SFAR 73

[Jeff]

I've been a pilot for about 22 years, and I'm relatively new to helicopters--just getting my CFII 1 1/2 years ago. I did all my helicopter training in a 300CBi, and I have a couple hours dual in a B206-B and about 6 hours in an R-22. Before flying the R-22, I heard a lot of bad things. One experienced instructor I talked to tried to mitigate all the bad things I had heard, but it was hard to believe. Additionally, Robinsons have special requirements for acting as PIC and even manipulating the controls that are set out by SFAR 73. So why shouldn't I believe the negative things people say about Robinsons? The crux of the negative comments was two-fold. First, they have low rotor inertia, so you can really get into trouble fast if your engine fails and don't get the collective down IMMEDIATELY. Second, rotor RPM is such a big issue, that Robinson finally had to install a governor to keep people from getting into a low rotor RPM condition, a problem associated with low rotor inertia.

 

I finally had the opportunity to take some dual in an R-22. At the first lesson, I didn't really like it, but that was due to the design of the cyclic. I did, however, admit that it seemed more stable while hovering with a tailwind that the 300. By the second lesson, I had become comfortable with the cyclic and about the only thing I didn't care for was the lack of a force trim on the cyclic that the 300 has. By now, I think it is a fine machine. It is faily well-behaved in an autorotation, and it's easier to fly than the 300 because the governor all but takes away your concern for maintaining rotor RPM. Part of the SFAR 73 requirement is to fly it with the governor off. The correlator on the R-22 is MUCH better than the correlator on the 300. I only had to tweak the throttle once or twice from pick-up, around the pattern, to set-down.

 

So now my point... finally. The Schweizer 300 has the same issues as the R-22 (or worse). The 300 has low rotor inertia and no governor, yet is deemed by some as one of the safest training helicopters out there. Why SFAR 73? In my opinion, Robinson sells the insurance for the helicopters it sells and the company is trying to reduce it's risk by getting the FAA to set PIC minimums for its helicopters, a function that is solely done by the insurance industry for other makes and models. The hour requirements in SFAR 73 are good for checkouts in different helicopters, but I don't think we need the SFAR. If Robinsons are that unique that they need special reqirements to be PIC, then the FAA should just require a type rating for them.

 

I appreciate any comments any of you have on this topic.

 

Jeff

[delorean]

Excellent post......So often people get into R22s with a bad attitude to begin with, and will refuse to like them no matter how much fun they're having.

 

Like the t-bar, I love that thing. If I could get one in my 206, I'd have it. It makes slope landings much easier, you can get it up out of the way on the ground, it takes less than 30 seconds to put the duals in, there isn't a second set of bellcranks and mixers to get jammed or fail, and most of all it's much more comfortable to fly with since you can adjust the vertical orientation.

 

But you can say all that, and someone will come back with, "....that is the most god awful, dangerous, uncomfortable thing ever designed, blah, blah...." I think it mostly has to do with the fact that the helicopter is so difficult to fly initially. People don't like to admit that they couldn't get it under control, so let's blame it on that cyclic, right?

 

Above you said that Robinson HAD to install a governor, that's not necessarily true. They introduced the governor system in the early 90s (92-93, I think?) It was a $5,000+ option that would manipulate the throttle and collective. Not many people liked it or were buying it. So Frank removed the collective function and perfected the throttle movement. He lobbied the FAA to AD it's installation in 1995 and raised the prices of his helicopter ~$5,000 to cover the cost. Pretty smart guy.

 

Frank also lobbied the FAA for SFAR 73. In the early 80s when these came out, his target market was commuters in downtown LA--NOT the training market. So his helicopters were in all the flight schools and he didn't like it as the crash reports came in. He went to the FAA, not the other way around. Well the government was going to take a long time to do anything (13 years to be exact), so Frank opened the safety school, made his own insurance, made purchase agreements, and ferry requirements.

 

By the time SFAR 73 finally came out, he had lowered the fatal accident rate by leaps and bounds. By then the accidents are what they are now, mostly dynamic rollover and screwed up autos. Either way, all his rules through the factory and Pathfinder insurance are still MUCH higher than SFAR 73, but they have been relaxed a bit. For instance, up until 2002, you couldn't buy an R44 or receive dual in it until you had 200 PIC heli with 50+ in an R22.

