UK Over Water Singles- Update: Sensible Decision

[quidam]

Apologies for being lazy, but below is a copy of an email forwarded by the Helicopter Club of Great Britain.
Nice to see that this was mentioned at the recent small helicopter safety seminar :mad:

No Floats? Over water helicopter flight ban proposed by CAA.
No more helicopter flights to France?

One of the most serious threats to our use of helicopters is hidden away in a recent CAA consultation letter entitled "Proposal to amend the ANO to enable compliance with ICAO standards for GA operations."
View it at www.caa.co.uk/srg/general_aviation/_document_._asp It is a 2.2 Mb _document_._ The letter and the 15 appendices detail the proposed ANO amendments.

The most serious for helicopters are:
Appendix 8 (ELT)
Appendix 10 (Flights over water) and
Appendix 15 (Helicopter flights over water).


The Flotation proposal
The most serious: "Helicopter flights over water - means of flotation", proposes that no single engine helicopter can fly out of autorotational distance from land suitable for an emergency landing, unless equipped with floats. Even twins would not be able to fly more than 10 minutes flying time from land without floats.
This is plainly ridiculous, and grossly unreasonable. It would suddenly make illegal one of the great uses of our helicopters - quickly and easily crossing the channel.
It is impossible to fit floats to the Robinson R22 and R44 unless it was built with them.
Where it is structurally possible to fit floats to other helicopters, they are prohibitively expensive to buy and maintain, and significantly affect performance and weight. They can even be a safety hazard in themselves if they don't work perfectly. The cost of the proposal to owners is out of all proportion to the risk.

If this proposal becomes law, most of our Club's member's helicopters will not be able to legally fly to France, Ireland, the Isle of Wight, or even across the Thames & Severn estuaries and Cumbrian lakes. And of course, if the flight is not legal, the helicopter is not insured.

The ELT proposal
It is proposed that private helicopters must carry an automatic, fixed, ELT to fly over water.
The equipment cost is at least £1850 plus fitting.
Fixed wing aircraft just need a hand held ELT (cost around US$500), and only then when 50nm or more away from land.
And because helicopters will also have to carry a life raft, another, separate, ELT must be carried in that raft as well!

The Life Raft proposal
Helicopters will have to carry a life raft, as well as life jackets, and the life raft must contain a long list of equipment including paddles, flares, water and that extra ELT. Where will you put that in your R22, Schweizer, Enstrom or R44?

Whilst it is wise to carry life jackets, and a raft if you have room, it is very unjust and completely unnecessary and unreasonable to mandate this equipment, the effect of which will prevent many helicopters flying over water at all.

General
It should be a matter of individual choice for private helicopter operators whether or not to fit these items of equipment, and most of us have managed very well without them for years.
It has always been the CAA's philosophy not try to protect the pilot from himself on private flights. Their mission is to protect the paying public on public transport flights. The only reason the CAA are proposing such draconian rules now, is for their own administrative convenience - so the UK can comply with ICAO standards, regardless of whether or not those standards are practical, sensible, fair, necessary or even reasonable for flight safety. It is a bureaucratic 'tick in the box' as far as CAA is concerned. There is no suggestion in the consultation document of a safety case for these impositions, and no cost/benefit analysis has been performed.
And there is the usual "Gold Plating" of regulations - other countries helicopters do not have these ICAO standards imposed on them.
Helicopters are severely discriminated against by the ICAO standards.
Non public transport fixed wing aircraft are far less severely regulated, only being affected by these proposals when over 50nm away from land. Closer than that, and fixed wing aircraft don't have to have an ELT, a raft or flotation equipment.
In contrast ICAO private helicopter standards are almost the same as for public transport flights in terms of equipment required.
Therefore the ICAO standards are unreasonable, unfair and wildly excessive in the case of non public transport helicopters.

The CAA proposals are poorly drafted, and refer to helicopters whose certificate of airworthiness classifies them as group A or B, when actually, few helicopters are so classified. Also the life raft proposal reads as if it applies only to helicopters with more than 20 seats. It is actually the CAA's intention to apply all the proposals to all helicopters. Do not think (as I initially did) that the proposals as drafted will not apply to us. They will, unless we act forcefully and in large numbers.

Please write with your comments to the CAA to:
Mr. David Beavan
GAD CAA
Aviation House
Gatwick Airport
W. Sussex RH6 0YR
explaining your objections to the proposals, to arrive as soon as possible, but no later than 31 January 2004.

The Club will of course be responding in full to the CAA, but as usual, it is the volume of responses received that carry the weight, so every member should make their views known now, whilst there is still time to stop the proposal progressing.

Points the Club will be making include:
ICAO standards severely discriminate against non public transport helicopters, as compared with non public transport fixed wing.

ICAO standards should be changed so that private helicopters are treated the same as private fixed wing. There is no significant difference in the mechanical failure risk during enroute flight, between fixed wing and helicopters, and if anything, helicopter engines are more reliable.

There are huge compliance costs for private owners, as opposed to the zero cost impact stated in the proposal.

There is no requirement to follow ICAO standards to fly in other countries. Aircraft only have to be legal in their country of registration.

There is no safety case for the proposals, especially the helicopter flotation proposal.

The cost of fitting and maintaining floats is out of all proportion to the mechanical failure risk of crossing the channel for a few minutes a few times a year.

Mechanical failure over water has not been a major cause of accidents in the last 20+ years.

Private helicopter pilots have been happily and safely flying over water without floats for decades. The CAA can easily file a difference with ICAO to allow them to continue to do so, without floats, as they have up to now.

It would be impossible to fit floats to most R22 and R44 helicopters.

It would cost £????? to fit floats to my helicopter, which is not a reasonable expense for such a short time spent over water.

It is unreasonable to effectively ban large numbers of the UK helicopter fleet of small helicopters from crossing the channel.

There is no room in 2 seat helicopters to carry a life raft

Why should helicopters have to carry a life raft when fixed wing aircraft don't?

There is no room/weight to fit an automatic ELT to the Robinson R22 and the Schweizer 300,

It is ludicrous to require the carriage of two ELT's.

The proposals assume that an automatic ELT delivers more safety that a portable unit. However, should a helicopter sink in water or catch fire, a fixed ELT would be useless, and a portable one that the crew or passengers could take with them would be of much greater value..

Fixed wing aircraft can comply using personally carried ELT's so why not helicopters?

The CAA should consider less severe options, such as a gross weight below which these rules would not apply, e.g. 2730kg.

The CAA could apply the private fixed wing proposals to private helicopters.

The CAA can choose which ICAO standards to implement.

The imposition of new requirements such as this, should be based on an objective, demonstrable case that the equipment confers greater benefits than it does disadvantages (of, for example, cost, weight, installation problems or procedural difficulties).

These proposals are for the CAA's administrative convenience, and not for any likely safety benefit to UK persons at all

Demand Equality with fixed wing

It should be individual choice to decide whether or not to fit the proposed equipment

It is not the CAA's remit to protect the private pilot from himself.

If you want to fit your helicopter with all this equipment then fine. If you want to fight these proposals, get writing.

and do have a happy Christmas and a prosperous new year!

Jeremy James

Hon. Secretary Well my letters gonna be in the post :ok:





If the link above doesn't work - try this one: CAA Proposals (http://www.caa.co.uk/docs/224/srg_gad_ICAO_LofC&RIA.pdf)
Heliport

[Bertie Thruster]

I suppose you think immersion suits are a waste of payload too?

You shouldn't be relying on a rapid recovery by the RAF. SeaKing serviceability isn't what it used to be. (Rumoured that all east coast SAR helos were u/s at the same time recently, for a variety of snags.)

I had the 'pleasure' of recovering a downed private FW pilot from the Channel some years ago. He was dressed in shirt and trousers. Decent looking life jacket held him up quite nicely. He looked asleep. Hand held PLB on lanyard (not holding it though, it was below him down in the water, quite useless. Possibly hands too cold to hold it)) No injuries, no water in lungs, just the cold water..................

Sea temp about 12'C. Our graphs indicated he lasted about half an hour.

Of course it wasn't going to happen to him. And it was his choice.

I agree with you. It should be a matter of personal choice.

Like wearing seat belts in private cars.

[NickLappos]

In a stunning revelation, the CAA today announced that they have embarked on a program to eliminate all aircraft accidents. John Higgensbotthom, CAA safety Coordinator and Seldom Quoted pundit described the new program as "A stunning concept likely to eliminate all air safety issues throughout the UK."

His plan, endorsed by the UK aviation aurhorities and scheduled to become law within a fortnight is "simple and effective", Higgensbotthom said, "We simply ban all aircraft from leaving the ground."

Asked to comment on the likelyhood that this will slow air commerce and make UK aircraft operators somewhat less economically viable, Higgensbottham said, "That seems to be a common misconception." When questioned further, it became clear that the misconception was not regarding the effect such a ruling would have on flight operations. Rather, the misconception was that somehow the British public were misinformed as to exactly how CAA was chartered.

"Continued Flight Operations?" Higgensbottham asked, "Exactly how would CAA be concerned with that?"

