I Am From the FAA And I Here To Help You! [Archive]

mfriskel

4th Oct 2011, 01:46

I sat in a court room and watched 2 FAA Safety Inspectors tesify, under oath, that you were not allowed to operate in the Hv curve. One was supposedly a long time utility pilot who had over 5000 hours of utility flying under his belt, and it was his opinion that you should not enter the Hv curve. The other was a recent military departee who had never flown commercial at all, but testified that you were not allowed be enter the Hv curve. They did not differenciate between power settings or loads, take-off, landing or slow-flight, just a blanket statement that it was not allowed. The truely sad part is that the Federal Judge ruled in their favor. I guess these inspectors don't require maximum performance take-off on evaluations.
The bottom line is the FAA is not your friend, is not always competant and is never to be trusted with your livelyhood.

HeliTester

4th Oct 2011, 03:03

mfriskel,

Please explain exactly when (in your opinion) it is OK to enter the H-V avoid area.

HT

mfriskel

4th Oct 2011, 03:37

In most single engine helicopters I have flown, you are in the "depicted" Hv curve any time you perform a maximum performance take-off.

Most long-line operations keep you in the Hv curve.

Many times you will see yourself in the "depicted" Hv curve during steep approaches.

When you look at how and where the "depicted" Hv curve is developed, it only is applicable and max gross weight, take-off power applied and within the curve. With that, you can see that a take-off at 100% power and max gross weight may place you within the "depicted" Hv curve at 40 knots while performing slow flight at the same gross weight, altitude and airspeed could well put you at a low power setting and in a condition favorable to a successful autorotation. Add a 20 knot headwind and it is no big deal.

When you tear it down further- and what the inspectors could not understand, is that the Hv digram applies to specific conditions. Outside of those conditions the digram may or may not apply. You may even find yourself operating outside the depicted diagram at a density altitude that does not afford capability to do a successful autorotative landing, even to a smooth hard surface.
You may find yourself well within the "depicted" curve but at a lower density altitude than chart was developed at and have much improved autorotative capabilities.

The Hv diagram is normally located in the "performance" chapter of the flight manual, and not the "limitations" chapter. If there is an operational need to operate in the depicted curve, nothing regulatory prohibits it. If you have an engine failure within that area, do not expect the aircraft to fare well. From the engine failures we have seen in the industry over the past several years, it seems there is no need for an Hv curve as most helicopters, and unfortunatly many occupants do not fare to well even in an engine failure from normal cruise.

Gordy

4th Oct 2011, 05:26

HeliTester

Please explain exactly when (in your opinion) it is OK to enter the H-V avoid area.

You are joking right? You do realize that almost all external load operations are conducted inside the "shaded" area on the H/V curve?

kevin_mayes

4th Oct 2011, 06:17

Hi, Chaps...
A good example of "inside the curve" would be Octobers Calander picture?
Kev.

HillerBee

4th Oct 2011, 06:25

incompetent, it's hard to believe :ugh::ugh::ugh:

HV Curve is not a limitation (it's to avoid if possible), helicopters are useless if it would be.

170'

4th Oct 2011, 06:26

Helitester...

Please explain exactly when (in your opinion) it is not OK to enter the H-V avoid area.

170'

westhawk

4th Oct 2011, 06:36

Yeah that avionics inspector looks pretty silly in the video. I doubt one could find a better witness for the operator at any price. In my dealings with FAA inspectors, I've rarely encountered such a nimrod, but they are out there. I was once ramp checked by the inspector who was once pretty well known as the dope who grounded a light twin for "bent props". He had previously been assigned to an airline and had no idea that "Q-tip" props existed! I felt sorry for him because he was actually a decent fellow. But he sure screwed the pooch on that one.

As to the operator in question, this outfit has been known to me for years as an operator to steer well clear of. Their safety record (http://aviation-safety.net/database/operator/airline.php?var=7216) speaks for itself and word around the 135 business has never been complimentary of this operator. Training, crew duty and maintenance issues have been areas where credible individuals have accused them of cutting corners and that's being kind. The instances cited by the FSF in the above link are just the tip of the iceberg in terms of incidents which have occurred.

It's no small wonder the FAA went after them, but it's inexplicable that they sent the bench warmers to do the job. The old NASEP inspection teams would have documented the evidence needed to close the book on these guys for good. Even the regular FSDO guys I've dealt with over the last 20 years would do far better. Inexplicable.

