Advisory Circular (AC) No. 700-048

• (1) Standard operating procedures (SOPs) respecting Reduced Ground Roll (RGR) take-offs must describe the duties of the pilot flying (PF) and pilot monitoring (PM) during normal and emergency RGR take-off procedures.
• (2) SOPs should reflect the information provided in Appendix B, (k) Initial and Recurrent Training – Normal and Emergency Procedures, subparagraphs (2) and (3).

• (1) RGR Take-offs must be conducted in accordance with the procedures and limitations specified in the Transport Canada (TC) approved RGR Take-off Aircraft Flight Manual Supplement (AFMS).
• (2) The procedures and limitations specified in the approved RGR Take-off Aircraft Flight Manual (AFM) Supplement have been developed to mitigate the hazards associated with an aircraft being airborne at a speed less than V₁ – including those associated with the aircraft becoming airborne at a speed less than V_MCA.
• (3) The limitations specified in the approved RGR Take-off AFMS include:
  • The aircraft shall have a fully functioning auto feather system installed and operating
  • Minimum Flight Crew of 2 pilots
  • Approved Flap Setting for RGR take-off is 20
  • Required placards installed; and
  • RGR Take-offs restricted to DAY VMC only.

• (1) When planning an RGR take-off, the suitability of the take-off surface as well as the area available for a landing in case of a rejected take-off must be assessed.
• (2) For the purpose of an RGR take-off, the length of the runway (take-off surface) required is not limited by accelerate-stop distance (ASD). The value for ASD published in the approved RGR Take-off AFMS is to be used as a guide to ensure that a suitable area for a forced landing is available if a rejected take-off is initiated while airborne prior to V₁. A suitable area for a forced landing can be understood to be an area that provides the flight crew with a reasonable capability to safely land the aircraft.
• (3) Similarly, for the purpose of an RGR take-off, the length of the runway (take-off surface) required is not limited by accelerate-go distance (take-off distance to 35 feet with an engine failure at V₁). It is recommended that the value for accelerate-go published in the approved RGR Take-off AFMS be used as a guide to ensure that a suitable area is available, clear of obstacles along the take-off path, to continue the take-off if an engine fails at V₁.
• (4) RGR take-offs are frequently conducted on surfaces that are not dry, hard, or level. Therefore, air operators, private operators and pilots must consider and allow for degradation in take-off performance arising from the unique characteristics of each runway (take-off surface) at which an RGR take-off is conducted.
• (5) Information respecting the factors which can negatively affect take-off performance may be found in the Viking DHC-6 Twin Otter Reduced Ground Roll (RGR) Take-off – Pilot Procedures and Training Guide (PPTG).
• (6) Subpart 704 pilots and air operators are reminded that when conducting operations from gravel runways, they must also comply with the regulatory requirements to add an extra factor, when such operations are not specifically addressed in the Aeroplane Flight Manual, a Supplement to the Aeroplane Flight Manual, or in data from another source that is acceptable to the Minister.

• (1) In determining whether the meteorological conditions are adequate, the flight crew must assess that they will be able to maintain visual contact with the ground and avoid obstacles.

• (1) Reserved

• (1) The approved RGR take-off normal and emergency procedures require increased skill and alertness and also feature an elevated workload relative to a conventional take-off, for this reason, the minimum flight crew for an RGR take-off consists of two pilots. This is a limitation specified in the approved RGR Take-off AFMS.
• (2) If an engine failure or other emergency affecting the safety of flight occurs prior to V₁, the associated hazards - including those associated with being airborne at a speed less than V_MCA - can be effectively minimized by reducing power on the operative engine and conducting a rejected take-off. Having two pilots facilitates the immediate recognition and announcement of an engine failure by the PM as well as the prompt reaction by the PF.
• (3) A Second-In-Command (SIC), who meets the applicable ground training, flight training, and recency requirements specified in paragraphs (h) through (q), can serve as the PF during an RGR take-off.
• (4) The PNF/PM must be qualified in accordance with the air operator’s approved training program or private operator’s training program (as applicable) for DHC-6 pilots, and must also meet the RGR ground training requirements.

