Legal Question

How to keep the Cessna 170 flying and airworthy.

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kimble
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Legal Question

Post by kimble »

Gentlemen two questions: is "avoid slips when using full flaps" a required placard in the 170B? Does the TC Data sheet list all the required placards?

The placard question is important, because a ramp check by your Friendly Aviation Inspector can catch a violation without seeing your log books.
It is kind of like a hunting dog, once he gets the sent of game, the hunt is on.

Kimble
Tom Downey
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Post by Tom Downey »

The Type certificate gives:

NOTE 2. (a) The following placards must be displayed in front of and in clear view of the pilot:

Model 170

"This airplane must be operated as a normal or utility category airplane in compliance with the Airplane Flight Manual."

NORMAL

"No acrobatic maneuvers including spins approved. With two people in the rear seat both front seats must be occupied."

UTILITY

"No acrobatic maneuvers approved except those listed in the Airplane Flight Manual. Baggage compartment and rear seat must not be occupied."

Models 170A and 170B

"This airplane must be operated as a normal or utility category airplane in compliance with the Airplane Flight Manual."

NORMAL

"No acrobatic maneuvers including spins approved."

"Both tanks on for takeoff and landing."

UTILITY

"No acrobatic maneuvers approved except those listed in the Airplane Flight Manual. Baggage compartment and rear seat must not be occupied."

Models 170A and 170B (Seaplanes)

"Retract Water Rudder During Takeoff and Landing."

Model 170B Seaplane

"Intentional Spins Prohibited" (Normal and Utility Categories)

(b) The following placard must be displayed in the baggage compartment:

"Maximum Baggage 120 lb. For additional loading instructions see Weight and Balance Data."

(c) The following placard must be displayed in front of and in clear view of the pilot for those aircraft with Items Nos. 208(g) and 208(h) installed:

"Do not extend or retract skis while in motion on the ground."


SO the type certificate also says

Models 170, 170A, 170B -- (-2)

402. (a) FAA Approved Airplane Flight Manual and pertinent revisions applicable to the particular model, serial number, and landing gear installation

This is where you will find the warning you mentioned.
Tom Downey A&P-IA
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Bruce Fenstermacher
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Post by Bruce Fenstermacher »

What Tom is trying to say I think is the Type Certificate and any applicable ADs or modifications, either one time approvals or STCs done to your aircraft, which call for a placard is where you would go for the list of necessary placards.

I don't have one in front of me but I don't think the Approved Flight Manual with revisions which Tom refers, which in our case is a a single sheet of paper, warns against slips with flaps.

That verbage may be contained in the Owners Manual which in our case is a small multi sheet book. The Owners Manual is not approved data. Point that out to the Fed if he insists the placard is needed.[/b]
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kimble
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legal questions

Post by kimble »

Gentlemen,
Thank you for your input, time and consideration to the questions.
I purposely broached the subject because legal requirements seem to be neglected. We have a lousy situation concerning placards. There is not a single source where all required placards are to be found.

The IA's are probably the best informed and the most critical link in the airworthiness chain, but on occasion, I have my doubts. Point in question, I have just completed an inspection of a 170B.
There was six required placartd missing. No airworthiness certificate displayed, no current weight and balance (aircraft had not been weighed since 1956 and it had gained 74 lbs). There were six modifications not logged or 337s completed.
The previous IA signed off an annual with it in this condition and complied with and AD on a prop that is not even installed on this aircraft.

"Avoiding slips when using full flaps" there is a good and well known reason for this warning. For both questions, I suggest FAR23.1541, (a),(2) "Any additional information, instrument markings, and placards required for the safe operation if it has unusual design, operating, or handling characteristics." FAR23.1541, (c),(2) The placard and marking information for all categories in which the airplane is to be certificated must be furnished in the Airplane Flight Manual".

For those of us who have occasional insomnia, I suggest the reading of FAR 23.1541 through FAR 23.1567.

Thank you gentlemen for your time and effort,
Kimble
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GAHorn
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Post by GAHorn »

There IS one place all req'd placards are listed: The Type Certificate. The Approved Flight Manual also lists them.
The Cessna 170 was approved under CAR3, not FAR 23.
'53 B-model N146YS SN:25713
50th Anniversary of Flight Model. Winner-Best Original 170B, 100th Anniversary of Flight Convention.
An originality nut (mostly) for the right reasons. ;)
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GAHorn
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Post by GAHorn »

Kimble posted a reply to this thread but did so under an entirely new topic. I have copied his msg here. Please keep threads together and do not create a new topic for individual replys. Thank you. - George
kimble wrote:Sorry George, I can not agree with you. Bruce has already listed some legitimate sources of required placards. I can think of several more required placards that are not listed in these two holy grail sources.

I am going by memory on this one and do not have a copy of the CAR, but isn't FAR23 a carryover regulation?

Anyway, the point I am trying to make is be careful. The Feds do not need to see your log books to pull you on the mat. It has been a standard joke for years, If it doesn't work or has a bad characteristic, install a placard. The manufacturers cover a multitude of sins by installing placards.

Personal example: I recently walked up to a man's aircraft and asked, what is that switch was for? He did not know and there was not a placard stating what it was for. He had his aircraft in the radio shop today and they placarded the switch speaker/phones.

