We should not point fingers
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oleary:
In an S-61, you're always certified under Part 29. The configuration (>9 passengers) will determine whether you have to obey the limitation of the H-V curve or not. It's like any other limitation in the flight manual.
Whether you are fire-fighting or carrying passengers, you have to obey the limits in the flight manual, at least in any country I've ever heard of.
In an S-61, you're always certified under Part 29. The configuration (>9 passengers) will determine whether you have to obey the limitation of the H-V curve or not. It's like any other limitation in the flight manual.
Whether you are fire-fighting or carrying passengers, you have to obey the limits in the flight manual, at least in any country I've ever heard of.
Shawn - at the time of me writing the previous post I was under the impression that the firefighting/logging purpose of the aircraft meant the seats had been taken out and it was being used as a van. I understand now that it had up to 16 seats fitted in it...apologies.
But still the NTSB report makes absolutely no reference whatsoever to the H/V curve. Why is that then?
But still the NTSB report makes absolutely no reference whatsoever to the H/V curve. Why is that then?
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Shawn,
Earlier in the discussion you and SASless (and others) discussed operation within the H-V curve. Once again you correctly point out that
Section 1.6.33 (p-24) of the NTSB report indirectly addresses limits when it states
In addition, Section 1.18.6 (p-82) states
What am I missing here? Public Use Aircraft can’t possibly be exempted from all Operating Limits. If they are exempted from certain limits, then who grants those exemptions?
HT
Earlier in the discussion you and SASless (and others) discussed operation within the H-V curve. Once again you correctly point out that
In an S-61, you're always certified under Part 29. The configuration (>9 passengers) will determine whether you have to obey the limitation of the H-V curve or not. It's like any other limitation in the flight manual.
Section 1.6.33 (p-24) of the NTSB report indirectly addresses limits when it states
In an April 26, 2010, memorandum, the FAA responded to a request from NTSB investigators for clarification as to whether the use of performance charts contained in RFMS #8 was appropriate when no external load was being carried. The memorandum noted that, because the helicopter was being operated as a public aircraft, it was not subject to 14 CFR 91.9(a), which states that “no person may operate a civil aircraft without complying with the operating limitations specified in the approved Airplane or Rotorcraft Flight Manual.” However, if the helicopter had been operated as a civil aircraft, “use of the performance figures in RFMS [#8] for maximum gross weight calculations when no external-load was being carried would be contrary to the limitations contained in the RFMS, and therefore contrary to 14 C.F.R. § 91.9(a).
Both the USFS and the DOI conduct firefighting flights on behalf of the U.S. Government. Aircraft conducting these flights are considered to be public aircraft, which are exempt from many FAA regulations applicable to civil aircraft.
What am I missing here? Public Use Aircraft can’t possibly be exempted from all Operating Limits. If they are exempted from certain limits, then who grants those exemptions?
HT
Last edited by HeliTester; 25th Feb 2013 at 19:10. Reason: Clarification
Public Use Aircraft can’t possibly be exempted from Operating Limits.
g. Which Regulations in 14 CFR Do Not Apply to PAOs? In general, regulations that include the term “civil aircraft” in their applicability do not apply to PAOs (i.e., part 91 § 91.7, Civil Aircraft Airworthiness).
Tis is a huge mess. Basically after the Carson accident everyone pointed fingers away from themselves, including the FAA. Nobody really knew who had oversight. It is still being worked out now. I just got yet more contract modifications with respect to Public Use Status.
Basically as of right now, we would inform our FAA office that we "may" be required to operate "public use". The forest service would then determine at the beginning of a flight if it fell under public or civil use. If under public, then they would assume oversight until they release us back to "civil" at the end of the flight. The FAA would have NO oversight during the flight, or until we were released again. The USFS has agreed they will issue the "public use declaration" for each flight, and have no problem doing so. The Dept. of Interior however, do not agree with the USFS and have only issued the declaration one time that they have admitted to.
So......there I am on a National Park fire, and they will not issue the declaration---I am not able to carry their firefighterws with their tools to the fire. Conversely, if I am carrying USFS firefighters, (exact same uniform etc) I can do it.
The whole thing is a mess with too many different agencies trying to maintain control. For once I praise the FAA and USFS who are both being pro-active and trying to sort this out.
Let us not forget....it is a miracle that anyone got out of this aircraft;
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Godry et al:
A real mess!!!
Somewhere, someone must have dictated that some limitations must be followed. Please tell me that is at least true...
Otherwise, I think the government is leaving themselves open for a real mess.
A real mess!!!
Somewhere, someone must have dictated that some limitations must be followed. Please tell me that is at least true...
Otherwise, I think the government is leaving themselves open for a real mess.
The Government is a Mess.....and we all know that.
As usual....every agency wants to do it their own way.
