Twin Otter combi ops

[twinotter3H]

This is directed to all Canadian DHC6 pilots/operators.

Im wondering if anyone has been pressured by TC lately to modify the way the twin has been traditionally loaded ie. pile everything in front, secure the load, and pax in the back. Now they're forcing us to leave all exits available whenever operating with passengers. Normally i would say this is completely acceptable, but on the twin the 300 series we operate have 2 underwing exits which aren't in place on the 100 and 200 series (they have the overhead hatch in the rear). They say those must be clear and even if we would install the overhead hatch (the airframe has the spot ready) we wouldn't be allowed to block the exits. So what has been happening for 40 years without a problem is all of a sudden an issue. On top of things they're requiring us to leave a 9" passage from the pax to the cockpit. This means that on the 300 series we can't load anything in front of the underwing exits, only aft and on the right side leaving a corridor on the left.

So the long and short of it is we're having to do 2 trips for what we used to do with one, thus driving up costs to the client whether it be Inuit, Cree, hunters, fishers, outfitters, whomever.

Just wondering if this is something which is affecting any other twin otter operators, and what kind of solutions people are coming up with.

[Rudy]

Maybe weld up the underwing exits so the don't exist anymore and then install the roof hatch?
What's the reason for the 9" corridor?

[ettw]

There were noises about this issue just as I was leaving the Twin Otter world (sigh.... ). I thought it was just assinine.

I mean, sometimes we had just 2 pax in the rear of the Twin with 2500 pounds of freight in front. Jesus, they had 1 exit each, that were big enough for any of the people we flew but it appeared as if we were going to have to maintain an aisle and top clearance. Stupid.

Think about it. Where are the under wing exits? How many people sit aft of those exits? 13 if I remember correctly. You're telling me that 13 people can't get their asses out of TWO doors that are 48" high by 30 or so inches wide? Come on......

So let TC do the investigation. How many passengers have been injured or killed as a result of NOT being able to use the under wing exits on Twin Otters? I'm guessing not many but thats just a guess. Throw into that can of worms the King Air 200. If I remember correctly, there is only 1 emergency exit on the 200, on the right side + the main cabin door. Yet you can put 13 people in that machine in a commuter config.

Piss me off........

Cheers,

ETTW

[snoopy]

Interestingly, the CARS can probably answer that question for you - and I don't think you'll find this is a recent change:

DIVISION IV - PRE-FLIGHT AND FUEL REQUIREMENTS

Carry-on Baggage, Equipment and Cargo

602.86 (1) No person shall operate an aircraft with carry-on baggage, equipment or cargo on board, unless the carry-on baggage, equipment and cargo are

(a) stowed in a bin, compartment, rack or other location that is certified in accordance with the aircraft type certificate in respect of the stowage of carry-on baggage, equipment or cargo; or

(b) restrained so as to prevent them from shifting during movement of the aircraft on the surface and during take-off, landing and in-flight turbulence.

(2) No person shall operate an aircraft with carry-on baggage, equipment or cargo on board unless

(a) the safety equipment, the normal and emergency exits that are accessible to passengers and the aisles between the flight deck and a passenger compartment are not wholly or partially blocked by carry-on baggage, equipment or cargo;

(b) all of the equipment and cargo that are stowed in a passenger compartment are packaged or covered to avoid possible injury to persons on board;

(c) where the aircraft is type-certificated to carry 10 or more passengers and passengers are carried on board,

(i) no passenger's view of any "seat belt" sign, "no smoking" sign or exit sign is obscured by carry-on baggage, equipment or cargo except if an auxiliary sign is visible to the passenger or another means of notification of the passenger is available,

(ii) all of the passenger service carts and trolleys are securely restrained during movement of the aircraft on the surface, take-off and landing, and during in-flight turbulence where the pilot-in-command or in-charge flight attendant has directed that the cabin be secured pursuant to subsection 605.25(3) or (4), and

(iii) all of the video monitors that are suspended from the ceiling of the aircraft and extend into an aisle are stowed and securely restrained during take-off and landing; and

(d) all of the cargo that is stowed in a compartment to which crew members have access is stowed in such a manner as to allow a crew member to effectively reach all parts of the compartment with a hand-held fire extinguisher.