• (1) Take-off briefings serve an important role in preparing flight crews to make the reject/continue (stop/go) decision.
• (2) Further to the minimum briefing requirements specified in the SA, the pre-take-off briefing should include:
  • (a) the actions to be taken if an engine failure occurs or if any other aircraft malfunction or abnormality occurs :
    • during the take-off run, prior to liftoff (becoming airborne);
    • after the aircraft becomes airborne, prior to V₁; and
    • airborne, after V₁
  • (b) The actions to be taken with all engines operating normally, including:
    • the altitude at which obstacles will be cleared prior to the commencement of flap retraction.
  • (c) Any other pertinent factors, conditions or hazards
• (3) If a series of RGR take-offs is conducted from the same location for the purpose of flight training, the PIC may elect to only conduct this briefing prior to the first RGR take-off.
• (4) Pilots must constantly guard against complacency and must always be ready to make the appropriate decisions and take the correct actions. They must always be prepared to take timely action – especially when addressing an engine failure during an RGR take-off.

• (1) The objective of RGR take-off ground and flight training is to provide pilots with the necessary background knowledge required to safely conduct RGR take-offs during line operations.
• (2) These training requirements have been developed to address the unique characteristics of RGR take-offs and include the recommendations of the aircraft manufacturer.
• (3) Air operators, private operators and pilots should consult the manufacturer's guidance for additional information.
• (4) Air operators and private operators are also encouraged to enhance their individual training programs by including additional training events, requirements and/or information which they have determined to be appropriate for particular routes, aerodromes or areas of operation. These include, but are not limited to:
  • (a) Any requirements for initial operating experience (line indoctrination); and
  • (b) Flight crew pairing restrictions (such as requiring newly qualified RGR pilot-in-command to only fly with experienced second-in-command pilots).
• (5) Sources of information include, but are not limited to:
  • (a) Feedback from the training and checking pilots, as well as line pilots
  • (b) Analysis of past incidents; and
  • (c) Analysis of information received from other air operators, private operators and associations.

• (1) The aim of RGR flight training is to ensure that trainees are able to demonstrate the required proficiency. Therefore, RGR flight instructors must perform three vitally important functions:
  • (a) Instructing (facilitating the candidate’s learning and conveying information);
  • (b) Evaluating trainee performance (confirming that the trainee is able to successfully conduct the required manoeuvres);
  • (c) Documenting that the required training was completed and that the trainee demonstrated proficiency.
• (2) Instructors should reference the manufacturer’s guidance for specific criteria to be used in the assessment of RGR normal and emergency procedures.

• (1) Accurate and complete records serve as important tools to help air operators and private operators facilitate safe flight operations.
• (2) The retention period of 3 years is consistent with the requirements specified in sections 702.77, 703.99 and 704.117 of the CARs.

Overview

• (1) The objective of initial and recurrent RGR ground training is to provide pilot trainees with the necessary background knowledge required to:
  • (a) prepare for RGR flight training; and
  • (b) safely conduct RGR take-offs during line operations.
• (2) Pilots are not authorized to conduct RGR take-offs – either as PF or PM – unless than have met the applicable initial or recurrent ground training requirements specified in Paragraph (k) of the SA for RGR take-off.
• (3) To increase the effectiveness and benefits received from RGR ground training, it should be conducted as closely as possible prior to the associated flight training.
• (4) Air operators and private operators should establish appropriate prerequisites for an individual who will conduct the ground training. The requirements specified for RGR take-off flight instructors, which are described below, would also be suitable criteria for ground instructors.

Airspeeds

• (1) Ground training respecting airspeeds is intended to ensure that flight crews are aware of the aerodynamic factors associated with RGR take-offs.
• (2) Ground training regarding V_MCA should include the factors which affect V_MCA, the hazards associated with engine failure at a speed less than V_MCA, and how these hazards are mitigated.
• (3) Ground training regarding stalling speed should include the factors which affect stalling speed, the associated hazards, and how these hazards are mitigated.
• (4) Ground training respecting Decision Speed (V₁), is particularly important. Flight crews must have a thorough understanding of the reasons to conduct a rejected take-off:
  • (a) Prior to the aircraft becoming airborne, a take-off will be rejected because of an engine failure and can also be rejected because of other malfunctions or abnormalities; and
  • (b) Once the aircraft is airborne and at a speed less than V₁, there are limited reasons for conducting a rejected take-off; these include an engine failure or other emergencies affecting the safety of flight.

