SFAR 73 question...

[Justin DBC]

No one I've talked to seems to want to give me a clear answer on this. It looks fairly straight up on paper... I just want to double check before I act on it.

 

My friend is a rated pilot with about 2100 total time in helicopters. He has 0 Robbie time. According to SFAR 73, he needs to get the SFAR awareness training from a CFI to maniplulate the controls. Is this all he needs for me to leave the dual controls in the aircraft as long as I'm acting as PIC?

 

Thanks!

J-

[heli.pilot]

That's my understanding. The SFAR 73 awareness training is all the training that the average Joe off the street gets before they go up on a demo flight and manipulate the controls.

 

Are you a CFI?

[heli.pilot]

If he has any desire to act as PIC (in a Robbie) in the future, he either needs

i) 50 hours in Robinsons, or

ii) 10 hours of dual in a Robbie, including SFAR 73 flight training (not to be confused with awareness training), and an endorsement from a CFI.

 

If you are not a CFI, he could not log the time he flies with you as instruction received, so it would not count towards the 10 hours needed.

[Justin DBC]

Thats one of the problems. I'm not a CFI. He just wanted to go up and be able to manipulate the controls. It looks like as far as the SFAR is concerned he just couldn't like PIC and I know it couldn't be counted towards instruction. I was trying to ask around my school and none of the CFIs could give me a good answer on it. I talked to the chief instructor today and I guess regardless of the SFAR, they don't want anyone manipulating the controls without a CFI unless they have the Robbie hours, so I guess it's a bust. Anyone know anywhere around L.A. that doesn't have that policy? Seems kinda crappy considering all the time and experience he has.

 

J-

[Mikemv]

Dear Justin DBC, why would you be looking for someone to circumvent the SFAR and be unsafe. It is in place to prevent some repeats of prior accidents and events. Get your friend to take the training. It is higher time, experienced guys that will get in trouble in an R-22, R-44 the first few times!

[JDHelicopterPilot]

Thats one of the problems. I'm not a CFI. He just wanted to go up and be able to manipulate the controls. It looks like as far as the SFAR is concerned he just couldn't like PIC and I know it couldn't be counted towards instruction. I was trying to ask around my school and none of the CFIs could give me a good answer on it. I talked to the chief instructor today and I guess regardless of the SFAR, they don't want anyone manipulating the controls without a CFI unless they have the Robbie hours, so I guess it's a bust. Anyone know anywhere around L.A. that doesn't have that policy? Seems kinda crappy considering all the time and experience he has.

 

J-

 

I agree with Mike but would like to add something.

 

If you are not a CFI how will you be acting PIC if not on the controls? As Helipilot said he would need to have 10hrs dual in the R-22 including the SFAR 73 items before he could be acting PIC. The sign off in order for him to manipulate the controls is just that. Just so he can manipulate the controls safely in order to recieve said 10 hours instruction and final SFAR sign off. Sorry, no go.

 

JD

[heli.pilot]

Given what has been discussed, what do you guys make of SFAR 73, 4, b, 1, (i) - that says:

 

No person may act as pilot in command of a Robinson model R–22 unless that person:

 

(i) Has had at least 200 flight hours in helicopters, at least 50 flight hours of which were in the Robinson R–22; or

 

It goes on to say in (ii) about the 10 hours of dual.

 

In (i), it does not specify that those 50 hours have to be dual. If the time logged is NOT dual, it is because the other occupant was not a CFI. As JD said, my understanding is that only a CFI can be acting as PIC and yet not be on the controls. So if the person with the SFAR 73 endorsement is not a CFI, and not on the controls, they are not acting as PIC. This means the other person (who doesn't meet the requirements on SFAR 73) must be acting as PIC, which of course is not allowed by SFAR 73.

 

Does that make sense? Am I missing something? I guess I'm not clear on the application of part (i).

[JDHelicopterPilot]

The 50 hours of time in the R-22 per SFAR 73 4((1)(i) is not dual.

