Getting Even Closer

I take (and pass) my Part 135 check ride

I spent most of yesterday with an FAA inspector named Bill. Bill is my POI for Part 135 operations. Frankly, I can’t remember what those letters stand for. But what they mean is that he’s my main man at the FAA in all Part 135 matters.

Yesterday was the second day this week I spent time with Bill. On Wednesday, I’d gone down to Scottsdale (again) to set up my Operating Specifications document on the FAA’s computer system. The FAA has been using this system for years for the airlines and decided to make it mandatory for the smaller operators, including Part 135 operators like me. Rather than put me on the old system and convert me over to the new one, they just set me up on the new one. That’s what we did Wednesday. It took about two hours that morning. Then Bill and I spend another hour reviewing my Statement of Compliance, which still needed a little work, and my MEL, which needed a lot of work.

I had lunch with Paul, my very first flight instructor, and headed back up to Wickenburg, stopping at a mall in a vain attempt to purchase a quality handbag. (Too much junk in stores these days, but I’ll whine about that in another entry.) I stopped at my office and my hangar to pick up a few things, then went home. By 4:00 PM, I was washing Alex the Bird’s cage and my car. (I figured that if I had the hose out for one, I may as well use it on both.) After dinner with Mike, I hit the keyboard to update my Statement of Compliance so it would be ready for Bill in the morning. I added about eight pages in four hours.

A word here about the Statement of Compliance. This required document explains, in detail, how my company, Flying M Air, LLC, will comply with all of the requirements of FARs part 119 and 135. In order to write this, I had to read every single paragraph in each of those parts, make a heading for it, and write up how I’d comply or, if it didn’t apply to my operation, why it didn’t apply. (I wrote “Not applicable: Flying M Air, LLC does not operate multi-engine aircraft” or “Not applicable: Flying M Air, LLC does not provide scheduled service under Part 121” more times than I’d like to count.) Wednesday evening was my third pass at the document. In each revision, I’d been asked to add more detail. So the document kept getting fatter and fatter. Obviously, writing a document like this isn’t a big deal for me — I write for a living. But I could imagine some people really struggling. And it does take time, something that is extremely precious to me.

I was pretty sure my appointment with Bill was for 10:00 AM yesterday. But I figured I’d better be at the hangar at 9:00 AM, just in case I’d gotten that wrong. That wasn’t a big problem, since nervousness about the impending check ride had me up half the night. By 4:00 AM I was ready to climb out of bed and start my day.

Bill’s trip to Wickenburg would include my base inspection as well as my check ride. That means I had to get certain documents required to be at my base of operations, all filed neatly in my hangar. Since none of them were currently there, I had some paperwork to do at the office. I went there first and spent some time photocopying documents and filing the originals in a nice file box I’d bought to store in my new storage closet in the hangar. I used hanging folders with tabs. Very neat and orderly.

I also printed out the Statement of Compliance v3.0 and put it in a binder. I got together copies of my LLC organization documents, too. Those would go to Bill.

I stopped at Screamer’s for a breakfast burrito on the way to the airport. Screamer’s makes the best breakfast burrito I’ve ever had.

I was at the airport by 8:45 AM. I pulled open the hangar door so the sun would come in and warm it up a bit, then stood around, eating my burrito, chatting with Chris as he pulled out his Piper Cub and prepared it for a flight. He taxied away while I began organizing the hangar. By 9:00 AM, I’d pulled Zero-Mike-Lima out onto the ramp. At 9:10 AM, when I was about 1/3 through my preflight, Bill rolled up in his government-issued car.

“I thought you were coming at 10,” I told him.

“I’m always early,” he said. “Well, not always,” he amended after a moment.

Fifty minutes early is very early, at least in my book.

He did the base inspection first. He came into the hangar and I showed him where everything was. But because I didn’t have a desk or table or chairs in there (although I have plenty of room, now that the stagecoach is finally gone), we adjourned to his car to review everything. That required me to make more than a few trips from his car to the hangar to retrieve paperwork, books, and other documents. He was parked pretty close to the hangar door on my side, so getting in and out of his car was a bit of a pain, but not a big deal.

“You need a desk in there,” he said to me.

I told him that I had a desk all ready to be put in there but it was in storage and I needed help getting it out. I told him that my husband was procrastinating about it. I also said that I’d have a better chance at getting the desk out of storage now that an FAA official had told me I needed it. (Of course, when I relayed this to Mike that evening, Mike didn’t believe Bill had said I needed the desk.)

Chris returned with the Cub and tucked it away in Ed’s hangar before Bill could get a look at it. Some people are just FAA-shy. I think Chris is one of them.

