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NPA to JAR-OPS 3

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Old 31st Oct 2005, 16:22
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NPA to JAR-OPS 3

Offered for consultation on the jaa.nl website.
Some proposed amendments that will concern single and light-twin operators.
typically huge document to digest from Jaa.

Thanks to BHAB member, who's highlighted that the excessive amount of exposure time where a safe forced landing cannot be assured (up to 18secs single/ 9 seconds twin) which has been proposed will not just effect helipad ops but approaches to certain other sites.

However, to achieve this, UMS equipment equipment (£20K) must be fitted!!

Is it just me or has the purpose of the helicopter been lost on regulators? Do they seriously think that such an expense can be passed on to the customer, in addition to the other expensive proposals seeking approval?

In addition, it would appear that the regulators imagine that helicopter operators know which HLS they are going to use months in advance!

Don't forget that they already charge £100 for authorising 'excemptions'.

Let's face it - it's a conspiracy by the plank pilots and their powerful, payrolled, lobbyists to only allow commercial helicopter flights from licenced airfields - thereby doing away with the need for such vertical flight in the first place - v cunning but a tad obvious!!
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Old 31st Oct 2005, 18:03
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Unhappy

Here here the whole point of helicopters is to land and take off in places planes can't,and the risk's involed are are worth it for that very ability.

When you think that private pilots and students go in and out of very small sites without crashing every five minutes, then you might think that a full time pilot in a more powerfull machine should be able to do it any how they think fit.

I believe that we have a duty to protect people on the ground from heli's that might drop in through the roof but if people who use heli's are happy to take what are realy only small risk's, then they should be allowed too.

If those who seem to think you can make things safe by making it harder and harder to carry out flights get their way then they will, there won't be any flights at all.Or maybe we should all just stop listerning to them and self regulate......................
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Old 1st Nov 2005, 02:18
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"Let's face it - it's a conspiracy by the plank pilots and their powerful, payrolled, lobbyists to only allow commercial helicopter flights from licenced airfields"

I think you'll find (and I'm sure JimL will correct me if I'm wrong) that the driving force comes from the manufacturers and operators! I know for a fact that ECF were talking about it months before NPA-38 was published (if you get a chance to look at the Cat A 'increased slope' procedure for the EC-155 you'll see lots of clues!)

Please explain how introducing the concept of exposure for ground level heliports, thereby allowing take offs from sites previously not acceptable, is a move towards operating from a runway?
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Old 1st Nov 2005, 07:13
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Like 212man, I am somewhat baffled by the interpretation of NPA OPS-38 by EEDSL; as 212man has said, it was at the request of the operators and manufacturers that the proposal was undertaken.

The issue of UMS is an interesting one; the requirement for this equipment has been a feature of JAR-OPS 3 since NPA OPS-8 (1998) - when Exposure was first introduced. That it has not been universally implemented is due to the somewhat patchy nature of each NAA's progress towards full implementation of the code.

The main rationale for the proposal was: a simplification of the performance rules; removal the uncertainty that was a feature of certain impending dates when changes had to be made (2005 and 2010 - these have now been removed); and the introduction of ground level exposure. There is nothing for operators to fear in this proposal.

To put the NPA in perspective, here is the meat of the proposal in thumbnail form; if there is any part of this which has not been explained thoroughly in the NPA Explanatory Text, pose the question and I will attempt to explain the what, the why and the how.

