Minimum Safe Altitude - school wants to fire me

[anderse]

I have a tricky issue I need help.
Currently, I work in Florida as an FAA Flight Instructor.

I currently have five students PPL in a Cessna 172 and made ​​a big mistake that could cost me the job.

During Engine Out Procedures, I have a couple of times with each student, flown below the minimum safe altitude of 500 ft. My student did this on his 141-EOC with the Chief Pilot at school, and now I'm temporarily suspended from the position of my anticipation of a formal meeting with the school.

As you probably know, Florida is relatively flat, and when I have done Engine Out Procedures of open and flat fields, I have always made ​​sure that there have been buildings, power lines, animals or people nearby.

Quote 91.119 (c) of 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.
Based on the definition of "sparsely Populated Areas", I can say that I have not done anything wrong?

[AC788]

Not sure about the FARs, but in Canada, there is a clause in the CARs that allow you to go below the minimum altitude of 500' for the purpose of flight training. Perhaps the FAA has a similar regulation?

[cavortingcheetah]

Quote:

(when I have done Engine Out Procedures of open and flat fields, I have always made ​​sure that there have been buildings, power lines, animals or people nearby.)

Perhaps therein lies the CPs' less than enthusiastic attitude towards the training technique.

On a more serious note though, perhaps the problem lies not so much in any interpretation of regulations but rather that the student had not been sufficiently enjoined not to practice forced landings below 500ft agl. What you might demonstrate as an instructor, with the student, is not necessarily at all what he should attempt solo?

[Genghis the Engineer]

Comments:

(1) The OP doesn't seem to know the definition of MSA

(2) The Chief Instructor does seem to share the common, but in my opinion very wrong, view that you can effectively practice engine failures without going below 500ft agl.

(3) Much (not quite all) of the world has the 500MSD rule, which the OP seems to have been following quite legally. (And I'm sure that his post saying he was careful to always have something nearby to be within 500ft of is a typing error). In the UK it is part of what we call "Rule 5", but that is a solely UK definition.

(4) However, what did the flying school have in its own rules (known in the UK as the FOB or Flying Order Book)? If these clearly said not below 500ft AGL, then the OP was in breach of his conditions of employment.

(5) Overall, it seems to me that the best bet is to grovel, apologise, promise not to do it again, and ask for clear clarification of the working rules at that school.

G

[Cobalt]

The more important question is how to get through the meeting - they clearly think you did something wrong, and going in there with the regs saying you are right, even if it is true, is unlikely going to help...

I'd try to find out exactly what they think you did wrong... The student did it over a village, saying you told him it was ok? --> Admit you didn't teach him properly only to do that over wide open spaces, won't happen again.

Is it that you violated some internal rule? --> Fess up overlooking it, forgot OPS rule when reviewing the FAR, grovel, won't happen again...

Sorry, I know this sounds patronising (um, patronizing), I don't mean it that way... the more you know before you go into the meeting, the better you can prepare...


[Edit: Just saw Genghis said pretty much the same...]

[mad_jock]

Uk is one of the very few that do actually allow you below 500ft agl as long as your not near anything.

ICAO has the 500ft AGL unless landing and the UK has filed a difference.

I completely agree though that you can't teach PFL's properly unless you go below 500ft.

[pudoc]

I completely agree though that you can't teach PFL's properly unless you go below 500ft.

Not forgetting that flying fast over a river at 500ft isn't very fun.

[mad_jock]

Or particularly sensable.

There are valid reasons to go below 500ft in my book.

Fannying around for fun isn't one of them.

[pudoc]

I'm surprised you thought I was serious!!

[mad_jock]

Unfortunately your statement rings true for a small minority.

[jackcarls0n]

if your at pea then i guess bad news...
but either ways going below 500 feet is a no no at many schools..

[student88]

Is the issue they have that you broke the 500ft rule or is it more of a personal vendetta?

It's amazing how quickly a company will find a sackable offence just because you don't fit the profile.

Either way I wish you good luck.

[Cows getting bigger]

Ghengis, be careful. FAR 91.199 clearly describes the 500ft rule (ie the equivalent of UK Rules 5 & 6) as "Minimum safe altitudes"

[Genghis the Engineer]

There isn't a 91.199 (http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&rgn=div5&view=text&node=14:2.0.1.3.10&idno=14).

But fair point, 91.119 does say "altitude above", which the rest of us call "height" !

