Tag Archives: FARs

Flying in a Heat Wave: Safe? Legal?

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I explore the logic behind performance charts and what the FAA told me about flying in hot weather.

Upcoming Weather
Next week’s weather. It’s going to be hot.

I have a Part 135 check ride coming up on Tuesday. Per the National Weather Service — my primary source of weather information — the forecast high in Wenatchee for that day is 112°F.

If you live in any country other than the metric-unfriendly US, that’s 44.4°C.

IGE Hover Chart
The IGE Hover Chart for an R44 Raven II does not chart any performance data for temperatures above 40°C.

The In Ground Effect (IGE) Hover charts for a Robinson R44 Raven II, which is what I fly, end at 40°C. That is, they do not provide any performance data for 44.4°C.

Now I learned to fly in Arizona and on a typical summer afternoon, 112°F was not uncommon. We flew in all kinds of heat. Hell, I remember landing at Bullhead City one day and reading 123°F on my outside air temperature (OAT) gauge. (And that was in a helicopter without air conditioning.) If the flight school I attended — which is still in business — didn’t fly when it was above 104°F (40°C), they wouldn’t be able to fly half the day about a third of the year. No one questioned whether it was safe or legal. We just did it.

Time went by. Someone suggested to me that flying when the temperature was above 40°C was not only unsafe but illegal. “You’re a test pilot when you do that,” more than a few people have told me. “Your insurance wouldn’t cover you in a crash,” another said, “because you’re operating outside of published data.”

Curious to see what other pilots thought about this, I put a poll on Twitter and gave the Pilots of Twitter 24 hours to respond. I also asked for comments. A lively discussion got going in the comments. It was also pointed out that I could have added “Unsafe but legal” as one of the options with the shared opinion that “the FAA gives you enough rope to hang yourself with.”

I do recall airplanes being grounded at Phoenix Sky Harbor airport one day when temperatures were “too hot” for some of the airliners, although it wasn’t clear from articles I read about how the limit was established.

Well, in an effort to head off a “gotcha” by my FAA examiner, I emailed him this morning to warn him of the heat:

A quick heads up.

We’re expecting high temperatures of 112°F on Tuesday. If you are of the school of thought that says we can’t fly when temperatures exceed 104°F because that’s the highest temperature on performance charts, we should probably plan to fly very early, before the temperature tops out. …

If you’re not of that school of thought — I learned to fly in Arizona so I’m not — we should be fine. The helicopter does have air conditioning, although I’ve never tested it in 112°F weather.

Please let me know what time you plan to arrive.

He replied, in part:

I am unaware of a temperature limitation that restricts operations of the R-44. We can complete the ground during the afternoon of the 28th so we can fly on the morning of the 29th to minimize the effects of the heat. …

So that’s telling me that it’s legal. (But he’s not taking any chances or doesn’t want to test my air conditioning.)

Never Exceed Speed
Here’s a limitations chart: Never Exceed Speed. If I extrapolated, I think operations at lower elevations would be fine, but I certainly wouldn’t exceed about 85 knots 44°C at 8000 feet. (Heck, the helicopter would be vibrating like crazy at that speed and elevation anyway.)

Is it safe? Well, as this “test pilot” could tell you, if you extrapolate the data in the charts, keeping in mind the aircraft’s gross weight and the altitude you would be operating at, it can be. Keep the aircraft light, don’t plan any high altitude landings, and keep your speed down.

Chances are, the helicopter will continue to operate in heat that you won’t want to be flying in anyway.

Helicopter Minimum Altitudes

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I’m working on a much longer blog post, with photos, about my recently completed autumn vacation, but I thought I’d put this shorter post out because it’s quick and on my mind.

It started with someone on Twitter sharing a video from inside the cockpit of a helicopter flying low and fast over a forest road. There were no cars on the road and no poles or wires. It was an exciting little flight that reminded me of the kind of canyon flying I used to do in some very familiar, remote areas of Arizona. See for yourself.

