Clarification on Regulations. Kind inputs from all.

[captchopper]

Hello everyone.

I am to take a discussion with the Civil Aviation Authority of my country about a gray area in regulations. I am looking forward for inputs of what the regulations say about this in different countries. I have been trying to search websites of ICAO, TC, FAA, CAA, EASA but no luck. I have copied the current regulation below.


4. Requirements of flying more than one type of helicopter.

4.1 A pilot may operate more than one helicopter type from one and/or the other group, subject to the following conditions:
(a) The procedure as described in the Operations Manual shall be strictly
adhered to and the pilot has a valid license for the type helicopter.
(b) the pilot has a minimum of 2,000 h flying experience of which not less than
1,000 h as PIC on helicopters; and
(c) 300 h as PIC either in single or multiengine helicopters as relevant; and
(d) 50 h on each type of which 2 h in the last 90 days; and
(e) A proficiency check has been conducted within the last 6 month on
type and a proficiency check has been performed on any additional type within the same Group during a 12 month period; and
(f) Meets the recurrent training requirements on type; and
(g) Operations are conducted in the same environment i.e., offshore,
mountain, EMS, or if the environment is different the pilot has 300 h
previous relevant experience.

4.4 In any case not more than 2 helicopter types shall be operated in air transport within one commercial air transport duty period.

Now the thing is i do not meet point (b) and (c). According to me, this rule should be only to fly two types of helicopter in a single day otherwise someone like me who is endorsed/rated on two helicopters would be stuck to fly one one of them till I get 2000Hrs!! What is the purpose of having two endorsements then!
Please provide me with some regulations of other aviation authorities which allow you to fly the helicopters which u are rated on irrespective how many hour you have in total. These proofs would help me persuade to settle this glitch.
Thanks!

[JimL]

captchopper,

This subject has been raised before in http://www.pprune.org/rotorheads/439610-rating-only-one-type.html

The document, from which you provided an excerpt (found on the net as www.dgac.gov.in/cars/D7B-B10.pdf), appears to be well constructed and provides the DGCA's view on what is required to include additional types on the license. Your partial excerpt covers only the operation of more than one type of helicopter.

The requirement differs from from JAR-OPS 3 - AMC OPS 3.980 (below) - mainly in the required experience before operations of more than one type are permitted.

You appear to be correct that Paragraph 4 is worded such that even though a pilot is not disqualified from having additional types on the licence, they cannot be flown ('operated' in the language of the DGCA) concurrently until all clauses of 4.1 have been satisfied.

This leads to two observations: (1) the scope of the title of Paragraph 4 is too wide, appearing to include 'Private Flying' as well as 'Aerial Work'; and (2) the flying experience in clause (b) could be regarded as too restrictive.

Strangely, the clauses that you have not included (4.2 - 4.4) are restricted to condition for operations under CAT.

Interestingly, clause (c) appears to be irrelevant as the required '300 hrs PIC on helicopters' appears to be substantially less than the '1,000 hrs PIC on helicopters' required in clause (b). I would speculate that clause (b) should not have contained the condition PIC (otherwise it makes no sense) unless it is meant to ensure that the appropriate 'single' or 'twin' hours (depending on the new type) have been accumulated.

If I were challenging this requirement, I might restrict myself to the wording (scope) of Paragraph 4, and arguments surrounding clause (b): there appears to be sufficient protection contained in the other clauses such that (b) could be removed or at least the qualifying hours reduced substantially.

Jim

1 Operators of more than one helicopter variant or type should provide in the Operations Manual:

a. Flight crew members minimum experience level;

b. The process whereby flight crew qualified on one type or variant will be trained and qualified on another type or variant; and

c. Any additional recency requirements that may be required.

2 If a flight crew member operates more than one type or variant the following provisions should be satisfied:

a. The recency requirements specified in JAR OPS 3.970 should be met and confirmed prior to commercial air transport operations on any type, and the minimum number of flights on each type within a three month period specified in the Operations Manual;

b. JAR-OPS 3.965 requirements with regard to recurrent training;

c. JAR-OPS 3.965 requirements with regard to proficiency checks may be satisfied by a 6 monthly check on any one type or variant operated. However, a proficiency check on each type or variant operated should be completed every 12 months;

d. For helicopters with a maximum certificated take-off mass (MCTOM) exceeding 5 700 kg, or with a maximum approved passenger seating configuration (MAPSC) of more than 19:

i. The flight crew member should not fly more than two helicopter types;

ii. A minimum of 3 months and 150 hours experience on the type or variant should be achieved before the flight crew member should commence the conversion course onto the new type or variant;

iii. 28 days and/or 50 hours flying should then be achieved exclusively on the new type or variant; and

iv. A flight crew member should not be rostered to fly more than one type or significantly different variant of a type during a single duty period.

e. In the case of all other helicopters, a flight crew member should not operate more than three helicopter types or significantly different variant.

f. For a combination of helicopter and aeroplane:

i. A flight crew member may fly one helicopter type or variant and one aeroplane type irrespective of their maximum certificated take-off mass (MCTOM) or the maximum approved passenger seating configuration (MAPSC) that may be carried.

ii. If the helicopter type is covered by paragraph 2.d. then paragraphs 2.d.ii., 2.d.iii. and 2.d.iv should also apply in this case.

[AdamFrisch]

As a complete outsider these regulations seem like total insanity. Who comes up with these?

Isn't it my business if I want to be type rated and allowed to fly 1 or a 1000 different types? What's it to them - if I can prove currency and ability on them, then that should be all. I've never heard such stupidity.

It would be about as sane as asking for proof of children, family and a marriage certificate when you went to buy a SUV at the car dealer..

[JimL]

Adam,

Yes, that is why the scope of Paragraph 4 is being questioned.

However, if you wish to buy a ticket and put your children/mother into a helicopter which is being flown for the purposes of transportation (CAT), wouldn't you like to know that the pilot is not diluting his skill set by flying many types?

All things being equal, normal operations are never a problem; it's when abnormal conditions obtain or an emergency occurs that skills/competence are tested.

If you wish to see other opinions on this, look to the recent discussion about flying two (very different) variants of the same type on the North Sea. Consider also flying two versions of the same type with analogue and glass cockpits.

Airbus have got to terms with this by providing the same look-and-feel for their range of models; in the same vein EC have taken a similar approach with their cockpits and autopilots.

As with all of these issues, there is nothing wrong with the principle, it is the provision of appropriately scaled regulations that is tricky.

Little is gained by sitting on the sideline and saying it is all crap - engaging in the process of provision of the rules is the key.

Jim

[captchopper]

Thanx Jim, that was very knowledgeable! Is there any link u can tell me for JAR-OPS 3.980 and JAR-OPS 3.970, a pdf maybe?

[JimL]

captchopper,

Check your PMs.

Jim