 

WHAT SFAR 73-1 REALLY MEANS

 

EVERYONE: To manipulate the controls of an R-22, must have "Awareness Training" (ground instruction) outlined in paragraph 2.(a)(3)(i-v) with a sign-off for that training by an appropriately endorsed CFI (one who's authorized to give SFAR 73-1 training). Exception: If a helicopter pilot has recently attended the Robinson Factory Course, he/she can take his/her Robinson "graduation" certificate to the FAA FSDO and get a sign-off from the FAA for the Awareness ground training. See below for additional exceptions. Note that paragraph 2.(a)(4) of SFAR 73-1 only gives recent Factory Course attendees dispensation from paragraph 2.(a)(1) and 2.(a)(2), NOT any other part of the SFAR 73-1 requirements.

 

SOLO STUDENT: Must have had Awareness ground training with a sign-off prior to manipulating the controls, plus at least 20 hours dual in an R-22 including maneuvers outlined in paragraph (2)((3)(i-iii) with a sign-off prior to solo. NOTE: While (2)((3)(iv) "Low G" flight training is still contained in the SFAR, a subsequent FAA Airworthiness Directive and Flight Manual limitation prohibits doing "low G" training in flight.] The para. (2)((3)(i-iii) training and sign-off must be given each 90 days and is in addition to any other solo training or sign-offs required by FAR Part 61. Prospective students on a demo flight may not manipulate the controls without first having had the Awareness training. Since the SFAR doesn't define "manipulating the controls," one might safely assume that if only the instructor is manipulating (moving) the controls and the prospective student is merely following along on the controls, this would be OK so long as the instructor does not relinquish any operational control of the aircraft to the student.

 

RATED HELICOPTER PILOT WITH 200 HRS HELICOPTER/50 HRS R-22: To be PIC of an R-22, must have at least 200 hours helicopter, of which 50 hours was in the R-22, and must have evidence in his/her logbook of having completed the Awareness ground training w/sign-off sometime in the past. No immediate flight checkout under SFAR 73-1 is required, however, this pilot must have had some SFAR 73-1 ground and flight training and a sign-off for such training within the last two years. (See FLIGHT REVIEW , below.)

RATED HELICOPTER PILOT WITHOUT 2OO HRS HELICOPTER/50 HRS R-22: To be PIC must first have Awareness Training (ground instruction outlined above) and at least 10 hours dual in the R-22, including the "abnormal and emergency procedures" flight training specified in paragraph 2.((1)(ii)(A-C) with a sign-off for such flight training by an appropriately endorsed CFI. NOTE: While the flight training in para. 2.((1)(ii)(D) is still in the SFAR, this "Low G" training is no longer permitted in flight.

 

A rated helicopter pilot with less than 200/50 hours must repeat this paragraph 2.((1)(ii)(A-C) flight training requirement each 12 months until he/she accumulates 200 hours helicopter and 50 hours R-22 time. NOTE: The wording in Paragraph 2.((1)(ii) may be misleading in that it uses the term "flight review." As used in the SFAR, "flight review" only means the flight training required by paragraph 2.((1)(ii)(A-C) and should not be confused with the flight review (BFR) requirements of FAR 61.56.

 

CERTIFIED FLIGHT INSTRUCTOR: To instruct in an R-22 must have at least 200 hours helicopter of which 50 are in the R-22, Awareness Training w/sign-off, plus flight training by an FAA ASI/DPE in the maneuvers & procedures outlined in paragraph ((5)(iii)(A-C) w/sign-off by that ASI/DPE. The flight instructor must "satisfactorily demonstrate an ability to provide instruction on the Awareness Training items in paragraph 2(a)(3) and the flight training identified in paragraph 2((5)(iii)" in order to receive this endorsement from the ASI/DPE.

