Gents, I have been doing external lift work for over 20 years. We always submit a CAP with the FAA unless we are working in the swamps, mountains etc.

How and why do I see saw operators flying their saw at 500 feet over my hometown (major city metro area), to include neighborhoods, four lane major roads and industrial areas ?

At some point a saw will drop out of the sky, and at 700-800 lbs - it's not going to be good !

I am not a rat, but "Come On Man !"

So, when I am doing HEC with a certified dual hook system over a congested area I dont need a cap. The regs are clear and the interpretation cosistant. If you are using 80' of stick you need 80' clear on either side of you otherwise you need a cap.

Just curious, looking at FAR 133 and the AC for 133 operations I don't see the "daul hook" system mentioned as a reason not to need a CAP. The regs and the AC does talk about what a congested area is and isn't and the general requirements for a CAP. I haven't worked with a dual hook system so I simply don't have any experience with the rule which negates the requirement for a CAP.

The reason most operators preach about overflying buildings, homes, busy intersections etc. is that, regardless of the FARs, if you drop a load and it destroys property or people the operator, and perhaps the pilot, are likely to be held to some level of legal and financial  responsibility. The easy thing to do is just avoid property or people when possible.

I agree with Utility Slug. An AC is not a regulation but it does tell you a little about how the FAA will react to a mishap or accident. If you drop a load and it hits someone the AC indicates the Feds will call it a congested area for regulation purposes. 

My original question was about daul hook loads. I just didn't read anything that changed the CAP requirements. I guess if I ever use two hook systems I'll do the research.

In the FAAs own words. The Advisory Circular "perscribes a means, but perhaps not the only means of complying with a regulation"

in other words... if you do something that does not to get cited (if you get caught) you will than be given the opportunity to explain how your "alternate means of complaince" provided an equivlent lecel of safety to yourself your passengers and the public. If you cant do so the citation will stick. 

"presence of the public" is the FAA definition of the public. If you are pulling sockline without traffic stopped or doing HEC over a road and one car goes under you that is a potential 91.119 violation.

most likely the pilot is flying the saw along the Right of Way inbeteeen dwellings etc. Our Saw company is approved by the FAA to trim trees up to 200ft from a residence or public without notification. With notification and crowd control we can continue Closer. we are approved to fly over roads, interstates etc from the FAA at a certain height with the dual hook system. obviously we are only approved to cross between vehicles. These are all approvals approved by our POI in our specific 133 manual and ops specs. obviously unless you get these approvals you are restricted to FAR 133 and the guidance of 8900.1 chapter 7 section ....

20 years? ROOKIE!!!!