Non-PC Plod,
Anybody with experience in a well regulated environment would think as you do. I do. However in Spain the case is different.
The ‘Dirección de Aviación Civil’ has granted all sort of exemptions to the helicopter industry (you can read ‘Inaer’ if you wish, since they are ‘the Spanish Helicopter Industry’).
For instance, since 2003 operators are exempt from producing (and obviously using) a MEL. So pilots are only left with the MMEL which is useless since much of the equipment that you may have on board (specially on a SAR aircraft), is not mentioned. Pilots then rarely refer to this MMEL since it doesn’t give you any answer. They simply make up their mind on whether they’ll ‘go or not go’ based on their common sense. But nobody will dare to write a MEL that may say ‘no go’.
In terms of licensing, in mid 2009, some of the operations that Inaer have, including SASEMAR (Coastguard) were taken off the category of ‘Aerial Work’ to a category of ‘pseudo-government operation’. That move exempted all those operations from complying with JAR-OPS 3 and JAR-FCL 2. The other piece of legislation that Spain has, the ‘Reglamento de Circulación Aérea’ has little to do with this category as well. So, with this legal frame, operators are left to write their own rules.
So, to answer your question, the authority is indeed aware that the SASEMAR SAR AW139s are being flown by pilots with Single-Pilot type rating, with no CRM, no MCC, and some with no IR.
Furthermore, most of the commanders and SAR trainers of the SASEMAR operation only hold a CPL(H). Only a handful of them (I could count them with the fingers of one hand) have an ATPL(H).
Since JAR-OPS 3 doesn’t apply, there is no OM Part B, or Part E for the AW139. It is a fact that the SAR Manual does not mention the AW139 at all. So no SOPs for the aircraft, other than a few photocopies of some ‘guides and ideas’ left by the SAR trainer during his last visit 6 months ago. No SOPs, obviously you cannot train on MCC, neither you can run a Multi-Crew Type Rating course. It doesn’t matter… it’s not required by the authority.
In terms of HUET, obviously it is not a JAR requirement. However it is a SASEMAR requirement in the contract technical specifications, but everybody has turned a blind eye to this clause. Sadly, it may have been too late for some.
How can this happen? ‘Ministerio de Fomento’ is in charge of ‘Dirección de Aviación Civil’ and ‘SASEMAR’. And 66% of Inaer operations come from one customer: The government. (Please refer to the links in my previous post if you want to confirm this information). I leave up to you to draw your own conclusions.
The union is up in arms but they have very little negotiating power, pilots talk about this everyday in private, but in the outside world silence is deafening!
As usual, if you with to know more about this, please PM me.
Regards,
verticalflight