EASA Proposals - Take Action Now!!!
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perspective
Joel (and others),
I fully support your position- and the HCGB's stance.
It's about risk, and in particular risk management.
Like you I go across to Europe a lot, and I've been over the Alps 7 times this year, and to Denmark 5 times in the last 18 months.
These flights tend to start from various different places in the UK, including Belfast, and it would be quicker to head directly across the North Sea from (say) Norwich to (say) Holland on some of these trips.
But I chose to take the shortest route (basically Lydd to Cap Griz Nez). The risk exists, but I choose to minimise it.
Equally, over the Alps I select the lowest passes practical (still between 8,000 and 10,000 ft by the way), and try to fly where the ski slopes and villages are located just in case something goes wrong.
And I've bothered to go out and buy a new McMurdo PLB, and I wear a life jacket. In all weathers other than exceptional heat, I wear as many clothes as practical. Ok this isn't as good as an immersion suit, but if you do ditch, the more layers of clothing you have the better chance of survival you have.
I always take some water and a little food just in case we are stranded somewhere remote overnight.
In my view, the focus for flight safety in this ELB, mandatory floats, extra instrumentation and more engines has gone way off the mark.
The focus should be on making helicopter flying more accessible to those who want to do it, and thereby improving their skill levels so that they can cope with their in-flight conditions.
I don't have the stats to hand, but I'll bet you a pound to a penny that deaths due to weather conditions, including all "controlled flight into terrain" are way WAY higher than the number of deaths from exposure - be it on the side of a mountain or bobbing around in the English Channel - after a survivable forced landing.
To echo other's comments, ultimately it is a personal choice as to where your risk acceptance level lies. Private pilots do this for fun, it is not their job. If the conditions are beyond their capability, they can choose not to go, or land if the conditions deteriorate.
Owners see a helicopter as simply a mode of transport that enriches the quality of their lives, and they are quite right to want to lobby against badly thought out, and unworkeable, plans that will not make a jot of difference to the accident statistics.
Big Ls
I fully support your position- and the HCGB's stance.
It's about risk, and in particular risk management.
Like you I go across to Europe a lot, and I've been over the Alps 7 times this year, and to Denmark 5 times in the last 18 months.
These flights tend to start from various different places in the UK, including Belfast, and it would be quicker to head directly across the North Sea from (say) Norwich to (say) Holland on some of these trips.
But I chose to take the shortest route (basically Lydd to Cap Griz Nez). The risk exists, but I choose to minimise it.
Equally, over the Alps I select the lowest passes practical (still between 8,000 and 10,000 ft by the way), and try to fly where the ski slopes and villages are located just in case something goes wrong.
And I've bothered to go out and buy a new McMurdo PLB, and I wear a life jacket. In all weathers other than exceptional heat, I wear as many clothes as practical. Ok this isn't as good as an immersion suit, but if you do ditch, the more layers of clothing you have the better chance of survival you have.
I always take some water and a little food just in case we are stranded somewhere remote overnight.
In my view, the focus for flight safety in this ELB, mandatory floats, extra instrumentation and more engines has gone way off the mark.
The focus should be on making helicopter flying more accessible to those who want to do it, and thereby improving their skill levels so that they can cope with their in-flight conditions.
I don't have the stats to hand, but I'll bet you a pound to a penny that deaths due to weather conditions, including all "controlled flight into terrain" are way WAY higher than the number of deaths from exposure - be it on the side of a mountain or bobbing around in the English Channel - after a survivable forced landing.
To echo other's comments, ultimately it is a personal choice as to where your risk acceptance level lies. Private pilots do this for fun, it is not their job. If the conditions are beyond their capability, they can choose not to go, or land if the conditions deteriorate.
Owners see a helicopter as simply a mode of transport that enriches the quality of their lives, and they are quite right to want to lobby against badly thought out, and unworkeable, plans that will not make a jot of difference to the accident statistics.
Big Ls
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Dear Horror Box,
After I asked if anyone had stats regarding the safety of private helicopter flying over the English Channel and the Irish Sea you jumped straight in to say that an accident is bound to happen and yes if you wait long enough the chances are that everything that is possible will happen. However if the probability is low and people are willing to make a risk judgement then how dare you take away their freedom to do so.
