EMB145 PLT RPT ON HIS ACR'S ATTITUDE AND THE OBVIOUS DISAGREEMENT WITH THE FLT CREWS ON AN ACFT CONFIGN POLICY REGARDING THE USE OF FLAPS AT 22 DEGS VERSUS THE REQUIRED 45 DEGS. THIS 22 DEG FLAP CONFIGN IS USED BY FLT CREWS FOR APCHS AND LNDGS DURING TURBULENT WINDSHEAR CONDITIONS AT ANY ARPT.

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I DEVIATED FROM MY ACR'S COMPANY POLICY BY INTENTIONALLY PERFORMING A FLAPS 22 DEG LNDG INSTEAD OF THE NORMAL PROC OF FLAPS 45 DEG LNDG. THE REASON FOR THE DEV WAS THE HVY LNDG WT OF THE ACFT; THUS THE HIGH REF AND TARGET SPDS; IN COMBINATION WITH GUSTING WINDS ON THE GND. THE BIGGEST FACTOR IN MY JUDGEMENT TO EXECUTE THE LNDG IS FLYABILITY ISSUES. THE MAIN REASON FOR DOING THE FLAPS 22 DEG LNDG; AND FLYING A HIGHER APCH AND LNDG SPD; IS THAT THE ACFT HANDLES BETTER AND IS EASIER TO FLY. FLYING A FASTER APCH DURING GUSTY WINDS ALLOWS THE AIRPLANE TO PENETRATE AND SPEND LESS TIME IN EACH GUST WHICH LESSENS THE 'WALLOWING' FEEL TO THE ACFT. FLYING A FASTER APCH GIVES MORE AIRFLOW OVER THE AILERONS FOR MORE AUTH TO COUNTERACT THE GUSTS. SHOULD A GAR BE NECESSITATED BECAUSE OF A DANGEROUS LOSS OF SPD/LIFT; IT IS EASIER FOR THE PLANE TO PWR-OUT OF THE SIT USING A FLAPS 22 DEG CONFIGN THAN A FLAPS 45 DEG CONFIGN. I HAVE RECENT FIRST-HAND EXPERIENCE WITH THIS; AND KNOW HOW MUCH PWR IT TAKES TO PWR-OUT OF A SUDDEN LOSS OF LIFT SIT USING FLAPS 45 DEG CONFIGN. FLAPS 45 DEGS ARE LIKE BIG BARN DOORS; BEING IMPACTED MORE BY BIG GUSTS OF WIND THAN FLAPS 22 DEGS. FROM A CTLABILITY STANDPOINT; THIS IS AN ISSUE. AS A FO; I FLEW WITH SEVERAL CAPTS WHO EXECUTED FLAPS 22 DEG LNDGS FOR GUSTY WINDS AND/OR IN ANTICIPATION OF A POSSIBLE WINDSHEAR; AND THE NEED TO ESCAPE IT. IT WAS MY EXPERIENCE THAT THESE LNDGS TURNED OUT BETTER THAN THOSE PERFORMED BY THOSE WHO DID FLAPS 45 DEG LNDGS IN THE SAME CHALLENGING CONDITIONS. ANOTHER FACTOR IN MY JUDGEMENT TO EXECUTE A FLAPS 22 DEG LNDG WAS A SORT OF OBSERVANCE OF THE FLAPS 45 DEP SPD LIMITATION OF 145 KTS. WITH A TARGET SPD OF 140 KTS; WINDS 50 DEGS TO THE SIDE AT 20 KTS; GUSTING TO 38 KTS; JUST FOLLOWING SIMPLE COMPANY POLICY OF ADDING 1/2 THE HEADWIND AND ALL OF THE GUST; FOR A TOTAL UP TO 15 KTS; WOULD HAVE PUT ME OVER THE 145 KT LIMITATION SPD AT 155 KTS -- 10 KTS MORE THAN THE LIMITATION SPD. NOW; THAT IS JUST THE SPD I AM SUPPOSED TO FLY; WHAT ABOUT GUSTS FROM 20 KTS TO 38 KTS? WE ARE LOOKING AT AIRSPDS CONCEIVABLY UP TO 173 KTS -- 28 KTS HIGHER THAN THE LIMITATION. THESE ELEMENTS; LOGIC AND EXPERIENCE; TRAINING AND CONCERN FOR OBSERVANCE OF A STRUCTURAL LIMITATION; IS WHY I PERFORMED A FLAPS 22 DEGS LNDG. IT IS NOT