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AC 90-89C

Scott Hersha

Scott Hersha

Well Known Member
The new AC 90-89C has a statement on the first page that says:

“You should add flight test operational and performance data to the Aircraft Operating Handbook (AOH) so you can reference the data prior to each flight”

Do you think this means that we are required to have an Operating Handbook? Maybe that’s up to the FAA or DAR inspector that certifies your airplane, and is in addition to the Operating Limitations given after a successful inspection. I’m not saying it’s a bad idea - I have one that I’ve plagiarized from others on this site and added my own data - but is it a requirement? Mine is called a POH. Same thing I guess.

I haven’t read all 130 pages, so maybe the answer is in there somewhere.
 
Short answer is no, a POH is still not required by this AC or any other publication for E-AB aircraft.

From the preface (emphasis mine): "This advisory circular (AC) provides suggestions and safety-related recommendations....." and "The contents of this document do not have the force and effect of law and are not meant to bind the public in any way, and the document is intended only to provide information to the public regarding existing requirements under the law or agency policies. This AC is not mandatory and does not constitute a regulation."

That said, IMO you should have one - I do.
 
Aircraft Operating Handbook (AOH)

While I agree with the comments regarding the lack of regulatory requirement for a POH in E-AB, the updated AC discusses an AOH (which appears to be a slight course change for the FAA with this AC away from the term POH in regard to E-AB).

While not required to have one by regulation, if you choose to complete your Phase 1 via Task-Based flight testing instead of Hours Based, an AOH is required to complete flight testing based on the language "will" and "has been developed" in the excerpt from AC 90-809C, page 2-9 below.

This is rooted in the idea that if you want to complete your Phase 1 period via task-based flight testing, you will need a record of those task completions, which will be a basis for performance data in your AOH. In reality, this is a pretty simple effort and seems like a practical thing to do, e.g. "do the testing and document it".

The logbook entry documenting completion of the flight test will correspond to the following:
Completion of task-based flight test:
“I certify that all requirements of the task-based flight test plan have been completed in accordance with AC 90-89 and the aircraft is controllable throughout its normal range of speeds and throughout all maneuvers to be executed, has no hazardous operating characteristics or design features, and is safe for operation. An AOH has been developed and placed in the aircraft. The following aircraft operating data has been demonstrated during the flight testing: speeds VS0 ______, VX ______, and VY ______, and the weight ______ and CG location ______ at which they were obtained.”

Printed Name
Signature
 
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Scott Hersha said:
The new AC 90-89C has a statement on the first page that says:

“You should add flight test operational and performance data to the Aircraft Operating Handbook (AOH) so you can reference the data prior to each flight”

Do you think this means that we are required to have an Operating Handbook?
Click to expand...

"You should" and "you must" have very different meanings. "You should...," is a recommendation. The govt pretty much never uses that language for conveying regulatory requirements.
 
I have a POH for my RV-10 about 95% done - largely based on someone else's version from this site.

When the DAR met with me a couple of weeks ago to issue my airworthiness, he asked to review my POH. He didn't imply that it was optional for experimentals and since I have one in progress, I didn't argue with him.

There is no harm in putting one together to record engine performance, V speeds, checklists and procedures, etc. And if your DAR thinks that you need to have one, you are good to go.
 
RV7A Flyer said:
IOW, he made up a regulation. Awesome.
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My DAR worked with both the MIDO and FSDO. He had a bunch of extra requirements that another DAR said were for certified planes and had nothing to do with experimentals. Given this was my first build, I was too far down the path with him to realize that I was doing a lot of extra paperwork and other things, but all's well that ends well. Certificate issued. Flying as soon as I get over this bad cold and the weather cooperates.
 
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Auburntsts said:
I really hate this. While I agree that having a POH is a good idea, I detest FAA officials or any delegates making things up as they go.
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I honestly think we ought to have a review section here or somewhere where people could write reviews of DARs or FAA inspectors so people would have better info on whom to use and whom to avoid. At the top of my list to avoid would be anyone who just makes s**t up or has such a feeble understanding of the regulations that they can't apply the correct rules.

I know *I* am not allowed to just make up arbitrary requirements in my job. Can you say "fuel caps must be painted red"? Just as an example...

Yes, a POH is a good idea. Reminds me to go finish mine (I started it years ago, but quickly realized that a) it's a lot of work to do a nice one, and b) it's not for me, really, but for someone else...I already know all of this stuff, or it's in the library of documents and binders I have for the plane, or on my checklists, or the memory stick with all the tech details that is in the plane, etc.). I doubt I'd ever look at it again once I finished it, anyway.
 
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