NPRM TARGETS HELICOPTER AIR AMBULANCE, INCLUDES CHANGES FOR ALL PART 135
October 14, 2010
What’s at Issue
The Federal Aviation Administration (FAA) is proposing new regulations that will affect all Part 135 aircraft (whether fixed-wing or helicopter), and includes additional requirements for all Part 135 helicopters, and, most significantly, numerous changes for Part 135 air ambulance helicopters.
Why It’s Important
The Notice of Proposed Rulemaking (NPRM) includes significant changes for equipment, staffing, training and weather minimums for all helicopter air ambulance operations. Additionally, new equipment requirements are proposed that would apply to all Part 135 helicopters. Finally, the FAA also intends to change the Part 135 load manifest requirements for all Part 135 aircraft.
Major Provisions
Changes for All Part 135
The new regulations would amend §135.63 to require a load manifest for every flight. Today, the rule applies only to multi-engine aircraft. The FAA also intends to permit electronic or paper versions of the manifest to be carried on-board the aircraft and to permit an electronic version to be transmitted to the operator’s base in lieu of preparing a duplicate copy. This change would take effect immediately following publication of a final rule.
Changes for All Part 135 Helicopters
Change Proposed |
Proposed Effective Date
(expressed in time following a final rule) |
|
Radio altimeter required |
3 years |
|
Expanded over-water equipment requirements |
3 years |
|
Increased minimums for IFR alternate airports |
Immediate |
|
Pilots must demonstrate competency in recovery from inadvertent VMC into IMC |
Immediate |
Changes for Part 135 Air Ambulance Helicopters
Change Proposed |
Proposed Effective Date
(expressed in time following a final rule) |
|
Eliminate Part 91positioning flights with medical crew on-board |
Immediate |
|
Count all flight hours flown (even those with only medical personnel on-board) toward the pilot’s day flight time limits |
Immediate |
|
Instrument rating required for helicopter air ambulance pilots |
3 years |
|
Changes to VFR minimums and to VFR flight planning |
Immediate |
|
Permit IFR operations to locations without weather reporting |
Immediate |
|
Make completion of pre-flight risk assessments mandatory |
Immediate |
|
Severe weather detection, a light-weight aircraft recording system and HTAWS equipment required |
3 years |
|
Operations control center required for operators with 10 or more air ambulance helicopters |
2 years |
NATA Position
NATA agrees that the safety concerns for helicopter operations that were noted by the FAA in the NPRM preamble, particularly those for air ambulance operations, support some of the proposed regulatory changes. However, based upon the FAA’s own estimates the NPRM will be quite costly for those impacted. FAA estimates a ten year cost ranging from one to twenty million dollars for each helicopter air ambulance operator, depending on the business size.
NATA is evaluating the proposal and will submit comments to the FAA.
Status
The NPRM was published on October 12, 2010. Comments on the proposal are due by January 10, 2011. Click here to download the NPRM.
Staff Contact:
Jacqueline Rosser
Director, Regulatory Affairs
jrosser@nata.aero
View in PDF format.
For general press inquiries, contact Shannon Chambers at 703-298-1347 or schambers@nata.aero.
The National Air Transportation Association (NATA) has been the voice of aviation business for more than 80 years. Representing nearly 3,700 aviation businesses, NATA’s member companies provide a broad range of services to general aviation, the airlines and the military and NATA serves as the public policy group representing the interests of aviation businesses before Congress and the federal agencies.