AW139 G-LBAL helicopter crash in Gillingham, Norfolk
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That SAR Chap
Totally agree with SOP's, training, currency, etc, and I would add Experience, as someone has already posted that the Capt had probably never carried out a departure like this before. Whilst a north sea pilot, shuttling, may do hundreds of towering take-offs a month.
But there is certainly a case for establishing whether this can be carried out with compliance with the regulations and whether in this specific case in can be. And then once we know if it is legal or not, we can discus the how.
I take your point it can be carried out safety in the all engines operating case, but there is also a case that some operators may like to have safety in event of an engine failure. An engine failure prior to TDP at for instance 200ft when IMC, with buildings scattered all over the rejected area may not have a pretty ending.
So we are establishing for example
a) do you you need to be visual with surface at TDP so that you can land without damage to property on the ground - in the event of property being in the rejected area-rule 5(3)(a)
b) whether you can be IMC less than Vmini
The flight manual limitation of min 50kts for IFR which does not make much sense, IMC or VMC would seem more relevant. From a CS29 certification point of view Vmini does not seem to preclude IMC flight below Vmini. Yet if its in the limitations section of the RFM then it would seem to imply you need to be VFR until 50 kts. (VMC until 50 kts would make more sense)
Palma at the weekend is IFR departures only. (or used to be) So it may be a day with perfect viz and you cannot depart if you need to be VFR until 50 kts.
Totally agree with SOP's, training, currency, etc, and I would add Experience, as someone has already posted that the Capt had probably never carried out a departure like this before. Whilst a north sea pilot, shuttling, may do hundreds of towering take-offs a month.
But there is certainly a case for establishing whether this can be carried out with compliance with the regulations and whether in this specific case in can be. And then once we know if it is legal or not, we can discus the how.
I take your point it can be carried out safety in the all engines operating case, but there is also a case that some operators may like to have safety in event of an engine failure. An engine failure prior to TDP at for instance 200ft when IMC, with buildings scattered all over the rejected area may not have a pretty ending.
So we are establishing for example
a) do you you need to be visual with surface at TDP so that you can land without damage to property on the ground - in the event of property being in the rejected area-rule 5(3)(a)
b) whether you can be IMC less than Vmini
The flight manual limitation of min 50kts for IFR which does not make much sense, IMC or VMC would seem more relevant. From a CS29 certification point of view Vmini does not seem to preclude IMC flight below Vmini. Yet if its in the limitations section of the RFM then it would seem to imply you need to be VFR until 50 kts. (VMC until 50 kts would make more sense)
Palma at the weekend is IFR departures only. (or used to be) So it may be a day with perfect viz and you cannot depart if you need to be VFR until 50 kts.
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My favorite topic.
"Rules".
JimL got all huffy when asked him how these "Rules" came into being as it seems a logical question to ask when one considers all the contradictions and disparities cited by so many Posters here.
My ol' Daddy was a Master Electrician and had his own Construction business. One of his favorite comments to young Engineers was "Just because you draw a Mule standing on the Ceiling does not mean I can put him there.".
How many different problems have we listed?
We have comments from the USA, UK, Oz, Spain and where else suggesting all is not well with our various authorities implementation of the "Rules".
"Rules".
JimL got all huffy when asked him how these "Rules" came into being as it seems a logical question to ask when one considers all the contradictions and disparities cited by so many Posters here.
My ol' Daddy was a Master Electrician and had his own Construction business. One of his favorite comments to young Engineers was "Just because you draw a Mule standing on the Ceiling does not mean I can put him there.".
How many different problems have we listed?
We have comments from the USA, UK, Oz, Spain and where else suggesting all is not well with our various authorities implementation of the "Rules".
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a) do you you need to be visual with surface at TDP so that you can land without damage to property on the ground - in the event of property being in the rejected area-rule 5(3)(a)
(3) The low flying prohibitions are as follows:
(a) Failure of power unit
An aircraft shall not be flown below such height as would enable it to make an
emergency landing without causing danger to persons or property on the surface
in the event of a power unit failure.