[Thomas coupling]

Quidam:

Ooops, seems you are quite concerned, then?

For twins:

Firstly, France is never more than ten minutes flying time from England (unfortunately :ugh: ). You would need to only be 10 minutes from the mid point to continue!!!
Put it another way to take longer than 20 minutes flying time across the narrowest point of the channel would mean a g/s of about 25kts:O
So France is still viable. In fact so too is the rest of the western world as a result of this 'hop'.

Ireland, a little trickier: 46 Nm between Holyhead and Dublin. You'd need a g/s of atleast 138kts to be only ever 10 minutes from land. Wait for a windy day, that's what I say:ok:

IOM, shortest distance to english headland: 31 miles, to scottish headland: 16 miles...no problem there then.

Where else do you want to go in your private helicopter?????

You're wasting your time with the CAA, they are/will soon be owned by EASA.
What EASA says is LAW, as opposed to JAR which was recommended :mad:


For singles:

This new proposal / law is simply treating water the same as night. Hostile territory for singles - hence no fly without restrictions. Duty of care etc.....blah blah.


Why don't private members pair up and part ex their machines for a twin :ooh:

I must admit...I'd be mighty pi***ed if I was a private single owner.

[Helibelly]

I'll just second what Bertie T said. Spent a lot of time over the north sea as a Sar Boy, and the occasional wet drill in it. Dress to survive! Too many people fly with a 'it won't happen to me attitiude'. Yes the CAA seem intent on banning private aviation, but at times private flyers do some very dubious things!

[headsethair]

Private owners must fight this. There are no statistics at all which point to the necessity of the proposed new rules. For many owners these rules will mean that you are confined to the mainland of the UK - an unfair penalty to pay for being "offshore" from Europe.
The ELT issue is a real worry - I thought it had gone away. Portable ELT yes - fixed, no point. In the earlier CAA consultation on this they cited two cases where they claimed ELT would have helped. I looked into both of these and the CAA were wrong. They were both non-survivable accidents - and one of them was in such bad visibility that the police helicopter couldn't take off! SO what good would an ELT have been - the crash was witnessed and reported.
Floats for private operators - an expensive and unnecessary option. I also doubt the safety of such equipment - they can't be pre-flighted if they are pop-outs. I would particularly draw attention to the float pack on the R44 which is deployed using a gas bottle under the left front seat - compromising the manufacturer's own manual which states that no hard object should be stowed under the seats because this will affect the structural performance of the seat in a hard landing or crash.
Crazy crazy. The UK comprises a group of islands - we have to cross water to get anywhere in Europe. Just let us take the risk. (And before you flame me - count the number of helicopter water ditchings.........)
C'mon all - we have to stop this one. The CAA have got their sledgehammer out again - and there isn't a nut in sight!

[Whirlygig]

Help!

When I click on Quidam's link to CAA site, I get File Not Found. Anyone else having this difficulty.

Cheers

Whirlygig

[quidam]

Bertie/ TC

Don't get me wrong.

My other passion is scuba diving and I'm fully aware of how cold the waters off the UK can get :) Seatbelts are a legal requirement in cars BUT there is no law forcing a motorcyclist to wear full leathers boots and gloves.

I'm not an owner and aside from the odd lake or lock the most adventurous I've been is the Isle of Wight - and even then I'm ultra careful, carrying life jackets and routing further west along the coast in order to cross at the narrowest point by Milford.

I was more concerned with the indirect and silent manner of whats being proposed and the ramifications if it happens.

Costs aside I wonder where singles will stand with places like Farmoor reservoir and Sunbury lock both of which I've flown over.

I agree with some of the issues raised in the e mail I received from BHCGB and when I get a minute will look to read the full report.

Sorry Whirly I can't help with the link as I purely copied the email.

Part of me feels as the CAA say they are cash strapped and the majority of fatal incidents involving helicopters (according to the last small heli seminar) involved controlled flight into terrain and wire strikes that their efforts could be better used elsewhere :confused:

[RDRickster]

I'm not a fan of the FAA, mainly because "we are here to help" is an oxymoron. Nevertheless, I'm glad similar restrictions aren't proposed in the U.S. I agree with headsethair that this seems a bit ridiculous for General Aviation.

I suppose the closest scenario are the flights over the Great Lakes between the U.S. and Canada. Actually, the distance over water (Great Lakes) is quite a bit further than the Channel. Unless I'm mistaken, General Aviation pilots don't have to carry immersion suits, life rafts, additional ELT's, or equip their aircraft with floats. Now, Part 135 operations are a different story... understandably so.

The concept of floats as a primary safety measure is a joke. For example, in the R22 Mariner I've been flying around lately - the floats are rated for 12 inch waves only. That's it! Meaning, floats make it useful to land in protected harbors, calm rivers, intercoastal waterways, small bays, etc. In contrast, I've been flying over larger bays and the Atlantic seaboard.

The only thing floats will do for me is that it MIGHT give me a little more time to get out. You can guarantee that the ship will turn inverted as soon as you are in the water. The debate on whether or not General Aviation SHOULD be equiped with this gear is another matter.

To me, it's relates to the helmet in the cockpit question. It's a matter of personal choice... if you don't, it is definately taking a risk. (By the way - I've decided to get a helmet based on some of our conversations). That said, are there THAT many incidents where this Proposal is warrented? If there are a large number of crashes in the Channel, then the problem relates to aircraft maintenance, pilot training, or aeronautical decision making... not whether or not the ship is equipped with extra gear.

What's next... let's make a law that says sharp objects must be padded with 3/4' foam and proximity alarms when someone comes within 2 feet! :\

[Thomas coupling]

Quidam: correct me if I am wrong but what is the problem over reservoirs lakes, as long as you are within auto range of the bank, it's Ok??

[Cathar]

Whirlygig


The correct link appears to be:

http://www.caa.co.uk/docs/224/srg_gad_ICAO_LofC&RIA.pdf

[quidam]

TC,

Was referring to this that was contained within the email. I assume that BHCGB has done a fair amount of research before sending out their concerns.

I don't presume to be experienced. Just in the final stages of hour building before CPL course.


"If this proposal becomes law, most of our Club's member's helicopters will not be able to legally fly to France, Ireland, the Isle of Wight, or even across the Thames & Severn estuaries and Cumbrian lakes. And of course, if the flight is not legal, the helicopter is not insured."


Is what they are saying incorrect??????

[Heliport]

quidam

Thanks for posting the information here.

Opinions may differ, but at least pilots are now aware of the proposals and will be able form a view.

Heliport

[rotorspeed]

The fact is risk has always to be balanced against cost and practicalilty in everything in life, and this balance will change over time for various reasons. If we all equipped our cars with race-style roll cages and wore crash helmets on the road, fatalities would probably halve, but who is going to do it?

Maybe with the huge audience of PPRune, we can get some idea of the actual levels of risk involved with over-water flight in singles and twins, with and without floats.

If anyone knows of any heli forced landings/accidents over water in the last, say 10 years, please post the following info:

Year
Approx location, eg GOM, English Channel
Heli type, Reg if known
Single/Twin
Cause if known, eg engine failure, fuel exhaustion
Floats fitted?
Brief outcome, eg heli on floats remained upright long enough to launch dinghies, 3 rescued, or heli on floats rolled over on auto, 2 fatal, etc etc.

Of course it would not be unreasonable to assume that such data has been compiled by the CAA (and other aviation authorities) in order that any new regulations were proposed and implemented against a background of factual knowledge and relevant statistical analysis.

It would be good if we could use PPRune to enable us all to generate some useful data to help everyone make sensible decisions; the authorities determing what should be mandatory and pilots determining where they want to pitch their own balance.

[Whirlygig]

Thank you Cathar - just printed it off; 59 pages of light bedside reading ;)

Cheers

Whirlygig

[headsethair]

The more I think about this, the sneakier it looks.

(1) The CAA's circulation list (at the front of the document) is predominantly comprised of commercial operators - and they largely won't be interested in fighting the change because they've already got these rules under Public Transport. So - why didn't the CAA circulate to those who will be directly affected - private pilots and owners ?

(2) The CAA Small Helicopter Safety Seminar was on November 18. It was attended by 60 helicopter pilots - many private. Yet no mention was made of the "consultation" letter which we have now heard about. The date on that letter was November 6.

(3) The closing date for responses is January 31st 2004. Yet most of us have only learnt of this proposal this week. It's a crazy time of year and I just get the feeling that CAA SRG are hoping that this period sails by unnoticed.

We need firm, accurate responses from private helicopter pilots and owners. All those self-fly hirers.......get 'em writing.

[md 600 driver]

tried to read what sort of floats are required part of it says fixed floats my interpretation of this is actual flotation equiptment not blow up floats any one else a view of this

personally i think flight over water should be with floats [blow up type ] at least it one would have something to hold onto if it went belly up i put floats on the 600 for that reason

elts
all us registered helicopters should have fixed elts although there does seem to be argument about us reg helicopters based in the uk requiring them afaik

steve

[Thomas coupling]

Looking at the letter, the only juicy bit, really is the floats, isn't it?

