EASA Proposals - Take Action Now!!!
 

People,

I've just received a letter from the Helicopter Club of Great Britain regarding a consultation process that might result in some significant , and adverse, changes to the way helicopters can operate in the U.K.

The proposals include the installation of ELT's, emergency flotation equipment for flights over water (including twins) and other items of equipment for flying at night.

All operators, regardless of whether we are owners, have an opportunity to reply and we must do so or we could be seriously affected if these proposals are implemented.

I have summarised the proposals on my blog which can be found here New EASA Proposals. Take Action Now!!!! .

Please take a look, download the letter from the HCGB and make your responses to EASA before it's too late.

Joel

Done!

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Well done!
Thanks :ok:

Joel

JTobias - please do not take offense at my comments but I have to disagree quite strongly with your post. Of course this is my own opinion and I am not saying everyone must agree, but I do not think you should necessarily be telling people to complain about these measures just because that is your standpoint.

By all means people should read and make up their own minds, and then if they feel strongly enough contact the EASA.

However, I believe all of these measures are a good thing, and a step in the right direction. I fly offshore and over water every working day and would not dream of flying without some sort of serviceable flotation equipment. If you are advocating to do so in order to save money is a good idea, then I will have to disagree. Your comment "even for twins" also I find rather naive. Do you believe the only reason for ditching is an engine failure?

I really cannot see why any sensible pilot could disagree with any of this. Night flying on a dark night with a pitot/static failure or AI fail on you is perhaps a far scarier prospect than you realise, and to advocate again that the use of back-up instrumentation at night is a bad idea is frankly insane.
Whilst you may be happy to fly in such a manner, would your passengers/friends/family, in the aircraft also be so happy to know that you can be so complacent about the safety of their lives. There are way too many helicopter accidents every year, so anything and everything possible should be done to make it safer. I have lost way too many friends in helicopter accidents, so any improvements in safety must be welcomed.
I for one will FULLY SUPPORT the EASA proposals, and I am truly sorry that this may cost you money, but if it prevents anymore accidents and fatalities it can only be a good thing.
This is not intended as a personal attack on you, but I merely seek to point out that people should take all the facts (not just financial), and make up their own minds.

Errr, that's going to make things rather expensive for people who need to do a night rating for their CPL.

Are those who want light touch regulation also keen on light touch SAR when all goes wrong??

I liked the qoutes on the website that made the good old British CAA (c1998) look like the saviours of GA. Is someone using Bernie Ecclestone's rose tinted glasses to look at history?

As I said on the previous thread on this subject; this is an important juncture in European aviation and you should be prepared at least to go to the web site and take a look at the proposal.

The HCGB do have some interesting points but have missed one thing that might have been highlighted; at the last major revision of Annex 6 Part III, a decision was taken to follow the FAA lead and separate out the SARPs for instruments into three parts: VFR day; VFR night; and IFR. EASA have not chosen not to make the same simplification - it would have made a difference.

There are two elements in the list provided by the HCGB which do need highlighting: the requirement for a second attitude indicator for VFR night has no precedent in JARs or ICAO - it is a mistake; the requirement for an alternative source of static pressure for VFR night is also an overkill - it is usually required only for flight in IMC.

For CAT pilots: good luck in trying to establish the exact requirements for IFR instruments, the combination of inheritance, four rules and many AMCs will test your resolve to the limit.

The requirement for 'ditching approval'/'floats' for all helicopters comes straight out of JAR-OPS 3 because the ICAO text for GA is:which was intended to take care of offshore operations conducted by oil companies with their own helicopters; or to provide flexibility for (relatively) short over-water transits to be permitted to GA by the State.

Providing a raspberry to EASA will not do the trick; in the case of flotation equipment, it might be pointed out to them that the Commercial Rules are not proportionate and are not applied to GA in any existing regulation (if that is correct). It might also be a good idea to provide the contents of the ICAO note to these two clauses:Jim

Stats?
 

Does anyone have any figures for how many helicopter flights are taken over the irish sea or the English channel every year with A/C that do not have floats? Also how many of them have to ditch. I can't remember any happening in the past few years. Where are the hard facts for this supposed increase in safety? It seems to me to be a restriction on people's freedom. I hate the fact that a faceless European institution it trying to reduce our freedom to fly.
Time to pull out of Europe and all the !!!! is stands for.

