Crab
Of course it was a somewhat rhetorical question - I would have been very surprised if a SAR approach couldn't have been made with a 500ft or less cloudbase.

But perhaps you could be slightly more helpful - what sort of vis and cloudbase limits apply for a SAR over-sea let down? And what distance from land is required?

llamaman
 

SAR overwater letdowns are safe, as I understand.
Problem here is modern equipment paired with homemade charts, SOP etc.
Lots of details indeed, but no quality control or watertight or foolproof procedure towards LAND.

What I suggest is a few IFR charts to fuel bases and hospitals in Ireland.
I suppose most hospitals can be reached IFR by doing an ILS to airport then a short VMC segment to pad at hospital ?

With regards to IFR over land , I fail to see the principle difference between fixed wing and helicopter ( SAR or not).

I would think SAR is exiting enough as it is ,never mind shooting dodgy homemade approaches were proper and safe ones should be made by the State, that you contract for.

Would be interesting to compare with what the Irish Aer Corps use.

Also strong odds AAIU Chief flew a similar route as Aer Corps pilot.

I think the approaches differ in several ways. Because of the limited range of helicopters, I expect that alternates are fewer than for fixed wing. The missed may be structured differently. In some machines, it seems the approach can be vertical to a spot and crawl forward. Helicopters generally have more options. In most cases, it would be ground in sight, rather than runway in sight, at DH or MAP. Landing at an airport is likely not much different.

It's more likely in this type of work, with the experience and expertise of CHC, that they would do ad hoc or restricted approaches. The state should certainly be the approving authority, though.

All of what we are talking about is your routine landing spots, no?

Isn't it the case that once they have exposed themselves to low altitude mode the onus is entirely on the PIC to see and avoid obstacles? If so, and not-withstanding all those other factors which might get pinned on the operator or elsewhere, the core issue does seem to me the aircraft was operating in conditions which did not allow them to see and avoid obstacles in the flight path.

VFR minimums
 

Does anyone know what the company or regulatory VFR minimums were for this flight? The transitional flight from Black Rock to Black Sod is not an IFR procedure and so would require VFR minimums be met, including having visual surface reference requirements. I'm thinking with an overcast of 300-400', that it is unlikely VFR minimums were achieved and that a missed approach from the IFR letdown procedure would have been required.

The operative presumption was that there are no obstacles at 200 over the sea. Because if there are obstacles, if you presume they are there, and its dark, then you should be higher than any obstacle anywheres near your path. If you are using the radar to look for something you concede might be out there on a simple approach to a fuel area, then you shouldn't be at 200 feet. You are right that the choice of 200 feet is entirely the pilot's. What is in question is how she came to believe that was a safe choice. Because 500 feet was surely a safe choice.

Yes. And again that comes down to the thoroughness of the pre-flight planning, and the in-flight execution, which is the responsibility of the PIC.

If the SAR helicopter is cruising offshore / in archipelago at 200 ft AGL (9 nm from the landing site) in poor night VMC/IMC wx conditions, there is usually no one warning the crew about e.g. drifting or moving targets. For that reason the pilots should monitor/compare moving map and radar picture all the time
and be prepared to avoid the obstacles on route with a heading change.

Rotorspeed - as I said, the SAR letdowns can be conducted in zero vis/fog/in cloud, however you want to define it - that is the whole point of having a fully automatic letdown capability in a SAR helicopter.

For those FW orientated, think of it as a Cat III autoland that you can do anywhere over the sea providing you are using the radar correctly.

As to min distance from the land - we used to use about 0.5nm as an absolute minimum for the let down and we could close to around 75m in the coupled hover from there.

Although FAA rules permit otherwise, you are not VMC/VFR over the water at night even when you are completely clear of cloud.

Is that because other jurisdictions, i.e. UK and Ireland, require all night flight to be IFR, or is that just an over water rule.

There is legal night VFR in Canada and US, I think France and Portugal, too.

I've done a lot of night VFR. It's really IFR, or you're best to treat it that way. In remote areas, i.e. ocean, you can't really see things below an overcast, or sometimes not much even with a clear moonless sky. Full moon, yes, you can land at a strip with a full moon and no lights.

So you say that this was 100% an IFR flight because it was night?

200 feet doesn't seem right.

To be VFR, you need to be VMC. If you are not in sight of the surface, and you have no visible horizon, as is often the case over the sea at night, you cannot be VFR.

cncpc:

In the UK, we 'now' have night VFR as well.

Thanks Crab, appreciate your very helpful response, which confirms that SAR let downs can be in 0/0 conditions and 0.5nm offshore was your minimum. Presumably the S92 is even better equipped than the aircraft you were flying, so limits are not likely to be more restricting. So it certainly seems for this SAR crew, a task that requires a let down with say a 200ft cloudbase and 2000m vis, 2 miles offshore would be pretty straightforward stuff.

Given that, it seems extraordinary that approaching this refuelling stop at Blacksod was not a very straightforward task. Better weather, 5 miles of open sea south and 4 miles east, a sea level target with a big flashing light on top.

