Arkiv

Helicopter Offshore operations høringssvar

NHF har nå sendt inn sitt høringssvar til EASA som en respons på Helicopter Offshore Operations (HOFO) CRD 2013-10.

Høringssvaret er gjengitt under, med tidligere kommentarer fra NPA innfelt i bokser.

 

General comment:

Norsk Helikopteransattes Forbund (NHF) is an association representing the majority of engineers/mechanics, licensed engineers, and technical administrative personnel, employed by Norwegian helicopter operators and maintenance organizations. NHF was founded in 1984 and has since then, worked for maintaining a high level of safety standards throughout the helicopter offshore operations on the Norwegian sector of the North Sea. NHF is politically neutral, and as of today NHF organizes about 700 members, including all of the technical personnel, in the Norwegian helicopter offshore operations.

NHF has reviewed the CRD, and is very disappointed to see that the Agency is willing to achieve a level playing field and free movement of services/mutual acceptance of NAA, at the expense of the current level of safety on the Continental Shelf.

The way we operate in Norway, is quoted to be the “Gold standard” in the recent UK House of Commons Transport Committee 2nd report. It is therefore even more disappointing, to see that inputs from the Norwegian CAA, and Ministry of Transport and Communication, are mostly disregarded by the Agency.


The Helicopter Safety Study 3 (HSS-3) identifies potential threats for the Norwegian helicopter offshore operations, and this analysis is even included in NPA 2013-10. It is therefore very surprising that the Agency will commence with a rulemaking that will realize these threats.

Helicopter offshore operation is a highly specialized and complex operation mainly focused in dangerous and hostile environment, with rapid changes in weather conditions, and visibility,on the Continental Shelf, hence it requires a special regulation and oversight.

A level playing field can be achieved through retaining the Norwegian requirement to obtain an approval from the state where the operation is commencing. This requirement would be the same for all operators, hence a level playing field.

The reason for this is to have a Competent Authority with competent staff, which is qualified to issue approvals, have the oversight of the operation, also being close enough to communicate and cooperate with the operator and all other stakeholders involved.

In most of the Member States there is no knowledge and experience regarding this type of operations. This has been highlighted in HSS-3, and the latest UK helicopter safety report, from the House of Commons transport committee (HC 289).

Even the Agency suffered the same lack of knowledge and experience from helicopter offshore operations until they recently decided to recruit the current secretary of the working group from Norway. This fact alone should be more than what is required for the Agency, to understand the importance of establishing a competence requirement for the NAA, authorized to issue an HOFO SPA. The competence requirement was brought forward by NHF as a comment (97) to the NPA; however it appears that it has been ignored completely.

It is also very disturbing that there are no safety studies, no impact assessment, no SMS Change Management reports or other documentation, documenting the potential consequence of the rulemaking for the MS who already have a well-regulated operation.

The MS around the North Sea are also the ones who actually have this type of operation, and the impact for these will be very negative. Until such studies and documentation are in place, it is impossible to know how negative the impact of the rulemaking will be to safety.

The consequence by ignoring the past experience and research, can be fatal accidents, which could have been avoided if the Agency acted otherwise.

 

Question 2.12.1

Operator XYZ holds an offshore approval from MS A. Operator XYZ has one of its main activities in MS B.

Do stakeholders and NAAs see it as beneficial to introduce a regulatory requirement for operator XYZ to inform MS B before engaging into offshore operations from that MS?

Please justify your answer.

Answer to question 2.12.1 page 15

It is not satisfactory to only inform the MS B. The AOC and the SPA must be issued by the MS where the operation commences.

Justification:

This will enable a competent NAA to perform oversight, and as explained in the general comment section, communicate and cooperate with all stakeholders involved. Doing so, will enable the ongoing safety-improving work in the states around the North Sea to continue, not jeopardizing it just to achieve commercial goals. Other stakeholder commented this directly and indirectly in the CRD as well, and it is the common attitude by the Norwegian industry as a whole.  There is no justification/documentation for deregulating the industry to the extent as proposed in the NPA/CRD, and doing so without any well documented safety studies are irresponsible and unprofessional.

