There was an earlier thread on whether it was legal to fly an airplane under
part 91 into known icing if there was no specific prohibition against it in
the airplane's operating handbook. I asked the Seattle FSDO what their take
was on the issue. This is their reply:

Dear Mr. Campbell:

Thanks for your e-mail asking where the prohibition against flight into
known icing conditions resides in the Federal Aviation Regulations (FARs).

I am a Principal Operations Inspector with the Seattle FSDO and am assigned
to answer your question.

Actually, until a couple of weeks ago, I, like yourself, believed that it
resided in some dark part of Part 91 that I was not familiar with.

Unfortunately, at that time one of our brethren pilots caused me find out
the exact answer to this question. The rule is FAR 91.9 - "Civil Aircraft
Flight Manual, Marking, and Placard Requirements," paragraph (a). It says,
in short, "... no person may operate a civil aircraft without complying with
the operating limitations specified in ...." a Flight Manual specific to the
aircraft, by markings or placards, or ".... otherwise prescribed by the
certificating authority." Most light aircraft (i.e., Cessna 172s) have
either a specific placard and/or a mention in the operating handbook that
flight into known icing is forbidden. The unhappy pilot in question is
facing a violation for operating contrary to the operating limitations of
the aircraft by flying into icing conditions he knew existed (by virtue of a
briefing).

This goes back to how the aircraft was originally "type" certificated. In
the case of light single engine aircraft, such certification is done under
FAR Part 23. I think the tendency most of us have is to think that an
aircraft that has such a prohibition has been tested and failed. Of course,
what the prohibition in the type most likely means is that the aircraft has
not been tested in a known hazard. In the case of icing, it was probably
wisely assumed that such an operation with such an aircraft would likely
have a negative result.

If you consider the opposite situation, aircraft approved for flight into
known icing conditions have had specific testing, specific additional
equipment, and specific limitations added to the basic aircraft.

We are hoping that you will help us and the rest of the flying community
spread the word on how this "icing" limitation works in the FARs because our
experience tells us that there are folks flying who firmly believe that if
it's not written down, it must be okay to do it.

Thanks again. Please call me at (425) 227-2240 if you have other questions.



Dennis Franks, Seattle FSDO



----- Forwarded by Dennis Franks/ANM/FAA on 12/09/2003 05:26 PM -----


Sarah

Perotka-Moye To: Dennis Franks/ANM/FAA@FAA

cc:

12/06/2003 06:13 Subject: Flight into known icing conditions

PM

Dennis--

I overlooked this message, so it is coming to you late. Please respond to
Mr. Campbell and cc me on your response. I'll print out the question and
response for the files, so you don't need to.

Thanks,

Sarah

----- Forwarded by Sarah Perotka-Moye/ANM/FAA on 12/06/2003 06:10 PM -----


"Christopher J Campbell" To: Sarah Perotka-Moye/ANM/FAA@FAA

Subject: Flight into known icing conditions


12/01/2003 08:59

AM

Sarah,

We were talking about flight into known icing conditions the other day, and
someone asked where it is actually prohibited by the FARs. FAR 91.527
applies only to large and turbine powered aircraft, and Part 135 has its own
language prohibiting flight into known icing conditions, but there appears
to be no specific prohibition that applies to general aviation aircraft
under part 91. The only thing that I can find on the subject is the
prohibition against flight into icing conditions in the Limitations section
of the operating handbook in most modern light aircraft.

It would be helpful if I had any additional references that I could direct
my students to. Or am I wrong on this matter?

Christopher Campbell, CFII


--
Christopher J. Campbell
World Famous Flight Instructor
Port Orchard, WA


If you go around beating the Bush, don't complain if you rile the animals.

thanks for posting that.
I am a firm believer that icing is bad, even a little ice is bad.

C J Campbell wrote:

> There was an earlier thread on whether it was legal to fly an airplane under
> part 91 into known icing if there was no specific prohibition against it in
> the airplane's operating handbook. I asked the Seattle FSDO what their take
> was on the issue. This is their reply:
>
> Dear Mr. Campbell:
>
> Thanks for your e-mail asking where the prohibition against flight into
> known icing conditions resides in the Federal Aviation Regulations (FARs).
>
> I am a Principal Operations Inspector with the Seattle FSDO and am assigned
> to answer your question.
>
> Actually, until a couple of weeks ago, I, like yourself, believed that it
> resided in some dark part of Part 91 that I was not familiar with.
>
> Unfortunately, at that time one of our brethren pilots caused me find out
> the exact answer to this question. The rule is FAR 91.9 - "Civil Aircraft
> Flight Manual, Marking, and Placard Requirements," paragraph (a). It says,
> in short, "... no person may operate a civil aircraft without complying with
> the operating limitations specified in ...." a Flight Manual specific to the
> aircraft, by markings or placards, or ".... otherwise prescribed by the
> certificating authority." Most light aircraft (i.e., Cessna 172s) have
> either a specific placard and/or a mention in the operating handbook that
> flight into known icing is forbidden. The unhappy pilot in question is
> facing a violation for operating contrary to the operating limitations of
> the aircraft by flying into icing conditions he knew existed (by virtue of a
> briefing).
>
> This goes back to how the aircraft was originally "type" certificated. In
> the case of light single engine aircraft, such certification is done under
> FAR Part 23. I think the tendency most of us have is to think that an
> aircraft that has such a prohibition has been tested and failed. Of course,
> what the prohibition in the type most likely means is that the aircraft has
> not been tested in a known hazard. In the case of icing, it was probably
> wisely assumed that such an operation with such an aircraft would likely
> have a negative result.
>
> If you consider the opposite situation, aircraft approved for flight into
> known icing conditions have had specific testing, specific additional
> equipment, and specific limitations added to the basic aircraft.
>
> We are hoping that you will help us and the rest of the flying community
> spread the word on how this "icing" limitation works in the FARs because our
> experience tells us that there are folks flying who firmly believe that if
> it's not written down, it must be okay to do it.
>
> Thanks again. Please call me at (425) 227-2240 if you have other questions.
>
> Dennis Franks, Seattle FSDO
>
> ----- Forwarded by Dennis Franks/ANM/FAA on 12/09/2003 05:26 PM -----
>
> Sarah
>
> Perotka-Moye To: Dennis Franks/ANM/FAA@FAA
>
> cc:
>
> 12/06/2003 06:13 Subject: Flight into known icing conditions
>
> PM
>
> Dennis--
>
> I overlooked this message, so it is coming to you late. Please respond to
> Mr. Campbell and cc me on your response. I'll print out the question and
> response for the files, so you don't need to.
>
> Thanks,
>
> Sarah
>
> ----- Forwarded by Sarah Perotka-Moye/ANM/FAA on 12/06/2003 06:10 PM -----
>
> "Christopher J Campbell" To: Sarah Perotka-Moye/ANM/FAA@FAA
>
> Subject: Flight into known icing conditions
>
> 12/01/2003 08:59
>
> AM
>
> Sarah,
>
> We were talking about flight into known icing conditions the other day, and
> someone asked where it is actually prohibited by the FARs. FAR 91.527
> applies only to large and turbine powered aircraft, and Part 135 has its own
> language prohibiting flight into known icing conditions, but there appears
> to be no specific prohibition that applies to general aviation aircraft
> under part 91. The only thing that I can find on the subject is the
> prohibition against flight into icing conditions in the Limitations section
> of the operating handbook in most modern light aircraft.
>
> It would be helpful if I had any additional references that I could direct
> my students to. Or am I wrong on this matter?
>
> Christopher Campbell, CFII
>
> --
> Christopher J. Campbell
> World Famous Flight Instructor
> Port Orchard, WA
>
> If you go around beating the Bush, don't complain if you rile the animals.

"Jeff" > wrote in message
...
> thanks for posting that.
> I am a firm believer that icing is bad, even a little ice is bad.
>
> C J Campbell wrote:
>
> > There was an earlier thread on whether it was legal to fly an airplane
under
> > part 91 into known icing if there was no specific prohibition against it
in
> > the airplane's operating handbook. I asked the Seattle FSDO what their
take
> > was on the issue. This is their reply:
> >
> > Dear Mr. Campbell:
> >
> > Thanks for your e-mail asking where the prohibition against flight into
> > known icing conditions resides in the Federal Aviation Regulations
(FARs).
> >
> > I am a Principal Operations Inspector with the Seattle FSDO and am
assigned
> > to answer your question.
> >
> > Actually, until a couple of weeks ago, I, like yourself, believed that
it
> > resided in some dark part of Part 91 that I was not familiar with.
> >
> > Unfortunately, at that time one of our brethren pilots caused me find
out
> > the exact answer to this question. The rule is FAR 91.9 - "Civil
Aircraft
> > Flight Manual, Marking, and Placard Requirements," paragraph (a). It
says,
> > in short, "... no person may operate a civil aircraft without complying
with
> > the operating limitations specified in ...." a Flight Manual specific to
the
> > aircraft, by markings or placards, or ".... otherwise prescribed by the
> > certificating authority." Most light aircraft (i.e., Cessna 172s) have
> > either a specific placard and/or a mention in the operating handbook
that
> > flight into known icing is forbidden. The unhappy pilot in question is
> > facing a violation for operating contrary to the operating limitations
of
> > the aircraft by flying into icing conditions he knew existed (by virtue
of a
> > briefing).
> >
> > This goes back to how the aircraft was originally "type" certificated.
In
> > the case of light single engine aircraft, such certification is done
under
> > FAR Part 23.

And you know, the FSDO was doing fine until he got to here, but Type
Certification is a Part 21 activity. A change to the Type Certificate that
adds anti-icing capability through an STC would be Part 23, which would also
change the POH. It looks to me like he was parroting rai anyway.

