npa-ops 38 crd helicopter performance adopted at jaac 06-4 nov 06

NPA OPS 38 (JAR-OPS 3) Helicopter Performance & Miscellaneous Items

JAA LO of 203 31/01/07 Adopted at JAAC 06-4 Nov 06

NPA-OPS 38

(JAR-OPS 3)

Helicopter Performance &

Miscellaneous Items



EXPLANATORY NOTE PREAMBLE It was agreed at OST 05-1 that this proposal should be progressed as far as the post consultation review by OST and RST. It would then be held until the associated ICAO Annex 6 Part III amendment was finalised, before being adopted by the JAAC. It was also agreed at RST 05-1 that when reviewing the NPA, post consultation, the RST should pay particular attention to its compatibility with ICAO.

Following the public consultation period, the resultant CRD and final text proposals were reviewed at OST 06-3 June 06, where OST fully supported the plan for CJAA, HSST and EASA to review the NPA, before RST review. The NPA was then reviewed by CJAA, HSST and EASA before final review at RST 06-2 Aug 06, where the following recommendations were made by the RST Chairman:-

• Agree to submit NPA to JAAC for adoption provided that text on end of page 30 under (4) HEMS dispatch centre will be revised and on page 38 in para. 3.480 be rephrased.

• No need for 2nd consultation.

• Do not wait for ICAO, progress NPA...

INTRODUCTION

1. When JAR-OPS 3 was initially adopted it was accepted that further amplification of the document in detail would be necessary, and it was expected that user experience would also indicate areas of the document which needed alteration or improvement. At the time of adoption of JAR-OPS Part 3, the Helicopter Sub-Committee (HSC) of the Operations Committee (now respectively the Helicopter Sub-Sectorial Team (HSST) and Operations Sectorial Team (OST)) had a number of outstanding issues for further consideration, and both Authority and Industry representatives have since then promoted additional tasks. Thus inevitably JAR-OPS Part 3 will be the subject of continuing evolution and development. 2. The first package of new proposals for JAR-OPS Part 3 was distributed as NPA OPS-8 which resulted in ‘Change 1’, published on 1 February 1999. This also included NPA OPS-9 dealing with a postponement of the applicability date. The second package of proposals was NPA OPS-18, which addressed a number of important items raised as a result of implementation problems which resulted in amendment 2 with an applicability date of 1 January 2002. The third package of proposals was NPA OPS-27 and contained two elements: the first was ‘helicopter-specific’ proposals which result from: minor implementation problems; amplification of rules such as FDR/CVR; and changes made necessary as a result of revisions 5, 6, 7 and 8 to ICAO Annex 6 Part III and the second, a number of items already incorporated into JAR-OPS 1 such as CRM and occurrence reporting which could be seen as harmonisation issues - these resulted in amendment 3 with an applicability date of 1st April 2004; this also included NPA OPS-31 dealing with the revision of the Public Interest Sites appendix.

3. NPA OPS-38 is the fourth ‘package’ of proposals dealing with JAR-OPS 3 (Commercial Air Transportation – Helicopters) and it is made up of two elements:

3.1 The first element contains a small number of items that have been found to have caused implementation problems or result from a recommendation following an accident investigation;



the incorporation of proposed changes should have no detrimental effect upon safety. Each is discussed in detail in the proposal section.

3.2 The second element, and main part of the NPA, is concerned with performance, and results from:

3.2.1 Issues that were raised in NPA 27 but for which further development was required; NPA OPS-27 proposed: the adding of the definition of the take-off-flight-path which, although used in Subpart G and H, had never been defined; and changes to the requirements in Subpart G - Performance Class 1, to clarify the obstacle clearance criteria. Comments received during the NPA process indicated that, although the proposed changes were supported, they did not go far enough and did not show a clear distinction between obstacle clearance resulting from Certification of the Category A procedure, and clearance from obstacles resulting from the application of HFM data (at the site of the arrival/departure) by the operator.

3.2.2 Discussion on performance within the ICAO Helicopter and Tiltrotor Study Group (HTSG); continuing work in this Study Group has resulted in clarification of the intent of ICAO Annex 6 Part III, Section II, Chapter 3 and Attachment A. This clarification has permitted the requirement for Performance Classes 1, 2 & 3 to be simplified and guidance to be further expanded (see also paragraph 3.2.6 below)

3.2.3 A request from manufacturers and industry that exposure be extended to ground level take-off and landing (in NPA 8, exposure had been limited to elevated heliports and helidecks):

3.2.3.1 Prior to NPA OPS-8, all performance procedures were intended to meet one of two requirements: engine failure accountability; or a safe-forced-landing. NPA 8 introduced the principle of exposure to an engine failure where, for a very short period in the take-off or landing phase, the consequence of failure could be accepted providing that the probability of failure was low - the safety target being set to 5 x 10-8 per event. Assessment of the risk involved a comparison of the reliability of the engine/helicopter combination against the duration of the exposure period in the take-off/landing event (as exposure was only approved for elevated heliports/helidecks, the risk was limited to the deck-edge strike and, the time to reach the knee of the HV diagram (for singles) or Vstayup (for twins)).

3.2.3.2 During the period since the incorporation of NPA OPS-8, manufacturers have reported that the core reliability of turbine engines used in helicopters is in the range of 0.3 x 10-5 to 3 x 10-5 per flight hour. When these are combined with failures including: operational causes; maintenance causes; and non-core causes, the average failure rate rises above 1 x 10-5 per flight hour (this figure was established in a recent assessment of engine failure events in the UK using the MORs data-base; it should be noted that failures such as a loss of lubrication or a precautionary shut down - which would have had no impact during the duration of any take-off or landing phase - were not included in the computed failure rate.) However, there are a number of mitigating procedures which can be (and have been) put into place to bring the failure rate down to the more acceptable rate of 1 x 10-5 per flight hour, these include: the coating of compressor blades and inspection routines to reduce or eliminate failures due to corrosion; the installation of Usage Monitoring Systems (UMS) to monitor, and in some cases eliminate, the hot end events that might lead to turbine bursts (the most common of which is the hot start); the trending of engines for power assurance; and the careful monitoring of operations to reduce adverse environmental factors. With a reliability rate at or below 1 x 10-5 per flight hour, exposure to an engine failure in the take-off or landing phases (to the previously specified target of 5 x 10-8 per event) can extend to about eighteen seconds for a single and 9 seconds for a twin. 3.2.3.3 It is postulated that if the reliability rate of 1 x 10-5 per flight hour can be attained and maintained, the principle of exposure could be extended to ground level take-off and landing phases without increasing the risk beyond the specified safety target (5 x 10-8 per event).



3.2.3.4 The proposed changes to the requirements and, in particular, the bounding of the take-off and landing phases in Subpart H and I, should ensure that the safety target continues to be met. 3.2.4 A request from manufacturers and industry for simplification of the approval process for operations with exposure:

3.2.4.1 The acceptance of ground level exposure in the take-off and landing phases for up to 18 seconds reduces the need to specify alternative take-off and landing procedures (a source of additional cost for manufacturers), and existing take-off/landing procedures may be used (providing they can be conducted within the eighteen seconds (for singles) or 9 seconds (for twins)).

3.2.4.2 As a result of Authority comments on NPA OPS-8, extensive precautionary procedures were added to the rule material - these included: statistical methods for ensuring high confidence levels in the assessment of reliability; prescriptive rules for the establishment of procedures for take-off/landing; and prescriptive rules for the implementation of UMS and associated systems. In the period that exposure has been accepted, no increase in take-off or landing accidents has been observed: this has resulted in a request from manufacturers that elements of the existing procedures be relaxed.

3.2.4.3 The working party, in taking note of this request, are mindful that (as an example) the extensive prescriptive requirement for UMS has resulted in delayed fitting of this equipment to some fleets as compliance checking for certification has proved to be time consuming. It is proposed to move from a prescriptive to an objective requirement for UMS and place the compliance text in guidance - this should lead to a reduction of bureaucracy and a concomitant reduction in the time to take-up of this equipment (which can save the cost of installation by the elimination of a single hot start). The same is true of regulatory monitoring - replacement of the prescriptive text by guidance will give necessary leeway to Authorities in the acceptance of operators’ procedures.

3.2.5 Reduction in complexity of the rule text:

3.2.5.1 Performance Class 1 (PC1); on examination of the text contained in the take-off and landing rules it is observed that, as Category A manoeuvres are well described in the HFM, a generalised and more objective text can be used. It is also observed that, as the area in which obstacles have to be taken into account is identical for a number of rules, it is appropriate to place this text into Subpart F and refer to it; the same is true for environmental conditions (such as wind) and it is proposed to deal with this in the same way.

3.2.5.2 Performance Class 2 (PC2); is defined in ICAO as all-engines-operating (AEO) obstacle clearance in the early stages of the take-off (and late stages in the landing) and one-engine-operative obstacle clearance from a defined point. In view of the fact that once the defined point has been reached, the helicopter has to meet the same requirements specified in Subpart G - PC1, the text for ‘take-off-flight-path’ and ‘en-route critical power unit inoperative’ does not need to be repeated, only referenced. This permits a removal of duplicated text.

3.2.6 The requirement for additional and clearer guidance; It has long been recognised that helicopter performance is a complex subject which has relied on its derivation from fixed wing. Definitions and requirements that have been produced to account for the relative simplicity of runway operations do not deal adequately with the flexibility of the helicopter. As well as proposing a revision of take-off-distance required (TODRH) (the amendment of which deals with the unexceptional issue of obstacles on (the equivalent of) the runway) and including the definition of ‘take-off flight path’, there was a perceived need to produce descriptive guidance (words and diagrams) to illustrate principles that are specific to helicopters - particularly for non-runway operations. The guidance that is proposed is contained in Section II material in Subparts F, G, H and I, with the largest treatise (ACJ to Subpart H)) being a full description of the



derivation and application of Performance Class 2. Guidance on the application of take-off-distance-required (TODRH) is in Subpart F; alternatives to Category A procedures for helicopters with one-engine-inoperative (OEI), hover-out-of-ground-effect (HOGE) performance (to ease the problem of small take-off and landing surfaces) is in Subpart G; and the application of ground level exposure in the take-off and landing phases is in Subpart I.

4. This paper is divided into two parts:

a. This introduction which provides an overall view and an explanation of the proposals and/or the reason for the proposal; and

b. The proposed amendments, some of which amend existing text and some of which are new. As is common with NPA proposals, the proposed changes to the current text are shown by strikeout for deleted material and by bold italics for new material indicating the intended new wording. (Where a full rule or full guidance has been deleted, it is not always repeated in strikeout form.)

PROPOSALS 5. The following paragraphs contain the explanation for each proposal. As with the NPA material, it is subdivided into the relevant Subparts of the JAR and, for ease of reference, each proposal in this Explanatory Note has the Subpart letter/item and JAR-OPS reference and title. Each letter/item number reference points to a single proposal in the ‘package’ of proposals. All proposals related to a particular JAR number are grouped together in each Subpart irrespective of whether they are intended for Section 1 or for Section 2 of JAR-OPS Part 3. SUBPART B B.1 ACJ to Appendix 1 to JAR-OPS 3.005(d) subparagraph (a)(4) HEMS Flight. Although the definition of a HEMS Flight is precisely dealt with inside ‘Terminology’, there has been confusion about elements of the flight that comprise the whole HEMS Mission. On a number of occasions, a HEMS helicopter has been stranded at the Operating Base with insufficient fuel for a further HEMS Flight because it had been considered that a sector to refuel would not have been permitted under the auspices of the HEMS Flight. This ACJ provides guidance on those sectors that may be considered to be part of the mission.

B.1.1 It is not expected that there will be any financial or regulatory impact resulting from this proposal.

B.2 JAR-OPS 3.005(j) - NVIS Operations. Comprehensive guidance for Night Vision Imaging Systems (NVIS) is contained in TGL 34. It is anticipated that NAAs will approve any such operations in accordance with the guidance contained therein and enter the scope and limitation of NVIS operations in Section E – Special Authorisation/Approvals, of the AOC. The new rule specifies that operators are to have an Approval before operations can be conducted.

B.2.1 The use of this equipment is new in Commercial Air Transport operations; although the provision of equipment will be at a substantial cost to the operator, for HEMS alone the safety benefit and, for some States, the potential increase in operating hours, provides an opportunity to bring substantial benefit to the industry and the public at large. The use of the equipment is not mandatory and the cost for industry will have to be balanced against the potential benefits. The approval process is not expected to add to the costs to industry and it is not considered that there will be any financial or regulatory impact resulting from this proposal.



B.3 Consequential amendments to references in existing text as a result of performance proposals (and NPA 31):

B.3.1 Appendix 1 to JAR-OPS 3.005(d) paragraph (a). Remove the definition of ‘D’ - which has been replaced to Subpart F.

B.3.2 Appendix 1 to JAR-OPS 3.005(e): Paragraph (c); amend reference in (1) and (2) to correctly point to the new applicable paragraph in JAR-OPS 3.520(a)(2) and 3.535(a)(2); paragraph (d); amend reference at the end of the paragraph to point to the correct paragraph in Appendix 1 to JAR-OPS 3.517(a).

SUBPART D D.1 JAR-OPS 3.330 Accessibility of emergency equipment. After a recent ditching accident in Monaco where a passenger drowned, it was noted by the accident investigation bureau that survival may have been enhanced if a lifejacket had been worn. In conditions where a flight is taking place overwater in a non-hostile environment, it is extremely difficult for a regulator to specify when the wearing of a lifejacket becomes a critical element and might save the life of a passenger. It is proposed to make the operator responsible for establishing procedures to ensure that, for a helicopter operating in Performance Class 3, when conditions are such that - following a ditching - capsize is likely to occur before the lifejacket can be donned, it is worn and not just carried. (It should be noted that for offshore operations in support of oil, gas and mineral exploitation in a hostile environment, constant wear lifejackets are already required.)

D.1.1 This equipment is already required to be carried; the proposal is aimed at reducing the risk of flight over water where conditions indicate that there might be a problem fitting the lifejacket and then exiting the helicopter following a ditching. The cost to the industry will be mainly for the amendment of operations manual procedures - which might already contain this type of instruction for pilots. The increase of wear and tear on the equipment should not result in a reduction in the life of the equipment but, as has been shown in offshore operations in the North Sea, control of the passengers to ensure that they remove and stow the lifejackets before leaving the helicopter will have to be considered. It is not considered that there will be any substantial regulatory or financial impact resulting from this proposal.

• Who is affected? Operators who conduct PC3 operations over water.

• Impact on affected parties? Operators will have to develop procedures in their Operations Manuals and pilots will have to consider the application of such procedures.

• Impact on authorities resources? None.

• Hazards to be addressed? The time taken to locate and fit a lifejacket in conditions where the helicopter is prone to immediate capsize - following a ditching.

• Effectiveness of the proposed measure? The proposed measure should permit the operator/commander to consider procedures that will eliminate unnecessary drowning.

D.2 JAR-OPS 3.426 - Reporting of Flight Hours. The requirement of JAR-OPS 3.420/425 to report incidents and accidents is consistent with ICAO Annex 13, and is a link to a standardisation of incident reporting through ECCAIRS. However, statistical analysis to consider event rates per flight hour is difficult when the reporting of actual flight hours is poor or inaccurate. Headline rates of incidents and accidents are of less use to the regulator/industry than rates tied to an appropriate number base; the proposed collection of flight hours will permit comparative analyses to be carried out. As a secondary benefit, the provision of usage data will permit Authorities to establish statistics which should provide verification of the positive impact of operational and maintenance procedures imposed by JAR-OPS - thus closing the audit loop.

D.2.1 It is understood that the recording of annual flight hours is normal practice for operators in larger States and this requirement will not add to the bureaucratic burden. Analyses, when undertaken by Authorities, permit a more considered treatment of accidents and incidents;



extension of collection to States where data is not presently available might permit a European wide view and improve the significance of statistics where, because of the present amounts of data, there is a possibility of skewing. It is not considered that there will be any substantial regulatory or financial impact resulting from this proposal.

• Who is affected? All operators.

• Impact on affected parties? Data will have to be collated and retained.

• Impact on authorities resources? No additional resources will be required - unless such data is not at present collected and collated to provide accident/incident rates.

• Hazards to be addressed? The inability to provide quantitative analysis in order to establish and audit the effect of safety oversight.

• Effectiveness of the proposed measure? The proposed measure could provide a powerful audit tool for Authorities to measure the effectiveness of operational procedures. Aggregation of data between States will improve statistical significance.

SUBPART F F.0 The proposed revisions to Subpart F described below, are intended to improve the text by more clearly describing requirements; this is made possible by better understanding - gained since the implementation of Performance in the first edition - and the acknowledgement of current practice. It also signals a policy of bringing all general performance requirements into Subpart F. Terminology is improved by providing acronyms that are more clearly indicative of helicopters. Where a new definition has been provided or an existing one amended, it is because there was seen to be a gap in the present text. Except where specifically shown it is not considered that there will be any substantial regulatory or financial impact resulting from the proposals in Subpart F.

Except as otherwise indicated in subsections below:

• Who is affected? All operators.

• Impact on affected parties? No significant impact - improved understanding.

• Impact on authorities resources? No additional resources will be required.

• Hazards to be addressed? An improvement in the understanding of the issues of performance.

• Effectiveness of the proposed measure? The proposed measure could facilitate improved understanding of performance.

F.1 JAR-OPS 3.470 Applicability.

F.1.1 In JAR-OPS 3 Amendment 2, a helicopter with a Maximum Approved Passenger Seating Configuration (MAPSC) of more than 19 is required to operate in PC1. This requirement was based on the understanding that this class of helicopters would always have engine failure accountability. For a number of technical reasons, mainly concerned with the deck size and the helideck environment (both obstacle and wind related), it is not anticipated that operations in Performance Class 1 to helidecks will be technically feasible or economically justifiable in the foreseeable future (one engine inoperative, out of ground effect hover would be an acceptable method of compliance but this could result in a severe restriction on payload/range) and it is considered that the exclusion of this class of helicopter from helideck operations is no longer justified.



F.1.2 It is proposed to remove the restriction and permit operations - to helidecks only - on the basis of an Approval to operate with exposure under the conditions required for enhanced PC2 (enhanced in the sense that zero exposure should be the norm). The conditions under which these operations are permitted is set out and explained in the justification text in H.2 and H.3 below (and further explained in paragraphs 7.4.2 and 7.4.3 of ACJ TO Subpart H contained below).

F.1.3 Although it is accepted that the level of risk inevitably increases with the introduction of this alleviation, the exposure will be in the range of nil to limited, constrained to operations to helidecks and extend only to obstacles around and just below the helideck: it is likely that, with the additional performance requirements of PC2e, overall exposure will be well within the safety target discussed previously. At this time there are no helicopters that fall within the scope of this alleviation although it is not improbable that they will be introduced to these operations in the future.

• Who is affected? Any operator who is considering operations to helidecks with a recently certificated helicopter having a MAPSC of more than 19. These helicopters are presently denied access to helidecks in spite of their ability to operate to standards equivalent to PC1. At the time of proposed change, there are no helicopters operating to helidecks with more than 19 passengers.

• Impact on affected parties? Facilitation of operations to helidecks by helicopters carrying more than 19 passengers.


• Hazards to be addressed? The effect of the apparent reduction of the operational standard from PC1 to PC2e of modern powerful helicopters when operating to helidecks.

• Effectiveness of the proposed measure? The proposed will only be effective if more modern helicopters are utilised in the carriage of passengers to helidecks.

F.2 JAR-OPS 3.475 General. Presently contains an objective statement on the account to be taken of: environmental conditions; configuration; and the adverse effect of some systems. It is proposed to include in this text the prescriptive requirement for environmental conditions (of which the main element is wind) - broken out into its constituent parts. This will permit the removal of repetitive text from the requirements contained in Subparts G, H and I - thus simplifying those Subparts. There is a consequential amendment of IEM OPS 3.490(a)(3)(ii) in Subpart G (approval of wind factors in excess of 50%) which is renamed as ACJ OPS 3.475(c)(3)(ii)(C) and relocated into Subpart F.

F.2.1 The changes in this proposal are intended to bring all of the general requirements into Subpart F. It is not considered that there will be any substantial regulatory or financial impact resulting from this proposal.

F.3 JAR-OPS 3.477 – Obstacle accountability. This proposed new text updates the description of the area in which obstacles have to be considered (in all performance requirements) and repositions it in Subpart F. There is a consequential amendment to other Subparts; to remove the text and replace it with a reference. F.3.1 The changes in this proposal are intended to bring all of the general requirements into Subpart F. It is not considered that there will be any substantial regulatory or financial impact resulting from this proposal.

F.4 JAR-OPS 3.480 Terminology. There are a number of proposed amendments to this requirement:



F.4.1 Subparagraph (a); removal of the reference to Subpart J - none of the definitions contained in Subpart F are used in Subpart J.

F.4.2 Subparagraph (a)(5) D; this definition was originally contained in Appendix 1 to JAR-OPS 3.005(d) - HEMS, but not used in that Subpart. It has been repositioned into Subpart F.

F.4.3 Subparagraphs (a) 15, 16, 17, 24, 30 and 31; all have the acronym added to the definition to clarify the usage. In all of these definitions, with the exception of 17 - maximum approved passenger seating configuration (MAPSC), the acronyms contain the suffix ‘H’. As described earlier, this is to distinguish the helicopter definition from original fixed wing definition (in a number of cases the definition has also been amended to take account of helicopter specific issues).

F.4.4 Subparagraph (a)(31) Take-off distance required (TODRH); has been amended to take account of the unique capability of the helicopter. The original definition (which was taken from fixed wing) was oriented towards runway operations and contained a requirement to have a clear area (the runway and clearway) to the point in the take-off manoeuvre where the aircraft reaches a specified height after lifting. In helicopter operations a runway and clear area (in that sense) are not always required and, providing the procedure and performance permits, the only space that needs to be specified and clear is that which is required for the rejected take-off distance (re-landing following an engine failure before TDP). It is now made clear in the amended text that the continued take-off can be conducted over obstacles (for a further description see ACJ OPS 3.480(a)(31) - The application of TODRH); the definition now aligns with current practices in industry. It is not considered that there will be any substantial regulatory or financial impact resulting from this proposal.

F.4.5 Subparagraph (a)(32) Take-off flight path; was introduced to improve the understanding of its use in Subpart G and H - it is not defined in ICAO or JAR 1. The critical element of the definition is the use of ‘specified point’ - from where the take-off-flight-path begins; in PC1 the specified point is the end of take-off distance required (TODRH); in PC2 it may be DPATO or as an alternative 200 ft. Subpart G and H use this term to specify OEI obstacle clearance after the specified point has been reached. It is not considered that there will be any substantial regulatory or financial impact resulting from this proposal.

F.4.6 Subparagraph (b); it is proposed to delete this paragraph as most of the terms are now defined in paragraph (a).

F.4.7 IEM OPS 3.480(a)(1) and (2) Category A and Category B; reference to this IEM was omitted when it was added to Section 2 of JAR-OPS 3 at Change 1.

Editorial Note: As a matter of record, this IEM was added to JAR-OPS 3 to deal with an historical problem seen during the proposed implementation of JAR-OPS 3 in 1995. Prior to the advent of JAR 27 Category A, a number of small multi-engine helicopter types (AS355, B105 and A109) had been certificated under FAR 27 in compliance with FAR 29 engine isolation requirements as specified in FAA Advisory Circular AC 27-1; this was not intended, nor is it considered, to be an equivalent standard to JAR 27 Category A. In order to accommodate this historical fact and to permit these helicopters to continue to operate in Performance Class 1 or 2 - in compliance with Subpart G or H of JAR-OPS 3, a minimum set of additional airworthiness compliance requirements was drawn up by the JAA Helicopter Airworthiness Study Group and placed in the IEM. The IEM was structured logically; paragraph 1 - containing acceptable methods of compliance; and paragraph 2 - an acceptable standard of compliance for those helicopter types which had been certificated before the advent of JAR 27 Appendix C. Paragraph 3 of the IEM indicated that, before a helicopter was Approved to operate in Performance Class 1 or 2, it should have been established that scheduled performance data - compatible with Subparts G and H respectively - was available.

F.4.7.1 It is proposed to revise the header to ACJ OPS 3.480(a)(1) and (a)(2), add forward references to the rules, and backward reference to it from Subparts G, H and I ‘General’ paragraphs.



F.5 ACJ OPS 3.480(a)(31) The application of TODRH. As was explained in F.4.4 above, the proposed definition of TODRH now takes account of the capability of modern helicopters. In order that the full flexibility can be utilised, the ACJ contains a description and diagrams of the application of the revised definition. This is regarded as a clarification of existing practices; it is not considered that there will be any substantial regulatory or financial impact resulting from this proposal.

F.6 Consequential amendment of IEM OPS 3.480(a)(12) to (13) due to renumbering of JAR-OPS 3.480(a). SUBPART G G.0 The proposed revisions to Subpart G described below, are intended to improve the text by more clearly describing requirements in line with improved understanding gained since the implementation of PC1 in the first edition. A single set of requirements for ground level and elevated heliports, and removal of duplicated prescriptive text, has permitted simplification. Flexibility is added to the take-off and landing requirements in acknowledgement of the introduction of helicopters with more powerful engines; this can be seen both in the application of the revised take-off distance required (see F.5 above) and a removal of the reliance upon FATO sizes more appropriate for Category A procedures with less powerful helicopters. Except where specifically shown it is not considered that there will be any substantial regulatory or financial impact resulting from this proposal.

• Who is affected? All operators who are operating in PC1.

• Impact on affected parties? Simplification of the rule material will result in clearer procedures.


• Hazards to be addressed? The hazard, as a result of complicated procedures, has been reduced.

• Effectiveness of the proposed measure? The proposed rule changes will simplify procedures and result in a better understanding of PC1.

G.1 JAR-OPS 3.485 General. The reference to ACJ OPS 3.480(a)(1) and (a)(2) is added to this requirement. As was discussed in F.4.7 above, the reference was omitted when the original guidance material was added in Change 1.

G.2 JAR-OPS 3.490 Take-off. It is proposed to amend this requirement and simplify it.

G.2.1 It has been concluded that the requirements for non-elevated and elevated heliports are virtually identical: for an engine failure before TDP - a rejected take-off on the specified FATO is required whether that is a helideck, heliport or runway; for an engine failure at or after TDP - the take-off distance required must be within the take-off distance available or, using the revised definition of take-off distance required (TODRH), the take-off distance available can be disregarded if all accountable obstacles can be cleared by a vertical margin of 35 ft. These objective requirements have to be met on all occasions.

G.2.2 Additional simplification is achieved by removing the prescriptive text for the environmental factors - referring to it instead.

G.2.3 An additional paragraph (c), introduces the requirement to have a clear area for the back-up or sideways manoeuvre (when used) or, if not clear, to have demonstrated that any obstacle in that area can be cleared during a rejected, or continued, take-off. This latter element will



permit Authorities to approve procedures at sites with small obstacles - such as fences, in the rearward or sideward manoeuvring area.

G.2.4 The revised wording permits an alternative method of compliance (other than the Category A procedure) discussed in G.6 below by introducing the requirement for the maximum take-off mass specified in the Helicopter Flight Manual for the procedure to be used. This alternative to Category A, in not requiring a rejected take-off in the event of an engine failure, decouples the procedure from the size of heliport and will permit operations to heliports that have not been available for PC1 to this date. The proposal could legitimise existing heliports that, to this time, have required alleviation from Subpart G under Appendix 1 to JAR-OPS 3.005(i) - Public Interest Sites (mostly hospitals in city centres). This could result in a substantial reduction of investment in new infrastructure for HEMS operations.

• Who is affected? Operators with small twins who potentially operate to heliports which are too small for a Category A procedure but which have sufficient power reserves to eliminate the need to reject in the case of an engine failure.

• Impact on affected parties? Would permit the use existing heliports which are too small to be used or operated in PC1 with Category A procedure. This has the potential to take a number of operations out of reliance on the Public Interest Site appendix - and potentially, remove the need to redevelop some city centre (hospital) sites.

• Impact on authorities resources? This proposal has potential to eliminate the need for extensive redevelopment of existing city centre heliports (particularly on hospitals).

• Hazards to be addressed? There is, potentially, a reduction in hazards due to the elimination of the need to re-land at a heliport following an engine failure before TDP.

• Effectiveness of the proposed measure? The proposed measure permits the continued use of heliports which might have had to be removed or redeveloped.

G.3 JAR-OPS 3.495 Take-off Flight Path. In the interest of clarity it is proposed to delete the existing rule and substitute a new rule. The revised wording (together with the addition of the definition in JAR-OPS 3.480) makes clearer two important elements: (1) that the take-off flight path starts from the end of the take-off distance required; and (2) that the take-off mass may have to be reduced in order to achieve obstacle clearance. The revised rule is simplified by removal of prescriptive text describing the obstacle ‘accountable’ area and environmental conditions - referring instead to JAR-OPS 3.477 (see also F.3 above). It is not considered that there will be any substantial regulatory or financial impact resulting from this proposal. G.4 JAR-OPS 3.500 En-route - critical power unit inoperative. The proposed amendment is divided into three elements: the first breaks out the text to make it clearer; the second gives alleviation to flights that are conducted under VFR in sight of the surface; and the last reverses the logic of the text so that the normal obstacle clear corridor is 9.3 km (5 NM) increased to 18.5 km (10 nm) if the navigational accuracy does not meet the 95% containment. It is not considered that there will be any substantial regulatory or financial impact resulting from this proposal. G.5 JAR-OPS 3.510 Landing. The proposed amendment follows the logic of the amendments of the text in JAR-OPS 3.495 - Take-off, as described in G.2.1and G.2.2 above. The separate requirements for elevated and non-elevated heliports are combined into a single set of requirements and prescriptive text is removed in favour of reference. It has the potential to provide the same benefits described in G.2.4 above.



G.6 ACJ to JAR-OPS 3.490 and 3.510 Alternative take-off and landing procedures.

G.6.1 When Performance Class 1 was introduced into JAR-OPS 3, it was expected that the take-off and landing procedures would always be conducted in accordance with Category A procedures (defined by the manufacturer in compliance with JAR 29). Because of the need to re-land following an engine failure, the FATO specified for any Category A procedure had to be large enough for the average pilot to recover without incident and, for that reason, is rarely below 2D (D = the largest dimension of the helicopter when the rotors are turning) - a measurement that has been formalised in Annex 14.

G.6.2 Recent improvements in power available - particularly for the smaller twins certificated under JAR 27 - has resulted in a situation where an engine failure at the critical stage of the take-off or landing manoeuvre does not necessarily lead to a requirement to re-land.

G.6.3 Experience (in offshore operations) with elevated heliports/helidecks has shown that 1D has been large enough for normal operations to stable heliports. With the advent of helicopters with reserves of power such that an OEI HOGE can be achieved at mission weights, the need to re-landing following an engine failure has been removed and alternative methods of compliance with the take-off and landing requirements are now acceptable.

G.6.4 The proposed ACJ gives guidance on methods of compliance, other than Category A procedures, which might be acceptable to the Authority. It is considered that the most important application for this alternative method of compliance will be Public Interest Sites (PIS) in congested hostile environments (mainly hospitals) - where the size of the heliport had formerly required alleviation from Subpart G.

G.7 Consequential amendment to Subpart G Section 2 resulting from proposals above; Delete: IEM OPS 3.490(a)(1) & 3.510(a)(1); IEM OPS 3.490(a)(3)(ii); IEM OPS 3.490(b)(4) & 3.495(b)(5) (removed to Subpart F and renamed ACJ OPS 3.475(c)(3)(i i )) . Rename IEM OPS 3.500(a)(5) to ACJ OPS 3.500(b)(3). Delete IEM OPS 3.510(a)(3)( i).

SUBPART H H.0 The proposed revision of Subpart H is based upon three principles: simplification by removal of redundant text; introduction of ground level exposure; and rationalisation of requirements up to and beyond 2010.

H.0.1 The practical application of Performance Class 2 has been simplified by the removal of the requirement to calculate distances in those cases where obstacle clearance (AEO or OEI) is not an issue (the majority of cases).

H.0.2 The principles of Performance Class 2 have not, up to now, been well understood and it was felt necessary to produce ACJ to Subpart H with a full and complete discussion and description (complete with diagrams). In view of the comprehensive nature of the ACJ it is not considered necessary to repeat the discussion here.

• Who is affected? All operators with Category A certificated helicopters.

• Impact on affected parties? The rule change, together with knowledge gained from the explanatory text, has the potential to simplify operations in PC2. The introduction of (bounded) ground level exposure will permit the development of heliports with: a reduced ground surface requirement; and, a reduction in the obstacle clearance gradient.

• Impact on authorities resources? This proposal should be cost neutral to Authorities - the increase in PC2 operations with exposure should be offset by the simplified Approval process.



• Hazards to be addressed? There is a potential for an increase in risk from the expansion in exposure time (from deck-edge, to ground level to 200 feet) - however, it is believed that improved reliability will maintain the safety of these operations to the existing target.

• Effectiveness of the proposed measure? The proposed measure has the potential for increasing (substantially) the number of operations to PC2 standards.

H.1 JAR-OPS 3.515 General. The reference to ACJ OPS 3.480(a)(1) and (a)(2) is added to this requirement. As was discussed in F.4.7 above, the reference was omitted when the original guidance material was added in Change 1.

H.1.1 Following favourable experience with operations in PC2 to helidecks in a non-congested hostile environment (offshore operations), it is proposed to remove the previous restrictions contained in (a)(2). Although the removal of these restriction has the potential for introducing risk for operations to elevated heliports and helidecks, in practice there have been no operations without exposure and no increase in take-off or landing incidents/accidents has been observed.

H.1.2 As there have been no PC2 operations to elevated heliports and helidecks without exposure, it is not considered that there will be any substantial regulatory or financial impact resulting from this proposal.

H.2 JAR-OPS 3.517 Applicability. The changes introduced in Amendment 2 were based upon two elements: the requirement for approval for operations with exposure; and grandfather rights for existing operations with exposure to elevated heliports and helidecks outside a congested hostile environment. The proposed text contains a single requirement for approval for operations with exposure as discussed in paragraph 3.2.3 above - this includes exposure for ground level operations as well as operations to elevated heliports and helidecks.

H.2.1 Although these operations extend exposure - and the risk - beyond that considered in NPA 8, the limiting of exposure to the point where PC1 performance is achieved (bounded to 200 ft) and the requirement for second segment climb performance and AEO HOGE, should ensure that the risk is minimised. As has already been stated in the paragraphs of 3.2.3 and in particular in 3.2.3.2 and 3.2.3.3 above, bounding of exposure and mitigating procedures to enhance reliability should ensure that these operations remain within the safety target set in NPA 8. This proposal should convey a substantial benefit to operators both in the simplification of procedures and the introduction of ground level exposure (see additional analysis in H.0.2 above).

H.3 JAR-OPS 3.520 Take-off.

H.3.1 The proposed text simplifies the requirement into three elements: the first element is required of every take-off performed in PC2 - to meet second segment climb performance (this will ensure that the minimum requirement for the take-off flight path can be achieved); the second element - when operating without an approval for exposure, requires that surfaces are available for a safe-forced-landing; the third element contains the requirement for operations with exposure. Of the three requirements the first two contain simplification and it is not considered that there will be any substantial regulatory or financial impact resulting from the proposals. For the last, there is the potential to increase the potential risk of an engine failure during the ground level take-off phase. However, as discussed in the sub-paragraphs of 3.2.3 of the introduction, the bounding of the take-off and landing phases in Subpart H and I, should ensure that the safety target continues to be met.

H.3.2 Operations with exposure are divided into two cases: general operations for which AEO HOGE power is required; and operations to helidecks in a hostile environment (and for helicopters with a MAPSC of more than 19 - all helidecks) which are required to meet additional performance requirements that will ensure that the deck-edge miss and drop down are taken



into consideration (the so-called enhanced Performance Class 2 - PC2e).

H.3.2.1 In the first case, the performance requirement is the combination of the second segment climb performance and AEO HOGE performance. This has always been an element of JAR-OPS 3 and was formerly contained in IEM OPS 3.517(b), it is not expected that there will be any regulatory or financial impact resulting from this proposal;

H.3.2.2 In the second case, there are additional requirements that the procedure be appropriate and the deck-edge clearance and the drop down performance be calculated so that, in pure performance terms, they would be sufficient to ensure deck-edge miss and a continued take-off. This proposal removes the limit of PC 2 with exposure at 2010. As manufacturers already use performance modelling to predict the outcome of manoeuvres before flight testing, it is not expected that to produce a take-off or landing manoeuvre ensuring deck-edge clearance and drop down graphs - for the non-approved section of HFM - will substantially add to the cost of producing performance information. On the contrary, the absence of a requirement by 2010 to produce Category A procedures for helideck operations will save substantial amounts expended in flight testing these procedures on helidecks. The additional cost of validating performance models for vertical procedures can be absorbed into existing flight validation procedures; the testing and recording of flight paths during HV curve production could provide sufficient data to validate modelling of drop down. It is therefore expected that while there could be minor costs involved in performance modelling, there could potentially be substantial savings from the removal of the requirement for PC1 by 2010.

• Who is affected? Manufacturers, and operators operating to helidecks in a hostile environment post 2010.

• Impact on affected parties? Removes the requirement to operate in PC1 post 2010 and substitutes the requirement to operate in PC2e. This might require a reorganisation of the way that data is presented to the pilot: procedures, deck-edge clearance and drop down graphs will have to be contained within the non-approved section of the HFM.

• Impact on authorities resources? Such procedures will have to be accepted - it is not considered that this will add substantially to Authority’s work or resources.

• Hazards to be addressed? There should be no hazard introduced as a result of this proposal; on the contrary it has the ability to introduce a more practical and simple method of operation which could prevent collision with obstacles on and around helidecks (the main cause of accidents on helidecks).

• Effectiveness of the proposed measure? The proposed measure will introduce simple risk analysed procedures and remove the misunderstanding that PC1 is always possible in operations to helidecks.

H.4 JAR-OPS 3.525 Take-off Flight Path. It is proposed to delete the existing rule and substitute a new rule. The revised wording makes clear that the take-off flight path starts from DPATO - or no later than 200 ft above the take-off surface - from which PC1 requirements have to be met. This revision can be seen as a clarification of the original requirement and it is not considered that there will be any substantial regulatory or financial impact resulting from the proposal. H.5 JAR-OPS 3.530 En-route - Critical power unit inoperative. It is proposed to remove the existing text and point to the requirement in JAR-OPS 3.500. This revision can be seen as an editorial simplification of the organisation of the text and does not change the requirement.

H.6 JAR-OPS 3.535 Landing. The proposed amendment to the text of this requirement follows the same logic of the amendments of the text in JAR-OPS 3.520 Take-off as described in H.3 above.



H.7 Appendix 1 to JAR-OPS 3.517(a) Helicopter operations without an assured safe forced landing capability. The proposed appendix replaces an existing one.

H.7.1 As described in 3.2.4 and subsequent paragraphs, it is proposed to provide an appendix with objective requirements which relies upon extensive guidance material. The approval for these operations will require: a risk assessment; a set of conditions; and the implementation of a usage monitoring system (UMS).

H.7.2 The provision of an objective appendix and comprehensive guidance should improve the flexibility of the regulation. There could be a positive financial impact as bureaucracy will be reduced and the process of approval will be simplified.

H.7.3 The provision of guidance on how to conduct this assessment and approval is contained in ACJ - 1 to Appendix 1 to JAR-OPS 3.517(a) and ACJ - 2 to Appendix 1 to JAR-OPS 3.517(a) both of which are described below.

H.7.4 The revision of the Appendix requires that the following advisory material be deleted or amended as shown:

H.8 Delete the following: AMC to Appendix 1 to JAR-OPS 3.517(a); IEM OPS 3.517(a); IEM to Appendix 1 to JAR-OPS 3.517(a); IEM OPS 3.520; IEM OPS 3.520(a)(2); IEM OPS 3.530(a)(5). Amend IEM OPS 3.517(b) to be ACJ OPS 3.520(a)(3) and 3.535(a)(3). H.9 ACJ-1 to Appendix 1 to JAR-OPS 3.517(a) Helicopter operations without an assured safe forced landing capability. The proposed text of this ACJ gives guidance on the conduct of a risk assessment for approval of operations with exposure.

H.10 ACJ-2 to Appendix 1 to JAR-OPS 3.517(a) Helicopter operations without an assured safe forced landing capability. As was discussed in paragraph 3.2.4.2 and 3.2.4.3 above, experience has shown that the former requirement for procedures and equipment were too prescriptive. In view of this the material has been revised and is now contained in the proposed ACJ. H.11 ACJ to Subpart H Operations in Performance Class 2.

H.11.1 This new ACJ is a complete text which describes PC2 as established in JAR-OPS 3, Subpart H and was produced for the purpose of:

(a) discussing the underlying philosophy of Operations in Performance Class 2;

(b) showing simple methods of compliance; and

(c) explaining how to determine - with examples and diagrams:

• the take-off and landing masses;

• the length of the safe-forced-landing area;

• distances to establish obstacle clearance; and

• entry point(s) into Performance Class 1.

