Recently, a Chief Flight Instructor at a flight school emailed the other instructors claiming that the mnemonic device ARROW is incorrect and should not be used as a memory aid to recall the documents required for a flight. It begs the question: Is this idea off base? Let's dissect.
The A in ARROW, of course, refers to an airworthiness certificate, for which there is no disagreement. Per FAR 91.203(a)(1), all aircraft must have an airworthiness certificate on board for operation that is visible to pilots and passengers.
The first R stands for aircraft registration. This document is required per FAR 91.203(a)(2). Again, there's no controversy here.
The second R stands for radio operator license, which is no longer required in the United States and hasn't been for over two decades.
The O stands for operating limitations, and this is where the disagreement began. The literal interpretation leads us to Section 2 of most POHs beyond the 1970s, which lays out specific numbers and required placards in unambiguous terms. Per FAR 91.9(a), no aircraft is permitted to be operated beyond these specified limitations.
The disagreement in using ARROW, specifically the O, was that no letter/letters indicate that "an aircraft flight manual or pilots operating handbook" is required. However, for many years, it has been understood and accepted that the term "operating limitations" refers to AFM/POH because they are the documents that contain said operating limitations. The O is simply a shortcut.
FAR 91.9(a) specifies that such documents are required to be on board U.S.-registered civil aircraft, again in very clear and plain English. Additionally, without creating excessive alphabet mnemonic device mayhem, certain supplementary documents may be required, such as the GPS operating handbook for Garmin G1000s and GNS 430W.
Lastly, the W refers to weight and balance. The argument put forth was that there is no regulation requiring that a weight and balance sheet be on board to operate a U.S.-civil registered aircraft. Technically, this is true.
But again, the use of this letter comes with something of an understanding rather than a literal imperative. By combining regulations, we can come to an understanding of the weight and balance data requirements.
So, as it stands, replacing ARROW with a new mnemonic seems unlikely. However, you may need to dissect ARROW — all its specifics, generalities, and how they combine — to understand everything it requires.