Conditions and limitations

• (1) The conditions of the SA for RGR take-off and the limitations stipulated in the approved RGR Take-off AFMS have been specifically developed to ensure that RGR take-offs are conducted in a safe manner.
• (2) Ground training respecting conditions and limitations is intended to ensure that flight crews are aware of these important safety mitigations.

Normal and emergency procedures

• (1) The purpose of this element of ground training is to ensure the pilots have sufficient background knowledge to safely conduct the normal and emergency procedures specified in the approved RGR Take-off AFMS.
• (2) Items to be covered include, but are not necessarily limited to:
  • (a) all elements of the published procedure;
  • (b) the pre-take-off briefing stipulated in Paragraph (g) of the SA for RGR take-off;
  • (c) the "airborne V₁" concept, and the actions that must be taken should an engine failure occur during an RGR take-off:
    • (i) duties of the pilot monitoring, including, but not limited to: monitoring the engine instruments and promptly calling out any abnormalities, and
    • (ii) duties of the pilot flying (PF).
  • (d) The potential hazards associated with each of these procedures and how these potential hazards are mitigated.
• (3) The duties of each flight crew member must be clearly understood:
  • (a) During an RGR take-off, the PF needs to focus on flying the aircraft; the pilot must accurately control the aircraft’s flight path as he/she accelerates the aircraft at 5 feet or less above the take-off surface (while ensuring that the aircraft does not re-contact the surface).
  • (b) While the PF focuses on flying the aircraft, the PM must closely monitor the engine instruments, immediately call out any abnormalities and also call out V₁. (In so doing, the PM serves an important role in off-loading the engine monitoring function from the PF, increasing the PF’s situation awareness and facilitating the PF’s quick response to an engine failure.)
  • (c) It must also be understood that prior to V₁, a timely announcement of an engine failure from the PM and prompt action by the PF, will help to reduce the distance required to stop the aircraft during a rejected take-off. This is particularly important when conducting the procedure for Engine Failure Airborne, Prior to V₁.
  • (d) Additionally, it must be emphasized that the PM must call out V₁ in a timely manner, thereby facilitating the correct reject/continue (go/no go) decision on the part of the PF.

Performance charts

• (1) The purpose of this element of ground training is to ensure the pilots are able to determine that there is sufficient distance available to safety conduct a take-off and account for an engine failure or other abnormal or emergency, as stipulated in paragraph (c) for the SA for RGR take-off.
• (2) Pilots need to understand that for an RGR take-off, the length of the runway (take-off surface) is not limited by accelerate-stop distance (ASD). The value for ASD published in the approved RGR Take-off Supplement to the DHC-6 AFM is to be used as a guide to ensure that a suitable area for a forced landing is available if a rejected take-off is initiated while airborne prior to V₁.
• (3) RGR take-offs are frequently conducted on surfaces that are not dry, hard, or level. Therefore, pilots must understand the need to allow for degradation in take-off performance arising from the unique characteristics of each runway (take-off surface) at which an RGR take-off is conducted.
• (4) It is recommended that air operators and private operators address training respecting performance charts by providing trainees with practical examples from aerodromes within their own area of operations.
• (5) This training element can also be utilized to provide an opportunity to exercise pilot decision-making skills.

Written examination

• (1) The written examination can be either open-book or closed-book, as determined by the air operator or private operator.

• (1) The requirements respecting the validity periods for initial or recurrent ground training mirror the validity period requirements for initial or recurrent flight training.
• (2) A proven effective way for an individual to learn something – or to review something – is by teaching it. For this reason, ground training instructors have been given the flexibility to have their own personal validity period – for initial or recurrent ground training – renewed through the action of providing instruction, within the constraints specified.

• (1) In order to qualify an individual to serve as an instructor for RGR ground instruction, the ground training requirements specified in paragraphs (k) and (l), can be deemed to have been met if an individual:
  • (a) thoroughly reviews all of the elements of the initial or recurrent RGR ground training, as specified in paragraph (k);
  • (b) has been assessed to be qualified to conduct the RGR ground training by the air operator’s or private operator’s Chief Pilot or a person designated by the Chief Pilot; and
  • (c) has had this assessment documented and retained on the instructor's file for a period of three years as per paragraph (j)
• (2) If authorized in their approved training program, an air operator or private operator may engage a third party training organization to conduct RGR ground training, and may delegate the qualifying and assessment of RGR ground instructors – as specified in paragraphs (1) and (2) above – to the management of this training organization. In this case, the instructor and third party training organization must fulfill the requirements specified in paragraph (2), above – and the assessment of the instructor’s qualifications will be assessed and documented by a person designated by the senior management of the third party training organization.

