Blogging the FARs: Fuel Requirements

A look at FAR Part 91.151 and real life.

FAR Part 91.151: Fuel requirements for flight in VFR conditions, sets up minimum fuel requirements for flight in VFR conditions. In other words, it’s telling you, the pilot in command, how much fuel must be on board to fly legally.

Here’s the language:

(a) No person may begin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed:€”

(1) During the day, to fly after that for at least 30 minutes; or

(2) At night, to fly after that for at least 45 minutes.

(b) No person may begin a flight in a rotorcraft under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 20 minutes.

What does this mean?

It’s actually pretty straightforward. It’s saying two things:

  • First, it assumes that when you do your flight plan for a flight, you should know how much fuel is required for that flight. For example, if you expect the flight to your first intended landing point (your destination) to take 30 minutes and you burn 12 gallons per hour, that means you’ll need 6 gallons to get to that destination (12÷60×30).
  • Second, it’s requiring that you load additional fuel as follows: If you’re flying an airplane during the day time, you’ll need an extra 30 minutes worth of fuel to be legal; in this example, another 6 gallons for a total of 12 gallons. An airplane at night would need 45 minutes worth of extra fuel; 9 gallons (12÷60×45) in this example for a total of 15 gallons. And a helicopter, which often has its own special rules, only needs an extra 20 minutes of fuel day or night; 4 gallons (12÷60×20) in this example for a total of 10 gallons.

The assumptions here are very important. You need to do a flight plan to know how much fuel it will take to get to your destination. A flight plan should take into consideration wind speed and other weather conditions — for example, conditions that may require rerouting around storms or low-visibility areas. This is related to FAR Part 91.103: Preflight Action, which states, in part:

Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include—

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, and any known traffic delays of which the pilot in command has been advised by ATC;

By flight plan, I mean a real flight plan. Normally, that involves calculations using a whiz-wheel or handheld aviation calculator or the ever-popular Duats online service (my personal favorite). Looking at a chart and guessing doesn’t count.

What Would a Prudent Pilot Do?

Although I don’t like the phrase “a prudent pilot” — primarily because it was used on me by an FAA person who seemed to suggest that I might not be prudent — it is something to consider here. Using the example above, if you had to complete the flight as planned, would you just take the fuel required by the FARs? In other words, 12 gallons for an airplane during the day, 15 gallons for an airplane at night, or 10 gallons for a helicopter during the day?

A prudent pilot wouldn’t if he/she could safely take more. The limitations would depend on max gross weight; performance at high elevations, high temperatures, or high weight; and weight and balance. Performing weight and balance calculations and checking performance charts is part of the responsibilities of every pilot in command before a flight — that’s part of FAR Part 91.103, too. Remember, you need to “become familiar with all available information concerning that flight.” [Emphasis added.]

Why would more fuel be better?

Do I really need to ask?

More fuel means more time in flight. For me, that could mean the difference between taking an in-flight detour to follow a stream or river that’s rarely flowing or flying the boring straight route from point A to point B. Or the difference between successfully navigating around a fast-moving thunderstorm or having to land in the middle of nowhere to wait it out. Or having to pay $4.90/gallon for fuel at my destination rather than $3.47/gallon at my home base.

According to the 2006 Nall Report, 10.5% of aviation accidents in 2005 were due to poor fuel management — pilots running out of fuel or forgetting to switch fuel tanks. This is sheer stupidity by the pilots — something I call “stupid pilot tricks.” By taking on more fuel than you need, you’ll be reducing the chance of becoming one of these stupid pilots. (You can still be another kind of stupid pilot, though.)

You’ll also have one less thing to worry about in flight.

And if that ain’t prudent, I don’t know what is.

How do you make a million dollars in aviation?

Start with two million dollars.

That isn’t my joke — it’s standard aviation humor. And if you think it isn’t true, start an aviation-based business.

Yesterday, against all odds, UPS actually delivered the auxiliary fuel pump I needed to get Zero-Mike-Lima up and running again. Yes, on Saturday. In Wickenburg.

The UPS guy was at our neighbor’s house, looking for ours when we spotted him. Mike gave a New York hail-a-cab style whistle and the driver saw us waving at him from our hillside. Moments later, he was on our driveway in front of the house.