C J Campbell > wrote:

> Unfortunately, at that time one of our brethren pilots caused me find out
> the exact answer to this question. The rule is FAR 91.9 - "Civil Aircraft
> Flight Manual, Marking, and Placard Requirements," paragraph (a). It says,
> in short, "... no person may operate a civil aircraft without complying with
> the operating limitations specified in ...." a Flight Manual specific to the
> aircraft, by markings or placards, or ".... otherwise prescribed by the
> certificating authority." Most light aircraft (i.e., Cessna 172s) have
> either a specific placard and/or a mention in the operating handbook that
> flight into known icing is forbidden. The unhappy pilot in question is
> facing a violation for operating contrary to the operating limitations of
> the aircraft by flying into icing conditions he knew existed (by virtue of a
> briefing).

So my 1949 Bonanza that was certified under CAR 3 (I think that was
what it was called before we got part 21 or 23 or what ever it currently
is). It has no placards or verbage in the POH mentioning icing anywhere.
Therefore I am perfectly legal getting into known icing?

It would be rather stupid of me, but according to this referance I would
be legal?



--
Frank Stutzman
Bonanza N494B "Hula Girl"
Hood River, OR

"Frank Stutzman" > wrote in message
...
> C J Campbell > wrote:
>
> > Unfortunately, at that time one of our brethren pilots caused me find
out
> > the exact answer to this question. The rule is FAR 91.9 - "Civil
Aircraft
> > Flight Manual, Marking, and Placard Requirements," paragraph (a). It
says,
> > in short, "... no person may operate a civil aircraft without complying
with
> > the operating limitations specified in ...." a Flight Manual specific to
the
> > aircraft, by markings or placards, or ".... otherwise prescribed by the
> > certificating authority." Most light aircraft (i.e., Cessna 172s) have
> > either a specific placard and/or a mention in the operating handbook
that
> > flight into known icing is forbidden. The unhappy pilot in question is
> > facing a violation for operating contrary to the operating limitations
of
> > the aircraft by flying into icing conditions he knew existed (by virtue
of a
> > briefing).
>
> So my 1949 Bonanza that was certified under CAR 3 (I think that was
> what it was called before we got part 21 or 23 or what ever it currently
> is). It has no placards or verbage in the POH mentioning icing anywhere.
> Therefore I am perfectly legal getting into known icing?
>
> It would be rather stupid of me, but according to this referance I would
> be legal?

Si.

This is interesting but the question of the legality of flying an older
plane that does not have a placard prohibiting flight into icing remains
unanswered.

Mike
MU-2


"C J Campbell" > wrote in message
...
> There was an earlier thread on whether it was legal to fly an airplane
under
> part 91 into known icing if there was no specific prohibition against it
in
> the airplane's operating handbook. I asked the Seattle FSDO what their
take
> was on the issue. This is their reply:
>
> Dear Mr. Campbell:
>
> Thanks for your e-mail asking where the prohibition against flight into
> known icing conditions resides in the Federal Aviation Regulations (FARs).
>
> I am a Principal Operations Inspector with the Seattle FSDO and am
assigned
> to answer your question.
>
> Actually, until a couple of weeks ago, I, like yourself, believed that it
> resided in some dark part of Part 91 that I was not familiar with.
>
> Unfortunately, at that time one of our brethren pilots caused me find out
> the exact answer to this question. The rule is FAR 91.9 - "Civil Aircraft
> Flight Manual, Marking, and Placard Requirements," paragraph (a). It says,
> in short, "... no person may operate a civil aircraft without complying
with
> the operating limitations specified in ...." a Flight Manual specific to
the
> aircraft, by markings or placards, or ".... otherwise prescribed by the
> certificating authority." Most light aircraft (i.e., Cessna 172s) have
> either a specific placard and/or a mention in the operating handbook that
> flight into known icing is forbidden. The unhappy pilot in question is
> facing a violation for operating contrary to the operating limitations of
> the aircraft by flying into icing conditions he knew existed (by virtue of
a
> briefing).
>
> This goes back to how the aircraft was originally "type" certificated. In
> the case of light single engine aircraft, such certification is done under
> FAR Part 23. I think the tendency most of us have is to think that an
> aircraft that has such a prohibition has been tested and failed. Of
course,
> what the prohibition in the type most likely means is that the aircraft
has
> not been tested in a known hazard. In the case of icing, it was probably
> wisely assumed that such an operation with such an aircraft would likely
> have a negative result.
>
> If you consider the opposite situation, aircraft approved for flight into
> known icing conditions have had specific testing, specific additional
> equipment, and specific limitations added to the basic aircraft.
>
> We are hoping that you will help us and the rest of the flying community
> spread the word on how this "icing" limitation works in the FARs because
our
> experience tells us that there are folks flying who firmly believe that if
> it's not written down, it must be okay to do it.
>
> Thanks again. Please call me at (425) 227-2240 if you have other
questions.
>
>
>
> Dennis Franks, Seattle FSDO
>
>
>
> ----- Forwarded by Dennis Franks/ANM/FAA on 12/09/2003 05:26 PM -----
>
>
> Sarah
>
> Perotka-Moye To: Dennis Franks/ANM/FAA@FAA
>
> cc:
>
> 12/06/2003 06:13 Subject: Flight into known icing conditions
>
> PM
>
> Dennis--
>
> I overlooked this message, so it is coming to you late. Please respond to
> Mr. Campbell and cc me on your response. I'll print out the question and
> response for the files, so you don't need to.
>
> Thanks,
>
> Sarah
>
> ----- Forwarded by Sarah Perotka-Moye/ANM/FAA on 12/06/2003 06:10 PM -----
>
>
> "Christopher J Campbell" To: Sarah Perotka-Moye/ANM/FAA@FAA
>
> Subject: Flight into known icing conditions
>
>
> 12/01/2003 08:59
>
> AM
>
> Sarah,
>
> We were talking about flight into known icing conditions the other day,
and
> someone asked where it is actually prohibited by the FARs. FAR 91.527
> applies only to large and turbine powered aircraft, and Part 135 has its
own
> language prohibiting flight into known icing conditions, but there appears
> to be no specific prohibition that applies to general aviation aircraft
> under part 91. The only thing that I can find on the subject is the
> prohibition against flight into icing conditions in the Limitations
section
> of the operating handbook in most modern light aircraft.
>
> It would be helpful if I had any additional references that I could direct
> my students to. Or am I wrong on this matter?
>
> Christopher Campbell, CFII
>
>
> --
> Christopher J. Campbell
> World Famous Flight Instructor
> Port Orchard, WA
>
>
> If you go around beating the Bush, don't complain if you rile the animals.
>
>
>

"Mike Rapoport" > wrote in message
ink.net...
> This is interesting but the question of the legality of flying an older
> plane that does not have a placard prohibiting flight into icing remains
> unanswered.

There is no written prohibition to the activity in question. Such a suicide
would be legal and we would miss the operator greatly, but in case of
survival, there would be no prosecution; except Administratively.

C J Campbell wrote:
> There was an earlier thread on whether it was legal to fly an airplane under
> part 91 into known icing if there was no specific prohibition against it in
> the airplane's operating handbook. I asked the Seattle FSDO what their take
> was on the issue. This is their reply:

I think the issue is one of what constitutes known icing. Is it from a
pirep, weather balloon, etc., that has actually seen/encountered the
icing or is a forecast from some weather guy on the ground who thinks
ice might occur sufficient to constitute known icing. Most pilots of
light aircraft know it is both dumb and illegal to fly into a location
where icing is REALLY know to exist. However, to me, a forecast isn't
"known", it is "possible", maybe even "likely", but hardly known.


Matt

Frank Stutzman wrote:
> C J Campbell > wrote:
>
>
>>Unfortunately, at that time one of our brethren pilots caused me find out
>>the exact answer to this question. The rule is FAR 91.9 - "Civil Aircraft
>>Flight Manual, Marking, and Placard Requirements," paragraph (a). It says,
>>in short, "... no person may operate a civil aircraft without complying with
>>the operating limitations specified in ...." a Flight Manual specific to the
>>aircraft, by markings or placards, or ".... otherwise prescribed by the
>>certificating authority." Most light aircraft (i.e., Cessna 172s) have
>>either a specific placard and/or a mention in the operating handbook that
>>flight into known icing is forbidden. The unhappy pilot in question is
>>facing a violation for operating contrary to the operating limitations of
>>the aircraft by flying into icing conditions he knew existed (by virtue of a
>>briefing).
>
>
> So my 1949 Bonanza that was certified under CAR 3 (I think that was
> what it was called before we got part 21 or 23 or what ever it currently
> is). It has no placards or verbage in the POH mentioning icing anywhere.
> Therefore I am perfectly legal getting into known icing?
>
> It would be rather stupid of me, but according to this referance I would
> be legal?

You might be legal, but you'd also be a test pilot. They might throw
the book at you for impersonating a test pilot ... unless, that is, you
ARE a test pilot. :-)


Matt

No John, the FSDO has it right. The certification basis for most
small aircraft is FAR 23. Just check the type certificate data sheets
for any model. It is either CAR 3 or 23. FAR 21 is only the
procedural requirements for the issuance of a TC. There are no
specifications in 21. An STC must meet the same certification
requirements as a TC (FAR23).