 

For the most part, I like SFAR 73. I like the fact that a guy has to get 10 hrs in the a/c before he can act as PIC--much better than the ZERO hrs that is required for any other bird. I think CFIs should have more time than 5 hrs in one to be able to instruct. What I don't like is the fact that only 50% of R22 time counts toward the R44 (should be more like 75%). And having to take a BFR in an R22 AND R44 separately is a little excessive. Too much red tape on who and who can't give the CFI endorsements.

 

Don't you think pt. 61 should become more like SFAR 73??? Require a longer checkout/training for flying a different makes of helicopter? They already require 5 hrs in type for CFI'n, why not more for PIC'n? I guess they figure they'll leave it to the insurance companies.....which already govern this industry much tighter than the FAA (and always will).

 

But for all the people who like to harp on SFAR 73, look what the FAA did with the complex and high performance airplanes: extra training and an endorsement! Anything with flaps, constant speed prop, and retractable gear OR 201+ hp, requires a one-time endorsement after training and a checkout with a CFI. It's not that the planes were dangerous, just dangerous in the hands of a pilot who didn't know how to handle all the extra power or controls.

 

Again, thanks for the great post.

[volition]

Good point Delorean!!

[Jeff]

Don't you think pt. 61 should become more like SFAR 73??? Require a longer checkout/training for flying a different makes of helicopter? They already require 5 hrs in type for CFI'n, why not more for PIC'n? I guess they figure they'll leave it to the insurance companies.....which already govern this industry much tighter than the FAA (and always will).

 

But for all the people who like to harp on SFAR 73, look what the FAA did with the complex and high performance airplanes: extra training and an endorsement! Anything with flaps, constant speed prop, and retractable gear OR 201+ hp, requires a one-time endorsement after training and a checkout with a CFI. It's not that the planes were dangerous, just dangerous in the hands of a pilot who didn't know how to handle all the extra power or controls.

 

Again, thanks for the great post.

 

 

FAR Part 61 does require additional training for complex, high-performance, and tailwheel airplanes, and after that training you get an endorsement from a CFI. But Part 61 does not specify a minimum number of hours for this training. GAMA has some excellent guidelines for this type of training. I think SFAR 73 is a little too stringent. Perhaps Part 61 could require an instructor endorsement for R-22 and another for R-44 without specifying training times. CFI's could be required an absolute minimum of 15 hours PIC in R-22 and R-44 (where time in one can count partially toward time in the other) before they can give instruction for a certificate or rating. We in the helicopter industry need to set professional standards on helicopter transition and difference training and insurance checkouts. While the GAMA Specification No. 5 - Transition Training Master Syllabus applies to airplanes, we may be able to adapt it for use with helicopters. I have already emailed the president of GAMA asking if there is any such document for helicopters. No reply as of yet.

 

Jeff

[jtravis1]

I just came across a situation with regard to SFAR73 and doing a Bi-annual. It is posted on another thread on this forum.

 

Long story short, a 4000+hr helo pilot had not been flying since 2000. He is dual rated and has been flying during this time, just not helos. He was taking a new job with an EMS outfit and they wanted him current before they hired him. He called me for a BFR.

 

My FSDO said NO GO....because he did not have any Robbie time and said that the only way to do it was for him to do the 10 hours of dual..

 

 

Long story short, the company he is signing on with told him to just go out and do an hour or two of dual and I was to critique his maneuvers with regard to commercial standards.

 

This guy had not flown in 6 years and 90% of his hours were in big ships like Apaches and Cobras. He had not flown a small trainer since the TH-55 almost 25 years ago.

 

I was a little worried... But we did the awareness training and talked a little about the ship and he was very receptive. He did not even know the Robbie had the "t" bar and looked at me puzzled when I told him about it. I was prepared for this guy to think the Robbie was a little tinker toy and he did have some questions about what he had "heard" about Robbies.

 

I was also prepared for this guy to have his hands full with the 22....after all, he had been flying ships that carry missiles heavier then an empty 22

 

This was not the case at all though..... He lifted us off and was in full control. It was pretty windy (15gusting to 22) and he had no issues. I let him get acquainted for about 10 min on the ramp with some hovering and then we went on to go through the maneuvers.

 

I would demonstrate one and he would take it and pull it off just fine. Bam, bam, bam, one after another, we went through all the maneuvers. All up to commercial standards. He was a very good pilot with a great touch on the controls. After about an hour this guy was totally spot on. So, I decided to do a few autos.

 

I demonstrated the first one and talked through the maneuver. He gave it a shot, and except for over working it a little it was pretty good. By the third one, he had it down.