(a) Failure of power unit
An aircraft shall not be flown below such height as would enable it to make an
emergency landing without causing danger to persons or property on the surface
in the event of a power unit failure.
What a laugh. So what if the pilot fails? or tail rotor? Does 5(3)(a) not apply in these cases I wonder?
Tightgit
Be careful what you wish for chop jock. If that rule were to apply to tail rotor failure then none of us would go anywhere!
I appreciate that you're not wishing for anything, you are just having an ironic laugh at the apparent lack of logic
I appreciate that you're not wishing for anything, you are just having an ironic laugh at the apparent lack of logic
Continue take-off or continue take-off ?
Can we stop the chatter about do we/do we not have to be visual at TDP (or a fraction of a sec before..............you are confusing me! Court of law will apply common sense even if book doesn't.
Of course we do - there is no discussion - that is your decision point what next; continue take-off or continue take off?????
How else does one expect to 'reject' if you cannot see Mother earth - but saying that - how do you judge available RVR at a private site?
They would have used the infamous 1k tree or something similiar.
If not, then I'm afraid the book, it shall be thrown as Monsieur Proirot would say.......as there is some phrase about having to have sufficient visual references to carry out a landing after take-off in case of single engine failure prior to TDP etc.....
very sad 'accident' but I think all that knew (of) the owner are not really that surprised but unfortunately it do not think it will be the owner's estate that suffers when the ambulance chasers get active.
Offshore from a rig, the only rvr requirement for departure is that you can transition to forward flight as there is not the option of rejecting back to the deck once decision to go has been made (top of tdp, and, by design, no obstacles in vincinity of oei profile)
Also struck me how few hours the Captain had for such an operation - was that because everyone else didn't want to/or already had worked for the outfit???
Of course we do - there is no discussion - that is your decision point what next; continue take-off or continue take off?????
How else does one expect to 'reject' if you cannot see Mother earth - but saying that - how do you judge available RVR at a private site?
They would have used the infamous 1k tree or something similiar.
If not, then I'm afraid the book, it shall be thrown as Monsieur Proirot would say.......as there is some phrase about having to have sufficient visual references to carry out a landing after take-off in case of single engine failure prior to TDP etc.....
very sad 'accident' but I think all that knew (of) the owner are not really that surprised but unfortunately it do not think it will be the owner's estate that suffers when the ambulance chasers get active.
Offshore from a rig, the only rvr requirement for departure is that you can transition to forward flight as there is not the option of rejecting back to the deck once decision to go has been made (top of tdp, and, by design, no obstacles in vincinity of oei profile)
Also struck me how few hours the Captain had for such an operation - was that because everyone else didn't want to/or already had worked for the outfit???
Bering
Bristow offshore take-off minima in UK North Sea is 800m visibility.
How is this measured offshore??
On ETAP with no other rigs close by, or buoys at set distances, or a standby boat that could give you visibility it was impossible to give an accurate visibility it was pure guesswork. I asked for the rig weather station to be modified to give visibility (as the 40s did) but it was never done in my time
HF
Bristow offshore take-off minima in UK North Sea is 800m visibility.
On ETAP with no other rigs close by, or buoys at set distances, or a standby boat that could give you visibility it was impossible to give an accurate visibility it was pure guesswork. I asked for the rig weather station to be modified to give visibility (as the 40s did) but it was never done in my time
HF
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OK, again we have several answers for the same question.
Viz up to TDP, 250 meters for two Crew and Automated Viz measuring, and 800 meters offered up so far.
Is this another one of the "Rules" that is misunderstood or is this a function of multiple SOP's by multiple Operators?
Viz up to TDP, 250 meters for two Crew and Automated Viz measuring, and 800 meters offered up so far.
Is this another one of the "Rules" that is misunderstood or is this a function of multiple SOP's by multiple Operators?
No Bob, you have two answers to the one question. TDP is only applicable to a class one profile not the class two profile that is usually utilised offshore. The second of the two answers was merely saying that the first answer given was incorrect. No doubt someone will confirm that in the near future.