The first recommendation, A5, states:

‘With effect from 01 June 2014, the CAA will prohibit helicopter operators from conducting offshore flights, except in response to an offshore emergency, if the sea state at the offshore location that the helicopter is operating to/from exceeds sea state 6 in order to ensure a good prospect of recovery of survivors.’

Sea state 6 is defined as very rough sea with waves between 4 and 6 metres. To avoid uncertainty related to the actual size of the waves, UK CAA has introduced significant wave height of 6 metres instead of sea state 6 in the Safety Directive. The Agency, with RMT.0120 ‘Ditching occupant survivability’, is considering the same definition for the purpose of helicopter certification.

The allowance or prohibition of operations in an environment with a significant wave height of 6 metres or more is also linked to the search and rescue capabilities available in the area. Therefore, the Agency finds it difficult to propose a harmonised requirement while conditions may differ in the Member States and decisions might be better taken at a local level. It is to be noted that for CAT operations, there is already a requirement in CAT.OP.MPA.135(b) as follows:

‘The operator shall ensure that operations are conducted in accordance with any restriction on the routes or the areas of operation specified by the competent authority.’

As this requirement is only applicable to CAT and as SPA.HOFO will also apply to NCC and SPO, the Agency has decided to copy this subparagraph into SPA.HOFO.105.

Moreover, the Agency will include GM to ARO.OPS.200 containing information for the authorities which additional conditions for operations in certain areas might need to be specified via the AIP or by other means.

The Agency thinks that this sufficiently responds to the action A5.

Page 11 a5

Seastate survivability

The Agency seems to have forgotten planned staffing reductions offshore due to bad weather forecast. This is not classified as an offshore emergency. However it will have a great impact on offshore production to prohibit flights if weather forecasts show that there will be a Seastate 6 situation. 

Recommendation A7 states:

‘With effect from 01 June 2014, the CAA will require helicopter operators to amend their operational procedures to ensure that Emergency Floatation Systems are armed for all overwater departures and arrivals.’

The proposal highlights an important safety element. For CAT operations this is covered in CAT.OP.MPA.220, and the Agency has decided to duplicate the essential parts of the paragraph in SPA.HOFO.105 in order to be applicable also for NCC and SPO in offshore operations.

Page 12 A7

Arming of flotation gear

At several airports in Norway, the arrival and departure will be over water. The S-92A which is one of the major aircraft types used for offshore transportation, has a very low speed restrictions with floatation gear armed (Ref S-92A RFM). This will induce problems with traffic in and out of large airports, and probably reduce speed safety margins.

Recommendation A10 states:

‘With effect from 01 April 2016, the CAA will prohibit helicopter operators from conducting offshore helicopter operations, except in response to an offshore emergency, unless all occupants wear Emergency Breathing Systems that meet Category ‘A’ of the specification detailed in CAP 1034 in order to increase underwater survival time. This restriction will not apply when the helicopter is equipped with the side-floating helicopter scheme.’

The Agency supports the recommendation for emergency breathing system (EBS) as specified in A10. It is a tragic fact that due to a limited breath-hold time, especially in cold water, passengers have drowned following capsizing and submersion of the helicopter. Recommended emergency breathing system is considered an appropriate method to increase the time available for escape.

Consequently, a regulatory text requiring EBS category A for all on board during operations in hostile sea areas is included in SPA.HOFO.155.

A side-floating helicopter scheme is presently discussed in a separate rulemaking task, and the Agency will not introduce a regulatory link between such equipment and EBS.

Page 12 A10

Emergency Breathing System

As this is specialized equipment, so mandatory basic and frequent recurrence training must be required for the users.

2.13.

In order to measure the effectiveness of this regulatory activity, the Agency is proposing to set a number of performance indicators. The measurement of these indicators should help to identify certain trends and to facilitate a later review of the rules. As this is a rather new concept in the area of air operations and as the Agency will depend to a certain extent on MS, who are responsible for the implementation of the rules, stakeholders and NAAs are invited to comment specifically on these indicators.

 

1. Number of accidents or serious incidents in helicopter offshore operations: from the application of the new rule for 7 years compared to the reference period 2010-2015.