SASless, I see you're in Destin so I hope I'm not treading on any toes, but these guys are bad news and give 135 an even worse name than it deserves. (if that's possible!) They represent the on demand business at least as poorly as this inspector represents the FAA. I wouldn't work there if it was the last job in aviation.

One more thing regarding avionics inspectors: They are not required to hold an A&P certificate because their primary duties are supposed to be the inspection of avionics equipment and documentation for regulatory compliance. It's normal to see them working with OPS and Mx inspectors on base inspections, but this guy should never have been tasked with any responsibility for airworthiness inspection. The manager in charge and the overseeing regional legal council have some explaining to do.

170'

4th Oct 2011, 07:22

Westhawk...

Smart, well balanced post, and many of us know what you're saying to be true.

However, as the Fed's like to say; Rules is rules (paraphrasing) but there's that sticky little number called burden of proof.

No argument that the outfit concerned merit a severe slap in the chops, but this Inspector (POI) is beyond the pale. Did he actually know what a deposition is? and that he would be required to support his demand for emergency revocation with something, anything, that even vaguely resembled proof of non-compliance.

The entire thing is embarrasing to watch and the guy seems oblivious to the fact that it looks like a 'witch hunt'...The judge is unlikely to bring the operators reputation into consideration, and that's a good thing in this case that reputations are not considered, as their legal reputation could only be considered flawless after 30 years with no violations, But the fact wasn't challenged by the fed. Although he was a hurting unit by that point and was looking for the nearest door...

It couldn't be that hard for a smart POI to 'get the goods' on theses guys, but apparently the FAA is fresh out of smart or even partially competent POI's...

Blue skies...170'

vfr440

4th Oct 2011, 08:43

A close and long-time friend of mine is a DAR. He phrases the new approach from FAA thus
"We're not happy, 'till you're not happy" :ugh:

Some truth in this? - VFR

SilsoeSid

4th Oct 2011, 10:39

I can't be the only one looking forward to HeliTesters attempts to dig his way out of that hole !
:ok:

mfriskel, cracking explanation, I especially liked the highlighting of where to find the H/V graph.
:D

mfriskel

4th Oct 2011, 12:01

Check me if you have access to a current flight manual- is the 212, 412, 204 and 205 HV in limitations or performance chapter? They used to be in limitations, so in their case there is a good argument.
Still that would be a take-off limitation not an operations limitation. Wiggle room for operators.

[email protected]

4th Oct 2011, 13:09

Hey - didn't that guy in the video used to advise the Bush administration on foreign policy?:E

bigglesbutler

4th Oct 2011, 13:52

Hey - didn't that guy in the video used to advise the Bush administration on foreign policy?http://images.ibsrv.net/ibsrv/res/src:www.pprune.org/get/images/smilies/evil.gif

I thought it was advice on the banking sector.

SilsoeSid

4th Oct 2011, 14:14

mfriskel,

Woa, hold on there cowboy !
I was on your side :confused:

SASless

4th Oct 2011, 14:27

The issue is the competence of the FAA Inspector, his preparation of the case against the Operator....and not the Operator.

If the Operator warranted being shut down...make your case...and take action.

Assumptions don't cut it.....facts do.

Either the aircraft had overflown a 100 hour inspection or it had not. If it had flown more than a hundred hours and the Logbook did not show accurate entries...then that is a violation. Operating on the idea of what a guy said and not documenting the evidence is culpable negligence and in the case of an FAA Inspector....criminal conduct.

If the Operator had a long history of being an "outlaw"....why had the FAA not shut them down long before now...and why would it be hard to make a case?

A NASIP Team could make mince meat out of an outlaw outfit!

Thomas coupling

4th Oct 2011, 14:45

I wonder if (unknowingly) the FAA have contaminated the industry with statements like this, re the Dead man's curve.

Any yankee drivers out there genuinely believe the HV curve is a no go zone?

Be honest.........................

mfriskel

4th Oct 2011, 15:51

mfriskel,

Woa, hold on there cowboy !
I was on your side

I was just trying to be accurate and admit that some manuals may have the Hv as a limitation, but only a limitation for certain operations ie take-off

Most manuals that I reference do not have Hv as a limitation.