 

Since Robinson does not require attendees of the regular R-22 Factory Course to demonstrate "… an ability to provide instruction on the Awareness Training items in paragraph 2(a)(3) and the flight training identified in paragraph 2((5)(iii)," any CFI desiring to get the SFAR CFI signoff from the factory must discuss this with the factory prior to attending the course. Otherwise, the FAA may only accept the R-22 factory course graduation certificate as having met the Awareness ground training requirement.

 

FLIGHT REVIEW: If a person is eligible to be PIC of an R-22 under SFAR 73-1 and they take a BFR (FAR 61.56) in an R-22 to maintain currency and wish to keep flying R-22's, then in addition to the usual Part 61 BFR requirements, the pilot also must receive ground training in the awareness training subjects and the flight training as required by SFAR 73-1 paragraph 2©(3). Likewise, even if pilot is exempt from a BFR because of §61.56(d) or (e), or has taken a BFR in another type of aircraft, the FAA has determined that the requirements of SFAR 73-1 paragraph 2©(3) still apply, and the pilot must have an SFAR "flight review" and sign-off in an R-22 at least every 24 months. As stated in SFAR 73-1 section 1: "The requirements stated in this SFAR are in addition to the current requirements of Part 61." Therefore, everyone who flies an R-22 or R-44 must have had some SFAR-specific flight and ground training and a signoff for such training within the last two years.

Edited February 12, 2009 by JDHelicopterPilot

[JDHelicopterPilot]

Again, remember,

 

Your friend can't act as PIC since he doesn't have the training and sign offs from a CFI. Also, you can't because you are not a CFI and not manipulating the controls. Either you would have to be on the controls(which would defeat the point) or you would have to be a CFI.

[heli.pilot]

I guess I don't understand how someone without an SFAR 73 endorsement would get 50 hours in a Robinson without it being dual? Since the time needs to be with a CFI, as discussed, why not just do the 10 hours dual and training according to (ii)?

 

Thanks for your help JD.

Edited February 12, 2009 by heli.pilot

[HeliHelvig]

I currently have about 180 hours. I had a SFAR 73 PIC endorsement as of 2/4/08, when I obtained my private license. I haven't flown since the end of January and I now need a SFAR 73 flight review and a new endorsement.

 

So when I do my flight review I won't be able to log PIC time right?

[adam32]

Dang, I bet if you printed out all the rules for Robbies and weighed them, they would exceed the useful load...

[JDHelicopterPilot]

I guess I don't understand how someone without an SFAR 73 endorsement would get 50 hours in a Robinson without it being dual? Since the time needs to be with a CFI, as discussed, why not just do the 10 hours dual and training according to (ii)?

 

Thanks for your help JD.

 

 

Don't get confused. It's just that the R-22 SFAR flight review requirements change after a pilot reaches 200hours and 50 in the R-22. That's all. In order to get that 50 hours in the R-22 that pilot would have completed all of the SFAR training already. It just means now instead of a SFAR review every 12 calender months it 24 calender months.

Edited February 12, 2009 by JDHelicopterPilot

[JDHelicopterPilot]

I currently have about 180 hours. I had a SFAR 73 PIC endorsement as of 2/4/08, when I obtained my private license. I haven't flown since the end of January and I now need a SFAR 73 flight review and a new endorsement.

 

So when I do my flight review I won't be able to log PIC time right?

 

That is right. You do not need the usual Bi-Annual Flight Review per Part 61 yet. However, you do need the SFAR 73 to Part 61 Flight Review in the R-22. Then you will be able to log PIC time again. Once you reach 200hrs with 50 in the R-22 then said SFAR Flight Review will now be every 24 calender months just like the Bi-Annual Flight Review is.

[heli.pilot]

Don't get confused. It's just that the R-22 SFAR flight review requirements change after a pilot reaches 200hours and 50 in the R-22. That's all. In order to get that 50 hours in the R-22 that pilot would have completed all of the SFAR training already. It just means now instead of a SFAR review every 12 calender months it 24 calender months.

 

THANKYOU! That was driving me crazy. I already knew about the flight review every 12 months vs 24 months depending on whether or not you have 200 hours in helicopters, but for some reason I didn't connect the 50 hours in Robbies to that same rule. Thanks for clearing that up for me.