This placard thing is a bag of worms, be careful. If in doubt, stick a placard on it. If that switch had not had a placard, it would have been questioned. If it had said: "Potty Dump, activate only in congested areas," what brave soul is going to see if it works?

Gentlemen, have fun and keep them legal and flying,
Kimble
'53 B-model N146YS SN:25713
50th Anniversary of Flight Model. Winner-Best Original 170B, 100th Anniversary of Flight Convention.
An originality nut (mostly) for the right reasons. ;)
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GAHorn
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Post by GAHorn »

Kimble, the point I was attempting to make is that if the placards are not required by AFM or TCDS, then they are not required placards on original aircraft. (Placards required by STCs are applicable only to modified aircraft in accordance with the STC. That's why STC's can be a pitfall, especially aircraft with multiple STC's which may have absolutely contradictory operating procedures. The onus is upon the owner/operator to determine the total effect of multiply-modified aircraft. All STC's carry the warning to consider the total affect of subsequent STCs.) The placard you were preoccupied with, the so-called "slips with full flaps' placard is not a required placard. Neither is the fuel gauge placard "NO TAKE OFF" below 1/4 tanks. Those placards are merely advisory and not "required".
FAR 23 did not pre-empt CAR 3 or CAR 4 which predated it. Aircraft certificated under the previous FARs are not required to comply with later FARs. That's not to say that good operating practices don't abide by later criteria,....only that no requirement to comply with them exists.
'53 B-model N146YS SN:25713
50th Anniversary of Flight Model. Winner-Best Original 170B, 100th Anniversary of Flight Convention.
An originality nut (mostly) for the right reasons. ;)
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kimble
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Post by kimble »

George, we are working along the same line, but coming from different directions. Your last statement pretty well covers the subject. What does good operating pratice dictate? If there is a dangerous, unusual flight or equipment fluke - placard it.

George, I think this is a good type of dicsussion. But wheather CAR or FAR they should be used as guides to a safe operational environment.

Just remember, the FED is the man, right or wrong. I had one jump me one time because there was not an airworthiness certificate in the aircraft.
He was wrong, it was a PA-25 sprayer, which does not require an airworthiness certificate to be carried in the aircraft.

Thanks for moving my last posting, I hit the wrong button.
Kimble
R COLLINS
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Post by R COLLINS »

Too many placards can be a bad thing. I would prefer those around me to be scanning the horizon as I'm doing instead of reading placards, checklists, maps, radio's, gps's, the morning news and so on!!!!! :evil: RC
51 Cessna 170A N1263D
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GAHorn
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Post by GAHorn »

Kimble, every airplane has an airworthiness certificate (except gov't or "public use" airplanes. That's why the FAA can operate a DC-3 with illegally-polished props but you and I can't.)
PA-25's are no different regardless of their agricultural use.
The FED may be the MAN...but he can also be wrong. It just takes money and time to prove it. :?
Whenever a disagreement with the FED occurs, it's always best to be polite, be inquisitive in an educational sense, and (if he's insistent) get him to put his requirements in writing.
'53 B-model N146YS SN:25713
50th Anniversary of Flight Model. Winner-Best Original 170B, 100th Anniversary of Flight Convention.
An originality nut (mostly) for the right reasons. ;)
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kimble
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Post by kimble »

George, I guess you misunderstood my statement about the PA-25. I agree, It is required to have an airworthiness certificate. However, as I stated, it is not required to be carried in the aircraft.
FAR 91.203, 2, (b) clearly states "No person may operate a civil aircraft unless the airworthiness certificate ----- is displayed at the cabin or
cockpit entrance - - -".
However, FAR 137.33, (b) states: Not withstanding part 91 of this chapter, the registration and airworthiness certificates issued for the aircraft need not be carried in the aircraft." This is speaking about ag-aircraft.

Some of the young maintenance inspectors do not seem to be familiar with the regulation. I had one jump me about it and a sprayer friend of mine had the same thing happen to him.

In both instances we politely disagreed and everyone parted happy.

Keep up the good work,
Kimble
mvivion
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Post by mvivion »

Kimble,

I agree with George on this one. Here's a test for you:

Go to the FAA, request a checkride, recurrent, or whatever, or for a practical test. Take the test in a Cessna 170.

During one of your landing approaches, enter a slip with flaps extended.

See what the examiner says.

There is an easy answer to this: Slips with flaps extended are not PROHIBITED in these aircraft. The manufacturer simply recommends against them.

Now, if they were prohibited, they would require a placard. They are not, and they don't.

It is worthy of note that certain model years of Cessna 185 DO have the admonition that slips with flaps extended are PROHIBITED, and these specific aircraft require a placard. None of the other Cessnas do.

I had a student slip with flaps extended during a commercial checkride, and the examiner failed him. I had a rather extensive discussion with the examiner, a review of the applicable documents, a consultation with an FAA supervisor and they finished the checkride. The examiner in that case was an FAA ops inspector. He believed me when we were done.

Note that many Cessna tailwheel aircraft with skis installed are required to have a placard which states that slips with skis are prohibited. That's a different issue, and a different situation, aerodynamically, and a different admonition.

Mike Vivion
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