AHIA Topic – New Australian Part 133/138 Heli Performance

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Re: AHIA Topic – New Australian Part 133/138 Heli Performanc

Postby R Nest » Tue Nov 26 2013, 01:47

Performance Class 2 (PC2) - means the class of rotorcraft operations where, in the event of failure of a power unit, performance is available to enable the rotorcraft to safely continue the flight, except when the failure occurs early during the take-off manoeuvre or late in the landing manoeuvre, in which case a safe forced landing may be required. This is also sometimes known as “Pure PC2”.

Pure PC2, or variations of PC2, are likely to be a common requirement for many aspects of Air Transport and Aerial Work operations. The general principle of PC2 is that for take-offs and landings, below a height where a safe single engine climb out is possible (or a maximum of 200ft), it is permissible to accept a slight possibility of injury to those on board the aircraft. Although the requirement for a safe forced landing still ensures this remains a minor risk. Remember, PC1 worked on the principle of absolute engine failure safety, whereas PC2 is introducing some risk. The requirement for a safe forced landing is also designed to ensure that the public, or property, on the ground is not negatively impacted by the OEI forced landing.

Depending on obstacles, a safe single engine climb should be achievable once Vtoss (if below CAT A weights) or Vy (if above CAT A weights) is reached. So, once at Vtoss/Vy/200ft(your choice), PC2 requires the exact same standards as PC1, which in essence relates to achieving 100fpm rate of climb up to 200ft, 150fpm OEI rate of climb from 200-1000ft, and 50fpm rate of climb at the minimum safe height for flight, and avoiding obstacles.

So to run through a PC2 scenario from the start:

The Helipad – Although CASA will be defining recommended dimensions for PC2 helipad design, these will not necessarily define the requirements on a pilot. These standards are yet to be fully determined, but may be similar to the current requirements for a Standard HLS (CAAP 92-2), being 2Dx2D. As is currently the case, there may also be conditional allowances to operate to smaller areas (Basic HLS) on the basis of risk assessment and operations manual processes.

Take-off – The weight limit is aligned with the type of take-off being used. IGE weight limits may be used if the take-off is flown outside of the H-V curve, and so providing a safe forced landing if the surface is adequate. CAT A helipad weight limits and procedures should be used if desiring to conduct a more vertical, backing-up or lateral take-off. Vertical take-offs above CAT A weights will enter the H-V curve so preclude a Safe Forced Landing.

Take-off flight path – Up to achieving Vtoss/Vy/200ft(your choice), the aircraft must be flown such that it could achieve a safe forced landing in the event of an engine failure. As mentioned earlier this means staying outside the H-V curve, or within a CAT A weight and procedure. Once above the height of achieving Vtoss/Vy/200ft it is the same as PC1.

Enroute – The same as PC1, where 50fpm OEI rate of climb must be achievable.

Approach and Landing – From 1000ft down to 200ft, 150fpm OEI rate of climb must be achievable in the event of an engine failure requiring a baulked landing (go-around). Once below 200ft, either a baulked landing must be possible (with 35ft obstacle clearance), or a safe forced landing must be possible.

In regards to considering obstacles - below the height where a safe single-engine climb out is possible (or max 200ft) obstacles need to be avoided by a safe margin on the basis of flying with all engines operating. Once above that height obstacles must be avoided (by 35ft) on the assumption of OEI flight.

Under the European regulations, another aspect of PC2 that varies from PC1 is the lack of a requirement for formal surveys of the departure path obstacles. This measure of informality allows helicopter operations the flexibility to be conducted from many diverse and single-use landing sites. So, although we still have to avoid the obstacles by the same amount as PC1 (35ft), we require a lesser standard of proof – eg; pilot’s visual assessment of maps/terrain rather than formal surveys.