BECAUSE I AM CAVALIER; LAZY; OR NOT BEING ABLE TO GET STABILIZED AT FLAPS 45 DEGS BY 500 FT AGL. I PERFORMED THIS MANEUVER WITH CONFIDENCE KNOWING THAT THIS WAS THE MOST SAFE WAY TO LAND THE AIRPLANE GIVEN THE CIRCUMSTANCES. MANY ACR PLTS; WHEN PRESENTED THE SAME SET OF CIRCUMSTANCES -- HVY LNDG WT AND VERY GUSTY WINDS -- WILL DO A FLAPS 22 DEG LNDG. THESE ARE RARE CIRCUMSTANCES; MAYBE 2; 3; OR 4 A YR PER PLT. PLTS DO NOT WANT TO DEVIATE FROM COMPANY PROC. IF THEY SIMPLY HAD THE FLAPS 22 DEG PROC THERE WOULD HAVE BEEN NO DEV FROM COMPANY POLICY. YES; THERE ARE AVENUES TO SOLVING SUCH DISCREPANCIES; BUT SAFETY; ESPECIALLY THAT WHICH A PLT CAN CTL; CANNOT AND WILL NOT WAIT ON SAFETY COMMITTEE ORGANIZATION; AIRLINE CPR POLITICS; AND FAA EVALUATION. I HAVE PERSONALLY BROUGHT THE SUBJECT OF FLAPS 22 DEG LNDGS TO ACR'S ATTN SEVERAL TIMES. WHERE THE PROGRESS IS; I DO NOT KNOW. ALL I DO KNOW IS THAT WE DO NOT HAVE A FLAPS 22 DEG PROC -- AND THAT IS NOT MY FAULT. WHILE MANY OFFICIALS WOULD LIKE TO DEVELOP POLICIES THAT CAN AND WILL BE FOLLOWED 100% BY 100% OF THE PLTS; 100% OF THE TIME; IT SHOULD BE THEIR HIGHER AGENDA TO MAKE SURE PLTS SIMPLY USE GOOD JUDGEMENT AND OBTAIN SATISFACTORY RESULTS. IF YOU RECOGNIZE AND PROMOTE GOOD JUDGEMENT; YOU WILL GET A PLT THAT DELIVERS SAFE; COMFORTABLE; AND PROFITABLE FLTS. PERSONALLY; I THINK PLTS SHOULD FOLLOW PROCS -- PROCS THAT MAKE SENSE AND ARE DEVELOPED BY THOSE WHO DO THE JOB. WHEN THIS PARADIGM SHIFT IN PHILOSOPHY OCCURS; IS WHEN A REAL IMPROVEMENT IN SAFETY WILL OCCUR AT MY AIRLINES. CALLBACK CONVERSATION WITH RPTR REVEALED THE FOLLOWING INFO: RPTR ADMITTED THAT THEIR SAFETY GROUP IS NOT WELL ORGANIZED AS THEY FALL UNDER A GND TRANSPORTATION UNION'SAFFILIATION AND DO NOT HAVE A LOT OF CLOUT WITH THE FAA. AT A PLT MEETING THE ISSUE WAS ADDRESSED WITH THE CHIEF PLT SAYING THAT THIS ISSUE WAS ON A 'BACK BURNER' DUE TO A NEW ACFT COMING ON LINE AND THAT THEY DID NOT HAVE THE RESOURCES TO TACKLE THIS PROB RIGHT NOW. LATER IT WAS FOUND THAT THE ISSUE OF 22/45 WAS NOWHERE NEAR ANY 'BURNER.' RPTR SAID THAT ANOTHER ACR HAS THIS POLICY AND PROCS WITH THE SAME ACFT. HE ADDED THAT THE GRAPEVINE HAD IT THAT THIS AIRLINE ALSO SUFFERED 5 RWY EXCURSIONS OFF THE END BECAUSE OF FLAPS 22 DEG LNDGS; BUT ATTRIBUTED THIS TO 'PLT ERROR.' THERE HAS NOT BEEN AN EXCURSION ON THE END WITH HIS ACR. HE FURTHER STATED THAT THE INCREASE ON BUG SPD WAS BUT 10 KTS FOR 22 DEG FLAPS AND THAT HE HAD MADE ONE LATELY WITH A LIGHT ACFT IN A +38 KT WINDSHEAR CONDITION. HE SAID THERE WAS A 'VAST DIFFERENCE' IN THE HANDLING QUALITIES OF THE ACFT WITH 22 DEG FLAPS; FEELING IT WAS ALSO MUCH SAFER.