G

[Trolle]

Based on the definition of "sparsely Populated Areas", I can say that I have not done anything wrong?

Basically, as a pilot you get to consider:
1. Was it legal (per the FARs)?
2. Was it safe?

You answered your own question, if you stayed away from the cows and power lines then it was legal. However, if your school has a policy that you can't take students lower than 500 ft. then you basically busted their rule and should state why you did it, how you learned from this incident and that it won't repeat itself. Be humble, learn from it, move on, and possibly use this as a discussion point for an airline interview some day. No need for a school to fire you for this, at least not in my opinion.

Safety is another argument that can't necessarily be won by referring to a book. I would argue that it was safe and I have let my students go below 500 feet on several occasions. It's good practice for them to see what the view is outside their window below 500 feet.

On a side note, why didn't the chief pilot brief the student before departure, or state that of course all the school's rules will be followed on the flight, meaning the 500 foot rule. Easy way to avoid that situation.

I guess the questions are:
Did the school have a 500 foot rule in place
Did you know the school had the rule in place
Did the student know the school had the rule in place

I had an issue once as an instructor with a flight school owner. I called the AOPA and discussed it with a lawyer who told me my rights and how to proceed. You could call them and just hear what they have to say.

[B2N2]

An alternative way to safely practice these below 500' is to go to one of the many non towered airports in Florida and practice from overhead.
Obviously with making all the appropriate radio calls and keeping a sharp look-out for traffic.

I agree there is little training benefit to the student if they never see the result; however there is an inherent risk to descending that low and a practice emergency may turn into a real one if the student jams the throttle forward in a go-around and causes a rich-cut in a carbureted engine.

Realism vs acceptable risk.
You don't take them into an actual cloud either to practice 180 degree turns on instruments do you?
Practice and simualtion have the inherent short coming that they only duplicate the real thing to a certain extent.

That being said, there is nothing illegal in flying below 500' in a sparsely populated area.
The Chief Pilot should have briefed the applicant prior to the check as to what was expected and as to when to initiate the go-around.
The student may very well just have been waiting for the "word" and as a result of that descended below 500'.

I do many 141 EOC checks and I would never consider that a reason for failure. I need to be satisfied that the student can make the field, then I will let them know to initiate the go-around.
On occasion, if we end up low, I will operate the throttle/prop/mixture on the go-around.

But as stated earlier, you may have been "FAR-legal" but not "school-legal" in which case you don't have a leg to stand on.
And this being real-life, and real-life not being fair; you will never win a battle against the Chief Pilot/Instructor.
They want it this way, you did it that way...end of story.
Not something you should loose your job over but if you do, send me a PM.

[Shunter]

If you can't go sub-500ft without getting grief one really does wonder how effectively you can teach PFLs. Back in the day when I did my PPL we used to take it down to around 10ft. Whilst a real engine out is very different (way more draggy with a windmilling prop) when it did happen it was almost a non-issue.

Sometime later when I did my instructor rating the school commented that the question had been asked of the CAA how many instructors had been prosecuted as a result of low flying complaints as a result of PFLs, as no matter how far in the sticks you think you are people seem to have a habit of strolling out of the woods with their dog/horse as you come over the fence. Anyway... the answer was zero.

[Genghis the Engineer]

Just a thought - on numerous tests and lessons over the years I have heard some phrase along the lines of "and I will be responsible for compliance with the low flying regulations".

Depending upon what your student said, it's possible he was simply waiting to be told to go around? Let's face it, in flying a PFL, their mind should be on the reality of the exercise, not on the artificial aspect that has them put power on once the field is clearly defined.

G

[Ollie Onion]

I am with Genghis here, isn't it the instructor/examiner that should initiate the go-around when performing a PFL. I remember during my training I was told time and time again that it was up to the examiner to initiate the go around by calling it. When I was an instructor this is what I always did, generally I wouldn't allow the student to go below 500', when I wanted them to go all the way to the ground then I knew the location of a couple of 'little' grass airfields that I would get them to set up for a PFL, always shocked the hell out of them when we got to 500' and I would just say 'continue to a landing thankyou' :)

Your big problem here will be regardless of the FAA regs, what does the school operating manual state. Even if the regs allow you below 500' in certain circumstances the school rules may not! If the school doesn't specify then I would just argue you were legal and that the training benefit by going below 500' was worthwhile in certain circumstances.

Good Luck