Overview

• (1) The aim of the flight training is to ensure that trainees are able to demonstrate the required proficiency. Towards this end, instructors should reference the manufacturer’s guidance for specific criteria to be used in the assessment of RGR normal and emergency procedures.
• (2) In attaining the required proficiency, pilot trainees must have sufficient opportunity to practice each of the required procedures. For guidance in achieving the required proficiency, the matrix below provides recommendations for the minimum number of each manoeuvre which should be conducted in an aeroplane or flight simulation training device (FSTD):

  Training Element	Initial	Recurrent
  Normal Procedures (RGR), Take-off	5	2
  Engine Failure During Take-off, Prior to Liftoff	1	1
  Engine Failure Airborne, Prior to V1	2	1
  Engine Failure Airborne, After V1	2	1

• (3) Trainees may need to conduct additional manoeuvres, as required, in order to achieve the objective of having the flight instructor assess them as proficient.

Flight training conducted in an aeroplane

• (1) Warning: Air operators, private operators and flight instructors must utilize conservative judgement to ensure that adequate safety margins are provided during RGR take-off flight training conducted in an aeroplane. In particular, all personnel:
  • (a) must comply with the direction and guidance stipulated in this Annex; and
  • (b) should adhere to the recommendations respecting safe training practices provided in the Viking DHC-6 Twin Otter Reduced Ground Roll (RGR) Take-off – Pilot Procedures and Training Guide (PPTG). These include, but are not limited to recommendations respecting:
    • Minimum runway requirements (width and length);
    • Environmental requirements (including crosswind);
    • Altitude and airspeed requirements; and
    • Restrictions on the use of asymmetric power.
• (2) Air operators, private operators and flight instructors must be aware of the potential hazards and risks which exist during RGR flight training. These risks include, but are not necessarily limited to:
  • (a) runway over-run – especially during a rejected take-off (and landing) which is initiated while the aircraft is airborne at a speed less than V₁;
  • (b) lateral excursion from the runway – which may lead to contact with other aircraft or an obstacle – particularly if adequate directional control is not established and maintained throughout the take-off and/or rejected take-off;
  • (c) rough landing – if the controls are mishandled during a rejected take-off which is initiated while the aircraft is airborne at a speed less than V₁; and/or
  • (d) poor aircraft control resulting in a potential stall and/or loss of altitude – if the controls are mishandled during simulated engine failure which is initiated while the aircraft is airborne at a speed greater than V₁.
• (3) The training requirements for rejected take-offs can be satisfied by having the pilot undergoing training verbally explain these procedures during a briefing.

  Note: Training for “rejected take-offs” refers to both the Emergency Procedures, Engine Failure During Take-off, Prior to Liftoff and Emergency Procedures, Engine Failure Airborne, Prior to V₁ as detailed in Appendix A, subparagraphs (m)(ii) and (m)(iii) of this AC.

• (4) Air operators and private operators also have the option of conducting training for rejected take-offs in an aeroplane. The decision to conduct training for rejected take-offs in an aeroplane is at the discretion of the air operator or private air operator, and must be made in consideration of the factors listed above, and must also consider the experience level of the pilot conducting training and the pilot being trained.
• (5) When training for rejected take-offs in an aeroplane, the pilot conducting training must not create an asymmetric power situation by reducing power on one engine. Instead, the pilot conducting training should verbally prompt the pilot trainee to conduct the rejected take-off by calling “reject” (or whatever equivalent term has been adopted).
• (6) Training conducted in an aeroplane, respecting the approved RGR Take-off AFMS, Emergency Procedures, Engine Failure Airborne, After V₁, is subject to the following limitations:
  • (a) simulated engine failures shall be conducted at a safe altitude, not less than 4000 ft AGL; and
  • (b) simulated engine failures shall not be initiated at a speed less than V₁ + 5 kts.
• (7) The safe training practices provided in this AC and the Viking DHC-6 Twin Otter Reduced Ground Roll (RGR) Take-off – Pilot Procedures and Training Guide (PPTG) are intended to reflect the conservatism provided in numerous sources including, but not limited to, the following:
  • (a) Commercial Air Service Standard (CASS) 722 Schedule I - Pilot Proficiency Check (PPC) – Aeroplane;
  • (b) CASS 723 (Aeroplane) Schedule I – PPC;
  • (c) CASS 724 (Aeroplane) Schedule II – PPC - Aeroplane;
  • (d) TP 6533: Approved Check Pilot Manual, Appendix A – Safe Checking Practices; and
  • (e) TP 14727E, Second Edition, (11/2007) – Pilot Proficiency Check and Aircraft Type Rating, Flight Test Guide (Aeroplanes)
• (8) Where practicable, the pilot trainee should demonstrate the ability to conduct RGR take-offs during crosswind conditions.

