SFAR 73

[DebosDave]

Hello all,

 

I am writing a research paper on the need for SFAR 73. In my opinion all helicopter pilots need/get the training required by SFAR 73. It is important for all pilots to know those safety items. So, why do we need to single out the Robinson's any longer? The 300C has a low inertia rotor system, and there are several semi-rigid rotor systems out there. So my feeling is, that everyone needs to learn the training covered by SFAR 73, so there really isn't a need to single out Robinson's for this training, and hours requirements. This is the jist of how I currently feel about it. I am going to try and dig into it a bit deeper.

 

Do any of you have any information, opinions, or pointers with where to go for information on this subject? Any feelings on getting rid of the SFAR? Any feelings on why we need to keep it in place? I would love to hear your opinions.

 

Dave

[Gomer Pylot]

Ain't gonna happen. Frank Robinson lobbied for the SFAR, and is responsible for its existence, and unless he changes his mind, it will continue to exist, whether anyone else thinks it's needed or not.

[C of G]

The SFAR was a band aid to keep the type certificate. (In my opinion).

It was in response to the following report:

 

R22 Special report

 

 

Also check out this AD. This is what was killing the pilots (In my opinion).

 

MR Gearbox AD

 

When the NTSB does a special investigation on any other helicopter, you can look forward to another SFAR, if the company owner is savvy enough.

The SFAR was not a new idea, and was being taught at the factory and flight schools for years. Just making it a regulation didn't miraculously make the helicopter safer. Limiting low g pushovers was a good idea, though.

[arotrhd]

Get a little more familiar with SFAR73...there is and effective date and a termination date published. But, as GOMER mentioned, not a chance that it will be terminated and will likely have further extentions applied.

 

In a nutshell, the rule was applied way back when Robinson drivers were having far too many avoidable accidents (IMHO), even if they were considered delicate to the touch. Robinson, among others, happens to be turning the worlds skys dark with their aircraft and I think it's great. Can't wait 'til next year when there will be even more. But every time an R22 got balled up, Robinson was seen as a guilty co-conspirator and Frank said "Hell No", here's what we're going to do. He stepped up with a program that had, what some may feel, implications far beyond the original intent aannnddd with FAA support (what other way can it be made enforceable). Was it good for the industry and safety? you bet. Did Frank cover Robinson's a$$ in a big way? yup there too. Did the rule help to put a little more cash in Robinson's coffers? Let's see, right now it's about $1.5M/year in gross income. And Pathfinder req'ts...you can get the idea, but is t necessary as you propose?

 

To answer another this question, I'm not real fond or happy with having any more government rules forced upon me (especially with the real potential for some type of user fees to be enacted this year). Do I think there should be SFAR for Robinsons - or any other brands? NO. Let the manufacturers, operators and insurers set the requirements they deem necessary and keep the FAA and government out. That is a LAST resort, not a good first step. AMEN.

 

That being said, I am very much a proponent of safety training - I wrote a 300 page graduate dissertation regarding mandatory wire strike and obstacle avoidance training a few years back with some of my initial thoughts regarding "mandatory" being confirmed by many professional respondents...keep the government out of the house and out of the wallet. AMEN.

 

Do you think that IF the SFAR was terminated on 3/31/2008 that the Robinson safey course would cease existance and pilots would go back to happy -go-lucky, fat-dumb and stupid ways? Do you think it's absolutely necessary to have an expanded FAA SFAR to cover ALL manufacturers ?...what about factory training from Bell, AE and others? Does that count for something? Please expand other groups as watchdogs and standardization organizations. Just a few things I ask you to consider while contimplating your reaserch.

 

-WATCH FOR THE WIRES-

[DebosDave]

I think all of the safety aspects of the SFAR should be mandatory in primary training, and this can be enforced through the Practical Testing Standards. I just don't feel it is necessary to single out Robinson. You are right there is money in it all, but the insurance industry regulates most of this far greater anyhow. I just am not in agreement with the hours part of it all, and the fact that it is an SFAR instead of just revising the PTS. I don't like the fact that no matter how competent a pilot proves to be, or how safety concious he/she is, they can't fly Robinsons without a certain amount of time in them. Not to say that just anyone should be able to jump right into one and fly, but each person is different in their ability and comprehension.

 

These are just my opinions, and won't be the base of my paper. I haven't had enough chance to dig through enough research, but I do appreciate all of your input, it will help give me a direction!

 

Thanks,

 

Dave

[relyon]

... The 300C has a low inertia rotor system, ...

Not so. The 300C main rotor system has close to twice the inertia of the R22 and more per unit mass than a CH53.

 

Bob

[Rotorookie]

I understand the need for special training for the R22. But the R44?