Everything else makes sense and is relatively cheap. For example an ELT (AP) comes in at about £2200 plus fitting. So no big deal.

Those floats are another story. How much for a retro kit to, say an R22??

The sad thing is, they are next to useless when used in anger.

Don't think you're going to win this one, lads and lasses!


Mike M-Smith (Castle Air) stoofed into the channel around 1996-7?? Jet ranger, I think - engine failure. Sank almost immediately.

[john du'pruyting]

On first perusal of the table, it seems to say that only helicopters from performance class A and B will require floats, all others will just require scale H
Scale H
(i) Subject to sub-paragraph (ii), for each person on board, a lifejacket equipped with a
whistle and waterproof torch.
(ii) Lifejackets constructed and carried solely for use by children under three years of age
need not be equipped with a whistle.

However, a good time to confess that I don't know to what performance class private heli's are flying!

If you want to make a point to the CAA you had better do it quick...Replies by the end of Jan!

[RDRickster]

As far as retrofitting a ship with floats, say an R22 - it can't be done today. If it was'nt sold as a float equipped helicopter, then it can't be made into one. Specifically, the R22 Mariner has a type certificate just for that feature. Therefore, you can NOT take a new R22, buy the parts (floats, modified stinger, modified stabilizer, landing gear extensions for floats, battery brackets to move battery from under engine to under instrument panel, etc) and build it into a float ship.

Lifejacket requirement for over-water flights seems reasonable. ELT's mounted to the airframe probably won't make a difference one bit. As the antennae goes under water, they aren't affective at all (at least 1/3 of the antennae needs to be above water).

[Head Turner]

Risk - this is what has to be addressed.

As stated clearly above we are in a position to assess the risk against cost and likelyhood and act accordingly.

I am a non smoker but I can be killed by inhaling passive smoke, so I must wear a mask.
I am a pedestrian and can be killed by a motor vehicle mounting the pavement unprotected by a suitable barrier.
Both the above are in the hands of government and thay will do absolutely nothing about these dangers.
However they feel obliged to demand we protect ourselves against ourselves, STRANGE and unbalanced reasonong!

Twins can make the journeys across most common routes within the British Isles without requiring floats, ELT, life raft, immersion suit, and life jacket. However, these items should be worn/carried if you see that the risk to you is such that without them you would endanger yourself and others. The personal choice for private pilots and their passengers.

If I were able to buy a helicopter and my journeys were so often over water I would equip myself with all these safety features. However if it was once a year then I would accept the risk.

My opinion

[B Sousa]

Interesting comment above regarding Smoking and Government involvement. The biggest joke in the States is too listen to the Government scream and threaten the Cigarette Industry and then pass out subsidies to Tobacco Farmers......
I guess to equate one should think that if Aircraft cannot fly based on Government Regulations, there will be no accidents.....

[headsethair]

As the sole reason given by the CAA for this proposed change is to bring us into line with ICAO, I thought I'd get to the roots. Why does ICAO exist and what was the intention when they had their Chicago Convention in 1944 ?

"WHEREAS the future development of international civil aviation can greatly help to create and preserve friendship and understanding among the nations and peoples of the world, yet its abuse can become a threat to the general security; and

WHEREAS it is desirable to avoid friction and to promote that co-operation between nations and peoples upon which the peace of the world depends;

THEREFORE, the undersigned governments having agreed on certain principles and arrangements in order that international civil aviation may be developed in a safe and orderly manner and that international air transport services may be established on the basis of equality of opportunity and operated soundly and economically;

Have accordingly concluded this Convention to that end."

Which obviously means, let's do everything we can to stop UK helicopter pilots being able to cause "friction" anywhere else !

This is a terrible time - we are being restricted to our island. (There's obviously an Australian behind this somewhere....)

[md 600 driver]

no it will be the french

[Helinut]

If these are indeed simply ICAO requirements can any PPRUNERs tell us which ICAO member countries currently comply with all this stuff for private flights?

I suspect a large round number of other ICAO states comply with these standards.

The CAA needs to stop knee-jerking and start thinking properly about risk (fat chance). Except, of course, we are told that they aren't going to be able to regulate themselves in the future. Much more important for Europe will be what the EASA proposes .................

[Zlin526]

I suppose they could just implement it without consultation.....just like any other Quango.

But take a look at the recent Rule 5 consultation. 99 out of a 100 housewives disagreed with the restructuring of Rule 5(1)(e), to include a blanket "not below 500ft" rule, as in France etc. I hear that the CAA are now not planning to change it, so it can work to the sensible aviators advantage IF enough people disagree and write in with their concerns.

Z

[headsethair]

Z - agree with your point. All UK single-engine pilots should write with their views - by all means using the HCGB template as a basis. But include relevant personal experience. How many over water flights have you done (not within autorotational distance of land) in the past 5 years ? How many of those finished with a ditching ? And when you do fly over water what precautions do you take ?

If our community can show that the stats don't back up this change and that we do behave responsibly, then we have every chance of saving our freedom. I cannot believe that the CAA really want this change - one of their test pilots owns a floatless R22.

Write to:

David Beaven General Aviation Department (Policy) Civil Aviation Authority 1W Aviation House Gatwick Airport South Gatwick West Sussex RH6 0YR e-mail: [email protected] to arrive no later than 31 January 2004.

And take a look at what the ICAO has to say in its Convention : "international air transport services may be established on the basis of equality of opportunity and operated soundly and economically"

EQUALITY - with fixed wing ? ECONOMICALLY - confining a fleet of private helis to the mainland of the UK because of the costs and impossibility of compliance. Even worse if you live in Northern Ireland.

In any case, wasn't ICAO set-up for commercial aviation ? Why are private pilots being forced to comply with the Convention ? Do we need Flying Lawyer ?

[Head Turner]

In regard to floats;-

I have deployed floats once and the port one didn't inflate.

I have set the switches to arm the floats many times and on one occasion the floats, due to corrosion within the switches, inflated and I was well set for the overwater flight at the much reduced IAS.

A Question. - What is the performance criterior that floars are tested to? It's ok fitting floats but, in what situation will they provide the safety to the helicopter occupants. And more importantly when would it be better if they were not fitted.

The idea of floats in their present form is outdated and miss directed as to their functionality. A review is required before any acceptance of such devices is made mandatory.

In regard to over water flights;-

I have to agree that some form of bouyancy aid that would guarantie a safe landing on water and keep me and the helicopter safe until rescue was achieved is a definite plus.

I have spent many nervos minutes over water planning in my mind what to do if!. I am sure I would be doing the same thing even if floats were fitted because they are not guaranteed to work everytime.
I have worn immersion suit, life jacket and carried a life raft but not had floats fitted on these occasions.

A point of note.

As far as I can work it out. It is impossible for a pilot to deploy a life raft on his/her own.

I think the aero industry should again look at the developments within the automobile industry and 'modernise' before making legislation which on the surface (please accept the pun) iis only performing the 'rubber stamp syndome'

[coalface]

Will private single engine F/W be banned from flying within gliding distance of land?

Money spent of floats would be much better spent on something which would help stop ditchings. Any suggestions??

[Apical Industries]

Hello,

I was reading the postings regarding the potential requirement for floats to be installed for overwater flight. I understand the concerns regarding the debate from an operators point of view and will not presnet a position regarding the debate. I wanted your members to be aware that Apical Industries of Oceanside California has developed the first breakthrough in helicopter flotation since floats were invented for helicopters. Apical has certified and patented an emergency float system that has integrated liferafts installed on the floats. The system has two independent inflation systems one for the floats and a seperate system for the life rafts. The life rafts have three deployment points, one in the cockpit and one at each aft door of an aircraft externally mounted. Any of the deployment points for the raft system will inflate both rafts. The system is so light that we have installed them on aircraft as light as a 206 A model. We have a system certified for the 206,206L,407, 412 and are currently awaiting approval for the AS-350/355 AND BO-105. Companies like Petrolem Helicopters and Airlogistics have made commitments to convert their entire fleet to the system. We will also be certifying an emergency float system and an emergency float system with rafts for the R-44 that will be available to all R-44 owners not just Marinier models. Thank you for the opportunity to present this information.

Ron Gladnick
Apical Industries

[chopperman]

Money spent of floats would be much better spent on something which would help stop ditchings. Any suggestions??
A second engine?

Sorry, couldn't resist it :E

Chopperman.

[headsethair]

bump. UK pilots note and get your letters to CAA by 31st January.

[headsethair]

bumping again. Make sure the CAA gets your Christmas card!

[sloanejoe]

I've sent my e-mail to Mr Beaven and we're writing to our customers informing them of what the proposal will mean to our type of flying. Hopefully the more people that write the more our case will be heard. Does anyone know approximately how many PPL(H) holders there are currently in the UK so we can work out roughly what number of responses will be listened to?

[headsethair]

I have a copy of CAA stats listing all water ditchings for UK reg helis (twin and single) for the last 15 years.

Total number : 9, no fatalities no major injuries

TWIN TURBINE: 4 total, mainly North Sea. 2 engine failures (incl one that lost both engines), 1 transmission, 1 lightning strike.

