As recommended by the manufacturer...or, does the POH trump the ACS during a flight test?

Back in 1990 when this actually happened, we were using the Practical Test Standards. Same concept, however.

Teaching students who are smarter than me is educational for me as well. Case in point - Maria. Maria was one of those students who actually DID her assigned homework…and then some. 

Since she was working on her Commercial certificate, she darn near had the Cessna Cutlass RG manual memorized. One day, she pointed out that Cessna recommends that pattern work should be done with the landing gear down, as opposed to retracting it on each takeoff and extending it for each landing. Showing me the manual, page 4-20, amplified procedures for before landing, there was this statement “As a further precaution, leave the landing gear extended in go-around procedures or traffic patterns for touch-and-go landings.”

So we did.

Flight test day arrived and the examiner told Maria to go-around, which she did…with the gear down. Flew the pattern…gear down. Full stop landing. Asked to taxi back for a takeoff for pattern work, which she did leaving the gear down all the way through landing. GUMP check on every leg, mind you.

Maria was failed for ‘lack of knowledge of complex airplane procedures’. No amount of argument helped. Afterwards, we literally flew around the pattern one time, retracted the gear on takeoff and extended it to land, and then I signed Maria off for the re-test…which she took and passed that same day.

Although the examiner issued a temporary airman certificate, the examiner believed Maria could not have possibly learned those procedures in one circuit around the pattern. Truth be told – she didn’t. She had previously learned the procedures, but was following manufacturer recommendations like a good pilot should.

What do you think?

5 Replies
1516 Posts

@Daddis At AOPA
Should have been appealed to that DPE's POI at the FSDO.  Failing someone for following the POH isn't kosher.  And, BTW, gear retraction adds drag in the Cutlass as the doors open up to make way for the wheels which is why, IIRC, they say for short field/obstacle takeoffs to leave the gear down until clear of obstacles.


@Daddis At AOPA
I have a few comments.

I have a copy of the POH for a 1981 Cutlass.  I also conducted many practical tests for a Flight Instructor certificate in the Cutlass while I was an Inspector.  There was a national flight school based on the airport, that conducted a 30 day course for issuance of CFI and CFII (certificate mill).

First, the language on page 4-20 does not appear in the amplified procedures for Takeoff.  It appears in a section titled “Before Landing”. That portion of the procedures deals with items normally accomplished during a pre-landing check.  It starts out by stating “In view of the relatively low drag of the extended landing gear and the high allowable gear operating speed (140 KIAS), the landing gear should be extended before entering the traffic pattern.  This practice will allow more time to confirm that the landing gear is down and locked.”  I did rides for 10 years in a T-6.  It had three gear down indications (lights, pins in the panel that moved to show the position of the gear and a small clear window in the wing skin, through which it could be determined that the downlocks had engaged).  Checking these three items didn’t require more than 5 seconds. I’m not sure why Cessna thought it required such an inordinate amount of time to determine that the gear was extended.

This language led to applicants lowering the landing gear prior to even entering the Class D airspace for the airport at which we were based.  I often thought that, at that point, it would be a good time for a simulated engine failure.

It goes on with the language you quoted.

This should lead one to question the language concerning the “further precaution”.  I would guess that the first precaution would be the language concerning lowering the gear prior to entering the pattern.  The precautions seem to me to be directed towards minimizing the possibility of a gear-up landing.  There is no mention of any operating concern regarding the gear system.  This language was undoubtedly included by the attorneys for Cessna.  It also shows up in the POH I have for the Cessna 337 Skymaster.

There is an amplified procedure titled “Landing Gear Retraction”.  There is no mention there concerning leaving the gear down.  It states that “Landing gear retraction normally is started after reaching the point over the runway where a wheels-down, forced landing on that runway would become impractical”.

So, which amplified procedure takes precedence?

The Climb charts in the Performance section are predicated on “Gear Up”.

Next, let’s look at the PTS. The POH does not trump the PTS / ACS. 61.45(b) requires that the applicant provide an aircraft capable of performing all areas of operation for the practical test.  That is why, when someone showed up for a multi-engine test and said that the manufacturer doesn’t recommend shutting down an engine in flight, the applicant was instructed to return with an airplane that contained no such prohibition.

