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By Ron Whitney - Managing EditorFAA Rules Pic

The Federal Aviation Administration announced on Oct 7, 2010, via a Notice of Proposed Rule Making (NPRM), sweeping new equipment and regulation changes in an effort to enhance the safety of all helicopter operations.  While this action has been expected for many months, there will no doubt be a great deal of debate and political wrangling before any changes are actually put into place.

The NPRM process works like this; The FAA determines a particular need.  They then gather information from both internal and external (operator) sources, conduct an analysis, hold a series of meetings, determine a reasonable solution, then present it to the Administrator.  The Administrator then approves the plan and a NPRM is recorded in the Federal Register.  Once that is complete a ninety-day comment period begins, where all parties are given an opportunity to state their position, recommend changes, lobby for additions and deletions.  Once the comment period has ended, in this case January 10, 2011, the Administrator then approves or disapproves the final rules and the result becomes regulatory.

The Highlights

What these proposals could mean for Air Ambulance operators;

1. Require Helicopter Terrain Awareness and Warning Systems (HTAWS)
2. Seeks comments on recording systems for light aircraft.
3. Conduct all operations with any passengers under FAA Part 135.
4. Require Operational Control Centers if the operator has more than ten aircraft.
5. Mandate safety briefings for medical personnel.
6. Amend requirements for visual and instrument flight planning.
7. Ensure pilots hold an Instrument Rating.

What these proposals could mean for ALL commercial helicopter operators:

1. Revise Instrument alternate weather minimums.
2. Pilots must demonstrate proficiency in the recovery from inadvertent IMC conditions.
3. Equip their aircraft with radar altimeters.
4. Change the definition of “extended overwater operations”.
5. Prepare, transmit, and establish procedures to keep a Load Manifest (passenger list) on file and accuracy.

As we go to press only a few of the industries associations have commented on the FAA’s proposals.  The key word here is proposal.  It is rare that the first NPRM is what actually becomes regulatory.  The changes proposed by the FAA were not unexpected. 

The ironic aspect of this NPRM is that most of the well established air medical ambulance operators already have deployed the equipment mentioned above, and adopted the proposed training and operational changes.  This begs the question, what will these new rules actually change?

One aspect which will change, should these proposals become rules, is that all air medical operators will be required to equip their aircraft, train their crews, and conduct their operations in a fair and standard manner.  How that will be monitored remains to be seen.

What’s missing?

Many in the industry were quite surprised the FAA did not address what is believed to be the most pressing issue, flight at night or during reduced visibility.  Night Vision Goggles, along with Enhanced Vision Systems have been proven to increase the safety margins when crews are properly trained in the use of such equipment.  However, the FAA did not make a move to require this type of equipment, at this time.

It was also speculated that the FAA would mandate the installation of Traffic Collision Avoidance Systems (TCAS), but the subject was left off the table this go around. 

It is worth noting the FAA, in their press release announcing the NPRM, felt it was necessary (required?) to measure and comment on the economic impact of these proposed rules.  Begs another question, are we more concerned with the cost of safety?

We are very interested in your opinion on these new rules, send us an email at ron@rotorcraftpro.com or comment here and let us know what you think.


Thursday, November 04, 2010 12:33 AM
The one thing that would have a significant impact on reducing accident rates is to require an autopilot in all helicopter. Just my opinion. Seven years HEMS pilot. Three inadvertant IMC encounters; all at night.
Michael Cosgrove
# Michael Cosgrove
Thursday, November 04, 2010 3:38 AM
The list above is just highlights, not complete. READ THE NPRM, ALL OF IT.


You will find that most of what they propose will not solve the basic problem of IIMC without adequate recurrent training, recent experience, proper equipment, and supporting infrastructure to manage climb into. How will weight and balance logs help that? Pretty-colored risk assessment sheets to show accident investigators? An Ops Center with non-certificated personnel coercing reticent pilots to take flights? Lowered visibility minimums in airspace without visibility reporting? About half the operators exempt from much of it?

Then don't waste your time making your comments here. Post them at:


Don't just whine here, whine constructively where it might (yeah, right) make a difference.

James T. Crouse
Thursday, December 02, 2010 11:38 AM
I applaud the FAA for these proposed changes which should help helicopter safety and should save lives. Despite the efforts of manufacturers, operators and government agencies, the helicopter accident rate has not seen a major improvement.

For years, although the technology is readily available, the FAA has not mandated flight data recorders and cockpit voice recorders on smaller aircraft, including helicopters, which would help in post-accident analysis to determine the real cause of the crash. If this information were available, we could not only help the families of the victims of these terrible accidents, but we could use the information for prevention of future accidents.

Too often air safety investigators are left with trying to piece the facts together from wreckage scene components and other indirect data which can make the true cause difficult to determine. This often leads to blaming the pilot when, in fact, the aircraft and its systems might well have been at fault.

I believe the government should go further and mandate two pilots on all Part 135 helicopter operations, and insist on adequate ground-based flight following and operational management of medical helicopter operations, in addition to requiring flight recording devices on all light aircraft—helicopters and fixed-wing.

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