SINGLE TURBINE : 2 total. 1 Engine failure, 1 transmission

SINGLE PISTON : 3 total. 1 loss of control (but still managed a safe ditch), 1 transmission, 1 undetermined but loss of power.

Floats were deployed for all twins - in one case the speed of landing on the water ripped off the floats.
Singles did not deploy floats.
And the results in all cases were exactly the same.

Now compare these miniscule stats with fixed wing single ditchings..........single helis are being unfairly "singled out".

There is nothing in that stats to prove that floats save lives. I would post the CAA report here - but I'm not certain about copyright. I will email the report to Heliport and he can decide what to do.

[Helinut]

headstheair

If it is a formal CAA report at least give us the title and details. It may well be buried somewhere in the CAA's website

Thanks

[headsethair]

"It may well be buried somewhere in the CAA's website"

No it isn't - it is a specially prepared report based on parameters I filed with the CAA last week. Have emailed Heliport - I can't see why it can't be posted. The CAA say it must only be used for Flight Safety purposes - and that must surely mean it can be posted here in the interests of safety.

[headsethair]

Following are CAA records for the last 15 years. There have been 9 recorded "ditchings" in that period.

SUBJECT: DITCHINGS BY UK REGISTERED HELICOPTERS
PERIOD : SINCE 1 JANUARY 1988


A/C Type Sikorsky S61 OccNum 198802141
Date 13 Jul 1988 Location NORTH SEA

UK Reportable Accident : ENGINE FIRE WARNING. A/C DITCHED. ALL 21 OCCUPANTS RESCUED. A/C BURNED & SANK.

A/C AT 1500FT WHEN THERE WAS AN UNUSUAL NOISE ACCOMPANIED BY HIGH FREQUENCY VIBRATION. NR2 ENGINE FIRE WARNING ILLUMINATED & DRILLS CARRIED OUT BUT NR1 ENGINE FIRE WARNING FOLLOWED & SMOKE OBSERVED. SUCCESSFUL DITCHING & EVACUATION COMPLETED AS CABIN FILLED WITH DENSE SMOKE. SHORTLY AFTER ALIGHTING CONTROLS FROZE. A/C CONTINUED TO BURN WITH AN "INTENSE WHITE FLAME" IN AREA OF FORWARD GEARBOX & EVENTUALLY BROKE UP & SANK. EXAMINATION OF RECOVERED WRECKAGE REVEALED FAILURE BEGAN WITHIN NR2 POWER TURBINE WHERE NR5 BEARING CAGE HAD BROKEN-UP, SHOWING SIGNS OF SEVERE WEAR & OVERTEMPERATURE. NR4 BEARING & MAIN GEARBOX CONNECTING SHAFT ALSO DISPLACED CAUSING NR2 ENGINE AFT SUPPORT TUBE ASSEMBLY BREAKAGE. AAIB BULLETIN 1/89 & ACCIDENT REPORT 3/90 REFER. CAA CLOSURE: CAUSE OF NR5 BEARING FAILURE NOT POSITIVELY ESTABLISHED. CAA RESPONSES TO AAIB RECOMMENDATIONS ARE CONTAINED IN FOLLOW-UP ACTION ON ACCIDENT REPORT (FACTAR) NO.F3/90.



A/C Type Sikorsky S61 OccNum 198803819
Date 10 Nov 1988 Location NORTH SEA

UK Reportable Accident : LOW GEARBOX OIL PRESSURE WARNING ACCOMPANIED BY VIBRATION. A/C DITCHED, INVERTED & SANK. 13 POB SAFE.

WHINING/RUMBLING NOISE HEARD & LOW GEARBOX OIL PRESSURE INDICATION OCCURRED. PILOT INTENDED TO DIVERT TO RIG BUT WITH ONSET OF HF VIBRATION DECIDED TO DITCH. A/C ROLLED RIGHT & OVERTURNED IN 45MPH WINDS. 11 PAX & 2 CREW EVACUATED SAFELY & RESCUED BY SAR SERVICE. A/C SANK ON FOLLOWING DAY BUT WRECKAGE RETRIEVED FOR INVESTIGATION. A 30DEG (8IN) SEGMENT OF HELICAL GEAR WHEEL (P/N:S6135-20620-3) WAS MISSING (PIECES FOUND IN BOTTOM OF GEARBOX) DUE TO FATIGUE FAILURE CAUSED BY IMPURITIES IN THE STEEL. FAILURE ORIGINATED AT A GEAR TOOTH. AAIB BULLETIN 1/89 & ACCIDENT REPORT 1/90 REFER. CAA EMERG AD 030-01-89 IDENTIFIES GEARS FROM SAME BATCH OF STEEL AS FAILED ITEM & REQUIRES THEIR REMOVAL FROM SERVICE WITHIN 100HRS. SIKORSKY SUBSEQUENTLY REVISED THE MANUFACTURING PROCESS TO ENSURE PURITY OF STEEL. CAA CLOSURE: CAA RESPONSES TO AAIB RECOMMENDATIONS ARE CONTAINED IN FOLLOW-UP ACTION ON ACCIDENT REPORTS (FACTAR) NO.F1/90.



A/C Type Bolkow 105 OccNum 198901315
Date 25 Apr 1989 Location NORTH SEA

UK Reportable Accident : DOUBLE ENGINE FLAMEOUT DUE SNOW/SLUSH INGESTION. DITCHED IN SEA. NO INJURIES.

DURING AN OIL POLLUTION SURVEY THE A/C WAS POSITIONING TO LAND WHEN, AFTER ENCOUNTERING SLEET SHOWERS AT 2400FT (OAT +1 DEG C), BOTH ENGINES FAILED. AUTOROTATION ESTABLISHED & FLOATS INFLATED (AFTER INADVERTENT SELECTION OF FUEL JETTISON DUE PROXIMITY OF SWITCHES). A/C LANDED ON SEA WITH SOME FORWARD SPEED, THE RIGHT FRONT & BOTH REAR FLOAT BAGS BECAME PARTIALLY DETACHED. OCCUPANTS TRANSFERRED TO LIFERAFT & WERE SOON PICKED UP BY LOCAL CAR FERRY. AFTER A/C HAD BEEN TOWED ASHORE INVESTIGATION REVEALED THAT ONLY TWO FUEL BOOSTER PUMPS WERE STILL WORKING & THAT ALL PUMPS WERE CORRODED AS A RESULT OF SALT WATER INTRUSION. HOWEVER, NO OTHER DEFECT WAS FOUND TO ACCOUNT FOR THE DOUBLE ENGINE FAILURE WHICH IS ATTRIBUTED TO SNOW/SLUSH INGESTION. A/C HAD BEEN FLYING IN A COLD, UNSTABLE NORTHERLY AIRSTREAM WITH A MIXTURE OF RAIN & SNOW SHOWERS & TEMPS VARYING BETWEEN +3 & -2 DEG C. CALIBRATION CHECK OF THE OAT GAUGE REVEALED UNDERREAD OF 2 DEG C & A PARALLAX ERROR OF 5 DEG C DUE TO THE POSITION OF THE NEEDLE ABOVE THE DIAL FACE. AAIB BULLETIN 9/89 REFERS. FLIGHT MANUAL AMENDMED TO REQUIRE CONTINUOUS OPERATION OF IGNITION SYSTEM FOR FLIGHT IN FALLING SNOW. SB BO105-80-111 INTRODUCES MBB KIT NO 105-96233 OR 105-96238.CAA CLOSURE- NO FURTHER ACTION REQUIRED.



A/C Type Enstrom F28 OccNum 199101850
Date 12 Jun 1991 Location SNOWDONIA

UK Reportable Accident : WHILE HOVERING OVER LAKE, STRONG DOWNDRAUGHT CAUSED A/C TO SETTLE INTO WATER & SINK. NO INJ TO 2 POB.

THE A/C WAS ENGAGED IN AERIAL PHOTOGRAPHY OF A RESERVOIR DAM & WAS OPERATING IN THE LEE OF HIGH GROUND RISING 150FT ABOVE WATER LEVEL. LOCALISED POCKETS OF TURBULENCE & DOWNDRAUGHTS ARE REPORTED TO HAVE BEEN AFFECTING THE AREA. ON COMPLETION OF AN EXTENDED HOVER INTO A 210DEG/15-20KT WIND, THE A/C WAS TURNED & ACCELERATED DOWNWIND & IMMEDIATELY BEGAN TO LOSE HEIGHT. ALTHOUGH FULL POWER WAS APPLIED, MAIN ROTOR RPM DECAYED RAPIDLY. A DITCHING WAS CARRIED OUT & BOTH OCCUPANTS ESCAPED BEFORE THE A/C SANK. THE A/C WAS RECOVERED FROM THE WATER & SUBSEQUENT INSPN REVEALED NO EVIDENCE OF ANY MECHANICAL FAILURE. CAA CLOSURE: APPROPRIATE INFORMAL ACTION TAKEN.



A/C Type Bell 206 Jet Ranger OccNum 199200843
Date 20 Mar 1992 Location IRISH SEA

UK Reportable Accident : ENGINE FAILURE. MAYDAY. DITCHED INTO SEA & SANK. 1 POB RESCUED.

