"Bart" wrote in message
...
Ok, I just read the NPRM in its entirety. If enacted as is, you can
totally forget about the helicopter tour biz. There wont be one. The
proposed Part 136 amend. is a direct attack on the helicopters in
general and will remove every advantage that a helicopter provides over
an airplane for such operations. The float requirement will knock most
of the operators out of biz too. (I just spent a very painful 50 grand
putting them on my ship, but most operators dont have the budget to do
this in the crappy post 9/11 environment) Its not the adherence to 135
that is the danger to the Rotorcraft industry, but rather the additions
to more obscure part 136.
What's kind of ironic is the preamble to the NPRM cites a bunch of
incidents in Hawaii as justification, but buried deep within the
document they state that most of the operators were operating under part
135 anyway.
I think you are preaching to the choir here. Their analysis of costs
is just wild. For example, they figure that the costs for the average
operator to leave the tour industry, develop a new business plan, and go
into some other line of work is $600.00! And that includes lost income from
loss of business! They also give an estimated cost for floats which is
considerably less than what you paid.
Some of the justifications continued within the NPRM are totally
legitimate, and should be mandated across all ops regardless of what
type of operation it is. An example is that passengers should be
_WEARING_ their lifejacket and briefed its use and water egress for over
water ops. I've never done otherwise, and can't imagine why anyone
ignores this simple easy safety measure today. Even though most of my
tour flights are conducted over very shallow water (2-5 ft), I've never
allowed anyone to ride without a jacket and a water egress briefing.
I agree, and this need not be confined to the tour industry.
Im not sure how many real operators or pilots are in this group, but if
you give a rat's-ass at all about this industry, you should put some
effort into commenting on this. (it can be done anonymously btw)
See the link in the nprm for info on how to do it.
Again, I agree. If you sit back and let them screw you, you deserve
what you get.
Vaughn
Bart
The FAA proposal (all 20-some pages) is at:
http://dmses.dot.gov/docimages/p77/257434.pdf
This will cause the loss of lots of flying jobs, the FAA admits that few
sightseeing operations will be able to afford to operate under part 135,
so
the government is going to keep us all safer by keeping us on the
ground.
You have until Jan 20 to file your comments.
Vaughn