Cheers
TeeS
Cheers
TeeS
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Nope, just, very clearly stated in the ops manual, I can't vouch for other incorrect answers or other companies, 250m two crew offshore for Bristow.
Weather generally automated, although this can sometimes fail of course.
Provided that,
The Commander must establish that the take-off path is free of
obstacles.
Also for onshore that the commander must remain clear of cloud and in sight of the surface until TDP and in sight of the surface until the pilot has reached minimum speed flight for IMC in the particular type.
This will of course be for runway departures, not confined area take offs.
Even though it is contrary to our SOP we also regularly practice inadvertent entry into IMC in the hover in the simulator.
Which if not in the hover appears to be very similar to what happened to the crew in Norfolk.
Weather generally automated, although this can sometimes fail of course.
Provided that,
The Commander must establish that the take-off path is free of
obstacles.
Also for onshore that the commander must remain clear of cloud and in sight of the surface until TDP and in sight of the surface until the pilot has reached minimum speed flight for IMC in the particular type.
This will of course be for runway departures, not confined area take offs.
Even though it is contrary to our SOP we also regularly practice inadvertent entry into IMC in the hover in the simulator.
Which if not in the hover appears to be very similar to what happened to the crew in Norfolk.
Correct. You may well have a point at which you make a decision during the take off but don't confuse things by calling it a take off decision point. Your actions before, at or after TDP will guarantee certain performance in the event of an engine failure when class one. If you are performance class two then you have no such guarantee until you have reached your 'defined point after take off' DPATO
Cheers
TeeS
Cheers
TeeS
So for offshore ops, you can operate down to 250m vis for your rig departure (presumably not at night) and fly a PC1 profile to TDP before transitioning?
In vis of 250m as you transition into forward flight, are you looking at the visual horizon (oh no there isn't one in 250m vis) or the AI? How are you legally able to do this if you have a min speed on instruments of 50kts (unless there is a 50kt headwind)?
Your visual references as you leave the rig are the mist in front of you or the sea surface below you - in what way is that VMC or VFR? The comedy of 'clear of cloud in sight of the surface'?
It would appear the whole 50 kts VminI is given a stiff ignoring - something I find surprising in our rule-bound and litigious society.
In vis of 250m as you transition into forward flight, are you looking at the visual horizon (oh no there isn't one in 250m vis) or the AI? How are you legally able to do this if you have a min speed on instruments of 50kts (unless there is a 50kt headwind)?
Your visual references as you leave the rig are the mist in front of you or the sea surface below you - in what way is that VMC or VFR? The comedy of 'clear of cloud in sight of the surface'?
It would appear the whole 50 kts VminI is given a stiff ignoring - something I find surprising in our rule-bound and litigious society.
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You may well have a point at which you make a decision during the take off but don't confuse things by calling it a take off decision point.
Class One, Class Two or without giving any thought to Performance, Class, or color of uniform, when you make a Decision re landing or proceeding to fly, at the point in the Take Off process you make that Decision, is a Take Off Decision Point.
What label you stick on it is your choice but the Decision Point it is.
Crab,
Please comfort us by telling us the RAF does not have any such conflicts or conundrums in its handful of Regulations, Procedures, SOP's, and Flying Orders?
Bob - Argue the point with ICAO, here is their definition of TDP:
Cheers
TeeS
The point used in determining take-off performance from which, a power unit
failure occurring at this point, either a rejected take-off may be made
or a take-off safely continued.
Note: TDP applies to performance Class 1 helicopters.
failure occurring at this point, either a rejected take-off may be made
or a take-off safely continued.
Note: TDP applies to performance Class 1 helicopters.
TeeS
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When operating under JAR-OPs, as the three big offshore companies do, one has Ops Manuals.
The OMA (Ops Manual A) is company specific, it covers rules, minima and procedures which apply to all aircrew whatever aircraft type they fly.
The OMB (Ops Manual B) covers the specific helicopter type. Each type has its own book which looks very like the RFM, and includes Limitations, Normal SOPs, Emergencies, Performance, Weight and Balance, and more.
