34 Answers

Revisiting the W in ARROW

Asked by: Kris Kortokrax 28618 views FAA Regulations, General Aviation

In looking through different subjects on the forum, I came across “Where is the source for the W in ARROW?”

This is not a question. I too, sought a regulatory reference for the W, when I began instructing. After many years, I eventually discovered the following.

In the post, it was posited that the regulatory requirement for the weight and balance to be carried on board an aircraft resides in 91.103, 91.9 and 43.5.

91.103 deals with Preflight Action and details information with which we must become familiar before beginning a flight. Once I have determined that the aircraft is not over gross and is within CG limits, I’m good to go. It contains no requirement to carry W&B data on board the aircraft.

91.9 deals with compliance with Operating Limitations as specified in “AFM, markings, placards, OR as otherwise prescribed by the certificating authority of the country of registry.”

It goes on to address in (b)(2) the requirement to carry a “current AFM, approved manual material, markings, and placards, OR any combination thereof.” As above, once I confirm that the aircraft is not over gross or outside the CG limits, I’m done. Again there is no explicit requirement to carry W&B data.

43.5 deals with entries in maintenance records and contains no requirement to carry W&B data on board the aircraft. This section contains no operating rules (see Part 91).

SO, is it required that the Weight and Balance information be on board the aircraft? The answer is that it depends. There is no regulation in Part 91 that requires it.

In 14 CFR Part 3, section 3.5 (a) we find the definition of airworthy: Airworthy means the aircraft conforms to its type design and is in a condition for safe operation. Next, we must look at the Type Certificate Data Sheet, the basis for the type design.

For the Cessna 172 – TCDS 3A12 and Piper PA-28 series - TCDS 2A13, , Note 1 states: “Current weight and balance report together with list of equipment included in certificated empty weight, and loading instructions when necessary, must be provided for each aircraft at the time of original certification.”

For the Piper PA-18 – TCDS 1A2 and Mooney M20 series - TCDS 2A3, Note 1 states ” Current weight and balance report including list of equipment included in certificated weight empty, and loading instructions when necessary, must be in each aircraft at the time of original certification and at all times thereafter (except in the case of air carrier operators having an approved weight control system).”

The notes are part of the TCDS. In order for the Piper PA-18 and the Mooney M20 series to conform to their type design, the weight and balance report and equipment list must be on board the aircraft. If the W&B and equipment list are not on board, then the aircraft is not airworthy and that would constitute a violation of 91.7(a). In the case of the Cessna 172 and Piper PA-28 serires, the weight and balance report does not have to be on board the aircraft to be legal.

I fly many antique airplanes, for which there is no AFM, no POH, and the only W&B info is what was derived when the airplane was weighed after restoration. For example, look at the Type Certificate for a WACO RNF – ATC 311. It was manufactured in 1930 and the TC lists a “Standard Weight”, not a “Maximum Weight” as in the TC for a CE-172. There is no CG range specified for the airplane. If I am ramp checked and cannot produce official W&B info, there will be no violation.

I’m not saying that you should not have the Weight and Balance info on board. However, it doesn’t always need to be the officially issued document. The numbers written down on a piece of paper suffice if the TCDS doesn’t require the official paperwork to be on board. A calculation could be done before flight to assure compliance with the weight and CG limitations. If the W&B documents aren’t required to be on board, they could then be left safely on the ground.

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34 Answers

Nathan Parker on Nov 03, 2011

” There is no regulation in Part 91 that requires it.”

No, but the requirement for an AFM exists for most airplanes and current W&B is a required part of an AFM.

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Brian on Nov 04, 2011

§ 21.5 Airplane or Rotorcraft Flight Manual.
top
(a) With each airplane or rotorcraft not type certificated with an Airplane or Rotorcraft Flight Manual and having no flight time before March 1, 1979, the holder of a type certificate (including amended or supplemental type certificates) or the licensee of a type certificate must make available to the owner at the time of delivery of the aircraft a current approved Airplane or Rotorcraft Flight Manual.
(b) The Airplane or Rotorcraft Flight Manual required by paragraph (a) of this section must contain the following information:
(1) The operating limitations and information required to be furnished in an Airplane or Rotorcraft Flight Manual or in manual material, markings, and placards, by the applicable regulations under which the airplane or rotorcraft was type certificated.
(2) The maximum ambient atmospheric temperature for which engine cooling was demonstrated must be stated in the performance information section of the Flight Manual, if the applicable regulations under which the aircraft was type certificated do not require ambient temperature on engine cooling operating limitations in the Flight Manual.