“How many deliveries did you have to Wickenburg today?” I asked.

“Two,” he replied. “And you’re lucky it was me driving. I was out for four weeks. If the other Saturday driver can’t find a house, he just doesn’t deliver.”

Yes, I was lucky. I needed the part to replace the fuel pump that had gasped its final gasp on Friday, right at the end of a flight. Although the pump is redundant in flight (so there was no danger during the flight), I do need it to prime the engine at startup. I couldn’t fly without it. And I had three relatively lucrative gigs lined up between Sunday and Thursday.

The fuel pump cost $1,500. Add another $40 or $50 for overnight Saturday delivery by UPS. Then add the cost of the mechanic who graciously agreed to come in on Saturday — one of his usual days off — to install it. I told him to charge me extra. He said he would. Hell, it’s only fair. He could have said it would have to wait until Monday. Then I’d miss out on one (which turned into two) of my gigs.

Doing the Math

Unexpected repairs like this are only part of what makes operating an aviation business a lot more expensive than people think. How many times have I been at a rides gig where people asked how much fuel the helicopter burned? Every single one. I tell them it’s 16 to 18 gallons an hour and sometimes they ask how much fuel costs. I tell them $4 a gallon. They do some math in their head to come up with $64 per hour. Then they see us loading people on board for $30 a head, sometimes three at a time, and figure I can get 6 10-minute flights in per hour. That number comes out to $540/hour. Jeez! I must be making a fortune!

The truth of the matter is, fuel is among the least of my expenses.

What people always fail to consider is insurance (at about $11,500 per year); regular maintenance like oil changes ($120 each), 100-hour inspections ($2,000 each), annual inspections ($2,000 each); and the cost of the oh-so-important overhaul due at 2,200 hours that costs (currently) a whopping $182,000. (Do the math on that: $182,000 ÷ 2200 = $83/hour.)

And then there are things like this fuel pump. The original pump lasted only 416 hours. If the final cost of replacement is $1,700 (with all labor and expenses), that works out to another $4/hour. Add that to the cost of replacing my primary radio, which is currently in the shop and may be declared dead: $2,100 for a used one plus several hundred for troubleshooting the old one and swapping them out. And the cost of that clutch down-limit switch that had to be replaced 200 hours ago: the $8 part with $800 labor. And, oh yeah, let’s not forget $120 just to make sure my transponder is working right — that’s something I’ll be paying for every two calendar years.

How about the support stuff that doesn’t go on my helicopter? Like the $1,200 tow bar and the $600 golf cart (used, thank heaven) to pull it? And monthly rent for the hangar to keep it safe and dry and out of the sun? And the charts and other FAA publications I’m required to keep up to date, including sectionals (twice a year per chart), terminal area charts (twice a year per chart), airport/facilities directories (every 56 days), and the FAR/AIM (once a year)? Or how about my annual medical exam, which is required just to keep my license? Or credit card fees just so I can accept credit cards for payment?

And how about marketing? The $1,600 I just spent on 4-color, tri-fold brochures and the $459/month I spend during the high season to get them in brochure racks throughout the Phoenix area? And the cost of the trade show I’ll be attending later this month to sell my multi-day excursions to folks looking for a different kind of vacation?

And how about the cost of my ground crew on those outdoor ride gigs and the cost of permits and commissions just so I can do them? And the cost for operating the helicopter just to get to and from the gig — sometimes more than an hour each way? And the cost of the table and chairs and shade structure and signs that we use on those gigs? And those orange cones and all that yellow Caution tape? And overnight lodging and meals for me and the ground crew on distant, multi-day gigs?

Don’t get me wrong. I’m not complaining. I knew I was in for it when I launched this business.

But it does explain why I have to charge $450/hour for flight time. I’m not pocketing nearly $400 in profits as most people may think. I’m barely covering my costs.

Paying for It

Today is Sunday and Zero-Mike-Lima is sitting snug in its hangar, all ready to fly. I picked up a second tour today, one of my Ghost Towns & Mines air tours. Right after that, I’m doing my first ever Swansea Town site day trip. On Tuesday, I’m taking a winter visitor to Scottsdale for some upscale shopping. And on Thursday, I’m taking some folks to Sky Harbor so they can catch a flight to Canada. The total revenue for these four flights is estimated at $1,895. That’s revenue, not net income.