Under JAR-OPs a performance class one helicopter, being flown two crew, day or night, can depart an offshore deck in 250m vis, clear of could with surface in sight. The commander must ensure the path ahead is clear. This authority will be found in the OMA. These are IFR departure minima only, see JAR-Ops 3.430(a).
For performance class 2 helicopters its 800m vis until achieving PC1 capability. Currently the UK CAA allows PC2 offshore. Still an IFR minima. JAR-OPs 3.430(a)(3)(ii)
However, specifically, for the AW139, if the OMB reflects the RFM there will be a limitation saying "minimum airspeed under IFR is 50 KIAS".
If this is so (check your OMB), the OMB is more restrictive, in this case, than the OMA, as at night to maintain VMC thus complying with the Visual Flight Rules - until at 50 KIAS - you need inflight vis of 3km in UK Class G airspace, i.e. offshore. That is for as long as there is not a 50 kts hoolie, when immediately, you are permitted to comply with the Instrument Flight Rules.
(The UK 'VFR at Night' rules are notified in Civil Aviation Authority INFORMATION NOTICE Number: IN–2012/145 which supersedes the ANO.)
During the day one would be limited to 1500m (Class G) as the ICAO alleviation for just clear of cloud in sight of the surface in VFR below 1000ft above terrain is not permitted in UK airspace.
We are a little off tread. But the point Crab makes is an interesting one. The point is not that one can't fly solely on instruments below 50 KIAS in an AW139. Simply, that before reaching 50 KIAS one is not allowed to operate under Instrument Flight Rules, therefore you have no option but to comply with Visual Flight Rules.
This is not simply about weather, as the Visual Flight Rules and Instrument Flight Rules comprise more than just weather limits.
Crab noted that something has been given a "damned good ignoring", he is right, but as I say, it is not that you can't fly solely on instruments below 50 KIAS in a AW139, well not as the rule are currently written.
As the wording stands, the rules say, you can not depart offshore, (or from Gillingham - same airspace), in vis below 3km, clear of cloud and with the surface in sight, at night in a AW139 in UK Class G... unless the wind allows you to see 50 KIAS on the ASI.
This would still not allow one to depart from Gillingham as one could not comply with the IFRs i.e rules 33 and 34 of the ANO, assuming a private flight, or your OMA under JAR-OPS. I'm afraid in the Gillingham case one must have, a) 3km, b) to maintain clear of cloud and c) be in sight of the surface simply to conform with the Visual Flight Rules. Forget everything else, towering take offs, TDPs, sole reference - forget it.
If you drive a AW139 in the UK, apply the VFRs to the airspace you take off from, and explain how, without 1500m by day - 3km by night, clear of cloud, in sight of surface or 50 KIAS (50kts+ on the nose), you do it without breaking a limitation?
Are you legally allowed to break limitations on a wholesale basis? Have the Authority granted a waiver? Or has it just been given a "damned good ignoring".
By the way, if you fly a PC1 profile you will also comply with PC2 as PC1 is clearly more restrictive. This is required in the OMB of at least one of the large three operators in the UK.
That's as I see it. Please correct me if I'm wrong.
I'll leave it at that.
Over to the legislators and lawyers...
The OMA (Ops Manual A) is company specific, it covers rules, minima and procedures which apply to all aircrew whatever aircraft type they fly.
The OMB (Ops Manual B) covers the specific helicopter type. Each type has its own book which looks very like the RFM, and includes Limitations, Normal SOPs, Emergencies, Performance, Weight and Balance, and more.
Under JAR-OPs a performance class one helicopter, being flown two crew, day or night, can depart an offshore deck in 250m vis, clear of could with surface in sight. The commander must ensure the path ahead is clear. This authority will be found in the OMA. These are IFR departure minima only, see JAR-Ops 3.430(a).
For performance class 2 helicopters its 800m vis until achieving PC1 capability. Currently the UK CAA allows PC2 offshore. Still an IFR minima. JAR-OPs 3.430(a)(3)(ii)
However, specifically, for the AW139, if the OMB reflects the RFM there will be a limitation saying "minimum airspeed under IFR is 50 KIAS".
