R22 Required Equipment

[Whirlwind]

Not being one to take things at face value, I started to compare the R22 required equipment lists that were given to me by my previous and current flight schools, as well as the one given in the ASA Helicopter Oral Exam Guide. Since I found differences between them, I tried to trace each item back to FAR 91.205 or the Robinson Pilot's Operating Handbook (POH). This confirmed most of them, but there are still a few that I am not sure about.

 

For instance, I was told by both flight schools that the cylinder head temperature gauge is required, but the ASA Guide does not list it, and it is not specifically called out as required for flight in the Robinson POH. The explanation I was given by my instructor was that we are required to operate the helicopter within the limitations specified in the POH. Since the maximum limitation on the cylinde head temperature is listed as 500 deg F, the only way we know for sure that we are below the limit is for us to have an operating cylinder head temperature gauge.

 

While I can understand that argument, it seems a little obtuse. The Robinson POH requires certain equipment to be functional for flight (ie. the alternator, governor, low RPM warning system, and outside air temp gauge) and goes out of his way to specifically list them. If there are other "implied" pieces of equipment that are required, why aren't they also listed?

 

Other equipment that is questionable include the ammeter and the carbureter air temperature gauge.

 

Any words of wisdom from the CFI's out there???????????

[67november]

Whirly I'd say take a look at your MEL (minimum equipment list) to ensure what is needed for flying the 22.

 

that should answer your questions.

[joker]

I totally agree with you Whirlwind.

 

Which is why I asked this question a long time ago.

 

Have a look in 27.1305.(b )

 

You'll love that reference!

 

For "Other equipment that is questionable" look at the rest of that rule. (Although I can't specifically remember ammeter being there. Goto check!).

 

 

Joker

Edited February 25, 2007 by joker

[PA Pilot]

Whirly I'd say take a look at your MEL (minimum equipment list) to ensure what is needed for flying the 22.

 

that should answer your questions.

To my knowledge, there is no MEL for Robinsons. The limitations section of the POH contains the only limitations.

[nsdqjr]

First of all, that ASA study guide is full of all kinds of errors, I don't even let my students look at it.

 

Joker is right about referencing Part 27; however, Part 27 was written for manufacturers as the guidelines for obtaining a type certification, not for airworthiness from a PIC standpoint. I had a pretty good discussion with the POI down at the Orlando FSDO and basically he said teach the POH and 91.205. Since there isn't a MEL for the Robinson it's pretty easy to determine airworthiness.

 

If it's in 91.205 or the POH as required equipment, and it breaks, ya can't fly.

[Pogue]

To my knowledge, there is no MEL for Robinsons. The limitations section of the POH contains the only limitations.

Well, there is an MMEL for the R44 & R22 - http://www.opspecs.com/AFSDATA/MMELs/Final...4,%20R-22%20R1/

which implies there could be an MEL. I think most schools and private operators are going to be using the provisions of 91.213 instead of an MEL for simplicity's sake, but some one out there has probably gone through the paperwork...

[JDHelicopterPilot]

Well, there is an MMEL for the R44 & R22 - http://www.opspecs.com/AFSDATA/MMELs/Final...4,%20R-22%20R1/

which implies there could be an MEL. I think most schools and private operators are going to be using the provisions of 91.213 instead of an MEL for simplicity's sake, but some one out there has probably gone through the paperwork...

 

 

I came across this MMEL a long time ago and was just about to post the link to it but see you beat me to it. I never really have used it though because so many people have said that there wasn't one and I was going to check with the FSDO but never got around to it. Question: since there is one, that means we can use it right without additional paperwork or permission??? I think we can. Thanks. JD

[delorean]

A cylinder-head temp gauge does NOT have to be working for an R22 to be airworthy. (see below)

 

For an R22 under VFR non-135 ops, you need what is listed in 91.205.

 

-Altimeter

-Airspeed

-Oil pressure

-Oil temperature for air-cooled engine

-Magnetic Compass

-Manifold pressure Gauge

-Tachometer

-Fuel gauge for each tank

-Seat belts for anyone over 2 years old

-Floatation devices and a flare if beyond gliding distance from shore

 

-(Temp gauge for each LIQUID-COOLED engine) So not req'd

 

(91.205 also anti collision lights for airplanes, landing gear indicators for retracts, ELTs for airplanes, etc.)

 

Robinson FURTHER req's the following to be operational (since 91 doesn't include them):

 

-Low-rotor RPM system

-Alternator

-OAT gauge

-BOTH landing lights for night flight

 

This is under the "Limitations" section, therefore you MUST abide by it. Same goes anything that may be listed in the type certificate.

