Sikorsky FireHawk
Ok Nick,
I will readily admit I will not buy one....however you made a statement that purported the per hour cost of a Firehawk to be approximately 1000 USD per hour.
I challenged that statement and stated it was not correct. I suggested you could convince me by putting out how you arrived at that figure and still pay for training, insurance, personnel costs, utility bills, HAI entrance fees, retirement gifts, and Secretary Appreciation day flowers and candy.
You care not to do that...thus I can only assume you do not have those figures at hand and thus they were not considered in your calculations or those of the county when justifying the 1000 USD figure.
At three bucks a gallon....the fuel costs alone are going to be quite significant....and Winged S parts I know are not cheap. Throw in the pilots wages....County Bureaucratic scale with fully funded pension and such....with other benefits....the 1000 USD figure is not achieveable....by anyone....much less the government.
Also...as long as the state and county governments are building airforces....thus cutting out contract revenues for private operators....there is no reason for private contractors to dedicate such investment into assets that might be under bid by public use only air operations who do not have to show their real costs and fund themselves at great cost to the taxpayer.
I will readily admit I will not buy one....however you made a statement that purported the per hour cost of a Firehawk to be approximately 1000 USD per hour.
I challenged that statement and stated it was not correct. I suggested you could convince me by putting out how you arrived at that figure and still pay for training, insurance, personnel costs, utility bills, HAI entrance fees, retirement gifts, and Secretary Appreciation day flowers and candy.
You care not to do that...thus I can only assume you do not have those figures at hand and thus they were not considered in your calculations or those of the county when justifying the 1000 USD figure.
At three bucks a gallon....the fuel costs alone are going to be quite significant....and Winged S parts I know are not cheap. Throw in the pilots wages....County Bureaucratic scale with fully funded pension and such....with other benefits....the 1000 USD figure is not achieveable....by anyone....much less the government.
Also...as long as the state and county governments are building airforces....thus cutting out contract revenues for private operators....there is no reason for private contractors to dedicate such investment into assets that might be under bid by public use only air operations who do not have to show their real costs and fund themselves at great cost to the taxpayer.
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It would help you immensly, SASless, if you read the other posts before you wrote your responses. The $1000 per hour is in rotormatic's post, as the contracted maintenance rate with the county of LA. You don't have to believe it, but it would be nice if at least you read it.
Of course, just reading it is not enough, you'd have to understand it. It is the maintenance cost, so that fuel, pilots, insurance and lots of other stuff is not included.
Of course, just reading it is not enough, you'd have to understand it. It is the maintenance cost, so that fuel, pilots, insurance and lots of other stuff is not included.
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Table I: Army Mission Mix Specification
Blackhawk T700 Mission profile
Troop Assault 11.40
Resupplying 7.40
Aeromed Evacuation 23.30
Replacing Units 6.70
Transport of Recon. 5.20
Reinforce/Reposition 10.50
Troop Extraction 5.80
Aerial Command Post 4.40
Sling Load 8.40
Training 16.90
Totals 100.0
All values in % of engine operating life
Note sling load (external load) only 8.4% of operating proflie.
What % is the RHL profile of the Firehawk?
Was the Firehawk mission profile evaluated during the TC process?
Blackhawk T700 Mission profile
Troop Assault 11.40
Resupplying 7.40
Aeromed Evacuation 23.30
Replacing Units 6.70
Transport of Recon. 5.20
Reinforce/Reposition 10.50
Troop Extraction 5.80
Aerial Command Post 4.40
Sling Load 8.40
Training 16.90
Totals 100.0
All values in % of engine operating life
Note sling load (external load) only 8.4% of operating proflie.
What % is the RHL profile of the Firehawk?
Was the Firehawk mission profile evaluated during the TC process?
Last edited by rotormatic; 30th Sep 2005 at 18:45.
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Let me educate you:
What he is saying is that the Firehawk is now doing 90% of its work in the external load/ high lift cycle enviorment and the mission profile was only planned for 8.4% and that they have no plans to adjust for that. Such as the S-61 and the Bell 214B have done.
Look at the S-92. It can only do 4 lifts an hour I'm told.
Something has to give.
What he is saying is that the Firehawk is now doing 90% of its work in the external load/ high lift cycle enviorment and the mission profile was only planned for 8.4% and that they have no plans to adjust for that. Such as the S-61 and the Bell 214B have done.
