GM1 CAT.POL.H.225 Helicopter operations to/from a public interest site

UNDERLYING PRINCIPLES

(a)     General

The original Joint Aviation Authorities (JAA) Appendix 1 to JAR-OPS 3.005(i) was introduced in January 2002 to address problems that had been encountered by Member States at hospital sites due to the applicable performance requirements of JAR-OPS 3 Subparts G and H. These problems were enumerated in ACJ to Appendix 1 to JAR-OPS 3.005(d) paragraph 8, part of which is reproduced below.

‘8       Problems with hospital sites

During implementation of JAR-OPS 3, it was established that a number of States had encountered problems with the impact of performance rules where helicopters were operated for HEMS. Although States accept that progress should be made towards operations where risks associated with a critical power unit failure are eliminated, or limited by the exposure time concept, a number of landing sites exist which do not (or never can) allow operations to performance class 1 or 2 requirements.

These sites are generally found in a congested hostile environment:

—          in the grounds of hospitals; or

—          on hospital buildings;

The problem of hospital sites is mainly historical and, whilst the Authority could insist that such sites not be used - or used at such a low weight that critical power unit failure performance is assured, it would seriously curtail a number of existing operations.

Even though the rule for the use of such sites in hospital grounds for HEMS operations (Appendix 1 to JAR-OPS 3.005(d) sub-paragraph (c)(2)(i)(A)) attracts alleviation until 2005, it is only partial and will still impact upon present operations.

Because such operations are performed in the public interest, it was felt that the Authority should be able to exercise its discretion so as to allow continued use of such sites provided that it is satisfied that an adequate level of safety can be maintained - notwithstanding that the site does not allow operations to performance class 1 or 2 standards. However, it is in the interest of continuing improvements in safety that the alleviation of such operations be constrained to existing sites, and for a limited period.’

As stated in this ACJ and embodied in the text of the appendix, the solution was short-term (until 31 December 2004). During the commenting period of JAA NPA 18, representations were made to the JAA that the alleviation should be extended to 2009. The review committee, in not accepting this request, had in mind that this was a short-term solution to address an immediate problem, and a permanent solution should be sought.

(b)     After 1 January 2005

Although elimination of such sites would remove the problem, it is recognised that phasing out, or rebuilding existing hospital sites, is a long-term goal which may not be cost-effective, or even possible, in some Member States.

It should be noted, however, that CAT.POL.H.225(a) limits the problem by confining approvals to hospital sites established before 1 July 2002 (established in this context means either: built before that date, or brought into service before that date — this precise wording was used to avoid problems associated with a ground level aerodrome/operating site where no building would be required). Thus the problem of these sites is contained and reducing in severity. This date was set approximately 6 months after the intended implementation of the original JAR-OPS 3 appendix.

EASA adopted the JAA philosophy that, from 1st January 2005, approval would be confined to those sites where a CAT A procedure alone cannot solve the problem. The determination of whether the helicopter can or cannot be operated in accordance with performance class 1 should be established with the helicopter at a realistic payload and fuel to complete the mission. However, in order to reduce the risk at those sites, the application of the requirements contained in CAT.POL.H.225(a) should be applied.

Additionally and in order to promote understanding of the problem, the text contained in CAT.POL.H.225(c) refers to the performance class and not to ICAO Annex 14. Thus, Part C of the operations manual should reflect the non-conformance with performance class 1, as well as the site-specific procedures (approach and departure paths) to minimise the danger to third parties in the event of an incident.

The following paragraphs explain the problem and solutions.

(c)      The problem associated with such sites

There is a number of problems: some of which can be solved with the use of appropriate helicopters and procedures; and others which, because of the size of the site or the obstacle environment, cannot. They consist of:

(1)     the size of the surface of the site (smaller than that required by the manufacturer’s procedure);

(2)     an obstacle environment that prevents the use of the manufacturer’s procedure (obstacles in the backup area); and

(3)     an obstacle environment that does not allow recovery following an engine failure in the critical phase of take-off (a line of buildings requiring a demanding gradient of climb) at a realistic payload and fuel to complete the mission.

—         Problems associated with (c)(1): the inability to climb and conduct a rejected landing back to the site following an engine failure before the Decision Point (DP).

—         Problems associated with (c)(2): as in (c)(1)).

—         Problems associated with (c)(3): climb into an obstacle following an engine failure after DP.

Problems cannot be solved in the immediate future, but can, when mitigated with the use of the latest generation of helicopters (operated at a weight that can allow useful payloads and endurance), minimise exposure to risk.

(d)     Long-term solution

(1)     The derogation provided for by Article 6(6) of Regulation (EU) No 965/2012, which allows Member States to approve public interest sites under their own conditions, was meant to be a temporary transitional arrangement. This transitional arrangement was only intended to allow the continuation of existing sites. For this reason, any newly approved public interest sites that have been established since 28 October 2014 will have to be phased out by 25 May 2028.

(2)     No mandatory phase-out is foreseen for sites approved under a derogation from CAT.POL.H.225 that were established as public interest sites before 28 October 2014.

(3)     No mandatory phase-out is foreseen for sites approved under CAT.POL.H.225 that were established as public interest sites before 1 July 2002.

(4)     A public interest site should be considered to be established at the time when it was operated in the public interest for the first time.

(5)     As of 25 May 2024 there should be no more approvals of public interest sites that were established after 28 October 2014, in accordance with point ARO.OPS.220(c).

(6)     As of 25 May 2024 the obstacle environment at approved public interest sites should be kept under continued review in order to avoid new obstacles causing a significant safety impact, in accordance with point ARO.OPS.220(d).

Table 1

Duration of public interest site approvals

(7)     Since a number of hospital sites may remain approved public interest sites in the foreseeable future, it was considered important to keep minimum performance margins when operating these sites.

(i)      The performance level of 8 % climb gradient in the first segment required by point CAT.POL.H.225(a)(5) reflects ICAO Annex 14 Volume II in ‘Table 4-1 ‘Dimensions and slopes of obstacle limitations surfaces’.

This was established as a means of mitigating performance issues. It defines a proportionate mass penalty at such sites, thereby applying an additional performance margin to such operations in the interest of safety.

(ii)     The performance delta is achieved without the provision of further manufacturer’s data by using existing graphs to provide the reduced take-off mass (RTOM).

(iii)     If the solution in relation to the original problem is examined, the effects can be seen.

(A)     Solution with relation to (c)(1): although the problem still exists, the safest procedure is a dynamic take-off reducing the time taken to achieve Vstayup and thus allowing VFR recovery — if the failure occurs at or after Vy and 200 ft, an IFR recovery is possible.

(B)     Solution with relation to (c)(2): as in (c)(1) above.

(C)     Solution with relation to (c)(3): once again, this does not give a complete solution; however, the performance delta minimises the time during which a climb over the obstacle cannot be achieved.