–End of FAR 21.5–

The W&B is part of an aircrafts operating limitations.

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Kris Kortokrax on Nov 04, 2011

Can you provide a regulatory cite which establishes that “current W&B is a required part of an AFM?” I can find in 14 CFR 25 for Transport category aircraft a statement that empty weight and CG must be incorporated by reference in the AFM.

Where does the requirement exist in Part 21 or Part 23 for Normal category aircraft?
There is a requirement to establish empty weight and CG and manufacturers may choose to include the weight and balance report and equipment list in the AFM, however there is no regulatory requirement to do so.
The requirement you state does not show in AC 23-8B which deals with Flight Test for Normal airplanes, nor does it exist in Order 8110.4C which deals with Type Certification.

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Kris Kortokrax on Nov 04, 2011

Brian,
Your post arrived while I was composing the previous reply.
Of course, the operating limitations are part of the AFM. We all agree on that point.
Empty weight is not a limitation. If it were, then what are the limits? 14 CFR 23.9 establishes a requirement to determine the empty weight and CG, but there is no requirement to include that information in the AFM.

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Nathan Parker on Nov 04, 2011

§ 23.1589 Loading information.

The following loading information must be furnished:

(a) The weight and location of each item of equipment that can be easily removed, relocated, or replaced and that is installed when the airplane was weighed under the requirement of §23.25.

(b) Appropriate loading instructions for each possible loading condition between the maximum and minimum weights established under §23.25, to facilitate the center of gravity remaining within the limits established under §23.23.

==================
Strictly speaking, it doesn’t address the need to keep it constantly updated, so there is a break in the chain of logic to make the case airtight.

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Marc Newman on Nov 04, 2011

You don’t need weght an balance. In fact, everything required in or attached to the aircraft is overridden by the manual in the “airworthiness limitations section”. Meaning, if the aircraft says you must have a fire extinguisher – you must have it to be airworthy.
Part 91.191)
(3) The instruments and equipment listed in the manual that are required for a particular Category II or Category III operation have been inspected and maintained in accordance with the maintenance program contained in the manual.
… and…
91.403)
(c) No person may operate an aircraft for which a manufacturer’s maintenance manual or instructions for continued airworthiness has been issued that contains an airworthiness limitations section unless the mandatory replacement times, inspection intervals, and related procedures specified in that section or alternative inspection intervals and related procedures set forth in an operations specification approved by the Administrator under part 121 or 135 of this chapter or in accordance with an inspection program approved under §91.409(e) have been complied with.

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Brian on Nov 04, 2011

” If it were, then what are the limits?”

Of course the minimums aren’t a limit. But how do you prove you’re within maximum limits without an accurate starting point. Maximum limitations change, that is the purpose of the W&B sheet by my understanding. Things such as tip tanks, winglets or simimilar modifications to the wing design can alter the maximum takeoff weight. The W&B just happens to include both. I’m not sure I could site anything that particularly states that the starting point is needed, however, because I’ve never seen anything applicable beyond whats been presented here.

That said, I think you’d be hard pressed to slip this by any ramp check because when asked “how do you know you’re within weight limits” and you respond “magic” (joking of course, sorry), I don’t think he/she will be humored. Point is you’re supposed to be able to show that you’re within weight limitations for flight if ramp checked, without accurate starting information you simply cannot do this.

An asside, I was once told that to read a regulation we need to ask ourselves “what is the purpose.” And while the regulation might not meet that purpose by pure logic, such as in this case, it still the purpose that will get you in trouble. In this case I think the purpose is clear, “show you are within limitations.” Only my 02 now, for what that’s worth. Interesting topic still, thanks for continueing it.

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Nathan Parker on Nov 04, 2011

“Point is you’re supposed to be able to show that you’re within weight limitations for flight if ramp checked, without accurate starting information you simply cannot do this. ”

I discussed this with an FAA Safety Inspector once; he agreed with my research which showed that for airplanes with no AFM requirement and which lacked a type certificate requirement for W&B info, no regulation specifically required it to be on the airplane. He said his methodology would be that if he suspected an airplane to be overgross or out of CG, he would work up his own W&B for the airplane and present it to the pilot, asking that the pilot prove him wrong.

