Posted 13 years 33 days ago ago by Admin
By Ron Whitney - Managing Editor
The Federal Aviation Administration announced on Oct 7, 2010, via a Notice of Proposed Rule Making (NPRM), sweeping new equipment and regulation changes in an effort to enhance the safety of all helicopter operations. While this action has been expected for many months, there will no doubt be a great deal of debate and political wrangling before any changes are actually put into place.
The NPRM process works like this; The FAA determines a particular need. They then gather information from both internal and external (operator) sources, conduct an analysis, hold a series of meetings, determine a reasonable solution, then present it to the Administrator. The Administrator then approves the plan and a NPRM is recorded in the Federal Register. Once that is complete a ninety-day comment period begins, where all parties are given an opportunity to state their position, recommend changes, lobby for additions and deletions. Once the comment period has ended, in this case January 10, 2011, the Administrator then approves or disapproves the final rules and the result becomes regulatory.
What these proposals could mean for Air Ambulance operators;
1. Require Helicopter Terrain Awareness and Warning Systems (HTAWS)
2. Seeks comments on recording systems for light aircraft.
3. Conduct all operations with any passengers under FAA Part 135.
4. Require Operational Control Centers if the operator has more than ten aircraft.
5. Mandate safety briefings for medical personnel.
6. Amend requirements for visual and instrument flight planning.
7. Ensure pilots hold an Instrument Rating.
What these proposals could mean for ALL commercial helicopter operators:
1. Revise Instrument alternate weather minimums.
2. Pilots must demonstrate proficiency in the recovery from inadvertent IMC conditions.
3. Equip their aircraft with radar altimeters.
4. Change the definition of “extended overwater operations”.
5. Prepare, transmit, and establish procedures to keep a Load Manifest (passenger list) on file and accuracy.
As we go to press only a few of the industries associations have commented on the FAA’s proposals. The key word here is proposal. It is rare that the first NPRM is what actually becomes regulatory. The changes proposed by the FAA were not unexpected.
The ironic aspect of this NPRM is that most of the well established air medical ambulance operators already have deployed the equipment mentioned above, and adopted the proposed training and operational changes. This begs the question, what will these new rules actually change?
One aspect which will change, should these proposals become rules, is that all air medical operators will be required to equip their aircraft, train their crews, and conduct their operations in a fair and standard manner. How that will be monitored remains to be seen.
Many in the industry were quite surprised the FAA did not address what is believed to be the most pressing issue, flight at night or during reduced visibility. Night Vision Goggles, along with Enhanced Vision Systems have been proven to increase the safety margins when crews are properly trained in the use of such equipment. However, the FAA did not make a move to require this type of equipment, at this time.
It was also speculated that the FAA would mandate the installation of Traffic Collision Avoidance Systems (TCAS), but the subject was left off the table this go around.
It is worth noting the FAA, in their press release announcing the NPRM, felt it was necessary (required?) to measure and comment on the economic impact of these proposed rules. Begs another question, are we more concerned with the cost of safety?
We are very interested in your opinion on these new rules, send us an email at [email protected] or comment here and let us know what you think.