 

The more we flew the more fun we had. This guy was really getting into it. He LOVED the R22 and couldn't stop talking about how much fun it was to fly. He even liked the "t" bar. Being a shorter guy his first instinct was to hold on to the bottom of the grip as you would in a normal stick. I told him to just make a comfortable grip and let the stick fall where it does. He said it is the first ship he has ever flown where he doesnt have to move his hand to hit the PTT.

 

All in all, I feel very comfortable this guy would have no problems solo-ing a 22. I would have signed his BFR as well if I could have. But we did what we needed to do and he was satisfied.

 

I agree with the 20 hours before solo for a non rated pilot. It takes the pressure off the student and keeps it from being a race to the solo. But I think the 10 hours of dual to act as PIC for an already rated pilot is not the way to do it. It should be up to the discretion of the CFI and signed off when the CFI feels the pilot is ready.

 

I ran into this personally. I did my training in a Hughes 269 and R44. (there were no R22's around). By the time I got around to flying a 22, I already had my commercial. The 10 hours felt like a prison term. I did it in two days. After the first 2 hours there was not a whole lot else to do other then burn holes in the sky. It is a shame to spend 8 hours flying wishing you were doing something else....

 

I also think the requirements for the 44 should be removed. Just my $.02..

Edited December 1, 2006 by jtravis1

[Gunner]

my 2 cents...

 

SFAR73

 

doesn't hurt.... it helps.

[PA Pilot]

Frank also lobbied the FAA for SFAR 73. In the early 80s when these came out, his target market was commuters in downtown LA--NOT the training market. So his helicopters were in all the flight schools and he didn't like it as the crash reports came in. He went to the FAA, not the other way around. Well the government was going to take a long time to do anything (13 years to be exact), so Frank opened the safety school, made his own insurance, made purchase agreements, and ferry requirements.

You know, I've heard that both ways. At the Robinson Pilot Safety course this summer, somebody, and I think it was Tim Tucker, but I'm not positive, made a very emphatic statement that SFAR 73 was forced on Frank. I've also heard that SFAR 73 was supposed to expire but the FAA neglected to review it and it was kept on the books because of the FAA's inaction.

 

An unfortunate side effect of SFAR 73 is that I've heard Schweizer CFI's cite it to tell potential students "how dangerous" Robinsons are, and that they should learn in a Schweizer instead. Which is sheer BS in my book

[delorean]

I don't know about the "forced" part.....if so, why did he set all his minimums much higher than SFAR 73? The safety school started in 1983 and Pathfinder insurance minimums used to be much, much higher than they are now or even in 1995 when SFAR 73 was issued. Maybe it was forced in the very early years, it just took a long, long time to make it to the regs.

 

SFAR 73 was set to expire in September of last year or the year before. No changes, just the expiration date.

 

Yeah, Schweizer is using SFAR 73 as a marketing tool. Why shouldn't they? But is it working? Obviousely not. RHC is selling 800+ helicopters a year. I don't believe SAC has build anywhere near 800 helicopters in the last 10-15 years. But from what I heard, their main business is military contracts for wierd parts and such that no one else will take on.

[HH60Pilot]

I've been a pilot for about 22 years, and I'm relatively new to helicopters--just getting my CFII 1 1/2 years ago. I did all my helicopter training in a 300CBi, and I have a couple hours dual in a B206-B and about 6 hours in an R-22. Before flying the R-22, I heard a lot of bad things. One experienced instructor I talked to tried to mitigate all the bad things I had heard, but it was hard to believe. Additionally, Robinsons have special requirements for acting as PIC and even manipulating the controls that are set out by SFAR 73. So why shouldn't I believe the negative things people say about Robinsons? The crux of the negative comments was two-fold. First, they have low rotor inertia, so you can really get into trouble fast if your engine fails and don't get the collective down IMMEDIATELY. Second, rotor RPM is such a big issue, that Robinson finally had to install a governor to keep people from getting into a low rotor RPM condition, a problem associated with low rotor inertia.

 

I finally had the opportunity to take some dual in an R-22. At the first lesson, I didn't really like it, but that was due to the design of the cyclic. I did, however, admit that it seemed more stable while hovering with a tailwind that the 300. By the second lesson, I had become comfortable with the cyclic and about the only thing I didn't care for was the lack of a force trim on the cyclic that the 300 has. By now, I think it is a fine machine. It is faily well-behaved in an autorotation, and it's easier to fly than the 300 because the governor all but takes away your concern for maintaining rotor RPM. Part of the SFAR 73 requirement is to fly it with the governor off. The correlator on the R-22 is MUCH better than the correlator on the 300. I only had to tweak the throttle once or twice from pick-up, around the pattern, to set-down.