In general, I don’t think an argument of the form “how can you prove X without carrying it on the airplane” has much merit. A pilot has a lot of responsibilities to carry out before stepping on board the airplane and for most of them, there is no legal requirement to carry proof that he has fulfilled them. Thank goodness.

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John D. Collins on Nov 05, 2011

Kris,

I think you are technically correct, but the FAA provides the following information regarding a ramp inspection in their online Order 8900.1 Flight Standards Information Management System (FSIMS) manual that provides guidance to FAA Inspectors. So my advice would be to have the W&B with the equipment list on board the aircraft.

You can read the entire section at http://fsims.faa.gov/PICResults.aspx?mode=EBookContents , see Volume 6 Surveillance, Chapter 4 Ramp inspections. I have excerpted a portion on aircraft documents below for your convenience.

6-95    AIRCRAFT DOCUMENTS. Following are considerations when examining aircraft documents, including registration and airworthiness certificates and approved flight manuals. Discrepancies found concerning the airworthiness or registration certificates shall be brought to the attention of the operator, documented, and given to the airworthiness unit for action.

A.    N-Numbers. The N-number on the registration certificate must match the N-number on the airworthiness certificate.

B.    Registration Certificate. If the registered owner has changed you may see a temporary registration (Pink Slip) which is good for 120 days. If the ownership has changed without a Pink Slip or the N-numbers do not match, the registration is not valid.

C.    Radio Station License. An aircraft FCC radio license is required although the FAA does not regulate the requirement. The license may be for that particular N-number or a fleet license. The expiration date of the license is in the upper right hand corner. Any discrepancy concerning the radio license should be brought to the attention of the operator only.

D.    Flight Manual. An Aircraft Flight Manual is required to be on board the aircraft (§ 91.9) along with the appropriate markings and placards.

E.    Weight and Balance Information. Weight and balance documents, including a list of equipment, must be on board the aircraft. Some multiengine operators have Minimum Equipment Lists (MELs) with a letter of authorization issued by a district office. These constitute a supplemental type certificate for the aircraft and must be on board. The inspector should compare inoperative equipment to the MEL to assure compliance. (Refer to Related Task #58, Approve a Minimum Equipment List.)

F.    Airworthiness Certificate. The certificate most often seen by an inspector is a standard airworthiness certificate, which is issued for normal, utility, acrobatic, and transport category aircraft. A restricted, limited, or experimental certificate must be accompanied by a list of limitations and conditions (§§ 21.183 -21.191) necessary for safe operation. A Special Flight Permit (Ferry Permit) is issued to aircraft that may not be airworthy but are capable of safe flight under certain conditions which are listed and issued with the permit (§§ 21.197, 91.203, and 91.213). Review the list of limitations and conditions to assure a valid airworthiness certificate. The N-number on the certificate must match the N-number on the fuselage to be valid.

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Kris Kortokrax on Nov 05, 2011

Nathan,
You cite 23.1589 as requiring loading information. What you missed was 21.5(a) from Brian’s post which states that the AFM must be provided for aircraft built after March 1, 1979. We must also consider that airplanes such as the Cessna 150 and 172 and the Piper PA-28 series (constituting a large portion of the training fleet) were certificated under CAR 3, before there was an FAA or FAR Parts 21 & 23. CAR 3.777(b) exempts airplanes 6000 pounds and under from the requirement for an AFM. CAR 3.778(c)(2) still requires furnishing maximum weight, empty weight & CG, useful load and what constitutes useful load. No requirement to carry the info.

Other airplanes such as the Piper Cub (J-3), Luscombe and Ercoupe were certificated under CAR 4. CAR 4.752-T states that the maximum takeoff weight and maximum landing weight must be included in the Airplane Operating Manual to furnished with each airplane per CAR 4.755-T.

Marc,
“You don’t need weght an balance.”
You most certainly do need the weight and balance info if the type certificate requires it, as it does for some aircraft. A Cat II manual is not an AFM, neither is a maintenance manual.

Brian,
I want to be within weight and balance limits because I don’t want to become a test pilot, not because of a potential ramp check. I can just as easily do that by using a form which I design to perform the calculations which lists the empty weight and moment. If I chose, I could write the empty weight and moment on a bar napkin and it would still be available to do the calculation.