Helicopter video screenshot.
Here’s a screenshot from the video in question.

What followed was a bunch of comments, including some from a few people too lazy to look up the regulations who claimed that flying like that was illegal. When I pointed out that it was not illegal in the US, a particularly lazy, uninformed idiot quoted my tweet with a portion of the FARs in an attempt to prove me wrong. He didn’t. All he proved is that like so many people these days, he’s only capable of reading until he gets confirmation of what he wants the truth to be. The rest doesn’t matter.

Here’s the entire FAA regulation covering minimum flight altitudes in the US:

§91.119   Minimum safe altitudes: General.

Except when necessary for takeoff or landing, no person may operate an aircraft below the following altitudes:

(a) Anywhere. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface.

(b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 feet of the aircraft.

(c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not be operated closer than 500 feet to any person, vessel, vehicle, or structure.

(d) Helicopters, powered parachutes, and weight-shift-control aircraft. If the operation is conducted without hazard to persons or property on the surface—

(1) A helicopter may be operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and

(2) A powered parachute or weight-shift-control aircraft may be operated at less than the minimums prescribed in paragraph (c) of this section.

[Doc. No. 18334, 54 FR 34294, Aug. 18, 1989, as amended by Amdt. 91-311, 75 FR 5223, Feb. 1, 2010]

Did you read paragraph (d) and paragraph (1) right beneath it? I did, but the know-nothing twit pretending to be an expert on Twitter didn’t. It basically says that the paragraphs he quoted (paragraphs (b) and (c) above) don’t apply to helicopters.

I distinctly remember this FAR coming up during my primary training back in the late 1990s. It basically gives helicopter pilots permission to fly at any altitude they need or want to, given that “if a power unit fails, an emergency landing without undue hazard to persons or property on the surface.”

Take a look at the video. It looks to me as if the pilot is 50-100 feet off the ground. He’s moving at a good clip — at least 60 knots. (I tried to read the airspeed indicator but couldn’t.) With that altitude and airspeed combination, he’s not operating in the shaded area of the height/velocity diagram (or “deadman’s curve“). That means that a safe emergency landing is possible. And with nice smooth pavement beneath him, there’s plenty of suitable space for a landing if it was necessary. So it’s not in violation of paragraph (a) either.

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Flying M Air Logo

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Lots of people don’t get this. They assume the altitude rules apply equally to all aircraft. But they don’t. This makes it pretty clear. Trouble is, there are too many self-important assholes out there — especially on Twitter — who share inaccurate or incomplete information as fact — and too many lazy people willing to believe them without doing their own homework.

If you want to read more about this topic, here’s an old, long, rambling post I wrote about an experience related to this years ago.

Oh, and by the way, this post is about whether the flight is legal in the US. I won’t make any comments about whether it’s safe or whether the pilot is using good judgement. That’s a whole different topic.

Self-Publishing a Paperback with Amazon KDP

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Easy enough, but not ideal.

Part 107 Explained
Want to become a commercial drone pilot? Start by learning all about the FAA’s Part 107. This book will help. Buy the ebook edition on Amazon or from Apple. Or buy the paperback edition on Amazon.

Back in April, I wrote and published a short guide to FAR Part 107, which are the regulations governing commercial small UAS (drone) pilot operations. In the U.S., a pilot who wants to fly a drone for hire must get some training on these rules and then prove they know them by taking a test. If you’re not already a pilot, there’s additional certification and training that must be done. The FAA has recognized that a small UAS is an aircraft and must be regulated as such. As a helicopter pilot sharing airspace with drone pilots, I’m pretty happy about that, although I’m not happy about the folks who operate with little or no regard for the rules.

In preparing for the test and later answering people’s questions about the regulations, I looked for a guide that explained everything in plain English. When I couldn’t find one, I wrote one. It was my first book project in about four years and it wasn’t very tough for me. When it came time to publish it, I did it the easy way: I created ebook files in the correct formats and published them in the Apple bookstore and on Amazon.com.

