NBAA is asking the FAA to reconsider a proposed change to aircraft weight-and-balance requirements that would require operators to use actual weights of passengers and bags instead of the current standard average passenger and baggage weights, or conduct a survey to develop average weights for each operator every three years. The association comments were prompted by the release of a draft advisory circular, AC 120-27F “Weight and Balance control,” in November.
Because of the “limited details” applicable to Part 91, Part 91K, Part 125 and Part 135 operators, NBAA said it is concerned about “the very likely potential of differing requirements” as interpreted by each Flight Standards District Office/Certificate-Holding District Office and inspector. In addition, NBAA noted a fundamental difference between the crew and passenger weight figures as specified in the draft AC and those figures specified in aircraft certification rules. Many of the aircraft certification standards still reference 170 pounds.
The association said that because of the limited number of passengers on business aviation flights, and the considerable challenges that conducting a survey entails, NBAA members have indicated they would rather accept a heavier “average” or “segmented” weight than have to comply with a survey.