UK HEMS and NVGs
Very little stated by Ray in his presentation is new - it is a rehash of many 'CAT A'/'PC1' presentations in the past.
What appears to be the cogent point is Ray's statement that CAT A profiles cannot be flown with NVG unless they have been evaluated under those circumstances. Unless this is subject to a policy change, it will add a real expense to manufacturer's flight testing regimes which might have to include flight in 'rain', 'snow', 'low visibility' etc. Perhaps a more pragmatic view needs to be applied i.e. the presence of lighting.
The first thing without dispute is that operating to a PC1 heliport at night (with all of the associated lighting from Annex 14) with NVG must be acceptable under the proviso that operations with NVIS is an extension to VFR Operations under all circumstances - i.e. the pilot can come under the goggles at any time and meet the visual requirements for the manoeuvre.
The second thing without dispute is that PC1 can only be conducted to a landing site which meets all the conditions for PC1 operations - i.e. the site has been surveyed; the mass is sufficient to satisfy the RTODR/TODRH; and, obstacle clearances will be met.
Ray is a little behind with the requirements for a HEMS Operating Site (the ad hoc site or scene); it no longer says 'PC1 as far as possible' (which is oxymoronic) but PC2 (with the associated approvals for exposure).
Night Flight with NVG is one of the least problematic issue EASA has to address. More important perhaps is the lack of any airworthiness requirements for stability and control under circumstances where flight is being conducted under VFR and the visual cue environment is not sufficient to permit control without reference to instruments, or obstacle to be seen such that they can be avoided.
Jim
What appears to be the cogent point is Ray's statement that CAT A profiles cannot be flown with NVG unless they have been evaluated under those circumstances. Unless this is subject to a policy change, it will add a real expense to manufacturer's flight testing regimes which might have to include flight in 'rain', 'snow', 'low visibility' etc. Perhaps a more pragmatic view needs to be applied i.e. the presence of lighting.
The first thing without dispute is that operating to a PC1 heliport at night (with all of the associated lighting from Annex 14) with NVG must be acceptable under the proviso that operations with NVIS is an extension to VFR Operations under all circumstances - i.e. the pilot can come under the goggles at any time and meet the visual requirements for the manoeuvre.
The second thing without dispute is that PC1 can only be conducted to a landing site which meets all the conditions for PC1 operations - i.e. the site has been surveyed; the mass is sufficient to satisfy the RTODR/TODRH; and, obstacle clearances will be met.
Ray is a little behind with the requirements for a HEMS Operating Site (the ad hoc site or scene); it no longer says 'PC1 as far as possible' (which is oxymoronic) but PC2 (with the associated approvals for exposure).
Night Flight with NVG is one of the least problematic issue EASA has to address. More important perhaps is the lack of any airworthiness requirements for stability and control under circumstances where flight is being conducted under VFR and the visual cue environment is not sufficient to permit control without reference to instruments, or obstacle to be seen such that they can be avoided.
Jim
Jim,
If one adds NVG's....using the existing weather minima....and visibility minima....thus providing the ability to "see" those external cues by which to control the aircraft.....including landing and take off at ALL sites approved by the NAA....where is the problem in getting Approval for that?
You pose a straw man argument when you attempt to shift this discussion to Stability and Visual Flight without sufficient Visual Cues thus requiring the use of instruments to control the aircraft.
The discussion extant is about the use of NVG's for EMS Operations.
The discussion about flying VFR in IMC Conditions is an altogether different argument.
The only correlation I see is that by the NAA's approving the use of NVG's for all phases of flight especially Landing.....those cues shall (imperative tense used on purpose) be improved, enhanced, and far more plentiful thus negating the need for what we all know would prove to be a decades long pursuit of new certifications of new aircraft and Modification of existing aircraft.
NVG's mount to a helmet and only require a compatible lighting system which is technology already in common use.