In order to justify this lesser formality there will need to be established Operations Manual procedures and training to assist the pilot. For example, the pilot needs to know how much distance will be required to reach the height where a safe single-engine climb out is possible, assuming all engines remain operating, and following the chosen take-off method. From that point the pilot must know how much distance is then used in the possible OEI climb up to 200ft then up to 1000ft. Flight Manual performance charts are the source of data for working out these distances, without which it is impossible for the pilot to make informed decisions on the ability to avoid the departure path obstacles.

For example: A CAT A certified helicopter might be looking at taking off from a large flat, smooth, firm paddock. Our AEO take-off distance to 50ft/45kts might be worked out from the flight manual to be 200m. From 50ft/45kts our single-engine landing distance is calculated from the flight manual as being 100m. So provided our paddock is bigger than 200+100=300m we can do a safe forced landing from 50ft and therefore meet Pure PC2. If our paddock is exactly 300m, we need to ensure that beyond the 50ft/200m point we have the ability to safely fly away on one engine. So we now look to see that our CAT A Supplement provides us with OEI climb data for the speed we reached at 50ft, being 45ts. We then determine that we will have an 8% (4.6 deg) climb gradient (360fpm) at 45kts. So with this data in hand the pilot looks at the obstacles and is satisfied that from the 50ft/200m mark, the aircraft can out-climb or fly around any obstacles on the departure path.

If the obstacles were too high, the pilot would need a longer paddock so that the aircraft could be climbed up to 200ft AEO (whilst retaining the ability to reject), then look at the 8% gradient from 200ft. Alternatively, if within the CAT A weight helipad limits for a backing-up take-off the pilot could do a take-off to TDP (eg 150ft), then accelerate to 45kts. The 45kts would then be reached at a height of 150+50=200ft, and distance of 200m from the TDP. It will be worth operators coming up with standard worst-case numbers to aid in pilot decision-making for ensuring PC2 is complied with.

Although the examples above did not require formal survey of the obstacle environment in the way that PC1 does, there is still a requirement for the pilot’s decision to be based upon an Operations Manual methodology and knowledge of aircraft performance. There are other methods for working out PC2 distances that require more detail to explain, but I will leave this to CASA guidance material in the future.

I am sure many of you will have recognised that, due to the safe forced landing requirement, use of Pure PC2 will be practically difficult to achieve away from the runway environment or nice flat paddocks. So this brings us to the last of the performance sub-categories, and one that will be regularly used. This is known as “PC2 With Exposure”.

RN
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Re: AHIA Topic – New Australian Part 133/138 Heli Performanc

Postby R Nest » Wed Dec 4 2013, 09:17

PC2 WITH EXPOSURE

As mentioned in the previous post, Pure PC2 is the class of rotorcraft operations where, in the event of failure of a power unit, performance is available to enable the rotorcraft to safely continue the flight, except when the failure occurs early during the take-off manoeuvre or late in the landing manoeuvre, in which case a Safe Forced Landing may be required.

PC2 With Exposure is exactly the same as Pure PC2 (and therefore PC1) once above your chosen safe single-engine fly-away point (max 200ft). But, for PC2 With Exposure, below this point there is no longer the requirement for a Safe Forced Landing. Being “exposed” means there is no certainty of avoiding possible catastrophic damage to the aircraft, or injury to persons in the aircraft or on the ground. Many Air Transport and Aerial Work operations are likely to be eligible for operations using PC2 With Exposure, so it will be a crucial element of twin-engine operations.

Development of PC2 With Exposure as a performance sub-category is based upon a number of important mitigating factors, one of which is an agreed safety target of there being a 1:20 million chance of having an engine failure during the “exposed” stage of flight. There was also an assumption that demonstrable engine failure rates were 1:100,000 hours or better. 1:20 million÷1:100,000 reveals that provided the exposure period is less than 18 seconds then the safety target would be met. Having two engines doubles the chance of an engine failure so the exposure period target for twins becomes 9 seconds.

Initially PC2 With Exposure was developed for the offshore industry so as to provide a quantifiable safety regime in an environment where PC1 was not available. The possibility of deck-edge strikes, and sea conditions above Sea State 4, made Pure PC2 with safe forced landings impossible. Various different take-off and landing techniques were assessed against the 9-second target, which resulted in the knowledge that provided certain techniques were used, the safety target could generally be met. Regulation for PC2 With Exposure was then extended into the onshore environment.