John,
By reading the sections from your cite that deal with Radio Station License and Flight Manual, you can see how out of date (or out of touch) the Order is. When a conflict exists between an FAA Order and the regulations, the regulations will take precedence.
I’ve been ramp checked before and never asked for weight and balance info. If I show up on the ramp in a 1928 Laird biplane (which I have) and am asked for an AFM & W&B info (which I haven’t been), there is no manual and no W&B info, other than what was performed when the airplane was restored. Again, I have no desire to fly an aircraft beyond its limits.

My whole point with this discussion was to shed some light on the requirement to carry (or not to carry) the official weight and balance info. The AFM theory does not work for all cases. Airplanes manufactured prior to March 1, 1979 are required to have an AFM. The TCDS Note 1 theory does. Even for airplanes not required to have an AFM, the TCDS will require that W&B info and equipment list be provided, and in some cases it will require the info to be on board the aircraft “at all times.”

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Nathan Parker on Nov 05, 2011

“Nathan, You cite 23.1589 as requiring loading information. What you missed was 21.5(a) from Brian’s post which states that the AFM must be provided for aircraft built after March 1, 1979. ”

No, I didn’t miss that. I pointed out in my original post “the requirement for an AFM exists for most airplanes” (highlight added), which was an implicit nod to the fact that pre-1979 airplanes didn’t have an explicit requirement for an AFM, although many type certificates added the requirement before that date.

Also, in my discussion with the FAA Inspector I mentioned, I also acknowledged that an AFM isn’t required for some airplanes and even argued to him that in those cases, W&B information wasn’t required, which he seemed to agree with.

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Kris Kortokrax on Nov 05, 2011

Nathan,
Sorry about that. I fixated on your second post.

I would, however, disagree with the statement that most airplanes require an AFM. With the increase in production and sales post WWII and the decrease in production in the 1980’s, I would speculate that many more airplanes were produced under CAR 3 and CAR 4 and pre March 1, 1979 FAR 23, than those produced after March 1, 1979. When I look at the list of most produced aircraft on Wikipedia (yes, we all know how unreliable Wiki can be) I need to look far down the list to find an airplane certified under FAR 23. Just adding the numbers for Cessna 172, Piper Cherokee, Cessna 182 and 150, Piper J-3 and Bonanza’s (realizing that there were more Bonanzas produced between 1947 and 1979 than post 1979) accounts for a large portion of existing airplanes.

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Nathan Parker on Nov 05, 2011

“I would speculate that many more airplanes were produced under CAR 3 and CAR 4 and pre March 1, 1979 FAR 23, than those produced after March 1, 1979.”

Perhaps, but how many of them are still flying? And how many of them include a type certificate requirement to carry an AFM? Looking at the Type Certificate Data Sheets, pretty much all the Piper PA 28 aircraft have an AFM required. As for the Cessna’s, the C-172N, for instance, has the AFM as a required piece of equipment on the equipment list.

I don’t really know the percent of the fleet that has this requirement, but that’s a silly thing to argue about.

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John D. Collins on Nov 05, 2011

Kris,

I am not sure what you mean by “By reading the sections from your cite that deal with Radio Station License and Flight Manual, you can see how out of date (or out of touch) the Order is.” The section was last updated in Sept of 2007. If you read thru the rest of the section, they indicate that a radio station licence is not required and they don’t enforce it. The AFM they refer to is required by 91.9. Aircraft prior to March 1979 are required to have an AFM, after that date the AFM must meet the requirements of the regulation under which it was certified.

I agree that “When a conflict exists between an FAA Order and the regulations, the regulations will take precedence.” One of the reasons for Order 8900.1 is to attempt to standardize how the FAA inspectors accomplish their tasks. It used to be part of various orders and now is an online order that can be maintained when required for clarification. One of the big problems is the local interpretation differences between inspectors and FSDO offices.

All that said, this is a good question for the FAA Chief Counsel regarding whether or not carrying a W&B with equipment list is required and if so, under what conditions and under what regulatory basis.