Autos in the 44 are a dream compared to either the R22 or the 300! (sorry, "dream" is about as technical as I can get at this point in time)

Bob, how does rotor inertia in an R44 compare to that of a 300C? (Just put your elbow on the bed of the yellow Ford Ranger and pretend you're doing HSH ground).

 

Cheers

Roger.

[Goldy]

But every time an R22 got balled up, Robinson was seen as a guilty co-conspirator and Frank said "Hell No", here's what we're going to do. He stepped up with a program that had, what some may feel, implications far beyond the original intent aannnddd with FAA support (what other way can it be made enforceable). Was it good for the industry and safety? you bet. Did Frank cover Robinson's a$$ in a big way? yup there too. Did the rule help to put a little more cash in Robinson's coffers? Let's see, right now it's about $1.5M/year in gross income. And Pathfinder req'ts...you can get the idea, but is t necessary as you propose?

 

 

I have met Frank and had the opportunity to speak with him frankly (no pun intended). I have never asked him directly if he instigated the SFAR or not...however two individuals that report directly to Frank, insist he did not, and was never so pissed off as when the FAA gave him notice of it. This came at a critical ( read-cash flow) time for Robinson and almost sank him.

 

As far as 1.5M/year in gross income...ummm..I would guess closer to 250M ????

 

Pathfinder, the 2200 hour requirements and the 12 year rebuild are some of the most clever marketing I have ever seen. They have led to the direct success of Robinson. They are pure genius by design.

 

The special report that CofG speaks of did spawn the SFAR. The most curious part of the report is that they never resolved a single thing! They spoke of low rpm, low inertia blades, teetering hinge blade designs, etc...but never got even close as to why blades were diverging into tailbooms and cockpits with little or no notice. The Georgia tech study never was finished or provided any real value.

 

I can't believe the part where they compare the R22 to the Bell 47. "Both are 2 place helicopters, both with light inertia rotor systems"....what? Has anyone ever flown the two and think they are even close ?

 

I've always felt that the main rotor was so light, the blades could be reacting to turbulence or control inputs and overwhelm the stops. The Bell 47 I figured, did not experience this due to the MUCH higher weight and inertia of the blades. AND the weight of the airship is twice that of an R22 so you dont even notice the wind or turbulence, higher weight means the rotor is always heavier loaded ! But the gut feeling never really seemed to fit the weather when these accidents occurred.

 

I think CofG said it best....the real reason why this was happening was discovered later...by chance. And it was a mechanical design flaw causing the main rotor to separate from the mast. Hmmm..I dont recall Robinson ever actually saying that though ! (Attorneys prefer silence)

 

Bottom line is this. As long as the R22 is around, I suspect the SFAR will be also. While there are some good learning things in there, most apply really only to the R22 and dont mean a hill of beans to a B47 or 300 pilot. Leave it alone, it has helped raise awareness of many other issues that were killing pilots, that are specific to the R22/44 and has helped us become better pilots and the R22/44 to become better birds. Just ask anyone that has ever flown an original...or an R22 A model.

 

The FAA should have known something when the FAA test pilot crashed while testing the autorotational abilities of the R22 during type certification....hint here guys pay attention !

 

And to Rotorrookie reply about autos in an R44...dream is a good description.

 

As always, my opinion flavored with some conjecture and a lil humor on top.

 

Fly em safe

 

Goldy

[Goldy]

Not so. The 300C main rotor system has close to twice the inertia of the R22 and more per unit mass than a CH53.

 

Bob

 

 

ahhhhh, thats why they dont use Ch 53's for training !

[C of G]

Goldy,

 

Were you closely effected by an R22 blade divergent incident? The reason I'm asking is that the theory I put out isn't widely known, and, to be honest, I thought more discussion would have developed from it. It seems you tend to agree so I thought you must have been involved somehow. I had a discussion with someone very closely involved and that's how I found out about it. Can you elaborate on how the AD was found by chance? Thanks.....

[PA Pilot]

I have met Frank and had the opportunity to speak with him frankly (no pun intended). I have never asked him directly if he instigated the SFAR or not...however two individuals that report directly to Frank, insist he did not, and was never so pissed off as when the FAA gave him notice of it. This came at a critical ( read-cash flow) time for Robinson and almost sank him.

When I took the RHC pilot safety course last September, some instructor, and I don't recall who, said that RHC wanted SFAR 73 to expire on the last go around, but that the FAA screwed around with it to the point where the FAA decided to extend it again becuase they claimed they didn't have enough time to review it.

[delorean]

I like most of SFAR 73.....It makes up for all the shortcomings of Pt. 61.

 

However, I don't like how you have to take TWO different flight reviews to stay current in both R22s and R44s. And if you go to the reg's on a flight review, it has to be at least a 1.0 hrs w/ at least 1.0 hrs of ground instruction (unless you're a current CFI, then no ground).

