuals placards or other documents Also this CAAP provides guidance on the information required and the sources of that information

Status of this CAAP This is the initial issue of this CAAP and is the first on the subject of aircraft flight manuals

For further information Contact the CASA Office closest to you

Civil Aviation Advisory Publication May 1999

This publication is only advisory but it gives the CASA preferred method for complying with the Civil Aviation Regulations 1988 CAR 1988

It is not the only method but experience has shown that if you follow this method you will comply with CAR 1988

Always read this advice in conjunction with the appropriate regulations

Contents Background 2 Process 4 Transition arrangements 7

Detail information 8 55
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2 CAAP 54 1 0 Flight manuals for individual aircraft Draft Copy 18 5 99 INTRODUCTION A new type and model of aircraft is type certificated by a National Airworthiness Authority NAA before production The NAA responsible for a type certification accepted by CASA is termed the relevant NAA

Formerly an individual CASA approved Aircraft Flight Manual AFM was required for all aircraft registered in Australia even if the relevant NAA did not require an AFM Specific Australian requirements often caused alterations to be made to the AFM supplied by the manufacturer or Type Certificate TC holder

CASA has consulted with industry and simplified procedures for managing AFMs and related information The new procedures are harmonised with international practice as far as practicable

WHAT IS CASA'S POLICY IN RELATION TO FLIGHT MANUALS All aircraft must have the information necessary for the safe operation of the aircraft as specified in the applicable design standard located in the aircraft and available to the pilot

The required information may be in the form of an AFM placards or in other approved documents such as a Pilot's Operating Handbook POH The form and content of the information is that accepted and approved by the relevant NAA for the particular serial number aircraft when it was manufactured and delivered

When the manufacturer or TC holder has supplied an AFM that is clearly identified as an AFM approved by the relevant NAA then

that AFM will obviously become the CASA approved AFM for the particular aircraft type and model concerned

Some aircraft were not required to be provided with an AFM as long as the required information was provided in the form of placards or other documents Examples of these are the DC 3 and many aircraft with a maximum take off weight MTOW of 2722 kg 6000 lb or less manufactured in the USA and first flown before 1 March 1979 In some of these cases a POH or other operating document was provided by the manufacturer or TC holder

When the manufacturer or TC holder has supplied a POH that is clearly identified as containing information required by the relevant

NAA to be provided to the pilot that POH will become the CASA approved AFM for that particular aircraft type and model Examples of such POHs are those produced after 1975 in the General Aviation Manufacturer's Association GAMA format

Background 56
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3 CAAP 54 1 0 Flight manuals for individual aircraft Draft Copy 18 5 99 Aircraft which have not been type certificated to a civil design standard such as some ex military some sport aircraft etc do not require an AFM but information should be provided to the pilot

The CoR holder has the responsibility to ensure that the aircraft has the appropriate CASA approved AFM if required that all approved AFM amendments are incorporated to keep the information current and that all AFM supplements necessary for operating the aircraft in its actual configuration are incorporated

The CoR holder may nominate another person or organisation by letter of appointment to maintain the AFM as is often done with the maintenance of the aircraft itself

Note For some aircraft in Australia of the same type and model the type certification accepted may be different for specific aircraft thus requiring different AFMs eg a Brazilian aircraft with both Brazilian and US FAA certification Refer to the manufacturer or agent or CASA if in doubt

HOW DOES CASA ADMINISTER THE NEW RULES A summary of the new administration of individual aircraft flight manuals is

If an example is on the Australian Register of a type and model of aircraft required to be provided with an AFM or POH under the applicable airworthiness standards of the relevant NAA CASA will hold a master copy of that AFM or POH applicable to the serial number range concerned This copy is provided by the manufacturer or TC holder and is kept up to date by CASA for reference purposes

CASA will issue and provide a copy of the CASA Approval Page to the CoR holder upon request The CASA Approval Page identifies the document that is approved as the AFM This page is to be inserted at the front of the folder containing the manufacturer's or TC holder's AFM

The CoR holder is to complete and insert an Amendment Record Sheet in the front of the AFM folder as well This page lists the basic approved document identifier and all amendments and supplements that make up the AFM for the individual aircraft CASA has an Amendment Record Sheet form available or the CoR holder may use another that provides for similar information

When applying for a Certificate of Airworthiness CoA a CoR holder is to present the AFM or POH to an industry person holding an Instrument of Appointment IoA to issue CoAs or if CASA is requested to issue the CoA to CASA 57
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4 CAAP 54 1 0 Flight manuals for individual aircraft Draft Copy 18 5 99 This person or CASA will verify that the document is the appropriate AFM or POH for the aircraft is the current issue and contains all amendments and supplements to reflect the actual configuration of the aircraft