Understand that I’m a big proponent of ebooks and very rarely buy printed books anymore. It’s a lot more convenient for me to read on my iPad and I get the added benefit of taking as many books as I want with me on trips without adding any weight to my luggage. I assumed that the folks who wanted a book like this would be on the same page as me.

But apparently that isn’t so. Lots of people seem to really like printed books, even for something as short as this one.

I normally use a print on demand publisher for my paperback book publishing needs: Lightning Source. They are affiliated with Ingram, so any book I publish using their service is automatically listed in Books in Print and appears in bookstore book catalogs, including Amazon and Barnes and Noble. The service isn’t difficult to use if you have the ability to create a PDF in the correct format. I usually write my books in InDesign, which can spit out documents in the formats I need. I fill out a few online forms, I upload the content and cover files, I pay a nominal fee, and I wait. The books are usually available within a week or so.

But yesterday, while checking the sales for the Part 107 book on Amazon, I saw a link for creating a paperback using Kindle Direct Publishing (KDP). I did some research on how it worked, what it cost, and how royalties were calculated. It seemed straightforward enough so I thought I’d give it a try. I figured that if I didn’t like the results, I could cancel publication and get the paperback printed through Lightning Source.

I spent about five hours yesterday prepping the manuscript for print publication. The trouble was, the manuscript I’d published as an ebook was absolutely filled with links to references on the web and cross-references to book content. In the ebook, you could tap a link to go right to that source — another benefit of ebooks over printed books. I had to manually convert all of the references to URLs in footnotes or page references in parentheses. I also had to remove all of the URL formatting that had been applied to link text. And because many of the URLs were really long, I had to use a URL shortener — I prefer bit.ly — to give each link a short, custom URL.

When I was done, I tried creating a PDF but didn’t like the results. I was working with Microsoft Word 2011 — I never did go to the Office 365 suite — and it doesn’t offer many options for PDF files. And, for some reason, it was spitting out a separate PDF for each section of the document. (I used sections to add custom headers for each chapter of the book.)

Since the KDP system accepted Word documents, I uploaded in that format. I then spent another half hour recreating the book cover for print.

When I was all finished, I previewed the book. That’s when I discovered that KDP had changed pagination for some reason that wasn’t immediately apparent, thus making my table of contents incorrect. Great.

I was offered the option of downloading a “corrected” Word document, so I did. When I opened it up, I discovered that the “correction” included changing the margins for the document. I knew what they said the margins should be, but I thought that was a suggestion. Apparently, it was a requirement. So I opened my “uncorrected” file, changed the margins, updated the table of contents and cross-references page numbers, and made a few other minor tweaks. Then I saved the file, uploaded it again, and previewed the results. It was fine.

Ready for Publishing
Here’s the dialog that appeared when I clicked Publish.

I clicked the buttons that needed clicking and eventually saw a dialog box telling me that my paperback had been submitted. Although one message had told me it could take 72 hours, this one said 12 hours. Whoa.

I shut down my computer for the day and went about my business. It was only 3 PM. I think I spent a total of 6 or 7 hours on the conversion process.

This morning, a little black dog who will remain nameless in this discussion decided she needed to bark at the coyotes howling off in the distance at 3:15 AM. That was all I needed to wake me up.

I lay in bed for a while with my iPad, checking weather, doing a word puzzle I do every morning, and checking in on Twitter. Then I decided to check Amazon to see if my paperback book appeared. I was very surprised to see that it did.

Book Listing
Here’s my book, all ready for purchase. I think it might be #1 in New Release and #11 in in Books > Arts & Photography > Photography & Video > Aerial because I bought two copies this morning.

Of course, I bought two copies right away: one for me and one for my friend Jim, who got me into drones. The only way I’m going to see the book is by buying it. At least I earn royalties on the purchase.

I guess what blows me away is just how quickly the book was made available. When they said 12 hours, they weren’t kidding. I used standard Prime shipping; my book will arrive Monday because today is a holiday and they don’t deliver on weekends. Still, that means they’ll print and ship the book tomorrow.