 

So now my point... finally. The Schweizer 300 has the same issues as the R-22 (or worse). The 300 has low rotor inertia and no governor, yet is deemed by some as one of the safest training helicopters out there. Why SFAR 73? In my opinion, Robinson sells the insurance for the helicopters it sells and the company is trying to reduce it's risk by getting the FAA to set PIC minimums for its helicopters, a function that is solely done by the insurance industry for other makes and models. The hour requirements in SFAR 73 are good for checkouts in different helicopters, but I don't think we need the SFAR. If Robinsons are that unique that they need special reqirements to be PIC, then the FAA should just require a type rating for them.

 

I appreciate any comments any of you have on this topic.

 

Jeff

 

As was previously said, Robinson wasn't forced to install a governor and it was an option early on. The governor will stabilize the rotor RPM are the proper setting, the same way that a turbine engine keeps the rotor RPM at the proper setting. So, it's not the higher inertia rotor system that is keeping the pilot of a high inertia helicopter from getting into a low rotor situation, it is the design of the helicopter and engine that keeps it from happening. To me, not having a governor is not a big deal as the first helicopter I learned to fly had a manual throttle (TH-55) and until someone invented the governor for the helicopter, all helicopters had manual throttles. Once a pilot has suffecient hours in a helicopter that does not have a governor installed, the pilot will be making the minor inputs needed as a matter of course and without any coherent thought needed about the subject as it becomes second nature.

 

So, now your point...While you call the Schweizer a low inertia system, it has IMHO significantly more inertia than the R22 has (I'm sure one of the engineering types on the board can quote the numbers). I find the 300 much easier to autorotate than the R22 could ever be and the rotor RPM to be much more stable than the R22. I simply lower the collective, split the needles and monitor the rotor RPM. I may need to make one small check up on the collective after a bit to keep the rotor in the green, but there are no large or quick changes in the rotor RPM that can be quite common with the R22. The Schweizer 300/Hughes 269/TH-55 is such a solid and stable helicopter for autorotations that power recoveries were not taught at Ft. Rucker. We learned how to do an autorotational descend out in the practice area, but all autos at the field were full down from the beginning. I don't know of too many R22 CFI's that are willing to take new students and start teaching them full down autos from the start. Also, you can get a governor on the Schweizer.

 

So, is SFAR 73 needed, the answer is yes. Simply look at the accident statistics of the period prior to SFAR 73 and the stats since and I think you will agree that SFAR 73 is creating the results that it was designed for. Don't get me wrong, I'm not Robbie bashing and I think that the R22 is a great helicopter for what Frank intended it to be...a personal use aircraft.

 

Just my two-cents.

 

Doug

 

Added: I forgot to mention that if SFAR 73 wasn't such a good idea, then why does Frank require an addendum to the R44 sales agreement requiring that SFAR 73 be adhered to and that if the owner of the R44 sells the helicopter, that they agree to obtain in writing from the new owner that the new owner will operate the aircraft in accordance with the agreement. I just wonder how you can agree in advance that if you ever sell your helicopter (which is your right to do) that the buyer will agree to anything that Frank wants signed.

 

For those of you that haven't seen this addendum to the sales agreement, click here to read it.

Edited December 3, 2006 by HH60Pilot

[Jeff]

 

 

I looked through some autorotaion accidents on the NTSB's website in order to compare the safety record of the R-22 and the 300 (H269). I found 8 R-22 auto accidents and stopped counting at 10 H269 auto accidents. There were a lot more to look at after 10, but the point was made. I don't think there is anything wrong with either helicopter; I attribute the statistics to training and experience. SFAR 73 and Frank Robinson's efforts with his sales agreements, etc. are accomplishing exactly what they were intended for. I am going to speculate that a Robinson-trained instructor would be less likely to have an auto accident in any helicopter than someone who never had that training.

 

In the beginning, I wanted to know if SFAR 73 was really necessary. I'm beginning to see that it is not. What IS necessary is a change in Part 61 to increase training requirements for helicopters in general, not just a particular make and model. Maybe that is too drastic, but the stats I saw say that more training is needed--perhaps just for flight instructors. Afterall, the average pilot flying around doesn't seem to have problems with accidents from practice autorotations. The accidents are occurring during flight training.

 

So the new question is, "How do we bring flight instruction in other training helicopters up to the safety level of the Robinsons?"