Revision of Performance Subparts: F - General
  • Applicability changes to permit offshore operations in PC2 with more than 19 passengers (PC2e only)
  • Introduction of a single text for Environmental Conditions (wind, temperature and pressure) – used by all Subparts
  • Introduction of a single text for Obstacle Accountability – used by all Subparts
  • Definition of: TODRH amended to permit modern profiles; Take-off Flight Path added
  • Clarification of the use of ‘equivalence’ for twin engine helicopters certificated before Appendix C to FAR 27 (complete with pointers)
  • Addition of more comprehensive explanatory text
Revision of Performance Subparts: G - PC1
  • Introduction of Flexibility into PC1
  • Use of a single requirement for ground level and elevated heliports
  • Simplification of Procedures by removal of duplicated text and use of reference
  • Reduced reliance on Category A procedures
  • More recent Category A procedures recognised (achieved with change of definition of TODRH)
  • Addition of more comprehensive explanatory text
Revision of Performance Subparts: H – PC2
  • Simplification of Procedures by removal of duplicated text and use of reference
  • Introduction of ground level exposure to PC2
  • Introduction of PC2e for Operations in a Hostile Environment
  • Simplification of Approval process for exposure
  • Removal of limiting dates in performance Subparts
  • Addition of more comprehensive explanatory text
Revision of Performance Subparts: I – PC3
  • Simplification of Procedures by removal of duplicated text and use of reference
  • Reordering of the text in a more logical form
  • Introduction of ground level exposure to PC3
  • Simplification of Approval process for exposure
  • Addition of more comprehensive explanatory text
Proposed Revision of JAR-OPS 3 – Other Issues
  • Guidance on the extent of the HEMS mission
  • Requirement for NVG Approval
  • Accessibility of Emergency Equipment
  • Reporting of Flight Hours
  • Removal and amendment of terms in Subpart J
  • Clarification of ELT technical requirements (406 MHz)
  • Revision of the table for equipment requirements
  • Clarification of two training requirements in Subpart N
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Old 1st Nov 2005, 07:19
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EESDL

I agree with SAS. I know the prospect will not fill you with pleasure but I think you ought to read it again. I'm on my third go as I keep forgetting at what point in the script I became comotose. It is important though because I think the intention is to make life more simple and less complex plus being a little more sensitive to some commercial realities.

The quote you should focus on is that the cost of low level monitoring equipment can be recovered by the recording of an otherwise unrecorded 'hot start'

More reading less knee-jerk methinks.

G

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Old 1st Nov 2005, 08:16
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Geoffers, did you mean me? I've been called lots of names in my time, but never SASless!!
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Old 1st Nov 2005, 10:17
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sorreeeeeeeeeee 212

slip of the old brain cell 212 (not another one!) It was 0600 in the morning when I read your thread - that's my only excuse...... and then Jim piped up in the meantime and as usual straightened things out.

Alls well that ends well but that still leaves me struggling to come up with a formula for minimum performance at the platform helideck. Is HOGE going to cut it or do I factor it by 2.5% or 5% as some have recommended. Is there any science behind this???

G

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Old 1st Nov 2005, 20:22
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NPa to JAR-OPS 3

JimL

Could you help me with some misunderstanding of the NPA? Specifically 3.520. Is it correct that we are looking at the imminent implimentation of the requirement for approval for exposure, in accordance with 3.517(a), when operating from a helideck, if the helicopter cannot achieve AEO HOGE? If so am I correct in thinking that the various requirements to achieve that approval include, amongst other things the requirement for a 'Usage Monitoring System' that will record certain parameters, particularly engine details?

Assuming this is all correct, would it be also correct to say that the current generation of light twins and singles operating fom the Battersea Heliport will need to have this equipment installed if they cannot meet AEO HOGE?
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Old 1st Nov 2005, 21:33
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Sorry!
I'm now on my 3rd read and whilst it goes someway to simplify certain procedures and enhance 'safety' margins - the point I very badly made, obviously, is that it's envisaged that these proposed 'safety' margins will render the current fleet of single and light twins useless if they have the audacity to try and earn a living - as they have been doing, without disaster, for quite a while.

I keep nagging at the Boss to buy a new chopper but I'm stuck with an old 1980's AS355 - so I cannot see how the proposed regulations, as illustrated, will benefit me in doing my job. It will not benefit my passengers as they'll be left on the ground - or do we think that they'll pay for a ride in the more expensive machines on the market.

The remark about the conspiracy and the move to having to operate from 'airfields' was a tongue in cheek reference to other regulations that have been proposed that are aimed to improve security- ring fence security cordon, nominated personnel etc a la regs pertaining to >10Tonne aircraft. Thought the reference would have been enough for the comment to be valid, my mistake as I thought it might have been a hot topic amongst operators - especially now that Oil Rigs are to be called airfields:-)
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Old 2nd Nov 2005, 08:32
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Stinger,

As I hinted in my first post, the introduction of Exposure with its associated Appendices resulted from NPA-8 (in 1998); the proposals do not, in respect of Battersea, change anything at all. It is my understanding that existing operations are permitted by the CAA under the ANO, or under JAR-OPS 3 with exemptions. UMS (when exposure is permitted) has been a JAR-OPS 3 requirement for the last seven years.