 

At least with the one year req for pilots under 200 tt and/or less than 50 in type, it just has to cover low g, low rpm, and autos.......no time limit means you can easily do it in 0.3 hrs.

 

Rather than knocking SFAR 73 for being so restrictive, people should knock Pt. 61 for being so lax, eh?

[darwin]

Rather than knocking SFAR 73 for being so restrictive, people should knock Pt. 61 for being so lax, eh?

 

:(

Why do so many people incessantly feel that the answer to any "problem" is more government regulation?

[Gerhardt]

:(

Why do so many people incessantly feel that the answer to any "problem" is more government regulation?

 

Because the world is filled with enough stupid people that will do something unless they're told directly not to. And yet a lot of people will go on and do it anyway.

[apiaguy]

Amen Darwin....

 

Government cannot be responsible for protecting people from themselves.... You can make a law to protect me from you and you from me.... but never me from myself... it just makes poor law and government downfall.

 

SFAR 73 is fine by me for the R-22... the thing needs extra attention. I don't like the extra hassles and rules it stipulates but whatever.....Please don't encourage its furtherance to other makes. It is interesting the 44 is included... but I guess once a name is tarnished it is hard to seperate the product... I wonder if the 66 will get looped in as well.. it will be a Robinson.

 

By the way... the 300 IS a low inertia system.. even says so in the POH.

Just isn't AS low as the 22.

[delorean]

One reason the R44 is included is because of the accident in s/n 0003 in '93.

 

This was the accident where on takeoff roll the helicopter snap rolled right and impacted the ground. The fire destroyed mostly everything, but they found some broken cyclic control tubes. RHC blamed a low g pushover, the family & NTSB blamed a control tube failure. Every notice how HUGE the control tubes are in the R44?

 

This is why the R44 kind of disappeared for a few years after the it was type certified in 1992. I know that--with an exception of a few--the first several hundred where shipped overseas.

 

If you get a chance, read the NTSB report. Summer of 1993, 445RH, somewhere in southern CA. I heard this is one of the very few cases RHC ever settled out of court with a family.

[delorean]

:(

Why do so many people incessantly feel that the answer to any "problem" is more government regulation?

 

Whoooaaa....please don't put me in that crowd. I am not in any way for more government regulation in most cases. Believe me, I'm a BIG 2nd amendment supporter (just got another AK today--Yugo underfolder, very nice.)

 

However there has to be some restrictions, regulations, etc. For instance, it really ticks me off how these old geezers who can barely see or function can still get a driver's license.......and their family are the ones that finally have to take the keys away because they know what a danger they are to themselves and others. Where's the government in this? Hiding because of age discrimination and the fact they're going to have to pay to transport these seniors if they can't drive.

 

Flying is a privilege, not a right (certificate vs. a license) and therefore should be more restrictive. I don't see anything wrong with making a private pilot certificate more difficult to obtain--in the interest of safety, by the means of more training. I know that it becomes more of a financial problem......but its not like the gun laws where they're hitting you with tax stamps, loads of paperwork, waiting periods, etc just to make it more difficult hoping people will just give up. For the extra cash & time, you're getting extra training which may save your life.

 

This is one of the VERY few times I have called for tighter regs on something. Either way, the insurance company still and will always make their rules more restrictive which will dominate the industry.

[arotrhd]

"As far as 1.5M/year in gross income...ummm..I would guess closer to 250M ????"

 

Goldy: Sorry, I should have been more concise...I was referring to the Safety Course.

 

DeLorean: The crash & burn R44 accident was at El Monte (KEMT) ~12 East of downtown Hell A. Grew my fixed wings there a while back but, in the process, lost a couple of the few brain cells I had .

 

 

-WATCH FOR THE WIRES-

[apiaguy]

"I don't see anything wrong with making a private pilot certificate more difficult to obtain--in the interest of safety, by the means of more training. "

 

 

 

 

 

I think you just put yourself in "that crowd". How many accidents in aviation are due to the "old geezer" like in your automobile analogy?

More regs and making it more difficult to obtain a rating don't necessarily make it safer. So by you being along for the ride in supporting more government oversight, you are "that crowd"

 

p.s. not trying to start a fight... just my 2 cents based on your comments

Edited June 2, 2007 by apiaguy

[delorean]

"I don't see anything wrong with making a private pilot certificate more difficult to obtain--in the interest of safety, by the means of more training. "

I think you just put yourself in "that crowd". How many accidents in aviation are due to the "old geezer" like in your automobile analogy?