If the book looks as good as the ones I get through Lightning Source, I might have a new provider for my limited audience paperbacks. Let’s face it: Amazon sells more books than anyone else. For a book that normally would not appear in a brick and mortar bookstore, there isn’t much of a reason to get it in that Ingram catalog. And although I need to run the numbers, I suspect I might actually make more money publishing through Amazon; I’ll have to do a cost analysis to see.

As for ease of publishing, well, if you don’t try to get fancy and you use the Word template Amazon provides, it’s pretty darn easy to publish a book. So easy that I’m thinking of doing it again this month. The only thing I miss is the flexibility of getting my manuscript just the way I like it. Maybe it’s time to fire up InDesign and use that to create PDFs that KDP can’t change.

Another No Fly Decision

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Smoke in the area forces me to cancel a scenic flight.

I’ll start this one with a story.

Flashback: Grand Canyon 2004

When I flew for Papillon at the Grand Canyon, Mother Nature threw all kinds of weather at us. In the spring, it was wind, sometimes blowing as hard as 50 miles per hour, causing all kinds of mechanical turbulence on our prescribed tour routes over the forest and Canyon. In the early summer, it was heat and high density altitude, which made the departure and arrival in our rather confined landing zone challenging. Then there were the fast-moving monsoon storms that sped across the terrain, sometimes blocking our path across the canyon and forcing us to shut down when lightning near the airport made it unsafe to refuel. (And yes, we did fly within 20 miles of thunderstorms.) That lightning would often start fires in the forest along the Grand Canyon’s rims, filling the air with thick smoke that made it nearly impossible to see.

Special VFR at GCN
Here’s an early morning view on one of those smokey days at the Canyon. The R22 on the left is mine, parked at transient helicopter parking at Grand Canyon Airport. I used to commute to work by helicopter once in a while; I needed a special VFR clearance to get into the Class D airspace that day. The tall building in the haze is Papillon’s base with its tower.

Honestly: flying at the Grand Canyon is the best experience a helicopter pilot can get. There isn’t much that you don’t experience as far as flying conditions go.

On one late afternoon in August, the area was full of storms and smoke from numerous wildfires. I took off in trail behind at least six other helicopters with another four behind me for one of the short tours. The passengers had come off a bus and their tour had likely been booked years in advance. All 11 helicopters were flying with the same group.

When we reached the Dragon Corridor, where we were supposed to cross the Canyon, we found our way blocked by a thunderstorm that made it impossible to see the other side of the canyon. So one by one we made our radio calls, turned around, went back past the airport, and crossed over the Canyon in the Zuni Corridor. There was a short tour on that side that we’d been taught but Papillon didn’t sell. I’d never flown it, so I basically followed the helicopter in front of me, making the same calls he did when I reached vaguely recalled reporting points.

The air was thick with smoke. The visibility was definitely less than five miles, although it had to be more than three miles for flight to be legal. But maybe that’s what it was at the airport. It wasn’t that over the canyon. At one point, I lost sight of the strobe light of the helicopter in front of me and had to find my way back without him. (We did not have GPSs on board.) I only got a little lost and was very glad to finally see Grand Canyon Airport’s tower. I adjusted my course to put me where I was supposed to be, made my radio call, and landed.

They shut down flights for the day after that.

Afterwards, I went up to the Chief Pilot’s office. His name was Chuck and he’d always struck me as someone who was very reasonable. I complained about the visibility and asked him why we were taking people on scenic flights when we could barely see. His response stuck with me: “If they’re willing to pay and it’s safe to fly, we’ll fly them.”

I swore I’d never take that attitude with passengers in my tour business. Indeed, years later I turned down a flight I could have done because I was certain that wind and turbulence would have made my passengers miserable.

And I’ve turned down flight since. Today is one of those days.

Today: Smoke in the Wenatchee Valley

The hour-long tour for one of my client’s vice presidents and his out-of-town guests has been on my calendar for about two months. I have the passengers names and weights and have done my weight and balance calculations. I know where they want to go and what they want to see.

