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Operations Captain Roger Cox Identity of the Operator Revenue passengers on board No one claimed to be operator Multiple entities involved in initiation, authorization, and operation Entities Involved Southwest Orthopedic - airplane owner Owner’s pilot / airplane manager

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operations

Operations

Captain Roger Cox

identity of the operator
Identity of the Operator
  • Revenue passengers on board
  • No one claimed to be operator
  • Multiple entities involved in initiation, authorization, and operation
entities involved
Entities Involved
  • Southwest Orthopedic - airplane owner
  • Owner’s pilot / airplane manager
  • Interstate Helicopters - Part 135 helicopter operator
  • Accident pilot
  • Second pilot
  • Passengers - United Engines
relationship of entities
Relationship of Entities

Southwest Orthopedic

(Airplane owner)

Second Pilot

Pilot

Accident Flight

Airplane Owner’s Pilot

Interstate Helicopters

United Engines

(Customer)

the pilot
The Pilot
  • Accident flight conducted outside his regular employment
  • Chief pilot at another company
  • Qualified to fly Cessna 500 as single pilot under Part 91
the second pilot
The Second Pilot
  • Accident flight outside his regular employment
  • Normally flew piston twin, ran flight school
  • No record that he was trained on or current in Cessna 500
pilots qualifications
Pilots’ Qualifications
  • Neither pilot employed by Part 135 operator
  • Neither pilot trained under Part 135
  • Neither would have been able to fly a clearly identified commercial flight
  • Crew awareness of commercial nature of flight unknown
southwest orthopedic owner
Southwest Orthopedic (Owner)
  • Received hourly rate when airplane used by others
  • Believed airplane was “dry leased”
  • Could not explain “dry lease” or “operator”
  • Had no written or verbal lease agreements
14 cfr 91 23 truth in leasing
14 CFR 91.23: Truth in Leasing
  • Apply to airplanes more than 12,500 pounds
  • Expanded use of airplanes weighing less for charter operations
  • May operate without FAA knowledge of lease agreements
united engines passengers
United Engines (Passengers)
  • Believed accident flight was commercial charter
  • Stated that they did not lease
  • Had used Interstate Helicopters for airplane flights multiple times
  • Stated that Interstate Helicopters’ prices were cheaper than other airplane charter operators
interstate helicopters
Interstate Helicopters
  • Part 135 helicopter operator
  • No airplanes on certificate
  • “Put the [accident] flight together”
interstate helicopters12
Interstate Helicopters
  • Invoiced United Engines for airplanes as “lease” and “sales demo” flights
  • Paid airplane’s owner for use of airplane
  • Invoicing disguised flights, circumvented operating certificate
recommendation areas
Recommendation Areas
  • Responsibilities of each of four main entities involved in accident flight
  • FAA oversight
faa oversight
FAA Oversight
  • OKC FSDO reported staffing issues, inspector turnover
  • FAA ramp checks were rare
  • OKC FSDO investigated complaints about Interstate, found no basis
faa oversight15
FAA Oversight
  • Special Emphasis Inspection
    • Purpose: Detect improper operations
    • No major issues found at Interstate
faa enforcement action
FAA Enforcement Action
  • Interstate Helicopters’ Part 135 certificate revoked September 2008
  • Interstate Helicopters reached settlement with FAA, gained new Part 135 certificate in January 2009
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