It should be noted that PC2 With Exposure is not the same as Enhanced PC2 (PC2e), which I am sure will be familiar to our offshore colleagues. PC2e is a regime of specific offshore helideck operations and was developed as a way to avoid exposure to deck-edge strikes and ditchings, but without requiring PC1. PC2e requires specific flight manual charts and piloting techniques, not normally seen outside the modern offshore helicopter types.

In the context of PC2 With Exposure, here are some examples of what it means to be exposed:
• The take-off is flown outside of the H-V curve, or within the weights and profile of a CAT A procedure, BUT the forced landing area does not allow for “a reasonable expectancy of no injuries to persons in the aircraft or on the surface”. (eg; over bush, swamp, rocky ground, houses, public roads etc.)
• The take-off is flown over a Safe Forced Landing area, BUT the take-off is flown inside the H-V curve. (eg; vertical OGE take-off from a footy field.)
• The take-off is flown over a Safe Forced Landing area via a published CAT A flight path, BUT the aircraft mass is beyond the CAT A mass limits. (eg; using a back-up CAT A technique to a large hospital helipad.)
• Where the landing area provides a Safe Forced Landing, BUT the approach path is not flown via the published CAT A approach profile and/or within the CAT A mass limits for that procedure; or via the published standard flight manual approach profile, meaning via the published 50ft gate mentioned on the “single-engine landing distance chart”.

CASA will not approve an operator to conduct PC2 With Exposure operations unless that operator is able to meet a number of pre-requisites:
• Have a specific CASA instrument of approval.
• CAT A certification for that helicopter type – this does not mean within CAT A weight limits, just that CAT A procedures are in the flight manual.
• Written confirmation from the manufacturer that the engine/airframe combination meets the 1:100,000-hour failure rates.
• Rolling 5-year manufacturer’s data as evidence of continuing to meet the engine failure rate target above.
• Various airworthiness mitigators such as engine maintenance and modification standards, plus mandatory engine Usage Monitoring Systems (UMS).
• Operations Manual descriptions on the piloting techniques to be used for minimising the exposure time, and a training program to suit.

Regarding the final point of minimising exposure time, it was never the European intention that this had to be less than 9 seconds for each and every operating site. It is expected that the operator will limit exposure such that, on balance, the 9-second target is met for most operations. Very basic assessments will quickly reveal that achieving a safe single-engine climb out speed (Vtoss or Vy) from an IGE take-off technique is usually possible within about 4-8 seconds. However, achieving Vtoss/Vy from a vertical take-off in the bush may take >30 seconds. The combination of pilot education, and pilot application of the best procedure for the site will on balance achieve the 9-second target across the range of sites. If CASA start trying to mandate a 9-second time frame, this will restrict many operations, and go against the intent of the creators of PC2 With Exposure. We must wait for further detail from CASA!

As for Pure PC2, operations With Exposure will require Operations Manual guidance on how a pilot should determine when the exposure period is finished. From a planning point of view we need to try and define a height and distance where exposure finishes, and at which point we are able to continue with an OEI climb that adequately clears obstacles. However, bear in mind that the realistic HLS environment may require non-standard take-off methods to be used, so any planning numbers will be generic. The methods of calculation are no different to those discussed in the previous post, and could include reference to some of the following flight manual charts:

• AEO take-off distance over a 50ft obstacle.
• AEO distance to climb from 50ft to 200ft. (This chart may not always be provided but is handy because it allows AEO distance calculations for anywhere from 50-200ft.)
• CAT A clear area charts for take-off distance required (TODR) to reach a Vtoss climb at 35ft. (This chart gives much greater distances to Vtoss than the AEO charts above, because it is OEI. But if the AEO 50-200ft chart is not available then this chart may be required.)
• CAT A helipad charts for TODR to reach Vtoss.
• CAT A helipad drop-down height charts.
• OEI rate of climb at Vtoss.
• OEI rate of climb at Vy.
• OEI rate of climb at any other speed published.
• Landing profile diagrams.
• Single-engine landing distance from 50ft.