“

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Kris Kortokrax on Nov 06, 2011

Nathan,
Granted the POH,AFM was required by the type certificate for most of the Cherokees. For the 172N, 3,450 of them do not require an AFM and 2975 of them do. The serial number series produced in 1979 and after require it and that coincides with the regulatory requirement. There are 13,116 CE-150’s on the registry on faa.gov. I suspect a great number of them are still flying and are not required to have an AFM. As I stated earlier, my aim was to clarify from where the requirement to carry W&B info (if it exists for a particular airplane) resides. There are currently many airplanes flying which do not require an AFM. There is for most airplanes a requirement in the TCDS requiring that the manufacturer provide W&B info and equipment list. In some cases, there is a requirement in Note 1 that the info be carried. In those cases, the W&B info must be on board in order to comply the the type certification. If there is no requirement to carry in the TCDS and no requirement for an AFM, then one can legally operate the aircraft without the official W&B info and equipment list on board. Therefore, 91.9 does not constitute a blanket requirement to carry the official W&B info on board the aircraft

John,
You state that the ramp section of 8900.1 was last updated in September, 2007. Orders 8300, 8400 and 8700 were consolidated into the 8900 and promulgated in September, 2007. It has not been updated since the inception of 8900.1. That means in order to determine how out of date the info is, we would need to look at the 8700 to determine the last time the info was updated.

In the section you cited, it states that the pink copy of the registration is good for 120 days. 14 CFR 47.31(c) states that the pink is good for 90 days. What I am trying to illustrate is that one should not rely on the 8900.1 to determine complicance without verifying the information in the regulations. Regarding the requirement to carry W&B info on board (the W in ARROW), 91.9 is not the basis on which to rely, except for those aircraft which require an AFM (and not all do).

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John D. Collins on Nov 06, 2011

I only said that 91.9 was the basis for requiring the AFM. You read more into my comment if you extended it to W&B requirements as I did not mention W&B in that reference. You already pointed out that not all AFM contained a W&B. I am not sure if this back and forth is constructive, and still suggest that you ask the FAA Chief Counsel for an opinion, they are very willing to do this although it can take a few months before they provide an answer. I have used this as a means of getting clarification on other issues in the past and it takes very little effort on the requesters part.

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Kris Kortokrax on Nov 06, 2011

The last interpretation I requested took them 3 years to answer.

My comments were more directed at the inconsistencies between the Order and regulations and the failure of the FAA to update its supporting documents. Sorry if it came across otherwise.

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Brian on Nov 09, 2011

Kris, in your original post you stated, “SO, is it required that the Weight and Balance information be on board the aircraft? The answer is that it depends. There is no regulation in Part 91 that requires it.”

Just a couple posts ago you stated, “…and no requirement for an AFM, then one can legally operate the aircraft without the official W&B info…”

Before I continue, I’m in no way trying to stir things up or pick on you. That said, I’m confused as to your standing on the subject because the only thing the regulations require, post March 1, 1979, is an approved AFM and equipment list current on the day of certification.

To this you argued with me earlier, or so I though?, that the regulations do not require a W&B sheet; despite the clear need for an approved AFM with limitations information. Yet I read your recent post to say, so long as the regulations require the approved AFM (21.5 aircraft produced after March 1, 1979), that a W&B document is also required.

I guess my question is, then, which of the following do you agree with:

1) Any aircraft produced after March 1, 1979 or any aircraft required by TCDS (type certification data sheet) to carry a W&B must carry a W&B sheet or;

2) Do you still contend that, unless the TCDS requires a W&B be carried on the aircraft, you do not need a W&B sheet on board.

If you agree with the first one then we are, and always were, in complete agreement. If you don’t, well then I guess we don’t see eye to eye. Which is fine 🙂

Thank you again for revisiting the topic, it’s been a great discussion. Though I would love to see what the FAA has to say on this topic as you’ve made it quite apparent that discrepencies do exist in the logical reasoning view of the discussed regulations. Though I still contend that the purpose of regulation 21.5, and order 8900.1 posted by John would seem to agree, is to prove you are safely within weight limits by carrying an approved AFM with current W&B information.

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Brian on Nov 09, 2011

Nathan, “I discussed this with an FAA Safety Inspector once; he agreed with my research which showed that for airplanes with no AFM requirement and which lacked a type certificate requirement for W&B info…”

Brian – § 21.5 Airplane or Rotorcraft Flight Manual.
top(a) With each airplane or rotorcraft not type certificated with an Airplane or Rotorcraft Flight Manual and having no flight time before March 1, 1979,…current approved Airplane or Rotorcraft Flight Manual…”

I have only been discussing aircraft that require an approved AFM. After all the term AROW should be referenced to the current times, despite the possibility that one might fly an aircraft certified before March 1, 1979. Instructors teaching in aircraft produced before this date that don’t have a TCDS requiring a W&B can teach their students otherwise.

