Which has been the Point I have always tried to make when discussing "Rules"s, "Regulations", and "Laws".

They all have varying effect, force, and pertinence but are never absolute.

Even The Laws of Gravity can be defied but they too demand a reckoning if you get it wrong.

So we have the nonsense situation that a night rig departure, flown without real external references, is legal for public transport ops - despite the fact that the RFM is ignored because most aircraft have a VminI above 40 kts - yet a towering IF takeoff is illegal anywhere else for public transport ops without real external references:ugh:

Crab - A night rig departure is conducted over open water starting at a height AMSL of between 50 and 300 feet approx. The risks associated with this procedure are much much less than doing it over land at an unlicensed site.

In addition the potential errors in an offshore departure are captured, documented and trained. The manoeuvre is practised intensively BUT far more important than that is the fact that it is exactly the same procedure in daylight. One procedure, one muscle memory, one picture on the instruments significantly contributing to the success of the procedure.

Please do not compare what happened in this accident to the hundreds of thousands of successful night rig departures each year.

Competence, training and experience. There are no substitutes!

A night departure from a ship's deck is also an immediate transition from visual to instrument on many dark nights. Night North Sea rig departures were quite tame in comparison.

But they do need currency and capability, of both the pilot and the machine. Not wishing to detract from this accident and the loss of life but we have been doing many of these procedures for 40-50 years: surely someone must have considered their use in onshore ops?

But surely Crab's point is quite right! DB - Crab's issue was what's legal and presumably the height AMSL of a rig departure is irrelevant to that point. I'm not saying it's wrong - far from it. As you say, with good training and currency it's clearly fine.

But in reality there is surely no real difference to the skills and technique required for a safe night rig departure and those that should have been applied for this 0/0 139 departure, with the only caveat of ensuring no obstacles were too close. Plus as I've suggested before, I'd imagine many rig departures are at close to MTOW, making it harder. Safety standards are surely amonsgt the highest for rig PT too.

So, two points. Firstly how are the regulations complied with for night rig departures when no visual references are ahead? And secondly what's so wrong (regulations - potentially - aside) with land based 0/0 IMC departures, assuming appropriate training and currency?

It is almost a near certainty that the pilot of G-LBAL wasn't current in 0/0 takeoffs. I would wager he hadn't done one before but thought he could 'manage' it on this occasion. On paper 0/0's seem straight forward..........

On all sorties where IIMC or lack of visual references are expected we would advocate that the NHP must follow through and be prepared for disorientation.
Because this seems to be the cause of this accident.

rotorspeed

But offshore or from a raised helipad there is a huge difference. Climbing to 20 to 30 feet, probably with some lit part of the structure visible as a reference for the climb, a rotation that then guarantees you clear the initial ground obstacle and continue forward to try and gain airspeed in order to fly away - the 50 - 300 feet height, above sea level at which you begin is used to do that, and unless operating at a low helideck elevation at max all-up (which your ops manual probably prohibits) then even in the event of OEI you will fly away using slightly more nose down than standard 5 - 10 degrees for departure.

Onshore you have the obstacle of the ground always in front of you, or obstacles around you, and so without the required visual cue during a longer portion of the procedure ..... it quickly goes wrong if you do not follow the profile, or exceed pitch attitude references

It can go wrong offshore too, but there is more time to react / correct / monitor

One other aspect of night rig take-offs was the susceptibility of the pilot to the "leans". A very current pilot tends to suffer far less, but the NHP needs to be quick in his responses to over-controlling or loss of spatial awareness in the other seat. Add in a minor physical degradation such as unrecognised fatigue or the onset of a head cold and the leans can bite the most current. The manoeuvre is certainly not recommended for any pilot lacking in either currency or training.


Also IIRC off-shore a towering take-off was acceptable because officially all take-offs and landings were visual, no matter what time of day or night.


SND

Is the Rule the Rule except when it is not the Rule?


The Military using different "Rules" have done just that and have done these kinds of Take Offs both in training and in real life.

How many "Brown Out" Take Off's have Chinook and Black Hawk Pilots done in Afghanistan and Iraq over the past Ten Years, including doing Underslung Loads?

Onshore we are confronted with conforming to the "Rules".

In the USA, we suffer from an FAA that is Fixed Wing focused and who have a system of Rule Making that generally adds to existing Rules rather than going back to a Zero Based Solution and starting over to arrive at a completely new Rule that incorporates improvements and advances in Technology and Science. As a result far too many limitations are placed on Helicopters purely as a result of the "Rule" being crafted around Airplane capabilities and thus limit the versatility of the Helicopter.