The smoke started blowing in last week, which is kind of weird because (1) there aren’t any fires nearby and (2) there isn’t much wind. Apparently the fires are mostly in British Columbia (Canada), which isn’t very far from here, was well as in northwestern Washington State, on the other side of the Cascades. There was a rumor going around that there’s a fire in Blewett Pass, which is actually quite close, but I can’t find any information anywhere about that, and I have good sources to check.

Smoke from the Airliner
As this photo from my friend shows, the smoke was a thick blanket up to about 14,000-18,000 feet.

So the smoke is drifting down from Canada on a light breeze. It’s settling in the Columbia River Valley at Wenatchee. And elsewhere. A friend who who took a Horizon Airlines flight out on Thursday sent a picture from 20,000 feet and there was a blanket of smoke right beneath the plane. It was so bad I blogged about it.

For the first few days, it was a light haze. But yesterday it settled in so thick that not only could I smell the smoke, but I couldn’t see the river from my house, let alone the airport on the shelf right above it. Sure enough, the airport was reporting 1-1/4 mile visibility. Instrument meteorological conditions (IMC), meaning that it wasn’t legal for me to fly without getting a special VFR clearance from Seattle.

Bad View
I shot this photo from my deck yesterday when the visibility was at its worse.

Foreflight Weather
Turning on ForeFlight’s visibility layer displays visibility in miles at each airport that provides this data. Clicking the number displays details.

I emailed my client yesterday, asking him to check in with me an hour before the flight. But I wound up calling him this morning, two hours before the flight. I’d used ForeFlight, the basis of my electronic flight bag, to check conditions at Pangborn Memorial Airport, which I could barely see across the river. It was reporting visibility at 2-1/2 miles: IMC.

Could I fly in these conditions? Technically, yes. I could get a Special VFR clearance to leave my home (which is within Pangborn’s Class E airspace) and fly up to Baker Flats where my client would be waiting. That’s in Class G airspace where only 1/2 mile visibility is required for helicopters during the day. I could then do the whole tour, making sure I stayed out of class E airspace or get another clearance if I wanted to enter Class E. So yes, it’s legal.

But is it safe? Well, since I would always remain within sight of the ground and whatever’s at least a half mile in from of me and I can fly at virtually any speed to keep it safe, then yes, it’s safe.

So by Papillon’s standards — at least those back in 2004 when I flew there — I shouldn’t hesitate to do the flight. After all, it’s money in the bank, right?

I don’t think that way. It’s all about passenger experience. Other than me getting paid for a hour of flight time, what’s the benefit? The tour would be terrible — my passengers wouldn’t be able to see more than a mile or two during the entire flight. What’s “scenic” about that?

My client understood perfectly. He was happy to cancel. We agreed that we’d keep an eye on conditions and that if, by some miracle, a wind kicked up and blew some of the smoke out, we could try in the afternoon. Or maybe tomorrow. I’ve got nothing on my schedule. But it’s more likely that we won’t do it at all since his guests are leaving town on the 6 AM flight tomorrow morning. (Provided Horizon can get the last flight in tonight.)

In the meantime, I don’t mind staying home today. It’s better indoors with the windows shut than outside breathing that crap we’re importing from Canada.

The FAA’s Irrational Application of a Rule

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A little about my Vertical column and the responses to it.

If you’re a helicopter pilot, you’re likely familiar with Vertical Magazine. Simply put, it’s the premiere helicopter pilot/operator publication, with great articles and amazing photography. It not only informs those of us in the helicopter industry, but it keeps us enthusiastic about being part of what’s admittedly a rather elite club.

Vertical MagazineIf you read the June/July issue (download here as a pdf), you may have seen page 10’s Talking Point column. And if you know this blog, you probably realized that the Maria Langer who wrote that month’s column is the same Maria Langer who has been blogging here since 2003. Yeah: me.

I haven’t blogged about this yet because, frankly, I still can’t believe it happened.