 

RHC, nor the FAA require the cylinder head temp gauge be operational for flight. They don't require the Carb heat gauge either. Could you safely fly w/o either? Yes......depends on the temp/dew point though. Both would have to be written up and labled "Inoperative".

 

While pt. 27 requires the helicopter to be manufactured with a cylinder head temperature gauge, pt. 91, nor RHC requires it to be working for flight. If they did, it would be listed under pt. 91.205 as "Temperature gauge required for each liquid cooled engine [and air-cooled engines installed on a rotorcraft]" or in Sec.2 Limitations of the R22 POH.

[Pogue]

Question: since there is one, that means we can use it right without additional paperwork or permission??? I think we can. Thanks. JD

I don't think so - I think you use the MMEL to develop an MEL which has to be approved. Remember, the FAA considers the MEL to be a suplimental type certificate and it's specific to each airframe. Personally I don't see any advantage to an MEL in General Aviation - I think the advantage is in standardizing practices in a large operation.

[delorean]

I don't think so - I think you use the MMEL to develop an MEL which has to be approved. Remember, the FAA considers the MEL to be a suplimental type certificate and it's specific to each airframe. Personally I don't see any advantage to an MEL in General Aviation - I think the advantage is in standardizing practices in a large operation.

 

That's correct. RHC and the FAA put together a MMEL as a starting point. You use it as a guide to develop your own. If you want to try to get it approved word for word, you may just get it approved. It's the same way for the text in pt.135 and your Operation Specs.

 

And they're kind of handy especially if you have a lot of supplemental equipment on board (search lights, radar alt, load speakers, cargo hook system, medical equipment, etc.) It will give you X amount of days to get it fixed after it's deferred.

 

The main things on the R22 MMEL that are nice to defer are the stobe light, fuel gauges, and rotor brake. I've had all fail in Robinsons several times and they would otherwise ground the aircraft until they're replaced.

[JDHelicopterPilot]

That's correct. RHC and the FAA put together a MMEL as a starting point. You use it as a guide to develop your own. If you want to try to get it approved word for word, you may just get it approved. It's the same way for the text in pt.135 and your Operation Specs.

 

And they're kind of handy especially if you have a lot of supplemental equipment on board (search lights, radar alt, load speakers, cargo hook system, medical equipment, etc.) It will give you X amount of days to get it fixed after it's deferred.

 

The main things on the R22 MMEL that are nice to defer are the stobe light, fuel gauges, and rotor brake. I've had all fail in Robinsons several times and they would otherwise ground the aircraft until they're replaced.

 

 

The way I was brought up in my training in reguards to MMEL's and MEL's was that........and it may not be right.....

 

MMEL's were for make and model of aircraft and could be used for such. After all hasn't the FAA already approved the one that is posted in the link? I was then told that MEL's were created for a specific aircraft such as N1234SC. This was since some aircraft had extra equipment not needed to safe flight of the aircraft or redundant systems with which one could do with out for a period of time.

 

Is this not true?

 

Does an operator have to be approved by the FAA then to use a MMEL even though the one posted above has already been FAA approved?

 

If it's only a guideline then for operators to create their own MEL then large operators would have to make one for each A/C in theri fleet??

 

JD

[delorean]

Does an operator have to be approved by the FAA then to use a MMEL even though the one posted above has already been FAA approved?

 

If it's only a guideline then for operators to create their own MEL then large operators would have to make one for each A/C in theri fleet??

 

You cannot defer inoperative equipment from the MMEL. It's basically a guide. Nothing else. In order to defer inoperative equipment under a MEL you MUST have an approved MEL written specifically for your aircraft. Otherwise 91.205 would be a book in itself for each make/model.

 

The Master Minimum Equipment List (MMEL) is developed by the manufacturer and FAA for the purposes of defining the basic minimum equipment otherwise required by 91.205 or the manufacturer. From there, you can QUICKLY make your own MEL using the standards off their list, plus extra equipment, however, each other piece will be considered one by one on their repair time and remedy.

 

For instance, the MMEL says if you have a bad fuel gauge, fill both tanks and don't fly over 2.0 hrs. That's a quick, easy fix you can write into your MEL that's already approved by the FAA. If you want to take that up to 2.5 or 3.0 hrs, you are going to have to produce fuel burn charts and all kinds of data for different fuels, at different temps, and at all power settings. Good luck, not gonna happen in a reasonable amount of time.