Just enough to cover the cash outlay for that fuel pump and labor.

Would I give it all up? Hell, no! But I do hope the new fuel pump lasts longer than 416 hours.

In-Flight “Emergency”…

…on a check ride.

There’s no better way to test a pilot on his or her knowledge of emergency procedures than to simulate an in-flight unusual situation. I hesitate to use the word emergency here, because what most check pilots simulate is not really a full emergency. It’s more of a situation that requires the pilot’s attention, knowledge of procedures, judgement, and action.

Real Throttle Chops are a Thing of the Past

Gone (or almost gone) are the days when helicopter flight instructors or examiners did “throttle chops.” A throttle chop is a simulated engine failure in which the instructor or examiner twists the throttle to idle suddenly during flight. The engine and rotor RPM needles split and the rotor RPM needle immediately starts to drop. The student or pilot in command is required to immediately enter an autorotation. The experts estimate that the pilot has about two seconds to react properly. Failure to react could lead to unrecoverable low rotor RPM, which is a very bad thing.

Flight instructors and examiners pretty much stopped doing real throttle chops — the kind with absolutely no warning to the student — when helicopters started crashing. It seemed that in some cases, the student pilot or pilot in command wouldn’t react fast enough and the instructor or examiner didn’t either. Or, in some rare cases, the sudden reduction in power caused the engine to hiccup and really fail. Now most instructors usually warn the student in advance. Some slowly reduce the throttle, which leads to an audible change in engine sound that warns the student — not to mention that he or she can usually feel the adjustment in his or her collective hand. Others do a throttle chop and enter the autorotation at the same time, not even giving the student a chance to react.

Robinson Helicopter issued several safety notices recommending against throttle chops (see SN-27 and SN-38). The company even amended its Pilot Operating Handbook so practice autorotations would be done with just a tiny needle split rather than a full throttle-to-idle setting. (Not a very good simulation of an engine failure, if you ask me.)

So What’s an Instructor/Examiner to Do?

One of the instructor/examiners I’ve worked with in the past was extremely fond of failing instruments or illuminating warning lights. This particular instructor, who works for Robinson Helicopter, has a whole collection of circuit breaker tricks that he uses on unsuspecting students. He’ll pull an engine tach circuit breaker so the engine tachometer drops to 0 during flight. No lights, just that dead gauge. He does it to see how long before the pilot notices and whether the pilot knows what do do about it. He’ll do the same for other gauges that are important but not vital to safe flight.

I took my commercial check ride with this particular instructor/examiner and he made me do a run-on landing with “failed” engine tachometer, rotor tachometer, and governor (switch the governor off to simulate). The trick was to make very small collective inputs and hope the mechanical correlator would keep the RPM within range; listening to the sound of the engine helped a tiny bit. But I still managed to make that low rotor RPM horn go off as we approached the runway surface. Evidently, I exercised enough finesse, because although he was disappointed that the horn had come on, he didn’t fail me for it. Personally, I like to see him do it perfectly.

(A side note here. What real-life situation would require you to land with all that stuff inoperable? The only thing I can think of is a complete electrical failure. But even then, I think there’s some trick in the Robinson wiring scheme that keeps the tachs alive. Just can’t remember what it might be right now. Guess I need to look it up.)

My Recent Mechanical Failure

I’ve taken 6 check rides since I started flying about 8 years ago: 1 private, 1 commercial, and 4 Part 135s. There’s usually some kind of simulated failure during a flight. So when the Aux Fuel light came on during my most recent check ride on Thursday, my first inclination was to ask the examiner, “Did you do that?”

“What?”

We were doing an instrument approach at Williams Gateway Airport and I think he was paying more attention to my altimeter (I was supposed to be at 1880 feet) than anything else.

“That light,” I replied.

He saw the light. “No,” he said.

I didn’t believe him and asked him again. He repeated that he wasn’t responsible.

“Is the circuit breaker out?” I asked.

He looked down at the bank of circuit breakers at the base of his seat. “Yes.”

