3 SituationIt had been suggested that the existing requirements for HEMS Mountain operations did not take into consideration the limitations imposed by the lack of One Engine Inoperative (OEI) performance that apparently exists when twin-engine helicopters are operated at altitudes up to and above 8,000ft.It had also been suggested that some singles can fly up to these altitudes and still have sufficient reserves of performance to conduct HEMS.
4 SituationIt was thought that Appendix 1 to JAR-OPS 3.005(d) might have be amended to permit single-engine helicopters to conduct HEMS in mountainous areas - i.e. in a hostile environment - where the flights have to be operated to HEMS Operating Sites above an altitude of 5,000ft.HSST WP-06/08.0 was developed to review the relevance of the suggestions and to propose a suitable amendment.Following discussion of the original paper, an additional amendment to the performance rules (WP-07/03.4) was proposed, accepted by OST and forwarded to EASA in May 07.
5 SituationA follow-up paper was requested by the HSST to clarify the remaining issues and conclusions were offered to interested parties.The paper was rewritten with its scope widened to consider HEMS Mountain operations in the High Alps.This has resulted in a final set of conclusions and recommendations which might have been transposed into a proposed ACJ but for the current regulatory framework.The TGL route for more rapid publication was suggested by JAA-T LO and accepted by the HSST.
6 Background IssuesThe existing JAR-OPS 3 HEMS requirements do not take into consideration the limitations that could exist for All Engine Operating (AEO) Hover Out of Ground Effect (HOGE), and One Engine Inoperative (OEI) performance, when twin-engine helicopters are operated at altitudes up to 16,000ft – particularly with temperatures in excess of ISA
7 Background IssuesThe requirements do not take into consideration the effect on HEMS response time when the number of potential casualties is subject to exceptional conditions that result from an influx of a large, and transient, population engaged in recreational activities such as winter sports.
8 Background IssuesThe requirements do not take into consideration techniques and equipment currently used for the insertion and extraction of personnel in the mountain rescue environment.Because of the nature of mountain operations, landing is not always possible at HEMS/rescue sites; it is therefore necessary to have available a means of access/recovery utilising Human External Cargo (HEC) provisions.HEC is undertaken by hoist, long haul or short haul (the last two using fixed ropes attached to the cargo hook(s) – suitably approved for that purpose).
9 Background IssuesSome reliance is placed on interpretation of Note in Appendix 1 to 3.005(d)“The Authority is empowered to decide which operation is a HEMS operation in the sense of this Appendix”This can lead to different interpretationsAt least one State facing a challenge on requiring compliance with this AppendixGuidance was needed to alleviate concerns (and to avoid a potential legal challenge)Regulatory change timing precludes providing guidance inside JAR-OPS 3
10 Draft TGL 43The proposed TGL will provide guidance for affected Authorities to determine the conditions under which some HEMS mountain operations, conducted by an AOC holder, might be taken outside the scope of CAT regulation whilst retaining the level of safety necessary for such operations by the appropriate assessment and management of risk.
11 InformationHEMS operating site: A site selected by the commander during a HEMS flight for HHO, landing and take-off.Because this is the primary pick up site related to an incident or accident, its use can never be pre-planned and therefore attracts alleviations from operating procedures and performance rules - when appropriate
12 Appendix 1 to JAR-OPS 3.005(d) InformationAppendix 1 to JAR-OPS 3.005(d)Helicopters conducting operations to/from a HEMS operating site located in a hostile environment shall as far as possible be operated in Performance Class 2. accordance with Subpart G (Performance Class 1).The commander shall make every reasonable effort to minimise the period during which there would be danger to helicopter occupants and persons on the surface in the event of failure of a power unitPerformance Class 3 operations shall not be conducted over a hostile environment
13 TGL Composition The TGL is extensive and contains: DiscussionAnalysisConclusionsRecommendationsConsideration was made to shorten the paper but then aspects of the subject might not be fully addressedTGL is therefore complete with all references and detail to enable an Authority to determine the conditions under which an Operator might be granted an Approval
14 TGL - Main ConclusionsSome aspects of mountain rescue cannot be conducted under the existing requirements of the HEMS appendixProvision should be made to permit a contingency plan for evacuation of a casualty when operations to/from the HEMS Operating Site at high altitudes are beyond the capability of a twin-engine helicopter operating in PC2Provision should be made to permit a contingency plan to come into effect when the number of missions exceeds the (agreed) normal operational capacity
15 TGL - Main ConclusionsClarification that for mountain rescue involving more than one helicopter, the one which, as part of its mission, is performing the act of inserting, or extracting, the mountain specialist(s) is not considered to be operating in CATClarification that mountain rescue involving a helicopter using a Personal Carrying Device System (PCDS) in a Fixed Line Flyaway is not considered to be CATThe Authority should ensure that adequate equipment, meeting the requirements of CS 27/29 in respect of HEC, together with procedures in the OM, provides a JAR-OPS 3 equivalent safety for crew members and casualty
16 TGL – Main Recommendations An AOC holder with a HEMS Approval should be alleviated from the requirement to conduct specific phases of operations under the (full) requirements of CATSuch alleviation should be permitted to an AOC holder only when in compliance with a risk assessed contingency plan submitted to, and accepted by, the AuthoritySpecific phases of operation should not be regarded as being operations in CAT and therefore should not be required to be conducted under the requirements of JAR-OPS 3
17 ConsultationConsiderable consultation has been conducted within the HSST and in the HEMS organisations (EHA/EHAC) together with several of the affected mountain operatorsthey are in support of the this guidance material
18 Summary and Final Assessment The TGL will provide guidance for Authorities and Operators (on the intent of the ‘note’) so that they might develop suitable procedures to address the special conditions experienced by HEMS operators in high mountain areas which were not intended, or expected, to be covered under the basic tenets of JAR-OPS 3 Appendix 1 to 3.005(d)It is recommended that the TGL be approved for publication as soon as possible to give the information some provenance and so that use may be made of it by those concerned