[Goldy]

I currently have about 180 hours. I had a SFAR 73 PIC endorsement as of 2/4/08, when I obtained my private license. I haven't flown since the end of January and I now need a SFAR 73 flight review and a new endorsement.

 

So when I do my flight review I won't be able to log PIC time right?

 

 

Alex- always, always, always, do your SFAR 73 sign off the day BEFORE it expires so there is no confusion if you can log the PIC.

 

That being said, mine expired last week as well....damn it. I'll do yours if you sign mine ? JK, guess its time to go flying with the boss this week.

 

Goldy

Edited February 12, 2009 by Goldy

[Goldy]

No one I've talked to seems to want to give me a clear answer on this. It looks fairly straight up on paper... I just want to double check before I act on it.

 

My friend is a rated pilot with about 2100 total time in helicopters. He has 0 Robbie time. According to SFAR 73, he needs to get the SFAR awareness training from a CFI to maniplulate the controls. Is this all he needs for me to leave the dual controls in the aircraft as long as I'm acting as PIC?

 

Thanks!

J-

 

Justin- This would be really hard for your friend to understand.....with over 2000 hours, but you are probably safer with 100 Robbie hours total than he is with 2000 turbine hours but flying an R22. Its simply a delicate machine in some ways, bulletproof in others. ...you gotta know what you can and cant do, and thats what the SFAR is all about.

 

A lot of higher time pilots enjoy flying the lil 22, or other small ships. They are small, fast, responsive...fun to fly.

 

Have him take the training and do the required hours, he'll have a blast flying it and be safe doing it.

 

Goldy

[choppedair]

Your school is right to not allow you to leave the controls in. You are not a CFI and have no business letting someone else manipulate the controls while you are renting their helicopter.

 

Goldy is right that you are probably safer in that helicopter than he would be.

Every time I've instructed a pilot who has had lots of turbine time it's a little bit challenging. Mostly throttle control issues (they can't tolerate the governor working constantly), but also the t-bar cyclic and the overall sensitivity.

 

If he is truly interested to see what it is like he should just pay for an intro flight.

[Tenacious T]

If he is truly interested to see what it is like he should just pay for an intro flight.

 

 

This is the most sensible thing to do, if he wants to get a taste of R22 he should get a CFI to give him awareness training then a demo flight. It would be a safer, controlled situation and there's no risk of getting in trouble with the operator for using their aircraft in an unauthorized way. If he likes it he can then go for the 10 hrs. of dual for the PIC requirement would probably be considered checked out for rental at that point, depending on the owner.

[Justin DBC]

Dear Justin DBC, why would you be looking for someone to circumvent the SFAR and be unsafe. It is in place to prevent some repeats of prior accidents and events. Get your friend to take the training. It is higher time, experienced guys that will get in trouble in an R-22, R-44 the first few times!

 

 

First off... Thanks for the overwhelming response to my little question

 

I'm still a bit confused. If he was not the sole manipulator of the controls, he would not be acting as PIC. I guess I'm just a bit shakey on what the FAR meant by "manipulating the controls". It's not very specific as far as if that means for dual or just for flight training (unless I missed something). That's why I asked the question in the first place.

 

In my defense, I am certainly not trying to circumvent the SFAR (or ANY regulation) and I don't have any intention of ever doing something unsafe in an aircraft. My chief instructor made it seem like it was just a school policy. I was simply asking for clarification. If the SFAR allows for it, then I would be fine allowing him to jump on the controls for a little bit after he had recieved the awareness training. If the SFAR doesn't allow for it, that's fine too. I just wanted to know where it stands. I had talked to several CFIs about this and reviewed the SFAR with several high-time military pilots (IPs and SPs) who felt that it was unclear.