H.11.2 There is a discussion of the derivation of Performance Class 2 from the ICAO Standard and a description of an alleviation which may be approved following a Risk Assessment. It reproduces relevant definitions, examines the basic requirements, discusses the limits of operation and considers the benefits of the use of Performance Class 2. It contains examples of Performance Class 2 in specific circumstances, and explains how these examples may be generalised to provide operators with methods of calculating distances and obstacle clearance.



SUBPART I I.0 The proposed revision of Subpart I contains two elements the simplification of text by removal of duplication and re-ordering, and the introduction of ground level exposure.

I.0.1 Although this proposal extends exposure - and the risk - beyond that considered in NPA 8, the limiting of exposure to 200 ft should ensure that the risk is constrained. As has already been stated in the paragraphs of 3.2.3 and in particular in 3.2.3.2 and 3.2.3.3 above, bounding of exposure and mitigating procedures to enhance reliability should ensure that these operations remain within the safety target set in NPA 8. This proposal should convey a substantial benefit to operators both in the simplification of procedures and the introduction of ground level exposure.

• Who is affected? All operators operating in PC3.

• Impact on affected parties? Simplification of the rules will engender better understanding of the requirement.


• Hazards to be addressed? There is a potential for an increase in the exposure time (from the knee of the HV diagram, to 200 feet) - however, it is believed that improved reliability will maintain the safety of these operations to the existing target.

• Effectiveness of the proposed measure? The proposed measure will simplify operations in PC3 and will legitimise (what is considered to be) the way that operations are presently conducted.

I.1 JAR-OPS 3.540 General.

I.1.1 The reference to ACJ OPS 3.480(a)(1) and (a)(2) is added to this requirement. As was discussed in F.4.7 above, the reference was omitted when the original guidance material was added in Change 1.

I.1.2 The introduction of ground level exposure requires an amendment of (a)(2) to provide alleviation for those operations. Introduction of ground level exposure and extant exposure for operations to heliports in a non hostile environment means that the prohibition for operations to helidecks in a non-hostile environment has no further logical basis - it is proposed to remove the prohibition. The alleviation for ground level exposure is contained in paragraph (b); the text in (b)(1) and (b)(2) specifies the limitation for the exposure. The rationale for the limitations is provided in ACJ 3.540(b) - which is described below.

I.1.3 To ensure that the introduction of ground level exposure does not complicate the existing elements of the rule, it is proposed to divide the text into the three logical parts: that which has to be complied with; that which may be complied with; and that which is prohibited.

I.2 JAR-OPS 3.545 Take-off. The text of this rule is simplified by removing the prescriptive text for application of environmental conditions - the requirement is provided in JAR-OPS 3.475. The proposed rule contains an editorial amendment in a reference to JAR-OPS 3.005(e). I.3 JAR-OPS 3.550 En-route. The proposed rule contains an editorial amendment in a reference to JAR-OPS 3.005(e). I.4 JAR-OPS 3.555 Landing. The text of this rule is simplified by removing the prescriptive text for application of environmental conditions - the requirement is provided in JAR-OPS 3.475.



The proposed rule contains an editorial amendment in a reference to JAR-OPS 3.005(e). I.5 ACJ OPS 3.540(b) The take-off and landing phases (Performance Class 3). This proposed ACJ contains the rationale for the use of the terms take-off and landing phases; it also provides several case studies to demonstrate the use, and limitations, of ground level exposure.

SUBPART J Appendix 1 to JAR-OPS 3.625 - Mass and Balance Documentation. The term Zero Fuel Mass is not used in helicopters and there is no definition in JAR-OPS 3.607. It is proposed to delete the term in Appendix 1 to JAR-OPS 3.625 (a)(1)(i)(I). The revision is a clarification and will have no regulatory or financial impact.

J.2 JAR-OPS 3.605(e) Fuel Density. When this rule was written, only the military designation was considered; the revision inserts the civilian designation alongside the military. The revision is a clarification and will have no regulatory or financial impact.

SUBPART K

K.1 JAR-OPS 3.650, 3.652 and ACJ OPS 3.650/3.652 - Flight and Navigational Instruments and Associate Equipment.

K.1.1 JAR-OPS 3.650 and 3.652: There was a different wording used in JAR-OPS 3 than in airworthiness JAR 27/29 to define magnetic compass and stabilized direction indicators. Especially the latter created some implementation problems in Germany. Also it came apparent that the fulfilment for the stabilized direction indicator differs for VFR night and IFR. Therefore it is proposed to use the same wording as JAR-27/29 and to make the difference in equipment between VFR night and IFR more clear. Furthermore it was agreed in the HSST and with consultation of the EQSC to change the wording of “”pitot heater failure warning indicator” into “pitot heater failure annunciation”. The revision is a clarification of existing requirements and will have no substantial regulatory impact. However, because of the interpretation issues between the different JAA countries there will be a positive financial impact because the proposed changes do not require several helicopters to be retrofitted.

K.1.2 The former table (IEM OPS 3.650/3.652) with its accompanying notes, was an attempt to condense parts of the rules of JAR-OPS 3.650/3.652 into a simple table for compliance checking. Experience has shown that the combination of the Certification Requirements and the Operational Requirements was rather more complicated than the original table indicated. After discussions which, as an option had the removal of the table, the majority opted for retention of an amended table. The resulting ACJ corrects the contents of the former IEM in regard to the rule text; renames it as ACJ in accordance with JAR-11 and considers compliance with JAR 29 as well as JAR-OPS 3 (see also K.3.1). The revision is a clarification of existing requirements and will have no substantial regulatory or financial impact.

K.2 JAR-OPS 3.820 Automatic Emergency Locator Transmitter. The intent of JAR-OPS 3.820 is retained but it is proposed that the (presently pointed to) Standard from ICAO Annex 10 is incorporated in the text to make the rule clear and transparent. The revision is a clarification and will have no regulatory or financial impact.

K.3 JAR-OPS 3.827 and JAR-OPS 3.837. The proposed changes will require the use of approved immersion suits thereby providing a link, for new suits, to the new JTSOs (ETSOs). It will also achieve harmonization with other international standards such as EN ISO 15027-1 & -3, and IMO Resolution A.689(17). As existing suits are already approved to a national standard, the new standard will only effect new approvals, it is not expected that the proposal will have a regulatory or financial impact.



K.4 ACJ OPS 3.827. In addition, the method used to calculate the survival time, described in IEM (ACJ) OPS 3.827, is problematical for a number of reasons and takes no account of the effect of cold shock.

K.4.1 The present method is based on the measurement of Clo values, the unit used by physiologists to define the value of clothing insulation. Clo values are mainly used to measure the insulation of dry clothing at 1 atm. Immersed clo is rarely used and limited experience has been established. Clo varies considerably with pressure and moisture.

K.4.2 The curves in current Figure 2 are derived from Wissler model, modified by Hayes, 1987. They have been derived from laboratory results with calm sea conditions and where the air is still and warm. They do not include the influence of wind chill and sea state, which may be significant in this environment, and there is no guidance on how to assess these effects.

K.4.3 Cold shock is probably the single most important factor limiting the escape of an uninjured victim from a capsized helicopter, particularly in cold seas. Cold shock is caused by the sudden drop in skin temperature on immersion and is independent of the rescue time. It is characterised by a gasp reflex and uncontrolled breathing. In the event of submersion, cold shock greatly reduces the breath hold time. Immersion suit insulation is required to delay the onset of cold shock thereby extending the available escape time from a submerged helicopter.

K.4.4 The calm water survival time curves have been replaced by a table of times within which the most vulnerable individuals are likely to drown. This table is extracted from a paper by Robertson and Simpson (1995). It provides a more conservative estimate of survival times based on the factors identified in Figure 1. It also considers the primary threats to survival and is not focused on hypothermia.

K.4.5 Reference: Robertson, D H and Simpson, M E (1995). Review Of Probable Survival Times For Immersion In The North Sea. HSE Report OTO 95 038.

K.4.6 Editorial corrections to references are also included. The amendment and replacement of one standard by another is a simplification of existing requirements and will have no substantial regulatory or financial impact.



K.5 JAR-OPS 3.830 Liferafts and JAR-OPS 3.835 Survival equipment.

K.5.1 Both of the rules contain requirements for the carriage of ELT(S)s. As with JAR-OPS 3.820 above, the standard of the equipment is specified by reference to ICAO Annex 10. A new appendix (Appendix 1 to JAR-OPS 3.830) is proposed to clarify the requirement for ELT(S) carried in accordance with these JARs - with regard to the Standard of ICAO Annex 10. As with JAR-OPS 3.820 the reference to ICAO Annex 10 is replaced with precise requirements.

K.5.2 The method of carriage of ELT(s) is not harmonised across Europe. Offshore operators comply with JAR-OPS 3.830(a)(3) by requiring crew members to carry ELT(S)s attached to their constant wear lifejackets. These crew members could be flying a helicopter registered before January 1 2002 on one day and one registered after 2002 on the next.

K.5.3 A similar situation exists with ELT(S) carried in survival packs/liferafts. The ELT(S) is contained in the survival pack which itself is packed inside the liferaft – this liferaft may be exchanged between aircraft which have been certificated either before or after January 1 2001.

K.5.4 In view of these methods of carriage and the flexibility for switching, it is proposed that January 1 2005 becomes single compliance date for the technical standard of ELT(S)s.

K.5.5 The proposal to replace several dates with a single compliance date removes confusion - mainly for offshore operators. The proposal should have no significant adverse financial impact.

• Who is affected? Mostly offshore operators.

• Impact on affected parties? Simplification of the rules and a single compliance date will make the existing rules easier to understand and comply with.


• Hazards to be addressed? On extended overwater operations; exposure to a ditching without the 406Mhz frequency, or the ELT firing without a ditching, might cause a delay, or result in an inadvertent call out, of SAR. As the probability of ditching is a rare event, it is unlikely that there will be one in the time between the promulgation and implementation of the rule.

• Effectiveness of the proposed measure? The proposed measure simplifies the rule and permits some time in which to address the problems of the switching of registered ELTs between helicopters. By 2005, it is considered that programs will be in place to apply the registered codes as the equipment is placed in the helicopter.

SUBPART N N.1 AMC OPS 3.945 - Conversion Course Syllabus. In order to achieve consistency with Subpart O - Crew members other than flight crew, the text is amended to make clear the distinction between crew members and flight crew members and the interaction between the two. The revision is a clarification of an existing requirement and will have no substantial regulatory or financial impact.

N.2 Appendix 1 to JAR-OPS 3.965 paragraph (a)(3)(iii)(E). In helicopter passenger operations, crew members are rarely carried (unlike aeroplanes). If there is an incident or accident it is important that the pilot has the skills to carry out first aid. The amended text ensures that the appropriate training is given: for HEMS, when paramedics are carried on every flight, it may have less importance than for other flights. The revision is a clarification of an existing requirement and should have no substantial regulatory or financial impact



REGULATORY IMPACT ASSESSMENT

Regulatory Impact Assessment for the amendment of JAR-OPS 3 for the purpose of improving performance regulations by simplification of the requirements and by adding detailed guidance and explanation.

1 Purpose and Intended Effect of the Measure 1.1 Service experience since the introduction of JAR-OPS 3 in 1995 has indicated that, although performance requirements have generally been in compliance with ICAO Annex 6 Part III Chapter 3 (the exception being the introduction of exposure in NPA OPS-8), they are considered to be overly rigid and difficult to comply with - particularly when operating in Performance Classes 2 & 3 from ground level heliports. 1.2 Assessment of JAR-OPS 3 by the Helicopter Sub-Sectorial Team (HSST), and Annex 6 Part III by the ICAO Helicopter and Tiltrotor Study Group (HTSG – which has proposed a complimentary amendment to Annex 6 Part III), has resulted in proposals for amendment in order to make both Standards pragmatic and more in line with existing custom and practice. This proposal for JAR-OPS 3 mirrors the proposal for Chapter 3 of Annex 6 Part III. 1.3 Operations in Performance Class 1 are well described but do not, at present, take advantage of the knowledge that has been gained since the adoption of Annex 6 Part III in 1990. In particular, there has been an introduction of helicopters which can operate in Performance Class 1 to the smallest heliports (both ground level and elevated) and restricted sites as well as from traditional clear area runways. Further, more powerful engines and gearboxes that are now present in the lighter and medium twins has permitted reduction of the reliance on Category A procedures - as is signalled in the discussions of CDP and LDP in the certification guidance of AC 29-2C. None of this is presently described in the extant ICAO Annex 6 or JAR-OPS 3. 1.4 With the exception of the early part of the take-off and late part of the landing, requirement for Operations in Performance Class 2 are identical to those in Performance Class 1; this indicates a simplification of the requirements by using references rather than repeating identical passages. 1.5 As has been proposed in ICAO Annex 6, a single description of the obstacle accountability area and environmental factors permits a reduction in the volume of text, for it allows these clauses to be removed from Subparts G, H and I and re-placed into Subpart F -Performance General. 1.6 In view of the issues described above, it is considered that all common performance text should be contained in a modified Subpart F – Performance General. It is also proposed to amend this Subpart by inclusion of new definitions and modification of existing ones. 1.7 Operations in Performance Classes 2 & 3 (with the exception of those which are undertaken in offshore operations or to runways/clear-areas) are generally from non-improved ad hoc sites - which were not designed to be in compliance with the extant ICAO Annex 14. These may be chosen from the air or from a map in accordance with JAR-OPS 3.220 and its associated guidance. Pre-surveying and authorising of these landing sites is not the norm – they are usually chosen using the alternative procedure called for in AMC No 1 to OPS 3.220 paragraph 5. 1.8 In the absence of accident data to indicate that there is a pressing safety issue or evidence of an increase in accidents or incidents since the introduction of exposure in NPA



OPS-8, it is considered that a limited relaxation of the requirements is justified; in view of this NPA OPS-38 contains a proposal and justification to extend exposure to ground level heliports. 1.9 The absence of accidents related to exposure, and the presence of adverse comments on the complexity of the process of approval for exposure, has led to a proposal to simplify the approval process to ease the regulatory burden to manufacturers, operators and States. 1.10 Compliance – and therefore safety – could be further improved by better understanding of performance classes; there has therefore been an introduction of extensive guidance material describing procedures for all performance classes. 1.11 The extant JAR-OPS 3 has a number of dates after which certain options will be closed. In particular: 1.11.1 31st March 2005 remains as the date when a number of grandfather rights are removed – specifically, the opportunity to continue to operate with exposure to helidecks without a formal approval. 1.11.2 31st December 2009 is the date when all approvals to operate with exposure expire; the original intent (at that date) was to require a safe-forced-landing for Operations in Performance Class 2 or specify Operations in Performance Class 1 if exposure is present; the explanatory text of NPA OPS-38 explains why that will not be possible at that date – or even later. 1.12 One objective of this proposal is to remove all such dates and provide appropriate regulation for performance which will endure and provide an acceptable level of safety into the foreseeable future. 2 Options 2.1 Option 1: One course of action would be to do nothing. This could result in a missed opportunity to simplify the regulations thus lowering the costs to operators and the Authority. It might also result in continued non-compliance with the existing regulation thus potentially lowering the safety standard. However, there will still be a need to resolve the actions that have to be taken at the dates that presently exist in JAR-OPS 3. 2.2 Option 2: The second course of action would be to retain the text of the regulation substantially as it is but to resolve the issue of the dates and the policy thereafter. Such a policy could be either: (a) eliminate exposure by December 31st 2009 and signal that Operations in Performance Class 1 would be required from that date unless a safe-forced-landing could be carried out; or (b) to remove the date and signal that the existing policy on exposure would be continued from that date. 2.2.1 Option 2 (a): The explanatory text of NPA OPS-38 adequately describes why Operations in Performance Class 1 will not be possible to helidecks in the foreseeable future. This option could also eliminate Operations in Performance Classes 2 & 3 from all but prepared (and larger) sites. This is not considered to be a viable option. 2.2.2 Option 2 (b): Retention of the extant text but removal of the dates is a feasible option but would miss the opportunity to improve the safety of offshore operations that has become possible due to the recent introduction of new models. It would also deny to operators, ground level operations with exposure in Performance Classes 2 & 3 - which, anecdotal evidence indicates, is presently being undertaken outside of the regulation.



2.3 Option 3: Would result in an amendment of the regulation in accordance with the proposal in NPA OPS-38; this would result in: the introduction of more appropriate definitions and procedures for Operations in Performance Class 1; a reduction and simplification of the code for all Performance Classes; a simplification of the approval process for exposure; the introduction of ground level exposure; and the introduction of Enhanced Performance Class 2 (PC2e) for offshore operations in a hostile environment. All of these elements would permit the revised code to be proportional to the risks. This is the preferred option. 3 Impact 3.1 Sectors Affected 3.1.1 Authorities; will be positively impacted by this proposal as the approval process for exposure will be simplified and re-placed into guidance. Regulatory oversight should also be improved by the simplification of the code and by the reduction of non-compliance. It is not at this time clear what the cost of implementation of the new code will be for each State but, it should be offset by stability resulting from the removal of the necessity for a change of policy at the dates signalled in the extant regulation. The code will also be submitted to EASA without the necessity for further amendment in 2010. 3.1.2 Operators; will be positively impacted by this proposal; there should be no cost of compliance arising from this proposal for onshore operators - with the exception of the cost of amendment of operations manuals to take account of the introduction of ground level exposure. Offshore operators who operate to helidecks in a hostile environment will be impacted after December 31st 2009 but this has already been signalled in the extant version of JAR-OPS 3 - which requires Operation in Performance Class 1 after that date. Operations in PC2e will have been well established by the due date as preparation by the manufacturers for such operations have been taking place since 2004. It is expected that new helicopter types will be brought into service in 2005 with such procedures in place. 3.1.3 Manufacturers; will be positively impacted by this proposal by the simplification of the process for approval of exposure. For those manufacturers who offer existing helicopters for offshore operations in a hostile environment, there will be an additional requirement for the provision of Flight Manual data for PC2e; as is described in NPA OPS-38, this procedures will require the production of data from a validated model for: the procedure; deck-edge clearance; and drop down. For manufacturers of new helicopter types, the provision of such data will be part of the normal certification process. The cost of provision of such data will be more than offset by the removal of the requirement to provide Category A procedures for helicopters used in offshore operations.



3.2 Impacts Identified 3.2.1 All of the elements of the proposal are discussed in the explanatory text of NPA OPS-38 and further regulatory impact is considered in detail there – the following text considers the overall impact of the proposed amendment of the performance regulation. 3.2.2 Safety 3.2.2.1 Prior to NPA OPS-8, all performance procedures were intended meet one of two requirements: engine failure accountability; or a safe-forced-landing. NPA 8 introduced the principle of exposure to an engine failure where, for a very short period in the take-off or landing phase, the consequence of failure could be accepted providing that the probability of failure was low - the safety target being set to 5 x 10-8 per event. Assessment of the risk involved a comparison of the reliability of the engine/helicopter combination against the duration of the exposure period in the take-off/landing event (as exposure was only approved for elevated heliports/helidecks, the risk was limited to the deck-edge strike and, the time to reach the knee of the HV diagram (for singles) or Vstayup (for twins)). 3.2.2.2 During the period since the incorporation of NPA OPS-8, manufacturers have reported that the core reliability of turbine engines used in helicopters is in the range of 0.3 x 10-5 to 3 x 10-5 per flight hour. When these are combined with failures due to: operational causes; maintenance causes; and non-core causes, the average failure rate rises above 1 x 10-

5 per flight hour (this figure was established in a recent assessment of engine failure events in the UK using the MORs data-base; it should be noted that failures such as a loss of lubrication or a precautionary shut down - which would have had no impact during the duration of any take-off or landing phase - were not included in the computed failure rate.) However, there are a number of mitigating procedures which can be (and have been) put into place to bring the failure rate down to the more acceptable rate of 1 x 10-5 per flight hour, these include: the coating of compressor blades and inspection routines to reduce or eliminate failures due to corrosion; the installation of Usage Monitoring Systems (UMS) to monitor, and in some cases eliminate, the hot end events that might lead to turbine bursts (the most common of which is the hot start); the trending of engines for power assurance; and the careful monitoring of operations to reduce adverse environmental factors. With a reliability rate at or below 1 x 10-5 per flight hour, exposure to an engine failure in the take-off or landing phases (to the previously specified target of 5 x 10-8 per event) can extend to about 18 seconds for a single and nine seconds for a twin. 3.2.2.3 It is postulated that if the reliability rate of 1 x 10-5 per flight hour can be attained and maintained, the principle of exposure could be extended to ground level take-off and landing phases without increasing the risk beyond the specified safety target (5 x 10-8 per event). The proposed changes to the requirements and, in particular, the bounding of the take-off and landing phases in Subpart H and I, should ensure that the safety target continues to be met. 3.2.2.4 The introduction of PC2e will substantially enhance safety in offshore operations to helidecks in a hostile environment; additionally, the development of a procedure for offshore operations by the manufacturers will also provide the opportunity to eliminate operations with exposure to helidecks in a non-hostile environment. The latest helicopters can provide deck-edge clearance within their operational envelope - even in tropical climates (the critical element for a hostile environment being drop down into heavy and cold seas); this opens up the opportunity to operate in pure PC2 – i.e. with a safe-forced-landing and without exposure to the hazardous event of a deck-edge strike. 3.2.3 Economic



3.2.3.1 When these proposals are compared with those in the extant JAR-OPS 3, the economic effect is, on balance, positive. 3.2.3.2 Authorities; will have a benefit in that there will be a simplification of procedures for approval and safety oversight. On the negative side, there will be the cost of amendment of their existing code. 3.2.3.3 Operators; onshore operators will have a benefit as they will have the opportunity to expand their operations. For offshore operators the proposal will be cost neutral or positive as they will be able to extend the working life of some of their latest helicopters. They will also not now have to underwrite the provision of Category A procedure for offshore operations to helidecks. 3.2.3.4 Manufacturers; it is considered that, on balance, there will be a benefit to manufacturers; they will be able to offset cost of the provision of data for PC2e against the much higher costs of the provision of Category A procedures by 2010; they will also benefit from the simplification of the approval for exposure. There could be additional costs from the proposal to introduce ground level exposure as most benefit will be obtained when the All Engines Operating (AEO) distances can be calculated – if this is provided, it will be possible to tailor the declared distances and the Obstacle Limitation Surfaces of the heliport to the AEO capabilities of the helicopter. 3.2.4 Harmonisation 3.2.4.1 ICAO; this proposal has been correlated with the proposed amendment of the SARPs of Annex 6 Part III. The proposals have been written by members who have participated in both groups. Adoption of the ICAO proposal and the proposal contained in NPA OPS-38 would result in a compliant and harmonised text. 3.2.4.2 FAA; recent discussions in ICAO have resulted in the FAA considering the introduction of performance requirements into FAR 91 and FAR 135. Although this is unlikely to lead to the introduction of the Performance Classes (for reasons that will not be considered here), the practical result could be the introduction of ‘the equivalent’ to Operations in Performance Classes 2 & 3 with ground level exposure. 3.2.4.3 States outside the FAA and JAA; in view of the work of the ICAO HTSG, a number of other States are likely to amend their performance regulations to be in compliance with the proposed SARPs; this could result in a world-wide harmonised performance standard in line with this proposal. 3.2.5 Environmental 3.2.5.1 It is not considered that there will be any detrimental effect on the environment resulting from this proposal. The addition of procedures designed to eliminate the risk associated with operations to Public Interest Sites - which are mainly at situated hospitals in city centres - should not result in increased traffic in cities but will reduce the risks associated with an engine failure. 3.2.6 Social 3.2.6.1 It is not considered that there will be any detrimental social effect resulting from this proposal. 3.2.7 Other aviation requirements outside the JAA scope



3.2.7.1 This proposal is likely to have a beneficial effect on the ICAO Heliport Design Working Group (HDWG) as they seek to reduce the required heliport sizes and increased gradients for Operations in Performance Classes 2 & 3. In their deliberations, they have already considered the advantage of ground level exposure and have made proposals in line with this principle.

4 Consultation 4.1 This proposal has been extensively discussed; elements of it concerned with Operations in Performance Class 1 resulted from proposals that were originally published in NPA OPS-27 and were subject to comments from a number of States. All of the concepts have been presented to, and discussed with, the manufacturers (who originally proposed the simplified text); procedures for offshore operations have been extensively discussed with the affected operators and have been presented to the Oil Companies (for whom PC2e will provide a safety level that a number of them have recently campaigned for). 4.2 As has already been mentioned, this proposal has been closely co-ordinated with the proposal for amendment of Annex 6 Part III; on view of that the actual text has had wide circulation world-wide and is considered to be mature. The introduction of the concept of PC2e has already begun in the Norwegian North Sea and in some non-JAA States; it will be in use by the offshore industry before it appears as a change in JAR-OPS 3. 4.3 The simplified procedure for approval for exposure and, in particular, the system for establishing engine reliability has been the subject of many discussions – not least in the ICAO HTSG where a similar system for the assessment of engine reliability has been proposed for IMC operations in PC3 (helicopter SEIMC). 5 Summary and Final Assessment 5.1 The proposed changes provide a substantial simplification to the extant rules. There is no substantial negative financial impact and, providing the reliability of the engines can be maintained at or better than 1 x 10-5 per flight hour, there is no good reason why ground level exposure shouldn’t be introduced while still meeting the existing safety target of 5 x 10-8 per take-off or landing event. 5.2 Simplification of the approval process for exposure has the potential to reduce costs to manufacturers and Authorities. The replacement of the compliance requirements from Appendix to ACJ should remove those barriers which have prevented the uptake of UMS – thus facilitating the improvement of engine reliability 5.3 The removal of the reliance upon the Category A procedure, will improve the ability of smaller more powerful helicopters to work to smaller heliports. The proposal could legitimise existing heliports which, to this time, have required alleviation (mostly hospitals in city centres). This could result in a substantial reduction of investment in new infrastructure for HEMS operations. 5.4 The introduction of PC2e will allow offshore operations to be conducted with greater safety without the unnecessary (and unrealisable) requirement for operations in PC1; it will provide engine failure accountability (zero exposure) on all but the exceptional occasion. The cost of the provision of PC2e will be substantially less than that for a Category A procedure – thus providing a substantial saving for manufacturers (and consequently operators). 5.5 Simplification of procedures and introduction of ground level exposure in Performance Classes 2 & 3 has the potential to reduce, substantially, the required size of heliports and



reduce the Obstacle Limitation Surfaces; providing engine reliability can be maintained or improved, this will still permit operations to the accepted safety target. 5.6 The removal of the uncertainty, which surrounds the future policy associated with the removal of exposure by 2010, will permit the industry to make investment decisions with confidence that the regulations will remain stable with acceptable levels of safety into the foreseeable future.



TEXT PROPOSALS

INDEX

SUBPART B 30 ITEM - B.1 Introduction of ACJ to Appendix 1 to JAR-OPS 3.005(d) 30 paragraph (a)(4) HEMS Mission ITEM - B.2 Insertion of new rule JAR-OPS 3.005(j) – NVIS 30 ITEM - B.3 Consequential amendments 31 ITEM - B.3.1 Amendment of Appendix 1 to JAR-OPS 3.005(d) – HEMS 31 ITEM - B.3.2 Amendment of Appendix 1 to JAR-OPS 3.005(e) – Performance Over a hostile environment 31 SUBPART D 32 ITEM - D.1 Insertion of new JAR-OPS 3.330(a) – Accessibility of emergency equipment 32 ITEM - D.2 Insertion of new JAR-OPS 3.426 – Flight hours reporting 32 ITEM - D.2.1 Introduction of ACJ-OPS 3.426 – Flight hours reporting 32 SUBPART F 33 ITEM - F.1 Amendment of JAR-OPS 3.470 – Performance applicability 33 ITEM - F.2 Amendment of JAR-OPS 3.475 – Performance general 33 ITEM - F.3 Insertion of new JAR-OPS 3.477 – Obstacle accountability 34 ITEM - F.4 Amendment of JAR-OPS 3.480 – Terminology 36 ITEM - F.4.1 Amendment of IEM-OPS 3.480 – Changed to ACJ 37 ITEM - F.5 Introduction of ACJ-OPS 3.480(a)(31) – Application of TODRH 38 SUBPART G 42 ITEM - G.1 Amendment of JAR-OPS 3.485 – Performance Class 1 general 42 ITEM - G.2 Amendment of JAR-OPS 3.490 – Performance Class 1 Take-off 42 ITEM - G.3 Replacement of JAR-OPS 3.495 – Take-off flight path PC1 44 ITEM - G.4 Amendment of JAR-OPS 3.500 – En-route performance PC1 44



ITEM - G.4.1 Amendment of IEM OPS 3.500 (a) (5) 46 ITEM - G.5 Amendment of JAR-OPS 3.510 – Landing PC1 46 ITEM - G.6 Introduction of ACJ-OPS 3.490 & 510 – Alternative procedures 48 ITEM - G.7 Consequential amendments to Subpart G Section 2 49 SUBPART H 51 ITEM - H.1 Amendment of JAR-OPS 3.515 – Performance Class 2 general 51 ITEM - H.2 Replacement of JAR-OPS 3.517 – Operations without an assured safe forced landing capability 51 ITEM - H.3 Amendment of JAR-OPS 3.520 – Performance Class 2 Take-off 52 ITEM - H.4 Replacement of JAR-OPS 3.525 – Take-off flight path 55 ITEM - H.5 Amendment of JAR-OPS 3.530 – En-route performance PC2 56 ITEM - H.6 Amendment of JAR-OPS 3.535 – Landing PC2 57 ITEM - H.7 Replacement of Appendix 1 to JAR-OPS 3.517(a) – Operations without assured forced landing capability 60 ITEM - H.8 Consequential amendments to Subpart H Section 61 ITEM - H.9 Introduction of ACJ-1 to Appendix 1 to JAR-OPS 3.517(a) – Operations without an assured forced landing capability 61 ITEM - H.10 Introduction of ACJ-2 to Appendix 1 to JAR-OPS 3.517(a) – Operations without an assured forced landing capability 62 ITEM - H.11 Introduction of ACJ to Subpart H – Operations in Performance Class 2 64 SUBPART I 78 ITEM - I.1 Amendment of JAR-OPS 3.540 – Performance Class 2 General 78 ITEM - I.2 Amendment of JAR-OPS 3.545 – Performance Class 3 Take-off 79 ITEM - I.3 Amendment of JAR-OPS 3.550 – En-route performance PC3 79 ITEM - I.4 Amendment of JAR-OPS 3.555 – Landing PC2 80 ITEM - I.5 Introduction of ACJ-OPS 3.540(b) – Take-off and landing phases PC3 81

SUBPART J 83



ITEM - J.1 Amendment of Appendix 1 to JAR-OPS 3.625 – Zero fuel mass 83 ITEM - J.2 Amendment of IEM-OPS 3.605(e) – Fuel densities 83 SUBPART K 84 ITEM - K.1 Amendment of JAR-OPS 3.650, 3.652 and ACJ-OPS 3.650/3.652 – Flight and navigational instruments and associated equipment 84 ITEM - K.2 Amendment of JAR-OPS 3.820 – ELTs 87 ITEM - K.3 Amendment of JAR-OPS 3.827 and 3.837 – Crew Survival Suits 88 ITEM - K.4 Deletion of IEM-OPS 3.827 & insertion of ACJ-OPS 3.827 – Calculation of survival time 88 ITEM - K.5 Amendment of JAR-OPS 3.830 – Liferafts and ELTs 90 SUBPART N 92 ITEM - N.1 Amendment of AMC-OPS 3.945 – Conversion course syllabus 92 ITEM - N.2 Amendment of Appendix 1 to JAR-OPS 3.965 – First-aid training 92



Item B.1

Add new ACJ ACJ to Appendix 1 to JAR-OPS 3.005(d), paragraph (a)(4) HEMS mission (See Appendix 1 to JAR-OPS 3.005(d), paragraph (a)(4)

1. A HEMS mission normally starts and ends at the HEMS Operating Base following tasking by the “HEMS Dispatch Centre”. Tasking can also occur when airborne, or on the ground at locations other than the HEMS Operating Base. 2. I t is intended that the following elements be regarded as integral parts of the HEMS mission - f l ights to and from the HEMS Operating Site when init iated by the HEMS Dispatch Centre; - f l ights to and from a heliport for the delivery or pick-up of medical supplies and/or persons required for completion of the HEMS mission; - f l ights to and from a heliport for refuell ing required for completion of the HEMS mission. All these f l ights are subject to the applicable requirements and alleviations of the HEMS appendix. Add the reference to the new ACJ

(4) Helicopter Emergency Medical Service (HEMS) f l ight . A fl ight by a helicopter operating under a HEMS approval, the purpose of which is to facil i tate emergency medical assistance, where immediate and rapid transportat ion is essential , by carrying:

( i) Medical personnel; or

( i i) Medical supplies (equipment, blood, organs, drugs); or

( i i i) I l l or injured persons and other persons directly involved.

(See also ACJ to Appendix 1 to JAR-OPS 3.005(d), paragraph (a)(4).)

Consequential amendment

Add new definition to Appendix 1 to JAR-OPS 3.005(d) - paragraph (a)(4) and renumber the following definit ions

(4) HEMS dispatch centre. A place where, if established, the coordination or control of the HEMS flight takes



place. I t may be located in a HEMS Operating Base.

Item B.2

Insert new rule (j) into JAR-OPS 3.005

( j) Night VFR operations with the aid of Night Vision Imaging Systems (NVIS) shall only be conducted in accordance with JAR-OPS 3 and procedures contained in the Operations Manual for which a specific approval is required.

Item B.3 Consequential amendments: Item B.3.1

Appendix 1 to JAR-OPS 3.005(d) Helicopter Emergency Medical Service (See ACJ Appendix 1 to JAR-OPS 3.005(d))

Note: The Authority is empowered to decide which operation is a HEMS operation in the sense of this Appendix.

(a) Terminology

(1) D . The largest dimension of the helicopter when the rotors are turning.

Renumber i tems from this point

ItemB.3.2

Appendix 1 to JAR-OPS 3.005(e) Helicopter operations over a hosti le environment located outside a congested area (See IEM to Appendix 1 to JAR-OPS 3.005(e))

(a) and (b) Unchanged

(c) Performance Class 2 alleviation. Helicopters operating in Performance Class 2 over a hostile environment located outside a congested area and with a maximum approved passenger seating configuration [(MAPSC)] of 9 or less passengers are exempt from the following requirements of JAR-OPS Part 3, Subpart H:

(1) JAR-OPS 3.520(a)(2)(i)(A);



(2) JAR-OPS 3.535(a)(2)(i)(B).

(d) Performance Class 3 alleviation. Helicopters operating in Performance Class 3 over a hostile environment located outside a congested area and with a maximum approved passenger seating configuration [(MAPSC)] of 6 or less are exempt from the requirement of JAR-OPS 3.240(a)(5) provided that the operator complies with Appendix 1 to JAR-OPS 3.517(a), sub-paragraphs (a)(2)(i) & (ii) & (v).

Consequential amendment to Appendix 1 to JAR-OPS 3.005(i) - paragraph (d)

Amend reference at end of paragraph

From (See Appendix 1 to JAR-OPS 3.517(a) subparagraphs (a)(2)(ii) and (v) and (b)(2) and (b)(5)).

To (See Appendix 1 to JAR-OPS 3.517(a) subparagraphs (a)(2)(i) and (ii) and (b)(2) and (b)(5)).



Item D.1 Insert new JAR-OPS 3.330(a) as follows;

JAR-OPS 3.330 Accessibil ity of

emergency equipment

(a) The operator shall establish procedures to ensure that when operating overwater in Performance Class 3, account is taken of the duration of the fl ight and condit ions to be encountered when deciding if the l ifejackets should be worn by all occupants .

(b) The commander shall ensure that relevant emergency equipment remains easily accessible for immediate use.

Item D.2 Insert new JAR-OPS 3.426 as follows;

JAR-OPS 3.426 Flight hours reporting (See ACJ OPS 3.426)

(a) An operator shall make available to the Authority the hours f lown for each helicopter operated during the previous calendar year .

Item D.2.1 Insert new ACJ OPS 3.426 as follows;

ACJ OPS 3.426 Flight hours reporting (See JAR-OPS 3.426)

The requirement of JAR-OPS 3.426 may be achieved by making available ei ther:

- the fl ight hours f lown by each helicopter – identified by i ts serial number and registration mark - during the elapsed calendar year; or

- the total f l ight hours of each helicopter – identified by i ts serial number and registration mark – on the 31s t of December of the elapsed calendar year.

Where possible, the operator should have available, for each helicopter, the breakdown of hours for CAT, aerial work, general aviation. If the exact hours for the functional activity cannot be established, the est imated proportion wil l be sufficient .

I tem D.3



Insert text into the exist ing JAR-OPS 3.210(d as follows:

(d) An operator shall mot permit a helicopter rotor to be turned under power for the purpose of f l ight without a qualified pilot at the controls (see ACJ OPS 3.210(d)) .

Insert new ACJ into Section 2 Subpart D

ACJ OPS 3.210(d)

The intent of this paragraph is to ensure that the pilot remains at the controls when the rotors are turning under power whilst not preventing ground runs being conducted by qualif ied personnel other than pilots. The operator should ensure that the qualification of personnel, other than pilots, who are authorised to conduct ground runs is described in the appropriate manual.



Item F.1

Amend paragraph (a) as shown

JAR-OPS 3.470 Applicability

(a) An operator shall ensure that helicopters which have a maximum approved passenger seating configuration of more than 19, or helicopters operating to/from heliports located in a congested hosti le environment, are operated in accordance with JAR-OPS Part 3, Subpart G (Performance Class 1);

(1) helicopters operating to/from heliports located in a congested hosti le environment: or

(2) helicopters which have a maximum approved passenger seating configuration (MAPSC) of more than 19;

are operated in accordance with JAR-OPS Part 3, Subpart G (Performance Class 1); except that helicopters:

with a maximum approved passenger seating configuration (MAPSC) of more than 19 and operated to/from helidecks; which may be operated in accordance with JAR-OPS 3.517(a)

or

which have an operational approval in accordance with Appendix 1 to JAR-OPS 3.005(i)

(b) and (c) unchanged

Item F.2

Amend JAR-OPS 3.475 paragraph (c) as shown

JAR-OPS 3.475 General

(a) to (b) unchanged

(c) When showing compliance with the requirements of the appropriate Subpart , due account shall be taken of the following parameters: helicopter configuration, environmental conditions and the operation of systems which have an adverse effect on performance.

(1) mass of the helicopter;



(2) helicopter configuration;

(3) environmental condit ions, in particular:

( i)pressure-alt i tude, and temperature;

( i i) wind:

(A) for take-off , take-off f l ight path and landing requirements, accountabil i ty for wind shall be no more than 50% of any reported steady head wind component of 5 knots or more.

(B) Where take-off and landing with a tai l wind component is permitted in the Helicopter Flight Manual, and in all cases for the take-off f l ight path, not less than 150% of any reported tai l wind component shall be taken into account.

(C) Where precise wind measuring equipment enables accurate measurement of wind velocity over the point of take-off and landing, alternate wind components specific to a si te may be approved by the Authority. (See ACJ OPS 3.475(c)(3)(i i));

(4) operating techniques; and

(5) operation of any system which have adverse effect on performance.

Consequential amendment to the t i t le of IEM OPS 3.490(a)(3)(i i)(b) & 3.495(b)(4) to ACJ OPS 3.475(c)(3)(i i)

Item F.3

Add new JAR-OPS 3.477

JAR-OPS 3.477 – Obstacle accountability

(See ACJ to Subpart H)

(a) For the purpose of obstacle clearance requirements, an obstacle, located beyond the FATO, in the take-off f l ight path or the missed approach fl ight path, shall be considered if i ts lateral distance from the nearest point on the



surface below the intended fl ight path is not further than:

(1) For VFR operations:

( i) half of the minimum FATO (or the equivalent term used in the Flight Manual) width defined in the Helicopter Flight Manual (or, when no width is defined 0.75 D), plus 0.25 t imes D (or 3 m, whichever is greater), plus:

0.10 DR for VFR day operations

0.15 DR for VFR night operations

(2) For IFR operations:

( i) 1.5 D (or 30 m, whichever is greater), plus:

0.10 DR for IFR operations with accurate course guidance

0.15 DR for IFR operations with standard course guidance

0.30 DR for IFR operations without course guidance

(i i) when considering the missed approach fl ight path, the divergence of the obstacle accountabil i ty area only applies after the end of the take-off distance available;

( i i i ) s tandard course guidance includes ADF and VOR guidance. Accurate course guidance include ILS, MLS or other course guidance providing an equivalent navigational accuracy.

(3) For operations with initial take-off conducted visually and converted to IFR/IMC at a transit ion point , the cri teria required in (1) apply up to the transition point then the cri teria required in (2) apply after the transit ion point:

( i) the transition point cannot be located before the end of TODRH for helicopters operating in performance Class 1 and before the DPATO for helicopters operating in performance Class 2;

(b) For take-off using a backup (or a lateral transit ion) procedure; for the



purpose of obstacle clearance requirements, an obstacle, located in the back-up (or lateral transit ion) area, shall be considered if i ts lateral distance from the nearest point on the surface below the intended flight path is not further than:

(1) half of the minimum FATO (or the equivalent term used in the Flight Manual) width defined in the Helicopter Flight Manual (or, when no width is defined 0.75 D), plus 0.25 times D (or 3 m, whichever is greater), plus 0.10 for VFR day, or 0.15 for VFR night, of the distance travelled from the back of the FATO.

