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Is a POH required?

RA9A

Member
At the airport today the question came up do experimental aircraft need a POH
No one seamed to agree, what is the correct answer on this?
 
POH

Not required. Any combination of placards, instrument makings, etc will suffice.
The NTSB of course would like to make POH mandatory for EAB.
 
AROW ??

I think the correct answer is that the only required documents are Airworthiness, Registration, Operating Limits, and Weight and Balance. AROW.

I would think that you could Operating Limits and W&B in one document which might be a specific POH for the airplane.

Maybe that's on certified but it's good to have anyway.
 
I've heard recently from an experienced DAR friend in Tennessee that the Feds are emphasizing the importance of having a POH for E-AB's for the airworthiness inspection. It might be worth a call to your FSDO if you're preparing for inspection. I don't know where it's written that you need one, but it would be smart anyway, even if some of the data is just Van's published performance numbers.
 
O is Owner's Manual, not Operating Limitations. Operating Limitations is really a part of the Airworthiness Certificate.
 
Jesse, as stated the O is for operating limitations. For an older CAR 3 certified aircraft the operating limitations usually resided in the "owners manual" and on some other aircraft such as the Pipers it obviously could also be found in the Aircraft Flight Manual. Part 23 certified airplanes no longer come with "owners manuals" instead they have a Pilot's Operating Handbook as well as a AFM.

The two EAB aircraft I have owned did not have a POH produced by the original builder, instead the operating limitations were listed from data taken during phase 1 testing and the form was signed by a FSDO inspector.
 
Relevant FARs

§91.9 Civil aircraft flight manual, marking, and placard requirements.
(a) Except as provided in paragraph (d) of this section, no person may operate a civil aircraft without complying with the operating limitations specified in the approved Airplane or Rotorcraft Flight Manual, markings, and placards, or as otherwise prescribed by the certificating authority of the country of registry.

(b) No person may operate a U.S.-registered civil aircraft—

(1) For which an Airplane or Rotorcraft Flight Manual is required by §21.5 of this chapter unless there is available in the aircraft a current, approved Airplane or Rotorcraft Flight Manual or the manual provided for in §121.141(b); and

(2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof.

(c) No person may operate a U.S.-registered civil aircraft unless that aircraft is identified in accordance with part 45 of this chapter.

(d) Any person taking off or landing a helicopter certificated under part 29 of this chapter at a heliport constructed over water may make such momentary flight as is necessary for takeoff or landing through the prohibited range of the limiting height-speed envelope established for the helicopter if that flight through the prohibited range takes place over water on which a safe ditching can be accomplished and if the helicopter is amphibious or is equipped with floats or other emergency flotation gear adequate to accomplish a safe emergency ditching on open water.

§21.5 Airplane or Rotorcraft Flight Manual.
(a) With each airplane or rotorcraft not type certificated with an Airplane or Rotorcraft Flight Manual and having no flight time before March 1, 1979, the holder of a type certificate (including amended or supplemental type certificates) or the licensee of a type certificate must make available to the owner at the time of delivery of the aircraft a current approved Airplane or Rotorcraft Flight Manual.

(b) The Airplane or Rotorcraft Flight Manual required by paragraph (a) of this section must contain the following information:

(1) The operating limitations and information required to be furnished in an Airplane or Rotorcraft Flight Manual or in manual material, markings, and placards, by the applicable regulations under which the airplane or rotorcraft was type certificated.

(2) The maximum ambient atmospheric temperature for which engine cooling was demonstrated must be stated in the performance information section of the Flight Manual, if the applicable regulations under which the aircraft was type certificated do not require ambient temperature on engine cooling operating limitations in the Flight Manual.
 
POH is highly recommended but not required. The Operating Limitations issued by the inspector complies with the POH requirements.
 
POH is highly recommended but not required. The Operating Limitations issued by the inspector complies with the POH requirements.

The quote from AC 90-89A -

d. Flight Manual: It is imperative a flight
manual describing the anticipated performance of the
aircraft be written by the aircraft builder/kit manufacturer.
The manual will be revised several times during
the flight test phase until it accurately reports
the aircraft?s performance.


http://www.faa.gov/documentLibrary/media/Advisory_Circular/AC 90-89A.pdf
 
I had an FAA FSDO inspector for my aircraft certification / inspection. As part of the package of documentation he wanted prior to looking at my aircraft, a POH was required. This was about 5 years ago.
 
I had an FAA FSDO inspector for my aircraft certification / inspection. As part of the package of documentation he wanted prior to looking at my aircraft, a POH was required. This was about 5 years ago.

Last July, the gentleman from FSDO asked to see my POH. He actually advised me well in advance that he would like to review the POH. However, he quickly stated that it wasn't required and he couldn't demand seeing it, but strongly recommended from a safety purpose that I create one.

I was fortunate in the he was very clear when he crossed the line from what was required and what he would suggest that I do beyond the requirements. Also to give him credit, he's stopped by multiple times stating, I'm not here representing my employer. I'm just a fellow A&P and EAA member, wanting to help improve safety.

To be honest, it was a great learning experience for me while I was going through through the process of creating my POH. It also helped me as I was going through Phase I to ensure I was capturing all the appropriate metrics.

bob
 
Required or not, it really strikes me as adding to the fun of the build. I mean, being able to write your own airplane owner's manual? Too cool! Early panel doodles show glovebox for just such documentation.

 
slippery slope

So what constitutes an 'acceptable' POH at the time of airworthiness inspection???

The aircraft has yet to fly....
 
So what constitutes an 'acceptable' POH at the time of airworthiness inspection???