HeliTester

4th Oct 2011, 21:55

Regrettably my earlier comment helped steer this discussion off-topic, but I think one more off-topic post is necessary to address the already posted the H-V comments.

mfriskel,

Thank’s for your thoughtful response. Your bottom line is basically the answer I was looking for. From a regulatory standpoint if the H-V diagram is located in the RFM Limitations Section it is not legal to enter the avoid area, but that’s not the case if it is located in the Performance Section where it is provided for information. I note that for Transport Category helicopters with more than 9 passenger seats the H-V diagram must be placed in the Limitations Section, but if those helicopters are configured with 9 or less passenger seats the H-V diagram may be placed in the Performance Section. I don’t know the reason for the FAA Inspectors’ testimony that you referred to, but if it was within the context of a large Transport Category helicopter accident resulting from engine failure within the H-V avoid area they might have been correct.

Gordy,

I recognize that an external load operation is a different animal, and FAR 133.47 states that the H-V diagram need not be placed in the RFM Limitations Section.

HillerBee and 170’,

If the H-V curve is located in the RFM Limitations Section it is most certainly a limitation, and it is not OK to operate in the H-V avoid area.

Whether or not the H-V curve is located in the Limitations Section or the Performance Section of the RFM it is an entity to be respected. Engine failures occurring within the H-V avoid area typically result in bent metal or worse. Based on my experience and that of my colleagues, helicopter manufacturers damage more aircraft during H-V envelope development testing than structural flight testing.

John R81

4th Oct 2011, 22:36

I always understood that the HV is drawn for take-off. An auto may take you straight through the HV curve but there is no "avoid" required (or possible!). I thought the approach to landing was something else.

Or did I misunderstand?

John

mfriskel

4th Oct 2011, 23:38

Part of the statement from the A139 located in the limitations chapter. Doesn't say do not enter, just safe landings can no0t be assured.

HEIGHT- VELOCITY LIMITATIONS
The Height-Velocity diagram defines, in the event of a single engine
failure during take off, landing or other operation near the surface, a
combination of airspeed and height above ground from which a safe
single engine landing on a smooth, level and hard surface cannot be
assured.

westhawk

5th Oct 2011, 02:26

There's no doubt the feds stuffed it up in this case and it will affect their credibility in the future. I wonder if they still have national teams capable of competent investigation. At the least, I hope the operator in question makes a more genuine effort towards compliance and safety.

170'

5th Oct 2011, 07:49

Helitester...
last para for westmark (sorry, got confused)

As you know,the posters on pproon hail from all over the blue ball (#0000FF oblate spheroid in JAR speak )

And each with different backgrounds.

Many of us work in longline ops where we are obviously inside the upper knee of the HV diagram from sunup to sundown. Now normally (but not every jurisdiction) we can`t carry pax. But a regular occurance is that we work into very tight LZs and Helispots with the longline, but 2 hours later we might drop the line off and we are moving pax in/out of those same LZs. I´m talking sometimes up to a nearly 250' vertical descent/ascent.

I´ve used nearly every kind of single and twin in this work, and many of them aged machines. some 212´s with the HV in the limitations and others not (as one example)

Now most of these are ops overseen by the oil comp safety guy(s) and NAA of the state (country) concerned.They are fully legal operations performed smack dab in the center of the HV on both arrival and departure with pax onboard.

The operations are performed with similar risk to EASA/JAA performance class 3;
as a 212 (or obviously an AS350B?) in a 200' hover with 8 (4 or 5) juggies on board will not fly away OEI no matter who´s driving. Especially if you've already dropped below the tree tops :eek:

Now you could claim that these ops are illegal due to the HVD being in the limitations section. I don´t know of an adequate response to that except that if an NAA approves the operation via Ops Specs or similar, it overrides other statutes... These ops are performed daily around the world ... That was the basis for throwing your question back at you inverted. Many people work in the HV on a daily basis, legally and as safe as we can make it with the equipment we´re given.

If you're in a situation where you never need to work in the shaded area of the HVD, it makes sense to avoid it as simply common sense. Although in many circumstances, a new player would be better advised to risk an approach slower and enter the HV, than to approach too hot to an unprepared site, especially if any serious elevation is involved. Just my personal opinion!

Finally, re your comment that the outfit in question ' hopefully will straighten up and fly right' in the future (paraphrased)... It's wishful thinking Amigo...

Remember the expression? "you can't polish a t#*d "

Blue skies...170'

topendtorque

5th Oct 2011, 22:00

Excellent post 170', especially the bit about the careful approach to a high DA. I wonder how the fabled "helitester'"would accomplish that if he first issued instruction to a newbie, "thou shalt not allow the aircraft into the danger side of the HV curve".

