JAA Land, CAT-A HEMS!!??
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JAA Land, CAT-A HEMS!!??
Question of the day,
I should be gratefull if somebody could help me with the following questions:
Q1. Do a HEMS helicopter according to the JARs ALLWAYS have to be performing to CAT-A (Performance Class 1) performance?
Q2. If not, why?
Thanks in advance,
Vertolot
I should be gratefull if somebody could help me with the following questions:
Q1. Do a HEMS helicopter according to the JARs ALLWAYS have to be performing to CAT-A (Performance Class 1) performance?
Q2. If not, why?
Thanks in advance,
Vertolot
When talking about 'JAR land' as you put it, you talk about operating in Performance Class 1 or 2 (PC1, PC2), not Cat A. The definitions and requirements for PC1 and PC2 can be found in JAR OPS-3, sub parts F, G and H (and also look at NPA-38 on the JAA web site). Cat A is a certification standard, within which are defined performance standards. Broadly speaking the Cat A performance requirements match those of PC 1.
EMS is still classed as Commercial Air Transport, so the aircraft has to operate to the appropriate performance standard for it's seating capacity. Generally this would require PC2. The other factor most relevant, is the operating environment: is it non-hostile non-congested, non-hostile congested, hostile non-congested or hostile congetsed? Generally a HEMS operation could expect to encounter at least two of those combinations during its operations, and that would also determine the performance standard expected. Likewise, day or night ops.
A brief explanation, possibly with some errors, but it should give you an idea!
EMS is still classed as Commercial Air Transport, so the aircraft has to operate to the appropriate performance standard for it's seating capacity. Generally this would require PC2. The other factor most relevant, is the operating environment: is it non-hostile non-congested, non-hostile congested, hostile non-congested or hostile congetsed? Generally a HEMS operation could expect to encounter at least two of those combinations during its operations, and that would also determine the performance standard expected. Likewise, day or night ops.
A brief explanation, possibly with some errors, but it should give you an idea!
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212man,
Thanks for the reply. I had a look at JAA website for NPA-38, but it wasn't possible to read it because it was closed by December 1 2005 (Comment Period). I understand that NPA stands for Notice of Proposed Amendment, what will this mean in plain English?
So lets take a case. We are going for a HEMS mission, picking up a patient in a non-hostale non-congested area and taking him to a hospital which is non hostale congested area. I undersstand that we have to be PC1 when going in for landing at the hospital in a congested area, but do we need to be PC1 when picking up the patient in the non-hostale non-congasted area? In otherword do we need to be PC1 during the hole mission or only when going into the hospital?
JAR-OPS3 says very clearly (to me...) that when going to hostile areas, congested areas we need to be PC1, but otherwise PC1 as far as possible !
In JAA Land are the operation regulated by the JAR-OPS3 or NPAs??
Thanks,
Thanks for the reply. I had a look at JAA website for NPA-38, but it wasn't possible to read it because it was closed by December 1 2005 (Comment Period). I understand that NPA stands for Notice of Proposed Amendment, what will this mean in plain English?
So lets take a case. We are going for a HEMS mission, picking up a patient in a non-hostale non-congested area and taking him to a hospital which is non hostale congested area. I undersstand that we have to be PC1 when going in for landing at the hospital in a congested area, but do we need to be PC1 when picking up the patient in the non-hostale non-congasted area? In otherword do we need to be PC1 during the hole mission or only when going into the hospital?
JAR-OPS3 says very clearly (to me...) that when going to hostile areas, congested areas we need to be PC1, but otherwise PC1 as far as possible !
In JAA Land are the operation regulated by the JAR-OPS3 or NPAs??
Thanks,
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212man,
Thanks for the reply. I had a look at JAA website for NPA-38, but it wasn't possible to read it because it was closed by December 1 2005 (Comment Period). I understand that NPA stands for Notice of Proposed Amendment, what will this mean in plain English?
So lets take a case. We are going for a HEMS mission, picking up a patient in a non-hostale non-congested area and taking him to a hospital which is non hostale congested area. I undersstand that we have to be PC1 when going in for landing at the hospital in a congested area, but do we need to be PC1 when picking up the patient in the non-hostale non-congasted area? In otherword do we need to be PC1 during the hole mission or only when going into the hospital?
JAR-OPS3 says very clearly (to me...) that when going to hostile areas, congested areas we need to be PC1, but otherwise PC1 as far as possible !
In JAA Land are the operation regulated by the JAR-OPS3 or NPAs??
Thanks,
Thanks for the reply. I had a look at JAA website for NPA-38, but it wasn't possible to read it because it was closed by December 1 2005 (Comment Period). I understand that NPA stands for Notice of Proposed Amendment, what will this mean in plain English?
So lets take a case. We are going for a HEMS mission, picking up a patient in a non-hostale non-congested area and taking him to a hospital which is non hostale congested area. I undersstand that we have to be PC1 when going in for landing at the hospital in a congested area, but do we need to be PC1 when picking up the patient in the non-hostale non-congasted area? In otherword do we need to be PC1 during the hole mission or only when going into the hospital?
