everybody who wants to operate under EASA part NCC
Nobody wants to operate under EASA part NCC. It is a particularly abominable part of regulation in a part of aviation where the accident rate is very low. There was no evidence whatsoever that this area of aviation had excessive risks that needed mitigating. Some of the worst aspects were removed (such as the factored ASDA requirements for twin turboprops), but it will still increase cost and reduce utility of quite a few aircraft for no good reason.
But it only applies to EASA “Complex” (+5.7 tonnes, jets, +20 seats, and just to screw king airs, twin turboprops). For the smaller GA fleet, part NCO applies.
Fine…
boscomantico wrote:
Why do you imply that everbody must have a rule on everything?
Not everybody. But everybody who wants to operate under EASA part NCC from next year on. An operating manual (= set of rules) and a quality system are required.
But then you have to set up your own rule instead, just like commercial operators do already now.
Why do you imply that everbody must have a rule on everything? 
I guess we will get rid of that rule when part-NCO comes into force.
But then you have to set up your own rule instead, just like commercial operators do already now. And I have yet to see a company operating manual that extends the limitations/recommendations of the manufacturer instead of further restricting them. So from my experience in commercial operations I expect manufacturer recommendations to become limitations with part NCC.
Cobalt wrote:
Did not prevent regulators (Sweden often quoted) to beg to differ and make it a mandatory item.
Yes, Swedish regulations are explicit in that a max. demonstrated crosswind figure in the POH is a limitation. I guess we will get rid of that rule when part-NCO comes into force.
Did not prevent regulators (Sweden often quoted) to beg to differ and make it a mandatory item.
Also, not all POHs are explicit in that this is not a limitation. I just had a look at the POHs that I have lying around.Piper PA23R-301T (Turbo Saratoga), DA42 (classic and NG), DA40 all don’t say it is not a limitation. Should not matter as it is in the name, but still.
C303T, SR22, and Columbia400 make it clear it is NOT a limitation.
POHs would be written differently if they were expected to be followed do the letter.
Cobalt wrote:
The interpretation that a max demo crosswind component is a limit because there is nothing explicit in the POH for anything higher.
Where do you read this? All POHs that I’ve ever seen have some wording to the effect of ‘this is not considered a limitation’, it’s simply the max crosswind the test pilot(s) could find during certification.
The most important one is the implied prohibition to fly the aircraft in any way not fully documented in the manual
Other, less safety relevant items:
The argument that I would make is that manuals (POHs and maintenance manuals alike) for large aircraft are written with the expectation to be complied with in detail, with lots of scrutiny, checks, negotiations etc.. They are also updated continuously. In addition, approved operations and maintenance manuals make it possible to adjust these if there is anything unsuitable.
POHs and maintenance materials etc. for light GA are written primarily with the FAA Part 91 regime in mind, where these mechanisms do not exist, so giving the kind of 30 year old typewritten pamphlet on yellowing paper the same “force of law” as A320 manufacturer’s SOPs is inappropriate.
So, it seems that we have been carried away a bit with that “you have to fly according to the POH because it’s the POH”, at least as far as procedures are concerned.
No, I think you’ve raised an important point. The EASA Basic Regulation says in Annex IV (Essential Requirements for OPS):
1.b. A flight must be performed in such a way that the operating procedures specified in the Flight Manual or, where required the Operations Manual, for the preparation and execution of the flight are followed.
Presumably that is undesirable for GA and we would like to change that.
Can you offer specific and documented examples of procedures in the Aircraft Flight Manual that are bad/wrong/dangerous please?
