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Over water Helicopter flight ban proposed by CAA
Apologies for being lazy, but below is a copy of an email forwarded by the Helicopter Club of Great Britain.
Nice to see that this was mentioned at the recent small helicopter safety seminar :mad: No Floats? Over water helicopter flight ban proposed by CAA. No more helicopter flights to France? One of the most serious threats to our use of helicopters is hidden away in a recent CAA consultation letter entitled "Proposal to amend the ANO to enable compliance with ICAO standards for GA operations." View it at http://www.caa.co.uk/srg/general_avi...document_._asp It is a 2.2 Mb _document_._ The letter and the 15 appendices detail the proposed ANO amendments. The most serious for helicopters are: Appendix 8 (ELT) Appendix 10 (Flights over water) and Appendix 15 (Helicopter flights over water). The Flotation proposal The most serious: "Helicopter flights over water - means of flotation", proposes that no single engine helicopter can fly out of autorotational distance from land suitable for an emergency landing, unless equipped with floats. Even twins would not be able to fly more than 10 minutes flying time from land without floats. This is plainly ridiculous, and grossly unreasonable. It would suddenly make illegal one of the great uses of our helicopters - quickly and easily crossing the channel. It is impossible to fit floats to the Robinson R22 and R44 unless it was built with them. Where it is structurally possible to fit floats to other helicopters, they are prohibitively expensive to buy and maintain, and significantly affect performance and weight. They can even be a safety hazard in themselves if they don't work perfectly. The cost of the proposal to owners is out of all proportion to the risk. If this proposal becomes law, most of our Club's member's helicopters will not be able to legally fly to France, Ireland, the Isle of Wight, or even across the Thames & Severn estuaries and Cumbrian lakes. And of course, if the flight is not legal, the helicopter is not insured. The ELT proposal It is proposed that private helicopters must carry an automatic, fixed, ELT to fly over water. The equipment cost is at least £1850 plus fitting. Fixed wing aircraft just need a hand held ELT (cost around US$500), and only then when 50nm or more away from land. And because helicopters will also have to carry a life raft, another, separate, ELT must be carried in that raft as well! The Life Raft proposal Helicopters will have to carry a life raft, as well as life jackets, and the life raft must contain a long list of equipment including paddles, flares, water and that extra ELT. Where will you put that in your R22, Schweizer, Enstrom or R44? Whilst it is wise to carry life jackets, and a raft if you have room, it is very unjust and completely unnecessary and unreasonable to mandate this equipment, the effect of which will prevent many helicopters flying over water at all. General It should be a matter of individual choice for private helicopter operators whether or not to fit these items of equipment, and most of us have managed very well without them for years. It has always been the CAA's philosophy not try to protect the pilot from himself on private flights. Their mission is to protect the paying public on public transport flights. The only reason the CAA are proposing such draconian rules now, is for their own administrative convenience - so the UK can comply with ICAO standards, regardless of whether or not those standards are practical, sensible, fair, necessary or even reasonable for flight safety. It is a bureaucratic 'tick in the box' as far as CAA is concerned. There is no suggestion in the consultation document of a safety case for these impositions, and no cost/benefit analysis has been performed. And there is the usual "Gold Plating" of regulations - other countries helicopters do not have these ICAO standards imposed on them. Helicopters are severely discriminated against by the ICAO standards. Non public transport fixed wing aircraft are far less severely regulated, only being affected by these proposals when over 50nm away from land. Closer than that, and fixed wing aircraft don't have to have an ELT, a raft or flotation equipment. In contrast ICAO private helicopter standards are almost the same as for public transport flights in terms of equipment required. Therefore the ICAO standards are unreasonable, unfair and wildly excessive in the case of non public transport helicopters. The CAA proposals are poorly drafted, and refer to helicopters whose certificate of airworthiness classifies them as group A or B, when actually, few helicopters are so classified. Also the life raft proposal reads as if it applies only to helicopters with more than 20 seats. It is actually the CAA's intention to apply all the proposals to all helicopters. Do not think (as I initially did) that the proposals as drafted will not apply to us. They will, unless we act forcefully and in large numbers. Please write with your comments to the CAA to: Mr. David Beavan GAD CAA Aviation House Gatwick Airport W. Sussex RH6 0YR explaining your objections to the proposals, to arrive as soon as possible, but no later than 31 January 2004. The Club will of course be responding in full to the CAA, but as usual, it is the volume of responses received that carry the weight, so every member should make their views known now, whilst there is still time to stop the proposal progressing. Points the Club will be making include: ICAO standards severely discriminate against non public transport helicopters, as compared with non public transport fixed wing. ICAO standards should be changed so that private helicopters are treated the same as private fixed wing. There is no significant difference in the mechanical failure risk during enroute flight, between fixed wing and helicopters, and if anything, helicopter engines are more reliable. There are huge compliance costs for private owners, as opposed to the zero cost impact stated in the proposal. There is no requirement to follow ICAO standards to fly in other countries. Aircraft only have to be legal in their country of