Narrative:

Due to full flight and alternate fuel on a short leg; we were needing to burn fuel to ensure we were below max landing weight at touchdown so I had configured to gear down flaps 45 prior to glide slope intercept. Due to landing performance on the wet runway at ZZZ a flaps 22 landing was not possible. The max weight meant that I could only add about 6 knots above vref to get my vapproach speed and this was only about 7 knots below flaps 45 maximum speed of 145 knots. This narrow window; fully configured and straight and level at 3900 MSL; led to very little speed margin to operate within. Identification: I called for go-around flaps 9 and added max power. The airspeed then exceeded the max flap speed anyway and got to 152 knots in the transition to go-around attitude. Cause: the wind at 3900 MSL was a quartering tailwind at roughly 60 knots while the ground reported variable at 5 knots. We reached the FAF (final approach fix) for the ILS 34 but I found the required descent rate to hold glide slope was steep; roughly 1400 rpm. I remarked to the first officer (first officer) that this might be too much but we were still above 1700 feet on the RA (radio altimeter) so I continued. At this time; a wind shear suddenly accelerated us to about 142 and I reduced some power to prevent flap speed exceedance. Another wind shear and we suddenly lost that speed and were at roughly vref with the trend bar much lower. Wind shear warning and stall warning systems were not activated. Response: we were cleared to climb runway heading to 4000 feet and contact departure. The aircraft was very difficult to control in moderate turbulence and windshears between 3000 and 4000 feet. We headed toward a hold and I decided we would try vectors to the ILS 22 and try to lose the tailwind but in vectoring onto final for runway 22 at 4000 feet the wind shear was so bad I was getting plus and minus 20 knots just in straight and level. I elected to discontinue this approach attempt as well and divert back to [the origin airport]. Suggestions: in situations of high aircraft weight combined with high; gusty winds and/or wind shear; the policy to remove momentary deviations up to 155 knots at flaps 45 is putting the pilots at a great disadvantage and decreasing safety margins. When a flaps 22 landing is not possible due to runway performance; we are forced to fly it flaps 45; not add proper wind correction amounts for approach speeds; and try to fly within a window of as low as 12 knots between vref and max flap speed. I believe this policy change should be reversed and momentary deviations up to 155 knots should again be allowed to restore previous speed and safety margins.

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Original NASA ASRS Text

Title: EMB-145 Captain reported aircraft flap speed exceedance during Missed Approach maneuver while experiencing wind shear.

Narrative: Due to full flight and alternate fuel on a short leg; we were needing to burn fuel to ensure we were below Max Landing Weight at touchdown so I had configured to gear down flaps 45 prior to glide slope intercept. Due to landing performance on the wet runway at ZZZ a flaps 22 landing was not possible. The max weight meant that I could only add about 6 knots above Vref to get my Vapproach speed and this was only about 7 knots below flaps 45 maximum speed of 145 knots. This narrow window; fully configured and straight and level at 3900 MSL; led to very little speed margin to operate within. Identification: I called for go-around flaps 9 and added max power. The airspeed then exceeded the max flap speed anyway and got to 152 knots in the transition to go-around attitude. Cause: The wind at 3900 MSL was a quartering tailwind at roughly 60 knots while the ground reported Variable at 5 knots. We reached the FAF (Final Approach Fix) for the ILS 34 but I found the required descent rate to hold glide slope was steep; roughly 1400 rpm. I remarked to the FO (First Officer) that this might be too much but we were still above 1700 feet on the RA (Radio Altimeter) so I continued. At this time; a wind shear suddenly accelerated us to about 142 and I reduced some power to prevent flap speed exceedance. Another wind shear and we suddenly lost that speed and were at roughly Vref with the trend bar much lower. Wind shear warning and stall warning systems were not activated. Response: We were cleared to climb runway heading to 4000 feet and contact departure. The aircraft was very difficult to control in moderate turbulence and windshears between 3000 and 4000 feet. We headed toward a hold and I decided we would try vectors to the ILS 22 and try to lose the tailwind but in vectoring onto final for Runway 22 at 4000 feet the wind shear was so bad I was getting plus and minus 20 knots just in straight and level. I elected to discontinue this approach attempt as well and divert back to [the origin airport]. Suggestions: In situations of high aircraft weight combined with high; gusty winds and/or wind shear; the policy to remove momentary deviations up to 155 knots at flaps 45 is putting the pilots at a great disadvantage and decreasing safety margins. When a flaps 22 landing is not possible due to runway performance; we are forced to fly it flaps 45; not add proper wind correction amounts for approach speeds; and try to fly within a window of as low as 12 knots between Vref and max flap speed. I believe this policy change should be reversed and momentary deviations up to 155 knots should again be allowed to restore previous speed and safety margins.

Data retrieved from NASA's ASRS site and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.