(so there's a gotcha on the cargo-only flights as well)

You could always apply for an exemption to the CARS. That way, if accepted, you'll still have a valid c of a, insurance and possibly a pilot license if something unexpected happens.

[twinotter3H]

Maybe weld up the underwing exits so the don't exist anymore and then install the roof hatch?

I think we looked into that, it would take an STC and TC says you can't change the aircraft from the way which it was originally certified.

What's the reason for the 9" corridor?

The 9" corridor is supposed to be the access for the pilot to the cabin and vice-versa. They say it has to be a 9" corridor from the floor to the roof, so even if you wanted to put a 1/4" board of plywood flat on the floor and strap it, you wouldn't be able to because its blocking the "floor to ceiling corridor". Ridiculous.

As ettw was saying, we often carry just a couple pax with tons of gear, and an atv or skidoo into the bush. With 2 people sitting at the back, they have 1 exit each. And the twin isn't like some pressurized a/c where if something were to happen the doors might get stuck. In an emergency landing or crash where there is some twisting or bending of the fuselage, i feel like the doors would be more likely to pop open than close shut.

Interestingly, the CARS can probably answer that question for you - and I don't think you'll find this is a recent change:

Thanks for your response. With all due respect, i don't think you were who i was targeting with this post. I know what the law states in the cars. With this post i was looking for constructive ideas and responses not interpretation of the law, TC does that well enough on their own. Good idea with the exemption to the cars, think thats a route already explored though. Seems TC won't budge. Im really looking to hear from others about how they're affected or dealing with their own twin combi-ops.

The twin otter has more emergency exits per pax than any other aircraft i can think of. With the overhead hatch, 7 exits. a 767-200 has 6 emergency exits.

It's as if they just wants to make it so hard and un-economical to fly the twin everyone will have to park them. Don't get me started with the 9 pax limit starting in 2010.

Frustrating......

[Brantford Beech Boy]

Many moons ago when I flew DHC-6 in the north, we loaded all the freight and bags at the rear of the cabin and pax up front.
This blocked the right rear door but the other 5 exits were easily to get to. Problem solved.


I know TC doesn't like cargo behind the pax without a bulkhead, but I don't know of any regulation dpecifically prohibiting it.
Of course the was restrained so as to prevent them from shifting during movement of the aircraft on the surface and during take-off, landing and in-flight turbulence with multiple 9G herc straps.

I remember a rumour that TC was going to require us to have cargo blankets but that never came to fruition.


but again, that was many moons ago.

BBB

[snoopy]

twinotter3H,

You may not have been targeting non-DHC-6 pilots, but the 600 series CARS do apply to everyone, including DHC-6 pilots. I realize you are asking how others deal with this loading problem, but the way you ask the question suggests that this reg has been ignored by DHC-6 pilots for the last 40 years.

You seem upset on behalf of your operator (maybe you're the operator) regarding the loss of profit. What I don't get is, if you load the aircraft in compliance with the CARS, and you have to do two trips instead of one, a) you get more flying and b) the company makes more money.

If all the DHC-6 operators operated in the same way, everyone would be flying legally, safely and making more money.

So what is wrong with that? Why sell the airplane short just because "its always been done that way?"

If it is really critical for the maximum efficiency of the aircraft to load it in the way you've been doing it, why didn't DeHavilland, Bombardier and now Viking, include provisions for this in the type design for the airplane. I'm guessing the manufacturer would want the liability/responsibility - but why not ask them?

Anyway, thanks for listening, and carry on....

cheers,
snoopy

[Cat Driver]

With this post i was looking for constructive ideas and responses not interpretation of the law, TC does that well enough on their own.

