The FAA has published formal notice of the new requirements for conducting “doors off” operations in the wake of the fatal March 11 FlyNYON flight operated by Liberty Helicopters in New York that killed all five passengers aboard. The passengers drowned after their helicopter autorotated into the East River and overturned during a doors-off photo flight in which they were wearing non-standard restraints. The pilot, who was wearing a standard restraint, escaped.
Under the notice, the FAA requires that operators of all doors-off flights for compensation obtain an FAA letter of authorization for the use of supplemental passenger restraint systems (SPRS). “The LOA will be issued after determining that the restraints to be used can be quickly released by a passenger with minimal difficulty and without impeding egress from the aircraft in an emergency,” it noted.
The FAA did not specify the type of restraint to be used but rather its characteristics, including that the “SPRS must not require the use of a knife to cut the restraint, the use of any other additional tool, or the assistance of any other person. An SPRS also must not require passenger training beyond what would be provided in a preflight briefing. The applicant bears the burden of clearly and convincingly demonstrating that the SPRS can be quickly released by a passenger with minimal difficulty and without impeding egress from the aircraft in an emergency.”
Applicants seeking a doors-off LOA must fill out FAA Form 7711-2 and upload an eight-second video to YouTube (unlisted encouraged) with a link. The video should show the occupant demonstrating release from the SPRS and be emailed along with the form to SPRS@faa.gov.