UK Over Water Singles- Update: Sensible Decision

[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]

Tongue firmly in cheek.....

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



Ducking for incoming from Crab

[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

[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.