Look at the S-92. It can only do 4 lifts an hour I'm told.
Something has to give.
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Nick
I always read your posts with interest but have one question.
You mentioned that since the L.A. county helicopters are "public use" they need no certificate (I paraphrased here) but surely they are operated under Part 133 and as such "has a valid standard or restricted category airworthines certificate" (Pt133.19 (a) (3))
Most of my companies firefighting helicopters are contracted to domestic government agencies and require either a restricted or standard category TC.
As an aside, to put the "R" in RHL try logging
I always read your posts with interest but have one question.
You mentioned that since the L.A. county helicopters are "public use" they need no certificate (I paraphrased here) but surely they are operated under Part 133 and as such "has a valid standard or restricted category airworthines certificate" (Pt133.19 (a) (3))
Most of my companies firefighting helicopters are contracted to domestic government agencies and require either a restricted or standard category TC.
As an aside, to put the "R" in RHL try logging
Mustangpilot....
Any idea of what the real cost per hour would look like on the Firehawk if all costs were added in to the direct hourly costs quoted by Rotormatic et al....and not Nick Lappos?
I wonder what the fuel costs alone for the FireHawk would be?
You reckon the State of California or LA County can be as cost effective as a private operator in the Southern California area is if computed on a cost per gallon or cost per flying hour?
If one assigns only the amount of overhead costs to the fire fighting when the aircraft is not used for other work....meaning the fire costs would accept all other overhead costs and not share the costs on a simple prorata basis....I can see no way the Fire only aircraft can be cost effective. Do you?
Using Sikorsky Data found doing a google search...and amending the fuel costs to 3.00 USD per gallon I come up with a per hour direct operating cost of 1430 USD before any other costs are applied. That number includes fuel, lubricants, Retirement Parts Cost, Labor rate of 54 USD, Overhaul and Repairs, and Engine Overhaul. (All assuming no additional wear and tear from doing repetitive external lifts beyond the 8.4% figure originally calculated for the aircraft I would assume.)
Any idea of what the real cost per hour would look like on the Firehawk if all costs were added in to the direct hourly costs quoted by Rotormatic et al....and not Nick Lappos?
I wonder what the fuel costs alone for the FireHawk would be?
You reckon the State of California or LA County can be as cost effective as a private operator in the Southern California area is if computed on a cost per gallon or cost per flying hour?
If one assigns only the amount of overhead costs to the fire fighting when the aircraft is not used for other work....meaning the fire costs would accept all other overhead costs and not share the costs on a simple prorata basis....I can see no way the Fire only aircraft can be cost effective. Do you?
Using Sikorsky Data found doing a google search...and amending the fuel costs to 3.00 USD per gallon I come up with a per hour direct operating cost of 1430 USD before any other costs are applied. That number includes fuel, lubricants, Retirement Parts Cost, Labor rate of 54 USD, Overhaul and Repairs, and Engine Overhaul. (All assuming no additional wear and tear from doing repetitive external lifts beyond the 8.4% figure originally calculated for the aircraft I would assume.)
Last edited by SASless; 30th Sep 2005 at 20:31.
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PT6ER,
The concept of public use is important and not very well understood. The US Army has to ask nobody's permission when it designs, builds, tests, produces and operates entire types of aircraft. The FAA cannot ask what the blades are made of, nor can they ask the Army pilots what type of license they have. That is because the Army is in "public use" and actually above the reach of the FAA. Now that that has sunk in, substitute for "Army" in that statement "LA County" or "Fargo, ND" or "State of Mississippi" and you get the drift.
In short, any FAR that the US Army or LA County chooses to operate to is voluntary.
rotormatic,
When you can design build or test a helicopter, you will be qualified to understand the stuff you publish. Until then, try to think really hard, really, really hard "Who designed the Black Hawk?" Then think really really hard (even harder, maybe) "Who guaranteed the maintemance costs that are part of the contract with LA County?"
Now if you really really thought about it, you might realize that the guys who wrote that contract are the same as the people who know the Black Hawk better that anybody, even you. That means they already thought about those questions (the ones you are still thinking about). That also means they are much more into the problem than your ten-words-deep understanding of fatigue life, or cycles.
When someone reads the book to people who wrote the book, its like the time I showed my Dad how to shoot pool.
