What is a "small rotorcraft" in the FAA's eyes

[jake50]

I know my best bet is to ask the FSDO or apply for a legal interpretation, but I'm looking for input on here first. 

This is mainly referencing 91.213, where it states "small rotorcraft" may operate without an MEL even if an MMEL has be developed for this aircraft.  If you go by small aircraft definition then this would lead you to believe the small rotorcraft is anything under 12,500lbs.  I personally wouldn't consider an 12,00 helicopter a small rotorcraft, but I'm no lawyer so I'm looking for input.  When you start reading legal interpretation there are many instances where they somewhat break down rotorcraft into turbine powered or non-turbine powered but never classify them as small or large rotorcraft.  

Thanks for your input.  

[iChris]

On 4/24/2020 at 7:10 PM, jake50 said:

I know my best bet is to ask the FSDO or apply for a legal interpretation, but I'm looking for input on here first. 

This is mainly referencing 91.213, where it states "small rotorcraft" may operate without an MEL even if an MMEL has be developed for this aircraft.  If you go by small aircraft definition then this would lead you to believe the small rotorcraft is anything under 12,500lbs. 

I personally wouldn't consider an 12,00 helicopter a small rotorcraft, but I'm no lawyer so I'm looking for input.  When you start reading legal interpretation there are many instances where they somewhat break down rotorcraft into turbine powered or non-turbine powered but never classify them as small or large rotorcraft.  

In FAA’s eyes a "small rotorcraft:" 

14 CFR Part 1.1 defines a small aircraft as an aircraft of 12,500 lbs. or less maximum certificated take-off weight.  Therefore, any rotorcraft, could be considered small by the Part 1.1 definition (aircraft) if the rotorcraft/helicopter is less than 12,500 lbs.  

Part 1.1 Aircraft means a device that is used or intended to be used for flight in the air.
Part 1.1 Small aircraft means aircraft of 12,500 pounds or less, maximum certificated takeoff weight.

 § 29.811 (f) Each emergency exit, and its means of opening, must be marked on the outside of the rotorcraft. In addition, the following apply: 

(1) There must be a 2-inch colored band outlining each passenger emergency exit, except small rotorcraft with a maximum weight of 12,500 pounds or less may have a 2-inch colored band outlining each exit release lever or device of passenger emergency exits which are normally used doors.

Edited April 26, 2020 by iChris