“Okay, it’s not a big deal,” I said. “It’s the auxiliary fuel pump. It’s a redundant system and we don’t need it for flight. The book says land as soon as practical. Do you want to push the circuit breaker back in?”

“No.”

(For the record, I would have.)

“Well, how about if we land here and have Kelly look at it?” I suggested. Kelly is my helicopter mechanic. By some unbelievable stroke of luck, we were landing at the airport where he was based and it wasn’t 5 PM yet.

He agreed that would be a good idea and talked to the tower for me. He then directed me to parking. I set it down in one of the helicopter parking spaces that Silver State uses. He pushed the circuit breaker back in. It popped back out. He got out to track down Kelly while I cooled down the engine and shut down.

Long story short: Kelly pulled off the side panel and found that one of the bolts on top of the fuel pump was loose. He removed the pump, bench tested it, tightened up the bolts, wrote up a logbook entry on a sticker for me, and sent us on our way. The whole process took a little more than an hour. The pump sounded much better when I primed the engine for startup and the light didn’t come on again as we did some more maneuvers at Williams Gateway and flew back to Scottsdale.

I passed the check ride. I like to think that the failed fuel pump helped me. It showed that I knew enough about the procedure to stay calm and make the right decision about it. In a way, it was a real-life “emergency” during the flight. Again, I don’t like to use the word emergency because there was never really any danger — unless, of course, the engine-driven fuel pump went bad, too. Then we’d have a problem.

Postscript

I flew back from Scottsdale with no further fuel pump problems.

The next day, I did a 50-minute scenic flight with two passengers on board. We were about 45 minutes into the flight — less than 5 miles from the airport — when the darn light came back on. I finished the tour — which was basically on the way to the airport anyway — and landed. When I pushed in the circuit breaker, it popped right out again.

When my passengers were on their way, I visited Ed, my local mechanic. I asked him to take a look at the pump when he had a chance, then put the helicopter away in my hangar, which is just down the row from his. He called with the bad news a while later. The pump was seized. I’d have to get a new one. I called the factory at 2:30 PM (their time) and managed to get it on a UPS truck for overnight (Saturday) delivery to Wickenburg. With luck, it’ll arrive as planned (Saturday deliver is a very iffy thing in Wickenburg) and Ed will put it in. I’ll be flying again on Sunday.

Unfortunately, it’ll take the flights I have scheduled on Sunday, Tuesday, and Thursday just to pay for the new pump.

Blogging the FARs: ATC Light Signals

For the first time, it might be something I need to know.

One of the nice things about my helicopter is that it has two com radios: a standard Bendix King KY196A and the radio that’s part of my Garmin 420 GPS.

My Radio Setup

Bendix King KY196AThe Bendix King is my primary radio and it’s wired into some controls on the cyclic stick. This is a neat feature that’s standard on Robinson helicopters. I can program 9 frequencies into the radio and cycle through them all without reaching down for the radio knobs or buttons. Once I get the frequency I want on standby, I simply push a second button on the cyclic to make that frequency active. I’ve got it programmed for all the CTAF (common traffic advisory frequencies), towers, and ATIS (automatic terminal information service) recordings of the airports I visit most: Wickenburg, Prescott, Deer Valley, etc.

Garmin 420The Garmin is primarily a GPS and I very seldom use the radio. It has the ability to automatically transfer the radio frequency for the current waypoint or selected airport to the standby slot, but when I’m flying, I don’t usually mess around too much with the GPS controls beyond simple Go To and Nearest functions. I prefer having a list of frequencies I need for a flight handy and manually tuning them in. A few times, I used the GPS to look up or check a frequency, but that was usually a practice exercise to make me more proficient with the GPS’s airport directory feature. I subscribe to the data card updates and usually have current (or at least recent) data in there, so it’s pretty reliable. It’s also a lot easier than fumbling with a chart while I’m flying. (One of the drawbacks of flying a helicopter is that you only have one hand to work with while you’re flying; your right hand is pretty much glued to the cyclic.) Another cool thing about the Garmin is that when paired with a Garmin GTX 330 transponder and flying within range of Class B airspace, it can graphically display traffic, as I wrote about here.