So does that mean it will never happen, or can never happen? Should we wait until a few people die in the sea first and a few very expensive SAR missions are deployed before we decide floats are a good idea?
Freedom to fly is fine as long as it is not unnecessarily endangering others or restricting their rights. You have the freedom to fly as long as you fly responsibly and in accordance with the relevant regulations, whether you agree with them or not. Far too many SAR aircraft are scrambled due to people essentially not taking proper precautions, and being prepared with respect to basic safety, and this is not just applicable to flying. This is an unnecessary cost both in monetary terms and in terms of the safety of crews who are going to come out and try and find the hapless individuals, who are expecting a pick-up when all goes wrong.
Freedom to fly is fine - but it is not free, It has a price, an that is responsibility. We must always consider our actions and ask "what if?"
We used to drive around in cars without seatbelts and airbags, but now that is unthinkable. We eventually realised how much this was costing the health services, and forced change. Agreed - a different scale, but the principle is the same.

What?! Have you any idea of the tiny profit margins in the flight training business?

I know it's safer to have all this extra equipment on public transport flights, but for doing a 5 hour night rating in a single-engine piston heli? Give me a break...

I (and others) still can, quite legally, in the UK. The Government did not require retro-fit of seatbelts, fog-lights and other "safety" items. And that is also a matter of principle.

This proposal does require retro-fitting of equipment which, as has been pointed out, is not feasible for smaller aircraft, whether or not a commercial flying school has to pay for the fit.

If we legislated for every possible accident, would we ever be allowed to get out of our beds? :}

Cheers

Whirls

warning sarcasm, disdain and anger follow
 

I know that name calling will not help my argument but I can't help thinking you are an arse.

People like you amaze me. If you think flying is so very dangerous don't do it. Go home wrap yourself in cotton wool and call your life over right now because in effect you are saying that people are not able to judge risks for themselves. I am a climber. I go out and climb up steep rock faces and sometimes even ice and snow and God forbid I sometimes do it in bad weather. People like you would ban me from doing if it looked like it might rain or if I didn't have the right qualifications. People like you are trying to kill me before I'm dead. I despise you and your arguments you are trying to create a world of the living dead. Time you hung your wings up and buggered off to a nursing home where people will make sure everything is safe for you.

Every one has a level of risk he\she will take,the problem is that there are others that think they should be making that decision for us, personally I would take a beacon, and wear a life vest if going over sea, as to the floats big decision, maybe if I flew over sea every day, as for the other instruments, light, for night flying jury out I don't, would have another look at my risk factor, if I did, at present playing with another control could prove riskier than fixed lamp.
If I was taking money for a flight yes I would expect a different level of safety, which I would expect to pay for on the hire cost.
Whirly & CDoc are both on the mark does the risk warrant the cost to the industry \ private flyer.
Left comments what a nightmare site, still they are trying to grow the empire I suppose:E

i don't see how that is totally relevant to the argument. If an aircraft does goes down in the water, SAR would attend whether the aircraft had floats or not; because the occupants would still need rescuing.

Is there a similar set of requirements being made for fixed wing?

Horror Box

Thanks for the reply. However, to a degree, your'e shooting the messenger.
All of the comments on my blog are made by the HCGB not me. I am simply regurgitating them. I do however fully agree with their viewpoint, which is why I put the post up.

In any case, although it's probably perfectly clear what my position is, I haven't told readers how to reply, just that they should consider the proposals and make a comment.!

as far as your comments are concerned, if you are flying offshore regularly in a commercial capacity, then I think you should have as much protection as you can get - floats or otherwise. However for most operators the requirement to install all of that equipment is simply un-necessary. I fly over the water 3 or 4 time each year and I don't want to have my ability to do this restricted.

I'm perfectly capable of accepting the risk and in terms of floats, there not going to have that much effect if I have a problem over water. Yes it would be great to have them but to insist on them with absoluteley no justifiable reason is preposterous. With respect to you (and I have no doubt you are a far more experienced pilot than I am) you (probably) aren't picking up the bill for your machine. And before you say were all putting finance before safety, were not. It's simply not a proportionate proposal.

There is every possibility that when I'm driving down the motorway in the fast lane I may have a blow out, but I don't have a double set of wheels at each corner of my axle.

I appreciate your comments, but these proposals need to be proportionate.

Joel

The new Bell 429 doesn't have a steerable landing light, but has a two-angle main landing light, and better lighting to the side than any other helicopter I've ever seen - does that meet the intent of the proposed new ruling????

Whirls fair lady......accidents can happen in bed too!

Thank you for this well put argument, it really adds to the quality of any debate! I hope no one I know is ever anywhere near you or your helicopter, and that you are not as unprofessional in your approach to flying as you appear through this post, because you are a bloody liability. I am afraid it is people like you who will give helicopter flying a bad name, and frankly it is better off without you. Whilst I can see and agree to a degree with the points others have made, I still think it is worthy of sensible discussion, something you have clearly already dismissed. :=

Yes - but an ELT will make it a hell of a lot quicker and easier.

