Why Are We Still Powering Down All Electronic Devices on Airliners?

There’s no real reason for it.

A Twitter/Google+ friend of mine, Chris, linked to an article on the New York Times website today, “Fliers Still Must Turn Off Devices, but It’s Not Clear Why.” His comment on Google+ pretty much echoed my sentiments:

I do all my book reading on an iPad, and it’s annoying that I can’t read during the beginning and end of a flight, likely for no legitimate reason.

This blog post takes a logical look at the practice and the regulations behind it.

What the FAA Says

In most instances, when an airline flight crew tells you to turn off portable electronic devices — usually on takeoff and landing — they make a reference to FAA regulations. But exactly what are the regulations?

Fortunately, we can read them for ourselves. Indeed, the Times article links to the actual Federal Aviation Regulations (FAR) governing portable electronic devices on aircraft, 121.306. Here it is in its entirety:

121.306 Portable electronic devices.

(a) Except as provided in paragraph (b) of this section, no person may operate, nor may any operator or pilot in command of an aircraft allow the operation of, any portable electronic device on any U.S.-registered civil aircraft operating under this part.

(b) Paragraph (a) of this section does not apply to—

(1) Portable voice recorders;

(2) Hearing aids;

(3) Heart pacemakers;

(4) Electric shavers; or

(5) Any other portable electronic device that the part 119 certificate holder has determined will not cause interference with the navigation or communication system of the aircraft on which it is to be used.

(c) The determination required by paragraph (b)(5) of this section shall be made by that part 119 certificate holder operating the particular device to be used.

So what this is saying is that you can’t operate any portable electronic device that the aircraft operator — the airline, in this case — says you can’t. (Read carefully; a is the rule and b is the loophole.) You can, however, always operate portable voice recorders, hearing aids, heart pacemakers (good thing!), and electric shavers (?).

So is the FAA saying you can’t operate an iPad (or any other electronic device) on a flight? No. It’s the airline that says you can’t.

Interference with Navigation or Communication Systems

In reading this carefully, you might assume that the airline has determined that devices such as an iPad may cause interference with navigation or communication systems. After all, that’s the only reason the FAA offers them the authority to require these devices to be powered down.

But as the Times piece points out, a 2006 study by the Radio Technical Commission for Aeronautics found no evidence that these devices can or can’t interfere. Sounds to me like someone was avoiding responsibility for making a decision.

In the meantime, many portable electronic devices, including iPads, Kindles, and smart phones have “airplane mode” settings that prevent them from sending or receiving radio signals. If this is truly the case, it should be impossible for these devices to interfere with navigation or communication systems when in airplane mode. And if all you want to do with your device is read a downloaded book or play with an app that doesn’t require Internet access, there should be no reason why you couldn’t do so.

And can someone really make the argument that an electronic device in airplane mode emits more radio interference than a pacemaker or electric shaver?

And what about the airlines that now offer wi-fi connectivity during the flight? You can’t have your device in airplane mode to take advantage of that service. Surely that says something about the possibility of radio interference: there is none. Evidently, if you’re paying the airline to use their wi-fi, it’s okay.

What’s So Special about Takeoff and Landing?

Of course, since you are allowed to use these devices during the cruise portion of the flight, that begs the question: What’s so special about takeoff and landing?

As a pilot, I can assure you that the pilot’s workload is heavier during the takeoff and landing portions of the flight. There’s more precise flying involved as well as more communication with air traffic control (ATC) and a greater need to watch out for and avoid other aircraft.

But in an airliner, the pilots are locked in the cockpit up front, with very little possibility of distractions from the plane full of seat-belted passengers behind them — even if some of them are busy reading the latest suspense thriller or playing an intense game of Angry Birds.

Are the aircraft’s electronics working harder? I don’t think so.

Are they more susceptible to interference? I can’t see how they could be.

So unless I’m wrong on any of these points, I can’t see why the airlines claim that, for safety reasons, these devices need to be powered off during takeoff and landing.

It’s a Control Issue

I have my own theory on why airlines force you to power down your devices during takeoff and landing: They don’t want their flight attendants competing with electronic devices for your attention.

By telling you to stow all this stuff, there’s less of a chance of you missing an important announcement or instruction. Theoretically, if the aircraft encountered a problem and they needed to instruct passengers on what they should do, they might find it easier to get and keep your attention if you weren’t reading an ebook or listening to your iPod or playing Angry Birds. Theoretically. But there are two arguments against this, too:

  • You can get just as absorbed in a printed book (or maybe even that damn SkyMall catalog) as you could in an ebook.
  • If something were amiss, the actual flight/landing conditions and/or other screaming/praying/seatback-jumping passengers would likely get your attention.