I have a copy of the Commercial PTS dated May 1, 1997. 

“Manufacturer’s recommendations” are referenced in the PTS.  Things like using the manufacturer’s recommended altitudes and airspeeds for maneuvers like Steep Turns, Chandelles, Slow Flight & Stalls.  During Short & Soft Field Takeoffs, it mentions retracting the gear after a positive rate of climb or “as specified by the manufacturer”.  There is no amplified procedure for short or soft field takeoffs. There is no separate procedure for soft field takeoffs.  As concerns gear retraction, I would use the Normal procedure if there are no obstructions or the Short Field procedure if there are obstructions.  The Go-Around task contains the same language.  The “Balked Landing” procedure in the POH does not reference retracting the landing gear.  There is not a prohibition concerning retracting the gear, just no mention of it. I suspect this is to preclude the pilot from retracting the gear too early during a go-around and settling onto the runway with the gear retracted.  Certainly, if the pilot executes a Go-around because the airport is unusable (due to snow on the runway or construction), he would not fly the trip home with the gear extended.  Thus, the note on page 4-20 addresses only operations where the plane will remain in the pattern (i.e. not every go-around, but only a go-around which would return for a landing at the same airport).

Now, let’s consider the Laws of Learning, specifically Primacy, Exercise and Recency.  We must realize that we are teaching our clients to be Commercial pilots and that they will likely be flying airplanes, other than the Cutlass, in their careers.  If the Cutlass is the pilot’s first exposure to complex airplanes and we teach them to leave the gear down, the law of Primacy will negatively impact them as they transition to other complex airplanes.  Exercise and Recency will negatively impact them while practicing for the practical test.  I had one Flight Instructor candidate, who was one of the best prepared people to show up for the ground portion.  We breezed through it.  We briefed the flight and the sequence we would follow.  We were to take off and then proceed to the practice area to perform maneuvers.  He lined up on the runway, departed, completed the checklist and turned toward the practice area.  Just one problem.  He had not retracted the gear, in spite of having referenced the checklist, which mentioned retracting the gear.  At that point the ride was over.  It broke my heart.  This brings up one of the Special Emphasis areas of the PTS / ACS.  Checklist usage.  If the checklist calls for gear retraction and the pilot does not retract the gear (because of language in the amplified procedure), that is a failure.  What did the checklist in your Cutlass say?

If you plan on pursuing a procedure during a practical test that might be a problem, the time to address it is during the briefing for the flight.  Not after a failure.

Ron, I didn’t recall the Cutlass having gear doors.  I looked at images of the Cutlass on the internet to refresh my memory.  The pictures show cutouts in the fuselage for the wheels, but no gear doors.

1516 Posts

@Kristian Kortokrax

Ron, I didn’t recall the Cutlass having gear doors.  I looked at images of the Cutlass on the internet to refresh my memory.  The pictures show cutouts in the fuselage for the wheels, but no gear doors.

That's what I get for relying on memory rather than looking it up.  Other Cessna retractable singles do have this in their books for this reason, but not the Gutless.


@Ronald Levy  @Kristian Kortokrax

The Cutlass RG does have nose gear doors, but no main gear doors. The main wheels retract aft into the fuselage while the nose wheel retracts forward under the engine.

Good insight from both of you on this topic. No matter how flat you make a pancake, it still has two sides; the same is true with many issues here, and this forum offers a venue for just that.

Unfortunately, as a relatively wet behind the ears instructor, I did not know then what I know now. It was a lesson learned that helped guide my training going forward.

Regarding the law of primacy mention, that is so true, but on Maria's very first Cutlass flight - gear up on takeoff and gear down to land - was hammered home. I have always had the ‘those who have and those who will’ discussion with anyone I train in a retract gear airplane. The goal, of course, is to keep oneself in the ‘those who will’ crowd until your last flight.

Maria is now a captain for a major air carrier flying the Airbus A-320. I would like to think that she occasionally looks back on the failure to gain some inspiration.


@Daddis At AOPA
I'd love to go back 50 years, knowing what I now know.  About everything, not just aviation.