Flight training conducted in a flight simulation training device (FSTD)

• (1) For training in an FSTD respecting a ground rejected take-off in accordance with the Engine Failure, Prior to Liftoff procedure, the engine failure should be simulated after nose wheel lift-off, while the main landing gear is still in contact with the runway (take-off surface).
• (2) For training in an FSTD respecting an airborne rejected take-off in accordance with the Engine Failure Airborne, Prior to V₁ procedure, the engine failure should be simulated when the aircraft is airborne at a speed less than V₁.
• (3) For training in an FSTD respecting an airborne continued take-off in accordance with the Engine Failure Airborne, After V₁ procedure, the engine failure should be simulated when the aircraft is airborne, after V₁. This training should include a simulated failure of the critical (left) engine.

(n) Validity period for initial and recurrent RGR flight training

• (1) Reserved

(o) Exception for the purposes of flight training

• (1) Paragraphs (m) and (n) are intended to restrict the conduct of RGR take-offs – for operational purposes – to those who have completed initial or recurrent RGR flight training. The imperative language used in these provisions therefore requires an exception (relief provision), to enable a pilot to conduct an RGR take-off – for the purpose of completing their required flight training. (Without such an exception, an unresolvable situation would be created, whereby a pilot could not conduct an RGR take-off for flight training – because they had not already completed their flight training.)
• (2) Paragraph (o) requires that “no passengers are carried” during RGR take-off flight training. In this context, other individuals who are required to be on board, for flight training and/or checking purposes, are not considered to be passengers. These may include:
  • (a) the air operator’s/private operator’s:
    • (i) pilot trainees, and
    • (ii) flight instructors and/or check pilots; and
  • (b) TC personnel.

(p) 90-Day recency requirement

• (1) The 90-day recency requirement is intended to mitigate the elevated workload, as well as the increased skill and alertness that are required when conducting an RGR take-off.
• (2) The RGR take-offs required for initial and recurrent flight training can be utilized to fulfill the requirements for 90-day recency.
• (3) The RGR take-offs may be conducted from any runway or surface in order to fulfill the requirements for 90-day recency. They may, for example, be conducted on a hard surface runway during a positioning flight, since there is no requirement for these take-offs to be conducted from an unprepared surface.

(q) Exception for the purpose of regaining the 90-day recency requirement

• (1) The goals of this condition are to ensure safety by ensuring that RGR take-offs are only conducted by those individuals who have completed the required RGR ground and flight training – and at the same time provide flexibility to air operators and private operators as to how the 90-day recency is regained.
• (2) An air operator or private operator may permit a person to conduct RGR take-off, providing:
  • (i) the person has met the ground training requirements specified in paragraphs (k) and (l); and
  • (ii) the person conducting the take-off:
    • (A) is receiving flight instruction (dual) from an individual who meets the requirements specified in paragraph (r); or
    • (B) satisfies the applicable validity requirements for initial or recurrent flight training, as specified in paragraphs (m) and (n), and no passengers are carried.

(r) Flight training instructor requirements

Overview

• (1) Flight instructors have a vitally important role in helping air operators and private operators to establish and maintain safe and effective RGR operations.
• (2) As a minimum, RGR flight instructors must meet the ground training, flight training and recency requirements that have been established for pilots to conduct RGR take-offs.
• (3) Air operators and private operators are also strongly encouraged to consider the important role that flight instructors perform – and the unique circumstances of their operations – in determining whatever additional knowledge, skill or experience requirements would be appropriate.
• (4) Examples of additional requirements include, but are not limited to:
  • (a) operational experience conducting RGR take-offs;
  • (b) experience as a training pilot; and/or
  • (c) experience as an approved check pilot (ACP).