 

Jeff

Edited December 3, 2006 by Jeff

[500E]

Interesting reading HH what discount does FR give for this agreement ? if everyone gets the discount surely this is the price not a discounted cost ?.

If they wont sell the thing without the agreement there is no discount

[RotorWeed]

You know, I've heard that both ways. At the Robinson Pilot Safety course this summer, somebody, and I think it was Tim Tucker, but I'm not positive, made a very emphatic statement that SFAR 73 was forced on Frank. I've also heard that SFAR 73 was supposed to expire but the FAA neglected to review it and it was kept on the books because of the FAA's inaction.

 

An unfortunate side effect of SFAR 73 is that I've heard Schweizer CFI's cite it to tell potential students "how dangerous" Robinsons are, and that they should learn in a Schweizer instead. Which is sheer BS in my book

 

 

I was told the same thing at the RHC safety school. They were emphatic that SFAR 73 was forced on them by the FAA. It wasn't Frank's idea.

 

RW

[delorean]

I was told the same thing at the RHC safety school. They were emphatic that SFAR 73 was forced on them by the FAA. It wasn't Frank's idea.

 

RW

 

Well, at safety school in Nov 2000, we were told the exact opposite.

[HH60Pilot]

Interesting reading HH what discount does FR give for this agreement ? if everyone gets the discount surely this is the price not a discounted cost ?.

If they wont sell the thing without the agreement there is no discount

 

500E,

 

Good question as I have never heard or seen anything as to what the financial consequences are if you don't agree to the addendum. I do not know if there is an additional fee attached to the purchase price if the buyer does not agree to sign the addendum, or if there is a discount taken off of the list price if the buyer does.

 

Maybe there is someone that has purchased an R44 since RHC has come up with the addendum that would be willing to shed some light on the subject. I'm also curious as to what happens to the financial consideration if the buyer then sells the R44 to someone that doesn't agree to the addendum. Does RHC then take the original purchaser to court to reclaim what was given in financial consideration on the original purchase?

 

Inquiring minds want to know.

 

Doug

[HH60Pilot]

Well, at safety school in Nov 2000, we were told the exact opposite.

 

Delorean,

 

I was at the safety school in 2004 as and told pretty much the same as you were, that it was more an idea from Frank than the FAA.

 

Doug

[nsdqjr]

Since everyone else added their two cents I suppose I will too. This is what the story was at the Robby course that I went to.

 

SFAR 73 was written with the help of Frank Robinson under the assumption that it was going to apply to ALL rotorcraft, not just his. The story goes that a big wig at the NTSB had a friend or relative that was killed in a Robinson and he wigged out and demanded some action be taken, hence the birth of SFAR 73. I don't know how accurate that is, but that's the story. Basically yeah, Frank helped them author SFAR 73, but it was mandated by the NTSB. The other hour requirements, as far as insurance is concerned, are just that. Hour requirements for insurance, which is a completely seperate issue from the regulations governing the aircraft. Do we need SFAR 73? In my humble opinion, anything that promotes safety and awareness is a positive, even if it's a pain in the backside, so I'm all for it. The SFAR 73 Awareness Training that I give new students is about an hour long. I think of it as their first ground lesson, not a mandatory talk. The problem comes when you get instructors that give the 5 minute SFAR and then go fly. At that point it's a waste.

 

Take the SFAR Awareness Training as a chance to learn (or teach) some valuable, and possibly life saving information. As far as the PIC and CFI requirements are concerned, if you train at a Robby school you'll get those hours without even thinking about it, and to be honest, a CFI with less than 200 hours scares the hell out of me.

 

Hot air expended.

[volition]

CFI with less then 500 hours, scares the hell out of me!!

[blave]

CFI with less then 500 hours, scares the hell out of me!!

 

I had the same attitude, and will still have it with any newbie CFI that I fly with. But I did my commercial rating with a guy that had right around 500 hours when we started last year, and I now have nothing but good things to say about him - that was a real eye opener but then I think that this fellow is a bit unusual in his dedication and perhaps maybe a bit of natural flying ability. He now has over 900 hours and I just hope he sticks around for a while so that I can do some recurrent training with him!

 

If you live in the San Jose, CA area, give Nice Air a call and ask for Marcus, and go see what new stuff he can teach you. I'm not a big Nice Air fan from a company standpoint, but they do maintain their helicopters (currently one 300CB, with another one in the shop for quite a while) fairly well and as stated they have an ace CFI working for them.

 

Dave Blevins