But let’s face it: airlines want to boss you around. They want to make sure you follow their rules. So they play the “safety” card. They tell you their policies are for your safety. And they they throw around phrases like “FAA Regulations” to make it all seem like they’re just following someone else’s rules. But as we’ve seen, they have the authority to make the rule, so it all comes back to them.

And that’s the way they like it.

How Cell Phones Fit Into This Discussion

Cell phone use is a completely different issue. In the U.S., it isn’t the FAA that prohibits cell phone use on airborne aircraft — it’s the FCC. You can find the complete rule on that in FCC regulation 22.925, which states (in part):

22.925   Prohibition on airborne operation of cellular telephones.

Cellular telephones installed in or carried aboard airplanes, balloons or any other type of aircraft must not be operated while such aircraft are airborne (not touching the ground). When any aircraft leaves the ground, all cellular telephones on board that aircraft must be turned off.

There are reasons for this, but an analysis of whether or not they’re valid is beyond the scope of this discussion.

I just want to be able to read books on my iPad from the moment I settle into my airliner seat to the moment I leave it.

Three Tips for Becoming a Better, Safer Pilot

My take on some advice offered by the FAASTeam.

The Deer Valley Pilot’s Association (DVPA) held its annual membership drive at Deer Valley Airport (DVT) in Phoenix yesterday. I’d joined the group earlier this month, when I discovered that membership entitled me to a $1.10/gallon discount on 100LL fuel at my preferred FBO there, Atlantic Aviation. One top-off was enough savings to pay the cost of a year’s membership.

DVPA EventI was so appreciative that when I heard about the event and the fact that a few aircraft would be on static display, I offered to put my helicopter on display. So yesterday morning, at 8:15 AM, I parked on the ramp in front of the terminal building to give attendees just one more aircraft to look at. I even hung out for a while and let kids climb into my seat.

FAA LogoThere were other organizations on hand, with tables set up under a big shade. The FAA’s Safety Team, which sponsors the WINGS pilot proficiency program, was one of them. They had a table full of informational flyers. Because of my general interest in helicopter accidents — which, by the way, I’m starting to think isn’t exactly healthy — I picked up a flyer titled “Helicopter Training Accidents.” Later, back home, I gave it a quick read.

The pamphlet focused on two areas of training accidents: autorotation and dynamic rollover. It provided a lot of bullet points under headings like “Autorotation — Common Errors” and “Dynamic Rollover Precautions.” It was pretty basic stuff, but good to read just to refresh my memory. I wish I could link to it here for reference, but I simply can’t find it online. I’ve scanned it; you can download it here. And believe me, there’s lots of online reference material available at their Web site.

But the most useful content — especially for new pilots or pilots falling into the complacency trap that can catch you at any experience level — were the bullet points under “Cockpit Resource Management and Personal Readiness.” Three of these points jumped out at me as great topics for discussion in a blog post. Here they are.

Oh, and although I’m a helicopter pilot and use helicopter examples here, most of this applies to airplanes, too.

Know your limits and observe them.

I think that this is one of the biggest causes of accidents — although I’d expand it to read “Know your limits and the limits of your aircraft and observe them.” Many of the accidents I’ve discussed in this blog can be categorized as what I call ‘stupid pilot tricks.” In so many cases, pilots overestimate their own skills or the capabilities of their aircraft either in general or under conditions they’re not accustomed to.

So how do you discover what your limits are? The best way is by experience. If you’ve successfully performed a maneuver consistently over time, that maneuver is probably within your limits — in the conditions in which you’re have successfully performed it. But whenever conditions differ, you need to proceed carefully to test your limits. For example, perhaps you’ve landed quite a few times off-airport on dirt and gravel in light wind conditions. But now you need to land on terrain littered with big rocks. Don’t assume that it’s just as easy as any other off-airport landing. Consider the risks and proceed carefully. Leave yourself an out. Don’t commit to setting down unless you know you can do it safely and then take off again later. The same goes for making an off-airport landing in a strong crosswind or tailwind situation. Or in dusty or snowy conditions. Have you done it successfully before? Multiple times? Consistently? Then it’s probably within your limits. But if the situation is brand new to you, you can’t possibly know for sure whether it’s within your limitations. Proceed with caution!

Advanced training can also help. If you find yourself with a need to perform maneuvers that you’re not sure about, find an experienced CFI and go flying with him. Let him train you, let him give you the additional support you might need to practice it safely. Isn’t it worth a few hundred dollars to get the experience you need to safely expand your personal limits?