If this is so (check your OMB), the OMB is more restrictive, in this case, than the OMA, as at night to maintain VMC thus complying with the Visual Flight Rules - until at 50 KIAS - you need inflight vis of 3km in UK Class G airspace, i.e. offshore. That is for as long as there is not a 50 kts hoolie, when immediately, you are permitted to comply with the Instrument Flight Rules.
(The UK 'VFR at Night' rules are notified in Civil Aviation Authority INFORMATION NOTICE Number: IN–2012/145 which supersedes the ANO.)
During the day one would be limited to 1500m (Class G) as the ICAO alleviation for just clear of cloud in sight of the surface in VFR below 1000ft above terrain is not permitted in UK airspace.
We are a little off tread. But the point Crab makes is an interesting one. The point is not that one can't fly solely on instruments below 50 KIAS in an AW139. Simply, that before reaching 50 KIAS one is not allowed to operate under Instrument Flight Rules, therefore you have no option but to comply with Visual Flight Rules.
This is not simply about weather, as the Visual Flight Rules and Instrument Flight Rules comprise more than just weather limits.
Crab noted that something has been given a "damned good ignoring", he is right, but as I say, it is not that you can't fly solely on instruments below 50 KIAS in a AW139, well not as the rule are currently written.
As the wording stands, the rules say, you can not depart offshore, (or from Gillingham - same airspace), in vis below 3km, clear of cloud and with the surface in sight, at night in a AW139 in UK Class G... unless the wind allows you to see 50 KIAS on the ASI.
This would still not allow one to depart from Gillingham as one could not comply with the IFRs i.e rules 33 and 34 of the ANO, assuming a private flight, or your OMA under JAR-OPS. I'm afraid in the Gillingham case one must have, a) 3km, b) to maintain clear of cloud and c) be in sight of the surface simply to conform with the Visual Flight Rules. Forget everything else, towering take offs, TDPs, sole reference - forget it.
If you drive a AW139 in the UK, apply the VFRs to the airspace you take off from, and explain how, without 1500m by day - 3km by night, clear of cloud, in sight of surface or 50 KIAS (50kts+ on the nose), you do it without breaking a limitation?
Are you legally allowed to break limitations on a wholesale basis? Have the Authority granted a waiver? Or has it just been given a "damned good ignoring".
By the way, if you fly a PC1 profile you will also comply with PC2 as PC1 is clearly more restrictive. This is required in the OMB of at least one of the large three operators in the UK.
That's as I see it. Please correct me if I'm wrong.
I'll leave it at that.
Over to the legislators and lawyers...
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Best post yet by anyone on this topic. Well Done, Sir!
The only thing that really confuses me is the reference in the 139 RFM (if as it is described to be) where it references "IFR" rather than "IMC".
As it describes it now, if one were operating at an Airport with weather barely less than VFR (say ceiling 900 feet and Vis .9 Miles) thus making the control zone IFR one would not be able to depart. Or do I miss some exception or waiver or loop hole in the Rules?
The only thing that really confuses me is the reference in the 139 RFM (if as it is described to be) where it references "IFR" rather than "IMC".
As it describes it now, if one were operating at an Airport with weather barely less than VFR (say ceiling 900 feet and Vis .9 Miles) thus making the control zone IFR one would not be able to depart. Or do I miss some exception or waiver or loop hole in the Rules?
RWandB, thanks for your post, it clarifies much of what I had thought - but presumably the issue isn't confined to the 139 as many other helos probably have a similar VminI in their RFMs?
Bob -
sorry Bob, I can't hold the MAA up as a shining beacon of how to regulate aviation, we have replaced one system of byzantine complexity with another that relies on box-ticking and coloured matrices to evaluate safety.
Bob -
Crab,
Please comfort us by telling us the RAF does not have any such conflicts or conundrums in its handful of Regulations, Procedures, SOP's, and Flying Orders?
Please comfort us by telling us the RAF does not have any such conflicts or conundrums in its handful of Regulations, Procedures, SOP's, and Flying Orders?
