Safety Recommendation a-82-025
Details
Synopsis: ON MAY 2, 1980, A MCDONNELL DOUGLAS CORPORATION DC-9-30, N980DC, WAS DAMAGED SUBSTANTIALLY DURING A LANDING ON RUNWAY 22 AT EDWARDS AIR FORCE BASE, CALIFORNIA. THE ACCIDENT OCCURRED DURING A LANDING IN WHICH THE FLIGHTCREW WAS USING PROCEDURES ESTABLISHED FOR THE OFFICIAL CERTI FICATION TEST TO DETERMINE THE HORIZONTAL DISTANCE REQUIRED TO LAND AND BRING THE AIRPLANE TO A FULL STOP AS REQUIRED BY 14 CFR 25.125.
Recommendation: THE NTSB RECOMMENDS THAT THE FEDERAL AVIATION ADMINISTRATION: UPON ADOPTION OF REVISED PROCEDURES FOR DEMONSTRATING OPERATIONAL LANDING DISTANCES FOR COMPLIANCE WITH 14 CFR 25.125, REVIEW THE OPERATIONAL RUNWAY LENGTH LIMITATIONS IN 14 CFR 121.195 WHICH ARE APPLIED TO CERTIFICATION LANDING DISTANCES SO THAT THEY DO NOT UNJUSTIFIABLY PENALIZE THE OPERATIONAL SPECIFICATIONS OF AIRPLANES.
Original recommendation transmittal letter: PDF
Overall Status: Closed - Unacceptable Action
Mode:
Location: Edwards Afb, CA, United States
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: LAX80FA092
Accident Reports:
Report #: AAR-82-02
Accident Date: 5/2/1980
Issue Date: 3/5/1982
Date Closed: 6/7/1985
Addressee(s) and Addressee Status: FAA (Closed - Unacceptable Action)
Keyword(s):

Safety Recommendation History
From: NTSB
To: FAA
Date: 6/7/1985
Response: We have reviewed the November 1, 1984, draft of a proposed Advisory Circular "Flight Test Guide for Certification of Transport Category Airplanes" relating to the demonstration of landing distance and its applicability to establishing operational limitations. We agree that the procedures which are proposed and which already have been used in the certification of the newest transport airplanes provide an enhanced level of safety in the certification flight test program. The revised procedures, however, do not satisfy the intent of part (b) of Safety Recommendation A-82-24 which addresses the unrealistic nature of landing distance data which results from the disparity between certification procedures and safe operational practices. The proposed procedures which permit extrapolation of demonstration data recognize that the certification data cannot be applied safely to actual flight capabilities. The Safety Board acknowledges that the safety margins applied to the certification data by the operational requirements of 14 CFR 121 have proven adequate in service. However, the Safety Board notes that airplanes certificated to the transport category requirements can be operated under 14 CFR 91 and that the pilots involved in such operations must be provided realistic landing distance data. Further, the Safety Board notes that the proposed procedures for landing distance determination conflict with the requirements stated in 25.101(1). Therefore, the revised procedures for determining landing distances only partially meet the intent of the Safety Board's recommendations. Since these revised procedures have become FAA certification policy and were used on two recent certification test programs, and will soon be used on a third, both recommendations are classified as "Closed--Unacceptable Action" status.

From: FAA
To: NTSB
Date: 9/19/1984
Response: FAA LETTER: AS NOTED IN OUR PREVIOUS RESPONSE TO RECOMMENDATION A-82-25, THERE IS GENERAL AGREEMENT WITHIN THE FAA AND THE INDUSTRY GROUPS WHICH HAVE REVIEWED THIS ENCLOSED DRAFT REVISION THAT THE PRESENT 14 CFR PART 121.195 LANDING DISTANCE FIELD LENGTHS ARE ACCEPTABLE. THE PROPOSED CHANGE TO THE FLIGHT TEST GUIDE DISCUSSED IN OUR RESPONSE TO RECOMMENDATION A-82-24 SHOULD NOT RESULT IN SUBSTANTIAL CHANGES IN LANDING FIELD LENGTHS. ONLY THE METHOD OF DETERMINING THE AIR DISTANCE, FROM 50 FEET ABOVE THE LANDING SURFACE TO THE POINT OF TOUCHDOWN, WOULD BE AFFECTED. THE RESULTING CHANGES IN FEDERAL AVIATION REGULATION FIELD LENGTHS SHOULD BE MINIMAL. WE WILL PROVIDE THE BOARD A COPY OF THE REVISED ENGINEERING FLIGHT TEST GUIDE FOR TRANSPORT CATEGORY AIRPLANES WHICH WE ANTICIPATE WILL BE AVAILABLE BEFORE APRIL 1, 1985.

From: NTSB
To: FAA
Date: 2/2/1983
Response: We are pleased to be informed that a proposed change to the Engineering Flight Guide for Transport Category Airplanes, FAA Order 8110.8, has been circulated within the FAA for review and coordination. We thank you for your offer to keep the Safety Board informed of significant progress. These recommendations remain in an "Open-- Acceptable Action" status.

From: FAA
To: NTSB
Date: 11/22/1982
Response: FAA LTR: THE FAA'S TRANSPORT AIRPLANE CERTIFICATION DIRECTORATE HAS BEEN REVIEWING THE CERTIFICATION POLICIES RELATED TO THE AIR PHASE OF LANDING DISTANCE DETERMINATION. A PROPOSED CHANGE TO THE ENGINEERING FLIGHT TEST GUIDE FOR TRANSPORT CATEGORY AIRPLANES, FAA ORDER 8110.8, HAS BEEN CIRCULATED WITHIN THE FAA FOR REVIEW AND COORDINATION. WHEN THIS INTERNAL FAA COORDINATION IS COMPLETED, THE PROPOSED CHANGE WILL BE RELEASED FOR REVIEW AND COMMENT BY VARIOUS INDUSTRY ORGANIZATIONS PRIOR TO ISSUANCE IN ITS FINAL FORM.

From: NTSB
To: FAA
Date: 9/30/1982
Response: Your review of all policies relating to the air phase of landing distances, and your proposal to revise the method by which the air phase of the landing distance is determined, fulfill the intent of the recommendation. Therefore, A-82-24 has been classified as "Open--Acceptable Action" pending completion of your review and the implementation of revisions to the procedures which are currently being used to demonstrate landing distances.

From: FAA
To: NTSB
Date: 5/19/1982
Response: FAA LTR: THERE IS A GENERAL AGREEMENT WITHIN THE FAA THAT THE LANDING DISTANCE FIELD LENGTHS ADDRESSED IN 14 CFR 121.195 ARE ACCEPTABLE. THE FAA PROPOSAL TO REVISE THE METHOD BY WHICH THE AIR PHASE OF THE LANDING DISTANCE IS DETERMINED, AS DISCUSSED IN OUR RESPONSE TO SAFETY RECOMMENDATION A-80-24, SHOULD NOT RESULT IN SUBSTANTIAL CHANGES IN FIELD LENGTHS. ONLY THE METHOD OF DETERMINING THE AIR DISTANCE, FROM 50 FEET ABOVE THE LANDING SURFACE TO THE POINT OF TOUCHDOWN, WOULD BE AFFECTED. THE RESULTING CHANGES IN 14 CFR 121.195 FIELD LENGTHS SHOULD BE MINIMAL.