But keep in mind, time is only going one way friend. Don’t believe me? Count how many more gray hairs I’ve given you since our JC days 😉 Point is, chances are pretty great that every student today will someday fly an airplane produced after 1979.

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Kris Kortokrax on Nov 18, 2011

Brian,
I had a conversation a couple of days ago with an engineer and a flight test pilot from the Chicago Aircraft Certification Office (ACO). I was told by them (the people who approve the AFM) that there is no regulatory requirement to include the empty weight and CG in the AFM. So, I guess I have to go with statement number 2.

Also, we need to consider that in the technological age in which we live, we can now carry such things as AFM, performance data, limitations and spreadsheets for calculating W&B on an iPad. The guidance for this is found in AC 91-78 and AC 120-76 (Appendix A & B).

As I have stated in other posts, I have thick skin and take no offense when someone disagrees with me.

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David Eberhardt on Dec 11, 2011

may I take a stab?
I read 91.9 Civil aircraft flight manual, marking, and placard requirements.
(a) “…no person may operate a civil aircraft without complying with the operating limitations specified in the approved Airplane or Rotorcraft Flight Manual”
I’ve always understood that weight and balance is an operating limit.
para (b) says you need to have the airplane manual in the airplane.

Maybe I’m missing the finer distinctions here, but it sure makes sense that you should have this info available in the airplane. As soon as you land at an airport other than the original departure airport, you would not be able to adequately comply with the requirements to adequately pre flight for your next takeoff, right?

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Kris Kortokrax on Dec 11, 2011

No one has suggested operating without complying with the operating limitations. The discussion centers around whether or not there is a regulation which requires the “official” weight and balance information as provided by the manufacturer to be on board the aircraft. If not required by the TCDS, one could conceivably carry the appropriate empty weight and empty moment information in electronic form or written in crayon on a bar napkin and still be able to comply with the max weight and CG limitations at any time.

As an aside, looking at your profile it states that you were a military instructor and are working towards civilian instructor ratings. See 14 CFR 61.73(g). You may apply for and receive a flight instructor certificate with airplane multiengine land and instrument airplane ratings based upon your military experience. The only thing you would need to study for is the Military Competency knowledge test. Also, if you want to instruct in single engine airplanes, you would need to add that rating to the certificate.

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David Eberhardt on Dec 11, 2011

Kris, I’m of the impression that weight and balance info is part of the ops limits. For example, the CG must be within forward and aft “limits”. The total weight, with pax, fuel, etc must be “within limits”.
91.9 Civil aircraft flight manual, marking, and placard requirements. (a) “…no person may operate a civil aircraft without complying with the operating limitations specified in the approved Airplane or Rotorcraft Flight Manual”
Why would your airplane not have an approved Flight Manual on board? And if you have that manual ob board, why wouldn’t it have weight and balance info within, so you can compute W&B compliance prior to every flight?

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David Eberhardt on Dec 11, 2011

“weight and balance in crayon or on a paper napkin” ? really?

LOL!

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Kris Kortokrax on Dec 11, 2011

The empty weight and moment are not limits. They are starting points for calculating whether the loaded aircraft will be within the limits, which are delineated in the type certificate data sheet (and restated in the Limitations section of the flight manual, if there is one published for the aircraft).

I fly several airplanes manufactured between 1927 and 1930. In those days, there were no approved Flight Manuals. Airspeed indicators and magnetic compasses were optional equipment.

If I have the empty weight and moment and know the stations for passengers, baggage and fuel (which are also stated in the type certificate data sheet), I can compute the loaded weight and CG and determine whether I am within limits or not.

Note that 91.9(b)(2) discusses aircaft for which an AFM is not required by 21.5. The list of forms which the limitations may take is an “or” list, not an “and” list. AFM is not required if none was produced.

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David Eberhardt on Dec 12, 2011

re: Kris said “I fly several airplanes manufactured between 1927 and 1930.” I see you mentioned that in your first post. Roger that Kris – for aircraft such as that, you are correct. I have always flown aircraft that are equiped with a complete AFM or POH which have the weight and balance info contained within.
Since the ARROW acronym has been so widely accepted, I’m not sure what your intent is here? But it was informative to me to learn that some older aircraft may not have the weight and balance charts I’m used to looking at.