Compound that by the lack of "Helicopter" IFR infrastructure such as low altitude airways and ATC capability then the Helicopter Industry is knee capped by the System.

Nick Lappos has done extensive Flight Testing to validate such a capability and has been an advocate for the creation of such a system. I have seen a couple of his Presentations on that Topic and appreciate his forward thinking about the concept.

Lappos is thinking about a complete IFR system and not just a single simple Take Off Technique which would only be a part of the overall program.


Poorly worded I would say but the intent is correct. One Procedure but the rest is full of variables that are known and predictable thus easier to cope with as a result. For an example, lightly loaded Aircraft, 40 knots of wind on the nose compared to a Maw Weight Aircraft and zero Wind. It is the same procedure but much difference in the way the aircraft handles and performs.

legal vs illegal
 

On a job like this you're either **** hot or you think you are and then you die;

and give a lot of "experts" a chance to brag about their own skills, the good old

days and how it should/ could have been done.

Human nature to think you are a lot better than you are; and easy to blame the

overpowering owner, life's circumstances and lack of rules, oversight from the

authorities etc. You are in charge, you reap the benefits, you pay the price.

As American Cowboy's used to say, "If you done it, it ain't bragging!".:=

In the words of a great American folk Hero, Harry Callahan, "A Man must know his own limitations!".:ok:

My point about the rig takeoffs is the legal operation of the aircraft on instruments (because you have no visual references) below VminI (50 kts in the case of the 139) despite that being in contravention of the RFM - how is that circle squared or is it given a stiff ignoring?

On the Sea King we have a low velocity indicator giving along and across doppler velocities so even below 50 kts you have a reference to work from - presumably NS helos have something similar (inertial nav based) to get round the problem.

But is the use of such devices legislated for and allowed for public transport ops over land?

The situation at worst is only a transient as the aircraft is accelerating with the "Towering" part of the take off only being enough to ensure clearing the Deck Edge and during the Towering portion there is some vision cues until passing over the edge of the deck. After that, it is Instruments only.

Just how much use is the Doppler cue for a Take Off?

Prior to the adoption of all those fancy devices, did not the RAF conduct Takeoffs without them? If the Doppler is so crucial in a Take Off however did the RAF get by in the past as they did?

We are not talking about SAR Ops and hovering about the Oggin, just departing a hell-deck from a Rig or Platform.

Your question is very appropriate since if One is obliged to control the aircraft by solely referring to Instruments exclusive of external cues then that is IMC flight even if it does not meet the definition of IMC which is based upon WEATHER criteria.

The wonderful FAA ignores that distinction as do Operators.

They will tell you to your Face the Weather is VMC/VFR because you have Ten Miles of Visibility underneath an Overcast on a Moonless Night. Granted if there is nothing to see like a ship with lights, an Oil Rig with Lights, or an Oil Platform with lights, there is nothing to be seen other than the Whites of your Eyes shining back from the Wind Screen, but to the FAA it is VFR Weather.

So I submit part of the answer lies in the definition of IMC/VMC/IFR/VFR.

Crab;


Onshore you are either making an IFR departure from a fully equipped airfield, or you are making a VFR departure from an unlicensed site or unequipped airfield, there is no such thing as an IFR departure from a private site, or unequipped airfield.


Second, when IFR the aircraft should be above the minimum safe altitude (around Gillingham they should have been at least around 2000')How does a pilot fly a visual departure when the cloud base is a few feet and the visibility "tens of metres" and get to his safe altitude without ignoring the requirement to be visual for his departure? Or are we back again to "I paid for an IFR helicopter and pilot, so fly it IFR!" from the bloke in the back? The rules go out the window because the real biggy in every pilot's mind is the engine failure case, which is so rare and the helicopter is so incredibly clever that it will deal with the conditions pertaining, despite the fact that maybe the pilot can't deal with them as he doesn't know how.


I have never seen the low velocity indicator on any onshore IFR machine, and I've flown most types, but in reality that would just be another bit of kit encouraging pilots to break the rules.


SND

Crab,

You saidThis is an interesting one, however that is not quite what the book says.

The 139 RFM says; "Minimum airspeed for flight under IFR (Vmini) ............. 50 KIAS."

So, It does not say you can't fly with sole reference to instruments below 50 KIAS.

It says you will not fly under Instrument Flight Rules with less than 50 KIAS.

We all know we can fly VMC under IFR. But one can't be VFR and IFR, it is one or the other. Therefore it must be VFR below 50 KIAS then VFR or IFR beyond.

Now I'll pull the pin and lob...