 

MMELs are kind of like STCs. They're written for everybody in that make/model, the major alteration is already approved by the FAA, the instructions are approved, and the continued airworthiness is approved, but you must obtain permission to install on your serial number and file paperwork with the FAA. They're quick, easy, and don't require you to hire an engineer and wait years to get things approved. Just like OpsSpecs too......pt 135 is a guide, the more you modify it, the longer you wait, and the more money you'll spend.

 

And yes, if an operator wants a MEL, they have to write one for each aircraft. If all the aircraft are the same make/model, a single MEL will have a list of all of their serial numbers on the control page. The FAA has to approve any additions to that list and an up-to-date copy has to be in each aircraft listed on the MEL.

[Tenacious T]

A cylinder-head temp gauge does NOT have to be working for an R22 to be airworthy. (see below)

 

For an R22 under VFR non-135 ops, you need what is listed in 91.205.

 

-Altimeter

-Airspeed

-Oil pressure

-Oil temperature for air-cooled engine

-Magnetic Compass

-Manifold pressure Gauge

-Tachometer

-Fuel gauge for each tank

-Seat belts for anyone over 2 years old

-Floatation devices and a flare if beyond gliding distance from shore

 

-(Temp gauge for each LIQUID-COOLED engine) So not req'd

 

(91.205 also anti collision lights for airplanes, landing gear indicators for retracts, ELTs for airplanes, etc.)

 

Robinson FURTHER req's the following to be operational (since 91 doesn't include them):

 

-Low-rotor RPM system

-Alternator

-OAT gauge

-BOTH landing lights for night flight

 

This is under the "Limitations" section, therefore you MUST abide by it. Same goes anything that may be listed in the type certificate.

 

RHC, nor the FAA require the cylinder head temp gauge be operational for flight. They don't require the Carb heat gauge either. Could you safely fly w/o either? Yes......depends on the temp/dew point though. Both would have to be written up and labled "Inoperative".

 

While pt. 27 requires the helicopter to be manufactured with a cylinder head temperature gauge, pt. 91, nor RHC requires it to be working for flight. If they did, it would be listed under pt. 91.205 as "Temperature gauge required for each liquid cooled engine [and air-cooled engines installed on a rotorcraft]" or in Sec.2 Limitations of the R22 POH.

 

Robinson also requires the governor to be operational for flight.

[delorean]

Robinson also requires the governor to be operational for flight.

 

Maybe not.....If memory serves the POH says something like "Flight with govenor selected OFF is prohibited unless it's malfunctioning or training is taking place."

 

If it was required to be operational for flight I always thought they would put it in the line where it says "the low-rotor RPM system, OAT gauge, and alternator must be operative for flight (....and throttle governor)."

 

That would be a great question for the safety school people. Anyone want to volunteer??

[Helibear]

Maybe not.....If memory serves the POH says something like "Flight with govenor selected OFF is prohibited unless it's malfunctioning or training is taking place."

 

If it was required to be operational for flight I always thought they would put it in the line where it says "the low-rotor RPM system, OAT gauge, and alternator must be operative for flight (....and throttle governor)."

 

That would be a great question for the safety school people. Anyone want to volunteer??

 

It is in that line "Alternator, RPM Governor, low RPM warning system, and OAT gage must be operational for flight." - R22 POH

 

Your quote from the POH is also correct. No flight with gov. off except for training and system malfunction.

 

So, if someone takes off with an INOP gov. he brakes the rules.

If the gov. has a malfunction during a flight one is allowed to continue the flight. see emergency procedures.

Wether this is a good idea or not is in the decision of the PIC.

 

When I was in Torrance they told us the reason for the "Flight prohibited with gov. selected off ..." is that the early R22´s didn´t had a gov. and there were quite a few pilots out there who where used to fly without gov. Some of them had the tendency just not to use it.

These guys said : Well, the gov has to be operational for flight, but nobody said that I have to use it. So I switch it off and don´t brake any rule.

 

So RHC changed the POH and now it says: The gov must be operational and the pilot has to use it.

 

Have a nice day

 

Rainer

[Whirlwind]

Thank you to everyone that has commented on this. After several times through the discussion and checking the various links and references, I believe that the fog is beginning to clear. It is also now understandable why I have 3 different "answers" from 3 differnt sources.

 

I can't find any place stating that the rotor tachometer has to be operational, only that the low rotor RPM warning system has to be working. Is that correct? I guess the thinking is that the engine tachometer is required, as is the governor, so the rotor speed should be automatically controlled - and if it isn't, then the low rotor horn and light will alert you to that fact....