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Radalt for helo Part-135 Ops


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Well, well, well...it seems that our not-so-favorite R-44 pilot here in Washington has got her panties all in a wad about having to install a radar altimeter in her little helicopter that is being operated under FAR Part 135. She wrote an article that got published in some venue (Mad Magazine?), and she's blogged about it, of course. About the radar altimeter she dismissively says, “Don't need it!” with an expression on her face like she just smelled a fart, perhaps one of her own. She claims that if she needs to verify her separation from the terrain, all she need do is look out the window. Well, yeah! Can I get an amen?

 

But I wonder how that works at night?

 

You know, sometimes we fly over pretty sparsely-lit terrain. Sometimes that terrain below us is uneven. While it is true that a radar altimeter won't alert you that you're about to fly into a vertical cliff face (sayonara, Patsy Cline!), the device can warn you when you're flying into rising terrain of which you might not be aware. Not all of us are lucky enough to fly around in brand-new Bell 505's with dual Garmin G1000's.

 

And so I wonder how many of these Part-135 R-44's out there are allowed to fly charters at night? Because the way I look at it, when you're carrying people from here to there at night for hire, you damn well ought to know your exact height above the terrain. Sometimes just “looking out the window” isn't good enough. Can I get another amen?

 

Expensive? Yeah, you might say that. Tax deductible business expense? Yeah, that too.

 

Robbie owners complain that there is no room in their puny 5-hole(?) panel for such a large, heavy, complicated device. Plus, there's already a GoPro mounted there! But wait...the Garmin GRA 55 looks pretty neat. Instead of the usual, big analog dial, it's just a small digital display that doesn't appear to take up much room. It weighs five pounds, maybe. Maybe.

 

So...I'm not sure where exactly I stand on this issue. On one hand I see the need for all Part-135 operators to have a radalt. On the other, it is kind of governmental overreach.

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Robbie owners complain that there is no room in their puny 5-hole(?) panel for such a large, heavy, complicated device.

Five hole? Those went out with bell bottoms!

 

 

See, plenty of room for a nifty new gage,...and still space left for a picture of my dog!

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If requested, the FAA can issue a Letter of Deviation Authority for rotorcraft with a maximum gross weight of not more than 2,950 pounds. The op specs will contain a limitation of no NVG operations and a pilot training program which must incorporate whiteout, brownout, and flat-light conditions.

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If requested, the FAA can issue a Letter of Deviation Authority for rotorcraft with a maximum gross weight of not more than 2,950 pounds. The op specs will contain a limitation of no NVG operations and a pilot training program which must incorporate whiteout, brownout, and flat-light conditions.

 

She tried that and failed. If you read her letter she went all the way up to her congressman and got no where. $14,500 and a week of no revenue would sour my mood, too.

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Guys,

 

FSIMS 8900.405 https://www.faa.gov/documentlibrary/media/notice/n_8900.405.pdf

can be used to get an extension but installation will be required! The LODA was never intended for the R44 or R66.

 

HAI & USHST are working on getting a revision to the RA requirement as it was initially intended for accident reduction in the HAA/EMS world of night operations.

 

The R44 has a factory kit for installation.

 

I assisted a local 135 operator get this done for a R66 which has no retro fit kit from the factory. STC & DER required.

 

Robinson does ask if you want the RA installed during production.

 

I was contacted when the article came out by FAA/HAI for USHST input/feedback and my reply was:

 

{{Thanks for the article attachment.

Here are some comments to parts of the article:

[135 Operators (even single pilot operators need to stay abreast of regulation changes that they will have to comply with!) No excuses.

As far as brown out, white out (any off airport site) and flat light which can happen and it should not be stated or accepted that most 135 operators could not encounter these conditions, she is required to address these with training in those areas.

She needs to use the OEM as a source for equipment upgrades and guidance, - Robinson has a kit for the RA in a R44.]

I do understand her frustration and views, but she could have been more professional in her overall statement of operations.}}

 

All of this said, we can post NPRMs that will effect us here and assist each other in keeping ahead of coming requirements.

 

Mike

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But I wonder how that works at night?

 

And so I wonder how many of these Part-135 R-44's out there are allowed to fly charters at night? Because the way I look at it, when you're carrying people from here to there at night for hire, you damn well ought to know your exact height above the terrain. Sometimes just “looking out the window” isn't good enough. Can I get another amen?

 

Well were I fly it can be just black under me at night. So when I feel weird and my spidy senses go off I just turn on the landing light. If I dont like what I see I just turn it off. :D lol

 

Good point though....would be a nice tool on those occasions.

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Received from my peers at HAI today in a daily email.

 

News Staff posted on July 06, 2017 10:39

Note: This applies only to "N" Registered A/C that are operating under FAA regulation FAR Part 135

Effective April 25, 2017, to conduct operations under FAR Part 135 your R-44 was to have been equipped with a “Radio Altimeter.”

On June 5, 2017 the FAA published Change 527 to 8900.1 (Part A Operations Specification). This change effectively extended the compliance date for your Robinson R-44 to October 24, 2018.

If you wish to take advantage of the above extended compliance date and delay the equipping of your aircraft with a “Radio Altimeter” system and be able to continue operations under FAR Part 135, you must still apply for a “Letter of Deviation Authority” per OpSpec A160.

This LoD Authority allows you to operate without a Radar Altimeter for Part 135 operations until October 24, 2018, or until your Radio Altimeter is installed, whichever occurs sooner.

If you have questions about this rule or LoD, please contact HAI Flight Operations Department.

Note: If you are currently being prohibited from operating your R44 on your FAR Part 135 Certificate due to perceived noncompliance with OpSpec A160, you need to contact your local FSDO ASAP to resolve the issue. Also please advise the HAI Flight Operations Department so we can monitor the situation.

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