SFAR 73 to Part 61

[JDHelicopterPilot]

A quick question, a Pilot Examiner I know stated that in order to meet the currency requirement to carry passengers day or night as per 61.57 it can be in any type of rotorcraft, however, he said to meet SFAR 73 and to fly passengers in a r-22 or r-44 the 90 day currency requirement has to be done in either an r-22 or r-44. Is that true ? I looked it up and asked around and got different answers. The SFAR just says you cant act as PIC of an r-22 or r-44 unless you meet 61.57. Your thoughts?

[joker]

Going out on a limb here 'just because as one else has replied yet, but ....

 

Without absolutely no references to hand so completely off the top of my head I believe that currency does have to be in R22.

 

i.e. if you are both R22 and s300 rated and you maintained your night currency in a s300 , then you are still not current R22. However, if you do this in an R22 then you aro good to go in any aircraft of same category, Class, and type if required.

 

This is because of two sentences in the sfar.

 

I think it is part (d) which says that 61.57 must be done in the Robinson . Part 1 of the Sfar says that the sfar is "in addition" to the normal fars .

 

I hope this helps!

Joker

 

Maybe someone can find and post those references for me. I am currently on a pda in an airport!!

Edited December 18, 2006 by joker

[Superman]

Short answer is Yes..... To act as PIC in R22 or R44, currency requirements are per SFAR 73 and must be met in an R22 or R44 to carry PAX

 

Fly Safe

Clark

[JDHelicopterPilot]

That is my thinking as well, my chief pilot says otherwise. Also, another pilot friend I know says no. I am going to look into it more I think. Anyone else have an opinion? Also, here is a copy of something my DPE that used to be the Cheif Pilot of the school I went to. It was even posted at the local FSDO. The very last thing he says is the currency must be done in the R22 or R44. It's interesting how some pilots say yes and others say no.

Date: March 03, 2003 at 23:54:58

From: Barry

Subject: What SFAR 73 really means....

(not the full text)

When SFAR 73 came out, I wrote a little tome to explain it and submitted it to FAA AFS-600, where it resided on the FAA Pilot Examiner Bulletin Board for 5 years. Perhaps it may help you to better understand the SFAR. Beware, though, that merely taking a BFR in an R-22 or R-44 does not consititute a "flight review" within the meaning of SFAR 73-1.

 

Go to http://afs600.faa.gov and look for the Part 61 FAQ's and you will see at the end of them some SFAR-specific questions I submitted, and the responses of John Lynch, the author of Part 61 and Bob O'Haver, the author of SFAR 73. Here's what SFAR 73 really means:

******************* snip ***********************

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.

 

CURRENCY: In order to carry passengers, day or night in an R-22, a pilot must do their 90 day currency flying in an R-22.

(Revised 09-28-01)

Edited December 18, 2006 by JDHelicopterPilot

[flingwing206]

All it takes is a FAR/AIM.

 

Section iv (d) Currency Requirements (right at the end of the SFAR section)

 

Joker and Superman are correct, anyone thinking otherwise might want to have a read.

 

It's the same thing for a tailwheel airplane, btw.

[JDHelicopterPilot]

Ykies I don't know how I got all those smilies in there. Anyway, I even ready the SFAR with the Cheif Pilot and he tried to convince me that it wasn't required. That is why I am trying to get some solid feedback to make sure I didn't miss anything.

[flingwing206]

...I even read the SFAR with the Cheif Pilot and he tried to convince me that it wasn't required.

Yikes is right. It couldn't be much clearer.

 

"No person may act as pilot in command of a Robinson model R-22 or R-44 carrying passengers unles the pilot in command has met the recency of flight experience requirements of 61.57 in an R-22 or R-44 as appropriate."

 

Where is the grey area?

 

Now all this means is that if it's been 91 days since your last flight in an R22/R44, before you carry a passenger you must do three trips around the pattern by yourself in the R22/R44. If you're worried about freaking out a passenger, just tell them the helicopter was over-fueled and you have to burn some off before they get in!

 

Of course you can go with a CFI, but you can't act as PIC until the third landing. Now you want to really melt down your brain? During those initial three circuits with a CFI, can you log PIC?