 

Goldy... Me and my friend actually talked about that last week. When we were reading over the SFAR, we discussed what we would be comfortable doing. If it was a go, then we agreed he would only take the controls at straight and level flight and a safe altitude. He is very aware of the differences between flying an aircraft which, if left to it's own devices, will fly itself pretty well and one that doesn't even have a hydraulics system.

 

Tenacious, just to be clear, trying to violate the schools policy wasn't an option that was on the table. I'm gonna talk to him and see if he's got the money to put down for the 10 hours. In all honesty though, I don't think it's really going to be worth it to him will all the hours he logs at work anyways.

 

Once again, thanks for the input. I'm still a bit confused, but I always go with the most conservative response when I'm making a decision and there were quite a few conservative ones on this thread.

 

J-

Edited February 12, 2009 by Justin DBC

[heli.pilot]

First off... Thanks for the overwhelming response to my little question

 

I'm still a bit confused. If he was not the sole manipulator of the controls, he would not be acting as PIC. I guess I'm just a bit shakey on what the FAR meant by "manipulating the controls". It's not very specific as far as if that means for dual or just for flight training (unless I missed something). That's why I asked the question in the first place.

 

In my defense, I am certainly not trying to circumvent the SFAR (or ANY regulation) and I don't have any intention of ever doing something unsafe in an aircraft. My chief instructor made it seem like it was just a school policy. I was simply asking for clarification. If the SFAR allows for it, then I would be fine allowing him to jump on the controls for a little bit after he had recieved the awareness training. If the SFAR doesn't allow for it, that's fine too. I just wanted to know where it stands. I had talked to several CFIs about this and reviewed the SFAR with several high-time military pilots (IPs and SPs) who felt that it was unclear.

 

I hear you, and just for the record - I never had the impression that you were trying to do something shady by disobeying the SFAR or the school's policies.

 

This thread has certainly given me a little better clarity on SFAR 73.

 

If you had your CFI and you took your friend up, when he is on the controls he has to be PIC. When he has the controls you CANNOT be PIC since you don't have your CFI. Being a CFI would enable you to be acting as PIC, even when not on the controls. When two people (neither of whom are a CFI) go flying, only one person can be acting as PIC at any given moment. However if one of those people is a CFI, that person can be acting as PIC the whole flight even when not on the controls.

 

So because you don't have your CFI, when he has the controls he is considered to be acting as PIC - which of course is not allowed by SFAR 73. Basically he has to go up for 10 hours of dual, get the awareness training and flight training listed in SFAR 73 and get an endorsement from a CFI.

 

Does that clear it up at all?

 

This has been a good discussion and sure cleared up some things in my mind - there's lot's more "clearing up" to do in there though, that's for sure...

[Justin DBC]

Does that clear it up at all?

 

This has been a good discussion and sure cleared up some things in my mind - there's lot's more "clearing up" to do in there though, that's for sure...

 

Haha... It clears it up enough for now. I'm very careful trying to do anything I haven't been FULLY briefed on by my school. The regulations can be a bit decieving sometimes and I know plenty of high-hour pilots who still have lengthy debates on the finer points of some of the FARs. Do you think they're going to eventually come out with a FAR/AIM for dummies?

[heli.pilot]

Do you think they're going to eventually come out with a FAR/AIM for dummies?

 

I doubt it, heaven forbid we understand the FAR's!

[JDHelicopterPilot]

I think there is something in the FARs that states we are not allowed to understand them.

 

 

 

I have another note about CFIs logging PIC time. As stated already if your friend had the SFAR awareness training and you were a CFI you could both log PIC time. However, just becuase you are a CFI doesn't mean anytime you fly with a rated pilot you can log PIC time. You must also be providing instruction in order to do so.

[heli.pilot]

You must also be providing instruction in order to do so.

What exactly constitutes "providing instruction"? Obviously the more experience the pilot has, the less input the CFI is really making. How much input is enough to constitute instruction though?

 

I had a friend years ago who had his own business. Anytime we had lunch together, he'd always say "ask me how me how the business is doing". He figured that as long as business was mentioned it was a "business lunch" and he could write it off!