JAR-OPS3 says very clearly (to me...) that when going to hostile areas, congested areas we need to be PC1, but otherwise PC1 as far as possible !
In JAA Land are the operation regulated by the JAR-OPS3 or NPAs??
Thanks,
Notice of Proposed Amendment, what will this mean in plain English?
It means that should there be no adverse comment from any interested parties before the closing date for review, then the proposed changes will be introduced within a future amendment of JAR OPS (or whatever the NPA refers to). If there is comment and feedback, it is reviewed and possibly changes made, before implementation.
Until the NPA is implemented, you operate to the existing vesrion of OPS-3
If you are not required to operate PC1, you can operate PC2, simple!
It means that should there be no adverse comment from any interested parties before the closing date for review, then the proposed changes will be introduced within a future amendment of JAR OPS (or whatever the NPA refers to). If there is comment and feedback, it is reviewed and possibly changes made, before implementation.
Until the NPA is implemented, you operate to the existing vesrion of OPS-3
If you are not required to operate PC1, you can operate PC2, simple!
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EMS is still classed as Commercial Air Transport, so the aircraft has to operate to the appropriate performance standard for it's seating capacity. Generally this would require PC2. The other factor most relevant, is the operating environment: is it non-hostile non-congested, non-hostile congested, hostile non-congested or hostile congetsed? Generally a HEMS operation could expect to encounter at least two of those combinations during its operations, and that would also determine the performance standard expected.
I'm sure that I have seen photos of the London HEMS aircraft sitting at a roundabout in the middle of a road somewhere with wires and houses all around. I suppose the EC135 or AS365 is more powerful than I thought.
Commercial Air Transport should be for fare paying passengers - not patients whose mode of transport has been decided by a medical professionals (doctors or paramedics).
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Big Mike,
JAA Rules....
!!!! Anyway, we are a little bit confused as the CAA (will not mention what country..) has start to tell us that we have to be PC1 (CAT A) ALL THE TIME when flying a HEMS mission.
They are referring to JAR-OPS3 and NPA-38. Why they are referring to NPA-38 we have no clue as its only a Notice of Proposed Amendment, NOT the regulations. Also the JAR-OPS3 specify very clearly when you need to be PC1. For example when you are operating in an hostale congested area etc. and otherwise you just need to be PC1 as far as possible.
As far as possible the CAA is interprets as MUST ALWAYS !!!!????
HELP
JAA Rules....
!!!! Anyway, we are a little bit confused as the CAA (will not mention what country..) has start to tell us that we have to be PC1 (CAT A) ALL THE TIME when flying a HEMS mission.They are referring to JAR-OPS3 and NPA-38. Why they are referring to NPA-38 we have no clue as its only a Notice of Proposed Amendment, NOT the regulations. Also the JAR-OPS3 specify very clearly when you need to be PC1. For example when you are operating in an hostale congested area etc. and otherwise you just need to be PC1 as far as possible.
As far as possible the CAA is interprets as MUST ALWAYS !!!!????
HELP
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Vertolot
Here's a dilemma for you. PC1 (or CAT A for earlier types) will require a profile to be flown as per RFM. The profile will require the predication of LDPs etc on rad alt heights. Rad alts measure height directly under the aircraft .......... so unless you are flying into anything other than a football pitch you will never have enough accurate height data to fly the profiles. QED PC1 or Cat A will not be possible going into most 'primary sites' in 'congested' areas. We might as well go home then.
G
G
Geoffers,
Also recall the requirements for the landing/takeoff and reject area...flat, smooth, etc. I doubt there are many "scene" flight locations that meet that requirement. Throw in night time and I would assume lighting becomes a requirement as well. So much for EMS flying in that part of the world it sounds like.
Does the CAA operate like the FAA....the definition of congested area can be construed to mean a single pedestrian or single motorcar if it is under the flight path of the aircraft? The Case Law is the final determining authority and not merely the regulation as printed.
Also recall the requirements for the landing/takeoff and reject area...flat, smooth, etc. I doubt there are many "scene" flight locations that meet that requirement. Throw in night time and I would assume lighting becomes a requirement as well. So much for EMS flying in that part of the world it sounds like.
Does the CAA operate like the FAA....the definition of congested area can be construed to mean a single pedestrian or single motorcar if it is under the flight path of the aircraft? The Case Law is the final determining authority and not merely the regulation as printed.
There are no limits
It would be useful if we had a clear definition of 'congested area' rather than the completely nebulous one we have now! As you say, case law will prevail.
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HEMS or Air Ambulance
Referring to JAR ops A;ppendix 1 to 3.005(d) the authorities can determine what constitutes HEMS or Air Ambulance (CATO).
Assuming HEMS, this appendix only suggests that operations into a hospital located in a hostile environment require PC1 otherwise there is little guidance for helicopters under 5,700kg MTOW. This could be interpreted as suggesting that once you are not operating into a hostile hospital heliport, and not operating in PC3 over a hostile environment, you can conduct it to the satisfaction of the local authority to at least PC2 -which itself provides some alleviations for less than 9 pax and 2009 for exposure times.