The interpertation of the law by TC will vary from inspector to inspector....region to region.....but most important is their own agenda at the moment for how they interpet it.

I share your frustration with dealing with these issues because common sense will never enter the picture.

Snoopy has her head in the wrong place on this one with the comment that double the trips will make you more money because chartering airplanes is already very expensive without doubling it.

What a goofy industry.

[Rudy]

I don't know what the passengers look like in your neck of the woods but there's no way that 95% of mine are fitting into a 9" gap.

Don't get me started with the 9 pax limit starting in 2010.

More info on this please.

[Widow]

How does snoopy have her head in the wrong place? If you are an operator, don't you make more money on two trips than on one? Can't the same be said, plus the added bonus of extra hours for the log-book, often be said of the pilot?

It may cost the company/individual who is paying for the charter(s), but isn't that to be expected if one is to comply with the rules and therefore remain insured?

If they weren't enforcing the rule for the Twin Otter before, maybe something has happened that has reminded TC of why the rule is there to start with ... there seem to be quite a few old rules that they were lax about that they are now beginning to enforce.

[Cat Driver]

widow the point I was making is the whole "rules " thing in aviation has become so complicated and in some cases just plain goofy that everyone gets frustrated trying to conform.

This is a perfect example:

The 9" corridor is supposed to be the access for the pilot to the cabin and vice-versa. They say it has to be a 9" corridor from the floor to the roof, so even if you wanted to put a 1/4" board of plywood flat on the floor and strap it, you wouldn't be able to because its blocking the "floor to ceiling corridor".

I will not argue with you or Snoopy over this for two reasons.

(1) I have been in this industry long enough to know what is safe and to also understand stupidity when I see it. ( see above quote. )

(2) I know both you and Snoopy and have no desire to get into un-winnable arguments with either of you.

[snoopy]

Cat,

I have no desire to argue with anyone, nor change how other individuals fly their aircraft - I can only control how I fly mine.

What I posted above are the CARS, and they are quite clear, and in my mind, not unreasonable. The 9" width stipulation to the aisle, which is a requirement, is a TC interpretation or policy - not a law. That is why we need an industry ombudsman, and/or independent legal review board accessible to both sides - TC and industry. That way, regional and individual interpretations of the CARS would be eliminated. twinotter3H didn't mention his/her alternative suggestion to comply with the regs. Is that because he/she didn't have an alternative method to comply, or that TC didn't agree?

The CARS are what they are, and when the accident happens, they are the laws that prevail, and determine the validity of the C of A, insurance, pilot license, operator certificate and ultimately dictate who goes to jail.

It may be onerous, but there is a process in place to have laws changed and/or seek exemptions in order to protect your ass and keep you legal. The flip side is that TC has to (or is supposed to) go through the same process before changing the regs willy nilly.

If the need to operate the aircraft outside the regs is that critical, and I am not saying it is or it isn't, then the option is there. Otherwise, one has to hope they don't get caught with their pants down.

[MUSKEG]

I am sure most of you know how this works but in case you don't.

1) Lets say that a DHC-6 trip cost 4000.00 to move 3500lbs freight for fishing lodge in 2008. That is divided amongst 10 clients and low and behold at 400 bucks each you have enough clients to go around.
2) Same senario only double the cost for the same freight. Suddenly 800 bucks each to fly 50 miles to fish, not today sorry.
3) Fishing lodge closes and nobody flies.
4) Double your money does not work when most of the clients are useing money from the discretionary spending ledger.
5) But hey progress was made as nobody got hurt. Why to go T/C you did your job.
6) As long as there is work to do, mistakes will happen and people unfortunately will get hurt.
7) You can legislate the safest work place, but you can't legislate common sense.

[Widow]

If the client can't afford to do the trip "legally", then the client can't afford to do the trip.

This seems to be an especially cutthroat industry, and I don't see the harm in a few companies being forced out of business because they can't afford to operate legally.