Note The ICAO definition of an AFM is A manual associated with the CoA containing limitations within which the aircraft is to be considered airworthy and instructions and information necessary to the flight crew members for the safe operations of the aircraft

WHAT IS THE PROCESS FOR A COR HOLDER TO FOLLOW Prior to application for issue of a CoA a CoR holder or nominated representative must

Determine in what form the required AFM information is to be presented Refer to How do I find out what AFM or placards my aircraft should have on page 8

If an AFM or POH is required the applicant should obtain the document issued by the manufacturer or TC holder in accordance with the airworthiness standards of the relevant NAA applicable to the aircraft

Ensure that the document is current and contains all the latest approved amendments as well as all supplements needed to reflect the actual configuration of the aircraft

Obtain a copy of the CASA Approval Page for the aircraft type from CASA and insert this at the front of the folder containing the document

Obtain a blank of the Amendment Record Sheet from CASA or obtain another form prompting for similar information and fill it out with the appropriate information and insert this in the front of the folder containing the document also If a Log or List of Effective Pages LEP is required to define the AFM or POH then identifying details of the LEP are to be entered on the Amendment Record Sheet

Present the AFM or POH as part of the requirement for issue of a CoA

Provide a copy of the CASA Approval Page and the Amendment Record Sheet to the local CASA Office to be placed on the aircraft file

The AFM for the particular aircraft is retained by the CoR holder CASA does not hold a copy of the AFM for each aircraft only the master copy of the AFM or POH for the type and model of that aircraft applicable to the serial number range concerned

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5 CAAP 54 1 0 Flight manuals for individual aircraft Draft Copy 18 5 99 WHAT IF AN AFM IS NOT REQUIRED The CoR holder must ensure that if the AFM information required to be provided for the pilot is in the form of placards that those placards are installed in the aircraft All placards affixed to the aircraft are independently subject to maintenance system and Airworthiness Directive AD requirements

The person issuing the CoA is to verify that the placards are in place and are the appropriate ones

Aircraft for which an AFM is not required may be eligible for operations with door off Mogas glider towing etc and these operations are subject to AFM information contained in supplements These supplements may be kept in any convenient folder available to the pilot and should be listed with their current amendment status on an Amendment Record Sheet in the front of the folder A copy of that Amendment Record Sheet is to be provided to the local CASA Office for file

WHOSE RESPONSIBILITY IS IT TO KEEP THE AFM OR PLACARDS UP TO DATE

It is the responsibility of the CoR holder to ensure that any required AFM amendments and AFM supplements are incorporated The CoR holder or the nominated representative may make alterations to the AFM to incorporate approved amendments or insert or remove approved supplements as appropriate

Alterations to the AFM may be required because of e g manufacturer's general or particular amendment installation or removal of a modification or a modification that is subject to a Supplemental Type Certificate STC

an Airworthiness Directive AD or a CASA direction under subregulation 55 4 of CAR 1988

Most aircraft manufacturers provide an update service for each AFM or POH Some manufacturers update services are free to registered owners Other manufacturers may charge an annual subscription fee Changes approved by the relevant NAA or CASA must be incorporated

AFM supplements or revised placards required when installing manufacturer's or third party modifications or STCs are the responsibility of the person providing the design and are usually supplied with the installation kit 59
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6 CAAP 54 1 0 Flight manuals for individual aircraft Draft Copy 18 5 99 CASA will audit AFMs or placards containing the required AFM information for currency and applicability to the particular aircraft configuration and modification status This will be done during surveillance and ramp checks

DO I HAVE TO NOTIFY CASA OF CHANGES TO MY AFM Yes The local CASA Office will keep a record of the CASA Approval Page and Amendment Record Sheet which gives the composition and status of the AFM on the individual aircraft file

If any approved changes or amendments are made or approved supplements added or deleted the CoR holder or representative must supply a copy of the updated Amendment Record Sheet to the local CASA Office within 48 hours after the aircraft is flown for the first time after the change is made to the AFM No further CASA approval is required but the aircraft file will be amended accordingly

HOW DO I KNOW IF AFM AMENDMENTS OR SUPPLEMENTS ARE APPROVED DATA FOR INSERTION IN THE AFM

AFM amendments and supplements issued by the aircraft manufacturer or TC holder and approved by the relevant NAA are approved data for insertion in AFMs when applicable to the particular aircraft

