PT 135 help -FSDO problems

[cvsfly]

I need some 135 advice. We are currently a single pilot-in-command operator and are trying to upgrade to a basic. In putting together a training program, our FSDO has made the process drawn out. We use and intend to FSI for our aircraft specific training and checking. The manual they produced for our specific use (our name on it) was rejected outright. The main reason given was that some FSI proprietary info was still included in it. and the FSDO repeatedly asked we use a format from a sample program they provided on computer disk. I managed to put one togetherb but still am having trouble with a few items and when I address my questions in writing and question the FSDO's recommendations they said I have a bad attitude and in so many words threatened not to upgrade us based on th "poor attitude". (We operate 1 BE-200) Item 1: They say we must develop a flight manuever/procedure for a VFR approach "with 50% loss of engine power on one side". This is according to Inspector's Handbook 8400.10 Vol. 3 Chap 2, a table on pg 3-278.
FSI didn't uderstand what they were referring to and I can't find any reference to it (especially as a training manuever) anywhere else besides the 8400.10. I suggested that this document is a reference guide and was told that this is an "order" and is regulatory. Because I questioned it and are not immediately doing what they they had asked for, I have a bad attitude. I am sure I can make up a procedure for it, but does any one have any other references. Item 2: Windshear training. We have it in our ground training curriculum as req. by 135.345, but the FSDO asked for a flight training manuever/procedure. Again with FSI advice and reference to AC 120-50A it is only recommended for 135, required for 121, and then suggested only then in simulators. Again we plan on accomodating the FSDO. If the FSDO makes any more threats I have thought about legal council. Any advice there and what evidence do I need to display. I keep all written correspondances, but there have been alot of verbal communications that are hard to document.

 

[avbug]

You'll probably get posts about standing your ground and sticking up for your rights, but it's important to understand that when dealing with the FAA, you don't have rights. You have privileges. There is nothing in the FAA curriculum that is in your favor. If the inspector assigned to be your future POI or PMI doesn't like you, you're going to have an uphill battle. Period. A lot of one's dealings with the FAA, particularly at the FSDO level, depends upon an "attitude of compliance."

Remember that no one is obligated to grant you operating privileges. If there are hoops to jump through, jump through them.

You appear to be referring to Table 3.2.6.4 in HBAT 8400.10, Volume 3, Chapter 2. If you read the preceeding material in paragraph 499 (" PIC/SIC initial new hire and initial equipment flight training: transport and commuter category airplanes"), you'll find clarification to your question on the 50% power loss issue.

The HBAT is referring to the loss of power on one side, for a two engine airplane, or the loss of two engines, for a three engine airplane, or for a four engine airplane, the loss of power of two engines on one side.

The paragraph specifically calls for the following:

"Required Maneuvers and Procedures. Training in the maneuvers and procedures in table 3.2.6.4 must be conducted for satisfactory completion of initial new hire and initial equipment flight training...

...PICs must complete training in each training event in this table. SICs must complete training in each training event in this table. SIC training in the following events does not require manipulation of the primary aircraft controls but should emphasize duties of the pilot not flying: ...Approach and landing with 50% loss of power..."

Moving on to Table 3.2.6.4, the following statement is found under the "Approaches" requirements: "With 50% Loss of Power on One Side PIC M (2 engines inoperative on 3-engine airplanes)." The same statement applies to landings.

Takeoffs are specified differently, and stipulate climbs with one engine inoperative. In the case of the King Air, this amounts to the same thing.

You will have such climb tables and performance data available for the king air. The table doesn't mean that one engine is producing full power, and the other engine is producing 50% power. It means that you have experienced a 50% power loss, and that this loss occurs on one side. That is, in the King Air, you have an engine-out.

The POI is correct. This information is not suggested material, it's regulatory, and you must produce this information and incorporate it in your training to meet the requirements as spelled out in FAA Order 8400.10. This manual spells out your duties and requirements, as well as those of the POI. The POI has some lattitude in what he or she requires, but may not do less, or ask for less than what is in the handbook.

Note that table 3.2.6.4 is showing what training devices may be used to meet these training requirements. Every requirement is shown under the column "aircraft," as you may meet all these requirements in the airplane. Some cannot be met or demonstrated properly in various levels of simulators, or training devices. Accordingly, this figure was developed to show what can be used to meet the training requirements.

