"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