As for the limits of your aircraft, that’s pretty easy. Open the Pilot Operating Handbook and look them up. If you fly the same kind of aircraft often, you should have most of the limitations memorized, including a rough estimate of out of ground effect hover capabilities at various weights and density altitudes. And if you find yourself in a situation where you’re not sure if an operation is even possible for your aircraft, reach for that book and look it up to make sure. It’s required to be on the aircraft, so there’s no excuse not to consult it. I’m not ashamed to admit that I’ve done this several times. I even keep a copy of the book in my office to make sure I can handle unusual client requests before booking a flight.

Develop and use good habits (e.g., checklists).

The FAA loves checklists and I’ve been told by a few pilots that they won’t let you pass a check ride unless you use available check lists during the flight. While I agree that checklists are extremely helpful — I actually created my own for preflight, startup, and shutdown when I flew LongRangers at the Grand Canyon back in 2004 — I also feel that if you perform the same series of tasks in the same order without distraction more than 50 or 100 times, a checklist becomes a bit redundant. So if you’re expecting me to wax-poetic about checklists, I’m sorry to disappoint you.

What I will expound on, however, is the idea of developing good habits for all phases of flight. Here are a few examples from my own flying:

  • Always perform a preflight inspection in the same order.
  • When adding oil during preflight, always leave the cowl door open until the oil cap/dipstick is replaced. Do not close that cowl door unless the cap/dipstick is confirmed present and tight.
  • Just before stepping into the aircraft, always do a complete walk-around starting and ending at the pilot door. Use that walk-around to check for open cowling doors and fuel cap tightness one more time.
  • Always perform all parts of the startup procedure, from sitting in the pilot’s seat and fastening my seatbelt to loosening frictions just before bringing RPM to 100%, in the same order.
  • Always check to make sure all doors are secured before lifting up. (I can reach all doors from my seat and all their windows have fingerprints where I push on them before each flight.)
  • Always do a visual scan of the area before lifting up and then again before departing the area.

These things, when done regularly, become routine. I actually feel as if something is wrong if I neglect to perform one of these tasks. I have even gone so far to climb back out of the aircraft before starting up to check fuel caps if I can’t recall doing so.

What’s a bad habit? How about storing papers, pens, or other items in the area beneath the collective? While some aircraft have ample storage space there, many do not. Don’t place anything there that could prevent you from getting the collective down in a hurry if you need to. How about leaving dual controls in when non-rated passengers are on board? Do you really want to worry about some idiot pushing the cyclic, resting his feet on the pedals, or having his fat butt blocking the collective when you’re trying to pull pitch? Pull those controls out if you don’t want the person beside you able to mess with them. Or how about glazing over or skipping your passenger preflight briefing? Do you know how you’d feel if your passenger were trapped in the aircraft after a mishap because you neglect to tell him how to open the door?

Think about the things you do when you fly. What good (or bad) habits have you developed? Get rid of the bad ones — they’re not going to help you become a better or safer pilot. Instead, think about the things you need to do or be aware of when you fly and incorporate them into your workflow or cockpit management.

Be constructively critical of each flight.

This is my favorite of the tips, the one that made me think this was a topic to blog about.

The trouble is, too many pilots are head cases who think they can do no wrong. No matter how well or poorly they fly or complete a mission, they’re too full of themselves and confident in their own capabilities to review what they’ve done and think of how it could have gone better.

The Pick Up/Set Down Challenge

I must have written about this elsewhere, but I can’t find it so here it is.

When I flew at the Grand Canyon in 2004, I averaged 10-14 flights a day. The flying itself was rather tedious, with only two extremely well-defined routes and no room for deviation. There wasn’t any opportunity to make it more interesting — other than the challenges Mother Nature threw in our way — so I decided to focus on the part of the flight where there’s always room for improvement: those 10-14 pickups and set downs.

From nearly day 1, I concentrated on that part of the flight, working hard to make every single pick up or set down as smooth as I could make it. Then, right after each one, I’d give it a score from 1 to 10, with 10 being the kind of pick up or set down where you didn’t even feel the aircraft make or lose contact with the ground. I didn’t have many 10s — I’m a tough scorer — but after a few weeks and months, I didn’t have many below 6 either.

To this day, I do the same thing with pick ups and set downs. The result: I’m pretty sure that few fellow pilots would find much fault in most of my pick ups or set downs. The passengers think they’re great no matter how low I’d score them — but what do passengers know?

Have you ever considered doing something like this for your flying? Challenging yourself for no other reason than to improve yours own skills? If not, why not?