To me this appendix was written with 'wriggle room' which the authorities can use as they see fit. It seems harsh for any authority to suggest that all aspects of a HEMS flight should be conducted to PC1, for all mission sites.
With the expansion of ETOPS for the airlines, it seems entirely reasonable to me that exposure times should be practically considered for rotary wing ops as they are under PC2 (at least until 2009). We should have a more practical approach to risk assessment which is where some authorities lack either understanding or courage.
Assuming HEMS, this appendix only suggests that operations into a hospital located in a hostile environment require PC1 otherwise there is little guidance for helicopters under 5,700kg MTOW. This could be interpreted as suggesting that once you are not operating into a hostile hospital heliport, and not operating in PC3 over a hostile environment, you can conduct it to the satisfaction of the local authority to at least PC2 -which itself provides some alleviations for less than 9 pax and 2009 for exposure times.
To me this appendix was written with 'wriggle room' which the authorities can use as they see fit. It seems harsh for any authority to suggest that all aspects of a HEMS flight should be conducted to PC1, for all mission sites.
With the expansion of ETOPS for the airlines, it seems entirely reasonable to me that exposure times should be practically considered for rotary wing ops as they are under PC2 (at least until 2009). We should have a more practical approach to risk assessment which is where some authorities lack either understanding or courage.
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crunchingnumbers,
Thanks for your reply, it was good! I think you hit spot on....
We should have a more practical approach to risk assessment which is where some authorities lack either understanding or courage.
I think in our case it may be the authorities that lack a really good and deep understanding in the subject. When they are not sure about the matter and dont have a thruly understanding of the Helicopters performance (maybe don't have the resources...) it's easier for them to say as a authority that you just always have to be PC1........
This however could have significant impact on some operators but also on the hole HEMS industry in that country.
Thanks,
Thanks for your reply, it was good! I think you hit spot on....
We should have a more practical approach to risk assessment which is where some authorities lack either understanding or courage.
I think in our case it may be the authorities that lack a really good and deep understanding in the subject. When they are not sure about the matter and dont have a thruly understanding of the Helicopters performance (maybe don't have the resources...) it's easier for them to say as a authority that you just always have to be PC1........
This however could have significant impact on some operators but also on the hole HEMS industry in that country.
Thanks,
Vertalot,
Firstly I would recommend reading the regulations for they contain the answer to the question that you have posed. In particular Appendix 1 to JAR-OPS 3.005(d) paragraph (c)(2) and ACJ to Appendix 1 to JAR-OPS 3.005(d) “The HEMS philosophy”.
In practical terms 212man is correct in his statement that you have to meet the standard performance requirement of JAR-OPS 3 - but, as modified by the Appendix referenced above.
The following is therefore permitted:
If operating over a non-hostile environment operations can be conducted in PC3;
at a hospital in a congested hostile environment (city centre); operations conducted in PC1 except when an approval has been given under the Public Interest Site alleviation - which permits exposure on take-off and landing (a modified PC2 with exposure);
at the accident site; no performance requirement but pilots are expected to minimise exposure;
at the operating base; normal performance requirements apply - i.e. PC1, 2 or 3 as required by JAR-OPS 3.470.
As stated in the ACJ referenced above; the operating base is where the crew and helicopter are stationed and from where most sorties are started and ended. Complications occur when the operating base is in a congested hostile environment and specifically at a hospital; if this is the case then the local NAA will have to rule on what the requirement is. Basically, this situation should not occur as the base should have been risk assessed and located with safety in mind.
However, all are aware that as the HEMS helicopter becomes the trauma team mode of transport (see London HEMS), it becomes economical to base the helicopter at the hospital so that the trauma team can be gainfully employed when HEMS is not in action.
Jim
Firstly I would recommend reading the regulations for they contain the answer to the question that you have posed. In particular Appendix 1 to JAR-OPS 3.005(d) paragraph (c)(2) and ACJ to Appendix 1 to JAR-OPS 3.005(d) “The HEMS philosophy”.
In practical terms 212man is correct in his statement that you have to meet the standard performance requirement of JAR-OPS 3 - but, as modified by the Appendix referenced above.
The following is therefore permitted:
If operating over a non-hostile environment operations can be conducted in PC3;
at a hospital in a congested hostile environment (city centre); operations conducted in PC1 except when an approval has been given under the Public Interest Site alleviation - which permits exposure on take-off and landing (a modified PC2 with exposure);
at the accident site; no performance requirement but pilots are expected to minimise exposure;
at the operating base; normal performance requirements apply - i.e. PC1, 2 or 3 as required by JAR-OPS 3.470.
As stated in the ACJ referenced above; the operating base is where the crew and helicopter are stationed and from where most sorties are started and ended. Complications occur when the operating base is in a congested hostile environment and specifically at a hospital; if this is the case then the local NAA will have to rule on what the requirement is. Basically, this situation should not occur as the base should have been risk assessed and located with safety in mind.
However, all are aware that as the HEMS helicopter becomes the trauma team mode of transport (see London HEMS), it becomes economical to base the helicopter at the hospital so that the trauma team can be gainfully employed when HEMS is not in action.
Jim