For elevated heliports, the need for AEO HOGE performance - both for PC2 and 3 - is based upon a practical consideration that delta power above that required for hover in ground effect will be required if a dynamic procedure is to be used; even if a pull-and-go is used (for example in a single) the erosion of the ground cushion would result in a dangerous condition if sufficient power is not available to arrest the descent. (Those who operate S76As from the North Sea rigs will understand this only too well.)

With the proposal for the introduction of ground level exposure to 200ft, operations to limited areas which require steep or vertical climbs are envisaged - hence there is a need to introduce AEO HOGE performance to the rule under such conditions. (For PC2 there is also the base line requirement for second segment climb performance (150ft/min at Vy, 1000ft above the take-off surface).)

The conditions are not tied to the requirement for AEO HOGE performance but Exposure per se - the additional requirement for AEO HOGE has always been present in guidance but (with the proposal for the introduction of ground level exposure) it was considered that it would be better inside the rule.

EESDL,

I fear that my point (also made by others) may not have been well enough stated; with the understanding of how operations to Battersea are permitted (for which the condition of use have not changed for seven years - and in substance will not change with the introduction of NPA OPS-38 - i.e. the CAA permit operations by exemption) you may go about your business exactly as you do today. If however, you wish to take advantage of the introduction of ground level exposure (which was graphically described by CRAZYBROADSWORD above) which is proposed, you will need to apply the mitigating clauses.

The need for the provision of a safe-forced-landing - which derives from ICAO Annex 6 Part III - has always driven the requirement for operations from open areas; the proposed amendment to ICAO and to JAR-OPS 3 permits the State(s) to accept operations with Exposure (without the provision of a safe-forced-landing) when they are appropriately risk assessed. The JAA, in the explanatory text of NPA OPS-38, explains how ground level operations with exposure can be permitted to the existing safety target providing the engine achieves the reliability figure of one failure in 100,000 flight hours. One of the elements for the achievement of such a reliability figure is that certain events are eliminated or captured (to be appropriately dealt with).

UMS can assist in the achievement of this reliability figure in that it can prevent ‘hot starts’ (which change the structure of the crystals in the turbine blades) and inculcate a more considered approach to engine management (along with power assurance checks and improved maintenance procedures).

However, if you wish to continue to operate as you do today and not take (commercial) advantage of operating with ground level exposure, do so and there is no penalty.

Last edited by JimL; 2nd Nov 2005 at 09:08.
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Old 2nd Nov 2005, 16:27
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Thanks, Jim, for your explanation.

Sorry to keep on about Battersea Ops., but I guess it is an easily recognised example and important to a number of operators.

My understanding is that one significance of NPA 38 is that this is likely to be the last NPA before the demise of JAA and the enthronement of EASA. So the version of JAR-OPS resulting from NPA 38 will pass into European Law within the next couple of years.

At this stage the existing operations "permitted under JAR-OPS 3 with exemptions", will cease, as the CAA will no longer be in a position to issue these exemptions (?)

There is a justifiable concern that the current generation of light twins and singles will be then prevented from operating out of Battersea.

We could see the situation where Battersea Heliport is available to private flights only, as commercial operators are unlikely to be able to meet the requirements, particularly with respect to UMS.
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Old 2nd Nov 2005, 18:43
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Stinger,

I agree with you but that has been the situation for the last seven years.

One main reason for the production of NPA-38 was to remove the uncertainties surrounding future performance - it should have been home and dry by now as it was written, and submitted, in March 2004, in time to be implemented before April 2005. It was also coordinated with amendments to Annex 6 Part III.

EASA was not the big issue for most of Europe as they already implement the code - it was the introduction of ground level exposure.

There are likely to be more NPAs before EASA takes possession of, and modifies, the code - there are several major issues that are being addressed at this time.