The reality is that anyone can improve at least one aspect of any flight or mission. Just think about everything you did and focus on what wasn’t perfect. Then think about what you could have done to make it perfect — or at least closer to perfect.

Here are some examples:

  • During preflight, did you miss any inspections you should have done because you were distracted? If so, how could you prevent future distractions? (A friend of mine will restart a preflight inspection from the beginning if anyone interrupts him while he’s doing it.)
  • Did startup go smoothly? If not, what could you have done to make it better next time? (I’ve gotten to the point where I usually know how long to prime the engine before starting based on the ambient temperature.)
  • Was your departure smooth and within height-velocity diagram recommendations (if possible)? If not, what could have improved it?
  • Were your radio calls well-timed, concise, and correct? Is there anything you could have done to make them better?
  • Did you choose the best route to your destination? If not, what route might have been better and why?
  • Was your approach to landing suitable? If too steep/shallow, fast/slow, or with a tailwind, what could you have done to make it better or safer?

I can go on and on with examples, but you get the idea. Review each flight or mission and make mental notes about how it could have been better. Then, the next time you fly, act on those mental notes as appropriate. Not only will this make you a better, safer pilot, but it could help you develop some of those good habits I discussed earlier.

The point is, no matter how much experience you have and how great a pilot you think you are, you are not perfect and no flight is perfect. There’s always room for improvement. It takes a good pilot who is genuinely interested in becoming a better pilot to recognize this and work hard to get better. And better. And better.

Only You Can Make Yourself a Better, Safer Pilot

Not only is it within your control and capabilities to make yourself a better and safer pilot, but it’s your responsibility to do so. These three tips are a good place to get started.

What do you think?

LogTen Pro

A mini software review for pilots.

LogTen ProAt the end of 2010, nudged by the availability of a coupon code for 30% (I think) off, I purchased the Mac and iPad versions of LogTen Pro. This program, published by Coradine Aviation Systems, is designed primarily for airline pilots to log their flight time, trips, duty time, expenses, and other data. It can then generate any number of reports, including FAA-approved logbook pages and duty sheets. Of course, pilots with Macs don’t only live in the US, so LogTen Pro supports multiple countries and the reports needed to satisfy their own FAA-equivalent organizations.

Although, on the surface, LogTen Pro seems like overkill for logging pilot hours, its true power lies in the fact that you don’t need to log everything it lets you. For example, LogTen Pro enables you to log flight date, aircraft N-number, duty time in, hobbs out, time out, from airport, to airport, time in, hobbs in, and duty time out. That’s the kind of information an airline pilot might need or want to log. But, in reality, how many people really track that much information about their flights? LogTen Pro is perfectly satisfied just taking the flight date, N-number, from airport, to airport, and total time flown. And of course, you can log day vs. night time, VFR vs. IFR time, etc.

In other words, you can log as little or as much information as you like.

iPad version of LogTen ProOf course, the iPad version (shown here with a screen shot of all my 2010 activity) syncs with the Mac version, so I can log time on the go and sync it all up when I get back to my office. Or I can pull old log entries out of my paper logbook and enter them in my Mac and then sync it all to my iPad.

While LogTen Pro is a bit weak on logging helicopter flight time — for example, it supports the Rotorcraft category but did not include a Helicopter class (although, for some reason, it did have gyroplane; go figure) — it is highly customizable. I simply used one of the undefined Class fields to create a Helicopter class in my copy of the software. Although this is calculated properly in the logbook reports as is, I can also create custom log book pages that eliminate columns I don’t need and expand on ones I’m interested in tracking, such as High DA/Mountain (another custom field I created) or Turbine helicopter.

I could go on for thousands of words about this software — there’s a lot to it. But it would be better to let you view the Guided Tour and just try the software for yourself. If you’re a pilot with a Mac, iPhone, or iPad, download the demo version of the software and see what you think. If you’re geeky and love stats like I do, I think you’ll be sold.

Aviation Communications

It’s not as tough as you think.

When I was learning to fly back in the late 1990s, my flight instructor babied me when it came to radio communication. He did most of the talking. Because I wasn’t forced to talk on the radio during my training, I didn’t get as much practice as I should have. As a result, my radio communication skills were weak — to say the least.

Although I really like my original flight instructor — and still stay in touch with him after all these years — he really wasn’t doing me any favors by handling communication for me. That became apparent when I went through my commercial pilot training and got my commercial pilot certificate. Although I could fly to FAA-established standards, I was a nervous wreck when it came to using the radio.

I eventually learned by doing it. After all, there was no CFI along with me to do the talking, so I had to do it. It took about a year for me to relax and even more time to realize that it wasn’t such a big deal after all.