AFM supplements associated with STCs approved by the relevant NAA are approved AFM data if applicable to the particular aircraft

For an STC issued by an NAA different to the relevant NAA refer to CASA as that STC may not be applicable to the aircraft

An AFM supplement approved by CASA or an authorised person that is associated with an approved modification is approved AFM data if applicable to the particular aircraft

For Australian ADs that require a copy of the AD foreign AD or other specified document to be inserted in the AFM as an amendment those specified insertions are approved AFM data

CASA issued directions under subregulation 55 4 of CAR 1988 are approved data regarding the AFM

In all other cases refer to your local CASA Office 60
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7 CAAP 54 1 0 Flight manuals for individual aircraft Draft Copy 18 5 99 WHAT IF I ALREADY HAVE AN AFM APPROVED UNDER THE OLD CAR 138

The new regulations will take effect on the day the notice of the making of the regulations is published in the Commonwealth of Australia Gazette From this date applicants seeking issue of a CoA must comply with the new regulations However CASA has provided a twelve month transition period for aircraft that currently have an AFM approved under the old CAR 138

CoR holders are to ensure they have or obtain for each aircraft the AFM or POH that meets the new regulations as soon as practicable The old CAR 138 AFMs may remain in effect for up to twelve months from the commencement of the new regulations as long as the manufacturer's or TC holder's AFM or POH is not revised But if the AFM or POH is revised within the twelve months or it is necessary to add or remove a supplement due to change in aircraft configuration the CoR holder must change to the new CASA approved AFM to comply with the new regulations

In this transition period CASA will not give written directions to amend the old CAR 138 AFMs The CoR holder will be responsible to ensure that when the the required AFM or POH is revised the changeover to the new CASA approved AFM is accomplished

TRANSITION ARRANGEMENTS FOR AFMS PRODUCED BY CASA AND ITS PREDECESSORS KNOWN AS CIVIL MARK 1 AND CIVIL MARK 2 TYPE FLIGHT MANUALS

CASA and its predecessors issued a number of Civil Mark 1 AFMs for single engine aircraft and Civil Mark 2 AFMs for twin engine aircraft

For aircraft not required to be provided with an AFM or POH under the applicable airworthiness standards when the aircraft was manufactured and first flown the CoR holder will need to ensure that the placards required are available when the Civil Mark 1 or Civil Mark 2 flight manual is no longer in effect This applies mainly to some aircraft below 2722 kg MTOW manufactured in the USA and first flown prior to issue of POHs in the GAMA format in 1975

Other aircraft were required by the relevant NAA to have an AFM or POH issued by the manufacturer or the TC holder but were also issued with a Civil Mark 1 or Civil Mark 2 AFM by CASA or predecessors For these aircraft the CoR holder must ensure that a CASA approved AFM meeting the requirements of the new

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8 CAAP 54 1 0 Flight manuals for individual aircraft Draft Copy 18 5 99 regulations is provided in the aircraft when the Civil Mark 1 or Civil Mark 2 AFM no longer applies In some cases this may be a POH which has been approved as the AFM

TRANSITION ARRANGEMENTS FOR ALL OTHER AFMS The CoR holder is required to obtain and use the manufacturer's or TC holder's AFM or POH that meets the requirements of the new regulations within twelve months of the commencement of the regulations In many cases the existing AFM approved under the old CAR 138 may simply be returned to the configuration issued by the manufacturer or TC holder by removing the old CASA approved additional pages and inserting the new CASA Approval Page and Amendment Record Sheet

NOTIFICATION TO CASA If a new replacement or revised AFM or POH is now the AFM meeting the requirements of the new regulations the CoR holder is to supply a copy of the CASA Approval Page and the completed Amendment Record Sheet to the local CASA Office within 48 hours after the aircraft is flown for the first time after the change is made

MUST THE NEW CASA APPROVED AFM OR PLACARDS BE IN ENGLISH

Yes

WHERE ARE SUPPLEMENTS TO BE LOCATED IF AN AFM IS NOT REQUIRED

For aircraft not required to have a CASA approved AFM because an AFM or POH was not required when the aircraft was produced supplements may be located in the aircraft in any convenient folder available to the pilot Supplements should be in the form as provided by the manufacturer or otherwise in the GAMA format The supplements should be suitably indexed and appropriately recorded on an Amendment Record Sheet a copy of which should then be given to CASA

HOW DO I FIND OUT WHAT AFM OR PLACARDS MY AIRCRAFT SHOULD HAVE

The manufacturer of the aircraft or the TC holder provides the AFM or POH required by the applicable airworthiness standards of the relevant NAA This AFM information can be obtained from the manufacturer the TC holder or the distributor if it was not supplied when the aircraft was delivered or has been lost

