8900.1 CHG 240

Volume 6  Surveillance

chapter 5  PART 133 INSPECTIONS

Section 3  Monitor a Part 133 Congested Area Operation


6-1422    OBJECTIVE. Ensure compliance with a Congested Area Plan (CAP) and with the regulations. Successful completion of this task results in an indication of compliance or noncompliance in an operator’s file.

6-1423    GENERAL.

Indicates new/changed information.

A.    Authority. Title 14 of the Code of Federal Regulations (14 CFR) part 133, § 133.39 allows the Administrator to make the inspections and/or tests found necessary to ensure compliance with the regulations. The inspector conducting surveillance performs an essential safety function in connection with the external-load operation.

Indicates new/changed information.

B.    Frequency of Surveillance. The operator should expect the inspector to observe each congested area operation. The inspector should make his or her presence at the site known to the operator.

C.    Deviation from the CAP.

Indicates new/changed information.
1)    If the operator deviates from the CAP, it may pose a hazard to persons or property. With the exception of emergencies, deviation is not acceptable and may violate these regulations (refer to 14 CFR part 91, § 91.13 and § 133.33(d) and (e)).
2)    Refer to Volume 2, Chapter 7, Section 1 when concerned with deviations from a CAP for the purpose of an emergency.
Indicates new/changed information.
3)    The inspector may approve changes to the CAP onsite if the changes meet or exceed the criteria for original approval of the plan. The inspector should note the changes on the plan, sign the change noted, indicate the date and time approved, and return the plan to the operator.
Indicates new/changed information.
4)    The CAP submitted by the operator should contain alternative plans for as many variables as possible. With approved alternatives, the operator may not have to postpone the operation to seek Federal Aviation Administration (FAA) approval for plan modifications.

D.    Determining the Degree of Surveillance to Conduct.

1)    The operator should expect unannounced surveillance at any given operation.
2)    Normally, the inspector performs a full ramp check when an operation reveals a discrepancy. The inspector may also conduct full ramp checks as a planned work activity. (Refer to Volume 6, Chapter 5, Section 2.)
3)    Conduct the surveillance that is necessary to determine compliance.

E.    Inspector’s Role During Surveillance.

1)    It is the operator’s responsibility to conduct the operation according to the operator’s approved CAP and 14 CFR. It is the inspector’s role to monitor the operation. If the inspector observes an imminent violation, he or she must advise the operator to cease operations until the situation is corrected.
2)    Refer to Volume 3, Chapter 51, Section 6 for the criteria that the operation should meet.

F.    Followup Activities. Debrief the operator after surveillance, with an emphasis on reinforcing acceptable performance.

Indicates new/changed information.
1)    After surveillance of an operation, debrief the pilot (at the scene if possible) and the operator by written report or telephone call. This is especially important if there were minor discrepancies. Note minor discrepancies as “I” (information) in the PTRS.
Indicates new/changed information.
2)    In the event of discrepancies indicating deficient procedures, pilot proficiency, training, or equipment, advise the operator in writing of the deficiencies. A followup ramp inspection or test is appropriate. Note these types of discrepancies as an “F” (followup required) in the PTRS.
Indicates new/changed information.
3)    In the event of a possible 14 CFR violation, initiate an enforcement investigation into any violation you observe or become aware of. Note a violation as an “E” (enforcement action) in the PTRS (refer to Volume 7, Chapter 6, Section 1).


A.    Prerequisites. This task requires knowledge of the regulatory requirements of part 133 and FAA policies and qualification as an aviation safety inspector (ASI) (Operations). Experience as a rotorcraft external-load pilot is preferred but not required.

Indicates new/changed information.

B.    Coordination. Coordination with local government or political subdivisions is required. Coordinate with Airworthiness as necessary.


A.    References (current editions):

·    Title 14 CFR parts 1, 27, 29, 61, 91, and 133;

·    Advisory Circular (AC) 133.1, Rotorcraft External-Load Operations in Accordance with Federal Aviation Regulations Part 133; and

·    The PTRS Procedures Manual (PPM).