Misconceptions

The big misconception among pilots in training is that they must use a certain vocabulary and say things in a certain order to communicate with ATC. That is simply not the case.

The goal of radio communications is to simply communicate. How you say it doesn’t matter much as long as the message gets across and two way communication is established when needed.

The Basics of Making a Radio Call

Here’s an example. Suppose I’m flying from Wickenburg to Deer Valley Airport. Wickenburg (E25) is class G, so the only talking I need to do is on unicom for position reports, etc. Deer Valley (DVT) is a busy class D airport on the north side of Phoenix. I need to establish 2-way communication before entering the class D airspace, which starts about 5 miles out from the airport.

What do I need to say? It’s pretty simple:

  • Landing DVTWho I’m talking to: Deer Valley Tower
  • Who I am: helicopter Six-Three-Zero-Mike-Lima
  • Where I am: eight miles northwest
  • What I want: landing terminal helipad
  • ATIS confirmation: with bravo

Ideally, this is the best formula, keeping things short. The initial radio call would be:

Deer Valley Tower, helicopter Six-Three-Zero-Mike-Lima is eight northwest landing terminal helipad with bravo.

But the information doesn’t have to be in that order. I could also say:

Deer Valley Tower, helicopter Six-Three-Zero-Mike-Lima is eight northwest with bravo, landing terminal helipad.

If I leave something out, there’s no reason to panic. The tower will ask for the missing information. So if I leave out the ATIS confirmation, they’ll say something like:

Helicopter Zero-Mike-Lima, verify you have Information Bravo?

Or if I left out my position, they might say:

Helicopter Zero-Mike-Lima, say position?

I’d reply with the missing information:

Affirmative, Zero-Mike-Lima has bravo.

Or:

Helicopter Zero-Mike-Lima is eight miles northwest.

Responding to ATC

When the tower responds to my initial call, all I need to do is repeat back the important part of the instructions. So if the tower says,

Helicopter Six-Three-Zero-Mike-Lima, Deer Valley Tower, report 1 mile north at or below two thousand. Plan midfield crossing at two thousand.

What’s important? RIght now, just to acknowledge that I’ve heard the instructions and will report again a mile north. So I’d say,

Zero-Mike-Lima will report one north.

Done.

I might also include mention of that altitude restriction, but I usually don’t. Why? Because the tower usually repeats it when they clear me to cross the runway. (The helipads are south of the two runways.) So they might say

Helicopter Zero-Mike-Lima, Deer Valley Tower, we have you in sight. Cross both runways midfield at two thousand feet. Landing at the terminal helipad will be at your own risk.

I’d respond:

Zero-Mike-Lima crossing at two thousand.

I don’t have to repeat the risk thing. It’s the altitude restriction that they want to hear.

Note that in my original response, I chopped Six-Three off my call sign. Although a lot of the pilot reference material says not to do this until the tower does, I have never had a problem abbreviating my call sign before ATC does.

If ATC Makes a Mistake

Sadly, its pretty common for the tower to get my N-number wrong. I can’t tell you how often they think I said “Helicopter Six-Zero-Three-Mike-Lima.” They’d respond:

Helicopter Six-Zero-Three-Mike-Lima, Deer Valley Tower, report 1 mile north at or below two thousand. Plan midfield crossing at two thousand.

If they do that, my response to them corrects them using the entire N-number again, with stress on the scrambled characters:

Helicopter Six-THREE-ZERO-Mike-Lima will report one mile north.

In which case they repeat back the N number to correct themselves; no response is necessary.

If You Make a Mistake

I can’t tell you how many times I told a tower I was X miles east when I was really X miles west. Or X miles southwest when I was really X miles southeast. It happens. It’s dumb and sloppy, but it happens. It’s not the end of the world.

If you make a mistake and it’s something you think the tower needs to know, get back on the radio and correct yourself:

Sorry, Tower, Helicopter Zero-Mike-Lima is really eight northEAST.

I usually put the stress on the word(s) that correct what I got wrong the first time. The tower will repeat it back and you don’t need to respond unless you get new instructions.

You don’t have to tell the tower about every single mistake you make. Maybe you told the tower you were 12 miles out and you’re really only 11. Not a big deal. Direction is far more important so the tower knows what direction they should be looking for you.

Leaving Out Your N-Number

It’s very important to include your N-number — either the whole thing or the abbreviated version — in every communication with a tower. I recently heard an exchange between a tower and a pilot who neglected to mention his N-number. The tower basically ignored him for two or three calls, then chewed him out over the radio. How embarrassing.