Some of the measures being proposed ie emergency flotation gear are complete overkill for private owners. They will not aid safety and may in some pilots engender the belief that hey they will be ok because they have floats. It is just a very expensive modification that will be of benefit to next to no one. So it comes back to are you willing to risk being that one. If you are not then you probably already have a helicopter with floats or you won't fly over water anyway.
The long and short of it is EASA should keep it's nose out of it and allow pilots that are not flying for hire or reward to make their own decisions regarding the safety measures they deem appropriate.
After I asked if anyone had stats regarding the safety of private helicopter flying over the English Channel and the Irish Sea you jumped straight in to say that an accident is bound to happen and yes if you wait long enough the chances are that everything that is possible will happen. However if the probability is low and people are willing to make a risk judgement then how dare you take away their freedom to do so.
Some of the measures being proposed ie emergency flotation gear are complete overkill for private owners. They will not aid safety and may in some pilots engender the belief that hey they will be ok because they have floats. It is just a very expensive modification that will be of benefit to next to no one. So it comes back to are you willing to risk being that one. If you are not then you probably already have a helicopter with floats or you won't fly over water anyway.
The long and short of it is EASA should keep it's nose out of it and allow pilots that are not flying for hire or reward to make their own decisions regarding the safety measures they deem appropriate.
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I am a baby pilot, and this is my opinion. I will shortly be undertaking CPL flight training, and much of my time recently has been engaged in finding ways to reduce the cost. I am entirely self-funded, and have been from PPL onwards - no bursaries, no military training (not from lack of trying), etc. I am fortunate that I have a first career which pays enough to do this, and a partner who doesn't mind making sacrifices, but that doesn't mean I'm swimming in cash, or that it isn't a struggle. I agree with the sentiment behind these proposed regulations, but the implementation seems wrong. Ultimately, people who don't care about safety will ignore the regs anyway, and the law-abiding majority will take the hit. I would like to think that anyone flying any distance over water would carry an ELB and wear life-jackets, and seriously consider fitting floats to a machine that regularly flies over water. Certainly, for CAT, where there is a provable link between an additional safety measure and increased survival, mandate it. I plan to do my CPL in an R22, because that's what I'm familiar with, and that's what I can afford. If I need to do my night rating in an aircraft with a pitot heater and extra AH, plus a bunch of extra mods, who do you think will be paying for that? The school? Of course not, it'll just make my per-hour costs that much higher. It's likely that fewer people will be able to afford training, and the average age of new pilots will increase. I'm guessing overseas schools will benefit, too. If these proposals were accompanied by plans to ease the extra costs, I suspect people would be far more supportive. More safety is good, but it has to be an informed trade-off. Nobody forces me to train in a R22, I weigh up the risks and benefits, then vote with my feet. Just like those who choose to ride motorbikes without helmets (in theory), I know the risks and accept them. Mandating common sense just removes the ability for most people to make sensible decisions.
Avoid imitations
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Yes - but an ELT will make it a hell of a lot quicker and easier.
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I agree with Pandalet. These proposals are overkill for night flight training.
We've already seen the loss of the cheaper 'single engine IR route' in the UK, the requirement for a twin type rating to be held to sit an IR test (£10,000 down the toilet for most people), the daft "3 year ATPL exams expire" rule. All these regulations are just not suitable for helicopter training because of the horrendous costs involved.
It's all very well to sit there and say "these rules will make aviation safer", but I bet if you're the other side of the fence, struggling to afford a CPL, or an IR, or a night rating, you wouldn't be saying that.
Increasingly training to be a professional helicopter pilot in the UK is the reserve of the well-off (or rich parents), or ex-mil. That's not right.
The problem is the people that dream up these rules are are either admin bods/politicians/EU bods who just look at the fixed wing requirements and apply them to helicopters, or they are people in the "old boys club" of aviation who never had to spend a penny on their training.
If we are not careful, in five years time there won't be a flight training industry in the UK. (Then again, that's probably what the CAA secretly wants)
We've already seen the loss of the cheaper 'single engine IR route' in the UK, the requirement for a twin type rating to be held to sit an IR test (£10,000 down the toilet for most people), the daft "3 year ATPL exams expire" rule. All these regulations are just not suitable for helicopter training because of the horrendous costs involved.