A nice thing about having two radios is that I can monitor two frequencies at once. This is especially handy if I want to fly between, say Deer Valley and Scottsdale — a distance of about 9 miles — and want to listen to the Scottsdale ATIS while monitoring the Deer Valley tower for instructions or traffic information. In fact, I’m starting to get into the habit of using the GPS’s radio to monitor ATIS and the Bendix King for two-way communications.

Two Radios are Better than One

Of course, the best thing about having two radios is that if one of them fails, there’s another one there to use. And just recently, having two radios became a very good thing.

On a recent flight, while talking to an airport tower’s controller, I heard static in my headset about halfway through my transmission. Turns out, when the transmission turned to static, it also became garbled on the controller’s end. He couldn’t understand what I was saying. But I could hear him and everyone else just fine.

I immediately tuned in the proper frequency on the Garmin, flicked the right switches to talk on that radio, and retransmitted. No problem. So it wasn’t my push-to-talk switch. It was something in the radio.

I had the radio looked at the same day. Of course, the mechanic could not duplicate the problem. And neither could I on my way home.

Don’t you hate when that happens?

Well, the problem has reared its ugly head several times since then. I’ve had another mechanic and an avionics shop look at it. The mechanic couldn’t duplicate the problem. The avionics shop pulled the radio out for a bench test and could find nothing wrong with it. But they did find a mysterious nut (as in hardware) in the mounting bracket. Once removed, the radio appeared to seat better in the console. We thought the problem would go away. But it didn’t.

So I’m left with a radio that receives perfectly and transmits perfectly about 75% of the time along with a second radio that works fine. I’ve taken to talking on the Garmin and listening to ATIS on the Bendix King.

Unfortunately, no one seems to have a spare KY196A for me to swap temporarily with mine. Putting another radio in there and flying with it for a bit would help me confirm that the problem is the radio and not some kind of helicopter wiring problem. You see, if I put in a different radio and the problem goes away, the problem is definitely my radio. But if the problem persists with a different radio in there, the problem is in the helicopter’s wiring or something related. I tracked down a refurbished KY196A, which I can get for a whopping $2,100. The folks there have promised to take it back if the problem turns out to be in the helicopter rather than the radio. So I’ll be ordering it on Monday.

What All This Has to Do with Light Signals

As usual, I’ve turned a short topic into a long story. But it does explain why light signals are on my mind.

If my second radio also decides to stop transmitting reliably, I may be unable to communicate with a tower. That would not be a good thing if I wanted to land at a towered airport.

The AIM (Aeronautical Information Manual) has a procedure for this. (You can find it in Chapter 6, Section 4-2.) The first thing a pilot who has lost communication capabilities should do is turn his/her transponder to 7600. That sends out a signal that says, “Hey, I’m over here and my radio isn’t working.” If you’re lucky, the tower you’re trying to land out has radar capabilities and can “see” you and this signal. The tower will attempt communication and will react according the results.

In my case, I can hear the tower perfectly fine. I can even transmit a little. So the controller would probably work with that and communications would continue, although rather one-sidedly, with me getting instructions and either clicking my push to talk button or speaking briefly to acknowledge.

But if I couldn’t hear a thing — or couldn’t get the controller to understand that I could hear — the controller would take out the light signal gun and point it at me. And that’s when I’d need to know what the signals meant.

I saw one of these light signal guns close up once, on a visit to Chandler tower. It’s a handheld device that they had attached to the ceiling inside the tower. It can display/flash three different colors of light: red, green, and white. The controller points it at an aircraft having communications problems and either shines a steady light or flashes a light. The pilot is supposed to understand what the signals mean.

So what do they mean?

FAR 91.125: ATC light signals includes this useful table:

Color and type of signalMeaning with respect to aircraft on the surfaceMeaning with respect to aircraft in flight
Steady greenCleared for takeoffCleared to land.
Flashing greenCleared to taxiReturn for landing (to be followed by steady green at proper time).
Steady redStopGive way to other aircraft and continue circling.
Flashing redTaxi clear of runway in useAirport unsafe—do not land.
Flashing whiteReturn to starting point on airportNot applicable.
Alternating red and greenExercise extreme cautionExercise extreme caution.

How This Might Appear on a Check Ride

Testing you on your knowledge of this is pretty straightforward for an FAA Examiner. He’ll simply say something like “You discover that your radio doesn’t work as you approach Class Delta airspace. What do you do?”