What a dill, and like everyone else I am waiting for a suitable reply from him that relates to the real world.

Re the beak,

What seems most fascinating if not ferociously debilliating about this case is the prospect of any such like appearance before the same or similarly so called learned adjudicator, was the demonstration of a total lack of awareness of the difference between the precautionary principle and the imperitive instruction.

Also surely his learnings and skill sets must enable him to recognise a parochial but incorrect assertion from any galah regardless of that galah's employ.

Re the real world, found this on another web site, quite neat - and a timely reminder of what we do with these facinating contraptions, every damm day.

"If a man is in need of rescue,

an airplane can come in and

throw flowers on him,

and that's just about all.

But a helicopter could

come in and save his life."

Igor I Sikorsky

(the inventor of the modern helicopter )

HeliTester

6th Oct 2011, 22:42

topendtorque,

I agree that the 5th October post by 170’ is a good one. He took the time to explain that external lift and confined area operations within the H-V avoid area are sanctioned by NAAs via Operational Specifications and Operational Approvals. I understand and accept that. What I don’t understand is your demeanor.

HT

Gordy

6th Oct 2011, 22:59

Helitester

external lift and confined area operations within the H-V avoid area are sanctioned by NAAs via Operational Specifications and Operational Approvals.

They are not really sanctioned...in most helicopters there is NOTHING prohibiting it.

SASless

7th Oct 2011, 02:09

From one portion of the FAR's.....

Sec. 136.13

Helicopter performance plan and operations.

[(a) Each operator must complete a performance plan before each helicopter commercial air tour, or flight operated under 14 CFR 91.146 or 91.147. The pilot in command must review for accuracy and comply with the performance plan on the day the flight is flown. The performance plan must be based on the information in the Rotorcraft Flight Manual (RFM) for that helicopter, taking into consideration the maximum density altitude for which the operation is planned, in order to determine:
(1) Maximum gross weight and center of gravity (CG) limitations for hovering in ground effect;
(2) Maximum gross weight and CG limitations for hovering out of ground effect; and
(3) Maximum combination of weight, altitude, and temperature for which height/velocity information in the RFM is valid.
(b) Except for the approach to and transition from a hover for the purpose of takeoff and landing, or during takeoff and landing, the pilot in command must make a reasonable plan to operate the helicopter outside of the caution/warning/avoid area of the limiting height/velocity diagram.(c) Except for the approach to and transition from a hover for the purpose of takeoff and landing, during takeoff and landing, or when necessary for safety of flight, the pilot in command must operate the helicopter in compliance with the plan described in paragraph (b) of this section.]

mfriskel

7th Oct 2011, 02:15

Applicable to commercial air tours

SASless

7th Oct 2011, 02:18

Quoting Nick Lappos from an earlier post here at PPrune on the very subject.....and I think he sums it up quite nicely!

NickLappos22nd Aug 2006, 11:31
Having made a living producing H-V charts and the like, let me put my thoughts in a nutshell (it is coincident that my next Flight Dynamics column in "Heliops" is on the H-V curve, look there for more details!):

1) The H-V Curve is only precise at the one tested condition of weight, altitude, wind and temperature, it can be very very inaccurate if you are at a much lower weight, higher wind or much lower altitude/temp.
2) Is based upon programmed delays in lowering the collective. If you are quick as a bunny, your personal H-V ciurve would be much smaller, if you are slower, you cannot trust the H-V curve because it is too small for you.
3) If you are descending, the H-V curve is wrong, the real one would be very much smaller.
4) If you are climbing, the H-V curve would be very much bigger.
5) If you have 5 knots of steady wind, the H-V curve would be very very much smaller. With 20 knots of wind, there is practically no H-V curve.

It is my opinion that the H-V curve is a single point check of the engine-out performance, useful as only a general guide. It is not a bibical statement of assurance, but it is also not to be ignored. In a world where many people call for absolute, "thinkingless" solutions to problems, the H-V curve serves as a testament that you just can't put complex performance issues into one chart. To those who want absolutes, go into the toy business, helicopters are not for you!

topendtorque

9th Oct 2011, 10:32

Helitester,

Please understand that if you put "out there" that no one should ever contemplate flying inside the H-V curve especially here where so many newbies look about for tips and guidance, I would have to say something.