Surely, this is not that complicated a thing for reasonable, logical, and open minded people who seek to make easy, quick, and effective enhancements to night flying safety and expand the operational capability of a valuable asset such as EMS Helicopters.
In the UK or some parts of Europe where a speedy retrieval of injured and gravely ill patients is not a concern....perhaps there is no need for the capability.
In the United States....we see it differently.....and have fought this battle in the past and now the FAA is finally coming to the table on this. They came kicking and screaming....but they came.
Sounds to me like you folks are entering that stage of business where just like GPS....you will have to shed the "old way" and begin to embrace new technology.
Perhaps the NAA's should take a position more along the lines of "How can we make this happen?" Rather than the current attitude of throwing up every obstacle possible.
My impression of the EASA system is it seeks Utopia where every risk is eliminated.....no matter the cost. That is never going to work as Aviation is all about Risk....managed, controlled, acceptance of reasonable risk.
We will never see the end of aircraft crashing.....we just have to find a way to improve the chances of that not happening as best we can.
Upon consideration....perhaps the EASA way is best.....if no one flies....no one dies.....except for the Casualties on the side of the highway waiting for ground transport.
If one adds NVG's....using the existing weather minima....and visibility minima....thus providing the ability to "see" those external cues by which to control the aircraft.....including landing and take off at ALL sites approved by the NAA....where is the problem in getting Approval for that?
You pose a straw man argument when you attempt to shift this discussion to Stability and Visual Flight without sufficient Visual Cues thus requiring the use of instruments to control the aircraft.
The discussion extant is about the use of NVG's for EMS Operations.
The discussion about flying VFR in IMC Conditions is an altogether different argument.
The only correlation I see is that by the NAA's approving the use of NVG's for all phases of flight especially Landing.....those cues shall (imperative tense used on purpose) be improved, enhanced, and far more plentiful thus negating the need for what we all know would prove to be a decades long pursuit of new certifications of new aircraft and Modification of existing aircraft.
NVG's mount to a helmet and only require a compatible lighting system which is technology already in common use.
Surely, this is not that complicated a thing for reasonable, logical, and open minded people who seek to make easy, quick, and effective enhancements to night flying safety and expand the operational capability of a valuable asset such as EMS Helicopters.
In the UK or some parts of Europe where a speedy retrieval of injured and gravely ill patients is not a concern....perhaps there is no need for the capability.
In the United States....we see it differently.....and have fought this battle in the past and now the FAA is finally coming to the table on this. They came kicking and screaming....but they came.
Sounds to me like you folks are entering that stage of business where just like GPS....you will have to shed the "old way" and begin to embrace new technology.
Perhaps the NAA's should take a position more along the lines of "How can we make this happen?" Rather than the current attitude of throwing up every obstacle possible.
My impression of the EASA system is it seeks Utopia where every risk is eliminated.....no matter the cost. That is never going to work as Aviation is all about Risk....managed, controlled, acceptance of reasonable risk.
We will never see the end of aircraft crashing.....we just have to find a way to improve the chances of that not happening as best we can.
Upon consideration....perhaps the EASA way is best.....if no one flies....no one dies.....except for the Casualties on the side of the highway waiting for ground transport.
Thread Starter
So, given the content of TC's last post, is NVG flight for HEMS; a) going ahead, b) not going ahead, or c) they are still trying to decide, because I can't figure it out from reading that. 
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Mighty, Night HEMS using NVGs was approved last summer and I have been using them on HEMS missions since then. Bit pointless in the summer but definitely proving useful now.
Can you use them in all phases of flight in the UK?
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Pretty much from take off to landing. Cannot say too much as I am sure one of my many bosses will shoot me for divulging commercially sensitive stuff. Having flown on NVG in the military and some years later now in HEMS, I feel a lot safer flying the profiles we do. Goes without saying both very different types of flying but deinately not taking anything for granted.
Thread Starter
Night HEMS using NVGs was approved last summer and I have been using them on HEMS missions since then.