 

While the number of incidents is a retroactive measurement (the incident has happened and could not be prevented – either through a sufficient regulatory environment, oversight or correct application of rules and safety management), this indicator could give an indication if the regulatory framework is sufficient, or has loopholes, or lacks clarity. It should be taken into account that occurrences have several contributing factors and that it is not always easy to determine if the lack of rules was one of the main contributors. 7 years are proposed since FDM and VHM have longer transition periods.

 

2. Number of newly issued SPA approvals (no offshore activity before the applicability of this new rule).

 

This indicator measures if the new harmonised SPA approval leads to an increase in helicopter offshore activities, allowing new operators to enter the market. One of the objectives of this proposal is to provide harmonised rules for the EU, including NCC and SPO. Especially the aerial work sector is a relatively new offshore activity where EASA could not obtain much information. Having an overview of the approvals issued may provide a better insight into the activities and demands of this particular sector.

 

3. Shifts in the operator community – emerging of NCO operations.

 

This indicator is difficult to measure as NCO operations will not fall under any approval requirement. The Agency will depend on MS observing the activity in their territory and possibly information collected through ramp inspections. Several commentators voiced the concern that with this new proposal operational activity could shift from rather well regulated CAT operations to a non-commercial environment. This indicator should help to detect such trends and, together with indicator No 1, may provide some information if the regulatory framework is sufficient.

2.13 page 17

Accident and serious incident statistics as safety indicators are too reactive to monitor the consequences for deregulating and jeopardizing safety of the North Sea offshore operations. A more relevant and proactive indicator would be to monitor all mandatory reporting, and the frequency of such. It would also generate a greater amount of data, which right decisions and rulemaking could be based on. Today the reporting frequency differs significantly between the Member States. This is latest documented in CAP 1145 and House of Commons Transport Committee Offshore Helicopter Safety Second Report of session 2014-15, (HC 289). However with reference to the CRD question, it is hard to understand how statistics are going to be tracked at all, when the Member States don’t even know who is operating where or when in their hostile environment. In example if an operator from MS A has an accident in MS B. Should this increase the accident rate of MS A, MS B, or maybe both?

 

95

comment by: NHAF Technical committee

NHF supports development of strict and fair rules for Helicopter Offshore Operations. HOFO operations are very special, considering the high level of risk, involved in operations in such hostile environment. Therefore we recommend all operations covered by this regulation, to be regulated through an AOC approval, even for Non-commercial operations. Mandatory AOC provide higher requirements for procedures, organization, training, etc., who will affect safety in a positive manner.

The safety impact on operation, are also considered as rising with higher standards of rules and standards given by authorities directly.

In addition, maintenance done by same person on double/critical systems (engines, emergency equipment, flight controls, etc.) must be avoided. As for ETOPS operations, this is important to prevent possibility for critical failure in both systems. Justification: Reports from the operators around the North Sea, shows that maintenance induced errors, causes a major part of all incidents in their operations. Human factors should be considered as a valid element.

 

EASA response

Not accepted

 

Your support to the development of strict and fair rules for HOFO is appreciated.

As for AOC also to non-commercial operators: this is not possible as AOC is only for commercial air transport operators. See also the answer to your comment to Question 3.

The last part of the comment is supported. The subject of inspections on duplicate/critical systems is currently covered in Part-M (point M.A.402(a)) and in Part-145 (point AMC 145.A.65(b)(3)) and, therefore, outside the scope of the RMT as it is related to operational regulations.

The Agency reviewed these issues with the rulemaking task RMT.0222 (MDM.020), which resulted in the publication of NPA 2012-04, CRD 2012-04 and Opinion 06/2013.

Comment 95 page 61:

It seems like the Agency has not understood the comment. NCO/NCC operations must be illegal in hostile environment, and an AOC must be required for all operations. This is also justified in the comments from the Norwegian CAA, and the Norwegian Ministry of Transport and Communication in the CRD. The hostile environment is not less hostile to NCO and NCC operators; hence all requirements including AOC must apply. This is further justified by the additional solidity and oversight an AOC provides.

Regarding the Agency reference to M.A.402 it seems like the Agency does not understand the basics of ETOPS/maintenance on duplicate systems. M.A.402 is quoted below, and does not cover ETOPS requirements. Independent inspections are not the same as ETOPS requirements. The scope for independent inspections is different from ETOPS requirements.