(see ACJ OPS 3.490(d))

(c) Obstacles may be disregarded if they are si tuated beyond:

(1) 7 R for day operations if i t is assured that navigational accuracy can be achieved by reference to suitable visual cues during the cl imb;

(2) 10 R for night operations if i t is assured that navigational accuracy can be achieved by reference to suitable visual cues during the cl imb;

(3) 300 m if navigational accuracy can be achieved by appropriate navigation aids; and

(4) 900 m in the other cases

Item F.4

Amend JAR-OPS 3.480 as shown

JAR-OPS 3.480 Terminology

(a) Terms used in Subparts F, G, H, and I and J and not defined in JAR-1 have the following meaning:

(1) . 'Category A' with respect to helicopters means multi-engine helicopters designed with engine and system isolation features specified in JAR-27/29 CS-27/29 or equivalent acceptable to the JAA Authority and Helicopter Flight Manual performance information based on a critical engine failure concept which assures adequate designated surface area and adequate performance capability for continued safe flight in the event of an engine failure.

(2) to (4) unchanged



(5) D. The largest dimension of the helicopter when the rotors are turning.

Renumber (5) to (13) (all + 1)

Renumber and add the acronym into the t i t le of the following definitions

(1415) Landing distance available (LDAH)…

(1516) Landing distance required (LDRH) . The horizontal distance required to land and come to a full s top from a point 15m (50ft) 10.7 (35ft) above the landing surface.

(1617) Maximum approved passenger seating configuration (MAPSC)…

Renumber (17) to (23) (all + 1).

(24) Rejected take-off distance available (RTODAH). The length of the f inal approach and take-off area declared available and suitable for helicopters operated in Performance Class 1 to complete a rejected take-off .

(2325) Rejected take-off distance required (RTODRH)…

Renumber (27)and (28) (+ 1).

(2930) Take-off distance available (TODAH) . The length of the final approach and take-off area plus the length of helicopter clearway (if provided) declared available and suitable for helicopters to complete the take-off.

Amend the definit ion of take-off-distance-required

(3031) Take-off distance required (TODRH) . The horizontal distance required from the start of the take-off to the point at which VT O S S, a selected height of 10.7 m (35 ft)above the take-off surface, and a posit ive cl imb gradient are achieved, following fai lure of the cri t ical power unit being recognised at TDP, the remaining power–unit(s) operat ing within approved operating l imits . The selected height is to be determined with the use of Helicopter Flight Manual data, and is to be at least 10.7 m (35 ft) above:

( i) the take-off surface; or



( i i) as an alternative, a level defined by the highest obstacle in the take-off distance required.

Add new (32) definit ion of take-off- f l ight-path.

(32) Take-off f l ight path. The vertical and horizontal path, with the cri t ical power-unit inoperative, from a specified point in the take-off to 1000 ft above the surface.

Renumber to end of paragraph (plus 2).

Delete paragraph (b)

(b) The terms ' take-off distance required ' , ' take-off fl ight path ' , 'cr i t ical power unit inoperative en-route f l ight path' al l have their meanings defined in the airworthiness requirements under which the helicopter was cert ificated, or as specified by the Authority if i t f inds the data provided in the Helicopter Flight Manual inadequate for showing compliance with the performance operating limitat ions.

Item F.4.1

Amend the t i t le of IEM OPS 3.480(a)(1) and (a)(2) to ACJ OPS and insert new references

IEMACJ OPS 3.480(a)(1) and (a)(2) Category A and Category B See JAR-OPS 3.480(a)(1) and (a)(2) See JAR-OPS 3.485 See JAR-OPS 3.515(a)(1) See JAR-OPS 3.540(a)(1) Amend the t i t le of IEM OPS 3.480(a)(12) IEM OPS 3.480(a)(123) Terminology - Hostile Environment See JAR-OPS 3.480(a)(123)

Item F.5

Add new ACJ

ACJ OPS 3.480(a)(31) The application of TODRH See JAR-OPS 3.480(a)(31)

1. DISCUSSION

Original definit ions for helicopter performance were derived from aeroplanes; hence the definit ion of take-off distance owes much to operations from



runways. Helicopters on the other hand can operate from runways, confined and restricted areas and rooftop heliports - al l bounded by obstacles. As an analogy this is equivalent to a take-off from a runway with obstacles on and surrounding i t .

I t can therefore be seen that unless the original definit ions from aeroplanes are tailored for helicopters, the f lexibil i ty of the helicopter might be constrained by the language of operational performance.

This paper concentrates on the cri t ical term - Take-off Distance Required (TODRH) - and describes the methods to achieve compliance with i t and, in particular, the alternative procedure described in ICAO Annex 6 Attachment A 4.1.1.2(b):

. . . the take-off distance required does not exceed the takeoff distance available; or

As an al ternative, the take-off distance required may be disregarded provided that the helicopter with the cri t ical power-unit fai lure at the TDP can, when continuing the take-off, clear al l obstacles between the end of the take-off distance available and the point at which i t becomes established in a cl imb at VTOSS by a vert ical margin of 10.7 m (35 ft) or more. An obstacle is considered to be in the path of the helicopter if i ts distance from the nearest point on the surface below the intended l ine of f l ight does not exceed 30 m or 1.5 t imes the maximum dimension of the helicopter , whichever is greater .

2. DEFINITION OF TODRH

The definition of TODRH from JAR-OPS 3.480(a)(31) is as follows:

(31) Take-off distance required (TODRH). The horizontal distance required from the start of the take-off to the point at which VT O S S, a selected height, and a posit ive cl imb gradient are achieved, following failure of the cri t ical power-unit being recognised at TDP, the remaining power-unit(s) operating within approved operating l imits. The selected height is to be determined with the use of Helicopter Flight Manual data, and is to be at least 10.7 m (35 f t) above:

( i) the take-off surface; or

( i i) as an alternative, a level defined by the highest obstacle in the take-off distance required.

The original definition of TODRH was based only on the f irst part of this definition.

3. THE CLEAR AREA PROCEDURE (RUNWAY)

In the past , helicopters cert if icated in Category A would have had, at the least , a ‘clear area’ procedure. This procedure is analogous to an aeroplane Category A procedure and assumes a runway (ei ther metalled or grass) with a smooth surface suitable for an aeroplane take-off (see Figure 1).

The helicopter is assumed to accelerate down the FATO (runway) outside of the HV diagram. If the helicopter has an engine failure before TDP, i t must be able to land back on the FATO (runway) without damage to helicopter or passengers; if there is a failure at or after TDP the aircraft is permitted to lose height - providing i t does not descend below a specified height above the surface (usually 15 ft i f the TDP is above 15 f t) . Errors by the pilot are taken



into consideration but the smooth surface of the FATO limits serious damage if the error margin is eroded (e.g. by a change of wind conditions).

Figure 1 - Clear Area take-off

The operator only has to establish that the distances required are within the distance available ( take-off distance and reject distance). The original definit ion of TODRH meets this case exactly.

From the end of the TODRH obstacle clearance is given by the cl imb gradient of the f irst or second climb segment meeting the requirement of JAR-OPS 3.495 (or for PC2 - JAR-OPS 3.525). The clearance margin from obstacles in the take-off f l ight path takes account of the distance travelled from the end of the take-off distance required and operational conditions (IMC or VMC).

4. CATEGORY A PROCEDURES OTHER THAN CLEAR AREA

Procedures other than the clear area are treated somewhat differently. However, the short f ield procedure is somewhat of a hybrid as ei ther part of the definition of TODRH can be uti l ised ( the term ‘helipad’ is used in the following section to i l lustrate the principle only - i t is not intended as a replacement for ‘heliport’) .

4.1 Limited area, restricted area and helipad procedures (other than elevated)

The exact names of the procedure used for other than clear area are as many as there are manufacturers. However, principles for obstacle clearance are generic and the name is unimportant.

These procedures (see Figure 2 and Figure 3) are usually associated with an obstacle in the continued take-off area - usually shown as a l ine of trees or some other natural obstacle. As clearance above such obstacles is not readily associated with an accelerative procedure, as described in 3 above, a procedure using a vert ical cl imb (or a steep cl imb in the forward, sideways or rearward direction) is uti l ised.

15 ft

TDP

35 ft

Take-off Distance Required (i)

Vtoss & +Climb Gradient

Reject Distance



Figure 2 - Short Field take-off

With the added complication of a TDP principally defined by height together with obstacles in the continued take off area, a drop down to within 15 f t of the take-off surface is not deemed appropriate and the required obstacle clearance is set to 35 ft (usually called min-dip). The distance to the obstacle does not need to be calculated (provided i t is outside the rejected distance required), as clearance above all obstacles is provided by ensuring that helicopter does not descend below the min-dip associated with a level defined by the highest obstacle in the continued take-off area.

Figure 3 - Helipad take-off

These procedures depend upon the alternative definit ion of TODRH.

As shown in Figure 3, the point at which Vtoss and a posit ive rate of cl imb are met defines the TODRH. Obstacle clearance from that point is assured by meeting the requirement of JAR-OPS 3.495 (or for PC2 - JAR-OPS 3.525). Also shown in Figure 3 is the distance behind the helipad which is the back-up distance (B/U distance).

4.2 Elevated helipad procedures

The elevated helipad procedure (see Figure 4) is a special case of the ground level helipad procedure discussed above.

TDP

35 ft


Take-off Distance Required (ii) B/U distance

TDP

35 ft


Take-off Distance Required (ii)

Reject Distance



Figure 4 - Elevate Helipad take-off

The main difference is that drop down below the level of the take-off surface is permitted. In the drop down phase, the Category A procedure ensures deck-edge clearance but, once clear of the deck-edge, the 35 ft clearance from obstacles rel ies upon the calculation of drop down. The alternative definit ion of the TODRH is applied.

Note: 35ft may be inadequate at particular elevated heliports which are subject to adverse airflow effects, turbulence, etc.

TDP

35 ft


Take-off Distance Required (ii) B/U distance



Item G.1

Add reference to JAR-OPS 3.485 as shown

JAR–OPS 3.485 General

An operator shall ensure that helicopters operated in Performance Class 1 are cert ificated in Category A (see ACJ OPS 3.480(a)(1) and (a)(2)) .

Item G.2

Amend existing JAR-OPS 3.490 as shown

JAR-OPS 3.490 Take-off

(a) An operator shall ensure that:

(1) The take-off mass does not exceed the maximum take-off mass specified in the Helicopter Flight Manual , for the procedure to be used (see ACJ OPS 3.490 & 3.510)' s category A performance section for the pressure al t i tude and the ambient temperature at the heliport of departure. (See IEM OPS 3.490(a)(1) & 3.510(a)(1).)

(2) For Non-elevated Heliports tThe take-off mass is such that:

( i) i t is possible to reject the take-off and land on the FATO in case of the cri t ical power-unit failure being recognised at or before the TDP;

( i i) The rejected take-off distance required does not exceed the rejected take-off distance available; and

(i i i) The take-off distance required does not exceed the take-off distance available.

( iv) As an alternative, the requirement in JAR-OPS 3.490(a)(2)(i i i) above may be disregarded provided that the helicopter, with the cri t ical power-unit failure recognised at TDP can, when continuing the take-off, clear al l obstacles to the end of the take-off distance required by a vert ical margin of not less than 10.7 m (35 ft) (see ACJ OPS 3.480(a)(31));



(3) For Elevated Heliports and Helidecks the take-off mass does not exceed the maximum take-off mass specified in the Helicopter Flight Manual for the take-off procedure being used and is such that the helicopter is capable of:

( i) In the event of a cri t ical power unit failure being recognised at or before the take-off decision point TDP, rejecting the take-off and landing on the elevated heliport or helideck; and

( i i) In the event of a cri t ical power unit failure being recognised at or after TDP, continuing the take-off, clearing the elevated heliport or helideck and thereafter clearing al l obstacles under the f l ight path of the helicopter by a vert ical margin of at least 35 f t up to the end of the take-off distance required. Obstacle clearance margins in excess of 35 ft may be specified by the Authority at a part icular heliport . (See IEM OPS 3.490(a)(3)(i i) . )

(b) When showing compliance with sub-paragraph (a) above, account shall be taken of the following parameters appropriate parameters of JAR-OPS 3.475(c) at the heliport of departure:

(1) The pressure al t i tude;

(2) The ambient temperature;

(3) The take-off procedure to be used; and

(4) Not more than 50% of the reported head-wind component or, i f such data is provided, not less than 150% of the reported tail-wind component. [Alternative wind components specific to a si te may be approved by the Authori ty. (See IEM OPS 3.490(b)(4)) .

(c) The part of the take-off up to and including TDP shall be conducted in sight of the surface such that a rejected take-off can be carried out.

(d) For take-off using a backup (lateral transit ion) procedure, the operator shall ensure that, with the cri t ical power-unit inoperative, all obstacles in the back-up (lateral transit ion) area are cleared by an adequate margin (see ACJ OPS 3.490(d))



Add new ACJ

ACJ OPS 3.490(d) Obstacle Clearance in the Back-up Area See JAR-OPS 3.490(d) The requirement in JAR-OPS 3.490(d) has been established in order to take into account the following factors: In the back-up; the pilot has few visual cues and has to rely upon the altimeter and sight picture through the front window (if flight path guidance is not provided) to achieve an accurate rearward flight path. In the rejected take-off; the pilot has to be able to manage the descent against a varying forward speed whilst still ensuring an adequate clearance from obstacles until the helicopter gets in close proximity for landing on the FATO. In the continued take-off; the pilot has to be able to accelerate to Vtoss whilst ensuring an adequate clearance from obstacles. The requirements of JAR-OPS 3.490(d) may be achieved by establishing that, in the backup area: no obstacles are located within the safety zone below the rearward flight path when

described in the helicopter flight manual (see figure 1); (in the absence of such data in the helicopter flight manual, the operator should contact the manufacturer in order to define a safety zone);or during the backup, the rejected take-off and the continued take-off manoeuvres, obstacle

clearance has been demonstrated by a means acceptable to the authority.

Figure 5 – rearward flight path

An obstacle, in the backup area, is considered if its lateral distance from the nearest point on the surface below the intended flight path is not further than half of the minimum FATO (or the equivalent term used in the Flight Manual) width defined in the Helicopter Flight Manual (or, when no width is defined 0.75

Safety Zone

Max TDP

TDP

X metres Safety Zone

Y metres Z metres

z ft

y ft

Rearward Flight Path x degrees

No obstacle above this line



D), plus 0.25 times D (or 3m, whichever is greater); plus 0.10 for VFR day, or 0.15 for VFR night, of the distance travelled from the back of the FATO. (see figure 2).

Figure 2 – Obstacle accountability

Item G.3

Delete exist ing JAR-OPS 3.495 Inset new JAR-OPS 3.495

JAR-OPS 3.495 Take-off Flight Path

(a) An operator shall ensure that, from the end of the take-off distance required with the cri t ical power unit fai lure recognised at the TDP:

(1) The take-off mass is such that the take-off f l ight path provides a vert ical clearance of not less than 10.7 m (35 ft) for VFR operations and 10.7 m (35 ft) + 0.01 DR for IFR operations above all obstacles located in the cl imb path. Only obstacles as specified in JAR-OPS 3.477 have to be considered.

(2) . Where a change of direction of more than 15° is made, adequate allowance is made for the effect of bank angle on the abil i ty to comply with the obstacle clearance requirements. This turn is not to be init iated before reaching a height of 61 m (200 ft) above the take-off surface unless permitted as part of an approved procedure in the Flight Manual.

(b) When showing compliance with sub-paragraph (a) above, account shall be taken of the appropriate parameters of JAR-OPS 3.475(c) at the heliport of departure.

10 or 15 %

10 or 15 % Safety area Max TDP

FATO Safety zone

TDP



Item G.4

Amend existing JAR-OPS 3.500 as shown

JAR-OPS 3.500 En-route - critical power unit inoperative

(a) An operator shall ensure that:(1)T the en-route fl ight path with the cri t ical power unit inoperative, appropriate to the meteorological condit ions expected for the f l ight complies with ei ther sub-paragraph (1), (2) or (3) below at al l points along the route.

(21) When i t is intended that the f l ight wil l be conducted at any t ime out of sight of the surface, the mass of the helicopter permits a rate of cl imb of at least 50 f t /minute with the cri t ical power unit inoperative at an alt i tude of at least 300 m (1 000 ft) , 600 m , (2 000 ft) in areas of mountainous terrain , above all terrain and obstacles along the route within 9.3 km (5 nm) on either side of the intended track.obstacles along the route within 18·5 km (10 nm) on ei ther side of the intended track. When i t is intended that the fl ight wil l be conducted in VMC and in sight of the surface, the same requirement applies except that only obstacles within 900 m on ei ther side of the route need be considered.

(2) When i t is intended that the f l ight wil l be conducted without the surface in sight, the fl ight path permits the helicopter to continue flight from the cruising alt i tude to a height of 300 m (1000 ft) above a landing si te where a landing can be made in accordance with JAR-OPS 3.510. The flight path clears vert ically, by at least 300 m (1000 ft) , 600 m (2000 ft) in areas of mountainous terrain, all terrain and obstacles along the route within 9.3 km (5 nm) on ei ther side of the intended track. Drift-down techniques may be used.

(3) The fl ight path permits the helicopter to continue fl ight from the cruising alt i tude to a height of 300 m (1 000 ft) above the heliport where a landing can be made in accordance with JAR-OPS 3.510. The f l ight path clears vert ically, by at least 300 m (1 000 ft)



600 m (2 000 ft) in areas of mountainous terrain al l obstacles along the route within 18·5 km (10 nm) on ei ther side of the intended track. The cri t ical power unit is assumed to fai l at the most crit ical point along the route. When i t is intended that the fl ight will be conducted in VMC and in sight of the surface, the same requirement applies except that only obstacles within 900 m in either side of the route need be considered. Drift-down techniques may be used.

(3) When it is intended that the f l ight wil l be conducted in VMC with the surface in sight, the fl ight path permits the helicopter to continue flight from the cruising alt i tude to a height of 300 m (1000 ft) above a landing si te where a landing can be made in accordance with JAR-OPS 3.510, without f lying at any t ime below the appropriate minimum fl ight al t i tude, obstacles within 900m on either side of the route need to be considered.

(b) When showing compliance with paragraph (a)(2) or (a)(3) above, an operator shall ensure that:

(1) The cri t ical power unit is assumed to fail at the most cri t ical point along the route

(42) Account is taken of the effects of winds on the fl ight path.

(53) Fuel jett isoning is planned to take place only to an extent consistent with reaching the heliport with the required fuel reserves and using a safe procedure (See IEM OPS 3.500(b)(3)(a)(5)) .

(64) Fuel jett isoning is not planned below 1000 ft above terrain.

(b) When showing compliance with this paragraph, the width margins of sub-paragraphs (a)(2) and (a)(3) above may be reduced to 9·3 km (5 nm) if the required navigational accuracy can be achieved.

(c) The width margins of sub-paragraphs (a)(1) and (a)(2) above shall be increased to 18.5 km (10 nm) if the navigational accuracy cannot be met for 95% of the total f lying t ime (see JAR-OPS 3.240, 3.243 and 3.250.



Item G.4.1

Amend IEM OPS 3.500(a)(5)(b)(3)

Item G.5


JAR-OPS 3.510 Landing


(1) The landing mass of the helicopter at the est imated time of landing does not exceed the maximum mass specified in the Helicopter Flight Manual , for the procedure to be used (see ACJ OPS 3.490 & 3.510). ' s category A performance section for the pressure al t i tude and the ambient temperature expected for the est imated t ime of landing at the destination heliport , or any al ternate if required. (See IEM OPS 3.490(a)(1) & 3.510(a)(1)) .

(2) in the event of the cri t ical power-unit failure being recognised at any point at or before the LDP, i t is possible ei ther to land and stop within the FATO, or to perform a balked landing and clear all obstacles in the f l ight path by a vertical margin of 10.7 m (35 ft) (see ACJ OPS 3.480(a)(31)). Only obstacles as specified in JAR-OPS 3.477 have to be considered;

(3) in the event of the cri t ical power-unit failure being recognised at any point at or after the LDP, i t is possible to clear all obstacles in the approach path; and

(4) in the event of the cri t ical power-unit failure being recognised at any point at or after the LDP, i t is possible to land and stop within the FATO.

(b) When showing compliance with sub-paragraph (a) above, account shall be taken of the appropriate parameters of JAR-OPS 3.475(c) for the est imated time of landing at the dest ination heliport, or any alternate if required.



(2) For Non-elevated Heliports , the landing mass is such that , in the event of a cri t ical power unit fai lure being recognised at any point during the approach and landing phase the helicopter is capable of:

( i) In the event of a cri t ical power unit failure being recognised at or before the landing decision point (LDP), performing a baulked landing, clearing al l obstacles under the f l ight path; and

( i i) In the event of a cri t ical power unit failure being recognised at or after the LDP, landing and stopping within the landing distance available at the heliport .

(3) For Elevated Heliports and Helidecks, the landing mass does not exceed the maximum landing mass approved for the landing procedure being used and is such that the helicopter is capable of:

( i) In the event of a cri t ical power unit failure being recognised at or before LDP, performing a baulked landing, clearing the elevated heliport or helideck and thereafter clearing al l obstacles under] the f l ight path. (See IEM OPS 3.510(a)(3)(i) .)

( i i ) In the event of a cri t ical power unit failure being recognised at or after the LDP, landing on the elevated heliport or helideck.

(b) When showing compliance with sub-paragraph (a) above, account shall be taken of the following parameters for the est imated t ime of landing at the destination heliport or any alternate if required:


(2) The ambient air temperature;

(3) The landing procedure to be used;

(4) Not more than 50% of the expected head-wind component; and

(5) Any expected variat ion in the mass of the helicopter during fl ight .



(c) That part of the landing from the LDP to touchdown shall be conducted in sight of the surface.

Item G.6

Insert new ACJ

ACJ OPS 3.490 and 3.510 Application for alternative take-off and landing procedures Discussion A manufacturer’s Category A procedure defines profiles and scheduled data for take-off, climb, performance at minimum operating speed and landing, under specific environmental conditions and masses.

Associated with these profiles and conditions are minimum operating surfaces, take-off distances, climb performance and landing distances; these are provided (usually in graphic form) with the take-off and landing masses and the Take-off Decision Point (TDP) and Landing Decision Point (LDP).

The landing surface and the height of the TDP are directly related to the ability of the helicopter - following a power-unit failure before or at TDP - to reject onto the surface under forced landing conditions. The main considerations in establishing the minimum size of the landing surface are the scatter during flight testing of the reject manoeuvre, with the remaining engine operating within approved limits, and the required usable cue environment.

Hence an elevated site with few visual cues - apart from the surface itself - would require a greater surface area in order that the helicopter can be accurately positioned during the reject manoeuvre within the specified area. This usually results in the stipulation of a larger surface for an elevated site than for a ground level site (where lateral cues may be present).

This could have the unfortunate side-effect that a heliport which is built 3m above the surface (and therefore elevated by definition) might be out of operational scope for some helicopters - even though there might be a rich visual cue environment where rejects are not problematical. The presence of elevated sites where ground level surface requirements might be more appropriate could be brought to the attention of the Authority.

It can be seen that the size of the surface is directly related to the requirement of the helicopter to complete a rejected take-off following a power-unit failure. If the helicopter has sufficient power such that a failure before or at TDP will not lead to a requirement for rejected take-off, the need for large surfaces is removed; sufficient power for the purpose of this ACJ is considered to be the power required for hover-out-of-ground-effect (HOGE) one-engine-inoperative (OEI).

Following a power-unit failure at or after the TDP, the continued take-off path provides OEI clearance from the take-off surface and the distance to reach a point from where climb performance in the first, and subsequent segments, is assured.

If HOGE OEI performance exists at the height of the TDP, it follows that the continued take-off profile, which has been defined for a helicopter with a mass such that a rejected take-off would be required following a power-unit failure at or before TDP, would provide the same, or better, obstacle clearance and the same, or less, distance to reach a point where climb performance in the first, and subsequent segments, is assured.



If the TDP is shifted upwards, provided that the HOGE OEI performance is established at the revised TDP, it will not affect the shape of the continued take-off profile but should shift the min-dip upwards by the same amount that the revised TDP has been increased - with respect to the basic TDP.

Such assertions are concerned only with the vertical or the back-up procedures and can be regarded as achievable under the following circumstances:

1. When the procedure is flown, it is based upon a profile contained in the Helicopter Flight Manual (HFM) - with the exception of the necessity to perform a rejected take-off.

2. The HOGE OEI performance is specified as in AC 29-2C, MG 12 for the Human External Cargo (HEC) Class D requirements.

3. The TDP, if shifted upwards (or upwards and backward in the back-up procedure) will be the height at which the HOGE OEI performance is established.

4. If obstacles are permitted in the back-up area they should continue to be permitted with a revised TDP.

Methods of Application:

An operator may apply to the Authority for a reduction in the size of the take-off surface under the following conditions:

Compliance with the requirements of JAR-OPS 3.490, 3.495 and 3.510 can be assured with:

1 a procedure based upon an appropriate Category A take-off and landing profile scheduled in the HFM;

2 a take-off or landing mass not exceeding the mass scheduled in the HFM for a HOGE OEI in compliance with HEC Class D performance requirements ensuring that:

2.1 following a power-unit failure at or before TDP, there are adequate external references to ensure that the helicopter can be landed in a controlled manner; and

2.2 following a power-unit failure at or after the LDP there are adequate external references to ensure that the helicopter can be landed in a controlled manner.

An operator may apply to the Authority for an upwards shift of the TDP and LDP under the following conditions:

Compliance with the requirements of JAR-OPS 3.490, 3.495 and 3.510 can be assured with:

3 a procedure based upon an appropriate Category A take-off and landing profile scheduled in the HFM;

4 a take-off or landing mass not exceeding the mass scheduled in the HFM for a HOGE OEI in compliance with HEC Class D performance requirements ensuring that:

4.1 following a power-unit failure at or after TDP compliance with the obstacle clearance requirements of JAR-OPS 3.490(a)(2)(iv) and JAR-OPS 3.495 can be met; and

4.2 following a power-unit failure at or before the LDP the balked landing obstacle clearance requirements of JAR-OPS 3.510(a)(2) and JAR-OPS 3.495 can be met.



Alternatively, an operator may apply to the Authority for the use of the Category A ground level surface requirement for a specific elevated heliport when it can be demonstrated that the usable cue environment at that heliport would permit such a reduction.

Item G.7

Delete or amend Subpart G Section 2 material as indicated:

Delete: IEM OPS 3.490(a)(1) & 3.510(a)(1)

Delete IEM OPS 3.490(a)(3)(ii)

IEM OPS 3.490(b)(4) & 3.495(b)(5) (removed to Subpart F and renamed ACJ OPS 3.475(c)(3)(i i))

Rename IEM OPS 3.500(a)(5) to ACJ OPS 3.500(b)(3)

Delete IEM OPS 3.510(a)(3)(i) .



Item H.1



(a) An operator shall ensure that:(1) Hhelicopters operated in Performance Class 2 are certificated in Category A (see also ACJ to JAR-OPS 3.480(a)(1) and (a)(2)).

(2) Operations in Performance Class 2 other than those complying with JAR-OPS 3.517 are not conducted from/to ei ther elevated heliports or helidecks:

( i) At night; or

( i i ) When located in a hosti le environment.

Item H.2

Delete JAR-OPS 3.517 as shown

JAR-OPS 3.517 Applicability

(a) Performance Class 2 operations from/to helidecks or from/to elevated heliports in a non-hosti le environment or a non-congested hostile environment, may be conducted with an exposure t ime to a power unit fai lure during take-off or landing unti l 31 December 2009 (see IEM OPS 3.517(a)) , provided the operator has been granted a relevant approval by the Authority (See Appendix 1 to JAR-OPS 3.517(a), JAR-OPS 3.520, JAR-OPS 3.535).

(b) Performance Class 2 operations from/to ei ther elevated heliports in a non-congested hosti le environment or helidecks, not approved under sub-paragraph (a) above, may continue unti l 31 March 2005, provided they are conducted in accordance with procedures approved by the Authority [(See IEM OPS 3.517(b))

Insert new JAR-OPS 3.517

JAR-OPS 3.517 Operations Without an Assured Safe Forced Landing Capability

(a) An operator shall be satisfied that operations without an assured safe forced landing capabil i ty during the take-off and landing phases are not conducted unless



the operator has been granted the relevant approval by the Authority in accordance with Appendix 1 to JAR-OPS 3.517(a). (See also JAR-OPS 3.470(a)(1).)

Item H.3

Delete all after paragraph (a)(1) and insert new text

JAR-OPS 3.520 Take-off (See ACJ to Subpart H) (See IEM OPS 3.520) (See IEM-OPS 3.520 & 3.535)

(a) An operator shall be satisf ied that:

(1) The take-off mass does not exceed the maximum mass specified for a rate of climb of 150 f t /min at 300 m (1 000 ft) above the level of the heliport with the cri t ical power unit inoperative and the remaining power units operat ing at an appropriate power rating.

(2) For operations other than specified in JAR-OPS 3.517(a), the take-off is conducted such that a safe forced landing can be executed until the point where safe continuation of the f l ight is possible (see ACJ to Subpart H paragraph 6.2).

(3) For operations in accordance with JAR-OPS 3.517(a) in addit ion to the requirements of (a)(1) above:

( i) The take-off mass does not exceed the maximum mass specified in the Helicopter Flight Manual for an AEO OGE hover in st i l l air with all power units operating at an appropriate power rating.

( i i) For operations to/from a helideck:

(A) with a helicopter that has a maximum approved passenger seating configuration (MAPSC) of more than 19; and

(B) from 1st January 2010 any helicopter operated to/from a helideck located in a non-congested hosti le environment as defined in JAR-OPS 3.480(13)(i i)(A)



the take-off mass takes into account: the procedure; deck-edge miss; and drop down appropriate to the height of the helideck - with the cri t ical power unit(s) inoperative and the remaining power units operating at an appropriate power rating.

(b) When showing compliance with sub-paragraph (a) above, account shall be taken of the appropriate parameters of JAR-OPS 3.475(c) at the heliport of departure.

(c) The part of the take-off before the requirement of JAR-OPS 3.525 is met shall be conducted in sight of the surface.

(2) For operations without an approval to operate with an exposure t ime: (See IEM OPS 3.520(a)(2).)

( i) The take-off mass does not exceed the maximum take-off mass specified for the take-off procedure being used and is such that the helicopter is capable of:

(A) In the event of the cri t ical power unit fai lure being recognised at or before the defined point after take-off (DPATO), carrying out a safe forced landing on the heliport or on the surface; and

(B) In the event of the cri t ical power unit fai lure being recognised after the DPATO, continuing the f l ight .

( i i ) The part of the take-off during which the cri t ical power unit fai lure may lead to a forced landing is conducted only over a surface that permits a safe forced landing to be executed in the event of the cri t ical power unit fai lure.

(3) For operations on helidecks or elevated heliports located in a non hostile environment, with an approval to operate with an exposure t ime (see JAR-OPS 3.517(a)):

( i ) The take-off mass does not exceed the maximum take-off mass specified for the take-off procedure



being used and is such that the helicopter is capable of:

(A) In the event of the cri t ical power unit fai lure being recognised between the end of the exposure t ime and the DPATO, carrying out a safe forced landing on the heliport or on the surface; and

(B) In the event of the cri t ical power unit fai lure being recognised after the DPATO, continuing the fl ight.

( i i ) The part of the take-off between the end of the exposure t ime and the DPATO is conducted only over a surface that permits a safe forced landing to be executed in the event of the cri t ical power unit failure.

( i i i) If the cri t ical power unit fai lure occurs during the exposure t ime a safe force landing may not be possible.

(4) For operations on helidecks or elevated heliports located in a non-congested hosti le environment, with an approval to operate with an exposure t ime (See JAR-OPS 3.517(a)):

( i) The take-off mass does not exceed the maximum take-off mass specified for the take-off procedure being used and is such that , in the event of the cri t ical power unit fai lure being recognised after the end of the exposure t ime, the helicopter is capable of continuing the f l ight.

( i i ) If the cri t ical power unit fai lure occurs during the exposure t ime a safe force landing may not be possible.

(b) When showing compliance with sub-paragraph (a) above, account shall be taken of the following parameters at the heliport of departure:



(3) The take-off procedure to be used; and

(4) Not more than 50% of the reported head-wind component or, i f such



data is provided, not less than 150% of the reported tai l-wind component.

(c) The part of the take-off prior to or at the DPATO shall be conducted in sight of the surface.

Item H.4

Delete all and insert new (a)

JAR-OPS 3.525 Take-off Flight Path (See ACJ to Subpart H)

(a) An operator shall be satisfied that from DPATO or, as an alternative, no later than 200 ft above the take-off surface, with the cri t ical power-unit inoperative the requirements of JAR-OPS 3.495(a)(1), (2) and (b) are met.

(a) An operator shall ensure that , after the DPATO:

(1) The take-off f l ight path with the cri t ical power unit inoperative clears al l obstacles by a vert ical margin of not less than 10·7 m (35 ft) in VFR and at least 35 f t plus 0.01 DR in IFR. An obstacle need not be considered if i ts lateral margin from the nearest point on the surface below the intended fl ight path exceeds 30 m or 1·5 t imes the overall length of the helicopter, whichever is greater , plus

( i) 0·15 DR for VFR operations; or

( i i ) 0·30 DR for IFR operations.

(b) When showing compliance with sub-paragraph (a) above:

(1) Obstacles may be disregarded if they are situated beyond:

( i) 7R for day operations if i t is assured that navigational accuracy can be achieved by reference to suitable visual cues during the cl imb;

( i i ) 10R for night operat ions if i t is assured that navigational accuracy can be achieved by reference to suitable visual cues during the cl imb;

( i i i) 300 m if navigational accuracy can be achieved by navigation aids; and

(iv) 900 m in the other cases.



(2) Where a change of direction of more than 15° is made, vertical obstacle clearance requirements are to be increased by 5 m (15 ft) from the point at which the turn is init iated. This turn is not to be ini t iated before reaching a height of 30 m (100 ft) above the take-off surface.

(c) When showing compliance with sub-paragraph (a) above, account shall be taken of the following parameters at the heliport of departure:

(1) The mass of the helicopter at the commencement of the take-off;


(3) The ambient temperature; and

(4) Not more than 50% of the reported head-wind component when planning or, if such data is provided, not less than 150% of the reported tai l-wind component.

Item H.5

Amend (a) and delete the remainder

JAR-OPS 3.530 En-route - Critical power unit inoperative

(a) An operator shall ensure that the requirement of JAR-OPS 3.500 is met.

(1) The en-route f l ight path with the cri t ical power unit inoperative, appropriate to the meteorological condit ions expected for the fl ight , complies with ei ther sub-paragraph (2) or (3) below at all points along the route.

(2) When i t is intended that the f l ight wil l be conducted at any t ime out of sight of the surface, the mass of the helicopter permits a rate of cl imb of at least 50 f t /minute with the cri t ical power unit inoperative at an alt i tude of at least 300 m (1 000 ft) [600 m (2 000 ft) in areas of mountainous terrain] above all obstacles along the route within 18·5 km (10 nm) on either side of the intended track. When i t is intended that the fl ight wil l be conducted in VMC and in sight of the surface, the same requirement applies



except that only obstacles within 900 m on either side of the route need be considered.

(3) The fl ight path permits the helicopter to continue fl ight from the cruising alt i tude to a height of 300 m (1 000 ft) above the heliport where a landing can be made in accordance with JAR - OPS 3.535. The fl ight path clears vert ically, by at least 300 m (1 000 ft) [600 m (2 000 ft) in areas of mountainous terrain] al l obstacles along the route within 18·5 km (10 nm) on ei ther side of the intended track. The cri t ical power unit is assumed to fai l at the most crit ical point along the route. When i t is intended that the fl ight will be conducted in VMC and in sight of the surface, the same requirement applies except that only obstacles within 900 m on ei ther side of the route need be considered. Drift-down techniques may be used.

(4) Account is taken of the effects of winds on the fl ight path.

(5) Fuel jett isoning is planned to take place only to an extent consistent with reaching the heliport with the required fuel reserves and using a safe procedure [(See IEM OPS 3.530(a)(5))].

(6) Fuel jett isoning is not planned below 1 000 ft above terrain.

(b) When showing compliance with this paragraph, the width margins of sub-paragraphs (a)(2) and (a)(3) above may be reduced to 9·3 km (5 nm) if the required navigational accuracy can be achieved.

Item H.6

Delete all after paragraph (a)(1) and insert new text


(See IEM OPS 3.520 & 3.535) (See ACJ to Subpart H)

(a) An operator shall be satisf ied that:

(1) The landing mass at the est imated t ime of landing does not exceed the maximum mass specified for a rate of



climb of 150 ft /min at 300 m (1000 ft) above the level of the heliport with the cri t ical power unit inoperative and the remaining power units operating at an appropriate power rating.

(2) If the cri t ical power unit fails at any point in the approach path:

( i) a balked landing can be carried out meeting the requirement of JAR-OPS 3.525; or

( i i) for operations other than specified in JAR-OPS 3.517(a) the helicopter can perform a safe-forced-landing.

(3) For operations in accordance with JAR-OPS 3.517(a) in addit ion to the requirements of (a)(1) above:

( i) The landing mass does not exceed the maximum mass specified in the Helicopter Flight Manual for an AEO OGE hover in st i l l air with all power units operating at an appropriate power rating.

( i i) For operations to/from a helideck:

(A) with a helicopter that has a maximum approved passenger seating configuration (MAPSC) of more than 19; and

(B) from 1st January 2010 any helicopters operated to/from a helideck located in a non-congested hosti le environment as defined in JAR-OPS 3.480(13)(ii)(A)

the landing mass takes into account the procedure, and drop down appropriate to the height of the helideck - with the cri t ical power unit inoperative and the remaining power unit(s) operating at an appropriate power rating.

(b) When showing compliance with sub-paragraph (a) above, account shall be taken of the appropriate parameters of JAR-OPS 3.475(c) at the destination heliport or any alternate, if required.

(c) The part of the landing after which the requirement of JAR-OPS 3.525 cannot



be met shall be conducted in sight of the surface.

(2) For operations without an approval to operate with an exposure t ime:

( i) The landing mass is such that , in the event of the cri t ical power unit becoming inoperative at any point during the approach and landing phase, the helicopter, after clearing all obstacles under the f l ight path, is capable of:

(A) In the event of the cri t ical power unit fai lure being recognised before the defined point before landing (DPBL), continuing the fl ight; and

(B) In the event of the cri t ical power unit fai lure being recognised at or after the DPBL, carrying out a safe forced landing on the heliport or surface.

( i i ) The part of the landing during which power unit fai lure may lead to a forced landing is conducted only over a surface that permits a safe forced landing to be executed in the event of a power unit fai lure.

(3) For operations on helidecks or elevated heliports located in a non hostile environment, with an approval to operate with an exposure t ime (see JAR-OPS 3.517(a)):

( i ) The landing mass is such that , in the event of the cri t ical power unit becoming inoperative at any point during the approach and landing phase up to the exposure t ime, the helicopter, after clearing all obstacles under the f l ight path, is capable of:

(A) In the event of the cri t ical power unit fai lure being recognised before the defined point before landing (DPBL), continuing the fl ight; and

(B) In the event of the cri t ical power unit fai lure being recognised between the DPBL and the start of the exposure t ime, carrying out a



safe forced landing on the heliport or surface.


(4) For operations on helidecks or elevated heliports located in a non congested hosti le environment, with an approval to operate with an exposure t ime (see JAR-OPS 3.517(a)):

( i ) The landing mass is such that , in the event of the cri t ical power unit becoming inoperative at any point during the approach and landing phase up to the beginning of the exposure t ime, the helicopter, after clearing all obstacles under the f l ight path, is capable of continuing the f l ight.


(b) When showing compliance with sub-paragraph (a) above, account shall be taken of the following parameters at the est imated t ime of landing at the destination heliport or any alternate, if required:


(2) The ambient air temperature;

(3) The landing procedure to be used;

(4) Not more than 50% of the expected head-wind component; and

(5) Any expected variat ion in the mass of the helicopter during flight.

(c) That part of the landing from the DPBL to touchdown, shall be conducted in sight of the surface.

Item H.7

Delete exiting Appendix 1 to JAR-OPS 3.517(a) and insert new Appendix

Appendix 1 to JAR-OPS 3.517(a) Helicopter operations without an assured safe forced landing capability (See JAR-OPS 3.517(a)) (See ACJ-1 to Appendix 1 to JAR-OPS 3.517(a)) (See ACJ-2 to Appendix 1 to JAR-OPS 3.517(a))



(a) Approval:

(1) Following a risk assessment, an operator may be authorised to conduct operations without an assured safe forced landing capabili ty during the take-off and landing phases, under an approval specifying:

( i) The type of helicopter; and

(i i) The type of operations.

