SFAR 73 Grandfathering...

[Sideshow Bob]

Hey- I got my CFI-RH before SFAR 73 existed. I have about 300+ TT heli/RHC course and wondered if there was any grandfathering involved with SFAR 73? Am I required to be endorsed for flight/ground prior to operating as PIC in R22/44? What exactly do I need to have in my logbook...? Thanks!

[Goldy]

Hey- I got my CFI-RH before SFAR 73 existed. I have about 300+ TT heli/RHC course and wondered if there was any grandfathering involved with SFAR 73? Am I required to be endorsed for flight/ground prior to operating as PIC in R22/44? What exactly do I need to have in my logbook...? Thanks!

 

Grandfathering-No

Endorsements- Yes, exactly as required in 73, and the endorsements are separate for the 22 and the 44.

[joker]

What is 'grandfathering'?

 

By this, do you mean concessions due to your having the CFI-RH (R22) before the SFAR?

 

SFAR73-1 Section. 1 states clearly that:

 

The requirements stated in this SFAR are in addition to the current requirements of part 61.

You say you have already attended the Factory Course. When was this?

 

You don't need the awareness training endorsement (SFAR73-1 Section. 2(a)(1)) to simply manipulate the controls, if you can show satisfactory completion of the manufacturer's safety course after January 1, 1994.

 

You don't state how your hours are broken down between R22 and R44. This is important too. Let's say you already meet the requirements of SFAR73-1 Section. 2((1)(i), you may act as PIC of an R22 without further endorsement.

 

If you meet the R22 requirements (50 hours and 200 total hours) then you would only need 25 more hours in R44 to meet the requirements for R44.

 

If you fall short of 50 hours in both types, then yes, you need 10 hours of dual instruction and an endorsement before you may act as PIC.

 

You also need a valid 61.56 Flight Review endorsement taken in an R22 or R44. Lastly, any 61.57 currency requirements must have been done in the respective type of Robinson helicopter you wish to fly.

 

To instruct in these aircraft you must been authorized by endorsement from an FAA aviation safety inspector or authorized designated examiner that you have completed the appropriate training, meet the experience requirements and have satisfactorily demonstrated an ability to provide instruction on the general subject areas of paragraph 2(a)(3) of this SFAR, and the flight training identified in paragraph 2((5)(iii) of this SFAR.

 

Without being more specific about your factory course dates, and breakdown of your hours on type it is impossible to be more helpful. Hopefully this will be of some sort of help.

 

Actually, as a CFI, you should be confident to be able to find and interpret the SFAR yourself. It's pretty clear. However, there are some interesting bits as my question below will show!!!

 

Question for All: A CFI has 51 hours in R22 and 201 total helicopter hours. He has done some abnormal and emergency procedures training in R22s. He attended a normal factory course after January 1, 1994. He is current by 61.57 and has a valid 61.56 flight review.

If you were a FAA inspector or DPE, would you give him the final authorisation to instruct?

 

 

Joker

Edited October 22, 2007 by joker

[wannabe heli pilot]

Joker,I think that they would have had to have hit the 200 total time hour mark before their PIC endorsement for Robinsons expired. They also would have had the flight review completed in the 22. In addition, they must demonstrate the ability to provide instruction on the subjects of 2(a)(3) and flight training as outlined in 2((5)(iii) of SFAR73. Plus, meet 61.187((3). If they met all the above, I'd say yes to instruct in the 22. I've been wrong before though.

Edited October 22, 2007 by wannabe heli pilot

[joker]

Thanks Wannabe.

 

I see no other takers, so let me ask a couple of follow-on questions.

 

Has that pilot completed the awareness training as required in 2((5)(i) ?

 

Does he need an endorsement for this awareness training?

 

As a different scenario:

 

I think that they would have had to have hit the 200 total time hour mark before their PIC endorsement for Robinsons expired.

 

I'm not so sure about this. I could do my 10hrs dual in R22 and get a PIC endorsement. Fly a further 40 hours in R22. Then 15 moths later (PIC endorsement has run out), after having accrued 201 total hours (other helicopters), I could still in theory, satisfy all requirements to satisfy both 2((1)(i) and 2((5)(ii).

 

Joker

Edited October 22, 2007 by joker

[wannabe heli pilot]

 

Has that pilot completed the awareness training as required in 2((5)(i) ?

 

Does he need an endorsement for this awareness training?

 

As a different scenario:

I'm not so sure about this. I could do my 10hrs dual in R22 and get a PIC endorsement. Fly a further 40 hours in R22. Then 15 moths later (PIC endorsement has run out), after having accrued 201 total hours (other helicopters), I could still in theory, satisfy all requirements to satisfy both 2((1)(i) and 2((5)(ii).