Heard from another AA pilot last night that they have to revert to white
light at 150' to get around the EASA/PC1 problem.
We are flying in all kinds of environments (low cultural lighting areas, urban areas et al) and we can always use goggles (with white light) if we so choose - so you you get the best of both worlds being the advantages of NVG coupled with good peripheral cues coming from the white light (provided your goggle relief is ok.) No problems.
Is this stuff being made overly difficult ? Just a simple guy I am!
Cheers
Sounds to me like the PC1 "Problem" is a stupid assed Rule that has no basis in reality.....just another bureaucratic edict handed down and swallowed whole by the Operators.
I suppose there is an appeal process or some way to challenge it.....isn't there?
Can someone calculate the probability of both an Engine Failure and a Goggle Failure at a "Critical Point" of a Landing?
It would be the same for a Takeoff I would assume.
I do believe we are talking about a very damn small chance of that event ever happening at all....much less it resulting in the loss of an aircraft....even if that would happen as a result of said goggle failure.
Turning on a White Light, a Landing Light or Night Sun, does not harm the usefulness of NVG's.....or operating around ground based white light. Modern NVG's work fine with minimal "Wash Out".
I suppose there is an appeal process or some way to challenge it.....isn't there?
Can someone calculate the probability of both an Engine Failure and a Goggle Failure at a "Critical Point" of a Landing?
It would be the same for a Takeoff I would assume.
I do believe we are talking about a very damn small chance of that event ever happening at all....much less it resulting in the loss of an aircraft....even if that would happen as a result of said goggle failure.
Turning on a White Light, a Landing Light or Night Sun, does not harm the usefulness of NVG's.....or operating around ground based white light. Modern NVG's work fine with minimal "Wash Out".
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As 135driver said PC1 is not required at ad-hoc HEMS operating sites, so whilst CAT A profiles are flown where possible, the goggles can be worn to the ground.
Where PC1 is required when flying into a hospital pad (lit), or HEMS operating base (lit), the approach can be safely made off goggles.
Where PC1 is required when flying into a hospital pad (lit), or HEMS operating base (lit), the approach can be safely made off goggles.
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PC1 operations are not possible to an ad-hoc site due to the unsurveyed nature (possible hazards, uncertain surface, no lights, estimated size etc) yet EASA NAA's require PC1 for HEMS. This would prohibit practically all HEMS site landings, so PC2 is acceptable at HEMS operating sites.
EASA NAA's require PC1 for HEMS. This would prohibit practically all HEMS site landings, so PC2 is acceptable at HEMS operating sites.
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From EASA Part-SPA:
In simple terms there are three areas in HEMS operations where risk, beyond that allowed in Part-CAT and Part-ORO, are identified and related risks accepted:
(i) in the en-route phase, where alleviation is given from height and visibility rules;
(ii) at the accident site, where alleviation is given from the performance and size requirement; and
(iii) at an elevated hospital site in a congested hostile environment, where alleviation is given from the deck edge strike - providing elements of the CAT.POL.H.305 are satisfied.
In mitigation against these additional and considered risks, experience levels are set, specialist training is required (such as instrument training to compensate for the increased risk of inadvertent entry into cloud) and operation with two crew (two pilots, or one pilot and a HEMS technical crew member) is mandated. (HEMS crews and medical passengers are also expected to operate in accordance with good crew resource management (CRM) principles.)
In simple terms there are three areas in HEMS operations where risk, beyond that allowed in Part-CAT and Part-ORO, are identified and related risks accepted:
(i) in the en-route phase, where alleviation is given from height and visibility rules;
(ii) at the accident site, where alleviation is given from the performance and size requirement; and
(iii) at an elevated hospital site in a congested hostile environment, where alleviation is given from the deck edge strike - providing elements of the CAT.POL.H.305 are satisfied.