The aircraft has yet to fly....

As the AC says...

The quote from AC 90-89A -

d. Flight Manual: It is imperative a flight
manual describing the anticipated performance of the
aircraft
be written by the aircraft builder/kit manufacturer.
The manual will be revised several times during
the flight test phase until it accurately reports
the aircraft?s performance.



Describe the "Anticipated Performance " and edit during testing.

The AC also calls it a "Flight Manual" not a POH, which I would read as not really covering the systems...
 
As the AC says...

[
The AC also calls it a "Flight Manual" not a POH, which I would read as not really covering the systems...

I find that odd. I would think a significant benefit - especially for subsequent owners of the aircraft - would be describing any non-standard systems. For example, since I have electric trim controlled by both a switch on the stick, and also by the autopilot, runaway trim requires one to pull both CB's, then investigate.
 
I find that odd. I would think a significant benefit - especially for subsequent owners of the aircraft - would be describing any non-standard systems. For example, since I have electric trim controlled by both a switch on the stick, and also by the autopilot, runaway trim requires one to pull both CB's, then investigate.

It could be that they are more worried about actual flight characteristics during Phase I testing.

The AC is titled AMATEUR-BUILT AIRCRAFT AND ULTRALIGHT FLIGHT TESTING HANDBOOK after all.

It doesn't stop the owner from creating a good POH, but if he/she is the builder then a full POH is probably of more use to subsequent owners as you say, probably after Phase I testing.

You designed and installed the AP system, so for you it would just be a memory jogger. :)
 
As the AC says...

The quote from AC 90-89A -

d. Flight Manual: It is imperative a flight
manual describing the anticipated performance of the
aircraft
be written by the aircraft builder/kit manufacturer.
The manual will be revised several times during
the flight test phase until it accurately reports
the aircraft’s performance.



Describe the "Anticipated Performance " and edit during testing.

The AC also calls it a "Flight Manual" not a POH, which I would read as not really covering the systems...

Ok Mr. DAR, here is my manual:

"Aircraft leaves the ground at 55kts. Aircraft stalls at 50kts. Vne is 192kts."

Is that an acceptable manual since it anticipates performance of the aircraft?

If so, what value is that? If not, who determines how detailed it has to be?

Slippery slope.
 
One Approach...

I do not advocate a requirement for a handbook. But, there is something to be said for developing a manual of some sort. Prior to Phase I, this drill can assist the builder/test pilot with thinking through techniques and procedures that can subsequently employed and tweaked during test. A handbook can also be of tremendous benefit to a subsequent owner.

Part 3 of the transition manual is designed to provide a baseline, portions of which could be adopted to assist with developing a handbook for individual aircraft. Since each RV is unique, and the phase manual is generic in nature, limitations and performance data will have to be added as well as operation of specific equipment. Obviously, there is more than one way to skin a cat; and the phase manual only represents one possible approach for folks that may want to develop a manual but not necessarily start from scratch.

Due to the relative commonality of RV's, it would also be practical to develop a similar "straw man" to support Phase I operations, i.e., a set of generic, adaptable test cards, checklists, techniques and data crunching software that could assist folks in this phase. With an established kit design like an RV, there is a fine line between developmental test and operational/functional test. Generally, an RV type will fall into the later quality as the baseline performance and flight characteristics of the the type (when built and operated in accordance with designer's recommendations) have already been established and the objective of phase I is to confirm proper operation and validate anticipated performance while making sure the airplane doesn't have any "undocumented features" that will present a hazard to safety. A bit different than testing a one-off design.

Any one that wishes to collaborate with preparation of training or test materials designed to support our community is invited to comment on thread that Doug has set up as a sticky titled "Transition Training Syllabus" on the safety page--I'm certainly grateful for the input/critique.

Fly safe,

Vac
 
Ok Mr. DAR, here is my manual:

"Aircraft leaves the ground at 55kts. Aircraft stalls at 50kts. Vne is 192kts."

Is that an acceptable manual since it anticipates performance of the aircraft?

If so, what value is that? If not, who determines how detailed it has to be?

Slippery slope.

Not speaking for Mr DAR, but it would seem enough to lead to this required final statement at the end of Phase I testing -

?I certify that the prescribed flight test hours have been completed and the aircraft is controllable throughout its normal range of speeds and throughout all maneuvers to be executed, has no hazardous characteristics or design features, and is safe for operation. The following aircraft operating data has been demonstrated during the flight testing: speeds Vso ______, Vx ______, and Vy ______, and the weight ______, and CG location ______ at which they were obtained.?

It seems like the writer of AC 90-89 was as specific as he could be without using a "shall".
 
Just to be clear, I have no objections to a builder/buyer developing a POH if they wish. A case can be made for the value of a well-researched POH if the plane moves on to another pilot. But we keep hearing of cases where a DAR or FSDO inspector insists on a POH prior to issuing the airworthiness certificate.

I think we need to resist these efforts to 'write' regs where they don't exist.
 
Just to be clear, I have no objections to a builder/buyer developing a POH if they wish. A case can be made for the value of a well-researched POH if the plane moves on to another pilot. But we keep hearing of cases where a DAR or FSDO inspector insists on a POH prior to issuing the airworthiness certificate.

I think we need to resist these efforts to 'write' regs where they don't exist.

I agree completely. A significant number of early phase one fatals involves loss of control at low altitude. The individual in a high performance EAB who attempts a turnback from 200' AGL following an engine failure is not going to be "helped" by a POH, or handicapped by the lack of POH.
We must resist the efforts to make a POH mandatory for EAB.
 
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