"All maintenance shall be performed by qualified personnel, following the methods, techniques, standards and instructions specified in the M.A.401 maintenance data. Furthermore, an independent inspection shall be carried out after any flight safety sensitive maintenance task unless otherwise specified by Part-145 or agreed by the competent authority."

ETOPS is covered by Part-SPA, Subpart F / AMC 20-6 and some of it should also be mandated for HOFO operation by including relevant parts as requirement for HOFO approval.

 At least the following paragraphs should be included:

  1. AMC 20-6 - Appendix 6: TRAINING PROGRAMME
  2. AMC 20-6 - Appendix 8: CONTINUING AIRWORTHINESS CONSIDERATIONS

 

 

96

comment by: NHAF Technical committee

Question 1: NHF recommends that NCO operators follow the same sets of rules and restrictions as CAT operators. Justification: Offshore operators (drilling-, exploration- companies, etc.) may operate their own helicopter, as a NCO operation, but still be conducting an operation very similar to a CAT operator.

 

EASA response

Noted

An analysis of the comments to the questions and the conclusion drawn by the Agency is available in the explanatory note to the CRD.

Comment 96, page 70

See our answer to question 2.12.1 at page 15.

97

comment by: NHAF Technical committee

Question 2: SPA should be mandatory for operators offshore. Helicopter offshore operations are a very special type of operations, who require the operator to comply with a large set of special rules before starting operations. To be able to control, monitor and secure proper compliance, an SPA should be mandatory for these operators. The major countries operating in the North Sea, already have established SPA as a mandatory requirement.

The competent authority, who will issue the SPA, should be approved and properly qualified to control and monitor such SPA operations. Requirements for the competent authority capability to issue HOFO SPA, should be established and controlled by EASA prior to approving the competent authority.

 

EASA response

 

Noted

An analysis of the comments to the questions and the conclusion drawn by the Agency is available in the explanatory note to the CRD.

Comment 97, page 75:

We will again emphasize the importance of SPA for HOFO operations. As well, we would recommend a requirement for the Competent Authority, to be qualified for control and monitoring of HOFO operations. It is not all countries in Europe who even has a coastline!
Competence and capability for the NAA should therefore be assessed by EASA prior to be approved to issue such approvals to operators. Please also see CHC Helikopter Service, Norway CRD comment 113 and 238 for justification.

98

comment by: NHAF Technical committee

AOC should be mandatory for all HOFO operations. See general comments for justification.

 

EASA response

Noted

An analysis of the comments to the questions and the conclusion drawn by the Agency is available in the explanatory note to the CRD.

 

Comment 98, page 81:

See our answer to question 2.12.1 at page 15.


99

comment by: NHAF Technical committee

VHM should be mandatory for all HOFO operations. VHM provide both preventive maintenance possibilities and gives the possibility to investigate incidents and accidents in a wider perspective.

 

EASA response

Noted

An analysis of the comments to the questions and the conclusion drawn by the Agency is available in the explanatory note to the CRD.

 

Comment 99, page 85:

No further comments.

100

comment by: NHAF Technical committee

Question 5: Timeframe is appropriate

 

EASA response

Noted

An analysis of the comments to the questions and the conclusion drawn by the Agency is available in the explanatory note to the CRD.

 

Comment 100, page 90:

No further comments.

 

101

comment by: NHAF Technical committee

  

Question 6: Timeframe should be max 2 years, as technology is currently easy available for most of the helicopters operated offshore today.

 

EASA response

Noted

An analysis of the comments to the questions and the conclusion drawn by the Agency is available in the explanatory note to the CRD.

    

Comment 101, page 94/95:

No further comments.

102

comment by: NHAF Technical committee

Page 17:

Rules for CAT helicopter offshore flights

Paragraph 4 of Article 6 (Derogations) of the OPS cover regulation should still be available for the Member States even after implementation of HOFO regulations. This is justified by the need for issue of supplementary regulations, regarding special requirements in certain Member States. Justification: In Norway, “Samarbeidsforum for helikoptersikkerhet på norsk kontientalsokkel”, and the safety studies (HSS-1, 2 and 3), have been used for amending the regulations, and providing practical solutions to problems pinpointed in the safety studies.