While I wasn’t paying attention, the FAA issued FAR Part 135.160, which requires Part 135 on demand charter operators like me to install a radio altimeter. The rule has a loophole, which my Primary Operations Inspector (POI) at the Flight Standards District Office (FSDO) told me about: a waiver was available for helicopters less than 2,950 pounds max gross weight. My R44 has a max gross weight of 2,500 pounds and is VFR-only. Surely I’d get the waiver.

I didn’t.

What’s the Big Deal?

If you’re not familiar with what a radio altimeter is, you likely don’t understand how incredibly idiotic it is to require one in an R44. Here’s the deal. A radio altimeter — which is also sometimes called a radar altimeter — uses radio waves to measure the exact height of an aircraft over the ground. It then sends this data to a readout on the aircraft’s instrument panel so the pilot has this information handy.

Of course, a Robinson R44, which is what I fly, is a VFR-only aircraft. That means it’s only legal to fly in VFR (visual flight rules) conditions. That means you can see out the aircraft window. And that’s what Robinson pilots — all VFR pilots, for that matter — do when they want to know how high off the ground they are. They look. After all, they’re supposed to be looking outside anyway.

So for the FAA to require this kind of instrument on an aircraft that’s never going to need one makes absolutely no sense whatsoever.

Being the gadget person I am, I might not mind having a new toy in the cockpit. The trouble is, my cockpit’s panel must be modified to accommodate it, thus reducing my forward visibility, and the damn thing is going to cost me $14,500 to buy and have installed. And the helicopter will be offline for about a week while the mechanic tears it apart and drills holes in the fuselage to put it in.

There’s more to the story, but it’s mostly covered in the Vertical column. Go read it now; it’s on page 10. It’s short — they wouldn’t let me have more than 1,000 words. (I know; I gave them 1,200 and they cut 200 out.) See if you can read my frustration between the lines.

Responses

I got a number of responses to the column.

credits
This is kind of cool: they listed me as a contributing editor in that issue’s masthead.

The very first was from my friend Mike in Florida. He sent me an email message that included the Contributing Editor list you see here and a link to the article with his congratulations. Mike has also written for Vertical; he has a ton of experience and great writing skills.

A handful of other folks I knew texted or emailed me that they’d seen it. That was gratifying. I really do like writing for publication and should make a conscious effort to do it more often.

Then, the other day, about two weeks after it was first published, I got a call from someone at Helicopter Association International (HAI). HAI is a professional organization for helicopter pilots and operators. I used to be a member. It cost $600 a year and the only thing I got from them was a wooden membership plaque and a lot of paper. Safety posters, manuals, letters, newsletters, magazines. All kinds of crap to add to the clutter that had already taken over my life. When I dropped my membership after two or three years, they called to find out why. I told them they did nothing for small operators like me. They promised to change and conned me into joining for another year. Nothing changed. I was throwing my money away. I dropped my membership for good.

The HAI guy who called started by asking why I hadn’t come to HAI with the radio altimeter issue. After all, part of their member benefits was to be the voice of helicopter operators in Washington DC. Wrong question. I told him I wasn’t a member and then explained, in many, many words, why I’d quit. Then we talked a bit about the radio altimeter issue. He said he’d been working on it for a few days and he certainly did know a lot about it. He said that he wasn’t sure, but thought that HAI, which had been involved in the rulemaking comment process, had assumed it would only apply to medical helicopters. He said I shouldn’t get my hopes up but he and HAI were going to work on it. He wanted to stay in touch. Whatever. I gave him my email address.

When I hung up, I wondered why they were trying to close the barn door after the horse had already gotten out. After all, the FAA was not going to change the rule, especially after so many operators had already gone to such great expense to meet the requirement. HAI had dropped the ball for its small operators yet again. At least I hadn’t paid them to do it on my behalf.