Jim
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Old 2nd Nov 2005, 19:02
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JimL
Thanks for the clarification and history behind the issue.
My initial post echoed a couple a points disseminated by a BHAB letter doing the rounds - so i was a bit lazy in reviewing the detail. Must admit though, tad surprised at the perceived lack of impact to singles/light twins (older variety) as the letter is full of woe!
If there is a 'commercial' advantage to be had - I'm all for it but it's going to take many years of trading to recoup the 20K estimate for UMS installation:-(
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Old 2nd Nov 2005, 20:36
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So, my point is that the majority of operators, certainly in the south east of UK, who rely to a large extent on access to Battersea will find their operations severely curtailed, as a result of the requirement for exposure approval. This will cause serious economic hardship to many operators. Indeed the reduction in flights using the heliport may even result in the heliport itself becoming economically unviable, resulting in the loss of the heliport altogether.

Naturally this consideration is of far more consequence to the majority of onshore operators in the UK, than any suggested 'economic benefit' of fitting £20k UMS equipment to their helicopters.

While the need to address uncertainties surrounding future performance is undoubted. It is equally vital to protect current activities - or we may have no operators left to implement the wonderful new code - or heliport to expose ourselves at.
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Old 3rd Nov 2005, 09:20
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Glad to see that someone else can't quite appreciate the 'benefits' - but then Stinger might be as misguided as myself!!
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Old 3rd Nov 2005, 22:08
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JimL:
Probably just as well someone understands this stuff. Thank you for your concise summary. I've spent most of today trying to read the NPA. Luckily for me it's actually quite repetitive so if you've read it once you've already done your revision.

One question:
For PC2 there is also the base line requirement for second segment climb performance (150ft/min at Vy, 1000ft above the take-off surface)
That's an OEI requirement, right? How does that square with climb gradients quoted in percentages?

NS
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Old 4th Nov 2005, 04:02
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NorthSouth,
climb gradients are not a directly required function of OEI performance when considering PC2 in its purest form, but do become a factor when looking at the obstacle clearance requirements or IFR departures/missed approaches.

JAR/FAR 29 Cat A certification requirements express OEI performance in rates of climb, whereas the UK CAA used to require climb gardients for BCAR Group A certification. JAR OPS-3 and ICAO Annex 6 performance requirements mirror the Cat A requirements for PC1 and use elements of it for PC2.

Depending on the aircraft you operate, the Flight Manual may have graphs that allow you to calculate the climb gradients for Vtoss and/or Vy, which you can then use to confirm compliance with obstacle clearance or IFR requirements. It's a useful exercise to look at in any case; you may find the horizontal distances travelled somewhat eye watering!

To give an example for an aircraft with a typical Vy of 70 kts:

In the second segment, climbing at 150 ft/min, it covers 7090 ft for every 150 ft of climb. So, from 200 ft to 1000 ft it covers nearly 38000 ft, which is over 6 nm! (For info, I did not use Sine as the angle is so small!)

That same aircraft is climbing with a 2.1% gradient which is less than the usual minimum of 2.5% expected for a SID or missed approach procedure, so if flying IFR you would probably need to reduce the weight to increase the climb gradient.
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Old 4th Nov 2005, 09:22
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JIML

JimL
Congratulations on winning the Eric Brown Award at the BHAB Annual Dinner - well deserved I am sure.
I have sent you a PM so could you have a look and respond please?
Thanks
ANOrak
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Old 4th Nov 2005, 10:59
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Thanks ANOrak, no greater compliment than to receive the accolade of your peers - it was nice meeting with and talking to other PPruners.

Northsouth,

I have nothing to add to 212man’s comprehensive explanation.

However what he has illustrated by his provision of gradients and distances is one of the principle benefits of PC2. Whilst PC1 requires OEI climb performance from the take-off-distance-required (which for a clear area procedure is achieved at 35ft, Vtoss with a positive rate of climb), when using PC2 advantage can be taken of an all-engines-climb to 200ft (with exposure if necessary); hence the OEI climb gradient does not need to be applied until reaching that height.

This permits a two part gradient with the first achieved at twin engine power and the second at OEI - this has the potential to reduce substantially the amount of heliport surface and airspace required. When used in conjunction with Point-in-Space GPS procedures (if an entry point is established at 200ft) a flexible entry into IFR can be established. Although this will be of little use in areas where the obstacles and terrain do not permit such profiles, it will be extremely useful in flatter areas.

It is exactly this principle (and exposure to 200ft) that is needed by the ICAO Annex 14 (heliports) group in order to provide practical solutions to reduce the size of heliports and to make the airspace requirement more pragmatic.

Jim
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