Instructors for flight simulation training device (FSTD) only

• (1) It should be noted that individuals who conduct RGR flight instruction in an approved FSTD – and do not conduct RGR flight instruction in an aeroplane – can utilize an approved FSTD to:
  • (a) complete the flight training requirements for Normal Procedures, Take-off specified subparagraph (m) and (i); and
  • (b) complete the 3 take-offs mandated by the 90-day recency requirement specified in paragraph (p).

• (1) In order to qualify an individual to serve as an instructor for RGR flight instruction, the ground training requirements specified in paragraphs (k) and (l), can be deemed to have been met if an individual:
  • (a) thoroughly reviews all of the elements of the initial or recurrent RGR ground training, as specified in paragraph (k);
  • (b) has been assessed to be qualified to conduct the RGR ground training by the air operator’s or private operator’s Chief Pilot or a person designated by the Chief Pilot; and
  • (c) has had the above assessment documented and retained on the instructor's file for a period of three years as per paragraph (j).
• (2) In order to qualify an individual to serve as an instructor for RGR flight training in an aeroplane or in an FSTD, the flight training requirements specified in paragraphs (m) and (n), can be deemed to have been met if an individual:
  • (a) is employed by an air operator or private operator that has been issued and conducts operations in accordance with the SA, DHC-6 Twin Otter – Reduced Ground Roll (RGR) Take-off;
  • (b) has within the last year conducted take-offs utilizing the approved RGR take-off procedures;
  • (c) has been assessed to be qualified to conduct the approved RGR flight training in an aeroplane or in an FSTD by the air operator’s or private operator’s Chief Pilot or a person designated by the Chief Pilot; and
  • (d) has had the above assessment documented and retained on the instructor's file for a period of three years as per paragraph (j).
• (3) During the implementation and transition period for the RGR procedures, for the purpose of qualifying an individual to serve as an instructor for RGR flight training in an FSTD only, the flight training requirements specified in paragraphs (m) and (n), can be deemed to have been met if an individual:
  • (a) has received flight instruction as stipulated in condition (m), in an aeroplane or an FSTD which has been approved for RGR flight training, from a training pilot designated by the type certificate holder for the DHC-6, Viking Aircraft Ltd. (VAL);
  • (b) has, on the basis of their performance during the aforementioned training, been recommended to serve as a flight instructor by the type certificate holder’s designated training pilot;
  • (c) has been assessed to be qualified to conduct the approved RGR flight training by the air operator’s or private operator’s Chief Pilot or a person designated by the Chief Pilot; and
  • (d) has had the above assessment documented and retained on the instructor's file for a period of three years as per paragraph (j).
• (4) If authorized in their approved training program, an air operator or private operator may delegate a third party training organization to conduct RGR flight training, and may delegate the qualifying and assessment of RGR flight instructors – as specified in paragraphs (1) to (4) above – to the management of this third party training organization. In this case, the instructor and third party training organization must fulfill the applicable requirements specified in paragraphs (1) to (4), above – and the assessment of the instructor’s qualifications will be assessed and documented by a person designated by the senior management of the third party training organization.

(s) Flight simulation and training device requirements

Validation and approval of a flight simulation training device (FSTD)

• (1) For the purpose of initial and recurrent RGR flight training, paragraph (m) authorizes the use of an FSTD – which has been specifically validated and approved for RGR take-offs.
• (2) Applications for the validation and approval of an FSTD are submitted to the Technical Team Lead (TTL) of the TC National Simulator Evaluation Program (NSEP)
• (3) An overview of the process for having a FSDT validated and approved for RGR take-offs appears below:
  • (a) The “sponsor” (FSTD owner/operator) provides TCCA NSEP with a letter of intent (LoI) to add RGR take-off qualification to the device.
  • (b) The sponsor submits a letter of compliance (LoC) that the FSTD has been validated by a suitably qualified person for RGR take-off.
  • (c) TC NSEP either accepts the statement of compliance – and/or conducts an evaluation/validation. (This is typically done within a month of receipt of the LoC.)
  • (d) Because the RGR take-off involves a flight regime which is outside of the normal flight envelop and for which there is no data (airborne in ground effect at a speed less than V_MCA), a subjective validation would be conducted.
  • (e) The subjective validation would typically involve two pilots (one from industry and one from TC) who would subjectively validate the simulator for RGR take-offs.