Page 20: NHF support use of Option 2, as this will enable the authorities for control the operations, and make the operators to be in compliance with this regulations.

 

EASA response

Noted

Your first comment is not supported. The mentioned paragraph 4 was introduced to allow MS to continue offshore operations also according to national regulations. The paragraph, however, did not introduce a level-playing field, which was a major requirement for this RMT. The paragraph is therefore deleted following approval of the proposed regulations. If a MS identifies a safety issue, it could use Art 14.1 of the BR to put in place additional requirements.

Your second comment is coherent with the majority of responses. Hence Option 2 is accepted and chosen.

Comment 102, page 99:

NHF supported option 2 believing the Agency would retain the Norwegian requirement that the AOC and SPA have to be issued by the actual MS where the operation comences.

Helicopter Safety Study 3 identified threats for the Norwegian helicopter safety in the period 2010-2019:

“According to the report, the most important potential threats for helicopter safety in the period 2010–2019 are considered to be:

 

— lack of the possibility to maintain established Norwegian additional requirements

for offshore flights, or that it will not be possible to introduce new requirements adapted to the conditions on NCS;

 

— exemption from offshore special requirements and deviation from recommended guidelines;

 

— unwanted consequences from changes implemented by helicopter operators and other players in this area;

 

— reduced competence among technicians and pilots in helicopter companies due to retirement of existing personnel;

 

— lack of competence and resources regarding offshore helicopters in CAA-N; and

 

— too much focus on cost and revenues by the different players on NCS.”

Additionally this information is quoted by the Agency in the NPA. It is therefore very surprising and disappointing again, that the Agency is now making these threats a reality by ignoring the importance of past experience and where this type of operation actually commences which is mainly on the Norwegian and UK Continental Shelf.

To create a level playing field enabling free movement of services by use of option 2 to retain safety is only an illusion, since there is no need for such regulation in MS where there is no such operation. MS where this operation actually commences are already well regulated, and have a high level of competence and oversight. For these MS this rulemaking is a deregulation, which will impact the safety significantly when operators from the current non-regulated MS will access the market without proper competence, experience and oversight.

NHF also support CAA Norway comment 267, regarding level of safety. As Norway already has established rules and oversight of HOFO operations, the safety impact is negative to an unknown extent.

Also a hostile environment is quite different in several MS and even within the MS itself. Helicopter operation is not comparable with fixed wing operation where aircraft move internationally and even globally. Helicopter operation is more local and operates at a lower atmospheric level, and hence local knowledge is important for both the operators and the Competent Authority. There must be a possibility for additional requirements fitting the actual territory of operations.These requirements must be solid and invariable and retained in the IR, not only the AMC/GM.This does not, in our view conflict with level-playing-field, as it is the same requirements for all operators in the specific territory. Please see CRD comment 223, from the Civil Aviation Authority of Norway for further support.
As for use of BR art 14.1, NHF consider this paragraph not to be used by Competent Authorities for adding a requirement in example to have a national authorization for operation in Norway. If in use at all, this is to immediately stop a specific unsafe operation. This is supported by the Information Note: Handling of notifications in the context of the flexibility provisions under Articles 14(1), 14(4) and 14(6) of EU Regulation No 216/2008”, issued by the Directorate-General for mobility and transport in the European Commission.

As for the latest safety issue in offshore operations, the EC225LP bevelshaft case is an example. Since the Agency did not take proper action as the design authority, both UK CAA and Norwegian CAA issued safety directives prohibiting flights over hostile environment with this aircraft type. Based upon their national law (article 15 of the Air Navigation Order for UK, and Air Navigation Act (Luftfartsloven) §4-1 for Norway). This may be seen as an action of mistrust towards the Agency, and it is understood and supported by NHF.

 

 

103

comment by: NHAF Technical committee

Page 23:

I. (b) (1) NHF support the new definition of “Hostile environment”

Page 24: I (b) (2): Modify the text to include …helicopter hoist operations areas and operation sites within the territory.