So, the exposure period will be finished when our speed and height allow us to avoid all obstacles in the take-off path by either, out-climbing the obstacle by at least 35ft, or by visually flying around it. In broad terms, here are some examples of where exposure might finish for different environments, bearing in mind it must finish by 200ft above the HLS:
• Over flat (but rough) terrain the exposure period will coincide with the distance to reach 50ft AEO.
• From a rough paddock with 150ft trees at the end, but generally flat terrain, the exposure period will finish once above the trees and at an appropriate OEI climb speed.
• From a helipad on a pinnacle the exposure will finish once clear of the helipad edge and in a position to descend and accelerate to an appropriate OEI climb speed.
• From a helipad in a bowl-shaped valley, the exposure will finish once we are at a sufficient speed/height to out-climb the surrounding ridge-lines whilst OEI.
• From a ground level helipad in the city – exposure finishes when above the obstacles at an appropriate climb speed, and your OEI climb gradient will keep you above them.

It is also worth mentioning how CAT helipad procedures can greatly reduce (or eliminate) the exposure period if you are within the CAT A weight limits and your helipad is of sufficient size. In these cases, if you have CAT A helipad performance, and fly the profile, the exposure period need not commence until your TDP, or later. Before TDP you would conduct a safe forced landing back to the HLS. If your TDP is high enough to allow an OEI descending acceleration to your Vtoss then you may be able to avoid any exposure at all, provided your Vtoss climb gradient was sufficient to clear all the obstacles. CAT A helipad performance will give great opportunities to avoid exposure and so remain within Pure PC2.

There is a high expectation that CASA will eventually move down the path of Europe in that exposure will not be permitted over populous areas, for all but exceptional life-saving activity. In this day and age it is very difficult for governments to accept even a 1:20 million chance of an engine failure resulting in the deaths of innocent bystanders. I wonder what the probabilities are of other critical single-point failures occurring??

This completes my series of posts on this topic. Hopefully this has got some people on the path to a greater understanding of the Performance Class system. Feel free to pose questions, but bear in mind that only CASA may be able to answer some of them.

RN
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Re: AHIA Topic – New Australian Part 133/138 Heli Performanc

Postby muppet » Wed Dec 4 2013, 20:57

Thanks for this series of very good posts, nicely explained and a good effort to clarify some of the murk surrounding CAT A/PC1. Or perhaps that should be PC1/Cat A...

I note your earlier comment:
Category B rotorcraft have no guaranteed capability to continue safe flight in the event of an engine failure, and a forced landing is assumed.
An aircraft that is CAT B will therefore be either a single-engine helicopter, or a twin that is not using CAT A for reasons of: lack of manufacturers certification, choice of the pilot/operator, or due to being outside of the CAT A limitations.


Is it therefore accurate to infer from the above that any twin engine aircraft that is not certified by the manufacturer as Cat A, cannot legally (or most likely practically either!) satisfy a promulgated Category A requirement, regardless of what an operator may wish to assert?
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Re: AHIA Topic – New Australian Part 133/138 Heli Performanc

Postby R Nest » Thu Dec 5 2013, 09:11

Muppet,

I'm glad you were able to follow the discussion. It is not an easy one to write clearly about.

muppet wrote:Is it therefore accurate to infer from the above that any twin engine aircraft that is not certified by the manufacturer as Cat A, cannot legally (or most likely practically either!) satisfy a promulgated Category A requirement, regardless of what an operator may wish to assert?


Remember that CAT A will never be promulgated as a requirement by CASA, but they will usually promulgate a requirement to meet a Performance Class. PC1 can only be met by the use of CAT A flight manual data plus helipad and obstacle surveys, and meeting climb gradients. PC2 With Exposure requires CAT A certification without question.

