Petition for Rulemaking: Removal of F/A - 18 from list of aircraft

“Limited - to - Center Thrust ” . Introduction FAA order 8900.1 Volume 5, Section 4, item 5 - 88 lists the F/A - 18 as an aircraft in which a military pilot may only receive a multiengine operator or i nstructor rating “Limited - to - Center Thrust”. The reason stated is that “no published data on V MC ” has been provided by the manufacturer. As a n active test pilot with a Specialized Master’s degree in Experimental Flight Test Engineering, I intend to show through flight manual excerpts that the F/A - 18 not only has published VMC data, but that it is a suitable platform in which to conduct a multiengine practical test with respect to VMC tasks in accordance with 14 CFR Part 61.45 and the Pra c tical Test Standa rds . The intent of this petition is to allow military qualification in the F/A - 18 to transfer to an unrestricted multiengine qualification at the commercial pilot and instructor level. VMC D efined First, I will show that the NATOPS flight manual for F/A - 1 8, A1 - F18EA NFM - 000, clearly defines single engine minimum control speed (V MC ) in keeping with the intentions of 14 CFR P art 23.149 . Chapter 11: Flight Characteristics states: “ Single engine minimum control speed ( VMC ) is defined as the minimum airspeed r equired to maintain controlled flight with one engine operating. V MC airspeeds were determined at 14° AOA (angle of attack) for catapult launches, and 12° AOA for all other circumstances. V MC airspeed varies depending on AOA, lateral asymmetry, altitude, and day temperature.” Further along in the flight manual under the disc ussion of shipboard emergencies: “Catapult launch bulletins ensure an end - speed at least 15 knots above minimum controllable airspeed. VMC numbers for the F/A 18 E/F launch bulletins are defined at 14° AOA.” Further clarifying VMC and its importance, Chapter 8: Carrier - Based Procedures continues the discussion of V MC with respect to catapult launches and minimum airspeed required for safe flight: “Minimum catapult launch end speeds are governed by three limiting factors: Flaps FULL, minimum single engine control speed (V MC ), maximum longitudinal acceleration capability, and sink - off - bow. VMC is the airspeed below which the aircraft is not controllable with a single engine failure. The VMC airspeed governs the end - speed for most of the gross weight range in both MIL and MAX power (up to 60K MIL and 65K MAX, see figure 8 - 1, Table B). V MC is also a function of lateral weight asymmetry; therefore, end - speed must be increased for asymmet ric loadings (see figure 8 - 1, Table C).” Th ese section s and tables are included as attachments. The textbook Aerodynamics for Naval Aviators , NAVWEPS 00 - 80T - 80, defines minimum directional control speed a s “simply the equivalent airspeed (or dynamic press ure) to produce a required yawing moment with the maximum rudder deflection.” Recall that equivalent airspeed accounts for compressibility effects and is a correction to calibrated airspeed not displayed to the pilot. 14 CFR Part 23.149 defines theregul atory VMC as a calibrated airspeed, which is only equal to

equivalent airspeed at standard - day sea level conditions. When in the takeoff or landing configuration, F/A - 18 aircraft are flown referencing angle of attack to compensate for varying atmospheric conditions and aircraft configuration (weight and asymmetry). The F/A - 18 displays c alibrated airspeed to the pilot, but AOA is the primary reference in the shipboard environment. The calculation from a VMC in equivalent airspeed to calibrated airspeed be comes unnecessary when angle of attack is utilized. Due to the myriad aircraft configurations and the critical procedural timing of an engine failure during a catapult launch, it is inappropriate to define a single VMC number in knots of calibrated airspe ed because of the aforementioned errors . If a pilot, however, wishes to determine the V MC value in knots calibrated airspeed (KCAS), it is simply referenced in tables provided based on weights and asymmetry. These tables assume a standard day and have c orrections for non - standard conditions. For a practical example, we will assume a catapult launch at 50,000 pounds gross weight with little to no asymmetry , where VMC is the critical factor determining safe end - speed . Referring to Table B, we find 153 KC AS for minimum end - speed , which equates to MINIMUM SPEED, VMC , plus a 15 knot safety factor. Referencing the attached Ca tapult Launch Bulletin, Figure 3 , we verify that the stated MINIMUM SPEED for weights up to 50,000 pounds, VMC , is equal to 138 knots ( 153 minus 15) . The Catapult Launch Bulletin verifies the VMC data found in the flight manual discussion on minimum speeds . This procedure may be followed f or other aircraft gross weights, with a separate table for outside air temperature , in order to cor relate 14° AOA with a value in knots calibrated airspeed. The F/A - 18, thus, meets the requirement of FAA order 8900.1 Volume 5 Chapter 1 Section 4, 5 - 88E ( 2) which requires VMC data to be published in the approved flight manual. VMC and Emergency Procedu res Now that VMC has been defined for the F/A - 18 , we will investigate various emergency procedures for the aircraft and how VMC is addressed in operations . During an emergency catapult flyaway, where an engine has failed, the immediate action steps are a s follows: 1. Throttles
– MAX 2. Rudder
– Full against yaw/roll 3. Emergency jettison button

– PUSH 4. Maintain 10° to 12° pitch attitude with waterline symbol **Do not exceed 14° AOA (AOA warning tone) 5. If unable to arrest yaw/roll or stop settle

