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Tue, Oct 03, 2023

Vertical Aviation Technologies Encourages Comments to MOSAIC NPRM

Speak Now, or …

In light of the likelihood of MOSAIC ascending, imminently, from NPRM to the decidedly more august station of fully-ratified Federal Aviation Regulation, Brad Clark, president of light-helicopter maker Vertical Aviation Technologies, Inc. has set forth the following communique to his company’s customers:

“The FAA has recently released a Notice of Proposed Rule-Making (NPRM) called MOSAIC. It is a change to the Light Sport Aircraft (LSA) category and now includes helicopters. However, the FAA is proposing that LSA helicopters be two-seat only. The FAA is also proposing that Light Sport pilots can only fly two-seat Light Sport helicopters with simplified flight controls. If this NPRM is changed to four-seats then the Hummingbird [a Sikorsky S-52 derivative helicopter produced by Vertical Aviation Technologies] would be eligible as a Light Sport helicopter.

"I am asking everyone that is interested in a LSA Hummingbird to comment at www.regulations.gov/document/FAA-2023-1377-0001/comment . The comment-period ends in 25-days. Please read my comments below for reference. Don't use it word for word. More comments on this subject in regard to helicopters will help convince the FAA that there is interest."

Brad Clark.

Mr. Clark provided the following template upon which Vertical Aviation Technologies customers may base their respective comments to the FAA.

Thank you for the opportunity to comment on this proposed rule.

The new proposed definition of Light Sport category aircraft now includes helicopters. This is excellent, however, it limits the design to two-seats. This should be expanded to four-seat designs like that proposed for airplanes. A four-seat helicopter is no less safe than a two-seat, in fact, it is safer. Allowing four-seat designs for helicopters would allow for the following, all for safety and utility reasons, that are difficult to incorporate in two-seat helicopters:

  • Incorporate additional safety-enhancing designs and equipment like fuel-system crash-resistance and occupant protection.
  • Design airframes that are more rugged for the flight-training environment.
  • Increase fuel-load and aircraft range.
  • Allow for greater cabin-size to enable greater occupant heights and weights.
  • Heavier helicopters improve aircraft handling in gusts, turbulence, and crosswinds, reducing pilot workload.
  • Increase the suitability of helicopters for other intended operating purposes, including recreation, personal travel, flight training, and certain aerial work while maintaining an appropriable level of safety.

Piloting skills necessary to operate a four-seat helicopter do not differ from those skills required to operate a two-seat helicopter due to the similarity in design and operation. A four-seat helicopter is easier and safer to fly because of better performance margins. Larger rotor systems have better autorotation performance, therefore increasing safety. Larger helicopters usually have more blades, making the design quieter and environmentally better. Easier is safer, especially for flight training.

The FAA stated that they have little experience on the safety metrics of helicopters therefore limiting helicopters to two-seats. The FAA also stated that future rulemaking may extend the two-seat limitation as experience increases. The Hummingbird four-seat amateur build kit helicopter is a good example. This helicopter has been sold for thirty-five years, 360 have been sold as kits and over 250 [are] flying worldwide with an excellent safety record and zero fatal accidents. Because of the four-seat size, the Hummingbird helicopter is able to incorporate many safety features, like occupant protection, fuel-system crash-resistance, and post-crash fire protection, that are difficult to design into two-seat helicopters. It is the only four-seat amateur build kit helicopter.

In establishing a prescriptive limit for the number of seats, four-seats strikes a balance between risk and utility that is appropriate for a category of aircraft intended for recreation and personal use. Allowing a four-seat helicopter, like airplanes, to be assembled by the manufacturer in lieu of the 51-percent kit build, increases the safety continuum. There currently is only one certified four-seat piston-engine-powered helicopter available in the world. Increasing the seat capacity to four for Light Sport helicopters would make a more competitive market, increasing availability of four-seat helicopters for personal travel, recreation, training, and aerial work, while maintaining an appropriate level of safety.

I would like to see the performance-based requirements of Light Sport helicopters be four-seats and three-thousand-pounds gross weight. The three-thousand-pounds is appropriate for a four seat helicopter and is the same as the initial airplane proposed three-thousand-pound weight.

This proposed rule is requiring Sport Pilots to fly helicopters that have simplified flight-controls. I don’t believe this is in the best interest for safety. I found the definition confusing and vague, however, I believe simplified flight-controls are defined as automated, stability-augmented, fly-by-wire, computer-managed, flight-control systems that flies the helicopter itself. The pilot has no direct control of the control surfaces. Where is the enjoyment of not flying the aircraft? This is too complicated for a simple traditional helicopter. The cost alone for certification would be very high. The existing legacy designs of cyclic, collective, and pedals are simple, easy to fly, and proven. Direct mechanically-linked flight-control systems are proven, fail-safe systems. This proposed rule would make helicopters too expensive for the Sport Pilot and for training. Sport Pilots should be allowed to fly four-seat helicopters with traditional flight-controls. This would also ease barriers in flight-training for Sport Pilots and Sport Pilot instructors, given the availability of legacy three-or-four-seat helicopters. No existing helicopters, even certified, have this complicated concept. How does the computer pick a spot to land in the event of engine failure? The workload of operating a helicopter with traditional flight-controls is less than operating airplanes with multi-engines, controllable-pitch propellers and retractable landing-gear which are allowed in the proposal for airplanes. The FAA chose not to allow powered-lift privileges to sport pilots given the complexity. However, simplified flight-controls are just as complex. Simplified flight-control systems should be required on powered-lift multi-rotor aircraft only.

In summary;

  • Increase light sport helicopter designs to be four seats, the same as airplanes.
  • Eliminate the simplified flight control requirement for sport pilots for helicopters.

 

FMI: www.vertical-aviation.com

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