On Wed, 17 Dec 2003 10:58:06 -0800, "Tarver Engineering"
> wrote:

>
>"Jeff" > wrote in message
...
>> thanks for posting that.
>> I am a firm believer that icing is bad, even a little ice is bad.
>>
>> C J Campbell wrote:
>>
>> > There was an earlier thread on whether it was legal to fly an airplane
>under
>> > part 91 into known icing if there was no specific prohibition against it
>in
>> > the airplane's operating handbook. I asked the Seattle FSDO what their
>take
>> > was on the issue. This is their reply:
>> >
>> > Dear Mr. Campbell:
>> >
>> > Thanks for your e-mail asking where the prohibition against flight into
>> > known icing conditions resides in the Federal Aviation Regulations
>(FARs).
>> >
>> > I am a Principal Operations Inspector with the Seattle FSDO and am
>assigned
>> > to answer your question.
>> >
>> > Actually, until a couple of weeks ago, I, like yourself, believed that
>it
>> > resided in some dark part of Part 91 that I was not familiar with.
>> >
>> > Unfortunately, at that time one of our brethren pilots caused me find
>out
>> > the exact answer to this question. The rule is FAR 91.9 - "Civil
>Aircraft
>> > Flight Manual, Marking, and Placard Requirements," paragraph (a). It
>says,
>> > in short, "... no person may operate a civil aircraft without complying
>with
>> > the operating limitations specified in ...." a Flight Manual specific to
>the
>> > aircraft, by markings or placards, or ".... otherwise prescribed by the
>> > certificating authority." Most light aircraft (i.e., Cessna 172s) have
>> > either a specific placard and/or a mention in the operating handbook
>that
>> > flight into known icing is forbidden. The unhappy pilot in question is
>> > facing a violation for operating contrary to the operating limitations
>of
>> > the aircraft by flying into icing conditions he knew existed (by virtue
>of a
>> > briefing).
>> >
>> > This goes back to how the aircraft was originally "type" certificated.
>In
>> > the case of light single engine aircraft, such certification is done
>under
>> > FAR Part 23.
>
>And you know, the FSDO was doing fine until he got to here, but Type
>Certification is a Part 21 activity. A change to the Type Certificate that
>adds anti-icing capability through an STC would be Part 23, which would also
>change the POH. It looks to me like he was parroting rai anyway.
>

"Bill Zaleski" > wrote in message
...
> No John, the FSDO has it right. The certification basis for most
> small aircraft is FAR 23.

No, Bill, all Type Certificates are Part 21. Part 23 can only change an
existing Type Certificate, that is to say, the is no Law through which a
Type certificate can be issued under Part 23.

Look at any modern small aircraft type certificate data sheet and note
the certification basis. You will not find a single one that is
certified under FAR 21 They are all FAR 23. The original FSDO letter
you slammed mentioned "certified under FAR 23" You said he was wrong.
The certification basis IS FAR 23. Cite me one aircraft (small) that
has a certification basis of FAR21, as shown on it's TCDS.


On Wed, 17 Dec 2003 16:03:43 -0800, "Tarver Engineering"
> wrote:

>
>"Bill Zaleski" > wrote in message
...
>> No John, the FSDO has it right. The certification basis for most
>> small aircraft is FAR 23.
>
>No, Bill, all Type Certificates are Part 21. Part 23 can only change an
>existing Type Certificate, that is to say, the is no Law through which a
>Type certificate can be issued under Part 23.
>

"Bill Zaleski" > wrote in message
...
> Look at any modern small aircraft type certificate data sheet and note
> the certification basis. You will not find a single one that is
> certified under FAR 21 They are all FAR 23.

That is impossible, perhaps you are confusing changes to a type certificate
with the type certificate. A Part 21 entity has Authority well in excess of
what can be done under Part 23.

> The original FSDO letter
> you slammed mentioned "certified under FAR 23" You said he was wrong.

Nope, what I corrected is a referece to a "Type Certificate" issued under
Part 23, which is impossible.

> The certification basis IS FAR 23. Cite me one aircraft (small) that
> has a certification basis of FAR21, as shown on it's TCDS.

Non-sequitur.

John, you either have not or cannot provide me with an aircraft type
that is certificated under FAR 21. Why is this? Could it be that
perhaps, you are mistaken? Current small aircraft certification is
being done under FAR 23. The TCDS of modern aircraft confirms this.
Sorry to burst your bubble. Non-sequitur is not a valid way out. I
have provided the citation, you provide only your mouth.


On Wed, 17 Dec 2003 16:27:11 -0800, "Tarver Engineering"
> wrote:

>
>"Bill Zaleski" > wrote in message
...
>> Look at any modern small aircraft type certificate data sheet and note
>> the certification basis. You will not find a single one that is
>> certified under FAR 21 They are all FAR 23.
>
>That is impossible, perhaps you are confusing changes to a type certificate
>with the type certificate. A Part 21 entity has Authority well in excess of
>what can be done under Part 23.
>
>> The original FSDO letter
>> you slammed mentioned "certified under FAR 23" You said he was wrong.
>
>Nope, what I corrected is a referece to a "Type Certificate" issued under
>Part 23, which is impossible.
>
>> The certification basis IS FAR 23. Cite me one aircraft (small) that
>> has a certification basis of FAR21, as shown on it's TCDS.
>
>Non-sequitur.
>

"Bill Zaleski" > wrote in message
...
> John, you either have not or cannot provide me with an aircraft type
> that is certificated under FAR 21. Why is this?

All aircraft are Type Certificated under Part 21, there is no other means to
do so.

Well then John, why don't you look at any modern type cetificate data
sheet, note the certification basis, and report back to me how many
you find type certificated under FAR 21 vs. FAR 23, as I have told you
a couple of times already is the only current basis, for small
aircraft. Afraid to look, or don't know how to find a TCDS? If there
is no other means to TC an aircraft under, then the FAA needs to be
told, as there are hundreds certified under FAR 23. Just look.


On Wed, 17 Dec 2003 16:55:31 -0800, "Tarver Engineering"
> wrote:

>
>"Bill Zaleski" > wrote in message
...
>> John, you either have not or cannot provide me with an aircraft type
>> that is certificated under FAR 21. Why is this?
>
>All aircraft are Type Certificated under Part 21, there is no other means to
>do so.
>

"Bill Zaleski" > wrote in message
...
> Well then John, why don't you look at any modern type cetificate data
> sheet, note the certification basis, and report back to me how many
> you find type certificated under FAR 21 vs. FAR 23, as I have told you
> a couple of times already is the only current basis, for small
> aircraft.

No, but you are welcome to be so deluded.

Now, the rules of Part 23 can be used as a basis of certification, but there
is no way to issue a Type Certificate except under Part 21. In fact, as a
help for you to find a number of Part 21 only issued Type Certificated
aircraft, I'll refer you to RAH.

"Matthew S. Whiting" > wrote in message
...
> I think the issue is one of what constitutes known icing. Is it from a
> pirep, weather balloon, etc., that has actually seen/encountered the
> icing or is a forecast from some weather guy on the ground who thinks
> ice might occur sufficient to constitute known icing. Most pilots of
> light aircraft know it is both dumb and illegal to fly into a location
> where icing is REALLY know to exist. However, to me, a forecast isn't
> "known", it is "possible", maybe even "likely", but hardly known.

Are there really any AOMs that refer to "known icing"? The Cessna 152/172
AOMs I've seen prohibit flight in "known icing conditions". That's most
plausibly parsed as known icing-conditions, that is, known conditions that
are conducive to icing. So the icing itself doesn't have to be known, just
the conditions. And a forecast tells you of those conditions.

--Gary

Just name one of me, John, show me the certification basis as such in
the TCDS, and quit playing games.


On Wed, 17 Dec 2003 17:46:57 -0800, "Tarver Engineering"
> wrote:

>
>"Bill Zaleski" > wrote in message
...
>> Well then John, why don't you look at any modern type cetificate data
>> sheet, note the certification basis, and report back to me how many
>> you find type certificated under FAR 21 vs. FAR 23, as I have told you
>> a couple of times already is the only current basis, for small
>> aircraft.
>
>No, but you are welcome to be so deluded.
>
>Now, the rules of Part 23 can be used as a basis of certification, but there
>is no way to issue a Type Certificate except under Part 21. In fact, as a
>help for you to find a number of Part 21 only issued Type Certificated
>aircraft, I'll refer you to RAH.
>

Frank Stutzman > wrote in message >...
>
> So my 1949 Bonanza that was certified under CAR 3 (I think that was
> what it was called before we got part 21 or 23 or what ever it currently
> is). It has no placards or verbage in the POH mentioning icing anywhere.
> Therefore I am perfectly legal getting into known icing?
>
> It would be rather stupid of me, but according to this referance I would
> be legal?

Maybe not "illegal" with respect to a known icing FAR, but probably at
risk of a violation under the infamous 91.13 "careless and reckless"
FAR.

"Bill Zaleski" > wrote in message
...
> Just name one of me, John, show me the certification basis as such in
> the TCDS, and quit playing games.

I already refered you to a newsgroup apropriate to your posts. Most prople
come to rai for the real answer.

Sure, a newsgroup is a much better way to prove the point, instead of
FAR's and other documentation, which proves my position. As I recall
you have never been wrong before Tarver. No sense arguing with you.
You know better that the FAA. Quit wasting my time. I gave you the
means to prove yourself, and you ignored the offer. Perhaps hou need
to move to the newsgroup you think is so definitive. Why can't you
name just one aircraft that fits into this nonexistant certification
basis you refer to?


On Wed, 17 Dec 2003 18:03:29 -0800, "Tarver Engineering"
> wrote:

>
>"Bill Zaleski" > wrote in message
...
>> Just name one of me, John, show me the certification basis as such in
>> the TCDS, and quit playing games.
>
>I already refered you to a newsgroup apropriate to your posts. Most prople
>come to rai for the real answer.
>

There is no doubt that forecast icing is known icing to the FAA and the
NTSB. This has been beat to death many times here and in every aviation
publication.