Pure PC2 may be possible without CAT A certification, but this will depend on flight manual data which will need to provide charts for distance calculations for a climb to Vy and 200ft. If this is obtainable CASA may allow Pure PC2 without a CAT A certification.

So in essence, if you are not certified for CAT A, and don't have the RFM Supp, you can not adopt CAT A procedures because you don't know what they are. Some may confuse flying a backing-up take-off technique with being a CAT A procedure, but this is only true if it is done in accordance with the RFM Supp. Without the RFM Supp all you are doing is entering the H-V curve and exposing yourself to a potential crash with significant damage and injury potential.

Hope this helps.

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Re: AHIA Topic – New Australian Part 133/138 Heli Performanc

Postby muppet » Thu Dec 5 2013, 20:47

Yep, understood. Does indeed help, thank you. Was mainly wanting to check that any legal ability to comply has to be driven from manufacturer's certification and you have certainly confirmed that.
but this is only true if it is done in accordance with the RFM Supp
Gotta be certified procedure that is complied with. That bit seems simple enough. The rest has potential to confuse, but fortunately we chopper guys are plenty smart. Ta
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Re: AHIA Topic – New Australian Part 133/138 Heli Performanc

Postby arrrj » Thu Feb 6 2014, 00:42

Gents (experts...CY Heli, R Nest etc),

Can someone (or more than one expert) please comment on this statement taken from the "Rotortech 2014" programme.

"Can Robinson be successfully challenged in the light helicopter market ?". Over half of the Australian fleet are Robinsons. Product upgrades. Why R66 may be able to fly in some areas and the R44 is banned under pending CASA (EASA) rules ?

Arrrj

pop;

PS - the underlining is mine...not from the Rotortech mailout.
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Re: AHIA Topic – New Australian Part 133/138 Heli Performanc

Postby R Nest » Fri Feb 7 2014, 07:19

Arrrj,

I do not believe it is correct that the R22/R44 will be banned from populous areas. My understanding based on the last publicly available information was that pistons would be fine for charter operations over populous areas, albeit with some mitigation requirements such as emergency landing areas, pilot training in autos, ops manual procedures etc. Only when you start talking higher risk AWK operations at lower levels below 1000ft over populous areas are you likely to see requirements for turbines.

Hopefully the Part 133/138 NPRMs will be out in the next few months and clear things up a little.

Cheers,
RN
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Re: AHIA Topic – New Australian Part 133/138 Heli Performanc

Postby arrrj » Fri Feb 7 2014, 07:50

RN,

Thank you for kind response. I started a more detailed thread on BS and there is a bit of discussion going on there.

I guess we shall have to wait and see, however based on what happened in Europe (the A119 Koala was wiped out) and NZ (court action to allow singles to fly), I do not share your positive attitude about the changes.

Change for change sake, without factual merit, is lunacy and we should all fight against that.

Thanks again,
Arrrj
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Re: AHIA Topic – New Australian Part 133/138 Heli Performanc

Postby R Nest » Wed Feb 12 2014, 18:50

All,

Here is the latest information about where CASA are at with the Part 138 changes:

Update CASR Part 138 – Aerial Work Operations – Aeroplanes and Rotorcraft

CASR Part 138 is currently going through initial drafting processes with the Office of Parliamentary Council (OPC) and we are hoping to have a consultation copy of the Part available by mid to third quarter of this year. This will be presented in the form a NPRM to ensure each of the changes that have been incorporated are fully consulted with the relevant sectors of the industry.

The principal policy areas under consideration for draft provisions are as discussed at the CASR Part 138 meeting in Adelaide 26 September 2013 which include:

• The combining of both aeroplane and rotorcraft aerial work into one Part
• The certification rule set and the new registration model for simple aerial work operations
• The passenger carriage policy requirements, and
• The establishment of a set aerial work task risk assessment and management concepts

Drafting work on the Part has been taking a fair amount of time due to the diverse nature of aerial work, but we are making some progress and hope to make the above timelines subject to other priorities.