That being said, if special circumstances can be proven to be safe then exemptions should be permitted. If, once proven safe it still isn't permitted - because of rigidity or lack of common sense - then it proves the case for an ombudsman, as snoopy pointed out.

[hydraulic fluid]

A wake up call to all us pilots....this will make loading the C-185 and twins alot easier.Can I put a passenger in the front co-pilot seat and have only the pilot door as an emerg. exit,then fill and block the 2 rear doors with frieght.

[CD]

What's the reason for the 9" corridor?

It would appear to be an aircraft design requirement from the certification standards. In the aircraft certification world, you will find that 9" is the minimum permissable aisle width. The basic current design requirements in 523.815 for commuter category aeroplanes indicate that the width of the main passenger aisle at any point between seats must equal or exceed the following values:

Number of Passenger Seats: 10 through 19
Less than 25 inches from the floor: 9 inches
25 inches and more from the floor: 15 inches

Depending on the certification of the exits, there are different provisions based on the configuration:

Number of Passenger Seats: 10 or fewer
Less than 25 inches from the floor: 12 inches (A narrower width not less than 9 inches may be approved when substantiated by tests found necessary by the Minister)
25 inches and more from the floor: 15 inches

Number of Passenger Seats: 11 through 19
Less than 25 inches from the floor: 12 inches
25 inches and more from the floor: 20 inches

[snoopy]

Hi CD,

Thanks for that - interesting to know.

Hydraulic Fluid,

"A wake up call to all us pilots....this will make loading the C-185 and twins alot easier.Can I put a passenger in the front co-pilot seat and have only the pilot door as an emerg. exit,then fill and block the 2 rear doors with frieght."

You'd have to compare what you just said there, with the regs. It's been a while since I flew the C-185, but there weren't any aisles in it, as near as I can remember. Also, the CARS referred to normal and emergency exits accessible to the passenger.

cheers,
snoopy

[hydraulic fluid]

True snoopy,but alot of times a 185 pilot will put cargo behind the pilot seat ,along side the rear seat pass...thereby blocking the left hand door

[MKIII]

As an affected DHC-6 crew member. Let me tell you that we tried real hard to find solutions in order to comply with that new enforcement that we lately got from transport. The thing is, they don't want to hear a thing.

Like Cat Driver said on a previous reply, it seems that transport doesn't have the same way to apply the regulation from a region to another. Here in Québec, we have to keep row #1 and #2 free of any cargo (the first row being ahead of the underwing emergency exits for those not in the know), which becomes a CG loading issue as we almost always end up beyond the aft enveloppe if we take all the legal weight we're normally allowed. So we have to bump more stuff in order to not sit the plane on it's tail once the passengers sits in.

But I know from someone who operate in the prairies and northern region that transport allow them to block 1 underwing exit as long as they have the aisle way from the cockpit to the cabin, which means they can put cargo in row #1 and #2.
We can deal with the fact that we cannot put an ATV or Ski-Doo with paxs anymore, but reducing or cargo space that much, while others are not required, really doesn't help me give more credibility towards TC.

Back in the days, the big heads at TC used to be pilots with background in the industry (That's probably why there's some exemptions about the DHC-6 in the CAR's!!), but nowaday, they are getting replaced by lawers and other pepeole without any aviation background who don't see the logic of applying or doing regulations that reflect the environnement we fly in. It's much easier to wait and see what the FAA is going to do an do a copy paste of the US regulation afterward.

MKIII
DHC-6 Captain

[Cat Driver]

Back in the days, the big heads at TC used to be pilots with background in the industry

Yes and one could communicate with them both ways.

Now it is a one way street line of communication and regardless of how stupid their position may be there is only a one way communication.

I'm betting the old Cat will live to see these idiots completely @#$! up aviation to the point no one can afford to charter airplanes and there will be no aviation period.

[twotterflyer]

A small story!