Detail information 62
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9 CAAP 54 1 0 Flight manuals for individual aircraft Draft Copy 18 5 99 Placards required to be fitted to the aircraft by the applicable airworthiness standards of the relevant NAA are independently subject to maintenance system and AD requirements

The Type Certificate Data Sheet TCDS for each aircraft type usually lists the AFM or POH as well as placards required by the relevant NAA as part of the aircraft type certification Many maintenance organisations have access to this data through aircraft technical documentation suppliers such as Aircraft Technical Publishers ATP or similar service providers

If you are unsure of what manuals or placards you should have contact your maintenance organisation the manufacturer the TC holder or the distributor and seek advice

CASA maintains a database of the status of master AFMs for each type applicable to the serial number range and this database will eventually be put on the CASA website CoR holders may then be able to use the CASA website database when available to obtain the CASA approved AFM identifier and revision status

WHAT IF AN AFM IS REQUIRED FOR AN OLD AIRCRAFT BUT CANNOT BE FOUND

A CoA cannot be issued until the aircraft has the appropriate AFM It is the responsibility of the CoR holder to obtain a suitable AFM If the TC holder no longer exists the relevant NAA aircraft owner association or another individual aircraft owner may be able to provide a true copy of the certificated AFM CASA must be satisfied via copies of the relevant correspondence that the CoR holder has tried but been unsuccessful in obtaining the appropriate AFM from the normal sources and that the copy submitted is a true copy before accepting that copy to be the CASA approved AFM

The holder of an IoA under regulation 35 of CAR 1988 may be able to prepare an AFM The applicable design standard as usually summarised in the TCDS states the information including limitations required to be in the AFM For aircraft less than 5700 kg the GAMA POH AFM format is preferred for the presentation of that information However this AFM would require approval by CASA or by the holder of an IoA under subregulation 55 4 of CAR 1988 63
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10 CAAP 54 1 0 Flight manuals for individual aircraft Draft Copy 18 5 99 WHAT UNITS OF MEASUREMENT ARE REQUIRED The preferred units of measurement are as contained in AIP GEN 4 Weights kilograms Aeroplane dimensions millimetres Distances e g landing metres Liquid quantities litres Speeds knots Altitudes vertical distances feet Rate of climb feet per minute Pressures kilopascals Temperatures degrees Celsius Altimeter setting hectopascals

The units of measurement used in placards and on instrument markings as well as their consistency are independently subject to maintenance system and AD requirements

For Australian manufactured aircraft The units are to be where practicable in the preferred system For imported aircraft The preferred system of units for all measurements is recommended However the units of measurement in the AFM or POH produced by the manufacturer or TC holder and approved by the relevant NAA may remain unchanged It will be the responsibility of the CoR holder operator or pilot to provide appropriate conversion data if necessary to ensure that communications with ATC are in the preferred units and that the aircraft is operated without hazard

ARE AIRSPEEDS TO BE QUOTED IN IAS OR CAS The airspeeds datum IAS CAS or both specified in the AFM or POH approved by the relevant NAA and produced by the

manufacturer or TC holder need not be changed The airspeeds datum used in placards and instrument markings as well as their consistency are independently subject to maintenance

system and AD requirements

WHAT ABOUT WEIGHT AND BALANCE DATA 64
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11 CAAP 54 1 0 Flight manuals for individual aircraft Draft Copy 18 5 99 The AFM or POH and placards contain the certification weights and the centre of gravity envelope limits

Weight and balance information approved by a Weight Control Officer See CAO 100.7 is required and may be inserted in the folder containing the AFM without further approval or contained in a suitable document available to the pilot

WHAT ABOUT ADDITIONAL OPERATIONAL PERFORMANCE DATA The AFM is no longer required to contain limitations or operational performance data additional to AFM information approved by the relevant NAA

No factoring is required of the approved take off and landing performance data in the manufacturer's AFM or POH Operators should be aware that some operational requirements require extra or factored runway performance information and this information may be in a suitable supplement kept in the folder containing the AFM or in another suitable document

WHAT ABOUT RADIO SYSTEMS OPERATING LIMITATION PAGES CASA approved Radio Systems Operating Limitation RSOL page s are no longer required

ARE EQUIPMENT LISTS REQUIRED Equipment Lists are not required in the AFM unless contained in the AFM or POH issued by the manufacturer or TC holder

