I would like to tidy up my comments on this thread with my conclusions on the AW189 ESF CS 29.1587(b)(6) (these conclusions are an extract from Appendix A of the Response to NPA 2014-19 document posted on the H-V thread):
Conclusions on the AW189 Equivalent Safety Findings on CS 29.1578(b)(6)
Although the initiative to supply graphs that can be used to provide take-off and landing profiles in Performance Class 2 (and for ‘aerial work’ activities) is a move in the direction to removing the H-V Diagram as a Limitation, the boundaries of the ‘reject’ graph fall short of the requirements in CS 29.87, CS 29.1517, CS 29.1583 and CS 29.1587 on a number of counts:
1. The upper boundary of the ‘reject’ graph does not extended to the maximum mass specified in the RFM and therefore does not provide compliance with CS 29.87(a).
2. A failure to comply with CS 29.87(a) prevents compliance with CS 29.1587(b)(6).
Note: Compliance with 29.1587(b)(6) can be satisfied if compliance with 29.1583(f) is provided.
3. A failure to comply with CS 29.87(a) prevents compliance with CS 29.1517.
4. A failure to comply with CS 29.1517 prevents compliance with CS 29.1583(f).
Note: Compliance is not required of CS 29.1583(f) if the Category A procedures are in the limitations section or, are contained elsewhere and mandated by a statement/pointer in the limitations section.
It is not clear, from the contents of the limitations section, if the Category A procedures of the AW189 are, or are not, mandated. This is not an issue that is confined to the AW189 but is also observed in the AW139 RFM. By not showing compliance with CS 29.1853(f) (pointing to CS 29.1517), the requirement to apply the Category A procedures is indeterminate. Mandating the Category A procedures would seriously inhibit operations to other than airfields. It would prevent operations in Performance Class 2 under circumstances where such operations have been safely conducted since the introduction of the Performance Classes.
At the time when the ESF was approved, the AW189 was being introduced to offshore operations without a Category A Helideck Procedure in the RFM. If Category A procedures are mandated, this results in offshore operations in contravention to the RFM!
Even if a Category A Helideck procedure is introduced, there will be circumstances where complying with the procedure is not possible for environmental reasons. This is why there has never been a proposal for the introduction of operations in Performance Class 1 to Helidecks.
Although this equivalent safety finding is ostensibly concerned with the alternative method of providing information for compliance with CS 29.1587(b)(6), it is confounded by a lack of compliance with CS 29.1517 and CS 29.1583(f).
Jim