Bill and I made a list of the things I still needed to get together. He reviewed my Statement of Compliance, spot-checking a few problem areas. We found one typo and one paragraph that needed changing. He said I could probably finalize it for next week.

My ramp check came next. I asked him if it were true that the FAA could only ramp check commercial operators. (This is something that someone had claimed in a comment to one of my blog entries.) He laughed and said an FAA inspector could ramp check anyone he wanted to. And he proceeded to request all kinds of documents to prove airworthiness. The logbook entry for the last inspection was a sticky point, since the helicopter didn’t really have a last “inspection.” It had been inspected for airworthiness at 5.0 hours. It only had 27.4 hours on its Hobbs. Also, for some reason neither of us knew, the airworthiness certificate had an exception for the hydraulic controls.

Then we took a break so he could make some calls about the airworthiness certificate exemption and log book inspection entry. He spent some time returning phone calls while I finished my preflight.

Next came the check ride, oral part first. We sat in his car while he quizzed me about FAA regulations regarding Part 135 operations, FARs in general, aircraft-specific systems, and helicopter aerodynamics. It went on for about an hour and a half. I knew most of what he asked, although I did have some trouble with time-related items. For example, how many days you have before you have to report an aircraft malfunction (3) and how many days you have before you have to report an aircraft accident (10). I asked him why the FAA didn’t make all the times the same so they’d be easier to remember. He agreed (unofficially, of course) that the differences were stupid, but he said it was because the regulations had been drafted by different people.

That done, we went out to fly. I pulled Zero-Mike-Lima out onto the ramp and removed the ground handling gear. Bill did a thorough walk-around, peaking under the hood. He pointed out that my gearbox oil level looked low. I told him that it had been fine when the helicopter was level by the hangar and that it just looked low because it was cold and because it was parked on a slight slope. Every aircraft has its quirks and I was beginning to learn Zero-Mike-Lima’s.

He asked me to do a safety briefing, just like the one I’d do for my passengers. I did my usual, with two Part 135 items added: location and use of the fire extinguisher and location of the first aid kit. When I tried to demonstrate the door, he said he was familiar with it. “I’m going to show you anyway,” I said. “This is a check ride.” I wasn’t about to get fooled into skipping something I wasn’t supposed to skip.

We climbed in and buckled up. I started it up in two tries — it seems to take a lot of priming on cold mornings — and we settled down to warm it up. Bill started playing with my GPS. The plan had been to fly to Bagdad (a mining town about 50 miles northwest of Wickenburg not to be confused with a Middle East hot spot), but when he realized that neither Wickenburg nor Bagdad had instrument approaches, he decided we should fly to Prescott. I told him that I’d never flown an instrument approach and he assured me it would be easy, especially with the GPS to guide me. So we took off to the north.

It had become a windy day while we were taking care of business in my hangar and the car. The winds on the ground were about 10 to 12 knots and the winds aloft were at least 20 knots. This did not bother me in the least and I have my time at Papillon at the Grand Canyon to thank for that. I’d always been wind-shy — flying that little R22 in windy conditions was too much like piloting a cork on stormy seas. But last spring at the Grand Canyon, flying Bell 206L1s in winds that often gusted to 40 mph or more, turned me into a wind lover. “The wind is your friend,” someone had once told me. And they were right — a good, steady headwind is exactly what you need to get off the ground at high density altitude with a heavy load. But even though gusty and shifting winds could be challenging, when you deal with them enough, flying in them becomes second nature. You come to expect all the little things that could screw you up and this anticipation enables you to react quickly when they do. Frankly, I think flying in an environment like the Grand Canyon should be required for all professional helicopter pilots.

Bill and I chatted a bit about this during part of the flight and he pretty much agreed. But when he told me to deviate around a mountaintop I’d planned to fly right over, I realized that he wasn’t comfortable about the wind. Perhaps he’d spent too much time flying with pilots with less wind experience. Or perhaps he’d had a bit of bad wind experience himself. So we flew south past Peeples Valley and Wilhoit before getting close enough to Prescott to pick up the ATIS at 7000 feet.

