Fostaire Helicopters

SFAR 73 has out lived it purpose. It was concieved in an environment in which awareness of the R22/R44 helicopters flight characteristics was not widely known. This resulted in an unacceptably high accident rate. Since the SFAR, the entire helicopter community has been made aware of those flight characteristics and subsequent awareness of all 2 blade teetering main rotor flight envelope risks. This has resulted in a measurable decrease in accidents from exiting the "safe" flight envelope of these and other aircraft. The SFAR now, only serves to provide obsticales to pilots both highly experienced, and with low experience levels that require redundant training to be able to accept the duties of pilot in command in these aircraft. 2 examples: 1: High time pilot. (Myself) Certificates, ATP helicopter, CFI-I helicopter, Designated pilot examiner helicopter including Initial CFI, over 10,000 hours PIC helicopter accident incident free. Owner of a Robinson R22 helicopter with hundreds of hours and the factory school. Pilot experience in many types of piston helicopters of several thousands of hours. R/44 pilot experience of 15 hours with SFAR PIC endorsement. However I am unable to instruct in, or conduct check rides in this aircraft due to the SFAR restrictions in each specific model. Having each model specifically differentiated is not providing ANY increased level of safety above that provided by the normal make and model checks performed for all other helicopter types. 2: Low time pilot. (Candidate example) Commercial pilot/ instrument, CFI candidate. 150 hours pilot time most in the R22, instrument training in a Schwizer 300 CBI (no engine governor),with a "checkout" in the R44. This pilot upon achieving his or her CFI, can't instruct in the very machine that they have been flyhing since their first flight. Even upon accomplishing their 200 hours total time, they still have to have an additional 25 hours in the R44 to be able to generate revenue in these aircraft. Again, I don't see any SAFETY enhancment in this "specific model" discrimination for the SFAR. Having a "Robinson" blanket SFAR is not as burdensom as the current seperation of models, and I feel would provide the same level of safety awareness. What is going to happen to the new R-66 aircraft now in certification testing. Is this turbine aircraft wht the same rotor system as the R22/R44 going to be added to the SFAR with seperate model requirements? This has grown into a monster that is now providing road blocks to pilots rather than enhancing safety for the type as initially intended. Sincerely, Clarke Thomas President Fostaire Helicopters A&P, IA ATP helicopter, AMEL Comm. ASEL CFI, helicopter AMEL instrument instructor helicopter, AMEL DPE helicpter, Bell 206, HU 396, 269/300, Bell 47, R-22