The real pity is the NPA 2014 -19 itself.
The reason why it was written is clearly stated in Chapter 2 at 2.1.1 of the NPA:
“ Some aircraft flight manuals present HV envelope with variables for altitude and temperature included, allowing the pilots to insert the experienced values and thereby knowing whether or not operations will be performed inside the HV envelope. Other AFMs present conservative HV envelopes based on worst case scenarios. These are not allowing pilot calculations and are very limiting to operations”.
And the consequence of this poor HV definition (see page 10-24 of the NPA) is:
“ Avoiding the HV envelope requires reduction of landing or take-off masses for some helicopters types whilst others are prevented from operating.”
Therefore, to protect the operability of these helicopters, EASA decided to propose a change to Annex IV to regulation (EC) No 216/2008. The allowance to penetrate the HV envelope during take-off and landing from/to helideck is, in fact, included in the proposal of the European Commission for revision of Regulation No 216/2008 (see the EASA “Executive Director Decision 2016/005/R of 23 February 2016) .
This allowance, if introduced in the revised regulation No 216/2008, is:
a)unsafe because, when the HV really exists, an engine failure inside the HV envelope will be catastrophic
b)unfair with respect to those manufacturers who spent money and executed very dangerous test for defining a detailed HV envelope.
The right decision should have been to impose, to the manufacturers whose HFM did not provide a detailed HV charts, to define them and introduce in the Limitations section of the HFM.
In the USA FAR 91.9 d) gives similar alleviation but only when “ a safe ditching can be accomplished” and for specific helicopter’s configurations.
§91.9 Civil aircraft flight manual, marking, and placard requirements.
c)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 emergency ditching on open water.
Unfortunately this is not the case for the operations in the North Sea that is considered “hostile environment” and, therefore, a safe ditching cannot be accomplished.
In addition to this HV topic, I think that time has arrived for imposing that helicopters operating from/to helideck in CAT operations must:
a)be Category A certified
b)fly the Category A procedures (PC1) for Take-off and Landing from/to helideck
c)be (these procedures) in the Normal and Emergency Procedures sections of the HFM approved by EASA
This because people, regularly flying from/to the oil rigs, are passengers at all the effects and, as such, must be protected with the highest safety standards offered by technology and airworthiness regulations.
The usual justification that the helideck environment is so peculiar that PC1 procedures cannot be executed is inconsistent. In fact the procedures can be, to some extent, adapted to the specific helideck. But the important element concerning the safety is that helicopter is to be operated at the mass derived from the HFM at the Weight, Altitude, Temperature (WAT) curves applicable to the procedure that the pilot wants to fly. And, sometimes, the mass allowed is lower than the MCTOM
It has to be noted that similar obligations already exists in the Air Ops regulation 965 /2012. Annex IV Section 2.
CAT.POL.H.310 (c)(2) for Take-Off and CAT.POL.H.325(c)(2) for landing, require to fly PC2 enhanced procedures for operations from/to helideck for any helicopter operated in hostile environment.
And these procedures, that should not be invented by the operators but EASA approved, correspond to PC1 because allow to survive an engine failure either in take-off or landing from/to a helideck, without ditching.
I am wondering if the National Aviation Authorities (NAA) are imposing them or are granting an exemption.
I say that because when these procedures were introduced by JAR-OPS 3, Amend 5, in July 2007, some NAA’s granted exemptions to the operators with the usual justification that the adoption of these procedures imposed, to some helicopter models, to operate at mass below the MCTOM.
I hope that the European Institutions are sensible to safety and reject the EASA’s request for penetrating the HV envelope.
Sometimes safety should prevail on business.