 

Joker

 

Joker, Your welcome. This is nice to have someone to help interpret the FARS.

 

2((5)(i) states that awareness training must be completed as outlined in (2)(a).Then in (3) (i,ii,iii,iv,v) it outlines what that training must consist of. However in (4) it states that the safety course taken after January 1, 1994 may obtain the endorsement in lieu of said training.

 

In the other scenario I believe that the endorsement runs out after one year from the date of that it was issued.

 

To act as PIC in the 22 you must have had 200 hours in helicopters, 50 of those hours in the 22.

 

I think that the 151 hours (other than the 22) as well as the 50 hours 22 time would have to be completed prior to the expiration

of the instructor's PIC endorsement for the 22. Other wise another PIC endorsement would be required?

[joker]

Wannabe,

 

Scenario 1

 

Here is my point.

 

Read carefully 2(a)(4).

 

(4) A person who can show satisfactory completion of the manufacturer's safety course after January 1, 1994, may obtain an endorsement from an FAA aviation safety inspector in lieu of completing the awareness training required in paragraphs (a)(1) and (a)(2) of this section.

 

I have placed emphasis on the the point.

 

It does not include the 'training required in paragraph 5(i)' does it?

 

So the factory course that our CFI went on (as a new pilot) may not be used in lieu of the requirement of 5(i). This is because that 'normal' factory course does not necessarily cover how to provide instruction on the Awareness Training items in paragraph 2(a)(3) and the flight training identified in paragraph 2((5)(iii),".

 

Remember, the minimum requirements to attend the course is 3 hrs in R22. It would be stupid try to teach someone with 3 hrs, instructional techniques and theory!

 

Therefore he does not have any 'instructor-specific awareness training' for the purpose of becoming an instructor in R22. 5(i) and 5(iv) require this though.

 

Now, an FAA examiner or DPE may only authorise the CFI to instruct upon being satisfied that he has 'completed the appropriate training' 5(iv). What is appropriate training? The stuff the CFI got as a new pilot? No. Again, the CFIs initial R22 awareness training cannot count, as initial training is very different to advanced instructional training.

 

I would say there must be training after the initial training (normally later on), where the focus is on 'how to instruct' rather than just 'how not to kill yourself' in an R22. Evidence of this would be say, logbook records, ground school invoice etc..etc... 5(iii) requires some flight in abnormal and emergency procedures. So there must be at least one flight in the logbook. There must be evidence of ground awareness training too.

 

If I could not find evidence of this 'instructional level training' then I would not issue an authorisation, based on the CFI not meeting the requirements of 5(i) and 5(iv) 'appropriate training'.

 

This could be from any R22 authorised instructor, or indeed, a RHC instructor. I guess it could also be given by the examiner from which the authorisation is being sought!

 

As for the factory course, well a CFI candidate wishing to use a factory course as 'that' appropriate training, should work this out with RHC before attending, to ensure he gets this logged as such (i.e Awareness Training to meet the requirements of (5)(i)), and an RHC instructor's signature or certificate attesting to that. I guess this is why it is advisable to only attend the factory course much later, once you are ready to become a CFI. Then they can specifically make it an 'instructor' one, and you'll get more out of it for your money. In fact I believe that RHC instructors can actually sign off 5(iv) authorisations - the whole job lot. They just need to know that that's what you want.

 

I don't know how RHC handle this kind of request or how they differentiate their courses for 'experienced' or non-expereienced pilots. I have never been on the factory course! However, I do note that the application form does specifically ask the questions, "Are you working towards your CFI certificate" and, "If so, which helicopter do you intend to instruct in." Maybe this is how.

 

Does he need an endorsement for the (5)(i) requirement. No! He just needs some logged training.

 

OK, that's my take. Pretty complicated, but makes sense.

 

In fact, I checked through my logbook, and found 0.7hrs of 'SFAR Instructor Training' logged. I have a record of some ground training that day too. At that point I had 352 total hours and 62 R22 hours.

 

Scenario 2

 

Under Construction!

 

What fun! Ok - Usual disclaimer - I could be wrong!

 

Joker

Edited October 22, 2007 by joker

[wannabe heli pilot]

Joker, Fun it is! I'm curious though about the Robinson course as I've been told that a private or better was required to attend not just three hours. I'm guessing that means only three in the Robinsons included in the PPl certificate?

[joker]

Yep, Wannabe,

 

The minimums are PPL AND 3 hrs. So in theory you could go to the factory course the day of your PPL checkride (if you did the PPL in an R22).

 

Joker

 

http://robinsonheli.com/forms/application.pdf