The reason is simple. The newbies instructors would have already told them about the dangers of it and hopefully have briefed them that when they are doing confined areas approaches, especially in high DA, that they have to fly within it.

Part of the license test I hope.

To allow them to think that they can accomplish those maneuvres without entering the lower side of the H-V curve is dangerous to them.

It would be deserving of a good kick in the pants for anyone who is careless enough to allow his words for that impression to be gained.

That is my demeanour.

cheers tet

SASless

14th Oct 2011, 12:42

Now we hear the FAA is opening up yet another investigation....is this a case of Penis Envy....or an inspector holds some prurient interest in the situation?

FAA Investigates Skydiving Sex Stunt | NBC San Diego (http://www.nbcsandiego.com/news/weird/FAA-Investigates-Skydiving-Sex-Stunt--131818208.html)

Shawn Coyle

14th Oct 2011, 13:53

So an operations rule can override a limitation? Does that mean that if the operations rule required you to exceed takeoff power it would mean the takeoff power limitations can be ignored?

Simply put - if you have more than 9 passenger seats on board, the HV curve is a limitation, and must - repeat must - be treated as such.

If you have an accident in a helicopter with 9 or more passenger seats, and you were in the HV curve, don't expect much mercy from the legal system.

mfriskel

14th Oct 2011, 16:00

Shawn, Would you also infer that in a medium twin ie.. the B-412, you can only take-off, land or perform low altitude operations over "smooth, level, firm surfaces"? The Hv verbage and digram both state that is the only place the Hv curve is valid.
If this is the limitation you are addressing, then a STOL airplane would be a better mode of transport than a B-412. It definatly would prohibit the B412 from operations in mountains, rolling terrain, and even farm fields and pastures.

Troglodita

15th Oct 2011, 06:38

Helitester,

I note that for Transport Category helicopters with more than 9 passenger seats the H-V diagram must be placed in the Limitations Section, but if those helicopters are configured with 9 or less passenger seats the H-V diagram may be placed in the Performance Section.

Interestingly for the Bell 412 - the FAA place the HV Diagram in the Limitations section whereas the UK CAA (that well known follower of the least restrictive limitations :ugh:) place the HV Diagram in the Performance Section of their Bell 412 RFM.

Correct me (I'm sure you will!) if you think I am mistaken, but the 412 HV diagram is labelled Figure 1-4 Height - velocity diagram (OEI) so logic would suggest that it is promulgated to apply to OEI operations i.e. in the event of a power unit failure.

My Company fly CAT Class 1 profiles that subject to sufficient space (level flat surface) being available avoid the HV avoid curve on take-off and landing but this does not preclude operations to more restrictive sites where temporary incursion into the HV avoid curve may momentarily occur during AEO operations.

Trog

212man

15th Oct 2011, 07:14

All Part 29 aircraft must have the the H/V Curve in the Limitations section. the OEMs would prefer it in the Performance section - as would most people! Part 27 aircraft had it moved from Limitations to Performance around 1987 I think (JimL will know.)

Trog - I assume you are fishing with your comments about OEI? The statement means the curve applies to loss of an engine whilst AEO - as opposed to loss of both engines - not loss of the remaining engine whilst OEI already.

Troglodita

15th Oct 2011, 09:06

212 Man - you used to do a bit of fishing yourself when you were young!

Cheers

Trog

p.s. I was serious about the rest though!

Shawn Coyle

15th Oct 2011, 19:05

mfriskel:
What an interesting question!!
In all my years of flight testing and certification work, no-one has ever raised that point. I'll see what my current certification friends say, but in the interim, the intent of the HV curve when it's in the limitations section is to make sure you don't fly there. There is a bit of flex in the determination of the curve, in that no transients are allowed to be used in determining the curve, and those will certainly help in the real event.

Garry M

15th Oct 2011, 21:12

I know this has been done to death but folk need to go to the following link and have a read up on what the HV curve is.

http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/0/eb2a60e956980ddf86257515006af6e3/$FILE/Master%20AC%2027-1B%20thru%20Chg%203.pdf

Head to page page 76 and have a read of § 27.79 (Amendment 27-14) LIMITING HEIGHT-SPEED ENVELOPE.

it is completely irrelevant for landing and approaches. While it is a limitation for 10 seats or more, I cant see how it can be a limitation to the portions of flight to which it is not applicable nor tested.

