SFAR 73

[Jeff]

SFAR 73 expired 3/31/08. Does anyone know if it has been officially renewed, or has it been left to expire?

 

~Jeff

[Gerhardt]

I called the Kansas City FSDO who said that SFAR 73-1 runs through May 31, 2008.

 

I haven't read all of 73-1 but a quick reading looks to be the same as SFAR 73. I'm going to take a closer look now.

[Gerhardt]

I could be wrong, but methinks that SFAR 73 = SFAR 73-1. Just extended the expiration date two months.

[Jeff]

As far as I can tell, SFAR 73-1 did extend the expiration date of SFAR 73 to March 31, 2008, not May 31, 2008. I was not able to find any NPRM's that would extend the SFAR beyond yesterday. Of course, that doesn't mean that there aren't any; just that I didn't find them.

 

Any more info would be appreciated.

 

~Jeff

[C of G]

Renewed. But only for (approx) a year this time. Until June 30, 2009

 

http://www.faa.gov/regulations_policies/ru...ia/Robinson.pdf

[NorCalHeliKid]

June 2009! Hopefully that means Frankie is going to stop making the R-22 and get rid of the SFAR

[Pogue]

June 2009! Hopefully that means Frankie is going to stop making the R-22 and get rid of the SFAR

Why would the R22 going out of production - whenever that happens - have anything to do with SFAR 73 going away? There would still be several thousand R22's used in training...

[Goldy]

Renewed. But only for (approx) a year this time. Until June 30, 2009

 

http://www.faa.gov/regulations_policies/ru...ia/Robinson.pdf

 

CofG- Thanks for the link, I've been expecting this, I just didnt see any reason why the FAA would wait until the last possible second.

 

I love that the Administrative Procedures Act requires 30 days notice of rulemaking, and in this case, I guess 3 years notice that the SFAR was expiring just wasnt enough time, so they had to do it as an emergency action to exclude this....I love the FEDS !

 

Goldy

[relyon]

I noticed several items in the latest SFAR 73 rulemaking docket I think are worth noting:

• "A recent analysis of approximately 100 R-22 accidents that occurred between 2005 and 2008 indicated that none of them involved mast bumping, low rotor RPM (blade stall) or low "G" hazards. Because the training required by this SFAR addressed these hazards, the FAA believes that the training has been effective."
  
• "... this final rule will not have a significant economic impact on small entities."
  
• "Ordinarily under the Administrative Procedure Act, a substantive rule must be published not less than 30 days before its effective date except, among other things, if the agency finds "good cause" for making it effective sooner. ... For these reasons, and because this SFAR does not impose an additional burden on any person, the FAA finds good cause for making this amendment, which extends the duration of SFAR 73, effective March 31, 2008."
  
• The document is signed by Acting FAA Administrator Robert A. Sturgell on March 28, 2008.
  

With those and more in mind I've come to a few conclusions. First, as the docket indicates there are no addtional costs incurred at this time by continuing the SFAR. Second, there has been a significant reduction in accidents related to the hazards mentioned. Third, SFAR 73 has most definitely raised awareness regarding the very real dangers of two bladed semirigid rotor systems in all helicopters world wide. Finally, this all revolves around flight safety which takes into account the passenger and those on the ground that are affected by but have no knowledge of or control over what a given aircraft or pilot does (R-22/R-44 helicopters in this case specifically).

 

I support SFAR 73's continuance in light of the number of both the number of R-22 and R-44 helicopters in service and it's continuing popularity as a training helicopter. Like many before and since, I did my all my primary training, much of the advanced training, and a considerable amount of instruction myself in Robinson helicopters. I seriously doubt the SFAR delayed my progress in any way. I don't see any reason why it's renewal coming at the last moment comes as a shock to anyone and similarly don't think it makes a bit of difference.

 

Before anyone takes the time to point out that Frank Robinson himself states that he never intended the R-22 to be used as a trainer, I'll note that any small, low cost helicopter is going to be used as a trainer whether than was it's intended use or not. If he truly didn't want it used that way he could have made purchasers sign a binding use agreement like the R-44 or prohibited it's use in the POH/RFM. I'll guess that would have severely limited it's marketability.

 

Bob

 

PS - On a totally different note, I suggest folks read Mr. Sturgell's bio: http://www.faa.gov/about/key_officials/sturgell/. Very impressive.