The actual requirements are spelled out in the text, not in the figure to which you referred.

You're going to find that actual FAR 135 ops are much different than single pilot ops. Single pilot 135 isn't far from Part 91 operations. Actual 135 operations are going to be a different world for you. Getting the certification is only the very start. Establish and maintain good relations with your POI now; otherwise you'll have a losing uphill battle all the way through your daily operations. The POI can be your friend, or can be against you. Don't rub the POI the wrong way.

I've seen POI's who have gone out of their way to take care of their certificate holders. I've seen other certificate holders who managed to piss off their POI, and the POI lead the charge in every tiny minor infraction enforcement effort against the certificate holder. The POI is within his discretion either way, so it's best to make friends with the inspector, not fight him.

With respect to 135.345 providing a requirement for ground training in wind shear, one must also consider 135.347(a) & (b). These paragraphs specifically state:

"Initial, transition, upgrade, and differences training for pilots must include flight and practice in each of the maneuvers and procedures in the approved training program curriculum. The maneuvers and procedures required by paragraph (a) of this section must be performed in flight, except to the extent that certain maneuvers and procedures may be performed in an aircraft simulator, or an appropriate training device, as allowed by this subpart. "

This subparagraph requires you to establish flight training in accordance with an approved program. The approved program may include anything that the POI deems necessary. The basic guidance that the POI will use will be HBAT 8400.10. Beyond that, the POI will make determinations based on what you provide, and what is available, to determine what is acceptable. The inspector represents the administrator, and you have no program until he or she approves it. Your training must include whatever is required by the POI in establishing the requirements for approval.

Tread lightly in approaching your certification. Don't get into a battle of witts over the issue, and don't try to browbeat the inspector. Don't split hairs. If the inspector wants to see a paragraph covering performing approaches while wearing clown suits and high on glue, just draft the paragraph and get it approved. If the inspector wants to see a paragraph showing a requirement or provision for windshear training, then do it. It doesn't mean you need to go to 50' and seek out windshear. However, if you will be using the actual airplane for training and not a simulator, you should be prepared to demonstrate the windshear proceedures established by your program, in accordance with manufacturers recommendations.

Good luck!!

 

[cvsfly]

That was my question to the FSDO about the 50% loss of power on one side. Is that a one engine inoperative procedure (which we already had depicted) or a partial power on one side. They answered me in typical fashion replied with a question "well couldn't you have apartial loss of power - wouldn't you refer to a checklist?" I wanted to answer no, I would fgly the airplane first, decide if I should keep the power I had and make a normal approach or cage it and make a SE appr. , then refer to the checklist. The thing is I had a very good relationship with our previous POI, but I have found he left out a lot of things. He actually had us moving to a Basic (where the certificate was 2 years before, having an existing Ops Manual and a training program from Simuflite. Now we have had to resubmit everything as an original document - not a revision as well a new compliance statement. As many other pilots here have come and gone and recommended to the owner to drop the 135 cert, I may do the same. He likes being able to charter to his friends and business people and I guess feels the need for a tax write off. I can assure you with this one airplane, it costs us way more to comply with the FAA requirements than we will ever make. Especially now with the insurance. Our preminum renewal went up a 105% and a third of the preminim is to due to the fact we operate charter. I guess we are more dangerous as 135 because we are concentrating on all this inane paperwork and regs and not on flying.

 

[Corp Pilot]

My suggestion would be to change the heading on the "one engine inop" procedure and label it "one engine inop / partial power on one engine" checklist.

If your boss knows the people who he is "chartering" his aircraft to, and as long as he does not "hold himself out to the public", have him sign these people up on a "transportation contract" which states that the indivdual will pay "x" amount of dollars per hour and will use the aircraft "X" amount of hours per year. For every hour over the stated amount, he will pay "X" amount of dollars. Now you are no longer holding yourself out to the public and can get around the 135 regs. This being said, check with an aviation attorney first. The 135 company that I work for has a similiar agreement with a corporation and our FSDO (DTW) is fully aware of it. The aircraft is no longer on our 135 certificate. It is flown strictly 91.

Good Luck,

Corp Pilot

BTW - which FSDO are you dealing with?

