Here's the thing. (IMO).
After three years; information always available in the Aircraft Flight Manual (AFM) is 'discovered' by ATSB (after confirmation from the certificate holder). Final report – addendum -? Seriously.....
“The ATSB has received some clarifying information from the aircraft manufacturer, regarding the height at which the ‘engine shutdown to simulate engine failure in takeoff configuration’ procedure is recommended to be performed. The report has been amended with this information and is scheduled to be published on Wednesday 5 August 2020.”
There's a Devil in the detail: “engine shutdown to simulate engine failure in takeoff configuration”.
See - “engine shut down” - not reduced power – or; a 'simulated' engine shut down. The AFM bars a 'shutdown' below 5000'– which opens the loop hole to what is, in effect, the simulation of a 'partial' engine failure (zero thrust). There is no prohibition mentioned regarding this widely accepted practice – provided the engine power is retarded to 'zero thrust' all is well and the hundreds of check flights using this technique have returned to base in one piece. However, as an effective training 'tool' it leaves much to be desired.
It begs the question – which is the 'safer' (I know) practice; an engine 'stopped' at 5000 feet, the engagement of Negative Torques System (NTS) and the drills completed through to restart; or some legally arguable, open to human error procedure which in reality simulates neither a 'real failure' nor the techniques for using the NTS, nor trouble shooting, nor an in flight restart and decision making?
Clearly the 'safety and benefit' question emerges. For an operator to establish an 'in-house' Check and Training System (CTS) the whole box and dice is subject to a three phase scrutiny by the Civil Aviation SAFETY Authority (CASA). In the beginning, the manual supporting the system is submitted for scrutiny by CASA. This is well known to be a long, tedious, difficult process; the requested revisions completed and returned; often, through two or even three constructs. A one size fits all system is acceptable when only one 'type' is encompassed, however, with a mixed fleet there is a substantial amount additional data which must be incorporated. In any event; the practice and procedure for any aircraft must be based on the AFM; particularly on the 'Limitations' section which carries 'real' legal weight. A secondary, but equally important part of the AFM are the 'Warning, 'Caution' and 'Notes' inclusions within the body of the AFM. Open any AFM and those notes jump off the page – usually in 'bold' all capitals – 'Warning' - for example:-
Now; the manufacturer has, clearly and unequivocally stated in the AFM, and now reiterated to ATSB that there was a restriction placed on the height at which a shut down (stopped) Engine Failure after Take Off (EFATO) could be practised; for all variants (mark and model) of the aircraft. Engine shutdown requirements (whistles and bells), trouble shooting, followed by an in flight re-start and recovery is essential training. You can see where fuzzy logic has kicked in; despite clear warning in the AFM and a procedure being specified; BOTH CASA and operator have chosen to ignore this beneficial (from a training standpoint) logic and opted for some half measure which achieves little except 'tick-a-box' with an elevated risk level. The result ending spectacularly with three dead and the associated aftermath of the event. - Good enough?
“With respect to the change in the POH procedures applicable to serial number 0173 and onward, the aircraft manufacturer advised that: • there was no material difference between the aircraft from serial numbers 0173 and onward and the earlier serial numbers (0172 and prior) that necessitated a different method of simulating an engine failure in the take-off configuration • the statements in the earlier POH procedure that referenced the demonstration of VMCA have the same intent as the warning note in the POH for aircraft with serial numbers 0173 and onward, which states this procedure must not be practised at an altitude below 5,000 feet above ground level”.
The Brasilia fatal in the NT was conducted at low level with 'multiple failures' (EFATO and AF fail) at CASA direction; a very close call in Cairns was initiated by the same CASA FOI. The Renmark exercise has parallel 'logic'. It leaves a couple of 'safety logic' questions which demand answers. How was the EFATO check and training system approved by CASA in 'not quite' understanding the spirit, intent and operational logic of the AFM? You see – if you set the pilot a simulated engine problem which requires and 'in-flight' shut down; followed by the system checks; followed by the restart procedure; then set zero thrust and return to land; this constitutes a real check and training scenario. Anything else is essentially an unnecessary exercise which provides very little, except an elevated risk level – for little benefit.
Makes you wonder how many C441 check flights have been conducted in this manner. It may well be OK to do it, an accepted practice; but, what a court and bunch of lawyers will make of it is yet to be seen. It will not be pretty.
Toot – toot.