Cheers,

RN
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Re: AHIA Topic – New Australian Part 133/138 Heli Performanc

Postby R Nest » Thu Apr 17 2014, 22:40

Please see attached a document from CASA updating the status of the proposed performance rule changes with Parts 91, 133, 138. This document has been circulated as a way of informing industry of CASA's current thinking on the changes they propose making.

Also see attached a document that I have written, which questions some of CASA's changes and seeks clarification about certain areas of the changes which may have a commercial impact. In particular there are proposed requirements for having suitable (safe) forced landing areas and for remaining clear of any height-velocity diagram, and for certain equipment and operational mitigators under some circumstances. These will be of particular interest to anyone operating single-engine private or charter, or with twins expecting to use PC2.

Please express your views on this forum, but more importantly via formal processes to CASA. If you don't, you may find the new performance standards have a commercial impact on your operation.
Cheers,
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Re: AHIA Topic – New Australian Part 133/138 Heli Performanc

Postby R Nest » Fri Apr 18 2014, 01:52

Here is the other document in regards to the above post. My views on what we should be pushing.
RN
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Re: AHIA Topic – New Australian Part 133/138 Heli Performanc

Postby chocolate » Fri Apr 18 2014, 10:57

Thank you rn for taking the time to put this together. It's a bit of a surprise you say no more discussion papers or notice of proposed rule making consultations. I would have thought the mess over training regs and extending the time for introduction of same, would have shown that the heli industry needs a second period of consultation with notice of proposed rule making.

The first consultation brings about changes to the new regs and a second consult would iron out problems with changes made after the first consultation.

To return to your information. First question..is there definitions of the populous, somewhat populous and sparsely populated? Looks like a minefield of lawyer like interpretation just there. 500 ft v 1000 ft.

Choc
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Re: AHIA Topic – New Australian Part 133/138 Heli Performanc

Postby arrrj » Sat Apr 19 2014, 05:04

Hi Richard,

Thank you again for your kind update on this matter.

I am absolutely stunned that this topic is not the most read and commented on at BS…the changes are potentially massive for the helicopter industry, I wonder if all the drivers reading this actually know that, or doesn't anyone else care ?

Quote -

2. Regulation 91.714 is designed to introduce similar levels of aircraft operational safety and a reduction of exposure to risk for persons not involved in the flight but who may be under the flight path of the rotorcraft. It applies to adhoc general aviation (non AOC holder) rotorcraft operations at locations that are not recognised aerodromes in populous areas, like a public park, a football oval or private HLS.
It recognises the versatility of the rotorcraft, but also recognises that persons under the approach and departure flight paths for such a place are not, like those at a recognised aerodrome, aware of or involved in the decision to allow the rotorcraft to operate at the location or over their property for approach and departure.


Here's a question for you - and an example for others to consider. In relation to the underlined portion of above. I operate out of a CASA approved (and more importantly council approved) helipad (sole operator) in Sydney - a populous area, at least for 200-300 mtrs around the pad. The pad has been in use for 30 or so years. I suspect (unless the public below are blind and deaf) that everyone is AWARE that we are allowed to and do operate helicopters from this site. Does this mean that we are OK (assuming the rules are passed without variation) or not to continue to operate from the site ?

I do understand that the new rules would prohibit landing at a property in the city for an ad hoc pick up, and I can somewhat understand the reasoning for that (albeit that there is no statistical support for the claims).

All the best,
Arrrj
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Re: AHIA Topic – New Australian Part 133/138 Heli Performanc

Postby R Nest » Sat Apr 19 2014, 11:27

Choc,

Firstly regarding the NPRM process. I should amend my statement regarding the NPRM for Part 138. The Part 138 NPRM is still to come, and hopefully later in the year. That NPRM is being re-written from an older draft based upon the Part 138 meeting in Adelaide late last year. However, Parts 91 and 133 are past that stage and getting close to being presented to the minister for final approval.

