FAA-Approval of New Program Required by June 12
FAA Advisory Circular 120-27F, released in 2019, provides operators with guidance on aircraft weight and balance programs. Changes related to the use of average weights within the AC and the subsequent guidance to inspectors in Notice 8900.551, have proved challenging for many operators to implement.
All part 135 carriers currently using an average weights program with Operations Specification A096, A097 or A099 should already be in the process of working with their POI on program revisions necessary to obtain an amended OpSpec.
NATA has aided several members who encountered problems conforming to the new guidance, particularly as it relates to average baggage weights. It appears there is also a lack of education among some FAA inspectors who are unaware that they are expected to interface with each Part 135 operator to ensure their program complies and reissue the appropriate amended OpSpec.
By June 12, 2021 every operator that has not received an amended OpSpec must use Actual Weights when determining weight and balance.
If your POI has not yet notified you of this change, immediately contact him/her to initiate the process to ensure you may continue to have an average weight program.
Once you have completed your amended weight and balance program and provided it to your POI, the program will then move to FAA headquarters for their approval.
Operators should carefully review the AC and Notice as there are extensive changes to procedures.
Key factors operators should keep in mind when crafting their program:
· Actual crew members weights will be used
· It is preferred to use CDC average weights for passengers
· Baggage weights are either actual weight or an average weight determined by an operator-specific bag survey
· If using actual bag weights, remember that all scales require calibration.
The conduct of a survey to determine an operator’s approved average bag weight has been the greatest challenge presented by the program changes. In assisting members through this process, NATA has found that:
· A carrier can reduce the number of bags in the survey size. The carrier will need to justify a reduction from the 1,400 bags called for in the AC.
· The FAA will insist upon curtailments to ensure safety is maintained.
· Data from last year or a forecast for the coming year can be used. See example.
Example facts to support a reduction in baggage count for survey:
· Forecast 625 flights in the next 12 months
· Average number of passengers is 4
· Average number of seats available is 12
· Clientele are business and family
Average numbers of bags forecasted for next 12 months are 900 checked, 1400 personnel items and zero carry-on bags. Based on this 12-month forecast, a survey count of 1400 bags is improbable/impossible to obtain.
NATA members having trouble may contact Keith DeBerry Senior Advisor, Regulatory Affairs for assistance.