ENGINE OUT WARNING IN CRUISE. ENTERED AUTOROTATION. RELIGHT ATTEMPTED. DITCHED SUCCESSFULLY & EVACUATED A/C. DINGHY DROPPED TO PILOT IN WATER BY PASSING LIGHT A/C, PILOT RESCUED BY SAR HELICOPTER. A/C NOT RECOVERED. SEE AAIB BULLETIN 06/92, REF : EW/G92/03/09. CAA CLOSURE:NO CAA ACTION APPROPRIATE.



A/C Type SA332 Super Puma OccNum 199500167
Date 19 Jan 1995 Location NORTH SEA

UK Reportable Accident : Lightning strike to tail rotor. A/c ditched following loss of tail rotor control. Occupants evacuated into liferaft.

AAIB Formal investigation. The helicopter was conducting a charter flight, ferrying 16 maintenance engineers from Aberdeen to the Brae oilfield. Having just passed a position 120nm on the 062deg radial from the Aberdeen VHF omnirange (VOR) radio beacon, and whilst beginning its descent from 3000 feet above mean sea level (amsl), the helicopter was struck by lightning. This resulted in severe vibration which, a few minutes later, developed into a loss of tail rotor control, necessitating an immediate ditching in heavy seas. The ditching was executed successfully and the helicopter remained upright enabling the passengers and crew to board a heliraft, from which they were subsequently rescued. There were no injuries sustained and the passengers and crew were later returned to Aberdeen by helicopter and ship. Despite six to seven metre waves and a 30kt southerly wind, the helicopter remained afloat for some three hours and thirty minutes before it was brought alongside a safety vessel. However, whilst secured to this vessel the helicopter's flotation bags punctured and it sank some two hours later, at 1803 hours. AAIB Aircraft Accident Report 2/97 contains 8 Safety Recommendations which are addressed by CAA FACTOR F28/97. Tail rotor blades fitted to this a/c were of an early standard & not resistant to lightning strikes of the magnitude experienced in this accident. DGAC AD 96-099-059 requires that a/c flying in hostile areas, such as the North Sea, are equipped with blades of the latest standard. Mfr mods 332A07-41569 & 332A07-66150 also refer. CAA Closure: Hazard now controlled by action stated.



A/C Type Agusta Bell 206 OccNum 199502589
Date 29 Jun 1995 Location ALDERNEY 14N

UK Reportable Accident : A/c ditched into sea following engine power loss. A/c sank. No injuries.

In cruise at about 500ft AMSL, sudden severe 'kick' in yaw accompanied by abnormal mechanical noises from engine/transmission & engine chip warning. Pilot transmitted Mayday &, when another disturbance in yaw occurred followed by loss of engine power, initiated autorotation onto sea. A/c rolled left, filled with water & inverted. Although engineer escaped quickly, pilot initially had difficulty in vacating cockpit. However, he was wearing a lifejacket fitted with short term air supply system (STASS), with up to 3 minutes breathable air & was "extremely beneficial" in aiding escape. Another a/c heard Mayday & located site within 10 minutes. SAR helicopter arrived soon after & both survivors were winched aboard within 30 minutes of accident. Wreckage was not recovered but, from description of events, it was concluded that probable cause of accident was a major mechanical failure of engine gearbox assembly. See AAIB Bulletin 9/95, Ref : EW/G95/06/21. CAA CLOSURE-As wreckage not recovered no technical investigation possible. No further CAA action appropriate.



A/C Type Robinson R22 OccNum 199603615
Date 14 Aug 1996 Location GALWAY

UK Reportable Accident : Loud bang together with rapid yaw to left & total power loss. Autorotative ditching in sea. No injuries.

Abrupt left yaw had occurred at 1500ft after take off & then again at 1000ft after carb heat applied. Investigation by Irish authorities.



A/C Type Robinson R44 OccNum 200300426
Date 27 Jan 2003 Location Antarctic

UK Reportable Accident : The helicopter ditched in the sea off Antartica following an engine failure. Both crew members evacuated into a life raft and were rescued. AAIB AARF investigation.

Two pilots were flying an R44 from Cabo de Hornos in Southern Chile to Teniente Marsh Airbase on King George Island, Antarctica. After approximately 4 hours and 400 miles they experienced an engine vibration followed shortly by engine failure which forced them to ditch. They survived in a liferaft for the next 10 hours until rescued by the Chilean Navy. The helicopter sank and has not been recovered and as such the cause of the accident cannot be positively determined. See AAIB Bulletin 7/2003, ref: EW/G2003/01/18.
CAA Closure: No CAA action appropriate.

[headsethair]

So - now the Fixed Wing stats for the same period (15 years) - all UK registered aircraft ditchings (heli figures in brackets):

Total 28 (9)

TWIN 4 (4)

SINGLE 24 (5)

INJURIES 13 (0)

FATALITIES 5 (0)

CAUSES:
Singles: 16 engine failures, 4 fuel starvations, 2 loss of control, 1 fire (and that ignores the partridge in the pear tree who got there due to loss of control.) In the same period single helis had just 5 total : 2 engine, 2 trans, 1 loss of control.

Twins: 3 engine failures, 1 fuel. (Twin helis 2 engine, 1 trans, 1 lightning strike.)

Additionally there were 2 incidents of liferafts failing to inflate and one incident cause by floats coming loose.

Why are we being singled out ? Why are helis being asked to do more than fixed wing when it is plain that any problems lie firmly in the FW camp ?

[StevieTerrier]

Headsethair -

I thought the single helis had 5 ditchings - your bracketed comparison figures show them as having had 2??

I dont think there is any point trying to compare helis and fixed-wings. These stats are all well and good, but it's impossible to make a case without knowing the number of flights involved to give a percentage figure of flights ending in the drink.

And to be honest, how well would we really come out in a straight comparison vs single fixed-wing, when the air over the English Channel in summer is chock-a-block with small planks on their way to France for lunch? There may have been 5 times more fixed-wing incidents, but check out Le Touq on a sunny weekend and see what the ratio of G-Planks to G-Helos is. I think you'll find it well in excess of 5:1.

I totally agree that if people want to risk their lives flying single-engined over water, rotary or fixed-wing, then the CAA should let them get on with it.

If you try to justify the "no floats" argument by comparing incidents vs fixed-wing, I think you're on a loser. On the other hand if you point to the actual low NUMBER of helicopter incidents over that period, you might be heading along on the right lines.

[headsethair]

Stevie: stat corrected.

"I totally agree that if people want to risk their lives flying single-engined over water, rotary or fixed-wing, then the CAA should let them get on with it. "

With helicopters, according to the stats, the risks appear to about even whether it's single or twin. Although I'd be the first to admit that there are more twin miles over water than single.

Agree with the focus on numbers - I just hope the CAA have read their own stats before drafting the proposal.

[Droopystop]

Has this proposed ban got anything to do with the rumours in another forum about serviceability problems with RAF SAR aircraft???!

:E :E :E

Ducking for incoming from Crab :ouch:

[Gaseous]

This Proposal would appear to have serious implications for Blackpool based helicopters as the standard departure route to the south is about 4 miles over the Ribble estuary. At the point of the intersection with Warton's ATZ the crossing is still about a mile. If the cloudbase is too low to go over Warton the way round is all the way round Preston- about 20 miles. Then there are the Mersey and Dee estuarys. To go round these makes trips to Wales untenable. To the North the same problem occurs with the Solway Firth. I haven't been to Blackpool for a while but I should hope operators based there are vigourously lobbying the CAA. I should imagine other coastal areas suffer the same geographic problem. Let the CAA know. Then there are approaches to my favourite lakes hotels. I don't like being forced in downwind over populated, steep, wooded terrain. I would rather be over the lake for a few seconds.

P.S. My letter is in the post!

[rotorspeed]

Well done Headsethair on getting some stats from the CAA but puzzled to see they don't include the B206 that went down in the sea off Lyme Regis in April 1999 (AAIB 8/99). Incredibly lucky escape; LOC in IMC and ended up hitting the water in fog. No floats, no dinghy, no jackets. No injuries either for 2 POB after they sat on the upturned acft!

Clearly though need to differentiate actual numbers from statistical chance. The number of twin ditchings at 4 might only be one less (or now two) than the 5 of singles but the number of hours flown by twins over water compared with singles must be enormous. I'm sure someone can guesstimate North Sea hours per annum.

Outside of the North Sea, interesting to see not one single ditching for twins in the corporate/charter/private sectors. With Public Transport flights already requiring floats, there seems precious little case for mandatory floats on private twins. I think I'd rather have 70kgs more fuel (esp when IFR) and 5 kts than floats, for a 30 minute direct channel hop.

[headsethair]

You have less than 3 weeks to post your letters/get your emails to the CAA.

[headsethair]

UK Owners, Pilots, Self-Fly Hirers and Operators : you have one week to get your responses into the CAA.

[Head Turner]

This is a question for those who were the 'Watar Babies' in the accident noted above.