Bill made the radio calls, requesting an ILS approach. Prescott tower gave us a squawk code and Bill punched it in for me before I could reach for the buttons. Then Prescott told us to call outbound from Drake. That meant they wanted us on the localizer approach (at least according to Bill; I knew nothing about this stuff since I didn’t have more than the required amount of instrument training to get my commercial ticket). I think Bill realized that they weren’t going to give us vectors — Prescott is a very busy tower — so he punched the localizer approach into the GPS and I turned to the northwest toward the Drake VOR, following the vectors in the GPS. All the time, the GPS mapped our progress on its moving map, which really impressed Bill. At Drake, I turned toward Humpty and Bill called the tower. When they asked how we would terminate the approach, he told them we’d do a low pass over Runway 21L. I just followed the vectors on the GPS toward some unmarked spot in the high desert. We did a procedure turn and started inbound. Five miles out, the tower told us to break off the approach before reaching the runway and turn to a heading of 120. Traffic was using Runway 12, with winds 100 at 15 knots and the tower didn’t want us in the way. So I descended as if I was going to land, then turned to the left just before reaching the wash (which was running). Once we cleared Prescott’s airspace, we headed south, back toward Wickenburg.

We did some hood work over Wagoner. I hate hood work. It makes me sick. I did okay, but not great. Fortunately, I didn’t get sick. But I did need to open the vent a little.

Then we crossed over the Weavers, did a low rotor RPM recovery, and began our search for a confined space landing zone. Personally, I think the spot he picked was way too easy — I routinely land in tougher off-airport locations than that. Then we did an approach to a pinnacle. No problem. On the way back to the airport, we overflew the hospital because he wanted to see LifeNet’s new helipad there. He agreed with me that it was a pretty confined space.

Back at the airport I did an autorotation to a power recovery on Runway 5. It was a non-event. With a 15-knot quartering headwind, only two people on board, and light fuel, Zero-Mike-Lima floated to the ground. I did a hovering autorotation on the taxiway, then hover-taxied back to the ramp with an impressive tailwind and parked.

“Good check ride,” Bill said.

Whew.

After I shut down, we went back to his car, which we were now referring to as his mobile office, and he filled out all the official FAA forms he had to fill out to document that I’d passed the check ride. Then he endorsed my logbook. Then he left. It was 2:30 PM.

I fueled up Zero-Mike-Lima, topping it off in preparation for flying on Saturday, and put it away. I took the rest of the day off. I’d earned it.

They’re with the FAA and They’re Here to Help

I meet with the FAA and am pleasantly surprised by how helpful they really are.

It’s an old joke among pilots. You’ve just landed at the airport and parked your aircraft and a man walks up to you. “I’m with the FAA and I’m here to help,” he says. That’s the joke. When the FAA approaches you on an airport ramp, they’re probably there to do a ramp check. It’s like getting pulled over by a cop who wants to check your paperwork and the condition of your car. How helpful is that?

Well, this isn’t what happened to me, but it was on my mind when I went to the FAA’s office in Scottsdale for a meeting yesterday morning. But before I continue that story, let me take a few steps back.

I’ve been running a Part 91 helicopter tour business since October 2001. “Part 91” refers to the part of the Federal Aviation Regulations (FARs) that covers the type of commercial operation I did. It’s highly restrictive, but not highly regulated. Basically, anyone with a commercial pilot certificate and an aircraft — even a rented one! — can become a Part 91 tour operator without so much as filing a form with the FAA.

Part 91 is highly restrictive. For example, I can take passengers on “sightseeing” tours within 25 statute miles of my starting point. Draw a circle with a 25 mile radius around Wickenburg and you can see my general operating area. On the east, it stops just short of Lake Pleasant. On the North, it’s around Peeples Valley. West, it doesn’t quite make Aguila. And south, puts me somewhere beyond that mountain range south of Vulture Peak. So I’ve had to routinely turn down requests for flights over Lake Pleasant, Bagdad mine, and various locations in the Bradshaw Mountains.

Part 91 does not allow me to land and discharge passengers. So although I could show people Gold Bar Mine from the air, I couldn’t land on that nice piece of road on the ridge and let them out to explore. I also could not pick up the odd miner (read that any way you like) who wanted to be picked up in Wickenburg and dropped off on a mountaintop twelve miles away. This hurt business, especially when I had Tristan’s 4-seat helicopter last season. The most painful was a local resident who wanted me to be his air taxi service and take him to places like Meteor Crater and Sedona. Those flights would have been extremely lucrative for me and a lot of fun. Having to turn them down was probably the prodding I needed to take the next steps in my tour business.

Those steps were to buy an R44 helicopter (a 4-seater) and to apply for a Part 135 Air Carrier Certificate.

Buying the helicopter was a tough first step. The first hurdle was getting a good deal on a ship that would meet my needs. Justin at Hillsboro Aviation helped me out there. He cut me a great deal on a brand new ship. The next hurdle was coming up with $25,000 in cash as a deposit. It took me a few weeks of scraping, aided by a nice royalty check, to get the money together. I placed the order on my birthday, June 30, and asked for the custom N-number N630ML.