registration. There is no safety case for the proposals, especially the helicopter flotation proposal. The cost of fitting and maintaining floats is out of all proportion to the mechanical failure risk of crossing the channel for a few minutes a few times a year. Mechanical failure over water has not been a major cause of accidents in the last 20+ years. Private helicopter pilots have been happily and safely flying over water without floats for decades. The CAA can easily file a difference with ICAO to allow them to continue to do so, without floats, as they have up to now. It would be impossible to fit floats to most R22 and R44 helicopters. It would cost £????? to fit floats to my helicopter, which is not a reasonable expense for such a short time spent over water. It is unreasonable to effectively ban large numbers of the UK helicopter fleet of small helicopters from crossing the channel. There is no room in 2 seat helicopters to carry a life raft Why should helicopters have to carry a life raft when fixed wing aircraft don't? There is no room/weight to fit an automatic ELT to the Robinson R22 and the Schweizer 300, It is ludicrous to require the carriage of two ELT's. The proposals assume that an automatic ELT delivers more safety that a portable unit. However, should a helicopter sink in water or catch fire, a fixed ELT would be useless, and a portable one that the crew or passengers could take with them would be of much greater value.. Fixed wing aircraft can comply using personally carried ELT's so why not helicopters? The CAA should consider less severe options, such as a gross weight below which these rules would not apply, e.g. 2730kg. The CAA could apply the private fixed wing proposals to private helicopters. The CAA can choose which ICAO standards to implement. The imposition of new requirements such as this, should be based on an objective, demonstrable case that the equipment confers greater benefits than it does disadvantages (of, for example, cost, weight, installation problems or procedural difficulties). These proposals are for the CAA's administrative convenience, and not for any likely safety benefit to UK persons at all Demand Equality with fixed wing It should be individual choice to decide whether or not to fit the proposed equipment It is not the CAA's remit to protect the private pilot from himself. If you want to fit your helicopter with all this equipment then fine. If you want to fight these proposals, get writing. and do have a happy Christmas and a prosperous new year! Jeremy James Hon. Secretary If the link above doesn't work - try this one: CAA Proposals Heliport |
I suppose you think immersion suits are a waste of payload too?
You shouldn't be relying on a rapid recovery by the RAF. SeaKing serviceability isn't what it used to be. (Rumoured that all east coast SAR helos were u/s at the same time recently, for a variety of snags.) I had the 'pleasure' of recovering a downed private FW pilot from the Channel some years ago. He was dressed in shirt and trousers. Decent looking life jacket held him up quite nicely. He looked asleep. Hand held PLB on lanyard (not holding it though, it was below him down in the water, quite useless. Possibly hands too cold to hold it)) No injuries, no water in lungs, just the cold water.................. Sea temp about 12'C. Our graphs indicated he lasted about half an hour. Of course it wasn't going to happen to him. And it was his choice. I agree with you. It should be a matter of personal choice. Like wearing seat belts in private cars. |
In a stunning revelation, the CAA today announced that they have embarked on a program to eliminate all aircraft accidents. John Higgensbotthom, CAA safety Coordinator and Seldom Quoted pundit described the new program as "A stunning concept likely to eliminate all air safety issues throughout the UK."
His plan, endorsed by the UK aviation aurhorities and scheduled to become law within a fortnight is "simple and effective", Higgensbotthom said, "We simply ban all aircraft from leaving the ground." Asked to comment on the likelyhood that this will slow air commerce and make UK aircraft operators somewhat less economically viable, Higgensbottham said, "That seems to be a common misconception." When questioned further, it became clear that the misconception was not regarding the effect such a ruling would have on flight operations. Rather, the misconception was that somehow the British public were misinformed as to exactly how CAA was chartered. "Continued Flight Operations?" Higgensbottham asked, "Exactly how would CAA be concerned with that?" |
Quidam:
Ooops, seems you are quite concerned, then? For twins: Firstly, France is never more than ten minutes flying time from England (unfortunately :ugh: ). You would need to only be 10 minutes from the mid point to continue!!! Put it another way to take longer than 20 minutes flying time across the narrowest point of the channel would mean a g/s of about 25kts:O So France is still viable. In fact so too is the rest of the western world as a result of this 'hop'. Ireland, a little trickier: 46 Nm between Holyhead and Dublin. You'd need a g/s of atleast 138kts to be only ever 10 minutes from land. Wait for a windy day, that's what I say:ok: IOM, shortest distance to english headland: 31 miles, to scottish headland: 16 miles...no problem there then. Where else do you want to go in your private helicopter????? You're wasting your time with the CAA, they are/will soon be owned by EASA. What EASA says is LAW, as opposed to JAR which was recommended :mad: For singles: This new proposal / law is simply treating water the same as night. Hostile territory for singles - hence no fly without restrictions. Duty of care etc.....blah blah. Why don't private members pair up and part ex their machines for a twin :ooh: I must admit...I'd be mighty pi***ed if I was a private single owner. |
I'll just second what Bertie T said. Spent a lot of time over the north sea as a Sar Boy, and the occasional wet drill in it. Dress to survive! Too many people fly with a 'it won't happen to me attitiude'. Yes the CAA seem intent on banning private aviation, but at times private flyers do some very dubious things!