[cruise475]

June 2009! Hopefully that means Frankie is going to stop making the R-22 and get rid of the SFAR

 

I was just at the Factory Course and they made no indication that they had any plans to discontinue the R-22. As a matter of fact, they said that they were already sold out through 2009. (If it is true or not, who knows)

 

Frank also came in and said that they want to keep the SFAR for the R22 only, and that they are working on trying to get the FAA to take the R44 out of it. He said the reason is that the R44 is used by differant people for a other purposes. (mostly)

 

Again, take it for what it is worth.

[Goldy]

I was just at the Factory Course and they made no indication that they had any plans to discontinue the R-22. As a matter of fact, they said that they were already sold out through 2009. (If it is true or not, who knows)

 

Cruise- then you got a chance to walk the manufacturing floor....Frank didn't happen to mention WHERE he was going to build the R66 did he ?

[cruise475]

Cruise- then you got a chance to walk the manufacturing floor....Frank didn't happen to mention WHERE he was going to build the R66 did he ?

 

We did not get to walk the factory until after Frank spoke with us. However we did ask where they were planning on assembling the R66, and the guy who was walking us through told us he did not know.

[Goldy]

we did ask where they were planning on assembling the R66, and the guy who was walking us through told us he did not know.

 

Just look left at the old R22 line.....my humble opinion of course. Did Frank tell you why the R22 tail rotor was the length that it is ? (old Robbie history).

 

Sounds like you had a good time, it is a great couple days of learning...

 

Goldy

[NorCalHeliKid]

We did not get to walk the factory until after Frank spoke with us. However we did ask where they were planning on assembling the R66, and the guy who was walking us through told us he did not know.

 

There is a closed off room at the factory with a security door. Our tour leader told us that they were building the R-66 in that area. Honestly, who really cares.

[dowd]

why does sfar 73 have a expiration date ?

[caross]

Since SFAR73 is a special safety training section for Robinson (R22/R44) helicopters, I would theorize that that it is set up with an expiration date to force prompt and accurate updates. This way, there is a required review cycle and it does not allow the information to get stale.

 

Since there are so many students starting out on the R22 - and they are, by definition, most susceptible to making errors AND the fact that the helicopter's dynamics are different and a bit tricky make it most up for scrutiny.

 

Sooo...all eyes on Robinson... and one of the better ways to keep concern down is being very public about your safety training and your focus on keeping things up to date and accurate.

 

 

 

why does sfar 73 have a expiration date ?

[PMP Student]

Renewed. But only for (approx) a year this time. Until June 30, 2009

 

http://www.faa.gov/regulations_policies/ru...ia/Robinson.pdf

 

I just read this (skimmed it, actually) and it's clear that the reason for the extension to June 2009 is to allow enough time to do the paperwork to make SFAR 73 permanent. I take that to mean that the new SFAR 73 after June 2009 will no longer have a date of expiration or renewal.

 

I'm in the process of getting my private license on an R22. As an engineer in real life, I think a lot about worst-case scenarios. I can respect the improved accident stats, and agree with relyon that it is a good idea to keep this SFAR.

 

Marty

[Goldy]

I just read this (skimmed it, actually) and it's clear that the reason for the extension to June 2009 is to allow enough time to do the paperwork to make SFAR 73 permanent.

Marty

 

Marty- I dont think they want it permanent. It has been a "temporary" rule now for many many years. I think it has a lot to do with implementing a permanent rule against one manufacturer being a bit biased..

 

Goldy

[PMP Student]

Marty- I dont think they want it permanent. It has been a "temporary" rule now for many many years. I think it has a lot to do with implementing a permanent rule against one manufacturer being a bit biased..

 

Goldy

 

Goldy,

 

I only mentioned 'permanent' because it was mentioned in the Robinson.pdf document. Here is the reference (a little shortened) from page 10:

 

The reasons that justified the original issuance of SFAR 73 and the subsequent extensions of the

termination date of SFAR 73 still exist. … The FAA finds that the continuation of SFAR 73 for an

additional 15 months is necessary to keep in effect safety critical training and experience

requirements that are beneficial to those operating Robinson helicopters while the FAA completes

rulemaking in which it plans to make the SFAR permanent.

 

I agree it does seem biased against one manufacturer so there might be resistance to making it permanent.

 

Marty

[Goldy]

while the FAA completes

rulemaking in which it plans to make the SFAR permanent.

Marty

 

Marty- I had not read that, I stand corrected. Looks like perm status is around the corner. I think everyone is in the groove of compliance anyway...my personal standard is a check ride every 6 months in the 22..gotta keep that left arm ready to drop !

 

Goldy