More regs and making it more difficult to obtain a rating don't necessarily make it safer. So by you being along for the ride in supporting more government oversight, you are "that crowd"

 

p.s. not trying to start a fight... just my 2 cents based on your comments

 

 

Maybe the "old geezer" analogy was too far off--that was off the top of my head because recently in STL, there was a 80-something y/o lady that "got confused", slammed through a school cafeteria, and killed a kid. Here's something a little closer:

 

I really like what they did with drivers education, and young drivers laws in MO and IL. Years ago they changed it from age 15 = learners permit with parent and age 16 = unrestricted driving, to a step type system. After you passed drivers ed and got X amount hours with your parent or instructor, you could drive alone, sibling, or with one passenger over 18 (or 20?). You could only drive during daylight hours unless you were going to/from class or work. They made it illegal for them to talk on a cell phone even with handsfree system. As you got closer to 18 the restrictions were lifted one by one.

 

And I hear ya....More regs & more hours don't mean safer skies necessarily. But if it saves 1 out of 1000, do they bump up the reg's and penalize the other 999? Or does it have to be 1 out of 100? It's all based off that. Where you put the "1 out of whatever" is everyone's own opinion.

 

On example of regs I don't agree with is the 5 hr minimum for CFIs in helicopters and multiengine airplanes. So if I have a CFI rating w/ 200 hrs of R22 time, I only need 5 hrs in a S76 and I can legally give you dual in it. Gimmie a break. There was no way I was even qualified to give dual in the 206L after 5 hrs when I moved into it from a R22. And for airplane guys, you can go from a single engine Cessna, to Beechcraft, to Piper, etc without ANY training and legally give dual in a airplane make/model you've never been in before. Not right in my opinion. Most insurance companies put a minimum on it or require a sign off / checkride from a CFI.

 

Another example.....they require three hours of instrument training for airplane guys, why not in helicopters??? You are much more likely to die in helicopter d/t inadvertant IMC than in an airplane. Granted, you're usually underneath the clouds in a helicopter, but with the "clear and see & avoid" rule I think you're more likely to get into inadvertant IMC situation because the METAR never legally grounds you like in an airplane.

 

How about the PTS not requiring 180 autos for a private candidate (or does it now?) I flew with a guy that had his private and about 100 hrs. Came to me to start his commercial training. He had never done a 180 auto. Had one demonstrated ONCE. WTF????? You think you'll be lucky enough to have the engine quit on you while you're straight into the wind.

 

I'm not saying to make the private a 100 hr minimum--or even 50 hrs, just more requirements when it comes to experience and testing tolerances.

 

I like the 20 hr minimum for soloing students in SFAR 73 too. These guys soloing in 5 hrs in 269s just because they can hover is nuts. They may be able to hover the thing, but they're SCREWED if anything happens that's out of the norm. Whether that be a wind gust, a bad mag, whatever, they haven't had enough training to no what to do.

 

Just out of curiosity, where do you stand on the government mandating seat belt use in cars and helmets for motorcycle riders?

[apiaguy]

sorry to get off the topic of the thread... but since you asked.

Spent most of my life in Idaho... the most conservative state in the union.

Received my drivers license at age 14. Rode my motorcycle to Jr. high and high school. No motorcycle endorsement needed, nor helmet... (now you need an endorsement and helmet if under 16)

You still can't pull me over if I'm not wearing a seat belt (but you can get a ticket if you're pulled over for something else and you're not wearing it)

Soloed in 4.8 hours... there was no SFAR at the time

transitioned to the Hughes 269 with a CFI who had about 160 hrs. rotorcraft and did his "5 hrs" with me (my helicopter)

Did my flight review in my mooney from a CFI who had never flown one.

hmmm, what else...

Flight check ride for rotorcraft add-on was about 20 min. Oral part was listening to stories about Vietnam and everyone he knew who flies helicopters has pretty much died and all their gruesome stories.

Regs suit me just fine. Call me a cowboy hick, I love it!

Implement your "new" regs on yourself and your students.... let the rest of us use a little common sence.

[Goldy]

Goldy,

 

Were you closely effected by an R22 blade divergent incident?

 

Not directly, no. However my first round of flying was in a R22 back in 1986. Lots of crap was happening from 86-00. A couple video tapes were made of in flight Robbies when they were hit by a sudden break up. It didnt make sense that it was a low g/ mast bump situation. Even the NTSB reports couldnt ID it as a mast bump incident..just main rotor divergence..usually taking off either the tail or coming thru the cockpit...I'm glad to say I was never that close.

 

What I meant by discovering it by accident is the NTSB never figured it out...the Aussies did a couple investigations and they revealed the problem.

 

Interestingly, they don't include any of the AD's in the official R22 Flight Training Guide.

 

artrhd- EMT huh ? I fly there all the time...only airport you can lose in the haze while doing patterns!!

 

I think of that R44 incident there every time I am running down the runway. One of the few where it was pretty plain what caused the accident.

 

Are you still flying in LA ??

 

Goldy

Edited June 2, 2007 by Goldy