Luke Alcorn

Document ID: FAA-2002-13744-0017
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: August 11 2008, at 11:17 AM Eastern Daylight Time
Date Posted: August 11 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: August 11 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: November 5 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 806bbf25
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I am a current R22 instructor and believe that SFAR 73 has done great good for the safety and operation of the R22. I also believe the R44 should be included in the initial SFAR 73 training before being able to manipulate the controls, training should be provided. However, I feel the regulation should be changed to lower or eliminate the 50 or 25 hour requirement to teach and operate an R44. The R44 does not display the bad tendencies of handling characteristics of the R22. There is no reason a properly certified R22 pilot or instructor needs an additional 5 hours in the R44 to act as PIC and 25 hours plus a checkride to teach in the aircraft. Maybe that requirement can stay for initial non-robinson qualified instructors, but for an R22 qualified instructor, this is a useless requirement costing upwards of $12,000 to transition to this helicopter. A transition to a turbine helicopter has no requirement from the FAA and is more complex and difficult to fly than the R44. Same applies to the requirement for a Biennial Flight Review for both aircraft. If qualified in the R22 and a current BFR, why is a second one required for the R44? The systems are almost identical, except for hydraulics.

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Total: 2
Luke Alcorn
Public Submission    Posted: 08/11/2008     ID: FAA-2002-13744-0017

Nov 05,2008 11:59 PM ET
Fostaire Helicopters
Public Submission    Posted: 08/12/2008     ID: FAA-2002-13744-0018

Nov 05,2008 11:59 PM ET