Do you still fly in helicopters configured in the same way as when you ditched, or have you changed to a fully equipped(floats, ELT, immersion suit, life raft, life jacket etc) machine when flying over any water out of auto distance from land?

[headsethair]

Just one week left for the UK single engine helicopter community to keep their freedom to fly.

There are (according to a trawl through G-INFO on the CAA website) nearly 900 helicopters on the UK Register, of which 700 are singles.

237 R22s, 144 R44s, 124 Jet Rangers and hundreds of others.

Please don't let the ICAO or the CAA stop your freedom to take your own decisions.

[LOOSE NUT]

Heliport,

As this topic is quite important (imho) and has a deadline, can you make it one of those sticky threads for the whole of next week ?
Also anyone who has already sent thier views in to the CAA send in a reminder of your views and also encourage everyone who has flown with you to contribute to the effort as well.

LN

[Heliport]

Objections to the proposals must arrive no later than next Saturday: 31 January 2004.

You don't have to write a long complicated letter.

Bullet points will do, and may even be more effective.
(Your letter will be reduced to numbers on a spreadsheet.)

If you agree with all or any of the following points, just copy/paste them into your letter:

Helicopter Flights Over Water: Objections to proposed changes


ICAO standards severely discriminate against non public transport helicopters, as compared with non public transport fixed wing.
ICAO standards should be changed so that private helicopters are treated the same as private fixed wing. There is no significant difference in the mechanical failure risk during enroute flight, between fixed wing and helicopters, and if anything, helicopter engines are more reliable.
There are huge compliance costs for private owners, as opposed to the zero cost impact stated in the proposal.
There is no requirement to follow ICAO standards to fly in other countries. Aircraft only have to be legal in their country of registration.
There is no safety case for the proposals, especially the helicopter flotation proposal.

The cost of fitting and maintaining floats is out of all proportion to the mechanical failure risk of crossing the channel for a few minutes a few times a year.
Mechanical failure over water has not been a major cause of accidents in the last 20+ years.
Private helicopter pilots have been happily and safely flying over water without floats for decades. The CAA can easily file a difference with ICAO to allow them to continue to do so, without floats, as they have up to now.
It would be impossible to fit floats to most R22 and R44 helicopters.
It would cost £????? to fit floats to my helicopter, which is not a reasonable expense for such a short time spent over water.

There is no room in 2 seat helicopters to carry a life raft
Why should helicopters have to carry a life raft when fixed wing aircraft don't?

There is no room/weight to fit an automatic ELT to the Robinson R22 and the Schweizer 300,
It is ludicrous to require the carriage of two ELT's.
The proposals assume that an automatic ELT delivers more safety that a portable unit. However, should a helicopter sink in water or catch fire, a fixed ELT would be useless, and a portable one that the crew or passengers could take with them would be of much greater value..
Fixed wing aircraft can comply using personally carried ELT's so why not helicopters?

The CAA should consider less severe options, such as a gross weight below which these rules would not apply, e.g. 2730kg.
The CAA could apply the private fixed wing proposals to private helicopters.
The CAA can choose which ICAO standards to implement.
The imposition of new requirements such as this, should be based on an objective, demonstrable case that the equipment confers greater benefits than it does disadvantages (of, for example, cost, weight, installation problems or procedural difficulties).
These proposals are for the CAA's administrative convenience, and not for any likely safety benefit to UK persons at all
It should be individual choice to decide whether or not to fit the proposed equipment
It is not the CAA's remit to protect the private pilot from himself.
It is unreasonable to effectively ban large numbers of the UK helicopter fleet of small helicopters from crossing the channel.




Send your comments to:

Mr. David Beavan
GAD CAA
Aviation House
Gatwick Airport
W. Sussex RH6 0YR


Will objections make any difference?
Most people are understandably very cynical about whether the CAA ever takes any notice of objections from aviators, but there's nothing to lose by trying - except 10 minutes of your time and the price of a stamp.
Remember: If you don't respond, the CAA will put you in the 'No objection to the changes' category.

Professional Pilots
The large majority of Rotorheads members are professional pilots so won't be affected by these changes, but please consider helping our PPL members who include experienced self-fly hirers as well as private-owners.

Deadline: next Saturday: 31 January.
Why not do it now? It will only take you 10 minutes if you cut and paste.

Heliport

[Flying Lawyer]

Objections can be sent by e-mail.
Much quicker than writing and sending a letter by snailmail.

E-mail address: [email protected]


Curious that such significant changes which affect so many people are hidden away in a document which most people are unlikely to see or read. ;)


Tudor Owen

[Jarvy]

I have just posted my letter of objection to CAA. As I fly R22 & B206 from Manston if these changes are approved it would limit my direction of flight to west or south west as any other direction is over water!

[headsethair]

To date only 57 replies have been received by the CAA.

Out of 812 single engine owners in the UK.

Does that mean that 755 of you already have floats, 2 ELTs and a liferaft ??

[Heliport]

That's exactly the point the CAA often makes when they bring in legislation which imposes further restrictions. 'We put out a consultation paper saying precisely what we planned to do and only n people objected.'


In this instance, bear in mind that a high percentage of Rotorheads are professional pilots who fly under public transport regs.
It might be a good idea to e-mail this thread to any PPL friends who don't read Pprune - and ask them to pass it on to others.

[headsethair]

Here's a question. Whilst compiling my response letter, I looked through the list of names on the Circulation List the CAA attached to the Letter of Consultation.

The main reason why they have so far not had many responses would appear to be that they have entirely failed to circulate this thing to the correct target - private owners and self fly hirers. Their list is entirely composed of AOC holders and other bodies with little interest in the subject.

Aren't the CAA demanded by statute to ensure that their Consulations get to the right people ? They have the home address of every PPL (H) and the address of every registered single engine machine........so why haven't those people received Consultation letters ?

I also question the QUALITY of the data used to form their circulation list. One of the companies listed is KWIK FIT HOLDINGS PLC. This hasn't existed since 1999 when (Sir) Tom Farmer sold out to Ford Motor Company.

Do we have any way of questioning how this list was compiled ???

Flying Lawyer ?

[cyclic flare]

Response to an e mail i sent to David Beaven set out below

Thank you for your views on this proposal. After the end of the comment period, we intend to proceed to the next stage of the legal amendment process taking account of the comments received and the CAA's consideration and resolution of the points made by the correspondents. Please note that we will not generally reply in detail to individual correspondents as comments will be summarised during the next stage.



There is certainly no intention to make over-water helicopter flights illegal.



Regarding the ELT requirement, you have suggested that aeroplanes need only carry a hand held ELT, however that was not our proposal. The ICAO standard 6.12.3 for general aviation aeroplanes specifies an automatic ELT (Scale KK(ii) in this proposal).

Regards

David Beaven
Deputy Head of Policy
General Aviation Department

[Jarvy]

Sounds to me like they have already decided to go ahead with the changes.So just who do the CAA listen to???

[rotorboater]

I finaly got off my fat ar$e and sent my letter but it is only 1 of 50 or so apparantly:eek:

[headsethair]

I had a reply which inferred that a lot of the letters received so far are just "cut & pastes" of the same points - they want individual responses.....

[Flying Lawyer]

I had a reply which inferred that a lot of the letters received so far are just "cut & pastes" of the same points - they want individual responses.....
100 objections = 100 objections
100 people making a point = 100 people making a point

Whether 100 people spend time expressing themselves in their own individual style or save time by cutting & pasting what someone else has already written is irrelevant.

[Happy Landing !]

I wrote my letter (A cut and paste job) and received the following reply:

The response:

Dear Mr ********

Thank you for taking the time to send your views on this proposal. After the end of the comment period, we intend to proceed to the next stage of the legal amendment process taking account of the comments received and the CAA's consideration and resolution of the points made by the correspondents.
Please note that we will not generally reply in detail to individual
correspondents as comments will be summarised during the next stage.

I notice that your e-mail ends with a standard confidentiality clause. Please let me know whether this means that you do not want your views to be made known, as indicated in paragraph 3.2 of the letter of Consultation.

Regards

David Beaven
Deputy Head of Policy
General Aviation Department

My further Resonse:

Dear David,

Many thanks for your reply.

I hereby waver the confidentiality clause contained in my original email to you.

Signed: **************

His response:

----- Original Message -----
From: "Beaven David" <[email protected]>
To: <*******@********.co.uk>
Sent: Friday, December 19, 2003 1:07 PM
Subject: RE: Proposed changes to Helicopter rules over water.


Dear *********

Many thanks, and best wishes for a Merry Christmas.

Regards

David

My Response (Not wanting to let go )
-----Original Message-----
From: *********@********.co.uk [mailto:*********@*********.co.uk]
Sent: 19 December 2003 13:15
To: Beaven David
Subject: Re: Proposed changes to Helicopter rules over water.


Likewise David, Thank you.

btw - you are aware I expect that the helicopter community is rather "up in arms" about all this?

Lets hope that common sense prevails.

Kind regards.

********** ********

His Response:

I had heard as much!