 

[cvsfly]

FSDO - 13 , Columbia, SC

 

[Caveman]

"FSDO Problem"

Unfortunately that's redundant. I've never met a POI or an inspector that even closely resembled the term 'reasonable'. In my experience they have all been airline has beens or refugees from failed 135 ventures. Every single one of them was plagued with a myopic obsession with idiotic letter of the law interpretations despite the fact that the ruling defied logic and common sense.

Ever wonder why most folks will pay $200 or more to take a checkride with a DE instead of for free with a fed? Supposedly they both use the same PTS and regulations. Simple. The DE's are usually reasonable and conduct themselves professionally. They must be responsive to their customers or they will be out of business. The feds are not responsive nor concerned with their customers needs. They aren't about service or providing assistance or guidance and they are 100% unaccountable to their customer base. They are, for the most part, petty bureaucrats that can't make a living unless they are at the public nipple.

Are there exceptions to this ugly broad brush I'm using to condemn the Fools Against Aviation? Probably, but I darn sure haven't met any and I don't recall anybody openly praising one of them either. They must exist somewhere though. I wish I were wrong about the Federal Anti-aviation Administration, but what do you expect when the head of this elite organization has never piloted an aircraft nor owned/operated/run a commercial avaition business.

 

[HS125]

Cvsfly

Avbug is correct, 50% power loss is an engine failure on one side for a two engine airplane. This should be covered with the ONE ENGINE-INOPERATIVE VISUAL APPROACH and LANDING pictorial profile that Flight Safety should have included in the flight training section of the manual they put together for you. However, from my experience in dealing with Flight Safety and the FAA, the Flight Safety manual is not your approved training program; it is an addition to your approved training program. That is why your FSDO wants you to put together a Training Program using the disc that they gave you. If it is anything like the disc my POI gave me when he requested that I clean up my companies training program, it will be full of mistakes. And unfortunately, most POI’s will tell you what they want, but when you ask them for a little bit of an explanation as to how they want presented, they are of zero help.

Try this, maybe it will help. It worked for me and my POI was satisfied.

Put together the training program the way that they want it using the disc that they gave you. If your disc is anything like the one that my POI gave me, you will have a (Section B Contract Training). This is where you put Flight Safety in as the contracting training agency and the types of training that they will do. Add a page with a paragraph titled something like (Use of Contractor Training Programs)

The paragraph should state that your company will use Flight Safety for Beechcraft King Air 200 aircraft specific ground and flight training (Initial and Recurrent as well as 135 checking). It should also state that your company will use the FAA Approved 135 training program as supplied by flight safety that can be found in the appendix of your companies training program.

Then all you need to do is attach the Flight Safety training program to your training program as an appendix. You should be able to use Flight Safety’s manual without removing any of the Flight Safety proprietary info from the manual.

This is basically what I did when we added Flight Safety to do training and checking. Fortunately my POI was helpful in doing this and very cooperative. Unfortunately, not all FSDO’s or POI’s work the same way.

If you are still having a problem getting any where, I suggest a face to face with your POI. Tell him / her that you want to it right but are having trouble understanding exactly what he/she wants. If you have gotten off on the wrong foot with your POI fix it now. Most POI’s loved to be stroked and seem to get off on the fact that they have control. If you work with them, they will eventually start to back off and actually be helpful.

As far as windshear goes, I addressed it in the ground training section of our manual but not the flight. My POI never said a thing about it, and I sat with him for most of a day going through the manual before he signed it. And he didn’t request a single change!

Good Luck

 

[BTapsco]

"FSDO Problem"

>>>>>Ive never met a POI or inspector that even closely resembled 'reasonable'<<<<<

My experience is just the opposite. In the past 25 years, I've written Basic 135 manuals for 5 startups; served as pilot and DO on 3 of them. and in so doing have dealt with at least 8 POIs and and many more maintenance and avionics inspectors and in every case found them to be very helpful. I remember one, some years ago, who summarized my job as DO and his as POI "is to keep each other out of trouble. Yeah, getting the verbiage in the Ops, Training, MEL, MEL Management Program, MEL Training Program, revising manuals to include new stuff such as winsdshear training, hold short trainig and diagrams for approaches , etc. as all the additional requirements came into being was sometimes time-consuming and frustrating, it was always a cooperative effort between us.