The tower was right, though. If you don’t give your N-number, the tower doesn’t know who’s talking. How can it answer and provide instructions?

I’ll be the first to admit that I occasionally omit my N-Number when I’m having a “conversation” with a tower. For example, if a tower asks a direct question:

Helicopter Zero-Mike-Lima, confirm you have information Bravo.

I might answer:

That’s affirmative.

It’s also wrong. The only reason I get away with it is because (1) I immediately answered a question directed to me and (2) I am likely the only female pilot flying a helicopter in that airspace at that moment. It’s simple voice recognition on the part of the controller. But he has every right to demand I answer properly and I have no right to expect him to distinguish my voice from anyone else’s.

Requesting a Frequency Change

Deer Valley and ScottsdaleIn the Phoenix area, there’s less than a mile between the Deer Valley class D airspace and the Scottsdale class D airspace. The towers know this, of course, so if you’re flying from one to the other, they usually give you a frequency change when you’re less than three miles from the airport you’re leaving. Even if you didn’t ask for it, they’ll say something like:

Helicopter Zero-Mike-Lima, frequency change approved.

But sometimes they don’t cut you loose. Maybe they forgot. Maybe they’re busy. Maybe there’s traffic in your area and they want to be able to talk to you. Who knows? It doesn’t really matter. It’s pretty handy to get an early frequency change so you can listen to the ATIS and prepare for your radio call to the next tower.

To ask for it, just say:

Deer Valley Tower, Helicopter Zero-Mike-Lima requests frequency change.

The response will likely be:

Helicopter Zero-Mike-Lima, frequency change approved. Good day.

You can now change the radio frequency while still in their airspace.

Transitioning

I can’t tell you how many times I’ve avoided airspace just so I didn’t have to talk to a controller. I don’t do that anymore. Transitioning through the edge of a class D or C or even B surface airspace is easy. Just remember the formula:

  • Transition ExampleWho I’m talking to: Scottsdale Tower
  • Who I am: helicopter Six-Three-Zero-Mike-Lima
  • Where I am: six miles west
  • What I want: transition southeast through the southwest side of the airspace
  • ATIS confirmation: with bravo

So the call might be:

Scottsdale Tower, helicopter Six-Three-Zero-Mike-Lima is six miles west with bravo. I’d like to transition southeast through the southwest side of your airspace.

If you don’t mention the ATIS, no big deal. You’re not landing there, so you don’t need it. Chances are, they’ll give you the current altimeter setting anyway. They might say something like this:

Helicopter Six-Three-Zero-Mike-Lima, Scottsdale Tower, proceed as requested. Scottsdale altimeter two-niner-niner-seven.

I usually respond with something like,

Two-niner-niner-seven, Zero-Mike-Lima.

Or sometimes I just repeat my abbreviated N-number to acknowledge that I heard them. That’s it. When I’m clear of the airspace, if the tower frequency isn’t busy, I’ll say something like,

Scottsdale tower, helicopter Zero-Mike-Lima is clear to the south.

Otherwise, I don’t bother.

Unusual Requests

Once in a while, you might have an unusual request — something beyond simply coming or going or transitioning. I had one of these a few weeks ago.

A client wanted a custom tour of the Phoenix area that included circling five different addresses. When I plotted the addresses on SkyVector to create a flight plan, I realized that I’d be passing through and circling within Phoenix Sky Harbor class B and Chandler class D airspaces. The flight required me to talk to Glendale tower on departure, Phoenix tower on transition, Chandler tower for operation in the northeast corner of their airspace, Phoenix tower again for operation in their surface area before another transition, and back to Glendale tower for landing. All within about an hour.

Flight from Hell

Even though I’m pretty confident these days about my radio communication skills, I admit that I was nervous about this one — especially since most of the addresses we needed to circle were in subdivisions filled with lots of homes that look nearly identical from the air. I didn’t want my client disappointed, so navigation was a huge issue.

What is it they say about pilot priorities? Aviate, navigate, communicate. Of the three, the flying would be the easiest part!

Amazingly, this came off without a hitch. Why? Because I remembered the primarily goal of radio communication: to communicate what you need. So, for example, when I was still 10 miles out from Chandler, I said something like:

Chandler Tower, Helicopter Six-Three-Zero-Mike-Lima is ten miles northwest. We need to take some aerial photos of three targets in the northwest corner of your space. The closest to the airport is at Route 202 and Alma School.

The tower came back with:

Helicopter Zero Mike Lima, Chandler Tower. What altitude do you need?

Duh. I should have mentioned the altitude. But no big deal, huh? The tower just asked me for the information they needed. I replied:

Helicopter Zero-Mike-Lima will stay at or below two thousand feet.