(2) Such an approval wil l be subject to the following condit ions:

( i) A set of conditions to be implemented by the operator to obtain and maintain the approval for the helicopter type;

( i i) Implementation of a Usage Monitoring System;

Item H.8

Delete exiting interpretive and explanatory material as indicated:

AMC to Appendix 1 to JAR-OPS 3.517(a); IEM OPS 3.517(a); IEM to Appendix 1 to JAR-OPS 3.517(a); IEM OPS 3.520 IEM OPS 3.520(a)(2). IEM OPS 3.530(a)(5)

Amend IEM OPS 3.517(b) to be ACJ OPS 3.520(a)(3) and 3.535(a)(3)

Item H.9

Insert new ACJ-1 to Appendix 1 to JAR-OPS 3.517(a) to Subpart H

ACJ-1 to Appendix 1 to JAR-OPS 3.517(a) Helicopter operations without an assured safe forced landing capability 1. As part of the risk assessment prior to granting an approval under Appendix

1 to JAR-OPS 3.517(a), the operator should provide appropriate powerplant reliability statistics available for the helicopter type and the engine type.

2. Except in the case of new engines, such data should show sudden powerloss from the set of in-flight shutdown (IFSD) events not exceeding 1 per 100,000 engine hours in a 5 year moving window. However, a rate in excess of this



value, but not exceeding 3 per 100,000 engine hours, may be accepted by the Authority after an assessment showing an improving trend.

3. New engines should be assessed on a case-by-case basis.

4. After the initial assessment, updated statistics should be periodically reassessed; any adverse sustained trend will require an immediate evaluation to be accomplished by the operator in consultation with the Authority and the manufacturers concerned. The evaluation may result in corrective action or operational restrictions being applied.

5. The purpose of this paragraph is to provide guidance on how the in-service power plant sudden power loss rate is determined.

5.1. Share of roles between the helicopter and engine Type Certificate Holders (TCH).

a) The provision of documents establishing the in-service sudden power loss rate for the helicopter/engine installation; the interface with the operational Authority of the State of Design should be the Engine TCH or the Helicopter TCH depending on the way they share the corresponding analysis work.

b) The Engine TCH should provide the Helicopter TCH with a document including: the list of in-service power loss events, the applicability factor for each event (if used), and the assumptions made on the efficiency of any corrective actions implemented (if used).

c) The Engine or Helicopter TCH should provide the operational Authority of the State of Design or, where this Authority does not take responsibility, the operational Authority of the State of the Operator, with a document that details the calculation results - taking into account: the events caused by the engine and the events caused by the engine installation; the applicability factor for each event (if used), the assumptions made on the efficiency of any corrective actions implemented on the engine and on the helicopter (if used); and the calculation of the powerplant power loss rate,

5.2 Documentation

The following documentation should be updated every year.

5.2.1 The document with detailed methodology and calculation as distributed to the Authority of the State of Design.

5.2.2 A summary document with results of computation as made available on request to any operational Authority.

5.2.3 A Service Letter establishing the eligibility for such operation and defining the corresponding required configuration as provided to the operators.

5.3. Definition of the “sudden in-service power loss”.

The sudden in-service power loss is an engine power loss:

- larger than 30 % of the take-off power; and

- occurring during operation; and - without the occurrence of an early intelligible warning to inform and give sufficient time for the pilot to take any appropriate action.



5.4. Data base documentation.

Each power loss event should be documented, by the engine and/or helicopter TCH’s, as follows:

- incident report number; - engine type; - engine serial number; - helicopter serial number; - date; - event type (demanded IFSD, un-demanded IFSD); - presumed cause; - applicability factor when used ; - reference and assumed efficiency of the corrective actions that will have to be applied (if any);

5.5. Counting methodology.

Various methodologies for counting engine power loss rate have been accepted by Authorities. The following is an example of one of these methodologies:

5.5.1 The events resulting from:

- unknown causes (wreckage not found or totally destroyed, undocumented or unproven statements); or

- where the engine or the elements of the engine installation have not been investigated (for example when the engine has not been returned by the customer); or

- an unsuitable or non representative use (operation or maintenance) of the helicopter or the engine

are not counted as engine in-service sudden power loss and the applicability factor is 0%.

5.5.2 The events caused by:

- the engine or the engine installation; or - the engine or helicopter maintenance, when the applied maintenance was compliant with the Maintenance Manuals are counted as engine in-service sudden power loss and the applicability factor is 100%.

5.5.3 For the events where the engine or an element of the engine installation has been submitted to investigation which did not allow to define a presumed cause

the applicability factor is 50 %.

5.6. Efficiency of corrective actions.

The corrective actions made by the engine and helicopter manufacturers on the definition or maintenance of the engine or its installation could be defined as mandatory for specific JAR- OPS 3 operations. In this case the



associated reliability improvement could be considered as mitigating factor for the event.

A factor defining the efficiency of the corrective action could be applied to the applicability factor of the concerned event.

5.7. Method of calculation of the powerplant power loss rate.

The detailed method of calculation of the powerplant power loss rate should be documented by engine or helicopter TCH and accepted by the relevant Authority.

Item H.10

Insert new ACJ-2 to Appendix 1 to JAR-OPS 3.517(a) to Subpart H

ACJ-2 to Appendix 1 to JAR-OPS 3.517(a) Helicopter operations without an assured safe forced landing capability To obtain an approval under Appendix 1 to JAR-OPS 3.517(a), an operator conducting operations without an assured safe forced landing capability should implement the following:

1. Attain and then maintain the helicopter/engine modification standard defined by the manufacturer that has been designated to enhance reliability during the take-off and landing phases.

2. Conduct the preventive maintenance actions recommended by the helicopter or engine manufacturer as follows:

2.1 Engine oil spectrometric and debris analysis - as appropriate;

2.2 Engine trend monitoring, based on available power assurance checks;

2.3 Engine vibration analysis (plus any other vibration monitoring systems where fitted).

2.4 Oil consumption monitoring.

3. The Usage Monitoring System should fulfil at least the following:

3.1 Recording of the following data:

• Date and time of recording, or a reliable means of establishing these parameters;

• Amount of flight hours recorded during the day plus total flight time;

• N1 (gas producer RPM) cycle count;

• N2 (power turbine RPM) cycle count (if the engine features a free turbine);

• Turbine temperature exceedance: value, duration;

• Power-shaft torque exceedance: value, duration (if a torque sensor is fitted);

• Engine shafts speed exceedance: value, duration;



3.2 Data storage of the above parameters, if applicable, covering the maximum flight time in a day, and not less than 5 flight hours, with an appropriate sampling interval for each parameter.

3.3 The system should include a comprehensive self-test function with a malfunction indicator and a detection of power-off or sensor input disconnection.

3.4 A means should be available for downloading and analysis of the recorded parameters. Frequency of downloading should be sufficient to ensure data is not lost through over-writing.

3.5 The analysis of parameters gathered by the usage monitoring system, the frequency of such analysis and subsequent maintenance actions should be described in the maintenance documentation.

3.6 The data should be stored in an acceptable form and accessible to the Authority, for at least 24 months.

4. Include take-off and landing procedures in the operations manual, where they do not already exist in the Helicopter Flight Manual.

5. Establish training for flight crew which should include the discussion, demonstration, use and practice of the techniques necessary to minimise the risks;

6. Report to the manufacturer any loss of power control, engine shutdown (precautionary or otherwise) or power unit failure for any cause (excluding simulation of power unit failure during training). The content of each report should provide:

• Date and time;

• Operator (and Maintenance organisations where relevant);

• Type of helicopter and description of operations;

• Registration and serial number of airframe;

• Engine type and serial number;

• Power unit modification standard where relevant to failure;

• Engine position;

• Symptoms leading up to the event.

• Circumstances of power unit failure including phase of flight or ground operation;

• Consequences of the event;

• Weather/environmental conditions;

• Reason for power unit failure – if known;

• In case of an In Flight Shut Down (IFSD), nature of the IFSD (Demanded/Un-demanded);

• Procedure applied and any comment regarding engine restart potential;

• Engine hours and cycles (from new and last overhaul);

• Airframe flight hours;



• Rectification actions applied including, if any, component changes with part number and serial number of the removed equipments; and

• Any other relevant information

Item H.11

Insert new ACJ to Subpart H

ACJ to Subpart H Operations in Performance Class 2 See Subpart H

1. INTRODUCTION

This paper describes Performance Class 2 as established in JAR-OPS 3, Subpart H. It has been produced for the purpose of:

(a) discussing the underlying philosophy of Operations in Performance Class 2;

(b) showing simple methods of compliance; and

(c) explaining how to determine - with examples and diagrams:

• the take-off and landing masses;

• the length of the safe-forced-landing area;

• distances to establish obstacle clearance; and

• entry point(s) into Performance Class 1.

It discusses the derivation of Performance Class 2 from ICAO Annex 6 Part III and describes an alleviation which may be approved following a Risk Assessment.

It reproduces relevant definitions; examines the basic requirements; discusses the limits of operation; and considers the benefits of the use of Performance Class 2.

It contains examples of Performance Class 2 in specific circumstances, and explains how these examples may be generalised to provide the operators with methods of calculating landing distances and obstacle clearance.

2. DEFINITIONS

To assist in the reading of this paper, definitions from JAR-OPS 3, Subpart F have been reproduced:

Distance DR. DR is the horizontal distance that the helicopter has travelled from the end of the take-off distance available.

Defined point after take-off (DPATO). The point, within the take-off and initial climb phase, before which the helicopter’s ability to continue the flight safely, with the critical power unit inoperative, is not assured and a forced landing may be required.

Defined point before landing (DPBL). The point within the approach and landing phase, after which the helicopter’s ability to continue the flight safely, with the critical power unit inoperative, is not assured and a forced landing may be required.

Landing distance available (LDAH). The length of the final approach and take-off area plus any additional area declared available and suitable for helicopters to complete the landing manoeuvre from a defined height.



Landing distance required (LDRH). The horizontal distance required to land and come to a full stop from a point 15m (50ft) above the landing surface.

Performance Class 2. Performance Class 2 operations are those operations such that, in the event of critical power unit failure, performance is available to enable the helicopter to safely continue the flight, except when the failure occurs early during the take-off manoeuvre or late in the landing manoeuvre, in which cases a forced landing may be required.

Safe forced landing. Unavoidable landing or ditching with a reasonable expectancy of no injuries to persons in the aircraft or on the surface.

Take-off distance available. The length of the final approach and take-off area plus the length of any clearway (if provided) declared available and suitable for helicopters to complete the take-off.

The following terms, which are not defined in JAR-OPS 3 Subpart F, are used in the following text:

VT. A target speed at which to aim at the point of minimum ground clearance (min-dip) during acceleration from TDP to Vtoss.

V50. A target speed and height utilised to establish a Flight Manual distance (in compliance with the requirement of CS 29.63) from which climbout is possible.

Vstay-up. A colloquial term used to indicate a speed at which a descent would not result following a power-unit failure. This speed is several knots lower than Vtoss at the equivalent take-off mass.

3. WHAT DEFINES PERFORMANCE CLASS 2

Performance Class 2 can be considered as Performance Class 3 take-off or landing, and Performance Class 1 climb, cruise and descent. It comprises an All Engines Operating (AEO) obstacle clearance regime for the take-off or landing phases, and a One Engine Inoperative (OEI) obstacle clearance regime for the climb, cruise, descent, approach and missed approach phases.

Note: For the purpose of performance calculations in JAR-OPS 3, the JAR 29.67 Category A climb performance criteria is used:

• 150 ft/min at 1,000 ft (at Vy);

and depending on the choice of DPATO:

• 100 ft/min up to 200 ft (at Vtoss)

at the appropriate power settings.

3.1 Comparison of obstacle clearance in all Performance Classes

Figure 7 shows the profiles of the three Performance Classes - superimposed on one diagram.

• Performance Class 1 (PC 1); from TDP, requires OEI obstacle clearance in all phases of flight; the construction of Category A procedures, provides for a flight path to the first climb segment1, a level acceleration segment to Vy (which may be shown concurrent with the first segment), followed by the second climb segment2 from Vy at 200 ft (see Figure 6).



Figure 6- Performance Class 1 distances

• Performance Class 2 (PC 2); requires AEO obstacle clearance to DPATO and OEI from then on. The take-off mass has the PC 1 second segment climb performance at its basis therefore, at the point where Vy at 200 ft is reached, Performance Class 1 is achieved (see also Figure 8).

• Performance Class 3 (PC 3); requires AEO obstacle clearance in all phases.

Figure 7 - All Performance Classes (a comparison)

3.2 Comparison of the discontinued take-off in all Performance Classes

• PC 1 - requires a prepared surface on which a rejected landing can be undertaken (no damage); and

• PC 2 and 3 - require a safe-forced-landing surface (some damage can be tolerated but there must be a reasonable expectancy of no injuries to persons in the aircraft or third parties on the surface).

4. THE DERIVATION OF PERFORMANCE CLASS 2

Subpart H - PC 2 is primarily based on the the text of ICAO Annex 6 Part III Section II and its attachments - which provide for the following:

Reject T/O Distance

1 - T/O Distance Required

TDP

AEO

OEI

200 ft

First Segment 100 ft/min at Vtoss

Second Segment 150 ft/min at Vy

Acceleration from Vtoss to Vy

2 - Distance to Vy at 200 ft

DPATO between these two points

PC1 TDP

OEI 150 ft/min at Vy

PC 3-AEO profile PC 2 profile

Rejected landing/ Safe-forced-landing

AEO

OEI

200 ft

PC l profile

First Segment OEI 100 ft/min at Vtoss

Second Segment



a. Obstacle clearance before DPATO; the helicopter shall be able, with all engines operating, to clear all obstacles by an adequate margin until it is in a position to comply with b. below.

b. Obstacle clearance after DPATO; the helicopter shall be able, in the event of the critical power-unit becoming inoperative at any time after reaching DPATO, to continue the take-off clearing all obstacles along the flight path by an adequate margin until it is able to comply with en-route clearances.

c. Engine failure before DPATO; before the DPATO, failure of the critical power-unit may cause the helicopter to force land; therefore a safe-forced-landing should be possible (this is analogous to the requirement for a reject in Performance Class 1 but where some damage to the helicopter can be tolerated.)

5. BENEFITS OF JAR-OPS 3 PERFORMANCE CLASS 2

Operations in Performance Class 2 permit advantage to be taken of an all-engines-operating (AEO) procedure for a short period during take-off and landing - whilst retaining engine failure accountability in the climb, descent and cruise. The benefits include:

• Ability to use (the reduced) distances scheduled for the AEO - thus permitting operations to take place at smaller heliports and allowing airspace requirements to be reduced.

• Ability to operate when the safe-forced-landing distance available is located outside the boundary of the heliport.

• Ability to operate when the take-off-distance required is located outside the boundary of the heliport.

• Ability to use existing Category A profiles and distances when the surface conditions are not adequate for a reject but are suitable for a safe-forced-landing (for example when the ground is waterlogged).

Additionally, following a Risk Assessment when the use of exposure is permitted by the Authority:

• Ability to operate when a safe-forced landing is not assured in the take-off phase.

• Ability to penetrate the HV curve for short periods during take-off or landing.

6 IMPLEMENTATION OF PERFORMANCE CLASS 2 IN JAR-OPS 3

The following sections discuss the principles of the implementation of Performance Class 2.

6.1 Does ICAO spell it all out?

ICAO Annex 6 does not give guidance on how DPATO should be calculated nor does it require that distances be established for the take-off. However, it does require that, up to DPATO AEO, and from DPATO OEI, obstacle clearance is established (see Figure 8 and Figure 9 which are simplified versions of the diagrams contained in Annex 6 Part III, Attachment A).

Note: Annex 8 – Airworthiness of Aircraft (Part IV, Chapter 2.2.1.3.4) requires that an AEO distance be scheduled for all helicopters operating in Performance Classes 2 & 3. Annex 6 is dependent upon the scheduling of the AEO distances, required in Annex 8, to provide data for the location of DPATO.

When showing obstacle clearance, the divergent obstacle clearance height required for IFR is - as in Performance Class 1 - achieved by the application of the additional obstacle clearance of 0.01 DR (DR = the distance from the end of ‘take-off-distance-available’ - see the pictorial representation in Figure 9 and the definition in section 2. above).



As can also be seen from Figure 9, flight must be conducted in VFR until DPATO has been achieved (and deduced that if an engine failure occurs before DPATO, entry into IFR is not permitted (as the OEI climb gradient will not have been established)).

Figure 8 - Performance Class 2 Obstacle Clearance

Figure 9 - Performance Class 2 Obstacle Clearance (plan view)

6.2 Function of DPATO

From the preceding paragraphs it can be seen that DPATO is germane to PC 2. It can also be seen that, in view of the many aspects of DPATO, it has, potentially, to satisfy a number of requirements which are not necessarily synchronised (nor need to be).

It is clear that it is only possible to establish a single point for DPATO, satisfying the requirement of 4 b & 4 c above, when:

• accepting the TDP of a Category A procedure; or

• extending the safe-forced-landing requirement beyond required distances (if data is available to permit the calculation of the distance for a safe-forced-landing from the DPATO).

It could be argued that the essential requirement for DPATO is contained in section 4 b - OEI obstacle clearance. From careful examination of the flight path reproduced in Figure 8 above, it may be reasonably deduced that DPATO is the point at which adequate climb performance is established (examination of Category A procedures would indicate that this could be (in terms of mass, speed and height above the take-off surface) the conditions at the start of the first or second segments - or any point between.)

Take-off distance available

VMC required IMC possible

Distance DR

Clearway

(Obstacle)

(Obstacle)

FATO

Normal take-off

One engine inoperative

10.7

VFR 10.7 IFR 10.7 + 0.01 DR

Defined point after take-off

(Obstacle) (Obstacle)

AEO

OEI



Note: The diagrams in Attachment A of ICAO Annex 6, do not appear to take account of drop down - permitted under Category A procedures; similarly with helideck departures, the potential for acceleration in drop down below deck level (once the deck edge has been cleared) is also not shown. These omissions could be regarded as a simplification of the diagram, as drop down is discussed and accepted in the accompanying ICAO text.

It may reasonably be argued that, during the take-off and before reaching an appropriate climb speed (Vtoss or Vy), Vstayup will already have been achieved (where Vstayup is the ability to continue the flight and accelerate without descent - shown in some Category A procedures as VT or target speed) and where, in the event of an engine failure, no landing would be required.

It is postulated that, to practically satisfy all the requirements of sections 4 a, b and c above, we do not need to define DPATO at one synchronised point; we can meet requirements separately - i.e. defining the distance for a safe-forced-landing, and then establishing the OEI obstacle clearance flight path.

As the point at which the helicopter’s ability to continue the flight safely, with the critical power unit inoperative is the critical element, it is that for which DPATO is used in this text.

Figure 10 - The three elements in a PC 2 take-off

6.2.1 The three elements from the pilot’s perspective When seen from the pilot’s perspective (see Figure 10), there are three elements of the PC 2 take-off - each with associated related actions which need to be considered in the case of an engine failure: a. action in the event of an engine failure - up to the point where a forced-landing will be

required.

b. action in the event of an engine failure - from the point where OEI obstacle clearance is established (DPATO).

c. pre-considered action in the event of an engine failure - in the period between a. and b.

The action of the pilot in a. and b. is deterministic i.e. it remains the same for every occasion. For pre-consideration of the action at point c.; as is likely that the planned flight path will have to be abandoned (the point at which obstacle clearance using the OEI climb gradients not yet being reached) the pilot must (before take-off) have considered his options and the associated risks, and have in mind the course of action that will be pursued in the event of an engine failure during that short period. (As it is likely that any action will involve turning manoeuvres, the effect of turns on performance must be considered.)

Point b. (DPATO)

Point a. (TDP?)

AEO PC 2 profile

Safe-forced-landing

AEO

OEI

Pilot’s pre-considered action in the case of engine failure between points a. and b.

150 ft/min OEI



6.3 Take-off mass for Performance Class 2

As previously stated, Performance Class 2 is an AEO take-off which, from DPATO, has to meet the requirement for OEI obstacle clearance in the climb and en-route phases. Take-off mass is therefore the mass that gives at least the minimum climb performance of 150 ft/min at Vy, at 1000 ft above the take-off point, and obstacle clearance. As can be seen in Figure 11 below, the take-off mass may have to be modified when it does not provide the required OEI clearance from obstacles in the take-off-flight path (exactly as in Performance Class 1). This could occur when taking off from a heliport where the flight path has to clear an obstacle such a ridge line (or line of buildings) which can neither be: • flown around using VFR and see and avoid; nor

• cleared using the minimum climb gradient given by the take-off mass (150 ft/min at 1,000 ft)

In this case, the take-off mass has to be modified (using data contained in the HFM) to give an appropriate climb gradient.

Figure 11 - Performance Class 2 (enhanced climb gradient)

6,4 Do distances have to be calculated?

Distances do not have to be calculated if, by using pilot judgement or standard practice, it can be established that: • A safe-forced-landing is possible following an engine failure (notwithstanding that there

might be obstacles in the take-off path); and

• Obstacles can be cleared (or avoided) - AEO in the take-off phase and OEI in the climb.

If early entry (in the sense of cloud base) into IMC is expected - an IFR departure should be planned. However, standard masses and departures can be used when described in the Operations Manual.

6.5 The use of Category A data

In Category A procedures, TDP is the point at which either a rejected landing or a safe continuation of the flight, with OEI obstacle clearance, can be performed.

For PC 2 (when using Category A data), only the safe-forced-landing (reject) distance depends on the equivalent of the TDP; if an engine fails between TDP and DPATO the pilot has to decide what action is required - it is not necessary for a safe-forced-landing distance to be established from beyond the equivalent of TDP (see Figure 10 and discussion in section 6.2.1 above).

DPATO

150 ft/min OEI

Modified climb gradient OEI

AEO

OEI

VFR 10.7 IFR 10.7 + 0.01 DR



Category A procedures based on a fixed Vtoss are usually optimised either for the reduction of the rejected take-off distance, or the take-off distance. Category A procedures based on a variable Vtoss allow either a reduction in required distances (low Vtoss) or an improvement in OEI climb capability (high Vtoss). These optimisations may be beneficial in PC 2 to satisfy the dimensions of the take-off site.

In view of the different requirements for PC 2 (from PC 1), it is perfectly acceptable for the two calculations (one to establish the safe-forced-landing distance and the other to establish DPATO) to be based upon different Category A procedures. However, if this method is used, the mass resulting from the calculation cannot be more than the mass from the more limiting of the procedures.

6.6 DPATO and obstacle clearance

If it is necessary for OEI obstacle clearance to be established in the climb, the starting point (DPATO) for the (obstacle clearance) gradient has to be established. Once DPATO is defined, the OEI obstacle clearance is relatively easy to calculate with data from the HFM. 6.6.1 DPATO based on AEO distance In the simplest case; if provided, the scheduled AEO to 200 ft at Vy can be used (see Figure 12).

Figure 12 -Suggested AEO locations for DPATO

Otherwise, and if scheduled in the HFM, the AEO distance to 50ft (V50) – determined in accordance with JAR 29.63 - can be used (see Figure 12). Where this distance is used, it will be necessary to ensure that the V50 climb out speed is associated with a speed and mass for which OEI climb data is available so that, from V50, the OEI flight path can be constructed. 6.6.2 DPATO based on Category A distances It is not necessary for specific AEO distances to be used (although for obvious reasons it is preferable); if they are not available, a flight path (with OEI obstacle clearance) can be established using Category A distances (see Figure 13 and Figure 14) - which will then be conservative.

DPATO AEO 200 ft and Vy

DPATO CAT B V50

OEI obstacle clearance

(AEO to DPATO)

Safe-forced-landing

AEO

OEI

200 ft

OEI obstacle clearance

(AEO to DPATO)



Figure 13 - Using Cat A data; actual and apparent position of DPATO (Vtoss and start of first segment)

Note: the apparent DPATO is for planning purposes only in the case where AEO data is not available to construct the take-off flight path. The actual OEI flight path will provide better obstacle clearance than the apparent one (used to demonstrate the minimum requirement) - as seen from the firm and dashed lines in the above diagram.

Figure 14 - Using Cat A data; actual and apparent position of DPATO (Vy and start of second segment)

6.6.3 Use of most favourable Category A data The use of AEO data is recommended for calculating DPATO. However, where an AEO distance is not provided in the flight manual, distance to Vy at 200 ft, from the most favourable of the Category A procedures, can be used to construct a flight path (provided it can be demonstrated that AEO distance to 200 ft at Vy is always closer to the take-off point than the CAT A OEI flight path). In order to satisfy the requirement of JAR-OPS 3.525, the last point from where the start of OEI obstacle clearance can be shown is at 200 ft.

6.7 The calculation of DPATO - a summary

DPATO should be defined in terms of speed and height above the take-off surface and should be selected such that HFM data (or equivalent data) is available to establish the distance from the start of the take-off up to the DPATO (conservatively if necessary). 6.7.1 First method DPATO is selected as the HFM Category B take-off distance (V50 speed or any other take-off distance scheduled in accordance with JAR 29.63) provided that within the distance the helicopter can achieve:

PC 1 PC 2

Actual DPATO at Vy

AEO

OEI

Apparent DPATO Vy start of second segment

Apparent DPATO Vtoss start of first segment

PC 1

Actual DPATO At Vtoss

AEO

OEI

PC 2



• One of the Vtoss values (or the unique Vtoss value if is not variable) provided in the HFM, selected so as to assure a climb capability according to Cat A criteria; or

• Vy.

Compliance with JAR-OPS 3.525 would be shown from V50 (or the scheduled Category B take-off distance).

6.7.2 Second method DPATO is selected as equivalent to the TDP of a Category A clear area take-off procedure conducted in the same conditions.

Compliance with JAR-OPS 3.525 would be shown from the point at which Vtoss, a height of at least 35 ft above the take-off surface and a positive climb gradient are achieved (which is the Category A clear area take-off distance).

Safe-forced-landing areas should be available from the start of the take-off, to a distance equal to the Category A “clear area” rejected take-off distance.

6.7.3 Third method As an alternative; DPATO could be selected such that Helicopter Flight Manual one engine inoperative (OEI) data is available to establish a flight path initiated with a climb at that speed. This speed should then be:

• One of the Vtoss values (or the unique Vtoss value if is not variable) provided in the Helicopter Flight Manual, selected so as to assure a climb capability according to Cat A criteria; or

• Vy.

The height of the DPATO should be at least 35 ft and can be selected up to 200 ft. Compliance with JAR-OPS 3.525 would be shown from the selected height.

6.8 Safe-forced-landing distance

Except as provided in 6.7.2 above, the establishment of the safe-forced-landing distance could be problematical as is not likely that PC 2 specific data will be available in the HFM.

By definition, the Category A reject distance may be used when the surface is not suitable for a reject, but may be satisfactory for a safe-force-landing (for example where the surface is flooded or is covered with vegetation).

Any Category A (or other accepted) data may be used to establish the distance – however, once established it remains valid only if the Category A mass (or the mass from the accepted data) is used and the Category A (or accepted) AEO profile to the TDP is flown. In view of these constraints, the likeliest Category A procedures are the clear area or the short field (restricted area/site) procedures.

From Figure 15, it can be seen that if the Category B V50 procedure is used to establish DPATO, the combination of the distance to 50 ft and the Category A ‘clear area’ landing distance, required by JAR 29.81 (the horizontal distance required to land and come to a complete stop from a point 50 ft above the landing surface), will give a good indication of the maximum safe-forced-landing distance required (see also the discussion on Vstayup above).



Figure 15 - Category B (V50) safe-forced-landing distance

6.9 Performance Class 2 landing

For other than PC 2 operations to elevated heliport/helidecks (see the discussion in section 7.4.1 below), the principles for the landing case are much simpler. As the performance requirement for PC 1 and PC 2 landings are virtually identical, the condition of the landing surface is the main issue.

If the engine fails at any time during the approach, the helicopter must be able either: to perform a go-around meeting the requirements of JAR-OPS 3.525; or perform a safe-forced-landing on the surface. In view of this, and if using PC 1 data, the LDP should not be lower that the corresponding TDP (particularly in the case of a variable TDP).

The landing mass will be identical to the take-off mass for the same site (with consideration for any reduction due to obstacle clearance - as shown in Figure 11 above).

In the case of a balked landing (i.e. the landing site becomes blocked or unavailable during the approach); the full requirement for take-off obstacle clearance must be met.

7. OPERATIONS IN PERFORMANCE CLASS 2 WITH EXPOSURE

JAR-OPS 3 offers an opportunity to discount the requirement for an assured safe-forced-landing area in the take-off or landing phase - subject to an approval from the Authority. The following sections deals with this option:

7.1 Limit of Exposure

As stated above, Performance Class 2 has to ensure AEO obstacle clearance to DPATO and OEI obstacle clearance from that point. This does not change with the application of exposure.

It can therefore be stated that operations with exposure are concerned only with alleviation from the requirement for the provision of a safe-forced-landing.

The absolute limit of exposure is 200 ft - from which point OEI obstacle clearance must be shown.

7.2 The principle of Risk Assessment

ICAO Annex 6 Part III Chapter 3.1.2 (Fifth Edition July 2001) states that:

• 3.1.2 Performance Class 3 helicopters shall only be operated in conditions of weather and light, and over such routes and diversions therefrom, that permit a safe-forced-landing to be executed in the event of engine failure. The conditions of this paragraph apply also to performance Class 2 helicopters prior to the defined point after take-off and after the defined point before landing.

The ICAO Helicopter and Tiltrotor Study Group, is engaged in an ongoing process to amend Chapter 3 to take account of current practices – following this process the proposed text is likely to be:

Safe-forced-landing distance

V50

AEO Distance to V50 Cat A landing distance



• 3.1.2 In conditions where the safe continuation of flight is not ensured in the event of a critical power unit failure, helicopter operations shall be conducted in a manner that gives appropriate consideration for achieving a safe-forced-landing.

Although a safe-forced-landing may no longer be the (absolute) Standard, it is considered that Risk Assessment is obligatory to satisfy the amended requirement for ‘appropriate consideration’.

Risk Assessment used in JAR-OPS 3 for fulfilment of this proposed Standard is consistent with principles described in ‘AS/NZS 4360:1999’.

Note: terms used in this text and defined in the AS/NZS Standard are shown in Sentence Case e.g. Risk Assessment or Risk Reduction.

7.3 The application of Risk Assessment to JAR-OPS 3 Performance Class 2

Under circumstances where no risk attributable to engine failure (beyond that inherent in the safe-forced-landing) is present, operations in Performance Class 2 may be conducted in accordance with the non-alleviated requirements contained above - and a safe-forced-landing will be possible.

Under circumstances where such risk would be present i.e.: operations to an elevated heliport (deck edge strike); or, when permitted, operations from a site where a safe-forced-landing cannot be accomplished because the surface is inadequate; or where there is penetration into the HV curve for a short period during take-off or landing (a limitation in JAR 29 HFMs), operations have to be conducted under a specific approval.

Provided such operations are Risk Assessed and can be conducted to an established safety target - they may be approved.

7.3.1 The elements of the Risk Management The approval process consists of an operational Risk Assessment and the application of four principles: a safety target; a helicopter reliability assessment; continuing airworthiness; and mitigating procedures. 7.3.2 The safety target The main element of the JAA Risk Assessment when exposure was initially introduced into JAR-OPS 3 (NPA OPS-8), was the assumption that turbine engines in helicopters would have failure rates of about 1:100 000 per flying hour; which would permit (against the agreed safety target of 5 x 10-8 per event) an exposure of about 9 seconds for twins during the take-off or landing event. (When choosing this target it was assumed that the majority of current well maintained turbine powered helicopters would be capable of meeting the event target - it therefore represents the Residual Risk)

Note: Residual Risk is considered to be the risk that remains when all mitigating procedures - airworthiness and operational - are applied (see sections 7.3.4 and 7.3.5 below).

7.3.3 The reliability assessment The JAA reliability assessment was initiated to test the hypothesis (stated in 7.3.2 above) that the majority of turbine powered types would be able to meet the safety target. This hypothesis could only be confirmed by an examination of the manufacturers’ power-loss data. 7.3.4 Mitigating procedures (airworthiness) Mitigating procedures consist of a number of elements: the fulfilment of all manufacturers’ safety modifications; a comprehensive reporting system (both failures and usage data); and the implementation of a Usage Monitoring System (UMS). Each of these elements is to ensure that engines, once shown to be sufficiently reliable to meet the safety target, will sustain such reliability (or improve upon it).



The monitoring system is felt to be particularly important as it had already been demonstrated that when such systems are in place it inculcates a more considered approach to operations. In addition the elimination of ‘hot starts’, prevented by the UMS, itself minimises the incidents of turbine burst failures.

7.3.5 Mitigating procedures (operations) Operational and training procedures, to mitigate the risk - or minimise the consequences - are required of the operator. Such procedures are intended to minimise risk by ensuring that: the helicopter is operated within the exposed region for the minimum time; and simple but effective procedures are followed to minimise the consequence should an engine failure occur.

7.4 Operation with Exposure - the alleviation and the requirement

When operating with exposure, there is alleviation from the requirement to establish a safe-forced-landing area (which extends to landing as well as take-off); however, the requirement for obstacle clearance - AEO in the take-off and from DPATO OEI in the climb and en-route phases - remains (both for take-off and landing).

The take-off mass is obtained from the more limiting of the following:

• the climb performance of 150 ft/min at 1000 ft above the take-off point; or

• obstacle clearance (in accordance with 6.3 above); or

• AEO hover out of ground effect (HOGE) performance at the appropriate power setting.

(AEO HOGE is required to ensure acceleration when (near) vertical dynamic take-off techniques are being used. Additionally for elevated heliports/helidecks, it ensures a power reserve to offset ground cushion dissipation; and ensures that, during the landing manoeuvre, a stabilised HOGE is available - should it be required.)

7.4.1 Operations to elevated heliport/helidecks PC 2 operations to elevated heliports and helidecks are a specific case of operations with exposure. In these operations, the alleviation covers the possibility of:

• a deck-edge strike if the engine fails early in the take-off or late in the landing; and

• penetration into the HV Curve during take-off and landing; and

• forced landing with obstacles on the surface (hostile water conditions) below the elevated heliport (helideck).

The take-of mass is as stated above and relevant techniques are as described in ACJ OPS 3.520(a)(3) and 3.535(a)(3)

Note: It is unlikely that the DPATO will have to be calculated with operations to helidecks (due to the absence of obstacles in the take-off path).

7.4.2 Additional requirements for operations to Helidecks in a Hostile Environment

For a number of reasons (e.g. the deck size, and the helideck environment – including obstacles and wind vectors), it was not anticipated that operations in PC 1 would be technically feasible or economically justifiable by the projected JAA deadline of 2010 (OEI HOGE could have provided a method of compliance but this would have resulted in a severe and unwarranted restriction on payload/range).

However, due to the severe consequences of an engine failure to helicopters involved in take-off and landings to helidecks located in hostile sea areas (such as the North Sea or the North Atlantic), a policy of Risk Reduction is called for. As a result, enhanced Class 2 take-off and landing masses together with techniques that provide a high confidence of safety due to: deck-edge avoidance; and, drop-down that provides continued flight clear of the sea, are seen as practical measures.



For helicopters which have a Category A elevated helideck procedure, certification is satisfied by demonstrating a procedure and adjusted masses (adjusted for wind as well as temperature and pressure) which assure a 15ft deck edge clearance on take-off and landing. It is therefore recommended that manufacturers, when providing enhanced PC2 procedures, use the provision of this deck-edge clearance as their benchmark.

As the height of the helideck above the sea is a variable, drop down has to be calculated; once clear of the helideck, a helicopter operating in PC1 would be expected to meet the 35ft obstacle clearance. Under circumstances other than open sea areas and with less complex environmental conditions, this would not present difficulties. As the provision of drop down takes no account of operational circumstances, standard drop down graphs for enhanced PC2 - similar to those in existence for Category A procedures - are anticipated.

Under conditions of offshore operations, calculation of drop down is not a trivial matter - the following examples indicate some of the problems which might be encountered in hostile environments:

• Occasions when tide is not taken into account and the sea is running irregularly - the level of the obstacle (i.e. - the sea) is indefinable making a true calculation of drop down impossible.

• Occasions when it would not be possible - for operational reasons - for the approach and departure paths to be clear of obstacles - the ‘standard’ calculation of drop-down could not be applied.

Under these circumstances, practicality indicates that drop-down should be based upon the height of the deck AMSL and the 35ft clearance should be applied.

There are however, other and more complex issues which will also affect the deck-edge clearance and drop down calculations:

• When operating to moving decks on vessels, a recommended landing or take-off profile might not be possible because the helicopter might have to hover alongside in order that the rise and fall of the ship is mentally mapped; or, on take-off re-landing in the case of an engine failure might not be an option.

Under these circumstances, the Commander might adjust the profiles to address a hazard more serious or more likely than that presented by an engine failure.

It is because of these and other (unforeseen) circumstances that a prescriptive requirement is not used. However, the target remains a 15ft deck-edge clearance and a 35ft obstacle clearance and data should be provided such that, where practically possible, these clearances can be planned.

As accident/incident history indicates that the main hazard is collision with obstacles on the helideck due to human error, simple and reproducible take-off and landing procedures are recommended.

In view of the reasons stated above, the future requirement for PC 1 is replaced by the new requirement that the take-off mass takes into account: the procedure; deck-edge miss; and drop down appropriate to the height of the helideck. This will require calculation of take-off mass from information produced by manufacturers reflecting these elements. It is expected that such information will be produced by performance modelling/simulation using a model validated through limited flight testing. 7.4.3 Operations to Helidecks for Helicopters with a MAPSC of more than 19

The original requirement for operations of helicopters with a MAPSC of more than 19 was PC 1 (as set out in JAR-OPS 3.470(a)(2)).

However, when operating to helidecks, the problems enumerated in 7.4.2 above are equally applicable to these helicopters. In view of this, but taking into account that increased numbers



are (potentially) being carried, such operations are permitted in PC 2 (JAR-OPS 3.470(a)(2)) but, in all helideck environments (both hostile and non-hostile), have to satisfy, the additional requirements, set out in 7.4.2 above.



Item I.1

Amend JAR-OPS 3. 540 as shown



(1) Helicopters operated in Performance Class 3 are cert if icated in ei ther Category A or B (see also ACJ OPS 3.480(a) (1) and (a)(2)) .

(2) Operations are only conducted from/to those heliports and over such routes, areas and diversions contained in a non-hosti le environment, except for the take-off and landing phase as provided in (b) below that [ ] operations may be conducted in a hosti le environment when approved under JAR-OPS 3.005(e).

(b) An operator may conduct operations to/from a heliport located outside a congested hosti le environment, without an assured safe forced landing capabili ty during the take-off and landing phases (see ACJ OPS 3.540(b)):

(1) during take-off; before reaching Vy or 200 ft above the take-off surface; or

(2) during landing; below 200 ft above the landing surface;

provided the operator has been granted a relevant approval by the Authority in accordance with Appendix 1 to JAR-OPS 3.517(a).

(c) An operator shall ensure that operations are not conducted:

(1) out of sight of the surface;

(2) at night;

(3) when the ceil ing is less than 600 ft; or

(4) when the visibili ty is less than 800m.

(3) Operations are not conducted when the ceil ing is less than 600 ft above the local surface or the visibil i ty is less than 800 m and are always conducted in sight of the surface.



(4) Operations to/from elevated heliports in a non-hosti le environment may be conducted with an exposure t ime to a power unit fai lure during take-off or landing unti l 31 December 2009 (see IEM OPS 3.517(a)) , provided the operator has been granted a relevant approval by the Authori ty (See Appendix 1 to JAR-OPS 3.517(a).)

(5) Operations are not conducted from/to helidecks.

(6) Operations are not conducted at night .

Item I.2


JAR-OPS 3.545 Take-off

An operator shall ensure that:

(a) The take-off mass does not exceed the maximum take-off mass specified for a hover in ground effect with all power units operating at take-off power. If condit ions are such that a hover in ground effect is not l ikely to be established, the take-off mass shall not exceed the maximum take-off mass specified for a hover out of ground effect with all power units operating at take-off power.

(b) When showing compliance with sub-paragraph (a) above, account is taken of the following parameters at the heliport of departure:



(cb) in the event of a power unit fai lure, the helicopter is able to perform a safe forced landing, except when operated in accordance with the al leviation contained in sub-paragraph 3.540(b)(a)(2) or 3.540(a)(4) above.

Item I.3

Amend paragraph (b) of JAR-OPS 3.550 as shown

JAR-OPS 3.550 En-route




(a) The helicopter is able, with al l power units operating within the maximum continuous power conditions specified, to continue along i ts intended route or to a planned diversion without flying at any point below the appropriate minimum fl ight al t i tude; and

(b) in the event of a power unit fai lure, the helicopter is able to perform a safe forced landing except when operated in accordance with the al leviation contained in sub-paragraph 3.540(a)(2) above.

Item I.4




(a) The landing mass of the helicopter at the est imated t ime of landing does not exceed the maximum landing mass specified for a hover in ground effect , with al l power units operat ing at take-off power. If condit ions are such that a hover in ground effect is not l ikely to be established, the landing mass shall not exceed the maximum landing mass specified for a hover out of ground effect with all power units operating at take-off power.