There's lots of finger pointing at a poor APBSS and this clearly had its inadequacies as the AAIU made Safety Recommendation 1 ref CHC route guides to essentially highlight obstacle risk and limitations of EGPWS. But then the APBSS (probably) included no transit heights which was therefore at the judgement of the flight crew. It was after all only described as a "route guidance". The associated notes and CVR briefings will add much needed clarity in due course.

Some have said it was negligent for there not to have been an IFR let down procedure for Blacksod. But whilst it would have been helpful, we come back to the point that these SAR crews are presumably spending much of their time making let downs that are far trickier - it is bread and butter to them - and they are highly skilled and trained to do it safely.

Ironically I'm sure it would have been far safer if this APBSS approach had never existed and the crew had had to make their own approach. It's existence probably lulled them into assuming it was a clear VFR route in so a standard 200ft transit was ok. Still doesn't quite add up with why the captain flew over what she said was a "small little island... that's BLMO (sic) itself". Odd thing to do at 200ft at night in poor vis. Maybe she thought BLKMO was more like 28ft than 282ft.

It is a pointless exercise trying to ascertain whether this operation was conducted under VFR because, unlike IFR, there is no firm basis for establishing compliance without reference to: the State's regulations; any alleviation/mitigation that applies to CIVSAR; the requirements of the SAR OM; and, the company safety culture under which the rule set is applied.

That is why in an earlier post, the comment was made that 'culture of SAR in the civil era needs a review'.

It is quite inappropriate to quote other State's operational regulations in this discussion because they are not universally grounded. The ICAO Annex 2 Standard states:
Each State provides basic rules and layers them for types of operation. For example:
...and the layering:
Very few States make a requirement for 'reference to a horizon' or 'minimum visual cue environment' - because it is extremely difficult to 'justify'/'show compliance' with such requirements.

With respect to this accident, it appears that the APBSS chart, in the absence of vertical and visibility limits, is based upon those that apply to CAT - i.e. formerly JAR-OPS and then EASA OPS (as stated in my previous post).

The US regulation does appears to provide a basic (and sensible) objective that should have been met:

However, there has to be a judgement on whether the 'see and avoid' condition applies to the more esoteric 'sense and avoid'. Clearly whilst flight over open seas in the presence of unexpected ships is relatively simple to address, the conditions (and probable assumptions) under which APBSS was flown, raises doubt.

When the PIC said that the BLKMO waypoint was still 1nm ahead, so this might bring a conclusion that the waypoint and the geographical feature were understood not to be co-located.
Yes, odd thing to do at 200ft at night in poor viz. What is more odd is that the other three people on board must have agreed with the plan without realizing the danger, or suggesting an alternative. Presumably in SAR a broad outline of the plan is discussed among the crew, a course of action is agreed, and then carried out. Rather than the PIC decree a plan and everybody else just obeys without giving it much of a 2nd thought. Again, we need to revert to earlier inter-crew discussion which we're not privy to.

gulliBell

You could be right ref that the PIC thought the feature and waypoint were not co-located, but I'm not so sure. They were actually over the rocks that triggered the ALTITUDE alert just 0.65nm before Blackrock, not 1nm. Might not sound much different, but if the PIC's map scale was set so that the whole route into Blacksod was showing (or even much of it) I think it could have looked close enough for her to think those rocks and BLKMO were the same. Of course many of us are looking carefully at the fine detail now, but if we assume the crew weren't aware of the major hazard of this approach, given they had 10nm to run they might not have zoomed the map in to see fine detail until nearing Blacksod.

Some care are must be exercised when quoting US FAR's re night VFR.

Part 91 applies to Non-Air Taxi Operations and Part 135 applies to Air Taxi Operations.

The Surface Light Reference applies to Paert 135 .

VFR weather Minima are visibility and ceiling....with Clear of Cloud applying to Rotocraft in uncontrolled airspace.

That there is no visible horizon or surface light reference does not enter into determining VFR.

Under the FAR's one can be in a situation where you are VFR but must control the aircraft solely by reference to instruments (Part 91).

Until a Victim is aboard the aircraft it may be operated Part 91 rather than Part 135......as many HEMEs Operator did for years......with dozens of fatal crashes to prove it.

VFR minimums
 

What are VFR night minimums required of this operation, the most restrictive of regulation, Operation Specifcation or by the operator? For example if the night VFR minimum for ceiling was 1000ft, then the IFR approach should have terminated at 1000' if VMC was not achieved and a MAP initiated. What is the sense of going to 200RA when the VFR minimum is much higher, and VFR is necessary for the 10nm flight from Black Rock to Black Sod?

I've been reading a lot of very good posts concerning the EGPWS and radar usage, but think the fact that VFR minimums and therefore proper VMC may not have been achieved, was a major contributing factor.

RotorheadS92: You have to appreciate that the questions that you ask are not really relevant. If you can operate IMC low over the sea (as you can when doing SAR in a helicopter) then there is effectively no appropriate VMC minima. At night over the sea you can't really be VMC in the same way you are overland with lit towns etc. It can just be inky blackness all around you.
However as others have said VMC helicopters is COCISS, and as the back seaters could see the rocks on the camera that means that they were VMC, but given that you can be VMC and still not see anything it's not really relevant.