You reply that you tune your transponder to 7600 and circle outside the airspace until you see a light signal from the tower.

The examiner then says, “Okay, so you see the tower flashing a green light at you. What do you do?”

You explain that the signal means you should “return for landing” or enter the normal traffic pattern.

“You’re cleared to land?” the sly FAA examiner asks innocently.

“No. You need to wait for a steady green before you can land,” you reply, indicating full understanding of FAR 91.125.

To really prepare for this question on a test — and for it happening in real life — it’s a good idea to review the AIM Chapter 4, Section 3-13: Traffic Control Light Signals. Chapter 4, sections 2 and 3 provide additional information for working with Air Traffic Control at an airport. And, if you’re flying IFR (which I don’t), check out Chapter 6, Section 4: Two Way Radio Communications Failure.

Of course, all this might be led up with you explaining what’s required to enter Class D airspace in the first place. But that’s another FAR to explore.

One More Thing

I just remembered that I had a “voluntary radio failure” a while back when returning to non-Towered Wickenburg Airport (E25) from an off-airport location three years ago. If you’re interested, you can read about it here.

Blogging the FARs: Pilot in Command

A definition from FAR Part 1.1.

According the FAR Part 1.1: General Definitions:

Pilot in command means the person who:

(1) Has final authority and responsibility for the operation and safety of the flight;

(2) Has been designated as pilot in command before or during the flight; and

(3) Holds the appropriate category, class, and type rating, if appropriate, for the conduct of the flight.

How this Might Appear on Your Oral Exam

This seems like pretty simple stuff, but it always appears in an oral exam in one way or another. The examiner won’t ask for the definition. Instead, he’ll ask a question that refers to the definition, something like: “Who has final authority over the aircraft?” or, more slyly, “If the tower tells you, the pilot in command, something to do and you think it’s dangerous, should you do it?” The answers to those questions are the pilot in command (that’s you, if you’re taking the check ride) and no, respectively.

FAA examiners are very sly people. If they sense any doubt in your mind, they’ll push harder to get you to give them the wrong answer. The next question might be, “Are you sure? The tower is telling you to do it. Don’t they have authority?”

Don’t fall for this! Remember that when you’re pilot in command, you are the boss of the aircraft. But you also need to remember that if you don’t follow an ATC instruction, you better have a damn good reason why you didn’t and that reason better be somehow related to safety.

This is also covered in Part 91.3: Responsibility and authority of the pilot in command:

(a) The pilot in command of an aircraft is directly responsible for, and is the final authority as to, the operation of that aircraft.

(b) In an in-flight emergency requiring immediate action, the pilot in command may deviate from any rule of this part to the extent required to meet that emergency.

(c) Each pilot in command who deviates from a rule under paragraph (b) of this section shall, upon the request of the Administrator, send a written report of that deviation to the Administrator.

Stating the Obvious

The Part 1 definition also suggests that you can’t be a pilot-in-command until you qualify for it. For example, an airplane pilot can’t be a pilot in command of a helicopter until he/she gets a helicopter rating. And, oddly enough, a 5000-hour helicopter pilot who has been flying all kinds of helicopters but has never had any training in a Robinson R44 could not be a pilot in command of that helicopter. Why? Because there are additional regulations (specifically, SFAR 73) covering that make and model of helicopter.

The best thing to do before flying a different aircraft is to make sure you you have the rating(s) you need to fly it. When in doubt, ask a flight instructor, the company you may be renting from, or the FAA. My advice is to always fly with a flight instructor for at least 30 minutes in any different kind aircraft you’re flying for the first time. And make sure he/she signs off in your logbook before you go solo, just in case there is a problem. You (or your next of kin) want to be able to prove that you had some training in this lawsuit-happy country we live in.

Other Stuff to Check and Remember

And don’t forget the other Part 61 rules which also apply here, including qualifications, currency, etc. And the Part 67 medical requirements.

(To me, that’s the biggest problem with the FARs; they require you to look in a half dozen places just to get the answer to a question.)

By the way, the responsibilities of the pilot in command are also covered in the AIM Chapter 5, Section 5-5-1b.