(b) When showing compliance with sub-paragraph (a) above, account is taken of the following parameters at the est imated t ime of landing at the dest ination heliport or any al ternate, if required:



(cb) in the event of a power unit failure, the helicopter is able to perform a safe forced landing, except when operated in accordance with the alleviation contained in sub-paragraph 3.540(b).(a)(2) or 3.540(a)(4) above.



Item I.5

Insert new ACJ

ACJ OPS 3.540(b) The take-off and landing phases (Performance Class 3) See JAR-OPS 3.540(b)

1. To understand the use of ground level exposure in Performance Class 3, it is important first to be aware of the logic behind the use of ‘take-off and landing phases’; once this is clear, it is easier to appreciate the aspects and limits of the use of ground level exposure. This ACJ shows the derivation of the term from the ICAO definition of the ‘en-route phase’ and then gives practical examples of the use, and limitations on the use, of ground level exposure in JAR-OPS 3.540(b).

2. The take-off phase in Performance Class 1 and Performance Class 2 may be considered to be bounded by ‘the specified point in the take-off’ from which the Take-off Flight Path begins.

2.1 In Performance Class 1 this specified point is defined as “the end of the Take-off Distance Required”.

2.2 In Performance Class 2 this specified point is defined as “DPATO or, as an alternative, no later than 200 ft above the take-off surface”.

2.3 There is no simple equivalent point for bounding of the landing in Performance Class 1 & 2.

3. Take-off Flight Path is not used in Performance Class 3 and, consequently, the term ‘take-off and landing phases’ is used to bound the limit of exposure. For the purpose of Performance Class 3, the take-off and landing phases are considered to be bounded by:

for the take-off no later than Vy or 200 ft above the take-off surface; and

for the landing 200 ft above the landing surface. Note: in ICAO Annex 6 Part III, En-route phase is defined as being “That part of the flight from the end of the take-off and initial climb phase to the commencement of the approach and landing phase.” The use of take-off and landing phase in this text is used to distinguish the take-off from the initial climb, and the landing from the approach: they are considered to be complimentary and not contradictory.

4. Ground level exposure – and exposure for elevated heliports/helidecks in a non-hostile environment – is permitted for operations under an approval in accordance with Appendix 1 to JAR-OPS 3.517(a). Exposure in this case is limited to the ‘take-off and landing phases’.

What is the practical effect of this bounding of exposure? Consider a couple of examples:

A clearing: an operator may consider a take-off/landing in a clearing when there is sufficient power, with all engines operating, to clear all obstacles in the take-off path by an adequate margin (this, in ICAO, is meant to indicate 35 ft). Thus, the clearing may be bounded by bushes, fences, wires and, in the extreme, by power lines, high trees etc. Once the obstacle has been cleared – by using a steep or a vertical climb (which itself may infringe the HV diagram) - the helicopter reaches Vy or 200 ft, and from that point a safe forced landing must be possible. The effect is that whilst operation to a clearing is possible, operation to a clearing in the middle of a forest is not (except when operated in accordance with Appendix 1 to JAR-OPS 3.005(e)).



A heliport surrounded by rocks: the same applies when operating to a landing site that is surrounded by rocky ground. Once Vy or 200ft has been reached, a safe forced landing must be possible.

An elevated heliport/helideck: when operating to an elevated heliport/helideck in Performance Class 3, exposure is considered to be twofold: firstly, to a deck-edge strike if the engine fails after the decision to transition has been taken; and secondly, to operations in the HV diagram due to the height of the heliport/helideck. Once the take-off surface has been cleared and the helicopter has reached the knee of the HV diagram, the helicopter should be capable of making a safe forced landing.

5. Operation in accordance with JAR-OPS 3.540(b) does not permit excursions into a hostile environment per se and is specifically concerned with the absence of space to abort the take-off or landing when the take-off and landing space are limited; or when operating in the HV diagram.

6. Specifically, the use of this exception to the requirement for a safe forced landing (during take-off or landing) does not permit semi-continuous operations over a hostile environment such as a forest or hostile sea area. It can therefore be seen as a limited alleviation from JAR-OPS 3.540(a)(2) which states that:

“operations are only conducted to/from those heliports and over such routes, areas and diversions contained in a non-hostile environment...”

Consequential amendment to IEM OPS 3.520 & 3.535

Paragraph 5; amend reference from 3.520(a)(4) to 3.520(a)(3)

Paragraph 8; amend reference from 3.535(a)(4) to 3.535(a)(3)

Add a note after paragraph 4.3

4.3 At or after the DPATO, the OEI flight path should clear all obstacles by the margins specified in JAR-OPS 3.525.

Note: an engine failure outside of exposure time should result in a safe-forced-landing or safe continuation of the flight.

Add a note after paragraph 5.3

5.3 At or after the DPATO, the OEI flight path should clear all obstacles by the margins specified in JAR-OPS 3.525.

Note: an engine failure outside of exposure time should result in a safe-forced-landing or safe continuation of the flight.



Item J.1 Amend Appendix 1 to JAR-OPS 3.625(a)(1)(i)(I) as follows; Appendix 1 to JAR-OPS 3.625

Paragraph (a) to (a)(1)(i)(I) unchanged;

( iI) The Take-off Mass, Landing Mass and Zero Fuel Mass;

Item J.2 Amend IEM OPS 3.605(e) as follows IEM OPS 3.605(e) Fuel density See JAR-OPS 3.605(e) 1 If the actual fuel density is not known, the operator may use the standard fuel density values specified in the Operations Manual for determining the mass of the fuel load. Such standard values should be based on current fuel density measurements for the airports or areas concerned. Typical fuel density values are:

a. Gasoline (piston engine fuel) - 0.71

b. JET A1 (Jet fuel JP 1) - 0.79

c. JET B (Jet fuel JP 4) - 0.76

d. Oil - 0.88



Item K.1 JAR-OPS 3.650 Day VFR operations – Flight and navigational instruments and associated equipment (See AMC OPS 3.650/3.652) (See IEMACJ OPS 3.650/3.652)

An operator shall not operate a helicopter by day in accordance with Visual flight Rules (VFR) unless it is equipped with the flight and navigational instruments and associated equipment and, where applicable, under the conditions stated in the following sub-paragraphs:

(a) An magnetic compass; direction indicator;

(b) up to (h) unchanged

(i) In addition to the flight and navigational equipment required by sub-paragraphs (a) to (h) above, helicopters with a maximum certificated take-off mass (MCTOM) over 3 175 kg; or any helicopter when operating over water when out of sight of land or when the visibility is less than 1500 m, must be equipped with the following flight instruments:

(1) An attitude indicator; and

(2) A stabilised direction indicator gyroscopic direction indicator.

JAR-OPS 3.652 IFR or night operations – Flight and navigational instruments and associated equipment (See AMC OPS 3.650/3.652) (See IEMACJ OPS 3.650/3.652) first paragraph unchanged

(a) A magnetic compass; direction indicator; (b) and (c) unchanged (d) An airspeed indication system with heated

pitot tube or equivalent means for preventing malfunctioning due to either condensation or icing including a warning indication an annunciation of pitot heater failure. The pitot heater failure warning indication annunciation requirement does not apply to those helicopters with............

(e) to (h) unchanged



(i) A stabilised direction indicator gyroscopic direction indicator for VFR night and a magnetic gyroscopic direction indicator for IFR.

(k) until (m)(1) unchanged

(2) An airspeed indication system with heated pitot tube or equivalent means for preventing malfunctioning due to either condensation or icing including a warning indication an annunciation of pitot heater failure. The pitot heater failure warning indication annunciation requirement does not apply to those helicopters with............

(3) and (4) unchanged

(5) A stabilised direction indicator gyroscopic direction indicator for VFR night and a magnetic gyroscopic direction indicator for IFR

Delete former IEM OPS 3.650/3.652 and insert ACJ OPS 3.650/3.652 as shown



ACJ OPS 3.650/3.652 Flight and navigational instruments and associated equipment See JAR-OPS 3.650 and JAR-OPS 3.652

FLIGHTS UNDER VFR FLIGHTS UNDER IFR OR AT NIGHT

INSTRUMENT SINGLE PILOT

TWO PILOTS

REQUIRED

SINGLE PILOT

TWO PILOTS

REQUIRED

(a) (b) (c) (d) (e)

1 Magnetic direction indicator 1 1 1 1

2 Accurate Time Piece 1 1 1 1

3 OAT Indicator 1 1 1 1

4 Sensitive Pressure Altimeter 1 2 2 (Note 1) 2

5 Air Speed Indicator 1 2 1 2

6 Heated Pitot System 1 (Note 2) 2 (Note 2) 1 2

7 Pitot Heat Failure Annunciator

- - 1 (Note 3) 2 (Note 3)

8 Vertical Speed Indicator 1 2 1 2

9 Slip Indicator 1 2 1 2

10 Attitude Indicator 1 (Note 4 or Note 5)

2 (Note 4 or Note 5)

1 2

11 Gyroscopic direction Indicator



1 (Note 8) 2 (Note 8)

12 Magnetic gyroscopic direction Indicator

- - 1 (Note 7) 2 (Note 7)

13 Standby Attitude Indicator - - 1 (Note 6) 1 (Note 6)

14 Alternate Source of Static Pressure

- - 1 1

15 Chart holder - - 1 (Note 7) 1 (Note 7) NOTE 1: For single pilot night VFR operation one sensitive pressure altimeter may be substituted by

a radio altimeter (JAR-OPS 3.652(c)).

NOTE 2: Required for helicopters with a maximum certificated take-off mass (MCTOM) over 3 175 kg or having a maximum approved passenger seating configuration (MAPSC) of more than 9 (JAR-OPS 3.650(l)).

NOTE 3: The pitot heater failure annunciation applies to any helicopter issued with an individual Certificate of Airworthiness after 1 August 1999. It also applies before that date when: the helicopter has a MCTOM greater than 3 175 kg and a maximum approved passenger seating configuration (MAPSC) greater than 9 (JAR-OPS 3.652(d)).

NOTE 4: Required for helicopters with a maximum certificated take-off mass (MCTOM) over 3 175 kg (JAR-OPS 3.650(i)).



NOTE 5: Required for any helicopters when operating over water; when out of sight of land or when the visibility is less than 1500 m (JAR-OPS 3.650(i)).

NOTE 6: For helicopters with a maximum certificated take-off mass (MCTOM) over 3 175 kg, CS-29 1303(g) may require either a gyroscopic rate-of-turn indicator combined with a slip-skid indicator (turn and bank indicator) or a standby attitude indicator satisfying the requirements of JAR-OPS 3.652(h). (However, the original type certification standard should be referred to determine the exact requirement.)

NOTE 7: For IFR operation only

NOTE 8: For VFR night operations only.

Item K.2 Amend JAR-OPS 3.820 as shown

JAR-OPS 3.820 Automatic Emergency Locator Transmitter (See IEM OPS 3.820)

(a) An operator shall not operate a helicopter unless it is equipped with an automatic Emergency Locator Transmitter (ELT). attached to the helicopter in such a manner that, in the event of a crash, the probability of the ELT transmitting a detectable signal is maximised and the possibility of the ELT transmitting at any other time is minimised.

(b) An operator shall not operate a helicopter in Performance Class 1 or 2 on a flight over water in a hostile environment as defined in JAR-OPS 3.480(a)(13)(ii)(A) at a distance from land corresponding to more than 10 minutes flying time at normal cruising speed, on a flight in support of or in connection with the offshore exploitation of mineral resources (including gas), unless it is equipped with an Automatically Deployable Emergency Locator Transmitter (ELT(AD)).

(c) An operator must shall ensure that all the ELTs is are capable of transmitting on the distress frequencies prescribed in ICAO Annex 10 simultaneously on 121.5MHz and 406 MHz, are coded in accordance with ICAO Annex 10 and are registered with the national agency responsible for initiating Search and Rescue or another nominated agency.

Item K.3

JAR-OPS 3.827 Crew Survival Suits (See IEMACJ OPS 3.827)



(a) An operator shall not operate a helicopter in Performance Class 1 or 2 on a f l ight over water at a distance from land corresponding to more than 10 minutes f lying t ime at normal cruising speed from land on a f l ight in support of or in connection with the offshore exploitat ion of mineral resources ( including gas) when the weather report or forecasts available to the commander indicate that the sea temperature wil l be less than plus 10ºC during the f l ight or when the est imated rescue t ime exceeds the calculated estimated survival t ime unless each member of the crew is wearing a survival suit .

Item K.4

IEMACJ OPS 3.827 Crew Survival Suits – Calculating Estimating Survival Time

(See JAR-OPS 3.827)

1 Introduction

1.1 A person accidentally immersed in cold seas (typically offshore Northern Europe) will have a better chance of survival if he is wearing an effective survival suit in addition to a life-jacket. By wearing the survival suit, he can slow down the rate which his body temperature falls and protect himself from the greater risk of drowning brought about by incapacitation due to hypothermia.

1.2 The complete survival suit system – suit, life-jacket and clothes worn under the suit – should be able to keep the wearer alive long enough for the rescue services to find and recover him. In practice the limit is about 3 hours. If a group of persons in the water cannot be rescued within this time they are likely to have become so scattered and separated that location will be extremely difficult, especially in the rough water typical of Northern European sea areas. If it is expected that in water protection is required for periods greater than 3 hours, improvements should be sought in the search and rescue procedures rather than in the immersion suit protection.

2 Definitions

2.1 Clo value. The unit used by physiologists to define the value of clothing insulation. A typical business suit and the usual undergarments worn in an office have an in-air value of 1 clo. Clo values are substantially reduced when clothing is compressed (as it is by hydrostatic compression under an immersion suit) or wet.

2.2 Ten-percentile thin man. The tenth thinnest man in a sample of 100 men representing the offshore population. Thinness is measured by mean skin fold thickness.

2 Survival times

2.1 The aim must be to ensure that a man in the water can survive long enough to be rescued, i.e. his survival time must be greater than the likely rescue time. The factors affecting both times are shown in Figure 1. The figure emphasises that survival time is influenced by many factors, physical and human. Some of the factors are relevant to survival in cold water, some are relevant in water at any temperature.

Figure 1 not reproduced



2.3 The relationship between water temperature, insulation of clothing and calm water survival is shown in Figure 2. The curves in Figure 2 are appropriate for the 10-percentile thin man and assume that his survival time ends when his core body temperature drops to 34ºC. At this temperature he is unlikely to die from hypothermia but he may be so incapacitated by cold that he will die from drowning. Fatter men with more body insulation can expect to survive longer than predicted by the curves. The curves show that the survival suit and clothing worn underneath must have an insulation value of about 0.5 clo if the wearer is likely to survive for more than 2 hours when immersed in water. If he is wearing summer clothes beneath a leak-free survival suit, the 0.33 clo line indicates that he will survive for less than 2 hours in water at 5º and for less than 3 hours in water at 10º.

Fig. 2 Estimated calm water survival times plotted against water temperature for thin individuals (approx. 10th percentile mean skinfold thickness) wearing various levels of immersed clothing insulation. The lowest curve is for lightweight summer clothing insulation. The lowest curve is for lightweight summer clothing only. The other three are for assemblies including an immersion suit with increasing thicknesses of clothing worn beneath.

2.4 The different solid lines in Figure 2 are defined in terms of actual clothing as follows:

0.06 clo= The immersed insulation of a man in lightweight summer clothing (overalls and underpants) without a survival suit.

0.33 clo= The immersed insulation of a man in summer clothing (as above) but with an effective survival suit on top.

0.50 clo= The immersed insulation of a man with long-sleeved and long-legged cotton underwear, a work overall, a thick woollen jersey and an effective survival suit on top.

0.70 clo= The immersed insulation of a man wearing long sleeved and legged underwear, a pile fabric insulation garment, working overalls and an effective survival suit on top.

Replace and amend the existing text as follows:

2.2 Broad estimates of likely survival times for the thin offshore individual are given in Fig. 2. As survival time is significantly affected by the prevailing weather conditions at the time of immersion, the Beaufort wind scale has been used as an indicator of these surface conditions.

Times within which the most vulnerable individuals are likely to drown

Clothing assembly Beaufort wind force

(water temp 5ºc) (water temp 13ºc)

0 - 2 Within ¾ hour Within 1¼ hours

3 - 4 Within ½ hour Within ½ hour

Working clothes (no immersion suit)

5 and above Significantly less than ½ hour

Significantly less than ½ hour

Immersion suit worn over working

0 - 2 May well exceed 3 hours May well exceed 3 hours



3 - 4 Within 2¾ hours May well exceed 3 hours

clothes (with leakage inside suit)

5 and above Significantly less than 2¾ hours. May well exceed 1 hour

May well exceed 3 hours

Fig. 2 Timescale within which the most vulnerable individuals are likely to succumb to the prevailing conditions.

2.3 Consideration must also be given to escaping from the helicopter itself should it submerge or invert in the water. In this case escape time is limited to the length of time the occupants can hold their breath. The breath hold time can be greatly reduced by the effect of cold shock. Cold shock is caused by the sudden drop in skin temperature on immersion, and is characterised by a gasp reflex and uncontrolled breathing. The urge to breathe rapidly becomes overwhelming and, if still submerged, the individual will inhale water resulting in drowning. Delaying the onset of cold shock by wearing an immersion suit will extend the available escape time from a submerged helicopter.

3.42.4The effects of water leakage and hydrostatic compression on the insulation quality of clothing are well recognised. In a nominally dry system the insulation is provided by still air trapped within the clothing fibres and between the layers of suit and clothes. It has been observed that many systems lose some of their insulative capacity either because the clothes under the ‘waterproof’ survival suit get wet to some extent or because of hydrostatic compression of the whole assembly. As a result of water leakage and compression, survival times will be shortened. The wearing of warm clothing under the suit is recommended. clothing of a greater dry and non-compressed clo value must be worn to maintain survival time.

3.5 2.5Whatever type of survival suit and other clothing is provided, it should not be forgotten that significant heat loss can occur from the head. A survival suit should have an insulated hood. Besides preventing heat loss, it will give the wearer some protection against accidental impact.

Item K.5 Amend JAR-OPS 3.830 as shown

JAR-OPS 3.830 Life-rafts and survival ELTs onr extended overwater flights (See AMC OPS 3.830)

(a)(1) to (a)(2) unchanged

(3) At least one survival Emergency Locator Transmitter (ELT(S)) for each liferaft carried (but not more than a total of 2 ELTs are required), capable of transmitting on the distress frequencies prescribed in ICAO Annex 10Appendix 1 to JAR-OPS 3.830. (See also AMC OPS 3.830(a)(3));


JAR-OPS 3.835 Survival equipment (See IEM OPS 3.835)



(a) unchanged

(b) At least one survival Emergency Locator Transmitter (ELT(S)) capable of transmitting on the distress frequencies prescribed in Appendix 1 to JAR-OPS 3.830 (see also AMC OPS 3.830(a)(3)); and Introduce new Appendix 1 to JAR-OPS 3.830

Appendix 1 to JAR-OPS 3.830 Emergency Locator Transmitter (ELT(S)) (See JAR-OPS 3.830 and JAR-OPS 3.835)

(a) All ELT(S) shall be capable of transmitting simultaneously on 121.5 MHz and 406 MHz, be coded in accordance with ICAO Annex 10 and be registered with the national agency responsible for initiating Search and Rescue, or another nominated agency.

Amend AMC OPS 3830 as shown

AMC OPS 3.830(a)(2) Life-rafts and ELT for extended overwater flights See JAR-OPS 3.830(a)(2)

1 Each life-raft required by JAR-OPS 3.830 shall should conform to the following specification:

a. They shall should be of an approved design and stowed so as to facilitate their ready use in an emergency;

b. They shall should be radar conspicuous to standard airborne radar equipment;

c. When carrying more than one life-raft on board, at least 50% shall should be jettisonable by the crew while seated at their normal station, where necessary by remote control;

d. Those life-rafts which are not jettisonable by remote control or by the crew shall should be of such weight as to permit handling by one person. 40 kg shall should be considered a maximum weight.

2 Each life-raft required by JAR-OPS 3.830 shall should contain at least the following:

a. One approved survivor locator light;

b. One approved visual signalling device;

c. One canopy (for use as a sail, sunshade or rain catcher;

d. One radar reflector;

e. One 20 m retaining line designed to hold the life-raft near the helicopter but to release it if the helicopter becomes totally submerged;

f. One sea anchor;



g. One survival kit, appropriately equipped for the route to be flown, which shall should contain at least the following:

i. One life-raft repair kit;

ii. One bailing bucket;

iii. One signalling mirror;

iv. One police whistle;

v. One buoyant raft knife;

vi. One supplementary means of inflation;

vii. Seasickness tablets;

viii. One first-aid kit;

ix. One portable means of illumination;

x. One half litre of pure water and one sea water desalting kit;

xi. One comprehensive illustrated survival booklet in an appropriate language.

3 Batteries used in the ELTs should be replaced (or recharged, if the battery is rechargeable) when the equipment has been in use for more than 1 cumulative hour, and also when 50% of their useful life (or for rechargeable, 50% of their useful life of charge), as established by the equipment manufacturer has expired. The new expiration date for the replacement (or recharged) battery must should be legibly marked on the outside of the equipment. The battery useful life (or useful life of charge) requirements of this paragraph do not apply to batteries (such as water-activated batteries) that are essentially unaffected during probable storage intervals.



Item N.1

Amend AMC OPS 3.945 as shown

AMC OPS 3.945 – Conversion Course Syllabus

Paragraph 1 to 4 unchanged

4 Emergency and safety equipment training and checking. Emergency and safety equipment training should take place whenever practicable in conjunction with cabin crew members doing similar training with emphasis on co-ordinated procedures and two-way communications. 4.1 For new flight crew members, or as applicable on conversion, the following should be addressed: a. Instruction should be given on aeromedical topics which should include at least:

i. to v. unchanged

b. Training should also include: i. The importance of effective coordination between flight crew and cabin crew members;

ii. to 6 (d) unchanged

7 Discipline and responsibilities. Amongst other subjects, emphasis should be placed on discipline and an individual's responsibilities in relation to: a. His ongoing competence and fitness to operate as a flight crew member with special regard to flight time limitation requirements; and b. to 8 unchanged Item N.2 Amend paragraph (E) Appendix 1 to JAR-OPS 3.965 Recurrent Training and Checking - Pilots (See IEM to Appendix 1 to JAR OPS 3.965) (See ACJ-No 1 to JAR OPS 3.943) (See ACJ-No 2 to JAR OPS 3.943) (See IEM OPS 3.965) Paragraph (a) to (a)(3)(iii)(D) unchanged

(E) First aid; appropriate to the

helicopter type, the kind of operation and crew complement (particularly in the case when crew members are not carried).


CRD to NPA-OPS 38

(JAR-OPS 3 - Helicopter Performance & Miscellaneous Items)

Comment/Response Document NPA-OPS 38

(Section 1 material) Number Org. Comments Reason(s) for proposed

text/comment Response


Summary of NPA-OPS 38 comment phase Comment period: 01/07/2005 until 01/11/2005 Comment period extended: until 01/12/2005 Number of comments received: 110 CRD collated by: CJAA, Luz Mendes CRD sent for review to: Mr Marcus Müller (HSST Chairman) CRD sent on: 13 December 2005 Date for completion of review: 06 February 2005* Date for completion amended to 24 February 2006 by agreement between HSST and CJAA. Nomenclature for CRD review A = Accepted PA = Partially accepted D = Declined N = Noted





General 004 Slovak Rep.

CAA CAA SK has no comments on this NPA and has express support for its adoption.

Noted

037 CJAA RIA 3.2.2.2 & 3.2.2.3: Replace the existing paragraphs 3.2.2.2 & 3.2.2.3 by the following text:

3.2.2.2 It is considered that a risk of not more than 5 x 10-8 of an accident occurring during take-off or landing due to engine failure in circumstances where a safe forced landing is not possible, can be achieved; provided the mean engine failure rate is less than 2 per 100,000 hours and the exposure period is less than 5 seconds in the case of twin engine aircraft and 10 seconds for single engine aircraft.

3.2.2.3 If the required reliability rate can be achieved and maintained, the principle of exposure could be extended to ground level take-off and landing phases, provided the safety target of a risk factor of not more than 5 x 10-8 per event is maintained

The statements in the existing paragraphs 3.2.2.2 & 3.2.2.3 of the RIA are over optimistic and disguise the fact that engine reliability falls short of 1 x 10-5 per flight hour. It is demonstrated in the attached paper that for the Super Puma fleet on the UK register (which is not only the commonest type in service on the North Sea but, also, a fleet for which there are comprehensive statistics available) engine failure rates due to causal factors relevant to the approach and landing phases, have varied on an annual basis since 1995 from between 0 and 3 per 100,000 hours. When averaged over 5 years (500,000 engine hours), the rates in the past 11 years have exceeded 1.5 per 100,000 hours on more than 40% of occasions.

Constant reference in the RIA to engine failure rates of 1 per 100,000 hours, and to resulting safe exposure periods (involving a risk of 5 x 10-8 per event) of 9 and 18 seconds are misleading when the average failure rate is nearer to 2 per 100,000 hours, and for which the corresponding maximum exposure

Declined The reliability figure of 1:100 000 is substantiated for the world-wide fleet contained in the manufacturer’s analysis in Appendix B to this document.

See the detailed response below containing a Risk Assessment using only the UK Offshore Statistics.





periods should be no more than 5 and 10 seconds.

Consequently, in any inquiry following an accident which occurred during performance class 2 and 3 operations, the credibility of the exposure period concept could be called into question and the CJAA could be criticised, because the reliability of the engines had been over stated and the helicopters exposed to risk factors which were well in excess of the declared value of 5 x 10-8 during exposure periods which were too long.

It is not considered that the comment reflects the explanatory text as written.

Paragraph 3.2.2.2; introduces the engine failure rates reported by manufacturers since the introduction of exposure in NPA-OPS 8 and discusses how they might be improved to meet the desired rate of 1x10-5

Paragraph 3.2.2.3; follows discussion of the reported reliability rate with an expression of the view that if the rate of 1:100 000 can be met or exceeded, exposure could be extended to ground level.

Neither paragraph is considered to be ‘over optimistic’ because: the first reports results from the manufacturers (see the attached engine reliability figures and analysis which establishes the power-loss information to the methodology/criteria contained in comment 090); and the second puts forward a view that if the target figure is achieved (by the measures discussed) exposure could be extended to ground level.

As has been discovered during the years between the introduction of exposure and the production of NPA 38, this is a very complex issue. To make the overall situation clearer, it is best to introduce context by considering the projected accident rate where there is achievement of a reliability rate of (a) 1:100 000 or (b) 2:100 000.

The risk assessment below shows a projected accident rate for the population of all offshore helicopters on the UK register.





All take-offs and landings are assumed to be full exposure events - a pessimistic assumption on two counts because:

(1) the wind is reported to be above 17 kts - 21kts for 35% of the time in the Northern North Sea - where these helicopters operate (CAA Paper 2005-06); and

(2) the Super Puma is used mainly on-shore to rig transfer and not shuttling (i.e. rig take-off and landings are not much in excess of 1 in every 2 events ),

The UK CAA reports the following sectors for the North Sea:

Sectors/yr = 200,000*

Potential exposure events/yr = <400,000**

The probability of an event is therefore 5 x 10-8 x 400,000** = 0.02/year or 1 event in 50 years.

If as claimed by the commenter the reliability rate is between 1 and 2 per 100,000 the probability of an event would be at worst = 1 in 25yrs.

Zero wind results in the longest exposure; a recent paper examining maximum exposure for a range of helicopters operated to elevated heliports/helidecks with zero wind showed: for take-off, a mean of 5.63 seconds; and for landing a mean of 5.92 seconds; by using the data collected from the Bristow INTOPS data base, it can be observed that wind of less than 10 kts is reported to occur for only 13% of the time (the mean for the whole population of wind reports for the northern North Sea being 20.37 kts). With zero wind, both take-off and landing mean are in excess of the 5 seconds proposed by the commenter.

If wind is in excess of 30kts (which occurs on 20% of the time and results in no exposure) and rig only events are taken account, the range of probabilities of an accident is likely to be:

with a reliability of 1x10-5 - between 1 in 50 - 125*** years; and

with a reliability of 2x10-5 - between 1 in 25 - 75*** years.

* This figure is based upon information contained in CAA Paper 2005-06

** This figure assumes every sector is rig to rig - see (2) above.

*** This projection is based upon 80% of 200,000 exposure events (that is; considering only rig events with a wind of less than 30kts).





073 UK CAA paragraphs in section H and section I:

Wherever “An operator shall ensure that” appears in the paragraphs of Sections H and I replace with “An operator shall be satisfied that”.

It is unreasonable to require an operator to “ensure” something when he is unable to do it as the performance is unscheduled.

Accepted Amend text as indicated.

074 UK CAA I.0.1:

Extended flight through the H/V curve implied by the extension of exposure to ground level is not considered fully justified.

The principles behind the use of ‘exposure’ are broadly supported. However, the implied intention to extend the period of time spent in the H/V curve from momentary to a longer time for PC3 operations (up to 18 seconds for a single-engined helicopter) is not supported as the justification and impact assessment are not sufficiently comprehensive to allow agreement. There is no reference to flight through the H/V curve in Annex 6 SARPs.

Declined See the Risk Assessment contained in the response below which has been accepted by the commenter.

ICAO Annex 6 makes no reference to the HV diagram as it is considered to be within the scope of Annex 8, addressing only the issue of a safe forced landing.

The proposed text in ICAO Annex 6 Part 3 Section 2 Chapter 3.1.2 has been amended to

“3.1.2 In conditions where the safe continuation of flight is not ensured in the event of a critical power unit failure, helicopter operations shall be conducted in a manner that gives appropriate consideration for achieving a safe forced landing”

thus permitting States to risk assess operations under circumstances where a safe forced landing might not be possible.

There are a number of circumstances where this might occur: exposure to the surface over which the flight is conducted; obstacles in the take-off or landing path; flight in the HV diagram etc. Flight through the HV diagram was specifically considered by the ICAO HTSG in the revision of 3.1.2 as this was already permitted under FAR 91.9(d) and Appendix 1 to JAR-OPS 3.005(c) - and by default in other State’s regulations.

The following is offered as justification for the introduction of ground level exposure:

Providing an estimate of the impact of the introduction of ground level exposure is difficult because it is not clear - without specific data - how many exposure





events might result from this proposal. Assuming that at this time there are no ground level exposure events permitted for commercial air transport in the UK at present (excluding offshore operations for which data is available and which has been dealt with in the response to comment 037 above) the following estimate is provided.

In the text below, the initial projection is for the case when the engine reliability figure of 1:100,000 flight hours is met and exposure does not exceed 18 seconds for a single engine helicopter and 9 seconds for a twin; the second projection assumes half the reliability figure (2:100 000) and double the exposure (36/18 seconds); full exposure in all cases is assumed.

Using the following assumptions:

• there are 800 helicopters in the UK of which 400 are engaged in CAT:

• each of those CAT helicopters flies 20 sorties a week; there is exposure on 10 sorties; it does this for 50 weeks a year;

• for each helicopter there will be 500 (full) exposure events/year;

• for the UK fleet that results in 200,000 (full) exposure events/year;

• the JAA engine reliability figure of 1 x 10-5 (1:100,000) per flight hour is met;

• the JAA safety target of 5 x 10-8 (1:20,000,000) per event is met – i.e. no event for a single exceeding 18 seconds or a twin 9 seconds;

This would produce (a headline figure) for the UK of 1 additional accident (due to an engine-failure in the exposure period) in 100 years (1:20,000,000/200,000)

If the achieved reliability rate is halved (2:100,000) and the exposure time is doubled to 36/18 seconds, it would result, for the UK, in 1 additional accident in 25 years (5,000,000/200,000).

The economic benefits are difficult to quantify as it is not clear what number of new or replacement of events would occur; with the assumption that there are no ground level events taking place at this time (with the exception of operations presently conducted in accordance with HEMS, PIS and Hostile Environment appendices), the projection makes an assumption that 25% of take-off and landings would involve ground level exposure. This could provide a growth of helicopter use of 12.5% (half of the events are considered to be replacement events and half are considered to be new). However, the proposal is primarily intended to remove the onerous burden of providing large sites for helicopter operations without introducing a substantial increase in risk; in mitigation, the requirement for UMS and a system for monitoring power assurance, could lower the risk of engine failure in all modes of flight (which is estimated to be 1:100 000 per flight hour) and thus provide an overall benefit in safety to the industry. 109 Eurocopter See comment below:





In addition to the subjects covered by the NPA-OPS 38, Commentator identifies also the following modifications that shall be best introduced in the same time into JAR-OPS 3 Amendment 4.

1. The term “HEMS Dispatch Centre” is used in the proposed ACJ to Appendix 1 to JAR-OPS 3.005(d), but this new term has never been described in JAR-OPS 3. Commentator proposes therefore to add the definition for this “HEMS Dispatch Centre” into paragraph (a) Terminology of Appendix 1 to JAR-OPS 3.005(d) as new number (7):

• HEMS Dispatch Centre. It is an office where the coordination or control of the HEMS flight takes place. It may be located in an HEMS operating base.

Accepted - the text will be amended

2. The term “area” imbedded in the phrase “take-off area available” in the definition for FATO as written in subparagraph JAR-OPS 3.435 (a)(4) should be replaced by “distance” for consistency with the phrase used in paragraph JAR-OPS 3.480 (a)(30) for TODAH.

Declined – The definition is the same as that used in ICAO.

3. According to the NPA, the IEM OPS 3.520 & 3.535 shall further be kept. But this IEM contains descriptions or references of requirements that only fit to the current JAR-OPS 3.520 and 3.535. Therefore it should be updated to meet the new requirements structure as proposed by this NPA. The following parts of this IEM need modification in term of the cited references or additional descriptions should be introduced to make it clearer:

Accepted – the text of the IEM will be amended

• Paragraph 4 : Additional subparagraph 4.4 shall be introduced. It reads “4.4 If an engine failure occurs before exposure time begins or after exposure time ends and before DPATO, compliance with 3.520(a)(3) will enable a safe forced landing on the deck.

Noted – the additional text will be added to 4.2 of the IEM to meet the intent of the commenter

• Paragraph 5 : 3.520(a)(4) should be replaced by 3.520(a)(3). Additional subparagraph 5.4 should be introduced. It reads “5.4 If an engine failure occurs before exposure time begins or after exposure time ends and before DPATO, compliance with 3.520(a)(3) will enable a safe forced landing on the deck.

Noted – paragraph 5.2 will be amended to meet the intent of the commenter.

• Paragraph 8 : 3.535(a)(4) should be replaced by 3.535(a)(3).

Accepted.





JAR-OPS 3.005(j) - NVIS 022 Swedish CAA We agree to the proposed amendment but

would like to add another amendment to the proposed rule. (j) Night VFR operations with the aid of Night Vision Imaging Systems (NVIS) shall only be conducted in accordance with JAR-OPS 3 and procedures contained in the Operations Manual for which a specific approval is required. (Se ACJ to JAR-OPS 3.005 (j))

Taking into consideration EASA:s take over in a couple of years it would be desirable to add an ACJ to the new rule. We propose that a condensed version of TGL 34 is transformed to such an ACJ.

Accepted A new ACJ, based on TGL 34 and one that has already been on ANPA for JAR-OPS 0, will be produced by the HSST and presented as a new DNPA to the OST.

029 NCAA The guidance material contained in TGL #34 should be included in Section 2 of JAR-OPS 3.

CAA-Norway would like to see the guidance material contained in TGL #34, which is fundamental to NVIS approvals, included as an ACJ in Section 2, as the future of TGL material in the EASA regime, at least in an interim period, is uncertain.

Accepted See the response to 022 above

Appendix 1 to JAR-OPS 3.005(d) – HEMS. THERE WERE NO COMMENTS TO THIS APPENDIX Appendix 1 to JAR-OPS 3.005(e) – Performance over a hostile environment 018 Swedish CAA Subpart (b): We propose an amendment to the This proposal is intended to make it Declined.





captioned Appendix as follows: (b) Applicability. This Appendix shall only be applicable to turbine-powered helicopters operating over a hostile environment located outside a congested area where it has been substantiated that helicopter limitations, or other justifiable considerations, preclude the use of the appropriate performance criteria.

possible also for piston engine helicopters with modern engines, attaining the safety target, to apply to this Appendix. That does not mean that we open the doors for all helicopters. Those who want to apply to the Appendix have to show the reliability of the engines by statistics. They also have to comply with Appendix 1 to JAR-OPS 3.517 a) and its ACJ. The proposal is a logical adjustment to JAR-OPS 3.540 where no exemptions are made for piston engine helicopters. It is also an adjustment to make JAR-OPS 3 compatible with ICAO Annex 6 Part III.

This was not part of the NPA and a new proposal should be made which is accepted by the commenter.

019 Swedish CAA Subpart (c ): We would like to propose an amendment to the captioned Appendix: (c) Performance Class 2 alleviation. Helicopters operating in Performance Class 2 over a hostile environment located outside a congested area and with a maximum approved passenger seating configuration (MAPSC) of 9 or less passengers are exempt from the following requirements of JAR-OPS Part 3, Subpart H: (1) JAR-OPS 3.520(a)(2 (2) JAR-OPS 3.535(a)(2)

provided that the operator complies with Appendix 1 to JAR-OPS 3.517 (a).

We can not se any logical reason why there shouldn’t be a requirement of compliance with the referred Appendix in this case. Consequently we don’t think there is any need for this paragraph at all as the possibility of alleviation is taken care of in JAR-OPS 3.517 a)

Declined This was not part of the NPA and a new proposal should be made which is accepted by the commenter. To accept the revision would be to add an additional burden on operators and States in the provision of a reliability assessment – which is not at present required.

020 Swedish CAA Subparagraph (d): We propose an amendment By deleting the text, the paragraph also Declined.





as follows: (d) Performance Class 3 alleviation. Helicopters operating in Performance Class 3 over a hostile environment located outside a congested area and with a maximum approved passenger seating configuration (MAPSC) of 6 or less are exempt from the requirement of JAR-OPS 3.240(a)(5) provided that the operator complies with Appendix 1 to JAR-OPS 3.517(a). subparagraphs (a)(2)(ii) & (v).

will require compliance with Appendix 1 to JAR-OPS 3.517(a) subparagraph (a) (1) (i) and (ii). Even if no amount of Risk Assessment with regard to reliability can provide the justification for this type of exposure (hours) we think that it is logic and risk mitigating to require at least the same engine reliability for this type of operation as for start and landing without safe forced landing capability (ref. JAR-OPS 3.540 (b)). This proposal is in line with our proposal for a removal of turbine-powered helicopters in Appendix 1 to JAR-OPS 3.005 (e) subparagraph (b) and will prevent not reliable piston engines to operate under this Appendix.

See the comment in 19 above; however the text should be amended as follows: “subparagraphs (a)(2)(i) & (ii) & (v)

079 CJAA 1. Revised text as per NPA OPS 38 needs to retain reference to “IEM to Appendix 1 to JAR-OPS 3.005(e)” 2. Sub-paragraph (f) of the existing Appendix is an error. It does not belong in this Appendix at all!

printing errors. 1. Accepted. The reference to the IEM has been re-inserted. 2. Declined. This text was not included in the NPA.

080 CJAA See comment below It is considered that clarification of these points may aid discussion of comments made during the NPA process.

Noted. This text was not part of the NPA.

JAR-OPS 3.005(e) and the associated Appendices and the references thereto form an extremely complex regulatory regime which is very difficult to understand:

JAR-OPS 3.005(e)/Appendix 1 to JAR-OPS 3.005(e) permits turbine powered helicopters to be operated in a hostile/non-congested environment (in which, in the





event of an engine failure, a safe forced landing will not be possible) as follows:

(i) In Performance Class 1 (i.e. with full engine failure accountability);

(ii) In Performance Class 2 (i.e. when landing and taking-off, or otherwise operating at less than VTOSS):

(a) without (in the event of an engine failure) being able to carry out a safe forced landing (exemption from JAR-OPS 3.520(a)(2) & 3.535(a)(2)), and

(b) without operating in accordance with the exposure period concept of Appendix 1 to JAR-OPS 3.517(a).

(iii) In Performance Class 3 (i.e. for periods (not restricted to landing and take-off) which may extend to include entire flight sectors):

(a) without (in the event of an engine failure) being able to carry out a safe forced landing, and

(b) without operating in accordance with the exposure concept of Appendix 1 to JAR-OPS 3.517(a).

Provided:

The NAA considers the risk to be acceptable and has given an approval.

The helicopter is fitted with a UMS.

The operator complies with the conditions of the approval.





Appendix 1 to JAR-OPS 3.005(i) 021 Swedish CAA Subpara (d)(1): We propose an editorial change

in the text as follows: (d) Alleviation:

(1) Operations to/from a public interest site, may be conducted in accordance with Subpart H (Performance Class 2) and are exempt from the following requirements:

(i) the requirement of JAR-OPS3.520(a)(2); and

(ii) the requirement of JAR-OPS3.535(a)(2);

until 31 December 2004, provided that the operator has been granted a relevant approval

by the Authority (See Appendix 1 to JAR-OPS3.517(a)) subparagraphs (a)(2)(ii) and (v) and

(b)(2) and (b)(5)).

We believe that it is just an editorial mistake and that the text in Appendix 1 to JAR-OPS 3.005 (i), subparagraph (d) (1) has not been adjusted to the new Appendix 1 to JAR-OPS 3.517 (a).