Prior to Sept 2012 there was no VFR at night in the UK.

So how did a 139 legally reach the magic 50 KIAS - to continue IFR, the only option then available at night, in winds less that 50 kts?

A bit of a disconnect there!

Now, post Sept 2012, we do have VFR at night. For a helicopter one needs COCISoS & 3km in class G airspace (the typical offshore rig airspace and Gillingham) to conform with VFR.

So now, with less than 3km, how can a AW139 depart at night, in Class G? You need the VMC conditions (3Km +) to be VFR, remember the RFM says no IFR until you reach the magic 50 KIAS (Vmini) not no IMC.

Back to the 50 kts hoolie

See my dichotomy?

I can't believe it is a slip up in the RFM, then again...

Edited to add for clarity, the definition in the AW139 RFM for Vmini is 'Minimum airspeed for flight under IFR'

It says minimum speed on instruments.

The semantics around IFR or IMC seems to be a deliberate way to avoid the real question - can you fly below 50 kts by sole reference to instruments or can't you?

The manufacturers appear to have worded the RFM to allow operators and legislators to dance around the issue with each believing they are in the right, despite being (probably) diametrically opposed since the legislators don't wan't people doing it (because it can be dangerous) yet the operators do want the ability to comply with PC1 departures in conditions that are not really VMC.

Whilst realising that it is an unwise virgin that argues the legislation with JimL, I have to ask whether his definition of VminI is a genuine definition or an interpretation. The reason I ask is that I always ‘assumed’ that minimum speed on instruments was the speed below which you should not reduce to whilst flying on instruments, rather than specifically a speed to which you had to accelerate to before you could achieve safe flight on instruments.
As an example, the S61 (correct me if I’m wrong, it’s been a very long time) had a quoted minimum speed on instruments of 50 kts; however, one of the category A (in those days) take-off profiles had a TDP of 50ft and a minimum cloud base (or vertical visibility) for departure of 50ft. Allowing you to achieve TDP whilst theoretically remaining in visual contact with your rejected take-off area still in sight. This then left you to accelerate from a near vertical climb and an airspeed just registering on the ASI, into forward flight and up to something equating to VminI whilst IMC. Not a million miles from the procedures that are being talked about on this thread, the difference being that we would be carrying out this process from an airfield with a published SID or missed approach procedure to follow.
In my opinion, the important feature of such departures has nothing to do with doppler indicators or anything else that detracts from the primary task of setting an attitude and power setting appropriate to the procedure – to quote my personal guru of instrument flying, “Attitude plus Power = Performance”.
Please don’t confuse this rambling with a defence of departing from an essentially hostile environment (not in the JAR sense of the phrase) with negligible visibility. In my world, operations with an RVR below 400m require specific training and authorisation from the ‘competent authority’.

Cheers

TeeS

There are dichotomy's aplenty. My favourite is transport helos are not permitted to enter the H-V curve, yet you do it on every rig take off in the helos I'm familiar with.

In my book a rig take off at night is flight on instruments, and is IMC. Raise the old NVFR definition argument.

Tees - exactly what I am getting at - can you fly on instruments below 50 kts or not?

The doppler is just a handy way of confirming that your attitude plus power is giving you the desired performance - ie you are accelerating forward and not drifting laterally but it is not an alternative to selecting the correct attitude in the first place or maintaining a good IF scan.

This. There is a lot on here about the rules, but not much on the lack of SOPs for onshore operations.

The VSI works just fine below VminI as does a doppler meter (if fitted - and I'm not saying that it is essential for a safe zero/zero departure). For that reason, departures from the hover and coupled returns to the hover can be done safely. The safety of these manoeuvres relies on 2 components: Training (SOPs, currency etc) and aircraft fit.

Having only one of the above does not make for safe zero/zero ops. If the regulators have to get involved, then these 2 strands must be considered together.

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.

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".

Rule 5 (3) (a)

What a laugh. So what if the pilot fails? or tail rotor? Does 5(3)(a) not apply in these cases I wonder?

correct, does not apply! performance tends to account only for engine failure

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

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???

BeringHow 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:ugh:

HF

800m is incorrect, its 250m offshore 2 crew, measured by automated devices

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?

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

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.

No TDP for a Class Two Profile offshore?

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

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.

I would suggest calling the Decision Point in a Take Off not a Decision Point is confusing things.

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

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...

Best post yet by anyone on this topic. Well Done, Sir!:D:D:D:D

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?

Agreed, bloody good post RWB - can't believe I've got my copy of JAR-OPS 3 out at this time of the morning!!!!! I must get me a life!

TeeS :)

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.