All smoke no fire

[Bart]

With all the heated debate over trival issues that I've seen in this
newsgroup, I have to say I'm really disappointed with what I'm seeing as
response to a real issue that affects the value of operating a helicopter in
the US.

Maybe you guys don't understand the impact of the proposed rule change.
Here's what they're doing if it passes, this applies to all 121,135, and 91
operators:

* You'll be requred to fly at or above 1500 AGL during non takeoff and
landing phases

* You'll be required to have pop-out floats for overwater flights.

* Regardless of the airspace, you'll have to have cloud clearance of 500
below, 1000 above, and 2000 lateral,. as well as maintaining an 1200 ft AGL
alt.

* Gone is the ability to operate "without hazard to persons or property",
You'll be required to maintain airplane-like standoff distances.

* Operation within the H/V curve, regardless of flight phase is prohibited,
(IE: NO max performance or confined area departures / appches. )

Basically stated; The FAA will be removing any reason that you would want to
operate a helicopter vs. an airplane.

If you care about this at all, please voice your opinion at:
http://www1.faa.gov/avr/arm/forum/Hypertextedintroductorypage.htm

Bart

[Bob]

Bart...

Kindly direct us to that "FAA statement" in print regarding "no reason to
operate a helicopter rather than an airplane". While I would share some of
your panic stricken sounding concerns, on the matter of the "statement", I
think that you are full of ****, and will promptly apologise when you prove
otherwise.

Bob

[Bob]

OH (duh) I DO apologise already. "Basically Stated" is YOUR statement.

That's why there are NPRM's. I assume you voiced your concerns to the FAA
appropriately. This forum will get you nowhere.

Bob

[Bart]

Bob,

Yes, I did respond to the FAA, both with an initial comment and to their
online meeting thing. I also carefully read the NPRM a couple times, and I
looked at the incident reports that the FAA cited as justification for the
NPRM.

My concern is for the industry as a whole. I thought back about every
air-tour weve ever done, and not one of them would be legal under the new
NPRM. I can't even imagine any customer being happy with a tour conducted at
1200-1500 ft. Especially since they can hire an airplane to do the same ride
for 1/5th the cost that we would be able to do it. We already installed
floats on machine last year, and the cost was painful. I can imagine that
this requirement would be the kiss of death for some operators.

Bart

"Bob" > wrote in message
...
> OH (duh) I DO apologise already. "Basically Stated" is YOUR statement.
>
> That's why there are NPRM's. I assume you voiced your concerns to the FAA
> appropriately. This forum will get you nowhere.
>
> Bob
>
>

[Rocky]

"Bob" > wrote in message >...
> OH (duh) I DO apologise already. "Basically Stated" is YOUR statement.
>
> That's why there are NPRM's. I assume you voiced your concerns to the FAA
> appropriately. This forum will get you nowhere.
>
> Bob

Bob
Why run off someone with a voice of dissent? I was glad to see someone
cared enough to take time to alert those of us who DON'T spend a lot
of time watching the FAA and NPRM's.
Rocky

[Bob]

Matter of fact Rocky...I apologised to Bart RIGHT OFF as I said I would,
having misunderstood his post the first time I read it, not too carefully.
Having been in in heavy helicopter operations and maintenance for some 20
years...sightseeing with 206's, Astars, Twinstars, Dauphines et.al. and
transport category ops. with S-61N's, and Chinooks...I have a clue. At the
end of the day, however, what Bart is addressing is the Bottom Line, not
fixed wing vs. helicopter performance. I share some of his views, but not
all. Floats for continuous overwater operations sounds like a good idea to
me considering the altitudes HE wants to operate at. When a single engine
fails overwater in a helicopter, where are you going??? I thought you would
arrive at that conclusion. EVEN with floats sightseeing, I have seen ONE
float deploy. What does that do for your day, and that of your sightseers?

Perhaps I shouldn't invite myself to a recreational rotorcraft forum. I
guess I've been working with pros for a LOOOng time and may get testy with
some of the opionated, but less experienced. The FAR's and the NPRM's are
there for ALL operators whether you consider yourself exempt from them or
not, and the wise pay attention. Credit to Bart in that respect. I had NO
intention of starting a ****ing contest, although I HAVE seen a few
recreationalists who should be flying around in a cage. NO reflection
intended on the rest of you although their actions do cast aspersions,
wouldn't you agree?