Mike
MU-2


"Matthew S. Whiting" > wrote in message
...
> C J Campbell wrote:
> > There was an earlier thread on whether it was legal to fly an airplane
under
> > part 91 into known icing if there was no specific prohibition against it
in
> > the airplane's operating handbook. I asked the Seattle FSDO what their
take
> > was on the issue. This is their reply:
>
> I think the issue is one of what constitutes known icing. Is it from a
> pirep, weather balloon, etc., that has actually seen/encountered the
> icing or is a forecast from some weather guy on the ground who thinks
> ice might occur sufficient to constitute known icing. Most pilots of
> light aircraft know it is both dumb and illegal to fly into a location
> where icing is REALLY know to exist. However, to me, a forecast isn't
> "known", it is "possible", maybe even "likely", but hardly known.
>
>
> Matt
>

"Mike Rapoport" > wrote in message
ink.net...
>
> This is interesting but the question of the legality of flying an older
> plane that does not have a placard prohibiting flight into icing remains
> unanswered.
>

How so? The question was asked with regard to a Part 91 operation other
than a large or turbine powered aircraft. The answer was FAR 91.9.

"Matthew S. Whiting" > wrote in message
...
>
> You might be legal, but you'd also be a test pilot. They might throw
> the book at you for impersonating a test pilot ...
>

What FAR prohibits impersonating a test pilot?

"Bill Zaleski" > wrote in message
...
> Sure, a newsgroup is a much better way to prove the point, instead of
> FAR's and other documentation, which proves my position.

If we were to use CFR 14 Part 23 as a starting point, the title itself gives
all but the most egtotistical a clue. Then, if we look for Type
Certificate, we will find it in Part 21.

Simple enough for you Bill, give those FARs a read. :)

"James L. Freeman" > wrote in message
om...
>
> Maybe not "illegal" with respect to a known icing FAR, but probably at
> risk of a violation under the infamous 91.13 "careless and reckless"
> FAR.
>

FAR 91.13 applies only if the life or property of another is endangered.

"James L. Freeman" > wrote in message
om...
> Frank Stutzman > wrote in message
>...
> >
> > So my 1949 Bonanza that was certified under CAR 3 (I think that was
> > what it was called before we got part 21 or 23 or what ever it currently
> > is). It has no placards or verbage in the POH mentioning icing
anywhere.
> > Therefore I am perfectly legal getting into known icing?
> >
> > It would be rather stupid of me, but according to this referance I would
> > be legal?
>
> Maybe not "illegal" with respect to a known icing FAR, but probably at
> risk of a violation under the infamous 91.13 "careless and reckless"
> FAR.

Only if you endanger the person, or property, of another in doing so.

On Wed, 17 Dec 2003 22:33:38 GMT, "Matthew S. Whiting"
> wrote:

> However, to me, a forecast isn't
>"known", it is "possible", maybe even "likely", but hardly known.

I agree with your English. However, to the FAA, the forecast is "known".

The placards do not say just "known icing". They say "known icing
*conditions*". And both the FAA and NTSB hang their hat on saying that if
"icing conditions" are forecast, then they are known and you are in the
prohibited range even if "icing" does not exist.


Ron (EPM) (N5843Q, Mooney M20E) (CP, ASEL, ASES, IA)

John: The original topic and the subject of this whole tread is/was
ice certification. Those certification rules, and the basis for
certification are contained within FAR 23. That is the whole subject
of this thread. Part 21 deals with PRODUCTION BASIS and has nothing
whatsoever to do with the criteria for determining whether an aircraft
has icing approval. You chose to go off on a tangent. The FSDO guy
is still correct.


On Wed, 17 Dec 2003 19:22:21 -0800, "Tarver Engineering"
> wrote:

>
>"Bill Zaleski" > wrote in message
...
>> Sure, a newsgroup is a much better way to prove the point, instead of
>> FAR's and other documentation, which proves my position.
>
>If we were to use CFR 14 Part 23 as a starting point, the title itself gives
>all but the most egtotistical a clue. Then, if we look for Type
>Certificate, we will find it in Part 21.
>
>Simple enough for you Bill, give those FARs a read. :)
>

"Bill Zaleski" > wrote in message
...
> John: The original topic and the subject of this whole tread is/was
> ice certification. Those certification rules, and the basis for
> certification are contained within FAR 23. That is the whole subject
> of this thread.

Non-sequitur.

> Part 21 deals with PRODUCTION BASIS and has nothing
> whatsoever to do with the criteria for determining whether an aircraft
> has icing approval. You chose to go off on a tangent. The FSDO guy
> is still correct.

The only part of the letter I corrected has to do with what section of CFR
14 an aircraft's type Certificate is issued under, where the FSDO guy is
wrong. The fact that you have now caught on to haw rediculess you have
been, is a good reason for you to wish to change the subject, but also
irrelevent.

> On Wed, 17 Dec 2003 19:22:21 -0800, "Tarver Engineering"
> > wrote:
>
> >
> >"Bill Zaleski" > wrote in message
> ...
> >> Sure, a newsgroup is a much better way to prove the point, instead of
> >> FAR's and other documentation, which proves my position.
> >
> >If we were to use CFR 14 Part 23 as a starting point, the title itself
gives
> >all but the most egtotistical a clue. Then, if we look for Type
> >Certificate, we will find it in Part 21.
> >
> >Simple enough for you Bill, give those FARs a read. :)
> >
>

Hi guys,

Let me jump into the middle of this with both feet, and hope to escape without
too many flames... :)

14 CFR part 21 contains the procedural rules for obtaining a type certificate
and approval for changes to a type certificate (i.e., a Supplemental Type
Certificate), and airworthiness requirements for "unique" kinds of aircraft.
An applicant who applies for a Type Certificate or Supplemental Type Certifcate
under this part, is granted approval under part 21 if the FAA finds that the
design or change to a design shows compliance to the applicable airworthiness
requirements.

The airworthiness requirements to which the design, or change to a design, must
show compliance may be in part 21 (for example, primary category aircraft or
foreign aircraft accepted under a bilateral airworthiness agreement), or in one
of the airworthiness standards such as part 23 for normal, utility, acrobatic,
and commuter category airplanes.

The Type Certificate Data Sheet for an aircraft shows the Certification Basis.
The Certification Basis is the set of airworthiness standards to which
compliance was shown. For example, U.S. manufactured normal and utility
category airplanes are certificated to airworthiness standards contained in
part 23 or its predecessor, CAR 3. Primary Category aircraft are certificated
to airworthiness requirements listed in part 21, so part 21 would be listed in
the Type Certificate Data Sheet. However, procedural rules of part 21 are not
shown in the Data Sheet.

So, in following this thread, my impression is that you're both right. The
design approvals are issued under part 21, and the airworthiness requirements
to which compliance must be shown are listed in the Type Certificate Data
Sheet.

Nothin' like muddying the waters.... :)

Cheers,

Gordon.

"CivetOne" > wrote in message
...
> Hi guys,
>
> Let me jump into the middle of this with both feet, and hope to escape
without
> too many flames... :)
>
> 14 CFR part 21 contains the procedural rules for obtaining a type
certificate
> and approval for changes to a type certificate

Yes.

> (i.e., a Supplemental Type
> Certificate),

No, that is Part 23 for under 12,500 lbs.

<snip of rest without reading>

Let me be fair to the FSDO guy and agree that the icing capability is
usually added after the Part 21 Type Certificate is issued. Therefore, if
you have anti-icing capability for your small airplane, it is probably a
Part 23 STC change.

>> 14 CFR part 21 contains the procedural rules for obtaining a type
>certificate
>> and approval for changes to a type certificate
>
>Yes.
>
>> (i.e., a Supplemental Type
>> Certificate),
>
>No, that is Part 23 for under 12,500 lbs.
>
><snip of rest without reading>
>
>Let me be fair to the FSDO guy and agree that the icing capability is
>usually added after the Part 21 Type Certificate is issued. Therefore, if
>you have anti-icing capability for your small airplane, it is probably a
>Part 23 STC change.

Please allow me to delve into administrative minutia for a second.

I agree that, in our example, anti-icing capability added to a small airplane
after manufacture is a change to the type design, and that the airworthiness
rules to which the anti-icing equipment must be certificated are in part 23.
In addition to the equipment, the Kinds of Operations (23.1525) would need to
be changed to include flight in icing conditions.

However, the procedural rules governing the approval of a Supplemental Type
Certificate are in part 21. Subpart D of part 21 talks about changes to a type
certificate, and subpart E deals specifically with Supplemental Type
Certificates. Subpart E defines the applicable airworthiness requirements for
the STC in a similar fashion to subpart B for type certificates. In our icing
example, the applicable airworthiness requirements would be contained in part
23.

So, my bottom line is that the procedural requirements for obtaining design
approval of either a new design or changes to an existing design are contained
in part 21. The design approval, either a TC or an STC, is issued in
accordance with the procedures in part 21. The airworthiness requirements to
which the design or design change must comply are contained in the
airworthiness standards (e.g., part 23 for small airplanes), or part 21 for
unique aircraft (e.g., primary category).

Like I said at the beginning, "administrative minutia."

Cheers,

Gordon.

"CivetOne" > wrote in message
...

<snip>
> So, my bottom line is that the procedural requirements for obtaining
design
> approval of either a new design or changes to an existing design are
contained
> in part 21.

For the aircraft's manufacturer.

> The design approval, either a TC or an STC, is issued in
> accordance with the procedures in part 21.

No, the procedures contained in Part 23 are intended to enable a third party
to receive STC Aproval, for a change to a small airplane. From the STC,
with a licensing agreement in place, the parts used to make that change can
get PMA aproval.

> The airworthiness requirements to
> which the design or design change must comply are contained in the
> airworthiness standards (e.g., part 23 for small airplanes), or part 21
for
> unique aircraft (e.g., primary category).