Noted In view of the renumbering of the Appendix, amend the text as follows: “subparagraphs (a)(2)(i) & (ii) & (v)

JAR-OPS 3.210 023 Swedish CAA Para (d): We propose an amendment as follows:

(d) An operator shall not permit a helicopter rotor to be turned under power, for the purpose

The proposal is an adjustment to the new ICAO Annex 6, Part III and to an applied practice among operators in most countries. The Swedish Civil Aviation

Noted.

The intent of the ICAO proposal was not to legitimise the activity described by the Swedish CAA





of flight, without a qualified pilot at the controls. Authority has announced to JAA that we exempt the Swedish operators from the current rule. There are situations when a pilot has to leave the controls with the rotor spinning for safety reasons or for practical reasons. With this cognizance we believe it is better to allow pilots to leave the aircrafts while the rotor is spinning provided that the operator in the Operations Manual has stated the special conditions that should be met and provided that it is not inappropriate because of the construction of the helicopter. It is better that this is done legally and under stated conditions than illegal and out of control.

but to permit ground runs to be conducted by personnel other than flight crew.

This proposal has been debated at length on a number of occasions - both in ICAO and the HSST - and the conclusion always was not to permit the pilot to leave the controls if the rotors are turning under power.

If the amendment is accepted by the HSST and OST (and as there have been no comments against the ICAO proposal it could be achieved at this revision), it should be made clear that there should always be someone at the controls when the rotor is turned under power. To ensure that the intent is made clear an ACJ will be provided to say the following: “the intent of the text is to permit rotors-running ground runs to be conducted by other than pilots, not to legitimise the practice of leaving the controls whilst the rotor is being turned under power. The operator should ensure that the qualification of





such personnel is described in the appropriate manual.”

JAR-OPS 3.330(a). THERE WERE NO COMMENTS TO THIS JAR REQUIREMENT JAR-OPS 3.426 008 Veritair Where possible……………………will be

sufficient. There are strong cost implications to the operator into breaking down the hours into so many constituent parts. There appears to be no safety benefit derived from such a breakdown since normally the aircraft will remain on the same Maintenance Schedule. In compiling statistics for In-Flight Shutdowns or other component reliability issues the role of the aircraft is not particularly relevant in comparison with the overall failure rate.

Declined.

This refers to the ACJ and not the requirement.

The reason for asking for this breakdown in the guidance material is that it is important to understand why an engine has failed. When producing engine failure statistics, manufacturers always stress that helicopters used in Aerial Work are subject to more abuse that those for CAT.

It is clear that the manufacturers, in producing their reliability analyses, would prefer to weight their conclusions by taking advantage of such data.





The cost of the provision of this data will not be significant.

JAR-OPS 3.470 042 UK CAA (a)(2): a. Amend “except that

helicopters:” to “except helicopters:” b. Replace ‘bullet’ points with (i) and (ii).

To clarify text and standardise sub-paragraph numbering.

(a) Accepted. The word ‘that’ will be removed (b) Noted. Although the intent of the comment is understood these two bullets are not subdivisions of (a)(2) but are exemptions from the requirement to operate in PC1. If the bulleting is not acceptable, the two bullets should be coalesced into the single text immediately above. This is accepted by the UK CAA.

081 DGAC France Applicability, (a)(2): (a) An operator shal l ensure that:

(2) hel icopters […] are operated in accordance wi th […]; except that hel icopters: • which have […] may be operated in accordance wi th

See reason below: Noted. See the accepted comment in comment 042 above which satisfies the DGAC.





JAR-OPS 3.517(a) or • which have an operat ional approval in accordance wi th Appendix 1 to JAR-OPS 3.005( i) (b) Unless otherwise prescr ibed [ . . . ]

As written, the sentence in the second bullet of (a)(2) does not make any sense as it has no verb. Perhaps the editor was just in the process of deleting this portion of paragraph 2, as the editing rule in JAR-OPS 3 seems to be the following: • performance rules in subpart F (General) and G to I (PC 1 to 3), with punctual exemptions if needed, • “super exemptions” in JAR-OPS 3.005 (d) to (j), requiring a specific and global approval, restricted to some specific operations. As a matter of fact this seems to be the rationale behind the amendment to JAR-OPS 3.540 (Item I.1) which does not mention any more operations according to 3.005(e) (which allows exemption to safe force landing at take-off, landing and en-route, “where it has been substantiated that helicopter limitations, or other justifiable, preclude the use of the appropriate performance criteria), but only the punctual exemptions at take-off and landing. JAR-OPS 3.475 043 UK CAA Amend reference in final paragraph from “IEM

OPS 3.490(a)(3)(ii)” to “IEM OPS 3.490(b) and 3.495(b)(4)”

Incorrect reference. Accepted. The text will be amended accordingly

JAR-OPS 3.477 044 UK CAA (a)(3)(ii) and (iii):

Sub-paragraphs (ii) and (iii) should be connected to 3.477(a)(2).

Text of sub-paragraphs refers to that contained in 3.477(a)(2) and not (a)(3) and should be moved.

Accepted. The text will be moved as required.

045 UK CAA (b)(1):

Amend “RD. Rotor Diameter” to “R. Rotor radius”.

The proposed text does not conform with ICAO Annex 6 and is at variance with the previous version of JAR-OPS 3. Moving from R to RD with the same multiplication numbers (7 and 10) will

Accepted. The text will be amended accordingly





double the required distances for obstacle accountability. It is considered that this may be an oversight.

062 UK CAA (a)(1)&(2):

Delete hyphen symbol from in front of lines. Eg: “- 0.10 DR for VFR day operations”

Hyphen symbol could be misinterpreted as a minus symbol thereby negating the requirement of the paragraph.

Accepted. The minus sign will be removed but the text will remain indented.

082 DGAC France obstacle accountability, (a): (a) For the purpose of obstacle c learance requirements, an obstacle, located beyond the hel ipor t , in the take-of f f l ight path or the missed approach f l ight path, shal l be considered i f i ts lateral d is tance from the nearest point on the surface below the intended f l ight path is not fur ther than:

(1) For VFR operat ions: ( i ) -hal f of the minimum hel ipor t width of the necessary area def ined in the Hel icopter Fl ight Manual (or , when no width is def ined 0.75 D), p lus 0.25 t imes D (or 3 m, whichever is greater - or 1 D whichever is greater , p lus: -0.10 DR for VFR day operat ions -0.15 DR for VFR night operat ions” […]

In some flight manuals, the size of the necessary area for category A operations is different when operating from a surface heliport or from an elevated site. If we keep the text as it is, the obstacle accountability may be wider for an helicopter operating from an elevated site than for the same helicopter operating from a surface heliport. This is not consistent all the more so as the flight paths are the same. Moreover the word « heliport » is not appropriate in that case as it is too vague and the word « FATO » is not used in the HFM. It is the reason why we propose to use « necessary area ».

Partially Accepted (1) The revised text is much too imprecise; the text will be changed to: “FATO (or the equivalent term used in the Flight Manual)” To avoid complication, DGAC agrees that the text that introduces the additional factor of 1D will not be added. Note: Use FATO in whole of this text where heliport is used.





083 DGAC France […] (b) For take-of f us ing a backup (or s ideways) procedure, for the purpose of obstacle c learance requirements, an obstacle, in the backup area, shal l be considered i f i ts lateral d is tance f rom the nearest point on the surface below the intended f l ight path is not fur ther than: - hal f of the minimum width of the necessary area defined in the helicopter flight manual (or when no width is defined 0.75 L), plus 0.25 times L (or 3m, whichever is greater) - or 1 L whichever is greater, plus - 0.10 DR for VFR day operat ions - 0.15 DR for VFR night operat ions (See ACJ JAR-OPS 3.490 (d)).

(bc) Obstacles may be disregarded i f they are s i tuated beyond […]

We propose to add this paragraph in order to tell which obstacles have to be taken into account in the backup when using a back-up procedure.

Partially Accepted The text will be made consistent with the text above. D will be substituted for ‘L’.

JAR-OPS 3.480 009 Veritair JAR-OPS 3.480(a)(30) & ACJ OPS

3.480(a)(31): “……plus the length of any clearway or flyaway (if provided ………….

It is proposed to introduce a new definition of Helicopter Flyaway as follows:

The term clearway is defined in JAR 1 as only applicable to Aeroplanes certificated after 1959. No other definitions could be found in JAR-OPS 3.

This proposed definition of flyaway is in

Declined The term ‘helicopter clearway is defined in Annex 14. The proposal will be removed.





“Helicopter Flyaway means an area, between the ends of the Rejected Take Off Distance Available and the Take Off Distance Required (H), designated to allow a helicopter to accelerate from TDP to VTOSS. Where such an area lies outside the heliport boundary then all obstacles along the intended flight path must be cleared by a minimum of 10.7m (35ft) with one engine inoperative.”

the spirit of the ICAO Annex 6 Attachment A extract quoted in the ACJ Discussion. It also emphasises the vertical nature of Helicopter Performance capabilities in contrast to the more horizontal nature of Aeroplane Performance. Such a definition would remove the necessity to have such an area under the control of the appropriate authority and to only contain lightweight and frangible objects as defined in ICAO Appendix 2 Helicopter clearway. As an entirely new term it could be more easily integrated into the ICAO documents without having to re-define the ICAO Helicopter clearway. From a Safety viewpoint any third parties under the flyaway would be afforded the same protection as those at the end of the TODR(H).

046 UK CAA (27): Amend “RD. Rotor Diameter” to “R. Rotor radius”.

The proposed text does not conform with ICAO Annex 6 and is at variance with the previous version of JAR-OPS 3. Moving from R to RD with the same multiplication numbers (7 and 10) will double the required distances for obstacle accountability. It is considered that this may be an oversight.

Accepted. The text will be amended accordingly.

076 UK CAA (30):

a. The term “clearway” is not defined in JAR-OPS 3. b. Suggest new definition in 3.480:

The term is used with the definition of Take-off distance available but is itself undefined. Adding a definition would clarify the statement. The proposed new

Noted See the comment in 009 above.





“Clearway. The airspace above the surface selected and/or prepared as a suitable area through which a helicopter operated in PC 1 may accelerate and achieve a specific height during take-off.”

definition is similar to that being considered by the Annex 14 Working Group.

084 DGAC France “JAR-OPS 3.480 – Terminology […]

(1) ‘Category A’ with respect to hel icopters means mult i -engine hel icopters designed wi th engine and system isolat ion features speci f ied in JAR-27/29 or equivalent acceptable to the JAA EASA and Hel icopter Fl ight Manual performance information based on a cr i t ical engine fa i lure concept which assures adequate designated surface area and adequate performance capabi l i ty for cont inued safe f l ight in the event of an engine fa i lure

The JAA have no more responsibility in the field of airworthiness. Therefore “EASA” has to be written instead of “the JAA”.

Noted This is one of a number of terms in JAR-OPS 3 that will be resolved in preparation of the text for incorporation into the EU regulations. In the interim, the term will be replaced with ‘the Authority”. JAR 27/29 will also be changed to “the appropriate airworthiness code” with a recommendation that it is also applied to the whole of JAR-OPS 3.


(24) Rejected take-of f d istance avai lable (RTODAH) The length of the f inal approach and take-off area declared avai lable and sui table for hel icopters operated in Performance Class 1 to complete a re jected take-of f .

The ‘Rejected take-off distance available (RTODAH)’ has to be defined as it is used in JAR-OPS 3.490(a)(2)(ii). The proposed definition is consistent with the definitions of LDAH and TODAH.

Accepted The text will be amended accordingly.





(2425) Rejected take-off dis tance required (RTODRH) …


(16) Landing distance required (LDRH) The hor izontal d istance required to land and come to a ful l s top from a point 10.7 m (35 f t) 15 m (50 f t) above the landing surface.

The proposed change in the height mentioned in the definition of the LDRH results from a similar amendment of the definition of LDR in ICAO Annex 6, III, as proposed by State Letter N° 05-50, that states have just been commenting on (deadline November 30th, 2005)

Accepted. In view of the fact that existing helicopters have been certificated under a previous rule using other criteria - i.e. some have 25ft and others 35ft, a note will be added. “Older helicopters with an elevated heliport procedure may have been certificated with a landing distance specified from an alternative height.”

097 Eurocopter (5) D. The largest dimension of the helicopter when the rotors are turning. D should be replaced by L to be in consistence with ICAO Annex 6 Part III Attachment A Figures A-1 to A-11. Therefore references to D in 3.477 (a) should be modified accordingly

Declined JAR-OPS 3, Annex 14 and Annex 6 will all use ‘D’ – Eurocopter agrees with the retention and harmonisation on ‘D’.

JAR-OPS 3.485. THERE WERE NO COMMENTS TO THIS JAR REQUIREMENT





JAR-OPS 3.490 024 Swedish CAA We propose that Performance Class 2 with

exposure but without additional requirement of OEI HOGE performance (and in compliance with the performance requirement as for the rest in Appendix 1 to JAR-OPS 3.005 (d)) should be accepted for HEMS operations for take off and landing at HEMS bases and hospitals that are not fully in compliance with the AFM or Annex 14. This standard should be accepted without a special approval procedure concerning the so called Public Interest Sites. The actual implication of our proposal is a general Performance Class 2 requirement for HEMS instead of Performance Class 1.

The very strong focus on an engine failure in JAR-OPS 3 at the expense of other risk mitigating requirements is questionable, especially for HEMS operations. It is our view that the development of increasingly more reliable engines and sophisticated monitoring systems and preventing maintenance actions makes it unnecessary and misdirected to push the development in the direction of OEI HOGE performance. That is not in the interest of neither the operators nor their customers, except perhaps the oil industry (expensive and heavy engines).

Declined As was explained in the explanatory text, the proposal is to remove the reliance on Category A and the resulting limitation in sizes of heliports (generally 2D); this was undertaken because of the known difficulties in a number of States with the size of existing heliports. Whether Class 1 is an appropriate performance class for HEMS is not part of the NPA; this is accepted by the commenter.

048 UK CAA (a)(2)(i): a. The term “FATO” is undefined. Change to “Rejected take-off distance available (RTODRH)”. b. The paragraph appears superfluous when considered with above comment and 3.490(a)(2)(ii).

The acronym FATO is undefined in JAR-OPS 3 but is defined in ICAO Annex 6 Pt III. The term could be used if it was appropriate to the text and was defined in 3.480. This term also appears in ACJ OPS 3.490 and 3.510 and should be addressed in the same way.

(a) Declined FATO is defined in JAR-OPS 3.345(a)(4). (b) Declined The paragraph will be retained as it provides additional information which might assist the operator – this is accepted by the CAA.

087 DGAC France See comment below: We propose to change JAR OPS 3.490(d) to give the operator the responsibility to show that he is able to

Accepted The ACJ is accepted with the





clear the obstacles in the back-up. We propose to add an ACJ to explain why this requirement has been written and to give some clues on what can be done and accepted.

following revisions: L is substituted by D; The requirement for ‘or 1L’ is removed; and The highlighted text is amended. The ACJ (which refers only to obstacles in the back-up area) is new but has been extensively debated in the HSST and with the airworthiness members of that committee. There is no equivalent text in AC 29-2C even though this is implemented and included in Flight Manuals. Without this text, there is no guidance to complement the rule change.

• Amend proposed JAR-OPS 3.490(d) as follows: “(d) For take-off using a backup (or sideways) procedure, the back-up (sideways) distance shall be free of obstacles unless adequate clearance from the obstacle can be demonstrated during the backup (sideways), rejected take-off and continued take-off profiles the operator shall ensure that, with the critical power-unit inoperative, all obstacles in the backup (sideways) area are cleared by an adequate margin (see ACJ OPS 3.490(d)).” • and add a new ACJ OPS 3.490(d) as follows: “ACJ OPS 3.490(d) Obstacle Clearance in the Back-up Area See JAR-OPS 3.490(d) The requirement in JAR-OPS 3.490(d) has been established in order to take into account the following factors:





In the back-up; the pilot has few visual cues and has to rely upon the altimeter and sight picture through the front window (if flight path guidance is not provided) to achieve an accurate rearward flight path. In the rejected take-off; the pilot has to be able to manage the descent against a varying forward speed whilst still ensuring an adequate clearance from obstacles until the helicopter gets in close proximity for landing on the FATO. In the continued take-off; the pilot has to be able to accelerate to Vtoss whilst ensuring an adequate clearance from obstacles. The requirements of JAR-OPS 3.490(d) may be achieved by establishing that, in the backup area: no obstacles are located within the safety zone below the rearward flight path when described in the helicopter flight manual (see figure

1); (in the absence of such data in the helicopter flight manual, the operator should contact the manufacturer in order to define a safety zone);or during the normal backup, the rejected take-off and the continued take-off manoeuvres, obstacle clearance has been demonstrated by

a means acceptable to by the authority. Figure 16 – rearward flight path





An obstacle, in the backup area, is considered if its lateral distance from the nearest point on the surface below the intended flight path is not further than • half of the minimum width of the necessary area defined in the helicopter flight manual (or when no width is defined 0.75 L), plus 0.25 times L (or 3m, whichever is greater) • or 1 L whichever is greater, plus 0.10 DR for VFR day operations or 0.15 DR for VFR night operations (see figure 2).

Safety Zone

Max TDP

TDP

X metres Safety Zone

Y metres Z metres

z ft

y ft

Rearward Flight Path x degrees

No obstacle above this line





Figure 2 – Obstacle accountability

098 Eurocopter ( iv) As an alternative, the

requirement in JAR-OPS 3.490(a)(2)( i i i ) above may be disregarded provided that the helicopter, with the crit ical power-unit fai lure recognised at TDP can, when continuing the take-off , clear al l obstacles to the end of the take-off distance required by a vertical margin of not less than 10.7 m (35 ft) (see ACJ OPS 3.480(a)(31));

Declined The commenter agrees that the text as written is correct as it permits obstacles within the TODRH

10 or 15 %

10 or 15 % Safety area

Max TDP

FATO Safety zone

TDP





Should be read “clear all obstacles from the end of takeoff distance available”

JAR-OPS 3.495 010 Veritair Para (a)(1): The term VMC and IMC should be

used instead of VFR and IFR. It is possible to depart a Heliport under an IFR clearance but with the ability to “see and avoid” obstacles during the initial take-off path, operating VMC before entering cloud.

Declined. The provision of obstacle clearance is an issue of planning; there is no facility to take-off VFR only applying IFR clearance when entering cloud. The specification of IFR clearance requires the additional 1% to be applied from DR - which leaves no flexibility to permit a two slope departure.

039 Starspeed Should VFR and IFR be VMC and IMC Clarification Declined See the response to comment 010 above.

094 Eurocopter (2) . Where a change of d irect ion of more than 15° is made, adequate al lowance is made for the ef fect of bank angle on the abi l i ty to comply wi th the obstacle c learance requirements. This turn is not to be in i t iated before reaching a height of 30 m (100 f t ) above the take-of f

1. Reference to take-off surface is found inappropriate. When taking off from an elevated helipad the relevant surface to be taken into account is not the take-off surface. Mentioning height is sufficient, as height is always measured in reference to the actual overflown surface. 2. Some helicopters include in their

Partially Accepted. Suggest the following text: “This turn is not to be initiated before reaching a height of 61 m (200 ft), unless permitted as part of an approved procedure in the Flight Manual.” It was felt that the original height





surface. Proposed sentence “This turn is not to be in i t iated before reaching a height of 30 m (100 f t) , except if the turn below 30m (100ft) in Cat A procedure is authorized in the certified RFM.

certification process a demonstration of turn during takeoff path after an engine failure. This permits the operator to build safe takeoff path taking into account obstacles. Therefore when this possibility is certified and explained in RFM, it is unduly severe to forbid its use before 100 ft.

of 100ft was not fully justified; on further review and in the interest of safety, the height has been increased to 200ft (the height at which acceleration to Vy occurs and during which an improved power margin is available). It is not considered that this will have any impact on existing operations. This will be different from the ICAO text which still has the 100ft.

JAR-OPS 3.500 011 Veritair (3): Add “Drift-down techniques may be used.” Since Drift-down techniques are allowed

in paragraph (2) when out of sight of obstacles or terrain then it follows that it must be safe to use such techniques when operating with such obstacles and terrain in sight.

Such techniques would offer a better payload when transiting over hilly terrain without any loss of safety margins.

Noted. When this text was proposed, compliance with ICAO Annex 2 Chapter 4.6 b) (specifically the 500ft rule) was intended; drift down was not considered to be required - it was implied in the text “without flying below the appropriate minimum flight altitude”. No action required.

012 Veritair ( c): Will an ACJ be published to describe how an operator can determine whether navigational accuracy can meet the 95% containment level along a particular route?

This advice is necessary for the operator to ensure that he complies with the Regulation.

Noted. The text of paragraph (c) will be clarified with the following text: The width margins of sub-





paragraphs (a)(1) and (a)(2) above shall be increased to 18.5km (10nm) if the required navigational accuracy cannot be met for 95% of the containment level total flying time. (See JAR-OPS 3.240, 3.243 and 3.250)

052 UK CAA (a)(2) & (3):

a. At paragraph (a)(2), amend “out of sight of the surface” to “without the surface in sight”. b. At paragraph (A)(3), amend “in sight of the surface” to “with the surface in sight”.

a. Change of terminology aligns with changes to ICAO Annex 2. b. Replace similar text throughout JAR-OPS 3 to reflect ICAO Annex 2 change.

Accepted. Amend the text as indicated

053 UK CAA (c ):

a. It is not clear whose responsibility it is to increase the width margins. It is recommended that the paragraph is redrafted to retain the responsibility with the operator. b. The use of “95% containment level” is unsubstantiated.

a. It is unclear where the responsibility lies for increasing the width margins if the accuracy of navigation does not meet certain levels. Leaving the responsibility with the operator would seem more appropriate than placing the onus on the Authority.

b. It is not clear where the justification or documentation for the 95% containment level, as mentioned, is defined. This should be explained and justified.

(a) Declined. It has been accepted that, in accordance with JAR-OPS 3.243, the onus is upon the operator to be in compliance (b) Noted The UK CAA accepts the comment in 012 above.





054 UK CAA (a)(1):

Reposition ‘comma’ from after “600 m” to after “(1000 ft)”.

Correcting punctuation. Accepted. Amend the text as indicated

091 Eurocopter (a)(3):

Add at the end of the last sentence: … minimum flight altitude, obstacles within 900 m on either side of the route need to be considered.

Reference to the 900m lateral clearance on the route which is existing in the current rule is found appropriate and should not be cancelled

Accepted. This then will meet the same requirement as JAR-OPS 3.477.

099 Eurocopter (a)(21) When i t is intended that the f l ight wi l l be conducted at any t ime out of s ight of the surface, the mass of the hel icopter permits a rate of c l imb of at least 50 f t /minute wi th the cr i t ical power uni t inoperat ive at an al t i tude of at least 300 m (1 000 f t) 600 m , (2 000 f t) in areas of mountainous terra in , The coma between 600m and (2000ft) must be cancel led and to clar i fy the intent of the rules i t is suggested to read: at an al t i tude of at least 300 m (1 000 f t ) or 600 m _ (2 000 f t ) in areas of mountainous terrain

Noted. See the response to 054 above.





JAR-OPS 3.510 055 UK CAA (a)(2):

Paragraph (a)(2). Delete “when applicable”. “When applicable” is unnecessary as the “landing distance required” should always not exceed “the landing distance available”

Noted The text will be amended to state: “in the event of the critical power-unit failure being recognised at any point at or after the LDP it is possible to clear all obstacles in the approach path.” The text has also amended to provide a more logical order of likely events.

(2) in the event of the crit ical power-unit fai lure being recognised at any point at or before the LDP, it is possible either to land and stop within the FATO, or to perform a balked landing and clear all obstacles in the f l ight path by a vert ical margin of 10.7 m (35 ft) (see ACJ OPS 3.480(a)(31)) . Only obstacles as specif ied in JAR-OPS 3.477 have to be considered.

(3) when applicable, the landing distance required does not exceed the landing distance available; in the event of the crit ical power-unit fai lure being recognised at any point at or after the LDP it is possible to clear al l obstacles in the approach path.

(4) in the event of the crit ical power-unit fai lure being recognised at any point at or after the LDP, it is possible to land





and stop within the FATO; and

056 UK CAA (a)(3): a. FATO is undefined. b. Depending on the use of FATO, this paragraph may be superfluous.

a. Define FATO or use different terminology. b. Paragraph could be amalgamated with 3.510(a)(2).

Noted. See the response in comment 051.

057 UK CAA Propose new sub-paragraph (d). (d) The landing distance shall be free of obstacles unless adequate clearance from the obstacles can be demonstrated during the OEI landing and balked landing profiles.

In the same way that 3.490 permits obstacles in the backup distance (subject to adequate clearance) it may be necessary to also permit obstacles in the landing distance. A classic case would be a ground level helipad/short field site with a fence in the backup which would be permitted for 3.490 take-off but would preclude a landing back at the same site as 3.510 is written at present.

Noted. See the response to comment 055.

JAR-OPS 3.515 004 ÖAMTC The cancellation of paragraph JAR-OPS

3.515(2) and JAR-OPS 3.517 for Offshore Operators may have a lot of positive Impacts, but - thought reverse in case of HEMS Operations it has to be clarified that Appendix 1 to JAR-OPS 3.005(d)(2)(i)(A), where Performance Class 1 for HEMS Operations is stated as a requirement, is not touched by this proposed changes.

See reason below. Noted. In the current version of JAR-OPS 3, the basic requirement for performance is provided by JAR-OPS 3.470. The HEMS requirement is the same as other AOC operations when operating with third party risk - i.e. PC1. The HEMS appendix provides two alleviations: that





It has to be a requirement for all HEMS Operators to provide a maximum of a safe HEMS mission !

which is given by Appendix 1 to JAR-OPS 3.005(i) (the public interest site); and that given when at a HEMS operating site. It is not considered that any of the changes will affect HEMS apart from the ability to operate with ground level exposure - which is close to the current alleviation in the HEMS appendix. There could be implication for a HEMS operating base located in a non-congested hostile environment, which, up to now, required PC2 without exposure and which can now take advantage of ground level exposure (which does not apply if there is a third party risk).

a) As an example – a transport helicopter (SA315 – Lama) lost its 750kg load in an altitude at 3250m MSL due to unknown reasons. The load hits a cabin of a cablecar which was fallen down – 9 fatal injuries was the result (Sept.2005). The rescue of other insured persons on ground and the rescue of the people which was caught in other cabins of the cablecar would be possible with performance class 2 helicopters also, but with a not calculate able higher risk.

In order not to encourage a dispatcher to include a performance class 2 helicopter in such a rescue mission the requirements layed down in Appx.1 to 3.005(d) must be valid continued.

b) A economical reason, a lot of european HEMS Operators (ÖAMTC, ADAC, RACC, REGA,…) have invested in new JAR-OPS 3 conform helicopters, to fulfill JAA requirements and internal safety standards – so that a new discussion concerning the reasonable usage of performance class 1 helicopters at HEMS OPS. will be not succeed to aim a safe operation.

c) In “Aviation International News” – August 2005 – Daryl Murphy states a article concerning poor safety records addressed by EMS helicopter operators. So





in U.S they starts a lot of working groups (AMRM,…) to fix a higher safety level which is reached with, in Europe, almost existing requirements. 058 UK CAA (a):

a. Following the change to the section, delete the sub-paragraph (1) title and join up (a) with the rest of the remaining text. b. Amend “ACJ to JAR-OPS 3.480(a)(31)” to “ ACJ to JAR-OPS 3.480(a)(1) and (a)(2)”.

a. Simplification and clarity. b. Incorrect cross-reference.

(a) Accepted. Delete subhead (a) and make this one single text. (b) Accepted Amend as indicated.

104 Eurocopter (a) An operator shal l ensure that:

(1) Hel icopters operated in Performance Class 2 are cert i f icated in Category A (see also ACJ to JAR-OPS 3.480(a)(31)) . Reference should be corrected to read ACJ to JAR-OPS 3.480(a)(1)and (a)(2) .

Accepted. Amend as indicated.

JAR-OPS 3.517. THERE WERE NO COMMENTS TO THIS JAR REQUIREMENT JAR-OPS 3.520 013 Veritair Para (a)(3)(ii) (B): Why is “drop-down” required

in the Regulation? There are several small rig support vessels with helidecks lower than 30 ft above the water.

As long as the helicopter misses the deck

Declined. Drop down is not required by the rule. See the response below which





edge, then it should be able, if necessary, to carry out a safe forced landing in the water. The sea state at the time of take-off would have to be inside the promulgated Helicopter Flight Manual ditching limits. We could find no Regulation in JAR-OPS 3 that prevents the use of a hostile sea area as a safe forced landing area.

further explains the relationship between hostility and a safe forced landing. The text in the Shell comment in 015 below, discusses all of the important elements.

Judgement is required when applying the definition of safe forced landing to over-water flights (the boundary between hostile and non-hostile) as injury to persons in the aircraft extends beyond the touchdown it also includes capsize and, the subsequent evacuation and access to safety equipment (such as life vests and liferafts) under difficult conditions.

When attempting to allocate the boundary between hostile and non-hostile for overwater flights, it is best to revert to the two main elements for Risk Assessment: the probability of the event; and the consequence.

The probability of the event will depend upon the Performance Class in which the helicopter is being operated.

The consequence of the event will depend on the Sea State of the sea over which the operation is being performance and the certification of the flotation equipment.

Overwater helicopter operations are permitted in the knowledge that emergency situations may arise which may require an immediate and forced landing. Accordingly, (at amendment 9) ICAO Annex 6 Part 3 paragraphs 2.2.11 and 4.5.1, and national operating rules specified those circumstances where approved flotation and safety equipment must be carried; ICAO further states that Sea State shall be an integral part of ditching information.

Requirements for ditching approval are contained in FAR/CS 27/29.801. Paragraph (d) requires that flotation and stability must be demonstrated in reasonably probable sea conditions. Paragraph (b) requires that measures must be taken to minimise the probability that in an emergency landing on water, the behaviour of the rotorcraft would cause immediate injury to the occupants or would make it impossible for them to escape. Experience suggests that the greatest risk to the occupants in a ditching is drowning due to inability to evacuate the aircraft following capsize and subsequent flooding of the hull.

FAR/JAR require the designer to select the reasonably probable wave condition for the area in which the helicopter is expected to operate and to demonstrate that the probability of capsize has been minimised.

FAA and JAA have adopted an interpretation (AC29-2A para 337(a)(3)) which states that Sea State 4 is considered to satisfy the reasonably probable requirement. Most helicopters that apply for ditching approval are therefore certificated to Sea State 4.





Sea State 4 represents a wave height of 1.25 m - 2.5 m (4 ft - 8 ft) and wind speed of 17 kts - 21 kts.

The weather conditions up to Sea State 4 provide a pragmatic limit for operations within the non-hostile classification - particularly as it aligns with the standard for Certification for Ditching satisfying reasonably probable conditions. It is therefore suggested that, for operations over open sea areas, the boundary for ‘hostile’ should be set to above Sea State 4.

A recent study (CAA Paper 2005-06) of wave climates along a representative selection of main helicopter routes in the northern North Sea and West of Shetland indicates that Sea State 4 will be exceeded on 26%-36% of occasions over the whole year. During the winter period between December-February, this increases to between 51%-65%.

Clearly when considering routine offshore operations in the specified area, they can be (and are) regarded as permanently hostile and any regulation should make sufficient provision to ensure that ditching on take-off or landing is minimised. It was because of this that the proposal for JAR-OPS 3.520(a)(3)(ii)(B) and JAR-OPS 3.535(a)(3)(ii)(B) both contain reference to drop down.

016 Shell aircraft (3)(ii): (B) from 1st January 2010 any helicopter operated to/from a helideck located in non-congested hostile environment as defined in JAR-OPS 3.480(13)(ii)(a). For existing operations to certain helidecks, following a risk assessment, an operator may be authorised to conduct operations where the safe continuation of flight is not assured in the event of a critical power unit failure during the take-off and landing phases.

The explanatory note (H.3.2.2) confirms that this clause as stated would remove the limit of PC2 with exposure at 2010. For a variety of reasons, including limited the helideck size of some platforms in the North Sea, it may not be possible to introduce aircraft capable of achieving operations in PC1 or PC2e in this timescale. Precluding the use of helicopter transfers could result in the use of alternative options (such as boat transfers), which entail a greater degree of risk to personnel.

It is suggested, therefore, that where new aircraft are not available, existing operations to certain helidecks may be permitted by the National Authority beyond 1 January 2010, subject to a Safety Case assessment.

Noted (see also further comment below). The text below was provided by Shell Aircraft - subsequent to the comment period. As the clarification text illustrates so many of the points germane to PC2e, it was decided to publish it. With this revised comment the original point has been answered and the commenter is now satisfied.





016 (Shell) Clarification

The following passage can be seen as a clarification of our concerns which were (too) briefly expressed in the comment above. In view of our reassessment of the rule, we would like to add the following comment and withdraw our proposed amendment of the text.

The problems we were considering were the following:

1. Those occasions when tide is not taken into account and the sea is running irregularly - the level of the obstacle (i.e. - the sea) is indefinable making a true calculation of drop down impossible (practicality dictates that drop-down is based upon the height of the deck AMSL).

2. Those occasions when it would not be possible - for operational reasons - for the approach and departure paths to be free of obstacles - the ‘standard’ calculation of drop-down would not account for the obstacle.

3. Those occasions when departing from a vessel with a low deck in low wind conditions - drop-down would become a serious limit on payload.

4. Those occasions when operating to moving decks on vessels when the recommended landing or take-off profile would not be possible - the calculations would not be accurate.

Because of these cases (and there might be others) we would not wish to have a prescriptive requirement based upon a 15ft deck-edge miss and 35ft obstacle clearance. Although such figures might be recommended and be part of advisory material, it is our view that the rule itself cannot be so prescriptive and should remain objective.

On re-reading the text and after some discussions, we now understand more clearly that by containing the text of JAR-OPS 3.520(a)(3)(ii)(B) within the scope of the statement of applicability contained in JAR-OPS 3.520(a)(3) (which itself points to the text on Exposure), and retaining the objective requirement, the issues described above can be addressed by the operator to the satisfaction of their customers.

033 NCAA The need to refer to 3.517(a) for PC 2(e) in

3.520(a)(3) should be reconsidered The option of applying “pure” PC 2(e), without exposure, is a possibility in some environments/conditions, and may be preferred by some operators.

In PC2(e), whether you do or do not have a safe forced landing capability is irrelevant.

Noted. The clarification in comment 016 above, illustrates quite clearly why the referenced text is contained within the exposure clause. The presence and contents of the Norwegian Parliamentary





Recommendations is known and understood and it is clear that there could be a more stringent interpretation on the Norwegian Continental Shelf. As a matter of accuracy, ACJ to Subpart H explains the difference between Pure PC2 (deck-edge clearance with a ditching) and Enhanced PC2 (with performance for deck-edge clearance and drop down). It is clear that even with new aircraft types that are now operating offshore, operators in the tropics are more likely to utilise Pure PC2 than Enhanced PC2. The commenter accepts the response.

059 UK CAA (a):

Sub-paragraphs (2) &(3). Break out and separate the various different operations into simple to understand text with differing paragraphs and numbering. Eg PC2, PC2 with exposure, PC2e.

As proposed, the text is unhelpful in identifying the specific details for the various options covered. By expanding the sub-paragraphs, it will be easier for the user to understand the requirements.

Noted. The existing text has been accepted by the commenter.

060 UK CAA (a)(3)(ii):

Include minimum clearances for deck edge and surface.

To ensure a common standard and to allow procedures to be developed the minimum clearance should be specified in this paragraph. It is suggested that minimum acceptable standards for

Declined. See the clarification text of the Shell comment 016 for a clear discussion on why this would be extremely difficult without





clearance of any part of the aircraft might be 15 feet for the deck edge and 35 feet for the water surface.

specifying OEI HOGE performance - which is not regarded as justified. However the point is valid and the text of the ACJ to Subpart H will be amended to provide this guidance. The commenter accepts the addition to the ACJ.

061 UK CAA (a)(3)(ii)(B):

Amend implementation date to 5 years after ratification of NPA.

If ratification is delayed, the time remaining for compliance may be unreasonable for operators.

Noted. The CAA agrees that no significant effect is expected if the process is completed in 2006.

107 Eurocopter JAR-OPS 3.520 Take-off (See ACJ to Subpart H) (See IEM OPS 3.520) (See IEM-OPS 3.520 & 3.535) IEM OPS 3.520 deals with DPATO. As DPATO is no longer part of JAR-OPS 3.520, this reference should be deleted.

Accepted The reference and IEM will be deleted.






JAR-OPS 3.530. THERE WERE NO COMMENTS TO THIS JAR REQUIREMENT JAR-OPS 3.535 034 NCAA (a)(3): The need to refer to 3.517(a) for PC 2(e)

in 3.535(a)(3) should be reconsidered. The option of applying “pure” PC 2(e), without exposure, is a possibility in some environments/conditions, and may be preferred by some operators. In PC2(e), whether you do or do not have a safe forced landing capability is irrelevant.

Declined. See the response to 033 which has been accepted by the commenter.

040 Starspeed (a)(2)(i): and should read or There is no need for a balked landing AND a forced landing

Accepted. The word ‘and’ will be replaced by ‘or’.

063 UK CAA Sub-paragraphs (2) &(3). Break out and separate the various different operations into simple to understand text with differing paragraphs and numbering. Eg PC2, PC2 with exposure, PC2e

As proposed, the text is unhelpful in identifying the specific details for the various options covered. By expanding the sub-paragraphs, it will be easier for the user to understand the requirements.

Noted. The existing text has been accepted by the commenter.

093 Eurocopter (a) (2) For operations other than specified in JAR-OPS 3.517 (a), the approach is conducted such that, until the last point where safe continuation of the flight is possible, the helicopter can either perform a balked landing or a safe forced landing, and, beyond this point, a safe forced landing can be carried out.

In an approach there is a characteristic point until which it is possible to perform a balked landing and beyond which a safe force landing has to be carried out. Commentator estimates the NPA too prescriptive. Even if the failure occurs before this point the pilots should remain free to decide to land.

Noted. See the response in 040 above which is accepted by the commenter.





Appendix 1 to JAR-OPS 3.517(a) 007 BHAB (a) Approval

(2)

(ii) Implementation of a Usage Monitoring System on all helicopter types first certificated after 31 March 2006.

Since 1998, the UK Civil Aviation Authority has permitted operations without the necessary exposure approval (Official Record Series 4, General Exemption – Helicopters in Performance Class 2). It is accepted that operations with exposure are the future for helicopter operations and many modern aircraft can comply with the requirements. However, there are older types for which the cost of compliance would be unacceptable. Many of these aircraft are leased from private owners who would not contemplate the cost of fitting UMS in order to become compliant. Yet these aircraft have been operated to and from elevated heliports such as Battersea in complete safety for many years under the existing exemption and their removal from the market place would have an adverse effect upon the business of Battersea Heliport and the operators that use it.

By mandating a Usage Monitoring System for new helicopter types from an appropriate point in the future, commensurate with the incorporation of NPA 38 into JAR-OPS 3, the continued safe operation of older types should be

Declined. UMS has been a requirement for operations with exposure since Change 1 on 1st February 1999. NPA OPS-38 makes no new requirement for UMS merely replacing the text from Section 1 into Section 2.





permitted under a National exemption until such time as they are replaced, subject to the approval of the National Aviation Authority concerned.

015 London Helicopter Centres Ltd

I am in agreement with other members of the UK Industry that the proposed amendments, if implemented, will adversely affect continued operations specifically with regard to London Battersea Heliport for the majority of Single Engine and Light Twin Engine Helicopters operated in this country. This would have potentially catastrophic circumstances for London–based operators, such as ourselves, who derive a large part of their business from operations into and out of the City due to their geographical location.

It is widely agreed that the proposals should be re-worded to account for this and that consideration should be given to making a specific case for operations of this type.

1. At certain times Battersea must be considered as an Elevated Heliport.

2. The fitting of UMS to comply with the proposals is not a financially viable option for on-shore operators who, in the majority of cases, lease aircraft from private individuals.

3. The calculated permissible exposure times of 9 & 18 Seconds (Introduction, Page 3,Item 3.2.3.2) are in excess of requirements for safe operations from Battersea. It is generally accepted that 5 seconds would be an adequate, workable time of exposure to allow for a safe flight regime to be established.

4. The historical safety record of Battersea operations points to the effective maintenance and long term reliability of the UK helicopter fleet suggesting that special consideration (ie. Grandfather rights) could be given to these types to facilitate continued operations until such time as they are superseded by the introduction of new types, these being fitted with the

Declined. See the response to 007 above.





proposed UMS ex-factory.

025 Swedish CAA We disagree to the proposal moving section 1 material to section 2. We propose that those parts of the ACJ-2 to Appendix 1 to JAR-OPS 3.517 (a) that are the most important paragraphs concerning preventing maintenance actions, UMS criteria and handling, development of risk mitigating procedures and training are left in Section 1. Those requirements that have been found difficult to fulfil should either be moved to section 2 or be removed from JAR-OPS 3.