There's NO room up there ANYWHERE for the ignorant.
Bob

[Rocky]

"Bob" > wrote in message >...
> Matter of fact Rocky...I apologised to Bart RIGHT OFF as I said I would,
> having misunderstood his post the first time I read it, not too carefully.
> Having been in in heavy helicopter operations and maintenance for some 20
> years...sightseeing with 206's, Astars, Twinstars, Dauphines et.al. and
> transport category ops. with S-61N's, and Chinooks...I have a clue. At the
> end of the day, however, what Bart is addressing is the Bottom Line, not
> fixed wing vs. helicopter performance. I share some of his views, but not
> all. Floats for continuous overwater operations sounds like a good idea to
> me considering the altitudes HE wants to operate at. When a single engine
> fails overwater in a helicopter, where are you going??? I thought you would
> arrive at that conclusion. EVEN with floats sightseeing, I have seen ONE
> float deploy. What does that do for your day, and that of your sightseers?
>
> Perhaps I shouldn't invite myself to a recreational rotorcraft forum. I
> guess I've been working with pros for a LOOOng time and may get testy with
> some of the opionated, but less experienced. The FAR's and the NPRM's are
> there for ALL operators whether you consider yourself exempt from them or
> not, and the wise pay attention. Credit to Bart in that respect. I had NO
> intention of starting a ****ing contest, although I HAVE seen a few
> recreationalists who should be flying around in a cage. NO reflection
> intended on the rest of you although their actions do cast aspersions,
> wouldn't you agree?
>
> There's NO room up there ANYWHERE for the ignorant.
> Bob

Bob
Yep I pretty much agree with your point and position. Simple age has
kind of kicked me out of the seat after about 40 years so I don't have
the day to day interest that active guys like you have. When I was
making 100% of my living pulling/pushing controls in helicopters (and
airplanes) I was much more attuned to the NPRM's and made many
responses to them as appropriate. It was a real shock for me to find
out how few pilots DO respond, and how much weight is given to those
who DO. In fact, it was outright scary in some cases.
Like you, I too have been known to get a bit testy and have on more
than one occasion really ****ed off a few and got BBQ'd over it. That
in part may be why so many of the old pros opted out of this NG? I
just hang around and stick in my two bits worth once in a while when
something catches my eye.
If you lose an engine with a single engine airplane over water you are
in the same mess!! I gave that a lot of thought while ferrying
helicopters down south back in the early 80's and had to go out
offshore of Nicaraugua. Didn't want to become a house guest of the
Sandanistas for any prolonged period of time!
Fly safe up there. Best professional regards
Rocky

[Bob]

Rocky...
I appreciate your most courteous response and your experience. Myself, I've
been a maintenance guy for those years; bent lots of wrenches, but mostly
QC, & QA and therefore I was the first office to see all the regulatory B.S.
I've begrudgingly realized that all that nonsense was actually my passion
but it took a mandatory retirement due to MS to make me realize it. Maybe
we'll stick around and keep these guys honest, huh?
Bob

[LM Scott]

"Bob" > wrote in message
...
> Rocky...
> I appreciate your most courteous response and your experience. Myself,
I've
> been a maintenance guy for those years; bent lots of wrenches, but mostly
> QC, & QA and therefore I was the first office to see all the regulatory
B.S.
> I've begrudgingly realized that all that nonsense was actually my passion
> but it took a mandatory retirement due to MS to make me realize it. Maybe
> we'll stick around and keep these guys honest, huh?
> Bob
>
> As a wannabe/know-nothing I sure do hope you guys will stay around to keep
this forum honest!<G> Bob, you might enjoy looking back through the usenet
archives although I'm not sure how to get there myself. You'll be both
entertained at how vital and dynamic this group was a few years back and
saddened too by how much we've all lost by it's near death:( Do you hang
out on PPRUNE? It's a real pro forum but I hope you'll still come here for
informal conversation<G> Larry

[Stan Gosnell]

"Bart" > wrote in :

> With all the heated debate over trival issues that I've seen in this
> newsgroup, I have to say I'm really disappointed with what I'm seeing
> as response to a real issue that affects the value of operating a
> helicopter in the US.
>
> Maybe you guys don't understand the impact of the proposed rule
> change. Here's what they're doing if it passes, this applies to all
> 121,135, and 91 operators:

No, it does not apply to all operators. Don't lie about it just to scare
people.

> * You'll be requred to fly at or above 1500 AGL during non takeoff and
> landing phases

No, you won't. Helicopters can still go down to 300', which IMO is too low
anyway.

> * You'll be required to have pop-out floats for overwater flights.

So? You should have them if you're carrying fare-paying passengers over
water. If you don't, you're negligent.

> * Regardless of the airspace, you'll have to have cloud clearance of
> 500 below, 1000 above, and 2000 lateral,. as well as maintaining an
> 1200 ft AGL alt.

For tours, I don't see the problem. It is draconian, but trying to show
the sights in low visibility is stupid anyway. This ONLY applies to tour
operations, which have a poor record in poor weather.

> * Gone is the ability to operate "without hazard to persons or
> property", You'll be required to maintain airplane-like standoff
> distances.

Not true.

> * Operation within the H/V curve, regardless of flight phase is
> prohibited, (IE: NO max performance or confined area departures /
> appches. )

Again, not true. Takeoff and landing are excepted. This only prohibits
hovering inside volcanoes, etc, which has been killing innocent passengers.