Regarding the definitions for populous areas - I tried following my nose on that one and the best I could find was in the CASA dictionary which is "reserved for future use", so we don't have a definition that I can help you with. But I do think this definition will be clarified eventually. We can possibly expect many aspects of the new regulations to remain a little unclear until they are tested in court, when it may all come down to "expert opinions". Not much help for you I'm afraid.

RN
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Re: AHIA Topic – New Australian Part 133/138 Heli Performanc

Postby R Nest » Sat Apr 19 2014, 12:13

Arrrj,

Thanks for the question. This aspect is key to some of the changes, and reflects some of my concerns with the current wording. Currently, under Part 91 you will need a suitable forced landing area all the way up to your minimum height for flight (1000ft over the city), which means an assumption of no risk to persons on the ground. The door is open to amend this such that we need only have an "emergency landing area", but this still means protection of the public is absolute. In your example you will need a flight path that ensures you don't plonk down on top of people. Can this be achieved at your helipad all the way up to 1000ft - I would guess not??

However, if you operate to Part 133 you can get an exemption for the suitable forced landing area requirement if you have: chip detectors in engines and gearboxes, risk assessments for those take-offs, training in emergencies and autos, and ops manual descriptions. And must spend minimum time without the suitable forced landing area. In your example, you therefore can keep operating from your HLS provided the conditions are met.

Interestingly, in this example, you should be able to operate from your HLS under Part 133, but not under Part 91. It seems that the higher overall standards of Part 133 operations are allowing some extra flexibility over the cities, which Part 91 operators will not have!! My reading is that Private operations will have some problems over the cities in the future, which could be lessened by the use of twins.

RN
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Re: AHIA Topic – New Australian Part 133/138 Heli Performanc

Postby chocolate » Tue Apr 22 2014, 08:09

R nest, thanks for the update. I decided I had better start at the beginning so read pt 91. And right at the end is the populous definitions. Quite sensible definitions but I bet someone complaining about heli noise will test the definitions in court. Quite amusing you didn't find the definitions by following the obvious.

Reading 91 was bloody tortuous for some of it..full of double negatives in parts and very clear and kiss in most of it. Please mr truss don't sign this into law until they make all of it it plain English. It looks like different people have had a hand in writing different clauses of this reg.

And they have snuck in a few of the dreaded 'refer to 91.#. Only to find it sends you off somewhere else again to another clause. ,. Ahh for crying out loud! Just repeat the information. It's regulations not the act.

I don't see the single piston over populous is barred by the reg just have to able to show how you mitigated the risk was my reading. Please correct me if I am wrong because we don't need confusing regs with differing interpretations possible.
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Re: AHIA Topic – New Australian Part 133/138 Heli Performanc

Postby Jabberwocky » Tue Apr 22 2014, 09:32

Chocolate, if you don't mind could you please paste the populous definitions here? I won't have proper computer access for a few weeks and I'm eager to see what the definitions actually equate to.
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Re: AHIA Topic – New Australian Part 133/138 Heli Performanc

Postby arrrj » Tue Apr 22 2014, 11:21

Hi Richard,

I can get in / out of my HLS via various routes that allow for a landing in case of engine failure - I don't see how this differs from the current regulations though - I thought that this was a requirement, or at the very least common sense. I only have 200 -300 mtrs (depending on route) before I am over National Park. To use your terminology, we fly in and out of the HLS on certain paths to avoid "plonking" down on top of the public should there be a failure.

I have documented the routes for other pilots that occasionally use my HLS, and email this to them prior to agreeing access.

The difficulty will be the exact wording of whether my chosen landing sites, underneath approach / departure are suitable (i.e. allowed). Anyone operating from a private HLS should be very wary of these new (proposed) rules. That said, if yourself and others can have the wording changed to a) make sense and b) be achievable, then we all have a chance.

By the way, even 44's have chip detectors, what's new about this rule ? Do we need to fit extra ones to the aircraft we fly ?

