Høring - forslag om nye regler om allværsoperasjoner (all weather operations/AWO) og opplæring av flybesetning (flight crew training)

First of all,Norsk Flygerforbund (NF) is happy to see that IFR is an option that is more realistic with the proposed changes (for helicopters).

In the following we would like to comment on specific wording and procedures that may affect the ability to use IFR as a better option than marginal VFR.

AMC1 CAT.OP.MPA.125(d) Instrument departure and approach procedures

The initial proposal was to allow for Airborne Radar approaches to the coastline. This has been removed from the Opinion. That is disappointing, in particular for the operators that would benefit from such a procedure. At the next revision of the regulation, we welcome a second attempt to include this procedure into the regulation.

We disagree onthe argument: “In order to implement the ARA-L in normal CAT, SPO or NCC operations, the operator would need to put mitigation measures to reduce the risk, which might far exceed the investment necessary to design a PinS approach to coastal destinations.”

NPA 2018-04 –HEMS –Reduced VFR Minima to be used when instructed to proceed VFR

CAT.OP.MPA.110 Aerodrome Operating Minima –DH/MDA IFR approach table 6

• “PinS approaches with instructions to proceed VFR to an undefined or virtual destination the DH/MDH should be made with  reference to the ground below the MAPt”

This should not be restricted to what type of destination that is at reference. Regardless of an imaginary FATO or if there is a FATO close by, this should apply.

GM 9 CAT.OP.MPA.110 Aerodrome Operating Minima –Helicopters

• “If the vertical speed is above 1000 ft/min, a go-around should be considered”

Suggested new wording: If the vertical speed exceeds OEM recommended maximum, a go-around should be considered.

AMC3 SPA.LVO.100 LVTO Operations-Helicopters

• “On PinS departures to IDF,VIS  should not be less than 800 mand ceiling should not be less than 250 ft”

The visibility arguments during departure are  hung up in what to do if you need to return before you reach the IDF. A reduction in visibility down to the copter low vis of 400 meters should be possible if able to comply with the procedure on one engine. This is far less dangerous than maneuvering in low vis back to the FATO.

AMC3 SPA.LVO.105 c) Specific Approval

• Operating Procedures - CATIIILS
  • “The flight crew should consist of at least two pilots”
    
    Note:

• • • One pilot and one  technical crew member as for HELI SAC AT I & NVIS OPS under IFR (ref AMC4 SPA.LVO.100 (c) (f) (1) & AMC2 SPA.NVIS.130(f)(a)
    • The technical crew member training requirements are well described and sufficient
    • CAT II ILS is an important IFR enabler for onshore helicopter operations like HEMS, as it provides better alternate options

Suggested new wording:

The minimum crew should be two pilots or one pilot and a technical crew member.