The concept of public use is important and not very well understood. The US Army has to ask nobody's permission when it designs, builds, tests, produces and operates entire types of aircraft. The FAA cannot ask what the blades are made of, nor can they ask the Army pilots what type of license they have. That is because the Army is in "public use" and actually above the reach of the FAA. Now that that has sunk in, substitute for "Army" in that statement "LA County" or "Fargo, ND" or "State of Mississippi" and you get the drift.
In short, any FAR that the US Army or LA County chooses to operate to is voluntary.
rotormatic,
When you can design build or test a helicopter, you will be qualified to understand the stuff you publish. Until then, try to think really hard, really, really hard "Who designed the Black Hawk?" Then think really really hard (even harder, maybe) "Who guaranteed the maintemance costs that are part of the contract with LA County?"
Now if you really really thought about it, you might realize that the guys who wrote that contract are the same as the people who know the Black Hawk better that anybody, even you. That means they already thought about those questions (the ones you are still thinking about). That also means they are much more into the problem than your ten-words-deep understanding of fatigue life, or cycles.
When someone reads the book to people who wrote the book, its like the time I showed my Dad how to shoot pool.
Nick,
The USFS rates the S-70 at a fuel burn of 160 gph, an S-61 at 170 gph, the S-70 shows a load capability of 9,000 pounds and the S-61 (Carson's) at 11,000 pounds. The difference in revenue shows the 61 earning 123 USD more than the S-70 (2885 USD vice 2762 USD) which would suggest the 123 USD would more than pay for the extra ten gallons of fuel. That begs the question of what the Direct Cost for the S-61 is vice the S-70 and whether the LA County folks would be better off by contracting with Carson's vice running their own operation.
Link to a discussion of the Firehawk by an LA Pilot.
http://www.aviationtoday.com/cgi/rw/...03firehawk.htm
The USFS rates the S-70 at a fuel burn of 160 gph, an S-61 at 170 gph, the S-70 shows a load capability of 9,000 pounds and the S-61 (Carson's) at 11,000 pounds. The difference in revenue shows the 61 earning 123 USD more than the S-70 (2885 USD vice 2762 USD) which would suggest the 123 USD would more than pay for the extra ten gallons of fuel. That begs the question of what the Direct Cost for the S-61 is vice the S-70 and whether the LA County folks would be better off by contracting with Carson's vice running their own operation.
Link to a discussion of the Firehawk by an LA Pilot.
http://www.aviationtoday.com/cgi/rw/...03firehawk.htm
Last edited by SASless; 30th Sep 2005 at 20:55.
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According to the FAA website, Type Certificate Data Sheet H5NE covers the S70A It is in the restricted category. The Sikorsky homepage designates the Firehawk as an S70A but not knowing the serial numbers it is hard to see what applies.
What fun this is eh?
Generally, it would appear, having a dedicated single use flight department is more expensive than the alternative and that is what makes fractional ownership so appealing. Therefore it is hard to believe that it was cheaper for LA County to purchase and run S70A Firehawks against renting, on a seasonal basis, a helicopter that is used on other duties whilst not firefighting and therefore amortizing costs over a longe period. Do they use them for other duties? Big boys like their toys as well and that is a big factor even in our highly cost conscious world.
I have to 'fess up that I am biased against self ownership since I would prefer the customer rent my helicopters. So there is my freshly ground axe out in the open
What fun this is eh?
Generally, it would appear, having a dedicated single use flight department is more expensive than the alternative and that is what makes fractional ownership so appealing. Therefore it is hard to believe that it was cheaper for LA County to purchase and run S70A Firehawks against renting, on a seasonal basis, a helicopter that is used on other duties whilst not firefighting and therefore amortizing costs over a longe period. Do they use them for other duties? Big boys like their toys as well and that is a big factor even in our highly cost conscious world.
I have to 'fess up that I am biased against self ownership since I would prefer the customer rent my helicopters. So there is my freshly ground axe out in the open
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You guys miss the point, I think. Maybe you should go downtown and tell your fire departments to sell their fire engines, you know some people with buckets and axes, huh?
Don't the LA people get a vote? Oh, yea, they do, and they use a county fire department to fight fires, with a multiple use helicopter.
Knowing those LA County guys as I do, and the great job they do, I think they have more in common with SASless than he would admit.