In explanatory notes it is said that “experience has shown that the former requirement for procedures and equipment were too prescriptive”. It is also said that, by moving these prescriptive requirements from Section 1 to Section 2, “bureaucracy will be reduced” and “the flexibility of the regulation should improve”. It is our view that, even if the intention is good, there is an obvious risk that harmonisation in this field will be lost. By moving prescriptive requirements to Section 2 it is left to the national authority to assess what is acceptable or not, which is not so good for a desirable transparency.

Noted. The text that is now in the ACJ is considered to be best practice for which individual elements might or might not be possible for a given helicopter. This rationale applies equally to the UMS criteria as well as the maintenance and monitoring practices. This is accepted by the commenter.

064 UK CAA (a):

This Appendix seems superfluous and could be incorporated into the main paragraph 3.517(a). Subsequent ACJ material could relate to 3.517(a) also.

Reduction in cross-referencing and simplification.

Declined. The CAA accepts that the reason this is contained as an appendix is that it is referenced in other parts of JAR-OPS 3.

JAR-OPS 3.540 070 UK CAA (a)(1): Correcting reference. Accepted.





Reference should be amended from “ACJ OPS 3.480(a)(31)” to “ACJ OPS 3.480(a)(1) &(2)”

The text will be amended accordingly

092 Eurocopter JAR-OPS 3.540 General (c) An operator shall ensure that operations are not conducted:

(1) out of sight of the surface; (2) at night; or (3) when the cloud ceil ing is less than 600 ft . (4) when the visibi l ity is less than 800 m

This proposal is issued to make this paragraph consistent with the last revision of ICAO Annex 6

Accepted. This was an oversight when the proposal was being formulated. The text will be reinstated.





JAR-OPS 3.545. THERE WERE NO COMMENTS TO THIS JAR REQUIREMENT JAR-OPS 3.550. THERE WERE NO COMMENTS TO THIS JAR REQUIREMENT JAR-OPS 3.555. THERE WERE NO COMMENTS TO THIS JAR REQUIREMENT Appendix 1 to JAR-OPS 3.625. THERE WERE NO COMMENTS TO THIS JAR REQUIREMENT JAR-OPS 3.650, 3.652 and ACJ-OPS 3.650/3.652 006 Brunei Shell Item 7 in the table should say “Pitot Heat

Failure Annunciator” i.a.w Note 3 and the remarks in the NPA introduction.

Inconsistency Accepted. The text will be amended accordingly

100 Eurocopter (a) An magnetic compass; direction indicator; An should be changed by A






JAR-OPS 3.820 035 NCAA Delete applicability date in proposed new b) The proposed applicability date is already

passed. The paragraph probably only needs to state the requirement, without applicability date.

Accepted. See response on 089 below.

071 UK CAA (a)&(b):

Amalgamate the two paragraphs as the applicability date is now passed. Renumber following paragraphs accordingly.

Date for implementation has passed so paragraphs can be amalgamated to address the requirement.

Accepted. See response on 089 below.

089 DGAC France JAR-OPS 3.820 Automatic Emergency Locator Transmitter (See IEM OPS 3.820) (a) An operator shall not operate a helicopter unless it is equipped with an automatic Emergency Locator Transmitter (ELT) attached to the helicopter in such a manner that, in the event of a crash, the probability of the ELT transmitting a detectable signal is maximised and the possibility of the ELT transmitting at any other time is minimised. (b) From 1 January 2005, an operator shall not operate a helicopter unless it is equipped with an automatic ELT capable of transmitting on 121.5 MHz and 406 MHz simultaneously. (c b) An operator shall not operate a helicopter in Performance Class 1 or 2 on a flight over water in a hostile environment as defined in JAR-OPS 3.480(a)(12)(ii)(A) at a distance from

See reason below:

Partially Accepted. DGAC have accepted that the rule will be rewritten to meet the intent of the commenter. “Locator Transmitter (See IEM OPS 3.820) (a) An operator shall not operate a helicopter unless it is equipped with an automatic Emergency Locator Transmitter (ELT). (b) An operator shall not operate a helicopter in Performance Class 1 or 2 on a flight over water in a hostile environment as defined in JAR-OPS 3.480(a)(12)(ii)(A) at a distance from land corresponding to more than 10 minutes flying time at normal





land corresponding to more than 10 minutes flying time at normal cruising speed, on a flight in support of or in connection with the offshore exploitation of mineral resources (including gas), unless it is equipped with an Automatically Deployable Emergency Locator Transmitter (ELT(AD)) operating in accordance with (a) and (b). (d c) An operator shall ensure that all ELTs (1) are capable of transmitting on 121.5 MHz and 406 MHz simultaneously (2) are coded in accordance with ICAO Annex 10 and registered with the national agency responsible for initiating Search and Rescue or another nominated agency.

cruising speed, on a flight in support of or in connection with the offshore exploitation of mineral resources (including gas), unless it is equipped with an Automatically Deployable Emergency Locator Transmitter (ELT(AD)). (c) An operator shall ensure that all ELTs are capable of transmitting on 121.5 MHz and 406 MHz simultaneously and are coded in accordance with ICAO Annex 10 and registered with the national agency responsible for initiating Search and Rescue or another nominated agency.”

(a) As paragraph K2 of the Explanatory Note insists on the fact that “the intent of JAR-OPS 3.820 is retained but it is proposed that the (presently pointed to) Standard from ICAO Annex 10 is incorporated in the text to make the rule clear and transparent. The revision is a clarification and will have no regulatory or financial impact”, we do not understand why the end of paragraph a) has been deleted (some editorial mistake ?) and therefore propose to reintroduce it. (b) The date in paragraph b) is of no use as we are already after “1 January 2005”. The rest of the provision in b) is the first of the two technical specifications that automatic ELT (that have to be installed, according to (a)) have to comply with. Therefore that first technical specification should be moved to the same paragraph as the second one (the fact that they have to be coded according to annex 10), that is to say in the last paragraph ((d), renumbered paragraph (c), as (b) is hence deleted). (c) We don’t understand the purpose (nor the meaning) of adding “operating in accordance with (a) and (b)”. (d) (1) : See paragraph b) above. (2) : As all ELT are now required to be transmitting in 406 Mhz as well, the provision for coding according to Annex 10 applies to all ELT.





JAR-OPS 3.827 & 3.837 O1 EASA Comment to JAR-OPS 3.827

(a)

…unless each member of the crew is wearing an approved a survival suit.

…

Equipment is in general approved in accordance with JAR-OPS 3.630 (a)(1). It is therefore not required to repeat this in JAR OPS 3.827.

If this comment is not adopted, please justify the addition of this wording for Survival suits while it is not introduced for other survivability equipment such as life jackets and liferafts.

Also refer to EASA NPA 08-2005.


02 EASA Comment to JAR-OPS 3.837. Add the same text change to JAR-OPS 3.837

Consistency with JAR-OPS 3.827 Accepted. The text will be amended accordingly

110 Eurocopter JAR-OPS 3.827 Crew Survival Suits (See IEMACJ OPS 3.827) (a) An operator shal l not operate a hel icopter in Performance Class 1 or 2 on a f l ight over water at a distance from land corresponding to more than 10 minutes f ly ing t ime at normal cruis ing speed f rom land on a f l ight in support of or in connect ion wi th the of fshore exploi tat ion of mineral resources ( including gas)

Declined. Eurocopter agree that the word ‘Approved’ will be not be added to the text the reasons stated in comment 001 above.





when the weather report or forecasts avai lable to the commander indicate that the sea temperature wi l l be less than plus 10ºC dur ing the f l ight or when the est imated rescue t ime exceeds the calculated survival t ime unless each member of the crew is wear ing an approved survival sui t .

A term “approved” is proposed to be added into subparagraph JAR-OPS 3.827(a). For consistency, the commentator proposes also the same addition of “approved” prior to the “survival kit” in the subparagraph JAR-OPS 3.827(b)

JAR-OPS 3.830 072 UK CAA a. In the heading, amend “Life-rafts and

survival ELTs or extended overwater flights” to “Life-rafts and survival ELTs on extended overwater flights”. b. Delete applicability dates

a. Editorial amendment. b. Dates now passed and requirement implemented.

(a) Accepted. The text will be amended accordingly (b) Accepted. This is a reference to Appendix 1 to JAR-OPS 3.830. Delete the dates and coalesce the text into one paragraph (see response to 036 below).

108 Eurocopter (a)(1) to (a)(3) unchanged Accepted.





(3) At least one survival Emergency Locator Transmitter (ELT(S)) for each liferaft carried (but not more than a total of 2 ELTs are required), capable of transmitting on the distress frequencies prescribed in ICAO Annex 10Appendix 1 to JAR-OPS 3.830. (See also AMC OPS 3.830(a)(3)); Should be read (a)(2)

The text will be amended accordingly

Appendix 1 to JAR-OPS 3.830 036 NCAA Delete applicability date in both a) and b). The proposed applicability date is already

passed. The Appendix probably only needs to state the requirement, without applicability date.

Accepted. Revised text will be revised to read: “All ELT(S) shall be capable of transmitting simultaneously on 121.5 and 406 MHz and be coded in accordance with ICAO Annex 10 and registered with the national agency responsible for initiating Search and Rescue, or another nominated agency.”






ACJ to Appendix 1 to JAR-OPS 3.005(d) para (a)(4) HEMS mission 017 Swedish CAA We agree to the proposed amendment of this

ACJ but will, in connection with this, propose another amendment of the same ACJ.

The underlying principle is; the aviation risk should be proportional to the task.

It is for the medical professional to decide between HEMS or air ambulance preferably in consultation with the commander- not the pilot! For that reason, Medical staff who undertake to task medical sorties should be fully aware of the additional risks that are (potentially) present under HEMS operations (and the pre-requisite for the operator to hold a HEMS approval). (For example in some countries, hospitals have principle and alternative sites. The patient may be landed at the safer alternative site (usually in the grounds of the hospital) thus eliminating risk - against the small inconvenience of a short ambulance transfer from the site to the hospital.)

Once the decision between HEMS or air ambulance has been taken by the medical professional after consultation with the commander, the commander makes an operational judgement over the conduct of the

It is our experience that medical professionals not always have sufficient knowledge of the difference between the operational minima and other issues concerning HEMS and air ambulance respectively. Consequently they sometimes decide HEMS when it could have been done as an air ambulance or as an air ambulance when it should have been done as an HEMS. This results sometimes in a needless risk taking and in situations were the flight crew is uncertain of which rules they should apply at the moment.

Declined. This text has been extracted from existing ACJ to Appendix 1 to JAR-OPS 3.005(d) - which is not part of this NPA. If the commenter wishes to propose a change of that text, a new NPA should be initiated. The commenter accepts the response.





flight.

ACJ-OPS 3.426 THERE WERE NO COMMENTS TO THIS ACJ IEM-OPS 3.480 THERE WERE NO COMMENTS TO THIS IEM ACJ-OPS 3.480(a)(31) 047 UK CAA In figures 1-4, change “+ROC” to “positive climb

gradient”. Changing the undefined acronym aligns the ACJ with text in JAR-OPS 3.480(31).


051 UK CAA (3):

FATO is undefined and should be changed or defined.

The acronym FATO is undefined in JAR-OPS 3 but is defined in ICAO Annex 6 Pt III. The term could be used if it was appropriate to the text and was defined in 3.480. This term also appears in 3.490(a)(2)(i), ACJ OPS 3.490 and 3.510 and should be addressed in the same way.

Declined. The commenter accepts that the FATO is defined in JAR-OPS 3.435(a)(4).

103 Eurocopter IEMACJ OPS 3.480(a)(1) and (a)(2) Category A and Category B See JAR-OPS 3.480(a)(1) and (a)(2) See JAR-OPS 3.485 See JAR-OPS 3.515(a)(1) See JAR-OPS 3.540(a)(1) This reference is still valid and should not be deleted and a cross reference to ACJ OPS

Accepted. This is a reference to item F.4.1 and not to ACJ OPS 3.480(a)(31). The text will be amended accordingly





3.480(a)(1) and (a)(2) should be added at the end of the corresponding subparagraphs

IEM-OPS 3.500(a) (5). THERE WERE NO COMMENTS TO THIS IEM ACJ-OPS 3.490 & 3.510 030 NCAA The ACJ should be renamed ACJ to 3.490,

3.495 and 3.510 The ACJ contains references also to 3.495

Declined. Although there is reference to JAR-OPS 3.495, it is a passing reference to ensure that the “take off flight path” is considered. The commenter accepts the response.

031 NCAA Heliport minimum requirement for helidecks, and probably elevated heliports, should be a minimum of 1D.

Minimum FATO size should be harmonised with ICAO Annex 14, and should be co-ordinated through that process.

The “Methods of compliance” in the ACJ should be rephrased so as to limit operations to smaller than 1D FATOs to surface level heliports.

Noted. This is not a design issue and therefore unconnected with Annex 14; it is concerned only with operational requirements; it is already known that operations to sub-1D helidecks are conducted both onshore and offshore in PC 2 & 3. The intent of this proposal is to





introduce a method of compliance for PC1 when the heliport size does not meet the Category A limitation (usually 2D). The size will be removed from the ACJ so that the critical issue is the visual cues. The commenter accepts the revised text.

049 UK CAA Disagree with proposal for two reasons: a. Permitting use of an operator defined procedure for a PC 1 operation. b. The proposed procedure is not technically correct.

See reason below: Noted. The ACJ has been revised to address the points raised by the CAA. The new ACJ requires an approval to be given by the Authority before an operator can apply the procedure. The commenter accepts the amended ACJ.

a. A PC 1 operation should have assured protection against the effect of engine failure, this has been achieved in the past through airworthiness certificated procedures, these may have been developed by the manufacturer or in certain cases, such as variable TDP helipad, as a Supplementary Type Certificate (STC) by an operator/DOA which have then been certified by the Airworthiness Authority and an approved Flight Manual Supplement issued. The proposed alternative procedure would not have these safeguards as the operator could not define the flight path as required. These operations could well be acceptable as PC2 operations. The operator will be able to define the flight path because he is simply reducing the weight below the WAT limit (WAT limit is in the Limitations Section of the RFM). Therefore all the parameters required to establish the flight Path (TODRH; climb gradient, landing distance, balked landing distance) are available in the RFM either as a function of the weight or as a fixed value (and in this case the flight path computation will be very conservative). b. The Flight Manual HOGE OEI charts are static performance only, i.e. they represent the maximum hover weight and nothing more. In a dynamic situation, the rotor rpm will droop as the engine fails and the helicopter will loose some height. If the helicopter tries to fly away from the hover (even after the rotor rpm has recovered) the takeoff distance could be longer than the HFM helipad take-off distance, as the helipad distance would have been based on a fairly steep nose down acceleration. If the applicant’s technique is based on a gentle level acceleration away from the hover the helicopter will be in the high power required portion for some time and the excess power to accelerate will be small. The applicant could define a procedure with a nose down





acceleration to get out of the high power required region but would need to determine this drop down and distance. Similar considerations would also apply for the balked landing case. 050 UK CAA (2.1 & 2.3):

a. FATO is undefined in JAR-OPS. b. Minimum diameter of a FATO of not less than 0.85D is not substantiated but dimensions should align with ICAO Annex 14.

a. FATO is not defined in JAR-OPS and appears elsewhere in this NPA. Needs to be defined or alternate terms used.

b. There is no supporting evidence for 0.85D. This appears unnecessarily small for a PC1 operation unless supported by HFM information. In any case, this should be an aerodrome/heliport requirement and not an operations rule. It is suggested that not less than 1D would be more appropriate. It is also noted that the explanatory text at G.6.3 refers to 1D.

Noted. Reference to the size will not be included; there will only be reliance upon sufficient visual cues.

095 Eurocopter ACJ OPS 3.490 and 3.510 Alternative take-off and landing procedure ….Compliance with JAR-OPS 3.495 would have to be verified from a point at 35 ft above the TDP height, at the distance from the TDP determined in accordance with the above calculations. Methods of compliance: Compliance with the requirements of JAR-OPS 3.490, 3.495 and 3.510 may be assured with:

1. The guidance mentioning that compliance with JAR-OPS 3.495 would have to be verified from a point at “35 ft above the TDP height” shall actually be applicable, only if the take distance required is determined based on the “clear area” take-off, but not for other procedure like for example “short field” or “helipad”. For those cases, compliance with JAR-OPS 3.495 would have to be verified from a point at “not less than 35 ft above a level defined by the highest obstacle in the take-off distance required”. The commentator

Noted. See the response to 049 above. The commenter accepts the revised ACJ.





1 the use of an appropriate Category A take-off and landing procedure scheduled in the Helicopter Flight Manual; or 1. Should be read: “from a point at 35ft above a level defined by the highest obstacle in the takeoff distance required”. And the following sentence should be added: “For IFR operations, a vertical margin of not less than 35ft + 0,01 DR shall be considered” 2. This paragraph should be removed and the others renumbered accordingly

proposes therefore to include these different conditions. Finally, a remark concerning the vertical margin for IFR operations shall be added, thus avoiding the use of vertical margin of not less than 35 ft, which is just for VFR operations only. 2. The method of compliance for alternatives take-off and landing procedures, as written in the new ACJ OPS 3.490 and 3.510, lists in the first point a method which is applicable for the normal procedures. As this ACJ deals with the alternative take-off and landing procedures, this first point should then be removed and the following paragraphs renumbered accordingly.

106 Eurocopter IEM OPS 3.490(b)(4) & 3.495(b)(5)

(removed to Subpart F and renamed ACJ OPS 3.475(c)(3)( i i )) Reference should be made to JAR-OPS 3.475 in the renamed ACJ OPS 3.475 (c)(3)(ii)

Accepted. This is a consequential amendment to the changes in the NPA. The text will be amended accordingly

ACJ-1 to Appendix 1 to JAR-OPS 3.517(a) 026 Swedish CAA We agree to the captioned ACJ but propose a

change a change of the text as follows: There is a clear drawing up of the areas of responsibilities between the operator

Partially Accepted. The commenter accepts that the





1. As part of the risk assessment prior to granting an approval under Appendix 1 to JAR-OPS 3 .517 (a), the authority the applicant should consider appropriate reliability statistics or other appropriate documentation available verifying the power plant reliability of the helicopter type and the engine type.

and the Authority and consequently an approval procedure should reflect that. It is our view that it is the operators responsibility to conduct their own risk assessment and present it to the Authority. If the Authority wishes to scrutinize the basis of the operators risk assessment they can always do.

revised text meets the intent of the comment.

032 NCAA Consider replacing “Authority” by “Operator” or add “Operator” in paras 1&4.

The “Operator” is responsible to establish and maintain the Risk Assessment, and will consequently need to have access to relevant data from the manufacturer. The Authority will be involved, but only in reviewing the Risk Assessment as a basis for approval of the operations.

Accepted. The commenter accepts that the revised text meets the intent of the comment.

038 CJAA (2): 2 Except in the case of new engines, such data should show sudden power-loss from the set of in-flight shutdown (IFSD) events not exceeding 12 per 100,000 engine hours in a 5 year moving window. However, a rate in excess of this value, but not exceeding 3 per 100,000 engine hours, may be accepted by the Authority after assessment showing an improving trend.

An engine failure rate of less than 1 per 100,000 engine hours has not been achieved to date and the best data available on the most reliable of aircraft indicates that the 5 year mean failure rate is more likely to lie between 1 and 2 engine failures per 100,000 hours. Having demonstrated that this rate of engine failure can support exposure periods of 5 seconds for twins and 10 seconds for singles there is no justification for accepting a rate of failure of 3 per 100,000 hours.

Declined. See the response to comment 037. The HSST unanimously endorses this response. This text is in line with recent agreements at the HTSG for SEIMC for fixed wing and for IMC for PC 3 for helicopters. The text is intended to set the Standard for powerplant reliability at 1x10-5 but to permit excursions outside that figure to allow for statistical skewing - due to the scarcity of data. If such allowances are not provided, a situation could be





envisaged where a type (or several types using the same engine) is removed from operations with exposure because of a short term problem even though it is being resolved by the continuing airworthiness process - thus grounding whole populations of helicopters. See also the risk assessments contained in response to comments 037 and 074 above.

041 Starspeed This data is presently not available to small operators from Manufacturers making the use of exposure impossible. Furthermore the remainder of the section is impossible for small operators, requiring very occasional use of exposure time, to comply with. The greatest problem is the use of 6 metre elevated helipads on the River in London

Noted. Manufacturers have committed to making the engine/type reliability data available (see comment 090 from Bell, Sikorsky, EC and Agusta) and additional data in response to comment 037.

065 UK CAA The comment applies too to ACJ OPS 2 to Appendix 1 of 3.517(a):

It is not clear why there needs to be two ACJs. Recommend amalgamation.

Simplification. Noted. The CAA accepts that two ACJs are provided because they have totally different functions. ACJ 1 is provided to give guidance on compliance with the requirement for a Risk Assessment based upon the reliability of the engine/type combination.





ACJ 2 is provided to indicate which additional procedures and equipment should be fitted to ensure that the reliability target is attained and then maintained. The commenter has accepted the existing text.

077 UK CAA Paragraphs 1 and 4. Amend the text to place the onus on the “Operator” not the “Authority”. Text contained in the current Appendix 1 to 3.517(a) at paragraph (b)(1)(i) states that “The operator shall provide data acceptable to the Authority”. Similar text should appear in the proposed ACJ.

The proposed text places the onus of re-evaluation on the “Authority” and not the “Operator”. This text is disagreed with and should be amended to reverse the responsibility and reflect current procedures in Appendix 1 to 3.517(a).

Accepted. The text will be amended to replace “the Authority should consider” to “the operator should provide” in both paragraphs.

088 DGAC France • Modify the text to make it clear which Authority is concerned: the Authority (of the operator), “the authority responsible for the certification of the engine or helicopter” ?, “the Authority, together with the authority of the state of design” ? etc… • There should be some provision in the airworthiness texts to cover the “JAR-OPS 3.517” certification of the powerplant. Moreover, these aspects, on the verge between operations and airworthiness, should be treated in a common document, elaborated by people from operations and airworthiness, as is done for ETOPS with AMC 20. As EASA is now responsible for that sort of matter, the JAA should transfer that task to EASA as soon as possible to enable EASA to

The text as written is not precise enough. It is not clear who is responsible of what during the process of delivering, assessing, re-evaluating, etc…

Partially Accepted. As can be seen in comment 090 below, the manufacturers are in the process of defining a system of assessment of reliability that will meet the requirements of the DGAC. However, it is clear that any operational approval (as this is) will need to be ‘owned’ by the operational department of the Authority. The commenter accepts that the intent will be met.





incorporate it in its pluri-annual rulemaking program.

090 Agusta, Eurocopter, Bell & Sikorsky

See comment below: Provide a detailed guideline on how to deal with powerplant reliability assessment Clarification is needed on the following items: a. Share of roles between the engine and helicopter Type Certificate Holders, in order to calculate a powerplant power loss rate (caused by the engine and the engine installation). b. Definition of the sudden in-service power loss, c. Data basis documentation, d. Counting methodology: definition of the criteria for taking into account a sudden power loss event in the calculation of the power loss rate. e. Efficiency of corrective actions: possibility to take into account in the calculation of the efficiency of corrective actions made by the engine and/or helicopter manufacturers on the engine, engine installation or their maintenance. f. Method of calculation of the powerplant

Accepted. It has been decided to include this clarification into paragraph 5. of the ACJ as it introduces a framework for a standard methodology. The refined version of the text will be added to paragraph 5 of ACJ 1 to Appendix 1 to JAR-OPS 3.517(a). During the response process, the proposed text was amended to remove “in flight” in paragraph 5.3 and make other editorial changes.





power loss rate REGULATORY IMPACT ASSESSMENT The effect of this paragraph will be that all helicopter and engine manufacturers will use the same guideline for calculating the powerplant power loss rate, this leading to an accurate and realistic estimation of the powerplant reliability which is a major factor for an Authority to grant approvals for operations without an assured safe forced landing capability. There are not expected to be any additional economic, safety or other effects following this amendment.

Add at the end of present ACJ the following paragraph 5: 5. The purpose of this paragraph is to provide guidance on how the in-service power plant sudden power loss rate is determined. 5.1. Share of roles between the helicopter and engine Type Certificate Holders (TCH). a) As regards providing the documents establishing the in-service sudden power loss rate for the helicopter/engine installation, the interface with the operational Authority of the State of Design should be the engine TCH or the helicopter TCH depending on the way they share the corresponding analysis work. b) In any case, the engine TCH shall provide the helicopter TCH with a document including the list of in-service power loss events, the applicability factor for each event when used, and the assumptions made on the efficiency of any corrective actions implemented when used.





c) The engine or helicopter TCH should provide the operational Authority of the State of Design or, where this Authority does not take responsibility, the operational Authority of the State of the Operator, with a document that details the calculation results taking into account both the events caused by the engine and by the engine installation, the applicability factor for each event when used, the assumptions made on the efficiency of any corrective actions implemented on the engine and on the helicopter when used, and the calculation of the powerplant power loss rate, . 5.2 Documentation The following documentation should be updated every year. 5.2.1 The above document with detailed methodology and calculation is distributed to the Authority of the State of Design 5.2.2 A summary document with results of computation is made available on request to any operational Authority 5.2.3 A Service Letter establishing the eligibility for such operation and defining the corresponding required configuration is provided to the operators 5.3. Definition of the “sudden in-service power loss”. The sudden in-service power loss is an engine power loss: - larger than 30 % of the take-off power, - occurring in flight during operation, - without the occurrence of an early intelligible warning to inform and give sufficient time for the pilot to take any appropriate action .





5.4. Data basis documentation. Each power loss event should be documented, by the engine and helicopter TCH’s, as follows: - Incident report number - Engine type - Engine serial number - Helicopter serial number - Date - Event type (demanded IFSD, un-demanded IFSD) - Presumed cause - Applicability factor when used - Reference and assumed efficiency of the corrective actions that will have to be applied (if any) 5.5. Counting methodology. Various methodologies for counting engine power loss rate have been accepted by Authorities. The following is an example of one of these acceptable methodologies 5.5.1 Events: - from unknown causes (wreckage not found or totally destroyed, undocumented or unproven statements), or - for which the engine or the elements of the engine installation have not been investigated (for example when the engine has not been returned by the customer),





or - caused by an unsuitable or non representative use (operation or maintenance) of the helicopter or the engine, are not counted as engine in-service sudden power loss and the applicability factor is 0%. 5.5.2 Events caused by : - the engine or the engine installation, or - the engine or helicopter maintenance, when the applied maintenance was compliant with the Maintenance Manuals, are counted as engine in-service sudden power loss and the applicability factor is 100%. 5.5.3 For the events where the engine or an element of the engine installation has been submitted to investigation which did not allow to define a presumed cause, the applicability factor is 50 %. 5.6. Efficiency of corrective actions. The corrective actions made by the engine and helicopter manufacturers on the definition or maintenance of the engine or its installation could be defined as mandatory for specific JAR-OPS 3 operations. In this case the associated reliability improvement could be considered as mitigating factor for the event. A factor defining the efficiency of the corrective action could be applied to the applicability factor of the





concerned event. 5.7. Method of calculation of the powerplant power loss rate. The detailed method of calculation of the powerplant power loss rate should be documented by the engine or helicopter TCH and accepted by the relevant Authority.





ACJ-2 to Appendix 1 to JAR-OPS 3.517(a) 078 UK CAA para 3.4:

Paragraph 3.4 should indicate the minimum frequency required for UMS analysis and for acting on any results. It is suggested that a suitable frequency would be “daily”.

To provide guidance on a suitable frequency of data analysis to ensure that any hidden events are detected at a the earliest opportunity and before they may have a detrimental effect on performance reliability.

Partially Accepted. It has been agreed to amend 3.4 and 3.5 as follows: 3.4 A means should be available for downloading and analysis of the recorded parameters. Frequency of downloading should be sufficient to ensure the data is not lost though over-writing. 3.5 The analysis of parameters gathered by the usage monitoring system, the frequency of such analysis and subsequent maintenance actions should be described in the maintenance documentation.” Accepted by the commenter.

Introduction of ACJ to Subpart H 014 Veritair Point 5 (BENEFITS): Bullet point 3 can be

deleted if the use of flyaway and its definition in TODR(H), as detailed in file “BI02”, is accepted.

This ACJ is a well written but complex exposition of Class 2 performance. Future regulators, not involved with writing it, may take elements of the explanatory material and try to introduce it

Partially Accepted. See response to comment 009 above. The text will be amended to: “Ability to operate when the





as Regulatory material by taking a “back bearing” on some of the statements in the ACJ. This bullet point could be used to argue that Class 1 profiles should keep the TODA inside the airfield boundary, thus justifying the deletion of 3.490 (a) (2) (iv).

take-off-distance available required is located outside the boundary of the heliport.” The amendments to Performance Class 1 will permit the TODRH to be outside the boundary of the heliport providing obstacle clearance is ensured. The third bullet should therefore not be deleted but the text amended as above - it then applies the alternative use of TODRH. The comment referring to “taking a back bearing on some of the statements” is not understood as most of the benefits described in the ACJ exist today.

027 Swedish CAA The new ACJ is a good attempt to make the principles of Performance Class 2 more understandable and we agree to that. There are however a couple of things that still cause trouble or are not explained or defined enough: 1. A practical method for the pilot to determine the position of DPATO should be presented. 2. The interpretation of “appropriate power setting” in conjunction with 100 ft/min up to 200 ft (at Vtoss) should be clarified.

Pilots operating Performance Class 2 who have read the new text are still in need of a simple and practical method to determine the position of DPATO. Even if the abbreviations used are understandable they should be defined.

Partially Accepted. 1. Several methods of establishing DPATO have already been provided. 2. Appropriate power has been used because it could be 2.5 minute power or 2 minute power if 30 second power is provided. This will be found in the Flight Manual for any Category A procedure - as will Vtoss. 3. Accepted, these will be





3. Some abbreviations should be defined ( VT, V50 ) and the difference between Vstay up and Vtoss should be explained.

added to the definitions section of the ACJ. Accepted by the commenter.

028 NCAA CAA-N fully supports the proposed concept of Performance Class 2(e) with the option of allowing for an exposure period, both for elevated and surface level heliports.

There is however a worry that the indiscriminate use of exposure time might lead to a reduction from the present safety level. The responsibility to address this, and to ensure the appropriate safety level, rests off course with the individual operator and his authority, but there should possibly be added some guidance in JAR-OPS 3 to assist in developing and reviewing these Risk Assessments.

The main focus of the exposure concept is probability. Two other important aspects of risk in a safety level perspective are consequence and frequency. Up to now, use of exposure has been restricted to non-congested areas. If used in congested areas, the consequence could increase e.g. by exposing 3-parties. If more flights using exposure time are conducted, (larger part of the total flight hours performed in the exposure time regime) this could lead to an increased frequency of events. The opening up of exposure, might imply that exposure could be the modus operandi also from the land base for offshore operations. In both cases this would lead to a reduced safety level.

Guidance might indicate factors to be considered when considering use of exposure time, such as: restrictions for day/night operations, number of pax/movements, climatic/environmental considerations, third party risk.

Accepted. NPA 38 does not introduce exposure into congested areas where third parties will be exposed to risk. The commenter is correct that the introduction of ground level exposure has the potential to increase the accident rate. However the risk assessment contained in 074 above (which includes probability, consequence, and frequency) indicates that, for the State which has the most activity, the increase is only estimated to be one additional accident in 100 years. (This estimated increase does not, however, take into account the improvement in safety that should be obtained from the introduction of UMS, and other safety measures required for operations with exposure. These measures have the potential for lowering the engine failure rate, with a concomitant impact on other





phases of flight – i.e. in the cruise.) Additionally, from 2010, offshore operations in the North Sea and Atlantic Reaches will be conducted in enhanced PC2; although limited exposure is still permitted, it is substantially below the current level of risk associated with full exposure. The Norwegian CAA are content with this response and have agreed to provide additional guidance on Risk Assessments in JAR-OPS 3 which addresses the elements contained in the last paragraph of their comment.

066 UK CAA a. This is a long and detailed description of PC2. The content should be summarised and contain only material needed to support the specific sections.

b. With the proposed changes to ICAO Annex 6, the standards mentioned in the ACJ have been removed.

a. Due to the style of writing used, much of the text is difficult to understand and should be simplified. Some elements might be better placed outside JAR-OPS 3. Is it acceptable to have an ACJ for a whole section?

b. References to “standards in Annex 6” should be reviewed as most of them have been removed from Section II Chapter 3 in the proposed text provided by ICAO State Letter AN

(a) Declined The CAA have agreed that the text will evolve through normal amendment process following experience. (b) Accepted Paragraph 1. line 10 will be amended to replace “Standard” with “Annex 6 Part III.” Paragraph 4 will be amended to: “Subpart H – PC2 is primarily based upon the text of ICAO Annex 6 Part III Section II and





11/32.1-05/50 and placed as guidance in a Attachment A.

its attachment – which provides for the following.”

067 UK CAA 3.1:

Fig 5 should be redrawn to extend the T/O distance arrow to a 35 ft/Vtoss vertical line as it looks the same as the reject distance as shown.

Clarification for reader. Accepted. The two lines will be differentiated.

068 UK CAA 6.1:

a. Reference in “Note: Annex 8” is incorrect. Replace “(Part IV, Chapter 2.2.1.3.4)” with “(Part IV, Chapter 2.2.3.1.4)” b. Fig 8 is misleading in that the splay does not clearly depict VFR/IFR differences. c. The Figures variously use VFR/IFR and VMC/IMC which lacks standardisation.

a. Correcting reference. b. Clarity for reader. c. Standardising the use of VMC/IMC or VFR/IFR would aid clarity and indicate that the same parameters were being used in the diagrams and text.

(a) Accepted. The reference will be corrected. (b) Accepted The variable splay will be put into the diagram. (c) Accepted. The ACJ will be amended to standardise the text on VFR/IFR

069 UK CAA 7.4.2:

More information such as minimum deck edge clearance could be provided for PC2e explanation and background.

Improvement in level of information provided.

Accepted. The CAA have agreed that the rule text should remain objective and guidance on the deck-edge clearance and drop down will be provided in Paragraph 7.4.2

075 UK CAA 6.4:

The text describes whether distances need to be calculated or not and introduces the possibility of entry into cloud during the climb. If this was likely should the

It is considered that the text does not explain clearly when an operator has to carry out calculations. For planned entry into cloud during the take-off path it would be more appropriate to specify an IFR departure rather than allude to

Accepted. The CAA have agreed that the text will be amended to state: “If early entry (in the sense of cloud base) into an IMC





guidance promote an IFR departure process and obstacle accountability as it is unlikely that a precise cloud base would be known? Accompanying paragraphs and diagrams should standardise on VMC/IMC or VFR/IFR.

VFR then IFR as the accuracy of forecast or observed cloud base may not be sufficient to allow necessary calculation using the appropriate obstacle accountability formulae. There is some confusion introduced also in the accompanying paragraphs and diagrams by the varying use of VMC/IMC and VFR/IFR.

departure is required - calculations should be carried out…” to “If early entry into IMC (in the sense of cloud base) is expected an IFR departure should be planned”.

101 Eurocopter ACJ to Subpart H Operations in Performance Class 2 See Subpart H 6.2.1 The three elements from the pilot’s perspective When seen from the pilot’s perspective (see Figure 9), there are three elements of the PC 2 take-off - each with associated related actions which need to be considered in the case of an engine failure: d. action in the event of an engine failure - up to the point up where a forced-landing will be required. The second “up” is redundant and should be cancelled

Accepted. The text will be amended as indicated.

ACJ-OPS 3.540(b) THERE WERE NO COMMENTS TO THIS ACJ





IEM-OPS 3.605(e) THERE WERE NO COMMENTS TO THIS ACJ ACJ-OPS 3.650/3.652 102 Eurocopter See comment below: Accepted.

The text will be amended as indicated.

ACJ OPS 3.650/3.652

Flight and navigational instruments and associated equipment)

See JAR-OPS 3.650 and JAR-OPS 3.652

FLIGHTS UNDER VFR FLIGHTS UNDER IFR OR AT NIGHT


TWO PILOTS REQUIRED

SINGLE PILOT

TWO PILOTS REQUIRED

(a) (b) (c) (d) (e)




1 (VFR night)

2 (VFR night)

13 Standby Attitude Indicator 1 (Note 6) 1 (Note 6) 1 1

NOTE 6: For helicopters with a maximum certificated take-off mass (MCTOM) over 3 175 kg, JAR 29 1303(g) may require either a gyroscopic rate-of-turn indicator combined with a slip-skid indicator (turn and bank indicator) or a standby attitude indicator satisfying the requirements of JAR-OPS 3.652(h). (However, the original type certification standard should be referred to determine the exact requirement.)





NOTE 7: For IFR operation only

In the new ACJ OPS 3.650/3.652, the remark “VFR Night” for the instrument number 11 is not consistent with the other remarks in which the term “Note” is used; therefore “VFR Night” shall be replaced by “Note 8”. For the instrument number 13 the paragraph JAR-OPS 3.650 does not require any standby attitude indicator for Day VFR operations, this line 13 shall therefore be updated and the Note 6 shall be added for flights under IFR or at night.

A note 8 should be created.

FLIGHTS UNDER VFR FLIGHTS UNDER IFR

OR AT NIGHT


TWO PILOTS REQUIRED

SINGLE PILOT

TWO PILOTS

REQUIRED

(a) (b) (c) (d) (e)




1 (Note 8) 2 (Note 8)

13 Standby Attitude Indicator - - 1 (Note 6) 1 (Note 6)

NOTE 8: For VFR night operation only





Deletion of IEM-OPS 3.827 & insertion of ACJ-OPS 3.827 03 EASA a) Change paragraph titles and text to

read:

“calculated estimated survival time”

b) Provide a more clear guidance for the estimation of survival times. The guidance is required for the sea temperature range above 10ºC. ACJ OPS 3.827 provides information for a temperature of 5ºC and 13ºC.

c) Figure 2:

Delete the indications for “winter” or “summer”.

Replace symbol > by text “May well exceed”.

a) ACJ OPS 3.827 provides information on estimating survival times, not a calculation for survival times. This is mentioned as such in figure 1 and paragraph 2.2

b) The use of approved immersion suits is required when sea temperatures are below 10ºC.orwhen the estimated rescue time exceeds the estimated survival time. Therefore the survival time has to be estimated in case the sea temperature is above 10ºC. Benchmarking should be provided for that temperature range.

c) Seasons are not relevant in this table, only the water temperature is.

For consistency and readability the symbol should be replaced by text.

(a) Accepted. The text will be amended accordingly (b) Noted. This will take the re-formation of the HOSS and a great deal of time to resolve. It is suggested that a WG be formed to assess this suggestion and EASA be invited to Chair it. (c) Accepted. The text will be amended accordingly





AMC-OPS 3.830 096 Eurocopter a) In all paragraphs, replace the word “shall” by

“should” b) Delete § 1 c. (“When carrying more than one life-raft on board, at least 50 % shall be jettisonable by the crew while seated at their normal station, where necessary by remote control”)

For modification a): “should” is more appropriate than “shall” for guidance material. For modification b): § 1 c. represents a strong, constraining requirement on the helicopter definition which should be taken into account only in the helicopter early definition. Developing a “remote control deployable liferaft” once the helicopter basic definition is frozen represents a complex and costly installation for operators. Consequently our opinion is that this recommendation should be dealt at certification level only.

(a) Accepted. Although not part of the NPA this text should be amended to correct the use of the imperative. The text will be amended accordingly (b) Noted. This remains a recommendation by the Helicopter Safety and Survivability committee HOSS WP-99/8.5 and is a recommendation in Annex 6 Part III Section II Chapter 4.5.2.6. The amendment of the text (with the exception of (a) above, might be the subject of an NPA in the future.

AMC-OPS 3.945. THERE WERE NO COMMENTS TO THIS AMC

This attachment refers to CJAA comments at 037, 038.