To which they replied:

Helicopter Zero-Mike-Lima, you can proceed as requested. Chandler altimeter is three-zero-one-one. Report on point.

What he did was give me permission to do the job but also to let him know when I was at each location I needed to circle. I replied with my abbreviated N-number to let him know I’d heard him. Then, when I got to the first address, I said:

Chandler Tower, Helicopter Zero-Mike-Lima is on point at the first target.

To which he replied,

Helicopter Zero-Mike-Lima, thank you.

We repeated this exchange two more times. He also advised me of some traffic when I was at my second target; the traffic was at least 300 feet above me and not a factor. When I finished with the last target and departed to the north, I said:

Chandler Tower, helicopter Zero-Mike-Lima is clear to the north. Thanks for your help. Good day.

Although there was only one target in the Phoenix class B surface area, there was also another helicopter just outside the surface space, about a mile east of me, circling. The tower was busy with jets, but they also had to advise me of this traffic, which they saw on radar but weren’t talking to. Fortunately, I saw it both on my helicopter’s traffic information system (at my altitude!) and then visually. I was able to confirm that I would keep visual separation. We circled the site and departed to the north.

I like to think of this flight as my “final exam” in aviation communication. I passed.

Just Communicate

If you’re a pilot struggling with communication, relax. Magic words and phrases aren’t necessary. Just communicate. Tell the tower what you want. Believe me — they’ve heard it all. No matter how bad you think you are on the radio, there was someone worse only an hour ago.

Air traffic controllers are professionals. They deal with it. Do your best and you’ll do good enough.

And the more often you communicate while flying, the better you’ll get.

Getting a Part 135 Certificate

Don’t expect free help from me.

Last night, I received yet another e-mail from a helicopter operator with questions about getting a Part 135 certificate. I thought that it was about time for me to explain why people who e-mail me for free help about this won’t get it.

But first, a bit of an explanation of what a Part 135 Certificate is.

What Is a Part 135 Certificate?

A Part 135 certificate is literally a piece of paper issued by the FAA that permits a commercial aircraft operator to perform air-taxi operations. The phrase air-taxi refers to the mission of picking up a passenger at Point A and transport him to Point B. A Part 135 Certificate also permits an operator to conduct aerial tours beyond the 25 statute mile limitation set by Part 91 or the relatively new Part 136. Part 135 gets its name from the Federal Aviation Regulations (FARs) Part 135, but a Part 135 operator must also comply with all other applicable FARs, including Parts 61, 91, and 119.

Zero Mike Lima at Monument Valley

Zero-Mike-Lima at Monument Valley during one of my multi-day excursions.

A Part 135 certificate is worth more than its weight in gold for an operator that has one and can use it properly. For example, if I didn’t have one, I’d be limiting my operations to short tours within 25 miles of my starting point and aerial photo/survey flights. With a Part 135, however, I can also take my tours as far as I like, transport passengers between two points, and even offer day trips and multi-day excursions. In the highly competitive area I live in — Arizona is just swarming with helicopter operators — a Part 135 Certificate gives me the competitive edge I need to stay in business. (With less local competition, I might even become profitable. Wouldn’t that be special?)

There are three types of Part 135 certificates: Single Pilot, Single Pilot in Command, and Basic. I have a single Pilot Part 135 certificate. That means that under my company’s certificate, only one pilot is allowed to fly the aircraft under Part 135: me. (Hint to jobseekers: that’s one reason why I don’t ever hire other pilots.) A Single Pilot in Command certificate is similar, but is used mostly in organizations with aircraft that require more than one pilot; just one of those pilots is allowed to fly as pilot in command, but any other pilot can be second in command. The Basic Part 135 certificate — and I may have its name wrong — allows multiple pilots to act as pilot in command on multiple aircraft. The Grand Canyon tour operator I worked for had a Basic Part 135.

At a recent meeting at my local Flight Standards District Office (FSDO; pronounced fizz-doe), I learned that there are only 4,800 Part 135 certificates in the entire country. If you take a moment to consider what percentage of those could possibly be helicopter operators, you’ll realize that I’m part of a very small club.

The penalty for conducting a Part 135 operation without a Part 135 certificate? Well, I know of at least one pilot who had his license permanently suspended. Ouch. When you consider the amount of time and money a commercial pilot — especially a helicopter pilot — might have invested in a career, that’s a very costly penalty.

Airline operations, by the way, are Part 121, which has tighter regulations.