Regarding a "right" to have contractors bid on every/any thing, I don't think so. I personally want cops, firemen, prison guards, and army guys working for the public, mostly because I don't want any cheap-ass lowest bid contractor thinking that my home on a hillside is better protected with a run-out 40 year old design.
Anyone who thinks a Black Hawk isn't better suited doesn't earn my confidence! The question that LA County has answered is the one they ask regularly, what can be trusted to keep the fire off my family's butt? They answer it yearly when the approve their budget, and the Fire Hawks they buy.
The forestry service airplane structural failures (how many, three?)have shown us how bad contractors are at actually delivering a safe dependable product, haven't they?
Don't the LA people get a vote? Oh, yea, they do, and they use a county fire department to fight fires, with a multiple use helicopter.
Knowing those LA County guys as I do, and the great job they do, I think they have more in common with SASless than he would admit.
Regarding a "right" to have contractors bid on every/any thing, I don't think so. I personally want cops, firemen, prison guards, and army guys working for the public, mostly because I don't want any cheap-ass lowest bid contractor thinking that my home on a hillside is better protected with a run-out 40 year old design.
Anyone who thinks a Black Hawk isn't better suited doesn't earn my confidence! The question that LA County has answered is the one they ask regularly, what can be trusted to keep the fire off my family's butt? They answer it yearly when the approve their budget, and the Fire Hawks they buy.
The forestry service airplane structural failures (how many, three?)have shown us how bad contractors are at actually delivering a safe dependable product, haven't they?
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I believe the CL415 that came apart in France was government owned wasn't it?
As for firefighters, a lot of California's rural firefighting is already contracted out, all be it to another state entity, namely CDF. There are also a lot of privatly run jails out there too. We live in an "outsource" world I'm afraid.
I certainly do not think the Firehawk is ill suited but I'm interested if you think the S64 / CH54 and S61 firefighters rank as "run-out 40 year old designs" because the domestic and worldwide customers of Carson, Evergreen, Siller and Erickson don't think so.
Ahh, it must be nice to bleed UTC blue eh Nick? Just need to get them P&W engines on the rest of the Gulfstream range and it will be a perfect world!! (I have my 401K still residing in Connecticut too!!).
As for firefighters, a lot of California's rural firefighting is already contracted out, all be it to another state entity, namely CDF. There are also a lot of privatly run jails out there too. We live in an "outsource" world I'm afraid.
I certainly do not think the Firehawk is ill suited but I'm interested if you think the S64 / CH54 and S61 firefighters rank as "run-out 40 year old designs" because the domestic and worldwide customers of Carson, Evergreen, Siller and Erickson don't think so.
Ahh, it must be nice to bleed UTC blue eh Nick? Just need to get them P&W engines on the rest of the Gulfstream range and it will be a perfect world!! (I have my 401K still residing in Connecticut too!!).
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"In short, any FAR that LA County chooses to operate to is voluntary."
There are certain rules LA county needs to comply with...
SECTION 5. PUBLIC AIRCRAFT OPERATIONS
1. GENERAL.
A. Historically, public aircraft have been exempt
from many of the requirements in FAA regulations
applicable to civil aircraft, including those governing
aircraft airworthiness and flightcrew certification. The
passage of Public Law 103-411 (the Independent
Safety Board Act Amendment of 1994) made a major
change in the definition of “public aircraft.” This
change caused many former public aircraft operations
to become subject to the regulations governing civil
aircraft and pilot certification.
B. Legislative History.
The general purpose of the new law, as reflected in the legislative history, is to extend FAA regulatory oversight to some government aircraft operations.
In part, Congress determined that government-owned aircraft, which operate for commercial purposes should be subject to the regulations applicable to civil aircraft.
SUMMARY AS OF:
10/4/1994--House agreed to Senate amendment with amendment.
(Sec. 3) Revises the application of Federal Aviation Administration (FAA) economic and safety requirements of public aircraft to include governmental functions such as firefighting.....
There are certain rules LA county needs to comply with...
SECTION 5. PUBLIC AIRCRAFT OPERATIONS
1. GENERAL.
A. Historically, public aircraft have been exempt
from many of the requirements in FAA regulations
applicable to civil aircraft, including those governing
aircraft airworthiness and flightcrew certification. The
passage of Public Law 103-411 (the Independent
Safety Board Act Amendment of 1994) made a major
change in the definition of “public aircraft.” This
change caused many former public aircraft operations
to become subject to the regulations governing civil
aircraft and pilot certification.