 

EASA response

Not accepted

The comment on the definition of hostile environment is noted.

For the second comment, the term used in the operations regulation is ‘operating site’.

Justification or benefit for of the proposed change is not given.

Comment 103, page 102:

 The wording should still be changed to include ...within the territory:

"(84) 'Offshore location' means a location or destination on a fixed or floating offshore structure or vessel, and includes helidecks, helicopter operations areas and operating sites, within the territory.

This is justified by the fact that each Member State should be able to monitor all traffic in their territory. The term should be added in order to avoid uncertainty regarding the application of the HOFO requirements.

 

104

comment by: NHAF Technical committee

SPA.HOFO.100

(b)(2-3) please delete. AOC should be required for all operations offshore to ensure a high level of safety. (Higher requirements for procedures, organization, etc)

EASA response

Not accepted

An AOC can only be submitted to a CAT operator.

By requiring all operators to hold and AOC it would require non-commercial operators and commercial SPO operators to become CAT operators. This is not the intention of the RMT.


Comment 104, page 117:

Non-commercial operators should follow the same set of rules and requirements as for CAT AOC holders operating in hostile environment. If not, they should not operate in hostile environment. This is also justified in the comments from the Norwegian CAA and the Norwegian Ministry of Transport and Communication in the CRD. The hostile environment is the same for both CAT operators as for NCO/NCC operators.

 

 

 

105

comment by: NHAF Technical committee

  

Page 26:

SPA.HOFO.105 (b) (3): High-vis survival suit should be a mandatory requirement both for crew and passengers during offshore operations at all times. Justification: Weather conditions en-route may vary.

Page 27:

SPA.HOFO.125

NHF recommend mandatory flight following, for all offshore operations available to ATC. This flight following system should be of the ADS-B 1090ES standard, for flight separation by ATC. In addition to this operators may install additional flight following systems for extra optimization.

Justification: Raised level of safety, environmental effect and route planning.

Page 28:

SPA.HOFO.135

Table: Single pilot operations should not be approved for offshore operations.

Justification: Safety statistics shows that single pilot operations have a higher rate of incidents and accidents, than multi crew operations.

Page 29:

SPA.HOFO.150 (a) (1) (i)

Text should include: … public address (PA) system, which shall be easily readable for all pax, during all phases of flight.

(a)(1)(ii) Please delete this bullet point

Justification: Operational variations may cause pilots voice to become weak or even not understandable during critical situations.

SPA.HOFO.155

(a) Life jackets to be replaced by survival suits approved in accordance with offshore industrial standard, including requirements for High-vis.

(b) Manual release should be available at strategic points even after capsizing.

(c) Personal contained beacon in survival suit, of the non-smart type in addition to ELT for the helicopter.

Add following equipment to list:

(g) EGWPS/TAWS

(h) AVAD

(i) TCAS 2 or higher

Page 30:

SPA.HOFO.160 (b)

Add:

(4) Ensure VHM backup of downloaded data (Ground Station backup)

Justification: Important historical data are stored on the VHM Ground Station.

(5) Control and monitor VHM data, minimum once, every day of operation. Control and monitoring must be classified as maintenance, requiring CRS through a Part-145 organization.

Justification: To be able to monitor VHM data at a level, who provide safe operation. The VHM systems are often complex and special training is needed to interpret the collected data.

 

 

EASA response

Noted

SPA.HOFO.105: The existing regulatory requirements based on water temperature and light conditions are considered sufficient. Operators may decide on additional equipment requirement based on their risk assessment. Note also ETSO-2C503 requirements for new suits.

SPA.HOFO.125: Mandatory flight following equipment is defined by airspace categories (and ATC). When not mandated, it is required by SPA.HOFO.125 to use a system appropriate to the operator's requirements.

SPA.HOFO.135: Single-pilot operation was not considered a safety hazard and, therefore, not included in the risk matrix which is attached to the NPA.

If the safety statistics mentioned are related to offshore operations, the Agency is unaware of their existence.

SPA.HOFO.150: Text will be changed, but the requirement is already a regulatory requirement. The reason presented in the comment for removing it is not substantiated but based on an assumption.