 

 

BTW, the smilies come when you put a "B" before a ")", like this - you can uncheck the "Enable emoticons" box to stop that from happening.

[joker]

Yes Fling,

 

It is pretty clear cut!

 

I was attempting to seem humble before when I said I was going out on a limb!

 

I would suggest that JDHP's chief pilot go look again! TsK! A CP making such a basic error. I wonder how many students have broken the regs . based on his Interpretation?

 

Possibly an example of how a 'convenient' interpretation can be arrived at which Simply suits the needs of the interpreter.

 

But this one doesnt even lend to any interpretation... it's there in black and white! Something fishy going on

 

 

With much skill and finesse (I am still using a pda!) I have managed to cut and paste the other pertinent reference that JDHP needs! (In addition to the currency one in Fling's post.)

 

1. Applicability. Under the procedures prescribed herein, this SFAR applies to all persons who seek to manipulate the controls or act as pilot in command of a Robinson model R-22 or R-44 helicopter. The requirements stated in this SFAR are in addition to the current requirements of part 61.

 

Joker!

 

 

EDITED! TOO HASTY WITH REPLY!

 

Yes, that pilot may log the time that pilot is 'sole manipukator' of the controls!

 

Is that right Fling?

 

J

Edited December 18, 2006 by joker

[JDHelicopterPilot]

What he said was that if I meet my night or day currency in the R22 as needed then I don't have to do it in the R44. My argument is that is the FAR says "as Appropriate" which I would say means I would have to do my currency in each aircraft. I am correct to understand that I would have to keep my currency curent in both the R44 and R22 right?

[joker]

JDHP,

 

Silly me for thinking you meant what Fling and I have been harping on about for the last few posts!

 

Re. your latest question...

 

I think you are right.

 

If you maintain your currency in one you must also do so in the other.

 

In keeping with the mode of the SFAR, there is a definite distinction between the two makes and the training required. It wold follow then that the inclusion of the words 'as appropriate' is deliberate to maintain that distinction.

 

Joker

[Superman]

What he said was that if I meet my night or day currency in the R22 as needed then I don't have to do it in the R44. My argument is that is the FAR says "as Appropriate" which I would say means I would have to do my currency in each aircraft. I am correct to understand that I would have to keep my currency curent in both the R44 and R22 right?

 

 

It has always been my understanding that you had to maintain currency in both. The R22 didn't carry over to the R44 and vice versa

 

SFAR 73 is really pretty straight forward. The only time it is confusing is when we try to read something into it that isn't there to begin with.

 

 

Of course you can go with a CFI, but you can't act as PIC until the third landing. Now you want to really melt down your brain? During those initial three circuits with a CFI, can you log PIC?

 

I would say yes, you can "log" it as PIC time, even though you aren't "acting" as PIC

 

Fly Safe

Clark

[arotrhd]

Let's see where this [rule] goes AFTER March 31, 2008...of course, unless sooner superceded or rescinded.

 

My money is on superceded. Any thoughts?

 

-WATCH FOR THE WIRES-

 

 

RIP Paul, Katrina, Jerry & 410MA

[joker]

Seeing as the first one (1995 ) was due to expire in 1997, but was extended until 2002; and that one was extended until 2008 , I see no reason why they won't extend SFAR 73-1 for a further 6 years or longer.

 

Think of the liability if they recinded it and someone had an accident.

 

It is much easier to leave it there.

 

Just my opinion.

 

Joker

 

if you mean 'superseded' by being some changes made. than O. K. that is a possibility. but I don't think they will make it any less restrictive.

Edited December 18, 2006 by joker

[arotrhd]

Joker-

 

I agree completely with you in that the FAA will extend the rule for another 13 years, and the some more after that; I lumped the time extension in the superceded category - my bad if that is how it was conveyed. But, maybe Frank will have the R-66 (or whatever Robinson decides to name it) available in the next few years and then, technically speaking, the rule could be modified to incorporate it as well.

 

-WATCH FOR THE WIRES-

 

p.s. - rec'd you loud and clear on the Emu topic & I did appreciate the concern/feedback.