– EJECTJust as a Pa rt 23 - certified aircraft’s procedure states to maintain

airspeed above VMC , the F/A - 18 procedure states to maintain AOA below VMC AOA. In the discussion section of this emergency, the flight manual reiterates that VMC is defined at 14° AOA and that “contr ollability should be sufficient if airspeed is above VMC .” It is worth noting that single - engine controllability is guaranteed above VMC , not a positive climb rate. A single e ngine f ailure during a runway takeoff and the decision to abort or continue is s ubject to Minimum Go Speed charts , which is a hybrid of the regulatory speeds V 1 and V 2 . Since the F/A - 18 is a high thrust - to - weight aircraft, the abort/continue decision is typically made based on runway remaining to safely stop . If an engine fails on takeoff and takeoff is continued , the emergency procedure states to maintain “on speed, balanced flight ” as a higher restriction than VMC . On speed angle of attack in the F/A - 18 is 8.1° and provides the greatest amount of lift with flaps in HALF or FULL. A deceleration toward VMC would not only reduce climb performance, but introduce controllability problems. During up and away or cruise flight, with flaps in AUTO, the F/A - 18 displays excellent handling qualities thanks to its fully digital flight control system. Chapter 11 of the flight manual describes that an engine failure in this mode “results in no degradation in handling qualities under most circumstances at low AOA.” “At high AOA, engine failure results in a yaw toward the failed engine that is co ntrollable by quickly reducing AOA and countering the yaw with rudder.” Since no takeoff or landing is made with flaps in AUTO position, there is no requirement for a VMC demonstration in this configuration. The F/A - 18 as a suitable platform Under FAA ord er 8900.1 Volume 5 Chapter 1 Section 4, 5 - 88F Removal of Limited - to - Center Thrust Limitation From the Airplane Multiengine Land Rating , various tasks must be demonstrated in a suitable airplane at the commercial pilot level . All of these tasks are address ed in the F/A - 18 flight manual, annual NATOPS check flights and Instructor check flights.  Principles of Flight

– Engine Inoperative  Engine Failure During Takeoff Before VMC (Simulated)  Engine Failure After Lift - Off (Simulated)  Approach and Landing with an Inoperative Engine (Simulated)  Maneuvering with One Engine Inoperative  VMC Demonstration The F/A - 18 emergency procedures are typically built on the premise of flying to on - speed AOA during an engine failure to ensure maximum lift and the first five of thes e tasks are executed at that speed, 8.1° AOA. These EPs may be practiced during flight as on - speed AOAprovides sufficient margin to VMC . I will not expand on these tasks as

they are no particular concern to the V MC discussion. The VMC demonstration is t horoughly addressed through simulators. The Practical Test Standards for a multiengine pilot describe the VMC demonstration maneuver as a slow approach toward VMC while configured for takeoff. It also indicates that due to VMC being lower at altitude, re covery shall be made at the first indication of loss of directional control, stall warning or buffet. Recall that VMC is truly expressed in equivalent airspeed and is lower at altitude due to compressibility errors not accounted for in calibrated or indic ated airspeed. For F/A - 18 compliance, t he VMC procedures are demonstrat ed in the simulator after a low - airspeed catapult launch combined with an engine failure. Execution of the immediate action items previously discussed results in a recoverable scenari o , as long as AOA is maintained below VMC and sufficient thrust is available. T he ejection decision is often tested when airspeed is less than VMC and n ot all training scenarios are recoverable . During a flight demonstration , intentional departures are p rohibited in the F/A - 18, but a slow approach to stall warning, also 14° AOA, may be executed with one engine at idle power. This technique is in full compliance with the Practical Test Standards. Public Benefit Removal of this restriction will benefit the public interest by allowing qualified military pilots to more easily transition into the civilian sector. As there is not an instructor certification for Multiengine Limited - to - Center Thrust, an F/A - 18 instructor pilot is unable to transition to civilian instruction without great time and financial burdens. During basic aircraft transition, an F/A - 18 pilot will be able to easily transition between an AOA - referenced Vmc to one in knots calibrated airspeed , as most civilian aircraft are not equipped with A OA . Due to time - in - model minima on multi - engine instruction, there is not a compelling reason to limit an F/A - 18 instructor pilot to be certified as a multi - engine instructor. Conclusion I have demonstrated that the F/A - 18 has well - defined, published VMC data and that it more than meets the intent of 14 CFR Part 23.149 definitions as it accounts for both compressibility errors and aircraft configuration. This alone meets the requirement to remove F/A - 18 from the list of airplanes limited to center thrust. In addition, the aircraft is suitable to accomplish the task s delineated for multiengine pilots and instructors in the Practical Test Standards . Military competency based on the F/A - 18 should result in a multiengine rating without restriction at the commercial and instructor level . Footnote It is not cited in my petition, but I have also attached a paper published by the Society of Experimental Test Pilots describing the VMCtesting approach and changes made to the flight controls following a

loss of c ontrol and near - mishap. For additional details from Boeing , you may also contact Boeing ’s lead test pilot for F/A - 18, Mr. Michael Wallace at (301) 757 - 4202 or Michael.m.wallace@boeing.com . Very respectfu lly, Jeremy DeBons Lieutenant Test Pilot United States Navy