B. Legislative History.
The general purpose of the new law, as reflected in the legislative history, is to extend FAA regulatory oversight to some government aircraft operations.
In part, Congress determined that government-owned aircraft, which operate for commercial purposes should be subject to the regulations applicable to civil aircraft.
SUMMARY AS OF:
10/4/1994--House agreed to Senate amendment with amendment.
(Sec. 3) Revises the application of Federal Aviation Administration (FAA) economic and safety requirements of public aircraft to include governmental functions such as firefighting.....
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rotormatic, your post has nothing to do wth this discussion, but don't let that stop you!
PT6ER, I think your membername tells me you are the UTC guy! If I speak in stong terms about the Black Hawk, it is because I have 2500 hours in it, and was an SIP who trained the first Amy pilots in it. For guys to prefer a 45 year old S61 to it is simply worth a strong post or two, and exposes us to ask why they make it a Fire Hawk issue when in reality, they have strong commercial interests to defend, and it has nothing to do with the aircraft.
If SASless and rotormatic had the contract, there would be no discussion, they would fly Wright Flyers on the contract, if it made them an extra buck. They would defame the Black Hawk if it made the an extra buck, just as fast.
This thread has little to do with Fire Hawk, and lots to do with stone cold business.
PT6ER, I think your membername tells me you are the UTC guy! If I speak in stong terms about the Black Hawk, it is because I have 2500 hours in it, and was an SIP who trained the first Amy pilots in it. For guys to prefer a 45 year old S61 to it is simply worth a strong post or two, and exposes us to ask why they make it a Fire Hawk issue when in reality, they have strong commercial interests to defend, and it has nothing to do with the aircraft.
If SASless and rotormatic had the contract, there would be no discussion, they would fly Wright Flyers on the contract, if it made them an extra buck. They would defame the Black Hawk if it made the an extra buck, just as fast.
This thread has little to do with Fire Hawk, and lots to do with stone cold business.
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Now Sasless - you started this!
Let's stick to the aircraft itself. That's why I posted in the first place.
If you have a beef with Govt. Dept's doing work of commercial operators - talk to the bureaucrats. They are the ones who make the decisions.
I tell you right now - if LA County Fire Dept offered me a job flying one of these amazing aircraft, I'd jump at it. These are the guys who are professionals in the firefighting game and would probably outrun alot of "commercial operator" pilots - BECAUSE THEY DO IT EVERYDAY.
So saying "....move over guys and let the real men have a go" would not work in this case.
The real fact of life is that if the commercial operators would tender for a contract like this - they wouldn't be flying FireHawks.
Let's stick to the aircraft itself. That's why I posted in the first place.
If you have a beef with Govt. Dept's doing work of commercial operators - talk to the bureaucrats. They are the ones who make the decisions.
I tell you right now - if LA County Fire Dept offered me a job flying one of these amazing aircraft, I'd jump at it. These are the guys who are professionals in the firefighting game and would probably outrun alot of "commercial operator" pilots - BECAUSE THEY DO IT EVERYDAY.
So saying "....move over guys and let the real men have a go" would not work in this case.
The real fact of life is that if the commercial operators would tender for a contract like this - they wouldn't be flying FireHawks.
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"rotormatic, your post has nothing to do wth this discussion, but don't let that stop you!"
Mr. Lappos:
You brought up FAA oversite of public aircraft operations.....
Mr. Lappos:
You brought up FAA oversite of public aircraft operations.....
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Sorry Nick, You lose that one. Rotormatic is correct. Trust me, you won't beat him on FAR's. You did bring it up.
You are also wrong about the factories knowing everything about lift cycles. In the 214ST they wanted me to pay them $1,000,000.00 to do all the testing before they would support me. Obvioulsy they won and I ran.
There is no way the government can compete with the the HAwk or any other helicopter. Their figures are bogus and they don't include any overhead. Remember, the maintenance contract on the HAwks is part of the sales pitch. That is the only way LA was going to buy them. That's why it is so cheap. And guess what, it's working. They are buying yet another one!
You are also wrong about the factories knowing everything about lift cycles. In the 214ST they wanted me to pay them $1,000,000.00 to do all the testing before they would support me. Obvioulsy they won and I ran.
