What’s required…and what’s smart.

I recently got into a disagreement with another helicopter operator about the requirement for emergency locator transmitters (ELTs).

An ELT is a device that sends out a signal in the event of an unplanned landing or crash. Rescuers can use the signal to find the aircraft. Most ELTs are activated by impact, but they can also be manually turned on, either by a switch on the unit itself or a switch wired into the cockpit of the aircraft. My helicopter’s ELT has impact activation, a switch on the unit, and a switch inside the cockpit.

An ELT is a piece of equipment you hope you never need, but one you pray is working right when you do need it.

Who Needs It?

FAR Part 91.207 covers the requirement of an ELT. It starts out like this:

(a) Except as provided in paragraphs (e) and (f) of this section, no person may operate a U.S.-registered civil airplane unless–

(1) There is attached to the airplane an approved automatic type emergency locator transmitter that is in operable condition for the following operations, except that after June 21, 1995, an emergency locator transmitter that meets the requirements of TSO-C91 may not be used for new installations:

(i) Those operations governed by the supplemental air carrier and commercial operator rules of parts 121 and 125;

(ii) Charter flights governed by the domestic and flag air carrier rules of part 121 of this chapter; and

(iii) Operations governed by part 135 of this chapter; or

(2) For operations other than those specified in paragraph (a)(1) of this section, there must be attached to the airplane an approved personal type or an approved automatic type emergency locator transmitter that is in operable condition, except that after June 21, 1995, an emergency locator transmitter that meets the requirements of TSO-C91 may not be used for new installations.

This is the FAA’s way of saying that you can’t operate an airplane without an ELT attached unless the flight meets the requirements of paragraphs (e) and (f):

(e) Notwithstanding paragraph (a) of this section, a person may–

(1) Ferry a newly acquired airplane from the place where possession of it was taken to a place where the emergency locator transmitter is to be installed; and

(2) Ferry an airplane with an inoperative emergency locator transmitter from a place where repairs or replacements cannot be made to a place where they can be made.

No person other than required crewmembers may be carried aboard an airplane being ferried under paragraph (e) of this section.

(f) Paragraph (a) of this section does not apply to–

(1) Before January 1, 2004, turbojet-powered aircraft;

(2) Aircraft while engaged in scheduled flights by scheduled air carriers;

(3) Aircraft while engaged in training operations conducted entirely within a 50-nautical mile radius of the airport from which such local flight operations began;

(4) Aircraft while engaged in flight operations incident to design and testing;

(5) New aircraft while engaged in flight operations incident to their manufacture, preparation, and delivery;

(6) Aircraft while engaged in flight operations incident to the aerial application of chemicals and other substances for agricultural purposes;

(7) Aircraft certificated by the Administrator for research and development purposes;

(8) Aircraft while used for showing compliance with regulations, crew training, exhibition, air racing, or market surveys;

(9) Aircraft equipped to carry not more than one person.

(10) An aircraft during any period for which the transmitter has been temporarily removed for inspection, repair, modification, or replacement, subject to the following:

(i) No person may operate the aircraft unless the aircraft records contain an entry which includes the date of initial removal, the make, model, serial number, and reason for removing the transmitter, and a placard located in view of the pilot to show “ELT not installed.”

(ii) No person may operate the aircraft more than 90 days after the ELT is initially removed from the aircraft; and

(11) On and after January 1, 2004, aircraft with a maximum payload capacity of more than 18,000 pounds when used in air transportation.

Our argument centered around the point that this operator uses his helicopter for training, including cross-country flights in excess of 50 miles ((f)(3) above). So under the above rules, it seemed to me that he should be required to have an ELT on board. He argued that the rules applied to airplanes, not helicopters. And although the wording of the rule certainly supported his claim, I couldn’t believe that the FAA would exempt helicopters from the requirement.

So a few days later, while taking my Part 135 check ride, I asked my examiner. Actually, he asked me. And I told him about the disagreement I was having with my unnamed friend — I didn’t want to get him in trouble — and that I thought an ELT was required.

I was wrong. Helicopters are not required to have an ELT on board unless they’re doing Part 135 operations. [Note: The previous edit was made after a reader, Mark from Teterboro, confirmed that helicopters are not required to have ELTs, even for Part 135 operations. Read our discussion in the comments for this post to get the details. Thanks very much to Mark for taking the time to correct this.]

Personally, I think this is nutty. I wouldn’t dream of flying a helicopter some of the places I fly without that piece of potentially life-saving equipment on board. I don’t spend most of my flying time buzzing around a city or the suburbs where someone would notice a helicopter on the ground in their backyard or local park. I fly places where there aren’t paved roads for miles and miles. For example, on a straight-line flight from Wickenburg to Laughlin, NV, I fly over only two paved roads in a distance of 80 miles. And there ain’t many unpaved roads, houses, or even cows under me, either.

But the regs are the regs, so if my ELT broke or simply stopped functioning, I could continue to fly legally under part 91 as long as I wanted to. Would I do that? No.

The Rest of the Reg

Part 91.207 also covers requirements for mounting the ELT, testing it, and replacing its batteries. All of this maintenance stuff should be clearly logged in your Aircraft Log book, just in case someone comes along to take a peek at it — perhaps as part of a ramp check.

It’s another interesting example of how helicopter regulations differ from airplane regulations.

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.

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

The 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.

The 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:

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.