SPA.HOFO.155:

a) The standards are different in the different MS as some require survival suits with integrated life vest, others require life vest. Hence the regulation cannot be changed.

‘High-vis’ requirements are not further explained and therefore not commented upon.

b) This is an aircraft certification or airworthiness item. It is presently validated in another RMT regarding ditching survivability, and therefore outside the scope of this RMT.

c) This is not considered a prerequisite by all MS and members of the offshore industry.

g)&h) The Agency proposes to include a regulatory requirement for terrain awareness and warning system.

i) The Agency considers that anti-collision systems, such as TCAS II and similar, should be mandated by the airspace authorities. An operational regulation valid only for offshore helicopters is therefore not considered.

Presently TCAS II for helicopters is not considered to be regulated by SESAR.

SPA.HOFO.160: These are technical requirements and outside the remedy of this RMT.

       

Comment 105, page 117/118:

SPA.HOFO.105 (b) (3); the important change is to make survival suit mandatory for everybody onboard the helicopter. The text change is therefore supported. NHF support the ETSO-2C503 or higher standards.

SPA.HOFO.125: The system in use should always be available to ATC, for separation and search and rescue purposes. NHF also support CRD comment 233, from the Civil Aviation Authority of Norway regarding harmonization of ATC systems.
Installing a monitoring system available for the operator only, should be treated as a extra layer of safety, in addition to a mandatory flight following system available to the ATC provider.

SPA.HOFO.135: Single-pilot versus multi-crew should be considered as a safety hazard. Multicrew operations are widely recognized to be safer than single-pilot operations. No further justification should be necessary.

SPA.HOFO.150: Text change noted, but still there must be a requirement that messages must be easily readable during all phases of flight. PA system is especially important in helicopters due to the cabin noise level and the lack of cabin attendant. During an emergency, the outcome could be fatal if instructions from the crew are unreadable.

SPA.HOFO.155:     

(a) Introduction of survival suits noted. See also comment for SPA.HOFO.105 (b) (3).

(b) This may be an aircraft certification requirement (often as optional equipment), but for operation in hostile environment, this must be a requirement, and not an option to select when buying the helicopter.


(c) NHF is disappointed by the Agency's answer. As seen by latest ditching’s on the UK CS personal beacons may be very helpful to find people in the water. This is also considered to have a small economic impact on operators, as equipment is already in use in most of industry.  

(g/h) noted and supported                          

(i) Supported if mandated by airspace authorities. Until this is a fact, please include in HOFO regulations.


SPA.HOFO.160:

There must be a reference to valid maintenance regulation to make the VHM requirement trustworthy.
As seen after EC225LP bevelshaft failures, the VHM checking regime is now much stricter than before these incidents. There is no point in having a system installed in the aircraft if there is no requirement to perform a check of the data collected. Currently the established industry standard is a requirement to review VHM data before each flight, and the review requires a CRS in the aircraft technical log. Our request relates to the CRD comment 236 made by the Civil Aviation Authorities of Norway.

106

comment by: NHAF Technical committee

Page 44:

AMC SPA.HOFO.125 Flight following system

See SPA.HOFO.125 comment and delete bulletpoint (a)

Page 51:

AMC1 SPA.HOFO.160 (d)

Minimum standard for training should be Part-66 AML including type rating on A/C type. Maintenance personell should be trained in use of VHM system, and approved by Part-145 organization to perform VHM monitoring. VHM check and monitoring should be classified as maintenance requiring CRS.

Justification: Recent accidents in UK, with EC225 bevel gear breakdown, shows importance of monitoring of VHM data. This should therefore be considered as a critical task for further operations.

 

 

 

EASA response

Noted

The comment to page 44 is not understood.

The comments to page 51 are valid for an operator's technical department, but they cannot be included in operational regulations.

 

Comment 106, page 170:

AMC SPA.HOFO.125:

Satellite tracking should be deleted of modified to ensure that ATC always are involved in tracking. This is justified by raised level of safety (flight following preventing crashes etc.), positive environmental effects and route planning. Please also see our comment on SPA.HOFO.125.AMC1. SPA.HOFO.160 for furtherdetails.

 

For the Agency’s information, this comment has been published on our public web site.

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