I do wonder why the rules are changing, particularly in regard to helis over populous areas (again, 1000 feet was always the rule, but of course that does not apply for takeoffs and landings) when in Australia (and I have asked around for the last year or so) no one can quote a situation where anyone on the ground has been injured by a helicopter landing without power. Looks like rule changing "for no reason".

Wrap us all up in cotton wool, and ban those pesky helis !

Arrrj

PS - looks like at the very least I will have to pay an expert to sort this out for me, and ensure that we remain compliant... :roll:
R Nest
Silver Wings
Silver Wings
Posts: 16
Joined: Oct 2013

Re: AHIA Topic – New Australian Part 133/138 Heli Performanc

Postby R Nest » Sun Apr 27 2014, 01:00

Choc,
Well done for finding the definition for populous areas on page 267 out of 270 pages!! This is why the more of us whom get involved in the discussion the more likely we are to pick up relevant stuff. My mistake was looking to the current CASA library (which had nothing), and not realising it was added to the draft of Part 91.
You have discovered one of the problems - different draft versions!! You seem to have studied the draft document Part 91.714 (2011) which allows take-offs over a populous areas with just an "emergency landing area", whereas the revised 91.714 as attached in an earlier post requires "suitable forced landing areas". There is a big difference in the definitions as the first need not consider the pax, but the latter must. So we need to ensure the original draft is the one that gets up, otherwise Part 91 operations in populous areas will always require suitable forced landing areas which allow for protection of pax and public on the ground.

Jabber,
55. References to populous area, moderately populated area and sparsely populated area
For these Regulations:
(a) a populous area means an area that is substantially used for, or is in use for, residential, commercial, industrial or recreational purposes; and
(b) a moderately populated area means an area characterised by small farms and land holdings, frequent farmsteads, agriculture, sealed roads, power-line networks, farmed land, coastal waters within 5 km of shore areas with frequent towns and villages, estuaries and lakes with extant or frequent passage of water traffic, national parks, nature reserves, and the like; and
(c) a sparsely populated area means an area characterised by rangeland grazing, desert, uncultivated landscape, wilderness, infrequent homesteads, large land holdings, extensive uncleared land, salt lakes, navigable tracts of water without visible or frequent water traffic, and the like.

Arrrj,
Good on you for having areas that will avoid risk to the public. As mentioned above, under the latest Part 91.714 private (or aerial work) flight you will need a suitable forced landing area that allows an auto with low probability of injury to pax - UNLESS WE GET IT CHANGED. I read that you don't currently have this because bush land does not count unless it can be read as a moderately populated area - definitions dispute possible here!
Regarding chip detectors - this is a draft requirement under 133.405 if you want to avoid the need for the suitable forced landing over populous areas. I'm not up on piston helicopters, but I understand that not many of them currently have chip detector systems in their engines, main and t/r gear boxes.
Reasons for rule changes - alignment with ICAO and an attempt at a generational improvement in safety. I guess the philosophy of "more mitigators must be better" even if the evidence for the benefits of those mitigators remains thin!!

Thanks for the comments guys. Express your views in a civil fashion (as you have done) and it hopefully increases the chances that CASA will pay attention to them.
Cheers,
RN
arrrj
2nd Dan
2nd Dan
Posts: 338
Joined: Jul 2012

Re: AHIA Topic – New Australian Part 133/138 Heli Performanc

Postby arrrj » Sun Apr 27 2014, 06:51

Hi Richard,

I think your statement "UNLESS WE GET IT CHANGED"…is the key issue. Again, I am very surprised that this is not THE thread on BS, as the changes could affect everyone - read probably will affect everyone that drives a heli in Australia.

Check your PMs please.

As for my comment regarding 44's and chip detectors, that was meant as an example only (I was not being specific about that machine, however it is the most flown in Aus), and I do note that the 44 does have a MR and TR chip detector, so presumably the addition of one to the engine would allow compliance ?

The opportunity seems to be there for some sensible debate with CASA, and I (for one) am happy to contribute / comment / assist.

All the best,
Arrrj

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