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UK Over Water Singles- Update: Sensible Decision

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UK Over Water Singles- Update: Sensible Decision

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Old 27th Jan 2004, 21:02
  #61 (permalink)  
 
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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 !!
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Old 27th Jan 2004, 21:08
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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
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Old 27th Jan 2004, 22:26
  #63 (permalink)  
 
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Let's not get complacent!

"...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.
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Old 28th Jan 2004, 02:39
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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
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Old 28th Jan 2004, 03:25
  #65 (permalink)  
 
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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 !
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Old 28th Jan 2004, 07:39
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Comments sent today.

Thanks for the reminder headsethair.
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Old 28th Jan 2004, 08:32
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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.
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Old 28th Jan 2004, 12:41
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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.
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Old 28th Jan 2004, 17:48
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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!

Last edited by headsethair; 28th Jan 2004 at 20:22.
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Old 30th Jan 2004, 07:12
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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.
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Old 30th Jan 2004, 10:30
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Exclamation Deja vu

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
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Old 8th Mar 2004, 02:36
  #72 (permalink)  
 
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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 ...................
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Old 8th Mar 2004, 02:57
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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.

Heliport
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Old 29th Mar 2004, 13:59
  #74 (permalink)  
 
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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.
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Old 29th Mar 2004, 14:24
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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.
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Old 1st Apr 2004, 07:09
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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.
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Old 1st Apr 2004, 09:10
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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.
headsethair is offline  
Old 1st Apr 2004, 09:52
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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.
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Old 2nd Apr 2004, 07:37
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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!
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Old 1st May 2004, 17:36
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UK Over Water Singles : Sensible Decision

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."
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