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Class G Visibility Changes


cburg

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"Currently, helicopters operating in Class G airspace, under VFR and less than 1,200 feet above the surface, are required by § 91.155(B)(1) to remain clear of clouds and to operate at a speed that gives the pilot adequate opportunity to see any air traffic or obstruction in time to avoid a collision. The FAA proposed to revise § 91.155 to establish a minimum 1/2 statute mile visibility by day and one statute mile visibility at night."

http://www.gpo.gov/fdsys/pkg/FR-2014-...

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The FAA proposed to revise § 91.155 to establish a minimum 1/2 statute mile visibility by day and one statute mile visibility at night."

 

http://www.gpo.gov/fdsys/pkg/FR-2014-...

 

Few opinions in opposition:

 

 

Commenters from EGLI Air Haul also believe that part 91 should remain unchanged so that the pilot can decide whether visibility is adequate. In support of leaving the regulation unchanged, they cited an instance when an EGLI pilot made a decision to fly in conditions below those proposed in the NPRM to aid survivors of an airplane crash who were trapped on a mountainside. They contend that the proposed change to § 91.155 would have prevented this pilot from reaching the survivors.

 

The Los Angeles County Sheriff's department wrote that public safety agencies must be able to make “go/no go” decisions based on the higher experience level of their pilots and knowledge of the local flying areas. The commenter stated that weather restrictions would limit its ability to perform numerous search and rescue missions. Air Shasta also stated that a “detrimental consequence of these proposed limitations would be cancelling or delaying of search and rescue missions” it occasionally performs.

 

Westlog stated that the current requirement is safe for helicopters operating clear of clouds because they can stop and land at zero airspeed and commented that this helicopter operation is safer than an airplane operating clear of clouds at night with one mile of visibility when within1/2mile of the runway under § 91.155[2].

 

Additionally, Westlog noted that it operates in coastal Oregon and Northern California and frequents uncontrolled airports served by automated weather observation systems (AWOS). Because coastal advection fog is common in this area, the commenter explained, an AWOS will often report 1/4mile visibility when over half the airport is clear, with 15 miles visibility or more. Westlog claimed that, even with a reported1/4mile visibility, a helicopter can take off safely under visual flight rules by simply departing into the non-foggy area.

 

Air Shasta similarly commented that it has performed numerous searches when conditions at the departure airport were below what was proposed in the NPRM, but where it could find a point at the airport that was clear enough to depart safely.

 

The FAA is aware that visibility at some parts of an airport may be sufficiently clear to conduct operations even though the AWOS is reporting minimum visibility. Section 91.155 establishes flight visibility requirements for part 91 VFR operations. Therefore, if the pilot determines that flight visibility meets the requirements of § 91.155 at the takeoff location, despite the weather reported by the AWOS, the pilot may take off.

 

Based on the comments received and an additional review of the NPRM, the FAA is adopting the rule as proposed with two changes. First, the agency has changed proposed § 91.155(1) to allow helicopters to operate clear of clouds in an airport or heliport traffic pattern within1/2mile of the runway or helipad of intended landing if the flight visibility is1/2statute mile or more. The agency finds that this revision will provide an additional measure of flexibility when operating at night in an airport environment similar to that afforded to airplanes under the current rule. Second, for consistency with the existing regulation, the final rule incorporates the visibility minimums into § 91.155(a), instead of § 91.155(1) as proposed in the NPRM.

 

REF: Discussion of Public Comments and Final Rule

Edited by iChris
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Opinion:

There seems to be a cultural belief that rules and laws can be written to prevent all bad outcomes.

That has an unintended consequence by justifying a poor decision as legal in that it did not contradict any rules or laws.

Rules and laws are lowest common denominator broadly applied by those in position to do so. "I suppose it is tempting, if the only tool you have is a hammer, to treat everything as if it were a nail."

Accurate risk, capability, and benefit assessment followed by a sound plan well executed make for good outcomes. The lack of that process, especially the rational assessment of capability, is a common cause of aviation accidents.

All weather information is history or a SWAG.

The difference between one mile visibility and really bad conditions (operating clear of clouds) is pretty narrow at best. That fact has kept me from routinely operating in one mile vis for the last 46 years.

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Westlog stated that the current requirement is safe for helicopters operating clear of clouds because they can stop and land at zero airspeed and commented that this helicopter operation is safer than an airplane operating clear of clouds at night with one mile of visibility when within1/2mile of the runway under § 91.155[2].

Additionally, Westlog noted that it operates in coastal Oregon and Northern California and frequents uncontrolled airports served by automated weather observation systems (AWOS). Because coastal advection fog is common in this area, the commenter explained, an AWOS will often report 1/4mile visibility when over half the airport is clear, with 15 miles visibility or more. Westlog claimed that, even with a reported1/4mile visibility, a helicopter can take off safely under visual flight rules by simply departing into the non-foggy area.

 

 

At the Land and Live seminar at this year's Heliexpo I was getting the impression that the helicopter's ability to "stop and land at zero airspeed" was often ignored in low visibility accidents. As for the fog, I too fly on the coast and have seen that clear half of the airport become completely covered in 5 minutes!

 

Maybe they should just change the night minimums or have these operators operate on a different reg than 91? One thing is for sure Robbie Rangers, especially those who own their own R44, should be held to higher weather minimums!

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Opinion:

There seems to be a cultural belief that rules and laws can be written to prevent all bad outcomes.

That has an unintended consequence by justifying a poor decision as legal in that it did not contradict any rules or laws.

Rules and laws are lowest common denominator broadly applied by those in position to do so. "I suppose it is tempting, if the only tool you have is a hammer, to treat everything as if it were a nail."

Accurate risk, capability, and benefit assessment followed by a sound plan well executed make for good outcomes. The lack of that process, especially the rational assessment of capability, is a common cause of aviation accidents.

All weather information is history or a SWAG.

The difference between one mile visibility and really bad conditions (operating clear of clouds) is pretty narrow at best. That fact has kept me from routinely operating in one mile vis for the last 46 years.

Good point. It all depends on the pilot, there local area knowledge and task at hand. There is no cut and paste rule that's going to prevent bad decision making.

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Well i think they should leave it alone, its a pilots decision and his alone. Because the FARS says the the pilot in command is going to be responsible for what ever decision he or she makes. In some areas its doable and in other areas its not. Egli makes a good point on this. Were I live there is way to much things like cell phone towers sticking up that are not even charted. So common sense should tell a pilot than flying clear of clouds is not a good Idea. The rule change is not going to do anything to prevent weather related accidents, none of the regulations do, good decision making on the part of pilots dose, and saying no I am not going to do that!

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