In mitigation against these additional and considered risks, experience levels are set, specialist training is required (such as instrument training to compensate for the increased risk of inadvertent entry into cloud) and operation with two crew (two pilots, or one pilot and a HEMS technical crew member) is mandated. (HEMS crews and medical passengers are also expected to operate in accordance with good crew resource management (CRM) principles.)
There is no specific PC1 rule with respect to NVG, or vice versa; what is being discussed is an interpretation of operating practices by EASA 'Airworthiness Personnel'. It is not really clear why they have been asked for their opinion - particularly when the EASA opinion is no better than any other's (in the eye of the law).
Aucky has spelt it out exactly; the circumstances where PC1 is mandated is not in dispute, only the practice of using unlit heliports where PC1 is required.
Jim
Aucky has spelt it out exactly; the circumstances where PC1 is mandated is not in dispute, only the practice of using unlit heliports where PC1 is required.
Jim
Hi JimL
Please excuse a deliberately contentious statement/question, it's in the hope of promoting discussion as much as anything.
The only times that European HEMS operations are required to perform to PC1 is when operating to a hospital site in a congested hostile environment (subject to aircraft certification) or at an elevated heliport.
Would you agree?
Cheers
TeeS
Please excuse a deliberately contentious statement/question, it's in the hope of promoting discussion as much as anything.
The only times that European HEMS operations are required to perform to PC1 is when operating to a hospital site in a congested hostile environment (subject to aircraft certification) or at an elevated heliport.
Would you agree?
Cheers
TeeS
Hi Tees,
The regulations are in transition - from JAR-OPS to EASA OPS. During the final throes of the JAA a number of policy decisions were made that have found their way into the new regulation. For that reason (and for simplicity) it is probably better to look at what will be rather than what was.
In general, the application of the performance code for HEMS now mirrors that for CAT with two exceptions:
Operations to an elevated heliport (in any class) are permitted if there is no third party exposure. For example, operations to Battersea.
Under the circumstances being considered in this thread, PC1 would only be required when operating to a heliport in a congested hostile environment. Under all circumstances, a PC1 heliport would have to be fitted with such lights and visual aids that are prescribed by the State (for the moment Europe does not exercise competence on this matter).
The notion of operating PC1 (with a CAT A procedure) to an unimproved and unsurveyed site at night is risible (protection is imaginary). Flying a CAT A procedure at an unimproved site affords little protection; better that a risk-assessed procedure (for that site) which minimises exposure, is used.
Jim
The regulations are in transition - from JAR-OPS to EASA OPS. During the final throes of the JAA a number of policy decisions were made that have found their way into the new regulation. For that reason (and for simplicity) it is probably better to look at what will be rather than what was.
In general, the application of the performance code for HEMS now mirrors that for CAT with two exceptions:
1. For a HEMS Operating Site (the scene) in a congested hostile environment (built-up area), PC2, with exposure, is permitted (if approval has been sought and given). At all other HEMS Operating Sites, there are no restrictions on performance.
2. Operations at a public interest site (a hospital at a congested hostile environment) are permitted with the mitigation specified.
In concert with all CAT (Part CAT), operations with exposure will have to meet the appropriate requirements including engine monitoring (for HEMS the approval process is simplified).2. Operations at a public interest site (a hospital at a congested hostile environment) are permitted with the mitigation specified.
Operations to an elevated heliport (in any class) are permitted if there is no third party exposure. For example, operations to Battersea.
Under the circumstances being considered in this thread, PC1 would only be required when operating to a heliport in a congested hostile environment. Under all circumstances, a PC1 heliport would have to be fitted with such lights and visual aids that are prescribed by the State (for the moment Europe does not exercise competence on this matter).
The notion of operating PC1 (with a CAT A procedure) to an unimproved and unsurveyed site at night is risible (protection is imaginary). Flying a CAT A procedure at an unimproved site affords little protection; better that a risk-assessed procedure (for that site) which minimises exposure, is used.
Jim