The amendment process is expected to produce legislation that is requisite or expedient (those are the terms used in the relevant legislation) to fulfil the UK's treaty obligations and safety needs. This consultation is a vital and necessary part of that process - and there is certainly no intention to ban over water flights by helicopters.

David

My response

Agreed.

Providing we have floats/ELT/Life raft fitted or carried !
Are you aware of the cost implications for private owners?

===========================================
No further comments !!

[helipedro]

I just hope that Civil Aviation Authorities with warmer climates than Uk wont make compulsory to have floats fitted to the hundreds of the helicopters using bumbi buckets and water tanks to fight forest fires....Well maybe the could carry a bambi bucket with a 5 mile long sling to be at gliding distance......from a safe place to autorotate..of course

[headsethair]

"...and there is certainly no intention to ban over water flights by helicopters."

Well - he would say that. Has he ommitted the words "...by helicopters fitted with floats, liferafts and ELTs." ???

Because otherwise, he's correct ! If ICAO is adopted, over water flights by helicopters will be banned....unless you have F, L, ELT.

[Flingingwings]

I had this reply to my email. Reading the other replies posted it seems David Beaven also uses 'Cut and Paste'!


Dear XXXXX

Thank you for your views on this proposal. After the end of the comment period, we intend to proceed to the next stage of the legal amendment process taking account of the comments received and the CAA's consideration and resolution of the points made by the correspondents. Please note that we will not generally reply in detail to individual correspondents as comments will be summarised during the next stage.

Regarding the ELT requirement, you have suggested that aeroplanes need only carry a hand held ELT, however that was not our proposal. The ICAO standard 6.12.3 for general aviation aeroplanes specifies an automatic ELT (Scale KK(ii) in this proposal).

Regarding your general comments on the consultation, I should point out that we generally consult on proposals to amend the legislation through the representative associations. It is usual that the considered input we receive enables revised proposals to be satisfactorily formulated. The CAA's safety promotion initiatives generally address matters such as airmanship at the individual level.

I can assure you that in writing to all the airsports users and representative associations, the aviation press and other organisations, and publicising this consulation on the CAA website there was no intention to hide this information as you have suggested.

Regards

David Beaven
Deputy Head of Policy
General Aviation Department

[headsethair]

I don't think we should be concerned with how Mr Beaven writes his replies - he seems to be genuinely interested in the responses.

Our efforts should be concentrated on ensuring that he gets as many responses as possible by this Saturday 31st January.

The CAA has stated that they cannot write to all the people affected by this Consultation - I find that incredible and it is something that must be raised with the appropriate authorities. The CAA, as has been discussed here before, has apparently no govt funding and has to "stand alone". But it seems bizarre that it has no way of communicating with its database of people and machines.

So - please all get going on the jungle telegraph and ensure that as many private owners and private pilots get to hear about this proposed change. And that they RESPOND !

[Flying Lawyer]

Comments sent today.

Thanks for the reminder headsethair.

[Nigel Osborn]

Not being a UK PPL pilot or helicopter owner, I am very surprised that all of you are against all these proposals. I can understand the feeling about floats as they can be heavy and cost a bit but then helicopters are not cheap.
I don't understand why you don't want a liferaft or an ELT. I bought a small single seat liferaft which clipped onto my belt and was the size of a sandwich box. This meant if I ditched, the liferaft came with me even if there was a biiger one in the back. Only cost about $200.
I can't believe a little 1 pound ELT could not be easily fitted to any helicopter, however small. Having searched for numerous missing boats, people, plank wing and helicopters over the last 45 years, I know how much easier it is for the SAR pilot to find you if you were pinging away.
At the end of the day you are talking about your own life, so it is a very important decision to take.:confused:

[Heliport]

At the end of the day you are talking about your own life, so it is a very important decision to take. It's an important decision private pilots won't be allowed to make under these proposals.

[headsethair]

Nigel: You can bet your life that belt-mounted liferafts will not be permitted. The most popular helicopter in the UK is the R22 closely followed by the R44 - between them they account for 50% of single engine machines.

The R22 cannot carry a liferaft adequate for 2 people - and the 44 has to lose a pax to carry a raft (like many light helis). Neither machine can be retro-fitted with floats.

For the others: the cost of fitting floats is horrendous.

With regards to ELT: personal fine, but should be a commander decision. Fixed : not worth the weight for overwater ops because the machine will inevitably finish up with the antenna beneath the surface. Even with floats, the physics of a top-heavy heli in anything other than a light swell is going to mean a flip.

In any case - look at the stats (earlier). In 15 years of UK-reg SINGLE engine helicopters flying over water, there have only been 5 ditchings with no loss of life or injuries. None of these entailed floats. And only 1 had a liferaft, I believe.

(Interestingly, one of the incidents makes great play on the benefits of a STAS-equipped lifejacket which provides 3 mins of breathable air. This saved the life of a pilot who had trouble getting out of the machine.)

SE Fixed Wing has a far worse rec ord, and they are not now being compelled to have floats, liferafts or stay within glide distance of land.

And another thing - who says floats will work when you need them ? There's an instance posted earlier here about one of our group deploying floats and his port one did not inflate.

The vast majority of floats are pop-outs. These get checked annually, that's all. When you do your pre-flight all you can do is check bottle pressure. You have no idea whether any other part of the system is working. How many times have you heard someone say - "Ooops, it says "no step" there! Sorry" AFTER they've put their boot on the skid ??

An amusing aside: under current CAA Airworthiness rules, if you import an N reg ship to the UK and wish to add it to the UK register, you have to REMOVE the ELT fitted to that machine. That's been the case for years!

[Helinut]

If these proposals go ahead, the equipment required will all be CAA approved - for this read bulky, expensive and inevitably altered in some way that no one else ever thought of to satisfy some obscure CAA requirement.

[John Eacott]

We went through a similar, albeit less costly, problem some years ago, when CAA (Oz) got hot under the collar with proposals and edicts to fit fixed ELT's in all aircraft. AOPA Australia ran a good lobby, with very similar concerns to those put here, but the overriding point that was made (IIRC) was to give the public servants an option.

In our case, the point was made that fixed ELT's were of dubious value in the case of a ditching, or an aircraft fire. Option was to lobby for ELT's, but leave the choice to the owner/operator, whether to have fixed, portable, or both.

Sanity and common sense prevailed (after a long and hard flog) and that is now the option down here. As an operator, I have put both fixed 6 axis ELT's in each aircraft, plus personal ELT's in lifejackets, plus portables in each cockpit. Not cheap, but a bl**dy good insurance. Most contract pilots regularly turn up with a personal ELT clipped to their belt, quite commonplace these days.

Might I suggest that any lobbying done be well researched, and provide options/alternatives, rather than "don't agree, won't agree"? For instance, the certification and engineering costs associated with fixed ELT's is generally horrendous, and unacceptable to the average GA owner. Make that a supporting point for the option of portables, along with the other anti fixed installation issues.

Floats? Well, a difficult one, and hard to argue against on a purely safety issue. But how many other ICAO signatories comply with this standard? Present the case well, and it may get modified for >50nm offshore, or similar. No reason why personal liferafts, as described by Nigel, wouldn't be approved, if presented properly as an option. Especially as it is the most likely way that a Robbo driver will get to have one with him/her when exiting the aircraft in a hurry!

Just a few thoughts on a Friday afternoon ;)

[Helinut]

A bit of feedback on this one from the BHAB, in their magazine Rotorheads.

I won't copy it in full cos they will get mad, but the gist is that the CAA got a "large number of responses", they are "considering their position" and will return to its proposal with a subsequent Regulatory Impact Assessment in due course.

You can read into that what you will ...................

[Heliport]

I doubt if the BHAB will object when it's an issue like this which could have consequences for the UK rotary world in general, not only the commercial side. If they complain, I'm happy to take responsibility.

I don't understand why the CAA only provides feedback to 'organisations' that respond to consutation papers.
If sending reports by snailmail would be too expensive, they could at least respond to individuals who send comments by e-mail. :confused:

Heliport

[Head Turner]

How much do you value your life when contemplating an over water flight?

How much are you willing to pay for 1. an injection to protect you from a deadly virus, 2. a top class meal at a top class restaurant?

I am just posting this as I value my life so much so that I would fit any aids which will provide some measure of protecting me until a rescue is made.

I agree whole heartedly with what John Eacott is saying and rather than mandatory legislation it should be to the individual to provide for him/herself.

Where this rationale is not 'watertight' is when there are other occupants in the helicopter and some form of protection must be afforded to them. They shoud not be required to rely on the captains judgement or to put it another way they have the right to be fully protected whatever the opinion of the pilot is.

Floats should be fitted.
Life jackets worn.
Life raft carried ONLY IF it can be deployed by those on board
ELT's should be fitted to the life jacket so that it is immediately available to use. Clipped in the cockpit is impractical.
Immersion suit is a sensible addition in cool waters.

Cost of all this is about 3-5% of the purchase price of the helicopter. Or this could be more for little 'copters.

[headsethair]

Head: Are you forgetting a few important facts ?

The R22 Mariner is discontinued. The R22 & the R44 cannot be retro-fitted with floats.