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Private owners must fight this. There are no statistics at all which point to the necessity of the proposed new rules. For many owners these rules will mean that you are confined to the mainland of the UK - an unfair penalty to pay for being "offshore" from Europe.
The ELT issue is a real worry - I thought it had gone away. Portable ELT yes - fixed, no point. In the earlier CAA consultation on this they cited two cases where they claimed ELT would have helped. I looked into both of these and the CAA were wrong. They were both non-survivable accidents - and one of them was in such bad visibility that the police helicopter couldn't take off! SO what good would an ELT have been - the crash was witnessed and reported. Floats for private operators - an expensive and unnecessary option. I also doubt the safety of such equipment - they can't be pre-flighted if they are pop-outs. I would particularly draw attention to the float pack on the R44 which is deployed using a gas bottle under the left front seat - compromising the manufacturer's own manual which states that no hard object should be stowed under the seats because this will affect the structural performance of the seat in a hard landing or crash. Crazy crazy. The UK comprises a group of islands - we have to cross water to get anywhere in Europe. Just let us take the risk. (And before you flame me - count the number of helicopter water ditchings.........) C'mon all - we have to stop this one. The CAA have got their sledgehammer out again - and there isn't a nut in sight! |
Help!
When I click on Quidam's link to CAA site, I get File Not Found. Anyone else having this difficulty. Cheers Whirlygig |
Bertie/ TC
Don't get me wrong. My other passion is scuba diving and I'm fully aware of how cold the waters off the UK can get :) Seatbelts are a legal requirement in cars BUT there is no law forcing a motorcyclist to wear full leathers boots and gloves. I'm not an owner and aside from the odd lake or lock the most adventurous I've been is the Isle of Wight - and even then I'm ultra careful, carrying life jackets and routing further west along the coast in order to cross at the narrowest point by Milford. I was more concerned with the indirect and silent manner of whats being proposed and the ramifications if it happens. Costs aside I wonder where singles will stand with places like Farmoor reservoir and Sunbury lock both of which I've flown over. I agree with some of the issues raised in the e mail I received from BHCGB and when I get a minute will look to read the full report. Sorry Whirly I can't help with the link as I purely copied the email. Part of me feels as the CAA say they are cash strapped and the majority of fatal incidents involving helicopters (according to the last small heli seminar) involved controlled flight into terrain and wire strikes that their efforts could be better used elsewhere :confused: |
I'm not a fan of the FAA, mainly because "we are here to help" is an oxymoron. Nevertheless, I'm glad similar restrictions aren't proposed in the U.S. I agree with headsethair that this seems a bit ridiculous for General Aviation.
I suppose the closest scenario are the flights over the Great Lakes between the U.S. and Canada. Actually, the distance over water (Great Lakes) is quite a bit further than the Channel. Unless I'm mistaken, General Aviation pilots don't have to carry immersion suits, life rafts, additional ELT's, or equip their aircraft with floats. Now, Part 135 operations are a different story... understandably so. The concept of floats as a primary safety measure is a joke. For example, in the R22 Mariner I've been flying around lately - the floats are rated for 12 inch waves only. That's it! Meaning, floats make it useful to land in protected harbors, calm rivers, intercoastal waterways, small bays, etc. In contrast, I've been flying over larger bays and the Atlantic seaboard. The only thing floats will do for me is that it MIGHT give me a little more time to get out. You can guarantee that the ship will turn inverted as soon as you are in the water. The debate on whether or not General Aviation SHOULD be equiped with this gear is another matter. To me, it's relates to the helmet in the cockpit question. It's a matter of personal choice... if you don't, it is definately taking a risk. (By the way - I've decided to get a helmet based on some of our conversations). That said, are there THAT many incidents where this Proposal is warrented? If there are a large number of crashes in the Channel, then the problem relates to aircraft maintenance, pilot training, or aeronautical decision making... not whether or not the ship is equipped with extra gear. What's next... let's make a law that says sharp objects must be padded with 3/4' foam and proximity alarms when someone comes within 2 feet! :\ |
Quidam: correct me if I am wrong but what is the problem over reservoirs lakes, as long as you are within auto range of the bank, it's Ok??