"Matthew S. Whiting" > wrote in message
...

|
| You might be legal, but you'd also be a test pilot. They might throw
| the book at you for impersonating a test pilot ... unless, that is, you
| ARE a test pilot. :-)
|

What FAR spells out the requirements for certification of a test pilot?

"Steven P. McNicoll" > wrote in message
ink.net...
>
> "James L. Freeman" > wrote in message
> om...
> >
> > Maybe not "illegal" with respect to a known icing FAR, but probably at
> > risk of a violation under the infamous 91.13 "careless and reckless"
> > FAR.
> >
>
> FAR 91.13 applies only if the life or property of another is endangered.

I guess if you're renting the plane, it does apply.

-- David Brooks

Parts produced under an STC do not need PMA approval. Chew on that
one, Tarver.



On Wed, 17 Dec 2003 21:56:07 -0800, "Tarver Engineering"
> wrote:

>
>"CivetOne" > wrote in message
...
>
><snip>
>> So, my bottom line is that the procedural requirements for obtaining
>design
>> approval of either a new design or changes to an existing design are
>contained
>> in part 21.
>
>For the aircraft's manufacturer.
>
>> The design approval, either a TC or an STC, is issued in
>> accordance with the procedures in part 21.
>
>No, the procedures contained in Part 23 are intended to enable a third party
>to receive STC Aproval, for a change to a small airplane. From the STC,
>with a licensing agreement in place, the parts used to make that change can
>get PMA aproval.
>
>> The airworthiness requirements to
>> which the design or design change must comply are contained in the
>> airworthiness standards (e.g., part 23 for small airplanes), or part 21
>for
>> unique aircraft (e.g., primary category).
>

Gary Drescher wrote:
> "Matthew S. Whiting" > wrote in message
> ...
>
>>I think the issue is one of what constitutes known icing. Is it from a
>>pirep, weather balloon, etc., that has actually seen/encountered the
>>icing or is a forecast from some weather guy on the ground who thinks
>>ice might occur sufficient to constitute known icing. Most pilots of
>>light aircraft know it is both dumb and illegal to fly into a location
>>where icing is REALLY know to exist. However, to me, a forecast isn't
>>"known", it is "possible", maybe even "likely", but hardly known.
>
>
> Are there really any AOMs that refer to "known icing"? The Cessna 152/172
> AOMs I've seen prohibit flight in "known icing conditions". That's most
> plausibly parsed as known icing-conditions, that is, known conditions that
> are conducive to icing. So the icing itself doesn't have to be known, just
> the conditions. And a forecast tells you of those conditions.

Well, I have no idea what Cessna was thinking or intending when they
wrote that, but, I'd interpret it as known - icing conditions. I don't
think parsing it your way is at all the most plausible. It is like
saying not to land if it conditions exist that might cause a crosswind
in excess of the demonstrated crosswind. We worry about the actual
crosswind, not what might exist. To me, it is much more plausible that
they would be consistent with all such limitations and apply them to
actual prevailing circumstances, not based on conditions which might
lead to such circumstances. Just my opinion though, as I said I don't
claim to know what Cessna intended.


Matt

Steven P. McNicoll wrote:
> "Matthew S. Whiting" > wrote in message
> ...
>
>>You might be legal, but you'd also be a test pilot. They might throw
>>the book at you for impersonating a test pilot ...
>>
>
>
> What FAR prohibits impersonating a test pilot?

It's called "tongue in cheek", Steven.


Matt

C J Campbell wrote:
> "Matthew S. Whiting" > wrote in message
> ...
>
> |
> | You might be legal, but you'd also be a test pilot. They might throw
> | the book at you for impersonating a test pilot ... unless, that is, you
> | ARE a test pilot. :-)
> |
>
> What FAR spells out the requirements for certification of a test pilot?
>
>

None that I'm aware of. Looks like you didn't catch the tongue-in-cheek
nature of my comment either. I thought the smiley would give it away
for sure. I guess some folks here are just too literal...

Matt

"Matthew S. Whiting" > wrote in message
...
> Gary Drescher wrote:
> > "Matthew S. Whiting" > wrote in message
> > ...
> > Are there really any AOMs that refer to "known icing"? The Cessna
152/172
> > AOMs I've seen prohibit flight in "known icing conditions". That's most
> > plausibly parsed as known icing-conditions, that is, known conditions
that
> > are conducive to icing. So the icing itself doesn't have to be known,
just
> > the conditions. And a forecast tells you of those conditions.
>
> Well, I have no idea what Cessna was thinking or intending when they
> wrote that,

They could certainly have stated it more clearly, I agree.

> but, I'd interpret it as known - icing conditions. I don't
> think parsing it your way is at all the most plausible. It is like
> saying not to land if it conditions exist that might cause a crosswind
> in excess of the demonstrated crosswind.

It *would* be like saying that if the AOM's demonstrated-crosswind statement
were a limitation (it's not, at least for 152s and 172s) and, more to the
point, if it were stated as a prohibition against flying in "known
excessive-crosswind conditions". Presumably, the other AOM limitations are
not stated that way precisely because they would then have the wrong
meaning.

> We worry about the actual
> crosswind, not what might exist. To me, it is much more plausible that
> they would be consistent with all such limitations and apply them to
> actual prevailing circumstances, not based on conditions which might
> lead to such circumstances.

First, the very fact that they phrase the icing limitation differently than
other limitations strongly suggests that they intend something different for
that one. Second, it's not at all plausible to have a "consistent" response
to very different sorts of circumstances. There's no reason to prohibit
landing in conditions that are merely conducive to excessive crosswinds,
because (even if the demonstrated-crosswind statement were a limitation, and
even if there were no weather reporting at the destination) it would still
be reasonable to attempt a landing and find out if the crosswind is in fact
excessive. If not, the pilot can simply go around and try again, or divert
to a better-aligned runway. But conditions conducive to icing are usually
dangerous to probe empirically--by the time you get your answer, you may
already be in trouble. That's not always the case, but it is the case often
enough that it's reasonable to prohibit such probes (or at least much more
reasonable than it would be to prohibit you from probing the crosswind
conditions).

> Just my opinion though, as I said I don't claim to know what Cessna
intended.

Yup, the FARs and AOMs are overdue for a massive rewrite. Maybe by the next
Centennial. :)

--Gary

>
>
> Matt
>

"Steven P. McNicoll" > wrote in message et>...
> "James L. Freeman" > wrote in message
> om...
> >
> > Maybe not "illegal" with respect to a known icing FAR, but probably at
> > risk of a violation under the infamous 91.13 "careless and reckless"
> > FAR.
> >
>
> FAR 91.13 applies only if the life or property of another is endangered.

In the past, the FAA has taken a very broad interpretation of what
constitutes endangerment of life and property, and it only needs to be
potential, not actual. For example, in Administrator vs. Holter, et.
al., 5 NTSB 826 (1985), it was applied to a pilot who landed at the
wrong airport. And in Administrator vs. Feldman, EA-2913 (1989), it
was applied to a pilot who flew IFR without an instrument rating. It
seems to me it would be easy to argue potential endangerment in almost
any circumstance involving flight, hence the risk of a 91.13 violation
anytime the FAA decides to go after you, and especially if it is an
issue of judgement or "good practice" rather than a clear violation of
a specific FAR. That's why I think someone would be at risk of a
91.13 violation for flying in conditions conducive to icing, even if
he or she were legal only due to the old age of thier aircraft.

It would be interesting to know what percent of cases involve the
charge of a 91.13 violation, alone and in combination with other FARs,
and in what percent of cases the 91.13 violation was eventually
upheld.

Gary Drescher wrote:
> "Matthew S. Whiting" > wrote in message
> ...
>
>>Gary Drescher wrote:
>>
>>>"Matthew S. Whiting" > wrote in message
...
>>>Are there really any AOMs that refer to "known icing"? The Cessna
>>
> 152/172
>
>>>AOMs I've seen prohibit flight in "known icing conditions". That's most
>>>plausibly parsed as known icing-conditions, that is, known conditions
>>
> that
>
>>>are conducive to icing. So the icing itself doesn't have to be known,
>>
> just
>
>>>the conditions. And a forecast tells you of those conditions.
>>
>>Well, I have no idea what Cessna was thinking or intending when they
>>wrote that,
>
>
> They could certainly have stated it more clearly, I agree.
>
>
>>but, I'd interpret it as known - icing conditions. I don't
>>think parsing it your way is at all the most plausible. It is like
>>saying not to land if it conditions exist that might cause a crosswind
>>in excess of the demonstrated crosswind.
>
>
> It *would* be like saying that if the AOM's demonstrated-crosswind statement
> were a limitation (it's not, at least for 152s and 172s) and, more to the
> point, if it were stated as a prohibition against flying in "known
> excessive-crosswind conditions". Presumably, the other AOM limitations are
> not stated that way precisely because they would then have the wrong
> meaning.
>
>
>>We worry about the actual
>>crosswind, not what might exist. To me, it is much more plausible that
>>they would be consistent with all such limitations and apply them to
>>actual prevailing circumstances, not based on conditions which might
>>lead to such circumstances.
>
>
> First, the very fact that they phrase the icing limitation differently than
> other limitations strongly suggests that they intend something different for
> that one. Second, it's not at all plausible to have a "consistent" response
> to very different sorts of circumstances. There's no reason to prohibit
> landing in conditions that are merely conducive to excessive crosswinds,
> because (even if the demonstrated-crosswind statement were a limitation, and
> even if there were no weather reporting at the destination) it would still
> be reasonable to attempt a landing and find out if the crosswind is in fact
> excessive. If not, the pilot can simply go around and try again, or divert
> to a better-aligned runway. But conditions conducive to icing are usually
> dangerous to probe empirically--by the time you get your answer, you may
> already be in trouble. That's not always the case, but it is the case often
> enough that it's reasonable to prohibit such probes (or at least much more
> reasonable than it would be to prohibit you from probing the crosswind
> conditions).
>
>
>>Just my opinion though, as I said I don't claim to know what Cessna
>
> intended.
>
> Yup, the FARs and AOMs are overdue for a massive rewrite. Maybe by the next
> Centennial. :)

You're an optimist, obviously!