The R22 doesn't have the spare weight to carry 2 ELTs.

The extra weight of all the proposed devices added to any light helicopter actually gives those machines less margin for error and therefore makes them less safe.

As for pax - they have a choice. They can be given the stats and take an informed, personal decision. (And I know what it would be.)

Finally, why should there be legislation to cover an event which hardly ever occurs ?

Let's concentrate on the REAL safety issues associated with helicopters : the most common causes of fatal and non-fatal accidents. Let's stop the wire-strikes, CFIT, settling with power and downright carelessness which costs lives and gives helicopters a bad name.

And let's realise that if you give people floats, ELTs and life jackets they will reward you with even more carelessness. It's like the question I once asked a car safety designer - "What's the safest car ?".

"One with a 12 inch spike extending from the steering wheel boss towards the driver," was the answer.

Air bags, ABS, anti-skid axles - they just give people some strange licence to misbehave. And flying can easily go down the same expensive route.

[Head Turner]

Headsethair - - Thanks for your comments and I have to agree wholeheartedly.
My note was to focus just on the 'over water' aspect of the business of flying helicopters.

[headsethair]

Head: Cheers!

The rules against single engine ops in this country are more than draconian. They are just not based on facts. Engine failures in SEH are unheard of these days. However, that doesn't mean that it isn't going to happen - so we all have to take responsibility for our decisions.

Even with floats, ELT etc there is no guarantee that you will be saved. There is no guarantee that you will execute a perfect auto onto a 2 metre swell. There is no guarantee that your seat belt, otherwise a fine lifesaver, could not lead to your untimely demise trapping you in the upturned cockpit. So - should we ban seat belts ? Of course not.

And, my main bugbear, the astoundingly unsound asumption that twins are safer than singles. Not from the stats, they're not. More weight, more to go wrong, more likely to suffer some sort of breakdown.

Sadly the European led "pro twin turbine" lobby is heavily funded and has all the right connections.

So decent helicopter flying will always remain beyond the means of most Europeans.

Here's bizarre - I fly 3 friends down the Thames for a sightseeing trip through London - one of THE greatest heli trips in the world. As soon as I charge them for the privilege it apparently becomes more dangerous and I have to (under PT rules) have floats. This very act makes the whole trip borderline on fuel.

What's the safe answer ?

Maybe the future will make it EASA-ier. But I doubt it.

[imabell]

your right headsethair,

everything is centred around engine failure, so you must have two.

so why not two transmissions, two tailrotor drives, etc.

if helicopters were that unreliable you wouldn't get in one, i wouldn't.

twin engined helicopters with one out just take you a bit further to the crash site.

the two engine argument is a crock.

by the way, in australia at the moment the emergecy helicopters of the gov't emergency services are not being utilised much because the medical unions are arguing about life insurance for the staff.

this organisation has highly trained pilots flying 412's, they have had only one incident (minor) that i can remember but because of the problems (accidents) encountered by other operators , nothing to do with the machines, they are not being tasked for medical retrieval.

even though there has been a series of accidents here over the years it has to be said that the (single engined) helicopters were in perfect working order when they came to grief. a twin would have met the same fate. they don't fly themselves.

the problem here is far from resolved. what a waste of a very expensive but effective resourse.:sad:

[Head Turner]

Again I have to agree with the logic of Headsethair.

Now here's one for the 'more engines the better' brigade.

IF there was a three engined small helicopter would that allow unrestricted flights over water. Or four, or five.

Odd isn't it that we fly 100+ people across the Atlantic on just two engines. It used to be done on four engines.

So why are the aeroplanes flying with fewer engines than before and helicopters are requiring more engines?

What is the insurance providers view of the risk comparison between twin and single engined operations over water?

Just to be even more critical. Was it not a twin engined helicopter that crashed at an RN airfield. Nowt to do with the number of engines fitted but that it only had one tail rotor. B407's have only one tail rotor and they are flying over lots of water!

[headsethair]

Praise be to the CAA! They have listened and acted.

For Private single engine helicopter flights over water, from Jan 2006, a portable ELT will be required for any flight that is more than 10 minutes from land at cruise speed.

Fixed ELT and Float proposals abandoned. And other safety equipment will be the Commander's decision.

Well done to all who wrote in response to the Consultation. We await the actual ANO wording....

in the meantime this is from the CAA website:

"Changes to the proposal The CAA has considered comments 1-5-1 to 1-5-10 and information available from the UK accident record. It appears that, for small helicopters at least, ditchings may be generally survivable even without floatation equipment. Although the technical requirements of floatation equipment are common to all helicopters, irrespective of the purpose of the flight, it is accepted that the requirements for General Aviation do not have to be the same as for public transport operations. Implementation of requirements for helicopter floatation equipment would mean that many owners would be unable to comply, and would in effect be prohibited from flying to many destinations in accordance with established custom and practice. For the types of helicopter where compliance is feasible, the costs of compliance may be considered to be unjustified (see 1-15-4), particularly where owners fly over water for only a few hours each year. (See also 1-G-7 and comments made in relation to other emergency equipment, 1-10-15 and 1-10-17). Having considered all of the foregoing, the CAA has decided that it would be inappropriate to mandate permanent or rapidly deployable means of floatation for General Aviation helicopter flights over water, although owners may of course continue to fit such equipment if they wish.":O

[rotorcraig]

Well done!

Document that headsethair quotes ref floatation equipment is here (http://www.caa.co.uk/docs/224/Appendix%2015a.pdf)

Document referencing ELT is here (http://www.caa.co.uk/docs/224/Appendix%208a.pdf)Changes to the proposal

Having considered all the comments received (1-8-1 to 1-8-21), this proposal has been amended to require either an automatic ELT or a survival ELT (ELT(S)) for extended flights over water. Since the implications for survival after ditching are similar, irrespective of the class of aircraft flown, the disparities between the ICAO standards for aeroplanes and helicopters seem unjustified. Therefore it is proposed that the circumstances in which aeroplanes and helicopters will be required to carry an ELT will be the same.

In assessing the likelihood of ditching it seems that the most important factor to be considered is the amount of time that will be spent exposed to the risk of flying over water (see 1-G-7) and this is more significant than any perceived differences between different classes of aircraft (see comments made in relation to other emergency equipment, 1-10-15 and 1-10-17). The revised proposal gives responsibility for the commander to decide if an ELT is to be carried, e.g. on shorter flights when the prescribed distances will not be exceeded and the time exposed to the risks of flight over water may be limited.

Views are sought regarding two alternative proposals for Article 43A. Option A makes explicit that the survival equipment to be considered includes ELTs. This option reflects the approach being developed in JAR-OPS 0; and would more clearly demonstrate an alternative means of compliance with the relevant ICAO standards. Option B provides a more general formulation. Each of these options needs to be read in conjunction with the other equipment (including radio apparatus) requirements specified elsewhere in the Air Navigation Order. Each option is intended to have the same substantive effect. If expressing a preference for either one or the other, please explain the reasoning behind your preference. It is suggested that the relative merits of these options should be considered in conjunction with the Appendix 10a proposals.Full Comments and Responses document is here (http://www.caa.co.uk/docs/224/Comment_response.pdf)

RC

[Helinut]

Well done everyone who contributed and indeed to the CAA for listening to the comments received - it gives hope for the future where there is a sensible balanced result frm such a process

[Clive Roberts]

Hi,
Can anyone please point me towards the current (2022) legislation in force?

Thanks,

Clive.

[8021123]

Clive,
Accessing any UK aviation regulation easily these days is a challenge in itself!
That aside (and assuming UK law applies to your operation), you'll find it here: UK CAA website (https://info.caa.co.uk/uk-regulations/air-operations/). (The AMC & Guidance Material is accessible too.).
The authoritative source is from The National Archives - 'legislation.gov.uk' (https://www.legislation.gov.uk/eur/2012/965/contents).
Depending on whether the aircraft is 'Complex' or Other Than Complex', search in the IDE bit (Instruments, Data & Equipment) of NCC or NCO respectively.
Enjoy...

[Clive Roberts]

Thanks, 8021123.

By the way, if your 'number' originates from the same place as mine, I think I joined that organisation a scant few years before you did!

[md 600 driver]

Thanks, 8021123.

By the way, if your 'number' originates from the same place as mine, I think I joined that organisation a scant few years before you did!

mine started 24

[Clive Roberts]

Wow! So, what was Trenchard really like?

[[email protected]]

Mine only differs in the 4th and 6th digits and I joined Mar 82.

[Clive Roberts]

Interesting, about the numbers. One never forgets that number from years ago. Burned into the psyche on numerous drill parades!

Though, with all respect, I have never understood why contributors to forums always have ... erm ... pseudonyms.
It's certainly popular on the motorbike and car forums I visit. But here on PPRuNe, I cannot see why one would wish to remain anonymous. Security? Surely not.

I for one would find it more interesting to know whom I was exchanging missives with. Might even recognise each other from the dim and distant.

And these 'icons'. Perhaps they have replaced our names as our identity. A cursory look at other posts indicates to me that people on this forum don't make use of 'em. Goodo.