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TC,
Was referring to this that was contained within the email. I assume that BHCGB has done a fair amount of research before sending out their concerns. I don't presume to be experienced. Just in the final stages of hour building before CPL course. "If this proposal becomes law, most of our Club's member's helicopters will not be able to legally fly to France, Ireland, the Isle of Wight, or even across the Thames & Severn estuaries and Cumbrian lakes. And of course, if the flight is not legal, the helicopter is not insured." Is what they are saying incorrect?????? |
quidam
Thanks for posting the information here. Opinions may differ, but at least pilots are now aware of the proposals and will be able form a view. Heliport |
The fact is risk has always to be balanced against cost and practicalilty in everything in life, and this balance will change over time for various reasons. If we all equipped our cars with race-style roll cages and wore crash helmets on the road, fatalities would probably halve, but who is going to do it?
Maybe with the huge audience of PPRune, we can get some idea of the actual levels of risk involved with over-water flight in singles and twins, with and without floats. If anyone knows of any heli forced landings/accidents over water in the last, say 10 years, please post the following info: Year Approx location, eg GOM, English Channel Heli type, Reg if known Single/Twin Cause if known, eg engine failure, fuel exhaustion Floats fitted? Brief outcome, eg heli on floats remained upright long enough to launch dinghies, 3 rescued, or heli on floats rolled over on auto, 2 fatal, etc etc. Of course it would not be unreasonable to assume that such data has been compiled by the CAA (and other aviation authorities) in order that any new regulations were proposed and implemented against a background of factual knowledge and relevant statistical analysis. It would be good if we could use PPRune to enable us all to generate some useful data to help everyone make sensible decisions; the authorities determing what should be mandatory and pilots determining where they want to pitch their own balance. |
Thank you Cathar - just printed it off; 59 pages of light bedside reading ;)
Cheers Whirlygig |
The more I think about this, the sneakier it looks.
(1) The CAA's circulation list (at the front of the document) is predominantly comprised of commercial operators - and they largely won't be interested in fighting the change because they've already got these rules under Public Transport. So - why didn't the CAA circulate to those who will be directly affected - private pilots and owners ? (2) The CAA Small Helicopter Safety Seminar was on November 18. It was attended by 60 helicopter pilots - many private. Yet no mention was made of the "consultation" letter which we have now heard about. The date on that letter was November 6. (3) The closing date for responses is January 31st 2004. Yet most of us have only learnt of this proposal this week. It's a crazy time of year and I just get the feeling that CAA SRG are hoping that this period sails by unnoticed. We need firm, accurate responses from private helicopter pilots and owners. All those self-fly hirers.......get 'em writing. |
tried to read what sort of floats are required part of it says fixed floats my interpretation of this is actual flotation equiptment not blow up floats any one else a view of this
personally i think flight over water should be with floats [blow up type ] at least it one would have something to hold onto if it went belly up i put floats on the 600 for that reason elts all us registered helicopters should have fixed elts although there does seem to be argument about us reg helicopters based in the uk requiring them afaik steve |
Looking at the letter, the only juicy bit, really is the floats, isn't it?
Everything else makes sense and is relatively cheap. For example an ELT (AP) comes in at about £2200 plus fitting. So no big deal. Those floats are another story. How much for a retro kit to, say an R22?? The sad thing is, they are next to useless when used in anger. Don't think you're going to win this one, lads and lasses! Mike M-Smith (Castle Air) stoofed into the channel around 1996-7?? Jet ranger, I think - engine failure. Sank almost immediately. |
On first perusal of the table, it seems to say that only helicopters from performance class A and B will require floats, all others will just require scale H
Scale H (i) Subject to sub-paragraph (ii), for each person on board, a lifejacket equipped with a whistle and waterproof torch. (ii) Lifejackets constructed and carried solely for use by children under three years of age need not be equipped with a whistle. However, a good time to confess that I don't know to what performance class private heli's are flying! If you want to make a point to the CAA you had better do it quick...Replies by the end of Jan! |
As far as retrofitting a ship with floats, say an R22 - it can't be done today. If it was'nt sold as a float equipped helicopter, then it can't be made into one. Specifically, the R22 Mariner has a type certificate just for that feature. Therefore, you can NOT take a new R22, buy the parts (floats, modified stinger, modified stabilizer, landing gear extensions for floats, battery brackets to move battery from under engine to under instrument panel, etc) and build it into a float ship.
Lifejacket requirement for over-water flights seems reasonable. ELT's mounted to the airframe probably won't make a difference one bit. As the antennae goes under water, they aren't affective at all (at least 1/3 of the antennae needs to be above water). |
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