178

ENGINE FAILURES UK SUPER PUMA

0

0.5

1

1.5

2

2.5

3

3.5

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005

FAIL

UR

E R

ATE

PER

100

,000

HR

S

ANNUAL FAILURE RATE5 YEAR MOVING WINDOW


179

SUPER PUMAS ON THE UNITED KINGDOM REGISTER ENGINE FAILURE STATISTICS

YEAR 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005* ENGINE FAILURES

2 1 0 3 1 0 3 3 1 2 1

ANNUAL FLIGHT HOURS

43287

48252

48190

51959

50872

52026

52219

52950

53450

57683

57000

ANNUAL ENGINE HOURS

86574

96504

96380

103918

101744

104052

104438

105900

106900

115366

114000

ANNUAL FAILURE RATE PER 105 HRS

2.3

1.0

0

2.9

1

0

2.9

2.8

0.9

1.7

0.9

1.4 1.0 1.4 1.9 1.3 1.7 1.8

1.8 x 10-5 HRS

1.7 x 10-5 HRS

1.3 x 10-5 HRS

1.9 x 10-5 HRS

1.4 x 10-5 HRS

1.0 x 10-5 HRS

5 YEAR MOVING WINDOW FAILURE RATE PER 105 HRS

1.4 x 10-5 HRS


180

In order to analyse the data further (as shown below) two assumptions have been made: (a) that the sample of annual engine failure rates for the Super Puma helicopter is representative of the population of engine failure rates of Super Pumas in general, and (b) that the distribution of annual engine failure rates conforms to a Normal distribution. From the table of annual engine failure rates, it can be calculated that for the whole sample, comprising 11 years of engine data: (i) The Arithmetic Mean engine failure rate of the sample = 1.49 x 10-5 (ii) The Standard Deviation (SD) of the sample = ±1.1 x 10-5 (iii) The Standard Error (SE) of the Sampling Mean = ±0.33 x 10-5 (SE = SD ÷ √11) From this it follows that:

• there will be in the order of an 87% probability that the population mean of all engine failure rates of this group will lie between 1 x 10-5 and 2 x 10-5;

• there will be in the order of a 93 % probability that the population mean of engine

failure rates will be greater than 1 x 10-5, and

• there will be in the order of only a 7% probability that the population mean of engine failure rates will be less than 1 x 10-5

1.49 x 10-5

2 x 10-5 1 x 10-5

87% 6% 7%

- 1.48 SE + 1.54 SE

ENGINE FAILURE RATES DISTRIBUTION OF SAMPLING MEAN


181

Other Types: The S 61N and S 76 fleets on the UK register are much smaller than the Super Puma fleet and have filed correspondingly fewer engine failure occurrences and flown fewer hours. However, the indications of engine failure rates are not very different from that contained in the analysis of Super Puma engine failure events: Engine Failure Rates S 61N 1995 - 2004 Between 5 & 6 engine failures in 289554 hours = 1.7 to 2.1 x 10-5 hrs; S76 1995 – 2004 Between 6 & 9 engine failures in 355024 hours = 1.7 to 2.5 x 10-5 hrs.


182

SUPER PUMAS ON THE UNITED KINGDOM REGISTER - ENGINE FAILURE REPORTS OF SIGNIFICANCE TO LANDING AND TAKE-OFF MANOEUVRES

1. Operator : Bristow Occurrence Date : 05 Jan 1995 A/C Reg : G-BMCX Location : OIL RIG A/C Series (Gen) : Location Info : Engine Type : TURBOMECA

MAKILA Inv Status : Closed

Constr. Number : 2164 Executor : FOPS2 Perm. To Publish : Full Publication Reporter Ref : Classification : Occurrences Event(s) : Other Occurrence P Pretitle Other Occurrence : Helideck swamped by 70ft wave. Double engine flameout. A/c shutdown for inspection. P Precis Incident associated with unpredictable natural phenomenon. Appropriate checks conducted by reporter prior to further (non Public Transport) flight. CAA CLOSURE: Hazard acceptable provided frequency of occurrence remains low. 2. A/C Type : SA332 Super Puma Occurrence Number : 199500948 Operator : Bristow Occurrence Date : 12 Mar 1995 A/C Reg : G-BMCW Location : CHINA A/C Series (Gen) : Location Info : Engine Type : TURBOMECA


Constr. Number : 2161 Executor : RO Aberdeen Perm. To Publish : Limited Publication

(Sensitive) Reporter Ref : 1232

Classification : Occurrences Event(s) : Other Occurrence P Pretitle Other Occurrence : Fuel pressure fell to zero. Drills completed. Nr1 engine ran down. Pan call. Engine failed to relight. A/c returned. P Precis Before both attempts to relight, fuel pressure on both fuel pumps had risen to 75bar & on trying to relight, pressure fell to zero with appropriate warning. Investigation found pipe from boost pump canister to the jet pump in the LH long tank was off the rear bulkhead fitting in tank. Pipe refitted, ground run/tests carried out satis. Opr's investigation/consultation with mfr ongoing & checklist procedures for fuel pressure warning indications under review. See Digest 95/D/05. Reporter has agreed with a/c mfr to replace current fuel line union (rubber hose secured by jubilee clip) with "crashworthy fuel connection coupling". CAA Closure: Hazard adequately controlled by reporter's action. 3.

NOT INCLUDED IN SAMPLE It is considered unlikely that a wave would swamp engines if the helicopter was at a greater height i.e. on approach or transitioning on take-off


183

A/C Type : SA332 Super Puma Occurrence Number : 199502728 Operator : Bristow Occurrence Date : 30 Jun 1995 A/C Reg : G-BLXS Location : NORTH SEA A/C Series (Gen) : Location Info : Engine Type : TURBOMECA

MAKILA Inv Status : Closed On Receipt

Constr. Number : 2157 Executor : SDD Perm. To Publish : Full Publication Reporter Ref : 1241 Classification : Occurrences Event(s) : Other Occurrence P Pretitle Other Occurrence : Nr2 engine ran down with "Fuel" & "Fuel Pressure" warning after landing. A/c shut down. P Precis Investigation found Nr2 main fuel feed pipe from booster pump separated from airframe connection in RH longitudinal tank. Pipe re-connected. Operator alert message distributed, fleet check found one other fuel pipe not fully located. Independent inspection of tank main fuel lines at installation to be incorporated into company procedures. See also 95/00948. 4. A/C Type : SA332 Super Puma Occurrence Number : 199603852 Operator : Bristow Occurrence Date : 13 Aug 1996 A/C Reg : G-TIGW Location : ABERDEEN (ADN) A/C Series (Gen) : Location Info : Engine Type : TURBOMECA


Constr. Number : 2059 Executor : SDD Perm. To Publish : Full Publication Reporter Ref : 1286 Classification : Occurrences Event(s) : Other Occurrence PPretitle Other Occurrence : NG split of 800 with 'DIFF NG' & 'Power 2' warnings on approach. After landing, during engine wash, nr2 flamed out with SSL at ground idle. Precis Nr2 ECU changed & ground run completed satis. Mfr informed. 5. A/C Type : SA332 Super Puma Occurrence Number : 199605089 Operator : Brintel Helicopters Ltd Occurrence Date : 09 Nov 1996 A/C Reg : G-BWHN Location : NORTH SEA A/C Series (Gen) : Location Info : Engine Type : TURBOMECA


Constr. Number : 2017 Executor : FOI (Helicopters) Perm. To Publish : Full Publication Reporter Ref : A332/36/96 Classification : Occurrences Event(s) : Other Occurrence P Pretitle Other Occurrence : Engine pop stall possibly due to salt water contamination. PPrecis While parked on oil rig it was noted that salt water was leaking from a fire hydrant. Although water was flowing below a/c there was no contamination of windscreen & therefore no apparent hazard to engines.

NOT INCLUDED IN SAMPLE It is considered that the degradation of engine performance was not sufficient to be counted as an engine failure.


184

However, shortly after take off, engine pop stall occurred. Selecting bleed valves off also induced pop stalling so a/c returned to base with bleed valves on & at reduced power. Problem of salt water contamination addressed by issue of Flying Staff Instruction GEN/12/96, which contains advice on avoidance & remedial action. CAA CLOSURE: Hazard adequately controlled by reporters actions. 6. A/C Type : SA332 Super Puma Occurrence Number : 199704727 Operator : HELIKOPTER S Occurrence Date : 08 Sep 1997 A/C Reg : LN-OPG Location : Norwegian Sea A/C Series (Gen) : Location Info : Engine Type : TURBOMECA


Constr. Number : 2344 Executor : Propulsion Dept Perm. To Publish : Limited Publication

(foreign) Reporter Ref :

Classification : All Other Accidents Event(s) : Foreign Accident P Pretitle Uncontrolled impact with sea following uncontained turbine failure & loss of main rotor control. 12 fatalities. P Precis Norwegian CAA investigation. Vibration/out of balance associated with a pre-existing RH main gearbox/engine output shaft coupling problem damaged the overspeed and NTL phonic wheels. This disabled the overspeed protection system and caused the NTL induction system to underread. In sensing the NTL underspeed, the control system increased NG to its maximum. The coupling then failed, causing an uncontrolled overspeed of the power turbine which burst at approx 170%. The uncontained debris from the RH engine penetrated the LH engine casing, causing an uncontained failure of the LH engine. At the time of the accident the crew were troubleshooting an ‘OVSE’ caption which illuminates when there is a problem with the overspeed or NTL indication system. Following the accident an AD was raised to introduce a Flight Manual emergency procedure which required that an ‘OVSE’ caption during flight be addressed by reducing the respective engine to idle then shutting it down. ADs were also issued requiring checks to be carried out in respect of engine to MGB couplings; in particular, measurement of input shaft and free power turbine vibration levels and verification of ‘O’ ring seal installation. Turbomeca have since redesigned the overspeed protection system to incorporate a new control law which will reduce the engine to a sub-idle condition (65% NG) when two or more channels (overspeed and NTL speed indication) are considered to be unserviceable. The Flight Manual has also been revised to address changes to operating procedures. CAA Closure: Hazard now controlled by actions stated. Update Jul 2000: DGAC France has issued ADs (2000-067 & 068) mandating Turbomeca .SB/Mod TO203 & TU205A. UK CAA LTO 2071 also refers. 7. A/C Type : SA332 Super Puma Occurrence Number : 199800286 Operator : Brintel Helicopters Ltd Occurrence Date : 20 Jan 1998 A/C Reg : G-BKZE Location : A/C Series (Gen) : Location Info : Engine Type : TURBOMECA


Constr. Number : 2102 Executor : RO Aberdeen Perm. To Publish : Full Publication Reporter Ref : 332/03/98 Classification : Occurrences Event(s) : Other Occurrence P Pretitle Other Occurrence : "DIFF NG" warning. Nr1 engine at approx 26000rpm - nr2 approx 32000rpm. On landing helideck crew indicated fuel leak. Nr1 engine flamed out on shutdown.

NOT INCLUDED IN SAMPLE This event concerned a foreign aircraft from a different sample for which the usage is not available


185

P Precis Overspeed drain valve, PN 007491800, leaking - changed. CAA Closure: Hazard acceptable provided frequency of occurrence remains low. 8. A/C Type : SA332 Super Puma Occurrence Number : 199804129 Operator : Bond Helicopters Occurrence Date : 20 Jul 1998 A/C Reg : G-PUMB Location : ABERDEEN (ADN) A/C Series (Gen) : Location Info : Engine Type : TURBOMECA


Constr. Number : 2075 Executor : RO Aberdeen Perm. To Publish : Full Publication Reporter Ref : C980705 Classification : Serious Incidents Event(s) : Serious Incident P Pretitle Serious Incident : Nr2 engine ran down. Pan call. A/c landed safely. P Precis AAIB Field investigation. During maintenance of the driveshaft, the end coupling was not bolted to the shaft flange. The inspection procedures were not applied in a way that would have detected this omission. On flight test the fit of the coupling in the shaft could sustain some torque but eventually the coupling spun in the shaft & drive was lost. See AAIB Bulletin 11/99, ref: EW/C98/07/05. Operators maintenance programmes revised to clearly identify the critical points requiring duplicate inspections. CAA Closure : Hazard now controlled by actions stated. 9. A/C Type : SA332 Super Puma Occurrence Number : 199805491 Operator : Bond Helicopters Occurrence Date : 18 Sep 1998 A/C Reg : G-PUMD Location : A/C Series (Gen) : Location Info : Engine Type : TURBOMECA


Constr. Number : 2077 Executor : RO Aberdeen Perm. To Publish : Full Publication Reporter Ref : 934 Classification : Occurrences Event(s) : Other Occurrence PPretitle Other Occurrence : 'DIFF NG' & 'POWER 1' warnings plus LF lateral vibration. Nr1 engine rpm low - FFCL retarded & vibration ceased. Engine shutdown. A/c landed safely. P Precis Fault traced to ECU - unit changed & function checks completed satis. CAA Closure: Hazard acceptable provided frequency of occurrence remains low. 10. A/C Type : SA332 Super Puma Occurrence Number : 199905806 Operator : Bond Helicopters Occurrence Date : 31 Aug 1999 A/C Reg : G-PUMN Location : North Sea


186

A/C Series (Gen) : Location Info : Engine Type : TURBOMECA


Constr. Number : 2484 Executor : RO Aberdeen Perm. To Publish : Full Publication Reporter Ref : 1019 Classification : Occurrences Event(s) : Other Occurrence P Pretitle Nr1 engine run down. Pan call. A/c returned. Precis In cruise at FL70, a/c began to fishtail with PWR1 & DIFF NG illuminating on CWP. Nr1 torque reduced to 20% & NG to 84.6%. Checklist actioned. Pan declared & a/c returned. Failure attributed to loss of governor control associated with failure of nr1 DECU. Investigation of DECU by OEM resulted in no fault found. CAA Closure: The hazard is acceptable provided the frequency remains low. 11. A/C Type : SA332 Super Puma Occurrence Number : 200103522 Operator : Bristow Occurrence Date : 25 May 2001 A/C Reg : G-BWMG Location : North Sea A/C Series (Gen) : L Location Info : Engine Type : TURBOMECA


Constr. Number : 2046 Executor : SDD Perm. To Publish : Full Publication Reporter Ref : 74/01/332 Classification : Occurrences Event(s) : Engine/Malfunction Power Loss - First Engine

Emergency Call Contingency

P Pretitle Nr2 engine run down. Pan call. Run on landing carried out with AFS in attendance. Precis During cruise the nr2 engine twice ran down to flight idle but recovered to normal cruise parameters while the checklist was being actioned. On the third occasion the nr2 engine ran down to zero torque. An emergency was declared and a safe run on landing carried out with AFS in attendance. Fault traced to Fuel Control Unit (FCU) PN 0164168200 which was changed, subsequent ground run and flight test completed satis. 12. A/C Type : SA332 Super Puma Occurrence Number : 200103534 Operator : Bristow Occurrence Date : 25 May 2001 A/C Reg : G-TIGB Location : North Sea A/C Series (Gen) : L Location Info : Engine Type : TURBOMECA


Constr. Number : 2023 Executor : SDD Perm. To Publish : Full Publication Reporter Ref : 72/01/332 Classification : Occurrences Event(s) : Engine/Malfunction Power Loss - First Engine Pretitle Nr1 engine rundown.


187

Precis Nr1 engine ran down to 26,000 NG accompanied by a drop in T4. Nr2 engine matched the power demand, alarm sounded and 'DIFF NG' illuminated. After approx 30 seconds nr1 engine returned to normal power settings but within 5 minutes the sequence repeated. While the emergency procedure sheets were being read the nr1 engine returned to normal and stayed that way for the rest of the flight. However, during taxi in the nr1 engine ran down again briefly, this time accompanied by a 'POWER 1' caption. A normal shutdown was carried out. NTL harness and PPNg connector resistance checks carried out satis; ECUs swapped, ground run and 10 minute airtest carried out satis Aircraft returned to service. On taxiing to dispersal nr1 engine ran down. Fuel control unit changed. Ground runs and airtest carried out satis. Aircraft returned to service. See also 2001/03522. 13. A/C Type : SA332 Super Puma Occurrence Number : 200105052 Operator : CHC Scotia Occurrence Date : 23 Jul 2001 A/C Reg : G-BSOI Location : Prestwick A/C Series (Gen) : L Location Info : Engine Type : TURBOMECA


Constr. Number : 2063 Executor : SDD Perm. To Publish : Full Publication Reporter Ref : 1225 Classification : Occurrences Event(s) : Engine/Malfunction Power Loss - First Engine

Diversion /Return Pretitle Nr2 engine rundown. P Precis Nr2 engine ran down and froze at between 23,000-24,000 NG during climb. 'DIFF NG' illuminated, nr2 NF split and nr2 torque fell to zero. Emergency procedures actioned, aircraft returned and landed safely. 14. A/C Type : SA332 Super Puma Occurrence Number : 200200223 Operator : CHC Scotia Occurrence Date : 17 Jan 2002 A/C Reg : G-PUMK Location : Aberdeen (ADN) A/C Series (Gen) : L Location Info : Engine Type : TURBOMECA


Constr. Number : 2067 Executor : RO Aberdeen Perm. To Publish : Full Publication Reporter Ref : 08/02/332 Classification : Occurrences Event(s) : Engine Fire / Overheat / Smoke

Engine Malfunction Engine Shutdown Emergency Call Diversion /Return

Pretitle Nr2 engine fire in flight. PAN declared. Aircraft returned. P Precis During climb out for air test (following nr2 engine malfunction/shut down on previous day) various warnings appeared, including 'Diff Ng', 'Power' and nr2 engine fire warning. Mirror checked and revealed a fierce fire around nr2 engine bay. Speed and power reduced, emergency checklist drills completed (with nr2 engine being secured) and nr2 engine fire extinguisher operated. Fire appeared to extinguish, although PAN declared and single engine landing carried out. Fire services checked engine bay and confirmed that fire was extinguished. Maintenance Error Investigation carried out. Fuel leak which caused fire probably caused by maintenance error. Engine fuel feed to start solenoid probably not fully tightened post maintenance. The


188

operator has now introduced duplicate inspections of all fuel lines in engine bay when these are disturbed by maintenance. Additionally, human factors awareness training days have been introduced. CAA Closure: The hazard is controlled by the actions stated above. 15. A/C Type : SA332 Super Puma Occurrence Number : 200207164 Operator : CHC Scotia Occurrence Date : 06 Oct 2002 A/C Reg : G-PUML Location : Aberdeen (ADN) A/C Series (Gen) : L Location Info : Engine Type : TURBOMECA


Constr. Number : 2073 Executor : RO Aberdeen Perm. To Publish : Full Publication Reporter Ref : 145/02/332 Classification : Occurrences Event(s) : A/c Maintenance

Engine/Malfunction Power Loss - First Engine Loss of A/c Control

PrPretitle Nr2 engine failure during air test. Autorotation followed by single engine landing. P Precis With the nr1 engine retarded to test for maximum Ng on nr2 engine during downwind leg of circuit on a test flight, there was an audible "bang" with a violent "fishtailing" of the aircraft. The aircraft entered autorotation, the nr1 engine was reinstated to flight idle and recovery made for a single engine landing. Following the debrief / investigations for audible "bang" during the Max Ng on nr2 engine, nr2 engine was found to have oil around the rear labyrinth seal. During the nr2 engine removal, the right hand freewheel of the MGB was found seized. The MGB was replaced. CVFDR removed and record retained for playback. Nr2 engine was also replaced. IHUMS confirmed the free wheel failure occurred in flight during the max Ng check of nr2 engine, and not during start up. No broken shafts were found during the MGB change. From the strip report of the MGB, the freewheel oil jet was found to be completely blocked by "dirt". It was not possible to determine how long this condition had existed, but the wear pattern on the roller seat would have developed over a long period since the free wheel unit is normally engaged, thus no wear would normally take place. The conclusion of the strip report suggests that the root cause of the failure was the clogged jet, which it is suggested was contaminated from overhaul, some 2265 hrs previously. The overhauler has been notified, and the operator has subsequently conducted audits of the contracted transmission overhaul facilities. See also 200207657. CAA Closure: The hazard is adequately controlled by the actions stated above. 16. A/C Type : SA332 Super Puma Occurrence Number : 200209302 Operator : CHC Scotia Occurrence Date : 31 Dec 2002 A/C Reg : G-PUMK Location : En Route A/C Series (Gen) : L Location Info : Engine Type : TURBOMECA



Engine Shutdown Emergency Call Diversion /Return

P Pretitle Nr2 engine governor malfunction. PAN declared. Aircraft returned.


189

Precis In cruise at an altitude of 3000ft, "Pwr 2" illuminated momentarily. One minute later nr2 engine reduced to 23000 Ng with associated "Diff Ng" and "Pwr 2" warning lights. Ng increased on nr1 engine to compensate for the power loss. The checklist was actioned and nr2 engine was shut down manually. PAN declared and the aircraft returned to base with no further incident. See also 200205248 and 200202799. 17. A/C Type : SA332 Super Puma Occurrence Number : 200303000 Operator : CHC Scotia Occurrence Date : 17 May 2003 A/C Reg : G-PUMN Location : Longside A/C Series (Gen) : L Location Info : Engine Type : TURBOMECA


Constr. Number : 2484 Executor : RO Aberdeen Perm. To Publish : Full Publication Reporter Ref : 064/03/332 Classification : Occurrences Event(s) : Engine Fire / Overheat / Smoke

Engine/Malfunction Power Loss - First Engine Engine Shutdown Emergency Call

Pretitle Nr2 engine fire warning. Checklist actioned - engine shutdown and MAYDAY declared. Aircraft continued to Aberdeen on one engine and landed safely. Precis On return to base nr2 engine compressor was found to be seized, with evidence of scorching on the compressor case. The engine was replaced with serviceable one. Engine strip down, with engine manufacturer involvement, revealed that the cause was due to movement of a threaded connection between the first and second stage compressor stators. The manufacturer has released modification TU237 in the interim, and further improvements in this area are under evaluation to secure the stator. CAA Closure: No further CAA action practicable. 18. A/C Type : SA332 Super Puma Occurrence Number : 200304568 Operator : CHC Scotia Occurrence Date : 15 Jul 2003 A/C Reg : G-PUMS Location : North Sea A/C Series (Gen) : L Location Info : Engine Type : TURBOMECA


Constr. Number : 2504 Executor : RO Aberdeen Perm. To Publish : Full Publication Reporter Ref : 094/03/332 Classification : Occurrences Event(s) : Engine/Malfunction Power Loss - First Engine

Engine/Malfunction Power Loss - Additional Engine Engine Shutdown Diversion /Return Emergency Call

Pretitle Nr1 engine chip warning/temp increase followed by fire warning during shut down. Nr2 engine T4 also began to increase. Aircraft diverted to Sumburgh. Oil starvation due to carbonisation. Precis A vibration was felt followed 2 seconds later by a nr1 engine chip warning. Checklist procedures were actioned during which nr1 engine T4 started to rise. The engine was shutdown at which point the nr1 engine fire warning activated. The fire warning ceased on completion of the shutdown procedure. A MAYDAY was declared and a diversion to Sumburgh initiated. It was then noticed that nr2 T4 was rising and

NOT INCLUDED IN SAMPLE Although the engine seized and a fire warning resulted, the engine appears to have been shut down deliberately.


190

fluctuating. The collective was lowered to gauge the effect on T4; there was a small effect in that T4 would reduce and stabilise and then start to rise again. The collective was reduced further and the aircraft descended to 500ft amsl and ATC were advised by the pilot of a possible ditching. Airspeed hold was engaged at Vy, the T4 stabilised and the aircraft flew level and maintained 500ft amsl, landing safely at Sumburgh. Nr1 engine compressor found seized. CVFDR removed to assist investigation. Engine replaced and full follow up ground runs and air tests carried out. Both engines satisfied test criteria. Investigation revealed failure of bearings 4 and 5, this was caused by oil starvation, which was a result of the oil jets becoming carbonised. There were issues to do with oil additives and their percentage content in the oil, and the periodicity of oil change (currently 3 yearly) is to be reviewed. All operator L2 engines have had their oil checked since this incident, and no anomalies have been found. Additionally a check valve was found to be faulty. Joint report issued by the engine overhaul and the engine manufacturer contained seven recommendations, although it is likely that the root cause will never be established. Amongst the recommendations are:- 1) Replacement of spring in the check valve, in this engine it wasn't operating correctly; 2) Respect "Stabilization" phase during engine shutdown; 3)Checks for degradation of engine oil; 4) Replacement of Jet tube at over-haul. CAA Closure: The hazard is adequately controlled by the action stated above. 19. A/C Type : SA332 Super Puma Occurrence Number : 200308313 Operator : CHC Scotia Occurrence Date : 01 Dec 2003 A/C Reg : G-PUMK Location : Aberdeen (ADN) A/C Series (Gen) : L Location Info : 65nm ESE Engine Type : TURBOMECA


Constr. Number : 2067 Executor : RO Aberdeen Perm. To Publish : Full Publication Reporter Ref : 154/03/332 Classification : Occurrences Event(s) : Engine/Malfunction Power Loss - First Engine

Engine Shutdown Emergency Call Diversion /Return Emergency Descent

Pretitle Nr1 engine failure. PAN declared. Aircraft returned. Fuel Control Unit (FCU) failed. Precis At 3000ft during the cruise (approx 65nm out), the nr1 engine ran down to ground idle with corresponding 'POWER 1'and 'DIFF NG' warnings illuminated but no 'GOV' lights. No fire was evident, therefore fault diagnosed iaw FRCs as a run down to idle, the appropriate engine governor failure drill was actioned and the engine shut down. A PAN was declared and immediate return requested. The aircraft would not maintain 3000ft at INTERCON power setting, therefore descent requested to 2000ft. At 2000ft the aircraft maintained altitude with 80kts IAS and the engine below INTERCON limits. The aircraft returned to base without further incident and a "One Engine Inoperative" (OEI) landing was carried out. Total aircraft hours 22732. On return fault finding process found nr1 Engine FCU Piston Position as a function of High Pressure Generator (PPNG) coil with high resistance between pins 2 and 8. FCU replaced with serviceable item. Post installation ground runs/airtest carried out - reported 'satis'. On-going problem with the FCU. The modified units to TU228 have an improved terminal potting for the PPNG coil. There will be a trial fit for evaluation, under authority of OEM. Pre-mod TU228, the engine may run down to idle or run up with a PPNG failure and in the case of a run down (this event), the indications are similar to a forced run down due to the operation of TU 215 (i.e. governing failure). To avoid any confusion and potential run up to over speed by advancing the affected engine into the positive manual range, the Flight Manual requires the engine to be shut down in the event of a run down to idle. Post mod TU228, a PPNG failure would drive the engine to 28200 Ng (i.e. cruise power setting) and the engine would therefore not have to be shut down. CAA Closure: The hazard is adequately controlled by the action stated above. 20. A/C Type : SA332 Super Puma Occurrence Number : 200403448


191

Operator : Bristow Occurrence Date : 26 May 2004 A/C Reg : G-TIGF Location : North Sea A/C Series (Gen) : L Location Info : Engine Type : TURBOMECA


Constr. Number : 2030 Executor : SDD Perm. To Publish : Full Publication Reporter Ref : 73/04/332 Classification : Occurrences Event(s) : A/c Equipment / System Malfunction

Emergency Call Pretitle Nr2 engine rundown in flight. PAN declared. Precis In cruise nr2 engine ran down and Ng froze at 28200 rpm. EOP carried out and PAN declared. Continued to Scatsta and landed without further incident. The aircraft was subsequently returned to base with the nr2 engine ECU in the fall back mode i.e. engine frozen at 28200Ng. Nr2 engine NTL harness, PPNG and anticipator checks were carried out. During the PPNG check it was noticed that the voltage was erratic by 0.03V indicating that the Fuel Control Unit (FCU) was faulty. The FCU was replaced and flight test carried out satisfactory. 21. A/C Type : SA332 Super Puma Occurrence Number : 200405652 Operator : Bristow Occurrence Date : 13 Aug 2004 A/C Reg : G-TIGJ Location : Ninian North rig A/C Series (Gen) : L Location Info : 5nm N Engine Type : TURBOMECA



Emergency Call Diversion /Return

Pretitle Nr2 engine run down. PAN declared. Diversion. Nr2 Fuel Control Unit (FCU) fault suspected. Precis During cruise at 500ft enroute to the Murchison platform, nr2 engine ran down and the "DIFF NG", "POWER 2" and alarm warning lights activated but with no "GOV" or "OVERSPEED" warning lights illuminated. The emergency checklist was consulted for an engine run down and the appropriate actions taken. A PAN was declared and following a crew discussion it was decided to divert to the alternate airfield (Scatsta), where an uneventful landing was carried out. During subsequent engineering investigation PPNG resistance was checked from nr2 Engine Control Unit (ECU) to FCU and pins 17 - 19 were found to show a resistance starting from 288 ohms rapidly increasing past 9M ohms. A confirmation check was made at FCU PPNG (fixed) connector to verify that the fault was not aircraft wiring or engine loom. NTL harness resistance checked and found satisfactory. Nr2 FCU (p/n 016418350) was replaced together with nr2 ECU (p/n 0177698260) as a precaution and the aircraft was assessed as serviceable following a successful test flight. Total airframe hours 23934.17, FCU TSN/TSO 1335.00, ECU TSN/TSO 2794.18/2074.30. 22. A/C Type : SA332 Super Puma Occurrence Number : 200502241 Operator : CHC Scotia Occurrence Date : 22 Mar 2005 A/C Reg : G-PUMS Location : Aberdeen (ADN) A/C Series (Gen) : L2 Location Info : Engine Type : TURBOMECA Inv Status : Open


192

MAKILA Constr. Number : 2504 Executor : RO Aberdeen Perm. To Publish : Full Publication Reporter Ref : Classification : Occurrences Event(s) : Engine/Malfunction Power Loss - First Engine

Emergency Call P Pretitle PAN declared due to single engine failure on approach. Uneventful landing with fire services in attendance. P Precis

This attachment from Eurocopter refers to Responses to comments 037, 038.

"Ce document est la propriété d'EUROCOPTER, il ne peut être communiqué à des tiers et/ou reproduit sans l'autorisation préalable écrite d'EUROCOPTER et son contenu ne peut être divulgué". © EUROCOPTER 01/2007 page : 193

a

Marignane, le 24 Janvier 2005

Direction Technique Support STXP n° 303/05 Ind c

OTIN M. Gaubert

AS 332 L/C, L1/C1, L2 - MAKILA 1A, 1A1, 1A2

JAR OPS 3 – Powerplant sudden in-service power loss calculation

With regards to Appendix 1 to JAR OPS 3.517(a), Eurocopter have to calculate the sudden in-service power loss rate, for some engine / helicopter families. EC use the data given by the engine manufacturer (Turbomeca) coming from a yearly commonly EC/Turbomeca checked data basis. The methodology is reminded hereafter. EC modify the rate given by the engine manufacturer using the methodology explained hereafter and taking into account the powerplant failures. Results: Period: 1999 to 2003 Engine Flight Hours: 1 855 841 hours Correctives actions:

• For the engine: Yes (TU 228, 229, 230) • For the helicopter: No

Number of corrected power losses due to the engine: 16 (1) Number of corrected power losses due to the helicopter: 2,5 (1) (1) Refer to Tables enclosed here after

So, the sudden power loss rate for the helicopter/engine is: (16 + 2,5)/1 855 841 = 0,99 E-5/ Engine hour with corrective actions



Daniel RICHARD Daniel FRANCOIS

Methodology for engine manufacturer For each engine family

Definition of “Sudden in-service power loss”: An engine power loss,

– larger than 30% of the take off power, – occurring in flight during operation, – without the occurrence of an early warning to inform and give

sufficient time for the pilot to take any appropriate safety measure.

Engine counting methodology:

– The events from uncertain source, for which the engine has not been investigated (for example, when the engine has not been returned by the customer) or the events assigned to:

– The unsuitable or non-representative use (operation or maintenance) of the engine;

– The Aircraft itself; are not counted as an engine sudden in-service power loss (Factor = 0).

– The events assigned to:

– The engine; – The engine maintenance, where the applied maintenance was

compliant with the Maintenance Manual; are counted as an engine sudden in-service power loss (Factor = 1).

– For the events where the engine has been submitted to

investigation which did not allow to define a presumed cause, the applicability counting is arbitrarily fixed at 50% (Factor = 0.5).

Efficiency of corrective actions:

– Corrective actions can be fixed as a rule for operating in specific JAR-OPS 3 conditions.

– In this case, associated reliability improvement can be considered. A factor defining an efficiency of the corrective action is defined



by the concerned specialists and applied to the occurrence rate of the concerned event.



Methodology for helicopter manufacturer For each helicopter family, equipped with one engine

family Helicopter counting methodology: – Take into account the events as defined by the engine manufacturer in

the “engine power loss” document, but limited to the concerned helicopter family

– Take into account all engine-caused events (for the concerned

helicopter family) as defined by the engine manufacturer in the “engine power loss” document (Factor = 1 or 0.5)

– For the events (for the concerned helicopter family) assigned by

the engine manufacturer to the aircraft (Factor = 0):

– Take into account all events caused by the helicopter installation (including the helicopter maintenance where the applied maintenance was compliant with the Maintenance Manual),

– Exclude the events from uncertain source, for which the

helicopter has not been investigated, or the events assigned to the unsuitable or non-representative use (operation or maintenance) of the helicopter,

– For the events assigned to the helicopter installation, where

the helicopter installation has been submitted to investigation which did not allow to define a presumed cause, the applicability factor is arbitrarily fixed at 50 % (Factor = 0.5)

Efficiency of corrective actions:

– Corrective actions, if defined by the helicopter manufacturer in a minimum required helicopter modification standard, can be taken into account in the powerplant power loss rate by applying an applicability factor lower than 1 (reliability improvement factor) to the concerned event.

Calculation of power loss occurrence rate:



The occurrence rate is calculated dividing the number of events (corrected with the here above factors) by the number of engine operating hours on the concerned helicopter family during a period of 5 years.

"Ce document est la propriété d'EUROCOPTER, il ne peut être communiqué à des tiers et/ou reproduit sans l'autorisation préalable écrite d'EUROCOPTER et son contenu ne peut être divulgué© EUROCOPTER 01/2007 page : 198

List of events “Abrupt Power Loss” with Engine cause

Repo

rt n

°

Engine

typ

e

Engine

n°

Aircr

aft

n°

Dat

e

Even

t

Phas

e

Pres

umed

cau

se

App

licab

ility

fac

tor

Corr

ective

act

ion

Estimat

ed e

fficienc

y

App

licab

ility

fac

tor

with

cor

rect

ive

action

s

R 99 131

Makila 1A2 3089 2484 02/9/99 Power

Loss Cruise ECU 1 0,0 1,0

R 00 022 Makila 1A 437 2077 21/02/00 Unc.

IFSD Cruise ECU 0,5 0,0 0,5

R 00 117 Makila 1A 202 2023 13/07/00 Power

Loss Cruise ECU 1 SL 1819/98 and 1820/98 information on renewed ECU 0,0 1,0

R 00 179 Makila 1A 428 2071 27/10/00 Power

Loss Before

Take off FCU 1 PPNG Sensor modification- TU 228 0,6 0,4

R 00 039

Makila 1A2 3101 2348 20/3/00 Power

Loss Approach FCU 1 0,0 1,0

R 00 155

Makila 1A2 3113 2500 10/10/00 Power

Loss Cruise FCU 1 PPNG Sensor modification- TU 228 0,6 0,4

R 01 225 Makila 1A 217 2101 14/02/01 Power

Loss Cruise CFT Electronic Card 0,5 0,0 0,5

R 01 070 Makila 1A 417 2023 25/05/01 Power

Loss Cruise FCU 0,5 0,0 0,5

R 01 105 Makila 1A 625 2046 25/05/01 Power


R 01 094 Makila 1A 251 / 25/06/01 Power


R 01 227 Makila 1A 190 2063 23/07/01 Power

Loss Cruise ECU 0,5 0,00 05



R 01 228 Makila 1A 454 2038 26/07/01 Power

Loss Cruise CFT Electronic Card 0,5 0,00 0,5

R 01 230 Makila 1A 177 2179 28/09/01 Power

Loss Hovering ECU 0,5 0,00 0,5

R 01 088

Makila 1A2 3058 2449 18/06/01 Power

Loss After

Take off ECU 0,5 0,00 0,5

R 02 017 Makila 1A 186 2067 16/01/02 Power


R 02 114

Makila 1A1 2497 2497 05/6/02 Power

Loss Approach ECU 0,5 0,00 0,5

R 02 163

Makila 1A1 2542 / 02/8/02 Unc.

IFSD Unknown FCU 1 PPNG Sensor modification- TU 228 0,6 0,4

R 03 105 Makila 1A 540 2099 15/05/03 Power


R 03 253 Makila 1A 362 2067 01/12/03 Power


R 03 119

Makila 1A1 2337 / 24/04/03 Power


R 03 140

Makila 1A1 2306 2271 01/07/03 Power

Loss Cruise ECU 0,5 0,0 0,5



R 03 104

Makila 1A2 3018 2484 17/05/03 Unc.

IFSD Cruise Axial compressor guide vane 1 Axial compressor guide vane rotating 0,0 1,0

R 03 201

Makila 1A2 3084 2504 18/06/03 Power


R 03 156

Makila 1A2 3009 2477 23/7/03 Power

Loss Approach FCU 1 PPNG Sensor modification- TU 229 0,6 0,4

R 03 202

Makila 1A2 3076 2504 19/8/03 Power


R 03 211

Makila 1A2 3157 2590 22/8/03 Power

Loss Cruise NTL Harness 1 / 0,0 1,0

R 03 246

Makila 1A2 3068 2348 20/11/03 Power

Loss Approach Bleed valve 1 / 0,0 1,0

R 03 254

Makila 1A2 3122 2503 02/12/03 Power

Loss Cruise FCU 0,5 / 0,0 0,5

22 TOTAL / 16


List of events “Abrupt Power Loss” without Engine cause

Repo

rt n

°

A/C

typ

e

A/C

n°

Dat

e

Even

t

Phas

e

Pres

umed

cau

se

App

licab

ility

fac

tor

Corr

ective

act

ion

Estimat

ed e

fficienc

y

Aplicab

ility

fac

tor

with

co

rrec

tive

act

ion

Commen

ts

/ AS 532 U2 2447 03/01/00 Unc. IFSD Cruise

FOD (ice)Rupture of the intermediate gear of the module

05 0 / / 0 Conditions/Operational: EAIP no good

operational using.

/ AS 532 U2 2457 29/03/00 Unc. IFSD Cruise Freezing conditions 0 / / 0 Conditions/Operational: EAIP no good

operational using.

/ AS 332 L 2139 04/05/01 Unc. IFSD Cruise MGB/Engine coupling 1 / / 1 Bendix coupling broken

/ AS 532 U2 2433 23/11/01 Unc. IFSD Take off Snow conditions 0 / / 0 Conditions/Operational: Maintenance IFSD

BY snow absorption, Air intake not cleaned.

/ AS 332 L 2067 21/09/02 Unc. IFSD Test

flight Oil sprinkle (free wheel) 0 / / 0 Conditions/Operational: Maintenance No respect of the MGB Overhaul procedure.



/ AS332 L1 2381 11/12/02 Power loss Cruise Electrostatic discharge 1 / / 1 Irreversibility of the uncommanded Power

reduction

/ AS 332 L 2067 31/12/02 Power loss Cruise Engine malfunction 0 / / 0

Engine power loss occurred in cruise one minute after «Pwr 2» momentarily

illumination. Transposed to the take-off and landing phases, the duration of one minute

prevents any risk to have a power loss occurring during the risk exposure phases.

/ AS 332 L1 2172 15/7/03 Unc. IFSD Hovering FOD 0 / / 0

Conditions/Operational: Maintenance Axial compressor blades loss following a mark

caused by a sprinkle rupture of the Engine flushing duct. The mark should be detected

/ AS 332 L2 2572 14/8/03 Unc. IFSD / MGB/Engine coupling (BENDIX

coupling) 0,5 / / 0,5

Conditions/Operational Aircraft with EURO ARMS system. Following the Red alarm for few days ago, the corrective maintenance

actions are not carried out.

2,5 TOTAL / 2,5

Unc. IFSD=In Flight Shut Down non commanded FOD= Foreign Object Dammage MGB/Engine= Main Gear Box/Engine EAIP = Engine Air Intake Protection ALF = After Last Flight check


Helicopter Type ENG

Engine Engine flight hours (on the concerned helicopter

type) (1999-2003)

Engine alone

Power loss rate (10-5/h)

Powerplant (Eng + H/C)

Power loss rate (10-5/h)

AS 332 L/C, L1/C1, L2 2 MAKILA 1A, 1A1, 1A2 1.855.841 0,86 0,99 AS 365N3, EC155 B/B1 2 ARRIEL 2 C/2C1/2C2 144.390 0 0 SA 365 C1, C2, C3, N, N1, N2 2 ARRIEL 1A1, 1A2, 1C, 1C1, 1C2 1.289.304 0,21 0,21 AS 355N 2 ARRIUS 1A 507.555 0,02 0,21 AS 355 F, F1 et F2 2 ALLISON 250-C20F 996.752 0,10 0,20 AS 350 B/BA/B1/B2 1 ARRIEL 1B/1D/1D1 3.617.490 0,29 0,29 AS 350 B3 / EC130B4 1 ARRIEL 2B/2B1 445.160 0 0 EC 120B 1 ARRIUS 2F 263.597 0,04 0,22 330 F /G/J 2 TURMO IV A / C 367934 0 0 SA 315B (Lama), SE3160 (Alouette III), SA 316B/C (Alouette III) SA 313 (Alouette II)

1 ARTOUSTE III B/B1/D ARTOUSTE II C5 / C6

1.157.818 (II + III) 0,24 0,24

SA 3180, 318B / C (Alouette II) SA 319B (Alouette III) Gazelle 341/342

1 ASTAZOU II A / A2 ASTAZOU XIV B ASTAZOU III/XIVH

1.014.672 0,08 0,08

EC145 / BK117 C-1, C-2 2 ARRIEL 1E2 113.486 0 0 BK117 A-3/A-4/B-1/B-2 2 LTS101-650B – 750B 1.072.126 0,19 0,19 EC135 T-1/T-2 2 ARRIUS 2B1/2B2 384.878 0,29 0,29 EC135 P-1/P-2 2 PW 206B/206B2 364.000 0,27 0,27 BO105 2 ALLISON 250-C20B 2.050.000 0,09 0,09

npa-ops 38 crd helicopter performance adopted at jaac 06-4 nov 06

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