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David Eberhardt on Dec 12, 2011

Kris – I also came accross this:
“In 1975, the US General Aviation Manufacturer’s Association introduced the ‘GAMASpecification No. 1’ format for the ‘Pilot’s Operating Handbook’ (POH). This formatwas later adopted by ICAO in their Guidance Document 9516 in 1991, and is nowrequired for all newly certified aircraft by ICAO member states. Most light aircraftlisted as built in 1976 or later, have provided Pilot’s Operating Handbooks (POHs) inthis format.”
chapter 6 of this POH contains weight and balance

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Kris Kortokrax on Dec 12, 2011

Yes, ARROW has been around for a long time. It doesn’t address the need for the equipment list to be on board for certain airplanes. The R for radio station license applies only outside the United States. I have never been a fan of doing something or doing it in a certain way because “that’s the way we have always done it.” I teach my students not only the rules, but the exceptions. In this case and some others (TOMATO FLAMES for 91.205 VFR equipment) the acronym serves to provide an easy way to recall various regulatory items. However, there is no explicit Part 91 reulation that states that the “official” empty weight and empty moment provided by the manufacturer must be carried aboard the aircraft.

When serving as chief instructor in Part 141 and Part 61 flight schools, I prepared a single page Word document that contained a grid for calculating the loaded weight and CG and provided a graphic depiction of the limiting envelope. Students were required to do the actual calculation (as opposed to using an Excel spreadsheet or iPhone app or any other short cut). This method meets the requirement to determine whether the pilots were operating within the limits set by the manufacturer. It just didn’t require the arbitrary carriage of the manufacturer’s “official” document. The numbers don’t change based on whether they appear on a sheet from the manufacturer or are transposed onto a much more useable document that I provided my students.

Also, note that in my post of November 18, I spoke with people from the Aircraft Certification Office (FAA), who stated that there is no regulatory requirement to include empty weight and moment in the AFM. If the manufacturer decides to provide it, OK. However, there is no regulatory requirement to do so, hence the W in ARROW cannot be universally substantiated by a Part 91 regulatory reference.
The GAMA specification is not a regulation. It is a consensus reached between manufacturers (and a good one, I might add). As far as ICAO is concerned, it does not regulate U.S. aircraft operations. 14 CFR 91.703 only requires our compliance with ICAO Annex 2 when operating over the high seas or in a foreign country (i.e., a Second in Command type rating is not required for operation in the U.S., but is required for operations in foreign countries).

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David Eberhardt on Dec 12, 2011

Kris – are you’re students training to be lawyers or pilots?

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Kris Kortokrax on Dec 12, 2011

They all ended up as pilots. With the sometimes heavy handed enforcement actions from the FAA, we might benefit from thinking like a lawyer (no, I’m not a lawyer, but I did sleep at a Holiday Inn last night).

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Wes Beard on Jan 21, 2012

From AOPA ePilot Quiz Me section dated 1.20.2012.

Question: Many pilots use the mnemonic AROW to remember what documents are required to be on board their aircraft under FAR Part 91.9. This regulation does not mention weight and balance, only operating limitations. Where in the regulations does the “W” in the AROW mnemonic come from?

Answer: The weight and balance requirement comes from the definition of operating limitations. If the aircraft was certified under Part 23, part of the certification requirements include a range of weights and center of gravity to be established for all aircraft under FAR 23.23. Then under FAR 23.1519, the numbers calculated in FAR 23.23 are included in the operating limitations. Finally under FAR 23.1583 these numbers need to be placed in the aircraft flight manual (AFM) or equivalent. So, a weight and balance would need to be included in the AFM carried in the aircraft. Learn more about required aircraft documents online.

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David Eberhardt on Jan 21, 2012

Wes – FAA approved Airplane Flight Manuals are also required to meet a common standard these days which includes a weight and balance section.

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David Eberhardt on Jan 21, 2012

see Pilot’s Handbook of Aeronautical Knowledge
By Federal Aviation Administration

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Robert Chapin on Apr 18, 2015

John D. Collins wrote above that Order 8900.1 required “Weight and balance documents, including a list of equipment, must be on board the aircraft.”

The latest reference, 8900.1, Vol. 6, Ch 1, Sec 4, 6-95 (D) states, “W&B documents, including a list of equipment, as appropriately revised, should be available for the inspector’s review.”

I’ve experienced ramp inspections on two occasions so far, and I’m glad I had all the documents on board.

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Revisiting the W in ARROW

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