Matt

Mike Rapoport wrote:

> There is no doubt that forecast icing is known icing to the FAA and the
> NTSB. This has been beat to death many times here and in every aviation
> publication.

The problem is (as always) the edge cases:

1. If icing is forecast at 15,000 ft, is flight at 3,000 ft considered a
flight into known icing? What about a flight at 14,000 ft?

2. The U.S. Current Icing Potential is a percentage, not a boolean. Is a
current icing potential of 10% equivalent to known icing? What about 25%?

3. Is VFR flight under a blue sky considered a flight into known icing when
a high probability of icing was forecast at that altitude in that area?
What about VFR under a high overcast with good visibility and no visible
precipitation?

etc.


All the best,


David

"David Megginson" > wrote in message
. cable.rogers.com...
> Mike Rapoport wrote:
>
> > There is no doubt that forecast icing is known icing to the FAA and the
> > NTSB. This has been beat to death many times here and in every aviation
> > publication.
>
> The problem is (as always) the edge cases:
>
> 1. If icing is forecast at 15,000 ft, is flight at 3,000 ft considered a
> flight into known icing? What about a flight at 14,000 ft?
>

Ice is forecast in clouds and precipitation from the freezing level to some
altitude. If you are below the freezing level then you are not in the area
forecast for iciing. This is not an "edge case", the icing is forecast only
at certain altitudes, the area outside of those altitudes has no forecast
for icing.

> 2. The U.S. Current Icing Potential is a percentage, not a boolean. Is a
> current icing potential of 10% equivalent to known icing? What about 25%?
>

Known icing is the area, altitudes and conditions in airmet Zulu. You have
to be within the described area, AND in the described conditions (cloud or
precip), AND between the freezing level and the upper altitude limit. Ice
is not forecast (or possible) if any of the three conditions are not met.

> 3. Is VFR flight under a blue sky considered a flight into known icing
when
> a high probability of icing was forecast at that altitude in that area?

As above the icing is forecast in clouds and precipitiation. It is not
forecast in clear air. It is imposible in clear air.

> What about VFR under a high overcast with good visibility and no visible
> precipitation?
>
This is probably subject to interpretation.

Mike
MU-2

>
> All the best,
>
>
> David
>

Ice is "known" to be present anytime there is visible moisture in the liquid
state and the temp is below freezing. There will ALWAYS be icing under
these conditions. Always, no exceptions.

Mike
MU-2

"Matthew S. Whiting" > wrote in message
...
> Gary Drescher wrote:
> > "Matthew S. Whiting" > wrote in message
> > ...
> >
> >>I think the issue is one of what constitutes known icing. Is it from a
> >>pirep, weather balloon, etc., that has actually seen/encountered the
> >>icing or is a forecast from some weather guy on the ground who thinks
> >>ice might occur sufficient to constitute known icing. Most pilots of
> >>light aircraft know it is both dumb and illegal to fly into a location
> >>where icing is REALLY know to exist. However, to me, a forecast isn't
> >>"known", it is "possible", maybe even "likely", but hardly known.
> >
> >
> > Are there really any AOMs that refer to "known icing"? The Cessna
152/172
> > AOMs I've seen prohibit flight in "known icing conditions". That's most
> > plausibly parsed as known icing-conditions, that is, known conditions
that
> > are conducive to icing. So the icing itself doesn't have to be known,
just
> > the conditions. And a forecast tells you of those conditions.
>
> Well, I have no idea what Cessna was thinking or intending when they
> wrote that, but, I'd interpret it as known - icing conditions. I don't
> think parsing it your way is at all the most plausible. It is like
> saying not to land if it conditions exist that might cause a crosswind
> in excess of the demonstrated crosswind. We worry about the actual
> crosswind, not what might exist. To me, it is much more plausible that
> they would be consistent with all such limitations and apply them to
> actual prevailing circumstances, not based on conditions which might
> lead to such circumstances. Just my opinion though, as I said I don't
> claim to know what Cessna intended.
>
>
> Matt
>

"Bill Zaleski" > wrote in message
...
> Parts produced under an STC do not need PMA approval. Chew on that
> one, Tarver.

Only if the STC holder is a DAS, which is of course Part 21 authority.

> On Wed, 17 Dec 2003 21:56:07 -0800, "Tarver Engineering"
> > wrote:
>
> >
> >"CivetOne" > wrote in message
> ...
> >
> ><snip>
> >> So, my bottom line is that the procedural requirements for obtaining
> >design
> >> approval of either a new design or changes to an existing design are
> >contained
> >> in part 21.
> >
> >For the aircraft's manufacturer.
> >
> >> The design approval, either a TC or an STC, is issued in
> >> accordance with the procedures in part 21.
> >
> >No, the procedures contained in Part 23 are intended to enable a third
party
> >to receive STC Aproval, for a change to a small airplane. From the STC,
> >with a licensing agreement in place, the parts used to make that change
can
> >get PMA aproval.
> >
> >> The airworthiness requirements to
> >> which the design or design change must comply are contained in the
> >> airworthiness standards (e.g., part 23 for small airplanes), or part 21
> >for
> >> unique aircraft (e.g., primary category).
> >
>

Simply not true, John. A DAS must be tied to a repair station. There
are many STC holders that are not repair stations. They still can
produce approved parts without a PMA. The reference is FAR 21.435


On Thu, 18 Dec 2003 07:22:47 -0800, "Tarver Engineering"
> wrote:

>
>"Bill Zaleski" > wrote in message
...
>> Parts produced under an STC do not need PMA approval. Chew on that
>> one, Tarver.
>
>Only if the STC holder is a DAS, which is of course Part 21 authority.
>
>> On Wed, 17 Dec 2003 21:56:07 -0800, "Tarver Engineering"
>> > wrote:
>>
>> >
>> >"CivetOne" > wrote in message
>> ...
>> >
>> ><snip>
>> >> So, my bottom line is that the procedural requirements for obtaining
>> >design
>> >> approval of either a new design or changes to an existing design are
>> >contained
>> >> in part 21.
>> >
>> >For the aircraft's manufacturer.
>> >
>> >> The design approval, either a TC or an STC, is issued in
>> >> accordance with the procedures in part 21.
>> >
>> >No, the procedures contained in Part 23 are intended to enable a third
>party
>> >to receive STC Aproval, for a change to a small airplane. From the STC,
>> >with a licensing agreement in place, the parts used to make that change
>can
>> >get PMA aproval.
>> >
>> >> The airworthiness requirements to
>> >> which the design or design change must comply are contained in the
>> >> airworthiness standards (e.g., part 23 for small airplanes), or part 21
>> >for
>> >> unique aircraft (e.g., primary category).
>> >
>>
>

"Bill Zaleski" > wrote in message
...
> Simply not true, John. A DAS must be tied to a repair station. There
> are many STC holders that are not repair stations.

The Authority to self aprove parts is in CFR 14 Part 21, "DAS"; for an STC
the DAS owns.

> They still can
> produce approved parts without a PMA. The reference is FAR 21.435

Who aproved the parts, if there is no PMA, or TSOA?

Mike Rapoport wrote:
> Ice is "known" to be present anytime there is visible moisture in the liquid
> state and the temp is below freezing. There will ALWAYS be icing under
> these conditions. Always, no exceptions.

Depends on how you interpret icing. I've flown for more than an hour
through ice crystals that were visible in the air, but which did not
accumulate on the airframe of my C-182. If I'm not accumulating ice on
the airframe, I don't consider it to be "icing conditions." Same as
flying through snow. I've flown through snow for literally hours and
never accumulated any on the airframe.


Matt

On Thu, 18 Dec 2003 08:00:45 -0800, "Tarver Engineering"
> wrote:

>
>"Bill Zaleski" > wrote in message
...
>> Simply not true, John. A DAS must be tied to a repair station. There
>> are many STC holders that are not repair stations.
>
>The Authority to self aprove parts is in CFR 14 Part 21, "DAS"; for an STC
>the DAS owns.
>
>> They still can
>> produce approved parts without a PMA. The reference is FAR 21.435
>
>Who aproved the parts, if there is no PMA, or TSOA?


The FAA does, under FAR 21.119 There are 11 ways to produce an
approved part. The PMA process is just one of them. You don't need
to hold a DAS to sell approved parts. You are clouding the issue.
Why can't you stick to one topic? You will gain a better
understanding by not confusing yourself.

I think post this is generally well understood. The question has
always been how to parse the phrase "Known icing conditions". Is it
"(Known icing) conditions" or "Known (icing conditions)". It makes a
huge difference whether its illegal to fly in any thing that is known
to maybe make ice (we understand very little about why ice forms) or
is it ok as long as you know the conditions aren't making ice (i.e.
PIREP).

BTW: Accoring to your FSDO, it is legal for a J-3 cub to fly in "Known
Icing Conditions" because no such limitation exists in its
certification.

-Robert, CFI

"Bill Zaleski" > wrote in message

<snip>
> The FAA does, under FAR 21.119 There are 11 ways to produce an
> approved part. The PMA process is just one of them. You don't need
> to hold a DAS to sell approved parts.

No, you need to have a DAS to self Approve parts.

> You are clouding the issue.
> Why can't you stick to one topic?

All of the thread drift is you, Mr. Zaleski. Once you were wrong about my
initial post to this thread, you have been franticly flailing about wanting
to be right about something.

> You will gain a better
> understanding by not confusing yourself.