The most recent response came just today and it prompted me to write this blog post. It was an email from a Facebook friend. I actually got two versions of it; I think this is the one he sent first which he apparently thought he lost:

Hey Maria
My name is Scott ##### and I took a $40 ride with you at the 2006 Goodyear Airshow out to PIR and back.
In 2007 I started flight training. We’re “friends” on Facebook and I always enjoy your posts and writings on your blog.
I just finished reading your article in Vertical magazine and couldn’t resist contacting you with my comments.
What a horrible situation for you. I’m severely confused as to why a Federal, as in a single national government agency, interprets the rules differently at each FSDO. It should be the same across the United States! How frustrating I’m sure this is for you.
This industry is tough enough as it is and for a single pilot, single aircraft operator, you’ve been extremely successful. Now this?
At least you got the temporary A160 but you shouldn’t have to have the radar altimeter installed at all! To me it’s very cut and dry: 135.160 does not apply to VFR aircraft weighing less than 2,950 pounds! Where’s the Misinterpretation?
I guess you can’t just cancel your installation appointment at Quantum in December, but hopefully you can get around paying for equipment you’ll never use.
Good luck to you Maria.

First, I have to say how gratifying it is to have been instrumental in a person deciding to learn how to fly helicopters. Wow. Just wow.

Second, it’s cut and dry to me, too! And most of the folks I spoke to that don’t happen to work at the FAA. And there’s nothing I’d like more than to cancel my December appointment with Quantum to get the radio altimeter installed.

But I wrote him a more informative response and I thought I’d share it here. It says a few things I couldn’t say in Vertical. (Or maybe they were in the 200 words that had to be left on the cutting room floor.)

Hi, Scott. Thanks for writing.

Unfortunately, every word of my Vertical piece is true. The FAA will NOT give me the waiver. They don’t care that my helicopter is small or VFR-only or or that the panel is full or that the rule was written in such a way to exclude R44s like mine. They do not operate logically. I worked with AOPA and an aviation attorney. I got my Congressman and one of my Senators involved. I had an email correspondence going with THREE men with the FAA in Washington who are responsible for making the rule. My lawyer spoke to people in Washington, too. They won’t budge. In fact, they told my lawyer that they’re going to rewrite the guidance so R44 helicopters can’t be excluded.

Problem is, medical helicopters crashed and people made noise at the FAA. The FAA needed a fix to turn down the heat. Radio altimeter makers promised a solution that would work and lobbied hard for it. They’re all over the comments for the regulation proposal. And since they have more time and money to throw at it, they won. The FAA bought into their Band Aid — or at least made us buy into it — whether it can help us or not. They didn’t seem to care that the real fix was better pilot training, less pressure on pilots to fly in IMC conditions, and a company culture that values safety over profits.

Understand this: the FAA doesn’t care about small operators or even pilots. They exist to regulate and ensure safety — or at least the illusion of safety. Your best chance of having a successful aviation career is to stay off their radar.

I pissed off a lot of people with my radio altimeter fight and I suspect they gave me the temporary waiver just to shut me up. I got a call from HAI the other day and they say they’re going to follow up. Too little, too late. But at least someone else will be making noise since I, like my fellow Part 135 Robinson owners, have given up.

I’m nearing the end of my career. I figure I have about 10 years left as a pilot. So I don’t mind throwing myself under the bus in an effort to seek fairness and logic. I don’t recommend you doing the same.

Unless HAI or someone else is successful in talking reason into the FAA on this matter, I’ll be plunking down $14,500 in December to have this useless instrument installed. And then I’ll pull the circuit breaker and let the panel stay dark so it doesn’t distract me from what’s outside the cockpit — which is where every VFR pilot should be looking.

And life will go on.

I’m fortunate in that even though it will take YEARS for me to earn that money back with Part 135 work, my cherry drying and frost work puts enough money in the bank to make the expenditure possible. Without that, I’d likely have to cease charter operations and possibly close up shop. I suspect others have found themselves in that situation. So much for government helping small businesses.

Thanks for your concern. Best wishes with your endeavors.

Maria

And that’s about all I have to say on the matter.