It's all very well to sit there and say "these rules will make aviation safer", but I bet if you're the other side of the fence, struggling to afford a CPL, or an IR, or a night rating, you wouldn't be saying that.
Increasingly training to be a professional helicopter pilot in the UK is the reserve of the well-off (or rich parents), or ex-mil. That's not right.
The problem is the people that dream up these rules are are either admin bods/politicians/EU bods who just look at the fixed wing requirements and apply them to helicopters, or they are people in the "old boys club" of aviation who never had to spend a penny on their training.
If we are not careful, in five years time there won't be a flight training industry in the UK. (Then again, that's probably what the CAA secretly wants)
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to the Controller
The irony about the floats-across-the-water proposal is that it only applies to helicopters, and not to Cessna 152s, C172s and all other fixed wing aircraft.
I'm reasonably confident that to glide to the other side of the Channel you'd have to go very, very high in a Cessna, and I doubt if anyone would do this anyway.
And there's no chance if you are going from the UK to the Channel Islands, the Isle of Man, Ireland.
It goes to prove two things:
(i) the proposals are not applying fixed wing rules to rotary
(ii) the proposals are completely inconsistent regarding flight safety
Whether they are plain daft or not is a matter of opinion, of course.
As for CAA not wanting flight training, nothing could be further from the truth.
I work with a new flight training academy that teaches PPL(H), CPL(H), distance learning CPL(H) ground school courses, IR, IRI and MCC courses.
Therefore we have quite a lot of contact with both the CAA and EASA and they are very keen to see the industry of flight training grow here in the UK.
It's up to us - not the CAA - to try and attract customers to the UK from all over the world, and to ensure that we offer quality, service and world-class standards to the next generation of PPLs and CPLs.
Big Ls
I'm reasonably confident that to glide to the other side of the Channel you'd have to go very, very high in a Cessna, and I doubt if anyone would do this anyway.
And there's no chance if you are going from the UK to the Channel Islands, the Isle of Man, Ireland.
It goes to prove two things:
(i) the proposals are not applying fixed wing rules to rotary
(ii) the proposals are completely inconsistent regarding flight safety
Whether they are plain daft or not is a matter of opinion, of course.
As for CAA not wanting flight training, nothing could be further from the truth.
I work with a new flight training academy that teaches PPL(H), CPL(H), distance learning CPL(H) ground school courses, IR, IRI and MCC courses.
Therefore we have quite a lot of contact with both the CAA and EASA and they are very keen to see the industry of flight training grow here in the UK.
It's up to us - not the CAA - to try and attract customers to the UK from all over the world, and to ensure that we offer quality, service and world-class standards to the next generation of PPLs and CPLs.
Big Ls
I also support the HCGB stance.....If you fly an R22 or similar ,you cannot fit floats and would have to detour just to fly from Bristol to Newport ,whilst the Isle of Wight would be out of bounds.Also where do I put the liferaft?
The point..... well made by others.... is for pilots to evaluate the risk...wear lifejackets and take a PLB ( a lot more useful than telling the rescue services where your sunken helicopter is !).
Almost nothing in the proposals makes practical sense ,none of it is borne out by the historical accident record and it is just going to cost private pilots a whole shed load of money ,and in some cases ground the aircraft because they cannot economically comply.
If you read the HCGB respones you will see a very well argued case ,with practical alternatives suggested and as many people as possible need to write with similar views.
Incidentally I found the circuituos comments route quite difficult to navigate and instead sent separate e mails ,quoting the relevant NPA numbers ,to the npa easa address.
It obviously worked as I got an acknowlegement.
The point..... well made by others.... is for pilots to evaluate the risk...wear lifejackets and take a PLB ( a lot more useful than telling the rescue services where your sunken helicopter is !).
Almost nothing in the proposals makes practical sense ,none of it is borne out by the historical accident record and it is just going to cost private pilots a whole shed load of money ,and in some cases ground the aircraft because they cannot economically comply.
If you read the HCGB respones you will see a very well argued case ,with practical alternatives suggested and as many people as possible need to write with similar views.