I am in the Aproved parts business, you are the only one confused, Mr.
Zaleski.

Please reread the word "liquid".

Mike
MU-2


"Matthew S. Whiting" > wrote in message
...
> Mike Rapoport wrote:
> > Ice is "known" to be present anytime there is visible moisture in the
liquid
> > state and the temp is below freezing. There will ALWAYS be icing under
> > these conditions. Always, no exceptions.
>
> Depends on how you interpret icing. I've flown for more than an hour
> through ice crystals that were visible in the air, but which did not
> accumulate on the airframe of my C-182. If I'm not accumulating ice on
> the airframe, I don't consider it to be "icing conditions." Same as
> flying through snow. I've flown through snow for literally hours and
> never accumulated any on the airframe.
>
>
> Matt
>

"Robert M. Gary" > wrote in message
om...
> I think post this is generally well understood. The question has
> always been how to parse the phrase "Known icing conditions". Is it
> "(Known icing) conditions" or "Known (icing conditions)". It makes a
> huge difference whether its illegal to fly in any thing that is known
> to maybe make ice (we understand very little about why ice forms) or
> is it ok as long as you know the conditions aren't making ice (i.e.
> PIREP).
>
> BTW: Accoring to your FSDO, it is legal for a J-3 cub to fly in "Known
> Icing Conditions" because no such limitation exists in its
> certification.

And you used to be able to buy cigarretes without a warning label, it didn't
make smoking safe.

Mike Rapoport wrote:
> Please reread the word "liquid".
>
> Mike
> MU-2
>
>
> "Matthew S. Whiting" > wrote in message
> ...
>
>>Mike Rapoport wrote:
>>
>>>Ice is "known" to be present anytime there is visible moisture in the
>>
> liquid
>
>>>state and the temp is below freezing. There will ALWAYS be icing under
>>>these conditions. Always, no exceptions.
>>
>>Depends on how you interpret icing. I've flown for more than an hour
>>through ice crystals that were visible in the air, but which did not
>>accumulate on the airframe of my C-182. If I'm not accumulating ice on
>>the airframe, I don't consider it to be "icing conditions." Same as
>>flying through snow. I've flown through snow for literally hours and
>>never accumulated any on the airframe.
>>
>>
>>Matt

Gotcha, however, I don't think that is the criterion the NWS uses when
making forecasts of icing conditions. If it is, I'm impressed.
Certainly hasn't been my experience in the northeast during the winter
months.


Matt

The existance of moisture in the liquid state is, of course, the heart of
the problem. Since liquid water is unstable below 0C it will always be
somewhat hit and miss but my own experience is that if there is any lifting
activity then there will be ice in the (cumulus type) clouds. Also any
clouds with "hard" (as opposed to feathered) edges are full of ice.

Mike
MU-2

edges "Matthew S. Whiting" > wrote in message
...
> Mike Rapoport wrote:
> > Please reread the word "liquid".
> >
> > Mike
> > MU-2
> >
> >
> > "Matthew S. Whiting" > wrote in message
> > ...
> >
> >>Mike Rapoport wrote:
> >>
> >>>Ice is "known" to be present anytime there is visible moisture in the
> >>
> > liquid
> >
> >>>state and the temp is below freezing. There will ALWAYS be icing under
> >>>these conditions. Always, no exceptions.
> >>
> >>Depends on how you interpret icing. I've flown for more than an hour
> >>through ice crystals that were visible in the air, but which did not
> >>accumulate on the airframe of my C-182. If I'm not accumulating ice on
> >>the airframe, I don't consider it to be "icing conditions." Same as
> >>flying through snow. I've flown through snow for literally hours and
> >>never accumulated any on the airframe.
> >>
> >>
> >>Matt
>
> Gotcha, however, I don't think that is the criterion the NWS uses when
> making forecasts of icing conditions. If it is, I'm impressed.
> Certainly hasn't been my experience in the northeast during the winter
> months.
>
>
> Matt
>
>
>

You can't spell approved, but you are in that business, eh? The
holder of an STC has the approval to produce and sell parts used in
that STC. He does not have to hold a DAS. The STC method of parts
production is a much less painful way vs. the PMA route, and is used
quite often to avoid having to comply with the added QC of the PMA
process. But of course you know that John, being in the "Aproved
parts business". I gave you the cite and you ignored it. You quote
things that are not supported by FAR's . Why don't you quit
generalizing and cite some accurate references that are on point?

Never mind, I have no more time to dwell on this. Have a nice day.


On Thu, 18 Dec 2003 09:19:34 -0800, "Tarver Engineering"
> wrote:

>
>"Bill Zaleski" > wrote in message
>
><snip>
>> The FAA does, under FAR 21.119 There are 11 ways to produce an
>> approved part. The PMA process is just one of them. You don't need
>> to hold a DAS to sell approved parts.
>
>No, you need to have a DAS to self Approve parts.
>
>> You are clouding the issue.
>> Why can't you stick to one topic?
>
>All of the thread drift is you, Mr. Zaleski. Once you were wrong about my
>initial post to this thread, you have been franticly flailing about wanting
>to be right about something.
>
>> You will gain a better
>> understanding by not confusing yourself.
>
>I am in the Aproved parts business, you are the only one confused, Mr.
>Zaleski.
>

"Bill Zaleski" > wrote in message
...

<snip>
> But of course you know that John, being in the "Aproved
> parts business". I gave you the cite and you ignored it.

Dude, head somplace else to troll CFR 14.

The FAA reply starting this thread illustrates one of the many frustrations I
have with the FAA. Given a very specific question, they responded with some
generalities and then sidestepped the answer. They also completely ignored
other implied parts of the question.

If there is NO PROHIBITION ANYWHERE for a specific aircraft, say because it was
grandfathered, then is it prohibited from flying legally in known icing? What
is the FAA's take on using the "careless and reckless" rule in this case?

There are no noises in this letter from the FAA about that. Thus, Steven P.
McNicoll and I will continue to disagree on whether or not it's legal (in most
cases).

Nothing like possibly a definate maybe from the folks that make the rules.

Jose

--
(for Email, make the obvious changes in my address)

I just, within the hour, was introduced to the "Tarver cronicles".
Had I known what your previous experience with dealing with rather
well known aviation issues was, I would have not wasted the bandwidth
trying to communicate with you. It seems that your primary goal as a
poster is to argue and bash. I have better things to do, John. You
never try to educate or explain. Just confuse and argue. I wish I
knew this a couple of posts earlier. Live and learn. If I am guilty
of trolling, so is everyone who tries to inform on this ng.


On Thu, 18 Dec 2003 15:04:10 -0800, "Tarver Engineering"
> wrote:

>
>"Bill Zaleski" > wrote in message
...
>
><snip>
>> But of course you know that John, being in the "Aproved
>> parts business". I gave you the cite and you ignored it.
>
>Dude, head somplace else to troll CFR 14.
>

"Bill Zaleski" > wrote in message
...
> I just, within the hour, was introduced to the "Tarver cronicles".

That is an extensive archive troll and you should find it to be identical to
your own cluelessness, Bill.

Literal-retentive, I think.

"Matthew S. Whiting" > wrote in message
...
> C J Campbell wrote:
> > "Matthew S. Whiting" > wrote in message
> > ...
> >
> > |
> > | You might be legal, but you'd also be a test pilot. They might throw
> > | the book at you for impersonating a test pilot ... unless, that is,
you
> > | ARE a test pilot. :-)
> > |
> >
> > What FAR spells out the requirements for certification of a test pilot?
> >
> >
>
> None that I'm aware of. Looks like you didn't catch the tongue-in-cheek
> nature of my comment either. I thought the smiley would give it away
> for sure. I guess some folks here are just too literal...
>
> Matt
>

"Gary Drescher" > wrote in
news:bphEb.420856$275.1299498@attbi_s53:

<snip>

> Yup, the FARs and AOMs are overdue for a massive rewrite. Maybe by the
> next Centennial. :)


Perhaps complete elimination would solve the problem!

>
>
>"CivetOne" > wrote in message
...
>
><snip>
>> So, my bottom line is that the procedural requirements for obtaining
>design
>> approval of either a new design or changes to an existing design are
>contained
>> in part 21.
>
>For the aircraft's manufacturer.
>
>> The design approval, either a TC or an STC, is issued in
>> accordance with the procedures in part 21.
>
>No, the procedures contained in Part 23 are intended to enable a third party
>to receive STC Aproval, for a change to a small airplane. From the STC,
>with a licensing agreement in place, the parts used to make that change can
>get PMA aproval.
>
>> The airworthiness requirements to
>> which the design or design change must comply are contained in the
>> airworthiness standards (e.g., part 23 for small airplanes), or part 21
>for
>> unique aircraft (e.g., primary category).

I must respectfully disagree with your statement that the procedures contained
in part 23 are intended to enable a third party to receive STC approval. The
procedures are not in part 23, but in part 21. To support my statement, let me
quote directly from 14 CFR part 21:

§ 21.111 Applicability.
This subpart prescribes procedural requirements for the issue of
supplemental type certificates.

§ 21.113 Requirement of supplemental type certificate.
Any person who alters a product by introducing a major change in type
design, not great enough to require a new application for a type
certificate under § 21.19, shall apply to the Administrator for a supplemental
type certificate, except that the holder of a type certificate for the
product may apply for amendment of the original type certificate. The
application must be made in a form and manner prescribed by the
Administrator.

§ 21.115 Applicable requirements.
(a) Each applicant for a supplemental type certificate must show that the
altered product meets applicable requirements specified in § 21.101
and, in the case of an acoustical change described in § 21.93(b), show
compliance with the applicable noise requirements of part 36 of
this chapter and, in the case of an emissions change described in § 21.93(c),
show compliance with the applicable fuel venting and exhaust emissions
requirements of part 34 of this chapter.
(b) Each applicant for a supplemental type certificate must meet §§ 21.33
and 21.53 with respect to each change in the type design.