There is no way the government can compete with the the HAwk or any other helicopter. Their figures are bogus and they don't include any overhead. Remember, the maintenance contract on the HAwks is part of the sales pitch. That is the only way LA was going to buy them. That's why it is so cheap. And guess what, it's working. They are buying yet another one!
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Maybe a good idea as an industry, might be to determine the real cost and at least substantiate the argument?
Get your good friends at the HAI to make a Freedom of Information Act (FOIA) request for the actual operational cost for these helicopters.
Be sure to specify;
All acquisition costs.
All Management costs.
All maintenance costs.
All Facility costs, including overhead and utilities.
All training costs.
All support costs, including contractors and consulting.
All travel costs, including vehicles charged to this operation.
All incidental expenses/per diems.
A complete breakdown of pay and benefits, including retirement for each and every person who is costed against this operation.
Fuel costs.
Any insurance and liability costs.
All overhaul and repair costs, not included in the maintenance package.
And while you're at it.
Make the exact same request for that other Government boondoggle - the Cobra project that the USFS keeps hidden away from prying eyes.
I have a sneaking suspicion that once they see the bottom line numbers for these projects you won't hear too many complaints about the cost of commercial operators performing these missions. The hourly rates for all the commercial operators bidding government contracts are public domain information, so why not do the same for the Government operators?
Get your good friends at the HAI to make a Freedom of Information Act (FOIA) request for the actual operational cost for these helicopters.
Be sure to specify;
All acquisition costs.
All Management costs.
All maintenance costs.
All Facility costs, including overhead and utilities.
All training costs.
All support costs, including contractors and consulting.
All travel costs, including vehicles charged to this operation.
All incidental expenses/per diems.
A complete breakdown of pay and benefits, including retirement for each and every person who is costed against this operation.
Fuel costs.
Any insurance and liability costs.
All overhaul and repair costs, not included in the maintenance package.
And while you're at it.
Make the exact same request for that other Government boondoggle - the Cobra project that the USFS keeps hidden away from prying eyes.
I have a sneaking suspicion that once they see the bottom line numbers for these projects you won't hear too many complaints about the cost of commercial operators performing these missions. The hourly rates for all the commercial operators bidding government contracts are public domain information, so why not do the same for the Government operators?
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Mustang-
On regs, rotormatic is WRONG, the LA County fire operations are NOT run by FAR, no matter what long posts he makes, and how he flogs his keyboard. He IS beaten on FAR;s because LA isn't using them.
Regarding maintenance cost, I have no earthly idea what you or SASless are talking about, and I will bet you don't know either. The Fire Hawks are covered by a factory guaranteed maintenance contract - a full aircraft "power by the hour". It is a moneymaker for Sikorsky, and provides assured expenses for the operator. It covers components and replacements, so I do not know how you think "the maintenance contract on the HAwks is part of the sales pitch" as if it not somehow a contract, nonetheless. After 9,000,000 hours of Hawk flying, Sikorsky knows what it costs to run one, even with rotormatic scribbling down the cycles and muttering as he does so.
Also, I believe the "government" does not have to compete, it just does, like the Army in Iraq or my town's fire department. I stand by my point, the Fire Hawk is not the discussion here, the fact that you guys don't get to bid is the point, isn't it?
On regs, rotormatic is WRONG, the LA County fire operations are NOT run by FAR, no matter what long posts he makes, and how he flogs his keyboard. He IS beaten on FAR;s because LA isn't using them.
Regarding maintenance cost, I have no earthly idea what you or SASless are talking about, and I will bet you don't know either. The Fire Hawks are covered by a factory guaranteed maintenance contract - a full aircraft "power by the hour". It is a moneymaker for Sikorsky, and provides assured expenses for the operator. It covers components and replacements, so I do not know how you think "the maintenance contract on the HAwks is part of the sales pitch" as if it not somehow a contract, nonetheless. After 9,000,000 hours of Hawk flying, Sikorsky knows what it costs to run one, even with rotormatic scribbling down the cycles and muttering as he does so.
Also, I believe the "government" does not have to compete, it just does, like the Army in Iraq or my town's fire department. I stand by my point, the Fire Hawk is not the discussion here, the fact that you guys don't get to bid is the point, isn't it?