HeliTester

18th Oct 2011, 20:18

H-V Discussion Summary

There has been a lot of discussion about where the H-V diagram is placed within the RFM and when it’s OK to enter the H-V avoid area. I tried summarize the key discussion points below in an attempt to get to the bottom line.

Mfriskel points out that H-V is in the limitations section of the AW-139 RFM.

Troglodita pointed out that H-V is in the limitations section of the B-412 FAA RFM.

I recently discovered that H-V is in the limitations section of the S-76 RFM, but there is also a Supplement to that RFM that specifically addresses S-76 aircraft configured with 9 or less passenger seats in which H-V is moved to the performance section.

Shawn Coyle points out that if you have more than 9 passenger seats on board, the HV curve is a limitation, and must be treated as such.

SASless pointed out that FAR-136.13 instructs Commercial Air Tour operators to make a reasonable plan to operate outside the H-V avoid area except during takeoff and landing and approach to or transition from hover.

I pointed out that FAR 133.47 states that for external load operations the H-V diagram need not be placed in the RFM Limitations Section.

170’ points out that external lift and confined area operations within the H-V avoid area are approved by NAAs via Operational Specifications and Operational Approvals.

Shawn Coyle questions whether an operations rule can override a limitation.

212man points out that All Part 29 aircraft must have the H-V Curve in the Limitations section.

Troglodita mentions that his company flies CAT Class 1 profiles that subject to sufficient space (level flat surface) being available avoid the HV avoid curve on take-off and landing but this does not preclude operations to more restrictive sites where temporary incursion into the HV avoid curve may momentarily occur during AEO operations.

So considering all this, is the bottom line that for NAA ops approved CAT Class 2 and Class 3 operations it’s OK to enter the H-V avoid area, except for Part 29 helicopters configured with more than 9 passenger seats? And does that probably make sense because external load aircraft and air tour aircraft are typically configured with 9 or less passenger seats, and Class 1 aircraft that have Category A takeoff and landing engine failure accountability are typically configured with 10 or more passenger seats?

JimL

19th Oct 2011, 07:45

HeliTester,

Two elements that you appear to have missed:

The first is from FAR 91.9(d)

(d) Any person taking off or landing a helicopter certificated under part 29 of this chapter at a heliport constructed over water may make such momentary flight as is necessary for takeoff or landing through the prohibited range of the limiting height-speed envelope established for the helicopter if that flight through the prohibited range takes place over water on which a safe ditching can be accomplished and if the helicopter is amphibious or is equipped with floats or other emergency flotation gear adequate to accomplish a safe emergenc ditching on open water.
...and the second from Appendix 1 to JAR-OPS 3.005(c)

Appendix 1 to JAR-OPS 3.005(c)
Helicopter Flight Manual limitations

(a) For helicopters certificated in Category A, a momentary flight through the height velocity (HV) envelope is allowed during the take-off and landing phases, when the helicopter is operated according to any of the following requirements:
(1) JAR-OPS 3.517; or
(2) [Appendix 1 to JAR-OPS 3.005(i); or]
(3) Appendix 1 to JAR-OPS 3.005(e).
both of which apply to helicopters certificated under Part 29 - where the HV diagram is in the limitations section.

This was seen as a problem in the recent transposition of JAR-OPS into EASA OPS; the alleviation has been removed with a proviso that the HV diagram - as a limitation - will be resolved before implementation.

Notwithstanding all of those instances of flight in/through the HV diagram which have been described in this thread, operations in CAT cannot be undertaken without flight through the HV diagram when: operating offshore; and when operating with ground level exposure.

Until the HV diagram is replaced to the performance section, there is a need to alleviate within an operational rule for all types of operation. The FAR rule and the alleviation presently available to CAT in Europe are both too limited in scope; FAR 91.9(d) needs to be extended (to onshore) and the JAR CAT rule needs to extend to private operations. While 'heliport regulations' continue to include profiles which forces flight within the HV diagram in their projected paths, it is a head-in-the-sand attitude to ignore the fact that such operations will be conducted in non-compliance with the helicopter limitations.

Not to permit such operations would confine operations, with larger helicopters, to airfields (or large open spaces) or to operations in Performance Class 1.

There is no thing as a Class 1 helicopter; helicopters operate in Performance Classes 1, 2 or 3 in accordance/compliance with the operational rules.

Attempting to regulate the operation of aircraft from within the Airworthiness Code has always been doomed to failure.

Jim