> Basically stated; The FAA will be removing any reason that you would
> want to operate a helicopter vs. an airplane.

You're full of it. All this just is not true.

> If you care about this at all, please voice your opinion at:
> http://www1.faa.gov/avr/arm/forum/Hypertextedintroductorypage.htm

My opinion is that this NPRM is far overdue.

--
Regards,

Stan

[Bart]

"Stan Gosnell" > wrote in message
> > Maybe you guys don't understand the impact of the proposed rule
> > change. Here's what they're doing if it passes, this applies to all
> > 121,135, and 91 operators:
>
> No, it does not apply to all operators. Don't lie about it just to scare
> people.

It applies to all operators conducting air-tours under these parts
Application of the new Part 136 appears to extend these limitations to all
passenger for hire operations. It was not my intent to scare, only to
motivate others to read the NPRM and comment to the FAA on how they felt
about it.

>
> > * You'll be requred to fly at or above 1500 AGL during non takeoff and
> > landing phases
>
> No, you won't. Helicopters can still go down to 300', which IMO is too
low
> anyway.

Only with a pre-approved waiver from the FSDO. I agree the 300 is very low,
pls don't interpret my disagreement with the NPRM as a desire on my part to
fly within the regimes that it would restrict.

> > * You'll be required to have pop-out floats for overwater flights.
>
> So? You should have them if you're carrying fare-paying passengers over
> water. If you don't, you're negligent.

What if the water you're flying over only has an avg depth of 3-4 ft? I
just don't know if there's data to support the actual benefit of floats when
compared to single engine airplanes conducting the same operation. It would
have been nice if they provided some. I've already installed floats, so
obviously I think they are of value.

>
> > * Regardless of the airspace, you'll have to have cloud clearance of
> > 500 below, 1000 above, and 2000 lateral,. as well as maintaining an
> > 1200 ft AGL alt.
>
> For tours, I don't see the problem. It is draconian, but trying to show
> the sights in low visibility is stupid anyway. This ONLY applies to tour
> operations, which have a poor record in poor weather.
>

I totally agree that good visibility is a prereqisite to a good tour. Poor
visibility is not synonymous with cloud clearance at these minimums though.
I fly in an area that is heavily populated by fighter jets that operate 1200
and above at extreme speeds. I won't go anywhere near any cloud because of
this. The clouds here tend to always manifest seem themselves right around
1200 - 1400 feet though. 2000 lateral is not enough, hell even 1 mile
lateral is not enough, so if I see ANY cloud that might obstruct some
fighter pilot's view of me, I decend to an altitude that I know they don't
fly at, and also allows them to see me. Unfortunately this means Im going to
be at 600-700 feet which would not be permitted under the new FAR. (BTW I
also repainted the helicopter from black to yellow with hi-viz rotors to
improve our odds of being seen. )


> > * Gone is the ability to operate "without hazard to persons or
> > property", You'll be required to maintain airplane-like standoff
> > distances.
>
> Not true.

True: "Under proposed paragraph (a), no person may conduct a commercial air
tour closer than a horizontal radius of 1,500 ft to any person, structure,
vehicle, or vessel; or 1000 feet to raw terrain."

>
> > * Operation within the H/V curve, regardless of flight phase is
> > prohibited, (IE: NO max performance or confined area departures /
> > appches. )
>
> Again, not true. Takeoff and landing are excepted. This only prohibits
> hovering inside volcanoes, etc, which has been killing innocent
passengers.

No, it is true. Here's the language: "This proposal is intended to prohibit
pilots from operating withing the avoid area of the heght/velocity diagram
for that helicopter."
I saw no exception for landings and takeoffs. Also, since they use the
phrase "the carriage of passengers for compensation or hire" , and since
you'll have to operate under 135, or 121, and in compliance with the new
part 136, it would appear that they are prohibiting operation within the H/V
for all passenger operations.

I could be wrong, but I read it several times and thats how it looks to me.
If you think for a second that I would endorse anyone coming to a 300 ft
hover over anything while carrying passengers then you've really
misunderstood my intent.


>
> > Basically stated; The FAA will be removing any reason that you would
> > want to operate a helicopter vs. an airplane.
>
> You're full of it. All this just is not true.

Ok, since you took the time to read the thing, you tell me exactly what tour
under the new rules could not be conductucted equally well in a Cessna 172?
What customer is going to pay the difference in cost between the the two if
the ride they take is pretty much exactly the same?

Of the people who responded to my posting, most _assumed_ that because I
didn't care for the NPRM that it equated to my desire to do all the things
that it would prohibit. Wrong, Wrong, Wrong! I just think that generically
replacing pilot discretion with one-size-fits-all regulation is not
necessary and may in-fact create unintended hazards in combination with
undue financial hardship for operators.

Bart