WHERE DO I OBTAIN A DOOR OFF OR OTHER LOCAL AFM SUPPLEMENT

Any such supplement must be approved This could be manufacturer's approved data approved foreign STC data or a local AFM supplement approved by CASA or a person holding an IoA under subregulation 55 4 of CAR 1988 after an engineering assessment and flight test if required for door off operations a local modification or a local STC

Note The CoR holder has the responsibility to ensure that any previously issued local supplement is compatible with the manufacturer's or TC holder's AFM or POH that becomes the new CASA approved AFM The CoR holder should contact CASA if in any doubt about this 65
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12 CAAP 54 1 0 Flight manuals for individual aircraft Draft Copy 18 5 99 MUST THE AFM BE CARRIED IN THE AIRCRAFT For aircraft operated under an Air Operators Certificate the AFM need not be carried in the aircraft provided an operations manual is carried which contains the operational information that is contained in the AFM and does not conflict with the AFM An exemption is no longer required If the AFM is amended then the operations manual would also need to be amended All other aircraft for which an AFM is required must carry the AFM

WHAT ARE THE AFM REQUIREMENTS FOR AMATEUR BUILT ABAA OR AMATEUR BUILT EXPERIMENTAL AIRCRAFT

These 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 is made available to the pilot This may be in some form of a document provided by the designer or owner and or placards Design standards such as FAR 23 give information as to the information that should be presented in such a document For aircraft less than 5700 kg the GAMA POH AFM format is preferred for the presentation of that information

As a minimum the following information should be provided to the pilot

airspeed limitations powerplant limitations weight and loading information operations permitted normal and emergency procedures Minimum field length for take off and landing

WHAT ARE THE AFM REQUIREMENTS FOR OTHER SPORTING AIRCRAFT

There are no AFM requirements for hang gliders operated under CAO 95.8 ultralight aircraft operated under 95.10 and 95.55 gyroplanes operated under CAO 95.12 and CAO 95.12.1 weightshift aircraft and powered parachutes operated under CAO 95.32 66
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13 CAAP 54 1 0 Flight manuals for individual aircraft Draft Copy 18 5 99 WHAT ARE THE AFM REQUIREMENTS FOR MANNED FREE BALLOONS AND GLIDERS

Manned free balloons and gliders are treated the same as other certificated aircraft

WHAT ARE THE AFM REQUIREMENTS FOR HISTORIC AND EXMILITARY LIMITED AND EXPERIMENTAL AIRCRAFT

Since these aircraft do not necessarily conform to civil airworthiness standards there may be no formal requirement to have an AFM The aircraft should be operated in accordance with the manuals pilot's notes placards etc provided for the aircraft by a military authority or manufacturer for example or in accordance with the limitations specified for the aircraft on the CoA

Richard G Yates Assistant Director Aviation Safety Standards 67
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Summary of Responses NPRM 9801AW Flight Manual Management Procedures Page C1 ANNEX C List of respondents to NPRM 9801AW consenting to publishing name

H J Brownscombe Richard Skiba Dr Wolfgang W Frick Independent Aviation Consultant K P Jones Adrian Clements Australian Ballooning Federation Allan Taylor Australian Airports Association AAA Gary Williams R F D S Central Section Peter Kable AJC Bankstown Pty Ltd Kenneth Stanley Jones Pilot Aircraft Owner Operator Rohan Salgado CASA Stephan Mahoney CASA John Chesterfield Phoenix Air Training Services J A Jeff Pedrina Independant Aviation Consultancy David J Kirkpatrick Skippers Aviation Pty Ltd Captain Tony Russell Australian Federation of Air Pilots Colin R Nicholson Gippsland Aeronautics Bart Beech AOPA Boyd Park National Jet Systems Bill Gibbings Australian Communication Electronics Glenn McKay Associated Airlines Pty Ltd Alan Terrell Regional Airlines Association of Australia

Two respondents requested that their name not be published The rest did not indicate 69
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Summary of Responses NPRM 9801AW Flight Manual Management Procedures Page C2 INTENTIONALLY LEFT BLANK 70
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Copies Of This Summary Of Responses To NPRM 9801AW Can Be Obtained By One Of The Following Means

Post no stamp required Reply Paid 744 NPRM Administration Regulatory Framework Program GPO Box 2005 CANBERRA ACT 2601

CASA Website www casa gov au

E mail nprm fmm casa gov au

Telephone 1800 687 342

Fax free call 1800 653 897

Specific inquiries regarding the content of this Summary of Responses can be sent to the address above or by telephoning Ralph Murphy on 131 757 for the cost of a local call or direct on

02 6217 1815 71

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