To whom it may concern:
As a current 135 operator, former airline pilot, current DPE in airplanes and helicopters who currently owns and operates 4 twin Cessna aircraft affected by this NPRM, if feel I have some relevant input.
With over 20,000hrs and 40 years of flying experience, I feel this proposed AD is not necessary. We currently fly over 2500 hours annually in CE-340s and CE-414A. Most are known ice approved. We fly all over the US mostly in the North West and encounter ice regularly.
THE EMPHASIS MUST BE ON PILOT TRAINING, NOT LIMITING AIRCRAFT. We employ 8 pilots and continually train for icing encounters. In any aircraft, if ice is encountered, the pilots should try to get out of the conditions or limit the ice ASAP.
Most of the time when I have flown in areas of reported ice, even minutes later, the encounter is different than reported. ISA +/- cloud moisture content and if the aircraft is climbing or descending are all factors.
Please put the emphasis on AERONAUTICAL DECISION MAKING, than putting a limit on an aircraft. In addition the extra speed required per the placard should be INCLUDED IN TRAINING, and part of the Decision Making process.
Sincerely,
Kent W. Potter
Kent William Potter
This is comment on Proposed Rule
Airworthiness Directives: Cessna Aircraft Company Airplanes; Initial Regulatory Flexibility Analysis
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