Chopper Doc... I'll fly with you anytime...

perspective
 

Joel (and others),

I fully support your position- and the HCGB's stance.

It's about risk, and in particular risk management.

Like you I go across to Europe a lot, and I've been over the Alps 7 times this year, and to Denmark 5 times in the last 18 months.

These flights tend to start from various different places in the UK, including Belfast, and it would be quicker to head directly across the North Sea from (say) Norwich to (say) Holland on some of these trips.

But I chose to take the shortest route (basically Lydd to Cap Griz Nez). The risk exists, but I choose to minimise it.

Equally, over the Alps I select the lowest passes practical (still between 8,000 and 10,000 ft by the way), and try to fly where the ski slopes and villages are located just in case something goes wrong.

And I've bothered to go out and buy a new McMurdo PLB, and I wear a life jacket. In all weathers other than exceptional heat, I wear as many clothes as practical. Ok this isn't as good as an immersion suit, but if you do ditch, the more layers of clothing you have the better chance of survival you have.

I always take some water and a little food just in case we are stranded somewhere remote overnight.

In my view, the focus for flight safety in this ELB, mandatory floats, extra instrumentation and more engines has gone way off the mark.

The focus should be on making helicopter flying more accessible to those who want to do it, and thereby improving their skill levels so that they can cope with their in-flight conditions.

I don't have the stats to hand, but I'll bet you a pound to a penny that deaths due to weather conditions, including all "controlled flight into terrain" are way WAY higher than the number of deaths from exposure - be it on the side of a mountain or bobbing around in the English Channel - after a survivable forced landing.

To echo other's comments, ultimately it is a personal choice as to where your risk acceptance level lies. Private pilots do this for fun, it is not their job. If the conditions are beyond their capability, they can choose not to go, or land if the conditions deteriorate.

Owners see a helicopter as simply a mode of transport that enriches the quality of their lives, and they are quite right to want to lobby against badly thought out, and unworkeable, plans that will not make a jot of difference to the accident statistics.

Big Ls

Dear Horror Box,

After I asked if anyone had stats regarding the safety of private helicopter flying over the English Channel and the Irish Sea you jumped straight in to say that an accident is bound to happen and yes if you wait long enough the chances are that everything that is possible will happen. However if the probability is low and people are willing to make a risk judgement then how dare you take away their freedom to do so.
Some of the measures being proposed ie emergency flotation gear are complete overkill for private owners. They will not aid safety and may in some pilots engender the belief that hey they will be ok because they have floats. It is just a very expensive modification that will be of benefit to next to no one. So it comes back to are you willing to risk being that one. If you are not then you probably already have a helicopter with floats or you won't fly over water anyway.
The long and short of it is EASA should keep it's nose out of it and allow pilots that are not flying for hire or reward to make their own decisions regarding the safety measures they deem appropriate.

I am a baby pilot, and this is my opinion. I will shortly be undertaking CPL flight training, and much of my time recently has been engaged in finding ways to reduce the cost. I am entirely self-funded, and have been from PPL onwards - no bursaries, no military training (not from lack of trying), etc. I am fortunate that I have a first career which pays enough to do this, and a partner who doesn't mind making sacrifices, but that doesn't mean I'm swimming in cash, or that it isn't a struggle. I agree with the sentiment behind these proposed regulations, but the implementation seems wrong. Ultimately, people who don't care about safety will ignore the regs anyway, and the law-abiding majority will take the hit. I would like to think that anyone flying any distance over water would carry an ELB and wear life-jackets, and seriously consider fitting floats to a machine that regularly flies over water. Certainly, for CAT, where there is a provable link between an additional safety measure and increased survival, mandate it. I plan to do my CPL in an R22, because that's what I'm familiar with, and that's what I can afford. If I need to do my night rating in an aircraft with a pitot heater and extra AH, plus a bunch of extra mods, who do you think will be paying for that? The school? Of course not, it'll just make my per-hour costs that much higher. It's likely that fewer people will be able to afford training, and the average age of new pilots will increase. I'm guessing overseas schools will benefit, too. If these proposals were accompanied by plans to ease the extra costs, I suspect people would be far more supportive. More safety is good, but it has to be an informed trade-off. Nobody forces me to train in a R22, I weigh up the risks and benefits, then vote with my feet. Just like those who choose to ride motorbikes without helmets (in theory), I know the risks and accept them. Mandating common sense just removes the ability for most people to make sensible decisions.