Incidentally I found the circuituos comments route quite difficult to navigate and instead sent separate e mails ,quoting the relevant NPA numbers ,to the npa easa address.
It obviously worked as I got an acknowlegement.
Hovering AND talking
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both the CAA and EASA and they are very keen to see the industry of flight training grow here in the UK.
Cheers
Whirls
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very keen to see the industry of flight training grow here in the UK
You'd have to be an idiot to go all the way from zero to CPL/IR in the UK (£120,000+ ?)
I think ATPL UK distance learning is a growing market though.
These proposals largely affect private flyers - and methinks this Forum is not the best place to look for sympathy.
That argument doesn't appear to have been applied to the private maritime community who still happily sail or power into the seas with no licensing necessary. I think you'll find that they've cost SAR a lot more than private aviation. However, surely you want SAR to be busy - otherwise your state-funded bean counters will be closing you down ?
Not really. A fixed ELT will be utterly useless once the helicopter has either (a) sunk or (b) turned turtle on its floats in anything other than a mild swell (unless you mandate ELT antennae on top and bottom of the machine.) And, as made clear by HCGB, a good smooth auto onto water will not automatically light-up a fixed ELT.
A Personal locator with a crew member wearing a lifejacket would seem to be a more reliable method of actually saving lives, rather than finding an empty helicopter.
However, my new McMurdo has some interesting "facts" in the small print. The new 406 technology can mean a 45 minute delay in getting the signal through (whereas the old VHF was instant), the unit doesn't float (!), and the antenna needs to be clear of water. Brilliant.
Should we wait until a few people die in the sea first and a few very expensive SAR missions are deployed before we decide floats are a good idea?
Yes - but an ELT will make it a hell of a lot quicker and easier.
A Personal locator with a crew member wearing a lifejacket would seem to be a more reliable method of actually saving lives, rather than finding an empty helicopter.
However, my new McMurdo has some interesting "facts" in the small print. The new 406 technology can mean a 45 minute delay in getting the signal through (whereas the old VHF was instant), the unit doesn't float (!), and the antenna needs to be clear of water. Brilliant.
The point..... well made by others.... is for pilots to evaluate the risk...wear lifejackets and take a PLB ( a lot more useful than telling the rescue services where your sunken helicopter is !).
The proposed changes are half baked, if floats are deemed necessary, surely life raft and/or immersion suites are critical items as well? Or do we expect a perfect emergency landing in seas calm enough for passengers to remain tucked inside the cockpit until rescue?
What is missing is a range of comfortable(!) immersion suites that don't necessarily need to combat north sea temps in winter for an hour where 30 minutes survival from Feb to September would cover most GA movements.
4 x immersion suites +4 PLB are more versatile cheaper and better than floats?
Last time I enquired the cost of a daily use lightweight immersion suite designed for helicopter crew with a zippered neck was around £1000.
Mickjoebill
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Are these NEW?
Are you guys telling me you haven't had the requirement for alt static, movable light and pitot heat previously in the UK? When I took my PPL(H) back in 1993-96 it was all required.
Mickjoeb,
SEMS will sell you a very decent Aerosafe Hyperdry suit for less than £300 and you can rent them for about £40 a day.
Even a Civilian TOFS (Typhoon) suit is only £389 net.
SEMS will sell you a very decent Aerosafe Hyperdry suit for less than £300 and you can rent them for about £40 a day.
Even a Civilian TOFS (Typhoon) suit is only £389 net.
Hovering AND talking
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you can rent them for about £40 a day.
Risk management? I'd risk the extra £260 for a nice new one
Cheers
Whirls
The ones we've always received for rental have been new - in any case I can't imagine that SEMS would rent out anything that might even be slightly scuffed. And how do you know that one you bought, say, a year ago is still waterproof ? Foxes, apparently, get some sort of sexual high from chewing rubber & neoprene. They sniff it out. Random thought, maybe ! But that's why we've had to replace all outdoor rubber-sheathed cabling with PVC.
They also get a kick from leather! Must tell you about my neighbour whose home was invaded via catflap whilst on holiday. Shoes, handbags & leather sofa all attacked. And some "interesting" stains.
Enough.
They also get a kick from leather! Must tell you about my neighbour whose home was invaded via catflap whilst on holiday. Shoes, handbags & leather sofa all attacked. And some "interesting" stains.