After three years; information always available in the Aircraft Flight Manual (AFM) is 'discovered' by ATSB (after confirmation from the certificate holder). Final report – addendum -? Seriously.....
“The ATSB has received some clarifying information from the aircraft manufacturer, regarding the height at which the ‘engine shutdown to simulate engine failure in takeoff configuration’ procedure is recommended to be performed. The report has been amended with this information and is scheduled to be published on Wednesday 5 August 2020.”
There's a Devil in the detail: “engine shutdown to simulate engine failure in takeoff configuration”.
See - “engine shut down” - not reduced power – or; a 'simulated' engine shut down. The AFM bars a 'shutdown' below 5000'– which opens the loop hole to what is, in effect, the simulation of a 'partial' engine failure (zero thrust). There is no prohibition mentioned regarding this widely accepted practice – provided the engine power is retarded to 'zero thrust' all is well and the hundreds of check flights using this technique have returned to base in one piece. However, as an effective training 'tool' it leaves much to be desired.
It begs the question – which is the 'safer' (I know) practice; an engine 'stopped' at 5000 feet, the engagement of Negative Torques System (NTS) and the drills completed through to restart; or some legally arguable, open to human error procedure which in reality simulates neither a 'real failure' nor the techniques for using the NTS, nor trouble shooting, nor an in flight restart and decision making?
Clearly the 'safety and benefit' question emerges. For an operator to establish an 'in-house' Check and Training System (CTS) the whole box and dice is subject to a three phase scrutiny by the Civil Aviation SAFETY Authority (CASA). In the beginning, the manual supporting the system is submitted for scrutiny by CASA. This is well known to be a long, tedious, difficult process; the requested revisions completed and returned; often, through two or even three constructs. A one size fits all system is acceptable when only one 'type' is encompassed, however, with a mixed fleet there is a substantial amount additional data which must be incorporated. In any event; the practice and procedure for any aircraft must be based on the AFM; particularly on the 'Limitations' section which carries 'real' legal weight. A secondary, but equally important part of the AFM are the 'Warning, 'Caution' and 'Notes' inclusions within the body of the AFM. Open any AFM and those notes jump off the page – usually in 'bold' all capitals – 'Warning' - for example:-
WARNING.
“IF AN ENGINE FAILURE IS ACCOMPANIED BY A LEFT ESSENTIAL BUS FAILURE” etc. Now; the manufacturer has, clearly and unequivocally stated in the AFM, and now reiterated to ATSB that there was a restriction placed on the height at which a shut down (stopped) Engine Failure after Take Off (EFATO) could be practised; for all variants (mark and model) of the aircraft. Engine shutdown requirements (whistles and bells), trouble shooting, followed by an in flight re-start and recovery is essential training. You can see where fuzzy logic has kicked in; despite clear warning in the AFM and a procedure being specified; BOTH CASA and operator have chosen to ignore this beneficial (from a training standpoint) logic and opted for some half measure which achieves little except 'tick-a-box' with an elevated risk level. The result ending spectacularly with three dead and the associated aftermath of the event. - Good enough?
“With respect to the change in the POH procedures applicable to serial number 0173 and onward, the aircraft manufacturer advised that: • there was no material difference between the aircraft from serial numbers 0173 and onward and the earlier serial numbers (0172 and prior) that necessitated a different method of simulating an engine failure in the take-off configuration • the statements in the earlier POH procedure that referenced the demonstration of VMCA have the same intent as the warning note in the POH for aircraft with serial numbers 0173 and onward, which states this procedure must not be practised at an altitude below 5,000 feet above ground level”.
The Brasilia fatal in the NT was conducted at low level with 'multiple failures' (EFATO and AF fail) at CASA direction; a very close call in Cairns was initiated by the same CASA FOI. The Renmark exercise has parallel 'logic'. It leaves a couple of 'safety logic' questions which demand answers. How was the EFATO check and training system approved by CASA in 'not quite' understanding the spirit, intent and operational logic of the AFM? You see – if you set the pilot a simulated engine problem which requires and 'in-flight' shut down; followed by the system checks; followed by the restart procedure; then set zero thrust and return to land; this constitutes a real check and training scenario. Anything else is essentially an unnecessary exercise which provides very little, except an elevated risk level – for little benefit.
Makes you wonder how many C441 check flights have been conducted in this manner. It may well be OK to do it, an accepted practice; but, what a court and bunch of lawyers will make of it is yet to be seen. It will not be pretty.
Toot – toot.