COMMUTER PIC COMPLAINS OF ACFT PERFORMANCE WITH REGARDS TO RWY LENGTH REQUIRED UNDER FARS FOR TRANSPORT ACFT VERSUS PROVISIONALLY CERTIFIED CIVIL ACFT OPERATING LIMITATIONS UNDER SFAR 41. OBSTRUCTION STANDARDS CLRNC ALSO A MATTER OF CONCERN.

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I HAVE BROUGHT UP THE FOLLOWING CONCERNS TO OUR MGMNT: OUR RWY ANALYSIS DATA FOR THE METRO AT EYW AND APF DOES NOT PROVIDE FOR OBSTACLE CLRNC. MGMNT HAS DONE NOTHING ABOUT IT. THEY HAVE NOT ACKNOWLEDGED MY MEMO. IT IS THE OPINION OF MANY PEOPLE THAT THE SA227 IS AN SFAR 41 ACFT; SO IT DOES NOT REQUIRE OBSTACLE CLRNC EXCEPT AS REQUIRED BY OURS OPS SPECS FOR LOW VISIBILITY TKOF (LESS THAN 1200 RVR). AT MOST ARPTS; CLB PERFORMANCE IS LIMITING. AT EYW AND APF; THE RWY ANALYSIS CHARTS IN THE ACFT SHOW WE CAN TKOF AT 14500 LBS AT 35 DEGS C. THIS IS BASED ON 2 ENG CLB TO 50 FT; ACCELERATED/STOP AND BRAKING DISTANCE. AT 35 DEGS C THE SINGLE ENG CLB TO 35 FT INDICATES ABOUT 7200 FT OF RWY IS REQUIRED. (APR HAS 5000 FT; EYW HAS 4800 FT.) OUR PLTS ARE TRAINED TO ABORT BEFORE V1 OR TO CONTINUE AFTER V1 (IF THERE IS A PROB). ABOVE 15-20 DEGS C; A 14500 LB ACFT WOULD NOT HAVE ENOUGH RWY TO ACCELERATE AND CLB OUT. OUR CUSTOMERS BUY ACR X TICKETS. I DON'T THINK THEY REALIZE THE SUBSTANDARD LEVEL OF SAFETY ON A COMMUTER FLT VERSUS A TRANSPORT CATEGORY ACFT. MY COMPANY COULD RESTRICT TKOF WT OR USE ALCOHOL WATER; BUT REFUSES TO. I BELIEVE THE MGMNT OF FLT OPS (WHO GET A BONUS FOR PERFORMANCE) HAVE CHOSEN TO NOT ADDRESS THE ISSUE. I UNDERSTAND A MEMO WAS WRITTEN BY SOMEONE IN THE TRAINING DEPT TO RESPOND TO MY MEMO. I NEVER GOT THE MEMO; APPARENTLY IT WAS SQUASHED BY MGMNT. I GUESS A WRITTEN RESPONSE WOULD PREVENT A DEFENSE OF 'PLAUSIBLE DENIABILITY' BY MGMNT.