§ 21.117 Issue of supplemental type certificates.
(a) An applicant is entitled to a supplemental type certificate if he meets
the requirements of §§ 21.113 and 21.115.
(b) A supplemental type certificate consists of -
(1) The approval by the Administrator of a change in the type design of
the product; and
(2) The type certificate previously issued for the product.

The § 21.101 rule mentioned in § 21.115(a) prescribes the applicable
airworthiness rules. In our example, the prescribed rules would be found in
part 23. There are no provisions for issuance of STCs or PMAs in part 23.

Cheers,

Gordon.

"Bill Zaleski" > wrote in message
...
> You can't spell approved, but you are in that business, eh? The
> holder of an STC has the approval to produce and sell parts used in
> that STC. He does not have to hold a DAS. The STC method of parts
> production is a much less painful way vs. the PMA route, and is used
> quite often to avoid having to comply with the added QC of the PMA
> process. But of course you know that John, being in the "Aproved
> parts business". I gave you the cite and you ignored it. You quote
> things that are not supported by FAR's . Why don't you quit
> generalizing and cite some accurate references that are on point?
>
> Never mind, I have no more time to dwell on this. Have a nice day.

Bill, you remind me of the ****house lawyers (read: defendants) I used to
see that tried to tell the JUDGE what the law said.

"CivetOne" > wrote in message
...

<snip>
> The § 21.101 rule mentioned in § 21.115(a) prescribes the applicable
> airworthiness rules. In our example, the prescribed rules would be found
in
> part 23. There are no provisions for issuance of STCs or PMAs in part 23.

The only thing Part 23 is about is STCs. In fact, that is the title of Part
23.

"Matthew S. Whiting" > wrote in message
...
| C J Campbell wrote:
| > "Matthew S. Whiting" > wrote in message
| > ...
| >
| > |
| > | You might be legal, but you'd also be a test pilot. They might throw
| > | the book at you for impersonating a test pilot ... unless, that is,
you
| > | ARE a test pilot. :-)
| > |
| >
| > What FAR spells out the requirements for certification of a test pilot?
| >
| >
|
| None that I'm aware of. Looks like you didn't catch the tongue-in-cheek
| nature of my comment either. I thought the smiley would give it away
| for sure. I guess some folks here are just too literal...
|

The response was in the same spirit as your post.

"Tarver Engineering" wrote
> The only thing Part 23 is about is STCs.
> In fact, that is the title of Part 23.


Title 14--Aeronautics and Space
CHAPTER I--FEDERAL AVIATION ADMINISTRATION, DEPARTMENT OF
TRANSPORTATION
Part 23: Airworthiness standards: Normal, utility, acrobatic, and
commuter category airplanes

Section 23.1: Applicability.
(a) This part prescribes airworthiness standards for the issue of
type certificates, and changes to those certificates, for airplanes
in the normal, utility, acrobatic, and commuter categories.

(b) Each person who applies under Part 21 for such a certificate or
change must show compliance with the applicable requirements of this
part.


Ah well.............

Bob

"Mike Rapoport" > wrote in message et>...
> Ice is "known" to be present anytime there is visible moisture in the liquid
> state and the temp is below freezing. There will ALWAYS be icing under
> these conditions. Always, no exceptions.
>

I"m not sure at what point you consider clouds to be liquid versus gas
(vapor). I've often flown in the clouds at -5C without picking up any
ice. I've also flown in the same looking clouds and did pick up ice. I
still believe that there is a lot yet to learn about predicting ice.
It seems like you are many times more likely to pick up ice in
cumulous clouds than stratus (from practical experience). It also
seems like stratus usually only make ice near the top. Richard Collins
has often written on the continuing research the gov't is doing trying
to better predict when ice will occur.

-Robert

"Mike Rapoport" > wrote in message et>...
> "David Megginson" > wrote in message
> . cable.rogers.com...
> > Mike Rapoport wrote:
> >
> > > There is no doubt that forecast icing is known icing to the FAA and the
> > > NTSB. This has been beat to death many times here and in every aviation
> > > publication.
> >
> > The problem is (as always) the edge cases:
> >
> > 1. If icing is forecast at 15,000 ft, is flight at 3,000 ft considered a
> > flight into known icing? What about a flight at 14,000 ft?
> >
>
> Ice is forecast in clouds and precipitation from the freezing level to some
> altitude. If you are below the freezing level then you are not in the area
> forecast for iciing. This is not an "edge case", the icing is forecast only
> at certain altitudes, the area outside of those altitudes has no forecast
> for icing.

But often you can fly at that altitude in the clouds and get nothing.
The research contiues....

"Robert M. Gary" > wrote in message
om...
> "Mike Rapoport" > wrote in message
et>...
> > "David Megginson" > wrote in message
> > . cable.rogers.com...
> > > Mike Rapoport wrote:
> > >
> > > > There is no doubt that forecast icing is known icing to the FAA and
the
> > > > NTSB. This has been beat to death many times here and in every
aviation
> > > > publication.
> > >
> > > The problem is (as always) the edge cases:
> > >
> > > 1. If icing is forecast at 15,000 ft, is flight at 3,000 ft considered
a
> > > flight into known icing? What about a flight at 14,000 ft?
> > >
> >
> > Ice is forecast in clouds and precipitation from the freezing level to
some
> > altitude. If you are below the freezing level then you are not in the
area
> > forecast for iciing. This is not an "edge case", the icing is forecast
only
> > at certain altitudes, the area outside of those altitudes has no
forecast
> > for icing.
>
> But often you can fly at that altitude in the clouds and get nothing.
> The research contiues....

True. I was merely defining the area (horizontal and vertical) which was
considered to be known icing.

Mike
MU-2

C J Campbell wrote:
> "Matthew S. Whiting" > wrote in message
> ...
> | C J Campbell wrote:
> | > "Matthew S. Whiting" > wrote in message
> | > ...
> | >
> | > |
> | > | You might be legal, but you'd also be a test pilot. They might throw
> | > | the book at you for impersonating a test pilot ... unless, that is,
> you
> | > | ARE a test pilot. :-)
> | > |
> | >
> | > What FAR spells out the requirements for certification of a test pilot?
> | >
> | >
> |
> | None that I'm aware of. Looks like you didn't catch the tongue-in-cheek
> | nature of my comment either. I thought the smiley would give it away
> | for sure. I guess some folks here are just too literal...
> |
>
> The response was in the same spirit as your post.
>
>

But you forgot the smiley! :-)

Matt

Robert M. Gary wrote:
> "Mike Rapoport" > wrote in message et>...
>
>>Ice is "known" to be present anytime there is visible moisture in the liquid
>>state and the temp is below freezing. There will ALWAYS be icing under
>>these conditions. Always, no exceptions.
>>
>
>
> I"m not sure at what point you consider clouds to be liquid versus gas
> (vapor). I've often flown in the clouds at -5C without picking up any
> ice. I've also flown in the same looking clouds and did pick up ice. I
> still believe that there is a lot yet to learn about predicting ice.
> It seems like you are many times more likely to pick up ice in
> cumulous clouds than stratus (from practical experience). It also
> seems like stratus usually only make ice near the top. Richard Collins
> has often written on the continuing research the gov't is doing trying
> to better predict when ice will occur.

Yes, pretty hard to size water "droplets" when they are submillimeter to
micron sizes. That's why I advocate allowing the pilot the latitude to
take a look and make the call in real-time. Same as judging visibility
on an ILS. It is what it is when you are there, not what someone on the
ground things it is.


Matt

"Robert Moore" > wrote in message
. 6...
> "Tarver Engineering" wrote
> > The only thing Part 23 is about is STCs.
> > In fact, that is the title of Part 23.
>
>
> Title 14--Aeronautics and Space
> CHAPTER I--FEDERAL AVIATION ADMINISTRATION, DEPARTMENT OF
> TRANSPORTATION
> Part 23: Airworthiness standards: Normal, utility, acrobatic, and
> commuter category airplanes

Yes, Bob, soon Part 21 will be re-written. Perhaps it will not be the same
as when Part 145 can of worms was opened up and all the worms had babies. :)

"Tom Fleischman" > wrote in message
rthlink.net...
> In article >, Tarver Engineering
> > wrote:
>
> > "Bill Zaleski" > wrote in message
> > ...
> > > I just, within the hour, was introduced to the "Tarver cronicles".
> >
> > That is an extensive archive troll and you should find it to be
identical to
> > your own cluelessness, Bill.

> Why don't you two go get a room and be done with it.

What do you think, Bill, do you want to suck my dick?

"Matthew S. Whiting" > wrote in message >...
> Robert M. Gary wrote:
> > "Mike Rapoport" > wrote in message et>...
> Yes, pretty hard to size water "droplets" when they are submillimeter to
> micron sizes. That's why I advocate allowing the pilot the latitude to
> take a look and make the call in real-time. Same as judging visibility
> on an ILS. It is what it is when you are there, not what someone on the
> ground things it is.

I 100% agree with you. This modern FAA attitude of "you will burst
into flames if a piece of ice gets on your plane" is probably not
helping anyone other than to keep IFR pilots on the ground on days
when ice can still be avoided. I'm not discounting the dangers of ice
and I would never just hang out in it but I agree that pilot's should
have more latitude.

-Robert

"Tarver Engineering" > wrote in message >...
> "Robert M. Gary" > wrote in message
> om...

> And you used to be able to buy cigarretes without a warning label, it didn't
> make smoking safe.

I'm just waiting for the day when a new Chevy will have a placard
saying, "Warning, operation of this vehicle may cause death or bodily
injury".