How to Get a Part 135 Certificate

You work with your local FSDO to get a Part 135 Certificate. It requires multiple meetings at the FSDO to work your way through a flow chart of activities. Although I’ve heard of people getting their Single Pilot Part 135 as quickly as three months — it took me four months — it takes other people years. In fact, more than a few operators have gone out of business while working through the process.

Want Help Writing a Statement of Compliance?

When I wrote this blog post back in 2010, I was firmly against helping operators create their Statement of Compliance. At time time, I was based in Arizona with a lot of competition making it damn near impossible to turn a profit. Things are different now. It’s 2017 and I’m comfortably settled in Washington State with a small market but little competition for Part 135 work. In addition, I have found more lucrative sources of flying revenue that don’t require a Part 135 certificate at all. Add to that the FAA’s recent requirement for all Part 135 helicopter operators to have a radio altimeter and the cost to obtain that and I’m a bit softer about helping others — for a fee. Let’s just say that the FAA has motivated me to sell my experience and possibly increase its workload.

So here’s the deal. If you’re interested in getting help writing a Statement of Compliance for a Part 135 certificate, use the form on the Contact page of this site to get in touch with me. Tell me a little about your business and the aircraft you fly, the kind of Part 135 certificate you’re seeking, and where you are in the process with your FSDO. If I think I can help you, I’ll let you know what kind of compensation I need to write a Statement of Compliance for you.

Keep in mind that although this will make the process easier, it’s still time-consuming and you’ll still have a lot of work to do on your own.

There’s a lot of paperwork. The biggest challenge to most people is the creation of a Statement of Compliance. That’s where you list all the applicable FARs and state exactly how you will comply. My Statement of Compliance, written in 2005, was 54 pages long. It wasn’t difficult for me to create because, after all, I am a writer. But I’d say that 90% of the people who try to get their Part 135 certificate stumble on this component, which occurs about halfway through that flow chart.

You’ll also need to get on a drug testing program, create a training manual for carrying (or not carrying) HazMat, and obtain a secure location for basing your aircraft. You’ll need to create forms for pilots to log time flown, aircraft flight time, and squawks. You’ll need to have perfect maintenance records. If you’re going for a Basic Part 135, you’ll need all kinds of other manuals and documents, as well as staff in predetermined positions, such as Director of Operations, Director of Maintenance, etc.

The FAA did not make the process easy. If it were easy, everyone would have a Part 135. Instead, they made it a challenge.

I am extremely fortunate to be working with an excellent FSDO full of people who are reasonable and helpful. Yes, I’m required to jump through the same hoops as everyone else, but my contacts at the local FSDO help me make those jumps. In turn, I comply with their requests promptly, without question. After all, their mission is to keep me safe. Why wouldn’t I want to be safe?

Why I’d Rather Not Help You Get Your Part 135 Certificate

I’ve already given you several hints on why I’d rather not help you get your Part 135 Certificate. Did you read between the lines to get the answer? If not, I’ll spell it out for you.

  • Rise to the challenge. I personally believe that the FAA makes it challenging to get a Part 135 Certificate as a test to see if applicants are worthy. Let’s face it: the FSDO folks spell out what you need to do — using a flowchart, for Pete’s sake! If you come into the application process with the right attitude, they’ll help you achieve your goal. But they won’t just give you a certificate for showing up. You have to earn it. By jumping through all the hoops and smiling the whole time, you’ll prove that you have the right stuff to be a safe and cooperative aircraft operator. If I — or anyone else — help you get your certificate, you won’t prove anything other than that you can’t do it alone.
  • Membership has its privileges. That old American Express slogan can easily be applied to the 4,800-member club of Part 135 certificate holders. We can do things that Part 91 operators can’t. This gives us far more flexibility in our operations. I can’t tell you what a joy it was to finally be able to say yes to a client request for an air-taxi flight. Saying yes means more business, more revenue.

I get e-mails and calls at least twice a month from helicopter operators hoping I’ll help them get their Part 135 certificate or make their business grow. Apparently, it isn’t enough for me to write about my own experiences here so they can use them as learning tools. Instead, they want me to take them by the hand and walk them through the process.

Why should I? What’s in it for me?

I did the hard work I needed to do to get my certificate and build my business. Isn’t it in my best interest to have other operators jump through the same hoops I did and prove they’re worthy of getting a Part 135 certificate? Wouldn’t I rather be sharing the skies with pilots who passed muster with the FAA? Wouldn’t I rather refer overflow business to an operator I know has the ability to do his own homework?

You want a Part 135 certificate? Take my advice: Call your local FSDO and set up a meeting to get started. Then put a smile on your face, roll up your sleeves, and get to work.