The best thing that could happen would be for a single Federal Agency be designated as the aircraft Lease Control Agent, and all the various agencies have to go to that single agency with their demand for aircraft. That way the Operators would have a single standard to meet and only one contracting office to deal with.
If that agency adopted the most strict standard used by any/all of the mulitiple agencies....Safety would be very much enhanced.
The Killer to the idea is when the other agencies had to start paying the Aircraft Agency for its Administrative Costs.....the Bureaucrats would rebel!
As usual....every agency wants to do it their own way.
The best thing that could happen would be for a single Federal Agency be designated as the aircraft Lease Control Agent, and all the various agencies have to go to that single agency with their demand for aircraft. That way the Operators would have a single standard to meet and only one contracting office to deal with.
If that agency adopted the most strict standard used by any/all of the mulitiple agencies....Safety would be very much enhanced.
The Killer to the idea is when the other agencies had to start paying the Aircraft Agency for its Administrative Costs.....the Bureaucrats would rebel!
Somewhere, someone must have dictated that some limitations must be followed. Please tell me that is at least true...
As for the H/V diagram being in the limitations section---I cannot comment on that as I do not know. I will say that the departure did not look like a confined area departure. All of the take offs I did form the same spot were normal airspeed over altitude..... I will go back and see if I can find more pictures from the LZ itself.
Can someone confirm then whether the a/c was operating inside the H/V curve at the time of the accident (whether it was advisory or a limitation).
Secondly, why isn't the FAA the place where the buck stops?
What is so difficult for the FAA to certify all flights and place them into certain categories? Public/private/aerial etc.
A flight manual description of the H/V curve affects the flying performance of the aeroplane. The aeroplane doesn't know or care it is public or private flight??? It doesn't know or care it is advisory or mandatory. If the fan(s) stops inside the H/V curve you will suffer the consequences - given certain conditions.
Secondly, why isn't the FAA the place where the buck stops?
What is so difficult for the FAA to certify all flights and place them into certain categories? Public/private/aerial etc.
A flight manual description of the H/V curve affects the flying performance of the aeroplane. The aeroplane doesn't know or care it is public or private flight??? It doesn't know or care it is advisory or mandatory. If the fan(s) stops inside the H/V curve you will suffer the consequences - given certain conditions.
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Thomas,
You are correct that the airplane does not care, but the people do. The FAA has made clear in the case of class B HEC just as public use that risk is relative.
Essentially, it is too much risk to expose paying passengers for hire unbeknownst to them, but not so dangerous as to disallow trained persons who accept the risk in the course of an effort to perform such critical duties.
Give it the common sense test. Is it realistic to pull firefighters out of the northern california forrests without entering the HV curve, Nope. The only thing they could have done differently in that regard is limit the aircraft to 9 seats.
You are correct that the airplane does not care, but the people do. The FAA has made clear in the case of class B HEC just as public use that risk is relative.
Essentially, it is too much risk to expose paying passengers for hire unbeknownst to them, but not so dangerous as to disallow trained persons who accept the risk in the course of an effort to perform such critical duties.
Give it the common sense test. Is it realistic to pull firefighters out of the northern california forrests without entering the HV curve, Nope. The only thing they could have done differently in that regard is limit the aircraft to 9 seats.
500guy makes a very good point.
“Give it the common sense test. Is it realistic to pull firefighters out of the northern California forests without entering the HV curve, Nope. The only thing they could have done differently in that regard is limit the aircraft to 9 seats.”
Are we confusing HV curve avoidance with Cat A type operations? Once the helicopter departs an area with a smooth hard surface most capabilities for an emergency autorotative or OEI landing are dramatically reduced or eliminated. Unless the helicopter is operated in these remote areas at a weight that allows for an OEI fly away it will always be at risk of having no choice but to land without regard to the local terrain.
“Give it the common sense test. Is it realistic to pull firefighters out of the northern California forests without entering the HV curve, Nope. The only thing they could have done differently in that regard is limit the aircraft to 9 seats.”
Are we confusing HV curve avoidance with Cat A type operations? Once the helicopter departs an area with a smooth hard surface most capabilities for an emergency autorotative or OEI landing are dramatically reduced or eliminated. Unless the helicopter is operated in these remote areas at a weight that allows for an OEI fly away it will always be at risk of having no choice but to land without regard to the local terrain.
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Are we confusing HV curve avoidance with Cat A type operations
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My reading of the NTSB report is that the crew were in fact, exceeding limitations. On all of the takeoffs from the crash site helipad, they were using 2.5 minute OEI (and co-incidentally, topping) N1 limits (the rotor was drooping at a constant N1, which would only happen when the compressor can't turn any faster.
Takeoffs at lower altitudes did not result in rotor RPM droop.
If that's not exceeding a limit, I don't know what it's called.
Takeoffs at lower altitudes did not result in rotor RPM droop.
If that's not exceeding a limit, I don't know what it's called.
