U.S. Department 

of Transportation 

Federal Aviation 

Administration 

JUN 24 2016 

Mr. David K. Campbell 

PO Box 402 

Tucker, GA 30085-0402 

Dear Mr. Campbell: 

800 Independence Ave., S.W. 

Washington, DC 20591 

This letter is a follow-up response to the Office of Rulemaking's (ARM) letter dated June 10, 

2016. ARM responded to your January 13, 2016 comment, posted to the public docket (No. 

F AA-2016-0886), petitioning the Federal Aviation Administration (FAA) to" ... help transition 

the way that aircraft weight and balance is performed and taught now." 

Background: The Office ofRulemaking (ARM) reviewed your request and determined that the 

issues you raised do not meet the criteria to pursue rulemaking. ARM's letter explained its 

determination was based on the guidelines found in Title 14, Code of Federal Regulations (14 

CFR), part 11. Thus, ARM closed your petition for rulemalcing, in accordance with 14 CFR 

section(§) 11.73. ARM also noted that there are no pertinent regulations within 14 CFR to 

amend. The Pilot's Handbook of Aeronautical Knowledge and the Aircraft Weight and Balance 

Handbook, along with all other handbooks, are guidance material. In view of this fact, ARM 

referred your request to the General Aviation and Commercial Division (AFS-800) to consider 

your suggestions for changes to FAA guidance publications. 

In your petition for rulemaking, you state: 

Currently, the Pilot's Handbook of Aeronautical Knowledge (F AA-H-8083-25A) and the 

Aircraft Weight and Balance Handbook (FAA-H-8083-lA) contain several methods for 

performing Weight and Balance. For instance, in the Pilot's Handbook of Aeronautical 

Knowledge, there are ti1!'ee methods mentioned on pages 9-7 through 9-11; the 

Computational Method, the Graph Method, and the Table Method. However, all of these 

methods are based on technologies that existed in the 1940s. The Graph Method and Table 

Method come from an era when slide rules were used as calculating tools. 

As a ±light instructor, you advocate for a more advanced method, the Spreadsheet Method, to 

preform and teach aircraft weight and balance (W&B). 

FAA Analysis: In considering your request, AFS-800 determined that the transition you propose 

does not serve the public interest because it would eliminate established methods contained 

within our guidance, which provide unique benefits to the end user. For example, the 

Computational Method is the basis for all W &B computations. Airmen involved in calculating 

an aircraft's W &B need to understand the fundamentals of the complete process. Instructors 

generally use this method to teach individuals the basic elements needed to gain a full 

understanding of the actual gross weight of an aircraft in comparison to the aircraft's weight 
2 

limitation, and the actual center of gravity (CG) in comparison to the CG limit. Many airplane 

manufacturers provide the Table or Graph Method to its customers as the method of choice for 

calculating its airplane's W&B (proprietary airplane). The Table Method eliminates the need to 

use multiplication and division due to the use of a series of tables. The Graph Method is similar 

to the Table Method and only needs an addition of two graphs. Hence, manufacturers continue to 

provide these methods in modem airplane flight manuals (AFM),. These methods of calculating 

W &B provide reliable results, promote knowledge transfer, and are still widely used as the 

chosen methods for preforming and teaching aircraft W &B, 

The Spreadsheet Method that you propose is an automated version of the Computation Method. 

In advocating the sole use of this method, you state: 

Today, in 2015, we have an advanced computational method referr-ed to as the "Spreadsheet 

Method". Here, all possible needs can be met. The Spreadsheet Method needs only inputs 

that outputs longitudinal CG and, if needed, lateral Center of Gravity calculations. In 

addition, if Percentage of Mean Aerodynamic Chord calculations are needed, it would be 

practical to do those calculations within a spreadsheet. All CG and Weight calculations are 

best performed in a spreadsheet that allows entries to be checked instantly for possible en-or. 

The FAA agrees that your comments and arguments for the proposed change in your petition 

have merit. The FAA understands the efficiency of the Spreadsheet Method. The FAA also 

understands that many airmen use this automated method to calculate aircraft W &B. Yet, the 

Spreadsheet method may not meet "all possible needs" as you contend. For example: 

• The Spreadsheet Method requires the use of an automated device that may not always be 

available; 

• Not all airmen possess an automated device and/or the skills needed to use it; 

• If the automation fails, an alternative method to calculate W &B is needed; and 

• To learn and prefmm W &B effectively, students and stakeholder need to understand the 

entire concept, which generally involves leaming the Computational Method. 

Determination: For the reasons above, and because manufacturers and stakeholders continue to 

find the Computational Method, the Graph Method, and the Table Method beneficial, the FAA 

dete1mined that supporting an exclusive transition to the Spreadsheet Method for preforming and 

teaching W &B is not in the public interest. However, we will place your comments and 

arguments for the proposed change in our database, which we will examine when we consider 

any future updates to pertinent guidance publications. 

Should you have any additional questions regarding this issue, please contact Mr. Allan Kash in 

the Ainnan Training and Certification Branch (AFS-81 0) via email at allan.g.kash@faa.gov or 

by phone, (202) 267-1100. 

Sincerely, 

I • r:L. tu \j c.( ~ ?:::,~ f'll--" James A. Viola 

Manager, General Aviation and Commercial Division 

Flight Standards Service