B.    Forms. None.

Indicates new/changed information.

C.    Job Aids:

·    Part 133 Ramp Inspection Job Aid (Volume 6, Chapter 5, Section 2, Figure 6-66, Part 133 Ramp Inspection Job Aid),

·    Approved CAP,

·    Camera or video recorder, and

·    Sample letters and figures.

6-1426    PROCEDURES.

Indicates new/changed information.

A.    Review the CAP. Before visiting the operation site, review the CAP. Become familiar with the restrictions, limitations, and alternatives documented for this plan.

B.    PTRS. Open the PTRS record.

C.    Onsite Activity. Observe the operation and note whether it occurs according to plan. Check for the following, as appropriate.

1)    Operational area is secured (unoccupied by persons) and the radius is at least the proper minimum size for the proposed operation.
2)    Emergency landing site secured.
3)    Adequate security available at the site.
4)    Appropriate streets blocked off.
5)    Required buildings (or proper portions thereof) are unoccupied.
6)    The length of load plus the length of attaching means (hook and cable, etc.) does not exceed the radius of the operational area.
7)    Observe how the operator picks up and carries the load and brings it to a stabilized hover.
8)    Observe whether the route follows the plan, if the operator drags the load, and whether the load bumps into obstructions.
9)    Check the delivery (set) site and observe whether the height of the load above the building exceeds the CAP.
10)    Monitor pilot proficiency. The load should not oscillate excessively. In addition, evaluate pilot coordination with ground crew.
11)    Determine the quality of ground crew performance. The ground crew should give and interpret any required hand signals correctly.

D.    Surveillance Results Satisfactory.

1)    It may be desirable to conduct a random ramp check. If so, refer to Volume 6, Chapter 5, Section 2.
2)    Debrief the operator, if desired.
3)    Close the PTRS record.

E.    Satisfactory Operation with Minor Discrepancies.

1)    Bring the discrepancy to the attention of the operator at the site or notify the operator by letter (Figure 6-70 Letter Confirming Discrepancies During Congested Area Operation), according to the situation.
Indicates new/changed information.
2)    Document discrepancies to the “Remarks” section of the PTRS.
3)    Close the PTRS record.

F.    Unsatisfactory Operation. If the operation was unsatisfactory and constituted a violation of 14 CFR, refer to Volume 7, Chapter 6, Section 1.

6-1427    TASK OUTCOMES.

·    An indication in the operator’s file of a satisfactory operation, with or without discrepancies; or

·    An indication in the operator’s file of an unsatisfactory operation.

Indicates new/changed information.


·    Possible change in frequency of surveillance,

·    Possible reexamination of pilots involved in an unsatisfactory operation, and

·    Possible monitoring of this or other operators engaging in congested area operations.

Figure 6-70.  Letter Confirming Discrepancies During Congested Area Operation

FAA Letterhead


[Name and address of operator]

Dear [operator’s name]:

We noted certain discrepancies during surveillance of the rotorcraft external-load operations conducted at [street address, city, and state] on [date and time].

[List the specific discrepancies and, if contrary to Title 14 of the Code of Federal Regulations (14 CFR), indicate the related 14 CFR.]

[Indicate how the operator did not follow the approved Congested Area Plan (CAP).]

[List corrective action, if any, taken during the surveillance.]

[NOTE TO INSPECTORS: If the discrepancy resulted in a violation, you may use this letter as a letter of investigation in an enforcement action. If the discrepancy resulted in a violation of the 14 CFR and you used this letter for enforcement purposes, add the following:]

This matter is under investigation by the FAA. We wish to offer you an opportunity to discuss the incident personally and submit a written statement. If you desire to do either, accomplish this within 10 days following receipt of this letter. Your statement should contain all pertinent facts and any extenuating or mitigating circumstances that you believe may have a bearing on the incident. If we do not hear from you within the specified time, we will process our report without the benefit of your statement.


[Principal operations inspector’s (POI) signature]

RESERVED. Paragraphs 6-1429 through 6-1445.