Thus began the 6-month waiting period to get the helicopter. Robinson sells more helicopters than all other helicopter manufacturers combined, and their factory in Torrance, CA was in the process of being expanded. But I could wait 6 months. It would take me that long to scrape up the rest of the down payment and arrange for a loan. Besides, who wants to fly a helicopter in Wickenburg in the summer? Air conditioning was not an option.

To make the helicopter pay for itself — at least in part — I’d have to expand the tour business beyond the 25-mile, no stopping limitations set by Part 91. So in October, I applied for a Single Pilot Part 135 certificate.

Part 135 has three types of certificates. The basic certificate is for a large operation, like Papillon, for example, which has multiple helicopters and multiple pilots. I was a Part 135 pilot for Papillon’s Part 135 operation. Then there’s a single pilot-in-command certificate, which is for operations that have multiple aircraft and pilots but only one pilot who will act as pilot-in-command (PIC). This is primarily for operations with multi-pilot aircraft so there’s a handful of second-in-command (SIC) pilots to fly with the PIC. Finally, there’s a single-pilot Part 135 certificate. That’s for organizations like mine. One pilot will be doing all the flying in at least one aircraft that’s owned or leased.

Although I could apply for a basic Part 135 certificate, there’s no reason to. It’s a lot more paperwork and it takes a lot longer for the FAA to process. And there’s absolutely no benefit for me, since I’m the only pilot.

The application process is a bit lengthy. First, you go to the local Flight Standards District Office (FSDO, pronounced fizdoe) and watch a video that outlines the certification process. I did that last year, in the summer, when I was toying with the idea of applying. (That was an expensive trip to Scottsdale. I wound up buying a new car while I was down there.) I was hoping to lease Tristan’s helicopter for the season and when he didn’t come through right away, I abandoned the idea of applying. But the FSDO sent me a package of materials to get started anyway and I kept it. So when I decided to get off my butt and apply, I had everything I needed. I filled out the Pre-application Statement of Intent (PASI) form and sent it in along with a cover letter. That was on October 18. And then I waited.

One thing I know about government agencies is that they sometimes need to be gently reminded that you’re waiting for something. (I worked for the New York City Comptroller’s Office for five years, so I know exactly how bad civil servants can be.) So on November 3, I called the FSDO to see how far my form had progressed. After a bit of research, I was told that my case had been turned over to Charlie for processing. But Charlie wasn’t in. I should call back tomorrow.

I called back. Charlie didn’t know anything about it and didn’t seem too happy to hear about it. He asked me if I knew that the process usually takes three to four months, possibly five. I told him, choosing my words carefully, that I’d heard that it could take that long. He told me I’d need a Statement of Compliance and that usually took a very long time to prepare. And a HazMat training program. I asked him what the next step was. He said a pre-application meeting. And then he did something that surprised me: he offered to meet with me the following Monday morning at 9 AM. I jumped on the suggestion and agreed.

Over the weekend, I did my homework. I spent all of Saturday working on a Statement of Compliance so it would apply to Flying M Air. It took most of the day and required me to read every paragraph of FAR Parts 119 and 135, understand them (the tricky part), and determine whether they applied to my operation and, if so, how. I learned a lot about the FARs that day. When I was finished, the document was 47 pages long. I included a title page and table of contents, along with headers and footers, so it would look professional and be easy to read. I also went through all the documents I could find in my package and online — the Atlanta FSDO’s Web site was extremely helpful — to learn what I could about the process. I wrote down questions. I wrote down assumptions. I got together additional documents, including my resume, a formal application letter, a copy of my purchase agreement for the helicopter, and a summary of my logged helicopter hours.

On Monday morning, after printing the Statement of Compliance and other documents at my office (no printer at home), I hopped in the car and began the long drive to Scottsdale. It had rained overnight and was still raining in parts of Scottsdale. Arizona drivers are completely clueless about driving in the rain. Fortunately, they tend to be more cautious than less. Unfortunately, that means they drive a lot slower. So it took me a full 90 minutes to get to North Perimeter Road, off Princess Blvd. I got a parking space right out front and went in.

After I signed in, Charlie was summoned. He didn’t look happy. He said, “I’m not the person you’ll be working with. But I’ll take you to that person.”

I was already being shuffled around. I remembered my audit days at the City of New York, when the civil service shuffle was a part of my daily life. But I could deal with it and would.

He took me through a maze of cubicles and stopped in front of one, where a man was working at a computer. He looked up. “This is Maria,” Charlie said. “I told you about her this morning.” He turned to me. “This is Bill.” And then he left.