Agreed (I used to fly SAR). The type I fly these days already has one as standard fit. But, having any equipment fitted doesn't prevent it ditching in the first place.

I agree with Pandalet. These proposals are overkill for night flight training.

We've already seen the loss of the cheaper 'single engine IR route' in the UK, the requirement for a twin type rating to be held to sit an IR test (£10,000 down the toilet for most people), the daft "3 year ATPL exams expire" rule. All these regulations are just not suitable for helicopter training because of the horrendous costs involved.

It's all very well to sit there and say "these rules will make aviation safer", but I bet if you're the other side of the fence, struggling to afford a CPL, or an IR, or a night rating, you wouldn't be saying that.

Increasingly training to be a professional helicopter pilot in the UK is the reserve of the well-off (or rich parents), or ex-mil. That's not right.

The problem is the people that dream up these rules are are either admin bods/politicians/EU bods who just look at the fixed wing requirements and apply them to helicopters, or they are people in the "old boys club" of aviation who never had to spend a penny on their training.

If we are not careful, in five years time there won't be a flight training industry in the UK. (Then again, that's probably what the CAA secretly wants)

to the Controller
 

The irony about the floats-across-the-water proposal is that it only applies to helicopters, and not to Cessna 152s, C172s and all other fixed wing aircraft.

I'm reasonably confident that to glide to the other side of the Channel you'd have to go very, very high in a Cessna, and I doubt if anyone would do this anyway.

And there's no chance if you are going from the UK to the Channel Islands, the Isle of Man, Ireland.

It goes to prove two things:

(i) the proposals are not applying fixed wing rules to rotary
(ii) the proposals are completely inconsistent regarding flight safety

Whether they are plain daft or not is a matter of opinion, of course.

As for CAA not wanting flight training, nothing could be further from the truth.

I work with a new flight training academy that teaches PPL(H), CPL(H), distance learning CPL(H) ground school courses, IR, IRI and MCC courses.

Therefore we have quite a lot of contact with both the CAA and EASA and they are very keen to see the industry of flight training grow here in the UK.

It's up to us - not the CAA - to try and attract customers to the UK from all over the world, and to ensure that we offer quality, service and world-class standards to the next generation of PPLs and CPLs.

Big Ls

I also support the HCGB stance.....If you fly an R22 or similar ,you cannot fit floats and would have to detour just to fly from Bristol to Newport ,whilst the Isle of Wight would be out of bounds.Also where do I put the liferaft?

The point..... well made by others.... is for pilots to evaluate the risk...wear lifejackets and take a PLB ( a lot more useful than telling the rescue services where your sunken helicopter is !).

Almost nothing in the proposals makes practical sense ,none of it is borne out by the historical accident record and it is just going to cost private pilots a whole shed load of money ,and in some cases ground the aircraft because they cannot economically comply.
If you read the HCGB respones you will see a very well argued case ,with practical alternatives suggested and as many people as possible need to write with similar views.
Incidentally I found the circuituos comments route quite difficult to navigate and instead sent separate e mails ,quoting the relevant NPA numbers ,to the npa easa address.
It obviously worked as I got an acknowlegement.

Of course they are; more money and jobs for them!! :}

Cheers

Whirls

Sorry to be a pessimist but it ain't going to happen (£300+ for an hours training in an R22 anyone?). The UK is just too damn expensive for helicopter flight training. It's the preserve of 'mid-life-crisis PPL businessmen'.

You'd have to be an idiot to go all the way from zero to CPL/IR in the UK (£120,000+ ?)

I think ATPL UK distance learning is a growing market though.

These proposals largely affect private flyers - and methinks this Forum is not the best place to look for sympathy.

That argument doesn't appear to have been applied to the private maritime community who still happily sail or power into the seas with no licensing necessary. I think you'll find that they've cost SAR a lot more than private aviation. However, surely you want SAR to be busy - otherwise your state-funded bean counters will be closing you down ?

Not really. A fixed ELT will be utterly useless once the helicopter has either (a) sunk or (b) turned turtle on its floats in anything other than a mild swell (unless you mandate ELT antennae on top and bottom of the machine.) And, as made clear by HCGB, a good smooth auto onto water will not automatically light-up a fixed ELT.

A Personal locator with a crew member wearing a lifejacket would seem to be a more reliable method of actually saving lives, rather than finding an empty helicopter.

However, my new McMurdo has some interesting "facts" in the small print. The new 406 technology can mean a 45 minute delay in getting the signal through (whereas the old VHF was instant), the unit doesn't float (!), and the antenna needs to be clear of water. Brilliant.