Enough.
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We can add as many things as we can think of for every possible scenario and claim a increase in safety because we now have all the floats, elt's standby systems, liferafts etc. I am just wandering whether we are not getting to the point where all these safety equipments for a possible but rare incident are not ensuring the incident will occur sooner than later. Why? These things does not weigh nothing. Everything added to a helicopter decreases it's safety margin as it requires more and more power every flight causing more and more wear and tear at a much faster rate than anticipated. I am not just referring to engines here but blades having to cone twice as much, pitch link bearings being under permanent max loading, swashplates buckling under the aerodynamic forces as the scissors slowly starts wearing away, gearboxes and their mounts having to absorb max torque leading to TGB and blades etc, etc, etc. How many helicopters(twin and/or single) can take all this equipment and still allow the pilot sufficient payload to ensure a power margin and sufficient fuel onboard?
Once we fitted all the new safety equipment, how long before the next additions are added as we think up more scenarios? Soon the closest we will get to flying singles AND light twins will be a ground run on the helipad as they just will not take off.
Once we fitted all the new safety equipment, how long before the next additions are added as we think up more scenarios? Soon the closest we will get to flying singles AND light twins will be a ground run on the helipad as they just will not take off.
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Victor papa,
Do we understand you to say that it is unsafe flying these machines within their design envelope?
On what basis do these aircraft obtain their type certificate?
Do we understand you to say that it is unsafe flying these machines within their design envelope?
On what basis do these aircraft obtain their type certificate?
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Mars, all helo's are safe within their designed specs. Where all of these safety equipments part of their designed/Cat A specs at the time of certification? That is my question. Everytime we add something afterwards in the interest of safety are we not getting to the point where we are comprimising safety with all the extra safety equipment demanded and putting the original design under pressure? Take a 105. Certified plenty years ago, will it pass Cat A today with all these extra safety equipment regarding MAUW?
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Victor papa,
You appear to be calling into question the basis of Supplemental Type-Certificates; you need to go back to Part 21 and re-read Subpart E.
We all know EC's stance on STCs but trying to stop the practice is a Canute like gesture (he tried to command the tides). Perhaps more effective control is necessary but that is a matter for standards and not the basic code - and has nothing to do with operational regulations.
Any STC that effects airworthiness of the aircraft will be assessed against its certification basis. The function of that assessment will be to address those issues raised in your first post.
The BO105 was never certificated for CAT A; it gets its operational approval by virtue of compliance with alternative criteria. All aircraft must be operated within their MAUM - not to do so would invalidate the C of A.
By the way, Perfrej is absolutely correct; there is nothing new in the proposed requirement for landing lights for UK registered aircraft - they are already required under Schedule 4 Scale G(5) and (6) of the ANO.
The reference by the HCGB to ICAO SARPs is not correct; the Standards for GA are addressed in Annex 6 Part III Section III - they are not the same as those for CAT. That EASA has chosen to apply a CAT Standard (for floats) to GA is a matter which can/should be commented.
Making outrageous public statements serves only to discredit the forum.
You appear to be calling into question the basis of Supplemental Type-Certificates; you need to go back to Part 21 and re-read Subpart E.
We all know EC's stance on STCs but trying to stop the practice is a Canute like gesture (he tried to command the tides). Perhaps more effective control is necessary but that is a matter for standards and not the basic code - and has nothing to do with operational regulations.
Any STC that effects airworthiness of the aircraft will be assessed against its certification basis. The function of that assessment will be to address those issues raised in your first post.
The BO105 was never certificated for CAT A; it gets its operational approval by virtue of compliance with alternative criteria. All aircraft must be operated within their MAUM - not to do so would invalidate the C of A.
By the way, Perfrej is absolutely correct; there is nothing new in the proposed requirement for landing lights for UK registered aircraft - they are already required under Schedule 4 Scale G(5) and (6) of the ANO.
The reference by the HCGB to ICAO SARPs is not correct; the Standards for GA are addressed in Annex 6 Part III Section III - they are not the same as those for CAT. That EASA has chosen to apply a CAT Standard (for floats) to GA is a matter which can/should be commented.
Making outrageous public statements serves only to discredit the forum.