Bill looked flustered. He admitted that the first time he’d heard about me was that morning and that he didn’t realize I was coming in that day. Mentally, I prepared to be dismissed. But he grabbed a white binder and led me to a conference room — the same room I’d seen the video in over a year before. There was a big white board on the wall that listed all the Part 135 certificates in progress. Flying M Air was the second from the bottom, with a date of 10/20/04. That was a good sign. I was on the board.

The binder he’d brought with him was not mine. He left me in the room while he searched for mine. He came back empty-handed twice, but vowed to find it. After about 15 minutes, he returned with the binder and another man, Rhuno. Rhuno, it turned out, was his boss. At first, I thought he was only going to stay in the meeting for a while, but he wound up staying for the whole meeting.

Bill went over a extremely large, scary-looking flowchart that described the Part 135 process. And I started pulling documents out of my briefcase. The Statement of Compliance. The formal application letter. My resume. My flight hours. The helicopter purchase documents. They were surprised. I don’t think many applicants bring so many documents with them on the first meeting. But I was driving down from Wickenburg and didn’t want to make the drive more often than necessary. I also wanted to do my part to keep the ball in their court, minimizing delays.

Bill looked at the flowchart. In that one meeting, we’d made our way through about 1/3 of it. He and Rhuno got other documents for me. The HazMat training program. (Even though I won’t carry hazardous materials, I have to have a program that identifies them so I won’t inadvertently take them on board. HazMat now falls under the Transportation Security Administration (TSA), so my program will have to be approved by them.) A sample Operations Specifications. A minimum equipment list (MEL) for R44 helicopters. I don’t think they could have been any more helpful. I left with twice as much paper as I came with, even after dropping off my 47-page Statement of Compliance.

Along the way, I asked Rhuno how long he thought the process would take. He said that since I’d obviously done my homework and a Single-Pilot certification was usually a lot faster and easier than a basic Part 135.

“What do you think?” I asked meekly. “Is it possible to have it done by January?”

“Sure,” he said, meaning it. Later in the meeting, they led me to believe that they might be able to have everything done except the aircraft inspection before my helicopter arrived. And that’s only a month from now!

We had a great talk at the end of the meeting. They were surprised that I was the only tour operator in Wickenburg. I told them a little about Wickenburg’s economy and the difficulty in selling tours to people who were either conservative about their entertainment or on a low budget. I told him I planned to supplement my Part 135 work with Part 91 rides at special events.

In discussing Wickenburg’s growth, I mentioned Prop 421 and how glad I was that it had failed. Rhuno said it was a good thing it had failed. He said that zoning was vital in growing communities. He compared Carefree to Cave Creek, two communities, side by side. From the beginning, Carefree had always had strict zoning while Cave Creek did not. I’m familiar with the two towns. Carefree is a much nice community with higher property values and a more pleasant atmosphere. I’d much rather see Wickenburg get like Carefree than its neighbor.

Rhuno had heard about my work at Wickenburg airport, back when I had the fuel manager’s contract. He’d heard a lot of good things about the terminal’s renovations and new services there. I told him I’d given it up because of employee problems and an overload of frustrations. I also told him my honest opinion, which is that the town doesn’t care much about the airport. I told him about the jets that come and go all winter long and the big money that comes to town with them. More money arrives in Wickenburg by jet than by car. (My favorite story is the family that arrived last December in three Lear jets for their annual family reunion/vacation at Rancho de los Caballeros. The Dad handed over a check for $30,000 and told the los Cab guy to tell him when that ran out. And I’m not making this up. I was there.) You think the town would make the point of entry for these people a little more pleasing? You think they’d provide some additional services — like a fuel truck — to help service the jets that bring them? You think they’d try to get a restaurant built at the airport to attract more fly-in visitors? The unfortunate answer is No. And that’s why Wickenburg loses so much Jet traffic to Glendale, Deer Valley, and Scottsdale. The pilots would rather stay in these metro areas — and fill up while they’re there — than what they see as neglected outpost of civilization. Remember, they’re basing their opinion of Wickenburg on what they see at the airport and it just doesn’t stack up to what they see elsewhere.

Don’t let me get started.

Anyway, when I left my meeting with Bill and Rhuno, I was extremely impressed and happy. I’d started my certification process late, but it looked as if I’d get it all done by the time the season got up to full swing. The FAA wasn’t trying to hold me back — as I’d thought it might. It was trying to help. And I drove away from the Scottsdale FSDO with new respect for the folks who control aviation in this country.