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 letteris a follow-up response to the Office ofRulemaking's (ARM) letter dated June 10, 2016. ARM responded to your January 13, 2016 comment, postedto the public docket (No. FAA-2016-0886), petitioning the Federal AviationAdministration (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 thatthe issues youraised do not meet the criteriato pursue rulemaking. ARM's letter explained its determination was based onthe guidelines found in Title 14, Code ofFederal 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 CFRto amend. The Pilot's Handbook ofAeronautical Knowledge and the Aircraft Weight and Balance Handbook, along with all other handbooks, are guidance material. In view ofthis 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 ofAeronautical Knowledge (FAA-H-8083-25A) andthe Aircraft Weight and Balance Handbook (FAA-H-8083-lA) contain several methods for performing Weight and Balance. For instance, inthe Pilot's Handbook ofAeronautical Knowledge, there are ti1!'ee methods mentioned onpages 9-7 through 9-11; the Computational Method, the Graph Method, and the Table Method. However, all ofthese methods are based ontechnologies 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).
FAAAnalysis: Inconsidering your request, AFS-800 determined that thetransition youpropose does not serve the public interest because it would eliminate established methods contained within our guidance, which provide unique benefits to the enduser. 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 ofthe complete process. Instructors generallyuse this method to teach individuals the basic elements needed to gain a full understanding ofthe actual gross weight ofan aircraft in comparison to the aircraft's weight2
limitation, and the actual center ofgravity (CG) in comparison to the CG limit. Many airplane manufacturers provide the Table or Graph Method to its customers as the method ofchoice for calculating its airplane's W&B (proprietary airplane). The Table Method eliminates the needto
use multiplication and division due to the use ofa series oftables. The Graph Method is similar to the Table Method and only needs an addition oftwo graphs. Hence, manufacturers continue to provide these methods inmodemairplane 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 SpreadsheetMethod that youpropose is an automated version ofthe ComputationMethod. In advocating the sole use ofthis method, you state: Today, in2015, we have an advanced computational method referr-ed to as the "Spreadsheet Method". Here, all possible needs can be met. The SpreadsheetMethod needs only inputs that outputs longitudinal CG and, ifneeded, lateral Center ofGravity calculations. In addition, ifPercentage ofMeanAerodynamic Chord calculations are needed, it wouldbe practicalto do those calculations within a spreadsheet. All CG and Weight calculations are bestperformed 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 inyour petition have merit. The FAA understands the efficiency ofthe Spreadsheet Method. The FAA also understands that many airmen use this automated methodto calculate aircraft W&B. Yet, the Spreadsheet method maynot meet "allpossible needs" as you contend. For example:

• The SpreadsheetMethod requires the use ofan automated device that may not always be available;
• Not all airmenpossess an automated device and/or the skills needed to use it;
• Ifthe 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 leamingthe 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 exclusivetransition to the SpreadsheetMethodfor preforming and teaching W&B is not inthe 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 youhave any additional questions regarding this issue, please contactMr. Allan Kash in the Ainnan Training and CertificationBranch (AFS-810) via email at allan.g.kash@faa.gov or by phone, (202) 267-1100. Sincerely, 

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# f'll--" James A. Viola Manager, General Aviation and Commercial Division Flight Standards Service