Attached R22 dolly wheels while in flight....legal?

Curyfury · January 6, 2015

if i attach the dolly wheels using zip ties, would it be considered legal?

I know, i know, i pretty much know the answer, but im hoping someone will say, "yes, its legal and here is why..."

The reason i ask is because i think it is legal...maybe not the best idea, but legal because a) its not "permanently" attached b ) all the weight is being handled by the eye holes for the wheels that are legally and permanently attached and the zip ties will only prevent the wheels from sliding out and the handle from moving. Once in that position, the wheels are above the landing skid so they wont drag or touch while landing or on the ground.

And for arguments sake, lets assume there is no interior storage space for the wheels. Not looking for alternatives, just a yes or no.

apiaguy · January 6, 2015

no it is not legal. But you could fashion and get approved a mounting location for them externally.

Curyfury · January 6, 2015

no it is not legal. But you could fashion and get approved a mounting location for them externally.

Is this just a personal opinion or can you state a rule that makes it illegal? Again, my main argument is that its not permanently attached.

adam32 · January 6, 2015

Some machines have "flyable" ground handling wheels...the R22 isn't one of them.

apiaguy · January 6, 2015

FAR 43 Appx A

Major alteration means an alteration not listed in the aircraft, aircraft engine, or propeller specifications—

(1) That might appreciably affect weight, balance, structural strength, performance, powerplant operation, flight characteristics, or other qualities affecting airworthiness; or

(2) That is not done according to accepted practices or cannot be done by elementary operations.

I would consider the ground handling wheels to appreciably affect nearly all of #1 and attaching them with zip ties would definitely be contrary to #2 even if you considered them to be elementary.

This doesn't mean you can't have flyable ground wheels.. but there is a venue for that and it doesn't include zip ties.

Astro · January 6, 2015

Its only legal if you use duct tape!

However Safety Notice 13 does say to not attached things to the skids.

Flight1 · January 7, 2015

The preflight checklist says "ground handling wheels removed". If you don't remove them, have you done a proper preflight? And therefore is the aircraft safe for flight

280fxColorado · January 7, 2015

When I was a student pilot we watched a particularly obnoxious and arrogant R44 owner coming in to land at the ramp after a scenic tour over downtown Boston, with the ground handling wheels still attached!! After the blades stopped, he opened the door, beamed a smile our way, and smugly swaggered towards the hangar. He called out and asked if we could bring his ground handling wheels... my CFI pointed back towards the R44. The look on the owners face: PRICELESS.

APIAguy is right on the money about "Major Alterations." Regardless, I wouldn't trust a couple zipties to to protect my life, my certificate, and the safety of the people beneath me. If you're still in doubt, call your local FSDO. What do you think the answer will be?

iChris · January 7, 2015

if i attach the dolly wheels using zip ties, would it be considered legal?
I know, i know, i pretty much know the answer, but im hoping someone will say, "yes, its legal and here is why..."

The reason i ask is because i think it is legal...maybe not the best idea, but legal because a) its not "permanently" attached b ) all the weight is being handled by the eye holes for the wheels that are legally and permanently attached and the zip ties will only prevent the wheels from sliding out and the handle from moving. Once in that position, the wheels are above the landing skid so they wont drag or touch while landing or on the ground.

And for arguments sake, lets assume there is no interior storage space for the wheels. Not looking for alternatives, just a yes or no.

This came up in a May 2012 post that was recently returned to life Oct. 2014. Rotormatic1 posted an interesting FAA Memorandum on items temporary mounted to the helicopter. These types of temporary attachments are not always subject to the regulatory purview of 14 CFR part 43. They maybe legal; however, you are responsible if it falls off.

Do these wheels truly stand as having an appreciably effect (meaning a considerable, substantial, significant, or sizable effect)?

The Appendix A, titled "Major Alterations, Major Repairs, and Preventive Maintenance", provides a broad spectrum of alterations that are typically considered major. This Appendix does not encompass the numerous possible alterations that could be accomplished to an aircraft and therefore relies heavily on the definitions of major and minor alterations, contained in 14 CFR part 1.

Because of the varying installation possibilities of this equipment, the major vs. minor determination is done on a case-by-case basis and made by the installer.

Major alterations are those that have an appreciable effect on the weight, balance, structural strength, performance, powerplant operation, flight characteristics, or other qualities affecting airworthiness. If the installation did affect one of the above listed variables, then the installation would be considered major and would require approved technical data prior to returning the aircraft to service.

Another consideration, in the case of this type of equipment, is the applicability of the term "alteration". FAA Order 8110.3 7E, defines an alteration as "a modification of an aircraft from one sound state to another sound state". The use of suction cups, or other temporary methods of attachment (not including permanent mechanical attachments to the aircraft), would not be considered a modification to the aircraft. These temporary attachments would not be subject to the regulatory purview of 14 CFR part 43.

The uses of these type attachments however are not supported by the FAA, and may (in the case of an in-flight detachment) lead to "careless operations" as provided for in 14 CFR sections 91.13 and 91.15.

Request for Clarification: External Camera Mounts - FAA Aircraft Maintenance Division, AFS-300

May 2012 Post - go-pro-mounts/

Edited January 7, 2015 by iChris

nightsta1ker · January 17, 2015

You know they fit under the seat, right?

eagle5 · January 17, 2015

...
And for arguments sake, lets assume there is no interior storage space for the wheels. Not looking for alternatives, just a yes or no.

Francis Meyrick · February 16, 2015

Nope. No way. Nein. Keine Chance. Forgettit.

I know a dumb ass pilot who was cruising along quite happily, in an R-22, humming to himself, when ATC called him. To say: "we just got a phone call you still got your wheels attached!"

And said dufus (a CFII) quit humming, looked out the side windows... and, sure enough...

(and no zip ties, either)

Arrrghhh...!