Here here, but and its a big but, for a significant portion of the year around UK shores a life jacket and plb will do nothing but enable location of your superchilled corpse if a survival suite is not being worn.

The proposed changes are half baked, if floats are deemed necessary, surely life raft and/or immersion suites are critical items as well? Or do we expect a perfect emergency landing in seas calm enough for passengers to remain tucked inside the cockpit until rescue?

What is missing is a range of comfortable(!) immersion suites that don't necessarily need to combat north sea temps in winter for an hour where 30 minutes survival from Feb to September would cover most GA movements.
4 x immersion suites +4 PLB are more versatile cheaper and better than floats?

Last time I enquired the cost of a daily use lightweight immersion suite designed for helicopter crew with a zippered neck was around £1000.

Mickjoebill

Are these NEW?
 

Are you guys telling me you haven't had the requirement for alt static, movable light and pitot heat previously in the UK? When I took my PPL(H) back in 1993-96 it was all required.

Mickjoeb,

SEMS will sell you a very decent Aerosafe Hyperdry suit for less than £300 and you can rent them for about £40 a day.

Even a Civilian TOFS (Typhoon) suit is only £389 net.

No thanks. :eek:

Risk management? I'd risk the extra £260 for a nice new one :}

Cheers

Whirls

The ones we've always received for rental have been new - in any case I can't imagine that SEMS would rent out anything that might even be slightly scuffed. And how do you know that one you bought, say, a year ago is still waterproof ? Foxes, apparently, get some sort of sexual high from chewing rubber & neoprene. They sniff it out. Random thought, maybe ! But that's why we've had to replace all outdoor rubber-sheathed cabling with PVC.

They also get a kick from leather! Must tell you about my neighbour whose home was invaded via catflap whilst on holiday. Shoes, handbags & leather sofa all attacked. And some "interesting" stains.

Enough.

We can add as many things as we can think of for every possible scenario and claim a increase in safety because we now have all the floats, elt's standby systems, liferafts etc. I am just wandering whether we are not getting to the point where all these safety equipments for a possible but rare incident are not ensuring the incident will occur sooner than later. Why? These things does not weigh nothing. Everything added to a helicopter decreases it's safety margin as it requires more and more power every flight causing more and more wear and tear at a much faster rate than anticipated. I am not just referring to engines here but blades having to cone twice as much, pitch link bearings being under permanent max loading, swashplates buckling under the aerodynamic forces as the scissors slowly starts wearing away, gearboxes and their mounts having to absorb max torque leading to TGB and blades etc, etc, etc. How many helicopters(twin and/or single) can take all this equipment and still allow the pilot sufficient payload to ensure a power margin and sufficient fuel onboard?

Once we fitted all the new safety equipment, how long before the next additions are added as we think up more scenarios? Soon the closest we will get to flying singles AND light twins will be a ground run on the helipad as they just will not take off.

Victor papa,

Do we understand you to say that it is unsafe flying these machines within their design envelope?

On what basis do these aircraft obtain their type certificate?

Mars, all helo's are safe within their designed specs. Where all of these safety equipments part of their designed/Cat A specs at the time of certification? That is my question. Everytime we add something afterwards in the interest of safety are we not getting to the point where we are comprimising safety with all the extra safety equipment demanded and putting the original design under pressure? Take a 105. Certified plenty years ago, will it pass Cat A today with all these extra safety equipment regarding MAUW?

SAS loving dangerously again I see
Sorry "living"

Victor papa,

You appear to be calling into question the basis of Supplemental Type-Certificates; you need to go back to Part 21 and re-read Subpart E.

We all know EC's stance on STCs but trying to stop the practice is a Canute like gesture (he tried to command the tides). Perhaps more effective control is necessary but that is a matter for standards and not the basic code - and has nothing to do with operational regulations.

Any STC that effects airworthiness of the aircraft will be assessed against its certification basis. The function of that assessment will be to address those issues raised in your first post.

The BO105 was never certificated for CAT A; it gets its operational approval by virtue of compliance with alternative criteria. All aircraft must be operated within their MAUM - not to do so would invalidate the C of A.

By the way, Perfrej is absolutely correct; there is nothing new in the proposed requirement for landing lights for UK registered aircraft - they are already required under Schedule 4 Scale G(5) and (6) of the ANO.

The reference by the HCGB to ICAO SARPs is not correct; the Standards for GA are addressed in Annex 6 Part III Section III - they are not the same as those for CAT. That EASA has chosen to apply a CAT Standard (for floats) to GA is a matter which can/should be commented.

Making outrageous public statements serves only to discredit the forum.