Some years ago on my last trip into a camp on ice in the spring (beginning of June) with a combi load (a mixture of camp supplies and people) and only one emergency exit(RH underwing) blocked by plywood standing on side strapped and secured my R/H main wheel broke through the ice at taxi speed. By the time I had shut down the engines (lucky no prop strike) and looking towards the cabin to tell the passengers to evacuate the only thing I saw was the left hand main entrance door open and all the passengers out on the ice watching to see if it was going to sink!

This goes to show that in a case where there are many exits and even though you brief all the passengers on the available exits they will be more likely to use the exit they entered.

The plywood in turn became handy to get the bird out of the hole.

[PanEuropean]

TwinOtter3H:

Here is a possible solution to the problem you face.

The two emergency exits under the wing were introduced to comply with SFAR 23 regulations (Mod 6/1193 and SB 6/201 at Revision A refer). They are not required if you are operating under the original CAR 3 certification of the aircraft, however, all Series 300 aircraft are equipped with them.

The requirement for four emergency exits in the cabin is reasonable if the cabin is full with 19 people - just the same way the requirement that a 747 have 8 full size exits (4 on each side) is reasonable if the 747 is fully occupied with passengers. I do recall quite clearly that when Air Canada was operating 747 Combis, the last 2 exits at the back of the aircraft were unavailable to the passengers, because a solid wall was installed immediately aft of the L3 and R3 exit doors. Only cargo was carried aft of that solid wall.

I think you could make a reasonable case to your TCCA operations inspector that if you restrict passenger occupancy to 9 passengers or less, then safety would be adequately served by having the passengers in the last 3 rows and only having the two rear cabin exits available. That's no different than the interior configuration of any ATR (where the crew are blocked off from the passengers by the baggage).

The key issue, I think, is the concept of '9 passengers or less'. If you try to use that strategy, I think you might get somewhere.

I don't think that the TCCA people are out to make your life miserable, nor are they out to impose economic hardship. They just have to enforce the rules the way they are written. In light of that, if you can make a good argument that you can offer an equivalent level of safety (that is the key phrase) by limiting occupancy on combi runs to 9 passengers or less, and partitioning the cabin into a front (cargo) and rear (passenger) space, and you write a SOP to address that, then I think your TCCA guy (or girl) will listen to you. Be aware that you may need to have a functioning PA system (so you can talk to them in an emergency) if you implement this strategy.

[Edo]

This sounds like the proposed AD to the c-206, it was dropped after COPA and commercial operators protested. It dealt with the 4 pax config.
Normally a 206 would be loaded with 1 in the co-pilot seat, 2 in the center and 1 on the right hand side, near the exit. As per the proposed AD anytime there was more than 2 pax one center seat would have to be removed and no freight was to be loaded on the floor. So for 3 pax one still had to sit in the back, for 4 pax 2 had to sit in the back 1 on the middle and 1 in the co pilot seat. pretty hard to keep a 206 in cofg limits in that config. this would have effectivy turned the aircraft into a 3 place aircraft. might as well have a 185.
And before anyone slams me i agree the doors on the 206 suck for the back pax, but its still a 5 pax aircraft, thats the way it was certified. i always briefed the pax on the use of the back door, then told them to follow me out the front left door if we ever had to evacuate.

In the end it was realized that to conform to the AD it would almost always place the a/c out of aft limits when carrying 4 pax.

Common sense should prevail on the twin otter as well, I fully agree if you have 13 pax all exits need to be accessible, but if you have 2 pax load her up and keep the 2 big doors open at the back.

Whats next, will we have to remove the bulkhead from all caravans now? how many people can squeeze past the bulkhead to get to one of the crew exits? As it stands now you have to take the bulkhead out on floats, but not wheels.

[Cannonballer]

Did i mis-interpret or will this also hinder the way Caravans and Otters are loaded aswell as the -6?

[PanEuropean]

Cannonballer: Did i mis-interpret or will this also hinder the way Caravans and Otters are loaded as well as the DHC-6?

I don't think the issue is quite the same for the Caravans and DHC-3 single Otters, because these two aircraft don't have four exits in the cabin.